Rate Case Filings
Long-cycle programs where regulation, capital, and grid reliability define the pace.
Inside this journey
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Rate Case Discovery
Clarify desired revenue outcomes, filing timeline, stakeholders, data readiness, and risk tolerances to shape a defensible filing plan.
Discovery Questions
Start Here: The Immediate Picture
- What's the immediate reason you're preparing or considering a rate case today?
- What is your target filing window (month & year) and how fixed is that timeline?
- Who on your team will be the day-to-day point(s) for this engagement?
- Thinking back to your last rate case, what went surprisingly well and what still nags at you?
- Which of these best describes how advanced your internal revenue requirement and cost-of-service models are right now?
If the Case Could Burn Your Plan, Where Would It Hurt?
- If the commission approved materially less revenue than you request, what would be the single biggest consequence for your utility?
- How would such an outcome affect the finance team’s ability to access capital or refinance debt?
- Which stakeholder groups would be most vocal or vulnerable if the case doesn't go as planned?
- When you picture worst-case scenarios, what's the feeling that resurfaces most—fear of optics, financial pain, internal blame, or something else?
- Have you ever faced an unexpected outcome in a prior case that you now consider preventable? What happened and why do you think it was avoidable?
Who Really Holds the Decision Levers?
- We often find that formal 'owners' are unclear—who must approve the final filing and what are their priorities?
- If one of those decision makers were to push back, what are they most likely to challenge—costs, timing, optics, or contractor fees?
- Which external relationships are already in place or required (e.g., outside counsel, financial advisors, expert witnesses)? Please list roles and any named firms.
- How confident are you that your sponsors (board/executives) will stand behind trade-offs such as phased increases, staged capital recovery, or settlement concessions?
- Who internally will be responsible for discovery coordination, and do they have bandwidth for tight turnarounds?
How Solid Is Your Evidence—And Where Is It Fragile?
- Most teams assume their data is ready—what would surprise a skeptical commissioner or intervenor about your data or model accuracy?
- Which datasets are already reconciled to audited financials and which are not?
- How long would it take your team to produce a complete response to a broad data request (e.g., 30–60 data items)?
- Which cost drivers do you expect will draw the most evidentiary scrutiny from staff or intervenors?
- Are there legacy allocation methods, accounting judgments, or one-off adjustments you suspect will be challenged? Please describe.
What's Your Appetite for Risk, Settlement, and Trade‑Offs?
- If you had to pick a posture today—aggressive litigant, pragmatic settler, or somewhere in between—where would you land and why?
- How much downside (percent of requested revenue) is acceptable to preserve other priorities (e.g., avoiding bad precedent or protecting capital projects)?
- Would you be willing to allocate additional budget to retain higher-profile expert witnesses if it materially improves defensibility?
- Which trade-offs would you accept to reach a timely settlement—rate design concessions, staged recovery, or reduced backtest / true-up features?
- How do perceptions of political risk or customer sentiment influence your tolerance for settlement or aggressive positions?
What Would 'A Win' Actually Feel Like?
- Beyond 'approved revenue', what three outcomes would make this case a clear success for you?
- How will you measure success internally—financial metrics, stakeholder sentiment, timeline adherence, or something else?
- Which audiences must feel satisfied after the order (board, investors, regulators, customers), and what would satisfaction look like for each?
- If you could pick one non-financial legacy from this case (e.g., a precedent on cost allocation or meter policy), what would it be?
- How important is speed-to-order versus maximizing total revenue—do you prefer a faster, smaller win or a slower, fuller recovery?
Practical Roadmap: Who Does What, When?
- Given your timeline, which of these engagement modules do you expect to include in scope?
- Which internal teams will own inputs for each module (e.g., finance for revenue, operations for plant), and where do you anticipate handoffs will break down?
- What is the single earliest milestone that must be met to preserve your filing date (e.g., audited financials, board approval, model build)?
- How many dedicated consulting / expert hours do you anticipate approving for core modeling and testimony (ballpark)?
- Who will serve as the contract/fee approver and what procurement or legal review timelines should we factor in?
Hidden Roadblocks We See—Are Any Yours?
- Many utilities discover last-minute problems—legacy allocation issues, missing supporting workpapers, or IT reporting gaps. Which of these, if any, feel familiar?
- If we asked your finance or operations leads to list three process changes they'd need to avoid surprises, what would they say?
- How comfortable are you sharing sensitive materials (audited schedules, executive summaries) under a strict NDA to accelerate our assessment?
- What has typically blocked fixing these hidden issues in the past—budget limits, competing priorities, or lack of clear ownership?
- If we prioritized one remediation to reduce evidentiary risk quickly, which would you choose?
Signals of Commitment & The Small Steps That Unlock Momentum
- If today we proposed a scoped plan that addressed your top three risks, what internal approvals would you need to proceed?
- What is the earliest practical date your team could begin a formal discovery kickoff with consultants?
- Which of these would signal to you that a consultant is the right partner: proven local commission experience, defensible testimony, senior-expert availability, or fixed-fee certainty?
- What would stop you from moving forward even if a plan met your top needs—budget, timing, politics, or something else?
- What single small commitment (e.g., NDA, intake call, preliminary data share) would you be willing to make in the next 7 days to see a tailored filing plan?
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Case Strategy Workshop
Translate your financials, capital plan, and jurisdictional precedent into a shared roadmap showing expected outcomes, evidentiary risks, and mitigation options.
Experience Meetings
- Pre-Workshop Data Alignment
- Case Strategy Core Workshop (Diagnosis → Roadmap)
- Modeling & Sensitivity Review (Proof)
- Testimony & Evidentiary Strategy Alignment (Validation)
- Decision & Roadmap Mutualization
- Agree on a testimony drafting and mock hearing schedule to meet filing milestones.
- Legal/regulatory lead to draft risk narratives for the top three evidentiary exposures.
- Assign owners to each mitigation option and schedule follow-up deep-dives as needed.
- Model Inputs Recap
- Prove the expected outcome ranges for each roadmap with model outputs.
- Quantify the materiality of key evidentiary exposures under sensitivity cases.
- Agree which scenario(s) should advance to testimony drafting based on tolerances.
- Modeling team to deliver a scenario workbook with toggles and a one-page executive summary.
- Regulatory lead to annotate model lines that require documentary support or exhibits.
- Finance to confirm any additional reconciliations for high-sensitivity items within 5 business days.
- Narrative & Testimony Themes
- Produce a clear testimony narrative aligned to the chosen roadmap.
- Confirm witness assignments and evidence owners with committed review timelines.
- Identify top cross-examination vulnerabilities and agree initial mitigation tactics.
- Introductions & Objectives
- Draft team to produce testimony outlines for each witness within agreed timelines.
- Evidence owners to begin collecting and labeling exhibits tied to model lines and assertions.
- Schedule first mock hearing slot and assemble cross-exam panel from consulting team.
- Executive Recap of Options & Recommended Roadmap
- Obtain executive/stakeholder sign-off on the recommended roadmap.
- Lock staffing (including expert witness commitments), milestones, and deliverables for the filing phase.
- Agree clear acceptance criteria and governance to manage tradeoffs during the filing.
- Publish the signed roadmap document including milestones, owners, and acceptance criteria.
- Trigger contract/engagement updates for any expert witness commitments or additional resourcing.
- Schedule the first drafting kickoff and mock hearing planning session on the agreed timeline.
- Produce a single agreed current-state sentence for use in the workshop.
- Produce an explicit consequence statement quantifying key impacts.
- Complete a data inventory with owners and deadlines for all required inputs.
- Ensure all participants understand pre-work and attend the Core Workshop prepared.
- Utility to deliver reconciled financials, capital plan, and most recent cost-of-service model by X date.
- Regulatory team to draft single-sentence current-state and one-paragraph consequence to circulate for confirmation.
- Assign SME contacts for billing, finance, and capital projects and confirm availability for Core Workshop.
- Re-state Current State & Consequence
- Produce 2–3 candidate strategy roadmaps linking inputs to expected outcomes.
- Identify and prioritize evidentiary risks for each roadmap with initial mitigation options.
- Agree decision criteria and governance for selecting a final strategy.
- Ensure every roadmap ties back to the documented consequence and the agreed future state.
- Modeling team to build the 2–3 candidate revenue outcomes and circulate within 48 hours.
- Single-Sentence Current State
- Witness Matrix & Role Assignments
- Scenario Outcomes Walkthrough
- Define Future State (outcome-focused)
- Confirmed Evidentiary Risks & Mitigations
- Milestones, Staffing & Deliverables
- Exhibit & Documentary Requirements
- Sensitivity & Stress Tests
- Financials & Capital Plan Walkthrough
- Explicit Consequence Statement
- Required Data Inventory
- Precedent Adjustment Simulations
- Jurisdictional Precedent Mapping
- Acceptance Criteria & Governance
- Cross-Examination Risk & Mock Q's
- Sign-Off & Immediate Next Steps
- Scenario Roadmap Development
- Implications & Recommended Advancement
- Drafting Timeline & Review Gates
- Data Gaps & Access Plan
- Pre-work & Logistics
- Evidentiary Risk Identification
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Engagement Scope
Define modules (revenue requirement, cost-of-service, rate design, testimony, discovery, settlement, post-order compliance), deliverables, owners, and acceptance criteria.
Scope Configuration
- Build Excel cost-of-service model
- Prepare revenue requirement exhibits and workpapers
- Draft direct testimony and supporting exhibits
- Draft rebuttal testimony and exhibits
- Produce rate design and proposed tariffs
- Calculate customer bill impacts and class allocations
- Prepare discovery responses and supporting workpapers
- Run mock cross-examination and hearing drills
- Deliver expert witness testimony at evidentiary hearing
- Develop alternative allocation and rate design scenarios
- Negotiate settlement terms and draft settlement language
- Prepare compliance filings and tariff implementation schedules
- Update cost-of-service model with approved order adjustments
Scope Questions
Build Excel cost-of-service model
- Do you need a new cost-of-service model built from scratch or an update to an existing model?
- Which customer classes and rate schedules must be included in the model?
- What level of detail is required for functional separation and allocator schedules?
- What data sources will be available to populate the model (e.g., GL, payroll, plant ledger, interval meter data)?
- Who will own the model internally and who are the external reviewers (roles/names)?
- What are your acceptance criteria for the model (e.g., explainability, audit trail, version control, reconciliation to audited statements)?
Prepare revenue requirement exhibits and workpapers
- Which test year and rate base methodology should the exhibits reflect?
- Which major adjustment categories must be addressed (e.g., O&M, depreciation, taxes, capital additions, AFUDC)?
- What level of supporting documentation is required for each adjustment (e.g., detailed schedules, source documents, workpapers)?
- Are there jurisdictional or commission-specific exhibit formats we must follow?
- Who will review and approve exhibits internally (roles and expected review cycles)?
- What are the delivery and acceptance milestones for revenue requirement deliverables?
Draft direct testimony and supporting exhibits
- How many witnesses (subject-matter experts) will provide direct testimony?
- Which topics must each direct witness cover (e.g., revenue requirement, rate design, cost allocation, depreciation)?
- Do you have preferred authors or in-house SMEs who will co-draft testimony?
- What length/level of technical detail is expected in testimony (concise summary vs. detailed technical analysis)?
- What exhibit formats are required (e.g., inline tables, Excel workpapers, PDF exhibits)?
- How many review cycles and turnaround time should we budget for testimony drafting?
Draft rebuttal testimony and exhibits
- Do you anticipate filing rebuttal testimony based on intervenor or staff positions?
- What is the expected rapid-turnaround window for rebuttal drafting after receiving opposing testimony (days)?
- Which subject areas are most likely to require rebuttal (e.g., revenue requirement adjustments, allocation, rate design)?
- Will rebuttal authors be the same witnesses as direct or different personnel?
- What supporting data and workpapers must be ready to support rebuttal positions?
- What quality control or legal review is required before rebuttal filing?
Produce rate design and proposed tariffs
- Are you requesting class-specific rate changes or a system-wide increase allocation?
- Which rate design objectives should guide the work (e.g., cost-based, revenue stability, bill impact mitigation, modernization)?
- Which tariff components must be updated (e.g., energy charges, demand charges, fixed charges, riders)?
- Do you require tariff language drafted to commission filing standards and local format?
- Should alternative rate designs (e.g., TOU, inclining block, demand charges) be developed and compared?
- What acceptance criteria will you use to approve proposed tariffs (e.g., legal sign-off, finance sign-off, customer impact thresholds)?
Calculate customer bill impacts and class allocations
- What sample size and customer data granularity are available for bill impact analysis (e.g., entire billing dataset, representative sample, interval data)?
- Should bill impacts be shown for typical customers and for high/low usage percentiles?
- Do you require regional or demographic segmentation for bill impacts (e.g., residential by territory, low-income programs)?
- Which metrics should the allocation analysis focus on (e.g., revenue recovery by class, cost-causation, fairness indices)?
- What formats are needed for presenting bill impacts (e.g., tables, charts, downloadable spreadsheets)?
- What acceptance thresholds for bill changes would trigger redesign or additional mitigation (e.g., >10% increase for any cohort)?
Prepare discovery responses and supporting workpapers
- Who will serve as the primary contact for discovery responses and approvals?
- What typical volume and complexity of discovery do you expect (e.g., low volume, extensive data requests, multiple interrogatories/subpoenas)?
- What standard turnaround SLA do you require for responses (e.g., 7 days, 14 days, 30 days)?
- Are there confidentiality or privilege considerations that affect production and redaction?
- In what format should supporting workpapers be delivered (e.g., native Excel with formulas, PDF with index)?
- Do you require a discovery log and version control for produced documents?
Run mock cross-examination and hearing drills
- Which witnesses will participate in mock hearings and what is their availability?
- What types of drills do you want (e.g., technical cross-examination, prosecutorial questioning, full hearing simulation)?
- How long should each mock session be and how many iterations are desired?
- Do you want written scoring and red-team feedback after drills?
- Will drills be remote, in-person, or hybrid and who provides materials (exhibits, testimony)?
- What acceptance criteria determine if a witness is ready for the evidentiary hearing?
Deliver expert witness testimony at evidentiary hearing
- Which experts will testify and what are their primary topics/credentials?
- Are travel, lodging, and hearing-day logistics required to be coordinated by the consultant?
- Do you require written hearing scripts, speaking notes, or exhibit binders for each witness?
- What is the expected level of direct courtroom representation (e.g., testify only, testify + respond to cross, full hearing advocacy)?
- Are deposition preparations or pre-filed exchanges part of testimony deliverables?
Develop alternative allocation and rate design scenarios
- How many alternative scenarios should we develop and compare?
- Which evaluation criteria should be used to compare scenarios (e.g., revenue recovery, bill impacts, customer equity, regulatory risk)?
- Do you want probabilistic or sensitivity analyses for key assumptions (e.g., sales forecast, load growth)?
- Should alternatives include phased implementations or transition mechanisms (e.g., gradual fixed charge increases)?
- What deliverable format is preferred for scenario comparison (e.g., summary matrix, dashboard, full workpapers)?
Negotiate settlement terms and draft settlement language
- Do you intend to pursue settlement discussions with intervenors and staff?
- Which parties will likely participate in settlement negotiations (e.g., commission staff, consumer advocates, industry intervenors)?
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Mutual Commit
Finalize scope, staffing (including expert witness commitments), fees, milestones, and contractual terms required to proceed to filing.
Agreement Modules
- Statement of Work (SOW)
- Master Services Agreement (MSA) / Engagement Agreement
- Fee Schedule & Payment Terms
- Staffing & Expert Witness Commitments
- Milestones & Project Plan
- Change Order & Scope Management
- Data Access, Security & Privacy Agreement (DPA)
- Confidentiality & Privilege Addendum
- Expense Reimbursement & Travel Policy
- Insurance & Indemnity Confirmation
- Regulatory Filings & Representation Authorization
- Termination, Transition & Data Handover
- Acceptance & Executive Signoff Checklist
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Filing & Hearing Execution
Coordinate model builds, testimony drafting, discovery responses, settlement negotiations, mock hearing prep, and hearing representation on a detailed schedule with clear owners.
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Post-Order Success & Compliance
Validate order impacts, complete compliance filings and rate implementation, and keep a shared channel for issues, enhancements, and next-case readiness.
Success Reviews
- Order Impact Validation Workshop
- Compliance Filing & Documentation Review
- Rate Implementation & Billing Systems Coordination
- Post-Order Issues, Enhancements & Next-Case Readiness Channel Kickoff
- Stakeholder Communications & Regulatory Reporting
Issues & Enhancements
- Agree on a next-case readiness checklist and initial timeline to avoid rework in the next filing cycle.
- One-sentence current state & go-live target
- Have a verified implementation mapping from tariff to billing tables with assigned engineers and deadlines.
- Agree on and schedule parallel runs with defined acceptance criteria to validate customer bills.
- Ensure customer care materials are ready and coordinated with the go-live date.
- Load new rate tables into the staging environment and schedule parallel billing runs.
- Publish customer notice drafts and FAQ to be finalized by communications owner.
- Document rollback criteria and emergency contacts for the implementation window.
- Current state & consequence in one sentence
- Stand up a shared channel with clear ownership and access for ongoing post-order work.
- Create a prioritized backlog with SLAs so critical issues are resolved before billing or reporting cycles are impacted.
- Pre-work review and objective statement
- Create the shared collaboration channel, invite stakeholders, and upload the validated model and filing artifacts.
- Populate the backlog with identified items, set priorities, and assign initial owners.
- Schedule recurring issue triage meetings and quarterly readiness reviews.
- Mandated reporting and notification requirements
- Agree on a legally reviewed set of external messages and delivery schedule.
- Assign owners for each mandated report and customer notification with due dates.
- Establish monitoring and escalation procedures for stakeholder responses post-notice.
- Finalize and route customer notices and municipal briefings for legal and executive approval.
- Assign regulatory report owners and schedule the data pulls and draft timelines.
- Set up dashboard tracking for inquiries and media mentions during the implementation window.
- Have a single, validated statement of 'what changes' in the revenue requirement and rate tables.
- Quantify the financial consequence (dollars and bill impacts) of each order directive.
- Obtain model-level sign-off and an actionable owner list for residual items.
- Identify any unresolved legal or evidentiary questions that require follow-up with counsel.
- Apply validated order changes to the master cost-of-service model and post updated version to shared repo.
- Prepare redline tariff and transitional language for compliance filing.
- Document sign-offs and circulate a one-page change summary to executive sponsors.
- Compliance checklist review
- Produce a complete, internally approved compliance filing package ready for e-file on the target date.
- Ensure all exhibits and schedules reconcile exactly to the validated model outputs.
- Assign the e-filing owner and establish a rollback/correction plan if the commission requests changes.
- Finalize and lock the filing package; upload to the shared compliance folder with file naming and version number.
- Obtain required executive and legal signatures and certify the affidavits.
- Schedule and confirm the e-file owner and backup for the filing date.
- Explicit consequence framing
- Message alignment and approval path
- Channel platform, participants, and access rules
- Tariff-to-billing mapping
- Supporting schedules and exhibits alignment
- Test plan: parallel runs and validation cases
- Triage process and SLAs
- Customer notice timing and segmentation
- Legal and affidavit review
- Line-by-line model mapping
- Regulatory reporting logistics
- Proof — run & review updated model scenarios
- Customer care and external communications alignment
- Formatting, redlines, and version control
- Backlog creation and prioritization
- Filing logistics and timeline
- Validation & sign-off
- Cadence, owners, and next-case readiness checklist
- Contingency and rollback procedures
- Monitoring and response plan
- Next steps and owners