General rate proceeding filings by electric, natural gas,
pipeline, and Class A telecommunications companies as defined in WAC
480-120-034
must include the information described in this section. The company and all
parties to an adjudication in a general rate proceeding must file all required
documents in electronic form consistent with the requirements in WAC
480-07-140
and by the next business day must file five paper copies of all testimony and
exhibits unless the commission establishes a different number. If an exhibit is
a database, spreadsheet, or model, the paper copy of that exhibit may simply
reference or describe its contents if printing the entirety of the database,
spreadsheet, or model would result in a document exceeding five pages and would
render the data, spreadsheet cells, or model unusable. The party, however, must
submit a complete electronic version of the database, spreadsheet, or model,
with all information, formulae, and functionality intact, as part of the
party's electronic filing.
(1)
Testimony and exhibits. The company's initial filing and any
supplemental filings the commission authorizes must include all testimony and
exhibits the company intends to present as its direct case. The company must
serve a copy of the initial filing on the public counsel unit of the Washington
state attorney general's office at the time the company makes the filing with
the commission if the proceeding is the type in which public counsel generally
appears or has appeared in the past. The filing must include a
results-of-operations statement showing test year actual results and any
restating and pro forma adjustments in columnar format that support the
company's general rate request. The company must identify each restating and
pro forma adjustment and the effect of that adjustment on the company's
operations and revenue requirement. The testimony must include a written
description of each proposed restating and pro forma adjustment describing the
reason, theory, and calculation of the adjustment.
(2)
Tariff sheets. The company's
initial filing must include the company's proposed new or revised tariff sheets
in legislative format (i.e., with strike-through to indicate the material to be
deleted or replaced and underlining to indicate the material to be inserted)
consistent with the requirements in WAC
480-80-105,
as well as copies of any tariff sheets that are referenced in the new or
amended tariff sheets.
(3)
Detailed support for proposals.
(a)
General. The company
must include in its initial testimony and exhibits, including those addressing
accounting adjustments, sufficient detail, calculations, information, and
descriptions necessary to meet its burden of proof. Any party responding to the
company's proposal also must include in that party's testimony and exhibits
sufficient detail, calculations, information, and descriptions necessary to
support its filed case.
(b)
Capital structure and rate of return. The company must include
in testimony and exhibits a detailed description of the development of any
capital structure and rate of return proposals. Any other party that files
testimony or exhibits that propose revisions to the company's current capital
structure or authorized rate of return also must provide similar detailed
information in testimony and exhibits supporting its proposal.
(c)
Restating and pro forma
adjustments. Each party that proposes restating or pro forma
adjustments must include in its testimony and exhibits a detailed portrayal of
the restating and pro forma adjustments the party uses to support its proposal
or position. That portrayal must specify all relevant assumptions and include
specific references to charts of accounts, financial reports, studies, and all
similar records on which the party relies. Testimony and exhibits must include
support for, and calculations showing, the derivation of each input number used
in the detailed portrayal, as well as the derivation of all interstate and
multiservice allocation factors.
(i)
Restating adjustments adjust the booked operating results for any defects or
infirmities in actual recorded results of operations that can distort test
period earnings. Restating adjustments are also used to adjust from an
as-recorded basis to a basis that the commission accepts for determining rates.
Restating adjustments must be calculated based on the unadjusted test year
operating results, not on another party's adjustments. The commission may
refuse to consider any adjustment that is not calculated consistent with this
requirement. Nonexclusive examples of restating adjustments are adjustments
that:
(A) Remove prior period
amounts;
(B) Eliminate
below-the-line items that were recorded as operating expenses in
error;
(C) Adjust from book
estimates to actual amounts;
(D)
Annualize ongoing costs that the company began to incur part way through the
test year;
(E) Normalize weather or
hydro conditions; or
(F) Eliminate
or normalize extraordinary items recorded during the test period.
(ii) Pro forma adjustments give
effect for the test period to all known and measurable changes that are not
offset by other factors. The company and any other party filing testimony and
exhibits proposing pro forma adjustments must identify dollar values and
underlying reasons for each proposed pro forma adjustment. Pro forma
adjustments must be calculated based on the restated operating results. Pro
forma fixed and variable power costs, net of power sales, may be calculated
directly based either on test year normalized demand and energy load, or on the
future rate year demand and energy load factored back to test year loads.
(iii) If a party proposes to
calculate an adjustment in a manner different than the method the commission
most recently accepted or authorized for the company, the party must also
include in testimony and exhibits the rationale for, and documents that
demonstrate, how that adjustment would be calculated under the methodology
previously accepted by the commission and must explain the reason for the
proposed change. Commission approval of a settlement does not constitute
commission acceptance of any underlying methodology unless the commission so
states in the order approving the settlement.
(d)
Revenue sources. The
company must include in testimony and exhibits a detailed portrayal of revenue
from regulated sources, by source, during the test year and the changes that
would result in those revenues if the commission approves the company's
request, including an explanation of how the resulting changes were
derived.
(e)
Achievement of
rate of return. The company must demonstrate in testimony and exhibits
why the company has not achieved its authorized rate of return and what actions
the company has taken prior to and during the test year to improve its earnings
in addition to its request for increased rates. If the company has not taken
any such actions, the company must explain why it has not.
(f)
Rate base and results of
operations. The company's testimony and exhibits must include a
representation of the company's actual rate base and results of operations
during the test period, calculated in the same manner the commission used to
calculate the revenue requirement in the final order in the company's most
recent general rate proceeding.
(g)
Affiliate and subsidiary transactions. The company's testimony
and exhibits must supplement, as necessary, the annual affiliate and subsidiary
transaction reports required in rules governing reporting for the applicable
industry to include all such transactions during the test period. The company
must identify all affiliate and subsidiary transactions that materially affect
the proposed rates. The company must support the allocation method the company
used to distribute common costs between regulated and nonregulated affiliated
entities and the dollar amount of those costs.
(h)
Electronic documents and
confidentiality. Electronic files must be fully functional and include
all formulas and linked spreadsheet files. Electronic files that support
exhibits must use logical file paths, as necessary, by witness and must use
identifying file names consistent with the naming requirements in WAC
480-07-140.
A party may file a document with locked, hidden, or password protected cells
only if such restricted access is necessary to protect the information within
the cells that is not subject to public disclosure. The party must identify
each locked, hidden, or password protected cell and must designate such cells,
as well as any other information the party contends is confidential under
RCW
80.04.095 or otherwise protected from public
disclosure, in compliance with the requirements in WAC
480-07-160
and any applicable protective order. The party must make such information
accessible to all persons who have signed the protective order or are otherwise
entitled to access the information including, but not necessarily limited to,
commission staff and public counsel. Redacted versions of models or
spreadsheets that contain information that is designated as confidential or
highly confidential or otherwise protected from public disclosure must be in
.pdf format (using Adobe Acrobat or comparable software) and must mask the
information protected from public disclosure as required in WAC
480-07-160.
(i)
Referenced documents. If
a party's testimony or exhibits refer to a document including, but not limited
to, a report, study, analysis, survey, article, or court or agency decision,
the party's testimony and exhibits must include that document except as
provided below:
(i) A party may include an
official citation or internet Uniform Resource Locator (URL) to a commission
order or to a court opinion or other state or federal agency decision, rather
than the document itself, if that decision is reported in a generally accepted
publication (e.g., Washington Reports Second (Wn.2d), Public Utility Reports
(P.U.R.), etc.) or if the document is readily available on the web site of the
agency that entered that decision;
(ii) A party may include only the relevant
excerpts of a voluminous document if the party also provides a publicly
accessible internet URL to the entire document or describes the omitted
portions of the document and their content and makes those portions available
to the other parties and the commission upon request; and
(iii) A party is not required to file or
distribute materials subject to third-party copyright protection but must
describe those materials and their content and make them available for
inspection upon request by the parties and the commission.
(4)
Work papers.
(a)
General. Work papers are
documents that support the technical aspects of a party's testimony and
exhibits. Work papers may include, but are not limited to, calculations, data
analysis and raw data. Work papers are not a part of a party's direct case.
Within five business days after each party files and serves its testimony and
exhibits, the party also must provide to all other parties the work papers on
which each of its witnesses relied when preparing testimony and exhibits. All
work papers must comply with the requirements of this subsection.
(b)
Organization. Work
papers must be plainly identified and well organized, with different documents
or sections separated by or into tabs, and must include an index. All work
papers must be cross-referenced and include a description of the
cross-referencing methodology.
(c)
Any work papers provided to other parties must comply with requirements
governing electronic documents and confidentiality in subsection (3)(h) and
referenced documents in subsection (3)(i) of this section.
(d)
Filing designated work papers
with the commission. If the commission determines that it needs
information in addition to a party's testimony and exhibits, the commission may
issue a bench request for designated portions of that party's work papers. The
commission will receive into evidence the work papers a party provides in
response to a bench request unless the commission rejects that response, either
in response to an objection or on the commission's own motion, as provided in
WAC
480-07-405(7)(b).
The commission will not rely on any other work papers as the basis for any
finding of fact or conclusion of law in the proceeding unless the commission
formally admits such work papers into the evidentiary record.
(5)
Summary document.
(a)
Contents. The company
must include in its initial filing a document that summarizes the information
in this subsection (5)(a) on an annualized basis, if applicable, and must
itemize revenues from any temporary, interim, periodic, or other noncontinuing
tariffs. The company must include in its rate change percentage and revenue
change calculations any revenues from proposed general rate change tariffs that
would supersede revenue from noncontinuing tariffs. The summary document must
include:
(i) The date and amount of the last
general rate change the commission authorized for the company and the revenue
the company realized from that change during the test period based on the
company's test period units of sale (e.g., kilowatt hours, therms,
etc.);
(ii) Total revenues the
company is realizing at its present rates and the total revenues the company
would realize at the requested rates;
(iii) Requested revenue change in percentage,
in total and by major customer class;
(iv) Requested revenue change in dollars, in
total and by major customer class;
(v) The representative effect of the request
in dollars for the average monthly use per customer, by customer class or other
similar meaningful representation, including, but not limited to, the effect of
the proposed rate change in dollars per month on residential customers by usage
categories;
(vi) Most current
customer count, by major customer class;
(vii) Current authorized overall rate of
return and authorized rate of return on common equity;
(viii) Actual rate of return and actual rate
of return on common equity for the test period;
(ix) Requested overall rate of return and
requested rate of return on common equity, and the method or methods used to
calculate the requested rates of return;
(x) Requested capital structure;
(xi) Requested net operating
income;
(xii) Requested rate base
and method of calculation, or equivalent; and
(xiii) Revenue effect of any requested
attrition allowance.
(b)
Required service.
(i)
Persons to receive service. The company must serve the summary document on the
persons designated below on the same date it files the summary document with
the commission:
(A) The public counsel unit
of the Washington state attorney general's office;
(B) All intervenors on the commission's
master service list for the company's most recent general rate
proceeding;
(C) All intervenors on
the master service list for any other rate proceeding involving the company
during the five years prior to the company's filing, if the company's rate
change request may affect the rates established or considered in that prior
proceeding; and
(D) All persons who
have informed the company in writing that they wish to be provided with the
summary document required under this section.
(ii) Cover letter. The company must enclose a
cover letter with the summary document stating that the company's prefiled
testimony and exhibits, and the accompanying work papers, are available from
the company on request, subject to any restrictions on information that is
protected from public disclosure, if the company is not serving them along with
the summary document.
(iii)
Limitation. This service requirement does not create a right to service or
notice of future filings in the proceeding to the persons named to receive the
summary. Any person other than commission staff and public counsel who wishes
to be served documents subsequently filed in the general rate proceeding must
petition to intervene in that proceeding.
(6)
Cost of service studies. The
initial filing must include a cost of service study that complies with chapter
480-85 WAC.
(7)
Additional
documents. The company's initial filing must include the following
documents or an internet URL for each of these documents:
(a) The company's most recent annual report
to shareholders, if any, and any subsequent quarterly reports to
shareholders;
(b) The company's
most recent FERC Form 1 and FERC Form 2 for electric and natural gas companies;
and
(c) The company's Form 10K's,
Form 10Q's, any prospectuses for any issuances of securities, and quarterly
reports to stockholders, if any, for the most recent two years prior to the
rate change request.