BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION DIRECT TESTIMONY LOVITA GRIFFIN, EEP RATE ANALYST

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1 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF CENTERPOINT ENERGY ARKANSAS GAS FOR APPROVAL OF ITS QUICK START ENERGY EFFICIENCY PROGRAM, PORTFOLIO AND PLAN INCLUDING ITS COST RECOVERY RIDER ) ) ) ) ) ) DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN, EEP RATE ANALYST ON BEHALF OF THE GENERAL STAFF OF THE ARKANSAS PUBLIC SERVICE COMMISSION May 8,

2 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN I. INTRODUCTION Q. Please state your name and business address. A. My name is Lovita Griffin and my business address is Arkansas Public Service Commission (Commission), 1000 Center Street, Little Rock, Arkansas, Q. Are you the same Lovita Griffin who filed Suspension Testimony in this docket on April 2, 2015, on behalf of the General Staff (Staff) of the Commission? A. Yes, I am. II. PURPOSE OF TESTIMONY Q. What is the purpose of your testimony? A. The purpose of my testimony is to make a recommendation regarding the annual redetermination of the Energy Efficiency Cost Recovery (EECR) Rate filed by CenterPoint Energy Arkansas (CEA or Company) on March 31, Additionally, I will address the Energy Efficiency Program Portfolio Annual Report filed by CEA on March 31, III. ENERGY EFFICIENCY COST RECOVERY RATE Q. Why did CEA file the annual redetermination of the EECR Rate? A. Pursuant to Section 5.3 of its tariff, CEA filed its 2015 Attachment A in support of its annual redetermination of the EECR Rate to be applied to customers bills rendered on and after the first billing cycle of June The filing was made in accordance with provisions of Section 7 of the -2-2

3 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN Commission s Rules for Conservation and Energy Efficiency Programs (C&EE Rules) approved in Order No. 25 of Docket No R. Q. What is the Company allowed to collect through the EECR? A. Rule 7(A) of the C&EE Rules states that cost recovery shall be limited to the incremental costs of providing conservation and energy efficiency (EE) programs that are not already included in the current rates of the utility, and may include direct program costs, Lost Contributions to Fixed Costs (LCFC), and utility EE incentives. Q. What steps did you take in reviewing the redetermination of the 2015 EECR Rate (2015 EECR Rate) calculated in Attachment A? A. I reviewed all components used in the development of the 2015 EECR Rate. There are four components used in developing the Program Year (PY) 2015 Recoverable Cost; each component is listed below: a) The PY 2015 EE Portfolio Budget; b) The PY 2015 Projected LCFC; c) The PY 2014 Utility Performance Incentive (Incentive); and d) The true-up of the PY 2014 Recoverable Cost. Table 1 summarizes the four components and the resulting Recoverable Cost for The results from PY 2012 through PY 2015 are included in Table 1. I will address each of the four components in turn

4 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN 1 Table 1 Program Year Recoverable Cost Program Year Portfolio Budget Projected LCFC Performance Incentive Prior Year "True-Up" Other Adjustments Recoverable Cost (a) (b) (c) (d) (e) (f)=(a)+(b)+(c)+(d)+(e) 2012 $6,583,254 $139,777 $235,723 $483,983 $0 $7,442, $7,272,763 $242,627 $479,757 $1,284,886 $0 $9,280, $7,272,763 $261,682 $535,068 $46,123 $0 $8,115, $7,272,764 $1,095,723 $509,093 ($2,991,187) $0 $5,886, PY 2015 Portfolio Budget Q. Was the PY 2015 Portfolio Budget approved by the Commission? A. Yes. CEA used the PY 2015 Portfolio Budget of $7,272,764 approved by the Commission in Order No. 73, dated October 28, 2014 in this docket and Order No. 15 in Docket No U, which approved the existing PY 2014 budgets for use in PY PY 2015 Projected LCFC Q. What is LCFC? A. LCFC refers to the reduction in potential utility sales revenue resulting from decreased energy volumes due to EE measures implemented under utility-funded EE programs. The contemporaneous recovery of LCFC that results from EE programs was authorized by Order No. 14 in Docket No U (LCFC Order). LCFC is a cumulative savings based on measures installed in the current PY and prior PYs. The cumulative savings from the measures installed in a prior PY will continue until the expected life of the measure expires or until the Company implements new base rates through a general rate case, at which time the cumulative portion resets to zero. -4-4

5 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN 1 2 Q. Please describe the PY 2015 Projected LCFC component. A. CEA s current base rates were implemented 2007 pursuant to a general 3 rate application. 1 Therefore, CEA s PY 2015 Projected LCFC consists of five years of cumulative savings as follows: 1) The full year impact of the annualized net evaluated energy savings for measures installed in PY 2011; 2) The full year impact of the annualized net evaluated energy savings for measures installed in PY 2012; 3) The full year impact of the annualized net evaluated energy savings for measures installed in PY 2013; 4) The full year impact of the annualized net evaluated energy savings for measures installed in PY 2014; and 5) The estimated partial year impact of the expected net energy savings for measures that will be installed in PY The components of the PY Projected 2015 LCFC are summarized in Table 2. Table 2 Prior to 2014 Full Year Evaluated Savings PY 2015 Projected LCFC 2014 Full Year Evaluated Savings 2015 Estimated Partial Year Impact Total Projected LCFC (a) (b) (c) (d)=(a)+(b)+(c) $632,567 $193,588 $269,568 $1,095,723 1 Order No. 6, Docket U. -5-5

6 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN Q. Please explain in more detail the three components of the PY 2015 Projected LCFC shown in Table 2. A. The first component (a) is the annualized net evaluated energy savings attributed to measures installed in PY 2011, PY 2012, and PY 2013 that will realize a cumulative full year savings 4,552,325 Therms in PY This energy savings results in an LCFC of $632,567 in PY The second component (b) is the annualized net evaluated energy savings attributed to measures installed in PY 2014 that will realize a full year savings of 1,634,775 Therms in PY This energy savings results in an LCFC of $193,588 in PY The third and final component (c) is the estimated non-annualized net energy savings attributed to measures that will be installed in PY 2015, including the true-up of the projected PY 2014 LCFC. CEA has estimated that the 2015 measures will have a partial year savings of 1,550,974 Therms in PY 2015, with an estimated energy savings resulting in an LCFC of $275,512 in PY However, in PY 2014 CEA over estimated its PY 2014 LCFC by $5,944. To account for this CEA has reduced its PY 2015 LCFC by 244,105 Therms, which results in a reduction in LCFC of $5,944. This adjustment results in a total estimated PY 2015 partial impact savings of 1,306,869 Therms, with an estimated energy savings resulting in an LCFC of $269,

7 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN These three components result in a cumulative energy savings of 7,493,969 Therms and a cumulative LCFC of $1,095,723 in PY 2015, reflected as Table 2, column (d). Q. Did CEA change the methodology used to calculate LCFC for PY 2015? A. Yes. CEA previously operated under its Billing Determinant Adjustment Rider (BDA) which modified its rates to reflect reduction in sales volumes. Since CEA accounted for those lost revenues related to EE through its BDA, it did not include prior PY cumulative savings in its projected LCFC calculations. In this filing, CEA has proposed to collect its cumulative LCFC through the EECR Rate. As a result, and consistent with the LCFC Order, CEA will adjust its BDA to prevent double-counting of any sales reductions already included in the LCFC recovery through the EECR. The change in the LCFC methodology is supported by Company witness Thomas D. Stevens in his Direct Testimony, starting on page 6 at line 7. Q. Do the methodology and calculations used by CEA to develop its PY 2015 Projected LCFC appear to be reasonable? A. Yes. My review of the Company s LCFC calculations revealed no mathematical errors. I reviewed the Company s Lost Contribution Rates (LCR) and the energy savings for estimated PY The LCR is consistent with CEA s currently approved LCR and the savings are consistent with the PY 2015 EE Program Filings. The methodologies utilized by the Company for its PY 2011 through PY 2014 evaluated LCFC -7-7

8 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN and its estimated PY 2015 LCFC calculations appear to be reasonable. Therefore, I conclude that the PY 2015 Projected LCFC as calculated by CEA is materially accurate. CEA has requested to recover PY 2015 Projected LCFC, in the amount of $1,095,723, which is 15% of its PY 2015 Portfolio Budget. Q. Did the Company true-up the PY 2014 LCFC? A. Yes. As I discussed above, the true-up for CEA s PY 2014 LCFC is reflected in the PY 2015 Projected LCFC of $1,095,723, as shown in Table 2, Column (d). Q. Do the methodology and calculations used by CEA to develop its PY 2014 LCFC true-up appear to be reasonable? A. Yes. CEA relied on after-the-fact, net energy savings, as determined by its independent Evaluation, Measurement and Verification (EM&V) contractor, ADM Associates, Inc.. The measures installed in PY 2014 were adjusted to account for the timing of the installation and heating and cooling degree days as appropriate. This is consistent with the LCFC Order. Therefore, I conclude that the true-up of the PY 2014 LCFC, as calculated by CEA, is materially accurate. PY 2014 Performance Incentive Q. Please describe the Incentive component. A. The Commission approved an Incentive related to EE savings achievement in Order No. 15 in Docket No U. The approved incentive mechanism awards the utility a shared savings of 10% of the -8-8

9 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN portfolio s net benefits for achievement above 80% of the goal. The Commission established a cap of 5% of portfolio budgets for achievement between 80% and 100% of the goal, and a cap of 7% for achievement above 100%. The Commission established goal for PY 2014 for gas utilities was 0.40% of the utility s PY 2010 annual energy sales. Q. Is CEA requesting recovery of an Incentive for PY 2014 results? A. Yes. CEA met the Commission s target in PY 2014 and is eligible for recovery of an Incentive. As shown in Table 3, CEA s savings goal was 2,268,882 Therms and CEA achieved savings of 2,743,851 Therms, which is 121% of the PY 2014 savings goal. CEA is therefore eligible to recover 7% of its Portfolio Budget or 10% of the 2014 Portfolio Net Benefits, whichever is smaller. CEA s performance Incentive for the PY 2014 is $509,094, which is $779,779 less than 10% of the net benefits. 14 Table 3 DERIVATION OF 2014 UTILITY PERFORMANCE INCENTIVE Net Savings 2014 Incentive Calculations Volume (Therms) 567,220,496 10% of Portfolio Net Benefits ($) $1,288,873 Commission Established Goal 0.40% Portfolio Budget ($) $7,272,765 Therms Goal 2,268,882 Incentive Cap 7% Therms Achieved 2,743,851 Maximum Allowed Incentive $ $509,094 % of Goal Achieved 121% Eligible Incentive $'s $509, Prior Year True-Up Q. Do the methodology and calculations used by CEA to develop its PY 2014 true-up appear to be reasonable? -9-9

10 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN A. Yes. I reviewed the calculations used by CEA for its PY 2014 true-up and found no mathematical errors. I compared the actual expenses in PY 2014 to those approved by Commission Order No. 73 in this docket. I also verified that CEA used the appropriate carrying charge rate as approved in its last rate case, Docket No U. The methodology utilized by the Company in its calculation of the PY 2014 true-up appears to be reasonable. Therefore, I conclude that the PY 2014 true-up, as calculated by CEA, is materially accurate. These amounts, along with the reported actual recoveries under the PY 2014 EECR Rates, are summarized in Table 4. Table 4 Program Year Program Year True-Up Actual Revenues Actual Expenses* (Over)/Under Collection Carrying Charges Prior Year Cumulative (Over)/Under Adjustments Cumulative (Over)/Under "True-Up" (a) (b) (c)=(b)-(a) (d) (e) (f) (g)=(c)+(d)+(e)+(f) 2012 $4,659,717 $5,335,788 $676,071 $24,623 $483,983 $100,210 $1,284, $7,967,865 $6,640,904 ($1,326,961) $9,482 $1,284,886 $78,715 $46, $9,057,676 $6,177,104 ($2,880,572) ($156,738) $46,123 $0 ($2,991,187) *Acutal Expenses include LCFC and utility performance incentives Other Adjustments Q. Did CEA make any adjustments to its calculation of the PY 2015 Recoverable Costs? A. No. As shown in Table 1, column (e) CEA did not have any adjustments Attachment A Q. Do the calculations used by CEA as reflected in PY 2015 Attachment A comply with prior Commission Orders in this docket?

11 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN A. Yes, the calculations in Attachment A appear to be consistent with CEA s 2015 Attachment A approved by Commission Order No. 73 in this docket. Based on the review as described above, I conclude that the Recoverable Cost of $5,886,393 as calculated by CEA is materially accurate. Q. If CEA s 2015 EECR Rate is approved by the Commission, what would be the impact on CEA s residential customers? A. If CEA s proposed 2015 EECR Rate is approved by the Commission, the current residential rate of $ would decrease to $ per Ccf. A residential customer consuming 50 Ccf per month would see an decrease in the EECR charge from $1.01 to $0.65. The current rates for all rate classes would change as shown in Table 5. Table 5 EECR RATES $/CCF or $/mmbtu Rate Class Current Proposed Difference % Change Residential (CCF) $ $ $ ( ) -36% Small Commercial (CCF) $ $ $ % Small Commercial (mmbtu) $ $ $ % Large Commercial (mmbtu) $ $ $ ( ) -42% IV. ENERGY EFFICIENCY ANNUAL REPORT Q. Did you review the PY 2014 Annual Report submitted by CEA? A. Yes. I have reviewed the PY 2014 Annual Report submitted by all seven of the investor owned utilities, including CEA. A summary of the utility annual reports is provided in Attachment A to my Testimony. Q. Has CEA s Annual Report been used as evidence to support its 2015 EECR Rate?

12 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN A, Yes. I verified that the PY 2014 expenses, LCFC, net energy savings, and Incentives reported in the Company s PY 2014 Annual Report were consistent with the 2015 EECR and used as evidence in the calculation of CEA s 2015 EECR Rate. Q. Did CEA remain within the Commission approved budget for PY 2014? A. Yes. CEA operated within the Portfolio Budget approved by the Commission for PY Q. Did you review the EM&V section of CEA s Annual Report? A. No, I did not. I relied on the evaluated net energy savings provided within the EM&V report, but I did not review how they were developed. The Independent EM&V Monitor (IEM) reviews and reports on the EM&V activities and efforts of each Company. The IEM Team, led by Dr. Katherine Johnson of Johnson Consulting Group, will be filing its annual report on EM&V activities to the Commission by June 1, The IEM Annual EM&V Report will provide an overview and assessment of the utilities and third-party administrators EM&V efforts. In addition to commenting on the quality of the EM&V efforts, the IEM report may also provide insights into program design and process issues which will address some of the Commission s questions regarding how effectively programs are working and ways to improve the viability of various programs

13 CENTERPOINT ENERGY ARKANSAS DOCKET NO TF DIRECT TESTIMONY OF LOVITA GRIFFIN V. FINDINGS AND RECOMMENDATIONS Q. What is your recommendation? A. I recommend that the Commission approve CEA s 2015 Attachment A in support of its annual redetermination of the EECR Rate as filed on March 31, Q. Do have any other recommendations? A. Yes. Although I have concluded that the approved methodology was used in the development of the 2015 Attachment A, I have not conducted a complete examination of the underlying data used in the development of the 2015 Attachment A. In order to avoid questions regarding Staff's right to review the underlying data used in developing the costs recovered from ratepayers, I recommend that the Commission s order explicitly state that its approval of the Company s 2015 Attachment A reserves Staff s right to subject the underlying data to ongoing compliance audits at Staff's discretion, and affirms the Commission s authority to order refunds (including the payment of carrying charges) in the event the Commission ultimately rules that any part of the program costs were not appropriate for recovery from customers. Q. Does this conclude your testimony? A. Yes, it does

14 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been served on all parties of record by electronic mail via the Electronic Filing System this 8 th day of May, /s/ Fran C. Hickman Fran C. Hickman

15 ATTACHMENT A Introduction Summary of Utility Program Year 2014 Annual Reports Section 9 Arkansas Public Service Commission s (Commission) Rules for Conservation and Energy Efficiency Programs (C&EE Rules) 1 requires all investor owned utilities (IOUs or utility) to file an annual report by May 1st of each year addressing the performance of all approved energy efficiency (EE) programs. In compliance with the C&EE rules, each investor owned electric and gas utility submitted its 2014 Annual Report consistent with the EE Standardized Annual Report Packet Versions 3.0 (SARP) 2 approved by Commission Order No. 16 in Docket No U. The General Staff of the Commission has prepared this Program Year (PY) 2014 Annual Report Summary. This summary provides information provided by the following seven IOUs: Electric Utilities o Entergy Arkansas, Inc. (EAI) o Southwestern Electric Power Company (SWEPCO) o Oklahoma Gas & Electric Company (OG&E) o The Empire District Electric Company (Empire) Natural Gas Utilities o CenterPoint Energy Arkansas Gas (CenterPoint) o SourceGas Arkansas Inc. (SourceGas) o Arkansas Oklahoma Gas Corporation (AOG) More details regarding each utility can be found in the individual Annual Reports filed by the utilities in each of their respective TF dockets or in the EE section of the Commission s website. 3 Beginning in 2007, all electric and natural gas utility customers in Arkansas were able to participate in EE quick start programs offered by their utility. New comprehensive programs became available in 2011 as utilities implemented their first set of three-year plans which included additional programs and expansion of existing quick start programs. With the start of the new comprehensive

16 plans, the Commission also set annual savings targets for PYs 2011, 2012, and The electric utilities EE savings targets were set at 0.25%, 0.50%, and 0.75% of each electric utility s 2010 sales for 2011, 2012, and 2013, respectively. The natural gas utilities EE savings targets were set at 0.20%, 0.30%, and 0.40% of each natural gas utility s 2010 sales for 2011, 2012, and 2013, respectively. Commission Order No. 2 in Docket U set an annual net energy savings target for PY 2014 of 0.75% for electric utilities and 0.40% natural gas utilities, using 2010 sales adjusted for Self- Direct customers as the baseline. All Commission established EE savings targets by PY are shown in Table 1. Table 1: Commission Established EE Saving Targets Program Year Electric Natural Gas Baseline Year % 0.20% % 0.30% % 0.40% % 0.40% % 0.50% % 0.50%

17 PY 2014 Net Energy Savings and Cost Electric Utilities In PY 2014, the combined EE program expenses by the four electric IOUs in Arkansas totaled $72.2 million dollars and resulted in net savings of 249,504 MWh. The reported EE portfolio results for each electric IOU in PY 2014, including net demand and net energy savings, actual expenses, Lost Contribution to Fix Cost (LCFC), performance incentives, and the cost-effectiveness for both the total resource cost (TRC) test and program administrator cost (PAC) test are shown in Table 2. Table 2: Reported PY 2014 Portfolio Results Net Energy Savings Cost Cost-Effectiveness Electric Utility Demand Energy Actual Performance LCFC TRC PAC MW MWh Expenses Incentives EAI ,507 $59,913,755 $4,225,925 $4,581, SWEPCO 14 30,056 $7,611,826 $2,373,855 $721, OG&E 3 13,794 $4,547,081 $1,893,174 $229, Empire $115,688 $20,141 $ TOTAL Arkansas ,504 $72,188,350 $8,513,095 $5,533,239 As shown above EAI, SWEPCO, and OG&E earned a performance incentive for its achieved savings in PY Those same three utilities also achieved a TRC and PAC test above 1.0. The TRC and PAC tests are two of the five cost-effectiveness tests as outlined in the California Standard Practice Manual. 4 The TRC test reflects the total benefits and costs to all customers, both participants and nonparticipants, in a utility s service territory. The TRC ratio is the net benefits of the portfolio divided by the total cost, including both the participants and the utility s costs. The PAC test reflects the total costs incurred by the program administrator (including incentive costs) and excludes any net costs incurred by the customers. The primary differences between the TRC and PAC tests are (1) the PAC test does not include any energy benefits for fuels the utility does not provide; (2) the PAC test does not include any participant contributions to the cost of the EE investment; and (3) the TRC test does 4 Electric Utilities 3 17

18 not include any incentives paid by the utility to the participants. A TRC or PAC ratio above 1.0 indicates that the portfolio is beneficial. The total cost for PY 2014 reported by the utilities includes actual expenses, LCFC, and performance incentives. The total combined cost for Arkansas electric utilities in PY 2014 was $86.2 million, which includes $8.5 million of LCFC and $5.5 million in performance incentives. The cost components for each utility s total cost in PY 2014 are shown in Figure 1. Figure 1: Percentage of Total PY 2014 Cost 100% 80% 60% 40% 20% Performance Incentives LCFC Actual Expenses 0% EAI SWEPCO OG&E Empire PY 2014 Net Energy Savings Targets In PY 2014 the electric IOUs on average saved 0.75% of the annual baseline sales. EAI achieved the highest level of net energy savings at 1.14% or 151% of the target while spending 92% of its budget. SWEPCO achieved net energy savings of 1.06% or 141% of the target while spending 74% of its budget. Both OG&E and Empire failed to reach the 0.75% target; however, OG&E did achieve 85% of the target at 0.64%. This qualified OG&E for a performance incentive (the Commission rules require a minimum of 80% of goal attainment to receive an incentive). 5 A summary overview of each electric utility s EE portfolio for PY 2014 is shown in Table 3. It compares budgets to the amounts actually spent; planned and evaluated net energy savings and the level of achievement towards the established savings target. The total state-wide net savings and expenses by each electric utility s contribution to the combined total are shown in Figure 2. The results by each utility at the program level can be found in Appendix A. 5 Docket No U, Order No. 15. Electric Utilities 4 18

19 Table 3: PY 2014 Plan Compared to Actuals Net Savings (MWh) Cost Commission Target* Electric Utility % of Plan Evaluated % Budget Actual % Baseline (MWh) Baseline EAI 208, ,507 98% $65,453,663 $59,913,755 92% 18,098, % SWEPCO 28,015 30, % $10,313,940 $7,611,826 74% 2,845, % OG&E 14,561 13,794 95% $4,590,967 $4,547,081 99% 2,171, % Empire 1, % $449,035 $115,688 26% 96, % *Target for PY 2014 was 0.75% of 2010 sales adjusted for Self-Direct. Figure 2: Total Arkansas PY 2014 Savings and Expenses by Utility Contribution Savings OG&E 6% Empire 0% SWEPCO 12% SWEPCO 11% OG&E 6% Expenses Empire 0% EAI 82% EAI 83% Historical EE Portfolio Results An overview of the historical goal achievement by each electric IOU, since savings targets were set by the Commission in 2011, is shown in Table 4. A comparison of the electric utilities goal achievement is shown in Figure 4. Table 4: Percent of Baseline Savings Utility PY 2011 PY 2012 PY 2013 PY 2014 EAI 0.19% 0.56% 1.01% 1.14% SWEPCO 0.26% 0.57% 0.82% 1.06% OG&E 0.18% 0.33% 0.60% 0.64% Empire 0.00% 0.10% 0.16% 0.15% Target 0.25% 0.50% 0.75% 0.75% -Baseline for PY 2011 through PY 2014 was 2010 sales adjusted for Self-Direct customer s sales. Electric Utilities 5 19

20 Figure 3: Percent of Baseline Savings PY 2011 through PY 2014 % of Baseline 1.20% 1.05% 0.90% 0.75% 0.60% 0.45% 0.30% 0.15% 0.00% Target EAI SWEPCO OG&E Empire Since PY 2011, SWEPCO is the only IOU to meet or exceed the target in each of the four years. In the last three years, EAI has met or exceeded the targets. OG&E continues to make improvement towards meeting the Commission s goals. The total combined MWh savings by the electric utilities has increased from 53,746 MWh in 2008 to over 249,504 MWh in PY Most utilities have experienced a steady increase in annual savings since PY 2011 when the new comprehensive plans were approved. An overview of the historical expenses compared to actual savings since PY 2008 is shown in Tables 5 and 6, respectively. A chart comparing the relationship between expenses and MWh savings since PY 2008 by electric utility is shown in Figure 4. Electric Utilities 6 20

21 Table 5: Actual Reported Expenses by Utility Utility PY 2008 PY 2009 PY 2010 PY 2011 PY 2012 PY 2013 PY 2014 EAI $5,125,000 $5,269,000 $10,713,410 $13,413,739 $25,515,019 $52,285,262 $59,913,755 SWEPCO $785,745 $811,505 $1,653,494 $3,467,187 $5,289,095 $6,803,249 $7,611,826 OG&E $322,719 $352,324 $1,278,500 $2,071,159 $3,255,512 $3,714,378 $4,547,081 Empire $10,916 $23,267 $37,728 $73,788 $56,406 $114,632 $115,688 Total $6,244,380 $6,456,096 $13,683,132 $19,025,873 $34,116,032 $62,917,521 $72,188,350 Table 6: Energy Savings (MWh) by Utility Utility EAI 45,662 48,042 44,251 41, , , ,507 SWEPCO 5,642 6,076 11,004 10,955 17,767 25,387 30,056 OG&E 2,435 5,608 4,143 4,955 7,596 13,411 13,794 Empire Total 53,746 59,726 59,406 57, , , ,504 Note: PY 2008 through PY 2010 is gross reported savings; starting in PY 2011 the Commission required net savings to be reported. Figure 4: Expenses and Energy Savings by Utility Note: PY 2008 through PY 2010 was adjusted to 80% of reported gross savings to reflect a net-to-gross savings comparable to PY 2011 through PY Electric Utilities 7 21

22 PY 2014 Net Energy Savings and Cost Natural Gas Utilities In PY 2014, the combined EE program expenses by the three natural gas utilities in Arkansas totaled $10.7 million dollars and resulted in net savings of 4,474,218 Therms. The reported EE portfolio results for each natural gas utility in PY 2014, including net demand and net energy savings, actual expenses, LCFC, performance incentives, and the cost-effectiveness for both the TRC test and PAC test are shown in Table 7. Table 7: Reported PY 2014 Portfolio Results Net Energy Savings Cost Cost-Effectiveness Natural Gas Utility Demand Energy Actual Performance LCFC TRC PAC Therms Therms Expenses Incentives CenterPoint 29,965 2,743,851 $5,584,482 $917,315 $509, SourceGas 8,519 1,138,776 $2,718,131 $7,380 $221, AOG 5, ,591 $2,438,257 $48,501 $181, TOTAL Arkansas 44,154 4,474,218 $10,740,870 $973,196 $913,029 As shown above all three natural gas utilities earned a performance incentive for its achieved savings in PY All three also had TRC and PAC tests above 1.0. The total cost for PY 2014 reported by the utilities includes actual expenses, LCFC, and performance incentives. The combined total cost for Arkansas natural gas utilities in PY 2014 was $12.6 million dollars, which includes $973,196 of LCFC and $913,029 in performance incentives. The cost components for each utility s total cost in PY 2014 are shown in Figure 5. Natural Gas Utilities 8 22

23 100% 80% Figure 5: Percentage of Total PY 2014 Cost 60% 40% 20% Performance Incentives LCFC Actual Expenses 0% CenterPoint SourceGas AOG PY 2014 Energy Savings Targets In PY 2014 the natural gas IOUs on average saved 0.57% of the annual baseline sales. AOG achieved the highest level of net energy savings at 0.72% or 181% of the target while spending 94% of its budget. SourceGas achieved net energy savings of 0.51% or 128% of the target while spending 86% of its budget. CenterPoint achieved 0.48% or 121% of the target while spending 77% of its budget. A summary overview of each natural gas utility s EE portfolio for PY 2014 is shown in Table 8. It compares budgets to the amounts actually spent, planned and evaluated net energy savings, and the level of achievement towards the established savings target. The total state-wide net savings and expenses by each natural gas utility s contribution to the combined total are shown in Figure 6. The results by each utility at the program level can be found in Appendix B. Natural Gas Utilities 9 23

24 Natural Gas Utility Table 8: PY 2014 Plan Compared to Actuals Net Savings (Therms) Cost Commission Target* Plan Evaluated % Budget Actual % Baseline (Therms) % of Baseline CenterPoint 3,636,260 2,743,851 75% $7,272,765 $5,584,482 77% 567,220, % SourceGas 1,003,050 1,138, % $3,170,827 $2,718,131 86% 222,353, % AOG 398, , % $2,599,676 $2,438,257 94% 81,825, % *Commission target for PY 2014 was 0.40% of 2010 sales adjusted for Self-Direct. Figure 6: Total Arkansas PY 2014 Savings and Expenses by Utility Contribution AOG 13% Net Savings AOG 23% Expenses CenterPoint 61% CenterPoint 52% SourceGas 26% SourceGas 25% Historical EE Portfolio Results An overview of the historical goal achievement by each natural gas IOU, since savings targets were set by the Commission in PY 2011, is shown in Table 9. A comparison of the natural gas utilities goal achievement is shown in Figure 7. Natural Gas Utilities 10 24

25 Table 9: Percent of Baseline Savings Utility PY 2011 PY 2012 PY 2013 PY 2014 CenterPoint 0.18% 0.34% 0.54% 0.48% SourceGas 0.13% 0.42% 0.69% 0.51% AOG 0.19% 0.41% 0.60% 0.72% Target 0.20% 0.30% 0.40% 0.40% -Baseline for PY 2011 through PY 2014 was 2010 sales adjusted for Self-Direct customer s sales. 0.90% 0.75% Figure 7: Percent of Baseline Savings PY 2011 through PY 2014 % of Baseline 0.60% 0.45% 0.30% 0.15% Target CenterPoint SourceGas AOG 0.00% Since PY 2012, each of the three natural gas utilities have met or exceeded the target. The total combined savings by the natural gas utilities has increased from 108,020 Therms in PY 2008 to over 4,474,218 Therms in PY Most utilities experienced a steady increase in annual savings from PY 2011 through PY However, in PY 2014 both CenterPoint and SourceGas experienced a decline in annual savings. An overview of the historical expenses compared to actual savings since PY 2008 is shown in Tables 10 and 11, respectively. A chart comparing the relationship between expenses and Therms savings since PY 2008 by utility is shown in Figure 8. Natural Gas Utilities 11 25

26 Table 10: Actual Reported Expenses by Utility Utility PY 2008 PY 2009 PY 2010 PY 2011 PY 2012 PY 2013 PY 2014 CenterPoint $726,728 $738,169 $2,190,839 $3,608,741 $5,335,789 $6,367,110 $5,584,482 SourceGas $157,810 $162,411 $393,714 $1,096,153 $1,780,096 $2,358,944 $2,718,131 AOG $143,809 $111,570 $372,218 $1,172,203 $2,304,511 $2,467,229 $2,438,257 Total $1,028,347 $1,012,150 $2,956,771 $5,877,097 $9,420,396 $11,193,283 $10,740,870 Table 11: Energy Savings (Therms) by Utility Utility PY 2008 PY 2009 PY 2010 PY 2011 PY 2012 PY 2013 PY 2014 CenterPoint 86, , ,666 1,171,015 2,019,379 3,080,775 2,743,851 SourceGas 9, , , ,308 1,544,913 1,138,776 AOG 12,124 41,093 57, , , , ,591 Total 108, , ,275 1,673,947 3,322,917 5,184,824 4,474,218 Note: PY 2008 through PY 2010 is gross reported savings; starting in PY 2011 the Commission required net savings to be reported. Figure 8: Expenses and Energy Savings by Utility Note: PY 2008 through PY 2010 was adjusted to 80% of reported gross savings to reflect a net-to-gross savings comparable to PY 2011 through PY Natural Gas Utilities 12 26

27 Appendix A: Individual Electric Utilities PY 2014 EE Portfolio Results EAI Program Net Energy Savings (kwh) Program Cost Participants TRC Plan Evaluated % Budget Actual % Plan Actual % Ratio Residential Efficient Cooling Solutions 9,100,000 9,980, % $ 3,153,000 $ 3,097,755 98% 10,061 9,068 90% 1.60 Energy Solutions for Manufacture Homes 641, , % $ 836,000 $ 845, % 1,819 1,006 55% 0.56 Energy Solutions for Multi-Family 455,000 1,130, % $ 426,000 $ 515, % 408 1, % 2.03 Energy Star New Homes 1,084,000 49,268 5% $ 531,000 $ 378,899 71% % 0.10 Home Energy Solutions 15,811,000 16,642, % $ 11,237,000 $ 11,216, % 3,600 8, % 1.75 Lighting & Appliances 25,818,000 42,939, % $ 4,447,000 $ 4,409,506 99% 905,778 1,836, % 4.29 Residential Benchmarking Pilot 6,328,000 6,664, % $ 1,487,000 $ 1,154,974 78% 100, , % 0.87 Residential Direct Load Control $ 3,417,000 $ 3,759, % 15,003 17, % 2.69 Total Residential: 59,237,000 78,135, % $ 25,534,000 $ 25,378,369 99% 1,037,119 2,391, % 2.33 Small Business/C&I Small Business 9,998,000 12,199, % $ 2,489,000 $ 3,171, % 1, % 1.64 Total Small Business/C&I: 9,998,000 12,199, % $ 2,489,000 $ 3,171, % 1, % 1.64 Commercial & Industrial C&I Solutions Program 124,860,000 97,702,202 78% $ 27,838,000 $ 23,795,293 85% 1, % 1.63 City Smart 10,352,000 14,662, % $ 2,902,000 $ 2,815,908 97% % 1.28 Total Commercial &Industrial: 135,212, ,364,476 83% $ 30,740,000 $ 26,611,201 87% 1,587 1,092 69% 1.60 Agriculture Agricultural Energy Solutions 1,304,000 2,577, % $ 642,000 $ 391,596 61% % 4.28 Agricultural Irrigation Load Control $ 4,131,000 $ 3,810,523 92% 400 1, % 1.75 Total Agriculture: 1,304,000 2,577, % $ 4,773,000 $ 4,202,119 88% 550 1, % 2.00 Third Party Programs Arkansas Weatherization Program 2,890, ,868 8% $ 1,279,000 $ 214,827 17% Energy Efficiency Arkansas $ 232,000 $ 230,496 99% n/a Total Third Party Programs: 2,890, ,868 8% $ 1,511,000 $ 445,323 29% Regulatory $ 406,663 $ 105,721 26% Total: 208,641, ,506,894 98% $ 65,453,663 $ 59,913,755 92% 1,040,581 2,394, % 1.88 EAI s Commercial and Industrial (C&I) Solutions Program provided approximately half of the PY 2014 net energy savings (97.7 million kwh) at a cost of $23.8 million followed by the Residential Lighting and Appliance Program at 42.9 million kwh and a cost of $4.4 million. The Company achieved 98% of its planned net energy savings, while spending 92% of the Portfolio s budget with 230% of planned participation. EAI s individual EE programs have TRC ratios ranging from 0.10 to 4.29, with an overall Portfolio TRC of Appendix A 13 27

28 SWEPCO Program Net Energy Savings (kwh) Program Cost Participants TRC Plan Evaluated % Budget Actual % Plan Actual % Ratio Residential ENERGY STAR Appliance Program 307,005 60,466 20% $ 625,123 $ 317,010 51% 2, % 0.21 Home Performance w/ ENERGY STAR 887,280 1,617, % $ 1,151,518 $ 1,101,743 96% 911 3, % 0.87 Online Audit Tool $ 12,400 $ 8,044 65% n/a Residential Standard Offer Program 2,668,000 7,807, % $ 1,716,417 $ 1,612,674 94% 9,569 17, % 3.88 Residential Lighting Program 4,484,176 5,097, % $ 569,276 $ 562,907 99% 54,198 41,459 76% 4.88 Total Residential: 8,346,461 14,583, % $ 4,074,734 $ 3,602,378 88% 67,111 63,243 94% 2.59 Small Business Small Business Direct Install 4,583,434 4,157,613 91% $ 1,059,155 $ 1,062, % % 3.59 Total Small Business: 4,583,434 4,157,613 91% $ 1,059,155 $ 1,062, % % 3.59 Commercial & Industrial Load Mngmnt Stndrd Offer Program 320, ,828 36% $ 342,600 $ 254,159 74% % Targeted Commercial & Industrial SOP 14,646,600 11,169,561 76% $ 4,265,404 $ 2,511,253 59% % 1.53 Total Commercial &Industrial: 14,966,600 11,283,389 75% $ 4,608,004 $ 2,765,412 60% % 1.81 Third Party Programs Arkansas Weatherization Program 118,427 31,154 26% $ 412,900 $ 42,069 10% % 4.20 Energy Efficiency Arkansas $ 34,147 $ 35, % n/a Total Third Party Programs: 118,427 31,154 26% $ 447,047 $ 77,447 17% % 4.20 Regulatory $ 125,000 $ 103,753 83% Total: 28,014,922 30,055, % $ 10,313,940 $ 7,611,826 74% 67,746 63,646 94% 2.33 SWEPCO s Targeted C&I Standard Offer Program provided almost one-third of the PY 2014 net energy savings (11.1 million kwh) at a cost of $2.5 million followed by the Residential Standard Offer Program at 7.8 million kwh and a cost of $1.6 million. The Company achieved 107% of its planned net energy savings, while spending 74% of the Portfolio s budget with 94% of planned participation. SWEPCO s individual EE programs have TRC ratios ranging from 0.21 to 26.41, with an overall Portfolio TRC of Appendix A 14 28

29 OG&E Residential Plan Evaluated % Budget Actual % Plan Actual % Ratio Multi-Family Direct Install 1,914,153 1,667,071 87% $ 268,893 $ 233,411 87% 2,050 1,884 92% 3.15 OG&E - AOG Weatherization 3,497,085 3,679, % $ 2,231,745 $ 2,231, % 1,620 1,372 85% 1.95 Student Energy Education 288, , % $ 88,694 $ 88, % 1,840 1, % 2.00 Small Business/C&I Program Total Residential: 5,700,030 5,658,584 99% $ 2,589,332 $ 2,553,851 99% 5,510 5,128 93% 2.08 Commercial Lighting 5,162,810 6,525, % $ 900,128 $ 958, % % 3.06 Commercial & Industrial Total Small Business: 5,162,810 6,525, % $ 900,128 $ 958, % % 3.06 C&I Standard Offer Program 3,596,963 1,606,746 45% $ 926,250 $ 949, % % 3.09 Total Commercial &Industrial: 3,596,963 1,606,746 45% $ 926,250 $ 949, % % 3.09 Third Party Programs Net Energy Savings (kwh) Program Cost Participants Arkansas Weatherization Program 100,821 3,141 3% $ 77,157 $ 22,914 30% % 0.14 Energy Efficiency Arkansas $ 21,600 $ 18,319 85% n/a Total Third Party Programs: 100,821 3,141 3% $ 98,757 $ 41,233 42% % 0.14 TRC Regulatory $ 76,500 $ 43,361 57% Total: 14,560,624 13,794,070 95% $ 4,590,967 $ 4,547,081 99% 5,782 5,381 93% 2.50 OG&E s Commercial Lighting Program provided approximately half of the 2014 net energy savings (6.5 million kwh) at a cost near $1 million followed by the Residential Weatherization Program (offered jointly with AOG) at 3.7 million kwh and a cost of $2.2 million. The Company achieved 95% of its planned net energy savings, while spending 99% of the Portfolio s budget with 93% of planned participation. OG&E s individual EE programs have TRC ratios ranging from 0.14 to 3.15, with an overall Portfolio TRC of Appendix A 15 29

30 Empire Program Net Energy Savings (kwh) Program Cost Participants TRC Plan Evaluated % Budget Actual % Plan Actual % Ratio Residential AC Tune-up & Duct Sealing 18, % $ 9,488 $ 300 3% % 1.14 High-efficiency Residential Lighting 53,870 23,128 43% $ 7,944 $ 8, % 1,440 1, % 1.27 Residential Weatherization Porgram 46,256 48, % $ 70,000 $ 61,192 87% % 1.65 School-Based Energy Education 191,835 15,787 8% $ 22,412 $ 8,385 37% % 1.04 Total Residential: 310,324 88,152 28% $ 109,844 $ 77,886 71% 2,200 1,937 88% 1.54 Residential/Small Business Energy Star Appliance 54, % $ 10,480 $ 3,646 35% % 0.08 High-efficiency HVAC 33,285 3,442 $ 14,230 $ 4,196 29% Total Residential/Small Business: 87,786 3,659 4% $ 24,710 $ 7,842 32% % 0.48 Small Business/C&I Small Business Lighting 60,197-0% $ 49,825 $ - 0% 23-0% n/a Total Small Business/C&I: 60,197-0% $ 49,825 $ - 0% 23-0% n/a Commercial & Industrial C&I Audit $ 3,251 $ - 0% 10-0% n/a C&I (Custom) 229,797 55,453 24% $ 94,410 $ 21,510 23% % 0.66 C&I (Prescriptive) 481,262-0% $ 126,245 $ - 0% 100-0% n/a Total Commercial &Industrial: 711,059 55,453 8% $ 223,906 $ 21,510 10% % 0.66 All Classes Online Audit & Energy Calculator $ 2,000 $ % n/a Total All Classes: $ 2,000 $ % n/a Third Party Programs Arkansas Weatherization Program 950-0% $ 6,750 $ 434 6% 5-0% n/a Energy Efficiency Arkansas $ 2,000 $ 1,263 63% n/a Total Third Party Programs: 950-0% $ 8,750 $ 1,697 19% 5-0% n/a Regulatory $ 30,000 $ 6,024 20% Total: 1,170, ,264 13% $ 449,035 $ 115,688 26% 2,553 1,948 76% 0.94 Empire s C&I Custom Program provided approximately one-third of the 2014 net energy savings (55,453 kwh) at a cost of $21,510 followed by the Residential Weatherization Program at 48,939 kwh and a cost of $61,192. The Company achieved 13% of its planned net energy savings, while spending 26% of the Portfolio s budget with 76% of planned participation. Empire s individual EE programs have TRC ratios ranging from 0.08 to 1.65, with an overall Portfolio TRC of Appendix A 16 30

31 Appendix B: Individual Natural Gas Utilities PY 2014 EE Portfolio Results CenterPoint Residential Plan Evaluated % Budget Actual % Plan Actual % Ratio Home Energy Affordability Loan Program 26,860 9,012 34% $ 154,509 $ 25,988 17% % 1.53 Home Energy Reports 1,000,000 1,102, % $ 879,688 $ 871,505 99% 100,000 82,086 82% 1.20 Low Flow Showerhead & Faucet Aerator 147, , % $ 415,227 $ 282,502 68% 7,600 7,430 98% 6.60 Commercial & Industrial Total Residential: 1,174,300 1,264, % $ 1,449,424 $ 1,179,995 81% 107,934 89,541 83% 2.17 Commercial and Industrial Solutions 1,020,310 1,019, % $ 1,811,074 $ 1,788,563 99% 1, % 5.26 Commercial Boiler 580,900 21,213 4% $ 551,651 $ 150,113 27% % 1.95 Commercial Food Service 385,050 77,619 20% $ 331,594 $ 182,608 55% % 1.49 All Classes Program Total Commercial &Industrial: 1,986,260 1,118,128 56% $ 2,694,319 $ 2,121,284 79% 1, % 4.29 Space Heating 340, ,031 78% $ 1,657,299 $ 1,402,148 85% 2,305 1,837 80% 2.27 Water Heating 86,040 68,571 80% $ 792,864 $ 598,167 75% 1, % 1.37 Third Party Programs Net Energy Savings (Therms) Program Cost Participants Total All Classes: 426, ,603 78% $ 2,450,163 $ 2,000,314 82% 3,847 2,668 69% 2.02 Arkansas Weatherization Program 49,000 28,948 59% $ 503,910 $ 163,727 32% % 2.84 Energy Efficiency Arkansas $ 174,949 $ 119,162 68% n/a Total Third Party Programs: 49,000 28,948 59% $ 678,859 $ 282,889 42% % 2.84 TRC Regulatory $ - $ - - Total: 3,636,260 2,743,851 75% $ 7,272,765 $ 5,584,482 77% 113,695 93,004 82% 2.97 Centerpoint s Home Energy Reports provided 40% of the net energy savings (1,102,598 Therms) at a cost of $871,505 followed by the C&I Solutions Program at 1,019,296 Therms and a cost of $1,788,563. The Company achieved 75% of its planned net energy savings, while spending 77% of the Portfolio s budget with 82% of planned participation. CenterPoint s individual EE programs have TRC ratios ranging from 1.20 to 6.60, with an overall Portfolio TRC of Appendix B 17 31

32 SourceGas Residential Plan Evaluated % Budget Actual % Plan Actual % Ratio Home Energy Savings Program 174, , % $ 731,710 $ 710,695 97% 520 3, % 2.61 Opower Home Energy Report Program $ 3,110 $ 6 0% n/a Commercial & Industrial Total Residential: 174, , % $ 734,820 $ 710,701 97% 520 3, % 2.61 C&I Solutions 694, , % $ 1,525,075 $ 1,333,300 87% % 1.85 All Classes Program Total Commercial &Industrial: 694, , % $ 1,525,075 $ 1,333,300 87% % 1.85 Heating Equipment Rebate Program 54,690 73, % $ 487,454 $ 434,094 89% % 1.41 Water Heating Rebate Program 25,030 28, % $ 156,880 $ 145,302 93% % 1.72 Third Party Programs Net Energy Savings (Therms) Program Cost Participants Total All Classes: 79, , % $ 644,334 $ 579,396 90% 1,496 1,480 99% 1.48 Arkansas Weatherization Program 54,010 2,453 5% $ 150,446 $ 39,187 26% % 0.51 Energy Efficiency Arkansas $ 79,818 $ 49,658 62% n/a Total Third Party Programs: 54,010 2,453 5% $ 230,264 $ 88,845 39% % 0.51 TRC Regulatory $ 36,334 $ 5,890 16% Total: 1,003,050 1,138, % $ 3,170,827 $ 2,718,131 86% 2,854 5, % 1.95 SourceGas C&I Solutions Program provided approximately 70% of the 2014 net energy savings (789,523 Therms) at a cost of $1,333,300 followed by the Residential Home Energy Savings Program at 244,677 Therms and a cost of $710,695. The Company achieved 114% of its planned net energy savings, while spending 86% of the Portfolio s budget with 181% of planned participation. SourceGas individual EE programs have TRC ratios ranging from 0.51 to 2.61, with an overall Portfolio TRC of Appendix B 18 32

33 AOG Residential Plan Evaluated % Budget Actual % Plan Actual % Ratio AOG Weatherization Program 179, , % $ 1,495,003 $ 1,495, % 1,300 1,029 79% 1.73 Residential/Small Business Total Residential: 179, , % $ 1,495,003 $ 1,495, % 1,300 1,029 79% 1.73 Heating Equipment Rebates 8,496 24, % $ 228,495 $ 228, % % 1.16 Water Heating & Conservation 16,950 20, % $ 140,704 $ 110,187 78% 1,464 1,296 89% 1.63 Total Resiential/Small Business: 25,446 45, % $ 369,199 $ 338,682 92% 1,536 1, % 1.32 Small Business/C&I Program C&I Solutions 175, , % $ 373,330 $ 370,618 99% % 9.02 Third Party Programs Net Energy Savings (Therms) Program Cost Participants Total Small Business/C&I: 175, , % $ 373,330 $ 370,618 99% % 9.02 Arkansas Weatherization Program 18, % $ 64,644 $ 9,321 14% % 0.64 Energy Efficiency Arkansas $ 22,500 $ 11,760 52% n/a Total Third Party Programs: 18, % $ 87,144 $ 21,081 24% % 0.64 TRC Regulatory $ 275,000 $ 212,874 77% Total: 398, , % $ 2,599,676 $ 2,438,257 94% 3,040 2,753 91% 2.67 AOG s Small Business/C&I Program provided over half of the 2014 net energy savings (341,703 Therms) at a cost of $370,618 followed by the Residential Weatherization Program (offered jointly with OG&E) at 204,227 Therms and a cost of $1,495,002. The Company achieved 148% of its planned net energy savings, while spending 94% of the Portfolio s budget with 91% of planned participation. AOG s individual EE programs have TRC ratios ranging from 0.64 to 9.02, with an overall Portfolio TRC of Appendix B 19 33