7532 - Contract Executed
Docusign City Council Transmittal Coversheet
File Name
Purchasing Contact
City Council Target Date
Piggy Back Option
Contract Expiration
Ordinance
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Christa Christian
Not Applicable
PSA
PUCT Rate Filing Services
7532
February 9, 2021
12/31/2099
21-222
City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 1 of 12
PROFESSIONAL SERVICES AGREEMENT
FOR CONSULTING SERVICES
FILE 7532
STATE OF TEXAS §
COUNTY OF DENTON §
THIS AGREEMENT (the “Agreement”) is made and entered into on
________________________, by and between the City of Denton, Texas, a Texas municipal
corporation, with its principal office at 215 East McKinney Street, Denton, Denton County, Texas
76201, hereinafter called “OWNER” and NewGen Strategies and Solutions, LLC, a Colorado
Limited Liability Company with its corporate office at 225 Union Blvd., Suite 305, Lakewood,
CO. 80228, hereinafter called “CONSULTANT,” acting herein, by and through their duly
authorized representatives.
WITNESSETH, that in consideration of the covenants and agreements herein contained,
the parties hereto do mutually agree as follows:
ARTICLE I
CONSULTANT AS INDEPENDENT CONTRACTOR
The OWNER has selected CONSULTANT on the basis of demonstrated competence and
qualifications to perform the services herein described for a fair and reasonable price pursuant to
Chapter 2254 of the Texas Government Code. The OWNER hereby contracts with the
CONSULTANT as an independent contractor and not as an employee, and as such, the OWNER
will not assert control over the day-to-day operations of the CONSULTANT. The CONSULTANT
is customarily engaged to provide services as described herein independently and on a
nonexclusive basis in the course of its business. This Agreement does not in any way constitute a
joint venture between OWNER and CONSULTANT. The CONSULTANT hereby agrees to
perform the services described herein based on the skills required for the scope of work in
connection with the Project as stated in the sections to follow, with diligence and in accordance
with the highest professional standards customarily obtained for such services in the State of
Texas. The professional services set out herein are in connection with the following described
project:
The Project shall include, without limitation, PUCT Rate Filing Services, as described in
Exhibit A, which is on file at the purchasing office and incorporated herein (the “Project”).
ARTICLE II
SCOPE OF BASIC SERVICES
The CONSULTANT shall perform the following services in a professional manner:
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City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 2 of 12
A. The CONSULTANT shall perform all those services as necessary and as described in the
OWNER’s RFQ 7532– PUCT Rate Filing Services, which is on file at the purchasing office
and made a part hereof as Exhibit A as if written word for word herein.
B. To perform all those services set forth in CONSULTANT’s proposal, which proposal is
attached hereto and made a part hereof as Exhibit B as if written word for word herein.
C. CONSULTANT shall perform all those services set forth in individual task orders, as
described in Exhibit B, which shall be attached to this Agreement and made a part hereof.
D. If there is any conflict between the terms of this Agreement and the exhibits attached to
this Agreement, the terms and conditions of this Agreement will control over the terms and
conditions of the attached exhibits or task orders.
ARTICLE III
ADDITIONAL SERVICES
Additional services to be performed by the CONSULTANT, if authorized by the OWNER,
which are not included in the above-described Basic Services, may be negotiated as needed, per
rates included in Exhibit C.
A. Preparing applications and supporting documents for government grants, loans, or planning
advances and providing data for detailed applications.
B. Preparing data and reports for assistance to OWNER in preparation for hearings before
regulatory agencies, courts, arbitration panels or mediator, giving testimony, personally or
by deposition, and preparations therefore before any regulatory agency, court, arbitration
panel or mediator.
C. Assisting OWNER in preparing for, or appearing at litigation, mediation, arbitration, dispute
review boards, or other legal and/or administrative proceedings in the defense or prosecution
of claims disputes with Contractor(s).
D. Assisting OWNER in the defense or prosecution of litigation in connection with or in
addition to those services contemplated by this AGREEMENT. Such services, if any, shall
be furnished by CONSULTANT on a fee basis negotiated by the respective parties outside
of and in addition to this AGREEMENT.
E. Visits to the site in excess of the number of trips included in Exhibit B.
F. Preparing statements for invoicing or other documentation for billing other than for the
standard invoice for services attached to this professional services agreement.
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Standard Agreement for Professional Services Revised Date: 9/11/18 Page 3 of 12
ARTICLE IV
TIME OF COMPLETION
CONSULTANT is authorized to commence work under this contract upon execution of this
AGREEMENT. CONSULTANT shall perform and complete its obligations herein in a prompt
and continuous manner, so as to not delay the completion of the Project in accordance with the
schedules as described in Exhibit B. The contract shall remain effective for a period which may
reasonably be required for the completion of the Project, acceptance by an authorized
representative of the OWNER, exhaustion of authorized funds, or termination as provided in this
Agreement, whichever occurs first.
ARTICLE V
COMPENSATION
A. COMPENSATION TERMS:
1. “Subcontract Expense” is defined as expenses incurred by the CONSULTANT in
employment of others in outside firms for services related to this agreement.
2. “Direct Non-Labor Expense” is defined as that expense for any assignment incurred
by the CONSULTANT for supplies, transportation and equipment, travel,
communications, subsistence, and lodging away from home, and similar incidental
expenses in connection with that assignment.
B. BILLING AND PAYMENT: For and in consideration of the professional services to be
performed by the CONSULTANT herein, the OWNER agrees to pay, based on the cost
estimate detail at an hourly rate shown in Exhibit C which is attached hereto and made a
part of this Agreement as if written word for word herein, a total fee, including
reimbursement for direct non-labor expenses not to exceed $500,000.
Partial payments to the CONSULTANT will be made on the basis of detailed monthly
statements rendered to and approved by the OWNER through its City Manager or his
designee; however, under no circumstances shall any monthly statement for services
exceed the value of the work performed at the time a statement is rendered.
Nothing contained in this Article shall require the OWNER to pay for any work which is
unsatisfactory, as reasonably determined by the City Manager or his designee, or which is
not submitted in compliance with the terms of this Agreement. The OWNER shall not be
required to make any payments to the CONSULTANT when the CONSULTANT is in
default under this Agreement.
It is specifically understood and agreed that the CONSULTANT shall not be authorized to
undertake any work pursuant to this Agreement which would require additional payments
by the OWNER for any charge, expense, or reimbursement above the maximum not to
exceed fee as stated, without first having obtained written authorization from the OWNER.
The CONSULTANT shall not proceed to perform the services listed in Article III
“Additional Services,” without obtaining prior written authorization from the OWNER.
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City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 4 of 12
C. ADDITIONAL SERVICES: For additional services authorized in writing by the OWNER
in Article III, the CONSULTANT shall be paid based on the Schedule of Charges at an
hourly rate shown in Exhibit C. Payments for additional services shall be due and payable
upon submission by the CONSULTANT and approval by the City staff, and shall be in
accordance with subsection B hereof. Statements shall not be submitted more frequently
than monthly.
D. PAYMENT: If the OWNER fails to make payments due the CONSULTANT for services
and expenses within thirty (30) days after receipt of the CONSULTANT’s undisputed
statement thereof, the amounts due the CONSULTANT will be paid interest in accordance
with the Texas Government Code 2251.025. Additionally, the CONSULTANT may, after
giving seven (7) days’ written notice to the OWNER, suspend services under this
Agreement until the CONSULTANT has been paid in full all amounts due for services,
expenses, and charges. Nothing herein shall require the OWNER to pay the late charge if
the OWNER reasonably determines that the work is unsatisfactory, in accordance with this
Article V, “Compensation,” there is a bona fide dispute concerning the amount due, or the
invoice was not mailed to the address or in the form as described in this Agreement. The
OWNER will notify CONSULTANT of any disputes within twenty-one (21) days of
receipt of the invoice.
E. Invoices shall be sent directly to the City of Denton Accounts Payable Department, 215 E
McKinney St, Denton, TX, 76201-4299. A pro-forma invoice shall be sent to the contract
administrator. It is the intention of the City of Denton to make payment on completed
orders within thirty days after receipt of invoice or items; whichever is later, unless unusual
circumstances arise. Invoices must be fully documented as to labor, materials, and
equipment provided, if applicable, and must reference the City of Denton Purchase
Order Number in order to be processed. No payments shall be made on invoices not
listing a Purchase Order Number.
ARTICLE VI
OBSERVATION AND REVIEW OF THE WORK
The CONSULTANT will exercise reasonable care and due diligence in discovering and
promptly reporting to the OWNER any defects or deficiencies in the work of the CONSULTANT
or any subcontractors or subconsultants.
ARTICLE VII
OWNERSHIP OF DOCUMENTS
All documents prepared or furnished by the CONSULTANT (and CONSULTANT’s
subcontractors or subconsultants) pursuant to this Agreement are instruments of service, and shall
become the property of the OWNER upon the termination of this Agreement. The
CONSULTANT is entitled to retain copies of all such documents. The documents prepared and
furnished by the CONSULTANT are intended only to be applicable to this Project, and OWNER’s
use of these documents in other projects shall be at OWNER’s sole risk and expense. In the event
the OWNER uses any of the information or materials developed pursuant to this Agreement in
another project or for other purposes than specified herein, CONSULTANT is released from any
and all liability relating to their use in that project.
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Standard Agreement for Professional Services Revised Date: 9/11/18 Page 5 of 12
ARTICLE VIII
INDEMNITY AGREEMENT
THE CONSULTANT SHALL INDEMNIFY AND SAVE AND HOLD HARMLESS
THE OWNER AND ITS OFFICERS, OFFICIALS, AGENTS, AND EMPLOYEES FROM
AND AGAINST ANY AND ALL LIABILITY, CLAIMS, DEMANDS, DAMAGES,
LOSSES, AND EXPENSES, INCLUDING, BUT NOT LIMITED TO COURT COSTS AND
REASONABLE ATTORNEY FEES ASSERTED AGAINST OR INCURRED BY THE
OWNER, AND INCLUDING, WITHOUT LIMITATION, DAMAGES FOR BODILY AND
PERSONAL INJURY, DEATH AND PROPERTY DAMAGE, RESULTING FROM THE
NEGLIGENT ACTS OR OMISSIONS OF THE CONSULTANT OR ITS OFFICERS,
SHAREHOLDERS, AGENTS, OR EMPLOYEES INCIDENTAL TO, RELATED TO,
AND IN THE EXECUTION, OPERATION, OR PERFORMANCE OF THIS
AGREEMENT.
Nothing in this Agreement shall be construed to create a liability to any person who is not
a party to this Agreement, and nothing herein shall waive any of the parties’ defenses, both at law
or equity, to any claim, cause of action, or litigation filed by anyone not a party to this Agreement,
including the defense of governmental immunity, which defenses are hereby expressly reserved.
ARTICLE IX
INSURANCE
During the performance of the services under this Agreement, CONSULTANT
shall maintain insurance in compliance with the requirements of Exhibit D which is
attached hereto and made a part of this Agreement as if written word for word herein.
ARTICLE X
ALTERNATIVE DISPUTE RESOLUTION
The parties may agree to settle any disputes under this Agreement by submitting the dispute
to mediation with each party bearing its own costs of mediation. No mediation arising out of or
relating to this Agreement, involving one party’s disagreement may include the other party to the
disagreement without the other’s approval. Mediation will not be a condition precedent to suit.
ARTICLE XI
TERMINATION OF AGREEMENT
A. Notwithstanding any other provision of this Agreement, either party may terminate by
giving thirty (30) days’ advance written notice to the other party.
B. This Agreement may be terminated in whole or in part in the event of either party
substantially failing to fulfill its obligations under this Agreement. No such termination
will be affected unless the other party is given (1) written notice (delivered by certified
mail, return receipt requested) of intent to terminate and setting forth the reasons specifying
the non-performance, and not less than fifteen (15) calendar days to cure the failure; and
(2) an opportunity for consultation with the terminating party prior to termination.
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City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 6 of 12
C. If the Agreement is terminated prior to completion of the services to be provided hereunder,
CONSULTANT shall immediately cease all services and shall render a final bill for
services to the OWNER within thirty (30) days after the date of termination. The OWNER
shall pay CONSULTANT for all services properly rendered and satisfactorily performed
and for reimbursable expenses to termination incurred prior to the date of termination, in
accordance with Article V “Compensation.” Should the OWNER subsequently contract
with a new consultant for the continuation of services on the Project, CONSULTANT shall
cooperate in providing information. The CONSULTANT shall turn over all documents
prepared or furnished by CONSULTANT pursuant to this Agreement to the OWNER on
or before the date of termination, but may maintain copies of such documents for its use.
ARTICLE XII
RESPONSIBILITY FOR CLAIMS AND LIABILITIES
Approval by the OWNER shall not constitute, nor be deemed a release of the responsibility
and liability of the CONSULTANT, its employees, associates, agents, subcontractors, and
subconsultants for the accuracy and competency of their designs or other work; nor shall such
approval be deemed to be an assumption of such responsibility by the OWNER for any defect in
the design or other work prepared by the CONSULTANT, its employees, subcontractors, agents,
and consultants.
ARTICLE XIII
NOTICES
All notices, communications, and reports required or permitted under this Agreement shall
be personally delivered or mailed to the respective parties by depositing same in the United States
mail to the address shown below, certified mail, return receipt requested, unless otherwise
specified herein. Mailed notices shall be deemed communicated as of three (3) days’ mailing:
To CONSULTANT: To OWNER:
NewGen Strategies and Solutions, LLC City of Denton
Joseph Mancinelli Purchasing Manager –File 7532
225 Union Blvd., Suite 305 901B Texas Street
Lakewood, CO 90228 Denton, Texas 76209
All notices shall be deemed effective upon receipt by the party to whom such notice is
given, or within three (3) days’ mailing.
ARTICLE XIV
ENTIRE AGREEMENT
This Agreement and related exhibits constitute the complete and final expression of this
Agreement of the parties, and is intended as a complete and exclusive statement of the terms of
their agreements, and supersedes all prior contemporaneous offers, promises, representations,
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 7 of 12
negotiations, discussions, communications, and agreements which may have been made in
connection with the subject matter hereof.
ARTICLE XV
SEVERABILITY
If any provision of this Agreement is found or deemed by a court of competent jurisdiction
to be invalid or unenforceable, it shall be considered severable from the remainder of this
Agreement and shall not cause the remainder to be invalid or unenforceable. In such event, the
parties shall reform this Agreement to replace such stricken provision with a valid and enforceable
provision which comes as close as possible to expressing the intention of the stricken provision.
ARTICLE XVI
COMPLIANCE WITH LAWS
The CONSULTANT shall comply with all federal, state, and local laws, rules, regulations,
and ordinances applicable to the work covered hereunder as those laws may now read or
hereinafter be amended.
ARTICLE XVII
DISCRIMINATION PROHIBITED
In performing the services required hereunder, the CONSULTANT shall not discriminate
against any person on the basis of race, color, religion, sex, sexual orientation, national origin or
ancestry, age, or physical handicap.
ARTICLE XVIII
PERSONNEL
A. The CONSULTANT represents that it has or will secure, at its own expense, all personnel
required to perform all the services required under this Agreement. Such personnel shall
not be employees or officers of, or have any contractual relations with the OWNER.
CONSULTANT shall inform the OWNER of any conflict of interest or potential conflict
of interest that may arise during the term of this Agreement.
B. All services required hereunder will be performed by the CONSULTANT or under its
supervision. All personnel engaged in work shall be qualified, and shall be authorized and
permitted under state and local laws to perform such services.
ARTICLE XIX
ASSIGNABILITY
The CONSULTANT acknowledges that this Agreement is based on the demonstrated
competence and specific qualifications of the CONSULTANT and is therefore personal as to the
CONSULTANT. Therefore, the CONSULTANT shall not assign any interest in this Agreement,
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City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 8 of 12
and shall not transfer any interest in this Agreement (whether by assignment, novation, or
otherwise) without the prior written consent of the OWNER.
ARTICLE XX
MODIFICATION
No waiver or modification of this Agreement or of any covenant, condition, or limitation
herein contained shall be valid unless in writing and duly executed by the party to be charged
therewith, and no evidence of any waiver or modification shall be offered or received in evidence
in any proceeding arising between the parties hereto out of or affecting this Agreement, or the
rights or obligations of the parties hereunder, and unless such waiver or modification is in writing
and duly executed; and the parties further agree that the provisions of this section will not be
waived unless as set forth herein.
ARTICLE XXI
MISCELLANEOUS
A. The following exhibits are attached to and made a part of this Agreement:
Exhibit A – RFQ 7532– PUCT Rate Filing Services (on file at the purchasing office)
Exhibit B – Consultant’s Scope of Services Offer and Project Schedule
Exhibit C – Consultant’s Compensation Rate Sheet
Exhibit D – Consultant’s Insurance Requirements
Exhibit E – Conflict of Interest Questionnaire
What is called for by one exhibit shall be as binding as if called for by all. In the event of
an inconsistency or conflict in this Agreement and any of the provisions of the exhibits, the
inconsistency or conflict shall be resolved by giving precedence first to this Agreement
then to the exhibits in the order in which they are listed above.
B. This Agreement shall be governed by, construed, and enforced in accordance with, and
subject to, the laws of the State of Texas or federal law, where applicable, without regard
to the conflict of law principles of any jurisdiction. In the event there shall be any dispute
arising out of the terms and conditions of, or in connection with, this Agreement, the party
seeking relief shall submit such dispute to the District Courts of Denton County or if federal
diversity or subject matter jurisdiction exists, to the United States District Court for the
Eastern District of Texas-Sherman Division.
C. For the purpose of this Agreement, the key persons who will perform most of the work
hereunder shall be __________________. However, nothing herein shall limit
CONSULTANT from using other equally qualified and competent members of its firm to
perform the services required herein.
D. CONSULTANT shall commence, carry on, and complete any and all projects with all
applicable dispatch, in a sound, economical, and efficient manner and in accordance with
the provisions hereof. In accomplishing the projects, CONSULTANT shall take such steps
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Jill Schuepbach, Grant Rabon, Laurie Tomczyk and Joe Mancinelli
City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 9 of 12
as are appropriate to ensure that the work involved is properly coordinated with related
work being carried on by the OWNER.
E. The OWNER shall assist the CONSULTANT by placing at the CONSULTANT’s disposal
all available information pertinent to the Project, including previous reports, any other data
relative to the Project, and arranging for the access thereto, and make all provisions for the
CONSULTANT to enter in or upon public and private property as required for the
CONSULTANT to perform services under this Agreement.
F. The captions of this Agreement are for informational purposes only, and shall not in any
way affect the substantive terms or conditions of this Agreement.
G. The parties agree to transact business electronically. Any statutory requirements that
certain terms be in writing will be satisfied using electronic documents and signing.
Electronic signing of this document will be deemed an original for all legal purposes.
ARTICLE XXII
INDEPENDENT CONTRACTOR
CONSULTANT shall provide services to OWNER as an independent contractor, not as an
employee of the OWNER. CONSULTANT shall not have or claim any right arising from
employee status.
ARTICLE XXIII
RIGHT TO AUDIT
The OWNER shall have the right to audit and make copies of the books, records and computations
pertaining to this agreement. The CONTRACTOR shall retain such books, records, documents
and other evidence pertaining to this agreement during the contract period and five years thereafter,
except if an audit is in progress or audit findings are yet unresolved, in which case records shall be
kept until all audit tasks are completed and resolved. These books, records, documents and other
evidence shall be available, within 10 business days of written request. Further, the
CONTRACTOR shall also require all Subcontractors, material suppliers, and other payees to
retain all books, records, documents and other evidence pertaining to this agreement, and to allow
the OWNER similar access to those documents. All books and records will be made available
within a 50 mile radius of the City of Denton. The cost of the audit will be borne by the OWNER
unless the audit reveals an overpayment of 1% or greater. If an overpayment of 1% or greater
occurs, the reasonable cost of the audit, including any travel costs, must be borne by the
CONTRACTOR which must be payable within five business days of receipt of an invoice.
Failure to comply with the provisions of this section shall be a material breach of this contract and
shall constitute, in the OWNER’S sole discretion, grounds for termination thereof. Each of the
terms "books", "records", "documents" and "other evidence", as used above, shall be construed to
include drafts and electronic files, even if such drafts or electronic files are subsequently used to
generate or prepare a final printed document.
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Standard Agreement for Professional Services Revised Date: 9/11/18 Page 10 of 12
ARTICLE XXIV
Prohibition On Contracts With Companies Boycotting Israel
Supplier acknowledges that in accordance with Chapter 2270 of the Texas Government Code, City
is prohibited from entering into a contract with a company for goods or services unless the contract
contains a written verification from the company that it: (1) does not boycott Israel; and (2) will
not boycott Israel during the term of the contract. The terms “boycott Israel” and “company” shall
have the meanings ascribed to those terms in Section 808.001 of the Texas Government Code. By
signing this agreement, Supplier certifies that Supplier’s signature provides written verification
to the City that Supplier: (1) does not boycott Israel; and (2) will not boycott Israel during the
term of the agreement. Failure to meet or maintain the requirements under this provision will be
considered a material breach.
ARTICLE XXV
Prohibition On Contracts With Companies Doing Business with Iran, Sudan, or a
Foreign Terrorist Organization
Section 2252 of the Texas Government Code restricts CITY from contracting with companies that
do business with Iran, Sudan, or a foreign terrorist organization. By signing this agreement,
Supplier certifies that Supplier’s signature provides written verification to the City that Supplier,
pursuant to Chapter 2252, is not ineligible to enter into this agreement and will not become
ineligible to receive payments under this agreement by doing business with Iran, Sudan, or a
foreign terrorist organization. Failure to meet or maintain the requirements under this provision
will be considered a material breach.
ARTICLE XXVI
CERTIFICATE OF INTERESTED PARTIES ELECTRONIC FILING
In 2015, the Texas Legislature adopted House Bill 1295, which added section 2252.908 of the
Government Code. The law states that the City may not enter into this contract unless the
Contractor submits a disclosure of interested parties (Form 1295) to the City at the time the
Contractor submits the signed contract. The Texas Ethics Commission has adopted rules requiring
the business entity to file Form 1295 electronically with the Commission.
Contractor will be required to furnish a Certificate of Interest Parties before the contract is
awarded, in accordance with Government Code 2252.908.
The contractor shall:
1. Log onto the State Ethics Commission Website at :
https://www.ethics.state.tx.us/whatsnew/elf_info_form1295.htm
2. Register utilizing the tutorial provided by the State
3. Print a copy of the completed Form 1295
4. Enter the Certificate Number on page 2 of this contract.
5. Complete and sign the Form 1295
6. Email the form to purchasing@cityofdenton.com with the contract number in the subject line.
(EX: Contract 1234 – Form 1295)
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City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 11 of 12
The OWNER must acknowledge the receipt of the filed Form 1295 not later than the 30th day
after Council award. Once a Form 1295 is acknowledged, it will be posted to the Texas Ethics
Commission’s website within seven business days.
IN WITNESS HEREOF, the City of Denton, Texas has caused this Agreement to be
executed by its duly authorized City Manager, and CONSULTANT has executed this Agreement
through its duly authorized undersigned officer on this date______________________
CITY OF DENTON, TEXAS
“OWNER”
__________________________________
TODD HILEMAN, CITY MANAGER
ATTEST:
ROSA RIOS, CITY SECRETARY
BY: _______________________________
Company Name,
A Colorado Limited Liability Company
“CONSULTANT”
__________________________________
BY: Joseph Mancinelli
ITS:
____________________________
__________________________________
TEXAS ETHICS COMMISSION
CERTIFICATE NUMBER
THIS AGREEMENT HAS BEEN
BOTH REVIEWED AND APPROVED
as to financial and operational
obligations and business terms.
_______________ Antonio Puente, Jr
SIGNATURE PRINTED NAME
Executive Manager of Utilities_________
TITLE
_Denton Municipal Electric___________
DEPARTMENT
APPROVED AS TO LEGAL FORM:
AARON LEAL, CITY ATTORNEY
BY: ____________________________
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Director
2021-710708
Terrance Naulty
02/09/2021
City of Denton, Texas Contract 7532
Standard Agreement for Professional Services Revised Date: 9/11/18 Page 12 of 12
Exhibit A
RFQ 7532 – PUCT Rate Filing Services
(on file at the purchasing office)
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
PUCT TRANSMISSION COST OF SERVICE
RATE FILING SERVICES
CITY OF DENTON, TX –
DENTON MUNICIPAL ELECTRIC
RFQ #7532 | December 17, 2020
www.newgenstrategies.net
PREPARED BY:
SUSTAINABILITYSTAKEHOLDERS ECONOMICS STRATEGY
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271
EXHIBIT B
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
225 Union Boulevard, Suite 305
Lakewood, CO 80228
Phone: (720) 633-9514
Fax: (720) 633-9535
December 17, 2020
Submitted electronically (https://dentontx.ionwave.net)
Ms. Christa Christian, CPPB
Senior Buyer
City of Denton
901-B Texas Street
Denton, TX 76209
Subject: Request for Qualifications #: 7532
Transmission Rate Analysis and Filing Proposal
Dear Ms. Christian:
The City of Denton’s (City) Strategic Plan includes organization excellence, public infrastructure
improvements, economic development, the health and safety of the community, and environmental
stewardship. Denton Municipal Electric (DME) is helping to meet these strategic initiatives with the
purchase of electric vehicles (EV) in 2018, contracts for renewable energy, rebates for efficiency upgrades
and EVs, conversion of streetlights to light emitting diodes (LED), employee safety, and improvements to
system reliability.
As part of improving system reliability and supporting growth, DME has made significant investments in
the transmission system infrastructure. As DME adds transmission assets, DME can apply at the Public
Utility Commission of Texas (PUCT) to update their wholesale transmission rate in the Electric Reliability
Council of Texas (ERCOT). The transmission rate is paid by all other Transmission Service Providers (TSPs)
in ERCOT and allows DME to recover transmission-related expenses, as well as a return on their
transmission investment.
DME is requesting professional consulting services to update the DME wholesale transmission rate and
provide supporting analyses, white papers, and negotiations as needed. DME’s last full comprehensive
filing was based on a test year ending September 30, 2003. After reviewing the annual Earnings Reports,
the PUCT ordered DME to file a full comprehensive rate filing package in 2021. Since the last full filing,
DME has invested significantly in transmission plant, built the Denton Energy Center, and recently
acquired a large new customer. All these changes affect DME’s balance sheet and income statement and
will affect the transmission revenue requirement to be filed at the PUCT. The transmission revenue
requirement is an important source of revenue to DME; therefore, maximizing cost recovery of the
transmission system provides a direct benefit to DME retail electric customers. That is why we propose
to provide DME with a robust, insightful, and thorough transmission cost of service analysis to recover as
many transmission-related costs as possible from TSPs through the wholesale rate. We know that DME is
committed to providing the safest, most reliable electric service possible at the lowest possible price while
ensuring the best overall value to its retail customers.
We propose to support your needs with a rate consulting team that is extremely familiar with the
wholesale transmission rate filing process and has worked with numerous law firms in the Austin area.
Our Project Team is staffed with professionals who have worked on wholesale transmission rate projects
at the PUCT for over 20 years. Our team has a long history of working with municipal entities across the
country on a variety of critical financial and economic issues. As a company, we routinely provide insight
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Ms. Christa Christian
December 17, 2020
2 Thoughtful Decision Making for Uncertain Times
and analysis for electric, water, wastewater, solid waste, natural gas, and other municipal utility areas.
For DME, we offer our combination of extensive transmission cost of service analysis and litigation
experience.
I will be the primary point of contact for this proposal response and the individual authorized to
contractually bind the firm. My contact information is included below. Ms. Schuepbach, who is
experienced in transmission cost of service (TCOS) matters, will be your Project Manager.
We look forward to the prospect of renewing our working relationship with DME. If you have questions
concerning this proposal or would like additional information, please contact me directly at (720) 633-
9509 or jmancinelli@newgenstrategies.net.
Sincerely,
NewGen Strategies and Solutions, LLC
Joe Mancinelli Jill Schuepbach
President & CEO Executive Consultant
(720) 633-9509 (720) 924-7134
jmancinelli@newgenstrategies.net jschuepbach@newgenstrategies.net
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Table of Contents
COMPANY HISTORY AND BACKGROUND ........................................................................................ 1
PROJECT UNDERSTANDING ............................................................................................................ 1
SCOPE OF SERVICES ........................................................................................................................ 2
Task A: Rate Analyses and Filing ............................................................................................................... 3
Phase 1: Development of Interim-TCOS-RFP and Full-TCOS-RFP ......................................................... 3
Phase 2: TCOS Case Support ................................................................................................................. 6
Tasks B, C, and D: Continued Support ....................................................................................................... 7
PROJECT SCHEDULE ........................................................................................................................ 7
PROJECT TEAM ................................................................................................................................ 7
PERTINENT EXPERIENCE .................................................................................................................. 9
APPENDIX A – RESUMES
APPENDIX B – LETTERS OF RECOMMENDATION
APPENDIX C – SAMPLE REPORTS
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 1
COMPANY HISTORY AND BACKGROUND
NewGen Strategy and Solutions, LLC (NewGen) is a management and economic consulting firm
specializing in serving the utility industry and market. Established in August 2012, NewGen primarily
serves public sector utilities and provides nationally recognized expertise in utility cost of service and rate
design studies, load forecasting, financial feasibility studies, municipalization efforts, depreciation and
appraisal studies, litigation support for state and federal regulatory proceedings, utility financial planning,
and stakeholder engagement for electric, water, wastewater, solid waste, and natural gas utilities.
NewGen was created by consultants who are dedicated to our clients’ missions and recognized as experts
in our respective fields of service. “Thoughtful Decision Making for Uncertain Times” succinctly describes
our capability to provide our clients with solutions and recommendations tempered with our keen insight
into the growing role of stakeholders, resource availability (including renewables), environmental
concerns, cost of providing utility services, and economic conditions. This ensures an integrated approach
to delivering our products and services.
NewGen employs 48 professional and administrative staff, with 10 ownership members and a Board. Our
current staff has the capability to work on simultaneous assignments, and we have the capacity to add
staff and/or expand support from a network of teaming partners if needed. NewGen has 10 offices
located nationwide.
PROJECT UNDERSTANDING
Transmission Service Providers (TSPs) in the Electric Reliability Council of Texas (ERCOT) can earn a return
of and on their applicable transmission assets. TSPs have the choice to set their transmission rate through
a full comprehensive transmission cost of service (TCOS) filing, or an interim update filing.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
2 Thoughtful Decision Making for Uncertain Times
Under a full comprehensive TCOS filing, the application is submitted with written testimony describing
the analyses and results as required by the Public Utility Commission of Texas’ (PUCT) Transmission Cost
of Service Rate Filing Package for Non-Investor Owned Transmission Service Providers in the ERCOT (Non-
IOU TCOS-RFP or Full-TCOS-RFP) as adopted December 16, 1999 (Project No. 21276).
Under an interim update filing, the filing package is submitted with written testimony describing the
analyses and results as required by the PUCT’s Filing Requirements for Interim Update of Wholesale
Transmission Rates - Rate Filing Package (Interim-TCOS-RFP).
TSPs also file TCOS Earnings Report by June 1 of each year as required by 16 Texas Administrative Code
(TAC) § 25.73(b). The PUCT Staff files a memorandum summarizing their analysis of each TSP’s Earnings
Report. The PUCT Staff memorandum for the 2019 Earnings Reports recommended that Denton
Municipal Electric (DME) be called in to file a Full-TCOS-RFP. The PUCT Staff’s reasons were:
DME’s last comprehensive TCOS was over 15 years ago.
DME’s revenue requirement has increased thirteenfold since 2005.
DME’s transmission rate base has increased sixteenfold since 2005.
DME’s authorized rate of return of 28.05% was based on the Cash Flow Method, which may no
longer be appropriate given the growth of DME.
DME’s rate of return has consistently increased over the last three years.
DME has the 7th highest Non-IOU cost of service. The first six Non-IOUs have been in for filings
more recently than DME.
Per the PUCT Staff recommendations, DME is to file a Full-TCOS-RFP between September 30, 2021 and
December 31, 2021 using a test year coincident with DME’s fiscal year ending September 30, 2020. The
Full-TCOS-RFP must include a full development of an electric system revenue requirement, which is then
allocated to the transmission business function. The Full-TCOS-RFP requires numerous schedules that
contain information related to DME’s cost of doing business and operating information. The Full-TCOS-
RFP must be submitted with written testimony describing the analyses and results as required by the Full-
TCOS-RFP General Instructions. Once filed, the information will be scrutinized by PUCT staff and possibly
other intervening parties.
Given this requirement, DME is looking for a consultant with considerable experience in providing
professional services to support DME with an Interim-TCOS-RFP by July of 2021, a Full-TCOS-RFP by
November of 2021, and subsequent Interim-TCOS-RFPs as needed. DME is also requesting ongoing
support as needed. NewGen has worked for many Texas utilities supporting Full-TCOS-RFPs, Interim-
TCOS-RFPs, Earnings Reports, and utilities called in by the PUCT for overearning. NewGen has performed
each of the municipal rate methodologies allowed in the Full-TCOS-RFP, which include the rate of return
method, the debt service coverage method, and the cash flow method. NewGen will review each of the
approved methodologies as applied to DME and will advise and recommend to DME the most
advantageous method.
SCOPE OF SERVICES
The detailed Scope of Services supporting four primary tasks is outlined below.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 3
Task A: Rate Analyses and Filing
This effort will include all analyses, schedules, workpapers, testimony, and the updated tariff to support
any Interim-TCOS-RFP or the DME Full-TCOS-RFP . We will attend all meetings and coordinate with DME
and DME’s Legal Team.
Phase 1: Development of Interim-TCOS-RFP and Full-TCOS-RFP
Phase 1 includes an Interim-TCOS-RFP to be filed in July of 2021 and a Full-TCOS-RFP to be filed in
November of 2021.
Task A.1 Interim-TCOS-RFP: July 2021
TSPs may update their TCOS rate by filing an Interim-TCOS-RFP or a Full-TCOS-RFP. The Interim-TCOS-RFP
is an expedited process to update a TSP’s TCOS rate. The Interim-TCOS-RFP process allows TSPs to update
their TCOS rate based on any changes in transmission plant and depreciation. Testimony explaining the
transmission projects must accompany the required schedules. NewGen will create the schedules and
workpapers as required by the Interim-TCOS-RFP. Note that interim filing must use the revenue
requirement methodology previously approve by the PUCT.
Task A.1.1: Data Request and Review
NewGen will provide DME a detailed data request addressing important information required in
developing the Interim-TCOS-RFP for test year ending June 30, 2021. The requested information will
pertain to DME’s previous TCOS filings, transmission plant in service, accumulated depreciation,
depreciation expense, transmission facility descriptions, and other relevant information.
After reviewing the data, NewGen will host a Kick-Off or Planning Meeting with DME. The Project Team
will meet via conference call with DME and their Legal Team to discuss strategy and options for the
Interim-TCOS-RFP.
Deliverables:
Data Request.
Kick-Off/Planning Meeting.
Task A.1.2: Revenue Requirement and Schedule Development
The revenue requirement, schedules, and workpapers will be developed consistent with the Interim-
TCOS-RFP. We will rely on DME’s most recent financial data for either fiscal year end or more recent data
based on any new transmission plant placed into service. Upon completion of this task, the Project Team
will meet via conference call with DME and their Legal Team to discuss study results.
Deliverables:
Draft Interim TCOS model containing all schedules and workpapers.
Task A.1.3: Prepare Rate Filing Package
Upon completion of Task A.1.2, we expect that DME’s Legal Team will identify the witnesses and
associated scope of testimony required for the filing. We anticipate that NewGen will prepare all
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
4 Thoughtful Decision Making for Uncertain Times
schedules, workpapers, testimony, and the updated tariff in support of the analysis and filing. We
anticipate one NewGen witness; either Ms. Schuepbach, Mr. Rabon, or Mr. Mancinelli will be available to
sponsor the TCOS calculations and supporting schedules.
Deliverables:
Final Interim TCOS model containing all schedules, workpapers, and exhibits.
Updated Tariff with proposed wholesale transmission rate.
Testimony supporting the schedules, workpapers, exhibits, and tariff.
Once filed at the PUCT, ongoing support will be provided as described in Phase 2 below and Task B, C, and
D.
Task A.2: Full-TCOS-RFP to be filed in November 2021
The comprehensive Full-TCOS-RFP includes a full development of an electric system revenue requirement
which is then allocated to the transmission business function. The Full-TCOS-RFP requires numerous
schedules which contain information related to the TSP’s cost of doing business and operating
information. Functionalization factors are developed to functionalize costs related to operation and
maintenance expense, debt service, capital, and other items which are assigned to the transmission
business unit. Functionalization factors consider operation and maintenance procedures, labor cost, plant
investment, infrastructure design and use, voltage, and many other considerations. The test year revenue
requirement for the transmission system is prepared using these allocators. The revenue requirement is
developed consistent with the PUCT’s filing requirements. The Full-TCOS-RFP is then submitted with
written testimony describing the analyses and results as required by the PUCT’s rules. The following tasks
outline the steps in this process.
Task A.2.1: Data Request and Review
NewGen will provide DME a detailed data request addressing important information required in
developing the Full-TCOS-RFP for test year ending September 30, 2021. The requested information will
pertain to DME’s revenues, operation and maintenance costs, debt service, capital planning, plant in
service, transmission facility descriptions, system operating data, and other relevant information.
After reviewing the data, NewGen will host a Planning Meeting with DME. The Project Team will meet via
conference call with DME and their Legal Team to discuss strategy and options for the Full-TCOS-RFP.
Deliverables:
Data Request.
Planning Meeting.
Task A.2.2: Test Year Revenue Requirement
Based on information gathered in Task A.2.1, NewGen will develop a test year revenue requirement for
the transmission system based on the historical fiscal year 2020. Known and measurable adjustments will
be made to the historical results, as appropriate. The revenue requirement will be developed consistent
with the PUCT’s filing requirements.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 5
Deliverables:
Electric Revenue Requirement.
Task A.2.3: Functionalization Factors
NewGen will develop appropriate functionalization factors that assign costs related to operation and
maintenance expense, debt service, capital, and other items to the transmission business unit.
Functionalization factors will consider DME operation and maintenance procedures, labor cost, plant
investment, infrastructure design and use, voltage, and many other considerations. Functionalization
factors will be developed consistent with the PUCT’s guidelines.
Deliverables:
Functionalization Factors.
Functionalized Revenue Requirement.
Task A.2.4: Rate of Return Analysis and Strategies
NewGen will perform a preliminary TCOS analysis based on a test year coincident with DME’s fiscal year
ending September 30, 2020 and provide strategies for TCOS rate adjustments.
For the Full-TCOS-RFP, the PUCT allows three methods to be used for municipal utilities to calculate
return: Rate of Return, Debt Service Coverage, and Cash Flow. Each of the three methods will be reviewed
over multiple years as the most beneficial method to DME may change as capital structure, transmission
plant balances, or interest rates change.
The Cash Flow method develops a transmission revenue requirement on a “cash basis” similar to the
approach widely used by municipal utilities in retail rate making. The Cash Flow method determines the
cash need of the transmission function which primary includes operation and maintenance expenses, debt
service, cash funded capital projects, and payment of the City in lieu of taxes. The Debt Service Coverage
Method is similar to the Cash Flow Method but sets the revenue requirements based on operation and
maintenance expenses, debt service, and a coverage requirement as allowed by the PUCT for municipal
utilities. Finally, the Rate of Return Method uses the “Utility Approach” to ratemaking and establishes a
revenue requirement primarily using operation and maintenance expense, depreciation expense, interest
expense, and return on rate base. Rate Base primarily consists of DME’s net transmission plant in service.
The appropriate level of return is calculated using the Weighted Average Cost of Capital which examines
DME’s capital structure and associated cost of debt and cost of equity. For municipal utilities like DME,
the PUCT suggests a cost of equity as a function of the cost of debt.
NewGen will evaluate the advantages and disadvantages of DME filing under the three methods. NewGen
will develop the appropriate schedules and workpapers to support the rate of return method that benefits
DME. The workpapers may include adjustments and industry references.
Upon completion, the Project Team will meet via conference call with DME and the Legal Team to discuss
the results. NewGen will identify specific aspects of the analyses that are straightforward and other
potential areas that may be subject to alternative interpretation by the PUCT staff and interveners.
NewGen will discuss the TCOS strategy going forward, including which return method benefits DME over
time, and when DME should file to reset their TCOS rate. Based on the review of the analysis, revisions
may be made to optimize DME’s bargaining position entering the TCOS case. Based on feedback received
during this task of the Study, we will finalize the analysis.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
6 Thoughtful Decision Making for Uncertain Times
Deliverables:
Preliminary TCOS analysis using three methods of return.
Conference call to discuss TCOS results.
Rate of Return Calculation.
Task A.2.5: Schedules and Workpapers
Applying functionalization factors developed in Task A.2.3 to the revenue requirement developed in Task
A.2.2 yields the allocated TCOS for DME. Task A.2.4 results will determine the allowed ”return” on DME
transmission assets that will be included in the revenue requirement. NewGen will create the schedules
and workpapers as required by the Full-TCOS-RFP.
Deliverables:
TCOS model including all schedules and workpapers for DME Legal Team review.
Task A.2.6: Prepare Rate Filing Package
Upon completion of Task A.2.5, we expect that DME’s Legal Team will identify the number of witnesses
and associated scope of testimony required for the filing. NewGen will prepare all required schedules,
workpapers, testimony, and the updated tariff in support of the filing. We anticipate one or two NewGen
witnesses and we are flexible in assigning witnesses to the filing given the issues and the guidance of Legal
Team.
Deliverables:
Final full comprehensive TCOS model containing all schedules, workpapers, and exhibits.
Updated Tariff with proposed wholesale transmission rate.
Testimony supporting the schedules, workpapers, exhibits, and tariff.
Once filed at the PUCT, ongoing support will be provided as described in Phase 2 below and Tasks B, C,
and D.
Phase 2: TCOS Case Support
Our work efforts in Phase 2 will be largely dictated by the PUCT staff and any intervenors. Phase 2 is
entirely reactive and is subject to the response the case receives once filed. We anticipate work efforts
will be related to responding to interveners and PUCT staff questions through the discovery process,
developing rebuttal testimony, and testifying at the hearing.
Given the uncertain nature of this work, we propose to provide Phase 2 services on a time and materials
basis.
Deliverables:
Attend all requested meetings.
Support DME in response to the PUCT Staff’s requests for information.
Support DME in all negotiations or settlement meetings.
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PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 7
Provide rebuttal testimony if required.
Tasks B, C, and D: Continued Support
The purpose of Tasks B, C, and D is to support DME in a variety of activities including coordinating with
Legal Teams, ongoing regulatory support, analytical support, negotiation support, and consulting advice.
Task B involves monitoring the PUCT’s activities including orders and staff recommendations that may
have an impact on DME. New Gen will attend meetings as DME’s representative when requested by DME.
NewGen will routinely communicate with DME regarding any future events.
Task C involves working with both DME’s internal and external Legal Teams to draft, complete, and file all
Interim-TCOS-RFPs and Full-TCOS-RFPs with the PUCT on behalf of DME.
Task D includes additional analyses and project work as requested or directed by DME.
Deliverables:
Attend meetings to support DME’s interests.
Monitor the PUCT’s activities as they relate to DME.
Collaborate and coordinate with DME’s Legal Teams.
Provide support including analytical, negotiations, or consulting advice.
Any support provided to Denton in Tasks B, C, or D will only be performed upon written authorization of
Denton. Given the unknown level of effort for this work, we propose to provide Task B, C, and D services
on a time and materials basis.
PROJECT SCHEDULE
NewGen is available to begin work immediately. Upon award of this contract, NewGen will send a detailed
data request to support the Interim-TCOS-RFP being filed in July of 2021 and host a Kick-Off/Planning
Meeting. Once the Interim-TCOS-RFP is filed, NewGen will send a second data request to support the Full-
TCOS-RFP to be filed in November of 2021.
After the Full-TCOS-RFP is filed, NewGen will maintain ongoing communication with DME staff regarding
any happenings at the PUCT and to support any new Full-TCOS-RFPs, Interim-TCOS-RFPs, or Earnings
Reports.
PROJECT TEAM
NewGen evaluates the needs of each project and responds by assembling a Project Team of
knowledgeable professionals who are uniquely qualified to provide the services needed. The Project
Team includes experts in cost of service, rate design, transmission rates and tariffs, and analytical support
needed to accurately execute the work. NewGen seeks to be a trusted advisor to all our clients, and our
Project Team is committed to completing the identified services in a timely and professional manner.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
8 Thoughtful Decision Making for Uncertain Times
Jill Schuepbach will be the Project Manager for the Scope of Work. For Task A, NewGen proposes that
either Jill Schuepbach, Grant Rabon, or Joe Mancinelli will be the lead witness. Tasks B, C, and D will also
be supported by Grant Rabon. Analytical and administrative staff will prove support as needed. All Project
Team members have significant experience in the development of transmission rates using the various
PUCT available rate of return methodologies.
Our team will be based in both our Denver, Colorado and Austin, Texas offices. Jill Schuepbach and Joe
Mancinelli work in our Denver office, which has 14 employees. Grant Rabon works in our Austin office,
which has 6 employees. The addresses of each office are included below.
Branch Office Locations & Phone Numbers
Austin
8140 N Mopac Expy, Bldg 1, Suite 240
Austin, TX 78759
(512) 479-7900
Denver
225 Union Blvd, Suite 305
Denver, CO 80228
(720) 633-9514
A summary of the Project Team’s experience and qualifications follow. In addition, full resumes for each
of the three proposed Project Team members are included as Appendix A.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 9
Joseph Mancinelli, President & CEO | Phone Number: (720) 633-9509
Joe Mancinelli has over 30 years of experience as a utility consultant serving the public
utility industry. He is President and CEO of NewGen Strategies and Solutions, LLC and
has worked extensively for public power utilities across the country. Joe has advised
electric utilities, Public Utility Commissions, and large end users on utility economics,
retail and wholesale rates, stakeholder engagement, and related policy issues. He
regularly teaches across the country on ratemaking techniques and skills associated
with being an effective expert witness. In addition to rates and stakeholder engagement, Joe has
extensive experience in the areas of financial planning, bond financings, asset valuation, competitive
assessments, organizational reviews, and strategic planning.
Jill Schuepbach, Executive Consultant | Phone Number: (720) 924-7134
Jill Schuepbach has over 20 years of experience in the electric, water, wastewater, and
natural gas utility industries. Jill has proven analytical skills in the areas of engineering
economics, financial planning, and utility COS and rate design studies. In addition, Jill
has experience with feasibility studies, fuel price forecasting, market research, demand-
side management evaluations, litigation support, and expert witness testimony. Her
project experience includes work for municipal, investor-owned, and member-owned
utility clients.
Grant Rabon, Executive Consultant | Phone Number: (512) 900-8232
Since 2005, Grant Rabon has managed electric, water, wastewater, and solid waste
utility projects designed to safeguard clients’ financial integrity primarily through the
performance of financial risk assessments and feasibility studies, valuations/appraisals,
litigation support, and comprehensive cost of service analyses. He has testified at the
Public Utility Commission of Texas and the Louisiana Public Service Commission. He has
presented at industry conferences on the topics of rate design, financial planning,
compensation for decertification, regionalization, electric transmission regulation in Texas, and
distributed generation. Further, he is one of less than 20 individuals in the nation with an Accredited
Senior Appraiser designation in Public Utilities from the American Society of Appraisers.
PERTINENT EXPERIENCE
The Project Team is well qualified to provide DME with the services identified in the Request for
Qualifications (RFQ). Below we have included selected project descriptions that we believe are relevant
to services being requested by DME.
Greenville Electric Utility System (GEUS) | Full-TCOS-RFP, PUCT Petition to Reduce GEUS TCOS Rate,
and TCOS Earnings Report Filing
Date of Service: 1998 – 2020
Contact Name: Alicia Hooks, General Manager
Contact Info: 6000 Joe Ramsey Blvd., Greenville, TX 75402| (903) 457-2811 | ahooks@geus.org
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
10 Thoughtful Decision Making for Uncertain Times
Full-TCOS-RFP (Docket Nos. 51556, 42581, 37180, and 21648)
TSPs can update their TCOS rate by filing a Full-TCOS-RFP. The Full-TCOS-RFP includes a full development
of an electric system revenue requirement which is then allocated to the transmission business function.
The filing package requires numerous schedules which contain information related to the TSP’s cost of
doing business and operating information. Functionalization factors are developed to functionalize costs
related to operation and maintenance expense, debt service, capital, and other items which are assigned
to the transmission business unit. Functionalization factors consider operation and maintenance
procedures, labor cost, plant investment, infrastructure design and use, voltage, and many other
considerations. The test year revenue requirement for the transmission system is prepared using these
allocators. The revenue requirement is developed consistent with the PUCT’s filing requirements. The
Full-TCOS-RFP was submitted with written testimony describing the analyses and results as required by
the PUCT’s rules.
Since 1996, NewGen has periodically filed testimony before the PUCT in support of GEUS’s wholesale
transmission rates in ERCOT. NewGen filed Full-TCOS-RFPs in 1996, 1999, 2009, 2014, and 2020.
NewGen’s testimony was supported by a comprehensive unbundled cost of service analysis.
PUCT Petition to Reduce GEUS TCOS Rate (Docket No. 27789)
Each year the PUCT Staff files a memorandum summarizing their analysis of each TSP’s Earnings Reports
filed under the provisions of 16 TAC § 25.73. As a result of the PUCT Staff’s review of the 2001 Earnings
Reports, the PUCT filed a petition in 2003 to call in GEUS for excess earnings. NewGen negotiated with
the PUCT Staff on GEUS’s behalf to justify the GEUS revenue requirement and rate base. The PUCT and
GEUS settled and signed a Stipulation Agreement resolving specific contested issues raised by the PUCT
Staff in the petition.
TCOS Earnings Report Filing (Docket Nos. 50655, 49355, 48158, 46910, 45636, 44550, 42290, 41327, 40327,
39211, 37993, 36823, 35466, 34025, 32534, 30805, and 29343)
TSPs file a TCOS Earnings Report annually as required by PUCT Electric Substantive Rule 25.73(b). The
Earnings Report Filing requires the update of schedules and workpapers, and the use of the
functionalization factors that were approved in the last Full-TCOS-RFP. Based on these functionalization
factors, the costs related to operation and maintenance expense, debt service, capital, and other items
are assigned to the transmission business unit. Functionalization factors consider operation and
maintenance procedures, labor cost, plant investment, infrastructure design and use, voltage, and many
other considerations. The test year revenue requirement for the transmission system is prepared using
these allocators. The revenue requirement is developed consistent with the PUCT’s filing requirements.
Since 2001, NewGen has prepared the annual TCOS Earnings Reports for GEUS. NewGen compiles the
filing documents including schedules, workpapers, and exhibits. NewGen works in close coordination with
GEUS’s legal team to file the required public and confidential documents. The most recent TCOS Earnings
Report was completed on June 1, 2020 for fiscal year 2019.
Bryan Texas Utilities (BTU) | Interim-TCOS-RFP and TCOS Earnings Report Filing
Date of Service: 2012 – 2020
Contact Name: Doug Lyles, Chief Risk Officer & Manager
Contact Info: 205 E 28th St. Bryan TX 77803| (979) 821-5825 | dlyles@btuutilities.com
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 11
Interim-TCOS-RFP (51623, 48123, 44467, and 41920)
TSPs can update their TCOS rate by filing an Interim-TCOS-RFP or a Full-TCOS-RFP. The Interim-TCOS-RFP
is an expedited process to update a TSP’s TCOS rate. The Interim-TCOS-RFP process allows TSPs to update
their TCOS rate based on any changes in transmission plant. Testimony explaining the transmission
projects must accompany the required schedules.
NewGen prepared BTU’s Interim-TCOS-RFP for 2012, 2014, 2018, and 2020. NewGen worked with BTU
staff to prepare filing documents: schedules, workpapers, testimony, and the updated tariff. The TCOS
revenue requirement was developed consistent with the PUCT’s filing requirements.
TCOS Earnings Report Filing (Docket Nos. 50655, 49355, 48158, 46910, 45636, 44550, 42290, and 41327)
Since 2012, NewGen has assisted BTU in the preparation of the annual TCOS Earnings Report. NewGen
works with BTU staff to prepare filing documents, analyses, and workpapers. NewGen works in close
coordination with BTU’s legal team to file the required public and confidential documents. The most
recent TCOS Earnings Report was completed on June 1, 2020 for FY 2019.
Garland Power & Light (GPL) | Full-TCOS-RFPs and Interim-TCOS-RFPs
Date of Service: 2003 – 2014
Contact Name: Darrel Cline, CFO
Contact Info: 217 N. Fifth St., Garland, TX 75040| (972) 205-2671 | dcline@gpltexas.org
Full-TCOS-RFP (Docket Nos. 38709, 36439, and 28090)
NewGen periodically filed testimony before the PUCT in support of GPL’s wholesale transmission rates in
ERCOT. NewGen filed Full-TCOS-RFPs in 2003, 2009, and 2011. NewGen’s testimony was supported by a
comprehensive unbundled cost of service analysis.
Interim-TCOS-RFP (Docket Nos. 42630 and 31617)
NewGen prepared GPL’s Interim-TCOS-RFP for 2005 and 2014. NewGen worked with GPL staff to prepare
filing documents: schedules, workpapers, testimony, and the updated tariff. The TCOS revenue
requirement was developed consistent with the PUCT’s filing requirements.
Texas Municipal Power Agency (TMPA) | Interim-TCOS-RFP (Docket No. 51439)
Date of Service: 2020
Contact Name: Lyndi Birkhead, Director of Finance & Support Services
Contact Info: 12824 FM 244 Road, Anderson, TX 77830| (936) 873-1133 | lbirkhead@texasmpa.org
NewGen prepared TMPA’s Interim-TCOS-RFP for 2020. NewGen developed the filing documents to
convey the transmission plant in a manner consistent with TMPA’s PUCT approved depreciation rates,
including a simulated accumulated depreciation reserve, as well as accompanying testimony and
schedules. The TCOS revenue requirement was developed consistent with the PUCT’s filing requirements
and NewGen was the sole expert witness covering all required topics in our direct testimony. As of
December 8, 2020, the PUCT Staff recommended approval of the filed rate.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
12 Thoughtful Decision Making for Uncertain Times
Lubbock Power & Light (LP&L) | Full-TCOS-RFP (Docket No. 51100)
Date of Service: 2020 – Ongoing
Contact Name: Andy Burcham | Assistant Director & CFO
Contact Info: 1301 Broadway Street, Lubbock, TX 79401| (806) 775-3430 | aburcham@lpandl.com
NewGen was hired by Lloyd Gosselink to assist the firm in representing LP&L in the preparation and
prosecution of LP&L’s first application for wholesale transmission rates to be filed with the PUCT. This
TCOS was associated with LP&L’s integration with ERCOT. As such, it was a unique TCOS filing and rate
filing package. As LP&L’s first filing, NewGen developed the fully functionalized revenue requirement
based on a forecasted year with known and measurable adjustments for LP&L’s transmission system
upgrades and projected costs. NewGen provided direct testimony and rebuttal testimony, responded to
multiple requests for information from the PUCT Staff, and is currently supporting settlement negotiations
between LP&L and the PUCT Staff. As of December 9, 2020, LP&L and the PUCT reached a settlement in
principle and cancelled the hearing.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 1
APPENDIX A – RESUMES
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Joseph Mancinelli
President & CEO
jmancinelli@newgenstrategies.net
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Joseph Mancinelli has over 30 years of experience as a utility consultant to the public utility industry and serves as
President & CEO of NewGen Strategies and Solutions, LLC. NewGen offers a wide range of management, planning,
and engineering economic services to public power clients. His direct experience includes strategic and business
planning, cost of service and rate design analyses, performance management, economic analyses, asset valuation,
revenue bond financing in the roles of project manager, lead analyst, and expert witness. He regularly advises senior
management teams, utility boards, city councils, attorneys, and end-users. Additionally, he has taught cost of service
and rate design concepts through numerous presentations, seminars and classes in association with Electric Utility
Consultants, Inc., American Public Power Association, and various cooperative organizations.
Education
He has a Master of Business Administration in Finance from the University of Colorado and a Bachelor of Science in
Geophysical Engineering from the Colorado School of Mines.
Electric Cost of Service and Rate Design
Mr. Mancinelli has considerable experience leading project teams in the review and establishment of utility revenue
requirements, development of cost of service analyses and retail and wholesale rate design. He works with clients
and stakeholders in the understanding of cost of service and rate design principles and assists clients in the
development of the underlying policies and principals important in the rate setting process. He has worked for clients
across the country. Clients include wholesale and retail electric utilities, various stakeholder groups, public utility
commissions and large consumers of electricity. A sample of Mr. Mancinelli’s electric cost of service and rate design
clients include the following:
Austin Energy, Texas
Bose McKinney & Evans, LLP
Bryan Texas Utilities, Texas
Cleveland Public Power, Ohio
Continental Divide, New Mexico
CPS Energy, Texas
Deseret Power Cooperative, Utah
Estes Park Power & Light, Colorado
Fort Collins Utilities, Colorado
Farmington Electric Utility System
City of Garland Power and Light, Texas
GEUS, Texas
HNTB Corporation
Keys Energy Services, Florida
Lafayette Utilities System, Louisiana
Lloyd Gosselink Rochelle & Townsend, P.C.
Lubbock Power and Light, Texas
Nebraska Public Power District
New Braunfels Utilities, Texas
Plains Electric Generation and Transmission
Cooperative, Inc., New Mexico (now Tri-State)
Platte River Power Authority, Colorado
Richmond Power & Light, Indiana
Tri-State Generation & Transmission
Association, Inc., Colorado
U.S. Army, Huntsville, Alabama
United Power Electric Cooperative, Colorado
Navajo Tribal Utility Authority
Weatherford Municipal Utilities, Texas
Expert Witness and Litigation Support
Mr. Mancinelli has provided expert testimony for over 20 years regarding electric utility cost of service, rate design,
and ratemaking issues before state and local regulatory bodies and courts. He has national experience providing
litigation support regarding ratemaking matters at wholesale and retail levels in Alaska, California, Colorado, Guam,
Indiana, Michigan, Nebraska, New Mexico, Nevada, North Carolina, Texas, and Utah.
Mr. Mancinelli’s expert witness and litigation support includes:
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Joseph Mancinelli
President & CEO
Thoughtful Decision Making for Uncertain Times 2
Crawfordsville Electric Light & Power, Indiana Utility
Regulatory Commission, Cause No. 44684
Tri-State Generation and Transmission Association,
Inc., Federal Energy Regulatory Commission, Docket
Nos. ER20-676-000, ER20-1559-000, ER20-2417-000.
Richmond Power & Light, Indiana Utility Regulatory
Commission, Cause No. 45361.
Indiana Michigan Power Company, Indiana Utility
Regulatory Commission, Cause No. 45235.
Joint Community Choice Aggregators, Public Utility
Commission of the State of California, Application
No. 18-12-009.
Farmington Electric Utility System, New Mexico;
Federal Energy Regulatory Commission, Docket Nos.
QF19-1082-001, QF19-1083-001, QF19-1084-001
Southern Indiana Gas and Electric Company D/B/A
Vectren Energy Delivery of Indiana, Inc., Cause No.
43554 MCRA 21
U.S. Department of Defense, North Carolina Utilities
Commission, Docket No. E-2, Sub 1142
Nebraska Public Power District, Nebraska; Section
70, Article 13 Arbitration Panel
Northern Indiana Public Service Company, Indiana;
Cause Nos. 44688 and 44733-TDSIC-1
Bryan Texas Utilities, Texas; Docket Nos. 48123,
44467 and 41920
Lower Colorado River Authority, Texas; Cause Nos.
121-001-B and D-1GN-12-002156
Austin Energy, Texas; Docket No. 40627
Guam Power Authority, Guam; Docket No. 11-09
Brownsville Public Utilities Board, Texas; Docket Nos.
32905 and 38556
Brownsville Public Utilities Board, Texas; Texas Water
Commission; Docket No. 9013-M.
Xcel Energy, Colorado; Docket Number 02S – 315 EG.
Rocky Mountain Power, Utah; Docket No. 09-035-23
GEUS, Texas; Texas Public Utilities Commission;
Dockets No. 42581 and 37180
GEUS, Texas; Case Number 25591
Application of Sierra Pacific Power Company, Nevada;
with respect to retail rates; Docket No. 05-10003
Lamar Light and Power versus Colorado Aquature,
Colorado
AEP Texas Central Company, Texas; application of AEP
Texas Central Company for authority to change rates;
PUC Docket No. 28840
The City and County of Denver, Colorado; United
States District Court for the District of Colorado; Civil
Action No. 96-D-2968
Chugach Electric and Homer Electric Association,
Alaska; Regulatory Commission of Alaska; Docket No.
U-06-134
Traverse City Light and Power and Michigan Public
Service Commission; Case Numbers U-13716, U-12844
and U-13071
Plains Electric Generation and Transmission
Cooperative, Inc., New Mexico; New Mexico Public
Utilities Commission; Docket No. 2797
Workshops and Presentations
Mr. Mancinelli has given numerous presentations and participated in training and workshops in several states. These
activities have focused on cost of service, ratemaking, and competitive issues. Host organizations and the topics
Mr. Mancinelli presented are displayed below.
American Public Power Association
Costs and Benefits of Generation Resources
Innovative Rates and Rate Riders for Key Accounts
Including Risk Management in the Key Account
Function
Advanced Rate Making Concepts for Publicly
Owned Electric Systems
Retail Rate Design for Publicly Owned Electric
Systems
Electric Utility Consultants, Inc.
Rate Case Expert Witness Preparation
Introduction to Cost of Service Concepts and
Techniques for Electric Utilities
Introduction to Rate Design for Electric Utilities
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Joseph Mancinelli
President & CEO
3 Thoughtful Decision Making for Uncertain Times
Texas Public Power Association
Establishing Effective Financial Policies for Your
Utility
Contracting with Retail Customers
Developing Rate Design Strategies and
Financial Policies for Your Utility
New Mexico Rural Electric Association
Unbundling for Competition
Utah Association of Municipal Power and Utah Rural Electric Association
Electric Rate Unbundling
New Hampshire Electric Cooperative
Rate design and cost of service strategy and training program
Colorado Rural Electric Association
Net Metering Overview
Utah Municipal Power Agency
Cost of Service, Rates and Net Metering
High West Energy – Irrigation Members
Introduction to Cost of Service and Rate Design
Concepts
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Jill Schuepbach
Executive Consultant
jschuepbach@newgenstrategies.net
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Jill Schuepbach has been providing financial expertise to the utility industry for over 20 years. She has proven project
management and analytical skills in the areas of utility cost of service and rate design, financial planning, economic
and financial analysis, engineer of record, and pole attachment fees. In addition, Ms. Schuepbach has experience
with feasibility studies, litigation support, and preparation of expert witness testimony. Her project experience
includes work for municipal, investor-owned, and member-owned utility clients.
EDUCATION
Master of Business Administration, University of Colorado
Bachelor of Science in Mechanical Engineering, University of Missouri
PROFESSIONAL REGISTRATIONS / CERTIFICATIONS
Registered Professional Engineer (PE), Colorado
KEY EXPERTISE
Cost of Service and Rate Design
Project Financing
Engineer of Record
Economic and Financial Analysis
Litigation Support
Pole Attachment Fees
RELEVANT EXPERIENCE
Financial Forecasts, Cost of Service, and Rate Design
Ms. Schuepbach has assisted with numerous utility financial forecasts, cost of service, and rate design projects.
Financial Forecast tasks include developing models to balance capital spending and rate increases, support
compliance with debt covenants, and assist with general short-term and long-term decision making. Cost of Service
tasks include the development of the revenue requirement, functionalization and classification of costs, and
allocation of costs to customer classes. Rate Design tasks include a review of existing customer class criteria, design,
tariff development, and transitioning of models for the client’s future use. Additional analysis includes the
evaluation of miscellaneous charges and fees based on the utility’s costs and local and state policy. She has assisted
with training and workshops regarding cost of service and rate design theory, industry practice, and rate strategies
to governing bodies and boards. She has also presented rate study results and provided financial recommendations
to governing bodies, boards, and city councils.
She has performed electric, natural gas, and photovoltaic cost of service. Her efforts have also included support in contract negotiations in developing a rate to serve a large industrial load and unbundled transmission costs.
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Jill Schuepbach
Executive Consultant
Thoughtful Decision Making for Uncertain Times 2
Ms. Schuepbach’s clients for cost of service and rate design services include:
Brownsville Public Utilities Board, Texas
Bryan Texas Utilities, Texas
Estes Park, Colorado
Farmington Electric Utilities System, New Mexico
Glendale Water and Power, California
Greenville Electric Utility System (GEUS), Texas
Lafayette Public Power Authority, Louisiana
Lafayette Utilities System, Louisiana
Loup Power District, Nebraska
Navajo Tribal Utility Authority, Arizona
She has also evaluated energy consumption profiles, billing accuracy, base operations, contract terms, rate options,
asset/facilities upgrades (e.g., energy efficiency/demand response), distributed generation options, and tenant
billing recovery for the US Army.
Transmission Revenue Requirement Compliance Filings
Ms. Schuepbach has assisted with multiple transmission rate filings at the Regional Transmission Organization (RTO)
level and at the Federal Energy Regulatory Commission (FERC) regarding Annual Transmission Revenue
Requirements (ATRR) and methodologies for determining rates. Ms. Schuepbach’s clients include:
Bryan Texas Utilities, Texas
Greenville Electric Utility System (GEUS), Texas
City of Garland Power and Light, Texas
Independence Power & Light, Missouri
Financing of Public and Private Projects
Ms. Schuepbach has provided pro forma analysis supporting revenue bond financing for utilities and commercial
bank financings of privately developed projects. She developed and reviewed pro forma financial models for
technical and economic feasibility. The investment community that provides financing for these projects relies upon
these models. In addition, Ms. Schuepbach has experience with financial modeling for municipal clients and
alternative expansion plans for industrial clients interested in self-generation.
Ms. Schuepbach’s responsibilities have included updating and reviewing budgets, financial statements, capital plans,
and other financial inputs to the pro forma model; and reviewing technical and financial inputs to the pro forma
model, including financial modeling of utility operations to determine rate adequacy, future capital funding sources,
and compliance with bond covenants. Clients served by Ms. Schuepbach’s pro forma modeling experience include:
ATCO Power, Alberta, Canada
Bank of Nova Scotia and Credit Suisse First
Boston, Alabama
Brownsville Public Utilities Board, Texas
Citibank North America, Oklahoma
Lafayette Utilities System, Louisiana
UFJ Bank, Ratchaburi Province, Thailand
Engineer of Record and Consulting Engineer Reports
Ms. Schuepbach assists in the development of Consulting Engineer Reports and associated ordinance required
reviews for municipal utilities. These reviews typically require an annual assessment of each utility’s financial and
physical operations for the duration of the bond period. The field review typically includes a determination of the
condition of the physical assets of the utility, which also includes a review of the utility’s budgeting and planning
process. Ms. Schuepbach’s project experience includes:
Lafayette Utilities System, Louisiana Lafayette Public Power Authority, Louisiana
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Jill Schuepbach
Executive Consultant
3 Thoughtful Decision Making for Uncertain Times
Economic and Financial Analysis
Ms. Schuepbach has provided economic analyses for municipal utilities involving generation projects. These
evaluations included a review of the costs and operation of new generation units added to the existing generation
resources and an economic analysis of the proposed generation on retail rates.
Ms. Schuepbach assisted with the allocation of Hoover Power in Arizona, which included technical advice, review of
customer applications for completion and accuracy, and scenario analysis of the potential hydro power allocations.
Her clients have included:
Arizona Power Authority, Arizona
Brownsville Public Utilities Board, Texas
City of Bryan, Texas
Lafayette Utilities System, Louisiana
Litigation Support
Ms. Schuepbach has assisted in litigation support and preparation of expert witness testimony in Texas, Louisiana,
Missouri, and Indiana. Her testimony support is related to revenue requirements, cost of service, and rate design,
as well as the proper allocation of generation costs given a system’s unique characteristics. Ms. Schuepbach’s
litigation support clients include:
Brownsville Public Utility Board, Texas: Docket
Nos. 38556 and 32905
Bryan Texas Utilities, Texas: Docket Nos. 44467
and 41920
Greenville Electric Utility System (GEUS), Texas:
Dockets Nos. 45281 and 37180
Independence Power & Light, Missouri: Docket
No. ER15-1499-001
Lafayette Utilities System, Louisiana: Docket
No. 00994490
Northern Indiana Public Service Company,
Indiana: Cause Nos. 44688, 44733, and 45159
Indiana Michigan Power Company, Indiana:
Cause No. 45235
Pole Attachment Fees
Ms. Schuepbach has developed pole attachment fees for several clients. She has employed various methodologies
including those recommended by the Federal Communications Commission (FCC) and the American Public Power
Association (APPA). She has recommended rates for cable and communications companies based on the type of
poles to which they are attached. Her work also includes a review of the contract or agreement between the utility
and the customer. Her projects include:
Farmington Electric Utilities System, New
Mexico
Keys Energy Services, Florida
Navajo Tribal Utility Authority, Arizona
Navopache Electric Cooperative, Arizona and
New Mexico
Renewable Energy Feasibility
Ms. Schuepbach reviewed publicly available information regarding the feasibility of utilizing renewable energy
resources including wind, solar, biomass, geothermal, fuel cell, and ocean energies in the client’s service territory.
Her analysis included the history of the technology, advantages and disadvantages, capital and operating costs, and
expected future costs. The resultant report compared the costs of the renewable technology to existing fossil fuel
technologies including simple cycle, combined cycle, and coal plant. Her renewable energy clients include:
Lafayette Utilities System, Louisiana
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Jill Schuepbach
Executive Consultant
Thoughtful Decision Making for Uncertain Times 4
Demand Side Management
Ms. Schuepbach conducted demand side management (DSM) analyses including evaluation of cost effectiveness,
development of numeric goals, and development of testimony as well as preparation of technical reports based on
the economic evaluation. Her DSM clients include:
Florida Municipal Power Agency, Florida
JEA, Florida
Kissimmee Utility Authority, Florida
Lakeland Electric, Florida
Orlando Utilities Commission, Florida
Contract Review
Ms. Schuepbach has reviewed purchase and service contracts for independent engineering reports for natural gas
pipeline projects and compressor stations. Her project experience includes:
Citibank, North America and Export-Import
Bank of the United States, Tamaulipas, Mexico
North Baja Pipeline LLC, Arizona and California
Chilled Water Economic Evaluation
Ms. Schuepbach has experience in the economic evaluation of both self-build chilled water plants and purchasing
chilled water from an external entity. She has assessed the proposed rate structure for chilled water, designed
chilled water rates based on the development of a financial model that projects the profitability of the chilled water
plant over a six-year period and cost-of-service and rate design, reviewed terms of the chilled water service contract,
and advised owner’s project management teams on negotiating tactics. Ms. Schuepbach’s chilled water clients
include:
Long Center for the Performing Arts, Texas City of Mesa, Arizona
Load Aggregation Study
Ms. Schuepbach has experience with load aggregation for private consumers exploring opportunities to increase
their buying power. She has assisted in the evaluation of individual loads in support of a load aggregate study and
in the development of a licensed load aggregate entity to capitalize on market opportunities presented by
deregulation. She has also completed market assessments and energy provider profiles, developed a national
request for proposals (RFP), and assisted in the negotiations of multiple commodity agreements to service facilities
in multiple states. Ms. Schuepbach’s load aggregation clients include:
Level 3 Communications, Colorado Region IV School District, Texas
WORKSHOPS AND PRESENTATIONS
Ms. Schuepbach has given industry presentations focused on cost of service and ratemaking. Host organizations and
the topics Ms. Schuepbach presented include:
Electric Utility Consultants, Inc.
Introduction to Cost of Service Concepts and
Techniques for Electric Utilities
Introduction to Rate Design for Electric Utilities
California Public Utilities Commission
Cost of Service Concepts for Electric Utilities
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Grant Rabon
Executive Consultant
grabon@newgenstrategies.net
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Since 2005, Mr. Rabon has managed electric, water, wastewater, and solid waste utility projects designed to
safeguard clients’ financial integrity primarily through the performance of financial feasibility studies,
valuations/appraisals, or comprehensive cost of service analyses. His educational background facilitates a unique
understanding of the financial implications for technical projects. Further, he is one of less than 20 individuals in the
nation with an Accredited Senior Appraiser designation in Public Utilities from the American Society of Appraisers.
EDUCATION
▪ Master of Business Administration, University of Texas at Austin
▪ Bachelor of Science in Chemical Engineering, Texas A&M University
PROFESSIONAL REGISTRATIONS / CERTIFICATIONS
▪ Accredited Senior Appraiser (ASA) designation in Public Utilities from American Society of Appraisers
KEY EXPERTISE
▪ Cost of Service and Rate Design
▪ Financial Feasibility
▪ Utility Appraisals and Valuations
▪ Regulatory and Litigation Support
RELEVANT EXPERIENCE
Some of the following projects were completed by Mr. Rabon while employed by SAIC Energy, Environmental &
Infrastructure, LLC (formerly R.W. Beck).
Cost of Service and Rate Design
Mr. Rabon has conducted numerous comprehensive cost of service and rate design studies. Rates designed as a
result of these engagements equitably recover the cost of service and align with the utilities’ goals, including special
consideration for affordability and best practice rate structures. Stakeholder outreach and benchmarking analyses
were common tasks within these projects.
Key projects include:
▪ Austin Energy Cost of Service and Testimony – Conducted a comprehensive, unbundled cost of service analysis
for the electric utility and designed equitable rates to achieve the City of Austin’s goals, including improving
fixed cost recovery while incentivizing conservation through a five-tier rate structure and providing support for
distributed generation, such as rooftop solar. Filed direct testimony on behalf of the City of Austin d/b/a Austin
Energy at the Public Utility Commission of Texas in defense of the electric rates adopted by Austin City Council
(PUC Docket No. 40627). Later, in 2015, conducted various analyses on issues of critical importance to Austin
Energy, such as a financial reserves study and review of small commercial rates, and assisted Austin Energy staff
in an update to the cost of service and rate design. These projects included extensive public involvement and
stakeholder engagement.
▪ Lower Colorado River Authority Wholesale Water Benchmarking and Rate Analysis – Performed a
benchmarking analysis to identify best practices among wholesale water entities around the nation, with an
emphasis on innovative rate structures and water conservation efforts. A long-term rate analysis was conducted
to incorporate projected capital projects to expand the water supply over a 90-year horizon under various rate
structures.
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Grant Rabon
Executive Consultant
Thoughtful Decision Making for Uncertain Times 2
▪ Greenville Electric Utility System (GEUS) Electric Transmission Filing – Performed a quality assurance review of
a comprehensive cost of service analysis for the transmission function and regulated rate filing with the Public
Utility Commission of Texas.
▪ Texas Municipal Power Agency (TMPA) Electric Transmission Filing – Developed an interim regulated rate filing
for the transmission function with the Public Utility Commission of Texas and filed direct testimony on behalf of
TMPA (PUC Docket No. 51439).
▪ Georgetown Electric Utility – Conducted a series of rate projects for the City of Georgetown, Texas to improve
cost recovery and equity. This includes a redesign of the distributed generation rate tariff, evaluation of a large
contract customer load, and design of a new rate tariff for commercial ”fast charging” plug-in electric vehicle
charging stations.
▪ Other Cost of Service and Rate Design Studies – Conducted one or more comprehensive cost of service and
rate design studies for the following entities:
▪ City of Athens, Texas
▪ City of Borger, Texas
▪ City of Bryan, Texas
▪ City of Del Rio, Texas
▪ City of Greenville, Texas
▪ City of Hobbs, New Mexico
▪ City of Las Cruces, New Mexico
▪ City of Longview, Texas
▪ City of New Braunfels, Texas
▪ City of Nogales, Arizona
▪ City of Olathe, Kansas
▪ City of Peoria, Arizona
▪ City of Pflugerville, Texas
▪ City of Sealy, Texas
▪ City of Sioux Falls, South Dakota
▪ City of Stillwater, Oklahoma
▪ City of Sugar Land, Texas
▪ City of Tempe, Arizona
▪ City of Temple, Texas
▪ City of Tucson, Arizona
▪ City of Vernon, California
▪ City of Weatherford, Texas
▪ Greater Ouachita Water Company, Louisiana
▪ Levi Water Supply Corporation, Texas
▪ Liberty City Water Supply Corporation, Texas
▪ Gonzales County Water Supply Corporation,
Texas
▪ Manville Water Supply Corporation, Texas
▪ North Slope Borough, Alaska
▪ Pima County, Arizona
▪ Rockett Special Utility District, Texas
▪ St. Tammany Parish, Louisiana
▪ Snohomish County, Washington
▪ Town of Estes Park, Colorado
▪ Walker County Special Utility District, Texas
▪ Wellborn Special Utility District, Texas
▪ York County, South Carolina
Financial Feasibility
Mr. Rabon has evaluated the financial feasibility of various projects through business case analyses and the
development of financial models. This includes a project to evaluate a proposed 20 million-gallon-per-day brackish
groundwater desalination facility based on the relative capital and operational costs as well as total lifecycle costs
under various project delivery options, including traditional DBB, DB, DBO and a customized DBOOT. Another project
included financial feasibility modeling to evaluate the development of a proposed water source for a municipal
client.
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Grant Rabon
Executive Consultant
3 Thoughtful Decision Making for Uncertain Times
Utility Appraisals and Valuations
Mr. Rabon has conducted valuations as well as fair market value appraisals to determine an indication of value for
acquisitions/dispositions, or to evaluate municipalization or privatization of utilities. His experience also includes
service area valuations to determine compensation for decertification of areas covered by certificates of
convenience and necessity.
Key projects include:
Utility Acquisition and Regulated Rate Filing – Conducted a fair market value appraisal of an investor-owned
utility, including 13 water systems and 27 wastewater systems, in support of an acquisition of some of these
systems by Greater Ouachita Water Company (GOWC). Subsequently conducted a comprehensive cost of service
analysis for the existing water and wastewater utilities of GOWC and developed rates to recover all costs, including
the acquisition and necessary capital improvements. Filed required schedules with the Louisiana Public Service
Commission in support of the acquisition and rate request. (LPSC Docket No. U-32803)
Other Utility Appraisals or Valuations – Conducted one or more appraisal or valuation study of the following
entities:
▪ Aqua Texas, Inc. (a portion of the system)
▪ Aqua Indiana, Inc. (a portion of the system)
▪ Bi-County Water Supply Corporation
▪ Brownsville Navigation District
▪ Clear Water Estates Water System
▪ Commons Water Supply, Inc.
▪ El Jardin Water Supply Corporation
▪ City of El Paso’s Clint and McCombs Municipal
Landfills
▪ EnLink (a portion of a gas pipeline in Alexandria,
Louisiana)
▪ Esperanza Water Service Company
▪ Greater Ouachita Water Company
▪ Guadalupe-Blanco River Authority
▪ Jarrell-Schwertner Water Supply Corporation
▪ Johnson County Special Utility District
▪ Liberty City Water Supply Corporation
▪ Pennichuck Corporation’s water utility in the City
of Nashua
▪ Rice Water Supply & Sewer Supply Corporation
▪ City of Superior’s Moccasin Mike Landfill
▪ Xcel Energy’s electric distribution system in the
City of Boulder, Colorado
▪ Pacific Gas and Electric’s electric transmission and
distribution system in San Francisco, California
▪ An investor-owned utility’s electric distribution
system in a confidential location
Regulatory and Litigation Support
In addition to the regulatory work associated with some of the projects previously mentioned, Mr. Rabon has also
provided litigation support to his clients. This includes a project calculating damages owed to three electric
cooperatives and one municipally owned utility as part of a wholesale rate dispute with the Lower Colorado River
Authority in Travis and Kerr County, Texas District Courts. This included recreating billing determinants and the
development of a market access rate. (Cause No. D-1-GN-12-002156 and Cause No. 12-1001-B) In another project
Mr. Rabon calculated damages owed to a municipality in a contract dispute with its ERCOT Qualified Scheduling
Entity. Mr. Rabon has also been designated as an expert witness in a utility condemnation case in Louisiana.
Customer Advocacy and Engagement
Served as the residential rate advocate for Austin Water’s water, reclaimed water, and wastewater cost of service
and rate design study, representing the interests of the residential customer class in the process, much like the
Texas Office of Public Utility Counsel often does for regulated rate cases. This involved participating in a
stakeholder engagement process, and presenting at a series of independent meetings with residential customer
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Grant Rabon
Executive Consultant
Thoughtful Decision Making for Uncertain Times 4
groups around the City to explain the process and solicit feedback on important policy issues from residents. Also,
reviewed and critiqued Austin Water’s prior comprehensive rate review, completed in 2009, and the validity of the
methodologies employed therein. Finally, given that any rates proposed by Austin Water could be reviewed by the
Public Utility Commission of Texas, provided invaluable input on acceptable practices based on extensive prior
work in this venue.
PRESENTATIONS AND PUBLICATIONS
Mr. Rabon has given various industry presentations focused on utility finances and rates.
Texas Public Power Association Conferences
▪ Adapting to Distributed Generation (2017)
▪ Is Change Coming?: Transmission Rate Filings at the Public Utility Commission (2018)
▪ Effectively Managing Significant Rate Changes (2019)
Texas Rural Water Association Conferences
▪ Keeping Your System Financially Fit; Learn How to Set Good Water Rates (2012)
▪ CCN Valuations: Financial Considerations Related to Decertification and Expedited Release (2014)
▪ Water Rates 101 (2015)
▪ Financial Planning and Tools (2016)
▪ Rates that Support Current and Future Needs (2018)
▪ Financial Management and Fiduciary Responsibilities (2019)
▪ How to Structure Rates to Ensure a Successful Future for Your System (2019)
USDA Rural Development
▪ Nuts and Bolts of Setting Sustainable Rates (2018)
American Water Works Association and Water Environmental Federation’s Utility Management Conference
▪ Regionalization Efforts: A Louisiana Case Study (2013)
▪ Austin Water Affordability Assessment (2020)
National Rural Water Association Conferences
▪ Rate Planning for a Sustainable System (2018)
▪ Small Water System Financing 101 (2019)
TESTIMONY
Public Utility Commission of Texas
▪ Electric Rate Filing of Austin Energy – PUC Docket No. 40627
▪ Interim Electric Transmission Rate Filing of Texas Municipal Power Agency – PUC Docket No. 51439
Louisiana Public Service Commission
▪ Water and Wastewater Rate Filing of Greater Ouachita Water Company – LPSC Docket No. U-34865
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 1
APPENDIX B – LETTERS OF RECOMMENDATION
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December 16, 2020
via email
Subject: Letter of Recommendation for NewGen Strategies and Solutions
To Whom It May Concern:
GEUS has a long-standing professional relationship with NewGen Strategies and Solutions. For more than
20 years, Joe Mancinelli, Jill Schuepbach, and the NewGen staff have provided GEUS with professional
services pertaining to financial planning, retail electric cost of service, rate design, special contract rate
design, annual transmission Earnings Reports, and periodic transmission cost of service (TCOS) full
comprehensive filings. Additionally, NewGen supported GEUS when GEUS was called in by the Public
Utilities Commission of Texas (PUCT) for over earning with the GEUS wholesale transmission rate.
NewGen is currently supporting GEUS with a full comprehensive TCOS filing at the PUCT. NewGen
prepares the schedules, testimony, and tariff as required by the PUCT. NewGen works with GEUS’ legal
team to file the necessary documents.
The NewGen and GEUS teams also collaborate on an annual basis to file the Earnings Report as required
by the PUCT. These efforts involve reviewing historical data and adjusting as needed.
Throughout these various projects, NewGen team members were professional, responsive, and easy to
work with, and delivered work products that met or exceeded our expectations within the agreed-upon
budget and schedule. Please feel free to contact me if there are any questions regarding this
recommendation.
Sincerely,
Alicia Hooks
General Manager O: 903.457.2887 M: 972.977.4758
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 1
APPENDIX C – SAMPLE REPORTS
To provide Denton Municipal Electric with a comprehensive view of NewGen Strategies and Solutions’
approach to PUCT Transmission Cost of Service Rate Filing Services and our reports, we have included
both a full comprehensive rate filing package report from Greenville Electric Utility System (GEUS) –
Docket No. 51556 and an interim rate filing package report from Bryan Texas Utilities (BTU) – Docket No.
51623.
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PUC DOCKET NO. ___________________
APPLICATION OF GEUS TO CHANGE
RATES FOR WHOLESALE TRANSMISSION SERVICE
§
§ § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS
OF
JILL A. SCHUEPBACH
ON BEHALF OF
GREENVILLE ELECTRIC UTILITY SYSTEM (“GEUS”)
NOVEMBER 24, 2020
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PUC Docket No. _______________ 1 Direct Testimony & Attachments of Jill A. Schuepbach
PUC DOCKET NO. __________________
APPLICATION OF GEUS TO CHANGE
RATES FOR WHOLESALE TRANSMISSION SERVICE
§
§ § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS OF JILL A. SCHUEPBACH
TABLE OF CONTENTS Page
I. INTRODUCTION AND QUALIFICATIONS .............................................................2
II. RESULTS: SCHEDULE A ...........................................................................................5
III. RATE BASE: SCHEDULES B THROUGH B-12 .......................................................7
IV. RETURN ON RATE BASE: SCHEDULE C-2 ..........................................................11
V. OPERATION AND MAINTENANCE EXPENSE: D SCHEDULES .......................14
VI. DEPRECIATION AND AMORTIZATION EXPENSE: SCHEDULE E-1 ...............17
VII. TAXES OTHER THAN INCOME: SCHEDULE E-2 ................................................18
VIII. OTHER EXPENSES AND REVENUES: SCHEDULES E-4, E-5, AND E-6 ...........20
IX. SUMMARY AND RECOMMENDATIONS..............................................................22
ATTACHMENTS
Attachment JAS-1 Resume and Record of Testimony
Attachment JAS-2 Schedules and Workpapers (REDACTED)
Attachment JAS-3 Tariff for Wholesale Transmission Service
Attachment JAS-3A Tariff for Wholesale Transmission Service (redlined)
Attachment JAS-4 Workpapers to the Direct Testimony of Jill A. Schuepbach
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PUC Docket No. _______________ 2 Direct Testimony & Attachments of Jill A. Schuepbach
PUC DOCKET NO. __________________
APPLICATION OF GEUS TO CHANGE RATES FOR WHOLESALE TRANSMISSION SERVICE
§ § § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS OF JILL A. SCHUEPBACH
I. INTRODUCTION AND QUALIFICATIONS 1
Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND CURRENT 2 EMPLOYMENT POSITION. 3
A. My name is Jill A. Schuepbach. I am an Executive Consultant in the Energy Practice of 4
NewGen Strategies and Solutions, LLC (“NewGen”). My business address is 225 Union 5
Blvd., Suite 305, Lakewood, Colorado 80228. NewGen is a consulting firm that 6
specializes in utility rates, engineering economics, financial accounting, asset valuation, 7
appraisals, and business strategy for electric, natural gas, water, and wastewater utilities. 8
Q. PLEASE OUTLINE YOUR FORMAL EDUCATION. 9
A. I have a Master of Business Administration degree from the University of Colorado, and a 10
Bachelor of Science in Mechanical Engineering from the University of Missouri. In 11
addition to my undergraduate and graduate degrees, I am a registered Professional Engineer 12
in the state of Colorado. 13
Q. PLEASE DESCRIBE YOUR PROFESSIONAL EXPERIENCE. 14
A. I am an Executive Consultant in NewGen’s Energy Practice. I have been employed by 15
NewGen since September 2012. Prior to joining NewGen, I was employed by R. W. Beck, 16
Inc., and its successor (SAIC Energy, Environment & Infrastructure, Inc.) since 2001. 17
Prior to joining R. W. Beck, I was employed by Black & Veatch from 1998 through 2001. 18
I have more than 20 years of experience in economic analyses for the energy, water, and 19
natural gas industries. My work includes various assignments for private industry, local 20
governments, and utilities, including financial and economic analyses, cost of service and 21
rate studies, engineer of record, and pole attachment fees. I have been extensively involved 22
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PUC Docket No. _______________ 3 Direct Testimony & Attachments of Jill A. Schuepbach
in the development of unbundled cost of service and pricing models during my career. 1
Attachment JAS-1 to this testimony provides a summary of my qualifications. 2
Q. HAVE YOU TESTIFIED BEFORE ANY REGULATORY COMMISSIONS? 3
A. Yes. I submitted testimony to the Florida Public Service Commission as shown in my 4
resume and record of testimony included as Attachment JAS-1. 5
Q. WAS YOUR TESTIMONY PREPARED BY YOU OR UNDER YOUR DIRECT 6 SUPERVISION? 7
A. Yes. 8
Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 9
A. I am testifying on behalf of Greenville Electric Utility System (“GEUS”), which is a 10
municipally-owned Electric transmission and distribution utility serving the citizens of the 11
City of Greenville, Texas (the “City”) and customers outside the city limits of Greenville. 12
Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 13
A. The purpose of my testimony is to support GEUS’s application to change its wholesale 14
transmission service rates in accordance with the Public Utility Commission of Texas’ 15
(“Commission” or “PUC”) Transmission Cost of Service (“TCOS”) Rate Filing Package 16
(“RFP”) for Non-Investor Owned (“Non-IOU”) Transmission Service Providers (“TSPs”) 17
in Electric Reliability Council of Texas (“ERCOT”). 18
Based on the test-year ending September 30, 2019 (“TY2019”), GEUS’s TCOS revenue 19
requirement is $3,306,733 or $46.590 per megawatt (“MW”) as shown in Exhibit JAS-2: 20
Schedule A. This revenue requirement and its associated rate do not include rate case 21
expenses. I propose the rate case expenses be included as a surcharge to the tariff and 22
collected over a 12-month period. 23
Q. WHAT SCHEDULES AND EXHIBITS ARE YOU SPONSORING? 24
A. I am sponsoring the following TCOS Schedules and the supporting workpapers: 25
• Schedule A: Transmission Cost of Service 26
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• Schedule B and B-1 through B-12: Rate Base 1
• Schedule C-2: Debt Service Coverage (“DSC”) Method 2
• Schedule D-1 through D-5: Operating and Maintenance Expenses 3
• Schedule E-1 through E-6: Other Expenses and Revenues 4
• Schedules F-1 through F-7, F-9, and F-10: Functionalization Factors 5
Q. HAVE YOU PREPARED A TARIFF FOR THE TRANSMISSION ACCESS FEE 6
ASSOCIATED WITH THE GEUS TCOS? 7
A. Yes. The proposed Tariff is included as Attachment JAS-3. I am also providing a version 8
of the Tariff that shows the changes GEUS proposes relative to its current tariff. 9
Q. WHY IS GEUS FILING THIS TCOS RATE APPLICATION AT THIS TIME? 10
A. Pursuant to 16 Texas Administrative Code § 25.247,1 all Non-IOU TSPs are required to 11
submit a complete application for a comprehensive transmission-cost-of-service review or 12
an interim update by a specific date depending on the date of the order in the Non-IOU 13
TSP’s previous filing. GEUS’s last filing to change its wholesale transmission rate took 14
place in 2014 with an Order approving the rate on September 11, 2014.2 Based on this 15
date, GEUS is required to file by November 28, 2020. Rule 25.247 also requires Non-IOU 16
TSPs to file an application on an ongoing basis. 17
Q. ARE OTHER GEUS WITNESSES SUBMITTING TESTIMONY IN SUPPORT OF 18 GEUS’S TCOS? 19
A. Yes. Ms. Alicia Hooks and Mr. John Clifford Copeland of GEUS are submitting 20
testimony. Ms. Hooks, General Manager, discusses changes in GEUS’s operations since 21
GEUS’s last full TCOS filing in 2014, GEUS’s debt service, and GEUS’s plans for future 22
debt-funded transmission projects. Mr. Copeland, GEUS’s Business Services Director, 23
1 I will refer to the Commission’s rules found at 16 Tex. Admin. Code Chapter 25, as the Commission’s “Substantive Rules” or simply as “Rule 25.___.”
2 Docket No. 42581, Application of GEUS to Change Rates for Wholesale Transmission Service, Final Order (Sept. 11, 2014) ("Docket No. 42581").
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discusses GEUS’s debt service, adjustments to amortization, and adjustments to GEUS’s 1
expenses related to its transmission and distribution operations, and sponsors certain 2
workpapers supporting Schedule C-2, Schedule D-1, and Schedule E-1. 3
Q. WHAT IS THE BASIS YEAR FOR THE APPLICATION? 4
A. The schedules and workpapers are based on a test year ending September 30, 2019, which 5
corresponds to the end of GEUS’s 2019 fiscal year. GEUS’s TCOS is based on known and 6
measurable changes to GEUS’s test-year data. I explain these adjustments throughout my 7
testimony. 8
II. RESULTS: SCHEDULE A 9
Q. PLEASE DESCRIBE THE DEVELOPMENT OF SCHEDULE A, GEUS’ TCOS 10 REVENUE REQUIREMENT. 11
A. Schedule A shows a summary of the total GEUS cost of service functionalized into the 12
three utility functions of Generation, Transmission, and Distribution and shows GEUS’s 13
TCOS for its Transmission function for the following elements of its revenue requirement: 14
• Operation and maintenance (“O&M”) expense as shown in Schedule D 15
• Depreciation expense as shown in Schedule E-1 16
• Taxes other than income tax as shown in Schedule E-2 17
• Return on Invested Capital (“Rate Base”) as shown in Schedule B 18
Q. PLEASE SUMMARIZE THE RESULTS SHOWN IN SCHEDULE A. 19
A. GEUS’s TCOS revenue requirement includes a return calculated using the DSC Method, a 20
PUC approved method for Non-IOU transmission providers like GEUS. As shown in 21
Schedule A, the transmission revenue requirement for GEUS is $3,306,733. Based on the 22
2019 ERCOT average four coincident peak (“4CP”) load of 70,981 MW,3 the resulting 23
3 PUC Docket No. 50333, Commission Staff’s Petition to Set 2020 Wholesale Transmission Service Charges for the Electric Reliability Council of Texas, Inc., Final Order (May 1, 2020) (“Docket No. 50333”).
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GEUS Wholesale Transmission Rate is $46.590 per MW per year, compared to the current 1
rate of $36.090 per MW per year. 2
In Table 1 below, I show a comparison of GEUS’s TY2019 TCOS to GEUS’s TCOS the 3
Commission approved in Docket 42581. 4
Table 1 GEUS Transmission Cost of Service 5
Item
Docket No. 42581
Approved TY2013
Current
Application
TY2019 Difference Difference
Rate Base (Invested Capital) $6,488,531 $6,677,590 $189,059 2.9%
Return on Rate Base 6.28% 13.12% 6.84% 108.9%
Return $407,512 $876,036 $468,523 115.0%
O&M Expense $1,417,901 $1,812,764 $394,863 27.8%
Depreciation Expense $303,461 $244,020 ($59,440) (19.6%)
Taxes Other Than Income $227,500 $373,913 $146,413 64.4%
Return $407,512 $876,036 $468,523 115.0%
Less Other Revenues ($1,288) $0 $1,288 n/a
Revenue Requirement $2,355,086 $3,306,733 $951,647 40.4%
Access Fee ($/MW) $36.090 $46.590 $10.500 29.1%
Q. WHAT SOURCE DOCUMENTS WERE USED TO PREPARE THE SCHEDULES 6 AND WORKPAPERS IN JAS-2? 7
A. The primary source for the schedules and workpapers is GEUS’s Comprehensive Annual 8
Financial Report (“CAFR”) for the year ended September 30, 2019, which presents 9
GEUS’s operations for the provision of both electric service and GEUS’s cable/internet 10
services. GEUS’s 2019 CAFR summarizes GEUS’s Electric and Cable/Internet funds. 11
GEUS separately records operating expenses, plant, depreciation, assets, and liabilities for 12
each fund. 13
GEUS provided additional detailed reports and data as needed including asset reports. 14
These documents are attached as workpapers to the schedules where appropriate. Mr. 15
Copeland provided debt service and amortization schedules to support the RFP. 16
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Q. DOES GEUS FOLLOW THE UNIFORM SYSTEM OF ACCOUNTS 1 RECOGNIZED BY THE FEDERAL ENERGY REGULATORY COMMISSION 2
(“FERC”) PRESCRIBED FOR PUBLIC UTILITIES AND LICENSEES? 3
A. Yes; for purposes of GEUS’s TCOS, GEUS follows the FERC’s uniform system of 4
accounts. GEUS’s account numbers include a FERC code allowing the plant-in-service 5
and expense data to be summarized into the FERC uniform system of accounts. 6
III. RATE BASE: SCHEDULES B THROUGH B-12 7
Q. WHAT SOURCE DOCUMENTS FORM THE BASIS FOR THE “B” SCHEDULES 8 AND WORKPAPERS? 9
A. GEUS’s 2019 CAFR and supporting detailed documents served as sources in preparing the 10
data shown in the series of the B Schedules and related workpapers . 11
Q. PLEASE DESCRIBE SCHEDULE B, TRANSMISSION RATE BASE. 12
A. The Rate Base calculation consists of the sum of GEUS 2019 Original Cost of Plant 13
(“Gross Plant”) minus Accumulated Depreciation plus Construction Work in Progress 14
(“CWIP”) plus Materials and Supplies plus Cash Working Capital plus Prepayments plus 15
Other Rate Base items. GEUS’s 2019 CAFR served as the basis for the account balances 16
for Gross Plant, Accumulated Depreciation and CWIP, Materials & Supplies, and 17
Prepayments. 18
Q. WERE ANY ADJUSTMENTS MADE TO SCHEDULE B-1? 19
A. Yes. At year end, GEUS had $1,997,332 of CWIP. GEUS placed $1,897,037 of the 20
$1,997,332 of CWIP into service and this amount is now used and useful. The remaining 21
CWIP balance not in service is $100,295, as shown in Schedule B-4. Of the $1,897,037 of 22
plant placed into service, transmission represents $376,115 of that amount, distribution is 23
$1,517,621, and general plant is $3,300. 24
Schedule B-1 includes an adjustment to transmission Account 353 of $376,115. The 25
transmission plant placed into service includes the LTV substation transformer upgrade 26
and the Dent Road 69kV tie as shown in WP/B-4/1. The LTV substation transformer was 27
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in service and carrying load on June 16, 2020. The Dent Road tie was energized on 1
March 7, 2020. 2
Schedule B-1 includes an adjustment to distribution Account 362 of $1,517,621. The 3
general plant adjustment was made on Schedule B-2. Because $1,897,037 of CWIP is now 4
plant in service, GEUS increased its plant-in-service balance shown in Schedules B-1 and 5
B-2 to show the addition of $1,897,037 to its rate base. 6
Q. ARE THE ADJUSTMENTS TO GROSS PLANT IN SCHEDULE B-1 7 APPROPRIATE? 8
A. Yes. The capital projects that were CWIP as of September 30, 2019 are now in service and 9
are used and useful. 10
Q. PLEASE DESCRIBE THE ALLOCATION OF ORIGINAL COST OF PLANT IN 11 SCHEDULE B-1. 12
A. The Generation, Transmission, and Distribution Plant Accounts 310 through 373 were 13
directly assigned to the appropriate utility function. 14
Q. WERE ANY ADJUSTMENTS MADE TO SCHEDULE B-2? 15
A. Yes; consistent with the adjustments to transmission and distribution Gross Plant on 16
Schedule B-1, the general Gross Plant was also adjusted. The CWIP shown in WP/B-4/1 17
relates to the Phase 1 of the Operations Center renovation, which was completed February 18
of 2020. CWIP related to general Gross Plant totals $3,300 and is shown as an adjustment 19
to Account 390 on Schedule B-2. 20
Q. PLEASE DESCRIBE THE ALLOCATION OF GENERAL PLANT IN SCHEDULE 21 B-2. 22
A. GEUS allocated the accounts as follow: 23
• Accounts 389: Land and Land Rights, 390: Structures and Improvements, and 24
391: Office Furniture and Equipment were allocated to the transmission function using 25
the Payroll excluding Administrative and General Salaries and excluding the Contract 26
Labor (“PAYXAG”) allocator. GEUS does not maintain records to support an 27
allocation based on building square footage utilized by each of the major utility 28
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functions. The use of the PAYXAG allocator is reasonable and consistent with 1
GEUS’s previous TCOS filing, Docket 42581. 2
• Account 392: Transportation Equipment was allocated based on GEUS’s detailed fixed 3
asset records (Schedule F-9) as GEUS does not maintain records to support the separate 4
miles driven on transportation equipment attributed to each major utility function. 5
Directly allocating transportation equipment is reasonable and is consistent with 6
GEUS’s previous TCOS filing, Docket 42581. 7
• Account 393: Stores Equipment was allocated based on a detailed analysis of GEUS 8
inventory (Schedule F-7). This allocation method is reasonable and is consistent with 9
GEUS’s previous TCOS filing, Docket 42581. 10
• Accounts 394 - 396 were allocated to the transmission function using the Net Plant 11
excluding the General Plant (“PLTXGNL-N”) allocator per the instructions in the Non-12
IOU TCOS RFP. 13
• Account 398 was allocated directly to distribution as the expenses in the account are 14
distribution related. 15
Q. PLEASE DESCRIBE THE ALLOCATION OF COMMUNICATION EQUIPMENT 16 IN SCHEDULE B-3. 17
A. Account 397: Communication Equipment was allocated to the transmission function using 18
the PLTXGNL-N allocator. The use of the PLTXGNL-N allocator is reasonable and is 19
consistent with GEUS’s previous TCOS filing, Docket 42581. 20
Q. DOES GEUS HAVE ANY CONSTRUCTION WORK IN PROGRESS SHOWN ON 21 SCHEDULE B-4? 22
A. As I noted above, as of September 30, 2019, GEUS had $1,997,332 of CWIP. All projects 23
that were in process as of September 30, 2019 but are in service and used and useful were 24
moved to the appropriate Gross Plant accounts leaving a CWIP balance of $100,295 as 25
shown on Schedule B-4. The CWIP balance of $100,295 was adjusted in Schedule B-4 26
and is not used in the calculation of Rate Base on Schedule B.27
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Q. PLEASE DESCRIBE THE ALLOCATION OF ACCUMULATED 1 DEPRECIATION SHOWN IN SCHEDULE B-5. 2
A. GEUS allocated Accumulated Depreciation to the transmission function in a manner 3
consistent with the associated Gross Plant accounts on Schedules B-1, B-2, and B-3. 4
Q. DOES GEUS HAVE PLANT HELD FOR FUTURE USE? 5
A. No; as shown in Schedule B-6, GEUS does not have plant held for future use. 6
Q. DOES GEUS HAVE ACCUMULATED PROVISION BALANCE? 7
A. No; as shown in Schedule B-7, GEUS does not have an accumulated provision balance. 8
Q. PLEASE DESCRIBE THE ALLOCATION OF MATERIALS & SUPPLIES 9 SHOWN IN SCHEDULE B-8. 10
A. GEUS directly assigned Material and Supplies to the transmission function based on GEUS 11
personnel’s thorough review of GEUS’s inventory. In certain cases, GEUS allocated 12
inventories that benefited both the transmission and distribution functions to each function 13
based on transmission and distribution Gross Plant (“TDPLTXGNL-G”). Details of this 14
allocation are shown in Workpaper WP/F-7/1. The direct allocation of the inventory 15
presented in Schedule B-8 is appropriate and is consistent with the treatment of inventory 16
in GEUS’s previous TCOS filing, Docket 42581. 17
Q. PLEASE EXPLAIN HOW THE CASH WORKING CAPITAL WAS 18 DETERMINED. 19
A. In accordance with instructions in the Non-IOU TCOS RFP, the “one-eighth” method was 20
used to calculate the allowance for Cash Working Capital. Schedule B-9 Cash Working 21
Capital shows GEUS’s Cash Working Capital, which is premised on the sum of annual 22
O&M Expenses plus Taxes Other Than Income Taxes, multiplied by one-eighth, to arrive 23
at the amount of Cash Working Capital. 24
Q. PLEASE DESCRIBE THE ALLOCATION OF PREPAYMENTS SHOWN IN 25 SCHEDULE B-10. 26
A. Prepayments were based on GEUS’s 2019 CAFR and include expenses related to the 27
generation function. The Prepayments allocated to the transmission function are $0. 28
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Q. PLEASE DESCRIBE THE ALLOCATION OF OTHER RATE BASE ITEMS 1 SHOWN IN SCHEDULE B-11. 2
A. Other Rate Base Items include Customer Deposits and were allocated to the distribution 3
function as shown in Schedule B-11. The Other Rate Base allocated to the transmission 4
function are $0. 5
Q. DOES GEUS HAVE ANY REGULATORY ASSETS? 6
A. As shown in Schedule B-12, GEUS does not have regulatory assets. 7
Q. WHAT WAS THE RESULT OF THE TRANSMISSION RATE BASE 8 CALCULATION? 9
A. The resulting GEUS transmission Rate Base is $6,677,590. 10
IV. RETURN ON RATE BASE: SCHEDULE C-2 11
Q. WHICH RETURN METHOD DID GEUS USE TO CALCULATE RETURN ON 12 RATE BASE? 13
A. The Non-IOU TCOS RFP instructions allow for four methods in determining the Return 14
on Rate Base: 1) Rate-of-Return Method, 2) Debt-Service-Coverage (“DSC”) Method, 3) 15
Cash-Flow Method, and 4) Times-Interest-Earned Method. GEUS elected to use the DSC 16
Method to determine its return. 17
Q. WHY DID GEUS ELECT TO USE THE DSC METHOD TO DETERMINE ITS 18
RETURN? 19
A. GEUS’s current debt service obligations combined with anticipated near-term future debt-20
service obligations are significant for GEUS and require minimum cash requirements that 21
are more fairly reflected under the DSC Method. Over the next five years GEUS plans to 22
fund approximately $11 million of transmission investment with debt. 23
Q. PLEASE DESCRIBE THE DSC METHOD. 24
A. The DSC Method allows a utility to earn a return based on its debt service and the debt-25
service-coverage levels stated in the TSP’s most recently issued bond and debt covenants, 26
plus an additional coverage of 0.25. 27
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Debt-service coverage is a measure of annual revenues in excess of O&M costs that are 1
available to meet total system principal and interest payments and is expressed as a ratio. 2
For example, a debt service coverage ratio of 1.50 reflects that a utility, after paying its 3
O&M costs, has sufficient annual revenue to meet its principal and interest payments, plus 4
additional funds of 50% above the principal and interest payments to satisfy other cash 5
requirements of the system, such as capital investment needs and funding cash reserves. 6
Q. PLEASE DESCRIBE THE STEPS IN DETERMINING RETURN CALCULATED 7 UNDER THE DSC METHOD. 8
A. First, the Debt Service is multiplied by the required Debt Service Coverage plus 0.25 9
resulting in the Debt Service with Coverage. Second, the utility’s depreciation, 10
amortization, and interest income are subtracted from the Debt Service with Coverage 11
resulting in the Return. Third, the Return is divided by the Rate-Base balance to calculate 12
a percentage Return on Rate Base (%). Fourth, the Return on Rate Base (%) is multiplied 13
by the Transmission Rate Base from Schedule B resulting in the Transmission Return ($). 14
Fifth, the Transmission Return is included on Schedule A as part of the Transmission 15
Revenue Requirement. 16
Q. WHAT SOURCE DOCUMENTS WERE USED TO CALCULATE THE RETURN 17 ON RATE BASE USING THE DSC METHOD? 18
A. The source of data used to calculate GEUS’s return is GEUS’s debt-service-amortization 19
schedules as provided by Mr. Copeland 20
Q. WERE ANY ADJUSTMENTS MADE TO SCHEDULE C-2? 21
A. Yes. In 2019, GEUS refinanced all outstanding debt with revenue bonds pledged against 22
GEUS’s total system revenues. Also, in consideration of the timing of the 2019 refinancing 23
and to agree with GEUS’s long-term investment strategy that has been in place since 2018, 24
I made an additional adjustment to the annual debt service as described below and by Mr. 25
Copeland. Each of these adjustments is known and measurable. 26
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Q. PLEASE DESCRIBE THE ADDITIONAL DEBT SERVICE ADJUSTMENTS. 1
A. I made two adjustments to the debt service. First, I adjusted annual debt service payments 2
to agree with the FY 2020-2021 Budget4 as adopted by the Board. GEUS will make debt 3
service payments as shown in WP/C-2/1 consistent with the utility’s long-term financial 4
plan and as supported in Mr. Copeland’s testimony. Second, the debt service payment in 5
2019 represents a partial year as the new bonds were issued during the year. Therefore, I 6
annualized the 2019 payment to represent a full-year’s payment. The debt service on 7
Schedule C-2 represents the principal and interest payments that GEUS will make for fiscal 8
year 2020. 9
Q. DOES GEUS PLAN ON ISSUING ANY ADDITIONAL DEBT? 10
A. Yes, as I noted earlier, over the next five years GEUS plans to invest $11 million in 11
transmission assets and intends to fund that capital spending with debt totaling $11 million. 12
Q. WERE THE PLANNED DEBT ISSUES INCLUDED IN THE DSC 13 CALCULATION? 14
A. No. We did not include the proposed debt service in the DSC Method calculation. 15
However, GEUS will include the proposed debt in any future requests. 16
Q. WHAT IS GEUS’S REQUIRED LEVEL OF DEBT SERVICE COVERAGE? 17
A. The Board established a DSC ratio target of 2.25 times debt service for planning purposes. 18
However, GEUS must maintain a minimum DSC ratio of at least 1.25 times the average 19
annual debt service requirement as stipulated in its bond indentures. A copy of the City of 20
Greenville, Texas, Electric System Revenue Refunding Bonds Series 2019A Official 21
Statement is included as WP/C-2/2. 22
Q. WHAT DEBT SERVICE COVERAGE RATIO WAS USED IN THE DSC 23
ANALYSIS? 24
A. Although the Board directs GEUS management to operate under a 2.25 DSC ratio, for 25
GEUS’s TCOS application, I used a 1.25 minimum DSC ratio plus 0.25 as allowed by the 26
4 http://geus.org/DocumentCenter/View/694/FY2020-21-Proposed-Budget.
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PUC (or 1.50) to calculate GEUS’s return. Based on the level of debt service and the fiscal 1
needs of the utility, a 1.50 DSC ratio is sufficient. As shown in Schedule C-2, the resulting 2
Return on Rate Base using a 1.5 DSC ratio is 13.12%. 3
Q. WHAT WAS THE RESULTING RETURN? 4
A. Applying the 13.12% rate of return to Total Rate Base for the Transmission Function yields 5
a return of $876,036 (13.12% x $6,677,590) as shown in Schedule B. 6
Q. IS THE CALCULATED RETURN USING THE DSC METHOD COMPARABLE 7 TO AN IOU RETURN? 8
A. No; the calculated Return of 13.12% is a mathematical result of the DSC method. It is not 9
comparable to an IOU rate of return. Municipal utilities like GEUS do not issue stock to 10
third party investors and are not subject to return on equity metrics commonly used in 11
determining an IOU’s weighted average cost of capital (“WACC”) calculations. GEUS’s 12
only sources of capital originate from revenue from current earnings and debt pledged to 13
system revenues. Therefore, the return calculation is simply a mathematical result of 14
comparing cash needs with rate base. Comparing such a result with an approved IOU 15
return is not appropriate and is misleading. 16
V. OPERATION AND MAINTENANCE EXPENSE: D SCHEDULES 17
Q. WHAT SOURCE DOCUMENTS WERE USED TO PREPARE THE D 18 SCHEDULES AND WORKPAPERS? 19
A. I relied on GEUS’s 2019 CAFR and supporting detailed documents to prepare the D 20
Schedules and workpapers. 21
Q. PLEASE DESCRIBE SCHEDULE D-1, O&M EXPENSE. 22
A. Schedule D-1 contains the O&M expense for Accounts 500 through 917. The O&M 23
expense shown on Schedule D-1 does not include Payroll Taxes as those are contained in 24
Schedule E-2. Generation, Transmission, and Distribution O&M accounts 500 through 25
917 were directly assigned to the appropriate utility function per the instructions in the 26
Non-IOU TCOS RFP. 27
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Q. WERE ANY ADJUSTMENTS MADE IN SCHEDULE D-1? 1
A. Yes; adjustments were made to the following accounts: 2
• Account 560: Transmission Operations Supervision and Engineering 3
• Account 566: Miscellaneous Transmission Expense 4
• Account 580: Distribution Operations Supervision and Engineering 5
• Account 588: Miscellaneous Distribution Expense 6
Q. PLEASE DESCRIBE THE ADJUSTMENT TO FERC ACCOUNTS 560, 566, 580, 7
AND 588. 8
A. GEUS does not distinguish between transmission and distribution activity when booking 9
Operations Supervision, and Engineering expenses. GEUS books all supervision and 10
engineering expenses to Distribution Account 580. To reflect that a certain portion of these 11
expenses relate to the transmission function, Mr. Copeland adjusted these expenses as 12
described his testimony. 13
Similarly, GEUS does not distinguish between transmission and distribution Miscellaneous 14
Expenses. As a result, GEUS books all Miscellaneous Expenses to Account 588. Again, 15
as Mr. Copeland explains in his testimony, he adjusted the expenses for Account 588 to 16
reflect that a certain portion of Miscellaneous Expenses are related to the transmission 17
function. In total, these adjustments added expenses to Transmission operation Accounts 18
560 and 566 and equally reduced expenses in Distribution operation Accounts 580 and 19
588. These adjustments are shown on WP/D-1/1. 20
Q. IS THE EXPENSE ADJUSTMENT CONSISTENT WITH PREVIOUS GEUS TCOS 21
FILINGS? 22
A. Yes; the adjustment is consistent with the previous full filings Docket No. 371805 and 23
Docket No. 42581. In Docket No. 42581, the Commission approved allocation of 33% of 24
5 Docket No. 37180, Application of GEUS to Change Rates for Wholesale Transmission Service, Final Order (Nov. 2, 2009) (“Docket No. 37180”).
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the engineering expenses to GEUS’s Transmission Function. In this filing, GEUS 1
allocated 29% of the engineering expenses to GEUS’s Transmission Function. 2
Q. PLEASE DESCRIBE SCHEDULE D-2, ADMINISTRATIVE & GENERAL 3 EXPENSE. 4
A. Schedule D-2 contains the expenses for Accounts 920 through 935. The expenses shown 5
on Schedule D-2 do not include labor-related taxes as those are contained in Schedule E-6
2. Accounts 920 through 935 relate to Administration and General Expense and were 7
allocated as follows: 8
• Account 920: Administration and General Expense was allocated using the PAYXAG 9
allocator per the instructions in the Non-IOU TCOS RFP. 10
• Account 921: Office Supplies Expense was allocated using the PAYXAG allocator per 11
the instructions in the Non-IOU TCOS RFP. 12
• Account 924: Property Insurance Expense was allocated using the net plant-in-service 13
(“PLTSVC-N”) allocator per the instructions in the Non-IOU TCOS RFP. 14
• Account 925: Injuries and Damages Expense was allocated using the PAYXAG 15
allocator per the instructions in the Non-IOU TCOS RFP. 16
• Account 926: Pensions and Benefits Expense was allocated using the PAYXAG 17
allocator per the instructions in the Non-IOU TCOS RFP. 18
• Account 930: Miscellaneous General Expense was allocated using the PAYXAG 19
allocator per the instructions in the Non-IOU TCOS RFP. 20
• Account 930.1: General Advertising Expense was directly assigned to the Distribution 21
Function as these expenses are associated with GEUS retail customers. 22
• Account 930.2: Miscellaneous General Expense relates to Board activities and was 23
allocated to all GEUS utility functions using the PLTSVC-N allocator consistent with 24
GEUS’s previous TCOS filing, Docket 42581. 25
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• Account 935: Maintenance of General Plant Expense was allocated to all GEUS utility 1
functions based on net general plant (“GNLPLT-N”) per the instructions in the Non-2
IOU TCOS RFP. 3
Q. PLEASE DESCRIBE SCHEDULE D-3, PAYROLL EXPENSE. 4
A. Payroll Expense was allocated to the transmission function in a manner consistent with the 5
associated O&M expense accounts in Schedules D-1 and D-2. 6
Q. WERE ANY ADJUSTMENTS MADE TO SCHEDULE D-3? 7
A. Yes. Labor contained in FERC Accounts 560, 566, 580, and 588 was adjusted consistent 8
with Schedule D-1 to reflect that a certain portion of these expenses relate to the 9
transmission function. These adjustments are shown in WP/D-3/1 and are described by 10
Mr. Copeland. 11
Q. DOES GEUS HAVE ANY EXCLUSIONS? 12
A. No; as shown in Schedule D-5, GEUS does not have any exclusions. 13
Q. WHAT IS THE RESULT OF THE O&M EXPENSE CALCULATIONS? 14
A. GEUS’s transmission expense is $1,461,052 and its A&G expense related to Transmission 15
is $351,712, for a total O&M expense of $1,812,764, shown in Schedule A. 16
VI. DEPRECIATION AND AMORTIZATION EXPENSE: SCHEDULE E-1 17
Q. WHAT SOURCE DOCUMENTS WERE USED TO PREPARE THE E 18 SCHEDULES AND WORKPAPERS? 19
A. I relied on GEUS’s 2019 CAFR and supporting detailed documents to prepare the E 20
Schedules and workpapers. 21
Q. WERE THERE ANY ADJUSTMENTS TO THE DEPRECIATION 22 CALCULATION? 23
A. Yes; I adjusted the depreciation expense associated with the amount of CWIP that was 24
transferred into Gross Plant on Schedules B-1 and B-2 to reflect a full year of depreciation 25
based on GEUS’s depreciation rates as shown in WP/E-1/1. 26
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Q. WERE THERE ANY ADJUSTMENTS TO THE AMORTIZATION EXPENSE 1 CALCULATION? 2
A. Yes; I adjusted the amortization of the bond discount (premium). The amortization in the 3
test year represents a partial year of amortization related to the Series 2019A and 2019B 4
Bonds. Consistent with the treatment of debt service on Schedule C-2, I adjusted the 5
amortization amount to represent a full year, fiscal year 2020. These adjustments are 6
shown on WP/E-1/1 and described by Mr. Copeland. 7
Q. PLEASE DESCRIBE THE ALLOCATION OF DEPRECIATION TO THE 8 TRANSMISSION FUNCTION. 9
A. I allocated Depreciation Expense to the transmission function in a manner consistent with 10
the associated Gross Plant accounts on Schedules B-1, B-2, and B-3. 11
Q. PLEASE DESCRIBE THE ALLOCATION OF AMORTIZATION EXPENSE TO 12 THE TRANSMISSION FUNCTION. 13
A. The Amortization shown on Schedule E-1 is the amortization of the bond discount 14
(premium) associated with GEUS’s outstanding debt. GEUS issued the debt to fund 15
system capital improvements. I allocated the bond discount (premium) using the PLTSVC-16
N allocator as the debt is pledged against the GEUS system. 17
Q. WHAT WAS THE RESULT OF YOUR DEPRECIATION AND AMORTIZATION 18 EXPENSE CALCULATION? 19
A. The Depreciation and Amortization Expense related to the transmission function is 20
$244,020. 21
VII. TAXES OTHER THAN INCOME: SCHEDULE E-2 22
Q. WHAT SOURCE DOCUMENTS WERE USED TO PREPARE TAXES OTHER 23 THAN INCOME IN SCHEDULE E-2? 24
A. I relied on GEUS’s 2019 CAFR and supporting detailed documents to prepare Taxes Other 25
Than Income Tax. 26
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Q. WERE THERE ANY ADJUSTMENTS TO SCHEDULE E-2? 1
A. No adjustments were made to Schedule E-2. GEUS’s 2019 CAFR served as the basis for 2
the data contained in these schedules. 3
Q. PLEASE DESCRIBE THE TAXES OTHER THAN INCOME INCLUDED IN 4 SCHEDULE E-2? 5
A. Taxes Other Than Income include Payment in Lieu of Property Tax (“PILOT”), a General 6
Fund Transfer Fee, and a Board of Development Transfer Fee. City Charter requires GEUS 7
to pay the PILOT, General Fund Transfer Fee, and Board of Development Transfer Fee. 8
The General Fund Transfer Fee is 5% of revenues. The Board of Directors Transfer Fee is 9
1% of revenues. These transfers are not discretionary and are part of GEUS’s financial 10
obligations. 11
Additionally, GEUS is required to pay payroll taxes on behalf of its employees. 12
Q. PLEASE DESCRIBE THE ALLOCATION OF THE TAXES OTHER THAN 13 INCOME INCLUDED IN SCHEDULE E-2. 14
A. I allocated Taxes Other Than Income Tax to the transmission function based on the 15
underlying cost drivers. I allocated PILOT based on Net Plant reflecting that the tax is 16
based on utility plant in service. 17
The General Fund Transfer to the City is based on utility revenues and allocated to the 18
transmission function based on total utility revenue requirements (Schedule F-6). 19
I allocated Payroll Taxes consistent with the corresponding O&M accounts. 20
Q. WHAT IS THE RESULT OF THE TAXES OTHER THAN INCOME 21 ALLOCATIONS? 22
A. Allocation of the amount for PILOT results in $35,845 assigned to the transmission 23
function. Allocation of the General Fund Transfer to the City results in $271,327 assigned 24
to the transmission function. Allocation of Payroll Taxes results in $66,741 assigned to 25
the transmission function. The total expenses allocated to transmission on Schedule E-2 26
are $373,913. 27
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VIII. OTHER EXPENSES AND REVENUES: SCHEDULES E-4, E-5, AND E-6 1
Q. WHAT SOURCE DOCUMENTS WERE USED TO PREPARE SCHEDULES E-4, 2 E-5, AND E-6? 3
A. I relied on GEUS’s 2019 CAFR and supporting detailed documents to prepare Other 4
Expenses and Other Revenues. 5
Q. WERE THERE ANY ADJUSTMENTS TO SCHEDULES E-4, E-5, AND E-6? 6
A. No. 7
Q. DOES GEUS HAVE ANY “OTHER EXPENSES” IN SCHEDULE E-4? 8
A. No. 9
Q. DOES GEUS HAVE ANY “OTHER REVENUES” IN SCHEDULE E-5? 10
A. Yes. GEUS does have Other Revenues; these appear in Schedule E-5. The Other Revenues 11
are categorized as Off System Sales, TCOS Revenues, Other Billed Sales, 12
Reimbursements, Other Revenues, and Interest Income. 13
Q. PLEASE DESCRIBE HOW “OTHER REVENUES” IN SCHEDULE E-5 WERE 14
ALLOCATED. 15
A. GEUS allocated each account and/or group of accounts based on the underlying driver for 16
the revenues as described below: 17
• Off-System Sales Revenues were allocated to the Generation function as the revenues 18
are a result of market power sales. This allocation is consistent with GEUS’s previous 19
TCOS filing, Docket 42581. 20
• TCOS Revenues were allocated to the Distribution function per the instructions in the 21
Non-IOU TCOS RFP. 22
• Other Billed Sales/Charges were allocated to the Distribution function consistent with 23
GEUS’s previous TCOS filing, Docket 42581. 24
• Reimbursements were allocated to the Distribution function consistent with GEUS’s 25
previous TCOS filing, Docket 42581. 26
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• Pole Use Revenues were allocated to the Distribution function consistent with GEUS’s 1
previous TCOS filing, Docket 42581. 2
Q. HOW WAS INTEREST INCOME ALLOCATED ON SCHEDULE E-5? 3
A. GEUS allocated interest income based on the underlying driver for the funds earning 4
interest as described below: 5
• Fund 910 was allocated on total O&M consistent with GEUS’s previous TCOS filing, 6
Docket 42581. 7
• Fund 911 was allocated to the Generation function as this fund was created to support 8
generation. 9
• Fund 913 was allocated using the PLTSVC-N allocator consistent with GEUS’s 10
previous TCOS filing, Docket 42581. 11
Q. HOW WAS INTEREST INCOME APPLIED TO THE TCOS REVENUE 12 REQUIREMENT? 13
A. As GEUS uses the DSC method for the return on invested capital, interest income is a 14
deduction in the return calculation on Schedule C-2. As interest income is deducted in the 15
calculation of return on invested capital, it was excluded from the other revenues deducted 16
from the TCOS revenue requirement on Schedule A. 17
Q. DOES GEUS HAVE ANY REVENUES ASSOCIATED WITH TRANSMISSION 18 SERVICE OUTSIDE OF ERCOT? 19
A. No; as shown in Schedule E-6 GEUS does not have any revenues associated with 20
transmission service outside of ERCOT. 21
Q. DOES GEUS HAVE ANY REVENUES ASSOCIATED WITH WHEELING 22 UNDER EXISTING CONTRACTS? 23
A. No; as shown in Schedule E-6 GEUS does not have any revenues associated with wheeling 24
under existing contracts. 25
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Q. WHAT WAS THE RESULT OF THE OTHER EXPENSES AND REVENUES 1 CALCULATIONS AND ALLOCATIONS TO TRANSMISSION? 2
A. The total Other Expenses allocated to the Transmission function are $0. The Other 3
Revenues total allocated to the Transmission function, not including interest income, are 4
$0. The Interest Income allocated to the Transmission function is $20,705 and is accounted 5
for on Schedule C-2. 6
IX. SUMMARY AND RECOMMENDATIONS 7
Q. PLEASE SUMMARIZE GEUS’S NON-IOU TCOS RFP. 8
A. GEUS is submitting this Non-IOU TCOS RFP using the DSC Methodology. As I show in 9
Schedule A, GEUS’s TCOS revenue requirement is $3,306,733. GEUS developed the cost 10
of service consistent with the Non-IOU TCOS RFP, and it is fair and reasonable. The 11
resulting access charge is $46.590 per MW per year. 12
Q. WHAT DO YOU RECOMMEND? 13
A. I recommend the PUC approve GEUS’s Non-IOU TCOS RFP as filed. 14
Q. DOES THAT CONCLUDE YOUR TESTIMONY? 15
A. Yes. 16
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PUC DOCKET NO. ___________________
APPLICATION OF GEUS TO CHANGE
RATES FOR WHOLESALE TRANSMISSION SERVICE
§
§ § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS
OF JILL A. SCHUEPBACH
Attachment JAS-1
Resume and Record of Testimony
23 68
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Jill Schuepbach
Executive Consultant
jschuepbach@newgenstrategies.net
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Jill Schuepbach has been providing financial expertise to the utility industry for over 20 years. She has proven project
management and analytical skills in the areas of utility cost of service and rate design, financial planning, economic
and financial analysis, engineer of record, and pole attachment fees. In addition, Ms. Schuepbach has experience
with feasibility studies, litigation support, and preparing expert witness testimony. Her project experience includes
work for municipal, investor-owned, and member-owned utility clients.
EDUCATION
Master of Business Administration, University of Colorado
Bachelor of Science in Mechanical Engineering, University of Missouri
PROFESSIONAL REGISTRATIONS / CERTIFICATIONS
Registered Professional Engineer (PE), Colorado
KEY EXPERTISE
Cost of Service and Rate Design
Project Financing
Engineer of Record
Economic and Financial Analysis
Litigation Support
Pole Attachment Fees
RELEVANT EXPERIENCE
Financial Forecasts, Cost of Service and Rate Design
Ms. Schuepbach has assisted with numerous utility financial forecasts, cost of service, and rate design projects.
Financial Forecast tasks include developing models to balance capital spending and rate increases, support
compliance with debt covenants, and assist with general short-term and long-term decision making. Cost of Service
tasks include the development of the revenue requirement, functionalization and classification of costs, and
allocation of costs to customer classes. Rate Design tasks include a review of existing customer class criteria, design,
tariff development and transitioning of models for the client’s future use. Additional analysis include the evaluation
of miscellaneous charges and fees based on the utility’s costs and local and state policy. She has assisted with
training and workshops regarding cost of service and rate design theory, industry practice and rate strategies to
governing bodies and boards. She has also presented rate study results and provided financial recommendations to
governing bodies, boards, and city councils.
She has performed electric, natural gas, and photovoltaic cost of service. Her efforts have also included support in contract negotiations in developing a rate to serve a large industrial load and unbundled transmission costs.
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Jill Schuepbach
Executive Consultant
Thoughtful Decision Making for Uncertain Times 2
Ms. Schuepbach’s clients for cost of service and rate design services include:
Brownsville Public Utilities Board, Texas
Bryan Texas Utilities, Texas
Estes Park, Colorado
Farmington Electric Utilities System, New Mexico
Glendale Water and Power, California
GEUS, Texas
Lafayette Public Power Authority, Louisiana
Lafayette Utilities System, Louisiana
Loup Power District, Nebraska
Navajo Tribal Utility Authority, Arizona
She has also evaluated energy consumption profiles, billing accuracy, base operations, contract terms, rate options,
asset / facilities upgrades (e.g., energy efficiency/demand response), distributed generation options, and tenant
billing recovery for the US Army.
Transmission Revenue Requirement Compliance Filings
Ms. Schuepbach has assisted with multiple transmission rate filings at the Regional Transmission Organization (RTO)
level and at Federal Energy Regulatory Commission (FERC) regarding Annual Transmission Revenue Requirements
(ATRR), and methodologies for determining rates. Ms. Schuepbach’s clients include:
Bryan Texas Utilities, Texas
GEUS, Texas
City of Garland Power and Light, Texas
Independence Power & Light, Missouri
Engineer of Record and Consulting Engineer Reports
Ms. Schuepbach assists in the development of Consulting Engineer Reports and associated ordinance required
reviews for municipal utilities. These reviews typically require an annual assessment of the utilities’ financial and
physical operations for the duration of the bond period. The field review typically includes a determination of the
condition of the physical assets of the utility, which also includes a review of the utilities budgeting and planning
process. Ms. Schuepbach’s project experience includes:
Lafayette Utilities System, Louisiana Lafayette Public Power Authority, Louisiana
Economic and Financial Analysis
Ms. Schuepbach has provided economic analyses for municipal utilities involving generation projects. These
evaluations included reviewing the costs and operation of new generation units added to the existing generation
resources and the economic analysis of the proposed generation on retail rates.
Ms. Schuepbach assisted with the allocation of Hoover Power in Arizona, which included technical advice, reviewing
customer applications for completion and accuracy and scenario analysis of the potential hydro power allocations.
Her clients have included:
Arizona Power Authority, Arizona
Brownsville Public Utilities Board, Texas
City of Bryan, Texas
Lafayette Utilities System, Louisiana
Litigation Support
Ms. Schuepbach has assisted in litigation support and preparation of expert witness testimony in Texas, Louisiana,
Missouri, and Indiana. Her testimony support is related to revenue requirements, cost of service and rate design as
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Jill Schuepbach
Executive Consultant
3 Thoughtful Decision Making for Uncertain Times
well as the proper allocation of generation costs given a systems’ unique characteristics. Ms. Schuepbach’s litigation
support clients include:
Brownsville Public Utility Board, Texas: Docket
Nos. 38556 & 32905
Bryan Texas Utilities, Texas: Docket Nos. 44467 and 41920
GEUS: Texas’ Dockets Nos. 45281 and 37180
Independence Power & Light, Missouri; Docket
No. ER15-1499-001
Lafayette Utilities System, Louisiana; Docket
No. 00994490
Northern Indiana Public Service Company, Indiana; Cause Nos. 44688, 44733, 45159
Indiana Michigan Power Company, Indiana,
Cause No. 45235
Pole Attachment Fees
Ms. Schuepbach has developed pole attachment fees for several clients. She has employed various methodologies
including those recommended by the Federal Communications Commission (FCC) and the American Public Power
Association (APPA). She has recommended rates for cable and communications companies based on the type of
poles to which they are attached. Her work also includes a review of the contract or agreement between the utility
and the customer. Her projects include:
Farmington Electric Utilities System, New
Mexico
Keys Energy Services
Navajo Tribal Utility Authority, Arizona
Navopache Electric Cooperative
WORKSHOPS AND PRESENTATIONS
Ms. Schuepbach has given industry presentations focused on cost of service and ratemaking. Host organizations and
the topics Ms. Schuepbach presented include:
Electric Utility Consultants, Inc.
Introduction to Cost of Service Concepts and
Techniques for Electric Utilities
Introduction to Rate Design for Electric Utilities
California Public Utilities Commission
Cost of Service Concepts for Electric Utilities
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Record of Litigation Support and Testimony: Jill Schuepbach
Testimony
Utility Proceeding Subject Before Client Date
1.Orlando UtilitiesCommission Docket No. 010142 Demand Side Management Florida Public Service Commission Orlando Utilities Commission 2001
Litigation Support
Utility Proceeding Subject Before Client Date
1.Indiana Michigan PowerCompany Cause No. 45235 Petition of Indiana Michigan Power Company for authority to increase its rates and charges for electric utility service.
Indiana Utility Regulatory Commission City of Fort Wayne, City of Marion, and Marion Municipal Utilities 2019
2.Northern Indiana PublicService Company Cause No. 45159 Rate Case: Cost of Service, Rate Design and new Industrial Rate Structure Indiana Utility Regulatory Commission United States Steel 2019
3.Bryan Texas Utilities Docket No. 48123 Application of Bryan Texas Utilities for Interim Update of Wholesale Transmission Rates Pursuant to Substantive Rule 25.192(g)(1)
Public Utility Commission of Texas Bryan Texas Utilities 2018
4.Northern Indiana PublicService Company Cause No. 44733-TDSIC Transmission, Distribution, and Storage System Improvement Charge Indiana Utility Regulatory Commission United States Steel 2016
5.Northern Indiana PublicService Company Cause No. 44688 Rate Case: Cost of Service, Rate Design and Interruptible Demand Credits Indiana Utility Regulatory Commission United States Steel 2016
6.City of Independence (MO)Power and Light Docket No. ER15-1499-001
Annual Transmission Revenue Requirement within SPP Federal Energy Regulatory Commission City of Independence (MO) Power and Light 2015
7.Bryan Texas Utilities Docket No. 44467 Application to Change Rates for Wholesale Transmission Service: Interim Filing Public Utility Commission of Texas Bryan Texas Utilities 2015
8.GEUS Docket No. 42581 Application to Change Rates for Wholesale Transmission Service: Full Filing Public Utility Commission of Texas GEUS (Greenville, Texas) 2014
9.Bryan Texas Utilities Docket No. 41920 Application to Change Rates for Wholesale Transmission Service: Interim Filing Public Utility Commission of Texas Bryan Texas Utilities 2013
10.Brownsville Public UtilitiesBoard Docket No. 38556 Application to Change Rates for Wholesale Transmission Service: Full Filing Public Utility Commission of Texas Brownsville Public Utilities Board 2010
11.GEUS Docket No. 37180 Application to Change Rates for Wholesale Transmission Service: Full Filing Public Utility Commission of Texas GEUS (Greenville, Texas) 2009
12.Entergy Gulf States, Inc.Docket No. 00994490 Expropriation of Electric Distribution Facilities 15th Judicial District Court, Parish of Lafayette, Louisiana Lafayette Utilities System 2006
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PUC DOCKET NO. ___________________
APPLICATION OF GEUS TO CHANGE
RATES FOR WHOLESALE TRANSMISSION SERVICE
§
§ § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS
OF JILL A. SCHUEPBACH
(REDACTED)
Attachment JAS-2
Schedules and Workpapers
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Schedule A: Revenue RequirementTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Generation Transmission Distribution Total ReferenceFunctionFunctionFunctionSchedule(1)(2)(3)(4)(5)(6)
REVENUE REQUIREMENTEligible Fuel 272,176$ -$ -$ 272,176$ D-1Non-Eligible Fuel -$ -$ -$ -$ D-1Eligible Purchased Power 25,400,079$ -$ -$ 25,400,079$ D-1
Non-Eligible Purchased Power -$ -$ -$ -$ D-1Operation & Maintenance (less Labor Related Taxes)5,302,428$ 1,812,764$ 9,343,101$ 16,458,294$ D-1 & D-2Other Expenses -$ -$ -$ -$ E-4Decommissioning Expense -$ -$ -$ -$
Depreciation & Amortization 1,006,466$ 244,020$ 984,432$ 2,234,917$ E-1Federal Income Taxes -$ -$ -$ -$ E-3Taxes Other Than Income (Payments to the City)2,256,035$ 307,172$ 1,148,050$ 3,711,256$ E-2Taxes Other Than Income (Labor Related)149,295$ 66,741$ 244,948$ 460,985$ E-2
Total Operating Cost 34,386,479$ 2,430,697$ 11,720,531$ 48,537,707$
Return on Invested Capital 4,836,872$ 876,036$ 3,211,634$ 8,924,541$ BSubtotal Revenue Requirement 39,223,350$ 3,306,733$ 14,932,165$ 57,462,249$
Subtotal Revenue Requirement 39,223,350$ 3,306,733$ 14,932,165$ 57,462,249$ Less: Other Revenues 13,970,011$ -$ 2,245,062$ 16,215,073$ E-5 & E-6Unbundled Revenue Requirement 25,253,339$ 3,306,733$ 12,687,103$ 41,247,176$
ERCOT 4-CP MW 70,981 Docket 50333
Wholesale Transmission Rate $/MW $46.590
Wholesale Transmission Rate $/kW $0.04659
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Transmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Generation Transmission Distribution Total ReferenceFunctionFunctionFunctionSchedule(1)(2)(3)(4)(5)(6)
Rate BaseOriginal Cost of Plant 51,920,021$ 11,810,356$ 28,759,324$ 92,489,700$ B-1General Plant 2,708,926$ 1,343,075$ 6,789,368$ 10,841,370$ B-2Communication Equipment 28,414$ 5,215$ 14,180$ 47,809$ B-3
Accumulated Depreciation 22,650,576$ 6,920,964$ 16,936,364$ 46,507,904$ B-5Net Plant in Service 32,006,785$ 6,237,683$ 18,626,507$ 56,870,975$
Other Rate Base Items
CWIP -$ -$ -$ -$ B-4Plant Held for Future Use -$ -$ -$ -$ B-6Accumulated Provisions -$ -$ -$ -$ B-7Materials & Supplies 638,029$ 170,317$ 2,179,314$ 2,987,660$ B-8
Cash Working Capital 4,115,344$ 269,590$ 1,323,629$ 5,708,563$ B-9
Prepayments 108,934$ -$ -$ 108,934$ B-10Other Rate Base -$ -$ 2,351,254$ 2,351,254$ B-11Regulatory Assets -$ -$ -$ -$ B-12
Total Other Rate Base 4,862,308$ 439,907$ 5,854,197$ 11,156,411$
Total Rate Base 36,869,093$ 6,677,590$ 24,480,703$ 68,027,386$
Rate of Return 13.12%13.12%13.12%13.12%C-2
Return on Invested Capital 4,836,872$ 876,036$ 3,211,634$ 8,924,541$
Schedule B: Rate Base
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Schedule B-1: Original Cost of PlantTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Electric Plant in Service
Steam Production
310 Land & Land Rights WP/B-1/3 117,341$ -$ 117,341$ 117,341$ 117,341$ -$ -$ Generation311Structures and Improvements WP/B-1/3 1,082,096$ -$ 1,082,096$ 1,082,096$ 1,082,096$ -$ -$ Generation312Boiler Plant Equipment WP/B-1/3 6,707,487$ -$ 6,707,487$ 6,707,487$ 6,707,487$ -$ -$ Generation313Engines/Engine Driven Gen.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation314Turbogenerator Units WP/B-1/3 9,067,107$ -$ 9,067,107$ 9,067,107$ 9,067,107$ -$ -$ Generation
315 Accessory Electric Equip.WP/B-1/3 950,135$ -$ 950,135$ 950,135$ 950,135$ -$ -$ Generation316Misc. Power Plant Equip.WP/B-1/3 12,913$ -$ 12,913$ 12,913$ 12,913$ -$ -$ GenerationTotal Steam Production 17,937,079$ -$ 17,937,079$ 17,937,079$ 17,937,079$ -$ -$
Nuclear Production
320 Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation321Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation322Reactor Plant Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation323Engines/Engine Driven Gen.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation324Turbogenerator Units WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation
325 Accessory Electric Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation326Misc. Power Plant Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ GenerationTotal Nuclear Production -$ -$ -$ -$ -$ -$ -$
Hydraulic Production
330 Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation331Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation332Reservoirs, Dams, and Waterways WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation333Water Wheels, Turbines, & Generators WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation334Accessory Electric Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation
335 Miscellaneous Power Plant Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation336Roads, Railroads, and Bridges WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ GenerationTotal Hydraulic Production -$ -$ -$ -$ -$ -$ -$
Other Production
340 Land & Land Rights WP/B-1/3 43,850$ -$ 43,850$ 43,850$ 43,850$ -$ -$ Generation341Structures and Improvements WP/B-1/3 4,655,874$ -$ 4,655,874$ 4,655,874$ 4,655,874$ -$ -$ Generation342Fuel Holder, Producer & Acc WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation343Prime Movers WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation344GeneratorsWP/B-1/3 28,878,941$ -$ 28,878,941$ 28,878,941$ 28,878,941$ -$ -$ Generation
345 Accessory Plant Equipment WP/B-1/3 343,230$ -$ 343,230$ 343,230$ 343,230$ -$ -$ Generation346Misc. Power Plant Equipment WP/B-1/3 61,047$ -$ 61,047$ 61,047$ 61,047$ -$ -$ GenerationTotal Other Production 33,982,942$ -$ 33,982,942$ 33,982,942$ 33,982,942$ -$ -$
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Schedule B-1: Original Cost of PlantTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Total Production Plant 51,920,021$ -$ 51,920,021$ 51,920,021$ 51,920,021$ -$ -$
Electric Transmission Plant
350 Land and Land Rights WP/B-1/3 53,501$ -$ 53,501$ 53,501$ -$ 53,501$ -$ Transmission352Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission353Station Equipment WP/B-1/3 & WP/B-4/1 5,704,404$ 376,115$ 6,080,519$ 6,080,519$ -$ 6,080,519$ -$ Transmission354Towers and Fixtures WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission355Poles and Fixtures WP/B-1/3 1,156,632$ -$ 1,156,632$ 1,156,632$ -$ 1,156,632$ -$ Transmission
356 O.H. Conductors & Devices WP/B-1/3 4,519,704$ -$ 4,519,704$ 4,519,704$ -$ 4,519,704$ -$ Transmission357Underground Conduit WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission358Underground Conductors WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission359Roads and Trails WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ TransmissionTotal Electric Transmission Plant 11,434,241$ 376,115$ 11,810,356$ 11,810,356$ -$ 11,810,356$ -$
Electric Distribution Plant360Land and Land Rights WP/B-1/3 218,418$ -$ 218,418$ 218,418$ -$ -$ 218,418$ Distribution361Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution362Station Equipment WP/B-1/3 & WP/B-4/1 6,239,507$ 1,517,621$ 7,757,128$ 7,757,128$ -$ -$ 7,757,128$ Distribution
363 Storage Battery Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution364Poles, Towers & Fixtures WP/B-1/3 4,617,179$ -$ 4,617,179$ 4,617,179$ -$ -$ 4,617,179$ Distribution365O.H. Conductors & Devices WP/B-1/3 4,235,843$ -$ 4,235,843$ 4,235,843$ -$ -$ 4,235,843$ Distribution366Underground Conduits WP/B-1/3 1,865,939$ -$ 1,865,939$ 1,865,939$ -$ -$ 1,865,939$ Distribution367U.G. Conductors & Devices WP/B-1/3 3,078,563$ -$ 3,078,563$ 3,078,563$ -$ -$ 3,078,563$ Distribution
368 Line Transformers WP/B-1/3 4,357,638$ -$ 4,357,638$ 4,357,638$ -$ -$ 4,357,638$ Distribution369ServicesWP/B-1/3 546,593$ -$ 546,593$ 546,593$ -$ -$ 546,593$ Distribution370MetersWP/B-1/3 1,886,778$ -$ 1,886,778$ 1,886,778$ -$ -$ 1,886,778$ Distribution371Install. on Customer Prem.WP/B-1/3 94,496$ -$ 94,496$ 94,496$ -$ -$ 94,496$ Distribution372Leased Prop. on Cust. Premises WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution
373 Street Lights WP/B-1/3 100,748$ -$ 100,748$ 100,748$ -$ -$ 100,748$ DistributionTotal Electric Distribution Plant 27,241,702$ 1,517,621$ 28,759,324$ 28,759,324$ -$ -$ 28,759,324$
Total Electric Plant Original Cost 90,595,964$ 1,893,737$ 92,489,700$ 92,489,700$ 51,920,021$ 11,810,356$ 28,759,324$
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WP/B-1/1: GEUS 2019 Comprehensive Annual Financial ReportTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
See Attached Exhibit
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WP/B-1/2: GEUS 2019 Detailed Financial DataTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Total Account Lookup O&M W/O Payroll FICA Unemployment MedicareNo.Taxes Expenses(1)(2)(3)(4)(5)(6)(7)(8)(9)
Group : [910]Electric Operating Fund
Totals 45,841,805$ 8,309,347$ 379,194$ (7,524)$ 89,315$
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WP/B-1/3: Plant in Service, Accumulated Depreciation, Depreciation ExpenseTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Plant DepreciationAcct.Description G/L Balance Additions Deletions Transfers G/L Balance Balance Current Year Acc/Dep Transfers Balance
No.9/30/2018 9/30/2019 9/30/2018 Depreciation Removed For Del 9/30/2019(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)(12)
Electric
Land 3101 Land Steam 117,341$ -$ -$ -$ 117,341$ -$ -$ -$ -$ -$
3401 Land Diesel 43,850$ -$ -$ -$ 43,850$ -$ -$ -$ -$ -$ 3501 Land Transmission 53,501$ -$ -$ -$ 53,501$ -$ -$ -$ -$ -$ 3601 Land Distribution 218,418$ -$ -$ -$ 218,418$ -$ -$ -$ -$ -$ 3890 Land General 110,503$ -$ -$ -$ 110,503$ -$ -$ -$ -$ -$ Total Land 543,613$ -$ -$ -$ 543,613$ -$ -$ -$ -$ -$
Steam 3110 Structures 1,455,530$ -$ -$ (373,434)$ 1,082,096$ 1,016,660$ 3,710$ -$ -$ 1,020,370$ 3120 Boiler Plt Equip 4,886,434$ 1,821,053$ -$ -$ 6,707,487$ 1,373,213$ 317,712$ -$ -$ 1,690,925$ 3140 Generators 9,067,107$ -$ -$ -$ 9,067,107$ 8,220,222$ 38,848$ -$ -$ 8,259,070$ 3150 Acc Elec Equip 956,875$ 10,000$ (16,740)$ -$ 950,135$ 454,462$ 64,549$ (16,740)$ -$ 502,271$ 3160 Mis Pwr Plt Equip 12,913$ -$ -$ -$ 12,913$ 12,913$ -$ -$ -$ 12,913$ Total Steam 16,378,859$ 1,831,053$ (16,740)$ (373,434)$ 17,819,738$ 11,077,471$ 424,818$ (16,740)$ -$ 11,485,549$ 0 -$ Engine 341 Structures 4,655,874$ -$ -$ -$ 4,655,874$ 967,425$ 126,278$ -$ -$ 1,093,703$ 344 Engines 28,633,941$ -$ -$ -$ 28,633,941$ 7,391,232$ 864,994$ -$ -$ 8,256,226$ 3442 Renewable Generators -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 345 Acc Elec Equip 216,217$ 108,818$ -$ 18,195$ 343,230$ 159,847$ 23,122$ -$ -$ 182,970$
346 Mis Pwr Plt Equip 47,853$ 31,389$ -$ (18,195)$ 61,047$ 12,024$ 985$ -$ -$ 13,009$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$
Total Engines 33,553,885$ 140,207$ -$ -$ 33,694,092$ 8,530,528$ 1,015,379$ -$ -$ 9,545,907$ 0 -$
Renewables3442 Generators 245,000$ -$ -$ -$ 245,000$ 124,354$ 11,399$ -$ -$ 135,754$
Total Renewables 245,000$ -$ -$ -$ 245,000$ 124,354$ 11,399$ -$ -$ 135,754$
Transmission3530 Substations 5,714,414$ -$ (10,010)$ -$ 5,704,404$ 3,315,047$ 137,497$ (3,101)$ -$ 3,449,443$ 3555 TMPA Lines 1,156,632$ -$ -$ -$ 1,156,632$ 868,308$ 28,695$ -$ -$ 897,004$ 3565 GEUS Lines 4,241,141$ 369,821$ (91,258)$ -$ 4,519,704$ 1,790,277$ 120,087$ (91,258)$ -$ 1,819,106$ Total Transmission 11,112,187$ 369,821$ (101,268)$ -$ 11,380,739$ 5,973,632$ 286,280$ (94,360)$ -$ 6,165,552$ 0 -$ Distribution3620 Substations 6,239,507$ -$ -$ -$ 6,239,507$ 3,234,972$ 159,265$ -$ -$ 3,394,237$ 3640 Poles 4,535,340$ 215,667$ (133,828)$ -$ 4,617,179$ 2,145,115$ 141,897$ (133,828)$ -$ 2,153,184$ 3650 OH Conductors 3,995,821$ 241,671$ (1,649)$ -$ 4,235,843$ 1,769,653$ 128,454$ (1,649)$ -$ 1,896,458$ 3660 UG Conduit 1,820,226$ 126,186$ (80,474)$ -$ 1,865,939$ 957,847$ 81,428$ (80,474)$ -$ 958,801$ 3670 UG Conductors 3,031,745$ 142,626$ (95,808)$ -$ 3,078,563$ 1,578,850$ 143,653$ (95,808)$ -$ 1,626,696$
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WP/B-1/3: Plant in Service, Accumulated Depreciation, Depreciation ExpenseTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Plant DepreciationAcct.Description G/L Balance Additions Deletions Transfers G/L Balance Balance Current Year Acc/Dep Transfers Balance
No.9/30/2018 9/30/2019 9/30/2018 Depreciation Removed For Del 9/30/2019(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)(12)
3680 Transformers 4,371,693$ 254,113$ (268,168)$ -$ 4,357,638$ 2,227,643$ 198,950$ (268,168)$ -$ 2,158,425$
3690 Service Connect 575,577$ 5,305$ (34,289)$ -$ 546,593$ 309,339$ 26,776$ (34,289)$ -$ 301,825$ 3701 Meters 1,904,404$ 48,933$ (66,558)$ -$ 1,886,778$ 813,584$ 87,924$ (66,558)$ -$ 834,950$
3710 Vapor Lights 89,486$ 8,389$ (3,380)$ -$ 94,496$ 48,284$ 4,188$ (3,380)$ -$ 49,093$ 3750 St Lights/Signals 98,384$ 7,074$ (4,710)$ -$ 100,748$ 38,872$ 4,643$ (4,710)$ -$ 38,806$ Total Distribution 26,662,183$ 1,049,964$ (688,863)$ -$ 27,023,284$ 13,124,159$ 977,179$ (688,863)$ -$ 13,412,474$ 0 -$ General3901 Structures 5,948,457$ 30,755$ -$ (5,307)$ 5,973,905$ 2,581,676$ 183,452$ -$ -$ 2,765,127$ 3910 Furniture 564,538$ 62,065$ -$ -$ 626,603$ 197,529$ 14,753$ -$ -$ 212,282$ 3911 Office Equip -$ -$ (27,863)$ -$ (27,863)$ 275,220$ 16,341$ (27,863)$ -$ 263,699$ 3912 GENERAL / Meter 38,482$ -$ (4,356)$ -$ 34,126$ 32,293$ 1,727$ (4,356)$ -$ 29,664$ 3913 GENERAL / Customer Service -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 3914 GENERAL / Billing -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 3915 GENERAL / Cashiering 7,034$ -$ -$ -$ 7,034$ 7,034$ -$ -$ -$ 7,034$ 3920 Transport Equip 2,732,231$ 312,199$ (133,593)$ -$ 2,910,837$ 1,813,004$ 168,448$ (133,593)$ -$ 1,847,859$ 3930 WH Equip 69,324$ 14,960$ -$ -$ 84,284$ 63,913$ 3,185$ -$ -$ 67,098$ 394 Tools 13,918$ -$ -$ -$ 13,918$ 12,349$ 754$ -$ -$ 13,103$ 3950 Lab Equipment 336,292$ -$ (2,500)$ -$ 333,792$ 282,604$ 13,247$ (2,500)$ -$ 293,351$ 3960 Pwr Op Equip 317,094$ 125,120$ (43,665)$ -$ 398,548$ 240,671$ 18,635$ (43,665)$ -$ 215,642$ 3970 Comm Equip 47,809$ -$ -$ -$ 47,809$ 47,809$ -$ -$ -$ 47,809$ 3980 Miscellaneous Equipment -$ 372,382$ -$ -$ 372,382$ -$ -$ -$ -$ -$
Total General 10,075,177$ 917,481$ (211,976)$ (5,307)$ 10,775,375$ 5,554,102$ 420,541$ (211,976)$ -$ 5,762,667$
Total Electric (No CWIP)98,570,905$ 4,308,525$ (1,018,846)$ (378,741)$ 101,481,842$ 44,384,246$ 3,135,596$ (1,011,938)$ -$ 46,507,904$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-2: General PlantTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Electric General Plant389Land and Land Rights WP/B-1/3 110,503$ -$ 110,503$ 110,503$ 35,788$ 15,999$ 58,717$ PAYXAG390Structures and Improvements WP/B-1/3 & WP/B-4/1 5,973,905$ 3,300$ 5,977,205$ 5,977,205$ 1,935,787$ 865,380$ 3,176,038$ PAYXAG391Office Furniture & Equip.WP/B-1/3 639,900$ -$ 639,900$ 639,900$ 207,239$ 92,645$ 340,016$ PAYXAG392Transportation Equipment WP/B-1/3 2,910,837$ -$ 2,910,837$ 2,910,837$ 68,596$ 282,838$ 2,559,403$ TRANSPPLT-G393Stores Equipment WP/B-1/3 84,284$ -$ 84,284$ 84,284$ 17,999$ 4,805$ 61,480$ INV394Tools, Shop & Garage Equip.WP/B-1/3 13,918$ -$ 13,918$ 13,918$ 8,272$ 1,518$ 4,128$ PLTXGNL-N395Laboratory Equipment WP/B-1/3 333,792$ -$ 333,792$ 333,792$ 198,380$ 36,413$ 98,999$ PLTXGNL-N396Power Operated Equipment WP/B-1/3 398,548$ -$ 398,548$ 398,548$ 236,866$ 43,478$ 118,205$ PLTXGNL-N
397 See Schedule B-3 Schedule B-3 NA398Misc. Equipment WP/B-1/3 372,382$ -$ 372,382$ 372,382$ -$ -$ 372,382$ DISTRIBUTIONTotal General Plant 10,838,070$ 3,300$ 10,841,370$ 10,841,370$ 2,708,926$ 1,343,075$ 6,789,368$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-3: Communication EquipmentTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019
Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Communication Equipment397Communication Equipment WP/B-1/3 47,809$ -$ 47,809$ 47,809$ 28,414$ 5,215$ 14,180$ PLTXGNL-NTotal Communication Equipment 47,809$ -$ 47,809$ 47,809$ 28,414$ 5,215$ 14,180$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-4: Construction Work In ProgressTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation
No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Construction Work in ProgressCWIP 1,997,332$ (1,897,037)$ 100,295$ -$ -$ -$ -$ CWIP ProjectsTotal Construction Work in Progress 1,997,332$ (1,897,037)$ 100,295$ -$ -$ -$ -$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/B-4/1: GEUS CWIP Adjustment to Gross PlantTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Construction Work in ProgressTransmission ProjectsCWIP LTV - Transmission Substations NA 117,204$ -$ 117,204$ 117,204$ -$ 117,204$ -$ TransmissionCWIPTransmission Substation NA 152,357$ -$ 152,357$ 152,357$ -$ 152,357$ -$ TransmissionCWIPTransmission Substation NA 103,178$ -$ 103,178$ 103,178$ -$ 103,178$ -$ TransmissionSubtotal372,739$ -$ 372,739$ 372,739$ -$ 372,739$ -$ Distribution ProjectsCWIP LTV - Distribution Substations NA 544,986$ -$ 544,986$ 544,986$ -$ -$ 544,986$ DistributionCWIPDistribution Substations NA 862,167$ -$ 862,167$ 862,167$ -$ -$ 862,167$ DistributionCWIPDistribution Substations NA 96,845$ -$ 96,845$ 96,845$ -$ -$ 96,845$ DistributionCWIPAMINA100,295$ (100,295)$ -$ -$ -$ -$ -$ Not in ServiceSubtotal1,604,293$ (100,295)$ 1,503,998$ 1,503,998$ -$ -$ 1,503,998$ Engineering Labor AllocationCWIPEngineering Labor 17,000$ -$ 17,000$ 17,000$ -$ 3,376$ 13,623$ CWIP Projects
Engineering Labor Allocator
Directly Allocated CWIP 1,977,032$ (100,295)$ 1,876,737$ 1,876,737$ -$ 372,739$ 1,503,998$
Share of CWIP Projects 0.0%19.9%80.1%CWIP Projects
Transmission & Distribution CWIP 1,994,032$ (100,295)$ 1,893,737$ 1,893,737$ -$ 376,115$ 1,517,621$ CWIP Direct
General Plant ProjectsCWIP Operations Center Architecture NA 3,300$ -$ 3,300$ 3,300$
Total Construction Work in ProgressCWIP 1,997,332$ (100,295)$ 1,897,037$ 1,897,037$
Acct.Description Reference 2019 Known Updated Plant Allocation No.Schedule Balance Adjustments Balance Method(12)(13)(14)(15)(16)(17)(18)
Adjustment to Gross PlantTransmission353Station Equipment B-1 5,704,404$ 376,115$ 6,080,519$ DirectDistribution362Station Equipment B-1 6,239,507$ 1,517,621$ 7,757,128$ DirectGeneral Plant390 Structures and Improvements B-2 5,973,905$ 3,300$ 5,977,205$ Direct
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-5: Accumulated DepreciationTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Accumulated Depreciation
Steam Production310Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation311Structures and Improvements WP/B-1/3 1,020,370$ -$ 1,020,370$ 1,020,370$ 1,020,370$ -$ -$ Generation312Boiler Plant Equipment WP/B-1/3 1,690,925$ -$ 1,690,925$ 1,690,925$ 1,690,925$ -$ -$ Generation313Engines/Engine Driven Gen.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation314Turbogenerator Units WP/B-1/3 8,259,070$ -$ 8,259,070$ 8,259,070$ 8,259,070$ -$ -$ Generation315Accessory Electric Equip.WP/B-1/3 502,271$ -$ 502,271$ 502,271$ 502,271$ -$ -$ Generation316Misc. Power Plant Equip.WP/B-1/3 12,913$ -$ 12,913$ 12,913$ 12,913$ -$ -$ GenerationTotal Steam Production 11,485,549$ -$ 11,485,549$ 11,485,549$ 11,485,549$ -$ -$
Nuclear Production320Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation321Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation322Reactor Plant Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation323Engines/Engine Driven Gen.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation324Turbogenerator Units WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation325Accessory Electric Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation326Misc. Power Plant Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ GenerationTotal Nuclear Production -$ -$ -$ -$ -$ -$ -$
Hydraulic Production330Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation331Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation332Reservoirs, Dams, and Waterways WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation333Water Wheels, Turbines, and Generators WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation334Accessory Electric Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation335Miscellaneous Power Plant Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation336Roads, Railroads, and Bridges WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ GenerationTotal Hydraulic Production -$ -$ -$ -$ -$ -$ -$
Other Production340Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation341Structures and Improvements WP/B-1/3 1,093,703$ -$ 1,093,703$ 1,093,703$ 1,093,703$ -$ -$ Generation342Fuel Holder, Producer & Acc WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation343Prime Movers WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation344GeneratorsWP/B-1/3 8,391,980$ -$ 8,391,980$ 8,391,980$ 8,391,980$ -$ -$ Generation345Accessory Plant Equipment WP/B-1/3 182,970$ -$ 182,970$ 182,970$ 182,970$ -$ -$ Generation346Misc. Power Plant Equipment WP/B-1/3 13,009$ -$ 13,009$ 13,009$ 13,009$ -$ -$ GenerationTotal Other Production 9,681,661$ -$ 9,681,661$ 9,681,661$ 9,681,661$ -$ -$
Total Production Plant 21,167,210$ -$ 21,167,210$ 21,167,210$ 21,167,210$ -$ -$
Electric Transmission Plant350Land and Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission352Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission353Station Equipment WP/B-1/3 3,449,443$ -$ 3,449,443$ 3,449,443$ -$ 3,449,443$ -$ Transmission354Towers and Fixtures WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-5: Accumulated DepreciationTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
355 Poles and Fixtures WP/B-1/3 897,004$ -$ 897,004$ 897,004$ -$ 897,004$ -$ Transmission356O.H. Conductors & Devices WP/B-1/3 1,819,106$ -$ 1,819,106$ 1,819,106$ -$ 1,819,106$ -$ Transmission357Underground Conduit WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission358Underground Conductors WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission359Roads and Trails WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ TransmissionTotal Electric Transmission Plant 6,165,552$ -$ 6,165,552$ 6,165,552$ -$ 6,165,552$ -$
Electric Distribution Plant360Land and Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution361Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution362Station Equipment WP/B-1/3 3,394,237$ -$ 3,394,237$ 3,394,237$ -$ -$ 3,394,237$ Distribution363Storage Battery Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution364Poles, Towers & Fixtures WP/B-1/3 2,153,184$ -$ 2,153,184$ 2,153,184$ -$ -$ 2,153,184$ Distribution365O.H. Conductors & Devices WP/B-1/3 1,896,458$ -$ 1,896,458$ 1,896,458$ -$ -$ 1,896,458$ Distribution366Underground Conduits WP/B-1/3 958,801$ -$ 958,801$ 958,801$ -$ -$ 958,801$ Distribution367U.G. Conductors & Devices WP/B-1/3 1,626,696$ -$ 1,626,696$ 1,626,696$ -$ -$ 1,626,696$ Distribution368Line Transformers WP/B-1/3 2,158,425$ -$ 2,158,425$ 2,158,425$ -$ -$ 2,158,425$ Distribution369ServicesWP/B-1/3 301,825$ -$ 301,825$ 301,825$ -$ -$ 301,825$ Distribution370MetersWP/B-1/3 834,950$ -$ 834,950$ 834,950$ -$ -$ 834,950$ Distribution371Install. on Customer Prem.WP/B-1/3 49,093$ -$ 49,093$ 49,093$ -$ -$ 49,093$ Distribution372Leased Prop. on Cust. Premises WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution373Street Lights WP/B-1/3 38,806$ -$ 38,806$ 38,806$ -$ -$ 38,806$ DistributionTotal Electric Distribution Plant 13,412,474$ -$ 13,412,474$ 13,412,474$ -$ -$ 13,412,474$
Electric General Plant389Land and Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ NA390Structures and Improvements WP/B-1/3 2,765,127$ -$ 2,765,127$ 2,765,127$ 895,518$ 400,335$ 1,469,273$ PAYXAG391Office Furniture & Equip.WP/B-1/3 512,679$ -$ 512,679$ 512,679$ 166,037$ 74,226$ 272,416$ PAYXAG392Transportation Equipment WP/B-1/3 1,847,859$ -$ 1,847,859$ 1,847,859$ 68,775$ 214,855$ 1,564,229$ TRANSPPLT-G393Stores Equipment WP/B-1/3 67,098$ -$ 67,098$ 67,098$ 14,329$ 3,825$ 48,944$ INV394Tools, Shop & Garage Equip.WP/B-1/3 13,103$ -$ 13,103$ 13,103$ 7,787$ 1,429$ 3,886$ PLTXGNL-N395Laboratory Equipment WP/B-1/3 293,351$ -$ 293,351$ 293,351$ 174,345$ 32,002$ 87,005$ PLTXGNL-N396Power Operated Equipment WP/B-1/3 215,642$ -$ 215,642$ 215,642$ 128,160$ 23,524$ 63,957$ PLTXGNL-N397Communication Equipment WP/B-1/3 47,809$ -$ 47,809$ 47,809$ 28,414$ 5,215$ 14,180$ PLTXGNL-N398Misc. Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ NATotal Electric General Plant 5,762,667$ -$ 5,762,667$ 5,762,667$ 1,483,366$ 755,411$ 3,523,890$
Total Electric Accumulated Depreciation 46,507,904$ -$ 46,507,904$ 46,507,904$ 22,650,576$ 6,920,964$ 16,936,364$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-6: Plant Held for Future UseTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019
Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Plant Held For Future UseNANone WP/B-1/1 -$ -$ -$ -$ -$ -$ -$ NATotal Plant Held for Future Use -$ -$ -$ -$ -$ -$ -$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-7: Accumulated Provision BalanceTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation
No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Accumulated Provision BalanceNANone WP/B-1/1 -$ -$ -$ -$ -$ -$ -$ NATotal Accumulated Provision Balance -$ -$ -$ -$ -$ -$ -$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-8: Materials and SuppliesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Materials and Supplies
910-9-000000-15900-1540 Materials and Supplies WP/B-1/2 2,987,660$ -$ 2,987,660$ 2,987,660$ 638,029$ 170,317$ 2,179,314$ INVTotal Materials and Supplies 2,987,660$ -$ 2,987,660$ 2,987,660$ 638,029$ 170,317$ 2,179,314$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-9: Cash Working CapitalTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019
Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to No.Schedule Electric Transfers Texas Generation Transmission Distribution(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)
Cash Working CapitalNAOperations & Maintenance Schedule D-1 & D-2 42,130,549$ -$ 42,130,549$ 42,130,549$ 30,974,683$ 1,812,764$ 9,343,101$ NA PILOT, Payroll, Transfers E-2 4,172,241$ -$ 4,172,241$ 4,172,241$ 2,405,330$ 373,913$ 1,392,998$ Total O&M 46,302,790$ -$ 46,302,790$ 46,302,790$ 33,380,013$ 2,186,677$ 10,736,099$
Total Cash Working Capital 5,708,563$ -$ 5,708,563$ 5,708,563$ 4,115,344$ 269,590$ 1,323,629$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-10: PrepaymentsTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation
No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Prepayments910-9-000000-13297-1657 ERCOT CRR PREPAYMENTS WP/B-1/2 (2,616)$ -$ (2,616)$ (2,616)$ (2,616)$ -$ -$ Generation910-9-000000-13299-1655 ERCOT COLLATERAL WP/B-1/2 111,550$ -$ 111,550$ 111,550$ 111,550$ -$ -$ GenerationTotal Prepayments 108,934$ -$ 108,934$ 108,934$ 108,934$ -$ -$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-11: Other Rate Base ItemsTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Other Rate Base Items
910-9-000000-24000-2350 Customer Deposits WP/B-1/2 2,351,254$ -$ 2,351,254$ 2,351,254$ -$ -$ 2,351,254$ DistributionTotal Other Rate Base Items 2,351,254$ -$ 2,351,254$ 2,351,254$ -$ -$ 2,351,254$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-12: Regulatory AssetsTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Regulatory AssetsNA NA WP/B-1/1 -$ -$ -$ -$ -$ -$ -$ NATotal Regulatory Assets -$ -$ -$ -$ -$ -$ -$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule C-2: Debt Service Coverage MethodTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description 2019 Adjustment 2020 ReferenceDebt Service Schedule(1)(2)(3)(4)(5)
Rate of ReturnDebt Service2008 Interest Payment 499,483$ (499,483)$ -$ WP/C-2/12008 Principal Payment 515,000$ (515,000)$ -$ WP/C-2/12010 Interest Payment 1,959,172$ (1,959,172)$ -$ WP/C-2/12010 Principal Payment 1,745,000$ (1,745,000)$ -$ WP/C-2/12019AB Interest Payment 599,329$ 1,697,580$ 2,296,909$ WP/C-2/12019AB Principal Payment 3,200,000$ 2,235,000$ 5,435,000$ WP/C-2/1Debt Service Requirement 8,517,984$ (786,075)$ 7,731,909$
Debt Service CoverageDebt Covenant 1.25Additional Coverage 0.251.50
Debt Service with Coverage 11,597,864$
DeductionsDepreciation & Amortization 2,234,917$ Interest Income 438,405$ Total Deductions 2,673,322$
Return 8,924,541$
Rate Base 68,027,386$
Rate of Return 13.1%
Required Financial Ratios
Revenue per kWh
RevenuesOperating Revenues 48,537,707$ Schedule AInterest and Other Income 16,653,478$ Schedule E-5Total Revenues 65,191,185$
ExpensesOperating Expenses 46,302,790$ Depreciation & Amortization 2,234,917$ Interest Expense 1,697,580$ Total Expenses 50,235,288$
Net Income (Loss)14,955,898$
Net Income per Revenue Dollar 0.2294$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/C-2/1: Long Term Debt Service ScheduleTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Copeland
Payment Fiscal Year 2008 2008 2008 2010 2010 2010 2019A 2019A 2019A 2019B 2019B 2019B Total Total TotalDateEndedPrincipalInterestDebtPrincipalInterestDebtPrincipalInterestDebtPrincipalInterestDebtPrincipalInterestDebtPaymentPaymentServicePaymentPaymentServicePaymentPaymentServicePaymentPaymentServicePaymentPaymentService(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)(12)(13)(14)(15)(16)(17)
02/15/2019 2019 515,000$ 499,483$ 1,014,483$ 1,745,000$ 1,959,172$ 3,704,172$ -$ -$ -$ -$ -$ -$ 2,260,000$ 2,458,655$ 4,718,655$ 05/16/2019 2019 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 08/15/2019 2019 -$ -$ -$ -$ -$ -$ -$ 514,346$ 514,346$ 3,200,000$ 84,983$ 3,284,983$ 3,200,000$ 599,329$ 3,799,329$ 09/30/2019 2019 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2020 2020 -$ -$ -$ -$ -$ -$ 1,935,000$ 1,040,250$ 2,975,250$ -$ 132,392$ 132,392$ 1,935,000$ 1,172,642$ 3,107,642$ 08/15/2020 2020 -$ -$ -$ -$ -$ -$ -$ 991,875$ 991,875$ 3,500,000$ 132,392$ 3,632,392$ 3,500,000$ 1,124,267$ 4,624,267$ 09/30/2020 2020 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2021 2021 -$ -$ -$ -$ -$ -$ 2,045,000$ 991,875$ 3,036,875$ -$ 79,750$ 79,750$ 2,045,000$ 1,071,625$ 3,116,625$ 08/15/2021 2021 -$ -$ -$ -$ -$ -$ -$ 940,750$ 940,750$ 3,525,000$ 79,750$ 3,604,750$ 3,525,000$ 1,020,500$ 4,545,500$ 09/30/2021 2021 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2022 2022 -$ -$ -$ -$ -$ -$ 2,140,000$ 940,750$ 3,080,750$ -$ 31,281$ 31,281$ 2,140,000$ 972,031$ 3,112,031$ 08/15/2022 2022 -$ -$ -$ -$ -$ -$ -$ 887,250$ 887,250$ 2,275,000$ 31,281$ 2,306,281$ 2,275,000$ 918,531$ 3,193,531$ 09/30/2022 2022 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2023 2023 -$ -$ -$ -$ -$ -$ 2,250,000$ 887,250$ 3,137,250$ -$ -$ -$ 2,250,000$ 887,250$ 3,137,250$ 08/15/2023 2023 -$ -$ -$ -$ -$ -$ -$ 831,000$ 831,000$ -$ -$ -$ -$ 831,000$ 831,000$ 09/30/2023 2023 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2024 2024 -$ -$ -$ -$ -$ -$ 2,370,000$ 831,000$ 3,201,000$ -$ -$ -$ 2,370,000$ 831,000$ 3,201,000$ 08/15/2024 2024 -$ -$ -$ -$ -$ -$ 8,800,000$ 771,750$ 9,571,750$ -$ -$ -$ 8,800,000$ 771,750$ 9,571,750$ 09/30/2024 2024 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2025 2025 -$ -$ -$ -$ -$ -$ 2,490,000$ 551,750$ 3,041,750$ -$ -$ -$ 2,490,000$ 551,750$ 3,041,750$ 08/15/2025 2025 -$ -$ -$ -$ -$ -$ 4,000,000$ 489,500$ 4,489,500$ -$ -$ -$ 4,000,000$ 489,500$ 4,489,500$ 09/30/2025 2025 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2026 2026 -$ -$ -$ -$ -$ -$ 2,615,000$ 389,500$ 3,004,500$ -$ -$ -$ 2,615,000$ 389,500$ 3,004,500$ 08/15/2026 2026 -$ -$ -$ -$ -$ -$ 4,000,000$ 324,125$ 4,324,125$ -$ -$ -$ 4,000,000$ 324,125$ 4,324,125$ 09/30/2026 2026 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2027 2027 -$ -$ -$ -$ -$ -$ 2,750,000$ 224,125$ 2,974,125$ -$ -$ -$ 2,750,000$ 224,125$ 2,974,125$ 08/15/2027 2027 -$ -$ -$ -$ -$ -$ 4,000,000$ 155,375$ 4,155,375$ -$ -$ -$ 4,000,000$ 155,375$ 4,155,375$ 09/30/2027 2027 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2028 2028 -$ -$ -$ -$ -$ -$ 2,215,000$ 55,375$ 2,270,375$ -$ -$ -$ 2,215,000$ 55,375$ 2,270,375$ 08/15/2028 2028 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2028 2028 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2029 2029 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 08/15/2029 2029 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2029 2029 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2030 2030 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 08/15/2030 2030 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2030 2030 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2031 2031 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 08/15/2031 2031 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2031 2031 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2032 2032 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 08/15/2032 2032 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2032 2032 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2033 2033 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 08/15/2033 2033 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2033 2033 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2034 2034 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$
51 96
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/C-2/1: Long Term Debt Service ScheduleTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Copeland
Payment Fiscal Year 2008 2008 2008 2010 2010 2010 2019A 2019A 2019A 2019B 2019B 2019B Total Total TotalDateEndedPrincipalInterestDebtPrincipalInterestDebtPrincipalInterestDebtPrincipalInterestDebtPrincipalInterestDebtPaymentPaymentServicePaymentPaymentServicePaymentPaymentServicePaymentPaymentServicePaymentPaymentService(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)(12)(13)(14)(15)(16)(17)
08/15/2034 2034 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2034 2034 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 02/15/2035 2035 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 09/30/2035 2035 -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ -$ 515,000$ 499,483$ 1,014,483$ 1,745,000$ 1,959,172$ 3,704,172$ 41,610,000$ 11,817,846$ 53,427,846$ 12,500,000$ 571,830$ 13,071,830$ 56,370,000$ 14,848,330$ 71,218,330$
52 97
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/C-2/2: 2019A Revenue Refunding Bonds Official StatementTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
See Attached Workpaper
53 98
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/C-2/3: 2019B Revenue Refunding Bonds Official StatementTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
See Attached Workpaper
54 99
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-1: Operation and Maintenance ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Operation and Maintenance Expenses
Power Production ExpensesSteam Power GenerationOperation500Operation Super. & Eng.WP/B-1/2 Generation501Eligible Fuel WP/B-1/2 GenerationNon Eligible Fuel WP/B-1/2 Generation502Steam Expenses WP/B-1/2 Generation503Lake & Pumping Equipment WP/B-1/2 Generation505Electric Expenses WP/B-1/2 Generation506Misc. Steam power Expenses WP/B-1/2 Generation507RentsWP/B-1/2 Generation508Operation Supplies & Expenses GenerationSubtotal
Maintenance510Maint. Super. & Eng.WP/B-1/2 Generation511Maint. of Structures WP/B-1/2 Generation512Maint. of Boiler Plant WP/B-1/2 Generation513Maint. of Electric Plant WP/B-1/2 Generation514Maint. of Misc. Steam Plant WP/B-1/2 Generation515Maint. Of Steam Prod Plant WP/B-1/2 GenerationSubtotal
Nuclear Power GenerationOperation517Operation Supervision WP/B-1/2 Generation518Nuclear Fuel-Direct WP/B-1/2 Generation519Coolants and Water WP/B-1/2 Generation520Steam Expenses WP/B-1/2 Generation523Electric expenses WP/B-1/2 Generation524Misc. Nuclear Power Expenses WP/B-1/2 Generation525Rents-Allocable WP/B-1/2 GenerationSubtotal
Maintenance528Maint. Supervision WP/B-1/2 Generation529Maint. of Structures WP/B-1/2 Generation530Maint. of Reactor Plant WP/B-1/2 Generation531Maint. of Electric Plant WP/B-1/2 Generation532Maint. of Misc. Nuclear Plant WP/B-1/2 GenerationSubtotal
Hydraulic Generation
55 100
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-1: Operation and Maintenance ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Operation535Operation Supervision WP/B-1/2 Generation536Water for Power WP/B-1/2 Generation537Hydraulic Expenses WP/B-1/2 Generation538Electric Expenses WP/B-1/2 Generation539Misc.Hydralic Gen. Exp.WP/B-1/2 Generation540RentsWP/B-1/2 GenerationSubtotal
Maintenance541Maint. Supervision WP/B-1/2 Generation542Maint. of Structures WP/B-1/2 Generation543Maint. of Reservoirs, Dams, & Waterways WP/B-1/2 Generation544Maint. of Electric Plant WP/B-1/2 Generation545Maint. of Misc.Hydralic Gen. Exp.WP/B-1/2 GenerationSubtotal
Other Power GenerationOperation546Operation Super. & Engin.WP/B-1/2 Generation547FuelWP/B-1/2 Generation548Generation Expenses (Major Only)WP/B-1/2 Generation549Misc. Other Power Generation WP/B-1/2 Generation550RentsWP/B-1/2 GenerationSubtotal
Maintenance551Maintenance Super. & Engin.WP/B-1/2 Generation552Maintenance of Structures WP/B-1/2 Generation553Maint. Gener. & Elect. Plt.WP/B-1/2 Generation554Maint. Misc. Other power WP/B-1/2 GenerationSubtotal
Other Power Supply555Purchased Power WP/B-1/2 Generation556System Control & Load Dispatch WP/B-1/2 Generation557OtherWP/B-1/2 GenerationSubtotal
Total Power Production Expense
Transmission ExpenseOperation560Operation Super. & Engin.WP/B-1/2; WP/D-1/1 Transmission561Load Dispatching WP/B-1/2 Transmission
56 101
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-1: Operation and Maintenance ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
562 Station Equipment WP/B-1/2 Transmission563Overhead Line Expense WP/B-1/2 Transmission564Underground Line Expense WP/B-1/2 Transmission565Wheeling Expense WP/B-1/2 Distribution566Misc. Transmission Expense WP/B-1/2; WP/D-1/1 Transmission567Operation Supplies & Expenses WP/B-1/2 TransmissionSubtotal
Maintenance568Maintenance Super. & Engin.WP/B-1/2 Transmission569Maint. of Structures WP/B-1/2 Transmission570Maint. of Station Equipment WP/B-1/2 Transmission571Maint. of Overhead Lines WP/B-1/2 Transmission572Maint. of Underground Lines WP/B-1/2 Transmission573Maint. of Misc. Trans.Plant WP/B-1/2 Transmission574Maint. Of Trans. Plant WP/B-1/2 TransmissionSubtotal
Total Transmission Expenses
DistributionOperation580Operation Super. & Engin.WP/B-1/2; WP/D-1/1 Distribution581Load Dispatching WP/B-1/2 Distribution582Station Expense WP/B-1/2 Distribution583Overhead Line Expense WP/B-1/2 Distribution584Underground Line Expense WP/B-1/2 Distribution585Street Light & Signal Systems WP/B-1/2 Distribution586Meter Expenses WP/B-1/2 Distribution587Customer Installation Expense WP/B-1/2 Distribution588Misc. Distribution Expenses WP/B-1/2; WP/D-1/1 Distribution589RentsWP/B-1/2 DistributionSubtotal
Maintenance590Maintenance Super.& Engin.WP/B-1/2 Distribution591Maint. of Structures WP/B-1/2 Distribution592Maint. of Station Equipment WP/B-1/2 Distribution593Maint. of Overhead Lines WP/B-1/2 Distribution594Maint. of Underground Lines WP/B-1/2 Distribution595Maint. of Line Transformers WP/B-1/2 Distribution596Maint. of Street Lights WP/B-1/2 Distribution597Maint. of Meters WP/B-1/2 Distribution598Maint. of Misc. Dist. Plant.WP/B-1/2 DistributionSubtotal
57 102
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-1: Operation and Maintenance ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Total Distribution Expenses
Total Prod., Trans., & Dist. Expenses
Customer and Information Expenses
Customer Accounts Expenses901Supervision WP/B-1/2 Distribution902Meter Reading Expense WP/B-1/2 Distribution903Customer Records & Collect.WP/B-1/2 Distribution904Uncollectible Accounts WP/B-1/2 Distribution905Misc. Customer Account Exp.WP/B-1/2 DistributionSubtotal
Cust. Service & Information Expense906Customer Svc. & Infor.WP/B-1/2 Distribution907SupervisionWP/B-1/2 Distribution908Customer Assistance WP/B-1/2 Distribution909Inform. & Instruct. Adv. Exp.WP/B-1/2 Distribution910Misc. Cust. Service & Inform.WP/B-1/2 DistributionSubtotal
Sales Expense911Supervision WP/B-1/2 Distribution912Demonstrating & Selling Exp.WP/B-1/2 Distribution913Advertising Exp.WP/B-1/2 Distribution916Misc. Sales Exp.WP/B-1/2 Distribution917Sales Expense WP/B-1/2 DistributionSubtotal
Total Cust. Serv., Inform. & Sale Exp.
Total Operations and Maintenance Expenses 39,288,401$ -$ 39,288,401$ 39,288,401$ 30,129,639$ 1,461,052$ 7,697,710$
58 103
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/D-1/1: GEUS Engineering Expense AdjustmentTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Copeland
Description Reference FERC Total Allocation to Allocation to Allocation to Allocation Schedule Account No Electric Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)
Engineering Costs
Distribution
Operation Super. & Engin. Total WP/B-1/2 580 904,494$ -$ 263,310$ 641,184$ TDPLTXGNL-GMisc. Distribution Expenses Total WP/B-1/2 588 124,292$ -$ 36,183$ 88,109$ TDPLTXGNL-G
AdjustmentDistributionOperation Super. & Engin.580 (263,310)$ Misc. Distribution Expenses 588 (36,183)$
Transmission
Operation Super. & Engin.560 -$ 263,310$
Misc. Transmission Expense 566 -$ 36,183$ Total Engineering Adjustment -$ 299,493$ (299,493)$
59 104
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-2: Administrative and General ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Administrative & General Expenses920Admin. & General Salaries WP/B-1/2 1,457,440$ -$ 1,457,440$ 1,457,440$ 472,009$ 211,008$ 774,423$ PAYXAG921Office Supplies WP/B-1/2 332,479$ -$ 332,479$ 332,479$ 107,677$ 48,136$ 176,665$ PAYXAG
922 Admin. Exp. Transferred WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA923Outside Services WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA924Property Insurance Exp.WP/B-1/2 187,761$ -$ 187,761$ 187,761$ 105,671$ 20,594$ 61,496$ PLTSVC-N925Injuries & Damages WP/B-1/2 80,168$ -$ 80,168$ 80,168$ 25,963$ 11,607$ 42,598$ PAYXAG926Pensions & Benefits WP/B-1/2 161,168$ -$ 161,168$ 161,168$ 52,196$ 23,334$ 85,638$ PAYXAG
927 Franchise Requirements WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA928Regulatory Commission WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA929Duplicate Charges WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA930Miscellaneous General Expense WP/B-1/2 109,003$ -$ 109,003$ 109,003$ 35,302$ 15,781$ 57,920$ PAYXAG930.1 General Advertising Expense WP/B-1/2 348,603$ -$ 348,603$ 348,603$ -$ -$ 348,603$ DISTRIBUTION
930.2 Miscellaneous General Expense WP/B-1/2 72,388$ -$ 72,388$ 72,388$ 23,444$ 10,480$ 38,464$ PAYXAG931RentsWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA933Transportation Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA935Maint. of General Plant WP/B-1/2 93,138$ -$ 93,138$ 93,138$ 22,782$ 10,771$ 59,585$ GNLPLT-NTotal Admin. & General Expense 2,842,148$ -$ 2,842,148$ 2,842,148$ 845,044$ 351,712$ 1,645,391$
60 105
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-3: Payroll ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Payroll Expenses
Power Production Payroll ExpensesSteam Power GenerationOperation500Operation Super. & Eng.WP/B-4/2 671,569$ -$ 671,569$ 671,569$ 671,569$ -$ -$ Generation501Eligible Fuel WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation501Non Eligible Fuel WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation502Steam Expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation
503 Lake & Pumping Equipment WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation505Electric Expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation506Misc. Steam power Expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation507RentsWP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation508Operation Supplies & Expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ GenerationSubtotal671,569$ -$ 671,569$ 671,569$ 671,569$ -$ -$
Maintenance510Maint. Super. & Eng.WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation511Maint. of Structures WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation512Maint. of Boiler Plant WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation513Maint. of Electric Plant WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation514Maint. of Misc. Steam Plant WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation515Maint. Of Steam Plant 436,578$ -$ 436,578$ 436,578$ 436,578$ -$ -$ GenerationSubtotal436,578$ -$ 436,578$ 436,578$ 436,578$ -$ -$
Nuclear Power GenerationOperation517Operation Supervision WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation
518 Nuclear Fuel-Direct WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation519Coolants and Water WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation520Steam Expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation523Electric expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation524Misc. Nuclear Power Expenses WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation525Rents-Allocable WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation
Subtotal -$ -$ -$ -$ -$ -$ -$
Maintenance528Maint. Supervision WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation529Maint. of Structures WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation530Maint. of Reactor Plant WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation
61 106
DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-3: Payroll ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
531 Maint. of Electric Plant WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ Generation532Maint. of Misc. Nuclear Plant WP/B-4/2 -$ -$ -$ -$ -$ -$ -$ GenerationSubtotal-$ -$ -$ -$ -$ -$ -$
Hydraulic GenerationOperation535Operation Supervision WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation536Water for Power WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation537Hydraulic Expenses WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation538Electric Expenses WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation
539 Misc.Hydralic Gen. Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation540RentsWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ GenerationSubtotal-$ -$ -$ -$ -$ -$ -$
Maintenance541Maint. Supervision WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation542Maint. of Structures WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation543Maint. of Reservoirs, Dams, & Waterway WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation544Maint. of Electric Plant WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation545Maint. of Misc.Hydralic Gen. Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ GenerationSubtotal-$ -$ -$ -$ -$ -$ -$
Other Power GenerationOperation546Operation Super. & Engin.WP/B-1/2 659,968$ -$ 659,968$ 659,968$ 659,968$ -$ -$ Generation547FuelWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation548Generation Expenses (Major Only)WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation549Misc. Other Power Generation WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation550RentsWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation
Subtotal 659,968$ -$ 659,968$ 659,968$ 659,968$ -$ -$
Maintenance551Maintenance Super. & Engin.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation552Maintenance of Structures WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation553Maint. Gener. & Elect. Plt.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation
554 Maint. Misc. Other power WP/B-1/2 429,084$ -$ 429,084$ 429,084$ 429,084$ -$ -$ GenerationSubtotal429,084$ -$ 429,084$ 429,084$ 429,084$ -$ -$
Other Power Supply555Purchased Power WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation556System Control & Load Dispatch WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Generation
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-3: Payroll ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
575 Other WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ GenerationSubtotal-$ -$ -$ -$ -$ -$ -$
Total Power Production Payroll Expense 2,197,199$ -$ 2,197,199$ 2,197,199$ 2,197,199$ -$ -$
Transmission Payroll ExpenseOperation560Operation Super. & Engin.WP/B-1/2; WP/D-3/1 -$ 234,649$ 234,649$ 234,649$ -$ 234,649$ -$ Transmission561Load Dispatching WP/B-1/2 353,845$ -$ 353,845$ 353,845$ -$ 353,845$ -$ Transmission562Station Equipment WP/B-1/2 84,312$ -$ 84,312$ 84,312$ -$ 84,312$ -$ Transmission
563 Overhead Line Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission564Underground Line Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission565Wheeling Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution566Misc. Transmission Expense WP/B-1/2; WP/D-3/1 -$ 33,782$ 33,782$ 33,782$ -$ 33,782$ -$ Transmission567.0 Operation Supplies & Expenses WP/B-1/2 111,392$ -$ 111,392$ 111,392$ -$ 111,392$ -$ TransmissionSubtotal549,549$ 268,432$ 817,981$ 817,981$ -$ 817,981$ -$
Maintenance568Maintenance Super. & Engin.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission569Maint. of Structures WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission570Maint. of Station Equipment WP/B-1/2 104,789$ -$ 104,789$ 104,789$ -$ 104,789$ -$ Transmission571Maint. of Overhead Lines WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission572Maint. of Underground Lines WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission573Maint. of Misc. Trans.Plant WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Transmission574Maint. Of Trans. Plant WP/B-1/2 59,473$ -$ 59,473$ 59,473$ -$ 59,473$ -$ TransmissionSubtotal164,262$ -$ 164,262$ 164,262$ -$ 164,262$ -$
Total Transmission Payroll Expenses 713,811$ 268,432$ 982,243$ 982,243$ -$ 982,243$ -$
Distribution Payroll ExpenseOperation580Operation Super. & Engin.WP/B-1/2; WP/D-3/1 806,043$ (234,649)$ 571,394$ 571,394$ -$ -$ 571,394$ Distribution581Load Dispatching WP/B-1/2 222,245$ -$ 222,245$ 222,245$ -$ -$ 222,245$ Distribution582Station Expense WP/B-1/2 84,086$ -$ 84,086$ 84,086$ -$ -$ 84,086$ Distribution583Overhead Line Expense WP/B-1/2 147,905$ -$ 147,905$ 147,905$ -$ -$ 147,905$ Distribution
584 Underground Line Expense WP/B-1/2 146,411$ -$ 146,411$ 146,411$ -$ -$ 146,411$ Distribution585Street Light & Signal Systems WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution586Meter Expenses WP/B-1/2 110,627$ -$ 110,627$ 110,627$ -$ -$ 110,627$ Distribution587Customer Installation Expense WP/B-1/2 449$ -$ 449$ 449$ -$ -$ 449$ Distribution588Misc. Distribution Expenses WP/B-1/2; WP/D-3/1 116,045$ (33,782)$ 82,263$ 82,263$ -$ -$ 82,263$ Distribution589RentsWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-3: Payroll ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Subtotal 1,633,811$ (268,432)$ 1,365,379$ 1,365,379$ -$ -$ 1,365,379$
Maintenance590Maintenance Super.& Engin.WP/B-1/2 90,517$ -$ 90,517$ 90,517$ -$ -$ 90,517$ Distribution
591 Maint. of Structures WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution592Maint. of Station Equipment WP/B-1/2 105,296$ -$ 105,296$ 105,296$ -$ -$ 105,296$ Distribution593Maint. of Overhead Lines WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution594Maint. of Underground Lines WP/B-1/2 652,676$ -$ 652,676$ 652,676$ -$ -$ 652,676$ Distribution595Maint. of Line Transformers WP/B-1/2 12,605$ -$ 12,605$ 12,605$ -$ -$ 12,605$ Distribution596Maint. of Street Lights WP/B-1/2 11,904$ -$ 11,904$ 11,904$ -$ -$ 11,904$ Distribution
597 Maint. of Meters WP/B-1/2 51,734$ -$ 51,734$ 51,734$ -$ -$ 51,734$ Distribution598Maint. of Misc. Dist. Plant.WP/B-1/2 3,558$ -$ 3,558$ 3,558$ -$ -$ 3,558$ DistributionSubtotal928,290$ -$ 928,290$ 928,290$ -$ -$ 928,290$
Total Distribution Expenses 2,562,101$ (268,432)$ 2,293,669$ 2,293,669$ -$ -$ 2,293,669$
Total Prod., Trans., & Dist. Expenses 5,473,111$ -$ 5,473,111$ 5,473,111$ 2,197,199$ 982,243$ 2,293,669$
Customer and Information Payroll Expenses
Customer Accounts Expenses901Supervision WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution902Meter Reading Expense WP/B-1/2 439,998$ -$ 439,998$ 439,998$ -$ -$ 439,998$ Distribution903Customer Records & Collect.WP/B-1/2 424,727$ -$ 424,727$ 424,727$ -$ -$ 424,727$ Distribution904Uncollectible Accounts WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution905Misc. Customer Account Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ DistributionSubtotal864,725$ -$ 864,725$ 864,725$ -$ -$ 864,725$
Cust. Service & Information Expense906Customer Svc. & Infor.WP/B-1/2 446,541$ -$ 446,541$ 446,541$ -$ -$ 446,541$ Distribution907SupervisionWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution908Customer Assistance WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution909Inform. & Instruct. Adv. Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution910Misc. Cust. Service & Inform.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution
Subtotal 446,541$ -$ 446,541$ 446,541$ -$ -$ 446,541$
Sales Expense911Supervision WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution912Demonstrating & Selling Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution913Advertising Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-3: Payroll ExpensesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
916 Misc. Sales Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ Distribution917Sales Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ DistributionSubtotal-$ -$ -$ -$ -$ -$ -$
Total Cust. Serv., Inform. & Sale Payroll Exp.1,311,266$ -$ 1,311,266$ 1,311,266$ -$ -$ 1,311,266$
Total O&M Payroll Expense Before Admin. & General 6,784,377$ -$ 6,784,377$ 6,784,377$ 2,197,199$ 982,243$ 3,604,935$
Administrative & General Payroll Expenses920Admin. & General Salaries WP/B-1/2 988,439$ -$ 988,439$ 988,439$ 320,117$ 143,106$ 525,215$ PAYXAG
921 Office Supplies WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA922Admin. Exp. Transferred WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA923Outside Services WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA924Property Insurance Exp.WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA925Injuries & Damages WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA926Pensions & Benefits WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA
927 Franchise Requirements WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA928Regulatory Commission WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA929Duplicate Charges WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA930Miscellaneous General Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA930.1 General Advertising Expense WP/B-1/2 268,237$ -$ 268,237$ 268,237$ -$ -$ 268,237$ DISTRIBUTION930.2 Miscellaneous General Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA931RentsWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA933Transportation Expense WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA935Maint. of General Plant WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NA
Total Admin. & General Payroll Expense 1,256,676$ -$ 1,256,676$ 1,256,676$ 320,117$ 143,106$ 793,452$
Total O&M Payroll Expense 8,041,053$ -$ 8,041,053$ 8,041,053$ 2,517,316$ 1,125,349$ 4,398,388$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/D-3/1: GEUS Engineering Labor Expense AdjustmentTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Copeland
Description Reference FERC Total Allocation to Allocation to Allocation to Allocation Schedule Account No Electric Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)
Engineering LaborDistributionOperation Super. & Engin. Total WP/B-1/2 580 806,043$ -$ 234,649$ 571,394$ TDPLTXGNL-GMisc. Distribution Expenses Total WP/B-1/2 588 116,045$ -$ 33,782$ 82,263$ TDPLTXGNL-G
AdjustmentDistributionOperation Super. & Engin.580 (234,649)$ Misc. Distribution Expenses 588 (33,782)$ TransmissionOperation Super. & Engin.560 -$ 234,649$ Misc. Transmission Expense 566 -$ 33,782$ Total Engineering Labor Adjustment -$ 268,432$ (268,432)$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-4 is not included in the TCOS Rate Filing Package InstructionsTransmission Cost of Service
GEUSPeriod Ending September 30, 2019
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule D-5: Summary of Exclusions from Reporting PeriodTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description FERC Account No.Reporting Period
Amount(1)(2)(3)
Legislative Advocacy:See Note (a)N/A -$
Total Legislative Advocacy -$
Penalties and Fines:See Note (a)N/A -$
Total Penalties and Fines -$
Other Exclusions:See Note (a)N/A -$
Total Other Exclusions -$
Social/Recreational/Religious:See Note (a)N/A -$
Total Social/Recreational/Religious -$
Political:
See Note (a)N/A -$
Total Political -$
Total Exclusions -$
Note (a): Items within each category of exclusions shall be listed separately byFERC Account No. as recorded during the reporting period.
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule E-1: Depreciation and Amortization ExpenseTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Depreciation
Steam Production310Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation311Structures and Improvements WP/B-1/3 3,710$ -$ 3,710$ 3,710$ 3,710$ -$ -$ Generation312Boiler Plant Equipment WP/B-1/3 317,712$ -$ 317,712$ 317,712$ 317,712$ -$ -$ Generation313Engines/Engine Driven Gen.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation314Turbogenerator Units WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation315Accessory Electric Equip.WP/B-1/3 38,848$ -$ 38,848$ 38,848$ 38,848$ -$ -$ Generation
316 Misc. Power Plant Equip.WP/B-1/3 64,549$ -$ 64,549$ 64,549$ 64,549$ -$ -$ GenerationTotal Steam Production 424,818$ -$ 424,818$ 424,818$ 424,818$ -$ -$
Nuclear Production320Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation321Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation
322 Reactor Plant Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation323Engines/Engine Driven Gen.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation324Turbogenerator Units WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation
325 Accessory Electric Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation326Misc. Power Plant Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ GenerationTotal Nuclear Production -$ -$ -$ -$ -$ -$ -$
Hydraulic Production330Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation331Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation332Reservoirs, Dams, and Waterways WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation333Water Wheels, Turbines, and Generators WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation334Accessory Electric Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation335Miscellaneous Power Plant Equip.WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation336Roads, Railroads, and Bridges WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ GenerationTotal Hydraulic Production -$ -$ -$ -$ -$ -$ -$
Other Production340Land & Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation
341 Structures and Improvements WP/B-1/3 126,278$ -$ 126,278$ 126,278$ 126,278$ -$ -$ Generation342Fuel Holder, Producer & Acc WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation343Prime Movers WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Generation
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule E-1: Depreciation and Amortization ExpenseTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
344 Generators WP/B-1/3 876,393$ -$ 876,393$ 876,393$ 876,393$ -$ -$ Generation345Accessory Plant Equipment WP/B-1/3 23,122$ -$ 23,122$ 23,122$ 23,122$ -$ -$ Generation346Misc. Power Plant Equipment WP/B-1/3 985$ -$ 985$ 985$ 985$ -$ -$ GenerationTotal Other Production 1,026,779$ -$ 1,026,779$ 1,026,779$ 1,026,779$ -$ -$
Subtotal Electric Production Plant 1,451,596$ -$ 1,451,596$ 1,451,596$ 1,451,596$ -$ -$
Electric Transmission Plant350Land and Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission
352 Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission353Station Equipment WP/B-1/3 & WP/E-1/1 137,497$ 11,397$ 148,895$ 148,895$ -$ 148,895$ -$ Transmission354Towers and Fixtures WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission
355 Poles and Fixtures WP/B-1/3 28,695$ -$ 28,695$ 28,695$ -$ 28,695$ -$ Transmission356O.H. Conductors & Devices WP/B-1/3 120,087$ -$ 120,087$ 120,087$ -$ 120,087$ -$ Transmission357Underground Conduit WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission
358 Underground Conductors WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Transmission359Roads and Trails WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ TransmissionSubtotal Electric Transmission Plant 286,280$ 11,397$ 297,677$ 297,677$ -$ 297,677$ -$
Electric Distribution Plant360Land and Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution
361 Structures and Improvements WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution362Station Equipment WP/B-1/3 & WP/E-1/1 159,265$ 45,989$ 205,254$ 205,254$ -$ -$ 205,254$ Distribution363Storage Battery Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution364Poles, Towers & Fixtures WP/B-1/3 141,897$ -$ 141,897$ 141,897$ -$ -$ 141,897$ Distribution365O.H. Conductors & Devices WP/B-1/3 128,454$ -$ 128,454$ 128,454$ -$ -$ 128,454$ Distribution366Underground Conduits WP/B-1/3 81,428$ -$ 81,428$ 81,428$ -$ -$ 81,428$ Distribution367U.G. Conductors & Devices WP/B-1/3 143,653$ -$ 143,653$ 143,653$ -$ -$ 143,653$ Distribution368Line Transformers WP/B-1/3 198,950$ -$ 198,950$ 198,950$ -$ -$ 198,950$ Distribution369ServicesWP/B-1/3 26,776$ -$ 26,776$ 26,776$ -$ -$ 26,776$ Distribution370MetersWP/B-1/3 87,924$ -$ 87,924$ 87,924$ -$ -$ 87,924$ Distribution371Install. on Customer Prem.WP/B-1/3 4,188$ -$ 4,188$ 4,188$ -$ -$ 4,188$ Distribution372Leased Prop. on Cust. Premises WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ Distribution373Street Lights WP/B-1/3 4,643$ -$ 4,643$ 4,643$ -$ -$ 4,643$ Distribution
Subtotal Electric Distribution Plant 977,179$ 45,989$ 1,023,167$ 1,023,167$ -$ -$ 1,023,167$
Electric General Plant
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule E-1: Depreciation and Amortization ExpenseTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
389 Land and Land Rights WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ NA390Structures and Improvements WP/B-1/3 & WP/E-1/1 183,452$ 100$ 183,552$ 183,552$ 59,445$ 26,575$ 97,532$ PAYXAG391Office Furniture & Equip.WP/B-1/3 32,821$ -$ 32,821$ 32,821$ 10,630$ 4,752$ 17,440$ PAYXAG392Transportation Equipment WP/B-1/3 168,448$ -$ 168,448$ 168,448$ 3,970$ 16,368$ 148,111$ TRANSPPLT-G393Stores Equipment WP/B-1/3 3,185$ -$ 3,185$ 3,185$ 680$ 182$ 2,323$ INV394Tools, Shop & Garage Equip.WP/B-1/3 754$ -$ 754$ 754$ 448$ 82$ 223$ PLTXGNL-N395Laboratory Equipment WP/B-1/3 13,247$ -$ 13,247$ 13,247$ 7,873$ 1,445$ 3,929$ PLTXGNL-N396Power Operated Equipment WP/B-1/3 18,635$ -$ 18,635$ 18,635$ 11,075$ 2,033$ 5,527$ PLTXGNL-N397Communication Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ PLTXGNL-N
398 Misc. Equipment WP/B-1/3 -$ -$ -$ -$ -$ -$ -$ NASubtotal Electric General Plant 420,541$ 100$ 420,641$ 420,641$ 94,121$ 51,436$ 275,085$
Total Depreciation 3,135,596$ 57,486$ 3,193,082$ 3,193,082$ 1,545,717$ 349,113$ 1,298,252$
Amortization
Amortization of Discount (Premium)WP/E-1/2 (65,388)$ (892,776)$ (958,164)$ (958,164)$ (539,251)$ (105,093)$ (313,820)$ PLTSVC-NTotal Amortization (65,388)$ (892,776)$ (958,164)$ (958,164)$ (539,251)$ (105,093)$ (313,820)$
Total Depreciation & Amortization 3,070,208$ (835,290)$ 2,234,917$ 2,234,917$ 1,006,466$ 244,020$ 984,432$
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WP/E-1/1: GEUS CWIP Adjustment to DepreciationTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Known Asset Life Annual
No.Schedule Adjustments Years Depreciation(1)(2)(3)(4)(5)(6)
Adjustment to Depreciation ExpenseTransmission353Station Equipment WP/B-4/1 376,115$ 33 11,397$ Distribution362 Station Equipment WP/B-4/1 1,517,621$ 33 45,989$ General Plant
390 Structures and Improvements WP/B-4/1 3,300$ 33 100$
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
WP/E-1/2: GEUS AmortizationTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Copeland
Series 2019AB Series 2019AB Prior Bonds TotalDescriptionPremiumDiscountAmortizationGEUS(1)(2)(3)(4)(5)
Amortization2020 (936,240)$ 58,512$ (80,436)$ (958,164)$
2019 2020DescriptionAmortizationAdjustmentAmortization(6)(7)(8)(8)
Amortization Adjustment (65,388)$ (892,776)$ (958,164)$
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Schedule E-2: Taxes Other Than Income TaxTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Taxes Other Than Income
Property Tax NA Payment in Lieu of Taxes WP/B-1/2 326,809$ -$ 326,809$ 326,809$ 183,927$ 35,845$ 107,037$ PLTSVC-N
Transfers to the CityNAGeneral Fund Transfer Fee (5%)WP/B-1/2 2,757,060$ -$ 2,757,060$ 2,757,060$ 1,687,994$ 221,030$ 848,036$ REV REQNABoard of Development Transfer Fee (1%)WP/B-1/2 627,387$ -$ 627,387$ 627,387$ 384,114$ 50,297$ 192,976$ REV REQ
NA Payroll Taxes (1)NA F.I.C.A.WP/B-1/2 379,194$ -$ 379,194$ 379,194$ 122,806$ 54,900$ 201,488$ PAYXAG
NA Unemployment WP/B-1/2 (7,524)$ -$ (7,524)$ (7,524)$ (2,437)$ (1,089)$ (3,998)$ PAYXAGNAMedicareWP/B-1/2 89,315$ -$ 89,315$ 89,315$ 28,926$ 12,931$ 47,458$ PAYXAG
Total Taxes Other Than Income Tax 4,172,241$ -$ 4,172,241$ 4,172,241$ 2,405,330$ 373,913$ 1,392,998$
(1) Payroll Taxes do not include labor tax that was capitalized
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Schedule E-3: Federal Income Taxes Transmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method
(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Federal Income Taxes
NA None N/A -$ -$ -$ -$ -$ -$ -$ NATotal Federal Income Taxes -$ -$ -$ -$ -$ -$ -$
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Schedule E-4: Other ExpensesTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Other ExpensesNone WP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NATotal Other Expenses -$ -$ -$ -$ -$ -$ -$
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Schedule E-5: Other Revenue Items (Credit)Transmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Other Revenues Off System Sales WP/B-1/2 GenerationWP/B-1/2 GenerationWP/B-1/2 GenerationWP/B-1/2 GenerationWP/B-1/2 GenerationTCOS Revenues WP/B-1/2 DistributionOther Billed Sales WP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionReimbursementsWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionOtherWP/B-1/2 DistributionWP/B-1/2 GenerationWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionWP/B-1/2 DistributionTotal Other Revenue Items, not Including Interest Income 16,215,073$ -$ 16,215,073$ 16,215,073$ 13,970,011$ -$ 2,245,062$
Interest Income WP/B-1/2 TOMWP/B-1/2 GENWP/B-1/2 NAWP/B-1/2 PLTSVC-NTotal Interest Income 438,405$ -$ 438,405$ 438,405$ 316,484$ 20,705$ 101,216$
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Schedule E-6: Wheeling Revenue under Existing ContractsTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Acct.Description Reference Total Adjustments/Total Allocation to Allocation to Allocation to Allocation to Allocation No.Schedule Electric Transfers Texas Generation Transmission Distribution Method(1)(2)(3)(4)(5)(6)(7)(8)(9)(10)(11)
Wheeling Revenue Under Existing ContractsNANoneWP/B-1/2 -$ -$ -$ -$ -$ -$ -$ NATotal Wheeling Revenue Under Existing Contracts -$ -$ -$ -$ -$ -$ -$
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Schedule F-1: Total Payroll Excluding A&G and Contract Labor (PAYXAG) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric(1)(2)(3)(4)(5)(6)
Total Payroll Schedule D-3 6,784,377$ 2,197,199$ 982,243$ 3,604,935$
PAYXAG Factor 32.4%14.5%53.1%
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Schedule F-2: Net Plant in Service (PLTSVC-N) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric(1)(2)(3)(4)(5)(6)
Net Plant in Service Schedules B-1, B-2, B-3, B-5 56,870,975$ 32,006,785$ 6,237,683$ 18,626,507$
PLTSVC-N Factor 56.3%11.0%32.8%
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Schedule F-3: Total O&M (TOM) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric(1)(2)(3)(4)(5)(6)
Operations & Maintenance Expense D-1 and D-2 42,130,549$ 30,974,683$ 1,812,764$ 9,343,101$ Total Taxes Other Than Income Tax E-2 4,172,241$ 2,405,330$ 373,913$ 1,392,998$ Total 46,302,790$ 33,380,013$ 2,186,677$ 10,736,099$
TOM Factor 72.1%4.7%23.2%
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Schedule F-4: Net Plant in Service excluding General Plant (PLTXGNL-N) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric(1)(2)(3)(4)(5)(6)
Gross Plant excluding General Plant Schedule B-1 92,489,700$ 51,920,021$ 11,810,356$ 28,759,324$ Accum Depreciation Schedule B-5 40,745,236$ 21,167,210$ 6,165,552$ 13,412,474$ Net Plant in Service 51,744,464$ 30,752,811$ 5,644,804$ 15,346,849$
PLTXGNL-N Factor 59.4%10.9%29.7%
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Schedule F-5: General Net Plant in Service (GNLPLT-N) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric(1)(2)(3)(4)(5)(6)
General Gross Plant in Service Schedules B-2 and B-3 10,889,178$ 2,737,340$ 1,348,291$ 6,803,547$ Accumulated Depreciation Schedule B-5 5,762,667$ 1,483,366$ 755,411$ 3,523,890$ Net Plant in Service 5,126,511$ 1,253,974$ 592,879$ 3,279,657$
GNLPLT-N Factor 24.5%11.6%64.0%
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Schedule F-6: Revenue Requirement (REVREQ) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric(1)(2)(3)(4)(5)(6)
Revenue Requirement A 41,247,176$ 25,253,339$ 3,306,733$ 12,687,103$
REVREQ Factor 61.2%8.0%30.8%
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Schedule F-7: Inventory (INV) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric Allocation(1)(2)(3)(4)(5)(6)(7)
InventoryGeneration WP/F-7/1 635,433$ 635,433$ -$ -$ DirectTransmissionWP/F-7/1 137,556$ -$ 137,556$ -$ DirectDistributionWP/F-7/1 2,092,357$ -$ -$ 2,092,357$ Direct
Transmission Distribution WP/F-7/1 110,155$ -$ 32,068$ 78,087$ TDPLTXGNL-GInventory (Materials & Supplies)WP/F-7/1 2,975,501$ 635,433$ 169,623$ 2,170,445$
INV Factor 21.4%5.7%72.9%
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WP/F-7/1: Allocation of Materials and SuppliesTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Item Item Item Generation Transmission Distribution T&DLocationDescriptionDescriptionUnits on Hand Value Related(1)(2)(3)(4)(5)(6)(7)(8)(9)
Total Materials & Supplies/Inventory as of 09/30/19 2,975,501$ 635,433$ 137,556$ 2,092,357$ 110,155$
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Schedule F-8: Transmission & Distribution Gross Plant in Service Excluding General Plant (TDPLTXGNL-G) Functionalization FactorTransmission Cost of Service
GEUSPeriod Ending September 30, 2019Witness: Copeland
Description Reference Total Generation Transmission DistributionScheduleT&D(1)(2)(3)(4)(5)(6)
Gross Plant excluding General Plant B-1 40,569,680$ -$ 11,810,356$ 28,759,324$
TDPLTXGNL-G Factor 0.0%29.1%70.9%
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Schedule F-9: Transportation Equipment Gross Plant (TRANSPPLT-G) Functionalization FactorTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric Allocation
(1)(2)(3)(4)(5)(6)(7)
Transportation Equipment Gross PlantAccount 9010 (Generation)WP/F-9/1 68,288$ 68,288$ -$ -$ GenerationAccount 9101 (Admin: Customer)WP/F-9/1 20,975$ -$ -$ 20,975$ Distribution
Account 9131 (Customer Service)WP/F-9/1 158,267$ -$ -$ 158,267$ DistributionAccount 9310 (Engineering)WP/F-9/1 120,587$ -$ 35,104$ 85,483$ TDPLTXGNL-GAccount 9314 (Trans Subs)WP/F-9/1 72,133$ -$ 72,133$ -$ Transmission
Account 9315 (Dist Subs)WP/F-9/1 85,342$ -$ -$ 85,342$ DistributionAccount 9324 (Trans Lines)WP/F-9/1 174,327$ -$ 174,327$ -$ TransmissionAccount 9325 (Dist Lines)WP/F-9/1 2,197,811$ -$ -$ 2,197,811$ Distribution
Total Transportation Gross Plant 2,897,729$ 68,288$ 281,564$ 2,547,878$
TRANSPPLT-G Factor 2.4%9.7%87.9%
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WP/F-9/1: Transportation Equipment DetailTransmission Cost of Service
GEUSPeriod Ending September 30, 2019
See Attached Workpaper
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Schedule F-10: Transportation Equipment Accumulated Depreciation (TRANSPPLT-AD) Functionalization FactorTransmission Cost of ServiceGEUSPeriod Ending September 30, 2019Witness: Schuepbach
Description Reference Total Generation Transmission DistributionScheduleElectric Allocation
(1)(2)(3)(4)(5)(6)(7)
Transportation Equipment Accumulated DepreciationAccount 9010 (Generation)WP/F-9/1 68,288$ 68,288$ -$ -$ GenerationAccount 9101 (Admin: Customer)WP/F-9/1 2,447$ -$ -$ 2,447$ Distribution
Account 9131 (Customer Service)WP/F-9/1 90,586$ -$ -$ 90,586$ DistributionAccount 9310 (Engineering)WP/F-9/1 65,934$ -$ 19,194$ 46,740$ TDPLTXGNL-GAccount 9314 (Trans Subs)WP/F-9/1 33,959$ -$ 33,959$ -$ TransmissionAccount 9315 (Dist Subs)WP/F-9/1 27,794$ -$ -$ 27,794$ DistributionAccount 9324 (Trans Lines)WP/F-9/1 160,177$ -$ 160,177$ -$ Transmission
Account 9325 (Dist Lines)WP/F-9/1 1,385,567$ -$ -$ 1,385,567$ DistributionTotal Transportation Accumulated Depreciation 1,834,751$ 68,288$ 213,330$ 1,553,133$
TRANSPPLT-AD Factor 3.7%11.6%84.7%
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PUC DOCKET NO. ___________________
APPLICATION OF GEUS TO CHANGE
RATES FOR WHOLESALE TRANSMISSION SERVICE
§
§ § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS
OF JILL A. SCHUEPBACH
Attachment JAS-3
Tariff for Wholesale Transmission Service
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GEUS Tariff for Electric Service Wholesale Transmission Service Effective Date: _________ Sheet No. 1 of 4 Revision Date: NA _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Availability
GEUS, a municipally owned electric utility owned by the City of Greenville, will make Wholesale Transmission Service
(Transmission Service) available at all points where GEUS’ transmission facilities contained within the Electric Reliability Council of Texas (ERCOT) have adequate capacity and suitable voltage and are available. Service under
this tariff is Wholesale service and is not available for retail service.
Applicability
Transmission Service is applicable to wholesale transactions involving wholesale purchase of electric power and
energy. This tariff for Transmission Service is applicable to Transmission Service using any transmission facilities owned by GEUS in accordance with PUC Substantive Rules 25.191-.203.
Type of Service
Three phase, 60 hertz alternating current, delivered onto, or received from GEUS’ transmission system at 60,000 volts or greater and on transmission facilities that have been prepared and made available for this service.
Conditions
As a condition to obtaining Transmission Service, the Transmission Service Customer shall meet all ERCOT requirements as specified in the ERCOT Protocols and Operating Guides. GEUS will provide Transmission Service to
any eligible Transmission Service Customer, subject to the terms and conditions hereof the Public Utility Commission of Texas (PUC) Substantive Rule 25.198, provided that:
(A) the eligible Transmission Service Customer has completed an Application for Transmission Service, as
provided under PUC Substantive Rule 25.198;
(B) the eligible Transmission Service Customer and GEUS, or a third party, have completed installation of all
equipment specified under the Interconnection Agreement, consistent with NERC and ERCOT guidelines as set forth in PUC Substantive Rule 25.198;
(C) the eligible Transmission Service Customer has executed an Interconnection Agreement for service under
this tariff or, if necessary, requested in writing that GEUS file a proposed unexecuted agreement with the PUC;
(D) the eligible Transmission Service Customer has arranged for Ancillary Services necessary for the transaction;
(E) each wholesale load for which Transmission Service is requested maintains a power factor of 95% or greater
at each point of interconnection;
(F) the Transmission Service Customer has constructed, maintains and operates the facilities on its side of each
point of interconnection that are necessary to reliably interconnect and deliver power from a resource to
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GEUS Tariff for Electric Service Wholesale Transmission Service Effective Date: _________ Sheet No. 1 of 4 Revision Date: NA _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
GEUS’ transmission system and from GEUS’ transmission system to the Transmission Service Customer’s
loads;
(G) to the extent the Transmission Service requires the addition of facilities or upgrades to the transmission
system, such facilities have been placed in service.
Pricing for Transmission Service Within ERCOT
Charges for Transmission Service hereunder shall be in accordance with Texas Utility Code § 35.004(d) and PUC
Substantive Rule 25.192. For Transmission Service a Transmission Service Customer shall incur both an access charge, as set forth below, and loss compensation charges.
Annual Access Fee $46.590 per MW of coincident peak demand
determined in accordance with PUC Substantive Rule 25.192.
Charges for each calendar year shall be adjusted pursuant to the schedule in the PUC’s Order approving the transmission charges for that year.
Pricing for Transmission Service for Exports from ERCOT
Charges for Transmission Service for exports from ERCOT shall be in accordance with Texas Utility Code § 35.004(d) and PUC Substantive Rule 25.192. Transmission Service Customers exporting power from ERCOT will be assessed
Transmission Service charges for the use of the ERCOT transmission system, based on the amount of power exported
and the duration of the transaction. Charges for Transmission Service for exports from ERCOT shall be determined in accordance with PUC Substantive Rule 25.192(e) and shall be calculated using the charges set forth below:
Monthly Rate (June – September) $11.648 per MW Monthly Rate (October – May) $3.883 per MW
Weekly Rate (June – September) $2.673 per MW
Weekly Rate (October – May) $0.896 per MW
Daily Rate (June – September) $0.382 per MW
Daily Rate (October – May) $0.128 per MW
Hourly Rate (June – September) $0.016 per MW Hourly Rate (October – May) $0.005 per MW
The Transmission Service Customer scheduling the export of power over a DC tie is solely responsible to GEUS for payment of these Transmission Service charges. Charges for use of the ERCOT transmission system for export
purposes monthly shall not exceed the annual transmission charge for the transaction. Wholesale exports from ERCOT are subject to the satisfaction of applicable requirements necessary to provide export service.
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GEUS Tariff for Electric Service Wholesale Transmission Service Effective Date: _________ Sheet No. 1 of 4 Revision Date: NA _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Losses
A Transmission Service Customer that uses Transmission Service shall compensate GEUS for losses resulting from such Transmission Service. Losses shall be calculated by the Independent System Operator (ISO) in accordance with
the method set forth in the ERCOT Protocols.
Reliability Guidelines
To maintain reliability of the ERCOT transmission grid, GEUS shall operate its transmission system in accordance with
ERCOT Protocols, ERCOT Operating Guides, NERC guidelines, and any other guidelines of the ISO that may apply to GEUS’ transmission system.
GEUS reserves the right, consistent with good utility practice and on a non-discriminatory basis, to interrupt
Transmission Service without liability on GEUS’ part for the purpose of making necessary adjustments to, changes in, or repairs to its lines, substations and other facilities, or where the continuance of Transmission Service would endanger
persons or property. In the event of any adverse condition or disturbance on GEUS’ system or any other system directly or indirectly interconnected with GEUS’ system, GEUS, consistent with Good Utility Practice, also may interrupt
Transmission Service on a non-discriminatory basis in order to limit the extent or damage of the adverse condition or
disturbance, to prevent damage to generating or transmission facilities, or to expedite restoration of service.
GEUS will give the Transmission Service Customer as much advance notice as is practicable in the event of such
interruption and shall restore service with due diligence.
The Transmission Service Customer’s failure to respond to established emergency load shedding and curtailment procedures to relieve emergencies on GEUS’ transmission system may result in the Transmission Service Customer
being deemed by GEUS to be in default and may result in the termination of Transmission Service.
Voltage Support
GEUS will provide whatever devices are necessary to maintain proper operating voltages on the GEUS transmission
system in accordance with good utility practice for voltage support and in accordance with the requirements of the ISO.
Construction of New Facilities
Should new facilities be required to accommodate a request for planned Transmission Service, GEUS will follow the
procedures set forth in the PUC Substantive Rules in working with the Transmission Service Customer to upgrade the transmission system. Upon receipt of a request for Transmission Service, ERCOT shall, if necessary, perform a system
security screening study to assess the ability of the existing transmission system to support the requested Transmission Service. If existing facilities are inadequate to support the requested Transmission Service, the Transmission Service
Customer may be required to provide a contribution in aid of construction of direct assignment facilities. In that event,
GEUS will provide the customer with a facilities study that will include an estimate of the contribution in aid of construction of direct assignment facilities to be charged to the Transmission Service Customer for the cost of any
required facilities or upgrades, and the time required to complete such construction and initiate requested service.
Payment
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GEUS Tariff for Electric Service Wholesale Transmission Service Effective Date: _________ Sheet No. 1 of 4 Revision Date: NA _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Any charges due to GEUS under this rate schedule shall be billed in accordance with PUC Substantive Rule 25.202.
Customers shall make payment to GEUS in a manner consistent with the procedures and deadlines set forth in PUC Substantive Rule 25.202. Any late payments by customers or customer defaults shall be handled in accordance with
PUC Substantive Rule 25.202.
Payment Netting
This Transmission Service rate is subject to orders entered by the PUC related to payment netting. Inter-utility charges
are based on the net annual payments prescribed in the PUC’s orders relating to netting of payments.
Agreement
An agreement for Transmission Service containing terms and provisions consistent with PUC Substantive Rules
25.191-.203 is required prior to commencement of such service. Such agreement will require approval of the GEUS Board of Directors.
Definitions
Capitalized terms shall have the meanings set forth in PUC Substantive Rules 25.5 and 25.191 .203.
Amendments to Rules
In the event PUC Substantive Rules 25.191-.203 are amended or if a new rule is adopted governing the subject matter of this tariff, this tariff shall, nevertheless, remain effective until the new tariff(s) filed pursuant to any such amendment(s)
or such new rules are approved, unless the amendment(s) or new rules or an agreement of the parties provide otherwise.
Rate Case Expense Surcharge
In addition to the Annual Access Fee, the Transmission Service Customer shall pay $0.0____ per MW per month for twenty four months or until the rate case expenses approved in Docket No. _____ are fully recovered.
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PUC DOCKET NO. ___________________
APPLICATION OF GEUS TO CHANGE
RATES FOR WHOLESALE TRANSMISSION SERVICE
§
§ § §
BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS
DIRECT TESTIMONY AND ATTACHMENTS
OF JILL A. SCHUEPBACH
Attachment JAS-3A
Tariff for Wholesale Transmission Service (redlined)
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GEUS
Tariff Forfor Electric Service
WHOLESALE TRANSMISSION SERVICE
Wholesale Transmission Service
Effective Date: _____, 2014_________
Sheet No. 1
Page 4 of 54
Revision Date: NA
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Docket No. _____
Availability
To eligible Transmission Service Customers for Wholesale Transmission Service through the transmission
system of the City of Greenville, whoseGEUS, a municipally owned electric utility operates under the name of
GEUS, owned by the City of Greenville, will make Wholesale Transmission Service (Transmission Service) available
at all points where GEUS’ transmission facilities ofcontained within the Electric Reliability Council of Texas (ERCOT)
have adequate capacity and suitable voltage and are available to provide. Service under this tariff is Wholesale
service, in accordance with Public Utility PUC of Texas (PUC) Substantive Rules 25.191-.203. and is not
available for retail service.
Application
Applicable onlyApplicability
Transmission Service is applicable to wholesale transactions involving the wholesale purchase of electric
power and energy.
This tariff for Wholesale Transmission Service is applicable to Transmission Service using any transmission facilities
owned by GEUS in accordance with PUC Substantive Rules 25.191-.203.
Type of Service
Three phase, 60 hertz alternating current, delivered onto, or received from GEUS’ transmission system at 60,000 volts
or greater and on transmission facilities that have been prepared and made available for this service.
Conditions
Transmission Service Requirements
As a condition to obtaining wholesale Transmission Service, the Transmission Service customers shall
comply with all requirements for initiating Transmission Service in accordance with PUC
Substantive Rule 25.198, including the execution of an Interconnection Agreement with each
Transmission Provider and the Transmission Service Customer shall meet all Electric Reliability
Council of Texas (ERCOT) requirements as specified in the ERCOT Protocols and Operating Guides.
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GEUS
Tariff Forfor Electric Service
WHOLESALE TRANSMISSION SERVICE
Wholesale Transmission Service
Effective Date: _____, 2014_________
Sheet No. 1
Page 4 of 54
Revision Date: NA
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GEUS Wholesale Transmission Service Tariff
Docket No. _____
Conditions Precedent for Receiving Service
Subject to the terms and conditions hereof and of PUC Substantive Rule 25.198, GEUS will provide
wholesale Transmission Service to any eligible Transmission Service Customer, subject to the terms and conditions
hereof the Public Utility Commission of Texas (PUC) Substantive Rule 25.198, provided that:
A. (A) the eligible Transmission Service Customer has completed an Application for Transmission
Service, as provided under PUC Substantive Rule 25.198;
B. (B) the eligible Transmission Service Customer and GEUS, or a third party, have completed
installation of all equipment specified under the Interconnection Agreement, consistent with NERC and
ERCOT guidelines as set forth in PUC Substantive Rule 25.198;
C. (C) the eligible Transmission Service Customer has executed an Interconnection Agreement for
service under this tariff or, if necessary, requested in writing that GEUS file a proposed unexecuted
agreement with the PUC;
D. (D) the eligible Transmission Service Customer has arranged for Ancillary Services necessary for the
transaction;
E. (E) each wholesale load for which wholesale Transmission Service is requested maintains a power
factor of 95% or greater at each point of interconnection;
F. (F) the Transmission Service Customer has constructed, maintains and operates the facilities on its
side of each point of interconnection that are necessary to reliably interconnect and deliver power from a
resource to GEUS’ transmission system and from GEUS’ transmission system to the Transmission Service
Customer’s loads; and
G. (G) to the extent the Transmission Service requires the addition of facilities or upgrades to the
transmission system, such facilities have been placed in service.
Application Procedures
GEUS and the Transmission Service Customer shall comply with the application procedures for
Transmission Services set forth in PUC Substantive Rule 25.198, which shall govern such
procedures.
Construction of New Facilities
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GEUS
Tariff Forfor Electric Service
WHOLESALE TRANSMISSION SERVICE
Wholesale Transmission Service
Effective Date: _____, 2014_________
Sheet No. 1
Page 4 of 54
Revision Date: NA
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Docket No. _____
Construction of new facilities needed to accommodate a request for Transmission Service shall be
in accordance with the procedures set forth in PUC Substantive Rule 25.198. Upon receipt of a
request for Transmission Service, GEUS shall, if necessary, perform a System Security Study in
accordance with PUC Substantive Rule 25.198. Based on the results of the System Security Study,
GEUS may also perform Facilities Study, in accordance with PUC Substantive Rule 25.198. An
executed Facilities Study agreement with the Transmission Service Customer is required prior to
GEUS performing a Facilities Study. In the event that existing facilities are inadequate to support
the requested Transmission Service, GEUS may require the Transmission Service Customer to
provide a contribution in aid of construction attributable to directly assigned facilities.
Load Shedding and Curtailment
Transmission Service hereunder shall be subject to, and GEUS and the Transmission Service
Customer will comply with, the load shedding and curtailment procedures established under PUC
Substantive Rule 25.200. Any interruption shall be based on operational factors and shall not
accord a higher priority to GEUS’ retail and wholesale customers than to its customers taking
Transmission Service. Service to all customers shall be restored as quickly as possible.
Pricing for Transmission Service Within ERCOT
Charges for Transmission Service hereunder shall be in accordance with Texas Utility Code § 35.004(d).) and PUC
Substantive Rule 25.192. For Transmission Service a Transmission Service Customer shall incur both an access
charge, as set forth below, and loss compensation charges.
The Annual Access Fee – $0.03609 $46.590 per kWMW of coincident peak demand
determined in accordance with PUC Substantive Rule
25.192.
Charges for each calendar year shall be adjusted pursuant to the schedule in the PUC’s Order approving the
transmission changescharges for that year.
Pricing for Transmission Service for Exports from ERCOT
Charges for Transmission Service for exports from ERCOT shall be in accordance with Texas Utility Code § 35.004(d)
and PUC Substantive Rule 25.192. Transmission Service Customers exporting power from ERCOT will be assessed
an access chargeTransmission Service charges for the use of the ERCOT transmission system, based on the amount
of power exported and the duration of the service requestedtransaction. Charges for Transmission Service for
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GEUS
Tariff Forfor Electric Service
WHOLESALE TRANSMISSION SERVICE
Wholesale Transmission Service
Effective Date: _____, 2014_________
Sheet No. 1
Page 4 of 54
Revision Date: NA
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Docket No. _____
exports from ERCOT shall be determined in accordance with PUC Substantive Rule 25.192(e) and shall be calculated
using the charges set forth below:
Service Type
Access Rate
per kW of
Peak Demand
Monthly On-Peak $0.00902
Monthly Off-Peak $0.00301
Monthly Rate (June – September) $11.648 per MW
Monthly Rate (October – May) $3.883 per MW
Weekly Rate (June – September) $2.673 per MW
Weekly Rate (October – May) $0.896 per MW
Daily Rate (June – September) $0.382 per MW
Daily Rate (October – May) $0.128 per MW
Hourly Rate (June – September) $0.016 per MW
Hourly Rate (October – May) $0.005 per MW
The Transmission Service Customer scheduling the export of power over a DC tie is solely responsible to GEUS for
payment of these Transmission Service charges. Charges for use of the ERCOT transmission system for export
purposes monthly shall not exceed the annual transmission charge for the transaction. Wholesale exports from ERCOT
are subject to the satisfaction of applicable requirements necessary to provide export service.
Losses
A Transmission Service Customer that uses Transmission Service shall compensate GEUS for losses resulting from
such Transmission Service. Losses shall be calculated by the Independent System Operator (ISO) in accordance with
the methodsmethod set forth in the ERCOT Protocols.
Reliability Guidelines
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GEUS
Tariff Forfor Electric Service
WHOLESALE TRANSMISSION SERVICE
Wholesale Transmission Service
Effective Date: _____, 2014_________
Sheet No. 1
Page 4 of 54
Revision Date: NA
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GEUS Wholesale Transmission Service Tariff
Docket No. _____
To maintain reliability of the ERCOT transmission grid, GarlandGEUS shall operate its transmission system in
accordance with ERCOT Protocols, ERCOT Operating Guides, NERC Guidelinesguidelines, and any other guidelines
of the ISO that may apply to GEUS’ transmission system.
GEUS reserves the right, consistent with good utility practice and on a non-discriminatory basis, to interrupt
Transmission Service without liability on GEUS’ part for the purpose of making necessary adjustments to, changes in,
or repairs to its lines, substations and other facilities, or where the continuance of Transmission Service would endanger
persons or property. In the event of any adverse condition or disturbance on GEUS’ system or any other system
directly or indirectly interconnected with GEUS’ system, GEUS, consistent with Good Utility Practice, also may interrupt
Transmission Service on a non-discriminatory basis in order to limit the extent or damage of the adverse condition or
disturbance, to prevent damage to generating or transmission facilities, or to expedite restoration of service.
GEUS will give the Transmission Service Customer as much advance notice as is practicable in the event of such
interruption, and shall restore service with due diligence.
The Transmission Service Customer’s failure to respond to established emergency load shedding and curtailment
procedures to relieve emergencies on GEUS’ transmission system may result in the Transmission Service Customer
being deemed by GEUS to be in default and may result in the termination of Transmission Service.
Voltage Support
GEUS will provide whatever devices are necessary to maintain proper operating voltages on the GEUS transmission
system in accordance with good utility practice for voltage support and in accordance with the requirements of the ISO.
Construction of New Facilities
Should new facilities be required to accommodate a request for planned Transmission Service, GEUS will follow the
procedures set forth in the PUC Substantive Rules in working with the Transmission Service Customer to upgrade the
transmission system. Upon receipt of a request for Transmission Service, ERCOT shall, if necessary, perform a system
security screening study to assess the ability of the existing transmission system to support the requested Transmission
Service. If existing facilities are inadequate to support the requested Transmission Service, the Transmission Service
Customer may be required to provide a contribution in aid of construction of direct assignment facilities. In that event,
GEUS will provide the customer with a facilities study that will include an estimate of the contribution in aid of
construction of direct assignment facilities to be charged to the Transmission Service Customer for the cost of any
required facilities or upgrades, and the time required to complete such construction and initiate requested service.
Payment
Any charges due to GEUS under this rate schedule shall be billed in accordance with PUC Substantive Rule 25.202.
Customers shall make payment to GEUS in a manner consistent with the procedures and deadlines set forth in PUC
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GEUS
Tariff Forfor Electric Service
WHOLESALE TRANSMISSION SERVICE
Wholesale Transmission Service
Effective Date: _____, 2014_________
Sheet No. 1
Page 4 of 54
Revision Date: NA
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
GEUS Wholesale Transmission Service Tariff
Docket No. _____
Substantive Rule 25.202. Any late payments by customers or customer defaults shall be handled in accordance with
PUC Substantive Rule 25.202.
Payment Netting
This Rate for Wholesale Transmission Service rate is subject to orders entered by the PUC relatingrelated
to payment netting.
Inter-utility charges are based on the net annual payments prescribed in the PUC’s orders relating to netting of
payments.
Agreement
An agreement for Transmission Service containing terms and provisions consistent with PUC Substantive Rules
25.191-.203 is required prior to commencement of such service. Such agreement will require approval of the GEUS
Board of Directors.
Definitions
Capitalized terms shall have the meanings set forth in PUC Substantive Rules 25.5 and 25.191-. .203.
AmendmentAmendments to Rules
In the event PUC Substantive Rules 25.191-.203 are amended or if a new rule is adopted governing the subject matter
of this tariff, this tariff shall, nevertheless, remain effective until the new tariff(s) filed pursuant to any such amendment(s)
or such new rules are approved, unless the amendment(s) or new rules or an agreement of the parties provide
otherwise.
Rate Case Expense Surcharge
In addition to the Annual Access Fee, the Transmission Service Customer shall pay $0.0597740____ per MW per
month for twenty four months or until the rate case expenses approved in Docket No. _____ are fully recovered.
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PUC DOCKET NO. _________
APPLICATION OF BRYAN TEXAS
UTILITIES FOR INTERIM UPDATE OF
WHOLESALE TRANSMISSION RATES
§
§
§
PUBLIC UTILITY COMMISSION
OF TEXAS
TABLE OF CONTENTS
DESCRIPTION PAGE(S)
Application.....................................................................................................................................2-6
Exhibit A, Form of Notice .....................................................................................................7
Testimony
Direct Testimony of Jill A. Schuepbach ...........................................................................8-22
Exhibit JAS-1 Resume and Record of Testimony ...........................................................23-27
Exhibit JAS-2 Tariff for Wholesale Transmission Service (Redlined) ...........................28-33
Schedules and Workpapers
Schedules and Workpapers ..............................................................................................34-45
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PUC DOCKET NO. _______
APPLICATION OF BRYAN TEXAS
UTILITIES FOR INTERIM UPDATE OF
WHOLESALE TRANSMISSION RATES
§
§
§
PUBLIC UTILITY COMMISSION
OF TEXAS
APPLICATION OF
BRYAN TEXAS UTILITIES
TO THE HONORABLE PUBLIC UTILITY COMMISSION:
The City of Bryan, Texas, operating its municipally owned utility under the name Bryan
Texas Utilities (BTU), a transmission service provider (TSP) in the ERCOT region, files this
Application for Interim Update of Wholesale Transmission Rates pursuant to 16 Texas
Administrative Code (TAC) § 25.192(h)(1) and the Commission’s Interim TCOS Filing
Package, and respectfully shows the following:
I.
BACKGROUND AND AUTHORITY
BTU seeks an interim revision to its previously approved transmission cost of service
(TCOS) and wholesale transmission rate pursuant to, and consistent with, the requirements of the
Public Utility Commission of Texas (“Commission” or “PUC”) as set out in 16 TAC
§ 25.192(g)-(h), and the Filing Requirements For Interim Update of Wholesale Transmission
Rates Pursuant to Substantive Rule 25.193(a)(1)1 (the “Interim TCOS Filing Package”).
A transmission service provider “may apply to update its transmission rates on an interim
basis not more than twice per calendar year to reflect changes in its invested capital.”2
Proceedings pursuant to this rule are not intended to determine the reasonableness of the interim
costs.3 Rather, the rule provides that the Commission “shall review whether the costs of
1 Now 16 TAC § 25.192(h)(1).
2 16 TAC § 25.192(h)(1).
3 See 16 TAC § 25.192(g)(1).
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transmission plant additions are reasonable and necessary at the next complete review of the
TSP’s transmission cost of service.”4
II.
BTU’S FILING
With this Application, BTU files the Direct Testimony of Jill A. Schuepbach, as well as
the Interim TCOS Filing Package Schedules and Workpapers. BTU’s notice is attached as
Exhibit A and discussed in Section V below.
III.
COSTS INCLUDED IN BTU’S INTERIM TCOS UPDATE
BTU’s last TCOS was approved in Docket No. 48123,5 which used plant balances as of
December 31, 2017. This Application compares the actual September 30, 2020 transmission net
plant balances with the December 31, 2017 net plant balances established in Docket No. 48123.
The difference between these two balances constitutes the change in BTU’s rate base
documented in this Application.
IV.
RELIEF REQUESTED
The requested increase in total transmission rate base in this filing is $32,200,967 (see
Schedule B), with a total annual wholesale transmission revenue requirement increase of
$6,571,542 (see Schedule A). BTU further requests that the Commission approve an interim
update to its wholesale transmission rate of $0.511284 per kilowatt (see Schedule A).
BTU requests that this interim update to its wholesale transmission rate be effective as
soon as possible and no later than 60 days after the filing of the original Application, consistent
4 See 16 TAC § 25.192(g)(2).
5 Application of Bryan Texas Utilities for Interim Update of Wholesale Transmission Rates, Docket No. 48123,
Notice of Approval (Apr. 24, 2018).
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with 16 TAC § 25.192(h)(4)(C).6 Section 25.192(h)(2) specifically removes from this proceeding
any consideration or determination of whether the costs included in BTU’s Application are
reasonable and necessary.7 Because such determinations are reserved for a later proceeding, the
issues in this docket are very limited and it should be processed expeditiously.
V.
NOTICE AND PROCESSING
BTU will provide written notice pursuant to 16 TAC § 25.192(h)(4)(A) to all parties in
the last complete review of BTU’s TCOS,8 and to all of the distribution service providers listed
in the last docket in which the Commission set the annual transmission service charges for
ERCOT (Docket No. 50333).9 Such notice will be provided in the form attached as Exhibit A.
Upon completion of the notice described above, BTU will file an affidavit attesting to the
provision of such notice within a reasonable time and by such date as may be established by the
presiding officer.
BTU requests that the Commission docket this application upon receipt and issue an
order establishing an intervention deadline and requiring Commission Staff to comment on the
material sufficiency of the Application. Consistent with 16 TAC § 25.192(h)(4)(A), BTU
6 16 TAC § 25.192(h)(4)(C) provides that, if an application meets the requirements for informal disposition, the
presiding officer shall issue a notice of approval within 60 days of the date a materially sufficient application is
filed. There is also precedent for a shorter time frame for processing such applications. See Application of Texas
New Mexico Power Company for Interim Update of Wholesale Transmission Rates Pursuant to P.U.C. Subst. R.
§25.192(h)(1), Docket No. 40674 (Sept. 27, 2012) (Notice of Approval issued 35 days after application filed);
Application of Oncor Electric Delivery Company LLC for Interim Update of Wholesale Transmission Rates
Pursuant to Subst. R. § 25.192(h)(1), Docket No. 40603 (Aug. 29, 2012) (Notice of Approval issued 33 days after
application filed); Application of Brazos Electric Cooperative, Inc. for Interim Update of Wholesale Transmission
Rates Pursuant to P.U.C. Subst. R. 25.192(h), Docket No. 40465 (Jun. 6, 2012) (Notice of Approval issued 30 days
after application filed); Application of Brazos Electric Cooperative, Inc. for Interim Update of Wholesale
Transmission Rates Pursuant to P.U.C. Subst. R. 25.192(h), Docket No. 38822 (Nov. 22, 2010) (Notice of Approval
issued 35 days after application filed).
7 16 TAC § 25.192(h)(2).
8 Application of Bryan Texas Utilities to Change Rates for Wholesale Transmission Service, Docket No. 22616,
Final Order (May 9, 2001).
9 Commission Staff’s Petition to Set 2020 Wholesale Transmission Service Charges for the Electric Reliability
Council of Texas, Docket No. 50333, Order (May 1, 2020).
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requests that the intervention deadline be set 21 days from the date service of notice is
completed. BTU intends to serve notice by December 16, 2020, thus the intervention deadline in
this case should be January 6, 2021. If no timely requests to intervene are filed, BTU requests
that this Application be processed and approved informally pursuant to 16 TAC § 22.35,
consistent with 16 TAC § 25.192(h)(4)(C). In the alternative, and to the extent the Commission
determines such is necessary, BTU requests the scheduling of a prehearing conference as soon as
possible to address the processing of this docket.
To the extent the relief requested herein is contested in a manner that would prevent the
implementation of BTU’s request within 60 days of filing the Application, BTU respectfully
requests an opportunity for hearing, pursuant to 16 TAC § 22.125(c), to establish that good cause
exists for the Commission to grant BTU interim relief. In such event, BTU further requests
expedited treatment of this Application to permit the Commission to issue an interim order and
then a final order as expeditiously as possible thereafter.
VI.
PRAYER
WHEREFORE, PREMISES CONSIDERED, BTU respectfully requests that the
Commission: approve BTU’s Application and filing package; expeditiously order an interim
adjustment to BTU’s annual revenue requirement to a total of $36,291,373 (an increase of
$6,571,542); approve an interim wholesale transmission rate of $0.511284 per kilowatt effective
within 60 days of the filing of this Application; and grant such other and further relief to which
BTU may show itself entitled.
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Respectfully submitted,
Carl Galant
State Bar No. 24050633
Travis Vickery
State Bar No. 00794790
MCGINNIS LOCHRIDGE LLP
600 Congress Avenue, Suite 2100
Austin, Texas78701
(512) 495-6083
(512) 505-6383 FAX
cgalant@mcginnislaw.com
ATTORNEYS FOR BRYAN TEXAS UTILITIES
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EXHIBIT A
NOTICE OF RATE CHANGE REQUEST
On December 15, 2020, Bryan Texas Utilities (BTU) filed its Application for Interim
Update of Wholesale Transmission Rates pursuant to 16 Texas Administrative Code (TAC)
§25.192(h). BTU’s Application seeks an interim adjustment to the previously approved
transmission cost of service and wholesale transmission rate due to transmission investment in
excess of the level currently authorized in rates. If approved, BTU’s total rate base will increase
by $32,200,967, resulting in a total interim transmission cost of service revenue requirement
increase of $6,571,542 above the level currently in rates. BTU’s interim wholesale transmission
rate will increase to $0.511284 per kilowatt. BTU has requested that the proposed transmission
rate be implemented as soon as possible.
Because the Application requests a revision to BTU’s wholesale transmission rate to
reflect changes in its invested capital, affected customers include all distribution service
providers who pay wholesale transmission charges pursuant to 16 TAC § 25.192.
A complete copy of BTU’s Application is available for inspection at the offices of
McGinnis Lochridge, LLP, 600 Congress Ave., Suite 2100, Austin, Texas 78701.
Persons who wish to intervene in or comment upon these proceedings should notify the
Public Utility Commission of Texas as soon as possible, as an intervention deadline will be
imposed. 16 TAC § 25.192(h)(4)(A) establishes an intervention deadline of 21 days from the
date service of notice is completed. A request to intervene or for further information should be
made to the Public Utility Commission of Texas, P.O. Box 13326, Austin, Texas 78711-3326
and reference Docket No. _______________. Further information may also 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.
Bryan Texas Utilities
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PUC DOCKET NO. ______
APPLICATION OF BRYAN TEXAS
UTILITIES FOR INTERIM UPDATE OF
WHOLESALE TRANSMISSION RATES
§
§
§
§
PUBLIC UTILITY COMMISSION
OF TEXAS
DIRECT TESTIMONY
OF
JILL A. SCHUEPBACH
ON BEHALF OF
BRYAN TEXAS UTILITIES
DECEMBER 14, 2020
8
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PUC DOCKET NO. XXXXX
APPLICATION OF BRYAN TEXAS
UTILITIES FOR INTERIM UPDATE OF
WHOLESALE TRANSMISSION RATES
§
§
§
PUBLIC UTILITY COMMISSION
OF TEXAS
DIRECT TESTIMONY OF
JILL A. SCHUEPBACH
TABLE OF CONTENTS
Page
I.INTRODUCTION AND QUALIFICATIONS .............................................................1
II.REVENUE REQUIREMENT: SCHEDULE A ............................................................3
III.TRANSMISSION PROJECTS ......................................................................................5
IV.RATE BASE: SCHEDULES B, B-1, AND B-5 .........................................................10
V.DEPRECIATION EXPENSE: SCHEDULE E-1 ........................................................11
VI.PAYMENT IN LIEU OF TAXES: SCHEDULE F-1 .................................................11
VII.UPDATED WHOLESALE TRANSMISSION RATE ...............................................12
VIII.SUMMARY AND RECOMMENDATIONS..............................................................12
ATTACHMENTS
Attachment JAS-1 Resume and Record of Testimony
Attachment JAS-2 Tariff for Wholesale Transmission Service
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DIRECT TESTIMONY 1 JILL A. SCHUEPBACH
I.INTRODUCTION AND QUALIFICATIONS1
Q.PLEASE STATE YOUR NAME, BUSINESS ADDRESS, AND CURRENT2
EMPLOYMENT POSITION.3
A.My name is Jill A. Schuepbach. I am an Executive Consultant in the Energy Practice4
of NewGen Strategies and Solutions, LLC (“NewGen”). My business address is 2255
Union Blvd., Suite 305, Lakewood, Colorado 80228. NewGen is a consulting firm that6
specializes in utility rates, engineering economics, financial accounting, asset7
valuation, appraisals, and business strategy for electric, natural gas, water, and8
wastewater utilities.9
Q.PLEASE OUTLINE YOUR FORMAL EDUCATION.10
A.I have a Master of Business Administration degree from the University of Colorado,11
and a Bachelor of Science in Mechanical Engineering from the University of Missouri.12
In addition to my undergraduate and graduate degrees, I am a registered Professional13
Engineer in the state of Colorado.14
Q.PLEASE DESCRIBE YOUR PROFESSIONAL EXPERIENCE.15
A.I am an Executive Consultant in NewGen’s Energy Practice. I have been employed by16
NewGen since September 2012. Prior to joining NewGen, I was employed by R. W.17
Beck, Inc., and its successor (SAIC Energy, Environment & Infrastructure, Inc.) since18
2001. Prior to joining R. W. Beck, I was employed by Black & Veatch from 199819
through 2001.20
I have more than 20 years of experience in economic analyses for the energy, water,21
and natural gas industries. My work includes various assignments for private industry,22
local governments, and utilities, including financial and economic analyses, cost of23
service and rate studies, engineer of record, and pole attachment fees. I have been24
10
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DIRECT TESTIMONY 2 JILL A. SCHUEPBACH
extensively involved in the development of unbundled cost of service and pricing 1
models during my career. Attachment JAS-1 to this testimony provides a summary of 2
my qualifications. 3
Q. HAVE YOU TESTIFIED BEFORE ANY REGULATORY COMMISSIONS? 4
A. Yes. I submitted testimony to the Florida Public Service Commission and the Public 5
Utility Commission of Texas (“PUC” or “Commission”) as shown in my resume and 6
record of testimony included as Attachment JAS-1. 7
Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 8
A. I am testifying on behalf of Bryan Texas Utilities (“BTU”), which is a municipally 9
owned electric utility serving the citizens of Bryan, Texas. 10
Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 11
A. The purpose of my testimony is to support BTU’s application for an Interim Update of 12
its wholesale transmission rates pursuant to 16 Texas Administrative Code (“TAC”) 13
§ 25.192(h)(1) and the Interim Transmission Cost of Service Rate Filing Package 14
(“Interim-TCOS-RFP”). 15
Q. WERE THE SCHEDULES AND TARIFF PREPARED BY YOU OR UNDER 16
YOUR DIRECT SUPERVISION? 17
A. Yes. 18
Q. WHAT SOURCE DOCUMENTS WERE USED TO PREPARE THE 19
SCHEDULES CONTAINED IN THIS INTERIM UPDATE? 20
A. BTU financial reports for fiscal years ending September 30, 2018, 2019, and 2020 were 21
used to prepare the schedules. 22
11
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DIRECT TESTIMONY 3 JILL A. SCHUEPBACH
Q.IS THIS THE TYPE OF INFORMATION THAT EXPERTS IN THIS FIELD 1
WOULD NORMALLY RELY UPON?2
A.Yes.3
Q.DO BTU’S BOOKS AND RECORDS COMPLY WITH THE INTERIM TCOS4
RATE FILING INSTRUCTIONS?5
A.Yes. The TCOS rate filing package for non-investor owned utilities requires an6
applicant to utilize the system of accounts prescribed by the Federal Energy Regulatory7
Commission (“FERC”) chart of accounts or the chart of accounts prescribed by the8
municipal governing body. BTU’s books and records reflect the chart of accounts9
prescribed by the City of Bryan and are consistent with the FERC system of accounts.10
II.REVENUE REQUIREMENT: SCHEDULE A11
Q.PLEASE DESCRIBE THE COSTS INCLUDED IN BTU’S REVENUE12
REQUIREMENT.13
A.According to 16 TAC § 25.192(h)(1), an Electric Reliability Council of Texas14
(“ERCOT”) transmission service provider may update its wholesale transmission rate15
to “reflect the addition and retirement of transmission facilities and include appropriate16
depreciation, federal income tax and other associated taxes, and the Commission-17
authorized rate of return on such facilities as well as changes in loads.” BTU’s Interim18
Update includes the appropriate depreciation expense and Commission-authorized rate19
of return on net plant additions, as well as associated taxes.20
12
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DIRECT TESTIMONY 4 JILL A. SCHUEPBACH
The interim transmission revenue requirement BTU is requesting is $36,291,373, 1
which is an increase of $6,571,542 since BTU’s last interim transmission rate filing in 2
Docket No. 48123.1 3
Q. PLEASE SUMMARIZE THE RATE OF RETURN CALCULATION. 4
A. BTU’s approved rate of return was set in Docket No. 226162 at 11.71% of the rate base. 5
Applying the approved rate of return to the proposed rate base of $175,575,711 results 6
in a return of $20,559,916 as shown in Schedule B. 7
Q. PLEASE SUMMARIZE YOUR RESULTS. 8
A. Based on the allowances pursuant to 16 TAC § 25.192(h)(1), BTU’s transmission 9
revenue requirement as requested in this application is $36,291,373, compared to 10
$29,719,831 as approved by the Commission in Docket No. 48123. This is an increase 11
of $6,571,542 or 22.1%. 12
Based on the 2019 ERCOT average four coincident peak (“4CP”) load of 70,981 MW,3 13
the resulting BTU Wholesale Transmission Rate is $51.1284 per MW per year, 14
compared to the current rate of $44.1779 per MW per year. In Table 1 below, I show 15
a comparison of BTU’s 2020 TCOS with the BTU TCOS the Commission approved in 16
Docket 48123. 17
18
1 Application of Bryan Texas Utilities for Interim Update of Wholesale Transmission Rates, Docket No. 48123,
Notice of Approval (Apr. 24, 2018) (“Docket No. 48123”).
2 Application of Bryan Texas Utilities to Change Rates for Wholesale Transmission Service, Docket No. 22616,
Final Order (May 9, 2001) (“Docket No. 22616”).
3 Commission Staff’s Petition to Set 2020 Wholesale Transmission Service Charges for the Electric Reliability
Council of Texas, Inc., Docket No. 50333, Final Order (May 1, 2020) (“Docket No. 50333”).
13
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DIRECT TESTIMONY 5 JILL A. SCHUEPBACH
Table 1
BTU Transmission Cost of Service
Item
Docket No. 48123
Approved 2018
Current
Application
2020 Increase ($) Increase (%)
Rate Base (Invested Capital) $143,374,744 $175,575,711 $32,200,967 22.5%
Return on Rate Base 11.71% 11.71% $0 0.0%
Return $16,789,183 $20,559,916 $3,770,733 22.5%
O&M Expense $706,683 $706,683 $0 0.0%
Depreciation Expense $5,540,013 $6,862,890 $1,322,877 23.9%
Taxes Other Than Income $6,683,954 $8,161,885 $1,477,932 22.1%
Return $16,789,183 $20,559,916 $3,770,733 22.5%
Less Other Revenues $0 $0 $0 0.0%
Revenue Requirement $29,719,831 $36,291,373 $6,571,542 22.1%
Access Fee ($/MW) $44.1779 $51.1284 $6.950 15.7%
III.TRANSMISSION PROJECTS1
Q.PLEASE DESCRIBE THE TRANSMISSION PROJECTS INCLUDED IN2
BTU’S INTERIM UPDATE.3
A.Generally, BTU’s interim TCOS update includes the addition of transmission facilities4
at or above 60 kilovolts (“kV”) placed into service between December 31, 2017 and5
September 30, 2020. Specifically, BTU’s Interim Update includes the following6
transmission projects totaling an increase in gross plant of $45,786,203:7
Steele Store Substation 138 kV Bus Addition: BTU added a 138 kV ring bus to8
serve the existing Steele Store Substation. The station was converted from a 69 kV9
radial source to a 138 kV future looped system as part of the West System bulk10
electric system plan. The addition was placed into service in September 2020. A11
14
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DIRECT TESTIMONY 6 JILL A. SCHUEPBACH
certificate of convenience and necessity (“CCN”) was not required for this 1
substation project. The substation addition underwent independent review by 2
ERCOT. 3
Snook to Steele Store 138 kV Line: BTU designed and constructed a 138 kV 4
transmission line to improve reliability on the west side of BTU’s system. This is 5
a portion of the project to complete the 138 kV loop around the west side of BTU’s 6
system, which underwent independent review by ERCOT. The line was placed into 7
service in September 2020. This municipally owned utility project did not require 8
a CCN. 9
Rodgers Substation: BTU designed and constructed Rodgers Substation to replace 10
the existing Nall Lane Substation. Rodgers Substation was constructed as a 69 kV 11
ring bus to improve reliability in the inner-city load area and to provide additional 12
capacity to serve existing and future electric load. The substation was placed into 13
service in August 2020. A CCN was not required for this substation project. The 14
substation addition did not undergo independent review by ERCOT. 15
Annex 138 kV Transmission Loop-in: BTU reconstructed a section of an existing 16
69 kV transmission line to 138 kV standards to accommodate the new Leonard 17
Road Substation. The project is part of the future 138 kV line from Steele Store to 18
Atkins closing the West System. The project was placed into service in April 2020. 19
This municipally owned utility project did not require a CCN. The project did not 20
undergo independent review by ERCOT. 21
Graham Substation: BTU constructed a new 138 kV ring bus station and looped in 22
an existing 138 kV BTU transmission line to accommodate a new College Station 23
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DIRECT TESTIMONY 7 JILL A. SCHUEPBACH
distribution substation serving College Station customers. The project was placed 1
into service in May 2020. A CCN was not required for this substation project. The 2
project did not undergo independent review by ERCOT. 3
Texas Department of Transportation (“TxDOT”) FM 2818: BTU designed and4
reconstructed a section of 138 kV underground conductor to provide clearance for5
the TxDOT road work along FM 2818 between Luther Street and George Bush6
Drive. The underground cable capacity was increased to provide for future loading7
of the south side of BTU’s system. Optical ground wire (“OPGW”) was installed8
as shield wire to provide for better system reliability. The project was placed into9
service in May 2020. This municipally owned utility project did not require a CCN10
and did not undergo independent review by ERCOT.11
Greens Prairie to South Switch OPGW Installation: BTU added OPGW static to12
allow for removal of the existing fiber optic cable from the communications zone.13
The project was placed into service in December 2019. The project did not require14
a CCN and did not undergo independent review by ERCOT.15
Mobile Substation Driveway Access: BTU built new access roads into six16
transmission substations to allow for large equipment movement into and out of the17
substations. The projects were placed into service on various dates throughout18
2019. The projects did not require a CCN and did not undergo independent review19
by ERCOT.20
Nall Lane 69 kV Breaker Replacement: BTU replaced the old 69 kV oil circuit21
breaker with a new 69 kV SF6 circuit breaker. This ensures against oil spills and22
increases system reliability with a faster fault clearing breaker. The project was23
16
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DIRECT TESTIMONY 8 JILL A. SCHUEPBACH
placed into service in September 2018. The project did not require a CCN and did 1
not undergo independent review by ERCOT. 2
Atkins Switcher Upgrade: BTU installed a new Capacitor Switching device to3
replace a switch that had reached the end of its life and was not designed for4
capacitor switch operations. The project was placed into service in July 2018. The5
project did not require a CCN and did not undergo independent review by ERCOT.6
The capital expenditures associated with these facilities were not included in BTU’s 7
transmission rate base in its last rate proceedings in Docket No. 48123. 8
Q.ARE THESE PROJECTS DEEMED TRANSMISSION AS DESCRIBED IN 169
TAC § 25.192(C)(1)?10
A.Yes. All of these projects are transmission facilities based on the description in 1611
TAC § 25.192(c)(1). It is my understanding from the information provided by BTU12
staff that the nature and purpose of the projects included in this Interim Update were to13
meet anticipated load growth, ensure system reliability, and improve operational14
efficiency.15
Q.DESCRIBE THE TRANSMISSION PLANT RETIREMENTS INCLUDED IN16
BTU’S INTERIM UPDATE.17
A.BTU’s Interim Update includes transmission plant retirements totaling $1,170,681.18
These retirements are primarily a result of rebuilds and replacements associated with19
the projects described above. The retirements are identified below by account number.20
Account 353 Station Equipment retirements include:21
•The original circuit switchers for capacitor banks at Atkins Substation.22
•The transformer and 69 kV breaker at the Nall Substation.23
17
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DIRECT TESTIMONY 9 JILL A. SCHUEPBACH
• The 69 kV switch at the Briarcrest Substation. 1
•The remote terminal unit (“RTU”) at the Business Park Substation.2
•RTU at the South Switch Substation.3
Account 355 Pole and Fixture retirements include:4
•The transmission poles at Industrial Park and 28th Street.5
Account 356 Overhead Conductors and Devices retirements include:6
•The transmission poles associated with the TxDOT overhead to underground7
project.8
Account 357 Underground Conduit retirements include:9
•A duct bank associated with the TxDOT overhead to underground project.10
Account 358 Underground Conductors and Devices retirements include:11
•An underground cable associated with the TxDOT overhead to underground12
project.13
Q.PURSUANT TO GENERAL INSTRUCTION NO. 2 IN THE INTERIM-TCOS-14
RFP, ARE THE TRANSMISSION PROJECTS INCLUDED IN BTU’S15
INTERIM UPDATE LOCAL?16
A.Yes. The transmission projects included in BTU’s Interim Update are local. The17
projects are located within Brazos County and the surrounding counties to which BTU18
provides electric service.19
Q.PURSUANT TO GENERAL INSTRUCTION NO. 2 IN THE INTERIM-TCOS-20
RFP, ARE THE TRANSMISSION PROJECTS INCLUDED IN BTU’S21
INTERIM UPDATE CURRENTLY USED AND USEFUL?22
18
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DIRECT TESTIMONY 10 JILL A. SCHUEPBACH
A.Yes. As of September 30, 2020, the transmission projects included in BTU’s Interim 1
Update are completed, in service, and used and useful to the public. 2
Q.ARE ALL OF THE TRANSMISSION FACILITIES IDENTIFIED ABOVE3
INCLUDED IN THE PLANT IN SERVICE ACCOUNTS REFLECTED IN4
BTU’S BOOKS AND RECORDS?5
A.Yes.6
IV.RATE BASE: SCHEDULES B, B-1, AND B-57
Q.PLEASE DISCUSS THE INCREASE IN BTU’S GROSS TRANSMISSION8
PLANT INCLUDED IN THIS INTERIM UPDATE.9
A.The transmission plant increase included in the Interim Update is the difference in the10
transmission plant from BTU’s last interim transmission rate filing in 2018,11
Docket No. 48123, and the transmission plant as reflected in BTU’s September 30,12
2020 financial reports. The gross transmission plant in this filing is $226,911,509,13
which is an increase of $45,786,203.14
Q.PLEASE EXPLAIN THE INCREASE IN ACCUMULATED DEPRECIATION15
BALANCE AS SHOWN ON SCHEDULE B-5.16
A.The increase in the accumulated depreciation balance on Schedule B-5 is the difference17
between the approved accumulated depreciation balance in Docket No. 48123 and the18
accumulated depreciation from BTU’s September 30, 2020 financial reports. The19
transmission accumulated depreciation in this filing is $52,286,595, which is an20
increase of $13,585,236.21
Q.WHAT IS THE INCREASE IN NET TRANSMISSION PLANT?22
19
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DIRECT TESTIMONY 11 JILL A. SCHUEPBACH
A.The net transmission plant, including allocated general plant, in this filing is1
$174,624,914 as shown on Schedule B. This is an increase of $32,200,967 from Docket2
No. 48123.3
V.DEPRECIATION EXPENSE: SCHEDULE E-14
Q.PLEASE EXPLAIN HOW THE INCREASE IN DEPRECIATION EXPENSE IN5
THIS INTERIM UPDATE WAS CALCULATED.6
A.Pursuant to General Instruction No. 5 in the Interim-TCOS-RFP, the depreciation rates7
accepted by this Commission in BTU’s last full transmission rate filing, Docket8
No. 22616, were applied to the transmission plant additions included in the Interim9
Update to determine the increase in depreciation expense. This calculation is shown10
on Schedule E-1.11
VI.PAYMENT IN LIEU OF TAXES: SCHEDULE F-112
Q.PLEASE EXPLAIN THE CALCULATION OF OTHER TAXES ON13
SCHEDULE F-1.14
A.Pursuant to Commission 16 TAC § 25.192(h)(1), the Interim Update allows for15
inclusion of the increase in other associated taxes because of the increase in16
transmission plant additions. BTU’s payment in lieu of tax (“PILOT”) has increased17
because of plant additions. To determine the transmission portion of the PILOT, an18
effective rate was calculated based on the transmission PILOT approved in Docket19
No. 22616 divided by the transmission revenue requirement approved in that docket.20
The effective PILOT rate was applied to the transmission revenue requirement,21
excluding the PILOT component, which resulted in a transmission PILOT increase of22
$1,477,932 for BTU’s transmission system.23
20
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DIRECT TESTIMONY 12 JILL A. SCHUEPBACH
VII.UPDATED WHOLESALE TRANSMISSION RATE1
Q.PLEASE EXPLAIN THE WHOLESALE TRANSMISSION SERVICE RATE2
CALCULATION.3
4
5
6
7
8
A.The requested wholesale transmission service rate for BTU is equal to BTU’s updated
transmission revenue requirement as shown in Schedule A divided by the most recent
ERCOT 4CP of 70,981 MW pursuant to Docket No. 50333. BTU’s requested annual
access wholesale transmission rate is $511.284 per average 4CP MW.
VIII.SUMMARY AND RECOMMENDATIONS
B.PLEASE SUMMARIZE THIS INTERIM-TCOS-RFP.9
A.In this filing, BTU requests approval of additions to and retirements from its10
transmission assets that occurred from January 1, 2018 through September 30, 2020.11
This Interim Update application includes schedules supporting gross plant in service,12
accumulated depreciation, depreciation expense, taxes other than income, and return13
on rate base. Since BTU’s previous Interim Update in 2018, Docket No. 48123, BTU’s14
invested transmission capital has increased.15
Q.WHAT DO YOU RECOMMEND?16
A.Pursuant to Commission 16 TAC § 25.192(h)(1), BTU is eligible for an update to its17
wholesale transmission service rates. This is BTU’s first request for an interim update18
in 2020. BTU has followed the provisions of the General Instructions for the Interim19
Update rate filing and Commission 16 TAC § 25.192(h)(1). The transmission plant20
additions included in the Interim Update are used and useful. I recommend the PUC21
approve BTU’s rate tariff as attached in Exhibit JAS-2 as filed.22
Q.DOES THAT CONCLUDE YOUR TESTIMONY?23
A.Yes.24
21
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STATE OF COLORADO
COUNTY OF JEFFERSON
BEFORE ME, the undersigned authority, on this day personally appeared Jill A.
Schuepbach who, having been placed under oath by me, did depose as follows:
My name is Jill A. Schuepbach. I am of legal age and a resident of the State of
Colorado. The foregoing testimony and exhibits offered by me, and the opinions stated therein
are, to the best of my knowledge and belief, accurate, true, and correct.
Ji fA. Schuepbach
SUBSCRIBED AND SWORN TO BEFORE ME by the said Jill Schuepbach on this
day of December, 2020.
JENNIFER AGNES GIBBONS NOTARY PUBLIC STATE OF COLORADO NOTARY ID 20144006259 MY COMMISSION EXPIRES FEBRUARY 6,2022
DIRECT TESTIMONY
NZry— 5fate otColorado
13 JILL A. SCHUEPBACH
22
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Jill Schuepbach
Executive Consultant
jschuepbach@newgenstrategies.net
Economics | Strategy | Stakeholders | Sustainability
www.newgenstrategies.net
Jill Schuepbach has been providing financial expertise to the utility industry for over 20 years. She has proven project
management and analytical skills in the areas of utility cost of service and rate design, financial planning, economic
and financial analysis, engineer of record, and pole attachment fees. In addition, Ms. Schuepbach has experience
with feasibility studies, litigation support, and preparing expert witness testimony. Her project experience includes
work for municipal, investor-owned, and member-owned utility clients.
EDUCATION
Master of Business Administration, University of Colorado
Bachelor of Science in Mechanical Engineering, University of Missouri
PROFESSIONAL REGISTRATIONS / CERTIFICATIONS
Registered Professional Engineer (PE), Colorado
KEY EXPERTISE
Cost of Service and Rate Design
Project Financing
Engineer of Record
Economic and Financial Analysis
Litigation Support
Pole Attachment Fees
RELEVANT EXPERIENCE
Financial Forecasts, Cost of Service and Rate Design
Ms. Schuepbach has assisted with numerous utility financial forecasts, cost of service, and rate design projects.
Financial Forecast tasks include developing models to balance capital spending and rate increases, support
compliance with debt covenants, and assist with general short-term and long-term decision making. Cost of Service
tasks include the development of the revenue requirement, functionalization and classification of costs, and
allocation of costs to customer classes. Rate Design tasks include a review of existing customer class criteria, design,
tariff development and transitioning of models for the client’s future use. Additional analyses include the evaluation
of miscellaneous charges and fees based on the utility’s costs and local and state policy. She has assisted with
training and workshops regarding cost of service and rate design theory, industry practice and rate strategies to
governing bodies and boards. She has also presented rate study results and provided financial recommendations to
governing bodies, boards, and city councils.
She has performed electric, natural gas, and photovoltaic cost of service. Her efforts have also included support in
contract negotiations in developing a rate to serve a large industrial load and unbundled transmission costs.
Exhibit JAS-1
23
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Jill Schuepbach
Executive Consultant
Thoughtful Decision Making for Uncertain Times 2
Ms. Schuepbach’s clients for cost of service and rate design services include:
Brownsville Public Utilities Board, Texas
Bryan Texas Utilities, Texas
Estes Park, Colorado
Farmington Electric Utilities System, New
Mexico
Glendale Water and Power, California
GEUS, Texas
Lafayette Public Power Authority, Louisiana
Lafayette Utilities System, Louisiana
Loup Power District, Nebraska
Navajo Tribal Utility Authority, Arizona
She has also evaluated energy consumption profiles, billing accuracy, base operations, contract terms, rate options,
asset / facility upgrades (e.g., energy efficiency/demand response), distributed generation options, and tenant billing
recovery for the US Army.
Transmission Revenue Requirement Compliance Filings
Ms. Schuepbach has assisted with multiple transmission rate filings at the Regional Transmission Organization (RTO)
level and at Federal Energy Regulatory Commission (FERC) regarding Annual Transmission Revenue Requirements
(ATRR), and methodologies for determining rates. Ms. Schuepbach’s clients include:
Bryan Texas Utilities, Texas
GEUS, Texas
City of Garland Power and Light, Texas
Independence Power & Light, Missouri
Engineer of Record and Consulting Engineer Reports
Ms. Schuepbach assists in the development of Consulting Engineer Reports and associated ordinance required
reviews for municipal utilities. These reviews typically require an annual assessment of the utilities’ financial and
physical operations for the duration of the bond period. The field review typically includes a determination of the
condition of the physical assets of the utility, which also includes a review of the utilities budgeting and planning
process. Ms. Schuepbach’s project experience includes:
Lafayette Utilities System, Louisiana Lafayette Public Power Authority, Louisiana
Economic and Financial Analysis
Ms. Schuepbach has provided economic analyses for municipal utilities involving generation projects. These
evaluations included reviewing the costs and operation of new generation units added to the existing generation
resources and the economic analysis of the proposed generation on retail rates.
Ms. Schuepbach assisted with the allocation of Hoover Power in Arizona, which included technical advice, reviewing
customer applications for completion and accuracy and scenario analysis of the potential hydro power allocations.
Her clients have included:
Arizona Power Authority, Arizona
Brownsville Public Utilities Board, Texas
City of Bryan, Texas
Lafayette Utilities System, Louisiana
Litigation Support
Ms. Schuepbach has assisted in litigation support and preparation of expert witness testimony in Texas, Louisiana,
Missouri, and Indiana. Her testimony support is related to revenue requirements, cost of service and rate design as
24
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Jill Schuepbach
Executive Consultant
3 Thoughtful Decision Making for Uncertain Times
well as the proper allocation of generation costs given a systems’ unique characteristics. Ms. Schuepbach’s litigation
support clients include:
Brownsville Public Utility Board, Texas: Docket
Nos. 38556 & 32905
Bryan Texas Utilities, Texas: Docket Nos. 44467
and 41920
GEUS: Texas’ Dockets Nos. 45281 and 37180
Independence Power & Light, Missouri; Docket
No. ER15-1499-001
Lafayette Utilities System, Louisiana; Docket
No. 00994490
Northern Indiana Public Service Company,
Indiana; Cause Nos. 44688, 44733, 45159
Indiana Michigan Power Company, Indiana,
Cause No. 45235
Pole Attachment Fees
Ms. Schuepbach has developed pole attachment fees for several clients. She has employed various methodologies
including those recommended by the Federal Communications Commission (FCC) and the American Public Power
Association (APPA). She has recommended rates for cable and communications companies based on the type of
poles to which they are attached. Her work also includes a review of the contract or agreement between the utility
and the customer. Her projects include:
Farmington Electric Utilities System, New
Mexico
Keys Energy Services
Navajo Tribal Utility Authority, Arizona
Navopache Electric Cooperative
WORKSHOPS AND PRESENTATIONS
Ms. Schuepbach has given industry presentations focused on cost of service and ratemaking. Host organizations and
the topics Ms. Schuepbach presented include:
Electric Utility Consultants, Inc.
Introduction to Cost of Service Concepts and
Techniques for Electric Utilities
Introduction to Rate Design for Electric Utilities
California Public Utilities Commission
Cost of Service Concepts for Electric Utilities
25
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Record of Litigation Support and Testimony: Jill Schuepbach
Testimony
Utility Proceeding Subject Before Client Date
1.Orlando Utilities
Commission
Docket No.
010142
Demand Side Management Florida Public Service Commission Orlando Utilities Commission 2001
2.GEUS Docket No.
51556
Application to Change Rates for Wholesale
Transmission Service: Full Filing
Public Utility Commission of Texas GEUS (Greenville, Texas) 2020
26
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Record of Litigation Support and Testimony: Jill Schuepbach
Litigation Support
Utility Proceeding Subject Before Client Date
1.Indiana Michigan Power
Company
Cause No.
45235
Petition of Indiana Michigan Power Company for
authority to increase its rates and charges for electric
utility service.
Indiana Utility Regulatory
Commission
City of Fort Wayne, City of Marion, and
Marion Municipal Utilities
2019
2.Northern Indiana Public
Service Company
Cause No.
45159
Rate Case: Cost of Service, Rate Design and new
Industrial Rate Structure
Indiana Utility Regulatory
Commission
United States Steel 2019
3.Bryan Texas Utilities Docket No.
48123
Application of Bryan Texas Utilities for Interim Update of
Wholesale Transmission Rates Pursuant to Substantive
Rule 25.192(g)(1)
Public Utility Commission of Texas Bryan Texas Utilities 2018
4.Northern Indiana Public
Service Company
Cause No.
44733-TDSIC
Transmission, Distribution, and Storage System
Improvement Charge
Indiana Utility Regulatory
Commission
United States Steel 2016
5.Northern Indiana Public
Service Company
Cause No.
44688
Rate Case: Cost of Service, Rate Design and
Interruptible Demand Credits
Indiana Utility Regulatory
Commission
United States Steel 2016
6.City of Independence (MO)
Power and Light
Docket No.
ER15-1499-
001
Annual Transmission Revenue Requirement within SPP Federal Energy Regulatory
Commission
City of Independence (MO) Power and
Light
2015
7.Bryan Texas Utilities Docket No.
44467
Application to Change Rates for Wholesale
Transmission Service: Interim Filing
Public Utility Commission of Texas Bryan Texas Utilities 2015
8.GEUS Docket No.
42581
Application to Change Rates for Wholesale
Transmission Service: Full Filing
Public Utility Commission of Texas GEUS (Greenville, Texas) 2014
9.Bryan Texas Utilities Docket No.
41920
Application to Change Rates for Wholesale
Transmission Service: Interim Filing
Public Utility Commission of Texas Bryan Texas Utilities 2013
10.Brownsville Public Utilities
Board
Docket No.
38556
Application to Change Rates for Wholesale
Transmission Service: Full Filing
Public Utility Commission of Texas Brownsville Public Utilities Board 2010
11.GEUS Docket No.
37180
Application to Change Rates for Wholesale
Transmission Service: Full Filing
Public Utility Commission of Texas GEUS (Greenville, Texas) 2009
12.Entergy Gulf States, Inc.Docket No.
00994490
Expropriation of Electric Distribution Facilities 15th Judicial District Court, Parish of
Lafayette, Louisiana
Lafayette Utilities System 2006
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CITY OF BRYAN
TARIFF FOR ELECTRIC SERVICE
WHOLESALE TRANSMISSION SERVICE
Effective Date: April 24, 2018________, 2021 Sheet No. 1
Revised: April 13, 2018 Revision: 98
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City of Bryan - Wholesale Transmission Service Tariff
Availability
To eligible Transmission Service Customers for Wholesale Transmission Service through the
transmission system of the City of Bryan, whose municipally owned electric utility operates under
the name of Bryan Texas Utilities (BTU), at all points where transmission facilities of adequate
capacity and suitable voltage are available to provide service, in accordance with Public Utility
Commission of Texas (PUC) Substantive Rules 25.191-.203.
Application
Applicable only to wholesale transactions involving the wholesale purchase of electric power and
energy.
This tariff for Wholesale Transmission Service is applicable to Transmission Service using any
transmission facilities owned by BTU in accordance with PUC Substantive Rules 25.191-.203.
Type of Service
Three phase, 60 hertz alternating current, delivered onto or received from BTU’s transmission
system at 60,000 volts or greater and on transmission facilities that have been prepared and made
available for this service.
Transmission Service Requirements
As a condition to obtaining wholesale Transmission Service, the Transmission Service Customer
shall comply with all requirements for initiating Transmission Service in accordance with PUC
Substantive Rule 25.198, including the execution of an Interconnection Agreement with each
Transmission Provider, and the Transmission Service Customer shall meet all Electric Reliability
Council of Texas (ERCOT) requirements as specified in the ERCOT Protocols and Operating
Guides.
Exhibit JAS-2
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CITY OF BRYAN
TARIFF FOR ELECTRIC SERVICE
WHOLESALE TRANSMISSION SERVICE
Effective Date: April 24, 2018________, 2021 Sheet No. 1
Revised: April 13, 2018 Revision: 98
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City of Bryan - Wholesale Transmission Service Tariff
Conditions Precedent for Receiving Service
Subject to the terms and conditions hereof and of PUC Substantive Rule 25.198, BTU will provide
wholesale Transmission Service to any eligible Transmission Service Customer, provided that:
(A)the eligible Transmission Service Customer has completed an Application for
Transmission Service, as provided under PUC Substantive Rule 25.198;
(B)the eligible Transmission Service Customer and BTU, or a third party, have
completed installation of all equipment specified under the Interconnection
Agreement, consistent with NERC and ERCOT guidelines as set forth in PUC
Substantive Rule 25.198;
(C)the eligible Transmission Service Customer has executed an Interconnection
Agreement for service under this tariff or, if necessary, requested in writing that BTU
file a proposed unexecuted agreement with the Commission;
(D)the eligible Transmission Service Customer has arranged for Ancillary Services
necessary for the transaction;
(E)each wholesale load for which wholesale Transmission Service is requested
maintains a power factor of 95% or greater at each point of interconnection;
(F)the Transmission Service Customer has constructed, maintains and operates the
facilities on its side of each point of interconnection that are necessary to reliably
interconnect and deliver power from a resource to BTU’s transmission system and
from BTU’s transmission system to the Transmission Service Customer’s loads;
(G)to the extent the Transmission Service requires the addition of facilities or upgrades
to the transmission system, such facilities have been placed in service.
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CITY OF BRYAN
TARIFF FOR ELECTRIC SERVICE
WHOLESALE TRANSMISSION SERVICE
Effective Date: April 24, 2018________, 2021 Sheet No. 1
Revised: April 13, 2018 Revision: 98
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City of Bryan - Wholesale Transmission Service Tariff
Application Procedures
BTU and the Transmission Service Customer shall comply with the application procedures for
Transmission Services set forth in PUC Substantive Rule 25.198, which shall govern such
procedures.
Construction of New Facilities
Construction of new facilities needed to accommodate a request for Transmission Service shall be
in accordance with the procedures set forth in PUC Substantive Rule 25.198. Upon receipt of a
request for Transmission Service, BTU shall, if necessary, perform a System Security Study in
accordance with PUC Substantive Rule 25.198. Based on the results of the System Security Study,
BTU also may perform a Facilities Study, in accordance with PUC Substantive Rule 25.198. An
executed Facilities Study agreement with the Transmission Service Customer is required prior to
BTU performing a Facilities Study. In the event that existing facilities are inadequate to support the
requested Transmission Service, BTU may require the Transmission Service Customer to provide a
contribution in aid of construction attributable to directly assigned facilities.
Load Shedding and Curtailment
Transmission Service hereunder shall be subject to, and BTU and the Transmission Service
Customer will comply with, the load shedding and curtailment procedures established under PUC
Substantive Rule 25.200. Any interruption shall be based on operational factors and shall not accord
a higher priority to BTU’s retail and wholesale customers than to its customers taking Transmission
Service. Service to all customers shall be restored as quickly as possible.
Pricing for Transmission Service Within ERCOT
Charges for Transmission Service hereunder shall be in accordance with Texas Utility Code
§35.004(d). For Transmission Service a Transmission Service Customer shall incur both an access
charge, as set forth below, and loss compensation charges.
Annual Access Fee – $441.779511.284 / MW of coincident peak demand determined
in accordance with PUC Substantive Rule 25.192. I
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CITY OF BRYAN
TARIFF FOR ELECTRIC SERVICE
WHOLESALE TRANSMISSION SERVICE
Effective Date: April 24, 2018________, 2021 Sheet No. 1
Revised: April 13, 2018 Revision: 98
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City of Bryan - Wholesale Transmission Service Tariff
Charges for each calendar year shall be adjusted pursuant to the schedule in the PUC’s Order
approving the transmission charges for that year.
Pricing for Transmission Service for Exports from ERCOT
Charges for Transmission Service for exports from ERCOT shall be in accordance with Texas Utility
Code § 35.004(d) and PUC Substantive Rule 25.192. Transmission Service Customers exporting
power from ERCOT will be assessed transmission service charges for the use of the ERCOT
transmission system, based on the amount of power actually exported and the duration of the
transaction. Charges for Transmission Service for exports from ERCOT shall be determined in
accordance with PUC Substantive Rule 25.192(e) and shall be calculated using the charges set forth
below:
Monthly Rate (June – September)
Monthly Rate (October – May)
$110.445127.821 per MW
$36.81542.607 MW
Weekly Rate (June – September)
Weekly Rate (October – May)
$25.34829.336 per MW
$8.4969.832 per MW
Daily Rate (June – September)
Daily Rate (October – May)
$3.6214.191 per MW
$1.2101.401 per MW
Hourly Rate (June – September)
Hourly Rate (October – May)
$0.1510.175 per MW
$0.0500.058 per MW
The Transmission Service Customer scheduling the export of power over a DC tie is solely
responsible to BTU for payment of these transmission service charges. Charges for use of the ERCOT
transmission system for export purposes on a monthly basis shall not exceed the annual transmission
charge for the transaction. Wholesale exports from ERCOT are subject to the satisfaction of
applicable requirements necessary to provide export service.
Losses
Losses shall be calculated by the Independent System Operator (ISO) in accordance with the method
set forth in the ERCOT Protocols.
I
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CITY OF BRYAN
TARIFF FOR ELECTRIC SERVICE
WHOLESALE TRANSMISSION SERVICE
Effective Date: April 24, 2018________, 2021 Sheet No. 1
Revised: April 13, 2018 Revision: 98
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City of Bryan - Wholesale Transmission Service Tariff
Reliability Guidelines
To maintain reliability of the ERCOT transmission grid, BTU shall operate its transmission system
in accordance with ERCOT Protocols, ERCOT Operating Guides, NERC guidelines, and any other
guidelines of the ISO that may apply to BTU’s transmission system.
BTU reserves the right, consistent with good utility practice and on a non-discriminatory basis, to
interrupt Transmission Service without liability on BTU’s part for the purpose of making necessary
adjustments to, changes in, or repairs to its lines, substations and other facilities, or where the
continuance of Transmission Service would endanger persons or property. In the event of any
adverse condition or disturbance on BTU’s system or any other system directly or indirectly
interconnected with BTU’s system, BTU, consistent with Good Utility Practice, also may interrupt
Transmission Service on a non-discriminatory basis in order to limit the extent or damage of the
adverse condition or disturbance, to prevent damage to generating or transmission facilities, or to
expedite restoration of service.
BTU will give the Transmission Service Customer as much advance notice as is practicable in the
event of such interruption and shall restore service with due diligence.
The Transmission Service Customer’s failure to respond to established emergency load shedding
and curtailment procedures to relieve emergencies on BTU’s transmission system may result in the
Transmission Service Customer being deemed by BTU to be in default and may result in the
termination of Transmission Service.
Payment
Any charges due to BTU under this rate schedule shall be billed in accordance with PUC Substantive
Rule 25.202. Customers shall make payment to BTU in a manner consistent with the procedures
and deadlines set forth in PUC Substantive Rule 25.202. Any late payments by customers or
customer defaults shall be handled in accordance with PUC Substantive Rule 25.202.
Agreement
An agreement for Transmission Service containing terms and provisions consistent with PUC
Substantive Rules 25.191-.203 is required prior to commencement of such service. Such agreement
will require approval of the City Council of Bryan.
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CITY OF BRYAN
TARIFF FOR ELECTRIC SERVICE
WHOLESALE TRANSMISSION SERVICE
Effective Date: April 24, 2018________, 2021 Sheet No. 1
Revised: April 13, 2018 Revision: 98
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City of Bryan - Wholesale Transmission Service Tariff
Definitions
Capitalized terms shall have the meanings set forth in PUC Substantive Rules 25.5 and 25.191-.203.
Amendments to Rules
In the event PUC Substantive Rules 25.191-.203 are amended or if a new rule is adopted governing
the subject matter of this tariff, this tariff shall, nevertheless, remain effective until the new tariff(s)
filed pursuant to any such amendment(s) or such new rules are approved, unless the amendment(s)
or new rules or an agreement of the parties provide otherwise.
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DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule A (Interim): Summary of Interim Wholesale Transmission Cost of ServiceInterim Wholesale Transmission Cost of ServiceBryan Texas Utilities (BTU)Updated to September 30, 2020DescriptionTotalInterimInterimReferenceApprovedAnnual RevenueScheduleDocket 48123Increase Requirement(1)(2) (3) = (1) + (2)Revenue RequirementOperation & Maintenance $706,683$0 $706,683 Docket 22616Depreciation and Amortization$5,540,013 $1,322,877 $6,862,890 Schedule E-1Taxes Other Than Income Taxes $6,683,954 $1,477,932 $8,161,885 Schedule F-1Federal Income Tax $0$0$0Return on Rate Base$16,789,183 $3,770,733 $20,559,916 Schedule BTotal Revenue Requirement$29,719,831 $6,571,542 $36,291,373Other Revenues $0$0$0Docket 22616Total Revenue Requirement$29,719,831 $6,571,542 $36,291,373ERCOT AVERAGE 4 CP (kW) 67,273,101 70,980,872 Dockets 47777 and 50333Wholesale Rate $/kW$0.441779$0.511284DescriptionTariff RateTariff Rate$/kW$/MW(4)(5)Transmission Service within ERCOTAnnual Rate per kW0.511284$ 511.284$ Monthly Rate per kW 0.042607$ 42.607$ Transmission Service Exported from ERCOTMonthly Rates On-Peak 0.127821$ 127.821$ Monthly Rates Off-Peak 0.042607$ 42.607$ Weekly Rates On-Peak 0.029336$ 29.336$ Weekly Rates Off-Peak 0.009832$ 9.832$ Daily Rates On-Peak 0.004191$ 4.191$ Daily Rates Off-Peak 0.001401$ 1.401$ Hourly Rates On-Peak 0.000175$ 0.175$ Hourly Rates Off-Peak 0.000058$ 0.058$ 34DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B (Interim): Summary of Interim Wholesale Transmission Rate Base Interim Wholesale Transmission Rate BaseBryan Texas Utilities (BTU)Updated to September 30, 2020Total BalanceIncrease inReferenceDescriptionApprovedas of end of Rate Base &SchedulesDocket 48123update periodReturn(1)(2)(3) = (2) - (1)Direct Assigned:FERC Accounts 350 - 362Original Plant In Service$181,125,306$226,911,509$45,786,203B-1(Accumulated Depreciation)($38,701,358)($52,286,595)($13,585,236) B-5Net Plant In Service$142,423,947$174,624,914$32,200,967Allocated Plant Accounts- Net *$436,032$436,032$0 Docket 22616CWIP *$0$0$0 Docket 22616Working Capital *$514,765$514,765$0 Docket 22616Plant Held for Future Use *$0$0$0 Docket 22616Reserve for Insurance *$0$0$0 Docket 22616Other *$0$0$0 Docket 22616Total Rate Base$143,374,744$175,575,711$32,200,967Rate of Return *11.71%11.71%11.71% Docket 22616Return on Rate Base$16,789,183$20,559,916$3,770,73335DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-1 (Interim): Change in Gross PlantInterim Wholesale Transmission PlantBryan Texas Utilities (BTU)Updated to September 30, 2020Account DescriptionBalanceJanuary 1, 2018 to September 30, 2018October 1, 2018 to September 30, 2019October 1, 2019 to September 30, 2020No.December 31, 2017Additions Retirements/AffiliateBalanceAdditions Retirements/AffiliateBalanceAdditions Retirements/AffiliateBalanceDocket 48123Adjustments ExpensesAdjustments ExpensesAdjustments Expenses (1) (2) (3) (4) (5) = (1) +…+(4) (6) (7) (8) (9) = (5) +…+(8) (10) (11) (12) (13) = (9) +…+(12)Gross PlantA350 Land and Land Rights$3,748,286$10,100 $0 $0$3,758,386$0 $0 $0$3,758,386$1,444,778 $0 $0$5,203,164A352 Structures and Improvements $6,045,327$118,663 $0 $0$6,163,990$517,844 $0 $0$6,681,834$10,583 $0 $0$6,692,417A353 Station Equipment$83,493,040$1,970,616 ($392,146) $0$85,071,511$112,602 $0 $0$85,184,113$20,126,509 $0 $0$105,310,621A354 Towers and Fixtures$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0A355 Poles and Fixtures$57,258,404$27,892 ($13,127) $0$57,273,170$31,452 ($11,940) $0$57,292,682$5,236,416 ($14,437) $0$62,514,661A356 O.H. Conductors & Devices $26,134,317$3,470 $0 $0$26,137,787$211 $0 $0$26,137,997$12,321,613 ($31,224) $0$38,428,386A357 Underground Conduit$1,866,777$0 $0 $0$1,866,777$0 $0 $0$1,866,777($12,890) $0$1,853,886A358 Underground Conductors$2,172,888$1,759,065 ($473,500) $0$3,458,453$0 $0 $0$3,458,453$3,029,647 ($221,417) $0$6,266,683A359 Roads and Trails$406,267$2,888 $0 $0$409,154$232,131 $0 $0$641,286$406 $0 $0$641,692A360 Distribution above 60 kV$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0A361 Distribution above 60 kV$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0A362 Distribution above 60 kV$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0Total Transmission Plant-Gross$181,125,306 $3,892,694 ($878,773) $0 $184,139,227 $894,240 ($11,940) $0 $185,021,527 $42,169,951 ($279,969) $0 $226,911,50936DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-5 (Interim): Change in Accumulated DepreciationInterim Wholesale Transmission Accumulated DepreciationBryan Texas Utilities (BTU)Updated to September 30, 2020AccountDescriptionBalance January 1, 2018 to September 30, 2018 October 1, 2018 to September 30, 2019 October 1, 2019 to September 30, 2020No.December 31, 2017 Depreciation Retirements/ Balance Depreciation Retirements/ Balance Depreciation Retirements/ BalanceDocket 48123 ExpenseAdjustmentsExpenseAdjustmentsExpenseAdjustments (1) (2) (3) (4) = (1)+(2)+(3) (5) (6) (7) = (4)+ (5)+(6) (5) (6) (7) = (4)+ (5)+(6)Accumulated Depreciation A350 Land and Land Rights$0$0 $0$0$0 $0$0$0 $0$0A352 Structures and Improvements$1,705,777$136,405 $0$1,842,182$186,214 $0$2,028,396$200,649 $0$2,229,045A353 Station Equipment$22,791,616$1,895,861 ($553,990)$24,133,487$2,552,590 $0$26,686,077$2,637,016 ($11,932)$29,311,162A354 Towers and Fixtures$0$0 $0$0$0 $0$0$0 $0$0A355 Poles and Fixtures$8,586,496$1,288,314 ($14,668)$9,860,142$1,718,244 ($17,697)$11,560,689$1,731,983 ($103,850)$13,188,821A356 O.H. Conductors & Devices$4,379,539$588,022 $0$4,967,561$784,134 $0$5,751,696$818,496 ($59,520)$6,510,672A357 Underground Conduit$772,085$42,002 $0$814,087$56,003 $0$870,091$55,971 ($12,890)$913,171A358 Underground Conductors$424,031$233,925 ($510,390)$147,566$103,754 $0$251,320$136,135 ($337,935)$49,519A359 Roads and Trails$41,814$9,148 $0$50,963$13,995 $0$64,957$19,248 $0$84,205A360 Distribution above 60 kV$0$0 $0$0$0 $0$0$0 $0$0A361 Distribution above 60 kV$0$0 $0$0$0 $0$0$0 $0$0A362 Distribution above 60 kV$0$0 $0$0$0 $0$0$0 $0$0Transmission Accumulated Depreciation$38,701,358 $4,193,678 ($1,079,048) $41,815,988 $5,414,934 ($17,697) $47,213,225 $5,599,498 ($526,128) $52,286,59537DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule E-1 (Interim): Change in Depreciation ExpenseInterim Wholesale Transmission Depreciation ExpenseBryan Texas Utilities (BTU)Updated to September 30, 2020Account DescriptionDepreciation Expense Gross Plant BalanceAccumulated Deprec. Net Plant Balance Depreciation Depreciation Increase inNo. December 31, 2017September 30, 2020September 30, 2020 September 30, 2020 % Expense DepreciationDocket 48123 (Schedule B-1, Column 13) (Schedule B-5, Column 10) in last TCOS on Balance Expense (1) (2) (3) (4) = (2) - (3) (5) (6) = (2) * (5) (7) = (6) - (1)Depreciation ExpenseA350 Land and Land Rights$0$5,203,164$0 $5,203,164 0.0% $0 $0A352 Structures and Improvements$181,360$6,692,417$2,229,045 $4,463,371 3.0% $200,772 $19,413A353 Station Equipment$2,504,791$105,310,621$29,311,162 $75,999,460 3.0% $3,159,319 $654,527A354 Towers and Fixtures$0$0$0$0 3.0% $0 $0A355 Poles and Fixtures$1,717,752$62,514,661$13,188,821 $49,325,840 3.0% $1,875,440 $157,688A356 O.H. Conductors & Devices$784,029$38,428,386$6,510,672 $31,917,714 3.0% $1,152,852 $368,822A357 Underground Conduit$56,003$1,853,886$913,171 $940,715 3.0% $55,617 ($387)A358 Underground Conductors$65,187$6,266,683$49,519 $6,217,164 3.0% $188,000 $122,814A359 Roads and Trails$0$641,692$84,205 $557,487 0.0% $0 $0A360 Distribution above 60 kV$0$0$0$0$0 $0A361 Distribution above 60 kV$0$0$0$0$0 $0A362 Distribution above 60 kV$0$0$0$0$0 $0Transmission Depreciation Expense$5,309,123$226,911,509$52,286,595 $174,624,914$6,632,000 $1,322,877General Plant Depreciation Expense$230,890$230,890Total Depreciation Expense$5,540,013$6,862,89038DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule F-1 (Interim): Change in Payment In Lieu Of TaxesInterim Wholesale Transmission Cost of ServiceBryan Texas Utilities (BTU)Updated to September 30, 2020Description Balance ReferenceSchedule(1) (2)Docket 22616PILOT Approved $1,131,098 Docket 22616TCOS Net of PILOT $3,898,267 Docket 22616Effective rate 29.02% Docket 22616Docket 48123PILOT Approved $6,683,954 Docket 48123TCOS Net of PILOT $23,035,878 Docket 48123Effective rate 29.02% Docket 22616TCOS Ending September 30, 2020Effective rate 29.02% Docket 22616TCOS Net of PILOT $28,129,488 Schedule APILOT Proposed$8,161,885 ProposedTCOS Ending September 30, 2020$8,161,885 ProposedDocket 48123 PILOT Approved$6,683,954 Docket 48123Increase in PILOT from Docket 48123$1,477,93239DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule A (Interim): Summary of Interim Wholesale Transmission Cost of Service: Docket No. 48123Interim Wholesale Transmission Cost of ServiceBryan Texas Utilities (BTU)Updated to December 31, 2017DescriptionTotal InterimInterimReferenceApprovedAnnual RevenueScheduleDocket 44467Increase Requirement(1)(2)(3) = (1) + (2)Revenue RequirementOperation & Maintenance $706,683N/A$706,683 Docket 22616Depreciation and Amortization$4,859,711$680,302 $5,540,013 Schedule E-1Taxes Other Than Income Taxes $6,045,197$638,756 $6,683,954 Schedule F-1Federal Income Tax N/AN/AN/AReturn on Rate Base$15,268,046$1,521,136 $16,789,183 Schedule BTotal Revenue Requirement$26,879,637 $2,840,194 $29,719,831Other Revenues $0$0$0Docket 22616Total Revenue Requirement$26,879,637 $2,840,194 $29,719,831ERCOT AVERAGE 4 CP-in kW 63,680,710 67,273,101 Dockets 43881 and 47777Wholesale Rate $/kW$0.4221000$0.441780040DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B (Interim): Summary of Interim Wholesale Transmission Rate Base: Docket No. 48123Interim Wholesale Transmission Rate BaseBryan Texas Utilities (BTU)Updated to December 31, 2017Total BalanceIncrease in ReferenceDescriptionApprovedas of end of Rate Base & SchedulesDocket 44467 update periodReturn(1)(2)(3) = (2) - (1)Direct Assigned:FERC Accounts 350 - 362Original Plant In Service$158,207,382$181,125,306$22,917,923 B-1(Accumulated Depreciation)($28,773,496)($38,701,358) ($9,927,862) B-5Net Plant In Service$129,433,887 $142,423,947 $12,990,061Allocated Plant Accounts- Net *$436,032$436,032 $0 Docket 22616CWIP *$0$0$0 Docket 22616Working Capital *$514,765$514,765$0 Docket 22616Plant Held for Future Use *$0$0$0 Docket 22616Reserve for Insurance *$0$0$0 Docket 22616Other *$0$0$0 Docket 22616Total Rate Base$130,384,684 $143,374,744 $12,990,061Rate of Return *11.71%11.71%11.71% Docket 22616Return on Rate Base$15,268,046 $16,789,183 $1,521,13641DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-1 (Interim): Change in Gross Plant: Docket No. 48123Interim Wholesale Transmission PlantBryan Texas Utilities (BTU)Updated to December 31, 2017Account DescriptionBalanceJanuary 1, 2015 to September 30, 2015October 1, 2015 to September 30, 2016October 1, 2016 to September 30, 2017October 1, 2017 to December 31, 2017No.December 31, 2014Additions Retirements/Affiliate BalanceAdditions Retirements/Affiliate BalanceAdditions Retirements/Affiliate BalanceAdditions Retirements/Affiliate BalanceDocket 44467Adjustments ExpensesAdjustments ExpensesAdjustments ExpensesAdjustments Expenses (1) (2) (3) (4) (5) = (1) +…+(4) (6) (7) (8) (9) = (5) +…+(8) (10) (11) (12) (13) = (9) +…+(12) (14) (15) (16) (17) = (13) +…+(16)Gross PlantA350 Land and Land Rights$3,748,286 $0 $0 $0$3,748,286$0 $0 $0$3,748,286$0 $0 $0$3,748,286$0 $0 $0$3,748,286A352 Structures and Improvements$2,441,154 $0 $0 $0$2,441,154$259,476 $0 $0$2,700,630$2,725,524 $0 $0$5,426,154$619,172 $0 $0$6,045,327A353 Station Equipment$75,265,735 $1,139,537 $0 $0$76,405,272$1,461,732 $0 $0$77,867,004$6,331,037 ($705,000) $0$83,493,040$0 $0 $0$83,493,040A354 Towers and Fixtures$0 $0 $0 $0$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0A355 Poles and Fixtures$51,102,686 $2,874,036 $0 $0$53,976,722$2,051,073 ($787,083) $0$55,240,712$2,799,531 ($781,838) $0$57,258,404$0 $0 $0$57,258,404A356 O.H. Conductors & Devices$22,786,910 $153,881 $0 $0$22,940,791$1,806,512 ($636,830) $0$24,110,473$2,647,907 ($624,063) $0$26,134,317$0 $0 $0$26,134,317A357 Underground Conduit$1,664,553 $0 $0 $0$1,664,553$0 $0 $0$1,664,553$445,859 ($243,636) $0$1,866,777$0 $0 $0$1,866,777A358 Underground Conductors$1,032,981 $0 $0 $0$1,032,981$0 $0 $0$1,032,981$1,264,694 ($124,787) $0$2,172,888$0 $0 $0$2,172,888A359 Roads and Trails$165,078 $0 $0 $0$165,078$38,913 $0 $0$203,991$202,276 $0 $0$406,267$0 $0 $0$406,267A360 Distribution above 60 kV$0 $0 $0 $0$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0A361 Distribution above 60 kV$0 $0 $0 $0$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0A362 Distribution above 60 kV$0 $0 $0 $0$0$0 $0 $0$0$0 $0 $0$0$0 $0 $0$0Transmission Plant-Gross$158,207,382 $4,167,455 $0 $0 $162,374,837 $5,617,706 ($1,423,913) $0 $166,568,630 $16,416,827 ($2,479,324) $0 $180,506,133 $619,172 $0 $0 $181,125,30642DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule B-5 (Interim): Change in Accumulated Depreciation: Docket No. 48123Interim Wholesale Transmission Accumulated DepreciationBryan Texas Utilities (BTU)Updated to December 31, 2017Account DescriptionBalance January 1, 2015 to September 30, 2015 October 1, 2015 to September 30, 2016 October 1, 2016 to September 30, 2017 October 1, 2017 to December 31, 2017 Increase InNo.December 31, 2014 Depreciation Retirements/ Balance Depreciation Retirements/ Balance Depreciation Retirements/ Balance Depreciation Retirements/ BalanceAccumulated Docket 44467 Expense AdjustmentsExpense AdjustmentsExpense AdjustmentsExpense AdjustmentsDepreciation (1)(2) (3) (4) = (1)+(2)+(3) (5) (6) (7) = (4)+ (5)+(6) (5)(6) (7) = (4)+ (5)+(6) (8) (9) (10) = (7)+(8)+(9) (11)Accumulated Depreciation A350 Land and Land Rights$0 $0 $0$0$0 $0$0$0.00 $0.00$0$0 $0$0 $0A352 Structures and Improvements$1,435,104 $54,926 $0$1,490,030$75,955 $0$1,565,984$93,180.46 $5,915.54$1,665,080$40,696 $0$1,705,777 $270,673A353 Station Equipment$16,627,553 $1,699,608 $0$18,327,161$2,299,488 $0$20,626,649$2,396,760.39 ($857,990.72)$22,165,419$626,198 $0$22,791,616 $6,164,063A354 Towers and Fixtures$0 $0 $0$0$0 $0$0$0.00 $0.00$0$0 $0$0 $0A355 Poles and Fixtures$5,586,214 $1,152,522 $0$6,738,736$1,650,880 ($891,385)$7,498,231$1,676,180.95 ($1,017,354.23)$8,157,058$429,438 $0$8,586,496 $3,000,282A356 O.H. Conductors & Devices$3,747,546 $514,601 $0$4,262,147$719,823 ($741,132)$4,240,838$741,620.92 ($798,926.60)$4,183,532$196,007 $0$4,379,539 $631,993A357 Underground Conduit$898,901 $37,452 $0$936,353$49,937 $0$986,290$49,936.56 ($278,142.40)$758,084$14,001 $0$772,085 ($126,816)A358 Underground Conductors$455,287 $23,242 $0$478,529$30,989 $0$509,518$40,677.52 ($142,460.90)$407,735$16,297 $0$424,031 ($31,255)A359 Roads and Trails$22,892 $3,714 $0$26,606$5,536 $0$32,142$6,625.45 $0.00$38,767$3,047 $0$41,814 $18,923A360 Distribution above 60 kV$0 $0 $0$0$0 $0$0$0.00 $0.00$0$0 $0$0 $0A361 Distribution above 60 kV$0 $0 $0$0$0 $0$0$0.00 $0.00$0$0 $0$0 $0A362 Distribution above 60 kV$0 $0 $0$0$0 $0$0$0.00 $0.00$0$0 $0$0 $0Transmission Accumulated Depreciation$28,773,496 $3,486,066 $0 $32,259,562 $4,832,607 ($1,632,518) $35,459,652 $5,004,982 ($3,088,959) $37,375,675 $1,325,684 $0 $38,701,358 $9,927,86243DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule E-1 (Interim): Change in Depreciation Expense: Docket No. 48123Interim Wholesale Transmission Depreciation ExpenseBryan Texas Utilities (BTU)Updated to December 31, 2017AccountDescriptionDepreciation Expense Gross Plant BalanceAccumulated Deprec. Net Plant Balance Depreciation Depreciation Increase inNo. December 31, 2014December 31, 2017December 31, 2017 December 31, 2017 % Expense DepreciationDocket 44467 (Schedule B-1, Column 13) (Schedule B-5, Column 10) in last TCOS on Balance Expense (1) (2) (3) (4) = (2) - (3) (5) (6) = (2) * (5) (7) = (6) - (1)Depreciation ExpenseA350 Land and Land Rights$0$3,748,286 $0 $3,748,2860.0%$0 $0A352 Structures and Improvements$73,235$6,045,327 $1,705,777 $4,339,5503.0%$181,360 $108,125A353 Station Equipment$2,257,972$83,493,040 $22,791,616 $60,701,4243.0%$2,504,791 $246,819A354 Towers and Fixtures$0$0 $0 $03.0%$0 $0A355 Poles and Fixtures$1,533,081$57,258,404 $8,586,496 $48,671,9093.0%$1,717,752 $184,672A356 O.H. Conductors & Devices$683,607$26,134,317 $4,379,539 $21,754,7773.0%$784,029 $100,422A357 Underground Conduit$49,937$1,866,777 $772,085 $1,094,6923.0%$56,003 $6,067A358 Underground Conductors$30,989$2,172,888 $424,031 $1,748,8573.0%$65,187 $34,197A359 Roads and Trails$0$406,267 $41,814 $364,4530.0%$0 $0A360 Distribution above 60 kV$0$0 $0 $0 $0 $0A361 Distribution above 60 kV$0$0 $0 $0 $0 $0A362 Distribution above 60 kV$0$0 $0 $0 $0 $0Transmission Depreciation Expense$4,628,821$181,125,306$38,701,358 $142,423,947$5,309,123 $680,302General Plant Depreciation Expense$230,890$230,890Total Depreciation Expense$4,859,711$5,540,01344DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Schedule F-1 (Interim): Change in Payment In Lieu Of Taxes: Docket No. 48123Interim Wholesale Transmission Cost of ServiceBryan Texas Utilities (BTU)Updated to December 31, 2017Description Balance ReferenceSchedule(1) (2)Docket 22616PILOT Approved $1,131,098 Docket 22616TCOS Net of PILOT $3,898,267 Docket 22616Effective rate 29.02% Docket 22616Docket 44467PILOT Approved $6,045,197 Docket 44467TCOS Net of PILOT $20,834,440 Docket 44467Effective rate 29.02% Docket 22616TCOS Ending December 31, 2017Effective rate 29.02% Docket 22616TCOS Net of PILOT $23,035,878 Schedule APILOT Proposed$6,683,954 ProposedTCOS Ending December 31, 2017$6,683,954 ProposedDocket 44467 PILOT Approved$6,045,197 Docket 44467Increase in PILOT from Docket 44467$638,75645DocuSign Envelope ID: EA4AA3B2-6ABB-4501-BF57-E19983335271DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CITY OF DENTON
REQUEST FOR QUALIFICATIONS: #7532
PUCT TRANSMISSION COST OF SERVICE RATE FILING SERVICES
COST ESTIMATE
JANUARY 15, 2021
Submitted by:
Exhibit C
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
Thoughtful Decision Making for Uncertain Times 1
COST ESTIMATE
NewGen proposes the following fee schedule for Phase 1, Task A:
Phase 1: Development of Interim-TCOS-RFP and Full-TCOS-RFP
Task A: Rate Analysis and Filing Cost Estimate
Task A.1: Interim-TCOS-RFP, which includes the following tasks:
Task A.1.1: Data Request and Review
Task A.1.2: Revenue Requirement and Schedule Development
Task A.1.3: Prepare Rate Filing Package by July 2021
Task A.1 Subtotal $20,000
Task A.2: Full-TCOS-RFP, which includes the following tasks:
Task A.2.1: Data Request and Review
Task A.2.2: Test Year Revenue Requirement
Task A.2.3: Functionalization Factors
Task A.2.4: Rate of Return Analysis and Strategies
Task A.2.5: Schedules and Workpapers
Task A.2.6: Prepare Rate Filing Package by November 2021
Task A.2 Subtotal $75,000
Task A Total $95,000
The cost associated with this scope of services will be based on the hourly billing rates of the project team,
including the reimbursement of expenses at cost. We initially estimate the cost associated for Task A.1
to be $20,000 and Task A.2 to be $75,000 for a total of $95,000 for Task A. Total cost excludes travel-
related expenses.
Once the interim or full rate case is filed, the process can vary depending on the progress of the case, and
because of this we cannot predict the work effort required to successfully complete the assignment.
Therefore, we will assist the Legal Team as directed to support the filing. Our work efforts will likely be
responding to questions by the Commission staff. If parties intervene, the process may become more
complex. Accordingly, we have not developed a cost estimate for Task A Phase 2, and would invoice
Denton on a time and materials basis.
The level of effort for Tasks B, C, and D is unknown at this time and we propose to bill Denton based on
time and materials. Once the scope of Tasks B, C, and D is known, we will provide Denton an estimate for
approval before work is performed.
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CITY OF DENTON, TX
PUCT TCOS RATE FILING SERVICES
RFQ #: 7532
2 Thoughtful Decision Making for Uncertain Times
Billing rates are set forth as follows:
NewGen Strategies and Solutions 2021 Billing Rates
Position Hourly Billing Rate
President / Managing Director / Director $230 - $360
Executive Consultant $220 - $320
Senior Consultant $190 - $220
Consultant $135 - $150
Administrative Services $110
Note: Billing rates are subject to change based on annual reviews and salary increases.
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Exhibit D
Bidder's attention is directed to the insurance requirements below. It is highly recommended
that bidders confer with their respective insurance carriers or brokers to determine in advance
of Bid submission the availability of insurance certificates and endorsements as prescribed and
provided herein. If an apparent low bidder fails to comply strictly with the insurance
requirements, that bidder may be disqualified from award of the contract. Upon bid award, all
insurance requirements shall become contractual obligations, which the successful bidder shall
have a duty to maintain throughout the course of this contract.
STANDARD PROVISIONS:
Without limiting any of the other obligations or liabilities of the Contractor, the Contractor shall
provide and maintain until the contracted work has been completed and accepted by the City of
Denton, Owner, the minimum insurance coverage as indicated hereinafter.
As soon as practicable after notification of bid award, Contractor shall file with the Purchasing
Department satisfactory certificates of insurance, containing the bid number and title of the
project. Contractor may, upon written request to the Purchasing Department, ask for clarification
of any insurance requirements at any time; however, Contractors are strongly advised to make
such requests prior to bid opening, since the insurance requirements may not be modified or
waived after bid opening unless a written exception has been submitted with the bid. Contractor
shall not commence any work or deliver any material until he or she receives notification that
the contract has been accepted, approved, and signed by the City of Denton.
All insurance policies proposed or obtained in satisfaction of these requirements shall comply with
the following general specifications, and shall be maintained in compliance with these general
specifications throughout the duration of the Contract, or longer, if so noted:
Each policy shall be issued by a company authorized to do business in the State of Texas
with an A.M. Best Company rating of at least A- VII or better.
Any deductibles or self-insured retentions shall be declared in the bid proposal. If
requested by the City, the insurer shall reduce or eliminate such deductibles or
self-insured retentions with respect to the City, its officials, agents, employees and
volunteers; or, the contractor shall procure a bond guaranteeing payment of losses and
related investigations, claim administration and defense expenses.
Liability policies shall be endorsed to provide the following:
Name as additional insured the City of Denton, its Officials, Agents,
Employees and volunteers.
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That such insurance is primary to any other insurance available to the additional
insured with respect to claims covered under the policy and that this insurance
applies separately to each insured against whom claim is made or suit is brought.
The inclusion of more than one insured shall not operate to increase the insurer's
limit of liability.
Provide a Waiver of Subrogation in favor of the City of Denton, its officials,
agents, employees, and volunteers.
Cancellation: City requires 30 day written notice should any of the policies
described on the certificate be cancelled before the expiration date.
Should any of the required insurance be provided under a claims-made form,
Contractor shall maintain such coverage continuously throughout the term of
this contract and, without lapse, for a period of three years beyond the contract
expiration, such that occurrences arising during the contract term which give rise
to claims made after expiration of the contract shall be covered.
Should any of the required insurance be provided under a form of coverage that
includes a general annual aggregate limit providing for claims investigation or
legal defense costs to be included in the general annual aggregate limit, the
Contractor shall either double the occurrence limits or obtain Owners and
Contractors Protective Liability Insurance.
Should any required insurance lapse during the contract term, requests for
payments originating after such lapse shall not be processed until the City
receives satisfactory evidence of reinstated coverage as required by this contract,
effective as of the lapse date. If insurance is not reinstated, City may, at its sole
option, terminate this agreement effective on the date of the lapse.
SPECIFIC ADDITIONAL INSURANCE REQUIREMENTS:
All insurance policies proposed or obtained in satisfaction of this Contract shall additionally
comply with the following marked specifications, and shall be maintained in compliance with these
additional specifications throughout the duration of the Contract, or longer, if so noted:
[X ] A. General Liability Insurance:
General Liability insurance with combined single limits of not less than $1,000,000.00
shall be provided and maintained by the Contractor. The policy shall be written on an
occurrence basis either in a single policy or in a combination of underlying and
umbrella or excess policies.
If the Commercial General Liability form (ISO Form CG 0001 current edition) is used:
Coverage A shall include premises, operations, products, and completed
operations, independent contractors, contractual liability covering this
contract and broad form property damage coverage.
Coverage B shall include personal injury.
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Coverage C, medical payments, is not required.
If the Comprehensive General Liability form (ISO Form GL 0002 Current Edition and
ISO Form GL 0404) is used, it shall include at least:
Bodily injury and Property Damage Liability for premises, operations,
products and completed operations, independent contractors and property
damage resulting from explosion, collapse or underground (XCU)
exposures.
Broad form contractual liability (preferably by endorsement) covering this
contract, personal injury liability and broad form property damage liability.
[X] Automobile Liability Insurance:
Contractor shall provide Commercial Automobile Liability insurance with Combined
Single Limits (CSL) of not less than $500,000.00 either in a single policy or in a
combination of basic and umbrella or excess policies. The policy will include bodily injury
and property damage liability arising out of the operation, maintenance and use of all
automobiles and mobile equipment used in conjunction with this contract.
Satisfaction of the above requirement shall be in the form of a policy endorsement for:
any auto, or
all owned, hired and non-owned autos.
[X] Workers’ Compensation Insurance
Contractor shall purchase and maintain Worker's Compensation insurance which, in
addition to meeting the minimum statutory requirements for issuance of such insurance,
has Employer's Liability limits of at least $100,000 for each accident, $100,000 per each
employee, and a $500,000 policy limit for occupational disease. The City need not be
named as an "Additional Insured" but the insurer shall agree to waive all rights of
subrogation against the City, its officials, agents, employees and volunteers for any work
performed for the City by the Named Insured. For building or construction projects, the
Contractor shall comply with the provisions of Attachment 1 in accordance with §406.096
of the Texas Labor Code and rule 28TAC 110.110 of the Texas Worker's Compensation
Commission (TWCC).
[ ] Owner's and Contractor's Protective Liability Insurance
The Contractor shall obtain, pay for and maintain at all times during the prosecution of the
work under this contract, an Owner's and Contractor's Protective Liability insurance policy
naming the City as insured for property damage and bodily injury which may arise in the
prosecution of the work or Contractor's operations under this contract. Coverage shall be
on an "occurrence" basis, and the policy shall be issued by the same insurance company
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that carries the Contractor's liability insurance. Policy limits will be at least combined
bodily injury and property damage per occurrence with a aggregate.
[X] Professional Liability Insurance
Professional liability insurance with limits not less than $1,000,000 per claim with respect
to negligent acts, errors or omissions in connection with professional services is required
under this Agreement.
[ ] Builders' Risk Insurance
Builders' Risk Insurance, on an All-Risk form for 100% of the completed value shall be
provided. Such policy shall include as "Named Insured" the City of Denton and all
subcontractors as their interests may appear.
[ ] Commercial Crime
Provides coverage for the theft or disappearance of cash or checks, robbery inside/outside
the premises, burglary of the premises, and employee fidelity. The employee fidelity
portion of this coverage should be written on a “blanket” basis to cover all employees,
including new hires. This type insurance should be required if the contractor has access to
City funds. Limits of not less than each occurrence are required.
[ ] Additional Insurance
Other insurance may be required on an individual basis for extra hazardous contracts and
specific service agreements. If such additional insurance is required for a specific contract,
that requirement will be described in the "Specific Conditions" of the contract
specifications.
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ATTACHMENT 1
[ ] Workers’ Compensation Coverage for Building or Construction Projects for
Governmental Entities
A. Definitions:
Certificate of coverage ("certificate")-A copy of a certificate of insurance, a certificate
of authority to self-insure issued by the commission, or a coverage agreement (TWCC-
81, TWCC-82, TWCC-83, or TWCC-84), showing statutory workers' compensation
insurance coverage for the person's or entity's employees providing services on a
project, for the duration of the project.
Duration of the project - includes the time from the beginning of the work on the
project until the contractor's/person's work on the project has been completed and
accepted by the governmental entity.
Persons providing services on the project ("subcontractor" in §406.096) - includes all
persons or entities performing all or part of the services the contractor has undertaken
to perform on the project, regardless of whether that person contracted directly with
the contractor and regardless of whether that person has employees. This includes,
without limitation, independent contractors, subcontractors, leasing companies, motor
carriers, owner-operators, employees of any such entity, or employees of any entity
which furnishes persons to provide services on the project. "Services" include, without
limitation, providing, hauling, or delivering equipment or materials, or providing
labor, transportation, or other service related to a project. "Services" does not include
activities unrelated to the project, such as food/beverage vendors, office supply
deliveries, and delivery of portable toilets.
B. The contractor shall provide coverage, based on proper reporting of classification codes
and payroll amounts and filing of any overage agreements, which meets the statutory
requirements of Texas Labor Code, Section 401.011(44) for all employees of the
Contractor providing services on the project, for the duration of the project.
C. The Contractor must provide a certificate of coverage to the governmental entity prior
to being awarded the contract.
D. If the coverage period shown on the contractor's current certificate of coverage ends
during the duration of the project, the contractor must, prior to the end of the coverage
period, file a new certificate of coverage with the governmental entity showing that
coverage has been extended.
E. The contractor shall obtain from each person providing services on a project, and
provide to the governmental entity:
1) a certificate of coverage, prior to that person beginning work on the project, so the
governmental entity will have on file certificates of coverage showing coverage for
all persons providing services on the project; and
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2) no later than seven days after receipt by the contractor, a new certificate of coverage
showing extension of coverage, if the coverage period shown on the current
certificate of coverage ends during the duration of the project.
F. The contractor shall retain all required certificates of coverage for the duration of the
project and for one year thereafter.
G. The contractor shall notify the governmental entity in writing by certified mail or
personal delivery, within 10 days after the contractor knew or should have known, of
any change that materially affects the provision of coverage of any person providing
services on the project.
H. The contractor shall post on each project site a notice, in the text, form and manner
prescribed by the Texas Workers' Compensation Commission, informing all persons
providing services on the project that they are required to be covered, and stating how
a person may verify coverage and report lack of coverage.
I. The contractor shall contractually require each person with whom it contracts to
provide services on a project, to:
1) provide coverage, based on proper reporting of classification codes and payroll
amounts and filing of any coverage agreements, which meets the statutory
requirements of Texas Labor Code, Section 401.011(44) for all of its employees
providing services on the project, for the duration of the project;
2) provide to the contractor, prior to that person beginning work on the project, a
certificate of coverage showing that coverage is being provided for all employees
of the person providing services on the project, for the duration of the project;
3) provide the contractor, prior to the end of the coverage period, a new certificate of
coverage showing extension of coverage, if the coverage period shown on the
current certificate of coverage ends during the duration of the project;
4) obtain from each other person with whom it contracts, and provide to the contractor:
a) certificate of coverage, prior to the other person beginning work on the
project; and
b) a new certificate of coverage showing extension of coverage, prior to the end
of the coverage period, if the coverage period shown on the current certificate
of coverage ends during the duration of the project;
5) retain all required certificates of coverage on file for the duration of the project and
for one year thereafter;
6) notify the governmental entity in writing by certified mail or personal delivery,
within 10 days after the person knew or should have known, of any change that
materially affects the provision of coverage of any person providing services on the
project; and
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
7) Contractually require each person with whom it contracts, to perform as required
by paragraphs (1) - (7), with the certificates of coverage to be provided to the person
for whom they are providing services.
J. By signing this contract or providing or causing to be provided a certificate of coverage,
the contractor is representing to the governmental entity that all employees of the
contractor who will provide services on the project will be covered by workers'
compensation coverage for the duration of the project, that the coverage will be based
on proper reporting of classification codes and payroll amounts, and that all coverage
agreements will be filed with the appropriate insurance carrier or, in the case of a self-
insured, with the commission's Division of Self-Insurance Regulation. Providing false
or misleading information may subject the contractor to administrative penalties,
criminal penalties, civil penalties, or other civil actions.
K. The contractor’s failure to comply with any of these provisions is a breach of contract
by the contractor which entitles the governmental entity to declare the contract void if
the contractor does not remedy the breach within ten days after receipt of notice of
breach from the governmental entity.
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
CONFLICT OF INTEREST QUESTIONNAIRE
CONFLICT OF INTEREST QUESTIONNAIRE - FORM CIQ
For vendor or other person doing business with local governmental entity This questionnaire reflects changes made to the law by H.B. 23, 84th Leg., Regular Session. This questionnaire is being filed in accordance with Chapter 176, Local Government Code, by a vendor who has a business relationship as defined by Section 176.001(1-a) with a local governmental entity and the vendor meets requirements under Section 176.006(a).
By law this questionnaire must be filed with the records administrator of the local government entity not later than the 7th business day after the date the vendor becomes aware of facts that require the statement to be filed. See Section 176.006(a-1), Local Government Code.
A vendor commits an offense if the vendor knowingly violates Section 176.006, Local Government Code. An offense under this section is a misdemeanor.
1 Name of vendor who has a business relationship with local governmental entity.
2 Check this box if you are filing an update to a previously filed questionnaire.
(The law requires that you file an updated completed questionnaire with the appropriate filing authority not later than the 7th business day after the date on which you became aware that the originally filed questionnaire was incomplete or inaccurate.)
3 Name of local government officer about whom the information in this section is being disclosed.
Name of Officer
This section, (item 3 including subparts A, B, C & D), must be completed for each officer with whom the vendor has an employment or other business relationship as defined by Section 176.001(1-a), Local Government Code. Attach additional pages to this Form CIQ as necessary. A. Is the local government officer named in this section receiving or likely to receive taxable income, other than investment income, from the vendor? Yes No B. Is the vendor receiving or likely to receive taxable income, other than investment income, from or at the direction of the local government officer named in this section AND the taxable income is not received from the local governmental entity? Yes No C. Is the filer of this questionnaire employed by a corporation or other business entity with respect to which the local government officer serves as an officer or director, or holds an ownership of one percent or more? Yes No D. Describe each employment or business and family relationship with the local government officer named in this section.
4 I have no Conflict of Interest to disclose.
5
Signature of vendor doing business with the governmental entity Date
NewGen Strategies and Solutions, LLC
N/A
X
X
X
N/A
DocuSign Envelope ID: 934167DD-0E69-4EDF-99B7-80397C61F620
12/17/2020
Exhibit E
DocuSign Envelope ID: 7E461519-C4A0-4267-88EB-BE1F02954191
Certificate Of Completion
Envelope Id: 7E461519C4A0426788EBBE1F02954191 Status: Completed
Subject: Please DocuSign: City Council Contract 7532 PUCT Rate Filing Services
Source Envelope:
Document Pages: 214 Signatures: 5 Envelope Originator:
Certificate Pages: 6 Initials: 1 Christa Christian
AutoNav: Enabled
EnvelopeId Stamping: Enabled
Time Zone: (UTC-06:00) Central Time (US & Canada)
901B Texas Street
Denton, TX 76209
Christa.Christian@cityofdenton.com
IP Address: 198.49.140.104
Record Tracking
Status: Original
1/22/2021 9:30:58 AM
Holder: Christa Christian
Christa.Christian@cityofdenton.com
Location: DocuSign
Signer Events Signature Timestamp
Christa Christian
christa.christian@cityofdenton.com
Senior Buyer
City of Denton
Security Level: Email, Account Authentication
(None)
Completed
Using IP Address: 198.49.140.104
Sent: 1/22/2021 9:40:53 AM
Viewed: 1/22/2021 9:41:12 AM
Signed: 1/22/2021 9:42:05 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Lori Hewell
lori.hewell@cityofdenton.com
Purchasing Manager
City of Denton
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 198.49.140.104
Sent: 1/22/2021 9:42:08 AM
Viewed: 1/22/2021 10:04:43 AM
Signed: 1/22/2021 10:06:07 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Larry Collister
larry.collister@cityofdenton.com
First Assistant City Attorney
City of Denton
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 47.184.80.203
Sent: 1/22/2021 10:06:10 AM
Viewed: 1/24/2021 7:23:10 PM
Signed: 1/27/2021 7:50:31 AM
Electronic Record and Signature Disclosure:
Accepted: 9/26/2017 2:27:28 PM
ID: 01f5f868-f109-4e29-ad49-21db9046c882
Joseph Mancinelli
jmancinelli@newgenstrategies.net
Director
Security Level: Email, Account Authentication
(None)Signature Adoption: Pre-selected Style
Using IP Address: 73.243.28.139
Sent: 1/27/2021 7:50:35 AM
Viewed: 1/27/2021 10:34:39 AM
Signed: 1/27/2021 4:21:04 PM
Electronic Record and Signature Disclosure:
Accepted: 1/27/2021 10:34:39 AM
ID: 35d09002-1dc0-462d-94e4-598f5ec06fe6
Signer Events Signature Timestamp
Terrance Naulty
Terrance.Naulty@cityofdenton.com
Asst. General Manager
City of Denton
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 198.49.140.104
Sent: 1/29/2021 7:53:19 AM
Viewed: 1/29/2021 8:21:05 AM
Signed: 1/29/2021 8:21:33 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Cheyenne Defee
cheyenne.defee@cityofdenton.com
Contract Administrator
City of Denton
Security Level: Email, Account Authentication
(None)
Completed
Using IP Address: 198.49.140.104
Sent: 1/29/2021 8:21:37 AM
Viewed: 2/10/2021 8:10:43 AM
Signed: 2/10/2021 8:11:08 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Todd Hileman
Todd.Hileman@cityofdenton.com
City Manager
City of Denton
Security Level: Email, Account Authentication
(None)
Signature Adoption: Pre-selected Style
Using IP Address: 107.77.197.170
Sent: 2/10/2021 8:11:12 AM
Viewed: 2/10/2021 9:06:25 AM
Signed: 2/10/2021 9:06:31 AM
Electronic Record and Signature Disclosure:
Accepted: 7/25/2017 11:02:14 AM
ID: 57619fbf-2aec-4b1f-805d-6bd7d9966f21
Rosa Rios
rosa.rios@cityofdenton.com
City Secretary
Security Level: Email, Account Authentication
(None)Signature Adoption: Pre-selected Style
Using IP Address: 198.49.140.10
Sent: 2/10/2021 9:06:35 AM
Viewed: 2/10/2021 11:25:02 AM
Signed: 2/10/2021 11:25:31 AM
Electronic Record and Signature Disclosure:
Accepted: 2/10/2021 11:25:02 AM
ID: 7c773bc9-e385-4989-a6b3-a066dea6b4fc
In Person Signer Events Signature Timestamp
Editor Delivery Events Status Timestamp
Agent Delivery Events Status Timestamp
Intermediary Delivery Events Status Timestamp
Certified Delivery Events Status Timestamp
Carbon Copy Events Status Timestamp
Cheyenne Defee
cheyenne.defee@cityofdenton.com
Contract Administrator
City of Denton
Security Level: Email, Account Authentication
(None)
Sent: 1/22/2021 9:42:08 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Carbon Copy Events Status Timestamp
Sherri Thurman
sherri.thurman@cityofdenton.com
City of Denton
Security Level: Email, Account Authentication
(None)
Sent: 1/29/2021 8:21:36 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Gretna Jones
gretna.jones@cityofdenton.com
Legal Secretary
City of Denton
Security Level: Email, Account Authentication
(None)
Sent: 2/10/2021 8:11:11 AM
Viewed: 2/10/2021 8:13:01 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Zolina Parker
zolina.parker@cityofdenton.com
Security Level: Email, Account Authentication
(None)
Sent: 2/10/2021 11:25:35 AM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Juan Pagoada-Reyes
juan.pagoada-reyes@cityofdenton.com
City of Denton
Security Level: Email, Account Authentication
(None)
Sent: 2/10/2021 11:25:36 AM
Viewed: 2/10/2021 12:00:26 PM
Electronic Record and Signature Disclosure:
Not Offered via DocuSign
Antonio Puente
Antonio.Puente@cityofdenton.com
Exec Mgr of Utilities
Security Level: Email, Account Authentication
(None)
Sent: 1/27/2021 4:21:08 PM
Resent: 2/10/2021 11:25:37 AM
Electronic Record and Signature Disclosure:
Accepted: 2/8/2021 12:46:42 PM
ID: 70e27673-46d4-4446-b992-14c8550a2005
Witness Events Signature Timestamp
Notary Events Signature Timestamp
Envelope Summary Events Status Timestamps
Envelope Sent Hashed/Encrypted 1/22/2021 9:40:53 AM
Certified Delivered Security Checked 2/10/2021 11:25:02 AM
Signing Complete Security Checked 2/10/2021 11:25:31 AM
Completed Security Checked 2/10/2021 11:25:37 AM
Payment Events Status Timestamps
Electronic Record and Signature Disclosure
ELECTRONIC RECORD AND SIGNATURE DISCLOSURE
From time to time, City of Denton (we, us or Company) may be required by law to provide to
you certain written notices or disclosures. Described below are the terms and conditions for
providing to you such notices and disclosures electronically through your DocuSign, Inc.
(DocuSign) Express user account. Please read the information below carefully and thoroughly,
and if you can access this information electronically to your satisfaction and agree to these terms
and conditions, please confirm your agreement by clicking the 'I agree' button at the bottom of
this document.
Getting paper copies
At any time, you may request from us a paper copy of any record provided or made available
electronically to you by us. For such copies, as long as you are an authorized user of the
DocuSign system you will have the ability to download and print any documents we send to you
through your DocuSign user account for a limited period of time (usually 30 days) after such
documents are first sent to you. After such time, if you wish for us to send you paper copies of
any such documents from our office to you, you will be charged a $0.00 per-page fee. You may
request delivery of such paper copies from us by following the procedure described below.
Withdrawing your consent
If you decide to receive notices and disclosures from us electronically, you may at any time
change your mind and tell us that thereafter you want to receive required notices and disclosures
only in paper format. How you must inform us of your decision to receive future notices and
disclosure in paper format and withdraw your consent to receive notices and disclosures
electronically is described below.
Consequences of changing your mind
If you elect to receive required notices and disclosures only in paper format, it will slow the
speed at which we can complete certain steps in transactions with you and delivering services to
you because we will need first to send the required notices or disclosures to you in paper format,
and then wait until we receive back from you your acknowledgment of your receipt of such
paper notices or disclosures. To indicate to us that you are changing your mind, you must
withdraw your consent using the DocuSign 'Withdraw Consent' form on the signing page of your
DocuSign account. This will indicate to us that you have withdrawn your consent to receive
required notices and disclosures electronically from us and you will no longer be able to use your
DocuSign Express user account to receive required notices and consents electronically from us
or to sign electronically documents from us.
All notices and disclosures will be sent to you electronically
Unless you tell us otherwise in accordance with the procedures described herein, we will provide
electronically to you through your DocuSign user account all required notices, disclosures,
authorizations, acknowledgements, and other documents that are required to be provided or
made available to you during the course of our relationship with you. To reduce the chance of
you inadvertently not receiving any notice or disclosure, we prefer to provide all of the required
notices and disclosures to you by the same method and to the same address that you have given
us. Thus, you can receive all the disclosures and notices electronically or in paper format through
the paper mail delivery system. If you do not agree with this process, please let us know as
described below. Please also see the paragraph immediately above that describes the
consequences of your electing not to receive delivery of the notices and disclosures
electronically from us.
Electronic Record and Signature Disclosure created on: 7/21/2017 3:59:03 PM
Parties agreed to: Larry Collister, Joseph Mancinelli, Todd Hileman, Rosa Rios, Antonio Puente
How to contact City of Denton:
You may contact us to let us know of your changes as to how we may contact you electronically,
to request paper copies of certain information from us, and to withdraw your prior consent to
receive notices and disclosures electronically as follows:
To contact us by email send messages to: purchasing@cityofdenton.com
To advise City of Denton of your new e-mail address
To let us know of a change in your e-mail address where we should send notices and disclosures
electronically to you, you must send an email message to us at melissa.kraft@cityofdenton.com
and in the body of such request you must state: your previous e-mail address, your new e-mail
address. We do not require any other information from you to change your email address..
In addition, you must notify DocuSign, Inc to arrange for your new email address to be reflected
in your DocuSign account by following the process for changing e-mail in DocuSign.
To request paper copies from City of Denton
To request delivery from us of paper copies of the notices and disclosures previously provided
by us to you electronically, you must send us an e-mail to purchasing@cityofdenton.com and in
the body of such request you must state your e-mail address, full name, US Postal address, and
telephone number. We will bill you for any fees at that time, if any.
To withdraw your consent with City of Denton
To inform us that you no longer want to receive future notices and disclosures in electronic
format you may:
i. decline to sign a document from within your DocuSign account, and on the subsequent
page, select the check-box indicating you wish to withdraw your consent, or you may;
ii. send us an e-mail to purchasing@cityofdenton.com and in the body of such request you
must state your e-mail, full name, IS Postal Address, telephone number, and account
number. We do not need any other information from you to withdraw consent.. The
consequences of your withdrawing consent for online documents will be that transactions
may take a longer time to process..
Required hardware and software
Operating Systems: Windows2000? or WindowsXP?
Browsers (for SENDERS): Internet Explorer 6.0? or above
Browsers (for SIGNERS): Internet Explorer 6.0?, Mozilla FireFox 1.0,
NetScape 7.2 (or above)
Email: Access to a valid email account
Screen Resolution: 800 x 600 minimum
Enabled Security Settings:
•Allow per session cookies
•Users accessing the internet behind a Proxy
Server must enable HTTP 1.1 settings via
proxy connection
** These minimum requirements are subject to change. If these requirements change, we will
provide you with an email message at the email address we have on file for you at that time
providing you with the revised hardware and software requirements, at which time you will
have the right to withdraw your consent.
Acknowledging your access and consent to receive materials electronically
To confirm to us that you can access this information electronically, which will be similar to
other electronic notices and disclosures that we will provide to you, please verify that you
were able to read this electronic disclosure and that you also were able to print on paper or
electronically save this page for your future reference and access or that you were able to
e-mail this disclosure and consent to an address where you will be able to print on paper or
save it for your future reference and access. Further, if you consent to receiving notices and
disclosures exclusively in electronic format on the terms and conditions described above,
please let us know by clicking the 'I agree' button below.
By checking the 'I Agree' box, I confirm that:
• I can access and read this Electronic CONSENT TO ELECTRONIC RECEIPT OF
ELECTRONIC RECORD AND SIGNATURE DISCLOSURES document; and
• I can print on paper the disclosure or save or send the disclosure to a place where I can
print it, for future reference and access; and
• Until or unless I notify City of Denton as described above, I consent to receive from
exclusively through electronic means all notices, disclosures, authorizations,
acknowledgements, and other documents that are required to be provided or made
available to me by City of Denton during the course of my relationship with you.