OGE Energy : PUD 2020100072 - Settlement Testimony of Gwin Cash

BEFORE THE CORPORATION COMMISSION OF THE STATE OF OKLAHOMA

IN THE MATTER OF THE APPLICATION	)
OF OKLAHOMA GAS AND ELECTRIC	)
COMPANY FOR A FINANCING ORDER	)
PURSUANT TO THE FEBRUARY 2021	)	Cause No. 202100072
REGULATED UTILITY CONSUMER	)
PROTECTION ACT APPROVING	)
SECURITIZATION OF COSTS ARISING	)
FROM THE WINTER WEATHER EVENT	)
OF FEBRUARY 2021	)

Settlement Testimony

of

Gwin Cash

on behalf of

Oklahoma Gas and Electric Company

October 8, 2021

Settlement Testimony of Gwin Cash	Page 1 of 4
Cause No. PUD 202100072

Gwin Cash

Settlement Testimony

1. Q. Would you please state your name and business address?
2. A. My name is Gwin Cash. My business address is 321 North Harvey, Oklahoma City,

3		Oklahoma, 73102.
4
5	Q.	Are you the same Gwin Cash that previously filed rebuttal testimony in this
6		proceeding?
7	A.	Yes.
8

1. Q. What is the purpose of your Settlement Testimony?
2. A. The purpose of my testimony is to support the Joint Stipulation and Settlement Agreement

11	("Joint Stipulation") paragraphs seven and eight and Exhibit A to that agreement. The
12	Joint Stipulation resolves the issues contained in this Cause and represents a balancing of
13	interests among the Stipulating Parties. I believe that approval of the Joint Stipulation is
14	reasonable and in the public interest.
15

1. Q. Please discuss paragraph seven in the Joint Stipulation.
2. A. Paragraph seven incorporates two allocation and pricing modifications recommended by

18	Oklahoma Industrial Energy Consumers ("OIEC") witness Brian Collins in his
19	responsive testimony.
20	The first recommendation is to allocate Winter Event Securitization Mechanism
21	("WES") cost to Service Level ("SL") classes based on SL daily usage and the daily cost
22	incurred by OG&E. This adjustment to the filed allocation method is intended to more
23	closely align cost allocation with how costs were incurred during the Winter Event Period
24	("Event").
25	The second recommendation is to assess WES charges to SL 1 and 2 customers
26	according to their level of energy actually used during the Event. This is accomplished
27	by determining each customer's usage during the Event and dividing by 100,000 kWh to
28	arrive at a quantity of blocks that each customer will be billed a block rate each month
29	during the term of the WES. For SL 1 and 2 customers that had less than 100,000 kWh
	Settlement Testimony of Donald R. Rowlett	Page 2 of 4
	Cause No. PUD 202000021

1	used during the Event and SL 1 and 2 customers that are new to the system after the
2	Event, a minimum of one block will be assessed the WES block charge. This adjustment
3	to WES pricing for SL 1 and 2 customers will more closely recognize customer
4	contributions to energy usage during the Event.
5	Additionally, paragraph seven clarifies that Day-Ahead Pricing and Flex Pricing
6	customers' customer baseline usage will be utilized instead of actual usage for both
7	allocation and pricing purposes. This will ensure recognition for payments already made
8	and credits already received for these customers' usage above and below the customer
9	baseline.
10	Paragraph seven also clarifies that uncollectible WES amounts will be recorded
11	by SL and included for recovery in each respective SL class' true-up calculation.
12

1. Q. Please discuss paragraph eight and Exhibit A to the Joint Stipulation.
2. A. Paragraph 8 states the WES mechanism is attached to the Joint Stipulation as Exhibit A.

15	The WES includes the requirements of paragraph seven and also include language to ensure
16	recovery of revenues from customers such that bond payments will be made in full.
17	Sections of the mechanism are summarized as follows:
18	•	APPLICABILITY:
19		The WES will apply to customer usage for the SL 3, 4, and 5 classes and to fixed
20		blocks of usage for the SL 1 and 2 classes. Additionally it requires customers that
21		were either SL 1 or SL 2 during the Event to continue to receive the respective SL
22		1 or SL 2 pricing
23	•	TERM:
24		The WES will remain in effect until the complete repayment and retirement of the
25		customer backed bonds, or refunding bonds, associated with the Event.
26	•	ALLOCATION:
27		The SL energy allocators based on the daily allocation of cost are provided.
28	•	STANDARD FACTOR DETERMINATION:
29		This section provides the formula for calculating WES rates on a semi-annual basis
30		for all SL classes.
31	• NON-STANDARDFACTOR DETERMINATION:
	Settlement Testimony of Donald R. Rowlett	Page 3 of 4
	Cause No. PUD 202000021

1	This section is triggered when the billing units of any class are projected to be down
2	by 10% or more and provides a revised formula for calculating WES rates.
3	• INTERIM TRUE-UP:
4	This section allows the Company to submit interim factors outside of the standard
5	semi-annual timeframe if, at any time, the Company projects an under-recovery of
6	WES costs that would result in a draw on the Debt Service Reserve subaccount.
7

8 Q. Do you believe the Joint Stipulation is fair, just and reasonable, and in the public

9		interest?
10	A.	Yes, I believe the Joint Stipulation is fair, just and reasonable, and in the public interest. I
11		recommend the Commission approve the Joint Stipulation.
12

1. Q. Does this conclude your Settlement Testimony?
2. A. Yes.

Settlement Testimony of Donald R. Rowlett	Page 4 of 4
Cause No. PUD 202000021