Public Service Commission. November 2,2015. Re: CASE NO E-P MONONGAHELA POWER COMPANY and THE POTOMAC EDISON COMPANY

Transcription

1 01 Brooks Street, P.0 Box 1 Charleston, West Virginla 33 Public Service Commission of West Virginia Phone (30) Fax (30) 3003 November,01 Ingrid Ferrell, Executive Secretary Public Service Commission PO Box 1 Charleston, West Virginia 33 Dear Ms. Ferrell: Re: CASE NO. 1-1-E-P MONONGAHELA POWER COMPANY and THE POTOMAC EDISON COMPANY Enclosed for filing is an original and twelve copies of the PreJiled Direct Testimony ofsteve Wilson and Randall Short in the above-referenced proceedings. A copy has been served upon all parties of record. we Sincerely, JOHN R. AUVILLE Staff Attorney West Virginia State Bar I.D. No. 0 JWbg Enclosures H:\jauville\Word\l 1 monpower\testimony.doc

2 PUBLIC SERVICE COMMISSION OF WEST VIRGINIA CHARLESTON CASE NO. 1-1-E-P MONONGAHELA POWER COMPANY AND THE POTOMAC EDISON COMPANY CERTIFICATE OF SERVICE I. JOHN R. AUVILLE Staff Counsel for the Public Service Commission of West Virginia, hereby certify that I have served a copy of the foregoing Pvefiled Direct Testimony of Steve Wilson and Randall Short upon all parties of record by First Class United States Mail, postage prepaid this nd day of November, 01. Gary A. Jack, Esq. Senior Corporate Counsel Monongahela Power Company and The Potoinac Edison Company 00 1 NASA Boulevard Fairmont, WV Heather B. Osborn, Esq. Consumer Advocate Division 00 Union Building 3 Kanawha Boulevard, East Charleston, WV 301 Christopher L. Callas, Esq. Counsel, Monongahela Power and The Potomac Edison Company JacksonKelly PLLC PO Box 3 Charleston, WV 3 Emmett Pepper, Esq. Counsel West Virginia Citizen Action Group 0 Dixie Street Charleston, WV 3 Susan J. Riggs, Esq. Counsel West Virginia Energy Users Group Spilman Thomas & Battle PO Box 3 Charleston, WV JaHN R. AUVILLE Staff Attorney West Virginia State Bar I.D. No. 0

3

4 CASE NO. 1-1-E-P Page 1 DIRECT TESTIMONY OF: STEVE R. WILSON 1 Q. 3 A. Q- A Q: 0 A: 1 3 PLEASE STATE YOUR NAME, BUSINESS ADDRESS AND OCCUPATION. My name is Steve R. Wilson. My business address is 01 Brooks Street, Charleston, West Virginia, 33. I am employed as a Utilities Analyst with the Utilities Division of the Public Service Commission of West Virginia. PLEASE STATE YOUR BACKROUND AND QUALIFICATIONS. I graduated with an Associate s Degree in Commerce from Potomac State College in Keyser and earned a Bachelor s Degree in Business Management from West Virginia University in Morgantown. I also earned a MBA Degree from Frostburg State University in Frostburg, Maryland. I have been employed with the Public Service Commission for twenty-two years. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS CASE? The purpose of my testimony is to present Staffs recommendation related to the request made by Monongahela Power Company ( Mon Power ) and The Potomac Edison Company ( PE ) together, the ( Companies ), to adjust ENEC rates in their filing with the Commission ofaugust,01.

5 CASE NO. 1-1-E-P Page DIRECT TESTIMONY OF: STEVE R. WILSON 1 Q: 3 A: Q. 1 A WHY DID THE COMPANIES MAKE THIS FILING? In the Companies 00 general rate case, Case No E-T, the Companies proposed and the Commission accepted the re-establishment of the ENEC method of recovering net power supply costs, including fuel costs, purchased power costs, and other related expenses, net of related revenue. In addition, the Companies were directed to file ENEC information and its impact on electric rates on or before September 1, 00, and by September 1 of subsequent years. HAVE THE COMPANIES FILED AN ENEC CASE ANNUALLY SINCE THE 00 CASE? No. The Companies filed for the new ENEC rates in 00 and 00. In the Companies 00 base rate case, Case No. 0--E-T, a Joint Settlement agreement was reached whereby no ENEC case was to be filed in 0. As part of the agreement effective January 1, 0, the Companies ENEC rates were reduced and base rates were increased by $0 million. The Commission approved the Joint Settlement Agreement in the Companies 00 base rate case. The Companies filed an ENEC case in 0 in which the Commission issued an Order approving a Joint Stipulation that proposed the ENEC rates of the Companies should be increased to generate additional revenues of $. million to cover prior period under-recovery costs and projected net energy costs for 01, effective January 1, 01. The Companies filed an ENEC case in 01 in which the

6 CASE NO. 1-1-E-P Page 3 DIRECT TESTIMONY OF: STEVE R. WILSON 1 3 Q. A. 1 Q. 1 A Q. 3 Commission approved a $,0, decrease in ENEC rates. There was no ENEC filing for the year 0 pursuant to party agreement and Commission consent. WHEN WAS THE LAST ENEC CASE PRIOR TO THIS FILING? The last ENEC tiling was Case No. --E-P, filed on August,0, which covered the two-year period of July 1, 01 through June 30, 0. A Joint Stipulation was reached by the parties to this case and was dated December, 0, presented to the Commission, and accepted. PLEASE SUMMARIZE THE COMPANIES ORIGINAL PROPOSAL IN THIS FILING BEFORE THE COMMISSION. The original proposal was a $1,03,30 annual increase in ENEC rates to be effective on January 1, 01, or earlier, if possible. The amount was comprised of an under-recovery balance of $,, as of June 30, 01, a projected underrecovery of $3,0, for the 01 effective period, and an under-recovery from the Companies Temporary Transaction Surcharge ( TTS ) for the Harrison Power Station of $,,. HOW HAS THE COMPANIES PROPOSAL BEEN AFFECTED BY THE PJM TRANSITIONAL AUCTION FOR CAPACITY PERFORMANCE?

7 CASE NO. 1-1-E-P Page DIRECT TESTIMONY OF: STEVE R. WILSON A. Mon Power and PE filed supplemental direct testimony on September, 01. Company witness Jay A. Ruberto introduced testimony that projects an increase in capacity revenues of $,, during the period of June 1, 01 through December 31, 01, as a result of the Capacity Performance Transition Auction. Company witness Melanie Mancuso introduced testimony that projects an increase in capacity cost of $,,3 during the period of June 1, 01 through December 31, 01, as a result of the Capacity Performance Transition Auction. The net impact is an increase in revenues of $0,,3, which decreases the Companies ENEC proposal from roughly $1.1 million to $. million. The allocation to the Company rate schedules uses the same demand allocation factors as the original submission. Q. PLEASE SUMMARIZE THE COMPANY S REVISED PROPSAL. A. The Total Deferred ENEC Balance consists of demand revenue and energy revenue minus demand costs and energy costs. In addition, deferred costs from Case No. --E-P were removed along with their carrying charges from January, 01 to June, 01 in the amount of $1,0,1. Added into the amount was the aforementioned $,, representing the deferred TTS balance. The Total Deferred ENEC Fuel Balance appears on REV- as follows:

8 CASE NO. 1-1-E-P Page DIRECT TESTIMONY OF: STEVE R. WILSON OverKJnder Balance at June 30,01 $ (,3,) Deferred Costs from January, 01 to June, 01 (1,0,1) Deferred TTS Balance (,,) OverKJnder Forecast Balance (3,0,) Proposed Increase Effective January 1,01 $ 1,03,30 With the supplemental direct testimony filed by the Companies on September and the change in the PJM Transition Auction and the resultant effect upon the forecast period, the ENEC proposal is reduced to $. million. The change from the PJM Transition Auction is reflected in the OveriUnder Forecast Balance below: OverKJnder Balance at June 30,01 $ (,3,) Deferred Costs from January, 01 to June, 01 (1,0,1) Deferred TTS Balance (,,) Over/Under Forecast Balance ( 3,0,0) Proposed Increase Effective January 1,01 $,1, 1 3

9 CASE NO. 1-1-E-P Page DIRECT TESTIMONY OF: STEVE R. WILSON 1 Q* 3 A. Q. WHAT CHANGE IN ENEC RATES ARE THE COMPANIES REQUESTING BASED UPON THE REVISED REQUEST? The Companies propose to increase their annual ENEC rates by $, 1, effective January 1, 01, as shown on the previous page. This is an overall.% increase in ENEC revenues. HAVE YOU MADE ANY ADJUSTMENTS TO THE COMPANIES PROPOSED INCREASE? IO A Q. 1 No. My review of the historical period did not result in any adjustments to the reported underiover recovery amount. In addition, I do not have any adjustments to the forecast period. HAS STAFF DETEMINED THAT ANY ADJUSTMENTS SHOULD BE MADE TO THE ENEC RATES PROPOSED BY THE COMPANY? 1 A. 0 Staff offers two adjustments to the ENEC proposed rates. Those adjustments will be presented in the direct testimony of Staff witness Randall Short. 1 3 Q. A. DOES THIS CONCLUDE YOUR TESTIMONY? Yes.

10

11 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER 1 1 Q. 3 A. Q- A. PLEASE STATE YOUR NAME, OCCUPATION AND YOUR BUSINESS ADDRESS. My name is Randall R. Short and my business address is 01 Brooks Street, P.O. Box 1, Charleston, West Virginia 33. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? I am employed as the Deputy Director, Carrier and Consumer Operations Section of the Public Service Commission s Utilities Division. Q. 1 A. WHAT IS YOUR EDUCATION BACKGROUND AND WORK EXPERIENCE? I attended Marshall University and received a Bachelor of Science Degree in Business Administration in 1 and a Master s Degree in Business Administration in. I have received additional training through the Institute of Public Utilities at Michigan State University and the Center for Public Utilities at New Mexico State University. I was employed by the Consumer Advocate Division of the Public Service Commission of West Virginia for fifteen years as a Utilities Analyst. I began employment as a Utilities Analyst for the Public Service Commission in July 00. In 01 1 I moved to the Quality Assurance Section as an advisor to the Commission. I began my current position in October 01. I have been awarded the professional designation Certified Rate of Return Analyst (CRRA) by the National Society of Rate of Return Analysts. This designation is awarded based upon experience and the successful completion of a written examination. I am also a member of the Society of Utility and Regulatory Financial Analysts.

12 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER 1 3 Q. A. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THIS COMMISSION? Yes, I have previously submitted testimony in a wide variety of cases involving gas, electric, water and telephone issues before this Commission. 1 Q. A. WHAT IS THE PURPOSE OF YOUR TESTIMONY? The purpose of my testimony is to address two cost recovery components of the proposed Expanded Net Energy Cost ( ENEC ) filing for Monongahela Power Company and The Potomac Edison Company ( Companies ). Those two items are the Temporary Transaction Surcharge ( TTS ) and the recovery of costs related to the outage of Unit 1 of the Hannibal Lock and Dam Project. I will also address the quarterly ENEC rate adjustment proposed by Company Witness Raymond Valdes Q. A. PLEASE BRIEFLY EXPLAIN THE TEMPORARY TRANSACTION SURCHARGE AND HOW IT CAME TO BE PART OF THIS ENEC PROCEEDING. The TTS was implemented on October, 0, pursuant to the Commission Order in Case No. 1--E-PC. That case approved a generation transaction where Monongahela Power acquired the remaining.% of the Harrison Power Station ( Harrison ) and sold its.% share of the Pleasants Power Station. The Companies were authorized to impose a temporary transaction surcharge until rates from the next base rate case went into effect. The TTS was designed to recover the net increase in non-fuel operation and maintenance expenses 0fll

13 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER 3 ( O&M )), depreciation and amortization expenses and taxes other than income taxes, a return on incremental net plant, fuel inventory and materials and supplies resulting from completion of the generation transaction. The TTS remained in effect until February, 01, the day before the Companies base rates changed as a result of the Commission approved settlement agreement in Case No. -00-E-T. The settlement and Commission order in the generation transaction case provided for deferred accounting treatment with the final TTS regulatory asset or liability balance to be recovered or refunded to customers through rates determined in the next ENEC review following termination of the TTS. This case is the first ENEC case after the termination of the TTS Q. HAVE THE COMPANIES RECONCILED THE TTS IN THIS PROCEEDING? A. Yes. The Direct Testimony of Kevin Wise reflects a TTS deferral balance underrecovery of $,,3. He calculates that during the approximately seventeen months the TTS was in effect, rates were designed to produce $. million, while actual costs totaled $. million, as shortfall of $3 million. Additionally, revenues were $.3 million less during the review period than projected due to lower kwh energy and kw demand sales, producing a total under-recovery of $. million. 3OfII

14 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER 1 Q. 3 A. 1 WHAT COMPONENTS OF THE TTS LED TO THE ACTUAL COSTS BEING $3 MILLION HIGHER THAN PROJECTED COSTS AND HOW DID THE COMPANIES EXPLAIN THE DIFFERENCES? The biggest component was increased O&M expense of $. million, followed by return $. million, depreciation and amortization $3. million, and taxes other than income taxes $3. million. Excluding the increased O&M, the other increases in costs were largely driven by the timing of when the generation transaction actually occurred versus when it was first projected to occur. This resulted in different plant balances than originally estimated. The $. million increase in O&M expense during the seventeen month review period was almost entirely a result of $. million of O&M expense related to maintenance outages at Harrison booked to the TTS calculation for one mouth, December 0. 1 Q. 1 1 A HOW ARE THE COMPANIES PROPOSING TO RECOVER THE $. TTS DEFERRAL BALANCE? The Companies are seeking to recover the entire $. million TTS balance in the proposed ENEC recovery increment. The Companies proposed the TTS underrecovery be applied to the demand component of the correction factor. With a revised total ENEC proposed increase of $. million, as shown in the Supplemental Direct Testimony of Raymond Valdes, the $. million TTS surcharge accounts for approximately 3 1% of the total ENEC request. Absent the TTS surcharge, the proposed ENEC increase would be $0 million. 0f

15 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER 1 Q- 3 A WHAT CATEGORIES OF COSTS ARE TYPICALLY RECOVERED IN AN ENEC PROCEEDING? An ENEC case is a type of rate proceeding for electric utilities that reviews the fuel, purchased power, purchased transmission costs and PJM costs incurred by an electric utility to provide electric service to customers. It is sometimes referred to as a fuel review rate proceeding because the historical purpose of an ENEC case is for an electric utility to request rate adjustments that allow it to flow back to ratepayers the difference between those costs as allowed in rates and the net costs of obtaining fuel and fuel-related purchased power that the utility uses to produce electricity and provide electric service to customers. An ENEC proceeding does not address other costs such as salaries, maintenance, administrative costs and real estate expenses that are the subject of base-rate proceedings. ENEC proceedings do not contain any allowance for profit or rate of return. The Commission provides the Companies with an opportunity to recover net energy costs as long as they can demonstrate that they have been prudent and exercised reasonable management judgment incurring and controlling those costs. ENEC costs are typically the most volatile for the utility and comprise the greatest component of customer rates. Case No. --E-P, Order of January,01. 0 Q. 1 3 A. ARE YOU CLAIMING IT IS INAPPOPRIATE TO SET RATES TO RECOVER THE TTS DEFERRAL BALANCE IN THIS ENEC PROCEEDING BECAUSE THOSE TYPES OF COSTS HAVE NOT HISTORICALLY BEEN RECOVERED IN AN ENEC PROCEEDING? No, I am not. The approved stipulation and Commission order in the generation transaction case authorized the TTS and directed that rates be set in the first

16 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER ENEC proceeding following the termination of the TTS to reconcile the deferral balance. I cited the background language from last ENEC Order for the Companies to help explain the mechanics of a traditional ENEC proceeding and to differentiate what costs have historically been recovered. O&M expenses for work performed at the Companies owned facilities are typically recovered through base rates and the appropriate level of expense to be recovered is established by examining the level of expense during a test period. Because the level of O&M expenses may vary greatly from year to year, it is often prudent to look at the trend or average level of expense over a longer period The level of O&M expenses was highly variable during the review period. As I previously stated, the $. million variance of O&M expense is almost entirely reflective of one month of O&M expense, $. million allocated to the TTS calculation for December 0. The next highest month for O&M expense allocated to the TTS was $. million for November 0. Over the seventeen month review period, the average monthly O&M expense allocated was $3. million per month. If I exclude December 0 outlier figure from the calculation, the average O&M allocated to the TTS was only $. million per month. 0 Q. 1 3 A. ARE YOU PROPOSING A DIFFERENT CALCULATION FOR RECOVERY OF THE TTS DEFERRAL THAN THE COMPANIES PROPOASAL? Yes I am. I am proposing to include recovery of all of the TTS deferral amounts related to return, depreciation and amortization, taxes other than income taxes and ofii

17 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER revenue shortfalls in the proposed ENEC rate. Those totals were largely driven by timing issues and sales levels beyond the Companies control. O&M expenses, especially as related to planned outages, are more within the Companies control as related to the timing. While the stipulation in the generation transaction case provided for a reconciliation of the TTS deferral balance in this ENEC proceeding, I do not believe that it mandated those costs be recovered over a one-year period. I am proposing that the $. million of deferred O&M TTS expenses be amortized for recovery over a three-year period. Such a calculation provides $.3 million of deferred TTS O&M expense be included in the calculation of the ENEC increment for this period and the remaining $1. million be recovered in the next two ENEC periods. In summary I am proposing to include a total of $ million of the TTS deferral for recovery in the ENEC rate, which is $1. million less than the Companies proposed. The remaining $1. million will be amortized over the following two ENEC recovery periods. 1 1 Q. 1 PLEASE PROVIDE MORE DETAIL ABOUT THE OUTAGE AT UNIT 1 OF THE HANNIBAL LOCK AND DAM PROJECT AND ITS EFFECT ON THE COMPANIES CURRENT ENEC RECOVERY REQUEST. 0 A. The Hannibal Lock and Dam Project ( Hannibal ) is a hydroelectric power plant 1 located on the Ohio River at new Martinsville, WV. The Companies purchase the output from Hannibal under a Public Utility Regulatory Policies Act of 3 ( PURPA ) contract. According to Companies witness Mancuso, under the terms of the Hannibal contract, all operation and maintenance costs are paid by Monongahela Power (Mon Power) and are then included in the ENEC. OfII

18 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER In July 0, Unit 1 of the Hannibal Lock and Dam Project went offline due to failure of multiple bolts holding the turbine shaft in place. The unit is expected to be offline until July 01 (Mancuso Direct at pp. 1, ). An insurance claim has been filed to recover the costs of the repair. In her direct witness Mancuso states the O&M costs associated with the repair from July 0 through June 01 (the ENEC period) are $. million and that based on actual expenses paid, the insurance claim proceeds should equal what Mon Power has expended to date. In a data response to the Third West Virginia Energy User Group Request for Information, question, Ms Mancuso stated the actual costs associated with the Hannibal repair from July 0 to June 01 were $. million and are included in the Companies current ENEC recovery request. She went on to state that at the time of the ENEC filing, it was anticipated that $. million of costs would have been paid, but due to changes in the contract terms with vendors performing work at Hannibal, $ million of the $. million will now be included in the next ENEC cost recovery period Q. A. THE COMPANIES ARE SEEKING TO RECOVER EITHER $. MILLION OR $. MILLION THAT WERE INCLUDED AS EXPENSE IN THE ENEC RECOVERY REQUEST. WHAT ARE YOU PROPOSING? The Companies expect to recover through an insurance claim the O&M costs associated with the repair of the Hannibal Unit 1 facility. I am proposing that instead of including the Hannibal O&M repair costs in the ENEC recovery at this time, those costs be removed until the insurance claim is resolved.

19 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER Q. HAVE THE COMPANIES INCLUDED ANY OTHER COSTS ASSOCIATED WITH THE HANNIBAL PROJECT OUTAGE IN THEIR ENEC RECOVERY REQUEST? A. There were other items that are ordinarily reconciled in the ENEC due to the outage including lost generation but they were not included in the Companies ENEC calculation. As offered by the Companies, a claim for lost generation revenue is being made with the insurance company and any money received because of revenue that was lost by not generating while the repairs to Unit 1 were being made will be additional revenue to the benefit of ratepayers through the ENEC. If Hannibal had been fully operating during the ENEC period, the Companies would have realized a higher level of revenues from that facility. The ENEC request would have reflected those higher revenues, thus a lower ENEC request. Witness Mancuso testified that the value of the lost generation during the two year outage at Hannibal will be at least $. million. What is not clear is if the Companies had to replace that lost generation to satisfy load and if so, what was the cost? That would be a cost, not lost revenue. Further, I also am not able to tell how much of the $. million that Witness Mancuso estimates will be the minimum value of the lost generation during the two year outage is from the current ENEC period. Additionally, Mancuso stated the policy maximum for the Business Interruption claim is $. million, although it is not explained if that is an amount per year or for the entire outage. ofll

20 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER WHAT IS YOUR RECOMMENDATION REGAFUDING THE LOST 3 A. GENERATION REVENUE DUE TO THE OUTAGE AT HANNIBAL UNIT l? I propose to adjust the ENEC request to reflect the lost generation revenues during the ENEC period. Witness Mancuso testified the Companies expect to receive an insurance settlement for lost generation revenues. She states such settlement will be credited to a future ENEC. I am proposing to credit the amount to this ENEC. Q* 1 A COMPANIES WITNESS VALDES IS PROPOSING THE COMMISSION CONSIDER QUARTERLY ENEC RATE ADJUSTMENTS. EXPLAIN HOW THIS IS PROPOSAL IS DIFFERENT FROM THE CURRENT ANNUAL ENEC ADJUSTMENT. As proposed, the existing ENEC annual review process would continue with the same time frames as are currently in place. The Companies proposal is to supplement the existing process and provide for quarterly ENEC rate adjustments. The Companies propose adding quarterly rate adjustments, called a quarterly reconciliation factor ( R-Factor ) to reflect variations from the expected levels of expenses and revenues during each quarter and the actual level of revenues and expenses. The factor could be positive (indicating an under-recovery for the period, so increase the ENEC Rate in a future quarter) or negative (indicating an over-recovery-need to decrease the ENEC revenue in a future quarter) Quarters are defined as calendar quarter, beginning January 1, April 1, July 1 and October 1 of each year. 0fll

21 Case Number: 1-1-E-P DIRECT TESTIMONY OF RANDALL R. SHORT PAGE NUMBER 1 Q. 3 A WHAT ARE YOUR THOUGHTS REGARDING THE COMPANIES QUARTERLY ENEC RATE ADJUSTMENT PROPOSAL? I agree that as filed, the Companies proposed ENEC rate increase of $1 million is very large, representing an approximate 1.% increase in total rates. For some classes of customers the percentage increase is even larger. After the filing of Supplemental Direct by the Companies on September, 01 to reflect the favorable outcome of the transitional auction for capacity performance, the proposed increase is now $. million. That amount includes $. million associated with reconciliation of the TTS. The $. million reconciliation is not a typical included ENEC cost and distorts this year s request. Additionally, while I do not fault the Companies for proposing an idea to maybe help alleviate a large ENEC adjustment in the future, I am concerned with such frequent adjustments to rates and the potential problems. For large energy users like manufacturers, where energy costs are a large component of their manufacturing expense, it is important to be able to price their products accordingly, with some certainty for a period likely longer than a quarter. I am also concerned with the perception by residential and small commercial customers about electric rates that would change with such frequency. An annual ENEC review process allows an in depth examination of the proposed ENEC rate by all interested parties and I believe it would be burdensome to approve a quarterly ENEC adjustment upon those parties. 3 Q. A. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? Yes, it does. Ilofll