Control Number : 39896
Item Number : 62
Addendum StartPage : 0
SOAH Docket No. 473-12-2979
PUCT Docket No. 39896
APPLICATION OF ENTERGY
TEXAS, INC. FOR AUTHORITY TO
CHANGE RATES, RECONCILE FUEL
§
§
§
COSTS, AND OBTAIN DEFERRED
§
ACCOUNTING TREATMENT
§
P :,d i
i
^t^^ k:"/'^•O
BEFORE THE STATE OFFICC.
!9
OF
ADMINISTRATIVE HEARINGS
CITIES' SEVENTH REQUEST FOR INFORMATION
Pursuant to §22.144 of the Commission's Procedural Rules, the Cities of Bridge City,
Groves, Orange, Pine Forest, and West Orange, Texas ("Cities"), request that Entergy Texas,
Inc. ("ETI" or "Company"), by and through its attorneys of record, provide all information
requested on the attached Exhibit "A" within twenty (20) calendar days of receipt thereof
pursuant to P.U.C. Proc. R. 22.144(c)(1).
Pursuant to P.U.C. Proc. R. 22.144(c)(2), Cities further request that answers to the
requests for information be made under oath.
Each answer should identify the person
responsible for preparing that answer (other than the purely clerical aspects of its preparation)
and the name of the witness in this proceeding who will sponsor the answer and who can vouch
for its accuracy. In producing documents pursuant to this request for information, please indicate
the specific request(s) to which the document is being produced. These requests are continuing
in nature, and should there be a change in circumstances, which would modify or change an
answer supplied by you, such changed answer should be submitted immediately as a supplement
to your original answer pursuant to P.U.C. Proc. R. 22.144(i). Please answer each request and
sub-request in the order in which they are listed and in sufficient detail to provide a complete and
accurate answer to the request. Cities further request that each item of information be made
available as it is completed, rather than upon compilation of all information requested.
All information responsive to the requests on the attached Exhibit "A" should be sent to
the following via overnight courier, on a piecemeal basis as individual items become available:
Daniel J. Lawton
701 Brazos, Suite 500
Austin, Texas 78701
(512) 322-0019
(512) 716-8917 - fax
Page 1
0
DEFINITIONS AND INSTRUCTIONS
A.
"ETI," "the Company" or "you" refers to Entergy Texas, Inc., and any person
acting or purporting to act on their behalf, including without limitation, attorneys, agents,
advisors, investigators, representatives, employees or other persons.
The terms "document" or "documents" are used in their broadest sense to include,
B.
by way of illustration and not limitation, all written or graphic matter of every kind and
description whether printed, produced or reproduced by any process whether visually,
magnetically, mechanically, electronically or by hand, whether final or draft, original or
reproduction, whether or not claimed to be privileged or otherwise excludable from discovery,
and whether or not in your actual or constructive possession, custody, or control. The terms
include writings, correspondence, telegrams, memoranda, studies, reports, surveys, statistical
compilations, notes, calendars, tapes, computer disks, data on computer drives, e-mail, cards,
recordings, contracts, agreements, invoices, licenses, diaries, journals, accounts, pamphlets,
books, ledgers, publications, microfilm, microfiche and any other data compilations from which
information can be obtained and translated, but you if necessary, into reasonably useable form.
"Document" or "documents" shall also include every copy of a document where the copy
contains any commentary or notation of any kind that does not appear on the original or any
other copy.
Pursuant to Rule 196.4 of the Texas Rules of Civil Procedure, Cities specifically
C.
request that any electronic or magnetic data (which is included in the definition of "document")
that is responsive to a request herein be produced on CD-Rom in a format that is compatible with
Microsoft and/or Word Perfect and be produced with your response to these requests.
D.
The terms, "and" and "or" shall be construed both disjunctively and conjunctively
as necessary to make the request inclusive rather than exclusive.
E.
"Each" shall be construed to include the word "every" and "every" shall be
construed to include the word "each."
« any. „
F.
"Any" shall be construed to include "all" and "all" shall be construed to include
G.
The term "concerning," or one of its inflections, includes the following meanings:
relating to; referring to; pertaining to; regarding; discussing; mentioning; containing; reflecting;
evidencing; describing; showing; identifying; providing; disproving; consisting of, supporting;
contradicting; in any way legal, logically or factually connected with the matter to which the
term refers; or having a tendency to prove or disprove the matter to which the term refers.
H.
The term "including," or one of its inflections, means and refers to "including but
not limited to."
Page 2
I.
Words used in the plural shall also be taken to mean and include the singular.
Words used in the singular shall also be taken to mean and include the plural.
The present tense shall be construed to include the past tense, and the past tense
J.
shall be construed to include the present tense.
K.
If any document is withheld under any claim of privilege, please furnish a list
identifying each document for which a privilege is claimed, together with the following
information: date, sender, recipients or copies, subject matter of the document, and the basis
upon which such privilege is claimed.
L.
Pursuant to P.U.C. Proc. R. 22.144(g)(4), if the response to any' request is
voluminous, please provide a detailed index of the voluminous material.
M.
If the information requested is included in previously furnished exhibits,
workpapers, responses to other discovery inquiries or otherwise, in hard copy or electronic
format, please furnish specific references thereto, including Bates Stamp page citations and
detailed cross-references.
Respectfully submitted,
LAWTON LAW FIRM, P.C.
Ps A
Daniel J. La on
91082
Stephen Ma k
24041374
Molly L. Mayhall
24048265
701 Congress Ave., Suite 500
Austin, Texas 78701
(512) 322-0019
(512) 716-8917 Fax
ATTORNEY FOR CITIES
CERTIFICATE OF SERVICE
I hereby certify that a copy of this document was served on all parties of record in this
proceeding on this 3rd day of January, 2012, by First Class, U.S. Mail, hand delivery, facsimile,
or in accordance with SOAH Order No. 1 from this proceeding.
JIM ^ 6
1,4 a
6W
Molly . Ma hall '/
Page 3
ATTACHMENT A
SOAH Docket No. 473-12-2979
PUCT Docket No. 39896
APPLICATION OF ENTERGY
TEXAS, INC. FOR AUTHORITY TO
§
§
CHANGE RATES, RECONCILE FUEL §
COSTS, AND OBTAIN DEFERRED
§
ACCOUNTING TREATMENT
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
CITIES' SEVENTH REQUEST FOR INFORMATION
7-1.
[CWC] Please provide a copy of each cash working capital testimony, rebuttal testimony
and corresponding exhibits submitted by Mr. Joyce during the past 5 years.
7-2.
[CWC] Please provide a copy of each depreciation study, testimony, rebuttal testimony
and corresponding exhibits submitted by Mr. Joyce during the past 5 years.
7-3.
[CWC] Please provide a copy of each speech, article, paper, presentation, etc. submitted
by Mr. Joyce during the past 5 years regarding the topic of cash working capital or
depreciation.
7-4.
[CWC] For each of the Adjusted Test Year Amounts (Column (b)) and Amortization of
Prepayments (Column (c)) referenced on Exhibit JJJ-3, please provide the following:
a.
the source of each value, including the specific location within the Test Year cost
of service where it can be located, and a complete reconciliation to cost of service
values, if different,
b.
the calculation of the value,
c.
the amount by month reflected in the rate base component of prepayments for the
test year for each prepayment,
d.
the support and justification for claiming each prepayment amount as a
prepayment, and all work papers, assumptions, considerations, and material
reviewed and/or relied upon associated with the responses to each subpart above
in sufficient detail to verify the accuracy of each response.
Page 4
7-5.
[C WC] Please provide a detailed definition of "service period" as used on line 10, page 7
of Mr. Joyce's testimony. Further, to the extent there is a difference between "service
period" and when a product or service is provided or received, not when it is recorded on
the Company's books, specifically state so and provide all support and justification for
such position.
7-6.
[CWC] Please provide a detailed definition of what is meant by the phrase "costs were
incurred" as used on lines 18 and 19, page 7 of Mr. Joyce's testimony. Further, to the
extent there is a difference between when "costs were incurred" and when a product or
service is received, not when it is recorded on the Company's books, specifically state so
and provide all support and justification for such position.
7-7.
[CWC] For each sampling method employed as referenced on page 7 of Mr. Joyce's
testimony, please identify in detail the method, and provide all support and justification
that each sampling method is "typical" of the methods used to develop CWC studies.
7-8.
[CWC] Regarding the statement at page 10 of Mr. Joyce's testimony that the results of
the analysis to determine the number of days between meter reading date and billing date
were confirmed by the metering and billing calendars for the Test Year, please identify
and provide all analyses performed to establish that the number of days is the most
efficient period for such activity. Further, provide all work papers, assumptions,
considerations, and material reviewed and/or relied upon that supports any position that
the actual days for the activity during the Test Year is the most efficient period in
sufficient detail to verify the reasonableness of position.
7-9.
[CWC] Please provide a detailed narrative identifying and justifying the steps and time
duration of each step taken to read meters and process billing information through the
mailing of a bill for each customer class.
7-10.
[CWC] Please identify the type of electronic meter reading devices used to read meters
by customer class, and state the Company's ability to electronically upload meter reading
information to the billing computer system. Further, provide the number of meters read
by type of electronic device by customer class and the total number of meters read by
customer class. Finally, identify all plans and the estimated time frame for
Page 5
implementation of plans to convert the remaining meters so they can be read
electronically.
7-11.
[CWC] Regarding the statement at page 10 of Mr. Joyce's testimony that the collection
lag for MSS-4 and ISB revenues is based on the actual payment dates, please provide all
documents that set forth the contractual requirements for such process, along with all
support and justification for the establishment of such time frames. Further, provide and
fully support all prohibitions that would limit the issuance and payment of such amounts
earlier within the days permitted by the System Agreement.
7-12.
[CWC] Regarding the assumption that one business day is required to clear checks as
referenced on page 10 of Mr. Joyce's testimony, please provide all support and
justification for such assumption. Further, identify all efforts undertaken to eliminate
such delay, including, but not limited to lock-box arrangements.
7-13.
[CWC] Please identify and support the "number of transactions" criteria employed to
determine whether each component of Other Purchased Power components' would be
either sampled or fully reviewed for purposes of determining lead days as referenced on
page 12 of Mr. Joyce's testimony.
7-14.
[CWC] Regarding the claim on page 13 of Mr. Joyce's testimony that employees are paid
on Friday, which is the sixth day after the end of the pay period ending on Saturday,
please provide all support and justification for such claim. Further, provide all bases that
prohibit the reliance on Friday as the end of the pay period.
7-15.
[CWC] Regarding the determination of the average days of service being reimbursed for
payroll costs as referenced on page 13 of Mr. Joyce's testimony, please provide and
support all bases for such determination.
7-16.
[CWC] Regarding the revenue lag sample for the residential class, please provide the
sample information except for 99 customers with account numbers one greater than the
sample relied on in the lead/lag study (e.g., customer 18 rather than 17, customer 670
rather than 669, etc.). The information should be provided both in hard copy and on
electronic medium in Excel readable format.
Page 6
7-17.
[CWC] Please identify the percentage of residential customers that paid 30 to 59, 60 to
89, and 90 or longer days after their mailing date by month during the Test Year.
7-18.
[CWC] Please describe each program implemented during the past 5 years to reduce the
amount of time associated with the revenue collection lag experienced by the Company.
Further, state when each program was implemented and the results of each program.
7-19.
[CWC] Please describe and provide the results of each, if any, test performed to
determine whether a sampled customer bill represented an outlier in the determination of
revenue collection lags by class. If no tests were performed, fully explain why. Finally,
identify and support what constitutes an outlier for sampling purposes associated with
determining collection lags.
7-20.
[CWC] Please provide a detailed narrative along with a step-by-step calculation
corresponding and supporting the 195.77 day lead associated with vacation pay.
7-21.
[CWC] Please provide the actual pattern of vacation pay expensed by employee during
the test Year on electronic medium in Excel readable format, without identification of the
employee. Further, provide the amount of vacation pay carried over to the following
year.
7-22.
[CWC] Please identify each type of payroll other than vacation payroll an employee
earns, but that can be taken at a later date (e.g., sick leave, bereavement time, etc.). For
each such other type of payroll, provide the amount accrued by month during the Test
Year and the amount of those accruals used by month during the Test Year, as well as the
amount carried over past the end of the Test Year and a monthly listing after the test year
for those amounts used. The information should be provided on electronic medium in
Excel readable format.
7-23.
[CWC] Please identify the amount of employee deductions, by category, associated with
incentive compensation corresponding to the categories noted for regular payroll
deductions.
7-24.
[CWC] Please provide a detailed narrative, all support, and the step-by-step derivation of
each lead day used for each category of payroll deductions. Further, identify where each
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payroll deduction amount reflected in the lead/lag analysis can be specifically found in
the cost of service.
7-25.
[CWC] Please provide a complete copy of the Company's employee manual.
7-26.
[CWC] Please provide the Test Year amount of FAS 103, the transition component of
FAS 103, and pension expense, where in the lead/lag analyses each is reflected, and why
each was not separately analyzed.
7-27.
[CWC] Please provide the average length of employment for Company employees.
7-28.
[CWC] Please provide the time period required for an employee to be eligible for each
employee benefit.
7-29.
[CWC] Please provide the time period between when an employee incurs a medical
expense and the employee is reimbursed for such expense during the Test Year.
7-30.
[CWC] Please provide the Test Year amount of medical expense reimbursed to
employees.
7-31.
[CWC] Regarding the Other O&M - Affiliate Transactions group of expenses, please
explain, support and fully justify the assumption that such affiliate transactions transpired
during the prior month. Next, provide the contractual basis for the timing of each
payment. Further, provide a detailed categorization of each separate affiliate transaction,
and where in the cost of service each such amount is specifically located. Finally, to the
extent the amounts in the lead/lag analyses differ from the amount in the cost of service,
provide a detailed reconciliation and justification for the differences.
7-32.
[CWC] Regarding the lag days, positive lead days, reflected in the Other O&M - Third
Party sample, please explain and justify each value and why each is appropriately
included in the analyses.
7-33.
[CWC] Please explain and justify why an invoice was removed from the Other O&M -
Third Party sample analyses.
7-34.
[CWC] Regarding the O&M check float analysis, please explain and justify the decision
to establish an outlier criteria of specifically 15 plus days. Further, provide the dollar
Page 8
amount of each sample item removed in the check float calculation, and where in the
lead/lag study the results of the float analysis is reflected.
7-35.
[CWC] Please reconcile and justify the amounts in the O&M Check Float analysis with
the same invoice in the Other O&M lead day sample analysis.
7-36.
[CWC] Regarding sample items 19 and 24 of the Other O&M sample, invoice number
ET103007 and ET104005, please provide a clear copy of the invoice, a detailed narrative
identifying and explaining what is the product or service being provided, the actual
service period of the product or service, and why and how a conclusion was reached to
rely on the invoice date given the actual information contained on the invoice.
7-37.
[CWC] Regarding sample item 86 of the Other O&M sample, invoice OTD-SP-101,
please provide a narrative identifying how the service period was determined. Further,
explain and justify why such invoice should be included in the lead/lag study given the
nature of the product or service.
7-38.
[CWC] Please explain and justify the assumed mid December service period for Other
O&M sample item 89, invoice 5390, as it relates to the "At Risk Compensation"
component.
7-39.
[CWC] Please provide legible and complete copies of Other O&M sample items 93, 101,
135 and 137, invoice DEX 10013460, 06-011311-10218093-547992, 06-041911-
10300220-628271 and 06-050611-103000451-643699.
7-40.
[CWC] Please confirm that the service period for Other O&M sample item 96, invoice
1012011833333, is for the month of December rather than January. To the extent that the
Company claims the invoice is for the month of January, explain and justify prepayments
for legal services.
7-41.
[CWC] Please reconcile the amount for Other O&M sample item 118 between the
invoice and lead/lag study Excel spreadsheet. Further, explain how and if the February
related activity was factored into the lead day calculation. If the February activity was
not factored into the calculation, provide all support for such position.
Page 9
7-42.
[CWC] Regarding the reference to outliers on page 17 of Mr. Joyce's testimony, please
identify and substantiate what constitutes an outlier, as well as each outlier included in
sample.
7-43.
[CWC] Please provide the actual Federal Income Tax transactions by amount and date
for the past five years.
7-44.
[CWC] Please explain and justify why the lead days for Texas property taxes reflects the
payment clear date rather than the later of the payment clear date or the payment due
date.
7-45.
[CWC] Please explain and justify why Texas State Franchise Tax is not reflected in
prepayment rather than as a component of the lead/lag analyses. Further, provide the
amount of Texas State Franchise Tax reflected in prepayments on a monthly basis for the
13-month period corresponding to a rate base Test Year calculation, and if it was not
included in prepayments, then provide the monthly amounts as if it had been included.
7-46.
[CWC] Please provide a detailed narrative explanation along with a corresponding stepby-step numerical calculation and support for each value and calculation of the Levelized
Residential Billing calculation employed for lead/lag purposes.
7-47.
[CWC] As it relates to the Levelized Residential Billing component of the lead/lag
analysis, please provide the number and annual amount of billings of residential
customers subject to the billing process. Further, explain why the sample size was limited
to 20 bills, and why two of the bills have $0 of payments. Finally, state whether the
levelized billing process is intended not only to collect the expected annual level of
billings for any given customer, but may over or under collect the actual billings during
any given month.
7-48.
[CWC] Please state whether the Company has relied on shorter billing lag days for each
rate class in prior rate cases, and if so, support and justify why a longer billing lag is
appropriate at this time. Further, provide all work papers, assumptions, considerations,
and material reviewed and/or relied upon to support the response.
7-49.
[CWC] Please provide all support and justification for the number of days of float
associated with payments obtained by check, specifically addressing lock box operations.
Page 10
Further, provide a copy of all bank practices relied on for all assumptions reflected in the
quantification.
7-50.
[CWC] Please provide the payment terms associated with all pole attachment revenues.
Further, identify and support the treatment of such revenues in the lead/lag analysis.
7-51.
[CWC] Please provide the payment terms associated with all rents from electric
properties. Further, identify and support the treatment of such revenues in the lead/lag
analysis.
7-52.
[CWC] Please provide the payment terms associated with all miscellaneous service
revenues. Further, identify and support the treatment of such revenues in the lead/lag
analysis.
7-53.
[CWC] Please provide the payment terms associated with all forfeited discount revenues.
Further, identify and support the treatment of such revenues in the lead/lag analysis.
7-54.
[CWC] Please provide the payment terms associated with all miscellaneous revenues.
Further, identify and support the treatment of such revenues in the lead/lag analysis.
7-55.
[Property Insurance Reserve] For each storm that had incurred in the Company's service
territory from January 1997 through the most current month, please state the total amount
of the storm, total amount expensed per occurrence to the insurance reserve account and
the total amount capitalized. Please detail the costs booked for Hurricanes Rita and Ike
that were subsequently removed from the storm reserve.
7-56.
[Property Insurance Reserve] Please quantify the total amount of costs included in the
storm insurance reserve as a result of the January 1997 Ice Storm.
7-57.
[Property Insurance Reserve] Please provide the total costs, capital costs and expenses
associated with restoring power after the January 2007 Ice Storm.
7-58.
[Property Insurance Reserve] Please state the storm reserve balance as of test year end
and monthly to the most current month available. Please explain why Mr. Wilson used
the reserve balance as of June 2009 in his Exhibit GSW-2 calculations.
7-59.
Provide in native excel format, a detailed account of the storm insurance reserve balance
beginning from the Texas retail beginning balance determined in Docket No. 16705
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showing 1) the costs booked to the storm insurance reserve listed by storm or event and
amount, 2) the PUC approved annual accruals by month, 3) and sufficient detail to
determine any redetermination by ETI of costs booked that were subsequently removed
from or included in the storm reserve.
7-60.
Provide in native excel format, a copy of the costs booked to the storm reserve for the
period January 1997 to date with storm loss amounts segregated by (1) Storm or other
event, (2) production costs; (3) transmission costs; (4) distribution costs; and (5) general
costs. Your response should be provided in the same format, with the same information,
as the information provided in Docket No. 34800, question Cities 30-4.
7-61.
Provide any self insurance reserve policy approved by the Louisiana Public Service
Commission for Entergy Gulf States Louisiana, or any of its predecessors since 1997.
7-62.
Referring to ETI's response to Cities' RFI 22-7 in Docket No. 37744, for each adjustment
made to the insurance reserve, provide 1) the weather or catastrophic event causing the
charge, 2) the total expense incurred as a result of the event, 3) the charge originally
allocated to Texas retail customers, 4) the original justification for the charge allocated to
Texas retail customers, 5) the charge originally allocated to Louisiana retail customers, 6)
the original justification for the charge allocated to Louisiana retail customers, and 7)
ETI's reasoning for reallocating the charges to Texas, and 8) the calculation used to
determine the reallocation.
7-63.
Referring to the Direct Testimony of Gregory Wilson at page 5, line 7, provide all
supporting calculations, studies, or data relied upon to support the use of $150 million as
opposed to $100 million in Docket No. 37744.
7-64.
Please provide the line loss study and associated loss factors used in this rate proceeding.
Please include all calculations and workpapers.
7-65.
Please provide the line loss study and associated loss factors proposed in Docket No.
37744. Please include all calculations and workpapers.
7-66.
For each wholesale customer of ETI during the reconciliation period, provide the line loss
study and associated loss factors used for sales to the wholesale customer as well as any
wholesale contracts specifying or identifying any line loss study.
Page 12
7-67.
Provide any cost benefit analysis conducted by ETI or any predecessor in the last ten
years regarding the use of the Spindletop Gas Storage Facility versus other market
options for reliability or swing service, i.e., call options or imbalance agreements.
7-68.
For the previous six years, please provide any operating committee minutes discussing
the sale or other disposition of the Spindletop Gas Storage Facility.
7-69.
Please identify each of the pipeline connections to the Spindletop Facility and the
delivery capacity to the Facility and the take away capacity from the Facility for each
pipeline.
7-70.
Please provide the transportation agreements for each pipeline connected to the
Spindletop Facility.
7-71.
For each month of the reconciliation period, provide the detailed invoice from PB Energy
Storage Services, Inc.
7-72.
Provide the taxes other than income associated with the Spindletop Gas Storage and
Pipeline Facilities proposed to be included in the Company's revenue requirement.
7-73.
Provide the gross plant, accumulated depreciation, and net plant reflected in ETI's
proposed rates associated with the Spindletop Gas Storage and Pipeline Facilities by
FERC account proposed to be included in the Company's revenue requirement.
7-74.
Provide proposed depreciation expense associated with the Spindletop Gas Storage and
Pipeline Facilities by FERC account proposed to be included in the Company's revenue
requirement.
7-75.
Provide any other cost of service amount not previously identified above associated with
the Spindletop Gas Storage and Pipeline Facilities by FERC account proposed to be
included in the Company's revenue requirement.
7-76.
For the previous 10 years, provide all disruptions of gas supplies to Lewis Creek,
Louisiana Station, Nelson 3&4, Sabine Station, and Willow Glen for each instance
provide the following:
a. date of occurrence;
b. cause of disruption;
Page 13
c. duration of disruption;
d. location of disruption;
e. total spot purchases, in MMBtus, $/MMBtu, and total cost by supplier for the
period commencing 24 hours before disruption until 24 hours after disruption;
f.
total call options exercised, in MMBtus, $/MMBtu, and total cost by supplier for
the period commencing 24 hours before disruption until 24 hours after disruption;
g. total injections and total withdrawals, in MMBtus, $/MMBtu, and total cost from
Sabine Gas Storage Facility for the period commencing 24 hours before
disruption until 24 hours after disruption; and
h. state whether the supply disruption caused a generator curtailment or outage and,
if so, the duration of the curtailment or outage.
7-77.
For the previous ten years, please provide any operating committee minutes discussing
the use of natural gas call options.
7-78.
Referring to the Direct Testimony of Karen Mcllvoy at page 23, lines 2-4, please state the
contract price for swing flexibility service provided in each gas supply or transportation
contract of ETI for the reconciliation period. For each such contract term, provide the
contract and a schedule showing the monthly volumes of swing service, the $/MMBtu for
swing service, and the total monthly cost of swing service for the reconciliation period.
7-79.
Referring to the Direct Testimony of Karen Mcllvoy at page 23, lines 2-4, please state the
contract price for swing flexibility service provided in each gas supply or transportation
contract of Entergy Gulf States Louisiana for Nelson 3&4, Willow Glen and Louisiana
Station during the reconciliation period. For each such contract term, provide the
contract and a schedule showing the monthly volumes of swing service, the $/MMBtu for
swing service, and the total monthly cost of swing service for the reconciliation period.
7-80.
Provide the hourly injections and hourly withdrawals in MMbtus, $/MMbtu, and total
cost from the Spindletop Gas Storage Facility.
7-81.
Please state how hourly and intraday swing service was provided at Lewis Creek Station
for the reconciliation period and state the daily swing MMbtus, the cost of such service as
Page 14
well as the total cost of such services. Identify the contract terms or provide the invoices
backing up the Company's response. If none exist, provide the calculations and
assumptions used to determine the quantity of swing service provided as well as the daily
cost and total cost.
7-82.
Please state how hourly and intraday swing service was provided at Louisiana Station,
Nelson 3&4, and Willow Glen for the reconciliation period and state the daily swing
MMbtus, the cost per MMBtu of such service as well as the total cost of such services.
Identify the contract terms or provide the invoices backing up the Company's response.
If none exist, provide the calculations and assumptions used to determine the quantity of
swing service provided as well as the daily cost and total cost.
Page 15