Entergy Texas, Inc. v. Public Utility Commission of Texas, Office of Public Utility Counsel, and State of Texas Agencies and Institutions of Higher Education

Case Information

No. 03-14-00706-CV

IN THE THIRD DISTRICT COURT OF APPEALS ${}^{3\text{rd}}$ COURT OF APPEALS AT AUSTIN, TEXAS

INTERGY TEXAS, INC., Appellant, v.

PUBLIC UTILITY COMMISSION OF TEXAS, ET AL., Appellees.

Appeal from the 345th Judicial District Court, Travis County, Texas The Honorable Amy Clark Meachum, Judge Presiding

APPELLANT'S BRIEF

John F. Williams State Bar No. 21554100 jwilliams@dwmrlaw.com Marnie A. McCormick State Bar No. 00794264 mmccormick@dwmrlaw.com DUGGINS WREN MANN &; ROMERO, LLP 600 Congress Ave., Ste. 1900 (78701) P. O. Box 1149

Austin, Texas 78767-1149 (512) 744-9300 (512) 744-9399 fax

ATTORNEYS FOR APPELLANT ENTERGY TEXAS, INC.

ORAL ARGUMENT REQUESTED

February 2015

IDENTITY OF PARTIES AND COUNSEL

Pursuant to Rule 38.1(a), appellant provides this list of all parties to the order appealed from and the names and addresses of all trial and appellate counsel:

Plaintiff/Appellant:

Entergy Texas, Inc.

Defendant/Appellee:

Public Utility Commission of Texas

Intervenor:

Office of Public Utility Counsel

Trial counsel:

John F. Williams Marnie A. McCormick Patrick J. Pearsall DugGins Wren Mann &; Romero, LLP 600 Congress Ave., Ste. 1900 (78701) P. O. Box 1149

Austin, Texas 78767-1149 Appellate counsel: John F. Williams Marnie A. McCormick DugGINS WREN MANN &; ROMERO, LLP 600 Congress Ave., Ste. 1900 (78701) P. O. Box 1149

Austin, Texas 78767-1149 Trial counsel: Elizabeth R. B. Sterling Environmental Protection Division Office of the Attorney General P. O. Box 12548 (MC 066)

Austin, Texas 78711-2548 Trial counsel: Ross Henderson Sara J. Ferris Office of Public Utility Counsel 1701 N. Congress Ave., Ste. 9-180 P. O. Box 12397

Austin, Texas 78711-2397

Intervenor:

The State of Texas Agencies and Institutes of Higher Education ("State Agencies")

Trial counsel:

Susan M. Kelley Bryan L. Baker Administrative Law Division Office of the Attorney General P. O. Box 12548 (MC018-12)

Austin, Texas 78711-2548

Appellate counsel:

Katherine H. Farrell Administrative Law Division Office of the Attorney General P. O. Box 12548 (MC018-12)

Austin, Texas 78711-2548

Intervenor:

Texas Industrial Energy Consumers

Trial counsel:

Rex D. VanMiddlesworth Benjamin Hallmark Thompson Knight LLP 98 San Jacinto Blvd., Ste. 1900 Austin, Texas 78701 Meghan Griffiths Andrews Kurth LLP 111 Congress Ave., Ste. 1700 Austin, Texas 78701

TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL ..... i TABLE OF CONTENTS ..... iii INDEX OF AUTHORITIES ..... v STATEMENT OF THE CASE ..... ix STATEMENT REGARDING ORAL ARGUMENT ..... ix ISSUES PRESENTED ..... $x$ STATEMENT OF FACTS ..... 1 I. ETI is subject to traditional rate regulation. ..... 1 II. In ETI's 2011 rate case, the Commission included some but not all of ETI's expenses in its cost of service. ..... 2 A. Depreciation Expense ..... 3 B. Incentive Compensation ..... 5 III. The Commission disallowed some of ETI's rate case expenses in the rate case expense docket. ..... 7 SUMMARY OF THE ARGUMENT ..... 10 ARGUMENT AND AUTHORITIES ..... 13 I. The Commission's disallowance of ETI's costs of litigating the incentive compensation issue is arbitrary and capricious and an abuse of discretion. ..... 13 A. The Commission's finding that ETI was unreasonable in advocating recovery of financially-based incentive compensation is arbitrary and capricious. ..... 13 B. The Commission acted arbitrarily and abused its discretion by disallowing ETI's expenses of making its argument about financially-based incentive compensation. ..... 17

1. The Commission has never before disallowed the costs of making unsuccessful incentive compensation arguments. ..... 17
2. It was arbitrary and an abuse of discretion to impose a new standard upon ETI at the end of the administrative process. ..... 19
3. The Commission's action also constitutes improper ad hoc rulemaking. ..... 21 C. The Commission further erred in quantifying the expenses ETI incurred in seeking to include financially-based incentive compensation in rates. ..... 26
4. The Commission has never before required a utility to record its rate case expenses by issue, nor has the Commission used a proxy to quantify a disallowance. ..... 27
5. The Commission imposed a new standard upon ETI at the end of the contested case, again engaging in inappropriate ad hoc rulemaking. ..... 30 II. The Commission's disallowance of the ESI depreciation expense that ETI incurred in the rate case is not supported by substantial evidence and is arbitrary and capricious. ..... 32 CONCLUSION AND PRAYER ..... 36 CERTIFICATE OF COMPLIANCE ..... 37 APPENDICES ..... 39

INDEX OF AUTHORITIES

Cases Bluefield Waterworks &; Improvement Co. v. Public Serv. Comm'n of State of W.Va., 262 U.S. 679 (1923) ..... 2 CenterPoint Energy Entex v. Railroad Comm'n of Texas, 213 S.W.3d 364 (Tex. App. - Austin 2006, no pet.) ..... 23 City of Arlington v. Centerfolds, Inc., 232 S.W.3d 238 (Tex. App. - Fort Worth 2007, pet. denied) ..... 22 City of Corpus Christi v. Public Util. Comm'n of Tex., 51 S.W.3d 231 (Tex. 2001) ..... 3 City of El Paso v. El Paso Elec. Co., 851 S.W.2d 896 (Tex. App. - Austin 1993, writ denied) ..... 21,30 City of El Paso v. Public Util. Comm'n of Tex., 344 S.W.3d 609 (Tex. App. - Austin 2011, no pet.) ..... 2 City of El Paso v. Public Util. Comm'n of Tex., 883 S.W.2d 179 (Tex. 1994) ..... 2 Entergy Gulf States, Inc. v. Public Utility Comm'n of Tex., 173 S.W.3d 199 (Tex. App. - Austin 2005, pet. denied) ..... 23 Federal Power Comm'n v. Hope Natural Gas Co., 320 U.S. 591 (1944) ..... 2 Flores v. Employees Ret. Sys., 74 S.W.3d 532 (Tex. App. -- Austin 2002, pet. denied) ..... $20,21,30$ Harris County Hosp. Dist. v. Public Util. Comm'n of Tex., No. 03-10-00647-CV, 2012 WL 2989228 *7 (Tex. App. - Austin Jul. 13, 2012, no pet.) (not designated for publication) ..... 21,30 Oncor Elec. Delivery Co. v. Public Util. Comm'n of Tex., 406 S.W.3d 253 (Tex. App. - Austin 2013, no pet.) ..... passim

Public Util. Comm'n of Tex. v. Texas Telephone Ass'n, 163 S.W.3d 204 (Tex. App. - Austin 2005, no pet.) ..... 16 Railroad Comm'n of Tex. v. WBD Oil &; Gas Co., 104 S.W.3d 69 (Tex. 2003) ..... 22 Rodriguez v. Service Lloyds Ins. Co., 997 S.W.2d 248 (Tex. 1999) ..... 22, 23 South Tex. Indus. Servs., Inc. v. Texas Dep't of Water Res., 573 S.W.2d 302 (Tex. Civ. App. - Austin 1978, writ ref'd n.r.e.) ..... 16 Southwestern Bell Tel. Co. v. Public Util. Comm'n of Tex., 745 S.W.2d 918 (Tex. App. - Austin 1988, writ denied) ..... 23 State of Texas Agencies &; Institutions of Higher Learning v. Public Util. Comm'n of Tex., No. 03-11-00072-CV, 2014 WL 6893871 *31 (Tex. App. - Austin Dec. 4, 2014, no pet. h) ..... $10,13,15$ State v. Public Util. Comm'n of Tex., 883 S.W.2d 190 (Tex. 1994) ..... 3 Texas State Board of Pharmacy v. Witcher, 447 S.W.3d 520 (Tex. App. - Austin 2014, pet. filed) ..... passim Statutes Tex. Gov't Code Ann. § 2001.023 ..... 22 Tex. Gov't Code Ann. § 2001.029 ..... 22 Tex. Gov't Code Ann. §§ 2001.032-.033 ..... 22 Tex. Gov't Code Ann. § 2001.174 ..... $21,32,35$ Tex. Util. Code Ann. §§ 11.01, et seq. ..... 1 Tex. Util. Code Ann. § 36.051 ..... 1 Tex. Util. Code Ann. § 36.061 ..... 2,29 Tex. Util. Code Ann. §§ 39.001-.359 ..... 1

Texas Util. Code Ann. § 39.452 ..... 1 Rules 16 Tex. Admin. Code § 25.231 ..... 2 16 Tex. Admin. Code § 25.245 ..... passim 16 Tex. Admin. Code § 25.272 ..... 35 39 Tex. Reg. at 6445 ..... 25 Commission Proceedings Application of AEP Texas Central Co. for Authority to Change Rates, Docket No. 28840 ..... 14,18 Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309 ..... 16,18 Application of CenterPoint Energy Houston Electric, LLC for Authority to Change Rates, Docket No. 38339 ..... 17 Application of El Paso Electric Company to Change Rates, to Reconcile Fuel Costs, to Establish Formula-Based Fuel Factors, and to Establish an Energy Efficiency Cost Recovery Factor, Docket No. 37690 ..... 15 Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket No. 39896 ..... passim Application of Oncor Electric Delivery Company, LLC for Authority to Change Rates, Docket No. 35717 ..... 15 Application of Southwestern Electric Power Co. for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 40443 ..... 15 Application of Southwestern Electric Power Company for Authority to Change Rates, Docket No. 37364 ..... 15 Application of Southwestern Public Service Company Authority to Change Rates, to Reconcile Fuel and Purchased Power Costs for 2006 and 2007 and to Provide a Credit for Fuel Cost Savings, Docket No. 35763 ..... 15

In re El Paso Electric Co., Docket No. 9945 ..... 27, 28 Proceeding to Consider Rate Case Expenses Severed from Docket No. 28840, Docket No. 31433 ..... 18,28 Proceeding to Consider Rate Case Expenses Severed from Docket No. 33310 and Docket No. 33309, Docket No. 34301 ..... 18 Requests for Rate Case Expenses Severed from Docket No. 38339, Docket No. 39127 ..... 17

STATEMENT OF THE CASE

This is a suit for judicial review of the final order of the Public Utility Commission of Texas in its Docket Number 40295, a proceeding to determine the expenses Entergy Texas, Inc. may recover for prosecuting its 2011 base rate case. Entergy Texas, Inc. sought judicial review of the agency's disallowance of two categories of expense. ^[1] The district court, Judge Amy Clark Meachum presiding, summarily affirmed the order. ^[2]

STATEMENT REGARDING ORAL ARGUMENT

Cases involving public utility regulation usually involve complex regulatory principles, and this one is no exception. For that reason, the Court's decisional process would be aided by oral argument.

ISSUES PRESENTED

1. The Commission has historically stated a policy of disallowing incentive compensation that is tied to "financial" as opposed to "operational" measures, but the Commission has not clearly or consistently defined how to determine whether actual incentive costs fall in one category or the other. Despite that, and even though Entergy Texas, Inc. succeeded in convincing the Commission to change precedent in one respect, the Commission disallowed expenses of advocacy on the subject. Did the Commission act arbitrarily and capriciously by disallowing these expenses?
2. The Commission has never before disallowed a utility's expenses of making an unsuccessful attempt to include financially-based incentive compensation in rates. Did the Commission act arbitrarily and capriciously, or abuse its discretion, by imposing this new policy upon Entergy Texas, Inc., for the first time at the end of this contested case without adequate explanation, instead of imposing the new policy prospectively after a formal rulemaking proceeding?
3. The Commission for the first time quantified the disallowance using a "proxy" method that has no logical connection to the actual expense of making the purportedly unreasonable argument. Did the Commission act arbitrarily and capriciously or abuse its discretion by imposing this new method at the end of this contested case without adequate explanation, instead of imposing the new method prospectively after a formal rulemaking proceeding?
4. Entergy Texas, Inc. also presented unrebutted evidence that the depreciation expense it incurred for its affiliate's services in the rate case was reasonable and necessary. Is the Commission's disallowance of that expense, contrary to the Commission's treatment of analogous expense in the underlying rate case, unsupported by substantial evidence or arbitrary and capricious?

STATEMENT OF FACTS

Entergy Texas, Inc. ("ETI" or "the Company") is an investor-owned electric utility. ETI provides bundled generation, transmission, distribution, and customer services to over 400,000 retail customers in southeastern Texas.

I. ETI is subject to traditional rate regulation.

The services ETI provides to Texas retail customers are subject to regulation by the Public Utility Commission of Texas (the "Commission" or "PUCT") under the Public Utility Regulatory Act ("PURA"). ^[3] The Texas legislature in 1999 ordered electric utilities to "unbundle" their generation, transmission, distribution, and customer service functions as part of an effort to introduce competition into the Texas retail electric industry. See Tex. Util. Code Ann. §§ 39.001-.359. However, in 2009, the legislature amended PURA to require ETI to cease activities relating to the transition to retail competition. See id. § 39.452(i). Accordingly, ETI remains subject to traditional cost-of-service rate regulation. Id. § 39.452(a).

Under PURA and applicable constitutional principles, a traditionallyregulated utility is entitled to rates that afford it a "reasonable opportunity to earn a reasonable return on the utility's invested capital used and useful in providing service to the public in excess of the utility's reasonable and necessary operating expenses." Id. § 36.051; Federal Power Comm'n v. Hope Natural Gas Co., 320

U.S. 591, 603 (1944); Bluefield Waterworks &; Improvement Co. v. Public Serv. Comm'n of State of W.Va., 262 U.S. 679, 692 (1923). To set a rate, the Commission looks at a historical "test year" and determines the amount of money the utility will need to cover both its expenses and a return on its investment in the future. E.g., City of El Paso v. Public Util. Comm'n of Tex., 344 S.W.3d 609, 613 (Tex. App. - Austin 2011, no pet.); 16 Tex. Admin. Code 25.231. The total is called the utility's "revenue requirement" or "cost of service." See, e.g., City of El Paso v. Public Util. Comm'n of Tex., 883 S.W.2d 179, 187 (Tex. 1994); 16 Tex. Admin. Code § 25.231. PURA also authorizes the Commission to allow a utility to recover through rates the reasonable expenses of participating in a rate case. Tex. Util. Code Ann. § 36.061.

II. In ETI's 2011 rate case, the Commission included some but not all of ETI's expenses in its cost of service.

The Company initiated a general base rate case and fuel reconciliation in 2011 because the rates then in effect did not adequately compensate ETI for its cost of providing service. The Commission assigned Docket No. 39896 to that case. ^[4] ETI sought a total annual increase of $\backslash$ 104.8$ million. ^[5] ETI also asked to recover its expenses of preparing the filing and participating in the rate case. ^[6]

The Commission severed the request for recovery of rate case expenses from Docket No. 39896 and established new Docket No. 40295 to address that issue. ^[7] The Commission ordered in the rate case that ETI's base rates be increased by a total of $\backslash$ 27.7$ annually. ^[8] That decision is not challenged in this appeal. ^[9] However, two aspects of that decision are relevant to this appeal from the Commission's decision in the rate case expense docket.

A. Depreciation Expense

One of the expenses PURA entitles a utility to recover is the depreciation of reasonable and necessary capital investments. See, e.g., State v. Public Util. Comm'n of Tex., 883 S.W.2d 190, 199 (Tex. 1994) (PURA authorizes recovery of both a return on, and a return of, its rate base); City of Corpus Christi v. Public Util. Comm'n of Tex., 51 S.W.3d 231, 238 (Tex. 2001) (under traditional regulation, utility recovers prudent capital investments in its rates through depreciation). In its rate case, ETI sought to recover depreciation expense for

some of its own capital investments, including assets used by ETI employees to do their jobs during the test year. ^[10]

ETI also sought to recover depreciation expense it incurred for assets that its affiliate, Entergy Services, Inc. ("ESI"), used to provide general services to ETI during the test year. Company witness Stephanie Tumminello explained that ESI is a service company established to provide professional services primarily to ETI and other Entergy utilities that operate in other jurisdictions. ^[11] In order to support the operations that are necessary to provide these services, ESI must invest in depreciable assets like computer equipment, computer software systems, communications equipment, furniture, fixtures, and leasehold improvements. ^[12] ESI allocates depreciation expense to ETI and the other companies ESI serves according to the labor cost it bills to each of them. ^[13] Ms. Tumminello confirmed that the depreciation costs ESI charges to ETI do not include any profit or markup, and are based on the actual costs of the assets used in ESI's operations. ^[14] The

Commission included the test-year ESI depreciation expense in ETI's cost of service in Docket No. 39896. ^[15]

B. Incentive Compensation

In Docket No. 39896, ETI also requested that its rates include the cost of incentive compensation programs for the Company's employees. Company witness Kevin Gardner testified that the primary purpose of these programs, in conjunction with the Company's base pay program, is to enable ETI to attract and keep talented employees, whose efforts translate into safe and reliable electric service for customers. ^[16] Mr. Gardner acknowledged that the Commission has, in several past cases, not allowed utilities to include what has been termed "financially based incentive compensation" in their cost of service used to set rates. ^[17] Another Company witness, Jay C. Hartzell, PhD, ^[18] explained more specifically that incentive compensation tied to cost control measures, profitability measures, and stock prices has been deemed "financially based" in some past Commission dockets. ^[19] Mr. Gardner acknowledged that some (but not all) of ETI's test-year incentive compensation expenses fall within those categories. ^[20]

Both Mr. Gardner and Dr. Hartzell, however, testified that the Commission should consider including all of ETI's incentive compensation programs in ETI's cost of service. Both witnesses testified that the Company's incentive compensation programs generally benefit customers. ^[21] They focused specific comments on incentive compensation programs that are tied to cost control measures, explaining at length how those programs in particular benefit customers. ^[22]

After an evidentiary hearing, the Administrative Law Judges ("ALJs") recommended that over $\backslash$ 6 $millionofET{I}^{\prime }srequested$ \ $104.8$ million rate increase should be disallowed as financially-based incentive compensation. ^[23] The ALJs agreed with ETI, however, that incentive compensation tied to cost control measures should be included in rates. They distinguished prior Commission precedent on cost-control incentive compensation and reasoned that, "[t]he evidence in this case demonstrates that ratepayers benefit when a utility incentivizes its employee to control costs."24 The Commission, with a few exceptions, adopted the proposal for decision. The Commission disallowed ETI's request to include financially-based incentive compensation in rates, but contrary

to its prior decisions, agreed that incentive compensation tied to cost controls should not be treated as "financial" in nature, thus allowing its inclusion in rates. ^[25]

III. The Commission disallowed some of ETI's rate case expenses in the rate case expense docket.

In Docket No. 40295, the expense proceeding severed from Docket No. 39896, the ALJ granted party status to the City of Anahuac, et al. ("Cities"), State of Texas agencies and institutions of higher education ("State Agencies"), the Office of Public Utility Counsel ("OPUC"), and Texas Industrial Energy Consumers ("TIEC"). ^[26] ETI sought a total of roughly $\backslash$ 7.6 $millionofitsownexpenses,aswellasreimbursementforexpensesincurredbyCitiesintheamountofabout$ \ $1.2$ million. ^[27]

Two components of ETI's request are the subject of this appeal. First, the costs ETI sought to recover included those of seeking to include financially-based incentive compensation in the rates set in Docket No. 39896. Second, consistent with its request to recover in base rates the test-year depreciation expense ETI incurred for ESI's general services, ETI sought to recover the separate depreciation expense ETI incurred for the services ESI provided on ETI's behalf in the rate case. ^[28]

After an evidentiary hearing, the ALJ issued a proposal for decision recommending the Commission reduce ETI's requested expenses by some $\backslash$ 1.5$ million. ^[29] Some of that reduction was attributable to the ALJ's conclusion that ETI should not recover depreciation expense associated with ESI's efforts on the rate case. ^[30] Another part of the reduction was attributable to the ALJ's conclusion that ETI should not recover expenses associated with its efforts to recover financiallybased incentive compensation through rates. The ALJ concluded that ETI's effort to recover financially-based incentive compensation was an "aggressive," "long shot" argument. ^[31] The ALJ did not attempt to quantify the actual expenses ETI incurred in its effort to recover this compensation, but instead used a proxy for that amount. The ALJ determined the ratio that ETI's financially-based incentive compensation bore to ETI's total requested rate increase in Docket No. 39896, and then reduced ETI's rate case expenses by that same ratio. ^[32] The remainder of the ALJ's recommended disallowance was related to other issues that are not pertinent to this appeal. ^[33] The ALJ's proposal for decision is appended to this brief as Appendix A.

The Commission accepted some of the ALJ's recommendations and rejected others. The Commission agreed with the ALJ that ETI should not recover

depreciation expense associated with ESI's efforts in the rate case. ^[34] The Commission also agreed that it was "unreasonable" and "overly aggressive" for ETI to argue its rates should include financially-based incentive compensation. The Commission further agreed that the disallowance should be quantified using the ALJ's "proxy" approach. ^[35] The Commission's order is appended to this brief as Appendix B.

ETI timely filed a motion for rehearing challenging the Commission's decision to disallow the depreciation expense and the Commission's decision to disallow the expense of seeking to include financially-based incentive compensation in rates. ETI also challenged the Commission's method of quantifying the disallowance associated with the financially-based incentive compensation argument. ^[36] The motion was overruled by operation of law.

ETI sought judicial review of the Commission's decision. ^[37] State Agencies, OPUC, and TIEC intervened. ^[38] The district court summarily affirmed the Commission's decision. ^[39]

SUMMARY OF THE ARGUMENT

The Commission's decision is arbitrary and capricious in several respects. First, the finding that ETI was unreasonable for seeking to include incentive compensation in rates does not hold water in light of Commission precedent. Though the Commission has in the past disallowed incentive compensation that it has deemed "financially based," the Commission has never articulated a clear definition of that category of costs. In fact, the Commission has treated analogous costs differently in rate cases involving different utilities. As this Court recently recognized, whether a particular cost is "financially based" is a fact question. See State of Texas Agencies &; Institutions of Higher Learning v. Public Util. Comm'n of Tex., No. 03-11-00072-CV, 2014 WL 6893871 *31 (Tex. App. - Austin Dec. 4, 2014, no pet. h). It is not a settled principle of policy or law. Nor is the Commission bound to follow its previous decisions in the same way a court is bound. For these reasons, it cannot have been patently unreasonable for ETI to seek to persuade the Commission to consider including incentive compensation costs in rates.

Second, though the Commission has several times disallowed the expenses of various utilities' incentive compensation programs, the Commission has never before disallowed the costs of making an unsuccessful attempt to include them in rates. Indeed, the Commission has allowed other utilities to recover the costs of

making their unsuccessful arguments. The Commission imposed its new policy of disallowing this type of rate case expense for the first time at the end of this contested case. The Commission did not acknowledge its departure from its previous decisions, much less explain it or give ETI notice of the change when ETI could have done something about it. The Commission's decision is reversible on this basis alone. This Court reached that conclusion in an analogous appeal from a rate case expense order. See Oncor Elec. Delivery Co. v. Public Util. Comm'n of Tex., 406 S.W.3d 253, 267 (Tex. App. - Austin 2013, no pet.).

The Commission's decision is also reversible because it constitutes improper adjudicative rulemaking. The Commission actually engaged in a formal rulemaking on this issue soon after this case was decided. See 16 Tex. Admin. Code § 25.245. It was error for the Commission to impose its new policy upon ETI at the end of this contested case, instead of prospectively after engaging in a formal rulemaking proceeding. This Court recently reached a similar conclusion in a case involving a different agency. See Texas State Board of Pharmacy v. Witcher, 447 S.W.3d 520, 535 (Tex. App. - Austin 2014, pet. filed).

Even if the Commission were justified in disallowing the expenses of advocating recovery of incentive compensation costs, the Commission erred in quantifying the disallowance. ETI presented evidence of the expenses of making the argument. No party presented any evidence in rebuttal. Nevertheless, the ALJ

declined to attempt to quantify the actual expenses of making the argument. Instead, the ALJ used a "proxy" for actual expenses that results in a disallowance that bears no logical relationship to the purportedly "unreasonable" expense. Even though the Commission has never before used such a "proxy" method, the Commission used the proxy method at the end of this contested case, before it engaged in a formal rulemaking proceeding on the issue. The Commission's decision in this respect is arbitrary and capricious.

So is the Commission's disallowance of the ESI depreciation expense that ETI incurred for ESI's efforts in the rate case. The Commission's decision is not supported by any evidence in the record. Instead, it is based upon an illogical speculation that ETI would not have paid as much if it had hired an outside vendor to perform the services that ESI performed. No witness said anything supporting that speculation. Moreover, the Commission allowed ETI to recover the analogous depreciation expense it incurred for ESI's general services during the test year, finding it was a reasonable and necessary test-year expense. There is no rational basis in the evidence upon which to distinguish between ESI's use of assets to perform general services during the test year and ESI's use of the same assets to assist ETI in a rate case. The Commission's disallowance of the depreciation expense here must, therefore, be reversed.

ARGUMENT AND AUTHORITIES

I. The Commission's disallowance of ETI's costs of litigating the incentive compensation issue is arbitrary and capricious and an abuse of discretion.

The Commission determined that $\backslash$ 522,244.66$ of ETI's rate case expenses were "properly disallowed" because they were "attributable to unreasonable and overly aggressive arguments pursued by ETI in Docket 39896 related to financially-based incentive compensation. ^[40] The Commission's stated rationale for its decision was that:

The Commission has repeatedly ruled that a utility cannot recover the cost of financially-based incentive compensation because financial measures are of more immediate benefit to shareholders and financial measures are not necessary or reasonable to provide utility services. The Commission concludes that it should follow its well-established policy here. ^[41] A. The Commission's finding that ETI was unreasonable in advocating recovery of financially-based incentive compensation is arbitrary and capricious.

This Court recently acknowledged the Commission's policy of allowing the recovery of incentive compensation tied to operational performance, but denying recovery of incentive compensation tied to financial performance on the theory that the latter more immediately benefits shareholders than ratepayers. See State of Texas' Agencies &; Institutions of Higher Learning, supra, 2014 WL 6893871 *31

n. 34 (collecting cases). ETI does not disagree that the Commission has historically articulated this perceived dichotomy.

However, the division between the two types of costs is anything but clear under Commission precedent. The Commission has not foreclosed the possibility of recovering any incentives associated with numerical triggers. ^[42] Indeed, while the Commission has clearly identified two theoretical "buckets" of incentive costs, the Commission has not clearly or consistently advised utilities how to assign actual costs to one bucket or another. For example, though the Commission previously disallowed another utility's incentive compensation tied to cost controls, ^[43] the Commission allowed ETI to recover incentive compensation tied to cost controls in Docket No. 39896. ^[44] And though the Commission disallowed recovery of ETI's stock-based incentive payments in Docket No. 39896, ^[45] the Commission subsequently allowed another utility to recover the "restricted stock

units" it paid as incentive compensation. ^[46] Excerpts of these Commission decisions are compiled in Appendix C to this brief.

In short, the question of which incentives are "financial" versus "operational" in a given case is one of fact, to be decided in light of the evidence presented in that case. This Court said so in no uncertain terms in the State of Texas' Agencies case just two months ago. State of Texas' Agencies, 2014 WL 6893871 *31 ("Because the question of whether Oncor's incentive-compensation payments were 'financial' rather than 'operational' in nature is one of fact," the Court reviewed the Commission's assignment of costs to one category or the other for evidentiary support under the substantial evidence rule).

The fact that the Commission has not adopted a consistent approach is perhaps why many utilities have repeatedly raised the issue in rate cases for years. ^[47] It is also likely why PUCT Commissioner Anderson acknowledged that

the recovery of financially-based incentive costs may be possible in a "properly organized and evidenced" case. ^[48]

The findings that Commission policy was cemented long ago, and that it was unreasonable for ETI to seek recovery of financially-based incentives, simply cannot withstand scrutiny. The contours of financially-based incentive compensation are demonstrably not set in stone. ETI actually prevailed in Docket No. 39896 on some of its request to recover what had previously been deemed unrecoverable incentive compensation, resulting in an additional $\backslash$ 1$ million for recovery of incentive compensation costs. Even if the issue had not undergone any development over time, the Commission is not absolutely bound by its previous decisions and may change its policy on a given issue when relevant circumstances change. See, e.g., Public Util. Comm'n of Tex. v. Texas Telephone Ass'n, 163 S.W.3d 204, 218-19 (Tex. App. - Austin 2005, no pet.); South Tex. Indus. Servs., Inc. v. Texas Dep't of Water Res., 573 S.W.2d 302, 304 (Tex. Civ. App. - Austin 1978, writ ref'd n.r.e.). For all these reasons, ETI's litigation of the financiallybased incentive compensation issue in Docket No. 39896 cannot have been patently unreasonable. To the contrary, it is patently arbitrary for the Commission to treat the issue as a case-by-case, factual inquiry in multiple cases, including

ETI's 2011 rate case, and then treat it as a question of law governed by unvarying and unalterable precedent for purposes of rate case expense review.

B. The Commission acted arbitrarily and abused its discretion by disallowing ETI's expenses of making its argument about financially-based incentive compensation.

Regardless of how "aggressive" ETI's position was on the issue of financially-based incentive compensation, it was arbitrary and an abuse of discretion for the Commission to disallow the costs of asserting the argument in this case.

1. The Commission has never before disallowed the costs of making unsuccessful incentive compensation arguments.

Though the Commission had previously disallowed the inclusion of financially-based incentive compensation in rates, the Commission has consistently allowed utilities to recover the expenses associated with their efforts to recover the incentive costs. For example, the Commission disallowed some of CenterPoint's incentive compensation in Docket No. 38339, ^[49] but allowed CenterPoint to recover the expenses of making this argument. ^[50] Similarly, the Commission disallowed some of AEP Texas Central Company's long-term incentive compensation in

Docket No. 33309, ^[51] but allowed the company to recover the expenses of making its argument and expressly determined that they were reasonably incurred. ^[52]

Furthermore, the Commission disallowed some of AEP Central's "performance based" incentive compensation in Docket No. 28840, ^[53] but allowed the company to recover its expenses of making its argument, which the Commission expressly determined were reasonably incurred. ^[54] Excerpts from these Commission decisions are compiled at Appendix D to this brief.

This is the first time the Commission disallowed the expenses of advocating for the recovery of financially-based incentive compensation. Chairman Nelson acknowledged this fact at the open meeting in this very case:

And on C.2.a. which is financially based incentive compensation, I kind of struggled with this issue because I - I understood what all the different parties were articulating, but ultimately I'm not sure in this docket it's appropriate for us to impose a new policy of disallowing rate case expenses related to advocacy of long-shot positions. ^[55]

Nevertheless, the Commission imposed the new standard, for the first time, at the conclusion of this contested case.

2. It was arbitrary and an abuse of discretion to impose a new standard upon ETI at the end of the administrative process.

Parties are entitled to know what agency standards will be applied to them in advance of the administrative process. This Court recently reiterated this fundamental principle of Texas administrative and constitutional law in another rate case expense appeal. See Oncor Elec. Delivery Co., supra, 406 S.W.3d at 267. In Oncor, the Commission disallowed the utility's expenses that were incurred in the past because, the Commission declared, past rate case expenses that occurred outside the test year are not recoverable. This was a departure from the Commission's past interpretation of relevant principles, imposed long after the utility had incurred the expenses at issue. This Court held that the Commission's post-hearing imposition of a new policy was fundamentally unfair because by that time, it was too late for Oncor to comply with the new rule. Id. at 268-69.

The same thing happened here. The administrative process at issue began when Docket No. 39896 was filed. At that time, the Commission had given no indication whatsoever that it would not continue to allow recovery of otherwise reasonable expenses related to litigating incentive compensation. The Commission announced its new policy only after ETI had litigated the issue (and, ironically, won part of it). Had the Commission made the new policy known on a prospective basis, ETI would have had the opportunity to present its case differently.

The Commission's action in this case also violates another principle that was at issue in Oncor. That is, as this Court wrote, "[a]lthough agencies are not bound to follow their decisions in contested cases in the same way that courts must follow controlling precedent, an agency must explain its reasoning when it departs from prior norms." Id. at 267 (citing, e.g., Flores v. Employees Ret. Sys., 74 S.W.3d 532, 544-45 (Tex. App. -- Austin 2002, pet. denied)). Because the Commission in Oncor changed its position on the recovery of expenses incurred outside the test year without providing any explanation for its change in its prior practice - and denied Oncor's expenses on the basis of its new position - this Court reversed the Commission's decision. Id. at 272.

The same result should obtain here. Contrary to its consistent precedent allowing utilities to recover the cost of litigating the incentive compensation issue, the Commission for the first time declared it is unreasonable to incur expenses to litigate that issue. The Commission in its order did not acknowledge, much less explain, its departure from its precedent on this issue. Because the Commission gave no notice or justification for its about-face on the recovery of rate case expenses in this circumstance, the Commission's application of the policy to ETI in this case is arbitrary and capricious and an abuse of discretion. Harris County Hosp. Dist. v. Public Util. Comm'n of Tex., No. 03-10-00647-CV, 2012 WL 2989228 *7 (Tex. App. - Austin Jul. 13, 2012, no pet.) (not designated for

publication); Flores, 74 S.W.3d at 544-45; City of El Paso v. El Paso Elec. Co., 851 S.W.2d 896, 900 (Tex. App. - Austin 1993, writ denied). The decision must be reversed for that reason alone. See Tex. Gov't Code Ann. § 2001.174.

3. The Commission's action also constitutes improper ad hoc rulemaking.

The appropriate way for the Commission to impose a new policy like this is to engage in a rulemaking and impose the new standard upon the industry uniformly on a prospective basis.

When an agency adopts a new policy that it intends to apply irrespective of the circumstances of an individual case, the agency adopts a "rule." E.g., Witcher, supra, 447 S.W.3d at 528-30 &; 535-356. It is indisputable that the Commission in this case adopted a new rule of general applicability. The Commission did not in its order identify any facts peculiar to this case that suggest the policy applies only to this case. The Commission's broad conclusion that it is "unreasonable" to incur expense to litigate the recoverability of financially-based incentive compensation is based solely on something the Commission says is "well-established policy."56 The decision clearly has implications beyond the parties to the underlying proceeding. Indeed, as noted above, Chairman Nelson confirmed at an open meeting that the Commission was in this case setting a "new policy." She even

observed, on the record, that the subject is more properly addressed in a rulemaking. She said:

What I would like to do is, if it's okay with you, is open a rulemaking. I think just the issue in general of rate case expenses, whether it's a utility or the cities, I think it's something that we've needed to look at for a while, and this is the type of issue that would be appropriate to include in that type of a rulemaking. ^[57]

A state agency presumptively must promulgate new rules through rulemaking procedures, which include giving notice of a proposed new rule, soliciting public comment, submitting to legislative review, and entering an order to adopt the new rule. See Tex. Gov't Code Ann. §§ 2001.023; 2001.029; 2001.032-.033; Rodriguez v. Service Lloyds Ins. Co., 997 S.W.2d 248, 255 (Tex. 1999). Rulemaking hearings are different from contested case hearings in that "rulemaking procedures maximize 'public participation in the rulemaking process,' a stated purpose of the APA, while contested case procedures limit participation to those directly affected by the dispute." Railroad Comm'n of Tex. v. WBD Oil &; Gas Co., 104 S.W.3d 69, 77 (Tex. 2003) (footnote omitted), cited in City of Arlington v. Centerfolds, Inc., 232 S.W.3d 238, 253-54 (Tex. App. - Fort Worth 2007, pet. denied). By providing for formal rulemaking procedures, the legislature intended to ensure that the public and affected persons are heard on matters that affect them and receive notice of new rules. See Rodriguez, 997 S.W.2d at 255.

The legislature delegates formal rulemaking power to an agency with the expectation that an agency will ordinarily adopt rules of general application through that power. Id.

Allowing an agency to create broad amendments to its rules through administrative adjudication rather than through its rulemaking authority undercuts the APA. Rodriguez, 997 S.W.2d at 255. Only in "exceptional" cases may an agency choose to formulate and enforce a general requirement through a decision in a particular case. See, e.g., id.; Witcher, 447 S.W.3d at 535. As this Court recently reiterated in Witcher, supra, adjudicative rulemaking has been recognized as appropriate only when an agency is confronted with: (1) an issue of first impression; (2) a new or amended statutory scheme or administrative rules; or (3) an issue that cannot be adequately captured within the bounds of a general rule because the problem is so specialized and varying in nature. Witcher, 447 S.W.3d at 535; see also City of El Paso v. Public Util. Comm'n of Tex., 883 S.W.2d 179, 188-89 (Tex.1994); CenterPoint Energy Entex v. Railroad Comm'n of Texas, 213 S.W.3d 364, 369 (Tex. App. - Austin 2006, no pet.); Entergy Gulf States, Inc. v. Public Utility Comm'n of Tex., 173 S.W.3d 199, 212 (Tex. App. - Austin 2005, pet. denied); Southwestern Bell Tel. Co. v. Public Util. Comm'n of Tex., 745 S.W.2d 918, 926 (Tex. App. - Austin 1988, writ denied).

None of those circumstances is present here. First, whether a utility should be precluded from recovering expenses of arguing against a decision in a prior Commission proceeding is certainly not an issue of first impression. Virtually every rate case involves such a scenario; that is what drives the evolution of agency policy over time. And the expenses of making the particular argument at issue here - the recoverability of financially-based incentive compensation - have been awarded in numerous Commission dockets. ^[58] Second, the Commission's decision is not based upon any new or amended statutory provision or agency rule. Finally, whether a utility should be allowed to recover expenses of arguing against a prior Commission decision is not an issue so specialized or varying in nature that it cannot be adequately captured in a general rule.

Not only did Chairman Nelson expressly acknowledged that the issue is well-suited to a rulemaking proceeding, but the Commission ultimately did adopt a rule on this very subject. On August 6, 2014, the Commission adopted new Rule 25.245, entitled "Rate Case Expenses." See 16 Tex. Admin. Code § 25.245 (Appendix F). In that rule, the Commission set forth the criteria for review and determination of the reasonableness of rate case expenses. One of those criteria is whether "the utility's ... proposal on an issue in the rate case had no reasonable basis in law, policy, or fact and was not warranted by any reasonable argument for

the extension, modification, or reversal of commission precedent." Id. § 25.245(c)(4). In response to comments that there should be a delay in implementation of the rule to give parties adequate notice of its effect, the Commission noted that the "proposed rule will only apply to applications filed after the effective date of the rule and will not be applied retroactively." 39 Tex. Reg. at 6445 .

The Commission itself obviously recognizes that the recoverability of the expense of arguing against Commission precedent is the proper subject of a formal administrative rule, and one that should be applied on a prospective basis. Moreover, the standard that resulted from the formal rulemaking process, in which there was wide participation from all types of industry participants, does not penalize utilities for making "long shot" or "aggressive" arguments. Rather, the standard contemplates penalizing utilities for making arguments that have no reasonable basis in law or fact and not based on a reasonable argument for the extension, modification or reversal of Commission precedent. 16 Tex. Admin. Code § 25.245(c)(4). Given that ETI supported its argument in this case with abundant evidence and policy arguments, and those arguments resulted in the reversal of Commission policy in one respect, application of the rule would not result in a disallowance of rate case expenses in this case. The Commission's adoption of a more stringent policy in this contested case, before fully vetting it in

a formal rulemaking proceeding, was invalid ad hoc rulemaking and must be reversed. See, e.g., Witcher, 447 S.W.3d at 535.

C. The Commission further erred in quantifying the expenses ETI incurred in seeking to include financially-based incentive compensation in rates.

Even if the Commission's rationale for the disallowance were not reversible, the Commission's quantification of the disallowance should be reversed. The Commission adopted the ALJ's method of determining how much money should be disallowed for litigating the recovery of financially-based incentive compensation. The ALJ acknowledged that some of ETI's expenses relating to the pursuit of its financially-based incentive compensation are clear in the record. ^[59] The ALJ opined, however, that ETI's total cost of litigating the issue was not clear because the cost of discussing the issue at hearing and in post-hearing briefing was not separately identified in the record. ^[60] The ALJ, therefore, abandoned an effort to quantify the expenses of litigating the issue and instead used a proxy for that amount. ^[61] The ALJ recommended reducing the balance of ETI's otherwise reasonably incurred rate case expenses by the ratio of the disallowed incentive compensation to the total requested rate increase in Docket No. 39896. ^[62] Using this method, the Commission found that $\backslash$ 522,244.66$ of ETI's rate case expenses

were "related to" the financially-based incentive compensation argument. ^[63] The Commission's use of this "proxy" method for quantifying the disallowance is another significant, unexplained departure from Commission precedent and should be imposed, if at all, prospectively after a rulemaking proceeding.

1. The Commission has never before required a utility to record its rate case expenses by issue, nor has the Commission used a proxy to quantify a disallowance.

The ALJ ignored ETI's evidence based on his belief that the Company had the burden to "separate out any unreasonable expenses." ^[64] But there has never been any regulatory requirement for utilities to segregate fees and expenses based on speculation about what might later be considered to be a long-shot, aggressive position. Indeed, as noted above, the Commission has consistently authorized utilities to recover all their expenses of making arguments about incentive compensation, even when utilities have been partially unsuccessful in making those arguments.

Moreover, historically, when the Commission has disallowed rate case expenses tied to contested issues, it has quantified the disallowances based on actual amounts of expenses associated with testimony tied to the contested issue. ^[65]

For example, in Docket No. 9945, the Commission disallowed the "fees and expenses" of an El Paso Electric Company witness based on a finding that his testimony "contributed nothing to the docket." ^[66] Similarly, in Docket No. 31433, the Commission disallowed fifty percent of a Cities' witness's fees based on a finding that a survey she performed was "seriously flawed." ^[67] The fifty percent disallowance imposed was an estimate of the actual rate case expenses unreasonably incurred based on specific fees identified in the record evidence. The Commission did not resort to a proxy approach to determine the amount of the disallowance to be imposed.

The Commission's historical approach creates an appropriate and proportionate economic incentive to avoid unreasonable action by assessing the cost of the action and then disallowing that level of cost. The proxy method, on the other hand, has no actual relationship to the rate case expenses associated with the litigated issue. Because the disallowance is calculated based upon the proposed value of the position and not the cost of asserting the position, the disallowance will almost surely be more - or less - than the actual rate case expenses at issue. It is very unlikely, under this proxy approach, that the disallowance will even resemble the actual cost the utility incurred to litigate the particular issue.

In this case, no party contends that ETI actually incurred anywhere near $\backslash$ 522,244.66 $inexpensestopursuerecoveryoffinancially-basedincentivecompensation.ETIprovidedunrebuttedevidenceoftheamountofratecaseexpensesassociatedwiththewitnesseswhoaddressedtheissue.Dr.Hartzel{l}^{\prime }sdirectbillingstotheCompanytotaled$ \ $12,825.{}^{68}$ The rate case expenses associated with all of Mr. Gardner's work on the rate case were identified as $\backslash$ 277,668 .{ }^{69}$ Assuming arguendo that a disallowance was appropriate, the record does not support a disallowance of nearly twice the sum of these amounts. In fact, even if a disallowance were appropriate, the record reasonably supports a much lesser disallowance, because at least half of Mr. Gardner's testimony related to topics other than financially-based incentive compensation. And both Mr. Gardner and Dr. Hartzell's testimony focused in part upon cost-control-based incentive compensation, which is an issue upon which ETI prevailed. Nevertheless, hundreds of thousands of dollars in admittedly reasonable rate case expenses were disallowed. This is an illogical application of the applicable PURA provision, which authorizes the Commission to enable a utility to recover its reasonablyincurred rate case expenses. See Tex. Util. Code Ann. § 36.061(b).

2. The Commission imposed a new standard upon ETI at the end of the contested case, again engaging in inappropriate ad hoc rulemaking.

The imposition of the new standards for tracking expenses, and for quantifying disallowances, at the conclusion of the case, especially without any articulated rational justification, is arbitrary and capricious and an abuse of discretion. Oncor, 406 S.W.3d at 272; Harris County Hosp. Dist., 2012 WL 2989228 *7; Flores, 74 S.W.3d at 544-45; City of El Paso, 851 S.W.2d at 900. Moreover, these are not new issues, are not the subject of any new statute or rule, and are not so specialized or varying in nature that they cannot be adequately captured in a general rule. Therefore, the imposition of the new standards upon ETI in this case does not fall within the narrow set of exceptions to the general requirement that an agency develop and impose rules uniformly upon the industry through formal rulemaking proceedings. E.g., Witcher, 447 S.W.3d at 535.

The Commission argued below that it was not an abuse of discretion to employ these new standards at the end of this case, after ETI had already incurred and tracked its expenses as it had always done, because the Commission was "not making any new policy decision" and "not adopting a rule." Again, the Commission's recent rulemaking disproves its argument. The new rule pertaining to rate case expenses for the first time requires utilities to record their rate case expenses by issue. See 16 Tex. Admin. Code § 25.245(b)(6). It also details for the

first time how the Commission will quantify disallowances for various reasons. The Commission will "use estimates in lieu of actual costs if reasonably accurate and supported by the evidence." Id. § 25.245(d)(1). The Commission will disallow a percentage of total rate case expenses only when it determines that "rate case expenses as a whole were disproportionate, excessive, or unwarranted in relation to the nature and scope of the rate case...." Id. § 25.245 (c)(5) &; (d)(2)(A). Clearly, whether and when to use the "proxy" approach is the proper subject of a rulemaking.

The terms of the new rule make clear the very types of issues and responsibilities that ETI had no warning of and no ability to anticipate or comply with in this proceeding. It was an abuse of discretion for the Commission to fault ETI for the way it recorded its rate case expenses, and to craft and apply the "proxy" approach at the end of this case, after the utility had already incurred and recorded the expenses at issue in reliance on past Commission decisions. Imposition of the new standards on ETI in the context of this contested case, before even proposing the rule, was arbitrary and capricious and an abuse of discretion, just as it was to disallow the expenses of the incentive compensation advocacy in the first place. For any one of these reasons, this Court must reverse the Commission's decision on this issue and remand the case to the Commission for

further proceedings. Witcher, 447 S.W.3d at 534; Oncor, 406 S.W.3d at 272; see Tex. Gov't Code Ann. § 2001.174.

II. The Commission's disallowance of the ESI depreciation expense that ETI incurred in the rate case is not supported by substantial evidence and is arbitrary and capricious.

As explained above, ETI also sought to recover the costs of the work its affiliate, ESI, performed in connection with Docket No. 39896. In the rate case, the Commission found that the wage and depreciation expense associated with the general services ESI performed during the test year were "reasonable and necessary."70 In the rate case expense proceeding, however, the Commission allowed the wage expense but disallowed the $\backslash$ 207,683$ in depreciation expense. The only reason the Commission gave for disallowing the depreciation cost was that ETI "would not similarly recover such an expense in an arms-length transaction with an unaffiliated company."71

This decision is not supported by any evidence in the record. No one testified that ETI paid more for ESI's services than it would have paid to an outside vendor because ETI paid depreciation expense. To the contrary, ETI proffered unrefuted evidence in Docket No. 40295 that the costs of ESI's efforts, including the depreciation expense, were reasonable and necessary expenses of participating

in the rate case. ^[72] ETI witness Michael Considine testified that the ESI costs charged to ETI for work on Docket No. 39896 included the actual cost of ESI employee payroll, benefits, and taxes as well as depreciation expense associated with the depreciable assets that enable ESI employees to provide services, including those provided in connection with the ETI rate case. ^[73] Mr. Considine further explained:

The use of assets required to support employee service functions necessarily results in depreciation and amortization cost. ESI's depreciation expense is thus loaded to all project codes which incur ESI labor charges. The rate case project code here should likewise be charged its share of depreciation expense. ^[74]

ETI witness Stephanie Tumminello's testimony in the rate case, of which the ALJ took official notice, ^[75] further supports Mr. Considine's testimony. Again, Ms. Tumminello explained that ESI's depreciation expense is for computer equipment, software, communications equipment, furniture, fixtures, and leasehold improvements. ^[76] She confirmed that the depreciation costs charged to ETI represent actual costs and do not include any profit or mark-up. ^[77] She also

confirmed that ESI could not serve ETI without the depreciated assets. ^[78] There is no evidence to the contrary in the record.

The ALJ's speculation that ETI could have procured the services without equivalent expense from a non-affiliate appears to be the result of confusion over differences in how this cost is billed by ESI versus non-affiliated vendors. ETI's outside vendors, which use depreciable assets to the same extent ESI does, do not itemize their depreciation expense on their bills. That practice, however, does not support the conclusion that outside vendors do not recover depreciation expenses from ETI. It only shows that they are not required to bill with complete transparency, and do not necessarily bill their services at cost. The ALJ ultimately acknowledged that depreciation costs "would 'typically [be] imbedded in a vendor's labor costs billed to the Company." ^[79] This fact - deemed a "concession" by the ALJ — proves ETI's point.

ESI, in contrast to outside vendors, itemizes the costs of providing service to ETI to demonstrate that ESI does provide those services at cost. ^[80] The fact that the costs of ESI's services are tracked at a more granular level than those of outside vendors is a function of the Commission's affiliate rules, which require that an affiliate fully allocate its costs and prohibit a utility from subsidizing its affiliate's

business with funds from regulated activities. See 16 Tex. Admin. Code § 25.272(e)(1). ETI witness Mr. Considine confirmed that ESI expenses did not include prohibited expenses. ^[81] No witness testified to the contrary.

The Commission has argued that ETI's proof was not sufficient to establish these expenses were reasonably incurred because affiliate expenses are subject to more scrutiny than other categories of expense. But again, the Commission allowed ETI to include depreciation associated with ESI's general services in its test-year expenses in the underlying rate case. ^[82] The quality and character of proof of ESI depreciation expense is the same in both the rate case and the expense docket. Again, the ALJ at the outset of the hearing in the expense docket took judicial notice of the record in the rate case. ^[83] There is no rational basis in the record to include depreciation of ESI's office equipment in base rates when ESI is generally serving ETI but not when ESI is working on a rate case. ESI employees need to use office equipment for both general and rate-case tasks.

There is no logical rationale or any evidentiary support for disallowing this reasonable and necessary cost that ESI incurred to provide services to ETI in connection with Docket No. 39896. Accordingly, the Court must reverse the Commission's order on this issue. See Tex. Gov't Code Ann. § 2001.174.

CONCLUSION AND PRAYER

For the foregoing reasons, Entergy Texas, Inc. respectfully requests that the Court:

• reverse the district court's judgment upholding the Public Utility Commission of Texas's disallowance of depreciation expense associated with ESI's efforts on the rate case; and
• reverse the district court's judgment upholding the Commission's decision to disallow expenses associated with ETI's request to include financially-based incentive compensation in rates or, alternatively, reverse the judgment upholding the Commission's quantification of the disallowance for the expenses associated with the incentive compensation issue; and
• $$ remand the case to the Commission for proceedings consistent with the Court's decision.

ETI further requests its costs of court and any other relief to which it may show itself justly entitled.

Respectfully submitted,

DUGGINS WREN MANN &; ROMERO, LLP

By: /s/Marnie A. McCormick John F. Williams State Bar No. 21554100 jwilliams@dwmrlaw.com Marnie A. McCormick State Bar No. 00794264 mmccormick@dwmrlaw.com P. O. Box 1149

Austin, Texas 78767-1149 (512) 744-9300 (512) 744-9399 fax

ATTORNEYS FOR APPELLANT ENTERGY TEXAS, INC.

CERTIFICATE OF COMPLIANCE

I certify that this document contains 8,735 words in the portions of the document that are subject to the word limits of Texas Rule of Appellate Procedure 9.4(i), as measured by the undersigned's word-processing software. /s/ Marnie A. McCormick Marnie A. McCormick

CERTIFICATE OF SERVICE

As required by Texas Rule of Appellate Procedure 9.5, I certify that on the 6th day of February, 2015, the foregoing document was electronically filed with the Clerk of the Court using the electronic case filing system of the Court, and that a true and correct copy was served on the following lead counsel for all parties listed below via electronic service:

Elizabeth R. B. Sterling Environmental Protection Division Office of the Attorney General P. O. Box 12548 (MC 066)

Austin TX 78711-2548 Counsel for Appellee Public Utility Commission of Texas Rex D. VanMiddlesworth Benjamin Hallmark Thompson Knight LLP 98 San Jacinto Blvd., Ste. 1900 Austin TX 78701 Counsel for Appellee Texas Industrial Energy Consumers Katherine H. Farrell Administrative Law Division Office of the Attorney General P. O. Box 12548 (MC018-12)

Austin TX 78711-2548 Counsel for Appellee State Agencies Ross Henderson Office of Public Utility Counsel 1701 N. Congress Ave., Ste. 9-180 P. O. Box 12397

Austin TX 78711-2397 Counsel for Appellee Office of Public Utility Counsel /8/ Marnie A. McCormick Marnie A. McCormick

APPENDICES

A. ALJ's Proposal for Decision in Docket No. 40295 B. Commission's Final Order in Docket No. 40295 C. Excerpts of Commission Dockets Awarding and Denying Various forms of Incentive Compensation D. Excerpts of Commission Dockets Awarding Expenses of Unsuccessful Attempts to Recover Financially-Based Incentive Compensation E. Excerpts of Transcript of April 11, 2013 Commission Open Meeting F. Commission Substantive Rule 25.245 ("Rate Case Expenses") G. District Court's Final Judgment

Appendix A

ALJ's Proposal for Decision in Docket No. 40295

State Office of Administrative Hearings

2013 FEB 19 PM 3: 24 Fintion w.l. 1

Cathleen Parsley Chief Administrative Law Judge

February 19, 2013

TO: Stephen Journeay, Director Commission Advising and Docket Management William B. Travis State Office Building 1701 N. Congress, 7th Floor Austin, Texas 78701

RE: SOAH Docket No. 473-12-5573 PUC Docket No. 40295

Application of Entergy Texas, Inc. for Rate Case Expenses Pertaining to PUC Docket No. 39896

Enclosed is the Proposal for Decision (PFD) in the above-referenced case. By copy of this letter, the parties to this proceeding are being served with the PFD.

Please place this case on an open meeting agenda for the Commissioners' consideration. There is no deadline in this case. Please notify me and the parties of the open meeting date, as well as the deadlines for filing exceptions to the PFD, replies to the exceptions, and requests for oral argument.

HB/mle Enclosure xc: All Parties of Record

SOAH DOCKET NO. 473-12-5573
PUC DOCKET NO. 40295
2013FEB 19 PM 3:24

TABLE OF CONTENTS I. BACKGROUND ..... 1 II. JURISDICTION, NOTICE, AND PROCEDURAL HISTORY ..... 2 III. PARTIES ..... 2 IV. DISCUSSION ..... 3 A. Overview ..... 3 B. Cities' Rate Case Expenses ..... 4 C. ETI's Rate Case Expenses ..... 8

1. Challenges to Specific ETI Rate Case Expenses That are Relatively Quantifiable ..... 8 a. Costs Associated with Gerald Tucker, ETI's Consulting Expert ..... 8 b. Costs Associated with "Lessons Learned" ..... 10 c. ESI Depreciation Costs ..... 11 d. Miscellaneous Internal Rate Case Expenses ..... 13 e. Costs Associated with the Calpine-Carville PPA ..... 13 f. Specific Items That State Agencies Contend Cast Doubt on ETI's Overall Scrutiny of Its Expenses ..... 15 (1) External Legal Fees ..... 16 (2) Meals and Snacks ..... 17 (3) Courier and Taxi Services ..... 18 (4) Meals Over $\backslash$ 25$ ..... 19 (5) Clothing and Laundry Service ..... 20 (6) Airfare and Lodging ..... 20

1. Challenges to Specific ETI Rate Case Expenses That are Difficult to Quantify ..... 21 a. Financially-Based Incentive Compensation ..... 21 b. Transmission Equalization (MSS-2) Expenses ..... 25 c. Purchased Power Capacity Rider ..... 27
2. Proportional Reduction ..... 28 D. Recovery Method ..... 34
3. Rate Case Expense Allocation and the Recovery Mechanism ..... 34
4. ETI's Request to Earn a Return on the Unpaid Balance of Rate Case Expenses ..... 35 V. CONCLUSION ..... 36 VI. PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDERING PARAGRAPHS ..... 36 A. Findings of Fact ..... 36 B. Conclusions of Law ..... 38 C. Proposed Ordering Paragraphs ..... 39

SOAH DOCKET NO. 473-12-5573
PUC DOCKET NO. 40295

APPLICATION OF ENTERGY TEXAS, INC. FOR RATE CASE EXPENSES PERTAINING TO PUC DOCKET NO. 39896

BEFORE THE STATE OFFICE OF
$\S$
$\S$
$\S$
$\S$
ADDIINISTRATIVE HEARINGS

PROPOSAL FOR DECISION

I. BACKGROUND

Entergy Texas, Inc. (ETI) is an investor-owned electric utility with a retail service area located in southeastern Texas. ETI serves retail and wholesale electric customers in Texas. On November 28, 2011, ETI filed an application requesting approval of an increase in annual base rate revenues, a reconciliation of fuel costs, and authority to defer costs for the transition to the Midwest Independent System Operator (the ETI Application). On November 29, 2011, the Commission referred the ETI Application, PUC Docket No. 39896, to SOAH (Docket 39896). On April 4, 2012, the Administrative Law Judges (ALJs) presiding over Docket 39896 issued an order severing from Docket 39896 the issues relating to ETI's request to recover its rate case expenses and creating this docket, Docket 40295, for consideration of the rate case expenses.

In this Proposal for Decision (PFD), the ALJ recommends as follows:

• That Cities ^[1] be allowed to recover from ETI a total of $\backslash$ 1,201,569 $inratecaseexpenses(representing$ \ $1,125,769$ in rate case expenses incurred through August 31, 2012, plus up to $\backslash$ 75,800$ in rate case expenses as they are incurred after August 31, 2012); and
• That ETI be allowed to recover a total of $\backslash$ 7,344,113$ in rate case expenses.

II. JURISDICTION, NOTICE, AND PROCEDURAL HISTORY

The Public Utility Commission of Texas (Commission or PUC) has jurisdiction over ETI and this rate case expenses hearing pursuant to Texas Utility Code, Public Utility Regulatory Act (PURA) §§ 32.001, 33.002, and 35.004. The State Office of Administrative Hearings (SOAH) has jurisdiction over the contested case hearing, including the preparation of the proposal for decision (PFD) pursuant to PURA § 14.053 and Texas Government Code § 2003.049(b). ETI's notice of its application and notice of the hearing were not contested and, therefore, do not require further discussion here but will be addressed in the proposed findings of fact and conclusions of law.

The hearing on the merits in Docket 39896 was held in April-May, 2012. The PFD was issued on July 6, 2012. A Final Order in Docket 39896 was issued by the Commission on September 14, 2012. In response to motions for rehearing submitted by multiple parties, the Commission issued an Order on Rehearing on November 2, 2012, in Docket $39896{}^2$

The hearing on the merits in the present docket, Docket 40295, was held on November 28, 2012. The record remained open for the filing of post-hearing briefs. The record closed on December 21, 2012.

III. PARTIES

In addition to ETI, the following entities were granted party status in this case: Texas Industrial Energy Consumers (TIEC); State of Texas agencies and institutions of higher education (State Agencies); Office of Public Utility Counsel (OPUC); Cities; and the staff of the Public Utility Commission (Staff).

The following is a list of the parties who participated in the hearing and their counsel:

| PARTIES | REPRESENTATIVES | | :-- | :-- | | ETI | Steven H. Neinast, Wajiha Rizvi, and George Hoyt | | Cities | Stephen Mack | | TIEC | Meghan Griffiths | | State Agencies | Susan Kelley | | OPC | Sarah Ferris | | Staff | Brennan Foley |

IV. DISCUSSION

A. Overview

In the ETI Application, ETI requested, among other things, approval of an increase in annual revenues of approximately $\backslash$ 104.8 $million,proposedtariffschedulesincludingnewriderstorecovercostsrelatedtopurchased-powercapacityandrenewable-energycreditrequirements,andfinalreconciliationofitsfuelcosts.Priortothehearing,theCommissioneffectivelydeniedET{I}^{\prime }srequestforapurchased-powercapacityriderbyremovingitasanissuetobeaddressedinthehearingontheETIApplication.IntheirPFD,theALJsrecommendedanoverallrateincreaseforETIof$ \ $28.3$ million, did not recommend approving the renewable-energy credit rider sought by ETI, and recommended approving ETI's request to reconcile fuel and purchased power costs during the Reconciliation Period. ^[3] Ultimately, the Commission largely followed the recommendations contained in the PFD, but reduced the overall rate increase to $\backslash$ 27.7$ million. ^[4]

In this docket, Michael P. Considine, a Manager in the Regulatory Accounting Department of Entergy Services, Inc. (ESI), ETI's service company affiliate, testified in support of the company's claim for recovery of rate case expenses. He explained that ETI is seeking authority to recover its

rate case expenses over a three-year period, while earning a return on the unamortized balance. ^[5] ETI seeks to recover $\backslash$ 8,752,545^{6}$ in rate case expenses associated with Docket 39896 that were incurred and paid as of September 30, 2012. ^[7] Of that total, $\backslash$ 7,635,236 $wasincurredbyETIand$ \ $1,117,309$ was incurred by Cities. Of the total amount, ETI classifies $\backslash$ 3,908,214 $as"external"ratecaseexpenses(i.e.,thoseexpensespaidtooutsideaccountingservices,outsidecounsel,andoutsideconsultants),and$ \ $4,844,362$ as "internal" rate case expenses (i.e., those expenses related to direct expenses, payroll, benefits, and taxes of ETI and Entergy Services, Inc. (ESI), an affiliated company of ETI). ^[8] Mr. Considine offered the opinion that all of ETI's internal rate case expenses were reasonable and necessary. ^[9] Another ETI witness, Stephen F. Morris, offered his opinion that all of ETI's external rate case expenses were reasonable and necessary. ^[10] Mr. Morris is an attorney and certified public accountant who was retained by ETI to review the company's external rate case expenses. ^[11] ETI also seeks authority to defer until its next rate case all rate case expenses incurred in Docket 39896 after September 30, 2012. ^[12]

B. Cities' Rate Case Expenses

Pursuant to PURA § 33.023, any municipality participating in a ratemaking proceeding may engage attorneys, consultants, and others to assist it, and the electric utility "shall" reimburse the municipality for its "reasonable cost" of participating in the ratemaking proceeding "to the extent the [Commission] determines is reasonable."

In this case, Cities seek reimbursement for rate case expenses totaling $\backslash$ 1,201,568.61 $.Citiesidentifythisamountasthe"totalactualandestimatedratecaseexpenses"incurredbyCitiesinfourforums:(1)ET{I}^{\prime }sbaseratecasesbeforethemunicipalities;(2)participationinDocket39896;(3)participationinanyappealsofDocket39896;and(4)participationinthepresentcase,Docket$ 40295 .{ }^{13} $Ofthe$ \ $1,201,568.61$ total, $\backslash$ 1,125,768.61 $representsactualexpensesincurredbyCitiesthroughAugust31,2012,while$ \ $75,800$ represents Cities' estimated expenses through completion of Dockets 39896 and 40295, and any appeal. ^[14] Cities offered the expert testimony of Amalija "Amy" Hodgins, a former ALJ, who opined that these expenses were reasonable and should be reimbursed. ^[15]

No party challenged the reasonableness of Cities' expenditures through August 31, 2012 (i.e., $\backslash$ 1,125,768.61$ ), and the ALJ can find no reason to do so either.

Staff challenges, however, Cities' attempt to recover their estimated expenses after that date (i.e., $\backslash$ 75,800 $).Citiesseektobereimbursedfortheseestimatedexpensesonly"ifandwhentheyoccur,"uptothemaximumof$ \ $75,800.{}^{16}\mathrm{M}\mathrm{s}$ . Hodgins offered her opinion that the amount of the estimated expenses is reasonable. ^[17] In reliance upon Commission precedent from 2005, Ms. Hodgins argued that estimated rate case expenses are reimbursable. Ms. Hodgins testified as follows:

Projected rate case expenses can be, and routinely have been, found reasonable and reimbursable by this Commission. The fact that a municipality's rate case expenses have not all been incurred, as of the date of the determination of the reasonableness of rate case expenses, does not render them unreasonable. Expenses need only be reasonable and incurred to be recoverable.

The future activities and corresponding costs, that are the subject of estimation, are necessary to complete a proceeding before the Commission. The Commission in CenterPoint's CTC case found estimated costs to complete a case were recoverable once the estimated expenses were incurred and known and measurable. . . . Accordingly, it is reasonable for the Commission, in this proceeding, to consider and allow the Cities to recover the estimated costs to complete this proceeding, including possible judicial appeals, if and when those expenses are incurred. ^[18]

Staff argues, based upon Commission precedent, that Cities are not entitled to reimbursement for estimated future rate case expenses. ^[19] Staff does not challenge the reasonableness of the amount of estimated expenses, nor does any other party. Rather, Staff asserts that the Commission precedent relied upon by Ms. Hodgins has been superseded by more recent precedent. Specifically, in 2010, the Commission decided a case in which it disallowed estimated rate case expenses. In Docket 37772, the Commission disallowed recovery of estimated expenses, holding that "approving estimated rate-case expenses is not in the public interest," but allowed the cities involved in that case to seek "recovery of actual rate-case expenses included in the estimates in [the utility's] next rate case. ^[20] Thus, Staff argues that Cities' attempt to obtain its estimated expenses should be disallowed.

Staff further argues that Cities should not be entitled to recover the expenses associated with the preparation of the portion of Ms. Hodgins' testimony in which she advocates in support of the recovery of Cities' estimated expenses. By Staff's calculation, this reduction amounts to $\backslash$ 1,208.42$ (representing Cities' actual costs for Ms. Hodgins' testimony related to the recovery of estimated expenses). ^[21] No other party joins Staff in its opposition to Cities' estimated expenses.

The ALJ recommends that Cities' request with regard to its estimated expenses be granted. Pursuant to Section 33.023 of PURA, Cities are entitled to reimbursement for their expenses

reasonably incurred in this case. As noted above, no party challenged the reasonableness of Cities' estimation that its expenses after August 2012 would total $\backslash$ 75,800$. The ALJ concludes that the estimate is reasonable. ^[22] Most importantly, the ALJ notes that Cities are not actually seeking reimbursement of estimated rate case expenses. Rather, Cities asks for: (1) approval now of the reasonableness of its estimated expenses; but (2) reimbursement of those expenses only after they are incurred, and only up to the estimated amount of $\backslash$ 75,800$. Cities argue that, from a policy standpoint, it is more economical and efficient for Cities to request reimbursement of reasonable estimated rate case expenses to the extent they are incurred in this case, rather than requiring Cities to wait and ask for reimbursement of those expenses when ETI files a new rate case at some point in the future, a contingency which might not occur for many years. The ALJ agrees. The ALJ further believes that it would be unfair if Cities were obligated to wait until ETI files a new rate case in order to recover its estimated expenses from the present case. Any such arrangement would delay, potentially for years, Cities' recovery of its actual expenses in the present rate case, a result which seems contrary to the clear intent expressed in PURA § 33.023 that municipalities are entitled to reimbursement for their reasonable rate cases expenses. Moreover, such an arrangement would obligate Cities to participate in a future ETI rate case that they might otherwise have no interest in becoming a party to.

For these reasons, the ALJ recommends: (1) that Cities' rate case expenses be found to be reasonable in the amount of $\backslash$ 1,201,568.61 $(consistingof$ \ $1,125,768.61$ in actual expenses incurred by Cities through August 31, 2012, and $\backslash$ 75,800$ in estimated expenses to be incurred by Cities after August 31, 2012 through completion of Dockets 39896 and 40295, and any appeal); (2) that ETI be ordered to reimburse Cities for $\backslash$ 1,125,768.61$ in actual expenses incurred by Cities through August 31, 2012; and

(3) that ETI be ordered to reimburse Cities for actual expenses incurred by Cities after August 31, 2012, through completion of Dockets 39896 and 40295 and any appeal up to a maximum possible amount of $\backslash$ 75,800$.

C. ETI's Rate Case Expenses

Pursuant to PURA Section 36.061(b), the Commission "may" allow a utility to recover its "reasonable costs of participating in a [ratemaking proceeding] not to exceed that amount approved" by the Commission.

ETI seeks recovery of $\backslash$ 8,752,545 $inratecaseexpensesassociatedwithDocket39896thatwereincurredandpaidasofSeptember30,2012.However,thattotalincludesonlythe$ \ $1,125,768.61$ in expenses incurred by Cities through August 31, 2012, but does not also include the $\backslash$ 75,800 $inexpensesestimatedforCitiesasdiscussedabove.BecausetheALJisrecommendingthatCitie{s}^{\prime }estimatedexpensesbeapprovedasoutlinedabove,theALJdeemsET{I}^{\prime }soverallrequesttohavebeenincreasedby$ \ $75,800$ to a total amount of $\backslash$ 8,828,345$.

The parties other than ETI challenged various components of ETI's rate case expenses. Those challenges are discussed as follows.

1. Challenges to Specific ETI Rate Case Expenses That are Relatively Quantifiable

a. Costs Associated with Gerald Tucker, ETI's Consulting Expert

In Docket 39896, ETI retained Gerald Tucker as a consulting expert to assist in the preparation of the utility's case dealing with affiliate transactions. Mr. Tucker is an accountant who has experience regarding affiliate costs in Commission rate cases and who has commonly assisted ETI in its rate cases. ^[23]

State Agencies contend that Mr. Tucker's fees should be disallowed. No party other than State Agencies challenged Mr. Tucker's expenses. State Agencies complain that Mr. Tucker: (1) did not testify; (2) provided services that were described by ETI in only "the most general terms;" and (3) provided services (such as reviewing witness testimony, reviewing discovery responses, benchmarking, and assisting in preparing witnesses for deposition) that were duplicative of services provided by ETI's legal counsel or other consultants. Accordingly, State Agencies argue that the $\backslash$ 116,119$ representing Mr. Tucker's fees should be excluded from rate case expenses. ^[24]

ETI responds by contending that, over the last 20 years or so, the Commission has, at times, disallowed large percentages of utility companies' affiliate expenses, based upon the fact that ALJs and the Commissioners have had difficulty understanding the complex information supplied by utilities concerning affiliate transactions. In light of that history, ETI contends that it reasonably relied upon the expertise and accounting experience of Mr. Tucker to assist it in preparing and presenting information about the company's affiliate transactions in order to assure that it was understandable. According to ETI, Mr. Tucker has been involved in all rate cases of ETI and its predecessor since in 1997. ETI contends that Mr. Tucker's participation in Docket 39896 enabled the company to present clearer and more accurate information about its affiliate transactions. Moreover, ETI disputes that Mr. Tucker's work was duplicative of the work performed by the company's attorneys, pointing out that Mr. Tucker provided expertise from the accounting perspective, rather than from the legal perspective. ^[25]

The ALJ recommends that Mr. Tucker's fees be included in the rate case expenses. State Agencies are essentially arguing that it was solely the job of ETI's attorneys and its testifying experts to prepare the case regarding affiliate transactions and, therefore, any work performed by Mr. Tucker with regard to affiliate transactions was purely duplicative. The ALJ disagrees. As pointed out by ETI, the notion that multiple people with varied expertise cannot provide valuable input on a complex issue like affiliate transactions is overly simplistic. ETI demonstrated that Mr. Tucker

provided real expertise that benefited the company in the presentation of its case. In other words, ETI proved the reasonableness of Mr. Tucker's expenses.

b. Costs Associated with "Lessons Learned"

In Docket 39896, ETI included several charges from its law firm, Duggins, Wren, Mann &; Romero (Duggins Wren), for "lessons learned," as shown in a July 26, 2011 invoice from the law firm. The charges total $\backslash$ 5,743.50 .{ }^{26}$ According to ETI, the charges relate to a memo provided to ETI by the firm which contained a "detailed analysis of developments in ETI's last rate case as well as developments in four recent pertinent cases at the PUCT that had taken place since the last ETI rate case. ^[27] The memo identified procedural and substantive issues for ETI to consider while preparing its rate case in Docket $39896.{}^{28}$

State Agencies contend that any "lessons learned" should have already been learned in the prior rate case and, therefore, any "refreshing [of] the learning curve . . . should be a shareholder, not ratepayer, expense. Bringing one's attorneys 'up to speed' for the third rate case filed in five years ought to be regarded as the legal equivalent of a 'luxury item. ^[29] No party other than State Agencies challenged the "lessons learned" expenses.

ETI responds by contending that State Agencies are essentially seeking to punish the company for its efforts to learn from the past. ETI also contends that State Agencies' argument would have the perverse effect of increasing, rather than decreasing rate case expenses. According to ETI:

Incurring these costs to analyze lessons learned from litigating prior rate cases and important aspects of non-ETI Commission rate cases, if anything, reduces overall rate case expenses by supporting a more efficient case presentation and avoiding prior issues that lead to contention among the parties. ^[30]

The ALJ agrees and recommends that the "lessons learned" expenses be included in the rate case expenses. ETI demonstrated that the expenses were reasonable because they benefited the company in the presentation of its case.

c. ESI Depreciation Costs

ETI identified, as part of its "internal" rate case expenses, \$207,683 in "Depreciation &; Amort" expenses. ^[31] As explained by ETI witness Considine, the expenses are for the depreciation of assets (apparently office equipment) used by ESI employees who participated in the rate case. ^[32] Mr. Considine further testified that the costs were a reasonable and necessary part of ESI providing services for the rate case. ^[33]

State Agencies contend that recovery of such depreciation expenses should be denied because: (1) such a recovery is unprecedented; (2) ETI has failed to prove that the expenses were reasonable and necessary; and (3) the expenses were not "incurred" for the rate case. As to the last point, State Agencies explains: "ESI's depreciable property exists, and is presumably depreciated, whether or not proceedings in Texas take place. As such, this 'cost' was not necessary for ETI's participation in the rate case and should be disallowed. ^[334] No party other than State Agencies challenged the depreciation expenses.

ETI responds by explaining that the costs at issue are "a loader to ESI labor costs covering depreciation on office expenses and capital." Notably, however, ETI also concedes that such costs would "typically [be] embedded in a vendor's labor costs billed to the Company., ^[35]

The ALJ recommends that the depreciation expenses be disallowed. ETI has not cited to any precedent which would justify the recovery of these apparently unusual rate case expenses. Moreover, ETI has failed to prove the reasonableness of the expenses under the more stringent standards that are applicable to affiliate expenses. As explained in Railroad Comm'n v. Rio Grande Valley Gas Company, unlike arms-length transactions, affiliate transactions "are clearly tainted with the possibility of self-dealing. ^[36] The Commission and the courts have consistently placed a greater burden of proof upon a utility company to prove the reasonableness of transactions with its affiliated companies because of the potential for self-dealing.

In this case, ETI is seeking reimbursement of $\backslash$ 2.9 $millionforpaymentsitmadetoitsaffiliate,ESI,forworkdonebyESIemployeesrelevanttoDocket39896,plus\backslash$ 207,683 for depreciation of the assets used by the ESI employees in their work. ^[37] This is in stark contrast to its arms-length dealings with outside consultants. For example, ETI is seeking reimbursement for $\backslash$ 2.4$ million in expenses from Duggins Wren, but it is not also seeking to recover depreciation expenses for Duggins Wren's equipment. If the work done by ESI employees had, instead, been done by outside consultants, it is very doubtful that the outside consultants would also have expected an ETI payment for the depreciation of their equipment. Thus, the very nature of ETI's depreciation request calls its validity into question. Simply put, ETI has failed to establish that it is entitled to recover a depreciation expense related to an affiliate transaction because it would not similarly recover such an expense in an arms-length transaction with an unaffiliated company.

d. Miscellaneous Internal Rate Case Expenses

Under the heading of "Internal Rate Case Expenses (Non-Payroll)," ETI seeks recovery of a number of categories of expenses. State Agencies challenge the following four categories:

• "business meals/entertainment" in the amount of \$3,852;
• "other employee expenses" in the amount of $\backslash$ 3,423$;
• "employee mtgs/functions" in the amount of $\backslash$ 7,762$; and
• "utility bills" in the amount of $\backslash$ 2,518 .{ }^{38}$

According to State Agencies, the justification for these charges has not been explained, nor are they reasonable and necessary. No other party challenged these expenses.

ETI responds by explaining, in great detail, where the supporting documentation can be found, within the company's exhibits, to justify each of the expenses. ^[39] Without repeating that discussion here, the ALJ is convinced that the evidence in the record supports the conclusion that the expenses are reasonable and should be recovered by ETI.

e. Costs Associated with the Calpine-Carville PPA

In a "Recommendation" filed prior to the hearing in this matter, OPUC argued that the Commission should disallow the recovery of any rate case expenses associated with the regulatory approval of the Calpine-Carville Purchased Power Agreement (the Calpine-Carville PPA). In Docket 39896, ETI sought, and obtained, regulatory approval of the Calpine-Carville PPA. The affiliate expenses related to the contract were assigned to Project F3PPWET308. The Project F3PPWET308 costs were approved for recovery in Docket $39896.{}^{40}$ As a result, OPUC

contends that ETI has already recovered its expenses associated with the Calpine-Carville PPA and, if it were allowed to recovery those expenses again, it would be receiving a double recovery. ^[41] OPUC did not identify a specific dollar amount that it believes should be disallowed. Moreover, OPUC did not discuss this issue in any of its post-hearing briefing. In their post-hearing briefing, State Agencies "concurred" with OPUC's recommendation, but provided no discussion of the issue. ^[42]

ETI did discuss this issue in its post-hearing briefing. The company points out, correctly, that the Commission has already specifically rejected OPUC's double recovery argument. In Docket 39896, OPUC argued that the costs ETI sought related to the Calpine-Carville PPA should have been denied in that docket because they were, among other things, rate case expenses. The Commission specifically disagreed and allowed recovery of the costs in that docket. ^[43] In other words, because the Commission has already concluded that ETI did not recover any rate case expenses associated with the Calpine-Carville PPA in Docket 39896, the company will not be receiving a double recovery if it recovers such expenses in this docket.

Further, as explained by ETI witness Considine, costs were charged to Project F3PPWET308 (the internal project code for the Calpine-Carville PPA development costs) as the contract was being developed. Those costs were recovered in Docket 39896. On the other hand, costs were charged to Project F5PPETX011 (the internal project code for the rate case in Docket 39896) as testimony or other hearing-related work was performed for Docket 39896. According to ETI, it is only the latter costs, associated with Project F5PPETX011, that are being sought here. As a result, no double recovery will occur. ^[44] The ALJ concludes that ETI has the better argument on this issue, and

recommends that ETI be allowed to recover its rate case expenses associated with the Calpine-Carville PPA.

f. Specific Items That State Agencies Contend Cast Doubt on ETI's Overall Scrutiny of Its Expenses

State Agencies performed what they described as a number of "spot check" reviews of ETI's costs and identified several errors or items that they contend should be disallowed. Moreover, State Agencies contend that it is not only these specific items which should be disallowed. Rather, they argue that the flaws they have identified should cast doubt on the overall adequacy of the internal review process utilized by ETI in quantifying its rate case expenses. According to State Agencies, "[i]dentification of these questionable costs underscores the need for conservative, rather than liberal, standards for allowing rate case expenses. ^[345] Similarly, State Agencies argue that these items demonstrate ETI's "lack of diligence in exercising basic economic restraint." ^[46]

Staff agrees that State Agencies' examination of these issues "call[s] into question the thoroughness of ETI's review of its rate case expenses. ^[347] Staff further points out that, because the testimony of ETI witness Considine (who was the company's prime witness supporting the reasonableness of its internal rate case expenses) contained "mistakes that he was engaged to identify," his testimony "is of limited value." ^[48] In its Reply Brief, Staff reiterates: "Staff shares the concerns raised by State Agencies regarding the adequacy of ETI's review of its rate case expenses. ^[49] Similarly, OPUC agrees that State Agencies' examples illustrate that, as to rate case expenses, ETI did not act as a prudent gatekeeper. ^[50]

(1) External Legal Fees

ETI seeks to recover roughly $\backslash$ 2.4$ million in legal fees paid to the Duggins Wren law firm. ^[51] State Agencies argue that this amount should be reduced. ETI witness Stephen Morris was hired to review ETI's external legal expenses and testify about the reasonableness of those expenses. ^[52] State Agencies question the objectivity, quality, and extent of Mr. Morris' review. For example, State Agencies point out that, rather than being retained by ETI, he was retained by Duggins Wren, the firm whose fees he was to review. ^[53] Staff agrees that this arrangement "likely undermined Mr. Morris' objectivity."54

State Agencies also contend that, based upon his invoices, Mr. Morris spent only a "minimal" amount of time reviewing Duggins Wren's bills. ^[55] Yet, by State Agencies' own reckoning, Mr. Morris and his associate spent roughly 21 hours reviewing Duggins Wren bills. ^[56] Mr. Morris testified as to the reasonableness of the hourly rates charged by Duggins Wren. State Agencies argue, however, that Mr. Morris' focus was too narrow and he should have, instead, been critical of the fact that too many Duggins Wren attorneys, twelve, were involved in the case. ^[57] State Agencies are also critical of the fact that Mr. Morris apparently did not scrutinize Duggins Wren's bills for duplicative legal work. For example, State Agencies point out that on April 25, 2012, a day from the hearing in Docket 39896, five Duggins Wren attorneys billed a total of 26.3 hours for a hearing day that lasted less than seven hours and in which in-house ETI lawyers defended many of the witnesses. On the next day, April 26, six Duggins Wren attorneys billed a total of 24.4 hours for a hearing day that lasted less than eight hours and in which only three Duggins Wren attorneys participated. ^[58] State

Agencies contend that "a reduction is in order" for the Duggins Wren costs, but do not suggest what size the reduction should be.

ETI responds by defending the reasonableness of the Duggins Wren costs. For one thing, ETI points out that the $\backslash$ 2.4$ million in legal fees paid to Duggins Wren includes fees and expenses for five consultants billed through Duggins Wren without mark-up. ^[59] Additionally, ETI explains that the huge scope of the hearing necessitated substantial legal work. ETI presented 39 witnesses who discussed hundreds of categories of costs. ETI points out that while it used the services of 12 attorneys, they were opposed by 15 attorneys: four for Staff; three for TIEC; three for Cities; and one each for State Agencies, OPUC, U.S. Department of Energy, Kroger, and Wal-Mart. ^[60]

The ALJ is unswayed by State Agencies' arguments. Given the size and complexity of Docket 39896, the legal costs involved do not appear to be inordinate. Mr. Morris testified, credibly, that the fees and expenses charged by Duggins Wren were reasonable and necessary. The ALJ does not recommend any reduction of the fees in response to State Agencies' arguments.

(2) Meals and Snacks

State Agencies identified 19 entries in Duggins Wren invoices whereby the firm charged ETI for meals or snacks. According to State Agencies, most of these purchases occurred during business hours and involved only law firm personnel. ETI personnel were only occasionally involved in these purchases. Almost all of the charges were for meals or snacks delivered to Duggins Wren's offices. The purchases total $\backslash$ 2,723.54 .{ }^{61}$ State Agencies contend that these costs were not necessary for participation in Docket 39896 and should be disallowed.

Moreover, State Agencies point out that Duggins Wren is applying a different standard to itself than it applies to its own contractors. Pursuant to the contract by which Duggins Wren hired Mr. Morris, meals while he or his staff are located at his office are not reimbursable. ^[62] Thus, State Agencies conclude that Duggins Wren should be held to the same standard when passing on rate case expenses for office meals, beverages, and snacks. ^[63]

ETI responds by pointing out that the charges were not done routinely, but only when necessary to enable personnel "to work over lunch and dinner to meet certain deadlines . . . and as an alternative to purchasing reimbursable meals at restaurants when out-of-town members of the rate case team worked in Austin. ^[64] ETI describes the expenses as a reasonable part of prosecuting a laborious rate case. The ALJ agrees and does not recommend any disallowance of these costs.

(3) Courier and Taxi Services

State Agencies identified 20 dates in Duggins Wren invoices whereby the firm charged ETI for courier, taxi, or Federal Express charges for delivery of documents that State Agencies argue could have been delivered electronically. The charges total $\backslash$ 1,004.52 .{ }^{65}$ State Agencies contend that these costs were not necessary for participation in Docket 39896 and should be disallowed. State Agencies again point out that Duggins Wren is applying a different standard to itself than it applies to its own contractors. The contract by which Duggins Wren hired Mr. Morris states that "advances in technology, specifically transmission of information and documentation by e-mail, scanning, . . . etc. have made routine . . . delivery of hard copy documents less critical and, in many

cases, unnecessary."66 Thus, State Agencies conclude that Duggins Wren should be held to the same standard when passing on rate case expenses for document delivery. ^[67]

ETI responds by explaining the context of many of the charges. For example, two of the three cab fares were for a paralegal to attend and transport voluminous documents to the hearing, and the third was to transport the same paralegal to the Commission for legal research. ^[68] As to the courier and FedEx charges, ETI points out that Commission rules require some types of documents to be physically delivered for filing, and that the use of couriers and FedEx is sometimes entirely appropriate. ETI argues that it was "completely reasonable" for ETI to have incurred roughly $\backslash$ 1,000$ in courier and FedEx charges over the course of a rate case of the size and scope of Docket 39896. The ALJ agrees and recommends no disallowance of these charges.

(4) Meals Over $\backslash$ 25$

ETI asserts that its intent was to exclude from its rate case expenses any meals above $\backslash$ 25$ per person. ^[69] State Agencies have, however, identified at least six meals above $\backslash$ 25$ that were erroneously included as a part of ETI's rate case expenses. ^[70] ETI admits that at least some of these charges were included in error. ^[71] ETI disputes, however, the notion that these errors should call into question the overall reliability of its rate case expenses.

The ALJ agrees with ETI. This was a large case with a large number of expenses. The relatively few errors with respect to meals uncovered by State Agencies do not lead the ALJ to doubt the overall accuracy of ETI's accounting. Nevertheless, by the ALJ's reckoning, the total amount

that should be disallowed for meals over $\backslash$ 25 $(i.e.,theamountbywhichthemealsexceeded$ \ $25/$ meal) is $\backslash$ 281.04$.

(5) Clothing and Laundry Service

State Agencies identified, as part of ETI's requested rate case expenses, a $\backslash$ 10.44 $invoicefromaDugginsWrenattorneyforthepurchaseofashirtandsocks"duetounexpectedextendedstay."72Similarly,OPUCcontestsa$ \ $40.33$ laundry charge incurred by the same attorney for the same reason. ^[73] ETI witness Considine generally agreed that clothing charges by attorneys working on the rate case should not be passed through to ratepayers as a rate case expense. ^[74]

ETI argues that the expenses were reasonable because they were brought about by an unplanned, but necessary, extension of the attorney's business trip. ^[75] Mr. Morris testified that such expenses can be considered reasonable. ^[76] Nevertheless, ETI has agreed to no longer request reimbursement for the $\backslash$ 10.44 $clothingcharge.Becauselaundryhastobedoneregardlessofwhereonefindsoneself,theALJrecommendsthatthe$ \ $40.33$ laundry charge likewise be disallowed.

(6) Airfare and Lodging

State Agencies identify several charges for airfare by ETI employees or consultants that were in the $\backslash$ 500 $to$ \ $650$ range. State Agencies fault ETI for not controlling costs by securing discount, or at least more economical, fares. ^[77] Similarly, State Agencies complain that, too often, ETI employees or consultants "went 'first class' on accommodations," incurring charges of more than $\backslash$ 200$ per night

and, on occasion, $\backslash$ 300 $pernight.StateAgenciesalsocomplainofinadequatedocumentationoflodgingcharges,pointingtoa$ \ $479.55$ lodging charge without any underlying receipts. ^[78] ETI makes no response to these complaints.

The ALJ acknowledges that these complaints raise a legitimate concern. It is human nature to be more carefree with "other people's money" than with one's own. The complaints raised by State Agencies suggest that ETI may have been more lax with its spending because it believed that airfare and lodging expenses would ultimately be borne by its ratepayers. Nevertheless, other than for the $\backslash$ 479.55 $lodgingcharge,StateAgencie{s}^{\prime }complaintsaretoovagueandunproventojustifyanyspecificdisallowancerecommendationsbytheALJ.Forexample,althoughitmightnotalwayscost$ \ $600$ to get from Point A to Point B, such a fare might be unavoidable under certain circumstances. Without evidence in the record demonstrating that ETI paid $\backslash$ 600 $foranairfarewhenacheaperfarewasavailable,theALJcannotconcludethatthefarewasunreasonable.Thesamelogicappliestothelodgingcomplaints.Accordingly,theALJrecommendsnolargedisallowancesrelatedtoairfareandlodgingcharges,butdoesrecommenddisallowingthe$ \ $479.55$ lodging charge that is unsupported by receipts.

2. Challenges to Specific ETI Rate Case Expenses That are Difficult to Quantify

a. Financially-Based Incentive Compensation

One of the hotly contested issues in Docket 39896 concerned ETI's request to recover, through its rates, incentive compensation paid to its employees that was tied to the company's financial goals (financially-based incentive compensation). In Docket 39896, all parties, including ETI, agreed that Commission precedent mandated that financially-based incentive compensation is not recoverable. Nevertheless, in its application, ETI asked the Commission to reconsider its precedents on this issue. ETI contended that the reason why cost recovery had been denied for financially-based incentive compensation in prior rates cases was that, in those prior cases, there was

a lack of evidence showing sufficient benefits to ratepayers. ETI asserted that it assembled evidence not previously considered by the Commission showing the benefits to ratepayers of using financial measures in incentive compensation programs.

All of the other parties in Docket 39896 opposed ETI's efforts to recover the costs of its financially-based incentive compensation, uniformly agreeing that the Commission has a wellestablished and straightforward policy that incentive compensation tied to financial goals is not recoverable. In the PFD in Docket 39896, the ALJs concluded that ETI should not be entitled to recover its financially-based incentive compensation costs:

Simply put, the ALJs conclude that ETI has failed to establish a sufficient justification for overturning the well-established Commission policy that financially based incentive compensation is not recoverable. ^[79]

The Commission agreed and ordered that \ $6,196,037plusassociatedFICAtaxes(representingET{I}^{\prime }sfinancially-basedincentivecompensationpayments)shouldberemovedfromET{I}^{\prime }sOperatingandMaintenance(O\&M)expenses,and$ \ $335,752.96$ (representing ETI's capitalized incentive compensation that was financially-based) should be excluded from ETI's rate base. ^[80]

In this docket, Staff, State Agencies, and OPUC contend that ETI should not be entitled to recover any rate case expenses it incurred in attempting to recover its financially-based incentive costs in Docket 39896. For example, Staff argues that, by challenging "overwhelming Commission precedent," ETI did not act reasonably when it incurred expenses litigating for recovery of its financially-based incentive costs. ^[81] Staff contends that the Commission has such an "unequivocal" history of denying recovery for financially-based incentive payments that "ETI should have known

that litigating a position opposed to [it] was not a reasonable use of resources."82 State Agencies point out that Docket 39896 was merely the latest of three recent cases in which ETI sought, but failed to obtain, authority to charge ratepayers for its financially-based incentive costs (the others being Dockets 34800 and 37744). ^[83]

ETI defends its decision to seek to recover financially-based incentive costs in Docket 39896 by contending that the issue of the compensability of such costs is undergoing "continuing clarification" at the Commission. ^[84] Moreover, ETI suggests that, in open meetings, "Commissioners" have expressed some concern with the Commission's precedents on this issue and suggested recovery might be allowed in a "properly organized and evidenced" case. ^[85] Finally, ETI points to a recent SOAH order in an on-going SWEPCO rate case in which the ALJs denied State Agencies' attempt to have stricken testimony proffered by SWEPCO regarding financially-based incentive compensation. ^[86]

The ALJ agrees with Staff, State Agencies, and OPUC. It was obvious throughout the hearing in Docket 39896 that ETI was taking an aggressive position and making a "long-shot" argument in seeking recovery for its financially-based incentive compensation. ^[87] In its briefing in the present case, ETI cites to a number of cases in which, over the years, other utilities have requested recovery of financially-based incentive compensation. These examples, however, hurt ETI's cause more than they help it because all of the requests were unanimously denied by the Commission. This hardly suggests that the issue is undergoing "continuing clarification." Likewise, ETI's suggestion that "Commissioners" have expressed some concern with the Commission precedent overstates and distorts the facts. The statements relied upon by ETI came from a single Commissioner,

Mr. Anderson, not multiple Commissioners. Moreover, in that statement, Commissioner Anderson only obliquely implied that he might prefer to allow recovery for financially-based incentive costs, but he agreed that Commission precedent mandates otherwise, and the Commission voted unanimously to disallow such costs in the case before them. Additionally, Commissioner Anderson has stated that, if the Commission were to ever discontinue "such a long and accepted precedent," it should do so through "rulemaking" rather than "do it in a particular case."88

Finally, ETI's reliance on the recent SOAH order in the SWEPCO case is similarly misplaced. In that order, the ALJs effectively held that SWEPCO was not legally precluded from seeking recovery for its financially-based incentive compensation. It is one thing to acknowledge that a utility has a legal right to pursue a long-shot theory. It is another thing entirely, however, to hold that the ratepayers must pay the costs of the utility's pursuit of that long-shot.

Simply put, the ALJ concludes that ETI did not act reasonably when it incurred expenses litigating for recovery of its financially-based incentive costs in the face of clear and consistent precedent to the contrary on the issue. As such, the ALJ recommends that ETI's expenses be cut by some amount to account for this issue. The problem then becomes how to quantify the size of the disallowance. A few of ETI's expenses relating to the pursuit of its financially-based incentive compensation are clear. ETI utilized the services of Dr. Jay Hartzell as an expert witness on this issue. In total, ETI paid Dr. Hartzell at least $\backslash$ 12,825 $inconsultingfees,plus$ \ $13,680$ in legal fees related to the preparation of his testimony. ^[89] This, however, does not capture ETI's entire cost of litigating the issue of financially-based incentive compensation. Substantial costs were incurred, for example, in discussing the issue at the hearing and in post-hearing briefing. These additional amounts are not in the record. In Section IV.C. 3 of this PFD, below, the ALJ discusses various possible approaches for reducing the amount of rate case expenses recovered by ETI to account for the financially-based incentive compensation issue.

b. Transmission Equalization (MSS-2) Expenses

Another of the hotly contested issues in Docket 39896 concerned ETI's request to recover, through its rates, roughly $\backslash$ 9$ million more for transmission equalization payments than it actually paid in the Test Year. ETI is one of several "Entergy Operating Companies" that shares usage of an Entergy transmission grid. Payments for use of the grid (the transmission equalization payments) are made among the Entergy Operating Companies based upon a highly complex formula set out in the "MSS-2" agreement.

In the Test Year at issue in Docket 39896, ETI made transmission equalization payments totaling roughly $\backslash$ 1.7 $million.Ratherthanseekingtorecoveronly$ \ $1.7$ million, however, ETI sought to recover roughly $\backslash$ 10.7 $million,whichitclaimedrepresenteditsanticipatedtransmissionequalizationpaymentsintheRateYear.ETIclaimedtheadditional$ \ $9$ million was based on the company's estimates of transmission construction projects that were expected to have been completed by or during the Rate Year.

All other parties in Docket 39896 opposed ETI's effort to recover more than its Test Year expenses. The ALJs concluded that ETI failed to meet its burden to prove that its proposed Rate Year MSS-2 costs were known and measurable. ^[90] The Commission agreed and ordered that only ETI's Test Year costs should be counted. ^[91] The Commission described ETI's projection of its Rate Year expenses as "uncertain and speculative."92

In this docket, Staff, OPUC, and State Agencies contend that ETI should not be entitled to recover any rate case expenses it incurred in attempting to recover the additional $\backslash$ 9$ million in

projected transmission equalization payments. ^[93] As explained by Staff: "It was clearly unreasonable for ETI to have sought recovery for [its projected Rate Year costs] due to the exceedingly speculative nature of those costs, and therefore a disallowance to its requested rate case expense amount should be imposed. ^[994] OPUC witness Nathan Benedict testified that, by seeking the additional $\backslash$ 9$ million, ETI was, in effect, challenging the precedent that post-Test Year adjustments must be known and measurable. ^[95]

ETI responds by first disputing the notion that it was "challenging precedent" by seeking the additional $\backslash$ 9$ million.

ETI did not incur rate case expenses in pursuit of a position contrary to the wellestablished 'known and measurable' standard for PTYAs [post Test Year adjustments]. Rather, the Commission disagreed that the evidence put forth by ETI met that standard. This is a very important distinction. Finding that evidence put forth by a utility did not meet an established standard does not equate to a finding that the utility unreasonably contested the applicability of such standard. ^[96]

ETI further points out that the evidence in the record supported its contention that its actual post-Test Year transmission equalization payments were on an upward trend. ^[97]

The ALJ recommends that ETI's rate case expenses associated with its pursuit of the additional $\backslash$ 9$ million for post-Test Year transmission equalization payments be disallowed. The ALJ acknowledges the distinction made by ETI: It sought not to challenge the "known and measurable" precedent, but merely failed to meet the standard. In this regard, ETI's position as to transmission equalization payments was perhaps less controversial than its position as to financially-based incentive compensation. Nevertheless, ETI took another "long-shot" position as to its transmission equalization payments. Its claim was based on future transmission construction projects that might

never be undertaken and that were found by the Commission to have been speculative. Accordingly, the ALJ concludes that ETI did not act reasonably when it litigated the issue, and recommends that ETI's expenses related to this issue not be passed on to the ratepayers.

Having concluded that these rate case expenses should not be paid by the ratepayers, the problem again becomes how to quantify the expenses. ETI did not structure its rate case expenses in such a manner as to make it possible to determine how much of the expenses were incurred in pursuing the additional $\backslash$ 9$ million in transmission equalization payments. ^[98] In Section IV.C. 3 of this PFD, below, the ALJ discusses various possible approaches for reducing the amount of rate case expenses recovered by ETI to account for the transmission equalization payments issue.

c. Purchased Power Capacity Rider

In Docket 39896, ETI initially requested a Purchased Power Capacity Rider (PPCR), instead of including purchased capacity costs in base rates. The Commission, however, rejected the PPCR request in a Supplemental Preliminary Order on the grounds that the Commission already had a then-pending rulemaking effort underway to determine the structure of such a rider for all generating utilities. ^[99]

In this docket, Staff, OPUC, and State Agencies argue that ETI should not be entitled to recover any rate case expenses it incurred in attempting to secure a PPCR because it was too speculative in light of the pending rulemaking effort. ^[100]

ETI responds by contending that the mere fact that there was a rulemaking effort underway with respect to PPCRs did not mean that ETI was somehow precluded from seeking a PPCR through its application. Moreover, ETI notes that, in briefing during Docket 39896, Staff, State Agencies,

and TIEC all took the position that there was no legal impediment to ETI's seeking a PPCR in the rate case. ^[101]

The ALJ agrees with ETI and does not recommend any disallowances in relation to the PPCR request. The fact that there was a pending proposed rule at the time ETI asked for the rider should not be viewed as precluding ETI's request. Indeed, the very uncertainty inherent in the rulemaking process suggested that the accepted practices with regard to purchased capacity costs were in a state of flux and, therefore, it was reasonable for ETI to pursue the rider.

3. Proportional Reduction

In addition to the above challenges to specific items of expense incurred by ETI, a number of parties raised more generic concerns about the company's rate case expenses. State Agencies expressed concern that, as a general matter, rate case expenses in cases before the Commission appear to be "getting out of hand." ^[102] Staff "firmly agrees" with this concern. ^[103] State Agencies worry that utilities have no incentive to minimize the number of rate case proceedings or the efficiency of rate case presentation because they assume their costs will simply be passed on to ratepayers. ^[104] State Agencies urge the Commission to allocate rate case expenses in such a way that incentivizes utilities to more productively and efficiently use their time in rate cases. ^[105] OPUC agrees that the standard for evaluating the amount of rate cases expenses to be reimbursed ought to be structured so as to give a utility pause before deciding to pursue overly aggressive or novel arguments. ^[106]

Along these same lines, Staff and OPUC expressed concern about the frequency of ETI rate cases over recent years. Docket 39896 was the third ETI rate case in four years. Each case resulted in a rate increase and an obligation for the ratepayers to pay ETI's rate case expenses. ^[107] Staff and OPUC also expressed concern about the overall size of the rate case expenses in relation to the outcome of the underlying rate case. Total rate case expenses ( $\backslash$ 8.8 $million)equalroughlyone-thirdofthetotalapprovedrateincrease($ \ $27.7$ million). ^[108] Staff, State Agencies, and OPUC all expressed the concern that ETI did not provide good stewardship in incurring rate case expenses. ^[109]

In order to address these concerns, the parties have suggested a number of methodologies for reducing the rate case expenses.

• The 50/50 approach. State Agencies advocate two approaches for reducing the level of recovery of rate case expenses. State Agencies' primary recommendation is that ratepayers be charged for only $50\%$ of total rate case expenses. State Agencies argue that this approach would recognize that shareholders, who reap benefits from a rate increase, ought to also share in the cost of obtaining that rate increase. ^[110]
• The Results-Obtained Approach. Alternatively, State Agencies advocate allowing ETI to recover only $26.4\%$ of its rate case expenses, which is the ratio between the rate increase obtained in Docket 39896 ( $\backslash$ 27.7 $million)andtheincreasesoughtbyETI($ \ $104.8$ million). In other words, because ETI obtained only $26.4\%$ of the rate increase it sought, State Agencies contend that ETI similarly ought to be reimbursed for only $26.4\%$ of its rate case expenses. ^[111] OPUC also advocates this approach. ^[112]
• The Issue-Specific Reduction Approach. Alternatively, OPUC and Staff advocate an approach whereby ETI's recovery of rate case expenses is reduced by the ratio between the amounts unsuccessfully sought by ETI for financially-based incentive payments and transmission equalization payments and the rate increase sought by ETI. ETI unsuccessfully sought financially-based incentive payments of $\backslash$ 6.5$

million, and transmission equalization payments of $\backslash$ 9 $million,foratotalof$ \ $15.5$ million. ETI sought a total rate increase of $\backslash$ 104.8 $million.Underthisapproach,$ \ $15.5$ million would be divided by $\backslash$ 104.8 $milliontoarriveatareductionfactorof$ 14.8 \% $.Thus,ET{I}^{\prime }sratecaseexpenseswouldbereducedby$ 14.8 \% .{ }^{113}$

Not surprisingly, ETI vigorously opposes all of these approaches.

The ALJ agrees with the general concerns raised by Staff, State Agencies, and OPUC, and believes that a substantial cut to ETI's rate case expenses is warranted. Before evaluating the merits of the various approaches, however, it is helpful to revisit the applicable law relative to rate case expenses.

As noted previously, pursuant to PURA Section 36.061(b), the Commission "may" allow a utility to recover its "reasonable costs of participating in a [ratemaking proceeding] not to exceed the amount approved" by the Commission. This verbiage indicates that the Commission can approve some amount that is less than the reasonable costs. Section 36.061 (b) vests the Commission with "broad discretion" to determine the amount of rate cases expenses that should be recovered, ^[114] and its determination can be set aside only if it acts without reference to guiding rules or principles. ^[115] There is precedent, albeit from a different agency, suggesting that it is within the agency's discretion to find overall rate case expenses to be unreasonable even if the underlying individual cost items are found to be reasonable. ^[116] Because Section 36.061 (b) states that rate case expenses "may" be recovered, OPUC contends (and the ALJ agrees) that the Commission is not required to grant

recovery of every reasonable expense and can take into account other considerations. As explained by OPUC, "[w]ithout this discretion, rate case expense proceedings would be rendered into mere accounting exercises. ^[117] A number of factors--such as the time and labor required; the nature of the case; the size of the interest at stake; and the benefits to the client--have been deemed relevant to determining the reasonableness of rate case expenses. ^[118] Moreover, the parties agree that Rule 1.04(b) of the Texas Disciplinary Rules of Professional Conduct also provides a number of factors that can be considered when determining reasonableness of rate case expenses. ^[119]

With these basic parameters in mind, the ALJ turns to evaluating the three approaches outlined above. The ALJ begins by rejecting the 50/50 Approach. ETI and Staff argue that the approach is contrary to Commission precedent. ^[120] The ALJ agrees. Given that there are clear Commission precedents rejecting this approach, the ALJ recommends that it be rejected here.

The ALJ also recommends rejection of the Results-Obtained Approach, while acknowledging that it has some strong arguments in its favor. ETI argues that the approach is counter to Commission precedent. ^[121] However, according to Staff, the approach has been neither adopted nor rejected by the Commission. In other words, it is an issue of first impression. ^[122] OPUC and State Agencies support the use of this approach. It is unclear whether Staff explicitly supports this approach. However, Staff describes it as an "appealing" methodology "because it would provide a utility an incentive not to overreach in its rate increase request."123 Moreover, Staff argues that the methodology is akin to the performance-based standards regarding generation plant performance that

the Commission has approved in the past. For these reasons, Staff concludes that the Commission has the legal authority to apply the Results-Obtained Approach in this case. ^[124]

ETI complains, however, that it is a punitive and hindsight-driven approach to cost recovery, rather than basing cost recovery on whether a utility acted reasonably at the time it incurred such costs. ^[125] This is the primary reason why the ALJ recommends against the Results-Obtained Approach. Because it is an issue of first impression, ETI had no prior notice that its rate case expenses might be subject to such a standard. The ALJ simply believes it would be unacceptably draconian to slash ETI's rate case expenses by $73.6\%$ based upon a standard that ETI could not have known, beforehand, would be applied to it.

The ALJ recommends adoption of the Issue-Specific Reduction Approach in this case. Staff, OPUC, and State Agencies all support its use. ETI argues that use of the approach is unprecedented. ^[126] Staff counters (and the ALJ agrees) that, far from being unprecedented, the approach is entirely consistent with Commission precedent because the disallowance is a result of specific, unreasonable actions by ETI. ^[127]

ETI argues that the Issue-Specific Reduction Approach is improper because there is no evidence that the $14.8\%$ reduction equals the amount of expenses it incurred pursuing financiallybased incentive costs and transmission equalization payments. ^[128] Staff counters (and the ALJ agrees) that ETI bore the burden of proving its reasonable expenses, and that burden necessarily requires that it separate out any unreasonable expenses. Having failed to do so with respect to financially-based

incentives and transmission equalization payments, it is reasonable for the Commission to use the Issue-Specific Reduction Approach as a proxy for calculating those expenses. ^[129]

There is also a point of disagreement as to the proper application of the Issue-Specific Reduction Approach. ETI argues that the proponents of the approach are using the wrong denominator in its formulation. Rather than dividing $\backslash$ 15.5 $millionby$ \ $104.8$ million (the size of the rate increase sought by ETI), ETI asserts that $\backslash$ 15.5 $millionoughttobedividedby$ \ $2.1$ billion (the size of all of ETI's costs). ETI explains that, in Docket 39896, it was obligated to prove all of its costs, not just the amount of the increase it sought. Under such a formula, the reduction factor would be less than $1\%.{}^{130}$ As pointed out by Staff and OPUC, ^[131] ETI's reasoning is flawed. The entire purpose of this proceeding was for ETI to obtain a rate increase, not to preserve its preexisting rates. Indeed, the petition is styled "Application . . . for Authority to Change Rates . . . ."132 There would have been no need for a rate case if ETI merely sought approval of the same level of revenue approved in the last rate case. Because a revenue increase was the driving factor for this case, the amount of revenue increase requested is the appropriate benchmark to compare against disallowances.

Having concluded that the Issue-Specific Reduction Approach should be utilized in this case, the ALJ now discusses the application of the formula to the rate case expenses. As explained in the second paragraph of Section IV.C of this PFD, in order to take into account the $\backslash$ 75,800 $ofestimatedexpensesforCities,theALJrecommendsincreasingET{I}^{\prime }soverallratecaseexpensesrequestto$ \ $8,828,345$ . From that amount, the ALJ subtracts the specific disallowances discussed in Section IV.C. 1 of this PFD:

• $\backslash$ 207,683$ for depreciation;
• $\backslash$ 281 $mealsover$ \ $25$ ;
• $\backslash$ 10$ for clothing;
• $\backslash$ 40$ for laundry service; and
• $\backslash$ 480$ lodging.

This leaves a balance of $\backslash$ 8,619,851 $.Whenthatbalanceisreducedby$ 14.8 \% $,theremainderis$ \ $7,344,113$ . It is this amount of rate case expenses that the ALJ recommends ETI be allowed to recover.

D. Recovery Method

1. Rate Case Expense Allocation and the Recovery Mechanism

ETI proposes to allocate the approved rate case expenses among its retail classes using a revenue allocator based upon ETI's pro forma Test Year revenues. Staff proposes, instead, that the allocation be based on each retail rate classes's revenue requirement as approved by the Commission. Staff argues that its approach would be more consistent with recent Commission precedent. ^[133] Staff's specific recommendation is as follows: [T]hat ETI's Schedule RCE-2 rates be set in the compliance phase of this proceeding by multiplying the approved total amount by Staff's recommended class allocator and dividing the resulting class share both by ETI's proposed three-year amortization period and also by ETI's proposed class billing determinants. ^[134]

Staff further recommends that ETI be required to track its collections on Rider RCE and terminate billing in the month in which the approved amount has been billed. ^[135] ETI does not object to Staff's approach to allocation, so long as the Commission's final order includes standard language allowing the company to seek recovery of any additional rate case expenses incurred after September 30, 2012, in its subsequent rate case. ^[136] Staff does not object to this request by ETI. ^[137] No other party objects to this approach, and the ALJ can find no reason to do so either.

2. ETI's Request to Earn a Return on the Unpaid Balance of Rate Case Expenses

ETI asks that it be allowed to recover its rate case expenses over three years, and that it be allowed to recover a return on the unpaid balance of the expenses during that time. ^[138] No party objects to the three-year duration, but Staff opposes ETI's request to earn interest on its rate case expenses, contending that the Commission has consistently refused the recovery of a return on unamortized rate case expenses. ^[139] State Agencies agree with Staff. ^[140]

ETI responds by arguing that it is simply seeking to recover a necessary component of a cost that is amortized over a period of time. According to ETI, the request for a return on the unpaid balance merely represents the time value of money and the cost of the company's lost opportunity to use the funds elsewhere. ^[141] ETI cites to several Commission precedents in which a utility was allowed to recover interest on various cost-of-service items, including Docket 39896, in which ETI was allowed to earn a return on the unamortized balance of its Hurricane Rita Regulatory Asset over

five years. ^[142] ETI does not, however, cite to any Commission precedent specifically authorizing a return on unpaid rate case expenses.

Staff has the better argument. In Docket 30706, CenterPoint Energy Houston Electric (CenterPoint) sought to recover its rate case expenses over three years with a return on the unpaid balance. The Commission rejected CenterPoint's request for a return, explicitly noting its "practice of not permitting utilities to receive interest on unpaid rate-case expenses. ^[143] Consistent with this clear Commission precedent, the ALJ recommends that ETI's request to recover a return on the unpaid balance of its rate case expenses during the three-year payoff period be denied.

V. CONCLUSION

The ALJ recommends that the Commission implement the findings of the ALJ set forth in the discussion above by adopting the following proposed findings of fact and conclusions of law in the Commission's final order.

VI. PROPOSED FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDERING PARAGRAPHS

A. Findings of Fact

1. Entergy Texas, Inc. (ETI or the Company) is an investor-owned electric utility with a retail service area located in southeastern Texas.
2. On November 28, 2011, ETI filed an application (the ETI Application) requesting, among other things, approval of a proposed increase in annual base rate revenues of approximately $\backslash$ 111.8$ million over adjusted test year revenues, and a new rider for recovery of costs related to purchased power capacity. [^0] [^0]: ^[142] Docket 39896, Proposal for Decision at 17-23; see also, Petition of Texas-New Mexico Power Company for Approval of Regulatory Asset Treatment of Expenses Related to System Benefit Fund Payments, Docket No. 26942, Order at 4 (Findings of Fact 26-29)(Aug. 22, 2003). ^[143] Application of CenterPoint Energy Houston Electric, LLC for a Competition Transition Charge, Docket No. 30706, Order at 32 (Jul. 14, 2005).

1. On November 29, 2011, the Public Utility Commission of Texas (Commission or PUC) referred the ETI Application to the State Office of Administrative Hearings (SOAH) for a hearing and the matter was assigned docket number 39896 (Docket 39896).
2. On April 4, 2012, in Docket 39896, the ALJs issued SOAH Order No. 13 severing rate case expense issues into a new docket, the case at issue here, Application of Entergy Texas, Inc. for Rate Case Expenses Severed from PUC Docket No. 39896, Docket No. 40295.
3. The hearing on the merits in Docket 39896 was held in April-May 2012.
4. The Proposal for Decision (PFD) in Docket 39896 was issued July 6, 2012.
5. The Commission issued its final order in Docket 39896 on November 2, 2012.
6. The hearing on the merits in the present docket, Docket 40295, was held on November 28, 2012. The record closed on December 21, 2012, following the filing of post-hearing briefs.
7. The following parties were granted intervenor status in this docket: Office of Public Utility Counsel (OPUC); the cities of Anahuac, Beaumont, Bridge City, Cleveland, Conroe, Dayton, Groves, Houston, Huntsville, Montgomery, Navasota, Nederland, Oak Ridge North, Orange, Pine Forest, Rose City, Pinehurst, Port Arthur, Port Neches, Shenandoah, Silsbee, Sour Lake, Splendora, Vidor, and West Orange (Cities); State Agencies (State Agencies); and Texas Industrial Energy Consumers (TIEC). The staff (Staff) of the Commission was also a participant in this docket.
8. In Docket 39896, ETI adjusted its request for a proposed increase in annual base rate revenues to approximately $\backslash$ 104.8$ million over adjusted Test Year revenues.
9. In the PFD in Docket 39896, the ALJs recommended an overall rate increase of $\backslash$ 28.3$ million.
10. In its final order in Docket 39896, the Commission largely followed the recommendations contained in the PFD, but reduced ETI's overall rate increase to $\backslash$ 27.7$ million.
11. In this docket, ETI seeks to recover $\backslash$ 8.8$ million in rate case expenses associated with Docket 39896 .
12. Of that total, $\backslash$ 7.6 $millionwasincurredbyETIand$ \ $1.2$ million was incurred by Cities.
13. Cities proved that, through August 31, 2012, they reasonably incurred rate case expenses of $\backslash$ 1,125,768.61$ in Docket 39896 and this docket.
14. Cities reasonably estimated that their total rate case expenses in Docket 39896 and this docket after August 31, 2012 will total $\backslash$ 75,800$.

1. The amount of rate case expenses sought by ETI ( $\backslash$ 8.8 $million)ishigh,bothinabsoluteterms,andinrelationtotherateincreaseultimatelyobtainedbyETIinDocket39896($ \ $27.7$ million).
2. Rate case expenses for ETI in the amount of $\backslash$ 7,344,113$ are reasonable and necessary and should be allowed as a cost or expense by the Company. This amount is calculated by reducing the requested amount by the amounts listed and for the reasons stated below: a. $\backslash$ 207,683$ in depreciation of office equipment owned by Entergy Services, Inc. (ESI) (an affiliated company of ETI) and used by ESI employees for their work in Docket 39896 is not reasonable and is properly disallowed. b. $\backslash$ 281 $formealsover$ \ $25$ was erroneously sought by ETI, is not reasonable, and is properly disallowed. c. $\backslash$ 10$ for clothing purchased by an attorney for ETI is not reasonable and is properly disallowed. d. $\backslash$ 40$ for laundry charges by an attorney for ETI is not reasonable and is properly disallowed. e. $\backslash$ 480$ for a lodging charge unsupported by receipts is not reasonable and is properly disallowed. f. $\backslash$ 1,275,738$ attributable to unreasonable and overly aggressive arguments pursued by ETI in Docket 39896 related to financially-based incentive compensation and transmission equalization payments is properly disallowed.

B. Conclusions of Law

1. ETI is a "public utility" as that term is defined in the Public Utility Regulatory Act (PURA) $\S 11.004(1)$ and an "electric utility" as that term is defined in PURA § 31.002(6).
2. The Commission exercises regulatory authority over ETI and jurisdiction over the subject matter of this application pursuant to PURA $\S \S 32.001,32.101,33.002,33.051$ , and $36.101-111$ .
3. SOAH has jurisdiction over matters related to the conduct of the hearing and the preparation of a proposal for decision in this docket, pursuant to PURA § 14.053 and Tex. Gov't Code $\S 2003.049$ .
4. This docket was processed in accordance with the requirements of PURA and the Texas Administrative Procedure Act, Tex. Gov't Code Chapter 2001.

1. Pursuant to PURA § 33.051, the Commission has jurisdiction over an appeal from a municipality's rate proceeding.
2. Cities bore the burden to prove that the rate case expenses they incurred were reasonable. PURA § 33.023 .
3. Cities are entitled to reimbursement by ETI for: a. rate case expenses of $\backslash$ 1,125,768.61$ incurred in Docket 39896 and this docket through August 31, 2012; and b. actual expenses incurred by Cities in Docket 39896 and this docket after August 31, 2012, including any appeals, up to a maximum possible amount of $\backslash$ 75,800$.
4. ETI bore the burden of proving that the rate case expenses it incurred in Docket 39896 were reasonable. PURA § 36.061(b).
5. ETI proved the reasonableness of its rate case expenses in the amount of $\backslash$ 7,344.113$, and is entitled to claim that amount as a cost.

C. Proposed Ordering Paragraphs

In accordance with these findings of fact and conclusions of law, the Commission issues the following orders:

1. The Proposal for Decision prepared by the SOAH ALJs is adopted to the extent consistent with this Order.
2. All other motions, requests for entry of specific findings of fact and conclusions of law, and any other requests for general or specific relief, if not expressly granted, are denied.
3. Cities' and ETI's requests to recover rate case expenses are granted to the extent consistent with this Order.

SIGNED February 19, 2013.

Appendix B

Commission's Final Order in Docket No. 40295

PUC DOCKET NO. 40295
SOAH DOCKET NO. 473-12-5573

ORDER

This Order addresses the rate-case expenses pertaining to Docket No. 39896, ^[1] Entergy Texas, Inc.'s last rate case. Entergy requested $\backslash$ 8.8 $millioninrate-caseexpensesassociatedwithDocketNo.39896-$ \ $7.6$ million for Entergy's own rate-case expenses and $\backslash$ 1.2 $millionforCitie{s}^{\prime }rate-caseexpenses.TheproposalfordecisioninthisdocketwasissuedonFebruary19,2013.Intheproposalfordecision,theALJrecommendedallowingCitie{s}^{\prime }rate-caseexpensesincurredthroughAugust31,2012,plusupto$ \ $75,800$ in rate-case expenses as they are incurred after August 31, 2012. The ALJ also recommended that Entergy's rate-case expenses be reduced to account for Entergy taking certain positions in the rate case regarding financially-based incentive compensation and transmission equalization expenses. The Commission considered the proposal for decision at the April 11 and April 25, 2013 open meetings. The Commission adopts in part and reverses in part the proposal for decision, including findings of fact and conclusions of law.

I. Estimated Rate-Case Expenses

The Commission reverses the proposal for decision regarding Cities' $\backslash$ 75,800$ in estimated rate-case expenses to be incurred after August 31, 2012. ^[2] In Docket No. 37772, the Commission found that approving estimated rate-case expenses for two different parties representing Cities is not in the public interest and disallowed their recovery in the rate-case expense surcharge, but did not prohibit the Cities from seeking recovery of actual rate-case

expenses in the utility's next rate case. ^[3] The Commission affirms that holding here: Cities cannot recover for estimated rate-case expenses in this docket, but may seek recovery in Entergy's next rate case. To reflect its determination on this issue, the Commission adds new finding of fact 16 A , modifies conclusion of law 7 , and adds new conclusion of law 10 .

II. Proportional Reduction

The Commission affirms the proposal for decision regarding the need to reduce Entergy's recoverable expenses due to an unreasonable position pursued by Entergy in the rate case ^[4] and also affirms the use of the "issue-specific reduction approach" to determine how to calculate an appropriate reduction in rate-case expenses when the utility takes positions that are in conflict with Commission precedent. ^[5]

Specifically, the Commission agrees with the ALJ that reductions should be made to Entergy's recoverable rate-case expenses for Entergy attempting to recover financially-based incentive compensation in base rates. The Commission has repeatedly ruled that a utility cannot recover the cost of financially-based incentive compensation because financial measures are of more immediate benefit to shareholders and financial measures are not necessary or reasonable to provide utility services. ^[6] The Commission concludes that it should follow its well-established policy here.

However, the ALJ did not include all of the impacts attendant to the disallowance for incentive compensation. ^[7] To calculate the amount of the reduction in rate-case expenses related to financially-based incentive compensation, the Commission starts with Entergy's initial rate-

case expense request, reduced by $\backslash$ 208,494 $indisallowancesmadebythe$ \mathrm{ALJ}^{8} $andaffirmedbytheCommission.TheCommissionfurtherreducesthisamountbyanadditional$ \ $522.244\mathrm{.66}$ , which is the amount of rate-case expenses related to financially-based incentive compensation using the issue-specific reduction approach.

The Commission disagrees with the ALJ that Entergy's rate-case expenses should be reduced due to Entergy's request for transmission equalization (MSS-2 expenses). ^[9] Even though Entergy did not meet the burden of proof that the requested expenses were known and measureable changes to test-year expenses, the request for the MSS-2 expenses did not conflict with clear Commission precedent.

Accounting for these reductions, the Commission finds that rate-case expenses for ETI in the amount of $\backslash$ 6,896,037.73 $arereasonableandnecessary.Consequently,theCommissionisapprovingatotalamountof$ \ $8,021,806.34$ in allowable rate-case expenses in this docket.

To reflect its determinations on the proportional reduction issue, the Commission modifies finding of fact 18 and conclusion of law 9 .

III. Affiliate Payments

The Commission also finds that the price for Entergy's affiliate payments is not higher than the prices charged by the supplying affiliate for the same item or class of items to its other affiliates or divisions or a nonaffiliated person within the same market area or having the same market conditions. The Commission adds new finding of fact 19 and new conclusion of law 11 to reflect that Entergy met the requirements in PURA § 36.058 regarding payments to its affiliates for its rate-case expenses.

The Commission also makes minor corrections to conclusions of law 6 and 8 to incorporate the statutory reference into the language of the conclusion of law. Consistent with the discussion above, the Commission adopts the following findings of fact and conclusions of law:

IV. Findings of Fact

1. Entergy Texas, Inc. (ETI or the Company) is an investor-owned electric utility with a retail service area located in southeastern Texas.
2. On November 28, 2011, ETI filed an application (the ETI Application) requesting, among other things, approval of a proposed increase in annual base rate revenues of approximately $\backslash$ 111.8$ million over adjusted test year revenues, and a new rider for recovery of costs related to purchased power capacity.
3. On November 29, 2011, the Public Utility Commission of Texas (Commission or PUC) referred the ETI Application to the State Office of Administrative Hearings (SOAH) for a hearing and the matter was assigned docket number 39896 (Docket 39896).
4. On April 4, 2012, in Docket 39896, the ALJs issued SOAH Order No. 13 severing ratecase expense issues into a new docket, the case at issue here, Application of Entergy Texas, Inc. for Rate Case Expenses Severed from PUC Docket No. 39896, Docket No. 40295 .
5. The hearing on the merits in Docket 39896 was held in April-May 2012.
6. The Proposal for Decision (PFD) in Docket 39896 was issued July 6, 2012.
7. The Commission issued its final order in Docket 39896 on November 2, 2012.
8. The hearing on the merits in the present docket, Docket 40295 , was held on November 28, 2012. The record closed on December 21, 2012, following the filing of post-hearing briefs.
9. The following parties were granted intervenor status in this docket: Office of Public Utility Counsel (OPUC); the cities of Anahuac, Beaumont, Bridge City, Cleveland, Conroe, Dayton, Groves, Houston, Huntsville, Montgomery, Navasota, Nederland, Oak Ridge North, Orange, Pine Forest, Rose City, Pinehurst, Port Arthur, Port Neches, Shenandoah, Silsbee, Sour Lake, Splendora, Vidor, and West Orange (Cities); State Agencies; and Texas Industrial Energy Consumers (TIEC). The staff (Staff) of the Commission was also a participant in this docket.

1. In Docket 39896, ETI adjusted its request for a proposed increase in annual base rate revenues to approximately $\backslash$ 104.8$ million over adjusted Test Year revenues.
2. In the PFD in Docket 39896, the ALJs recommended an overall rate increase of $\backslash$ 28.3$ million.
3. In its final order in Docket 39896, the Commission largely followed the recommendations contained in the PFD, but reduced ETI's overall rate increase to $\backslash$ 27.7$ million.
4. In this docket, ETI seeks to recover $\backslash$ 8.8$ million in rate-case expenses associated with Docket 39896 .
5. Of that total, $\backslash$ 7.6 $millionwasincurredbyETIand$ \ $1.2$ million was incurred by Cities.
6. Cities proved that, through August 31, 2012, they reasonably incurred rate-case expenses of $\backslash$ 1,125,768.61$ in Docket 39896 and this docket.
7. Cities reasonably estimated that their total rate-case expenses in Docket 39896 and this docket after August 31, 2012 will total $\backslash$ 75,800$. 16A. The Commission finds that Cities' estimated expenses are not recoverable as rate-case expenses in this docket.
8. The amount of rate-case expenses sought by ETI ( $\backslash$ 8.8 $million)ishigh,bothinabsoluteterms,andinrelationtotherateincreaseultimatelyobtainedbyETIinDocket39896($ \ $27.7$ million).
9. Rate-case expenses for ETI in the amount of $\backslash$ 6,896,037.73$ are reasonable and necessary and should be allowed as a cost or expense by the Company. This amount is calculated by reducing the requested amount by the amounts listed and for the reasons stated below: a. $\backslash$ 207,683$ in depreciation of office equipment owned by Entergy Services, Inc. (ESI) (an affiliated company of ETI) and used by ESI employees for their work in Docket 39896 is not reasonable and is properly disallowed. b. $\backslash$ 281 $formealsover$ \ $25$ was erroneously sought by ETI, is not reasonable, and is properly disallowed.

c. $\backslash$ 10$ for clothing purchased by an attorney for ETI is not reasonable and is properly disallowed. d. $\backslash$ 40$ for laundry charges by an attorney for ETI is not reasonable and is properly disallowed. e. $\backslash$ 480$ for a lodging charge unsupported by receipts is not reasonable and is properly disallowed. f. $\backslash$ 522,244.66$ attributable to unreasonable and overly aggressive arguments pursued by ETI in Docket 39896 related to financially-based incentive compensation is properly disallowed. 19. The price for Entergy's affiliate payments is not higher than the prices charged by the supplying affiliate for the same item or class of items to its other affiliates or divisions or a nonaffiliated person within the same market area or having the same market conditions.

V. Conclusions of Law

1. ETI is a "public utility" as that term is defined in the Public Utility Regulatory Act (PURA) § 11.004(1) and an "electric utility" as that term is defined in PURA $\S 31.002(6)$ .
2. The Commission exercises regulatory authority over ETI and jurisdiction over the subject matter of this application pursuant to PURA $\S \S 32.001,32.101,33.002,33.051$ , and $36.101-111$ .
3. SOAH has jurisdiction over matters related to the conduct of the hearing and the preparation of a proposal for decision in this docket, pursuant to PURA § 14.053 and Tex. Gov't Code § 2003.049.
4. This docket was processed in accordance with the requirements of PURA and the Texas Administrative Procedure Act, Tex. Gov't Code Chapter 2001.
5. Pursuant to PURA § 33.051, the Commission has jurisdiction over an appeal from a municipality's rate proceeding.
6. Pursuant to PURA § 33.023, Cities bore the burden to prove that the rate-case expenses they incurred were reasonable.

1. Cities are entitled to reimbursement by ETI for rate-case expenses of $\backslash$ 1,125,768.61$ incurred in Docket 39896 and this docket through August 31, 2012.
2. Pursuant to PURA § 36.061 (b), ETI bore the burden of proving that the rate-case expenses it incurred in Docket No. 39896 were reasonable.
3. ETI proved the reasonableness of its rate-case expenses in the amount of $\backslash$ 6,896,037.73$, and is entitled to claim that amount as a cost.
4. Consistent with Commission precedent, it is not in the public interest to permit recovery of estimated rate-case expenses.
5. Entergy met the requirements of PURA $\S 36.058$ regarding payments to its affiliate for its rate-case expenses.

VI. Ordering Paragraphs

In accordance with these findings of fact and conclusions of law, the Commission issues the following orders:

1. The Proposal for Decision prepared by the SOAH ALJs is adopted to the extent consistent with this Order.
2. All other motions, requests for entry of specific findings of fact and conclusions of law, and any other requests for general or specific relief, if not expressly granted, are denied.
3. Cities' and ETI's requests to recover rate-case expenses are granted to the extent consistent with this Order.

PUBLIC UTILITY COMMISSION OF TEXAS

KENNETH W. ANDERSON; JR., COMMISSIONER

Appendix C

1. Incentive Compensation Tied to Cost Controls

a. From PUC Docket No. 28840, Application of AEP Texas Central Company for Authority to Change Rates:

Jul. 2, 2004, Proposal for Decision (pp. 77-81) (recommending disallowance of incentive compensation tied to financial measures; including "O&;M Expense" measure in financial measures)

Aug. 15, 2005, Final Order, pp. 35 &; 56 (FOFs 164-70 &; COL 45) (finding that AEP Texas Central Company had proven that only $34\%$ of its incentive compensation costs were "operationally based," as opposed to "financially based"; disallowing financially-based portion) b. From PUC Docket No. 39896, Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment:

Jul. 6, 2012, Proposal for Decision (pp. 1, 8, 165-75, &; 352) (proposing to disallow "financially-based" incentive compensation, but to allow include incentive compensation tied to cost controls, despite AEP Texas Central Company decision cited above)

Nov. 2, 2012, Order on Rehearing (pp. 7-8 &; FOFs 127-34) (disallowing "financially-based" incentive compensation, but not disallowing incentives that ALJ identified as tied to cost controls)

2. Restricted Stock-Based Incentives

a. From PUC Docket No. 39896, Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment:

Jul. 6, 2012, Proposal for Decision (pp. 1, 8, 165-75, &; 352) (proposing to disallow "financially-based" incentive compensation, including stock-based incentives)

Nov. 2, 2012, Order on Rehearing (pp. 7-8 &; FOFs 127-34) (disallowing "financially-based" incentive compensation) b. From PUC Docket No. 40443, Application of Southwestern Electric Power Co. for Authority to Change Rates and Reconcile Fuel Costs:

Mar. 6, 2014, Order on Rehearing (p. 13 &; FOFs 214-20) (allowing SWEPCO to recover restricted stock units that it paid as incentive compensation, while disallowing "financially-based" incentive compensation)

SOAH DOCKET NO. 473-04-1033
PUC DOCKET NO. 28840

| APPLICATION OF AEP TEXAS | § | BEFORE THE STATE OFFICE | | :-- | :--: | :--: | | CENTRAL COMPANY FOR | § | OF | | AUTHORITY TO CHANGE RATES | $\S$ | ADMINISTRATIVE HEARINGS |

PROPOSAL FOR DECISION

I. INTRODUCTION

A. History and Overview

This is an application by American Electric Power Company (AEP) Texas Central Company (the Company, TCC, or Applicant) for approval of a change in the rates that it may charge for the transmission and distribution (T&;D) of electricity. The Applicant is a T&;D utility that provides service to a 44,000 -square-mile area of south Texas. The service area includes the portion of Texas from just south of San Antonio to the Mexican border, and from Bay City west to Eagle Pass. Major cities in the Applicant's service area include Corpus Christi, McAllen, Harlingen, Laredo, and Victoria. The Applicant provides distribution services to about 785,000 electric connections, served by 28 retail electric providers (REPs). The Applicant's service area has a labor force population of just over 1 million. ^[1]

AEP, the Applicant's parent company, is one of the largest investor-owned public utility holding companies in the United States. AEP became active in the Texas electric utility service market when AEP merged with a Texas electric utility holding company, Central and South West Corporation (CSW), in June 2000. ^[2] Prior to the merger, the Applicant was known as Central Power and Light Co., a name now held by the affiliated REP. ^[3]

However, the ALJs recommend approval of the salary item of $\backslash$ 170,583 $.Sincethenumberofemployeesattheendofthetestyearcouldreasonablybeexpectedtocreatesalarycostsbeyondthetestyear,theproposedadjustmentappearstobebothknownandmeasurable.Further,sincetheraisescameintoeffectbeforetheendofthetestyear,theamountdoesnotviolatetheCommissio{n}^{\prime }spolicyannouncedinDocketNo.14965.Therefore,theALJsrecommendthattheproposedadjustmenttosalariesandrelatedtaxesshouldbedecreasedfrom$ \ $679,344$ to $\backslash$ 170,583$.

D. Incentive Compensation

The Applicant seeks to include in its cost of service calculations $\backslash$ 4.42$ million paid to employees during the test year as incentive compensation expenses. ^[264] The Applicant seeks no posttest year adjustments. ^[265] The Applicant's compensation of its employees at all levels involves both base compensation amounts and incentive components. ^[266] Although the Applicant offers three different incentive programs, $87\%$ of the total dollar amount is concentrated in one program, the Company-Wide Incentive Plan (CIP). ^[267]

The incentives in each of the programs were paid according to a set of performance measures. For CIP, the Applicant used two sets of measures, financial and operational, to establish eligibility for an incentive payment. The components of each are set forth below.

| Financial Measures | | | | :-- | :-- | :--: | | Measure ${}^{268}$ | Meaning | Weight | | Corporate Component | Earnings per share for AEP as a
whole ${}^{269}$ | $25\%$ | | O&;M Expense | Whether AEP performs under its
O&;M budget ${}^{270}$ | $20\%$ | | Capital Expenditures | Whether AEP performs under its
capital expenditure budget ${}^{271}$ | $15\%$ | | $3^{\text{rd}}$ Party Margins | A variety of categories, including
revenues for joint use of utility
poles, line extension fees,
litigation recoveries ${}^{272}$ | $3\%$ | | Transmission Revenues | Wheeling revenues ${}^{273}$ | $3\%$ | | | Financial Measures subtotal | $\mathbf{6}\mathbf{6}\mathbf{\%}$ |

| Operating Measures | | | | :-- | :-- | :--: | | Measure ^[274] | Meaning | Weight | | Reliability SAIFI | System average interruption
frequency index; measure of
outage frequency ^[275] | $12.5\%$ | | Reliability CAIDI | Customer average interruption
duration index; measure of length
of average interruption ^[276] | $12.5\%$ | | Commission Complaints | Number of state regulatory
complaints ^[277] | $6\%$ | | Customer Satisfaction | Third party survey of customer
satisfaction levels ^[278] | $3\%$ | | | Operating Measures subtotal | $\mathbf{3}\mathbf{4}\mathbf{\%}$ | | | Grand total | $100\%$ |

These criteria are not used to measure the performance of the Applicant's individual employees. Instead, they are used to measure the performance of AEP as a corporate entity-not just TCC or the other subsidiaries. ^[279] Thus, to the extent that the Applicant's employees are given an incentive, their rewards are made with respect to the overall performance of the holding company.

With regard to the measures themselves, the Financial Measures are of more immediate benefit to shareholders and less so to ratepayers. ^[280] Conversely, the Operating Measures are of more immediate benefit to ratepayers and less so to shareholders. ^[281] The question is whether these various interests satisfy the regulatory scheme by which expenses may be included as part of a proposed rate change. By statute, the Commission may not consider for ratemaking purposes an "expenditure, including an executive salary. . . [that the Commission] finds to be unreasonable, unnecessary, or not in the public interest."282 By rule, the Commission has interpreted the "public interest" requirement to mean that an expense is "reasonable and necessary to provide service to the public."283 [Emphasis supplied.]

CCR argues that the Commission should follow the lead of a number of other states, which disallow incentive compensation costs as a matter of policy. The reason, according to CCR, is that incentive payments are not related to improved utility service. Instead, their goal is to improve the stock or financial performance of the corporation. ^[284] CCR argues that the ratepayers and shareholders should split the cost equally. ^[285]

Cities argue a loser-takes-none approach: none of the Applicant's test year amount incentive expense should be allowed since the incentive plans provide far more benefits to shareholders than to ratepayers. ^[286]

The Applicant makes a plausible case for including in the cost of service the $34\%$ portion of the incentive expense that is related to Operational Measures. By their very nature, Operational Measures reflect goals that relate to the public interest. Indeed, many are required to be considered as independent issues in this proceeding. Although the Operational Measures relate to AEP as a corporate holding company rather than to the Applicant, the Applicant shares in those Operational Measures on an allocated basis. The ALIs find that the goals of the Operational Measures are in the public interest and reasonable and necessary to provide service to the public.

Although the Financial Measures may have been in the shareholders' interest, the Applicant could not show that they were in the public interest. The Applicant's brief asserts that "although the various incentive compensation plan goals may not directly benefit customers, this is beside the point. ^[287] [Emphasis in the original.] The ALIs acknowledge the first half of the statement, and we recommend that the Commission include in the cost of service the portion of the incentive compensation that relates to Operational Measures, $34\%$ of $\backslash$ 4.42$ million.

E. Pension Expense

The Applicant proposes to increase its test year pension expenses by $\backslash$ 7.2$ million. ^[288] The following table reflects the amounts of the Applicant's historical and projected pension-related expenses and contributions for plan years 2000-2005. ^[289] Projected amounts are shown in italics:

PUC DOCKET NO. 28840
SOAH DOCKET NO. 473-04-1033

APPLICATION OF AEP TEXAS
\author{ &; PUBLIC UTILITY COMMISSION

CENTRAL COMPANY FOR
\author{ &;
AUTHORITY TO CHANGE RATES

OF TEXAS

ORDER

}

This Order addresses the application of AEP Texas Central Company (TCC) for authority to change its rates. TCC initially filed its application on November 3, 2003, seeking approval of a revenue requirement of $\backslash$ 519.9 $million.ForthereasonsdiscussedinthisOrder,theCommissiondeterminesthatTC{C}^{\prime }sappropriaterevenuerequirementis$ \ $443,607,238$ . The reduction reflects an agreed disallowance of $\backslash$ 10.5 $millioninaffiliateexpenses,aswellasadditionaldisallowancesasdeterminedbytheCommission.Asallocated,thedistributionportionofTC{C}^{\prime }scurrentrevenuerequirementwillincreaseby$ \ $5.3$ million, whereas the wholesale transmission portion will decrease by $\backslash$ 14.1$ million.

As discussed in this Order, the Commission adopts in part and rejects in part the proposal for decision (PFD) and remand PFD issued by the State Office of Administrative Hearings (SOAH) administrative law judges (ALJs) in this proceeding, including the findings of fact and conclusions of law.

I. Procedural History

The Commission referred this case to SOAH on November 4, 2003, and SOAH issued its initial PFD on July 1, 2004. The Commission issued an Order on Remand on July 28, 2004, directing SOAH to consider the appropriate amount for a consolidated taxsavings adjustment, which was not calculated in the initial PFD. On August 25, 2004, the Commission issued a Second Order on Remand, directing SOAH to provide further evaluation regarding the following issues: affiliate costs, distribution administrative and general (A&;G) expense adjustments, depreciation expense, net salvage, special meter reading fee, connect fee and service reconnect fee, and priority disconnect fee. SOAH

F. Salary Adjustments and Related Taxes

1. Of the $\backslash$ 679,344 $insalaryadjustmentsandrelatedtaxesproposedbytheApplicant,$ \ $508,761$ was proposed for post-test-year raises for staff.

G. Incentive Compensation

1. The compensation packages that the Company offers its employees include a base payroll amount as well as an incentive-compensation portion. Both portions are part of an overall compensation package that is designed to be competitive in the marketplace and allow the Company to attract and retain qualified individuals as employees.
2. The Company requests to include the test-year level of incentive-compensation expense of $\backslash$ 4,422,937$ in cost of service.
3. The Company's incentives are set through two types of performance measures, financial and operational.
4. Thirty-four percent of the incentive-compensation expenses are for operational measures.
5. To the extent that the Applicant's employees are given an incentive, their rewards are made with respect to the overall performance of the holding company.
6. The financial measures are of more immediate benefit to shareholders, and the operating measures are of more immediate benefit to ratepayers.
7. Incentives to achieve operational measures are necessary and reasonable to provide T&;D utility services, but those to achieve financial measures are not.

H. Pension Expense

1. The Company proposes to increase test-year pension expenses by $\backslash$ 7,264,784 $from$ \ $30,812$ .

1. A utility that provides a service that does not come within the definition of any of the first three categories may seek to treat that offering as an "other" service.
2. An offering may properly be characterized as an "other" service; however, only if the service satisfies specific provisions of the Commission's rule. "Other services" are "limited to those services that: (I) maximize the value of [T&;D] system service facilities, and (II) are provided without additional personnel and facilities other than those essential to the provision of [T&;D] system services." P.U.C. Subst. R. 25.342(f)(1)(D)(i)(I) and (II). If the offering satisfies that definition, then the utility is also required to "credit all revenues received from the offering of this service during the test year after known and measurable adjustments are made to lower the revenue requirement of the transmission and distribution utility on which the rates are based."
3. Whatever its intention in approving the creation of the "other service" category, the Commission made clear that all revenues-and not net revenues-should be credited to the cost-of-service calculation. If, however, the costs and revenues of providing the other service are not included in the calculation of rates, then the test-year margins (revenues minus costs) received from the service should be credited to the cost-of-service calculation.
4. Deleted.
5. The Company failed to meet the legal requirements to recover $\backslash$ 508,761 $ofthe$ \ $679,344$ in proposed salary adjustments and related taxes.
6. The Applicant met its burden of proof with regard to incentive compensation but only with respect to that portion relating to Operational Measures; the amount includible in the cost of service is $34\%$ of $\backslash$ 4.42$ million.
7. TCC met its burden of proof with regard to pension expenses includible in the cost of service in the amount of $\backslash$ 30,812$.
8. The Applicant failed to meet its burden of proof on its proposed expense item for OPEB; the proposed expense item is not includible in the cost of service.

SOAH DOCKET NO. 473-12-2979
PUC 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

PROPOSAL FOR DECISION

I. INTRODUCTION [Germane to Preliminary Order Issue Nos. 1 and 4]

Entergy Texas, Inc. (ETI or the Company) is an investor-owned electric utility with a retail service area located in southeastern Texas. ETI serves retail and wholesale electric customers in Texas. As of June 30, 2011, ETI served approximately 412,000 Texas retail customers. The Federal Energy Regulatory Commission (FERC) regulates ETI's wholesale electric operations.

On November 28, 2011, ETI filed an application requesting approval of: (1) a proposed increase in annual base rate revenues of approximately $\backslash$ 111.8$ million over adjusted revenues for the period beginning July 1, 2010, and ending June 30, 2011 (Test Year); (2) a set of proposed tariff schedules presented in the Electric Utility Rate Filing Package for Generating Utilities accompanying ETI's application and including new riders for recovery of costs related to purchased power capacity and renewable energy credit requirements; (3) a request for final reconciliation of ETI's fuel and purchased power costs for the reconciliation period from July 1, 2009, to June 30, 2011 (Reconciliation Period); and (4) certain waivers to the instructions in Rate Filing Package Schedule V accompanying ETI's application. The rate year for ETI's proposed changes is June 1, 2012, through May 31, 2013 (Rate Year). ^[1] On April 13, 2012, adjusted its request for a proposed increase in annual base rate revenues to approximately $\backslash$ 104.8$ million over adjusted Test Year revenues.

Incentive Compensation

ETI should not be entitled to recover its financially based incentive compensation costs. Thus, the ALJs recommend removing $\backslash$ 6,196,037 $fromET{I}^{\prime }srequestedoperationandmaintenance$ (\mathrm{O} &; \mathrm{M})$ expenses. Additionally, an additional reduction should be made to account for the FICA taxes that ETI would have paid as a result of those costs.

Compensation and Benefit Levels

ETI met its burden to prove the reasonableness of its base pay and incentive package costs. It is reasonable to view market price for these categories of costs as lying within a range of $+/-$ 10 percent of median, rather than being a single point along a spectrum. As to both base pay and the incentive package, ETI has proven that its costs fall within such an acceptable range. Accordingly, the ALJs recommend rejecting the adjustments sought by Cities.

Nonqualified Executive Retirement Benefits

The ALJs recommend an adjustment to remove $\backslash$ 2,114,931$, representing the full costs associated with ETI's non-qualified executive retirement benefits.

Employee Relocation Costs

The Commission should allow ETI's relocation expenses.

Executive Perquisites

The ALJs recommend an adjustment to remove $\backslash$ 40,620$, representing the full cost of ETI's executive perquisite costs.

5. Interest on Customer Deposits

The ALJs recommend using the active customer deposits amount of $\backslash$ 35,872,476 $andthe\mathrm{2012in}terestrate,whichproducesarecommendedinterestexpenseof$ \ $43,047$ ( $\backslash$ 35,872,476$ multiplied by .12 percent).

full-time equivalent calculations need to be corrected. She included an incorrect assumption regarding part time employee salaries. Ms. Givens assumed that a part time employee's average salary is 50 percent of the full time average salary. In his rebuttal testimony, Mr. Considine provided the correct calculation of full time equivalents, thereby making it unnecessary to rely upon an assumed average. ^[567] According to Mr. Considine, the combined impacts of these errors is that Ms. Givens' ETI headcount adjustment overstated her O&;M payroll reduction by $\backslash$ 224,217 $,andherESIheadcountadjustmentunderstatedherO\&Mpayrollincreaseby$ \ $37,531.{}^{568}$ No party challenged these corrected numbers.

The ALJs are unpersuaded by Cities' attempt to exclude the April 2012 pay raises. There can be no real dispute about the fact that the pay raises are known and measurable. Moreover, there is an obvious logical inconsistency in the Cities' position - on the one hand they oppose consideration of certain pay raises because they fall outside the Test Year, and on the other hand they support consideration of headcount reductions even though they also fall well outside the Test Year.

The ALJs are also persuaded that, conceptually, the adjustments suggested by Staff are reasonable and appropriate. Indeed, all parties agree on this point. Moreover, no party challenged the corrections to Staff's adjustments that were suggested by ETI, and the ALJs can find no basis for challenging those corrections. Thus, the ALJs recommend that the Commission: (1) accept the payroll adjustments proposed in the ETI application; and (2) accept the further payroll adjustments proposed by Staff, corrected by ETI.

2. Incentive Compensation

One of the hotly contested issues concerns the extent to which ETI should be allowed to recover, through its rates, the incentive compensation it pays to its employees. All parties agree that Commission precedent generally identifies two types of incentive compensation, only one of which is recoverable. Specifically, pursuant to Commission precedent, incentive compensation that is tied

to operational goals is recoverable, while incentive compensation that is tied to financial goals is not. ^[569] In its application, however, ETI requests that if be allowed to recover its Test 3 can costs of all of its incentive compensation costs, regardless of whether those costs are tied to operational goals or to financial goals.

(a) Financially Based Incentive Compensation Should Not Be Recoverable

ETI acknowledges that costs of incentive compensation tied to financial goals have typically been disallowed by the Commission. However, ETI asks for the Commission to reconsider its precedents on this issue. ^[570] ETI argues that the Commission precedent is not, and should not be, a hard and fast rule. ETI contends that the reason why cost recovery has been denied for incentive compensation in prior rates causes that, in those prior cases, there was no lack of evidence showing sufficient customer benefits. ^[571] ETI asserts that, in this case, it has assembled evidence not previously considered by the Commission that shows the benefits to customers of using financial measures in incentive compensation programs. For example, ETI argues that incentive compensation that encourages the financial health of a company also benefits customers because: (1) if a company maintains a financially healthy position, it will tend to have a lower cost of capital that will in turn benefit customers through lower rates; (2) a financially healthy company will be more prepared for emergency events such as storms (which is particularly important in the Gulf Coast areas served by ETI, which are subject to experiencing hurricanes), and (3) with financial health, the costs of doing business with suppliers (of both goods and services, including labor) will remain lower because, for example, if a company was not in a financially stable condition, suppliers would tend to demand higher prices or more onerous credit terms, resulting in higher costs that would lead to higher rates than would otherwise occur.

ETI witness Kevin Gardner, Vice President of Human Resources for ESL, testified that customer, receive benefits from those positions of the incentive compensation plans that are tied to financial goals and measures. He explained that incentive compensation based on financial metrics is a reasonable, necessary, and common component of compensation for companies like ETI. He also opined that such incentives are a market necessity that ETI must include in its compensation packages; that it can hire and retain talented employees. He contended that customers benefit from the incentives because they attract and keep qualified people. ^[572] Mr. Gardner further testified that disallowing financially-based incentives would only encourage utilities to eliminate them, thus weakening the alignment of employees' financial interests with the interest of the ratepayers in having an efficiently run and financially healthy utility. He opined that having only operational incentives could encourage utilities to overspend in some areas resulting in an incomplete, imbalanced incentive program that would be atypical when compared with American industry in general. ^[573]

A second ETI witness, Dr. Jay Hartzell, also testified in favor of the concept of allowing ETI to recover its costs associated with its financially-based incentive compensation. He is a professor of finance in the business school at the University of Texas at Austin. Dr. Hartzell acknowledged the historical distinction that has been made by the Commission between compensation tied to financial measures and compensation tied to operational measures. However, he argues that this distinction is based upon a "false dichotomy" and that the more appropriate focus should be on whether customers benefit from the incentive in question, regardless of whether it is a financial or operational incentive. ^[574] Dr. Hartzell summarized his key opinion as follows:

In my opinion, a well-designed compensation plan that includes incentive compensation tied to cost controls, profitability, and stock prices would tend to provide greater benefits to customers than an otherwise similar compensation plan that did not include any such incentive compensation. ^[575]

Dr. Hartzell argues that compensation linked to stock prices (provided it is part of a reasonable, well-designed compensation plan) has four advantages for customers:

• helps ensure that managers will consider the financial health of the company when they make decisions, and it is in customers' interests for the company be financially healthy;
• provides an incentive for managers and employees to ensure that the company operates efficiently, resulting in lower rates than would otherwise occur;
• provides a monitoring mechanism for managerial decision making and the overall quality of management, and
• results in lower customer costs because capital markets will tend to reward efficient long-term investments or capital expenditures. ^[576]

Dr. Hartzell cited a number of studies which support the theory that the benefits of incentive compensation linked to stock price and profitability measures extend to customers of the company, such as by lowering the company's cost of capital, increasing the company's ability to respond to external shocks, improving customer satisfaction, and increasing oversight on managerial decisions. ^[577]

Conversely, Dr. Hartzell opined that if the use of incentive compensation linked to profitability and stock prices is discouraged, via Commission policy disallowing recovery of the costs of such compensation, then utility customers would be adversely affected. For example, if employees did not receive any incentive compensation, salaries would have to be higher to attract and retain the same quality of talent. Dr. Hartzell also testified that a compensation plan solely consisting of salary and incentives based on operational performance could likely lead to "horizon problems," meaning that, absent incentives to focus on the long run health of the company, managers might maximize their immediate compensation at the expense of longer-run benefits that the customer could have enjoyed. ^[578]

All of the other parties oppose ETI's efforts to recover the costs of its incentive compensation tied to financial goals. The parties uniformly agree that the Commission has a wellestablished and straightforward policy regarding the recoverability of incentive compensation through rates: incentive compensation that is tied to operational goals is recoverable; incentive compensation tied to financial goals is not. ^[379] They contend that ETI's position in this case lies directly in the face of that policy. TIEC points out that ETI has offered no legal authority, such as a statute or rule, which would justify its desire to have the Commission reverse its policy and allow the recovery of incentive compensation tied to financial goals. State Agencies similarly argue that ETI failed to establish a reasonably the Commission should deviate from its long-standing policy. The parties also support the reasoning behind the Commission's policy: that financially-based incentives are of more immediate benefit to shareholders, not ratepayers, and therefore are not necessary and reasonable for the provision of service.

State Agencies point out that, in support of his theory that financially-based incentives provide benefits to ratepayers, Dr. Hartzell relied upon studies of utilities, in competitive markets. Thus, State Agencies contend, the studies are of little to no benefit in evaluating the effects of financially-based incentives upon ETI customers because ETI is a monopoly that is not subject to competitive pressures. Moreover, State Agencies (commissioning) the underlying studies relied upon by Dr. Hartzell and assert, essentially, that the studies do not fully support the findings that Dr. Hartzell ascribes to them.

Staff refutes ETI's contention that the only reason why cost recovery has historically been denied for financially-based incentive compensation is that there has been a lack of evidence showing customer benefits. For example, Staff points out that, in one of the prior doakete, cited by ETI, the Commission disallowed recovery for financially-based incentive costs after stating, "Incentive compensation based on financial measures or goals is of more immediate benefit to

sharcholders. ^[580] This suggests that the question is not, as ETI contends, whether the incentives provide any benefit to ratepayers. Rather, the question is whether the incentives are primarily intended to provide benefits to shareholders.

Mark Garrett, an attorney and certified public accountant who works as a consultant in the area of public utility regulation, testified on behalf of the Cities in opposition to cost recovery for financially-based incentive compensation. He stated there are a number of reasons why it makes sense to exclude financially based incentive costs from rates: (1) there is no certainty from year to year what the level of incentive payments will be (because incentive payments are conditioned upon future events and triggers that might not occur), thereby making it difficult to set rates and recover a level of expense; (2) many of the types of factors that increase earnings per share—such as an unusually hot summer or customer growth—are outside the control of employees and have no value to customers; and (3) earnings-based incentives can discourage energy conservation. ^[581] Mr. Garrett also discussed the results of a survey of 24 other states, which revealed that 17 states closely follow Texas' approach, and none allow full recovery of incentive compensation. ^[582]

Mr. Garrett testified that ETI will not be placed at a competitive disadvantage in its ability to obtain and retain qualified employees if its financially-based incentives are disallowed. He stated that the Company's total payroll costs for 2011 were 10 percent above the market price, and that most of the above market payroll costs derived from the incentive program. ^[583]

The AL is conclude that ETI should not be entitled to recover its financially based incentive compensation costs. Based upon prior Commission precedents, the AL is conclude that the issue is not, as ETI contends, whether such incentives might provide any benefits to customers. The proper question to be asked is whether they provide benefits most immediately or predominantly to shareholders. Without at doubt, the primary purpose of financially based incentives, such as

incentives tied to earnings per share or stock price, is to benefit shareholders, not ratepayers. Even consisting Dr. Hartzell's testimony in the most generous light, any benefits that might accrue to ratepayers would be merely tangential to that primary purpose.

Moreover, even if the ALJ, were to completely accept as true the opinions offered by Dr. Hartzell, it would be of limited benefit to ETI because his opinions were almost completely theoretical. The premise of his testimony was that "a well-designed compensation plan" that includes incentive compensation tied to financial goals would "tend to provide greater benefits to customers" than a plan that did not include such compensation. ^[584] He stressed that the customer benefits of incentive compensation tied to financial goals can only exist if such compensation is part of a larger, reasonable, and well-designed overall compensation plan. ^[585] However, he did not meaningfully apply this abstract theory to ETI's compensation plan. For example, Dr. Hartzell did not offer an evaluation of ETI's compensation plan and conclude that it is "well designed," nor did he testify that ETI's incentives tied to financial goals actually provide benefits to its customers. He admitted that he did not study the details of ETI's incentive plans, nor did he do any type of analysis to see if the costs of ETI's incentive programs outweighed their benefits. ${}^{586}\mathrm{H}\mathrm{e}$ did not know the amounts of incentive compensation that was paid by ETI. ^[587] One of his major premises was that financially-based incentives can benefit customers by lowering their costs, but he did not know how ETI customer's costs compared with customer costs in the other Entergy operating companies. ^[588] Another of his major premises was that financially-based incentives can benefit customers by ensuring the financial health of the Company, but he made no attempt to determine whether ETI was, in fact, a financially healthy company. ^[589] By confining his testimony to the abstract, it is impossible to know whether Dr. Hartzell believes that ETI's incentive compensation tied to financial goals achieves the customer benefits that he believes such compensation can theoretically achieve.

It is true that Mr. Gardner described some of the specifics of ETI's incentive plans. However, because Dr. Harleell did not explain the metrics of what he would consider "it well-designed compensation plan," it is impossible to know if ETI's plan meets those metrics.

Simply put, the ALJ. conclude that ETI has failed to establish a sufficient justification for overturning the well-established Commission policy that financially based incentive compensation is not recoverable.

(b) The Adjustment for Financially-Based Incentive Compensation Costs

Having concluded that ETI is not entitled to recover the costs of its financially based incentive programs, it is necessary to determine the amount of those costs so that they may be removed from consideration in this rate case. The parties disagree on the correct amount. Staff argues that $\backslash$ 5.3$ million of ETI's incentive compensation is financially based. ^[590] TIEC contends the correct number is $\backslash$ 6.2$ million. ^[591] Cities contend it is $\backslash$ \ $4$ million. ^[592]

Broadly speaking, ETI has two categories of incentive compensation programs - annual programs and long-term programs. ETI witness Gardner testified that 100 percent of ETI's long-term programs are financially based, whereas an average, representing a far lower percentage, of the Company's annual programs are financially based. ^[593] Staff witness Givers applied those percentages to determine her estimate of the amount spent by ETI in the Test Year on financially based incentives. As to the Company's long-term programs, she recommended removing the entire costs of those programs (i.e. 100 percent) from the cost of service. As to the Company's annual programs, she recommended removing average percentage of the costs of those programs. Ms. Givens then applied the FICA tax rate to the total amount she identified as financially based costs to account for direct taxes that ETI would have paid as a result of those costs. By her estimate,

the FICA taxes associated with ETI's financially based incentives paid in the Test Year totaled \ $429,036.Intotal,Ms.Givensrecommendedremoving\backslash$ 5,609,092 (representing ETI's financially based incentives paid in the Test Year, plus FICA taxes associated with those payments) from ETI's requested O&;M expenses. However, based upon subsequent additional information supplied by ETI ^[594] relative to the actual payroll taxes paid by the Company for its financially based incentive compensation, Staff has agreed to lower its estimate of FICA taxes from $\backslash$ 129,096 $to$ \ $142,801$ . Thus, Staff now recommends removing $\backslash$ 5,323,798$ (representing ETI's financially based incentives paid in the Test Year, plus FICA taxes associated with those payments) from ETI's requested O&;M expenses. ^[595]

Like Ms. Givens for Staff, TIEC witness Pollock relied on the numbers and percentages concerning ETI's incentive programs that were provided by Mr. Gardner. However, Mr. Pollock calculated those numbers and percentages in a slightly different manner, leading to a different recommended reduction amount. Just as Ms. Givens did, as to the Company's long-term programs, he recommended removing the entire costs of those programs from the cost of service. ETI ул Gardner testified that actual percentages of each annual program were quite different than the average percentages for all programs used by Ms. Givens. ^[596] Thus, as to the Company's annual programs, while Ms. Givens applied the average percentage reduction to all of the annual programs, Mr. Pollock applied the actual percentage reductions applicable to each of the annual programs. Based on Mr. Pollock's calculations, TIEC recommends removing \$6,196,037 (representing ETI's financially based incentives paid in the Test Year) from ETI's requested O&;M expenses. ^[597] TIEC appears not to have taken into account any payroll taxes associated with ETI's financially based incentives.

Cities witness Garrett took a substantially different approach when he calculated his estimate of ETI's financially based incentive costs. He agreed with Ms. Givens and Mr. Pollock that

100 percent of the Company's long-term program costs should be removed from the cost of service. As to the annual programs, however, Mr. Garrett defined what qualities as "financially based" much more broadly than ETI, Staff, and TIEC. ETI witness Gardner testified that, when the Company's five annual programs were averaged together, specific percentages of those programs were financially based, armed at "cost control," and armed at "cost control, operational, safety." ^[598] Mr. Garrett added together, the percentage representing the financially based costs, the cost control costs, and roughly one-third of the cost-control, operational safety costs to arrive at the figure he identified as the amount of ETI's costs for its annual programs that is "related to financial performance measures."599 Cities, contend this approach is supported by the decision in a prior docket. ^[600] Based on Mr. Garrett's calculations, Cities recommend removing S8,397,232 (representing ETI's incentives "related to financial performance measures" paid in the Test Year) from ETI's requested OKM expenses. ^[601] Mr. Garrett also agreed with Mr. Givers that an additional reduction should be made to account for the EICA taxes that ETI would have paid as a result of those costs. ^[602]

The ALIs reject Cities' attempt to broadly expand the definition of what qualities as a financially based incentive to include items such as cost control measures. Cities' primary justification for doing so is that the Commission has done so previously in the AEP Texas case. As pointed out by ETI, however, the Commission did so in that case merely because AEP Texas lumped its cost control measures in with its financially based incentive costs. The evidence in this case demonstrates that ratepayers benefit when a utility incentives to employee to control costs. Even TIEC witness Pollock testified that "incentives that encourage employees to minimize costs and probably more or less in the best interest of ratepayers." ^[603] ETI further provided evidence

establishing that cost control incentives that result in lower costs for the Company likewise result in lower rates for customers. ^[604]

As to the approaches advocated by TIEC and Staff, the ALIs conclude that TIEC's approach more accurately captures the true cost of ETI's financially based incentive programs. Rather than averaging across all of ETI's annual programs (as was done by Staff), TIEC used the percentage applicable to the single annual program that included a component of financially based costs. Thus, the ALIs recommend removing $M_1,20,027$ (representing ETI's financially based incentives paid in the Test Year) from ETI's requested O&;M expenses. Additionally, the ALIs agree with Staff and Cities that an additional reduction should be made to account for the FICA taxes that ETI would have paid as a result of those costs. That amount is not specifically known at this time.

3. Compensation and Benefits Levels

In the application, ETI included, as part of its labor costs, $\backslash$ 54,965,005 $inbasepayrollpaidbyETIandESIintheTestYear.Italsoincluded$ \ $20,428,817$ in costs associated with various benefits (such as medical/dental, and life insurance) that ETI and ESI provided to their employees. ^[605] Cities contend that the amounts for base pay and the benefits package should be reduced by $\backslash$ 989,370 $and$ \ $2,860,034$ , respectively, because the amounts paid were above the market price. ^[606] No other party challenges the reasonableness of the base payroll and benefits package.

As to base payroll, Cities contends that the amount paid by ETI and ESI was 1.8 percent above the prevailing market price (above market). ^[607] Cities witness Garrett acknowledges that ETI and ESI are free to pay their employees at above market wages, but he contends that ratepayers should only be asked to pay the market rate for wages, which he contends constitute the only "necessary" costs of providing utility service. Thus, Mr. Garrett and Cities recommend a 1.8 percent

1. Staff has appropriately updated headcount levels to the most recent available data but errors made by Staff should be corrected. The corrections related to: (a) a double counting of three ETI and one ESI employee; (b) inadvertent use of the ETI benefits cost percentage in the calculation of ESI benefits costs; (c) an inappropriate reduction of savings plan costs when such costs were already included in the benefits percentage adjustments; and (d) corrections for full-time equivalents calculations. Staff's ETI headcount adjustment (AG-7) overstated operation and maintenance (O&;M) payroll reduction by $\backslash$ 224,217 $,andESIheadcountadjustment(AG-7)understatedO\&Mpayrollincreaseby$ \ $37,531$ .
2. ETI included $\backslash$ 14,187,744$ for incentive compensation expenses in its cost of service.
3. The compensation packages that ETI offers its employees include a base payroll amount, annual incentive programs, and long-term incentive programs. The majority of the compensation is for operational measures, but some is for financial measures.
4. Incentive compensation that is based on financial measures is of more immediate and predominant benefit to shareholders, whereas incentive compensation based on operational measures is of more immediate and predominant benefit to ratepayers.
5. Incentives to achieve operational measures are necessary and reasonable to provide utility services but those to achieve financial measures are not.
6. The $\backslash$ 5,376,975$ that was paid for long term incentive programs was tied to financial measures and, therefore, should not be included in ETI's cost of service.
7. Of the amounts that were paid pursuant to the Executive Annual Incentive Plan, $\backslash$ 819,062$ was tied to financial measures and, therefore, should be disallowed.
8. In total, the amount of incentive compensation that should be disallowed is $\backslash$ 6,196,037$ because it was related to financial measures that are not reasonable and necessary for the provision of electric service.
9. The amount of incentive compensation that should be included in the cost of service is $\backslash$ 7,991,707$.
10. To attract and retain highly qualified employees, the Entergy Companies provide a total package of compensation and benefits that is equivalent in scope and cost with what other comparable companies within the utility business and other industries provide for their employees.
11. When using a benchmark analysis to compare companies' levels of compensation, it is reasonable to view the market level of compensation as a range rather than a precise, single point.
12. ETI's base pay levels are at market.
13. ETI's benefits plan levels are within a reasonable range of market levels.

PUC DOCKET NO. 39896
SOAH DOCKET NO. 473-12-2979

| APPLICATION OF ENTERGY TEXAS, | | | :-- | :-- | | INC. FOR AUTHORITY TO CHANGE | | | RATES, RECONCILE FUEL COSTS, | | | AND OBTAIN DEFERRED | | | ACCOUNTING TREATMENT | |

ORDER ON REHEARING

This Order addresses the application of Entergy Texas, Inc. for authority to change rates, reconcile fuel costs, and defer costs for the transition to the Midwest Independent System Operator (MISO). In its application, Entergy requested approval of an increase in annual baserate revenues of approximately $\backslash$ 111.8 $million(laterloweredto$ \ $104.8$ million), proposed tariff schedules, including new riders to recover costs related to purchased-power capacity and renewable-energy credit requirements, requested final reconciliation of its fuel costs, and requested waivers to the rate-filing package requirements.

On July 6, 2012, the State Office of Administrative Hearings (SOAH) administrative law judges (ALJs) issued a proposal for decision in which they recommended an overall rate increase for Entergy of $\backslash$ 28.3 $millionresultinginatotalrevenuerequirementofapproximately$ \ $781$ million. The ALJs also recommended approving total fuel costs of approximately $\backslash$ 1.3$ billion. The ALJs did not recommend approving the renewable-energy credit rider and the Commission earlier removed the purchased-power capacity rider as an issue to be addressed in this docket. ^[1] On August 8, 2012, the ALJs filed corrections to the proposal for decision based on the exceptions and replies of the parties. ^[2] Except as discussed in this Order, the Commission adopts the proposal for decision, as corrected, including findings of fact and conclusions of law.

Parties filed motions for rehearing on September 25 and October 4, 2012 and filed replies to the motions for rehearing on October 15, 2012. The Commission considered the motions for

the ALJs. Accordingly, the Commission adds new finding of fact 65A to reflect the Commission's decision on this point.

E. Purchased-Power Capacity Expense

The ALJs rejected Entergy's request to recover $\backslash$ 31$ million more in purchased-power capacity costs than its actual test-year expenses because Entergy had failed to prove that the adjustment was known and measurable, ^[23] and because the request violated the matching principle. ^[24] Consequently, the ALJs recommended that Entergy's test-year expenses of $\backslash$ 245,432,884$ be used to set rates in this docket. ^[25]

Entergy pointed to an additional $\backslash$ 533,002$ of purchased-power capacity expenses that were properly included in Entergy's rate-filing package, but not provided for in the proposal for decision. ^[26] The Commission finds that an additional $\backslash$ 533,002 $($ \ $6,132$ for test-year expenses for Southwest Power Pool fees, $\backslash$ 654,082 $forToledoBendhydrofixed-charges,and$ -\ $127,212$ for an Entergy intra-system billing adjustment that were all recorded in FERC account 555) of purchased-power capacity costs were incurred during the test-year and should be added to the purchased-power capacity costs in Entergy's revenue requirement. The Commission modifies findings of fact 72 and 86 to reflect the inclusion of the additional $\backslash$ 533,002 $oftest-yearpurchased-powercapacitycosts,increasingthetotalamountto$ \ $245,965,886$ .

E. Labor Costs - Incentive Compensation

The ALJs found that \$6,196,037, representing Entergy's financially-based incentives paid in the test-year, should be removed from Entergy's O&;M expenses. ^[27] The ALJs agreed with Commission Staff and Cities that an additional reduction should be made to account for the FICA taxes that Entergy would have paid for those costs, ^[28] but did not include this reduction in a finding of fact.

The Commission agrees with the ALJs, but modifies finding of fact 133 to specifically include the decision that an additional reduction should be made to account for the FICA taxes Entergy would have paid on the disallowed financially-based incentive compensation. The Commission notes that this reduction for FICA taxes is reflected in the schedules attached to this Order. ^[29]

G. Affiliate Transactions

OPUC argued that Entergy's sales and marketing expenses exclusively benefit the larger commercial and industrial customers, but the majority of the sales, marketing, and customer service expenses are allocated to the operating companies based on customer counts. Therefore, the majority of these expenses are allocated to residential and small business customers. OPUC argued that it is inappropriate for residential and small business customers to pay for these expenses. ^[30] The ALJs did not adopt OPUC's position on this issue.

The Commission agrees with OPUC and reverses the proposal for decision regarding allocation of Entergy's sales and marketing expense and finds that $\backslash$ 2.086$ million of sales and marketing expense should be reallocated using direct assignment. The Commission has previously expressed its preference for direct assignment of affiliate expenses. ^[31] The Commission finds that the following amounts should be allocated based on a total-number-ofcustomers basis: (1) \ $46,490forProjectE10PCR56224-SalesandMarketing-EGSITexas;(2)$ \ $17,013$ for Project F3PCD10049 - Regulated Retail Systems O&;M and (3) \ $30,167forProjectF3PPMMALI2-MiddleMarketMkt.Development.Theremainder,\backslash$ 1,992,475, should be assigned to (1) General Service, (2) Large General Service and (3) Large Industrial Power Service. ^[32] The reallocation has the effect of increasing the revenue requirement allocated to the large business class customers and reduces the revenue requirement for small business and residential customers. New finding of fact 164A is added to reflect the proper allocation of these affiliate transactions.

1. FERC pronouncement AR-15 requires amortization over the same life as recommended based on standard life analysis. A standard life analysis determined that a five-year life was appropriate for general plant computer equipment (FERC Account 391.2). Therefore, a five year amortization for this account is reasonable and should be adopted.
2. ETI proposed adjustments to its test-year payroll costs to reflect: (a) changes to employee headcount levels at ETI and Entergy Services, Inc. (ESI); and (b) approved wage increases set to go into effect after the end of the test-year.
3. The proposed payroll adjustments are reasonable but should be updated to reflect the most recent available information on headcount levels as proposed by Commission Staff. In addition to adjusting payroll expense levels, the more recent headcount numbers should be used to adjust the level of payroll tax expense, benefits expense, and savings plan expense.
4. Staff has appropriately updated headcount levels to the most recent available data but errors made by Staff should be corrected. The corrections related to: (a) a double counting of three ETI and one ESI employee; (b) inadvertent use of the ETI benefits cost percentage in the calculation of ESI benefits costs; (c) an inappropriate reduction of savings plan costs when such costs were already included in the benefits percentage adjustments; and (d) corrections for full-time equivalents calculations. Staff's ETI headcount adjustment (AG-7) overstated operation and maintenance (O&;M) payroll reduction by $\backslash$ 224,217 $,andESIheadcountadjustment(AG-7)understatedO\&Mpayrollincreaseby$ \ $37,531$ .
5. ETI included $\backslash$ 14,187, / 44$ for incentive compensation expenses in its cost of service.
6. The compensation packages that ETI offers its employees include a base payroll amount, annual incentive programs, and long-term incentive programs. The majority of the compensation is for operational measures, but some is for financial measures.
7. Incentive compensation that is based on financial measures is of more immediate and predominant benefit to shareholders, whereas incentive compensation based on operational measures is of more immediate and predominant benefit to ratepayers.

1. Incentives to achieve operational measures are necessary and reasonable to provide utility services but those to achieve financial measures are not.
2. The $\backslash$ 5,376,97$ that was paid for long-term incentive programs was tied to financial measures and, therefore, should not be included in ETI's cost of service.
3. Of the amounts that were paid pursuant to the Executive Annual Incentive Plan, $\backslash$ 819,062$ was tied to financial measures and, therefore, should be disallowed.
4. In total, the amount of incentive compensation that should be disallowed is $\backslash$ 6,196,037$ because it was related to financial measures that are not reasonable and necessary for the provision of electric service. An additional reduction should be made to account for the FICA taxes ETI would have paid on the disallowed financially based incentive compensation.
5. The amount of incentive compensation that should be included in the cost of service is $\backslash$ 7,991,707$.
6. To attract and retain highly qualified employees, the Entergy companies provide a total package of compensation and benefits that is equivalent in scope and cost with what other comparable companies within the utility business and other industries provide for their employees.
7. When using a benchmark analysis to compare companies' levels of compensation, it is reasonable to view the market level of compensation as a range rather than a precise, single point.
8. ETI's base pay levels are at market.
9. ETI's benefits plan levels are within a reasonable range of market levels.
10. ETI's level of compensation and benefits expense is reasonable and necessary.
11. ETI provides non-qualified supplemental executive retirement plans for highly compensated individuals such as key managerial employees and executives that, because of limitations imposed under the Internal Revenue Code, would otherwise not receive retirement benefits on their annual compensation over $\backslash$ 245,000$ per year.

PUC DOCKET NO. 40443
SOAH DOCKET NO. 473-12-7519

APPLICATION OF SOUTHWESTERN ELECTRIC POWER COMPANY FOR AUTHORITY TO CHANGE RATES AND RECONCILE FUEL COSTS

PUBLIC UTILITY COMMISSION
$\S$
OF TEXAS

ORDER ON REHEARING

This Order addresses the application filed on July 27, 2012 by Southwestern Electric Power Company (SWEPCO) for authority to change its rates and reconcile its fuel costs. The primary contested issue regarding the proposed increase involves the portion of SWEPCO's share of the costs of the Turk coal plant in Hempstead, Arkansas that are allocated to Texas.

SWEPCO's application sought a total-company revenue requirement of $\backslash$ 1.033 $billion,exclusiveoffuelrevenues.TherequestedTexasretailrevenuerequirementexclusiveoffuelrevenueswas$ \ $329$ million, which reflected an increase in annual Texas retail revenues of $\backslash$ 83.37$ million over its adjusted test-year revenues. ^[1] The increase primarily consists of the inclusion of the newly constructed Turk coal plant and Stall gas plant. For the fuel reconciliation period from April 1, 2009 through December 31, 2011, SWEPCO sought to reconcile a cumulative fuel under-recovery balance of $\backslash$ 3,936,492$, including interest, and proposed no surcharge. SWEPCO's reconciliation included proposed revisions to Dolet Hills Lignite Company benchmark price.

The State Office of Administrative Hearings' administrative law judges (ALJs) issued a proposal for decision on May 20, 2013. The ALJs' recommended approval of the application, with certain adjustments. Regarding the Turk plant, the ALJs recommended the disallowance of all Turk costs over approximately $\backslash$ 934 $millionasbeingimprudentlyincurredincontinuingconstructionafterJune2010.TheALJsfurtherrecommendedthatapproximately$ \ $260$ million be allowed for the estimated costs to retrofit the Welsh Unit 2 coal plant that SWEPCO should have undertaken instead of completing the Turk plant. However, the ALJs recommended in the

J. Fuel Reconciliation

SWEPCO requested a good cause exception to recover consumables and allowances as fuel on a going-forward basis. The Commission is persuaded by the arguments of Commission Staff regarding this issue and rejects the ALJs' recommendation to disallow the request. Accordingly, finding of fact 322 is modified and conclusion of law 47 is modified.

K. Miscellaneous

Corrections to the findings of fact and conclusions of law are necessary to appropriately reflect the Commission's determinations regarding the following issues.

First, the findings regarding the unique aspects of SWEPCO's overall compensation program do not accurately reflect the ALJs' recommendation that the Commission adopts. Therefore, the Commission modifies finding of fact 147 to clarify that the portion of SWEPCO's annual and long-term incentive payments that are capitalized and that are financially based are excluded from SWEPCO's rate base because the benefits of such payments inure most immediately and predominantly to SWEPCO's shareholders, rather than its electric customers. Also, an error in finding of fact 220 is corrected to reflect that of SWEPCO's annual incentive compensation of $\backslash$ 10,728,117, \ $3,523,732$ is disallowed as financial goals. These same findings are clarified to reflect that the part of the long-term incentive compensation program that includes performance units is disallowed as being based on financial measures, and the part that includes restricted stock units is allowed - $\backslash$ 3,130,757 $isdisallowedfromthe$ \ $5,175,829$ in long-term incentive compensation.

Further, in accordance with other corrections noted by the ALJs in their July 2, 2013 letter, the amount of credit line fees is corrected in finding of fact 186. The Commission also modified finding of fact 242 to reflect its clarification that the test-year expenses for injuries and damages exceeds the average of the expense in the three previous years, and the amount should be disallowed completely and not amortized.

Also, the ordering provisions reflect the ALJs clarification that SWEPCO should provide a calculation in its compliance filing to include 12 months' weather normalized residential sales based on a 10-year normal to reflect the ALJs' recommendation adopted by the Commission.

General Plant

1. Asbestos removal in 1996 and the sale of an office building in 2004 should be removed from the removal cost and salvage data for FERC Account 390-General Plant for 1984-2011 upon which the net salvage rate for the account should be based. The net salvage rate of negative $3\%$ resulting from this modification is reasonable and reduces SWEPCO's initially requested depreciation expense by $\backslash$ 97,594 $onatotalCompanybasisand$ \ $32,938$ on a Texas jurisdictional basis.

Depreciation Reserve

1. The use of the remaining life depreciation method to recover differences between theoretical and actual depreciation reserves is the most appropriate method.
2. It is reasonable for SWEPCO to calculate depreciation reserve allocations on a straight-line basis over the remaining, expected useful life of the item or facility.

Payroll

1. SWEPCO made two adjustments to its test-year payroll. The Company updated payroll costs by annualizing the base payroll to the salary rates in effect at the end of the test year and by recognizing the effect of the merit and general increases that were awarded in 2012.
2. Because these payroll increases were awarded in 2012, they represent appropriate known and measurable adjustments to test-year expenses.
3. SWEPCO double-counted the Turk plant payroll by including Turk plant employees in the pro forma payroll O&;M as well as in the post-test-year adjustment.
4. SWEPCO's labor costs should be disallowed by the sum of $\backslash$ 197,688 $and$ \ $50,932$ , or $\backslash$ 248,620$.

Incentive Compensation

1. SWEPCO sought to recover in rate base a total amount of $\backslash$ 10,728,117 $paidasannualincentivecompensationtoitsemployeesand$ \ $5,175,829$ paid for long-term incentive compensation.

1. The PUC permits a utility to recover in its base rate incentives that are designed to achieve "operational measures" and that are necessary and reasonable to provide utility services, but not incentive programs that are designed to achieve "financial measures."
2. Operational measures are those designed to encourage a utility's employees to meet goals and standards relating to the efficient operation of the utility, a benefit to shareholders and ratepayers alike.
3. Financial measures are those designed to encourage employees to achieve financial targets, a benefit primarily to shareholders.
4. SWEPCO's "Regulatory" "Strategic" and "Margin Generating" annual incentive goals relate to financial measures.
5. SWEPCO's long-term incentive awards in the form of performance units relate to financial measures.
6. Of SWEPCO's annual incentive compensation of $\backslash$ 10,728,117, \ $3,523,732$ should be disallowed as financial goals. Of SWEPCO's long-term compensation, all but $\backslash$ 2,045,072$ of the total should be disallowed as financial goals.

Executive Perquisites

1. The $\backslash$ 16,350$ related to executive perquisites should not be included in rates because they provide no benefit to ratepayers and are not reasonable or necessary for the provision of electric service.

Relocation

1. SWEPCO's proposed relocation expense, in the amount of $\backslash$ 574,588$, is reasonable and necessary.

Pensions

1. It is reasonable to base pension expense in SWEPCO's cost of service upon the cost of $\backslash$ 8,306,420$ on a total Company basis calculated in the 2012 actuarial report prepared in accordance with FAS 87.

Appendix D

1. CenterPoint's Expenses from Docket No. 38339

a. From PUC Docket No. 38339, Application of CenterPoint Energy

Houston Electric, LLC for Authority to Change Rates: Dec. 3, 2010, Proposal for Decision (pp. 65-68) (recommending disallowance of CenterPoint's "long-term" incentive compensation based upon "clear line of Commission precedent" that it is financially based)

Jun. 23, 2011 Order on Rehearing, pp. 1 &; 22 (FOFs 81-83) (allowing CenterPoint to recover "short-term" incentive compensation but disallowing "long-term" incentive compensation) b. From PUC Docket No. 39127, Requests for Rate Case Expenses Severed from Docket No. 38339 (Application of CenterPoint Energy Houston Electric, LLC for Authority to Change Rates)

Jun. 6, 2011 Order (FOFs 6, 12, &; 20) (awarding CenterPoint's expenses of prosecuting Docket No. 38339; no mention of disallowance for unsuccessful attempt to recover incentive compensation in rates) 2. AEP Texas Central Company's Expenses from Docket No. 33309 a. From PUC Docket No. 33309, Application of AEP TCC for Authority to Change Rates

Mar. 4, 2008 Order on Rehearing, pp. 1 &; 12 (FOF 82) (disallowing AEP Texas Central Company's "annual and long-term incentive compensation related to financial incentives") b. From PUC Docket No. 34301, Proceeding to Consider Rate Case Expenses Severed from Docket No. 33310 and Docket No. 33309

May 23, 2008 Final Order (FOFs 18, 20, and 21)

(approving AEP Texas Central Company's rate case expenses; no mention of disallowance for unsuccessful attempt to recover incentive compensation in rates)

3. AEP Texas Central Company's Expenses from Docket No. 28840

a. From PUC Docket No. 28840, Application of AEP Texas Central Company for Authority to Change Rates

Aug. 15, 2005 Final Order, pp. 1 &; 35 (FOFs 164-70) (approving $34\%$ of company's incentive compensation as tied to "operational" measures, but disallowing the rest as tied to "financial measures ... of more immediate benefit to shareholders") b. From PUC Docket No. 31433, Proceeding to Consider Rate Case Expenses Severed from Docket No. 28840

Mar. 3, 2006 Order (FOF 26) (approving AEP Texas Central Company's rate case expenses; no mention of disallowance for unsuccessful attempt to recover incentive compensation in rates)

SOAH DOCKET NO. 473-10-5001
PUC DOCKET NO. 38339

APPLICATION OF CENTERPOINT ELECTRIC DELIVERY COMPANY, LLC, FOR AUTHORITY TO CHANGE RATES

BEFORE THE STATE OFFICE $\S$ $\frac{\text{OF}}{\text{ADMINISTRATIVE HEARINGS}}$

PROPOSAL FOR DECISION

I. INTRODUCTION [GERMANE TO PRELIMINARY ORDER ISSUE NO. 1]

CenterPoint Energy Houston Electric, LLC (CenterPoint, CEHE, or Company) is an investor-owned electric utility within the Electric Reliability Council of Texas (ERCOT) system. CenterPoint provides transmission and distribution (T&;D) electric services in a roughly 5,000 square-mile territory of the Southeast Coastal region of Texas, including the Houston area. CenterPoint is one of the largest T&;D utilities in Texas. It does not sell electricity or purchase electricity for resale, but instead provides transmission service to other electricity distribution companies, cooperatives, and municipalities, and distribution services to retail electric providers (REP). Although CenterPoint does not directly serve residential or industrial customers, the utility delivers electricity to over two million meters in 95 cities in Texas.

Pursuant to the Settlement Agreement reached as part of its 2006 rate case in Docket No. 32093, ^[1] CenterPoint filed a 2009 Earnings Monitoring Report (EMR) in March 2010 for review by the Public Utility Commission of Texas (Commission or PUC) staff (Staff), the City of Houston, and the Gulf Coast Coalition of Cities (GCCC). The 2009 EMR also showed that CenterPoint earned a weather-adjusted return on equity (ROE) of 9.81 percent. The 2009 EMR showed that CenterPoint earned a non-weather-adjusted ROE of 11.13 percent. On June 30, 2010, CenterPoint filed its Application with the Commission requesting authorization to increase its T&;D rates and a reconciliation of costs incurred related to its Advanced Metering System (AMS) deployment. CenterPoint filed this Application at the directive of Staff, the City of Houston, and GCCC, who

in an annual payroll expense of $\backslash$ 119,652,000 $,representingadecreaseof$ \ $3,342,000$ to CenterPoint's payroll expense. ^[257]

CenterPoint also requested an adjustment to benefit costs of $\backslash$ 1,727,000$ to reflect the post-test year adjustments made to salaries and wages. ^[258] Because this expense is a function of the amount of the requested increase to salaries and wages, Ms. Jacobs argued that it should be reduced by the same percentage as the reduction to the adjustment to salaries and wages. Ms. Jacobs recommended a decrease of 67.20 percent to CenterPoint's requested increase to payroll expense. Therefore, according to Ms. Jacobs, it is proper to adjust FERC Account 926 by the same 67.20 percent. This results in a decrease of $\backslash$ 1,160,544$ to CenterPoint's request. ^[259]

The ALJs are persuaded that Ms. Jacob's analysis is the correct one to apply in this instance. It properly excludes CenterPoint's estimated general wage increase of 3 percent for union employees, which is not a known and measurable adjustment, and accounts for changes in employee departures and additions. Similarly, it makes the appropriate adjustment to benefits, which are a function of the amount of the requested increase to salaries and wages and should, therefore, be reduced by the same percentage as the reduction to the adjustment to salaries and wages.

2. Incentive Compensation

CenterPoint is requesting $\backslash$ 5,204$ million in total annual long-term incentive (LTI) expense. ^[260] CenterPoint also is seeking recovery of costs related to its short-term incentive (STI) plan. CenterPoint contends that its STI and LTI plans are reasonable and necessary components of a total compensation package required to recruit, retain, and motivate employees. ^[261] According to

CenterPoint, these forms of compensation are the norm in the utility industry, without which CenterPoint cannot attract and maintain a qualified and skilled workforce. ^[262]

(a) LTI Expenses

OPC witness June Dively, GCCC witness Lane Kollen, and Staff witness Mary Jacobs all contend that the Company should not be allowed to recovery its LTI expense because of its use of financial measures. ^[263] According to CenterPoint, however, LTI, along with base pay and STI, helps make up the non-benefits portion of the Company's competitive compensation package that employees may compare to other employees in making employment decisions. CenterPoint stated that LTI ensures that Company employees are focused on the Company's health. Improved performance on corporate measures that increase stock price can lower a company's cost of capital, which, according to CenterPoint, results in lower financing costs for customers. ^[264]

The core of the intervenors' argument is that CenterPoint's LTI (and, in the case of TIEC, over half of its STI) violates Commission precedent because it is tied to financial measures. The intervenors argue that substantial precedent exists requiring a disallowance of CenterPoint's financial-based incentive compensation. In Docket No. 28840, the Commission adopted the ALIs' findings that the portions of American Electric Power Company's (AEP) incentive compensation program that were tied to operational performance measures are recoverable through rates but that portions tied to financial performance measures are not. ^[265] The ALIs examined AEP's "CIP" incentive compensation program and determined that 66 percent of the program was tied to financial

measures. ^[266] The Commission agreed with the ALJs that these measures "are of more immediate benefit to shareholders" and are not "necessary and reasonable to provide T&;D utility service."267

In Docket Nos. 33309 and 35717 the Commission reaffirmed the incentive compensation policy it set out in Docket No. 28840. In Docket No. 33309, the Commission found: "TCC's inclusion of annual and long-term incentive compensation related to financial incentives in cost of service is unreasonable because it is not necessary for the provision of T&;D utility services."268 In Docket No. 35717, the Commission similarly found that "[o]f the amount Oncor requested for incentive compensation, $\backslash$ 5,082,326$ should be removed because it is related to financial measures that are unreasonable and unnecessary for the provision of T&;D utility services. ^[269]

Although CenterPoint points to a recent Railroad Commission of Texas decision holding the incentive compensation should be recoverable, ^[270] that decision does not overcome the clear line of Commission precedent. Based on the evidence presented and Commission precedent, the ALJs recommend that the Commission exclude CenterPoint's LTI from recoverable expenses.

(b) STI Expenses

CenterPoint witness Woods states that the corporate and financial goals of STI are directly tied to metrics such as customer service and safety. The financial goals provide economic incentives for employees to conduct their business more effectively, manage expenses, and improve operating income. The Company's operational goals encourage safe and efficient operations, as well as

enhanced customer service. ^[271] In its initial brief, CenterPoint stated that no party disputes the Company's STI costs, but in its initial brief, TIEC contended that although some performance measures in CenterPoint's STI plan are operational, others are financial. Specifically, TIEC pointed to the goals "Core Operating Income" and "Controllable Expenses," which it claimed CenterPoint admitted were financial-based measures. ^[272] According to TIEC, these financial measures each represent 27 percent (collectively, 54 percent) of the overall goals of CenterPoint's STI.

CenterPoint argues that no witness in this proceeding supports TIEC's new position. According to CenterPoint, the evidence provided by the Company proving that STI is reasonable and necessary is undisputed in the record. ^[273] TIEC presented no evidence as to the nature of the goals it contended constituted impermissible financial goals. As a consequence, the ALJs find that TIEC's challenge to CenterPoint's inclusion of STI expenses fails and, therefore, recommend that the Commission find that CenterPoint's STI expenses are recoverable.

3. Employee Benefits

CenterPoint witness Woods states that CNP's benefits philosophy is to provide a comprehensive set of benefits to meet its employees' welfare and financial security needs in an affordable and efficient manner with the overall value targeted at the midpoint of the marketplace. According to Mr. Woods, CNP does this through a "one-company" approach with the objective of offering a common set of benefits to all its employees. ^[274] No party challenges the Company's benefits philosophy or alleges that CenterPoint's benefits package is excessive or unreasonable. Instead, OPC witness Dively recommends disallowances of $\backslash$ 1,082,000 $indeferredcompensationexpensesand$ \ $1,421,000$ in supplemental contract expenses based on the assertion that she cannot identify evidence or testimony on the reasonableness or necessity of these expenses. CenterPoint noted that Ms. Dively does not affirmatively contend that these types of expenses are unreasonable or unnecessary and that, when given the opportunity to conduct discovery on these expenses,

PUC DOCKET NO. 38339
SOAH DOCKET NO. 473-10-5001

This Order addresses the application of CenterPoint Electric Delivery Company, LLC for authority to change its rates. On June 30, 2010, CenterPoint filed its application with the Public Utility Commission of Texas requesting authority to increase its transmission and distribution rates and to reconcile costs related to its advanced metering system (AMS) deployment. CenterPoint originally requested a total net increase of $\backslash$ 110 $million:$ \ $18$ million represented the net increase associated with transmission service and $\backslash$ 92 $millionassociatedwithretaildeliveryservice.CenterPointrequestedarateofreturnoninvestmentof$ 9.0 \% $,basedonaproposedcapitalstructurehaving$ 50-50 $ratioofdebttoequity;a$ 6.74 \% $costofdebt;andareturnonequityof$ 11.25 \%$.

On December 3, 2010, the State Office of Administrative Hearings (SOAH) administrative law judges (ALJs) issued a proposal for decision in which they recommended an overall rate increase for CenterPoint of $\backslash$ 21.483$ million. ^[1] For the reasons discussed in this Order, the Commission adopts in part and rejects in part the proposal for decision, including findings of fact and conclusions of law, and determines that CenterPoint's appropriate systemwide adjusted rates will lead to a retail revenue increase of $\backslash$ 14.65 $millionandanoverallrevenuerequirementincreaseof$ \ $2.4$ million for both retail and wholesale combined. ^[2]

75A. CenterPoint's overall rate of return is as follows:

| COMPONENT | CAPITAL
STRUCTURE | COST OF CAPITAL | Weighted AVG
COST OF CAPITAL | | :--: | :-- | :-- | :-- | | LONG-TERM DEBT | $55.00\%$ | $6.74\%$ | $3.71\%$ | | COMMON EQUITY | $45.00\%$ | $10.00\%$ | $4.50\%$ | | TOTAL | $100.00\%$ | | $8.21\%$ |

Cost of Service

1. CenterPoint's test-year total transmission operations and maintenance (O&;M) expense in FERC accounts 560 through 573 as adjusted by the Commission in the amount of $\backslash$ 234.721$ million is reasonable and necessary.
2. CenterPoint's test-year total-distribution O&;M expense in FERC accounts 580 through 598 as adjusted by the Commission in the amount of $\backslash$ 188.132$ million is reasonable and necessary.
3. CenterPoint's proposed $\backslash$ 7.15$ million O&;M expenditure related to storm hardening is reasonable and necessary.
4. CenterPoint's requested total-customer-services-and-information expense of $\backslash$ 35.54$ million is reasonable and necessary.
5. CenterPoint's Commission-adjusted administrative-and-general-expense request of $\backslash$ 178.178$ million is reasonable and necessary.
6. The evidence demonstrates that CenterPoint's short-term incentive compensation plan (STI) is a reasonable and necessary component of a total compensation package required to recruit, retain, and motivate employees.
7. CenterPoint's long-term incentive-compensation plan (LTI) is not a reasonable and necessary component of CenterPoint's total compensation package.
8. The corporate and financial goals of STI are directly tied to metrics such as customer service and safety.

DOCKET NO. 39127

ORDER

This Order addresses the rate-case expenses CenterPoint Energy Houston Electric, LLC, the City of Houston and the Houston Coalition of Cities (COH/HCOC), Gulf Coast Coalition of Cities (GCCC), and Texas Coast Coalition of Cities (TCUC) incurred in connection with their participation in Docket No. 38339, Application of CenterPoint Energy Houston Electric, LLC for Authority to Change Rates.

As set forth in this Order, the Public Utility Commission of Texas determines that ratecase expenses incurred in Docket No. 38339 in the total amount of $\backslash$ 7,748,902.39$ are reasonable. This Order authorizes CenterPoint to implement a surcharge over a three-year period to recover this amount.

The Commission adopts the following findings of fact and conclusions of law:

I. Findings of Fact

1. CenterPoint is an investor-owned electric utility operating within the Electric Reliability Council of Texas.
2. On June 30, 2010, CenterPoint filed with the Commission a rate-case application in Docket No. 38339, Application of CenterPoint Energy Houston Electric, LLC for Authority to Change Rates.
3. On June 30, 2010, the Commission referred CenterPoint's application in Docket No. 38339 to the State Office of Administrative Hearings (SOAH) to conduct an evidentiary hearing on the merits and to issue a proposal for decision.
4. On December 2, 2010 the SOAH administrative law judges (ALJs) issued their proposal for decision in Docket No. 38339.

1. The proposal for decision approved actual CenterPoint rate-case expenses in the amount of $\backslash$ 3,081,759.38$ based on the following evidence:

CEHE Ex. 33 CEHE Ex. 33A CEHE Ex. 33B CEHE Ex. 34 direct testimony of Jeffrey S. Andrien supplemental direct testimony of Jeffrey S. Andrien second supplemental direct testimony of Jeffrey S. Andrien direct testimony of Daniel K. Hedges supplemental direct testimony of Daniel K. Hedges 6. The $\backslash$ 3,081,759.38 $inactualrate-caseexpensesforCenterPointapprovedintheproposalfordecisionreflectedareductionintheamountof$ \ $104,743.96$ proposed by Commission Staff and an additional reduction in the amount of $\backslash$ 250,000$ proposed by counsel for CenterPoint at the hearing on the merits. 7. The proposal for decision approved actual and estimated $\mathrm{C}\mathrm{O}\mathrm{H}/\mathrm{H}\mathrm{C}\mathrm{O}\mathrm{C}$ rate-case expenses in the amount of $\backslash$ 1,065,734.00$ based on the following evidence:

COH/HCOC Ex. 2 direct testimony of Brett Perlman COH/HCOC Ex. 4 direct testimony of Amalija Hodgins 8. The proposal for decision approved actual and estimated GCCC rate case expenses in the amount of $\backslash$ 634,334.83$ based on the following evidence:

GCCC Ex. 1 GCCC Ex. 2 direct testimony of Lane Kollen direct testimony of Clarence Johnson 9. The proposal for decision approved actual and estimated TCUC rate-case expenses in the amount of $\backslash$ 248,351.35$ based on the following evidence:

TCUC Ex. 2 direct testimony of James Brazell 10. No party filed exceptions to the proposal for decision's findings concerning rate-case expenses. 11. On January 6, 2011, Commission Staff, COH/HCOC, GCCC and TCUC filed a stipulation in Docket No. 38339 seeking approval of the following actual rate-case expenses: (a) for $\mathrm{C}\mathrm{O}\mathrm{H}/\mathrm{H}\mathrm{C}\mathrm{O}\mathrm{C},\backslash$ 936,752.14 $inrecoverablerate-caseexpensesthroughNovember30,2010;(b)forGCCC,$ \ $285,981.71$ in recoverable rate-case expenses through December 20, 2010; and (c) for TCUC, $\backslash$ 123,912.69$ in recoverable rate-case expenses through December 22, 2010.

1. On January 7, 2011, CenterPoint filed supplemental rate-case expense documentation in Docket No. 38339, supporting an additional $\backslash$ 2,752,888.99 $inactualrate-caseexpensesincurredthroughNovember2010,foratotalof$ \ $5,834,648.37$ in actual rate-case expenses through November 30, 2010. The $\backslash$ 2,752,888.99 $inadditionalrate-caseexpensesincurredthroughNovember2010isnetofa$ \ $179,902.56$ disallowance proposed by counsel for CenterPoint.
2. At the Commission's February 3, 2011 open meeting, the Commissioners decided to sever rate-case expenses from Docket No. 38339 for consideration in this docket.
3. On February 28, 2011, the Commission administrative law judge issued order No. 17 in Docket No. 38339 (order No. 1 in this docket) severing the issue of rate-case expenses from Docket No. 38339 and establishing this case, Docket No. 39127.
4. Order No. 17 in Docket No. 38339 (Order No. 1 in this docket) made the parties to Docket No. 38339 also parties to this docket.
5. Order No. 2 in this docket set a deadline of March 11, 2011 for any party to request a hearing on the rate-case expenses incurred in Docket No. 38339.
6. No party requested a hearing and all parties either agree to or do not oppose this Order.
7. On March 17, 2011, pursuant to Order No. 2 in this docket, Commission Staff filed a recommendation on the supplemental rate-case expense evidence submitted by CenterPoint on January 7, 2011 in Docket No. 38339. Staff recommended approval of the additional amount of actual expenses requested by CenterPoint.
8. On March 17, 2011, the parties submitted an unopposed request that the testimony, affidavits, and supporting documentation identified in attachment A to this Order be admitted into evidence in this proceeding.

CenterPoint incurred reasonable rate-case expenses for Docket No. 38339 through November 30, 2010 in the amount of $\backslash$ 5,834,648.37$. 21. $\mathrm{C}\mathrm{O}\mathrm{H}/\mathrm{H}\mathrm{C}\mathrm{O}\mathrm{C}$ incurred reasonable rate-case expenses for Docket No. 38339 through November 30, 2010 in the amount of $\backslash$ 1,322,943.10$.

PUC DOCKET NO. 33309 SOAH DOCKET NO. 473-07-0833

APPLICATION OF AEP TEXAS CENTRAL COMPANY FOR AUTHORITY TO CHANGE RATES

$\&\text{E PUBLIC UTILITY COMMISSION}\&\text{E}\&\text{OF TEXAS}$

ORDER ON REHEARING

On November 9, 2006, AEP Texas Central Company (TCC) filed an application for authority to change rates pursuant to PURA, ^[1] Chapter 36, requesting an increase in base rates that would produce an annual base revenue increase of $\backslash$ 62,709,174 $.Duringthecourseofthisproceeding,TCCreducedthisamounttoapproximately$ \ $49,952,000{.}^2$ TCC also seeks to terminate the merger savings and rate reduction riders implemented in Docket No. 19365, ^[3] further increasing its revenues by $\backslash$ 19,988,359 $annually.Therefore,thetotalrevenueincreasesoughtbyTCCinthisproceedingis$ \ $69,940,359$ .

The administrative law judges (ALJs) filed a proposal for decision (PFD) on August 30, 2007. In their PFD, the ALJs recommend that the Commission approve TCC's application, including termination of the merger savings and rate reduction riders, subject to the adjustments recommended in the Proposal for Decision (PFD). The recommendations reduce TCC's adjusted test year total revenue requirements from $\backslash$ 581,127,359 $to$ \ $531,123,478$ , a reduction of $\backslash$ 50,004,479$. TCC identified several number-run adjustments required to implement the ALJs' decision. ^[4] The Commission ordered Commission Staff to incorporate TCC's number-run corrections, which resulted

1. TCC's adjustment to Allocator 70, Non-Electric Other Accounts Receivable, is reasonable.
2. TCC's inclusion of annual and long-term incentive compensation related to financial incentives in cost of service is unreasonable because it is not necessary for the provision of T&;D utility services.
3. TCC reasonably determined group life insurance expense using an annualized June 2006 amount, with proper adjustments to cost of service to eliminate the portion of capitalized costs.
4. TCC reasonably determined savings plan (401k) expense using an annualized June 2006 amount, with proper adjustments to cost of service to eliminate the portion of capitalized costs, as adjusted in its rebuttal testimony.
5. TCC's pension expense of $\backslash$ 1,627,376 $,whichreflectsareductionof$ \ $456,000$ for negative pension expense under SFAS 87 related to former generation employees, is reasonable and necessary.
6. TCC's requested adjusted test-year amount of $\backslash$ 5,953,937 $forpostretirementbenefitsunderSFAS106,whichincluded$ \ $886,264$ in SFAS 106 transition adjustment amortization related to former generation employees, is reasonable.
7. Additional SFAS 106 postretirement benefit costs of $\backslash$ 564,736$ related to the former generation employees should be included in cost of service.
8. Total SFAS 106 postretirement benefit costs of $\backslash$ 6,518,673$ are reasonable and necessary.
9. A catastrophic property damage loss self-insurance program with an annual accrual of $\backslash$ 1,300,000 $andatargetreserveamountof$ \ $13$ million is in the public interest.
10. TCC's distribution O&;M expenses, with the removal of the payment to the Public Utilities Board of Brownsville from distribution station maintenance expense, are reasonable and necessary.
11. TCC's transmission O&;M expenses are reasonable and necessary.

DOCKET NO. 34301

ORDER

This Order addresses the recoverable rate-case expenses of AEP Texas Central Company (TCC), AEP Texas North Company (TNC), Cities served by TCC (TCC Cities) ^[1] and Cities served by TNC (TNC Cities) ^[2] in connection with their participation in TCC Docket No. 33309 and TNC Docket No. $33310{}^3$

As set forth in this Order, the Public Utility Commission of Texas (Commission) determines, as to Docket No. 33309, that TCC's reasonable and necessary rate case expenses through January 31, 2008, are $\backslash$ 4,214,935$ (including rate case expenses incurred in other Commission proceedings and addressed in Docket No. 33309) ^[4] and that TCC Cities' reasonable

1. On March 28, 2008, TCC, TCC Cities, TNC and TNC Cities filed their record designations and supporting documentation for their requested rate case expenses, consisting of invoices, timesheets, receipts, etc. TCC, TCC Cities, TNC, and TNC Cities further supported their requests by affidavits supporting the reasonableness and necessity of their rate case expenses.
2. On April 30, 2008, Commission Staff filed its recommendation that TCC's, TCC Cities', TNC's and TNC Cities' rate case expenses be approved. No party filed a statement of position opposing TCC's, TNC's, or Cities' requested rate case expense recovery. No party requested a hearing. The parties have submitted an agreed proposed order providing for full recovery of TCC's, TNC's, and Cities' requested rate case expense via an agreed three year surcharge to be collected by TCC and TNC.
3. On May 2, 2008, TCC and TNC filed proposed tariffs, with supporting calculations, (appended to this Order in "Attachment A") for recovery of the requested rate case expenses via a three year surcharge, consistent with the level of rate case expenses reviewed and approved by the Staff.
4. In these circumstances, the Commission finds that this proceeding is suitable for informal disposition.

TCC's Rate Case Expenses

1. TCC seeks recovery of $\backslash$ 2,912,132 $inrecoverableratecaseexpensesforDocketNo.33309throughJanuary31,2008.TCCfurtherseeksrecoveryof$ \ $1,302,803$ in recoverable rate case expenses incurred through January 2008 in other Commission proceedings, for a total recoverable amount of $\backslash$ 4,214,935$.
2. TCC's reasonable and necessary rate case expenses for Docket No. 33309 and the other Commission proceedings through January 2008 are $\backslash$ 4,214,935$.

TCC Cities' Rate Case Expenses

1. TCC Cities requested rate case expenses for Docket No. 33309 in the amount of $\backslash$ 1,131,709 $.Thisamountconsistedof$ \ $951,709$ in expenses actually incurred through February 29, 2008 and $\backslash$ 180,000$ in estimated expenses including appeals.

1. TCC Cities' reasonable and necessary rate case expenses for Docket No. 33309 are $\backslash$ 1,131,709$.

TCC Rate Case Expense Surcharge

1. Based on Finding of Fact Nos. 18 and 20, the aggregate amount of rate case expenses found reasonable and necessary for TCC and TCC Cities is $\backslash$ 5,346,644$.
2. It is appropriate for TCC to surcharge the aggregate rate case expenses found reasonable and necessary in Finding of Fact No. 21 to be collected from all customers over three years.
3. The proposed surcharge tariff filed by TCC on May 2, 2008, as shown in "Attachment A" to this Order, is just and reasonable for the purpose of collecting the rate case expenses authorized by this Order from all of TCC's customers over a period of three years.

TNC Rate Case Expenses

1. TNC seeks recovery of $\backslash$ 723,580$ in recoverable rate case expenses for TNC Docket No. 33310 through January 2008.
2. The rate case expenses included by TNC in its April 3, 2007, rate case expense filing in Docket No. 33310 were determined reasonable and necessary by the settlement of that proceeding.
3. TNC's reasonable and necessary rate case expenses for Docket No. 33310 through January 2008 are $\backslash$ 723,580$.

TNC Cities Rate Case Expenses

1. TNC Cities requested rate case expenses for Docket No. 33310 in the amount of $\backslash$ 338,931 $.Thisamountconsistedof$ \ $328,931$ in expenses actually incurred through February 29, 2008, and $\backslash$ 10,000$ in estimated expenses.
2. The rate case expenses included by TNC Cities along with their direct testimony in Docket No. 33310 were determined reasonable and necessary by the settlement of Docket No. 33310 .

PUC DOCKET NO. 28840
SOAH DOCKET NO. 473-04-1033

APPLICATION OF AEP TEXAS CENTRAL COMPANY FOR AUTHORITY TO CHANGE RATES

$\S$ PUBLIC UTILITY COMMISSION
$\S$
OF TEXAS

ORDER

This Order addresses the application of AEP Texas Central Company (TCC) for authority to change its rates. TCC initially filed its application on November 3, 2003, seeking approval of a revenue requirement of $\backslash$ 519.9 $million.ForthereasonsdiscussedinthisOrder,theCommissiondeterminesthatTC{C}^{\prime }sappropriaterevenuerequirementis$ \ $443,607,238$ . The reduction reflects an agreed disallowance of $\backslash$ 10.5 $millioninaffiliateexpenses,aswellasadditionaldisallowancesasdeterminedbytheCommission.Asallocated,thedistributionportionofTC{C}^{\prime }scurrentrevenuerequirementwillincreaseby$ \ $5.3$ million, whereas the wholesale transmission portion will decrease by $\backslash$ 14.1$ million.

As discussed in this Order, the Commission adopts in part and rejects in part the proposal for decision (PFD) and remand PFD issued by the State Office of Administrative Hearings (SOAH) administrative law judges (ALJs) in this proceeding, including the findings of fact and conclusions of law.

I. Procedural History

The Commission referred this case to SOAH on November 4, 2003, and SOAH issued its initial PFD on July 1, 2004. The Commission issued an Order on Remand on July 28, 2004, directing SOAH to consider the appropriate amount for a consolidated taxsavings adjustment, which was not calculated in the initial PFD. On August 25, 2004, the Commission issued a Second Order on Remand, directing SOAH to provide further evaluation regarding the following issues: affiliate costs, distribution administrative and general (A&;G) expense adjustments, depreciation expense, net salvage, special meter reading fee, connect fee and service reconnect fee, and priority disconnect fee. SOAH

F. Salary Adjustments and Related Taxes

1. Of the $\backslash$ 679,344 $insalaryadjustmentsandrelatedtaxesproposedbytheApplicant,$ \ $508,761$ was proposed for post-test-year raises for staff.

G. Incentive Compensation

1. The compensation packages that the Company offers its employees include a base payroll amount as well as an incentive-compensation portion. Both portions are part of an overall compensation package that is designed to be competitive in the marketplace and allow the Company to attract and retain qualified individuals as employees.
2. The Company requests to include the test-year level of incentive-compensation expense of $\backslash$ 4,422,937$ in cost of service.
3. The Company's incentives are set through two types of performance measures, financial and operational.
4. Thirty-four percent of the incentive-compensation expenses are for operational measures.
5. To the extent that the Applicant's employees are given an incentive, their rewards are made with respect to the overall performance of the holding company.
6. The financial measures are of more immediate benefit to shareholders, and the operating measures are of more immediate benefit to ratepayers.
7. Incentives to achieve operational measures are necessary and reasonable to provide T&;D utility services, but those to achieve financial measures are not.

H. Pension Expense

1. The Company proposes to increase test-year pension expenses by $\backslash$ 7,264,784 $from$ \ $30,812$ .

PROCEEDING TO CONSIDER RATE CASE EXPENSES SEVERED FROM DOCKET NO. 28840 (APPLICATION OF AEP TEXAS CENTRAL COMPANY FOR AUTHORITY TO CHANGE RATES)

ORDER

This Order addresses the recoverable rate-case expenses of AEP Texas Central Company (AEP Central) and of Cities ^[1] in connection with their participation in Docket No. 28840. ^[2] As set forth in this Order, the Public Utility Commission of Texas (Commission) determines that AEP Central's recoverable rate case expenses through June 2005 are $\backslash$ 2,938,130 $andthatCitie{s}^{\prime }recoverableratecaseexpensesare$ \ $1,350,149$ . As discussed herein, the Cities' expenses relating to witness Sarah Goodfriend have been reduced by one-half as recommended by the State Office of Administrative Hearings (SOAH) Administrative Law Judges in their Proposal for Decision (PFD) in Docket No. 28840. ^[3] This Order finds that $\backslash$ 4,288,429$ in rate-case expenses incurred by AEP Central and Cities is reasonable and necessary and authorizes AEP Central to implement a surcharge over three years to recover this amount.

I. Procedural History

On November 3, 2003, AEP Central filed an application seeking a change in its rates. This application was assigned Docket No. 28840, and the Commission referred the case to SOAH on November 4, 2003. SOAH issued its initial PFD in Docket No. 28840 on July 1, 2004, which contained certain findings on rate case expenses. In July and August 2004, the Commission issued two orders on remand in Docket No 28840 directing SOAH to consider further and provide further evaluation of certain specified issues, none of which involved rate case expenses. On November

1. In its filing of October 28, 2005, AEP Central indicated that it did not contest Staff's recommendation to disallow $\backslash$ 24,604$ of AEP Central's requested rate case expenses.
2. AEP Central's reasonable and necessary rate case expenses for Docket No. 28840 as of June 2005 are $\backslash$ 2,938,130$.

C. Cities' Rate Case Expenses

1. In its filing of September 9, 2005, Cities requested rate case expenses for Docket No. 28840 of $\backslash$ 1,391,925 $.Thisamountconsistedof$ \ $1,166,925$ in expenses actually incurred through July 2005 and $\backslash$ 225,000$ in estimated expenses including appeals.
2. Cities' actual expenses of $\backslash$ 1,166,925 $throughJuly\mathrm{2005in}cluded$ \ $83,253$ billed by Cities' witness Sarah Goodfriend.
3. The Commission adopts the SOAH ALJs' finding regarding disallowance of one-half of Dr. Goodfriend's expenses from Docket No. 28840 because of the inadequacies in the survey she performed. The record indicates that Dr. Goodfriend has billed the Cities $\backslash$ 83,253 $;thereforeadisallowanceofone-halfofherfeesis$ \ $41,626$ .
4. Based on Findings of Fact Nos. 27 through 29, Cities' recoverable rate case expenses are $\backslash$ 1,350,299$.
5. AEP Central's proposal to disallow Cities' witness Starnes expenses is not appropriate because the principal rate design issues raised by Cities benefit other rate payers.
6. Cities' rate case expenses are system costs that should be borne by all ratepayers because other ratepayers benefit from the Cities' participation.

D. Rate Case Expense Surcharge

1. Based on Finding of Fact Nos. 26 and 30, the aggregate amount of rate case expenses found reasonable and necessary for AEP Central and Cities are $\backslash$ 4,288,429$.

Appendix E

Excerpts of Transcript of April 11, 2013 Commission Open Meeting

TRANSCRIPT OF PROCEEDINGS BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS AUSTIN, TEXAS

IN THE MATTER OF THE OPEN MEETING) OF THURSDAY, APRIL 11, 2013 )

BE IT REMEMBERED THAT AT approximately 9:35 a.m., on Thursday, the 11th day of April 2013, the above-entitled matter came on for hearing at the Public Utility Commission of Texas, 1701 North Congress Avenue, William B. Travis Building, Austin, Texas, Commissioners' Hearing Room, before DONNA L. NELSON, CHAIRMAN and KENNETH W. ANDERSON, JR., COMMISSIONER; and the following proceedings were reported by Lou Ray, Certified Shorthand Reporter.

issue, but I would reverse on a few of the findings in the PFD. So the first one I would -- I think not -- I think we were clear in a recent decision that we would not allow estimated rate expenses to be recovered in -because they're estimated, and they could be recovered in the next docket when they're --

COMM. ANDERSON: Oh, you mean the -- CHAIRMAN NELSON: Yes, the Cities estimated -- I guess I should be clear, 4B the Cities rate case expenses, I would -- I agree with the ALJ in terms of everything except for the 75,800 that are estimated.

COMM. ANDERSON: I agree. And I agree with you generally with just a couple of exceptions. I thought -- I agreed with the PFD.

CHAIRMAN NELSON: Right. COMM. ANDERSON: I do think that one -that there's a finding of fact and conclusion of law that will need to be added just to comply with the requirements of 36.058 .

CHAIRMAN NELSON: I agree, on affiliate transactions.

COMM. ANDERSON: Yeah. But we can get back to that at the end.

CHAIRMAN NELSON: Okay. And on C.2.a.

KENNEDY REPORTING SERVICE, INC. 512.474 .2233

1 which is financially based incentive compensation, I 2 kind of struggled with this issue because I - I 3 understood what all the different parties were 4 articulating, but ultimately I'm not sure in this docket 5 it's appropriate for us to impose a new policy of 6 disallowing rate case expenses related to advocacy of 7 long-shot positions. 8 What I would like to do is, if it's okay 9 with you, is open a rulemaking. I think just the issue 10 in general of rate case expenses, whether it's a utility 11 or the cities, I think it's something that we've needed 12 to look at for a while, and this is the type of issue 13 that would be appropriate to include in that type of a 14 rulemaking. 15 COMM. ANDERSON: Well, I agree that we ought to open up a rulemaking on it. I -- with respect to the PFD itself -- because interestingly in the four and a half years I've been on the Commission, this is actually the first contested case that is -- with respect to -- CHAIRMAN NELSON: Right. COMM. ANDERSON: -- the expenses that's actually has gotten to us. On the issue of the PFD itself, this is one where I spent a lot of time. I would actually adopt the PFD on the issue of the -- the

Appendix F

Commission Substantive Rule 25.245 ("Rate Case Expenses")

Subchapter J. COSTS, RATES, AND TARIFFS.

DIVISION 1. RETAIL RATES.

§25.245. Rate-Case Expenses.

(a) Application. This section applies to utilities requesting recovery of expenses for ratemaking proceedings (rate-case expenses) pursuant to Public Utility Regulatory Act (PURA) §36.061(b)(2) and to municipalities requesting reimbursement for rate-case expenses pursuant to PURA §33.023(b). (b) Requirements for claiming recovery of or reimbursement for rate-case expenses. A utility or municipality requesting recovery of or reimbursement for its rate-case expenses shall have the burden to prove the reasonableness of such rate-case expenses by a preponderance of the evidence. A utility or municipality seeking recovery of or reimbursement for rate-case expenses shall file sufficient information that details and itemizes all rate-case expenses, including, but not limited to, evidence verified by testimony or affidavit, showing: (1) the nature, extent, and difficulty of the work done by the attorney or other professional in the rate case; (2) the time and labor required and expended by the attorney or other professional; (3) the fees or other consideration paid to the attorney or other professional for the services rendered; (4) the expenses incurred for lodging, meals and beverages, transportation, or other services or materials; (5) the nature and scope of the rate case, including: (A) the size of the utility and number and type of consumers served; (B) the amount of money or value of property or interest at stake; (C) the novelty or complexity of the issues addressed; (D) the amount and complexity of discovery; (E) the occurrence and length of a hearing; and (6) the specific issue or issues in the rate case and the amount of rate-case expenses reasonably associated with each issue. (c) Criteria for review and determination of reasonableness. In determining the reasonableness of the rate-case expenses, the presiding officer shall consider the relevant factors listed in subsection (b) of this section and any other factor shown to be relevant to the specific case. The presiding officer shall decide whether and the extent to which the evidence shows that: (1) the fees paid to, tasks performed by, or time spent on a task by an attorney or other professional were extreme or excessive; (2) the expenses incurred for lodging, meals and beverages, transportation, or other services or materials were extreme or excessive; (3) there was duplication of services or testimony; (4) the utility's or municipality's proposal on an issue in the rate case had no reasonable basis in law, policy, or fact and was not warranted by any reasonable argument for the extension, modification, or reversal of commission precedent; (5) rate-case expenses as a whole were disproportionate, excessive, or unwarranted in relation to the nature and scope of the rate case addressed by the evidence pursuant to subsection (b)(5) of this section; or (6) the utility or municipality failed to comply with the requirements for providing sufficient information pursuant to subsection (b) of this section.

CHAPTER 25. SUBSTANTIVE RULES APPLICABLE TO ELECTRIC SERVICE PROVIDERS.

Subchapter J. COSTS, RATES, AND TARIFFS.

DIVISION 1. RETAIL RATES.

(d) Calculation of allowed or disallowed rate-case expenses. (1) Based on the factors and criteria in subsections (b) and (c) of this section, the presiding officer shall allow or recommend allowance of recovery of rate-case expenses equal to the amount shown in the evidentiary record to have been actually and reasonably incurred by the requesting utility or municipality. The presiding officer shall disallow or recommend disallowance of recovery of rate-case expenses equal to the amount shown to have been not reasonably incurred under the criteria in subsection (c) of this section. A disallowance may be based on cost estimates in lieu of actual costs if reasonably accurate and supported by the evidence. (2) A disallowance pursuant to subsection (c)(5) of this section may be calculated as a proportion of a utility's or municipality's requested rate-case expenses using the following methodology or any other appropriate methodology: (A) For utilities, the ratio of: (i) the amount of the increase in revenue requirement requested by the utility that was denied, to (ii) the total amount of the increase in revenue requirement requested in a proceeding by the utility. (B) For municipalities, the ratio of: (i) the amount of the increase in revenue requirement requested by the utility unsuccessfully challenged by the municipality, to (ii) the total amount of the increase in revenue requirement challenged by the municipality. (3) If the evidence presented pursuant to subsection (b)(6) of this section does not enable the presiding officer to determine the appropriate disallowance of rate-case expenses reasonably associated with an issue with certainty and specificity, then the presiding officer may disallow or deny recovery of a proportion of a utility's or municipality's requested rate-case expenses using the following methodology or any other appropriate methodology: (A) For utilities, the ratio of: (i) the amount of the increase in revenue requirement requested by the utility in the rate case related to the issue(s) not reasonably supported by evidence of certainty and specificity, to (ii) the total amount of the increase in revenue requirement requested in a proceeding by the utility. (B) For municipalities, the ratio of: (i) the amount of the increase in revenue requirement requested by the utility in the rate case challenged by the municipality relating to the issue(s) not reasonably supported by evidence of certainty and specificity, to (ii) the total amount of the increase in revenue requirement challenged by the municipality.

Appendix G

District Court's Final Judgment

| COPY | NO. D-1-GN-13-002623 | OCT 102014 MC | | :--: | :--: | :--: | | | | At $10:14$ AM. | | ENTERGY TEXAS, INC., | § | IN THE DISTRICT COURT OF | | PLAINTIFF, | § | | | | § | | | v. | § | TRAVIS COUNTY, TEXAS | | | § | | | PUBLIC UTILITY COMMISSION | § | | | OF TEXAS, | § | | | DEFENDANT. | § | ${345}^{\text{TH}}$ JUDICIAL DISTRICT |

Final Judgment

On September 30, 2014, the Court heard this administrative appeal on the merits. Plaintiff Entergy Texas, Inc., defendant Public Utility Counsel of Texas, intervenor State Agencies and Institutions of Higher Learning, and intervenor Office of Public Utility Counsel appeared through counsel and announced ready. Intervenor Texas Industrial Energy Consumers, although properly notified of the hearing, did not enter an appearance at the hearing. The Court, having reviewed the pleadings, the administrative record, the briefs, and argument of counsel, finds that the Public Utility Commission's final order in its Docket 40295, the agency order under review in this cause, should be in all things affirmed.

IT IS THEREFORE ORDERED, ADJUDGED AND DECREED that the Final Order of the Public Utility Commission of Texas in its Docket No. 40295 is AFFIRMED.

IT IS FURTHER ORDERED that Plaintiff take nothing by its cause of action and that costs are assessed against the Plaintiff.

This is a final judgment that disposes of all parties and all claims and is appealable. All relief not expressly granted herein is DENIED.

Approved as to form:

Elizabeth R. B. Sterling Assistant Attorney General State Bar No. 19171100 Representing Defendant Public Utility Commission of Texas

Marnie A. McCormick Duggins Wren Mann &; Romero, LLP State Bar No. 00794264 Representing Plaintiff Entergy Texas, Inc.

Assistant Attorney General State Bar No. 11205700 Representing IntervenoyState Agencies

Ross Henderson Assistant Public Counsel Office of Public Utility Counsel State Bar No. 24046055 Representing Intervenor Office of Public Utility Counsel

Rex VanMiddlesworth Thompson &; Knight, LLP State Bar No. 20449400 Representing Intervenor Texas Industrial Energy Consumers

SOAH DOCKET NO. 473-12-5573 PUC DOCKET NO. 40295

APPLICATION OF ENTERGY TEXAS, INC. FOR RATE CASE EXPENSES PERTAINING TO PUC DOCKET NO. 39896 § BEFORE THE § PUBLIC UTILITY COMMISSION OF $\S$ TEXAS

DIRECT TESTIMONY AND WORKPAPERS OF

NATHAN A. BENEDICT

ON BEHALF OF THE OFFICE OF PUBLIC UTILITY COUNSEL

November 6, 2012 OPUC Exhibit No.

SOAH DOCKET NO. 473-12-5573 PUC DOCKET NO. 40295 DIRECT TESTIMONY AND WORKPAPERS OF NATHAN A. BENEDICT TABLE OF CONTENTS I. WITNESS IDENTIFICATION AND SCOPE OF TESTIMONY ..... 3 II. ..... 5 III. ETI'S RATE CASE EXPENSES ..... 5 APPENDIX A ..... 12 WORKPAPERS ..... 16

2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 3 A. My name is Nathan A. Benedict. My business address is 1701 North Congress Avenue, 4 Suite 9-180, Austin, Texas 78701. 5 Q. PLEASE STATE YOUR CURRENT EMPLOYMENT. 6 A. I am employed as Assistant Director of Regulatory Analysis for the Office of Public 7 Utility Counsel ("OPUC"). 8 Q. PLEASE STATE YOUR EDUCATIONAL BACKGROUND. 9 A. I hold a Bachelor of Arts degree in Economics and German from the University of the 10 Pacific, a Master of Arts in Economics from California State University, East Bay, and a 11 Master of Science in Economics from The University of Texas at Austin. My graduate 12 studies included substantial training in statistics and econometrics as well as 13 specialization in the fields of public finance and industrial organization. A summary of 14 my educational background is included in Appendix A. 15 Q. PLEASE STATE YOUR PROFESSIONAL BACKGROUND. 16 A. I have over eleven years of experience in the utility industry. From 1998 to 2005, I 17 worked for Pac-West Telecomm, a Competitive Local Exchange Carrier ("CLEC"). I 18 held various management positions within Pac-West's operations group, including 19 management of the team responsible for provisioning Directory Assistance, E911, Local 20 Number Portability, and local loops in tandem with incumbent carriers in Pac-West's 21 service territory. From 2005 to 2006, I consulted for another CLEC, Telepacific, where I 22 designed voice and data networks for small- to medium-sized commercial customers.

Since 2008, I have taught courses in microeconomics and macroeconomics as an adjunct faculty member of Austin Community College. I began my tenure with OPUC in 2008. A summary of my professional background is included in Appendix A. Q. HAVE YOU PREVIOUSLY TESTIFIED REGARDING ELECTRIC UTILITY MATTERS? A. Yes. Appendix A includes a list of the cases in which I have testified. Q. WHAT IS THE SUBJECT OF YOUR TESTIMONY? A. My testimony addresses the amount of rate case expenses requested by Entergy Texas, Inc. ("ETI" or "Company") $$ Q. PLEASE SUMMARIZE YOUR CONCLUSIONS. A. $◻$ With respect to the overall amount of rate case expenses ETI is allowed to recover, the expenses must be reasonable in order to be recovered, but the Commission is not required to grant recovery of every reasonable expense. Other considerations, such as the frequency of rate cases, the overall amount of rate case expenses in comparison to the granted rate increase, and the nature of the utility's rate case request should be important components of the Commission's review. Based on these considerations, I recommend a reduction to ETI's request of between 14.5 and 73.6 percent. ^[1]

II. 2 Q. 3 4 A. 5 6 Q. 7 A. 8 9 10 11 12 13 14 15 III. ETI'S RATE CASE EXPENSES

16 Q. WHAT IS THE AMOUNT OF ETI'S REQUESTED RATE CASE EXPENSES? 17 A. ETI has requested recovery of $\backslash$ 8,752,576$ in rate case expenses related to Docket 18 No. 39896 and incurred through September 30, 2012. ^[4]

Q. ARE THERE ANY OVERARCHING POLICY ISSUES THE COMMISSION SHOULD CONSIDER WHEN REVIEWING RATE CASE EXPENSES? A. Yes. Even when all of a utility's rate case expenses are deemed reasonable, the Commission is not required to grant dollar-for-dollar recovery. PURA Sec. 36.061(b)(1) gives the Commission discretion in allowing recovery of rate case expenses, stating that the regulatory authority "may allow" as an expense the reasonable cost of participating in the rate case. From a policy perspective, as the frequency of rate cases increases, it becomes increasingly important to manage the cost of rate cases borne by ratepayers. ^[5] In this docket, ETI's rate case expenses are substantial in comparison to the revenue increase granted in Docket No. 39896, which is the Company's third base rate case in little more than four years. Furthermore, the Company opted to litigate certain issues for which Commission precedent is long-established and clear. The cost of challenging Commission precedent on these issues forms part of the total rate case expenses ETI has requested to recover from ratepayers. Q. HOW DOES ETI'S RATE CASE EXPENSE REQUEST COMPARE TO THE REVENUE INCREASE GRANTED IN THE RATE CASE AND TO ITS RATE CASE EXPENSE IN PRIOR DOCKETS? A. ETI's rate case resulted in a revenue increase of approximately $\backslash$ 27.7$ million on an annual basis. ^[6] ETI's rate case expenses of approximately $\backslash$ 8.75$ million represent over 30

percent of the actual revenue increase the Company was granted by the Commission. In comparison, ETI's 2007 rate case, Docket No. 34800, resulted in a stipulated revenue increase of $\backslash$ 46.7 $millionandratecaseexpensesof$ \ $2.3$ million per year for three years to be recovered through a rider. ${}^{8,9}$ Docket No. 34800 involved two Hearings on the Merits and myriad settlement negotiations. ETI's 2009 rate case, Docket No. 37744, resulted in a stipulated revenue increase of $\backslash$ 59 $millioneffectiveAugust5,2010andanadditionalincreaseof$ \ $9$ million effective May 2, 2011. The revenue increase included an unspecified amount for rate case expenses to be fully amortized in 2010. ^[10] Thus, in recent years, ETI's ratepayers have borne the twin burdens of rate increases occurring more frequently while also paying for the substantial litigation costs associated with the rate increases.

Q. WERE SOME OF ETI'S RATE CASE EXPENSES INCURRED TO

CHALLENGE SETTLED PRECEDENT?

A. Yes. Part of the litigation costs in Docket No. 39896 relates to issues for which Commission precedent is clear. As part of its statutory discretion, the Commission could consider the degree to which ETI has overreached in its rate case when considering the amount of litigation expenses allowed for recovery. I will provide a few examples to illustrate this issue.

| 1 | ETI's rate filing package included a request to recover financial-based incentive | | :--: | :--: | | 2 | compensation. The ALJs note that all parties to the rate case, including ETI, agree that | | 3 | Commission precedent allows recovery of only one type of incentive-based | | 4 | compensation. While compensation tied to operational goals is recoverable, | | 5 | compensation tied to financial goals is not. ^[11] ETI, nonetheless, requested recovery of all | | 6 | incentive compensation costs, including those related to financial measures. Consistent | | 7 | with its long-standing precedent, the Commission disallowed $\backslash$ 6,196,037$ in financially- | | 8 | based incentive compensation. ^[12] | | 9 | A well-established criterion for the inclusion of an expense in rates is that the | | 10 | expense be known and measurable. ETI requested an additional $\backslash$ 9$ million in | | 11 | transmission equalization expense beyond the test year level. The Company's | | 12 | transmission equalization expenses are affected by changes in transmission investment | | 13 | made by the other Entergy Operating Companies. ETI estimated the transmission | | 14 | projects to be completed by the other Operating Companies through the end of the rate | | 15 | year to compute its adjustment. The ALJs found that because these projects are largely | | 16 | not yet built, and may never be built, use of these projects to make an adjustment to test | | 17 | year transmission equalization expense does not represent a known and measurable | | 18 | change. ^[13] In turn, the Commission denied ETI's request to add $\backslash$ 9$ million to its | | 19 | transmission equalization expense. ^[14] |

Finally, instead of including purchased capacity costs in base rates, ETI requested a purchased capacity rider in the rate case despite the fact that the Commission already had a pending rulemaking to determine the structure of such a rider for all generating utilities. Indeed, the Commission ultimately determined that the purchased capacity rider requested by ETI should not be considered in the rate case due to the pending rulemaking. ^[15]

While the Commission has the authority to grant the utility recovery of costs reasonably incurred in the litigation of its rate case, it is not required to do so. If there were no room for discretion, the Legislature would not have used the word "may" when giving the Commission the authority to grant recovery of rate case expenses. And without the Commission having discretion, rate case expense proceedings would be mere accounting exercises. A utility's request for recovery of rate case expenses should be considered in the larger context. The frequency of rate cases, the amount of rate case expenses relative to the size of the rate increase, and the type of relief requested by the utility in its rate case should affect the outcome of the rate case expense docket.

Q. SHOULD ETI BE ALLOWED TO RECOVER THE FULL AMOUNT OF ITS RATE CASE EXPENSES?

A. No. The policy considerations I have discussed warrant a reduction to ETI's recoverable rate case expenses. In addition, by exercising its discretion to limit rate case expenses, the Commission can encourage settlement of rate cases. Settlement reduces the cost of participation to all parties involved. Additionally, shifting a portion of rate case expenses

from ratepayers to shareholders when challenging well-settled principles of ratemaking will encourage a utility to carefully consider the degree to which it requests forms of relief that run afoul of Commission precedent.

Q. HOW LARGE OF A REDUCTION TO RECOVERABLE RATE CASE EXPENSES DO YOU RECOMMEND?

A. I suggest an upper and lower bound for any reduction the Commission decides to implement. ETI was granted a rate increase of $\backslash$ 27.7 $millioninDocketNo.39896,whichis$ \ $77.1$ million less than the Company's request of $\backslash$ 104.8$ million. Because the Commission reduced ETI's requested rate increase by approximately 73.6 percent, I believe that it is reasonable to reduce ETI's recoverable rate expenses by the same percentage. This 73.6 percent reduction forms the upper bound of my recommendation.

The lower bound of my recommendation is formulated by considering the elements of ETI's base rate case that challenged clear Commission precedent. As described earlier in my testimony, ETI requested recovery of financial-based incentive compensation and a projected increase in transmission equalization costs, both of which were denied by the Commission. The Company's request for recovery of financial-based incentive compensation and the pursuit of a change to transmission expense that was neither known nor measurable clearly contradict Commission precedent. It is not reasonable for ratepayers to pay ETI's litigation expenses on these issues. Combined, these issues contributed $\backslash$ 15.2 $milliontoET{I}^{\prime }srequestedrateincreaseof$ \ $104.8$ million, and the disallowance associated with these issues reduced ETI's requested increase by 14.5 percent. Thus, a reasonable lower bound to the Commission's reduction to ETI's

rate case expenses is 14.5 percent. Of course, this lower bound is based on the issues I have identified and could be adjusted upward based on the testimonies and recommendations of other parties to this docket.

Given my recommended band of 14.5 percent to 73.6 percent, it would be reasonable to disallow between $\backslash$ 1,269,123 $and$ \ $6,441,896$ of ETI's requested $\backslash$ 8,752,576$ in rate case expenses.

7 Q. DOES THIS CONCLUDE YOUR TESTIMONY?

8 A. At this time, yes.

APPENDIX A

EDUCATIONAL AND EMPLOYMENT HISTORY

NATHAN A. BENEDICT

EDUCATION

M.S., Economics.

Fields: Public Finance Industrial Organization The University of Texas at Austin, 2008 M.A., Economics.

California State University, East Bay, 2005 B.A., Economics, German.

University of the Pacific, 1999

EMPLOYMENT HISTORY

Assistant Director, Regulatory Analysis Office of Public Utility Counsel State of Texas October 2008 - Present Adjunct Assistant Professor, Economics Austin Community College January 2008 - Present Teaching Assistant Introductory Economics The University of Texas at Austin August 2007 - May 2008 Research Assistant Human Investment Research and Education (HIRE) Center California State University, East Bay July 2005 - July 2006 Service Engineer U.S. Telepacific Corp.

July 2005 - May 2006

Teaching Assistant Introductory Economics California State University, East Bay August 2005 - December 2005 Customer Relations Manager Senior Corporate Trainer Cross-Functional Assessment Manager Ordering and Provisioning Manager Pac-West Telecomm, Inc. April 1998 - March 2005

Testimony presented before the Texas Public Utility Commission:

Style

No. 39896 Application of Entergy Texas, Inc. for Authority to Change Rates and Reconcile Fuel Costs

No. 39366 Application of Entergy Texas, Inc. for Authority to Redetermine Rates for the Energy Efficiency Cost Recovery Factor Tariff and Request to Establish a Revised Energy Efficiency Goal and Cost Caps

No. 38306 Texas-New Mexico Power Company's Request for Approval of Advance Metering System (AMS) Deployment and AMS Surcharge

No. 37744 Application of Entergy Texas, Inc. for Authority to Change Rates and Reconcile Fuel Costs

No. 37482 Application of Entergy Texas, Inc. for Approval of a Power Cost Recovery Factor

No. 36952 Application of CenterPoint Energy Houston Electric, LLC to Defer Energy Efficiency Cost Recovery and for Approval of an Energy Efficiency Cost Recovery Factor

Subject

Revenue Requirement; Cost Allocation; Rate Design

Allocation of Energy Efficiency Performance Bonus

AMS Communications Network; Discretionary Service Charges; LowIncome Programs

Product Solicitation Process; Product Pricing; Miscellaneous Electric Service Charges; Rate Riders

Product Solicitation Process and Product Pricing

Computation of Energy Efficiency Performance Bonus

No. 36851 Application of the Electric Reliability Council of Texas, Inc. for Approval of a Revised Nodal Market Implementation Surcharge

No. 36025 Application of Texas-New Mexico Power Company for Authority to Change Rates

Project Funding Sources and Surcharge Allocation

Revenue Requirement; Cost Allocation; Rate Design

WORKPAPERS

DOCKET NO. 31433

PROCEEDING TO CONSIDER RATE CASE EXPENSES SEVERED FROM DOCKET NO. 28840 (APPLICATION OF AEP TEXAS CENTRAL COMPANY FOR AUTHORITY TO CHANGE RATES)

PUBLIC UPIMATY COMMISSION

$\begin{array}{c}\text{PUBLIC UPIMATY COMMISSION}\text{P.}3\text{- O.}14\hfill \end{array}$ FILIGE CLCIUNG

ORDER

This Order addresses the recoverable rate-case expenses of AEP Texas Central Company (AEP Central) and of Cities ^[1] in connection with their participation in Docket No. 28840. ^[2] As set forth in this Order, the Public Utility Commission of Texas (Commission) determines that AEP Central's recoverable rate case expenses through June 2005 are $\backslash$ 2,938,130 $andthatCitie{s}^{\prime }recoverableratecaseexpensesare$ \ $1,350,149$ . As discussed herein, the Cities' expenses relating to witness Sarah Goodfriend have been reduced by one-half as recommended by the State Office of Administrative Hearings (SOAH) Administrative Law Judges in their Proposal for Decision (PFD) in Docket No. 28840. ^[3] This Order finds that $\backslash$ 4,288,429$ in rate-case expenses incurred by AEP Central and Cities is reasonable and necessary and authorizes AEP Central to implement a surcharge over three years to recover this amount.

I. Procedural History

On November 3, 2003, AEP Central filed an application seeking a change in its rates. This application was assigned Docket No. 28840, and the Commission referred the case to SOAH on November 4, 2003. SOAH issued its initial PFD in Docket No. 28840 on July 1, 2004, which contained certain findings on rate case expenses. In July and August 2004, the Commission issued two orders on remand in Docket No 28840 directing SOAH to consider further and provide further evaluation of certain specified issues, none of which involved rate case expenses. On November

16, 2004, SOAH issued its Remand PFD. In addition, the Commission held hearings on certain matters relating to merger savings and affiliated expenses on March 3, 4, and 7. The Commission issued its final order in Docket No. 28840 on August 15, 2005. In that order, the Commission severed the determination of the reasonableness and necessity of rate case expenses to this proceeding, Docket No. 31433.4 While rate-case expenses were not addressed on the remand SOAH hearing and the Commission-held hearing, Cities and AEP incurred additional expenses as a result of these hearings, and submitted updated information on these additional expenses. Based on the submission, the Commission decided to sever the determination on rate-case expenses to examine this additional evidence. ^[5]

By Order No. 1 in this proceeding, AEP Central and Cities were directed to file detailed supporting documentation of their requested rate case expenses. On September 9, 2005, AEP Central and Cities filed such supporting documentation. On September 16 and October 10, 2005, AEP Central made supplemental filings that furnished additional supporting documentation with respect to certain of its requested expenses.

On October 14, 2005, the parties filed statements of position and on October 28, 2005, AEP Central filed its Motion for Ruling on Disputed Issue and Conditional Request for a Hearing. On December 12, 2005, the presiding officer issued Order No. 4, which requested clarification regarding contested issues. On December 22, 2005, the parties filed responses to Order No. 4.

The parties' filings established that there are no contested factual issues in Docket No. 31433 that have not been fully litigated in Docket No. 28840. To the extent AEP Central had previously conditionally requested a hearing, that request was withdrawn by AEP Central's December 22, 2005 filing. The sole disputed issue is the recoverability of one-half of Cities' witness Sarah Goodfriend's expenses, which the SOAH ALJs had recommended be disallowed in their PFD in Docket No. 28840 issued on July 1, 2004. Since there are no contested factual issues that have not already been fully litigated, an evidentiary hearing on the merits is not necessary or appropriate. The disposition of the sole contested issue is discussed in the subsequent section of this Order.

II. Recoverability of One-Half of Dr. Goodfriend's Expenses

In Docket No. 28840, AEP Central submitted testimony challenging the quality of a survey that formed the basis of testimony submitted by Cities witness, Dr. Sarah Goodfriend. ^[6] Following a full evidentiary hearing and briefing on this and other issues, the SOAH ALJs recommended that one-half of Dr. Goodfriend's expenses be disallowed because they found that the methodology of the survey she conducted was "seriously flawed." ^[7]

In severing the issue of rate case expenses from Docket No. 28840 to this proceeding, the Commission intended that the entire evidentiary record in Docket No. 28840 on rate case expenses as well as the Commission's initial decisions be carried over to this case. Thus, the evidentiary record on the quality of Dr. Goodfriend's work underlying her testimony in Docket No. 28840 and the SOAH ALJs' findings regarding the recoverability of one-half of her expenses are before the Commission for decision in this proceeding. The purpose of the severance, however, was to evaluate the detailed supporting documentation on updated rate-case expenses submitted by AEP Central and Cities. ^[8] This proceeding was not initiated as a forum for Cities to re-litigate Dr. Goodfriend's expenses.

The Commission had previously found that the ALJs correctly determined that one-half of Dr. Goodfriend's expenses should be disallowed ^[9] because the survey she conducted "was seriously flawed and that conclusions drawn from the data cannot be reasonably supported under current legal standards."10 The Commission reaffirms this determination, and therefore, the Commission adopts the SOAH ALJs' finding that one-half of Dr. Goodfriend's expenses should be disallowed. In addition, as there are no other outstanding contested issues related to the rate-case expense information submitted in Docket No. 28840 or the additional rate-case expense information

submitted in this docket, the Commission finds that the rate-case expenses of $\backslash$ 2,938,130 $forAEPCentraland$ \ $1,350,299$ for Cities are reasonable and necessary.

III. The SOAH ALJs' Findings and Conclusions in Docket No. 28840

In the PFD issued on July 1, 2004, in Docket No. 28840, the SOAH ALJs included Finding of Fact Nos. 210 through 216 and Conclusion of Law No. 58 addressing rate case expenses. The SOAH ALJs' findings were issued prior to the updating by AEP Central and Cities of their rate case expenses in their filings described in Finding of Fact No. 15. Thus, in order to reflect the updated factual evidence filed in Docket No. 31433 and certain other corrections described below, the Commission modifies the SOAH ALJs' Finding of Fact Nos. 210 through 216 as follows.

Finding of Fact Nos. 22 through 25 of this Order modify the SOAH ALJs' Finding of Fact No. 210 to reflect the updated amounts of rate case expenses found reasonable and necessary for AEP Central after reflecting the disallowance recommended by Staff. Finding of Fact No. 27 of this Order modifies the SOAH ALJs' Finding of Fact No. 211 to reflect the updated amount of Cities' requested rate case expenses. Finding of Fact Nos. 28 and 29 of this Order modify the SOAH ALJs' Finding of Fact No. 212 to reflect the updating of Dr. Goodfriend's portion of Cities' requested rate case expenses. Finding of Fact Nos. 31 and 32 of this Order adopt the SOAH ALJs' Finding of Fact Nos. 214 and 215. Finding of Fact No. 33 of this Order modifies the SOAH ALJs' Finding of Fact No. 216 to reflect the amounts found reasonable and necessary by the Commission based on the updated information in this proceeding and corrects it to reflect that the rate case expenses will be collected through a three-year surcharge and not through cost of service. Finding of Fact No. 34 of this Order supplements the SOAH ALJs' Finding of Fact No. 256 to reflect the updated amounts for AEP Central's and Cities' rate case expenses found reasonable and necessary by this Order. Finding of Fact No. 35 reflects the Commission's policy decision, in accordance with its decision in Docket No. 30706, ^[11] that AEP Central not be permitted to recover estimated appeal costs in this proceeding, but that AEP Central be afforded the opportunity to recover in its next rate case any reasonable and necessary expenses for Docket Nos. 28840 and 31433 that it

subsequently incurs that exceed the amounts found reasonable and necessary by this Order. Finally, Conclusion of Law No. 6 in this Order incorporates the SOAH ALJs' Conclusion of Law No. 58.

The Commission adopts the following findings of fact and conclusions of law:

IV. Findings of Fact

A. Background and Procedural Matters

1. AEP Central is an electric utility providing transmission and distribution (T&;D) services in a 44,000 square-mile area of South Texas that includes the portion of Texas from just south of San Antonio to the Mexican border and from Bay City west to Eagle Pass. AEP Central's service area is located within the Electric Reliability Council of Texas (ERCOT).
2. On November 3, 2003, AEP Central filed an application with the Commission to change its T&;D rates. The Commission assigned AEP Central's application to Docket No. 28840.
3. Concurrent with filing its application with the Commission, AEP Central filed a similar petition and statement of intent with each incorporated city in its certificated service area that retains jurisdiction over its retail rates. Eighty-six (86) cities denied AEP Central's petition and statement of intent. AEP Central filed petitions for review of those denials and filed motions to consolidate those petitions for review into Docket No. 28840.
4. On November 4, 2003, the Commission referred AEP Central's application in Docket No. 28840 to SOAH to conduct an evidentiary hearing on the merits and issue a PFD.
5. The following parties intervened and participated in the hearing in Docket No. 28840: Cities; Texas Industrial Energy Consumers (TIEC); CPL Retail Energy (CPL Retail); Coalition of Commercial Ratepayers (CCR); City of Garland, Alliance for Retail Markets (ARM); TXU Business Services (TXU); Texas Legal Services Center and Texas Ratepayers' Organization to Save Energy (TLSCROSE); South Texas Electric Cooperative, Inc. (STEC); State of Texas; Office of Public Utility Counsel (OPC); and Commission Staff (Staff).

1. In Docket No. 28840, AEP Central requested approval of a revenue requirement of $\backslash$ 519.9 $million,basedonanhistoricaltestyearofJuly1,2002,throughJune30,2003.Ofthatamount,$ \ $426.6$ million was for providing retail T&;D service (including the portion of the ERCOT-wide transmission costs) and $\backslash$ 93.3$ million for providing wholesale transmission service.
2. The evidentiary hearing on the merits in Docket No. 28840 was held on March 2 through March 18, 2004.
3. On July 1, 2004, the SOAH ALJs assigned to hear Docket No. 28840 issued their PFD. The PFD contained certain findings with respect to rate case expenses.
4. The Commission issued orders on July 28 and August 25, 2004, remanding portions of Docket No. 28840 to SOAH, none of which involved rate case expenses.
5. On November 16, 2004, the SOAH ALJs issued their Remand PFD in Docket No. 28840.
6. On March 3, 4, and 7, 2005, the Commission held hearings on merger savings and affiliate expenses.
7. On August 15, 2005, the Commission issued its final order in Docket No. 28840. In Ordering Paragraph 5 of that order, the Commission severed the determination of the reasonableness and necessity of rate case expenses into this proceeding, Docket No. 31433. All portions of the evidentiary record in Docket No. 28840 relevant to rate case expenses are part of the evidentiary record in this Docket No. 31433.
8. On August 26, 2005, the presiding officer issued Order No. 1, which required the parties to file evidence of rate case expenses and directed AEP Central and Cities to file supporting detailed documentation for their requested rate case expenses. Order No. 1 also made all parties to Docket No. 28840 parties to this proceeding.

1. On August 29, 2005, Cities requested clarification from the presiding officer regarding the extent of the supporting documentation the Cities were required to submit under Order No. 1.
2. On August 30, 2005, Order No. 2: Clarification of Order No. 1, was issued informing Cities that:

The entirety of the rate case expenses will be considered in this proceeding. To the extent supporting documentation for expenses prior to September 2004 is in the record of Docket No. 28840, Cities may simply provide the relevant cite to the record. If the supporting documentation for expenses is not in the Docket No. 28840 record, that information should be submitted in this proceeding. 16. On September 9, 2005, AEP Central and Cities filed supporting documentation for their requested rate case expenses, consisting of invoices, timesheets, receipts, etc. On September 16 and October 10, 2005, AEP Central filed supplemental information related to certain of its requested rate case expenses. 17. On September 19, 2005, the presiding officer established a procedural schedule for this docket. In accordance with the procedural schedule, statements of position were due on October 14, 2005, and requests for hearing were due on October 28, 2005. 18. On October 14, 2005, AEP Central, Cities, and Staff filed statements of position. In its statement of position, Staff questioned certain items of AEP Central's rate case expenses as lacking adequate supporting documentation. In its statement of position, AEP Central stated that the SOAH ALJs had recommended that one-half of Dr. Goodfriend's expenses be disallowed and noted that Cities' requested rate case expenses included the entire amount billed by Dr. Goodfriend to Cities, and not one-half of that amount. In its statement of position, Cities indicated that they did not contest any of AEP Central's rate case expenses, but indicated that if Cities' request associated with Dr. Goodfriend's work was contested, then Cities would urge that the standard applied to Dr. Goodfriend be applied to AEP Central's experts.

1. On October 28, 2005, AEP Central filed a motion for ruling on a disputed issue and conditionally requested a hearing seeking a Commission ruling on whether, by severing rate case expenses from Docket No. 28840, it intended to reopen for litigation the issue of Dr. Goodfriend's expenses which had been fully litigated in Docket No. 28840. AEP Central's pleading also included an identification of the portions of the record in Docket No. 28840 that addressed the issue of the quality of Dr. Goodfriend's work and the recovery of her rate case expenses.
2. On December 12, 2005, the presiding officer issued Order No. 4, which requested a clarification regarding a contested issue and directed Staff to file a list of disputed factual . issues and a list of threshold legal and policy issues that must be addressed before this proceeding can be resolved, and permitting AEP Central and Cities to make similar filings.
3. On December 22, 2005, AEP Central and Cities filed their responses to Order No. 4. In its response, AEP Central withdrew its conditional request for a hearing.
4. Based on the filings of the parties set forth in Finding of Fact Nos. 16, 18, 19, and 21, the Commission finds that no factual matters that have not already been fully litigated in Docket No. 28840 are at issue or disputed. The only disputed issue in this proceeding involves the recoverability of one-half of Cities' witness Goodfriend's expenses, which has been subjected to a full contested case evidentiary hearing, briefing, and the issuance by the SOAH ALJs of a PFD in Docket No. 28840.

B. AEP Central's Rate Case Expenses

1. Based on its filing of September 9, 2005, as supplemented by its filings of September 16 and October 10, 2005, AEP Central sought recovery of $\backslash$ 2,962,734$ in recoverable rate case expenses for Docket No. 28840 through June 2005.
2. In its statement of position filed on October 14, 2005, Staff questioned whether $\backslash$ 24,604$ of AEP Central's requested rate case expenses were supported by adequate underlying documentation and recommended disallowance of these expenses.

1. In its filing of October 28, 2005, AEP Central indicated that it did not contest Staff's recommendation to disallow $\backslash$ 24,604$ of AEP Central's requested rate case expenses.
2. AEP Central's reasonable and necessary rate case expenses for Docket No. 28840 as of June 2005 are $\backslash$ 2,938,130$.

C. Cities' Rate Case Expenses

1. In its filing of September 9, 2005, Cities requested rate case expenses for Docket No. 28840 of $\backslash$ 1,391,925 $.Thisamountconsistedof$ \ $1,166,925$ in expenses actually incurred through July 2005 and $\backslash$ 225,000$ in estimated expenses including appeals.
2. Cities' actual expenses of $\backslash$ 1,166,925 $throughJuly\mathrm{2005in}cluded$ \ $83,253$ billed by Cities' witness Sarah Goodfriend.
3. The Commission adopts the SOAH ALJs' finding regarding disallowance of one-half of Dr. Goodfriend's expenses from Docket No. 28840 because of the inadequacies in the survey she performed. The record indicates that Dr. Goodfriend has billed the Cities $\backslash$ 83,253 $;thereforeadisallowanceofone-halfofherfeesis$ \ $41,626$ .
4. Based on Findings of Fact Nos. 27 through 29, Cities' recoverable rate case expenses are $\backslash$ 1,350,299$.
5. AEP Central's proposal to disallow Cities' witness Starnes expenses is not appropriate because the principal rate design issues raised by Cities benefit other rate payers.
6. Cities' rate case expenses are system costs that should be borne by all ratepayers because other ratepayers benefit from the Cities' participation.

D. Rate Case Expense Surcharge

1. Based on Finding of Fact Nos. 26 and 30, the aggregate amount of rate case expenses found reasonable and necessary for AEP Central and Cities are $\backslash$ 4,288,429$.

1. It is appropriate for AEP Central to surcharge the aggregate rate case expenses found reasonable and necessary in Finding of Fact No. 33 to be collected from all customers over three years.

E. Subsequent Rate Case Expenses

1. To the extent AEP Central incurs rate case expenses for Docket Nos. 28840 and 31433 after June 2005, it is reasonable for it to recover such expenses in its next rate case to the extent it demonstrates that such additional expenses are reasonable and necessary. Also, to the extent that Cities incur rate case expenses for Docket Nos. 28840 and 31433 after July 2005 that cause Cities' aggregate rate case expenses to exceed the amount found recoverable by this Order, it is reasonable for AEP Central to recover such expenses in its next rate case to the extent found reasonable and necessary.

V. Conclusions of Law

1. AEP Central is an electric utility as defined by $\S \S 31.002$ of the Public Utility Regulatory Act, Tex. Util. Code Ann. §§ 11.001-66.017 (Vernon 1998 &; Supp. 2005) (PURA) and is therefore subject to the Commission's jurisdiction under PURA §§ 32.001, 33.051, and 36.102 .
2. AEP Central is a T&;D utility as defined in PURA § 31.002(19).
3. SOAH had jurisdiction over all matters relating to the conduct of the hearing in Docket No. 28840, including the preparation of a Proposal for Decision pursuant to PURA § 14.053 and Tex. Gov't Code Ann. § 2003.049(b).
4. AEP Central met its burden of proof regarding the amount of its rate case expenses for Docket No. 28840 through June 2005 found reasonable and necessary in Finding of Fact No. 26.

1. With the exception of the Cities' rate case expenses disallowed in Finding of Fact No. 29, Cities met their burden of proof that their rate case expenses for Docket No. 28840 are reasonable and necessary.
2. Cities are entitled to reimbursement for their rate case expenses as customers, as well as for being regulatory authorities.
3. The evidentiary record in Docket No. 28840 on rate case expenses, including the portion related to the quality of work performed by Dr. Goodfriend underlying her testimony submitted in Docket No. 28840 identified in AEP Central's pleading described in Finding of Fact No. 19, is part of the evidentiary record in this case together with the additional supporting documentation filed by AEP Central and Cities in this proceeding as discussed in Finding of Fact No. 16.
4. No contested issues of fact beyond those that were fully litigated, argued, and heard by the SOAH ALJs in Docket No. 28840 have been raised in this proceeding; therefore, there is no need for any further evidentiary hearing on the merits on recoverable rate case expenses in addition to those already held in Docket No. 28840.
5. When the issue of the quality of the work underlying Dr. Goodfriend's testimony in Docket No. 28840 was litigated before and the issue of the recoverability of her rate case expenses was briefed to the SOAH ALJs, Cities had the opportunity to challenge the quality of AEP Central's experts' substantive work and the recovery of their rate case expenses under the standard applied by the SOAH ALJs to Dr. Goodfriend's expenses. Cities failed to take advantage of that opportunity and no additional evidentiary hearing on the merits is appropriate in this proceeding as to that matter.

VI. Ordering Paragraphs

In accordance with these findings of fact and conclusions of law, the Commission issues the following Order:

1. The additional supporting documentation filed by AEP Central and Cities on September 9, 2005, and by AEP Central on September 16 and October 10, 2005, as discussed in Finding of Fact No. 16 above, is admitted into the evidentiary record of this Docket No. 31433.
2. To the extent provided in this order, the requests by AEP Central and Cities for determination of their reasonable and necessary rate case expenses for Docket No. 28840 are granted.
3. As set forth in Finding of Fact No. 34, AEP Central is authorized to surcharge, over a threeyear period, the aggregate rate case expenses for Docket No. 28840 found reasonable and necessary in Finding of Fact No. 33.
4. AEP Central shall file tariff sheets consistent with this Order (compliance tariff) no later than 20 days after receipt of this Order. The Compliance tariff, and all filings related to it, shall be filed in Tariff Control Number 32385 and shall be styled: Compliance Tariff of AEP Texas Central Company Pursuant to Final Order in Docket No. 31433 Severed from Docket No. 28840. The Filing shall include a transmittal letter stating that the tariffs attached are in compliance with this Order, giving the docket number, date of this Order, a list of tariff sheets filed, and any other necessary information. The timetable for review of the compliance tariff shall be established by the Commission's ALJ assigned to the tariff. In the event any sheets are modified or rejected, AEP Central shall file proposed revisions to those sheets in accordance with the Commission's ALJ. All subsequent filings in connection with the compliance tariff (i.e., requests for extensions, textual corrections, revisions) shall be filed in the Tariff Control Number provided above, and styled as set forth above. After issuance of the final order, no further filings other than those pertaining to a motion for rehearing shall be made in this docket.
5. As set forth in Finding of Fact No. 35, AEP Central may seek to recover in its next rate case expenses in connection with Docket Nos. 28840 and 31433 that it incurs after June 2005 and Cities' rate case expenses incurred in connection with Docket No. 28840 and 31433 that

exceed the amounts authorized to be recovered herein, to the extent such additional expenses are found reasonable and necessary. 6. All other motions, requests for entry of specific findings of fact and conclusions of law, and any other requests for general or specific relief, if not expressly granted herein, are denied.

SIGNED AT AUSTIN, TEXAS the $\frac{2}{2}\mathrm{d}$ day of $1/3$ aweek 2006. PUBLIC UTILITY COMMISSION OF TEXAS

TARIFF CONTROL NO. 32385 PUBLIC UTILITY COMMISSION OF TEXAS

COMPLIANCE TARIFF OF AEP TEXAS CENTRAL COMPANY PURSUANT TO FINAL ORDER IN DOCKET NO. 31433 SEVERED FROM DOCKET NO. 28840

MARCH 14, 2006

TABLE OF CONTENTS

| SECTION | FILE NAME | PAGE | | :-- | :-- | --: | | Transmittal letter | Letter - re Compliance RCE tariff.doc | 2 | | Attachment A | Rate Case Surcharg Rider.doc | 3 | | Attachment B | Rate Case ExP Rider Final Retail.xls | $4-7$ |

James R. Galloway Central Records Public Utility Commission of Texas 1701 N. Congress Austin, Texas 78711 Re: Tariff Control No. 32385 - Compliance Tariff of AEP Texas Central Company Pursuant to Final Order in Docket 31433 Severed from Docket No. 28840

Dear Mr. Galloway: Enclosed is the Rider RCS - Rate Case Surcharge tariff sheet for Retail Delivery Service of AEP Texas Central Company (TCC) filed herewith in compliance with the Final Order in Docket No. 31433, Proceeding To Consider Rate Case Expenses Severed From Docket No. 28840 (Application of AEP Texas Central Company For Authority To Change Rates issued on March 3, 2006. The Rider RCS - Rate Case Surcharge tariff sheet is the only tariff that is the subject of this filing and is enclosed as Attachment A, and the worksheets supporting the tariff sheet are enclosed as Attachment B.

TCC proposes that the attached rate schedules be effective for bills rendered on and after March 30, 2006, which is the first billing cycle for April 2006. TCC requests that the Administrative Law Judge (ALJ) assigned to this Tariff Control Number establish a procedural schedule allowing for that effective date. TCC requests that the tariffs be effective for billings on and after the effective date of the tariff to avoid potential implementation issues for TCC and the Retail Electric Providers.

As set forth in Attachment B, in addition to the Retail Delivery Service surcharge set forth in Rider RCS, TCC will also collect the wholesale jurisdictional allocated portion of the Docket No. 31433 rate case expenses from Wholesale Transmission customers served under TCC's Open Access Transmission Tariff (OATT).

If you have any questions, please do not hesitate to contact me at 512-481-4543. Thank you for your consideration in this matter.

cc: All parties of record in Docket No. 28840. Encl.

6.1.1.14.5 Rider RCS - Rate Case Surcharge

AVAILABILITY:

Rider RCS is designed to recover Commission approved rate case expenses associated with PUCT Docket No. $28840.{}^1$ Rider RCS is applicable to electric delivery service from the Company during the periods this schedule is in effect, and will be billed along with the other delivery service charges. Charges associated with Rider RCS will be determined in accordance with the applicable fee listed below. This schedule will be in effect from the first billing cycle of April 2006 and will end with the last billing cycle of March 2009.

MONTHLY RATE OTHER THAN FOR TRANSMISSION VOLTAGE SERVICE:

The monthly charge shall be determined by multiplying the appropriate Rider RCS Fee in the table below by the current month's billing kWh .

| Rate Schedule | Fee | | :-- | :--: | | Residential Service | $\backslash$ 0.000059$ per kWh | | Secondary Service Less than or Equal to 10 kW | $\backslash$ 0.000119$ per kWh | | Secondary Service Greater than 10 kW | $\backslash$ 0.000047$ per kWh | | Primary Service | $\backslash$ 0.000026$ per kWh | | Lighting Service | $\backslash$ 0.000119$ per kWh |

MONTHLY RATE FOR TRANSMISSION VOLTAGE SERVICE:

The RCS for the Transmission Service Class shall be collected on a revenue basis by applying the factor below to Transmission and Distribution base rate revenue. Base rate revenue is defined as the monthly sum of the distribution system charges, metering charge, customer service charge, transmission system use charges, and Rider TCRF charges.

Rate Schedule
Transmission Service

Base Revenue Factor 0.00242

NOTICE:

This Rate Schedule is subject to the Company's Tariff and Applicable Legal Authority.

Allocation of Rate Case Expenses

| Total Approved Rate Case Expenses (1) | $\backslash$ 4,288,279$ | | :--: | :--: | | Wholesale Transmission Rate Base Allocation Factor (2) | $35.37\%$ | | Distribution Rate Base Allocation Factor (2) | $64.63\%$ | | Wholesale Transmission Total Revenue Requirement | $\backslash$ 1,516,933.52$ | | Distribution Total Revenue Requirement | $\backslash$ 2,771,495.48$ | | 3-Year Recovery Annual Revenue Requirement | | | Wholesale Transmission | $\backslash$ 505,644.51$ | | Distribution | $\backslash$ 923,831.83$ |

Wholesale Transmission Rate Case Surcharge Factor Development Wholesale Transmission Annual Revenue Requirement Test Year ERCOT 4CP kW per average 4CP per year monthly rate case expense surcharge for wholesale transmission service per 4CP kW (3) $53,520,537$ $\backslash$ 0.00945$ $4,288,279$ 2 Jurisdictional allocation based on rate base. Schedule 2 - Final Order dated August 15, 2005 Wholesale Transmission Rate Base Distribution Rate Base

| 471,655,044 | $35.37\%$ | | --: | --: | | 861,731,781 | $64.63\%$ | | $1,333,386,825$ | $100.00\%$ |

3 In addition to the TCOS wholesale transmission access fee, TCC TSP shall bill a monthly rate of $\backslash$ 0.00079$ per kW of coincident peak demand for three years after the effective date of the rate case expense surcharge rider.

AEP Texas Central Company Compliance Filing Rate Case Expense Surcharge Rider Transmission Revenue Workpaper

| | Transmission | PFD Price | Billing Values | Billing
Determinants | PFD Revenue | | :--: | :--: | :--: | :--: | :--: | :--: | | Line | Summary | | | | | | 1 | Distribution | \ $0.20|80\%RatchetedkW|$ 16,542,232 $|\backslash$ 3,308,446 | | 2 | Transmission IDR | \ $1.66|ERCOTAvg4CP|$ 5,380,448 $|\backslash$ 8,931,544 | | 3 | Meter | \ $1,640.52|perCustomer|504|\backslash$ 826,822 | | 4 | Customer Services Charge IDR | \ $18.28|perCustomer|504|\backslash$ 9,213 | | 5 | Total Delivery System Charges | | | | \$13,076,026 | | 6 | | | | | | | 7 | | | | | | | 8 | | | | | | | 9 | | | | | | | 10 | Total Distribution Revenue Requirement | | | | \$13,076,026 | | 11 | | | | | | | 12 | TCRF IDR | \ $0.171100|ERCOTAvg4CP|$ 5,380,448 $|\backslash$ 920,595 | | 13 | | | | | | | 14 | Total PFD T&;D Revenue | | | | \$13,996,621 | | 15 | | | | | | | 16 | | | | | | | 17 | | | Distribution | \ $4,144,482|0.002420|\backslash$ 10,030 | | 18 | | | Transmission | \ $9,852,139|0.002420|\backslash$ 23,842 | | 19 | | | Total T&;D | \ $13,996,621|0.002420|\backslash$ 33,872 |

Duggins Wren Mann &; Romero, LLP

POST OFFICE BOX 1149
AUSTIN, TEXAS 78707

600 CONGRESS, SUITE 1900 AUSTIN, TEXAS 78701 TELEPHONE (519) 744-9300 TELEFAX (519) 744-9399

September 28, 2012

Honorable Donna L. Nelson, Chairman Honorable Kenneth W. Anderson, Jr. Honorable Rolando Pablos Public Utility Commission of Texas 1701 N. Congress Ave. Austin, Texas 78701

Re: Docket No. 40742, Compliance Tariff Pursuant to Final Order in Docket No. 38986 (Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment)

Docket (No. 39896; SOAH Docket No. 473-12-2979; Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment

Dear Commissioners: Entergy Texas, Inc. (ETI) has reviewed the corrections to the Commission's final order in Docket No. 39896 proposed in the motion for rehearing of the Commission Staff. ETI agrees that these technical corrections are necessary so that the order will be consistent with the Staff number runs and with the Commission decisions that result in the $\backslash$ 27.7$ million revenue increase approved in this case. ETI further understands that these corrections are not opposed by any party.

The date for the filing of compliance tariffs by the Company, under the Commission's current order, is October 4, 2012. To support implementation of new rates in as timely a fashion as possible (particularly given that the new rates relate back to service rendered on and after June 30, 2012), to support synchronizing the rate increase with the credit being implemented in ETI Docket No. 40542, ^[1] and in light of the absence of opposition to the Staff's proposed changes, it is ETI's intent to file its compliance tariffs on October $4^{\text{th}}$ consistent with the most current Staff number run. This number runs produces the $\backslash$ 27.7$ million revenue increase approved by the Commission, and reflects the ministerial corrections proposed in the Staff's recent motion for

DUGGINS WREN MANN &; ROMERO, LLP

September 28, 2012 Page 2 rehearing (but not yet reflected in the Commission's order). If the Commission makes any changes to its rulings in response to motions for rehearing that affect the approved revenue requirement or rates, ETI will address those changes in the tariff compliance process at that time.

cc: Parties of record

PUC DOCKET NO. 34800
SOAH DOCKET NO. 473-08-0334

This order addresses the application of Entergy Gulf States, Inc. (EGSI) ^[1] for authority to change rates and reconcile fuel costs. The docket was processed in accordance with applicable statutes and Public Utility Commission of Texas rules. EGSI, Commission Staff, the Office of Public Utility Counsel (OPC), the Community Associations of the Woodlands (CATW), the Entergy Texas, Inc. Service Area Cities' Steering Committee (Cities), the State of Texas, Texas Industrial Energy Consumers (TIEC), Texas Legal Services Center (TLSC), Texas Ratepayers' Organization to Save Energy (Texas ROSE), Wal-Mart Stores Texas, LLC, through their duly authorized representatives (Wal-Mart) (collectively, signatories) filed a stipulation and settlement agreement that resolves all of the issues in this proceeding. The Kroger Company and TX Energy, LLC did not sign the stipulation and do not oppose it. Consistent with the stipulation, EGSI's application is approved.

The Commission adopts the following findings of fact and conclusions of law:

I. Findings of Fact

Procedural History

1. On September 26, 2007, EGSI filed an application for approval of: (1) base rate tariffs and riders designed to collect a total non-fuel revenue requirement for the [^0] [^0]: ^[1] On December 31, 2007, EGSI jurisdictionally separated pursuant to $\S 39.452(e)$ of the Public Utility Regulatory Act (PURA), Tex. Util. CODE Ann. Title 2 and Entergy Texas, Inc. (ETI) succeeded to EGSI's certificate of

Texas retail jurisdiction of $\backslash$ 605$ million; (2) a set of proposed tariff schedules presented in the Electric Utility Rate Filing Package for Generating Utilities (RFP) accompanying EGSI's application; (3) a request for final reconciliation of EGSI's fuel and purchased power costs for the reconciliation period from January 1, 2006 to March 31, 2007, as well as deferred costs from prior proceedings; and (4) certain waivers to the instructions in RFP Schedule V accompanying EGSI's application. 2. The 12 -month test year used in EGSI's application ended on March 31, 2007. 3. EGSI provided notice by publication for four consecutive weeks before the effective date of the proposed rate change in newspapers having general circulation in each county of EGSI's Texas service territory. EGSI also mailed notice of its proposed rate change to all of its customers. Additionally, EGSI timely served notice of its statement of intent to change rates on all municipalities retaining original jurisdiction over its rates and services. 4. The following parties were granted intervenor status in this docket: OPC, Alliance for Retail Markets (ARM), CATW, Cities, Kroger Company, State, TIEC, TLSC, Texas ROSE, TX Energy, LLC, and Wal-Mart. ^[2] Commission Staff was also a participant in this docket. 5. On October 1, 2007, the Commission referred this case to the State Office of Administrative Hearings (SOAH) for processing. 6. EGSI appealed the rate decisions adopted by the Cities of Chester, Woodville, Ames, Dayton, Devers, Liberty, New Waverly, Riverside, Trinity, Bedias, Bremond, Caldwell, Calvert, Franklin, Madisonville, Somerville, Patton Village, Cut and Shoot, Willis, Plum Grove, Shepherd, Oak Ridge North, Normangee, Daisetta, Hardin, Corrigan, Groveton, Anderson, Kosse, North Cleveland, Woodloch, Midway, Panorama Village, Taylor Landing, Rose Hill Acres, China, Hearne, Bevil Oaks, Colmesneil, Kountz, Nome, Lumberton, and Todd Mission.

1. As provided for in Order Nos. 3, 9, 12, 14, and 23, the SOAH administrative law judges (ALJs) consolidated EGSI's appeals of the rate decisions adopted by the cities in Finding of Fact No. 6.
2. Cities participated in this case representing the Cities of Beaumont, Bridge City, Conroe, Groves, Houston, Huntsville, Navasota, Nederland, Orange, Pine Forest, Pinehurst, Port Arthur, Port Neches, Rose City, Shenandoah, Silsbee, Sour Lake, Vidor, and West Orange. These municipalities have adopted rates consistent with the stipulation discussed below.
3. The Commission established in its Order on Appeal of Order No. 8 an effective date for EGSI's proposed rate change of September 26, 2008.
4. On April 8, 2008, the State filed a motion for partial summary decision regarding the continued applicability of the $20\%$ base rate discount for state institutions of higher education under $\S 36.351$ of the Public Utility Regulatory Act, Tex. Util. CODE ANN. §§ 11.001-66.016 (Vernon 2007 &; Supp. 2008) (PURA).
5. On July 16, 2008, the SOAH ALJs issued a proposal for decision (PFD) recommending that the Commission grant the State's April 18, 2008 motion for partial summary decision.
6. On August 15, 2008, the Commission entered an order adopting the PFD on the State's motion for partial summary decision.
7. The Commission entered an order on November 4, 2008, extending the effective date of EGSI's proposed rate change until November 27, 2008.
8. Commission Staff, State, and TIEC filed a non-unanimous stipulation (NUS) on May 19, 2008. EGSI and certain other parties filed a separate NUS on May 20, 2008. ^[3] The EGSI NUS was opposed by Commission Staff, State, and TIEC. A hearing was held on both NUSs on June 23 through July 2, 2008.
9. At Open Meetings on October 23 and November 5, 2008, the Commission considered a PFD from the SOAH ALJs which recommended resolution of the rate

case through adoption of the EGSI NUS. On November 7, 2008, the Commission issued its order on remand rejecting the PFD and remanding the docket to SOAH for a hearing on the merits of EGSI's original application. 16. During the November 5, 2008 Open Meeting, EGSI agreed to extend the statutory jurisdictional deadline in this docket to March 2, 2009. EGSI subsequently agreed to extend the statutory jurisdictional deadline to March 16, 2009.4 17. The SOAH ALJs granted ARM's motion to withdraw as an intervenor on December 2, 2008, pursuant to Order No. 49. 18. The hearing on the merits on remand took place on December 3 and 4, 2008, and December 8 through December 12, 2008. The hearing was recessed on December 12, 2008, in order to allow the parties to work on concluding a settlement. 19. On December 16, 2008, the signatories submitted a settlement term sheet to reflect their agreement in principle resolving all outstanding issues regarding EGSI's application, including those issues raised by the Commission in its November 7, 2008 order on remand. 20. On December 16, 2008, the signatories submitted an agreed motion to implement interim rates. 21. On December 19, 2008, the SOAH ALJs filed Order No. 52, granting interim approval of rates consistent with the settlement term sheet, effective with bills rendered on and after January 28, 2009, for usage on and after December 19, 2008. 22. On February 5, 2009, the signatories submitted a stipulation resolving all outstanding issues in this docket. 23. On February 10, 2009, the SOAH ALJs filed Order No. 56, returning this docket to the Commission.

Description of the Stipulation and Settlement Agreement

1. The signatories agree that EGSI will institute an overall increase in base rate revenues of $\backslash$ 46.7$ million.
2. The signatories agree to a reasonable return on equity for EGSI of $10.00\%$ .
3. The signatories agree that the cost of service underlying the base-rate revenue increase does not include any unreasonable or unjust expenses.
4. The signatories agree that EGSI will implement a rate-case-expense rider to recover $\backslash$ 2.3$ million per year for three years. The rate-case expenses will be allocated to customer classes based on total base-rate revenues. The rates established under the rate-case expense rider will be determined based on energy consumption in kilowatt-hours ( kWh ), except for the Large Industrial Power Service (LIPS) customer class, whose rates will be set on a kilowatt ( kW ) basis.
5. The Signatories agree to leave the mechanisms for recovery of EGSI's municipal franchise-fee riders unchanged as a result of this docket.
6. The Signatories agree that EGSI's proposed Market Value Energy Rider (MVER) will not be offered as a result of this docket.
7. The signatories agree that the Incremental Purchased Capacity Recovery Rider (IPCR) will expire contemporaneously with the implementation of rates approved in Order No. 52.
8. The signatories agree that the base-rate revenue increase, the rate-case expense rider and the municipal franchise-fee riders addressed in the stipulation became effective for bills rendered on and after January 28, 2009 for usage on and after December 19, 2008, as approved in Order No. 52.
9. The signatories reached the following specific agreements regarding rate design as a part of the overall resolution of this docket: a. Supplemental Short Term Service (SSTS). Rate Schedule SSTS will terminate six months after a final, appealable order approving the stipulation is issued by the Commission in this docket. Beginning with the

base rates implemented as a result of this stipulation, EGSI will bill SSTS usage as follows: (SSTS charges + LIPS charges)/2. b. Interruptible Service (IS). Rate Schedule IS will be modified as follows: i. 30-minute notice service is eliminated; ii. The credit for 5 -minute notice service is reduced to $\backslash$ 3.75 / \mathrm{kW}$ month; iii. The credit for no-notice service is reduced to $\backslash$ 4.88 / \mathrm{kW}$-month; iv. The credits shall be applied to the LIPS and LIPS-Time of Use (TOU) tariffs (current High Load Factor Service (HLFS) and Large Power Service (LPS) customers will be transferred to LIPS); and v. Rate Schedule IS remains closed to new business. c. Competitive Generation Service. EGSI's competitive generation-service proposal shall not be withdrawn, but shall be severed from this docket and addressed in a separate docket wherein the Commission will (a) exercise its authority to approve, reject, or modify EGSI's proposal; and (b) address recovr. . any costs unrecovered as a result of the implementation of the . .ill. d 'aneous Electric Service Charges. No change shall be made to Miscellaneous Electric Service Charges. e. Lighting Class Rates. Lighting-class rates for all lighting fixtures shall be designed in a manner so that each fixture is charged a uniform base-rate percentage increase as established for the entire lighting class. f. Additional Facilities Charge (AFC). Rate Schedule AFC, governing additional-facilities charge, will be designed to result in a reduction to $1.49\%$ , with the resulting revenue reduction allocated among those customer classes with AFC revenue based on the percentage of AFC revenues in each customer class.

g. Economic as Available Power Service/Standby Maintenance Service. No substantive changes shall be made as a result of this docket to: (a) Rate Schedule EAPS, governing Economic-as-Available Power Service; or (b) Rate Schedule SMS, governing Standby Maintenance Service. h. Interconnection Terms and Conditions. No changes shall be made as a result of this docket to EGSI's terms and conditions regarding costs for interconnection of customers. i. Electric Extension Policy. No changes shall be made as a result of this docket to EGSI's electric extension policy. j. Large Interruptible Power Service. The signatories stipulate that the contract demand ratchet provisions in Rate Schedule LIPS will be retained; provided, however, that the billing demand provision contained in Paragraph V of Rate Schedule SSTS will no longer apply to customers taking service under Rate Schedule LIPS after Rate Schedule SSTS terminates. 33. The signatories agree to the class-cost allocation set forth in Attachment A to the stipulation and further agree that this allocation is reasonable. 34. The signatories agree to a River Bend nuclear generating station 20 -year life extension adjustment to EGSI's calculation of nuclear depreciation and decommissioning costs effective January 1, 2009. 35. The signatories agree that EGSI will reduce depreciation expense related to EGSI's steam production plants by the amount of $\backslash$ 2,731,478$ on a total Texas retail basis effective January 1, 2009. 36. The signatories agree that EGSI will present a new depreciation study as part of its next base-rate case, or by January 5, 2010, whichever is earlier. 37. The signatories agree that the base-rate increase, rate riders, and associated rate design and class-cost allocation agreed to in the stipulation are reasonable and are

reflected in the rate schedules approved by Order No. 52 and revised by errata filings on December 22, 2008, January 27, 2009, and March 5, 2009. 38. The signatories agree that EGSI will fund its Public Benefit Fund at an annualized amount of $\backslash$ 2$ million. 39. In order to include a greater portion of the eligible population in the Public Benefit Fund program, EGSI agrees to use its best efforts to contract for and implement an automatic enrollment program. EGSI's automatic enrollment program will be modeled upon the matching procedures used by other Texas utilities to identify eligible customers and will be implemented within 30 days of the Commission's filing of the final order in this case. 40. The signatories agree that EGSI will amend its low-income energy-efficiency program on a trial basis as specified in the stipulation. 41. The signatories agree that the amendment of EGSI's low-income energy-efficiency program does not increase base rates to recover uncollected expenses associated with revenues billed under EGSI's energy-efficiency rider approved in Docket No. 35626.5 42. The signatories agree to a fuel disallowance of $\backslash$ 4.5$ million, booked in the month of a final Commission order approving the application, consistent with the stipulation. 43. The signatories agree to adopt Commission Staff's position on the following resolution of fuel-related matters set out in Commission Staff's pre-filed direct testimony: (a) recovery of sulfur dioxide $\left(\mathrm{SO} {2}\right) $andnitrousoxide$ \left(\mathrm{NO} {\mathrm{x}}\right)$ emissions revenues recorded in Account 411.8 and expenses recorded in Account 509 will be allowed as eligible fuel expense going forward until further order of the Commission realigning such costs; (b) special circumstances should be granted to treat the costs of natural-gas call options incurred during the reconciliation period

as eligible fuel expense; (c) good cause exists to sever and defer the River Bend performance-based ratemaking (PBR) calculation for the final seven months of the reconciliation period to EGSI's next fuel reconciliation proceeding; and (d) the River Bend PBR plan should terminate in light of EGSI's jurisdictional separation.

Evidence Supporting the Stipulation and Agreement

1. Considered in light of (a) the pre-filed testimony by the parties entered into evidence, and (b) the additional evidence and testimony presented by the parties during the course of the hearing on the merits on EGSI's application, the stipulation is the result of compromise from each party, and these efforts, as well as the overall result of the stipulation viewed in light of the record evidence as a whole, support the reasonableness and benefits of the terms of the stipulation.
2. The evidence addressed in finding of fact 44 demonstrates that the rates, terms, and conditions resulting from the stipulation are just and reasonable and consistent with the public interest when the merits of the issues contested by Commission Staff and intervenors are considered.
3. The stipulated revenue requirement does not include any amounts for financialbased incentive compensation.
4. To the extent that affiliate costs are included in the stipulated revenue requirement and fuel expense, they are reasonable and necessary for each class of affiliate costs presented in EGSI's application.
5. To the extent that affiliate costs are included in the stipulated revenue requirement and fuel expense, the price charged to EGSI is not higher than the prices charged by the supplying affiliate for the same item or class of items to its other affiliates or divisions, or a non-affiliated person within the same market area or having the same market conditions.
6. The Texas retail revenue requirement in the stipulation does not include any of the following expenses, whether allocated or direct-billed to EGSI: legislative advocacy expenses; entertainment; charitable contributions; advertising expense to promote the increased consumption of electricity or to promote the image of the

electric utility industry; advertising products marketed by other affiliates; civil penalties or fines; any other expenses listed in PURA §§ 36.061, 36.062, and 36.063 ; payments made to cover costs of an accident, equipment failure, or negligence at a utility facility owned by a person or governmental body not selling power inside the State of Texas (except those made under an insurance or risksharing arrangement executed before the date of loss); the costs for processing a refund or credit under PURA § 36.110; any profit or loss that results from the sale of merchandise not integral to providing utility service; construction work in progress in rate base; or plant held for future use in rate base. 50. EGSI's current supplemental short-term service, Schedule SSTS, should be terminated within six months after the filing of a final, appealable Commission order in this docket, as provided for in the stipulation. 51. It is reasonable to modify EGSI's current interruptible service, Schedule IS, in accordance with the terms and conditions of the stipulation. 52. It is reasonable in light of the compromise reached in the stipulation for no substantive modifications to be made to EGSI's economic as-available power service, Schedule EAPS, or standby maintenance service, Schedule SMS. 53. The depreciation and decommissioning adjustments for nuclear production assets agreed to in the stipulation and consistent with Louisiana rate treatment are reasonable. 54. The depreciation adjustments to EGSI's steam production assets agreed to in the stipulation are reasonable. 55. The increase in storm cost accruals provided for in the stipulation is reasonable. 56. The low-income programs provided for in the stipulation are reasonable. 57. EGSI's energy-efficiency costs are recovered through a rider approved by the Commission in Docket No. 35626. 58. The PBR plan for the River Bend nuclear generating station contemplates an annual calculation of penalties and rewards. Good cause exists to sever and defer

the PBR calculation for the final seven months of the reconciliation period to EGSI's next fuel reconciliation proceeding. 59. It is reasonable to terminate the application of the PBR plan to the River Bend operations on and after January 1, 2008 when Entergy Texas, Inc. no longer has an ownership interest in River Bend. 60. EGSI is entitled to a special circumstances exception for the cost of the natural-gas call options because they resulted in increased reliability of supply and reduced fuel expense. 61. The class allocation methodologies described in the stipulation are reasonable. 62. The total level of invested capital in the Texas retail revenue requirement is reasonable. 63. The EGSI stipulation proposes to collect the existing incremental franchise fees of the Cities of Beaumont, Port Arthur, and Conroe as a municipal franchise-fee rider. The Commission has reviewed its finding in paragraph II.E of its remand order of November 7, 2008 and determines that the existing incremental franchise fees were the result of franchise agreements adopted subsequent to the passage of PURA $\S 39.456$ .

II. Conclusions of Law

1. EGSI is a public utility as that term is defined in PURA § 11.004(1) and an electric utility as that term is defined in PURA § 31.002(6).
2. The Commission exercises regulatory authority over EGSI and jurisdiction over the subject matter of this application pursuant to PURA §§ 14.001, 32.001, 32.101, $33.002,33.051,36.001-36.111,36.203,39.452$ , and 39.455 .
3. SOAH had jurisdiction over matters related to the conduct of the hearing and the preparation of a proposal for decision in this docket, pursuant to PURA § 14.053 and TEX. Gov't CODE ANN. § 2003.049.

1. This docket was processed in accordance with the requirements of PURA and the Texas Administrative Procedure Act. ^[6]
2. EGSI provided notice of its application in compliance with PURA § 36.103, P.U.C. Proc. R. 22.51(a), and P.U.C. Subst. R. 25.235(b)(1)-(3).
3. This docket contains no remaining contested issues of fact or law.
4. The stipulation, taken as a whole, is a just and reasonable resolution of all the issues it addresses, results in just and reasonable rates, terms and conditions, is supported by a preponderance of the credible evidence in the record, is consistent with the relevant provisions of PURA, and is consistent with the public interest.
5. EGSI has properly accounted for the amount of fuel and IPCR-related revenues collected pursuant to the fuel factor and Rider IPCR during the reconciliation period.

The revenue requirement, cost allocation, revenue distribution, and rate design implementing the stipulation result in rates that are just and reasonable, comply . . . .ue ratemaking provisions in PURA, and are not unreasonably discriminatory, prefer-tial, 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

1. The Commission has reviewed its finding in paragraph II.E of its remand order of November 7, 2008 and determines that because the existing incremental franchise fees were the result of franchise agreements subsequent to the passage of PURA $\S 39.456$ , they qualify as new franchise agreements and are therefore in compliance with PURA $\S 39.456$ when recovered as a municipal franchise-fee rider.
2. The final resolution of the instant docket does not impose any conditions, obligations, or limitations on EGSI's right to file a base-rate proceeding and obtain rate relief in accordance with PURA.
3. Consistent with the stipulation, EGSI has met its burden of proof in demonstrating that it is entitled to the agreed upon level of Texas retail base-rate and rider revenue.
4. Consistent with the stipulation and PURA, EGSI has met its burden of proof in demonstrating that the rates are just and reasonable.

III. Ordering Paragraphs

In accordance with these findings of fact and conclusions of law, the Commission issues the following orders:

1. Consistent with the stipulation, EGSI's application for authority to (a) change its rates; (b) reconcile its fuel and purchased power costs for the Reconciliation Period from January 1, 2006 to March 31, 2007, as well as deferred costs from prior proceedings; and (c) for other related relief is approved.
2. Consistent with the stipulation, the rates, terms, and conditions described in this order are approved.
3. Consistent with the stipulation, the tariffs and riders approved on an interim basis by Order No. 52 and revised by errata on December 22, 2008, January 27, 2009, and March 5, 2009, are approved.

1. Consistent with the stipulation, EGSI shall implement the low-income programs described in this order.
2. Consistent with the stipulation, EGSI's Competitive Generation Services tariff is severed from this docket and shall be addressed in Application of Entergy Texas, Inc. for Approval of Competitive Generation Services Tariff, Docket No. 36713.
3. Consistent with the stipulation, EGSI's storm-cost accruals shall be increased by $\backslash$ 2 $millionforatotalaccrualof$ \ $3.65$ million annually beginning January 1, 2009, which amount will be incorporated in revenues recovered through base rates.
4. Consistent with the stipulation, EGSI shall terminate rate schedule SSTS and Rider IPCR.
5. Consistent with the stipulation, EGSI shall adjust depreciation and decommissioning expense related to the River Bend nuclear generating station and depreciation expense related to EGSI's steam production assets.
6. Consistent with the stipulation, EGSI shall submit a new depreciation study.
7. Consistent with the stipulation, the Rider IPCR and fuel costs, including coalrelated costs deferred from prior proceedings are reconciled and approved through March 31, 2007.
8. EGSI shall adjust its fuel over/under recovery balance consistent with the findings in this order.
9. The entry of this order consistent with the stipulation does not indicate the Commission's endorsement of any principle or methodology that may underlie the stipulation. Neither should entry of this order be regarded as precedent as to the appropriateness of any principle or methodology underlying the stipulation.
10. All other motions, requests for entry of specific findings of fact, conclusions of law, and ordering paragraphs, and any other requests for general or specific relief, if not expressly granted in this order, are hereby denied.

SIGNED AT AUSTIN, TEXAS the $$ day of March 2009

PUBLIC UTILITY COMMISSION OF TEXAS

PUC DOCKET NO. 37744
SOAH DOCKET NO. 473-10-1962

APPLICATION OF ENTERGY TEXAS, INC. FOR AUTHORITY TO CHANGE RATES AND RECONCILE FUEL COSTS

PUBLIC UTILITY COMMISSION
OF TEXAS

ORDER

This Order addresses the application of Entergy Texas, Inc. (ETI) for authority to change rates and reconcile fuel costs. ETI, Commission Staff, the Office of Public Utility Counsel (OPUC), the Steering Committee of Cities Served by ETI (Cities), ^[1] Texas Industrial Energy Consumers (TIEC), The Kroger Company (Kroger), and Wal-Mart Stores Texas, LLC and Sam's East, Inc. (collectively Wal-Mart), through their duly authorized representatives entered into and filed a stipulation and settlement agreement that resolves all of the issues in this proceeding except the issues related to ETI's proposal for competitive generation service. Cottonwood Energy, L.P. and the State of Texas agencies and institutions of higher education (State Agencies) did not join but do not oppose the stipulation.

The Commission severed the competitive generation service issues into Docket No. ${38951}^2$ in Order No. 14.

The Commission adopts the following findings of fact and conclusions of law:

I. Findings of Fact

Procedural History

1. On December 30, 2009, ETI filed an application requesting approval of (1) base rate tariffs and riders designed to collect an overall revenue requirement of $\backslash$ 1,758.4 $million,whichincludesatotalnon-fuelretailrevenuerequirementof$ \ $838.3$ million (base rate revenues of $\backslash$ 486 $millionplusrevenuefromridersof$ \ $352.3$ million); (2) a set of proposed tariff schedules presented in the Electric Utility Rate Filing Package for Generating Utilities (RFP) accompanying ETI's application; (3) a request for final reconciliation of ETI's fuel and purchased power costs for the reconciliation period from April 1, 2007 to June 30, 2009; and (4) certain waivers to the instructions in RFP Schedule V accompanying ETI's application.
2. The 12 -month test year employed in ETI's filing ended on June 30, 2009.
3. ETI provided notice by publication for four consecutive weeks before the effective date of the proposed rate change in newspapers having general circulation in each county of ETI's Texas service territory. ETI also mailed notice of its proposed rate change to all of its customers. Additionally, ETI timely served notice of its statement of intent to change rates on all municipalities retaining original jurisdiction over its rates and services. ETI also published one-time supplemental notice by publication in newspapers and by bill insert.
4. The following parties were granted intervenor status in this docket: OPUC, Cities, Cottonwood, Kroger, State Agencies, TIEC, and Wal-Mart. Commission Staff was also a participant in this docket.
5. On January 4, 2010, the Commission referred this case to the State Office of Administrative Hearings (SOAH) for processing.
6. On February 19, 2010, the ALJs issued Order No. 3, which approved an agreement between ETI, Staff, Cities, State Agencies, OPUC, TIEC, Kroger, and Wal-Mart, to (1) establish an interim rate increase of $\backslash$ 17.5$ million annually above ETI's then-existing base rates commencing with service rendered on and after May 1, 2010 subject to true-up and refund for service rendered prior to September 13, 2010 to the extent final

overall rates established by the Commission amounted to less than a $\backslash$ 17.5$ million rate increase; (2) extend the jurisdictional deadline by which the Commission must issue a final order on the Company's rate request from July 5, 2010 to November 1, 2010; (3) establish a September 13, 2010 effective date for rates such that, notwithstanding the extension of the jurisdictional deadline, the final overall rates established by the Commission would relate back to service rendered on and after September 13, 2010; (4) require ETI to publish supplemental notice, once in newspapers and by a bill insert, setting forth the effect of its proposed rate change in terms of the percentage increase in non-fuel revenues; and (5) establish a procedural schedule and discovery deadlines for this proceeding. Order No. 3 also granted Mr. Kurt Boehm's motion for admission pro hac vice as counsel for Kroger and ETI's February 3 and February 11, 2010 petitions for review of cities' ordinances and motions to consolidate with respect to the rate decisions adopted by the Cities of Ames, Anderson, Bedias, Bevil Oaks, Bremond, Caldwell, Calvert, Chester, China, Colmesneil, Corrigan, Cut and Shoot, Daisetta, Dayton, Devers, Franklin, Groveton, Hardin, Hearne, Iola, Kosse, Kountze, Liberty, Lumberton, Madisonville, Midway, New Waverly, Normangee, Nome, Patton Village, Plum Grove, Riverside, Rose Hill Acres, Somerville, Taylor Landing, Todd Mission, Trinity, and Woodville. 7. On June 14, 2010, the ALJs issued Order No. 6 granting Staff's June 1, 2010 motion and severing rate case expense issues to Docket No. $38346.{}^3$ Through Order No. 6, the ALJs also granted ETI's March 12, April 29, and May 17 petitions for review and motions to consolidate with respect to the rate decisions adopted by the Cities of Anahuac, Beaumont, Bridge City, Cleveland, Conroe, Groves, Houston, Huntsville, Montgomery, Navasota, Nederland, Oak Ridge North, Orange, Panorama Village, Pine Forest, Pinehurst, Port Arthur, Port Neches, Roman Forest, Rose City, Shenandoah, Shepard, Silsbee, Sour Lake, Splendora, Vidor, West Orange, Willis, Woodbranch Village, and Woodloch.

1. The hearing on the merits commenced on July 13, 2010 and was immediately recessed in order to facilitate settlement negotiations. The hearing was again convened on July 15, 2010, at which time the signatories announced their intent to continue settlement discussions to resolve all issues related to the Company's application with the exception of those related to ETI's proposal for competitive generation service (CGS) and associated riders.
2. On August 6, 2010, the signatories submitted the stipulation resolving all outstanding issues regarding the Company's application with the exception of those related to ETI's CGS proposal. Under the stipulation, ETI will be allowed to implement base rate tariffs and riders designed to collect an overall revenue requirement of $\backslash$ 1,614.9$ million, ^[4] which includes a total non-fuel retail revenue requirement of $\backslash$ 694.9 $million(baseraterevenuesof$ \ $599$ million plus revenue from riders of $\backslash$ 95.9$ million). The signatories also submitted, on August 6, 2010, an agreed motion to revise interim rates and to consolidate the severed rate-case expense docket. The interim rates requested in the agreed motion mirrored the final rates proposed for Commission approval in the stipulation. The agreed motion further requested that the ALJs consolidate with the instant proceeding Docket No. 38346, related to severed Docket No. 37744 rate case expense issues, and admit the parties' pre-filed exhibits into evidence.
3. On July 16 and July 20, 2010, the ALJs held the hearing on the merits with respect to ETI's CGS proposal.
4. On August 9, 2010, the ALJs issued Order No. 12, granting approval of revised interim rates for usage on and after August 15, 2010.
5. On October 5, 2010, the ALJs issued a proposal for decision regarding issues related to ETI's CGS proposal.
6. On October 5, 2010, the ALJs issued Order No. 13, ordering the consolidation of Docket No. 38346, related to severed rate-case expense issues, into the instant proceeding, [^0] [^0]: ^[4] This figure includes fuel at test year prices. If current fuel prices are substituted for test year fuel prices, the overall revenue requirement figure would be $\backslash$ 1,504.0$ million.

admitting evidence, and returning this docket to the Commission consistent with the agreed motion filed on August 6, 2010. 14. The Commission considered this Docket at the November 10, 2010 and December 1, 2010 open meetings. 15. On November 30, 2010 ETI filed an unopposed motion to sever the competitive CGS issues from the settled issues in this docket. The Commission granted the motion at the December 1, 2010 open meeting and the Commission's decision was memorialized in Order No. 14 issued on December 3, 2010. The CGS issues were severed into Docket No. 38951 in Order No. 14.

Description of the stipulation and Settlement Agreement

1. The signatories to the settlement stipulated that ETI should be allowed to implement an initial overall increase in base-rate revenues of $\backslash$ 59 $millionforusageonandafterAugust15,2010.ThesignatoriesfurtherstipulatedthattheywouldrequestapprovalofinterimratesbytheALJspresidingorbytheCommission,asnecessary,toensuretimelyimplementationofthisinitialrateincrease.ThesignatoriesfurtherstipulatedthatETIshouldbeallowedtoimplementanadditionaloverallincreaseinbase-raterevenuesof$ \ $9$ million on an annualized basis effective for bills rendered on and after May 2, 2011, the first billing cycle for the revenue month of May.
2. The signatories agreed that ETI's authorized return on equity shall be $10.125\%$ and its weighted average cost of capital shall be $8.5209\%$ .
3. The signatories stipulated that the amount of rate increase authorized under finding of fact 16 includes rate-case expenses and contemplates their full amortization in 2010, and that this amount constitutes the full and final recovery of all rate-case expenses relating to Docket No. 37744.
4. The signatories stipulated to the amount of transmission and distribution invested capital by function as of June 30, 2009 as set out in attachment 1 to the stipulation.

1. The signatories stipulated that the Company's proposed purchased-power recovery rider will not be approved in this docket, and purchased capacity costs will be included in base rates.
2. The signatories stipulated that the Company's proposed transmission cost recovery factor (TCRF) will not be approved in this docket. The signatories stipulated to the baseline values as shown in attachment 2 to the stipulation to be used in the Company's request, if any, for a TCRF in a separate proceeding.
3. The signatories agreed that ETI's proposed cost-of-service adjustment rider and formula rate plan will not be approved in this docket.
4. The signatories stipulated that the Company's proposed renewable-energy-credit rider will not be approved in this docket, and the Company's renewable-energy-credit costs shall be recovered in base rates. The signatories further stipulated that a transmission customer that opts out pursuant to P.U.C. Subst. R. 25.173(j) shall receive a credit that offsets the amount of renewable-energy-credit costs that are recovered in base rates from the transmission customer.
5. The signatories agreed that ETI's proposed remote-communications-link rider should be approved as filed by the Company.
6. The signatories agreed that ETI's proposed market-valued-energy-reduction service rider will not be approved in this docket.
7. The signatories reached the following specific agreements regarding rate design as a part of the overall resolution of this docket: a. Rate Schedule IS. Rate Schedule IS will be opened to new business. In the Company's next base-rate case, the amount of interruptible credits recoverable from Texas retail customers shall be limited to an increase of $\backslash$ 1 $millionmorethantheamountrequestedinthisdocket(oratotalof$ \ $6.8$ million); provided, however, that in the next rate case, the Company may request an exception to this limitation upon a showing that the test-year credit amount in excess of the $\backslash$ 6.8$ million cap is both cost effective and necessary to meet the Company's generation reserve margin requirement. The signatories further agreed that the

Company will not offer additional interruptible service if the availability of total interruptible service supplied by the Company under all interruptible service riders exceeds $5\%$ of the projected aggregate Company peak demand unless the additional level of interruptible service offered in excess of the $5\%$ cap is both cost effective and necessary to meet the Company's generation reserve margin requirement. To the extent that the credit amount or participation level exceeds the limitations described in this paragraph and the Company includes test-year credits over the $\backslash$ 6.8 $millioncredit-amountcaporadditionalparticipationinexcessofthe$ 5 \%$ participation-level cap in its next rate case, the Company shall have the burden to prove whether those test-year credits or participation levels meet the standards established in this paragraph for inclusion in the test year. The standards in this paragraph are in addition to any requirements in PURA for inclusion of costs in rates. The signatories further agreed to the Schedule IS revisions shown on attachment 3 to the stipulation. b. Rate Schedule IHE. The signatories agreed that no change shall be made to rate schedule IHE in this docket. c. Liebling Class Rates. The signatories stipulated that the language under the paragraph relating to rate group C in rate schedule SHL will be revised to reflect that, where the Company agrees to install facilities other than its standard street light fixture and lamp as provided under Rate Group A, a lump sum payment will be required, based upon the installed cost of all facilities excluding the cost of the standard street light fixture and lamp, and the customer will be billed under rate group A. e. Electric Extension Policy. The signatories agreed to the line-extension terms and conditions as reflected in attachment 4 to the stipulation. f. Life-of-Contract Demand Ratchet. The signatories agreed that the life-of-contract demand ratchet provision in rate schedules Large Industrial Power Service, Large Industrial Power Service-Time of Day, General Service, General Service-Time of Day, Large General Service, and Large General Service-Time of

Day shall be excluded from rate schedules in ETI's next rate case. The signatories further stipulated that the foregoing rate schedules will be revised so that the life-of-contract demand ratchet provision shall not be applicable to new customers and shall not exceed the level in effect on August 15, 2010 for existing customers. g. Residential Customer Charge. The signatories agreed that the residential customer charge shall be increased to $\backslash$ 5.00$. h. Non-Sufficient Funds Charge. The signatories agreed that the non-sufficient funds charge shall be increased to $\backslash$ 15.00$. 27. The signatories agreed to the class cost allocation set forth in attachment 5 to the stipulation. 28. The signatories stipulated that the appropriate allocation between ETI's wholesale and retail jurisdictions of baseline values and costs to be included in a TCRF is to be addressed in the proceeding, if any, in which ETI seeks approval of a TCRF. 29. The signatories stipulated that no party waives its right to address in any subsequent proceeding the appropriate treatment for Texas retail ratemaking purposes of power sales between ETI and Entergy Gulf States Louisiana, L.L.C. 30. The signatories reached the following specific agreements regarding fuel-related issues as part of the overall resolution of this docket: a. Agreed Fuel Disallowance. The Company stipulated to a fuel disallowance of $\backslash$ 3.25$ million not associated with any particular issue raised by the signatories. The disallowance will be allocated pro rata with interest over each month of the reconciliation period and reflected in the refund in Docket No. 38403. ^[5] The signatories stipulated that the Company's fuel costs shall be finally reconciled for the reconciliation period of April 1, 2007 through June 30, 2009. b. Rider IPCR. The signatories agreed that ETI's eligible Rider IPCR costs for the

period April 1, 2007 through the date the rider terminated shall be finally reconciled with a disallowance of $\backslash$ 300,000$. The signatories further agreed that the under-recovered balance of Rider IPCR costs shall be booked as fuel expense in the month in which the Commission issues an order adopting the stipulation; provided, however, that the under-recovered balance shall be allocated to customer classes using A&;E4CP. c. Rough Production Cost Equalization (RPCE) Payments. The signatories agreed that ETI will credit an additional $\backslash$ 18.6$ million to Texas fuel-factor customers, which the signatories stipulated represents the remaining portion of RPCE payments ETI received in 2007 that were at issue in Docket No. 35269. ^[6] The RPCE credit shall be allocated to rate classes based on loss-adjusted kilowatt hours at plant for calendar year 2006. For customers in the Large Industrial Power Service rate class, the credit will be refunded based on the customer's actual kWh usage during the billing months of January 2006 through December 2006. Upon issuance of a final order approving the stipulation, the RPCEs shall be credited to customers as a separate one-month bill credit in the same form as the RFCEA Rider last approved in Docket No. 38098. ^[7] ETI agreed that it will terminate all appeals related to Docket No. 35269. 31. The signatories agreed that ETI will continue its accrual of storm-cost reserves at the level of $\backslash$ 3.65$ million annually and that this amount shall be subsumed in the base-rate revenue increase described in finding of fact 16 above. 32. The signatories agreed that ETI shall maintain River Bend depreciation rates at current levels, i.e., based on a 60 -year life. River Bend decommissioning costs will be set at $\backslash$ 2,019,000 $annually,whichisbaseduponalabor-factorescalationrateof$ 1.67 \% $,anenergy-factorescalationrateof$ 0.25 \%$, and a waste-burial-factor-escalation rate of

$1.71\%$ , resulting in an overall escalation rate of $3.62\%$ , and net investment yields as follows:

| | | | | :-- | :--: | :--: | | | Tax-Qualified | Non-Tax-Qualified | | | Investments | Investment | | 2010 | $5.475\%$ | $5.057\%$ | | 2011 | $5.837\%$ | $5.236\%$ | | 2012 | $6.306\%$ | $5.567\%$ | | 2013 | $6.304\%$ | $5.607\%$ | | 2014 | $6.481\%$ | $5.896\%$ | | 2015 | $6.493\%$ | $5.909\%$ | | 2016 | $6.412\%$ | $5.826\%$ | | 2017 | $6.412\%$ | $5.830\%$ | | 2018 | $6.364\%$ | $5.790\%$ | | 2019 | $6.316\%$ | $5.748\%$ | | 2020 | $6.268\%$ | $5.712\%$ | | 2021 | $6.220\%$ | $5.670\%$ | | 2022 | $2.503\%$ | $5.458\%$ | | 2023 | $5.817\%$ | $5.055\%$ | | 2024 | $5.382\%$ | $4.628\%$ | | 2025 | $5.036\%$ | $4.516\%$ | | 2026-2034 | $4.920\%$ | $4.409\%$ |

1. The signatories stipulated that the Company's depreciation rates for non-River Bend production plant, transmission, distribution, and general plant will remain at current levels and the Company will maintain its accounting records on a prospective basis for purposes of depreciation accrual, depreciation reserve, retirements, additions, salvage, and cost of removal by FERC account.

Consistency of the Agreement with PURA and the Commission Requirements

1. Considered in light of (1) the pre-filed testimony by the parties entered into evidence and (2) the additional evidence and testimony admitted during the course of the hearing on the merits on the Company's application, the stipulation is the result of compromise from each signatory, and these efforts, as well as the overall result of the stipulation viewed in light of the record evidence as a whole, support the reasonableness and benefits of the terms of the stipulation.

1. The evidence addressed in finding of fact 34 demonstrates that the rates, terms, and conditions resulting from the stipulation are just and reasonable and consistent with the public interest.
2. The total level of the Texas retail revenue requirement contemplated by the stipulation will allow ETI the opportunity to earn a reasonable return over and above its reasonable and necessary operating expense.
3. The stipulated revenue requirement is consistent with applicable provisions of PURA chapter 36 and the Commission's rules.
4. To the extent that affiliate costs are included in the stipulated revenue requirement and fuel expense, they are reasonable and necessary for each class of affiliate costs presented in ETI's application.
5. To the extent that affiliate costs are included in the stipulated revenue requirement and fuel expense, the price charged to ETI is not higher than the prices charged by the supplying affiliate for the same item or class of items to its other affiliates or divisions, or a non-affiliated person within the same market area or having the same market conditions.
6. The retail revenue requirement in the stipulation does not include any expenses prohibited from recovery under PURA.
7. A return on equity of $10.125\%$ and a weighted average cost of capital of $8.5209\%$ for ETI should be adopted consistent with the stipulation.
8. The agreed rate-design provisions and terms and conditions of service included in the stipulation are just and reasonable.
9. The treatment of rate-case expenses described in the stipulation is reasonable.
10. The Company's proposed remote-communications-link rider as filed by the Company is reasonable.
11. The depreciation rates agreed to in the stipulation are just and reasonable.

1. The recovery of $\backslash$ 2,019,000$ annually for decommissioning costs of nuclear production assets based on the factors agreed to in the stipulation is reasonable.
2. A $\backslash$ 3.65$ million annual storm cost accrual is reasonable.
3. The class allocation methodologies described in the stipulation are just and reasonable.
4. The fuel and IPCR-related provisions of the stipulation are reasonable.

II. Conclusions of Law

1. ETI is a public utility as that term is defined in PURA § 11.004(1) and an electric utility as that term is defined in PURA § 31.002(6).
2. The Commission exercises regulatory authority over ETI and jurisdiction over the subject matter of this application pursuant to PURA §§ 14.001, 32.001, 32.101, 33.002, 33.051, $36.001-\mathrm{.111},36.203,39.452$ , and 39.455 .
3. SOAH has jurisdiction over matters related to the conduct of the hearing and the preparation of a proposal for decision in this docket, pursuant to PURA § 14.053 and Tex. Gov't CODE ANN. § 2003.049.
4. This docket was processed in accordance with the requirements of PURA, the Texas Administrative Procedure Act, ^[8] and Commission rules.
5. ETI provided notice of its application in compliance with PURA § 36.103, P.U.C. Proc. R. 22.51(a), and P.U.C. Subst. R. 25.235(b)(1)-(3).
6. This docket contains no remaining contested issues of fact or law.
7. The stipulation, taken as a whole, is a just and reasonable resolution of all issues it addresses; results in just and reasonable rates, terms, and conditions; is supported by a preponderance of the credible evidence in the record; is consistent with the relevant provisions of PURA; and is consistent with the public interest.
8. ETI has properly accounted for the amount of fuel and IPCR-related revenues collected pursuant to the fuel factor and Rider IPCR. [^0] [^0]: ^[8] Tex. Gov't CODE Ann. Chapter 2001 (Vernon 2007 and Supp. 2009).

1. The revenue requirement, cost allocation, revenue distribution, and rate design implementing the stipulation result in rates that are just and reasonable, comply with the ratemaking provisions in PURA, and are not unreasonably discriminatory, preferential, or prejudicial.
2. Based on the evidence in this docket, the overall total invested capital through the end of the test year meets the requirement in PURA § 36.053(a) that electric utility rates be based on the original cost, less depreciation, of property used by and useful to the utility in providing service.
3. ETI has met its burden of proof in demonstrating that it is entitled to the level of retail base rate and rider revenue set out in the stipulation.
4. ETI has met its burden of proof in demonstrating that the rates resulting from the stipulation are just and reasonable, and consistent with PURA.

III. Ordering Paragraphs

1. ETI's application seeking authority to change its rates; reconcile its fuel and purchased power costs for the Reconciliation Period from April 1, 2007 to June 30, 2009; and for other related relief is approved consistent with the above findings of fact and conclusions of law.
2. Rates, terms, and conditions consistent with the stipulation are approved.
3. The tariffs and riders consistent with the stipulation are approved for the initial and second step rate increases.
4. ETI's request for waivers of RFP instructions (RFP Schedule V) is granted.
5. ETI shall adjust decommissioning expense related to the River Bend Nuclear Generating Station consistent with the terms of this Order.
6. Neither the stipulation and settlement agreement nor this Order constitutes the Commission's agreement with, or consent to, the manner in which ETI, or any entity affiliated with ETI, has interacted with any decommissioning trust to which ETI or its ratepayers have made contributions or provided funds. Furthermore, this Order in no

way constitutes a waiver or release of any conduct, whether or not such conduct occurred before the date of this Order, that may constitute a violation of any provision of state law, including, without limitation, the rules and regulations of this Commission relating to nuclear decommissioning trust funds; or prevents the Staff of the Commission from opening an investigation and taking enforcement action relating to violations of such rules and regulations. 7. Nothing contained in this Order constitutes the consent or approval, explicit or implied, of any modification, amendment or clarification of any power purchase agreement between ETI and any other Entergy entity relating to the River Bend Station. Without limiting the foregoing, nothing contained in this Order shall constitute the consent or approval of any modification, amendment, or clarification of any power purchase agreement between ETI and any other Entergy entity relating to the River Bend Station, which is made to address any concerns raised by the NRC in its Request for Additional Information regarding the River Bend Station dated March 11, 2010. 8. The Rider IPCR costs and eligible fuel costs requested by ETI are, consistent with this Order, reconciled through June 30, 2009, and are approved consistent with the stipulation. 9. ETI shall adjust its fuel over/under recovery balance consistent with the findings in this Order. 10. ETI shall file an RPCEA Rider consistent with the above findings of fact and conclusions of law to be effective with the first billing cycle of the billing month immediately following the effective date of this Order. 11. Because the final approved rates are equal to or higher than the interim rates adopted in Order No. 3, no refund of the interim rates authorized by Order No. 3 is necessary. 12. The interim rates approved in Order No. 12 are herby approved for the initial step rate increase contemplated by the stipulation, and ETI shall implement the second step rates for bills rendered on and after May 2, 2011, the first billing cycle for the revenue month of May.

1. Within 30 days of the date of this Order, ETI shall file a clean copy of all of the tariffs and schedules approved in this docket and a clean copy of the attachments to the stipulation.
2. The entry of this Order consistent with the stipulation does not indicate the Commission's endorsement of any principle or method that may underlie the stipulation. Neither should entry of this Order be regarded as a precedent as to the appropriateness of any principle or methodology underlying the stipulation.
3. All other motions, requests for entry of specific findings of fact, conclusions of law, and ordering paragraphs, and any other requests for general or specific relief, if not expressly granted in this order, are hereby denied.

SIGNED AT AUSTIN, TEXAS the $\frac{124}{130}$ day of December 2010

PUBLIC UTILITY COMMISSION OF TEXAS

BARRY T. SMITHERMAN, CHAIRMAN

DONNA L. NELSON, COMMISSIONER

SOAH DOCKET NO. 473-12-2979
PUC DOCKET NO. 39896

SUPPLEMENTAL PRELIMINARY ORDER

This Order identifies issues not to be addressed and additional issues to be addressed in this docket regarding Entergy Texas, Inc.'s request for a purchased-power recovery rider and Entergy's request to establish baseline values for a transmission cost recovery factor and a distribution cost recovery factor for future use when those two riders are implemented. ^[1]

Entergy filed its application for authority to change rates and to reconcile fuel costs pursuant to PURA ^[2] §§ 14.001, 32.001, 32.101, 36.101-.111, and 36.203-.206 on November 28, 2011. On November 29, 2011, the Commission issued an order referring this docket to the State Office Administrative Hearings (SOAH). On December 7, parties were requested to submit briefs regarding the purchased-power recovery rider and the request to establish baseline values for a transmission cost recovery factor and distribution cost recovery factor. The parties were notified that the Commission would consider a supplemental preliminary order to address the issues briefed. Entergy, Texas Industrial Energy Consumers, Commission Staff, and State Agencies filed responses to the order requesting briefing.

I. Supplemental Threshold Legal/Policy Determinations

The following statements of position were reached in consideration of the arguments of the parties: Issue No. 1 Should the Commission consider Entergy's proposed purchased-power recovery rider in this docket?

In its application in this docket, Entergy requested approval of a purchased-power recovery rider to recover all existing purchased capacity costs as well as future capacity costs. Entergy's proposal includes a mechanism to update the rider annually to reflect increases or decreases in purchased capacity costs and a reconciliation of costs recovered under the rider in Entergy's fuel reconciliation cases. To the extent any of the riders proposed by Entergy are not approved, Entergy has proposed to recover the associated costs through its base rates or other rate mechanism designed to recover non-fuel production-related costs.

The Commission finds that Entergy's proposed purchased-power recovery rider should not be considered in this docket due to the related rulemaking that is pending in Project No. 39246. ^[3] However, the Commission also finds it is appropriate to determine the amount of purchased-capacity costs in Entergy's rates in this docket. Issue No. 2 Is it appropriate and necessary to establish baseline values in this docket for a transmission cost recovery factor and distribution cost recovery factor that will be established in future dockets?

The Commission finds that it is appropriate and necessary to establish in this docket the baseline values that will be used to calculate Entergy's transmission cost recovery factor and distribution cost recovery factor in future dockets.

II. Supplemental Issues to be Addressed

1. What is the amount of purchased-capacity costs that are proposed to be included in Entergy's base rates? [^0] [^0]: 3 Rulemaking Concerning Recovery of Purchased Power Capacity Costs, Including Amendment of Substantive Rule 25.238, Project No. 39246 (pending).

1. What are the baseline values that should be used for calculating Entergy's future transmission cost recovery factor and distribution cost recovery factor?

This list of issues is not intended to be exhaustive. The parties and the ALJ are free to raise and address any issues relevant in this docket that they deem necessary, subject to any limitations imposed by the ALJ or by the Commission in future orders issued in this docket. The Commission reserves the right to identify and provide to the ALJ in the future any additional issues or areas that must be addressed, as permitted under TEX. Gov't CODE ANN. § 2003.049(e).

III. Issues Not to be Addressed

For the reasons discussed, Entergy's request for a purchased-power recovery rider shall not be addressed in this docket.

IV. Effect of Supplemental Preliminary Order

The Commission's discussion and conclusions in this Order regarding threshold legal and policy issues and issues that are not to be addressed should be considered dispositive of those matters. Questions, if any, regarding threshold legal and policy issues and issues that are not to be addressed may be certified to the Commission for clarification if the SOAH ALJ determines that such clarification is necessary. As to all other issues, this Order is preliminary in nature and is entered without prejudice to any party expressing views contrary to this Order before the SOAH ALJ at hearing. The SOAH ALJ, upon his or her own motion or upon the motion of any party, may deviate from the non-dispositive rulings of this Order when circumstances dictate that it is reasonable to do so. Any ruling by the SOAH ALJ that deviates from this Order may be appealed to the Commission. The Commission will not address whether this Order should be modified except upon its own motion or the appeal of a SOAH ALJ's order. Furthermore, this Order is not subject to motions for rehearing or reconsideration.

SIGNED AT AUSTIN, TEXAS the $\frac{14}{1}$ day of January 2012.

PUBLIC UTILITY COMMISSION OF TEXAS

DONNA L. NELSON, CHAIRMAN

ROLANDO PABLOS, COMMISSIONER

ENTERGY TEXAS, INC. PUBLIC UTILITY COMMISSION OF TEXAS SOAH DOCKET NO. 473-12-5573
PUC DOCKET NO. 40295

| Response of: Entergy Texas, Inc. to the First Set of Data Requests of Requesting Party: Office of Public Utility Counsel | Prepared By: Michael P. Considine Sponsoring Witness: Michael P. Considine Beginning Sequence No. 5513 | | :--: | :--: | | | Ending Sequence No. 5513 | | Question No.: OPUC 1-1 | Part No.: Addendum: | | Question: | |

Please state whether the rate case expenses sought to be recovered in this proceeding, Docket No. 40295, include expenses related to the regulatory approval of the Calpine Power Purchase Agreement (PPA) sought in PUC Docket No. 39896.

Response: Yes.

ENTERGY TEXAS, INC. PUBLIC UTILITY COMMISSION OF TEXAS
SOAH DOCKET NO. 473-12-5573
PUC DOCKET NO. 40295

| Response of: Entergy Texas, Inc. to the First Set of Data Requests of Requesting Party: Office of Public Utility Counsel | Prepared By: Michael P. Considine Sponsoring Witness: Michael P. Considine Beginning Sequence No. 6511 | | :--: | :--: | | | Ending Sequence No. 6511 |

Question No.: OPUC 1-2 Part No.: Addendum:

Question: If your answer to OPUC's RFI No. 1-1 is yes: a. State the amount of expenses requested in this proceeding that are associated with regulatory approval of the Calpine PPA. b. State whether the amount of said expenses was also requested as an affiliate expense related to project code F3PPWET308 in Docket No. 39896. c. Provide the basis for recovery of said expenses in Docket No. 40295. d. Provide a recalculation of your Docket No. 39896 requested recovery without these expenses. Include in your response the underlying data and calculations in native format.

Response: a. Costs associated with the regulatory approval of a specific PPA are not accounted for separately. Costs are accumulated on a project level basis and relate to the rate case project as a whole. b. No. c. The regulatory approval of the Calpine PPA was part of the overall rate case presented by the Company. The allowance or disallowance of particular costs by the Commission does not preclude the Company from recovering regulatory expenses incurred seeking recovery of such costs. d. See the response to part a.

ENTERGY TEXAS, INC. PUBLIC UTILITY COMMISSION OF TEXAS SOAH DOCKET NO. 473-12-5573
PUC DOCKET NO. 40295

| Response of: Entergy Texas, Inc. to the First Set of Data Requests of Requesting Party: Office of Public Utility Counsel | Prepared By: Michael P. Considine Sponsoring Witness: Michael P. Considine Beginning Sequence No. 5615
Ending Sequence No. 5615 | | :--: | :--: | | Question No.: OPUC 1-3 | Part No.: Addendum: | | Question: | |

If your answer to OPUC's RFI No. 1-1 is no, please provide data and other information to show that the amount being recovered as an affiliate expense related to project code F3PPWET308 in Docket No. 39896 has not also been requested for recovery in this proceeding as a rate case expense.

Response: See the response to OPUC 1-1.

ENTERGY TEXAS, INC. PUBLIC UTILITY COMMISSION OF TEXAS SOAH DOCKET NO. 473-12-2979
PUC DOCKET NO. 39896 - 2011 ETI Rate Case

Response of: Entergy Texas, Inc. to the Third Set of Data Requests of Requesting Party: Office of Public Utility Counsel

Prepared By: J. Stephen Dingle Sponsoring Witness: Patrick J. Cicio Beginning Sequence No.

Ending Sequence No.

Question No.: OPUC 3-17 Part No.: Addendum:

Question: a. Please explain why ETI will continue to incur expenses for negotiations related to the Calpine purchased power agreement after the test year. b. Explain in detail the Calpine PPA negotiation expenses that will be expected to be incurred in 2012 and 2013. c. Provide documentation supporting your response.

Response: a. The costs recorded in Project Code F3PPWET308 include costs associated with obtaining regulatory approval for the Calpine Contract, which processes extend beyond the test year. The Company expects to incur similar expenses in the future on an ongoing basis. b. These will be costs associated with responding to issues arising within the pending rate case in Texas, as well as participating in LPSC Docket No. U-30321. c. See the Project Summary for Project Code F3PPWET308 in Exhibit SBT-E.

ENTERGY TEXAS, INC. PUBLIC UTILITY COMMISSION OF TEXAS SOAH DOCKET NO. 473-12-2979
PUC DOCKET NO. 39896 - 2011 ETI Rate Case

Response of: Entergy Texas, Inc. to the Ninth Set of Data Requests of Requesting Party: Office of Public Utility Counsel

Prepared By: J. Stephen Dingle/Joe Bennett Sponsoring Witness: Patrick J. Cicio/Michael P. Considine Beginning Sequence No. 59154 Ending Sequence No. 59154

Question No.: OPUC 9-6 Part No.: Addendum:

Question: a. Regarding ETI's response to OPC RFI No. 3-17, is ETI implying that any rate case expenses related to the Calpine Contract in Docket No. 39896 (e.g. RFI responses, legal fees) will be charged to F3PPWET308? Please explain your response. b. Are there any other instances where Docket No. 39896 expenses are being charged to multiple projects? If so, please identify all costs and the associated project numbers.

Response: a. No rate case expenses were charged to that project code, although costs for that project code were included in ETI's costs. b. All costs pertaining to Docket No. 39896 should be recorded in Project Code F5PPETX011.

ENTERGY TEXAS, INC. PROJECT SUMMARY

Project Code

F3PPWET308

Description

SPO Calpine PPA/Project Houslo

2011 TX Rate Case Page 1168

ESI
Billing Method

OIRECTTX

Test Year Affiliate Billings to ETI:

| Account | Total | Exclusions | Pro Forma | Adjusted | | :--: | :--: | :--: | :--: | :--: | | 254000 - A/P - Affiliate | 0 | 0 | 0 | 0 | | 403100 - Deprecization Exp-Serv Co Alloc | 7,241 | 0 | 0 | 7,241 | | 4031AM - Deprec Exp billed from Serv Co | 5,168 | 0 | 0 | 5,168 | | 408110 - Employment Taxes | 11,679 | 0 | 412 | 12,091 | | 426500 - Other Oeductions | 0 | 0 | 0 | 0 | | 500000 - Oper Supervision &; Engineerm | 1,548 | 0 | 37 | 1,585 | | 506000 - Misc Steam Power Expenses | 2,931 | 0 | 70 | 3,001 | | 920000 - Adm &; General Salaries | 209,513 | 0 | 4,361 | 213,874 | | 921000 - Otfice Supplies And Expenses | 2,035 | 0 | 0 | 2,035 | | 923000 - Outside Services Employed | 110,951 | 0 | 0 | 110,951 | | 925000 - Employee Pension &; Benefits | 82,844 | 0 | $-555$ | 82,288 | | 930200 - Miscellaneous General Expense | $-2,271$ | 0 | 0 | $-2,271$ | | Total | 431,639 | 0 | 4,324 | 435,983 |

Detail By Class:

| Class | Total | Exclusions | Pro Forma | Adjusted | | :-- | --: | --: | --: | --: | | ENERGY ANO FUEL MANAGEMENT | 94,945 | 0 | $1,996·$ | 96,941 | | FEOERAL PRG AFFAIRS | 1,206 | 0 | $-1,206$ | 0 | | FOSSIL PLANT OPERATIONS | 7,037 | 0 | 139 | 7,176 | | TREASURY OPERATIONS | 12,539 | 0 | 245 | 12,784 | | HUMAN RESOURCES | 37,837 | 0 | $-67$ | 37,770 | | LEGAL SERVICES | 255,552 | 0 | 2,918 | 258,470 | | OTHER EXPENSES | 3,722 | 0 | 171 | 3,893 | | FINANCIAL SERVICES | 6,195 | 0 | 124 | 6,319 | | DEPRECIATION | 12,409 | 0 | 0 | 12,409 | | TAX SERVICES | 197 | 0 | 4 | 201 | | Total | 431,639 | 0 | 4,324 | 435,983 |

Scope of Work

Statement of Purpose: The overall purpose of this project is to capture and manage costs associated with the Power Purchase Agreement (PPA) from Calpine Corporation for Entergy Texas, Inc. (ETI).

Primary Aclivities: The primary activity associated with this project is the negotiations of the long-term PPA for the delivery of electric capacity, energy and other associated electric products from the Carville Facility for ETI.

Primary Products or Deliverables: The primary products or deliverables of this project are an executed and approved long-term PPA with Calpine Corporation for the delivery of electric capacity, energy and other associated electric products from the Carville facility to meet ETI's short and long-term capacity needs.

Justification of Billing Method: The costs associated with the project will include the internal and third-party costs associated with the PPA's negotiations. Amounts may not add or te to other schedules due to rounding. Project Code F3PPWET308

ENTERGY TEXAS, INC. PROJECT SUMMARY

Project Code

F3PPWET308

development, review and internal/regulatory approval process. These costs may lead to the execution of a long-term PPA with Calpine Corporation for the delivery of electric capacity, energy and other associated electric products from the Carvijie Facility that would benefit ETI and should therefore be charged only to ETI via billing method DIRECTTX.

ETI Exhibit No. 1

DOCKET NO. 39896

| APPLICATION OF ENTERGY | § | PUBLIC UTILITY COMMISSION | | :-- | :--: | :--: | | TEXAS, INC. FOR AUTHORITY | § | | | TO CHANGE RATES AND | § | OF TEXAS | | RECONCILE FUEL COSTS | § | |

DIRECT TESTIMONY

OF

MICHAEL P. CONSIDINE

ON BEHALF OF

ENTERGY TEXAS, INC.

NOVEMBER 2011

ENTERGY TEXAS, INC. DIRECT TESTIMONY OF MICHAEL P. CONSIDINE 2011 RATE CASE

TABLE OF CONTENTS

| I. | Witness Introduction and Qualifications | 1 | | :-- | :-- | --: | | II. | Purpose of Testimony | 2 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

F. Schedule G - Accounting Information ..... 35

1. Rate Case Expense Schedules ..... 52

VI. Rate Case Expenses ..... 60 VII. Conclusion ..... 62

| 1 | I. | WITNESS INTRODUCTION AND QUALIFICATIONS | | :--: | :--: | :--: | | 2 | Q. | PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. | | 3 | A. | My name is Michael P. Considine. My business address is 425 West | | 4 | | Capitol Avenue, Little Rock, Arkansas 72201. I am employed by Entergy | | 5 | | Services, Inc., the service company affiliate of Entergy Texas, Inc. ("ETI" | | 6 | | or the "Company") as a Senior Staff Accountant in the Rate Design and | | 7 | | Administration Department. | | 8 | | | | 9 | Q. | ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING? | | 10 | A. | I am testifying on behalf of Entergy Texas, Inc. ("ETI" or the "Company"). | | 11 | | | | 12 | Q. | DESCRIBE BRIEFLY YOUR EDUCATIONAL BACKGROUND AND | | 13 | | PROFESSIONAL EXPERIENCE. | | 14 | A. | I received a Bachelor of Science Degree in Professional Accountancy | | 15 | | from Louisiana Tech University in 2000. I began my career with Altel | | 16 | | Communications, first as an accountant in the general accounting | | 17 | | department, and then as a financial analyst in the financial planning | | 18 | | department. In October 2001, I accepted a position as an analyst in the | | 19 | | Transmission Business Operations department of Entergy Services, Inc. | | 20 | | In this regard, I was responsible for Open Access Transmission Tariff | | 21 | | ("OATT") monthly billings and the development of enhanced billing | | 22 | | processes for OATT customers. I transferred to the Rate Design and |

| 1 | from the PUC. The Company will collect actual expenses related to this | | :--: | :--: | | 2 | case and submit the expense amounts, along with supporting testimony, | | 3 | in accordance with the procedural schedule ultimately adopted by the | | 4 | Administrative Law Judge. | | 5 | | | 6 | Q. ARE COSTS OF ESI INCLUDED IN RATE CASE EXPENSE? | | 7 | A. Yes. ETI uses the services of ESI in preparing rate filings. Employees of | | 8 | ESI, such as myself, were required and needed to provide support or | | 9 | testimony in this proceeding. | | 10 | | | 11 | Q. PLEASE DESCRIBE THE PROCEDURE FOR REVIEWING THE | | 12 | COMPANY'S ACTUAL RATE CASE EXPENSES. | | 13 | A. There are a number of consultants and outside lawyers involved in | | 14 | preparing this rate case. The consultants have been retained by ESI or | | 15 | the Company or have been retained by legal counsel representing the | | 16 | Company to provide specialized work needed to support the rate filing. | | 17 | When billings are received from the consultants or through legal | | 18 | counsel, the appropriate personnel review the charges and approve them | | 19 | for payment. The bill is then forwarded to Accounts Payable for payment. | | 20 | Accounts Payable personnel review each bill submitted for payment to | | 21 | determine that proper approval has been made. |

Entergy Texas, Inc. Page 62 of 62 Direct Testimony of Michael P. Considine 2011 Rate Case

1 Q. HOW DOES THE COMPANY PROPOSE TO RECOVER RATE CASE 2 EXPENSES? 3 A. The Company proposes that it be permitted to recover these costs over a 4 three-year period, with a return on the unamortized balance.

5 6 VII. CONCLUSION 7

14 15 Q. DOES THIS CONCLUDE YOUR PREFILED DIRECT TESTIMONY? 16 A. Yes.

ETI Exhibit No. 7

SOAH DOCKET NO. 473-12-5573 PUCT DOCKET NO. 40295

APPLICATION OF ENTERGY TEXAS, INC. FOR RATE CASE EXPENSES PERTAINING TO PUC DOCKET NO. 39896 § BEFORE THE STATE OFFICE OF $\S$ ADMINISTRATIVE HEARINGS §

REBUTTAL TESTIMONY

OF

MICHAEL P. CONSIDINE

ON BEHALF OF

ENTERGY TEXAS, INC.

NOVEMBER 15, 2012

ENTERGY TEXAS, INC. REBUTTAL TESTIMONY OF MICHAEL P. CONSIDINE PUCT DOCKET NO. 40295

TABLE OF CONTENTS

Page I. WITNESS INTRODUCTION ..... 1 II. PURPOSE OF REBUTTAL TESTIMONY ..... 1 III. REBUTTAL ISSUES ..... 2 A. Allocation of Rate Case Expenses ..... 2 B. Return on the Unamortized Balance ..... 3 C. Frequency of Rate Cases ..... 4 D. Calpine-Carville PPA ..... 5 E. Costs Billed by Company Consultant Gerald Tucker ..... 7 F. Depreciation ..... 9 EXHIBITS

MPC-R-1: Excerpts from ETI's Response to Staff 9-1, Addendum 3

| 1 | | 1. | WITNESSINTRODUCTION | | :--: | :--: | :--: | :--: | | 2 | Q. | | PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. | | 3 | A. | My name is Michael P. Considine. My business address is 425 West | | | 4 | | Capitol Avenue, Little Rock, Arkansas 72201. I am employed by Entergy | | | 5 | | Services, Inc. ("ESI"), the service company affiliate of Entergy Texas, Inc. | | | 6 | | ("ETI" or the "Company") as a Manager in the Regulatory Accounting | | | 7 | | Department. I was formerly a Senior Staff Accountant in the Regulatory | | | 8 | | Accounting Department during Docket No. 39896. As a Manager in | | | 9 | | Regulatory Accounting, I am responsible for managing the work of those | | | 10 | | gathering, preparing, and analyzing accounting data for the Operating | | | 11 | | Companies for use in preparing rate filings. This includes coordination of | | | 12 | | accounting-related schedules and testimony filed with the various | | | 13 | | regulatory commissions that have jurisdiction over the Operating | | | 14 | | Companies. | | | 15 | | | | | 16 | Q. | ARE YOU THE SAME MICHAEL P. CONSIDINE THAT PREVIOUSLY | | | 17 | | FILED TESTIMONY IN BOTH DOCKET NO. 39896 AND THIS DOCKET? | | | 18 | A. | Yes. | | | 19 | | | | | 20 | | II. | PURPOSE OF REBUTTAL TESTIMONY | | 21 | Q. | WHAT IS THE PURPOSE OF THIS REBUTTAL TESTIMONY? | | | 22 | A. | The purpose of my rebuttal testimony is to respond to various issues | | | 23 | | raised in Staff and Intervenor Direct Testimonies and Recommendations | |

| Entergy Texas, Inc. | Page 2 of 11 | | :--: | :--: | | Rebuttal Testimony of Michael P. Considine | | | PUCT Docket No. 40295 | |

related to the Company's request to recover Docket No. 39896 rate case expenses associated with various aspects including issues related to the Company's request to recover internal rate case expenses. The rebuttal testimony of witness Stephen F. Morris addresses certain aspects of those same filings including issues related to outside legal counsel and outside accounting and consulting firms ("external rate case expenses").

III. REBUTTAL ISSUES

A. Allocation of Rate Case Expenses Q. PLEASE ADDRESS STAFF'S APPROACH TO THE ALLOCATION OF RATE CASE EXPENSES. A. Staff Witness Brian Murphy recommends a class revenue requirement allocator based upon each class' Commission-approved revenue requirement. ^[1] Mr. Murphy recommends that ETI's Schedule RCE-2 rates be set in the compliance phase of this proceeding by multiplying the approved total amount by Staff's recommended class allocator and dividing the resulting class share both by ETI's proposed three-year amortization period and also by ETI's proposed class billing determinants. ^[2] Mr. Murphy also recommends that the Company be required to track collection on Rider RCE and terminate billing in the billing month in which the approved amount has been billed.

| 1 | Q. | DOES ETI OBJECT TO STAFF'S ALLOCATION BASIS? | | :--: | :--: | :--: | | 2 | A. | No, ETI does not object to Staff's approach on allocation. | | 3 | | | | 4 | Q. | DOES THE COMPANY OBJECT TO TRACKING AND TERMINATING | | 5 | | THE RIDER ONCE THE APPROVED AMOUNT HAS BEEN BILLED? | | 6 | A. | The Company agrees with this approach so long as the final order | | 7 | | includes language following Commission precedent allowing the Company | | 8 | | to seek recovery of any additional rate case expenses accrued after | | 9 | | September 30, 2012 in its subsequent rate case. ^[3] | | 10 | | | | 11 | | B. Return on the Unamortized Balance | | 12 | Q. | PLEASE DESCRIBE STAFF'S RECOMMENDATION FOR THE RETURN | | 13 | | ON THE UNAMORTIZED BALANCE. | | 14 | A. | Staff's Recommendations suggest that ETI not be allowed to recover any | | 15 | | return on the unamortized balance as the Company had requested for the | | 16 | | three-year period over which ETI would be recovering the approved rate | | 17 | | case expenses. | | 18 | | | | 19 | Q. | WHAT IS YOUR VIEW ON THE RETURN ON THE UNAMORTIZED | | 20 | | BALANCE? |

Entergy Texas, Inc. Rebuttal Testimony of Michael P. Considine PUCT Docket No. 40295 1 A. The return is a necessary component of a cost that is amortized over a period of time. It represents the time value of money and the cost of the Company's lost opportunity to deploy those funds elsewhere. The Company's proposal reflects a reasonable balancing of interests on this issue as the Company is only proposing a return over the three-year recovery period and does not propose to recover the lost opportunity costs on the rate case expenses from the time they were incurred. If the Company is not permitted to recover a return on the unamortized portion of its approved rate case expenses, it will, in effect, incur a disallowance relative to the amount of rate case expenses approved by the Commission. Therefore, I disagree with Staff's recommendation on this point; the Company should be allowed to recover its return on the unamortized balance. C. Frequency of Rate Cases Q. PLEASE SUMMARIZE THE POLICY ISSUES RAISED BY PARTIES REGARDING THE FREQUENCY OF RATE CASES. A. Both the State Agencies in their Recommendations, and OPUC witness Nathan Benedict point to the frequency of rate cases as a reason the Commission should disallow otherwise reasonable rate case expenses. Mr. Benedict asserts that the Company has filed three base rate cases in a little more than four years and that this frequency places a burden on ratepayers. The State Agencies claim that frequent requests for rate relief

| Entergy Texas, Inc. | Page 5 of 11 | | :--: | :--: | | 1 | for electric utilities are shareholder-driven and because of that, half of rate | | 2 | case expenses should be paid for by the shareholders. | | 3 | | | 4 | D. DO YOU AGREE WITH THE ARGUMENTS MADE REGARDING THE | | 5 | FREQUENCY OF BASE RATE CASES? | | 6 | No. Rate cases are cost-driven. The Company is permitted to recover its | | 7 | reasonable and necessary costs and to have the opportunity to earn a | | 8 | reasonable return on invested capital. Each of ETI's recent base rate | | 9 | cases has resulted in a rate increase for the Company. Ironically, the | | 10 | Company has proposed on multiple occasions to establish rate riders to | | 11 | address the Company's rising costs that would substantially reduce the | | 12 | likelihood of the Company filing rate cases as frequently as it has in the | | 13 | last few years. These proposals have been opposed by the same parties | | 14 | who here complain about the frequency of rate cases. Without the ability | | 15 | to recover the increasing level of reasonable expenses through such | | 16 | riders, a utility is left with no recourse but to file a rate case. | | 17 | | | 18 | D. Calpine-Carville PPA | | 19 | PLEASE DESCRIBE OPUC'S RECOMMENDATIONS REGARDING THE | | 20 | CALPINE-CARVILLE PURCHASED POWER AGREEMENT. | | 21 | In its Recommendation and Request for Hearing, OPUC proposes that the | | 22 | Commission disallow the recovery of rate case expenses relating to the | | 23 | regulatory approval of this purchased power agreement ("PPA"). OPUC |

| 1 | states that the Company has already been granted recovery of costs associated with the regulatory approval process for the Calpine-Carville | | :--: | :--: | | 2 | PPA and the Company sought and obtained that regulatory approval in | | 3 | Docket No. 39896. Thus, it claims that if the Company were to also recover those costs as part of its rate case expenses in this docket, it | | 4 | would constitute double recovery. Specifically, OPUC mentioned a disallowance of the portion of the expenses related to the testimonies of | | 6 | Company witness Robert Cooper and the billable time of Company attorney Dick Westerburg. | | 7 | | | 8 | WHAT IS YOUR RESPONSE TO THE DISALLOWANCES SUGGESTED | | 9 | BY OPUC REGARDING THE CALPINE-CARVILLE PPA? | | 13 | OPUC fails to recognize an important distinction between the amounts at | | 14 | issue. An individual may have charged time to Project Code | | 15 | F3PPWET308 (that is, the internal project code for the Calpine PPA development costs) as the Calpine PPA was being developed, including | | 17 | time spent determining how regulatory approval of the PPA might generally be obtained and designing the PPA in a manner that would | | 19 | facilitate such approval. These costs would have occurred during the test year and were included for recovery in Docket No. 39896. However, an | | 20 | individual may have also charged time to Project Code F5PPETX011 (that is, the internal project code for the rate case filed by ETI in Docket No. | | 23 | 39896) as they developed testimony specifically for Docket No. 39896 or |

| 1 | responded to RFIs related to the Calpine PPA during the course of the | | :--: | :--: | | 2 | rate case. These costs would have occurred after the test year. Recovery | | 3 | of these latter costs was severed from Docket No. 39896 and is now being | | 4 | requested in this docket. Costs recorded to Project Code F5PPETX011 | | 5 | are the only costs the Company is proposing to recover in this instant | | 6 | docket. Therefore, no double recovery exists. ^[4] | | 7 | | | 8 | E. Costs Billed by Company Consultant Gerald Tucker | | 9 Q. | PLEASE BRIEFLY SUMMARIZE STATE AGENCIES' RECOMMENDED | | 10 | DISALLOWANCE FOR COSTS BILLED BY COMPANY CONSULTANT | | 11 | GERALD TUCKER. | | 12 | State Agencies recommended \$116,119 disallowance is based upon | | 13 | claims that services performed by Mr. Tucker are duplicative and go | | 14 | beyond reviewing affiliate costs. | | 15 | | | Q. | DO YOU AGREE WITH STATE AGENCIES' CHARACTERIZATION OF | | 17 | COSTS BILLED BY MR. TUCKER? | | 18 | No. Over the past two decades, the PUCT has at times disallowed large | | 19 | percentages of utilities' affiliate expenses, including those of Entergy Gulf | | 20 | States, Inc. ("EGSI"). One of the concerns raised in the past by the ALJs | | 21 | and the Commission has been an inability to understand the information |

presented by the utilities. As a result, the Company needs to ensure that it has experienced personnel to assist in the effective preparation and presentation of its rate cases. Mr. Tucker brings a level of expertise and perspective to ensure this effective preparation and presentation. He is an accountant and thus brings a perspective that the Company's outside counsel do not bring to a rate case.

Mr. Tucker has been involved in all ETI (formerly EGSI) rate cases since Docket No. 16705 in 1997 as well as numerous rate cases filed by other utilities in Texas. This extensive experience with ETI and its previous dockets is exactly the reason Mr. Tucker was asked to assist with the review of discovery as well. This review included completeness of the response, consistency with responses in the current and previous cases, and clarity of the response. Mr. Tucker also assisted with preparation for depositions of both Company and intervenor witnesses along with the preparation of Company testimony and rate filing package schedules. With Mr. Tucker's assistance, the Company is better able to provide the information in a clear and accurate manner that allows customer representatives to analyze the Company's costs and requested rates. Likewise, Mr. Tucker's assistance has been necessary to ensure, to the extent possible, that ETI's affiliate charges, in particular, are not susceptible to the substantial affiliate cost disallowance that was ordered

| 1 | in Docket No. 16705. ^[5] There are very few individuals who have as much | | :--: | :--: | | 2 | rate case experience with the Company as does Mr. Tucker, and there are | | 3 | no employees at the Company or ESI who have Mr. Tucker's experience | | 4 | with and knowledge of how other Texas utilities present their affiliate costs | | 5 | and other rate case matters. ^[6] | | 6 | | | 7 | F. Depreciation | | 8 Q. | PLEASE DESCRIBE THE STATE AGENCIES' RECOMMENDED | | 9 | DISALLOWANCES FOR DEPRECIATION. | | 10 A. | The State Agencies' reason for disallowing $\backslash$ 207,683$ is that there is no | | 11 | evidence to prove the reasonableness and necessity of this charge as a | | 12 | cost of participation in the base rate case. The State Agencies claim that | | 13 | the "attached detail" referenced in the summary spreadsheet was not | | 14 | attached. | | 15 | | | 16 Q. | HOW DO YOU RESPOND TO THE STATE AGENCIES' CLAIMS? | | 17 A. | The State Agencies are wrong. The detail State Agencies claims is | | 18 | lacking was in fact provided in the very RFI response State Agencies cites | | 19 | as deficient, ETI's response to Staff 9-1, Addendum 3. Accordingly, I have | | 20 | attached as Exhibit MPC-R-1 those portions of the Company's voluminous |

| 1 | response to Staff 9-1, Addendum 3 that contain the detail relevant to State | | :--: | :--: | | 2 | Agencies' allegation. | | 3 | Page 1 of Exhibit MPC-R-1 is the summary spreadsheet referenced | | 4 | by State Agencies containing the total of $\backslash$ 207,683$ for "Depreciation and | | 5 | Amort Expense." Page 2, the second tab of the same spreadsheet, | | 6 | provides additional information regarding the labor costs that drive the | | 7 | depreciation and amortization expense at issue, including the segregation | | 8 | of such labor costs by department. The remaining pages of Exhibit MPC- | | 9 | R-1 are a spreadsheet entitled "Roadmap to Internal Rate Case | | 10 | Expenses," which breaks down each of the totals comprising the "Internal | | 11 | Rate Case Expenses (Non-Payroll)" category addressed on the summary | | 12 | spreadsheet on Page 1, including the depreciation and amortization | | 13 | expense about which State Agencies complains. ^[7] Specifically, on Page 8 | | 14 | of Exhibit MPC-R-1, this roadmap spreadsheet breaks down the | | 15 | depreciation and amortization total by project code, year, month, resource | | 16 | code, resource description, monthly amount, and journal ID number. | | 17 | Thus, contrary to State Agencies' claim, the Company provided a | | 18 | "roadmap" of detail in support of the expense at issue. |

| 1 | Moreover, these costs are a reasonable and necessary part of | | :--: | :--: | | 2 | providing services. The use of assets required to support employee | | 3 | service functions necessarily results in depreciation and amortization cost. | | 4 | ESI's depreciation expense is thus loaded to all project codes which incur | | 5 | ESI labor charges. The rate case project code here should likewise be | | 6 | charged its share of depreciation expense. | | 7 | Accordingly, State Agencies' proposed disallowance should be | | 8 | rejected. | | 9 | | | 10 | Q. DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY? | | 11 | A. Yes. |

EXHIBIT MPC-R-1 Docket No. 40295 Page 1 of 14

ENTERGY TEXAS, INC.

RATE CASE EXPENSES PAID AND ACCRUED THROUGH THE MONTH ENDED SEPTEMBER 30, 2012 ETI 8/39/11 COS DOCKET 39898 RATE CASE EXPENSES STAPP DATA REQUEST 9-1 ADDENDUM 3

| ACCOUNTING | | AMOUNT | | :--: | :--: | :--: | | DELOTTE &; TOUCHE LLP Total | | 915,970 | | LESS: NON-CONFORMING D&;T EXPENSES | | (2,373) | | PRICEWATERHOUSE COOPERS LLP Total | | 122,168 | | LESS: NON-CONFORMING PWC EXPENSES | | (7) | | ACCOUNTING TOTAL | 1,035,758 | | | CONSULTANTS | | | | DOLGRES S STOKES DBA D STOKES CONSULTING | 17,290 | SEE ATTACHED DETAIL | | EXPERT POWERHOUSE LLC DBA EXPERGY | 172,752 | SEE ATTACHED DETAIL | | FINANCO INC | 125,220 | SEE ATTACHED DETAIL | | GERALD W TUCKER CPA | 116,119 | SEE ATTACHED DETAIL | | JAY HARTZEL | 12,825 | SEE ATTACHED DETAIL | | MILLER &; CHEVALIER CHARTERED | 19,443 | SEE ATTACHED DETAIL | | TOWERS WATSON PENNSYLVANIA INC | 2,288 | SEE ATTACHED DETAIL | | LESS: NON-CONFORMING TWP EXPENSES | | (22) | | CONSULTANTS TOTAL | 465,915 | | | LEGAL | | | | DUGGINS WHEN MANN &; ROMERO LLP | 2,408,607 | SEE ATTACHED DETAIL | | LESS: NON-CONFORMING DWWR EXPENSES | (88) | | | LEGAL TOTAL | 2,408,541 | | | INTERNAL RATE CASES EXPENSES (NON-PAYROLL) | | SEE ATTACHED DETAIL | | Business Mests/Entertainment | 3,852 | SEE ATTACHED DETAIL | | Cities Bills-Lawton Law Firm | 1,117,309 | SEE ATTACHED DETAIL | | Computer &; Office Supplies | 758 | SEE ATTACHED DETAIL | | Court Transcripts | 38,466 | SEE ATTACHED DETAIL | | Depreciation &; Amort Expenses | 207,683 | SEE ATTACHED DETAIL | | Employee Migs/Punctions | 7,762 | SEE ATTACHED DETAIL | | Legal Notices | 100,799 | SEE ATTACHED DETAIL | | Lodging | 18,959 | SEE ATTACHED DETAIL | | Other Employee Expenses | 3,423 | SEE ATTACHED DETAIL | | Other Office &; General | 5,829 | SEE ATTACHED DETAIL | | Pagers/Cellular Phines | 10 | SEE ATTACHED DETAIL | | Personal Car Mileage - Local | 2,784 | SEE ATTACHED DETAIL | | Postage and Overnight Delivery | 8,699 | SEE ATTACHED DETAIL | | Printing, Mailing &; Shipping | 12,601 | SEE ATTACHED DETAIL | | Service Company Recipient | 346,640 | SEE ATTACHED DETAIL | | Temporary Services | 66,943 | SEE ATTACHED DETAIL | | Travel Transportation | 24,125 | SEE ATTACHED DETAIL | | Utility Bills | 2,915 | SEE ATTACHED DETAIL | | LESS: NON-CONFORMING COMPANY EXPENSES | (590) | | | INTERNAL RATE CASES EXPENSES (NON-PAYROLL) TOTAL | 1,988,581 | | | ESIPAYROLL, BENEFITS &; TAXES | 2,875,781 | SEE ATTACHED DETAIL | | RATE CASE EXPENSES THROUGH 9/39/12 | 6,752,576 | |

EXHIBIT MPC-R-1 Docket No. 40295 Page 2 of 14 ENTERSY TEXAS INC. RATE CASE PAYROLL FOR ESI EMPLOYSES THROUGH SEPTEMBER 30, 2012 STI 609/11 COS DOCKET 35866 STAFF DATA REQUEST S-1 ADDENOUM 3

DEPARTMENT

| No. top zum, Siebut &; R.S. Cip | 1,423 | 14 | | :--: | :--: | :--: | | Cabecilara, the Deizit | 205 | 14 | | Ramdanna Precessing-Est | 120 | 8 | | Caci Customer Contact Siakins | 22,660 | 222 | | Customer Load Information Aars | 8,488 | 135 | | Caci Freeliner &; Cep | 4,800 | 21 | | End Pain, Cip Duod -Est | 42,480 | 4 | | Revenue Requirement &; Acrepues | 214,827 | 3,433 | | Rate Design &; Administration | 181,820 | 2,847 | | Regulation Lif̣pation Support | 181,102 | 5,200 | | Directio - Regulatory Projects | 15,285 | 220 | | Firecesting &; Analysis | 961 | 21 | | Fuel &; Special Risors | 14,915 | 227 | | Fair &; Regular | 162 | 1 | | Vp Regulatory Services | 17,770 | 100 | | Procurement&;Arms Optimization | 1,243 | 21 | | Regulatory Accounts | 383,904 | 5,001 | | Jobg Research &; Forecasting | 780 | 11 | | Wholesale Business | 1,460 | 19 | | Outlihution Engineering Detal | 31,121 | 424 | | Proj Costing/Uses Assets Opins | 4,023 | 28 | | Accounts Payable | 9,650 | 376 | | Affiliate Assets &; Allocations | 169,081 | 1,802 | | Corporate Planning &; Reforms | 16,172 | 177 | | Economic Reporting | 18,784 | 355 | | Other of Corp Risk Overpig | 971 | 4 | | Accounts Policy Convalions | 3,108 | 73 | | CPOL Utility Operations | 11,583 | 155 | | State And Local Taxes | 27,724 | 335 | | Regulatory Tax Support | 46,927 | 320 | | Office of Corp Risk Overpigh | 971 | 4 | | Accounting Policy And Research | 1,121 | 23 | | Corporate Ploation &; Reforms | 18,889 | 288 | | Business Services | 17,085 | 215 | | Income Tax Accounting | 14,710 | 245 | | On Tax Accounting &; Corruption | 5,808 | 45 | | Asset Management Support | 23,780 | 414 | | Director of NonInvest Region | 2,758 | 18 | | Corporate &; Service Design | 2,758 | 18 | | Compensation &; Benefits Design | 80,857 | 717 | | H5 Censoring &; Compensation | 36,540 | 427 | | H6 Crop | 10,200 | 55 | | H7 Total Revenue Pights | 5,288 | 58 | | H8 - Total Revenue Ops | 704 | 19 | | H9 - Budget Metrics | 1,900 | 33 | | H10 Legal Officer | 59,846 | 582 | | Legal Legal Officer | 59,846 | 582 | | Legal - Usiption - TX | 7,144 | 63 | | Legal - PERS | 2,105 | 17 | | Legal - General Counsel | 2,744 | 42 | | Legal - Reg - Corp | 5,131 | 46 | | Legal - Reg - TX | 143,580 | 2,903 | | Utility System Communications | 452 | 3 | | UP - Ancestry Communications | 240 | 5 | | PES COMBININGATIONS | 1,146 | 14 | | UPREV CHAIN BUBBERS SUPPORT | 5,892 | 129 | | DIPPOLY CHAIN BUBBERS SUPPORT | 2,894 | 19 | | Regulatory Affordtnergy Seldent | 187,308 | 3,223 | | UP COMBININGATIONAL Action | 1,898 | 49 | | Energy Analysis &; Reporting | 800 | 7 | | GPO ComplementBusiness Support | 19,289 | 107 | | GPO Complement Marking &; Models | 3,010 | 29 | | Operations Planning | 1,090 | 13 | | Supply Planning and Analysis | 714 | 15 | | GPO Company Communication | 11,384 | 113 | | GPO Supervision &; Refinement | 12,228 | 100 | | GPO Supervision &; Refinement | 12,228 | 100 | | GPO Supervision &; Refinement | 12,228 | 100 | | GPO Supervision &; Refinement | 12,228 | 100 | | GPO Supervision &; Refinement | 12,228 | 100 | | Total Regulatory Support | 29,885 | 368 |

| ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | :--: | :--: | :--: | :--: | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | | | ASSETS IN RATE CASE PREPARATION &; RPI RESPONSES | | | |

Roadmap to Internal Rate Case Expenses - Tab 1

| TYPE | Year | Period | Veh | | | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | M | 2012 | 1 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 22,220,00 | AP10490129 | 34090739 | 08835463 | 120820113085500 | | | M | 2012 | 2 | 2121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 73,650,30 | AP10494014 | 34301403 | 08653768 | 011030127589200 | | | M | 2012 | 3 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 138,686,33 | AP10500068 | 34416882 | 09921870 | 02131214230875 | | | M | 2012 | 4 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 212,018,15 | AP105046.09 | 34673874 | 09840206 | 0312122451415 | | | M | 2012 | 6 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 243,568,78 | AP10512628 | 34759476 | 09875731 | 05101224898788 | | | M | 2012 | 8 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 205,459,66 | AP10512628 | 34840036 | 10001030 | 0412201220881715 | | | M | 2012 | 7 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 171,942,78 | AP10517833 | 34981801 | 10028711 | 0611201317257875 | | | M | 2012 | 8 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 19,217,00 | AP10522061 | 35162078 | 10076715 | 071320122075700A | | | M | 2012 | 8 | 121293 | LAWTON LAW FIRM | CITIES BELLS-LAWTON LAW FIRM | 30,545,00 | AP10524040 | 35204280 | 10088028 | 081420123324500 | | | M | 2012 | 2 | 2420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 222,50 | AP10486288 | 34223084 | 08665038 | 1113047 | | | M | 2012 | 3 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 97,50 | AP10486873 | 34367369 | 08666614 | 1202083 | | | M | 2012 | 3 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 370,00 | AP10485873 | 34367371 | 08600615 | 1202085 | | | M | 2012 | 3 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 201,50 | AP10488873 | 34367373 | 08600617 | 1202081 | | | M | 2012 | 3 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 163,20 | AP10488873 | 34367404 | 08600616 | 1202077 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 586,10 | AP10505570 | 34592422 | 09848675 | 1204020 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 707,30 | AP10505570 | 34592426 | 09848674 | 1204022 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 171,80 | AP10505570 | 34592460 | 09848673 | 1203014 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 215,00 | AP10505570 | 34592483 | 09845671 | 1203028 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 488,15 | AP10505570 | 34592612 | 09845677 | 1202075 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 170,90 | AP10505570 | 34592614 | 09845676 | 1203010 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 191,80 | AP10505570 | 34592634 | 09845070 | 1203031 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 568,50 | AP10505570 | 34592646 | 09845668 | 1204014 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 555,00 | AP10505570 | 34592673 | 09845667 | 1204012 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 1,273,20 | AP10505570 | 34592678 | 09845666 | 1204009 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 1,068,30 | AP10505570 | 34592687 | 09845665 | 1204010 | | | M | 2012 | 4 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 1,058,70 | AP10505570 | 34592720 | 09845664 | 1204011 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 650,90 | AP10507640 | 34592390 | 09857273 | 1204021 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 3,540,10 | AP10510655 | 34774678 | 09888267 | 161475 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 2,784,10 | AP10510655 | 34774661 | 09888266 | 161478 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 3,628,30 | AP10510655 | 34774833 | 09888265 | 161463 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 3,162,10 | AP10510655 | 34774848 | 09888263 | 161466 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 3,401,50 | AP10510655 | 34774860 | 09888282 | 161216 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 2,647,90 | AP10510655 | 34774948 | 09888281 | 161278 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 1,723,70 | AP10510655 | 34774955 | 09888260 | 161582 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 3,351,10 | AP10510655 | 34774957 | 09888264 | 161468 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 3,212,50 | AP10510655 | 34775010 | 09885279 | 16276 | | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 1,254,70 | AP10514750 | 34917893 | 10018808 | 1204027 | |

Roadmap to Internal Rate Case Expenses - Tab 1

| M | 2012 | 6 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 577.10 | AP10514750 | 34817920 | 10016807 | 1204028 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | M | 2012 | 5 | 420254 | KENNEDY REPORTING SERVICE INC | COURT TRANSCRIPTS | 209.00 | AP10514750 | 34817962 | 10016808 | 1203012 | | M | 2011 | 12 | 077243 | OH COMMUNICATIONS INC DBA HENNEMAN | LEGAL NOTICES | 450.00 | AP10494135 | 33676793 | 08751285 | 7193 | | M | 2011 | 13 | 123457 | LEE GROUP | LEGAL NOTICES | 59,187.25 | AP10484125 | 33954744 | 09761569 | 39573 | | M | 2011 | 12 | 021189 | HEDERMAN BROTHERS | LEGAL NOTICES | 5,275.90 | AP10484125 | 33879798 | 09781469 | 101810 | | M | 2012 | 1 | 103834 | SUMMEROUR PARTNERS LLC | LEGAL NOTICES | 1,500.00 | AP10488545 | 34042096 | 09813600 | 1303 | | M | 2012 | 1 | 123457 | LEE GROUP | LEGAL NOTICES | 2,301.60 | AP10488645 | 34031413 | 09812338 | 39579 | | M | 2012 | 2 | 123457 | LEE GROUP | LEGAL NOTICES | 2,024.00 | AP10484014 | 34201217 | 09883540 | 39762 | | M | 2011 | 15 | 081644 | CITMARK USA. Nk. | PRINTING, MAILING &; SHIPPING | 7.81 | APE0473499 | 33590697 | 09708079 | 1283358_20 | | M | 2012 | 3 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 533.00 | AP10499673 | 34357282 | 08800491 | 0218201283300 | | M | 2012 | 3 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 552.50 | AP10499673 | 34357276 | 09900460 | 0122201202150 | | M | 2012 | 3 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 133.00 | AP10499873 | 34357294 | 09900489 | 0108201215300 | | M | 2012 | 3 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 62.00 | AP10499873 | 34357295 | 09900488 | 121120119600 | | M | 2012 | 3 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 671.00 | AP10499673 | 34357974 | 09900457 | 0205201269300 | | M | 2012 | 3 | 124088 | SUSAN JOOHIMSEN HOOD | PRINTING, MAILING &; SHIPPING | 1,315.00 | AP10500095 | 34417957 | 09898500 | 2128 | | M | 2012 | 4 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 414.60 | AP10505570 | 34592316 | 09948833 | 0218201244450 | | M | 2012 | 4 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 314.00 | AP10505879 | 34592514 | 09945834 | 0304201241800 | | M | 2012 | 4 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 615.50 | AP10505978 | 34592597 | 09945535 | 0401201269900 | | M | 2012 | 5 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 100.00 | AP10510555 | 34774576 | 09989056 | 0513201220250 | | M | 2012 | 5 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 210.00 | AP10510655 | 34774677 | 09989088 | 0415201225400 | | M | 2012 | 5 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 284.00 | AP10510659 | 34775028 | 09989087 | 0428201235900 | | M | 2012 | 5 | 147205 | ADVANCED DISCOVERY LLC | PRINTING, MAILING &; SHIPPING | 5,457.65 | AP10510665 | 34774650 | 09989230 | 845344 | | M | 2012 | 5 | 113932 | MAGIC COURIERS INC | PRINTING, MAILING &; SHIPPING | 25.00 | AP10514750 | 34815059 | 10016575 | 0810201233000 | | M | 2012 | 7 | 081644 | CITMARK USA. Nk. | PRINTING, MAILING &; SHIPPING | 811.65 | APE0519880 | (PCARD | 10036365 | 1477004_21 | | M | 2011 | 11 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 905.34 | AP10480635 | 33801639 | 09752952 | R273643-0-1-66195-66 | | M | 2011 | 11 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 136.95 | AP10480825 | 33801657 | 09752938 | R293477-0-1-66165-84 | | M | 2011 | 11 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 704.34 | AP10480525 | 33801675 | 09752950 | R302710-0-1-66165-105 | | M | 2011 | 11 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 1,006.95 | AP10480825 | 33801680 | 09752962 | R305768-0-1-66165-107 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 401.18 | AP10483223 | 33823011 | 09759311 | R305769-0-1-66370-46 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 568.88 | AP10483223 | 33823073 | 09759302 | R441438-0-1-66370-88 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 357.32 | AP10483223 | 33823101 | 09755200 | R473125-0-1-66370-125 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 496.65 | AP10483223 | 33823159 | 09759354 | R531785-0-1-66370-174 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 58.71 | AP10484047 | 33818290 | 09764431 | R723878-0-1-67127-81 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 58.71 | AP10485591 | 33906905 | 09765246 | R870109-0-1-67819-55 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 732.40 | AP10485581 | 33966907 | 09765255 | R870727-0-1-67819-57 | | M | 2011 | 12 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 577.62 | AP10486391 | 33978309 | 09768773 | 0030258-0-1-67827-96 | | M | 2012 | 1 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 408.35 | AP10488804 | 33998055 | 09803608 | 0134582-0-1-66375-114 | | M | 2012 | 1 | 124398 | GUIDANT GROUP INC | TEMPORARY SERVICES | 254.41 | AP10488804 | 34031976 | 09810506 | 0236368-0-1-66473-96 |

Roadmap to internal Rate Case Expenses - Tab 1

| M | 2012 | 1 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 460.53 | AP10468804 | 34031148 | 08810974 | 5264678-0-1-68473-158 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | M | 2012 | 1 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 541.80 | AP10488804 | 34088178 | 09819123 | 5264628-0-1-68812-33 | | M | 2012 | 1 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 303.34 | AP10488804 | 34089255 | 09819075 | 5317960-0-1-68812-108 | | M | 2012 | 1 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 541.13 | AP10489556 | 34108148 | 09828110 | 5320092-0-1-68136-45 | | M | 2012 | 1 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 283.77 | AP10480596 | 34108169 | 09828844 | 5388881-0-1-68136-66 | | M | 2012 | 1 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 1,566.84 | AP10490556 | 34105257 | 09828763 | 5397971-0-1-68136-144 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 117.42 | AP10483710 | 34126824 | 09836866 | 5438105-0-1-68472-84 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 451.60 | AP10493710 | 34136870 | 08836890 | 5408834-0-1-68472-130 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 722.40 | AP10482710 | 34136840 | 09836846 | 5481630-0-1-68472-180 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 3,724.17 | AP10463715 | 34136801 | 09836748 | 5428612-0-1-68472-61 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 185.93 | AP10463026 | 34174543 | 09844569 | 5538019-0-1-68813-59 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 735.98 | AP10463036 | 34174660 | 09845113 | 5544283-0-1-68813-115 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 60.22 | AP10483036 | 34174664 | 09844612 | 5548450-0-1-68813-119 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 2,734.17 | AP10483041 | 34174342 | 09844321 | 5478626-0-1-68813-37 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 264.41 | AP10484009 | 34212029 | 09863075 | 5633002-0-1-70207-110 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 722.40 | AP10484008 | 34212074 | 09863363 | 5699468-0-1-70207-155 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 2,332.46 | AP10484014 | 34211955 | 09863857 | 5883344-0-1-70207-36 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 1,442.21 | AP10484755 | 34249084 | 09862186 | 5885807-0-1-70540-49 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 136.96 | AP10484882 | 34249168 | 09862437 | 5712631-0-1-70546-123 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 577.52 | AP10484582 | 34249170 | 09862436 | 5713630-0-1-70545-135 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 284.42 | AP10487469 | 34281327 | 09870263 | 5798668-0-1-70609-88 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 577.62 | AP10487469 | 34281357 | 09870671 | 5808514-0-1-70609-128 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 2,386.86 | AP10487474 | 34281350 | 09870064 | 5728949-0-1-70609-51 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 117.42 | AP10497731 | 34324083 | 09879820 | 5808484-0-1-71240-104 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 722.40 | AP10497731 | 34324207 | 09879921 | 5864867-0-1-71240-188 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 1,210.74 | AP10497736 | 34323953 | 09879767 | 5863229-0-1-71240-44 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 749.50 | AP10498040 | 34307913 | 09881280 | 5980117-0-1-71624-52 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 136.95 | AP10498940 | 34307913 | 09881136 | 5972171-0-1-71624-70 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 1,335.38 | AP10498943 | 34307907 | 09890964 | 5941802-0-1-71624-44 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 185.92 | AP10498811 | 34403158 | 09898482 | 7054663-0-1-71602-115 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 541.80 | AP10499811 | 34403236 | 09898441 | 7091650-0-1-71802-136 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 1,636.08 | AP10499814 | 34403118 | 09898663 | 7050743-0-1-71802-59 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 35.14 | AP10500667 | 34441064 | 09909206 | 7174551-0-1-72251-110 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 577.02 | AP10500962 | 34441112 | 09909275 | 7210366-0-1-72251-158 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 668.70 | AP10500956 | 34440946 | 09908356 | 719267-1-72251-32 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 417.43 | AP10500968 | 34440947 | 09908403 | 719367-1-72251-33 | | M | 2012 | 2 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 2,849.80 | AP10500966 | 34440987 | 09908317 | 7124402-0-1-72281-53 | | M | 2012 | 4 | 124308 | GUIDANT GROUP INC | TEMPORARY SERVICES | 29.36 | AP10502695 | 34481744 | 09818922 | 7257743-0-1-72908-69 |

Roadmap to Internal Rate Case Expenses - Tab 1

| M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 686.28 | AP10902988 | 34481850 | 09918941 | T288245-0-1-72608-136 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 575.28 | AP10503000 | 34481718 | 09918824 | T224020-0-1-72808-44 | | M | 2012 | 4 | 124395 | GUDANT GROUP INC | TEMPORARY SERVICES | 29.36 | AP10803678 | 34518260 | 08926918 | T368855-0-1-73004-56 | | M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 577.53 | AP10803678 | 34518264 | 09927111 | T376437-0-1-73004-80 | | M | 2012 | 4 | 124358 | GUDANT GROUP INC | TEMPORARY SERVICES | 2,403.68 | AP10003884 | 34518243 | 08926581 | T332820-0-1-73004-39 | | M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 595.98 | AP10904402 | 34558487 | 08930027 | T472727-0-1-73358-120 | | M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 1,851.72 | AP10504408 | 34656390 | 08936200 | T433830-0-1-73388-83 | | M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 722.40 | AP10505602 | 34696210 | 08645940 | T577583-0-1-73647-138 | | M | 2012 | 4 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 589.77 | AP10505811 | 34696117 | 08646024 | T517025-0-1-73847-82 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 704.34 | AP10007632 | 34631148 | 08555272 | T676808-0-1-74054-132 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 3,133.68 | AP10807640 | 34631049 | 08555411 | T624381-0-1-74054-43 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 577.92 | AP10508139 | 34680284 | 05985197 | T791457-0-1-74402-113 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 3,581.73 | AP10508144 | 34680196 | 05983144 | T723238-0-1-74402-44 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 144.48 | AP10509041 | 34719143 | 09573718 | T858863-0-1-74712-133 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 2,670.75 | AP10509048 | 34719033 | 09573706 | T828944-0-1-74712-53 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 722.40 | AP10510232 | 34761007 | 09563517 | U008836-0-1-75122-162 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 2,207.82 | AP10510238 | 34760861 | 09583906 | T825341-0-1-75132-46 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 722.40 | AP10512621 | 34791746 | 09591098 | U008670-0-1-75429-34 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 144.48 | AP10512621 | 34829088 | 10900387 | U153500-0-1-75853-56 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 1,281.96 | AP10512628 | 34791756 | 08690894 | U024777-0-1-75439-44 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 1,136.52 | AP10512628 | 34829073 | 10000695 | U118840-0-1-75853-41 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 804.64 | AP10513813 | 34887502 | 10008737 | U082381-0-1-75037-48 | | M | 2012 | 7 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 640.88 | AP10515628 | 38016128 | 10045061 | U670743-0-1-77751-43 | | M | 2012 | 7 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 819.04 | AP10516157 | 38048430 | 10051564 | U781454-0-1-76106-48 | | M | 2012 | 7 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 35.61 | AP10520623 | 35080431 | 10063100 | U886276-0-1-78471-33 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 1,102.84 | AP10522508 | 35124474 | 10070678 | V017386-0-1-78842-44 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 498.08 | AP10522871 | 35167482 | 10077078 | U151908-0-1-78318-55 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | $-0.80$ | AP10524439 | 35124028 | 10082102 | U082361-0-1-78843-3 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | $-0.63$ | AP10524439 | 35124717 | 10081788 | U670743-0-1-78843-54 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | $-0.82$ | AP10524439 | 35124742 | 10091297 | U781454-0-1-78843-109 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | $-0.93$ | AP10524439 | 35124786 | 10091259 | U886276-0-1-78843-123 | | M | 2012 | 5 | 124398 | GUDANT GROUP INC | TEMPORARY SERVICES | 426.98 | AP10524710 | 35230243 | 10095441 | V370981-0-1-80515-47 |

1,336,117.88 TOTAL TYPE NOT $=M$ 626,757.00 TOTAL FROM TYPE $=M$ TAB 1,962,874.88 TOTAL COMPANY DIRECT EXPENSES (500.00) US\$S: NON-CONPORIMING COMPANY EXPENSES (See Add 2 to Staff 9-13 for breakout) 1,962,314.88 TOTAL REQUESTED COMPANY DIRECT EXPENSES

Roadmap to Internal Rate Case Expenses - Tab 2

Roadmap to Internal Rate Case Expenses - Tab 2

| FSPPETIO11 [2012 | 4]027 | Employee Migs/Punitions/Awards | 12.00 | EEX_SUMMARY | AP10603676 | 9020496 | THRY.MICHELLE H | 34523003 | 08828559 | 041112190893 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | FSPPETIO11 [2012 | 5]027 | Employee Migs/Punitions/Awards | 2,317.00 | EEX_SUMMARY | APE0609038 | 091644 | OTIBANK USA NA | PCAND | 00675348 | 1448843_21 | | FSPPETIO11 [2012 | 5]027 | Employee Migs/Punitions/Awards | 2,414.26 | EEX_SUMMARY | APE5514920 | 091644 | OTIBANK USA NA | 34888286 | 10020835 | 1462187_21 | | FSPPETIO11 [2012 | 7]027 | Employee Migs/Punitions/Awards | 191.24 | EEX_SUMMARY | APE0510688 | 091644 | OTIBANK USA NA | 35038063 | 10056365 | 1477004_21 | | FSPPETIO11 [2011 | 7]032 | Lodging | 86.32 | EEX_SUMMARY | AP10465584 | 9211893 | HOMELLLEWIS B | 33110980 | 08678339 | 070811109603 | | FSPPETIO11 [2011 | 8]032 | Lodging | 287.80 | EEX_SUMMARY | AP10469101 | 9228907 | HEANDNER.BARBARA | 33364230 | 08646834 | 09061165620 | | FSPPETIO11 [2011 | 8]032 | Lodging | 287.50 | EEX_SUMMARY | AP10465534 | 9212188 | CALORELLBRAN W | 33417570 | 09665771 | 091211148323 | | FSPPETIO11 [2011 | 10]032 | Lodging | 135.45 | EEX_SUMMARY | AP10475359 | 9229802 | DOSEGENE E | 33626811 | 09706411 | 101711126842 | | FSPPETIO11 [2011 | 11]032 | Lodging | 187.14 | EEX_SUMMARY | AP10478515 | 9312225 | HERRINGTON.CHESTER | 33712733 | 08726285 | 110211219988 | | FSPPETIO11 [2011 | 13]032 | Lodging | 2,682.30 | EEX_SUMMARY | AP10483434 | 9310006 | PLOCKLKWH C | 33883061 | 09773436 | 105911627547 | | FSPPETIO11 [2012 | 3]032 | Lodging | 276.45 | EEX_SUMMARY | AP10481469 | 9343503 | BORING.KONDYAN | 34317393 | 08676934 | 03021298307 | | FSPPETIO11 [2012 | 3]032 | Lodging | 225.20 | EEX_SUMMARY | AP10458956 | 9315259 | VONGRAMCHANN.KHAMSUNE | 34362846 | 09882157 | 020412114053 | | FSPPETIO11 [2012 | 3]032 | Lodging | 88.51 | EEX_SUMMARY | AP10600952 | 9311616 | GEOQ.PATRICK J | 34444162 | 09908135 | 03271288484 | | FSPPETIO11 [2012 | 4]032 | Lodging | 354.04 | EEX_SUMMARY | AP10603578 | 9230496 | THRY.MICHELLE H | 34633003 | 09628559 | 041112190893 | | FSPPETIO11 [2012 | 4]032 | Lodging | 187.19 | EEX_SUMMARY | AP10604955 | 9310724 | NONGAKIHELIAM R | 34686077 | 09941357 | 04131298506 | | FSPPETIO11 [2012 | 4]032 | Lodging | 175.88 | EEX_SUMMARY | AP10605184 | 9312152 | DORRIKOJOSEPH F | 34543266 | 09643519 | 041912415676 | | FSPPETIO11 [2013 | 4]032 | Lodging | 372.88 | EEX_SUMMARY | AP10605573 | 9341283 | CONSIDINE.MICHAEL P | 34698634 | 09946155 | 040612408666 | | FSPPETIO11 [2012 | 5]032 | Lodging | 480.70 | EEX_SUMMARY | AP10607633 | 9310946 | COOPER.NOSENT R | 34628123 | 09363664 | 04061299082 | | FSPPETIO11 [2012 | 5]032 | Lodging | 363.30 | EEX_SUMMARY | AP10607633 | 9312356 | GARREON.WIRFRED W | 34661098 | 09360070 | 020412325461 | | FSPPETIO11 [2012 | 5]032 | Lodging | 369.82 | EEX_SUMMARY | AP10607633 | 9320842 | TUMMINELLO.STEPHANIE B | 34628186 | 09982733 | 040012139144 | | FSPPETIO11 [2012 | 5]032 | Lodging | 355.38 | EEX_SUMMARY | AP10607633 | 9321046 | CHIGANXULA.MARIA F | 34626237 | 09962737 | 080112119001 | | FSPPETIO11 [2012 | 5]032 | Lodging | 228.80 | EEX_SUMMARY | AP10607633 | 9322452 | EDELAND.HEATHER G | 34537583 | 09954410 | 040012106841 | | FSPPETIO11 [2012 | 5]032 | Lodging | 918.76 | EEX_SUMMARY | AP10607633 | 9322666 | MCCULLAMAN F | 34637807 | 09964423 | 050112495365 | | FSPPETIO11 [2012 | 5]032 | Lodging | 240.25 | EEX_SUMMARY | AP10608139 | 9310946 | COOPER.NOSENT R | 34662301 | 09963985 | 03081243399 | | FSPPETIO11 [2012 | 5]032 | Lodging | 985.45 | EEX_SUMMARY | AP10608139 | 9311616 | GEOQ.PATRICK J | 34662213 | 09964000 | 080712206269 | | FSPPETIO11 [2013 | 5]032 | Lodging | 696.69 | EEX_SUMMARY | AP10608139 | 9314363 | TALKINGTON.MYRAL | 34662262 | 09363560 | 030812331368 | | FSPPETIO11 [2012 | 5]032 | Lodging | 287.88 | EEX_SUMMARY | AP10608139 | 9341283 | CONSEINE.MICHAEL P | 34662336 | 09364130 | 05081336428 | | FSPPETIO11 [2012 | 5]032 | Lodging | 214.67 | EEX_SUMMARY | AP10608144 | 9313421 | PIENCE JEUNJOH VERNON | 34662124 | 09963985 | 030712178309 | | FSPPETIO11 [2012 | 5]032 | Lodging | 641.75 | EEX_SUMMARY | AP10608144 | 9316388 | CONVINAN.SHAAN B | 34662144 | 09963982 | 080412244826 | | FSPPETIO11 [2012 | 5]032 | Lodging | 668.70 | EEX_SUMMARY | AP10608763 | 9334709 | LEWIS JAY A | 34705760 | 09365052 | 070113246111 | | FSPPETIO11 [2012 | 5]032 | Lodging | 1,494.76 | EEX_SUMMARY | AP10608003 | 9313658 | BARBILLEALK.CHRIS E | 34716160 | 09971167 | 030712304365 | | FSPPETIO11 [2012 | 5]032 | Lodging | 893.58 | EEX_SUMMARY | AP10609041 | 9313546 | MAY JK.PHILLIP R | 34722726 | 08973231 | 031812288055 | | FSPPETIO11 [2012 | 5]032 | Lodging | 1,010.11 | EEX_SUMMARY | AP10609268 | 9310860 | WESTERNLRG JFLJCUS R | 34725430 | 09975315 | 060812224922 | | FSPPETIO11 [2013 | 5]032 | Lodging | 173.88 | EEX_SUMMARY | AP10609633 | 9332466 | MOLLVOY.KAKEN | 34755355 | 03561193 | 03181244253 | | FSPPETIO11 [2012 | 5]032 | Lodging | 267.80 | EEX_SUMMARY | AP10610290 | 9335183 | MOLLOSKEY.MARGAREY | 34777185 | 03885837 | 052412115121 | | FSPPETIO11 [2012 | 5]032 | Lodging | 479.50 | EEX_SUMMARY | AP06000922 | | (Bliem Value) | | | | | FSPPETIO11 [2012 | 5]032 | Lodging | 653.20 | EEX_SUMMARY | AP10612021 | 9312139 | GALBRATH.PATRICA | 34643577 | 10001387 | 060212122366 |

Roadmap to Internal Rate Case Expenses - Tab 2

| FBPPET2011 [2012 | | 6033 | Lodging | 368.66|EEX_SUMMARY | AP10813621 | 0012182 | ROMANLJOSEPH F | 34803468 | 08082751 | 001772186858 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | FBPPET2011 [2012 | | 6033 | Lodging | 344.66|EEX_SUMMARY | AP10813621 | 0013698 | ROMANLNORY LUTNIER | 34810362 | 08085198 | 083312172184 | | FBPPET2011 [2012 | | 6033 | Lodging | 238.66|EEX_SUMMARY | AP10813621 | 0032482 | LESLANC,HEATHER G | 34843594 | 10001410 | 080712114113 | | FBPPET2011 [2012 | | 6033 | Lodging | 479.66|EEX_SUMMARY | AP10813628 | 0012421 | PIERCE JEHLIGN VERNON | 34789404 | 09998868 | 080412101383 | | FBPPET2011 [2012 | | 6033 | Lodging | 320.66|EEX_SUMMARY | AP10813304 | 0010493 | JAYCOE,DEVON S | 34858943 | 10004341 | 08081283871 | | FBPPET2011 [2012 | | 6033 | Lodging | 476.66|EEX_SUMMARY | AP09000003 | (Bierik Vakos) | | | | | | FBPPET2011 [2012 | | 7033 | Lodging | 662.66|EEX_SUMMARY | AP10817818 | 0011084 | GARDNER,KEVIN G | 34887833 | 10028776 | 080712180988 | | FBPPET2011 [2011 | | 7033 | Other Employees Expenses | 12.00|EEX_SUMMARY | AP10460193 | 0032482 | LESLANC,HEATHER G | 22138839 | 09581776 | 0714116860 | | FBPPET2011 [2011 | | 6033 | Other Employees Expenses | 17.76|EEX_SUMMARY | AP10464638 | 0012189 | CALDWELL,BRAIN W | 33365068 | 09814898 | 08081193605 | | FBPPET2011 [2011 | | 6038 | Other Employees Expenses | 3.90|EEX_SUMMARY | AP10454782 | 0033807 | HEAVENER, BARBARA | 33270387 | 09616786 | 08101145820 | | FBPPET2011 [2011 | | 6038 | Other Employees Expenses | 65.64|EEX_SUMMARY | AP10456101 | 0033807 | HEAVENER, BARBARA | 33394230 | 09540835 | 08081198820 | | FBPPET2011 [2011 | | 6038 | Other Employees Expenses | 88.81|EEX_SUMMARY | AP10468824 | 0012189 | CALDWELL,BRAIN W | 33417870 | 09685771 | 091211148332 | | FBPPET2011 [2011 | | 10028 | Other Employees Expenses | 24.00|EEX_SUMMARY | AP10474816 | 0032482 | LESLANC,HEATHER G | 33899053 | 09780116 | 10141119060 | | FBPPET2011 [2011 | | 10028 | Other Employees Expenses | 48.00|EEX_SUMMARY | AP10475368 | 0038802 | SOSS,GEVIS E | 29836811 | 08708411 | 101711135842 | | FBPPET2011 [2011 | | 11028 | Other Employees Expenses | 31.86|EEX_SUMMARY | AP10478815 | 0012338 | HERNINGTON,CHESTER | 33712733 | 08738395 | 110011319886 | | FBPPET2011 [2011 | | 12028 | Other Employees Expenses | 12.00|EEX_SUMMARY | AP10483223 | 0033059 | PORTAN,SUZANNE M | 32838113 | 08758432 | 1121111000 | | FBPPET2011 [2011 | | 13028 | Other Employees Expenses | 541.23|EEX_SUMMARY | AP10483434 | 0010308 | RLOOD,JOHN C | 33885081 | 08773438 | 120811627847 | | FBPPET2011 [2012 | | 11028 | Other Employees Expenses | 63.34|EEX_SUMMARY | AP10488804 | 0012773 | CALOGERO,WENZY D | 33883180 | 08798838 | 1228116234 | | FBPPET2011 [2012 | | 3028 | Other Employees Expenses | 26.00|EEX_SUMMARY | AP10497469 | 0043693 | BOLRIS,JOHATHAN | 34317303 | 08878834 | 03001288207 | | FBPPET2011 [2012 | | 3028 | Other Employees Expenses | 1.60|EEX_SUMMARY | AP10498441 | 0038763 | SCHEIARICH,PAUL A | 34360133 | 09688259 | 03081280408 | | FBPPET2011 [2012 | | 3028 | Other Employees Expenses | 63.60|EEX_SUMMARY | AP10499898 | 0015289 | VONGRAHAROHANH,ENPANSUNE | 34382946 | 08890157 | 030412114083 | | FBPPET2011 [2012 | | 3028 | Other Employees Expenses | 68.76|EEX_SUMMARY | AP10507902 | 0011616 | CIOO,FASTRICK J | 34444762 | 08908135 | 03271288484 | | FBPPET2011 [2012 | | 4028 | Other Employees Expenses | 114.00|EEX_SUMMARY | AP10508678 | 0030498 | THIRY, MICHELLE H | 34533003 | 08928559 | 041112190863 | | FBPPET2011 [2012 | | 4028 | Other Employees Expenses | 63.00|EEX_SUMMARY | AP10504955 | 0010724 | MORGAN,WILLIAM R | 34898077 | 09241367 | 04191208905 | | FBPPET2011 [2012 | | 4028 | Other Employees Expenses | 89.00|EEX_SUMMARY | AP10508192 | 0032482 | DOWING,JOSEPH F | 34593368 | 08943519 | 041912415876 | | FBPPET2011 [2012 | | 4028 | Other Employees Expenses | 84.00|EEX_SUMMARY | AP10508073 | 0041283 | CONSIGNER,MICHKE, P | 34928034 | 08948155 | 042612108888 | | FBPPET2011 [2012 | | 6028 | Other Employees Expenses | 40.00|EEX_SUMMARY | AP10507633 | 0012358 | GARRISON,WINPRED W | 34881098 | 08960070 | 089412325481 | | FBPPET2011 [2012 | | 6028 | Other Employees Expenses | 92.00|EEX_SUMMARY | AP10507633 | 0028842 | TUMMINE,LO,STEPHAWE B | 34838188 | 08983733 | 043012139144 | | FBPPET2011 [2012 | | 6028 | Other Employees Expenses | 26.00|EEX_SUMMARY | AP10507633 | 0032482 | LESLANC,HEATHER G | 34632893 | 08884418 | 043012108041 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 152.16|EEX_SUMMARY | AP10507633 | 0032898 | MCCULLA,MAWY F | 34637607 | 08884422 | 080712490388 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 101.61|EEX_SUMMARY | AP10508136 | 0011818 | CIOO,FASTRICK J | 34680213 | 08984003 | 080712286368 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 147.60|EEX_SUMMARY | AP10508136 | 0014388 | TALKINGTON,MYRA L | 34882052 | 08983993 | 080812321886 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 98.24|EEX_SUMMARY | AP10508136 | 0041283 | CONSIGNER,MICHKE, P | 34682206 | 08984135 | 08081288428 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 12.00|EEX_SUMMARY | AP10508144 | 0012421 | PIERCE JEHLIGN VERNON | 34882124 | 08983985 | 080712176308 | | FBPPET2011 [2012 | | 8028 | Other Employees Expenses | 90.83|EEX_SUMMARY | AP10508144 | 0013388 | CORVIRAN,SHANN B | 34682144 | 08983982 | 080412244808 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 123.90|EEX_SUMMARY | AP10508763 | 0024705 | LEWIS,JAY A | 34705799 | 08969282 | 080712248111 | | FBPPET2011 [2012 | | 5028 | Other Employees Expenses | 158.90|EEX_SUMMARY | AP10508803 | 0013658 | BARBILLOAUX,CHRISS E | 34716180 | 09971157 | 080712304389 |

Roadmap to Internal Rate Case Expenses - Tab 2

| FSPPET2011 | 2012 | $\backslash$ 3028$ | Other Employees Expenses | 13.66|EEX_SUMMARY | AP10808908 | 8010500 | FLOODJOHN C | 34716224 | 00871159 | 06111211359 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | FSPPET2011 | 2012 | 5028 | Other Employees Expenses | 140.66|EEX_SUMMARY | AP10808544 | 8012546 | MAY JF, PHILLIP R | 34720726 | 00873231 | 061212288365 | | FSPPET2011 | 2012 | 5028 | Other Employees Expenses | 255.06|EEX_SUMMARY | AP10808258 | 8010660 | WESTERBURG JR, LOUIS R | 34735436 | 00875315 | 060912224822 | | FSPPET2011 | 2012 | 5028 | Other Employees Expenses | 42.06|EEX_SUMMARY | AP10808833 | 8082466 | MOLVOY,KARSH | 34756220 | 00881193 | 05181244253 | | FSPPET2011 | 2012 | 5028 | Other Employees Expenses | 97.16|EEX_SUMMARY | AP10810290 | 8038153 | MOCUSHEY MARGARET | 34777185 | 00885637 | 052412113121 | | FSPPET2011 | 2012 | 6028 | Other Employees Expenses | 120.06|EEX_SUMMARY | AP10812621 | 8012139 | GALBRATH,PATRICA | 34843977 | 10001387 | 060712122389 | | FSPPET2011 | 2012 | 6028 | Other Employees Expenses | 146.00|EEX_SUMMARY | AP10812621 | 8013698 | ROBERTS RORY LUTHER | 34818362 | 06068198 | 052312172184 | | FSPPET2011 | 2012 | 6028 | Other Employees Expenses | 48.66|EEX_SUMMARY | AP10813621 | 8032402 | LERLANC, HEATHER G | 34842594 | 10001410 | 060712114113 | | FSPPET2011 | 2012 | 6028 | Other Employees Expenses | 60.86|EEX_SUMMARY | AP10813304 | 8010493 | LAYCO, DEVON S | 34855943 | 10004341 | 06081283871 | | FSPPET2011 | 2012 | 7028 | Other Employees Expenses | 144.06|EEX_SUMMARY | AP10817815 | 8011664 | GARDNER,KEVIN G | 34857933 | 10008776 | 062312180989 | | FSPPET2011 | 2011 | 12288 | Other Office &; General | 158.54|OQL_SUMMARY | AP10480429 | 836123 | XEROX BUSINESS CORP | 33780780 | 06774699 | 0721108151 | | FSPPET2011 | 2011 | 12288 | Other Office &; General | 5.233.78|OQL_SUMMARY | APE0485910 | 061644 | OTIBANK USA NA | PCARD | 06755009 | 1381581_20 | | FSPPET2011 | 2011 | 12288 | Other Office &; General | 8.35|OQL_SUMMARY | AP50486646 | 061644 | OTIBANK USA NA | PCARD | 06755009 | 1381581_20 | | FSPPET2011 | 2012 | 3288 | Other Office &; General | 438.10|OQL_SUMMARY | AP10490811 | 836123 | XEROX BUSINESS CORP | 34280568 | 09566770 | 0231108192 | | FSPPET2011 | 2012 | 6563 | Pagers/Cellular Priones | 9.95|TCM_SUMMARY | AP10512621 | 8012139 | GALBRATTH,PATRICA | 34843577 | 10001387 | 060712122386 | | FSPPET2011 | 2011 | 7028 | Personal Car Mileage - Local | 76.56|EEX_SUMMARY | AP10480163 | 8032452 | LERLANC, HEATHER G | 33138538 | 06081776 | 0714118850 | | FSPPET2011 | 2011 | 8026 | Personal Car Mileage - Local | 109.89|EEX_SUMMARY | AP10480101 | 8010667 | TAYLOR JR, JOHN E | 33392690 | 06648871 | 09061113388 | | FSPPET2011 | 2011 | 10026 | Personal Car Mileage - Local | 3.23|EEX_SUMMARY | AP10473573 | 8014149 | CASH,ROBERT G | 23543754 | 06667228 | 06261175866 | | FSPPET2011 | 2011 | 10026 | Personal Car Mileage - Local | 219.78|EEX_SUMMARY | AP10472996 | 8010567 | TAYLOR JR,JOHN E | 33534057 | 06080104 | 10061136244 | | FSPPET2011 | 2011 | 10026 | Personal Car Mileage - Local | 166.50|EEX_SUMMARY | AP10474816 | 8032402 | LERLANC, HEATHER G | 33509093 | 06700119 | 10141119050 | | FSPPET2011 | 2011 | 10026 | Personal Car Mileage - Local | 18.64|EEX_SUMMARY | AP10475208 | 8035602 | DOSS, GENE E | 33626811 | 06709411 | 101711120842 | | FSPPET2011 | 2012 | 3028 | Personal Car Mileage - Local | 277.56|EEX_SUMMARY | AP10488441 | 8035763 | SCHEI,WOX,PALS, A | 34360133 | 09006259 | 08091280408 | | FSPPET2011 | 2012 | 3028 | Personal Car Mileage - Local | 13.86|EEX_SUMMARY | AP10508962 | 8011616 | CIOO,PATRICK J | 34444162 | 06008135 | 03271268484 | | FSPPET2011 | 2012 | 6028 | Personal Car Mileage - Local | 30.53|EEX_SUMMARY | AP10503678 | 8030496 | THEY,MONELE H | 34633003 | 06628566 | 041112160853 | | FSPPET2011 | 2012 | 4028 | Personal Car Mileage - Local | 12.21|EEX_SUMMARY | AP10505194 | 8012102 | DOWING,JOSEPH F | 34593366 | 06943519 | 041912415876 | | FSPPET2011 | 2012 | 5028 | Personal Car Mileage - Local | 172.06|EEX_SUMMARY | AP10507633 | 8010645 | COOPER,ROBERT R | 34628123 | 06652684 | 04301268002 | | FSPPET2011 | 2012 | 5028 | Personal Car Mileage - Local | 177.69|EEX_SUMMARY | AP10507633 | 8013356 | GARRISON,WINFRED W | 34681088 | 06660870 | 030412325481 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 83.25|EEX_SUMMARY | AP10507633 | 8032452 | LERLANC, HEATHER G | 34637553 | 06654418 | 043012108541 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 172.06|EEX_SUMMARY | AP10508136 | 8010645 | COOPER,ROBERT R | 34692201 | 06663588 | 05081243388 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 95.52|EEX_SUMMARY | AP10508136 | 8011616 | CIOO,PATRICK J | 34682213 | 06964003 | 080712266369 | | FSPPET2011 | 2012 | 6026 | Personal Car Mileage - Local | 290.62|EEX_SUMMARY | AP10508144 | 8012421 | PIERCE JR,HUGH VERWIGH | 34682124 | 06693985 | 050712176309 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 290.64|EEX_SUMMARY | AP10508144 | 8015388 | CORWNAN,SHANKS B | 34682144 | 06963982 | 080412244806 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 27.75|EEX_SUMMARY | AP10508902 | 8002466 | MOLVOY,KARSH | 34716181 | 05671260 | 051412621210 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 99.90|EEX_SUMMARY | AP10508808 | 8010509 | FLOOD,JOHN C | 34716224 | 05671159 | 05111211556 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 166.50|EEX_SUMMARY | AP10508833 | 8052466 | MOLVOY,KARSH | 34738350 | 06081193 | 05181244253 | | FSPPET2011 | 2012 | 5026 | Personal Car Mileage - Local | 130.95|EEX_SUMMARY | AP80060002 | | (Stand Value) | | | | | FSPPET2011 | 2012 | 6026 | Personal Car Mileage - Local | 12.21|EEX_SUMMARY | AP10512621 | 8012152 | DOWING,JOSEPH F | 34603455 | 06662761 | 051712196808 |

Roadmap to Internal Rate Case Expenses - Tab 2

| FSPPET2011 [2012 | 5 | 6 | Personal Car Mileage - Local | 45.06 | ESC_SUMMARY | AP10512621 | 9013038 | ROBERTS,RORY LUTHER | 34816362 | 09995188 | 052312172184 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | FSPPET2011 [2012 | 5 | 5 | Personal Car Mileage - Local | 6.33 | ESC_SUMMARY | AP10513621 | 9032452 | LEBLANC,HEATHER G | 34843584 | 10001416 | 090712114113 | | FSPPET2011 [2012 | 5 | 5 | Personal Car Mileage - Local | 120.08 | ESC_SUMMARY | AP10513628 | 9012421 | PIERCE JR,HUGH VERMON | 34788404 | 09588665 | 053412101383 | | FSPPET2011 [2012 | 5 | 5 | Personal Car Mileage - Local | 27.75 | ESC_SUMMARY | AP10513204 | 9010403 | JAYCOX,DEVIGH S | 34855943 | 10004341 | 09081283871 | | FSPPET2011 [2012 | 5 | 5 | Personal Car Mileage - Local | -130.08 | ESC_SUMMARY | AP07000002 | | (Blank Value) | | | | | FSPPET2011 [2012 | 5 | 5 | Personal Car Mileage - Local | 76.02 | ESC_SUMMARY | AP10524013 | 9008784 | ROBINSON MARTHA.A | 35246254 | 10008533 | 0816125546 | | FSPPET2011 [2012 | 1 | 286 | Postage and Overnight Delivery | 2,605.74 | OGL_SUMMARY | APE0459027 | 091644 | CITBANK USA NA | 34070066 | 09823782 | 1396371_29 | | FSPPET2011 [2012 | 1 | 286 | Postage and Overnight Delivery | 880.76 | OGL_SUMMARY | APE0489827 | 091644 | CITBANK USA NA | PQAND | 09823782 | 1396371_29 | | FSPPET2011 [2012 | 2 | 286 | Postage and Overnight Delivery | 471.13 | OGL_SUMMARY | APE0404790 | 091644 | CITBANK USA NA | 34221310 | 09801265 | 1400712_21 | | FSPPET2011 [2012 | 3 | 286 | Postage and Overnight Delivery | 1,871.93 | OGL_SUMMARY | APE0600469 | 091644 | CITBANK USA NA | 34307795 | 09888307 | 1432474_21 | | FSPPET2011 [2012 | 4 | 286 | Postage and Overnight Delivery | 2,024.88 | OGL_SUMMARY | APE0504955 | 091644 | CITBANK USA NA | 34504900 | 09041903 | 1437205_21 | | FSPPET2011 [2012 | 4 | 286 | Postage and Overnight Delivery | 10.86 | OGL_SUMMARY | APE0604956 | 091644 | CITBANK USA NA | 34541795 | 09041903 | 1437205_21 | | FSPPET2011 [2012 | 4 | 286 | Postage and Overnight Delivery | 8.14 | OGL_SUMMARY | APE0604956 | 091644 | CITBANK USA NA | 34576212 | 09041903 | 1437205_21 | | FSPPET2011 [2012 | 5 | 286 | Postage and Overnight Delivery | 547.06 | OGL_SUMMARY | APE0606838 | 091644 | CITBANK USA NA | 34699058 | 09979248 | 1449843_21 | | FSPPET2011 [2012 | 5 | 286 | Postage and Overnight Delivery | 19.39 | OGL_SUMMARY | APE0609638 | 091644 | CITBANK USA NA | 34709602 | 09979348 | 1449843_21 | | FSPPET2011 [2012 | 6 | 286 | Postage and Overnight Delivery | 155.76 | OGL_SUMMARY | APE0514900 | 091644 | CITBANK USA NA | 34906481 | 10020935 | 1463167_21 | | FSPPET2011 [2012 | 7 | 286 | Postage and Overnight Delivery | 86.96 | OGL_SUMMARY | APE0519689 | 091644 | CITBANK USA NA | 34934607 | 10056265 | 1477004_21 | | FSPPET2011 [2012 | 7 | 286 | Postage and Overnight Delivery | 15.50 | OGL_SUMMARY | APE0519690 | 091644 | CITBANK USA NA | 35047707 | 10056265 | 1477004_21 | | FSPPET2011 [2011 | 6 | 636 | Safety Training Leader | 62.68 | ALC_SUMMARY | ALO0407773 | | (Blank Value) | | | | | FSPPET2011 [2011 | 9 | 636 | Safety Training Leader | 386.84 | ALC_SUMMARY | ALO0472418 | | (Blank Value) | | | | | FSPPET2011 [2011 | 10 | 636 | Safety Training Leader | 512.05 | ALC_SUMMARY | ALO0477045 | | (Blank Value) | | | | | FSPPET2011 [2011 | 11 | 636 | Safety Training Leader | 230.63 | ALC_SUMMARY | ALO0481783 | | (Blank Value) | | | | | FSPPET2011 [2011 | 12 | 636 | Safety Training Leader | 72.40 | ALC_SUMMARY | ALO0480380 | | (Blank Value) | | | | | FSPPET2011 [2012 | 1 | 1636 | Safety Training Leader | 28.63 | ALC_SUMMARY | ALO0481441 | | (Blank Value) | | | | | PSPPET2011 [2012 | 2 | 636 | Safety Training Leader | 89.02 | ALC_SUMMARY | ALO0408165 | | (Blank Value) | | | | | FSPPET2011 [2012 | 4 | 636 | Safety Training Leader | 142.56 | ALC_SUMMARY | ALO0506360 | | (Blank Value) | | | | | FSPPET2011 [2012 | 5 | 5 | Safety Training Leader | 200.07 | ALC_SUMMARY | ALO0511301 | | (Blank Value) | | | | | FSPPET2011 [2011 | 7 | 740 | Service Company Recipient | 7,701.63 | SCR_SUMMARY | ALO0402894 | | (Blank Value) | | | | | PSPPET2011 [2011 | 8 | 740 | Service Company Recipient | 27,693.15 | SCR_SUMMARY | ALO0407773 | | (Blank Value) | | | | | FSPPET2011 [2011 | 9 | 740 | Service Company Recipient | 33,068.33 | SCR_SUMMARY | ALO0472418 | | (Blank Value) | | | | | FSPPET2011 [2011 | 10 | 740 | Service Company Recipient | 38,845.46 | SCR_SUMMARY | ALO0477045 | | (Blank Value) | | | | | FSPPET2011 [2011 | 11 | 740 | Service Company Recipient | 35,887.61 | SCR_SUMMARY | ALO0481783 | | (Blank Value) | | | | | FSPPET2011 [2011 | 12 | 740 | Service Company Recipient | 28,744.81 | SCR_SUMMARY | ALO0486980 | | (Blank Value) | | | | | FSPPET2011 [2012 | 1 | 740 | Service Company Recipient | 34,830.73 | SCR_SUMMARY | ALO0481441 | | (Blank Value) | | | | | FSPPET2011 [2012 | 2 | 740 | Service Company Recipient | 33,753.06 | SCR_SUMMARY | ALO0408168 | | (Blank Value) | | | | | FSPPET2011 [2012 | 3 | 740 | Service Company Recipient | 25,737.01 | SCR_SUMMARY | ALO0501827 | | (Blank Value) | | | | | FSPPET2011 [2012 | 4 | 740 | Service Company Recipient | 32,875.43 | SCR_SUMMARY | ALO0506380 | | (Blank Value) | | | |

Roadmap to Internal Rate Case Expenses - Tab 2

| FSPPET2011 | 2012 | 5/740 | Service Company Recipient | 26,028.05/SCR_SUMMARY | ALCOG11301 | (Blank Value) | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | FSPPET2011 | 2012 | 6/740 | Service Company Recipient | 6,534.96/SCR_SUMMARY | ALCOG16356 | (Blank Value) | | | | | FSPPET2011 | 2012 | 7/740 | Service Company Recipient | 6,193.14/SCR_SUMMARY | ALCOG21270 | (Blank Value) | | | | | FSPPET2011 | 2012 | 8/740 | Service Company Recipient | 3,652.41/SCR_SUMMARY | ALCOG26273 | (Blank Value) | | | | | FSPPET2011 | 2011 | 7/031 | Travel Transportation | 820.69/DEX_SUMMARY | AP10468654 | 5011993 | HOWELL, J. RWIS E | 32110960 | 09975339 | 079811105923 | | FSPPET2011 | 2011 | 8/031 | Travel Transportation | 518.25/DEX_SUMMARY | AP10464636 | 5012189 | CALDWELL, BRAN W | 33260598 | 09914888 | 08991153600 | | FSPPET2011 | 2011 | 8/031 | Travel Transportation | 486.76/DEX_SUMMARY | AP10464782 | 5035807 | HEAVENER, BARBARA | 33276857 | 09816756 | 08101145520 | | FSPPET2011 | 2011 | 8/031 | Travel Transportation | 583.76/DEX_SUMMARY | AP10465080 | 5012169 | CALDWELL, BRAN W | 33331220 | 09828798 | 082211118656 | | FSPPET2011 | 2011 | 9/031 | Travel Transportation | 623.76/DEX_SUMMARY | AP10468101 | 5035807 | HEAVENER, BARBARA | 33384230 | 09846835 | 08921158820 | | FSPPET2011 | 2011 | 9/031 | Travel Transportation | 93.84/DEX_SUMMARY | AP10469824 | 5012169 | CALDWELL, BRAN W | 33417870 | 09856771 | 091211143322 | | FSPPET2011 | 2011 | 10/031 | Travel Transportation | 161.68/DEX_SUMMARY | AP10475263 | 5039802 | DOSS, GEINE E | 33626811 | 09708411 | 101711125842 | | FSPPET2011 | 2011 | 11/031 | Travel Transportation | 227.13/DEX_SUMMARY | AP10478515 | 5012225 | HERRIAGTON,CHESTER | 33712733 | 09726295 | 110311319996 | | FSPPET2011 | 2011 | 12/031 | Travel Transportation | 1,906.49/DEX_SUMMARY | AP10483434 | 5010808 | PLOSO, JOHN C | 33893061 | 09773438 | 129811627547 | | FSPPET2011 | 2012 | 3/031 | Travel Transportation | 696.62/DEX_SUMMARY | AP10487469 | 5043693 | BOLING, JOHN HAN | 34217303 | 09876624 | 03821299207 | | FSPPET2011 | 2012 | 3/031 | Travel Transportation | 540.36/DEX_SUMMARY | AP10498898 | 5018259 | VONDRIVAMICHARA, KHAMSUINE | 34382648 | 09882167 | 039412114052 | | FSPPET2011 | 2012 | 2/031 | Travel Transportation | 152.26/DEX_SUMMARY | AP10500952 | 5011616 | CICO,PATRICK J | 34444162 | 09908138 | 03271268484 | | FSPPET2011 | 2012 | 4/031 | Travel Transportation | 315.04/DEX_SUMMARY | AP10505679 | 5036466 | THIRY, MICHELLE H | 34622093 | 09928656 | 041112190893 | | FSPPET2011 | 2012 | 4/031 | Travel Transportation | 398.19/DEX_SUMMARY | AP10504855 | 5010734 | MORGAN, WILLAM R | 34586077 | 09941357 | 04191268508 | | FSPPET2011 | 2012 | 4/031 | Travel Transportation | 578.79/DEX_SUMMARY | AP10505184 | 5012152 | DOMINO, JOSEPH F | 34553266 | 09943519 | 041912415876 | | FSPPET2011 | 2012 | 4/031 | Travel Transportation | 581.70/DEX_SUMMARY | AP10505873 | 5041283 | CONS, EINE, MICHAEL P | 34608934 | 09948155 | 042012106869 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 586.20/DEX_SUMMARY | AP10507633 | 5033842 | TUMANWELL, O, STEPHAME B | 34628168 | 09982733 | 043012139144 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 612.29/DEX_SUMMARY | AP10507632 | 5031646 | CHENKOOLA,MARIA F | 34628237 | 09982737 | 080112118001 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 594.70/DEX_SUMMARY | AP10507633 | 5032452 | LEGANC, NEATHER G | 34637593 | 09954416 | 043012106541 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 1,492.45/DEX_SUMMARY | AP10507633 | 5032998 | MCCULLA,MARK F | 34637507 | 09954423 | 060113499385 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 1,117.27/DEX_SUMMARY | AP10508139 | 5011616 | CICO,PATRICK J | 34682213 | 09984003 | 060712268269 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 1,986.65/DEX_SUMMARY | AP10508139 | 5014065 | TALKINGTON, MYRA L | 34682262 | 09982980 | 060812301066 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 563.20/DEX_SUMMARY | AP10508139 | 5041383 | CONS, EINE, MICHAEL P | 34682336 | 09984120 | 06081236425 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 787.69/DEX_SUMMARY | AP10508783 | 5034705 | LEWIS, JAY A | 34706789 | 09999282 | 060112248111 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 1,367.06/DEX_SUMMARY | AP10508902 | 5013658 | BARBILL, EAUX, CHRISE E | 34716180 | 09971187 | 060712304269 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 1,218.66/DEX_SUMMARY | AP10509041 | 5013646 | MAY JR, PHILLIP R | 34725726 | 09973231 | 061012288065 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 726.64/DEX_SUMMARY | AP10508298 | 5010689 | WESTERBURG JR, LOUIS R | 34735439 | 09976315 | 060912224622 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 638.76/DEX_SUMMARY | AP10516290 | 5038153 | MCCLOSKEY, MARGARET | 34777185 | 09985837 | 063412115121 | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 20.96/DEX_SUMMARY | AP90050002 | (Blank Value) | | | | | FSPPET2011 | 2012 | 5/031 | Travel Transportation | 219.78/DEX_SUMMARY | AP10513821 | 5012138 | GALBRALTH, PAZRICA | 34843577 | 10001387 | 060712122346 | | FSPPET2011 | 2012 | 6/031 | Travel Transportation | 476.20/DEX_SUMMARY | AP10513821 | 5012152 | DOMINO, JOSEPH F | 34803485 | 09982761 | 031112196809 | | FSPPET2011 | 2012 | 6/031 | Travel Transportation | 1,059.88/DEX_SUMMARY | AP10513821 | 5013688 | ROBERTS, RORT LUTHER | 34816362 | 09995198 | 062312172184 | | FSPPET2011 | 2012 | 6/031 | Travel Transportation | 20.66/DEX_SUMMARY | AP10513821 | 5019330 | DOUCET, DONNA | 34786279 | 09988725 | 06291266932 |

Roadmap to Internal Rate Case Expenses - Tab 2

| FSPPETIO11 [2012] | | 6|631 | Travel Transportation | 769.60|EEX_SUMMARY | AP10913321 | 8032452 | E.ERLANC.HEATHER G | 34843584 | 10091419 | 060212114113 | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | FSPPETIO11 [2012] | 6|631 | Travel Transportation | 370.10|EEX_SUMMARY | AP10813304 | 9010493 | JAYCOF,GEVON S | 34858543 | 10004341 | 06081283871 | | FSPPETIO11 [2012] | 6|631 | Travel Transportation | -29.00|EEX_SUMMARY | AP00000002 | (blank Value) | | | | | FSPPETIO11 [2012] | 7|631 | Travel Transportation | 583.20|EEX_SUMMARY | AP10817915 | 9011964 | GARDNER,KEVIN G | 34957933 | 10028776 | 062312180989 | | FSPPETIO11 [2012] | 7|631 | Travel Transportation | 678.20|EEX_SUMMARY | AP10917815 | 9034795 | LEMIS, JAY A | 34956027 | 10028826 | 06271227279 | | FSPPETIO11 [2011] | 12|299 | Utility Bits | 2,018.33|COL_SUMMARY | USCO480954 | (blank Value) | | | |

626,757.00

ETI Exhibit No. 6

SOAH DOCKET NO. 473-12-5573 DOCKET NO. 40295

APPLICATION OF ENTERGY TEXAS, INC. FOR RATE CASE EXPENSES PERTAINING TO PUC DOCKET NO. 39896

$S$ BEFORE THE STATE OFFICE ${}^{\text{FIR}}{}_A{}^{\text{OO}}$

OF $\S$ \$ ADMINISTRATIVE HEARINGS

SUPPLEMENTAL DIRECT TESTIMONY

OF MICHAEL P. CONSIDINE ON BEHALF OF ENTERGY TEXAS, INC.

OCTOBER 25, 2012 ${32}^{\prime }$

ENTERGY TEXAS, INC. SUPPLEMENTAL DIRECT TESTIMONY OF MICHAEL P. CONSIDINE DOCKET NO. 40295

TABLE OF CONTENTS

| | | Page | | :-- | :-- | --: | | I. | Witness Introduction | 1 | | II. | Purpose of Supplemental Direct Testimony | 1 | | III. | Update Regarding Internal Rate Case Expenses | 2 | | IV. | Recovery of Rate Case Expenses | 5 |

EXHIBITS

Exhibit MPC-SD-5 Summary Rate Case Expense Spreadsheet Exhibit MPC-SD-6 ESI Rate Case Charges to ETI by Affiliate Class

| 1 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

the reasonableness and necessity of the internal rate case expenses paid in September 2012. Company witness Stephen Morris has filed direct and supplemental direct testimony in Docket No. 39896 and supplemental direct testimony in this docket on October 5, 2012 and contemporaneous with the filing of this testimony addressing the reasonableness and necessity of external rate case expenses.

III. UPDATE REGARDING INTERNAL RATE CASE EXPENSES

Q. SINCE FILING ITS RATE FILING PACKAGE, HAS THE COMPANY

PROVIDED ITS INCURRED RATE CASE EXPENSES? A. Yes. On February 21, 2012, in Docket No. 39896, the Company filed its initial responses to Staff's 9th Requests for Information ("RFIs"), including schedules of internal and external rate case expenses as of December 31, 2011. On March 13, 2012, in Docket No. 39896, the Company filed my first supplemental direct testimony with attached exhibits containing schedules of internal and external rate case expenses as of January 31, 2012. On March 16, in Docket No. 39896, the Company provided updates to its responses to Staff's 9th RFIs. On October 5, in this docket, the Company filed my second supplemental direct testimony with attached exhibits containing schedules of internal and external rate case expenses as of August 31, 2012, as well as further updates to its responses to Staff's 9th RFIs.

| 1 | Q. | DO YOU PROVIDE AN UPDATE REGARDING THE LEVELS OF | | :--: | :--: | :--: | | 2 | | INCURRED RATE CASE EXPENSES IN THIS PIECE OF | | 3 | | SUPPLEMENTAL DIRECT TESTIMONY? | | 4 | A. | Yes. The summary rate case expense spreadsheet, included as part of | | 5 | | the Company's third addendum to its response to Staff RFI 9-1 and filed | | 6 | | contemporaneously herewith, is attached as Exhibit MPC-SD-5. This | | 7 | | exhibit presents external rate case expenses by vendor and internal rate | | 8 | | case expenses by ETI direct expense category and ESI department. As | | 9 | | shown in Exhibit MPC-SD-5, as of September 30, 2012, the Company had | | 10 | | incurred $\backslash$ 3,908,214 $inexternalratecaseexpensesand$ \ $4,844,362$ in | | 11 | | internal rate case expenses. The Company requests recovery of these | | 12 | | rate case expenses. | | 13 | | | | 14 | Q. | HAVE YOU REVIEWED THE INTERNAL RATE CASE EXPENSES | | 15 | | PRESENTED IN EXHIBIT MPC-SD-5 TO DETERMINE WHETHER SUCH | | 16 | | EXPENSES ARE REASONABLE AND NECESSARY? | | 17 | A. | Yes. | | 18 | | | | 19 | Q. | HOW DID YOU DETERMINE WHETHER THE INCURRED INTERNAL | | 20 | | RATE CASE EXPENSES PRESENTED IN EXHIBIT MPC-SD-5 WERE | | 21 | | REASONABLE AND NECESSARY? | | 22 | A. | Internal rate case expenses are all captured in Project Code | | 23 | | F5PPETX011. The project code is used only for time and expense related |

to the Docket No. 39896 rate case, and all costs incurred by ESI in this project code are directly billed to ETI. The process through which costs are billed to project codes were described in Company witness Stephanie B. Tumminello's direct testimony from Docket No. 39896. In addition, the Company's affiliate class witnesses from Docket No. 39896, including those who address the ETI direct charges, explained how the budgeting and cost control processes work within their business units. For example, timesheet and expense reports are reviewed by supervisors to ensure accuracy. Also, in Docket No. 39896, Company witness Kevin G. Gardner supported the reasonableness and necessity of the compensation and benefits paid to ESI employees.

In Docket No. 39896, Company witnesses presented direct testimony regarding the various classes of affiliate costs that ETI received from ESI, and my Exhibit MPC-SD-6, attached hereto, shows the ESI rate case charges to ETI by affiliate class. The processes and practices described in the Company's Docket No. 39896 direct testimony regarding billing, budgeting, cost control, compensation, and benefits remain in effect today. These processes and practices help to ensure that the requested internal rate case expenses are necessary and reasonable, represent the actual costs of the services, do not include prohibited expenses, do not include charges for duplicative services or expenses, and are no higher than the prices charged to other affiliates, or to nonaffiliates, for the same or similar classes of item.

| 1 | Further, a review of the Company's requested rate case expenses is undertaken to determine that only appropriate charges are included in the rate case expense request, and inappropriate charges, such as charges for luxury items or excessive meals charges, are excluded. | | :--: | :--: | | 2 | WHAT DID YOU CONCLUDE WITH RESPECT TO THE REASONABLENESS AND NECESSITY OF THE COMPANY'S INCURRED INTERNAL RATE CASE EXPENSES? | | 3 | Based on my review and analysis, as described above, the Company's incurred internal rate case expenses are reasonable and necessary. | | 11 | | | 12 | IV. RECOVERY OF RATE CASE EXPENSES | | 13 | HOW DOES THE COMPANY PROPOSE TO RECOVER RATE CASE EXPENSES? | | 15 | As explained in my direct testimony, the Company proposes that it be permitted to recover all incurred rate case expenses over a three-year period, with a return on the unamortized balance. | | 16 | | | 17 | | | 19 | DOES THIS CONCLUDE YOUR SUPPLEMENTAL DIRECT TESTIMONY? | | 20 | TESTIMONY? | | 21 | Yes. |

ACCOUNTING

DELOTTE &; TOUCHE LLP Total LESS NON-CONFORMING D&;T EXPENSES PRICEWATERHOUSE COOPERS LLP Total LESS NON-CONFORMING PWC EXPENSES ACCOUNTING TOTAL

CONSULTANTS

DULORES S STOKES DBA D STOKES CONSULTING EXPERT POWERHOUSE LLC DBA EXPERGY FINANCO INC GERALD W TUCKER CPA JAY HARTZELL MILLER &; CHEVALIER CHARTERED TOWERS WATSON PENNSYLVAMA INC LESS NON-CONFORMING TWP EXPENSES CONSULTANTS TOTAL

LEGAL

DUGGINS WIEN MANN &; ROMERO LLP LESS NON-CONFORMING DWMR EXPENSES

LEGAL TOTAL

INTERNAL RATE CASES EXPENSES (NON-PAYROLL)

Business Meals/Entertainment Class Bills-Lowton Law Firm Computer &; Office Supplies Court Transcripts Depreciation &; Amort Expenses Employees Migs/Functions Legal Notices Lodging Other Employee Expenses Other Office &; General Pagers/Cellular Phones Personal Car Mileage - Local Postage and Overnight Delivery Printing, Mailing &; Shipping Service Company Recipient Temporary Services Travel Transportation Utility Bills LESS NON-CONFORMING COMPANY EXPENSES INTERNAL RATE CASES EXPENSES (NON-PAYROLL) TOTAL

ESI PAYROLL BENEFITS &; TAXES

RATE CASE EXPENSES THROUGH 9/30/12

• Please refer to the Company's response and addenda to Staff 9-1 for detail supporting the Accounting, Consultant, and Legal expenses addressed above. Amounts for Duggins Wren Mann &; Romero, LLP include fees and expenses from the following consultants: Commonwealth Consulting; Alliance Consulting; Lewis &; Ellis; Naman, Howell, Smith &; Lee; and Vector Advisors.

AMOUNT 915,970 (2,373) 122,168 (7) 1,035,758

17,290 172,752 125,220 116,119 12,625 19,443 2,288 (22)

465,915

2,406,607 (66)

2,406,541

See next tab and Ex. MPL-SD-8 for Detail

EXHIBIT MPC-SD-5 Dockat No. 40295 Page 2 of 2

| Dir. City Aells, Secur &; R. E. Cep | 1,423 | 14 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | :--: | :--: | :--: | :--: | | Collections, Eal Detail | 356 | 14 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Renaissance Processing-Eal | 120 | 8 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Cec Customer Contact Solution | 23,968 | 232 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Customer Load Information Adm | 8,468 | 135 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Uau President &; Ceo | 4,656 | 21 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Bud Fees, Cep (Sues -Eel | 40,490 | - | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Revenue Requirement &; Analyses | 214,527 | 3,422 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Rate Design &; Administration | 161,625 | 2,847 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Regulatory Litigation Support | 161,702 | 5,295 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Director - Regulatory Projects | 15,295 | 235 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Forecasting &; Analysis | 961 | 21 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Fuel &; Special Riders | 14,913 | 222 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Planning Analysis | 162 | 1 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Vp Regulatory Services | 17,770 | 100 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Procurement&;Aseal Optimization | 1,243 | 21 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Regulatory Accounting | 383,604 | 5,691 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Mlog Research &; Forecasting | 780 | 11 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Wholesale Business | 1,460 | 19 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Distribution Engineering Detai | 31,121 | 424 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Proj Costing/Picell Assets Opins | 4,022 | 59 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Accounts Payable | 9,660 | 376 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Affaide Acctg &; Allocations | 109,091 | 1,953 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Corporate Planning &; Perform | 10,172 | 177 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | External Reporting | 16,794 | 355 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Controller Utility Operations | 5,106 | 73 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | CFO: Utility Operations | 11,363 | 150 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | State And Local Taxes | 27,724 | 338 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Regulatory Tax Support | 46,937 | 338 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Office of Corp Risk Oversight | 571 | 4 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Accounting Policy And Research | 1,721 | 22 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Corporate Finance | 18,859 | 295 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Business Services | 17,085 | 218 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Income Tax Accounting | 14,719 | 245 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Dir. Tax Accounting &; Compdian | 5,986 | 45 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Asset Management Support | 23,780 | 414 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Director of Northwest Region | 2,756 | 18 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Compensation &; Benefits Design | 60,857 | 717 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | HR Compliance | 5,810 | 122 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | VP HR Operations | 1,393 | 22 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | HR - Project Management | 38,549 | 427 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | VP HR Programs | 10,396 | 59 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | HR - Total Rewards Prgms | 8,289 | 98 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | HR - Total Rewards Opis | 794 | 19 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | HR - Business Metrics | 1,960 | 33 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Chief Legal Officer | 58,949 | 562 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Legal - Litigation - TX | 7,144 | 63 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Legal - FERC | 2,156 | 17 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Legal - General Counsel | 2,744 | 42 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Legal - Reg - Corp | 5,151 | 45 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Legal - Reg - TX | 145,689 | 2,302 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Utility System Communications | 452 | 3 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | VP - Advocacy Communications | 240 | 6 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Federal Regulatory Affairs | 758 | 8 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | WEB COMMUNICATIONS | 1,146 | 14 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | System Regulatory Affairs(Dir) | 15,993 | 169 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Rish Management | 12,758 | 154 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Internal Audit | 2,882 | 41 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | SUPPLY CHAIN BUSINESS SUPPORT | 9,552 | 129 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | DIRECTOR SUPPLY CHAIN SUPPORT | 2,854 | 15 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Regulatory Affix/Energy Settim | 187,308 | 2,623 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | SPQ Compliance&;Contact Admin | 1,658 | 49 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Energy Analysis &; Reporting | 695 | 7 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | SPQ Compliance&;Business Suporl | 13,289 | 107 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Generation Planning &; Models | 3,016 | 29 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Operations Planning | 1,090 | 12 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Supply Planning andAnalysis | 742 | 15 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Power Supply | (11,584) | (133) | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | VP Energy Management | 487 | 4 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Gen Supun - Sq&;S | 12,286 | 100 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Regulatory Strategy | 46,512 | 487 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | sdra &; Enterprise Services | 4,277 | 44 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Security and Compliance | 6,826 | 61 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | Trans Regulatory Support | 29,685 | 395 | ASSIST IN RATE CASE PREPARATION &; RFI RESPONSES | | TOTAL ESI WAGES | 2,102,309 | 32,592 | |

Affiliate Rate Case Expenses Payroll, Benefits, Payroll Taxes, and Incentive Costs by Class Through Sept 30, 2012

Exhibit MPC-SD-6 Docket No. 40295 Page 1 of 1

| | | | | | :-- | :-- | :--: | :--: | | ADMINISTRATION | Pliuche, Tom | 1,879 | $0.07\%$ | | CUSTOMER SERVICE OPERATIONS | Stokes, Dolly | 42,071 | $1.46\%$ | | DISTRIBUTION OPERATIONS | Corkran, Shawn * | 41,169 | $1.43\%$ | | ENERGY AND FUEL MANAGEMENT | Cicio, Patrick | 236,250 | $8.22\%$ | | FEDERAL PRG AFFAIRS | Ferguson, Walter | 21,674 | $0.75\%$ | | FINANCIAL SERVICES | Doucet, Donna | 248,761 | $8.65\%$ | | FOSSIL PLANT OPERATIONS | Garrison, Wayne | 35,088 | $1.22\%$ | | HUMAN RESOURCES | Gardner, Kevin | 277,668 | $9.66\%$ | | INFORMATION TECHNOLOGY | Brown, Julie | 14,665 | $0.51\%$ | | INTERNAL &; EXTERNAL COMMUNICATIONS | Herrington, Chester | 2,438 | $0.08\%$ | | LEGAL SERVICES | Sloan, Robert D | 293,799 | $10.22\%$ | | OTHER EXPENSES | Tumminello, Stephanie B | 41,280 | $1.44\%$ | | REGULATORY SERVICES | May, Phillip | $1,385,044$ | $48.16\%$ | | RETAIL OPERATIONS | Stokes, Dolly | 2,965 | $0.10\%$ | | SUPPLY CHAIN | Hunter, Joseph | 16,603 | $0.58\%$ | | TAX SERVICES | Galbraith, Patricia | 125,787 | $4.37\%$ | | TRANSMISSION OPERATIONS | McCulla, Mark | 39,554 | $1.38\%$ | | TREASURY OPERATIONS | McNeal, Steve | 42,710 | $1.49\%$ | | UTILITY &; EXECUTIVE MANAGEMENT | Domino, Joe * | 6,176 | $0.21\%$ | | | | $2,875,781$ | $100.00\%$ | | | | | | | * ETI employees with affiliate costs | | | |

DOCKET NO. 39896

| APPLICATION OF ENTERGY | § | PUBLIC UTILITY COMMISSION | | :-- | :--: | :--: | | TEXAS, INC. FOR AUTHORITY | § | | | TO CHANGE RATES AND | § | OF TEXAS | | RECONCILE FUEL COSTS | § | |

DIRECT TESTIMONY

OF

KEVIN G. GARDNER

ON BEHALF OF

ENTERGY TEXAS, INC.

November 2011

ENTERGY TEXAS, INC.
DIRECT TESTIMONY OF KEVIN G. GARDNER 2011 RATE CASE

TABLE OF CONTENTS

Page I. Witness Identification and Qualifications ..... 1 II. Purpose and Organization of Testimony ..... 2 III. Relationship Between this Testimony Regarding Compensation and Benefits Costs and the Testimony of ETI's Other Witnesses ..... 3 IV. Compensation and Benefits Programs ..... 4 A. The Entergy Companies' Objective in Designing Compensation and Benefits Programs ..... 4 B. Compensation Programs ..... 5

1. The Entergy Companies' Approach to Compensation ..... 5
2. Description of the Entergy Companies' Compensation Program Design ..... 9
3. Additional Detail Regarding the Annual Incentive and Recognition Programs ..... 16
4. Additional Detail Regarding the Long-Term Incentive Programs ..... 20
5. The Test Year Compensation Programs and Costs are Necessary and Reasonable ..... 22
6. Commission Precedent Regarding Financially Based Incentive Compensation ..... 29 C. Benefit Plans ..... 33
7. Description of the Entergy Companies' Benefit Plans ..... 33
8. The Test Year Benefit Plans are Necessary and the Costs are Reasonable ..... 37 D. Other Labor-Related Costs ..... 43

E. Affiliate Benefits and Compensation Expenses ..... 46 V. Affiliate Expenses for the HUMAN RESOURCES Class ..... 47 A. Summary of Affiliate Expenses for the HR Class ..... 47 B. The HR Class Provides Necessary Services ..... 54 C. The HR Class Provides Necessary Services at a Reasonable Cost ..... 62

1. Objective Evidence ..... 62
2. Budget Planning ..... 64
3. Cost Trends ..... 66
4. Staffing Trends ..... 67
5. Cost Control and Process Improvement Initiatives ..... 68 D. The "Not Higher Than" and "At Cost" Standards ..... 69 E. Billing Allocation Methodology ..... 69

EXHIBITS

| KGG-1 | Annual Incentive Plan Summaries | | :--: | :--: | | KGG-2 | Equity Ownership Plan | | KGG-3 | Performance Unit Program Summaries and Management Level 6 Operational Incentive Plan | | KGG-4 | Incentive Compensation Allocation - Cost Control, Financial, Operational, Safety (Highly Sensitive) | | KGG-5 | Towers Watson 2011 BenVal Report (Highly Sensitive) | | KGG-6 | Paid Time Off Policies | | KGG-7 | Affiliate Families and Functions | | KGG-8 | Training Programs and Courses | | KGG-9 | Educational Assistance Program Policy | | KGG-10 | Saratoga Institute 2010 HR Staffing and Expenditures Comparison | | KGG-A | Affiliate Billings by Class and by Department | | KGG-B | Affiliate Billings by Class and by Project Code | | KGG-C | Affiliate Billings by Class, by Department, and by Project Code | | KGG-D | Pro Forma Adjustments to Affiliate Billings |

Entergy Texas, Inc. Page 1 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 I. WITNESS IDENTIFICATION AND QUALIFICATIONS Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, EMPLOYER AND JOB TITLE.

4 A. My name is Kevin G. Gardner. My business address is 639 Loyola 5 Avenue, New Orleans, Louisiana 70113. I am employed by Entergy 6 Services, Inc. ("ESI") ^[1] as Vice President, Human Resources - Total Rewards.

8 Q. ON WHOSE BEHALF ARE YOU TESTIFYING?

10 A. I am testifying on behalf of Entergy Texas, Inc. ("ETI" or the "Company"). 11 Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL WORK EXPERIENCE.

14 A. I earned a Bachelor's Degree in Business and a Master's in Business 15 Administration from the University of South Florida. I was promoted to my current position effective November 29, 2009. Prior to my current position, I had been Director of Human Resources ("HR") - Total Rewards since May 2005. I joined ESI in 1993 as a Senior Staff Compensation Analyst and have held a number of leadership roles in Human Resources including Manager of System Compensation, Director of HR and Director of HR - Total Rewards. Prior to joining ESI, I was employed by Florida

Power Corporation from 1986 to 1993, designing compensation programs and supporting general HR requirements. Prior to my employment with Florida Power Corporation, I held positions in general HR administration and marketing. Q. PLEASE DESCRIBE YOUR CURRENT RESPONSIBILITIES AND YOUR DEPARTMENT. A. I am responsible for the design, development, and administration of various compensation and benefits programs for ESI and the EOCs. ^[2] II. PURPOSE AND ORGANIZATION OF TESTIMONY Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? A. First, I describe the compensation, benefits, and other labor-related costs incurred by ESI and ETI and the other EOCs that provide services to ETI. I show how these programs are designed and managed to produce reasonable, market-competitive compensation and benefits programs.

Second, I describe the costs of the HR Class of affiliate services and demonstrate that the costs are reasonable and necessary.

1 Q. WHY ARE YOU QUALIFIED TO ADDRESS THESE ISSUES AND TO 2 PROVIDE THIS TESTIMONY? A. My job responsibilities, professional experience, and familiarity with the human resources department cover the scope of subjects I address in my testimony. Q. DO YOU SPONSOR ANY EXHIBITS? A. The list of exhibits to my testimony is contained in the table of contents. Q. DO YOU SPONSOR OR CO-SPONSOR ANY SCHEDULES IN THE RATE FILING PACKAGE ("RFP") THAT ETI HAS FILED IN THIS DOCKET? A. Yes, I sponsor Schedules G-1.5, G-2, and G-2.3. I co-sponsor Schedules G-1.6 and G-2.1 with Company witness Michael P. Considine. III. RELATIONSHIP BETWEEN THIS TESTIMONY REGARDING COMPENSATION AND BENEFITS COSTS AND THE TESTIMONY OF ETI'S OTHER WITNESSES Q. WHAT IS THE RELATIONSHIP BETWEEN YOUR TESTIMONY REGARDING COMPENSATION AND BENEFITS COSTS AND THE TESTIMONY OF ETI'S OTHER WITNESSES? A. Various ETI witnesses support the Test Year (July 2010 through June 2011) costs that contain internal labor dollars (e.g., ESI employee labor or ETI employee labor) from the perspective of whether the level and types

of activities for various utility and utility support functions are reasonable and necessary. My testimony demonstrates that the underlying compensation and benefits costs associated with these activities are the product of reasonable and necessary compensation and benefits programs that are designed and managed to yield reasonable costs.

IV. COMPENSATION AND BENEFITS PROGRAMS

A. The Entergy Companies' Objective in Designing Compensation and Benefits Programs Q. PLEASE DESCRIBE THE ENTERGY COMPANIES' OVERALL

OBJECTIVE IN DESIGNING THE COMPENSATION AND BENEFITS IT

PROVIDES. A. The Entergy Companies ^[3] must compete with other companies for talent based upon the total package of compensation and benefits each offers. In order to attract and retain highly qualified employees, the Entergy Companies provide a total package of compensation and benefits that is equivalent in scope and cost with what other comparable companies within the utility business and other industries provide for their employees. Although individual components within the total package of compensation and benefits programs may be above or below the market for which they compete for talent, the Entergy Companies' overall total compensation

and benefits package is comparable with industry medians. Regardless of the emphasis any particular company places on individual components of compensation and benefits, the comparisons among similar companies should be based upon the total costs of the companies' benefits and compensation programs.

B. Compensation Programs

1. The Entergy Companies' Approach to Compensation Q. WHAT FUNDAMENTAL PRINCIPLES GUIDE THE ENTERGY COMPANIES' COMPENSATION PROGRAMS? A. The Entergy Companies offer reasonable, competitive pay packages that are not only tied to each company's performance but also to individual employee performance. Employees are compensated through a combination of base pay and variable pay programs (e.g., annual incentive compensation). The Entergy Companies' total annual compensation (i.e., base pay plus annual incentive payments) across all job classifications is designed to be at market median.

Q. WHAT DOES IT MEAN THAT THE ENTERGY COMPANIES' TOTAL

ANNUAL COMPENSATION IS AT MARKET MEDIAN? A. It means that the total annual compensation is approximately within +/-10\% of the mid-point of the market based upon nationally recognized compensation surveys in which the Entergy Companies participate. By

mid-point of the market, I mean the point at which half the companies in the surveys pay total annual compensation that exceeds the Entergy Companies' total annual compensation and half the companies in the surveys pay less total annual compensation than do the Entergy Companies. The Entergy Companies seek to provide compensation that is within $+/-10\%$ of the mid-point of the market.

The Entergy Companies apply this design philosophy to base salary as well as incentive compensation programs (both annual and long-term), which I will discuss later in my testimony. In this way, the Entergy Companies intentionally design their compensation levels to pay the market median level of compensation if their employees meet the performance targets that are established. Of course, in any given year, the actual level of compensation under the incentive compensation programs may be above or below the market median, but that differential occurs solely due to actual performance versus the targets. Q. WHAT IS THE RELEVANCE OF HOW THE ENTERGY COMPANIES' COMPENSATION REGIME COMPARES TO THAT OF OTHER UTILITIES AND THE MARKET? A. In the long run, customers benefit from having a utility that is able to offer and does offer competitive compensation that attracts and keeps qualified people. If the Entergy Companies offered substantially below market compensation, then over time the quality of management and other

personnel would decline. As a consequence, so would service to customers.

Q. HOW DO YOU ENSURE THAT THE COMPENSATION PROGRAMS TARGET THE MARKET MEDIAN?

A. A nationally recognized external independent compensation consultant, Pay Governance LLC, has been engaged to evaluate and assess the compensation programs. The consultant offers subject matter expertise with respect to analyzing market survey data, assessing current market conditions, reviewing the prevalence of compensation elements and evaluating market trends in executive compensation.

The consultant provides compensation information to help ensure that all the Entergy Companies, including ETI and ESI, provide competitive compensation packages to attract, retain, motivate, and reward employees who can contribute to long-term operational and financial success.

Moreover, the Entergy Companies use numerous nationally recognized third-party surveys to evaluate compensation levels. These surveys provide data to ensure the competitiveness and reasonableness of pay practices. The list of recent surveys used by the Entergy Companies is shown below:

Table 1 Third-Party Surveys Used by the Entergy Companies' Compensation Department in Analyzing Pay Data

| Publisher Name | Survey | | :--: | :--: | | Towers Watson | Towers Watson Office Personnel Report, 2010 | | Towers Watson | Towers Watson Tech &; Skilled Trades Report, 2010 | | Towers Watson | Towers Watson Supervisory Mgmt Report, 2010 | | Stanton Group | Stanton Group Aviation Compensation Survey, 2010 | | Towers Watson | Towers Watson Professional Specialized Services Personnel, 2010 | | Towers Watson | Towers Watson Professional Administrative Services Personnel, 2010 | | Towers Watson | Towers Watson Middle Mgmt Report, 2010 | | Southern Gas Association | Southern Gas Association Energy Compensation Survey, 2009 | | Towers Watson | Towers Watson Top Mgmt Report, 2010 | | Towers Watson | Towers Executive CDB (Energy Services), 2010 | | Towers Watson | Towers Watson Mid-Mgmt &; Prof (Energy Services), 2010 | | Towers Watson | Amer Gas Assn Mgmt, Supv, and Prof &; Non-Exempt Comp Survey, 2010 | | Mercer Human Resource Consulting | Mercer Corp Mktg &; Comm, 2009 | | Mercer Human Resource Consulting | Mercer E-commerce Report, 2009 | | Mercer Human Resource Consulting | Mercer Fin, Acctg &; Legal, 2009 | | Mercer Human Resource Consulting | Mercer Human Res Mgmt, 2009 | | Mercer Human Resource Consulting | Mercer Info Tech, 2009 | | Mercer Human Resource Consulting | Mercer Logistics &; Supp Chn, 2009 | | Mercer Human Resource Consulting | Mercer Executive Survey, 2009 | | Mercer Human Resource Consulting | Mercer Metro Benchmark, 2009 | | Hewitt Associates | Hewitt Energy Marketing and Trading Compensation Survey, 2010 | | Hewitt Associates | Hewitt TCM Mgmt and Prof, 2010 | | Hewitt Associates | Hewitt TCM Exec, 2010 | | EAPDIS | EAPDIS Non-exempt survey | | World at Work | 2010-2011 Salary Budget Survey | | Towers Watson | 2010-2011 Salary Budget Survey | | Mercer Human Resource Consulting | 2010-2011 US Compensation Planning Survey | | Hewitt Associates | U.S. Salary Increase Survey for 2010 and 2011 |

2 3 Q. WHEN ANALYZING TOTAL COMPENSATION, DO THE ENTERGY

4 COMPANIES COMPARE THEMSELVES WITH PARTICULAR LABOR

5 MARKETS? 6 A. Yes. The Entergy Companies compare themselves with both the utility 7 industry and general industry in determining total compensation. Both

comparison groups are used because the Entergy Companies recruit from and lose talent to both utilities and general industry. The comparison recognizes that employees may pursue employment opportunities in either the utility market or general industry. Thus, the compensation levels must be competitive with both labor markets. Furthermore, when determining compensation comparison groups within those markets, the Entergy Companies compare themselves with companies or operations of similar size and scope.

Description of the Entergy Companies' Compensation Program Design PLEASE DESCRIBE THE ELEMENTS OF THE ENTERGY COMPANIES' COMPENSATION PROGRAM.

In general, employee compensation consists of three elements:

1. base pay;
2. annual incentives and recognition programs; and
3. long-term incentives.

These compensation programs are applicable throughout the Entergy Companies. Thus, ETI, ESI, and all of the other Entergy Companies use the same types of compensation programs.

1 Q. PLEASE DESCRIBE BASE PAY.

2 A. Base pay is the basic, non-variable, salary component of compensation. 3 Base pay is provided to all employees and remains the most common 4 form of payment throughout industries for all levels of employees. Base pay is designed to be comparable with base pay in relevant labor markets. Because most of the Entergy Companies' peers also provide incentive compensation, however, comparable base pay amounts will not, by themselves, produce a market competitive total compensation package.

9 10 Q. PLEASE DESCRIBE THE ANNUAL INCENTIVE PLANS. 11 A. During the Test Year, the Entergy Companies had five annual incentive plans. The five plans and the eligible employee groups were as follows:

• Executive Annual Incentive Plan ("EAIP"). Participation was limited to the Entergy Companies' officers (i.e., the Chief Executive Officer, Presidents, Executive Vice Presidents, Senior Vice Presidents, and Vice Presidents).
• Management Incentive Plan. Participation was limited to selected management personnel and key high-level individual contributor employees.

• Exempt Incentive Plan. Participation was limited to exempt
• Teamsharing Incentive Plan. Participation was limited to fulltime and part-time, non-exempt, ^[5] non-bargaining ^[6] employees who were ineligible for participation in another incentive plan. Certain non-exempt, bargaining employees ^[7] also are eligible for participation in this plan where it has been negotiated into the collective bargaining agreement.
• Teamsharing Plan for Selected Bargaining Units.

Participation was limited to full-time or part-time bargaining employees where this plan has been negotiated into the agreement.

Participation requirements and plan design for the five annual incentive plans are described in the plan summaries presented in Exhibit KGG-1. This exhibit covers the participation requirements during the Test Year.

5 Non-exempt employees refers to employees who are covered under the federal wage and hour law and must be paid overtime for all hours worked in excess of forty hours during a work week.

6 Non-bargaining employees are those not covered by any collective bargaining agreement.
7 Bargaining employees are those whose compensation, benefits, and work rules are covered by a collective bargaining agreement.

| 1 | Q. | PLEASE DESCRIBE THE EQUITY-BASED LONG-TERM INCENTIVES. | | :--: | :--: | :--: | | 2 | A. | Certain employees were eligible to receive stock option awards, restricted stock, and/or performance units under the Equity Ownership Plan ("EOP"). | | 4 | | The EOP is outlined in Exhibit KGG-2. | | 5 | | Restricted stock was added to the long-term incentive mix in January 2011. ML 1 through 4 employees (the Entergy Companies' most senior executives) are eligible for both stock options and restricted stock. | | 7 | | ML 5 employees (generally, the Entergy Companies' directors) are eligible for restricted stock only. Restricted stock is designed to deliver approximately the same value as stock options but using a significantly smaller number of shares. | | 8 | | ML 1-4 executives are also eligible to participate in the Performance Unit Programs, which are also called Long Term Incentive | | 10 | | Plans or "LTIP." Each LTIP is based upon a three-year performance period. The Test Year in this case (July 1, 2010 through June 30, 2011) affects four of these LTIPs, and costs from the four LTIPs accrued during the Test Year. The first applicable plan covers the three-year performance period of 2008-2010; the second plan covers 2009-2011; the third plan covers 2010-2012; and the fourth plan covers 2011-2013. Each plan provides participants with the opportunity to earn performance units (which I discuss below) based upon the Entergy Companies' performance | | 12 | | against a pre-set performance goal. The four Performance Unit Program summaries and plan designs are provided in Exhibit KGG-3. | | 13 | Performance Unit Programs, which are also called Long Term Incentive Plans or "LTIP." Each LTIP is based upon a three-year performance period. The Test Year in this case (July 1, 2010 through June 30, 2011) affects four of these LTIPs, and costs from the four LTIPs accrued during the Test Year. The first applicable plan covers the three-year performance period of 2008-2010; the second plan covers 2009-2011; the third plan covers 2010-2012; and the fourth plan covers 2011-2013. Each plan provides participants with the opportunity to earn performance units (which I discuss below) based upon the Entergy Companies' performance against a pre-set performance goal. The four Performance Unit Program summaries and plan designs are provided in Exhibit KGG-3. | |

| 1 | Q. | IN YOUR PREVIOUS ANSWER, YOU REFERRED TO PERFORMANCE | | :--: | :--: | :--: | | 2 | | UNITS, STOCK OPTIONS, AND RESTRICTED STOCK. PLEASE | | 3 | | EXPLAIN THE DISTINCTIONS AMONG THESE INCENTIVE DEVICES. | | 4 | A. | Under a performance unit plan, an employee is awarded at the start of a performance period (e.g., a thirty-six month performance cycle), a number | | 6 | | of performance units ("units"), shares of common stock, or cash that is | | 8 | | payable, in whole or in part, at the end of the performance period | | 9 | | depending upon the extent that performance targets are met. If the actual performance is at the target level, then the employee earns 100\% of the | | 12 | | units, shares, or cash. If the actual performance is below the target level, but above a minimum level, then the employee earns only a portion of the | | 13 | | units, shares, or cash. If the actual result is below the minimum level (e.g., less than $10\%$ of the target) then no payment is made to the | | 14 | | employee. (A performance unit is the cash equivalent of the stock price on a certain date.) | | 16 | | Stock options award employees the right to purchase shares of common stock at a set price (e.g., $\backslash$ 40$ per share). If the publicly traded | | 18 | | stock price increases above that set price (e.g., $\backslash$ 45 $pershare),thentheemployeehastheoptiontopurchasethestockatthesetprice($ \ $40$ in my example) and choose to either sell the stock at the then publicly traded | | 20 | | stock price ( $\backslash$ 45$ in my example) or retain ownership of the shares. | | 21 | | Under a restricted stock plan, an employee receives shares of common stock with restrictions that lift if certain contingencies occur, such |

as if the employee remains with the company for a specific period of time or the company achieves certain operational or financial goals. As mentioned earlier, the Entergy Companies instituted a restricted stock program effective January 1, 2011 with time based vesting period as part of its long-term incentive plan. Q. DURING THE TEST YEAR, DID THE ENTERGY COMPANIES IMPLEMENT A NEW INCENTIVE PLAN FOR MANAGEMENT LEVEL 6 EMPLOYEES? A. Yes. During the Test Year, the Entergy Companies added the ML 6 Operational Incentive Plan. The purpose of this plan is to recognize ML 6 employees (which generally include managers, superintendents, supervisors, and other high-level contributors) for their superior leadership and outstanding performance in the successful operation of the company's business and to encourage continuous employment by reinforcing to the plan participants that they are highly valued members of the company. The primary areas of focus for outstanding performance include contributions to increased reliability, plant operations, employee and public safety, cost control, customer service, and other critical corporate support functions including finance, legal, human resources, communications, procurement, IT, etc. This program provides a cash-based payout to the selected employees based on the decision of their senior leadership team, and it is designed to provide the median targeted long-term compensation

1 reasonable discretion to provide for overall compensation at market competitive levels by offering market median base pay levels and incentive compensation programs that are comparable to those offered by similar companies.

5

6 7 8 Q. ARE ANNUAL INCENTIVE COMPENSATION PLANS COMMONLY USED BY PRIVATE INDUSTRY? 10 A. Yes. The following Table 2 demonstrates that, during the Test Year, annual incentive plans were common among the utilities and energy industry and general industries:

Table 2 Prevalence of 2010 Annual Incentive Programs Percentage of Surveyed Companies Reporting Annual Incentive Plans Similar to the Entergy Companies World At Work 2010-2011 Salary Budget Survey

| Use Of Variable Pay | 2008 | 2009 | 2010 | | :-- | :--: | :--: | :--: | | Percent of Organizations Using Variable
Pay | $81\%$ | $80\%$ | $80\%$ |

MERCER 2010-2011 US Compensation Planning Report

| Use of Variable Pay | Executives | Mgmt | Professional | Office Personnel | Technician &; Skilled | | :--: | :--: | :--: | :--: | :--: | :--: | | All (For Profit) Organizations | $90\%$ | $88\%$ | $77\%$ | $63\%$ | $55\%$ | | By Industry (Energy) | $88\%$ | $86\%$ | $84\%$ | $81\%$ | $84\%$ |

Towers Watson 2010-2011 Salary Budget Survey

| Use of Variable Pay | # of Organizations Responding | # of Organizations Using Variable Pay | \% of Organizations Using Variable Pay | | :--: | :--: | :--: | :--: | | Entire Sample (For Profit) | 801 | 674 | $84\%$ | | Industry Sector (Utilities &; Energy) | 91 | 74 | $81\%$ |

2 Q. HAVE THE ENTERGY COMPANIES' MEASURES FOR DETERMINING 3 ANNUAL INCENTIVES CHANGED IN RECENT YEARS? 4 A. Yes. Effective January 1, 2008, the Entergy Companies replaced the 5 Entergy Achievement Multiplier ("EAM"), a composite of Entergy 6 Corporation's earnings per share and operating cash flow used as a 7 widespread individual performance measure, with new measures aligned 8 with meeting operational-based targets. Each business unit or

organization within the Entergy Companies designs its own operationalbased targets tailored to the specifics of its operational responsibilities, focus, and activities (e.g., fossil plant operations will have different targets than will the HR department). These operational-based targets include reliability goals (e.g., reduce the frequency and duration of customer outages), safety goals (e.g., reduce the number of employee accidents), customer service goals (e.g., improve the speed of answering customer calls), cost containment (e.g., reduce expenditures, or controlling the rate of growth in expenditures, such as on vehicle maintenance, etc.) or spending levels (e.g., complete a project under budget).

The EAM is still used as a performance measure for Entergy Corporation executives making up the Office of the Chief Executive and all EAIP participants in the Finance Department. The EAM is used as a funding mechanism to ensure adequate funds exist to pay the incentives, but not as a performance target except as noted above. There has been no substantial change in the measures used to determine annual incentives since ETI's last rate case, Docket No. 37744. Q. WHAT MOTIVATED THE CHANGE IN INCENTIVE COMPENSATION PLAN DESIGN? A. The intent of the change was to further re-enforce the link between incentive compensation and the control employees felt they could have over the achievement of certain goals, such as safety, customer service,

operational performance and cost control measures. These measures place additional focus on providing safe, cost-effective, and reliable service to customers.

Q. DO THE ENTERGY COMPANIES HAVE ANY OTHER INCENTIVE PROGRAMS? A. Yes. The Entergy Recognition Program allows for the reward of an employee with a one-time lump sum for exemplary work on a special project or assignment. The Impact Award is an important part of the Entergy Recognition Program. Impact Awards recognize individual or team members for outstanding achievement. Impact Awards are presented to employees in the form of cash. In general, Impact Awards recognize employees for their participation and contribution on a special project or assignment and recognizes significant achievement such as innovation, individual or team accomplishment, sustained high performance, extraordinary effort to resolve a problem, special project, act of heroism, and community service. Nomination of an employee or a team of employees for an Impact Award is most frequently initiated by the employee's immediate manager.

| 1 | Q. | IS IT REASONABLE FOR THE ENTERGY COMPANIES TO HAVE THIS PROGRAM? | | :--: | :--: | :--: | | 3 | A. | Yes. The recognition program is a valuable personnel practice. This program, which is generally associated with significant cost savings or improved work processes, helps to boost and maintain employee morale and productivity, and also contributes to reducing employee turnover by providing recognition for employee accomplishments. ETI's ratepayers benefit from the program because it encourages creative activity by employees that results in more cost efficiencies and a more productive and engaged workforce that provides better service to customers. | | 11 | | | | 12 | | 4. Additional Detail Regarding the Long-Term Incentive Programs | | 13 | Q. | ARE EQUITY-BASED LONG-TERM INCENTIVE COMPENSATION | | 14 | | PLANS COMMONLY USED BY COMPANIES SUCH AS THE ENTERGY | | 15 | | COMPANIES? | | 16 | A. | Yes. Equity-based long-term incentive plans are common among publicly traded companies. The following Table 3 shows that the majority of all independently-surveyed publicly-traded companies compensate top managers through an equity-based long-term incentive program, such as the LTIP, and 100\% of the Entergy Companies' utility peer group comprising the Philadelphia Electric index, provide this type of equity-based executive incentive program. In addition, the table shows that stock options and other types of equity programs, such as restricted |

stock, continue to be typical retention tools in both the general industry and utility companies. This type of equity-based plan places a greater portion of executive compensation at risk based on corporate performance compared to executive compensation programs that do not have variable pay strategies.

Table 3

Towers Watson's 2009 Long-Term Incentive Plan Survey (as used in the Entergy Companies' 2010 Senior Mgmt Competitive Compensation Analysis)

| LTI Plans
Offered | General Industry | Philadelphia
Electrics | | :-- | :--: | :--: | | Stock
Options | $63\%$ | $44\%$ | | Performance
Plans | $69\%$ | $100\%$ | | Restricted
Stock | $62\%$ | $67\%$ | | Other | $13\%$ | $0\%$ |

Q. HOW DO THE ENTERGY COMPANIES ENSURE THAT THESE LONGTERM INCENTIVES ARE AWARDED AT REASONABLE MARKET LEVELS? A. As I explained earlier, our compensation programs, including the long-term incentives, are benchmarked by an independent external consultant to determine their prevalence and ensure they are both competitive and reasonable by comparing them with the utility industry and general industry.

1. The Test Year Compensation Programs and Costs are Necessary and Reasonable
2. DURING THE TEST YEAR, WERE THE ENTERGY COMPANIES' COMPENSATION PROGRAMS REASONABLE AND NECESSARY? A. Yes. In order to provide services to ETI's customers, it is necessary to maintain an appropriately compensated workforce. Employees of all industries, including utilities, provide services to companies for pay, most often in the form of base pay and incentive compensation. The Entergy Companies' incentive plans are representative of similar plans that are used widely by utilities, the energy services sector, and all industries as an element of variable compensation programs. Further, the Entergy Companies' compensation levels are reasonable as described below.
3. IN PREPARING A BENCHMARK COMPARISON OF COMPENSATION LEVELS, HOW SHOULD ONE DEFINE THE "MARKET LEVEL" OF COMPENSATION?
4. As discussed above, when using a benchmark analysis to compare companies' levels of compensation, it is advisable to view the market level of compensation as a range (e.g., +/- 10\% of a mid-point) rather than a precise, single point. Although benchmarking has its place in compensation analyses, and is used by HR departments and professionals, there are differences in how companies match job responsibilities with job titles and in how companies complete the

compensation survey information. These limitations do not invalidate benchmark comparisons of compensation levels, but they do add an element of imprecision to any comparison of compensation by job title.

Towers Watson provides competitive analysis of the Entergy Companies' executive compensation to the market and support for the Entergy Companies' approach that a value between $90\%$ and $110\%$ of the median level of compensation is "at market." In fact, Towers Watson stated in its 2010 Competitive Compensation Analysis that because of differing job duties, individual characteristics, and experience levels, Towers Watson believes that a company's pay levels are competitive if they fall between $85\%$ and $115\%$ of the marketplace.

Q. WHAT ARE TARGET INCENTIVE COMPENSATION PAYMENTS?

A. Target incentive compensation payments are the percentages of base pay that employees would receive if the performance goals being measured under the incentive plan are achieved at target. The compensation the employee receives depends upon whether actual performance fails to meet the targets, meets targets, or exceeds the targets.

| Mercer
2010/2011
Salary Budget Survey | All For Profit
Industries at
Target | Energy
Industry at
Target | Entergy at
Target | | :-- | :--: | :--: | :--: | | Administrative and Clerical | $5\%$ | $6\%$ | $3.5\%$ | | Technician &; Skilled | $5\%$ | $6\%$ | $3.5\%$ | | Professional | $10\%$ | $10\%$ | $7\%$ | | Middle Management | $20\%$ | $20\%$ | $18\%$ | | Top Management | $40\%$ | $40\%$ | $48\%$ |

| Towers Watson 2010
Executive Database | General
Industries at
Target | Energy Services
Industry at
Target | Entergy at
Target | | :-- | :--: | :--: | :--: | | Middle Management | $25\%$ | $25\%$ | $17\%$ | | Top Management
(Directors) | $35\%$ | $35\%$ | $32\%$ | | Executives (Officers) | $50\%$ | $49\%$ | $48\%$ |

| 1 | Q. | FOR THE TEST YEAR, FOR THE LONG-TERM INCENTIVES, DID THE | | :--: | :--: | :--: | | 2 | | ENTERGY COMPANIES USE REASONABLE TARGETS FOR | | 3 | | ESTABLISHING TARGET INCENTIVE COMPENSATION PAYMENTS? | | 4 | A. | Yes, each year Pay Governance, the nationally recognized compensation | | 5 | | consultant, provides an analysis of the expected value of the Entergy | | 6 | | Companies' long-term incentives. The benchmarked data on the | | 7 | | long-term incentives at market median is presented in the analysis as an | | 8 | | expected dollar amount. This expected dollar amount is then converted | | 9 | | by Pay Governance into target performance units, stock options and | | 10 | | restricted stock. The ML 6 Operational Incentive Plan utilizes the | | 11 | | expected dollar amount as a guide in determining the target cash payout. | | 12 | | It does not need to be converted to a unit. The Board of Directors reviews | | 13 | | this data and, for 2010 and 2011, approved the recommended targets as | | 14 | | the long-term basis for the Entergy Companies' Compensation Model. | | 15 | | | | 16 | Q. | WITH REGARD TO THE RESULTS OF THE LONG-TERM INCENTIVES | | 17 | | FOR THE TEST YEAR, WERE THE ENTERGY COMPANIES' ACTUAL | | 18 | | PERFORMANCE UNIT AWARDS UNDER THE LONG-TERM | | 19 | | INCENTIVE PLAN AND STOCK OPTION PLAN REASONABLE? | | 20 | A. | Yes. As I discussed earlier, the use of equity-based incentive devices in | | 21 | | long-term incentive compensation plans is prevalent among publicly- | | 22 | | traded companies. In addition, as I discussed earlier, the Entergy | | 23 | | Companies intentionally design the long-term incentive plan to provide |

compensation at the market median. To that end, and as described above, the Entergy Companies perform an annual analysis of their target grant levels under the long-term incentive plan to ensure that the target levels of grants are set at the market median. Consequently, the Entergy Companies design the long-term incentive compensation plan to be at market. But as I also discussed earlier, when actual performance exceeds the target level of performance, then the actual awards have the potential to exceed the target level of awards. The converse is true as well: when actual performance is less than the target, then there is the potential that the actual awards will be less than the target level of awards. In fact, the payouts under the Performance Unit Programs in 2010 and 2011 were both below target. Payouts under the Performance Unit Programs were $57\%$ and $10\%$ of target respectively. Additionally, payouts under the ML 6 Operational Incentive Plan were 98\% of target.

Further, the use of equity-based devices in long-term incentive compensation plans is a wide-spread practice among general industry. Again, as I have noted, the Entergy Companies set target compensation at the market median. As with the performance unit awards, the Entergy Companies perform an annual analysis of the target level of stock options and restricted stock that are available for possible award to ensure that the target level is set at the market median. Thus, by design, the level of the stock option and restricted stock awards is at market. Therefore, given that the Entergy Companies structure the target level of stock option

and restricted stock awards to be at market, I conclude that the actual level of stock option and restricted awards for the Test Year is reasonable.

3

Q. WHAT CONCLUSION DO YOU DRAW FROM THIS ANALYSIS OF THE ENTERGY COMPANIES' COMPENSATION VERSUS THE MARKET? market median for individual components and in the aggregate. The design of the compensation program is reasonable and that design yielded a reasonable combination of base pay, annual incentive compensation, and long-term incentive compensation during the Test Year. 6. Commission Precedent Regarding Financially Based Incentive Compensation Q. ARE YOU AWARE OF COMMISSION PRECEDENT THAT HAS DISALLOWED FINANCIALLY BASED INCENTIVE COMPENSATION? A. Yes. I have been informed by counsel that what the Commission has termed financially based incentive compensation has been disallowed in several recent rate cases in Texas.

| 1 | Q. | IS A PORTION OF THE INCENTIVE COMPENSATION REQUESTED BY | | :--: | :--: | :--: | | 2 | | THE COMPANY IN THIS CASE TIED TO ITS PROFITABILITY AND STOCK PRICE? | | 4 | A. | Yes. Based on the methodology used to divide annual incentive pay between financial and operational measures utilized by the utility (and accepted by the Commission Staff) in PUCT Docket Nos. 34800 and 37744, approximately 14.1\% of ESI's annual incentive compensation is tied to financial measures such as profitability and stock price. See | | 8 | | Exhibit KGG-4. In addition, all of the equity-based long-term incentive compensation programs I describe above are tied to such financial | | 11 | | measures. On the other hand, none of the costs of the ML 6 Operational Incentive Plan are tied to financial measures of profitability or stock price. | | 13 | | | | 14 | Q. | IN LIGHT OF THE PRECEDENT YOU DESCRIBE ABOVE, WHY IS ETI REQUESTING RECOVERY OF TEST YEAR COMPENSATION COSTS | | 16 | | RELATED TO FINANCIALLY BASED MEASURES? | | 17 | A. | First, I am informed by counsel that the Commission precedent disaliowing financially based incentives is not required by statute or rulle and that the | | 18 | | Commission retains the authority to chart a different course. The facts and evidence presented are different in each case, and the Commission should continue to consider whether incentive programs, such as the | | 20 | | programs latescribe above, deserve to be divided into its subparts and, in part-disallowed. The operational and financial goals of the Entergy |

| 1 | would tend to demand higher prices or more onerous credit terms, resulting in higher costs that would lead to higher rates than would otherwiseoccur. | | :--: | :--: | | 4 | Additionally, disallowing financial-based performance targets only serves to encourage utilities to eliminate them, and such an approach | | 5 | weakens the alignment of employees' financial interests with the interest of the ratepayers in having an efficiently run and financially healthy utility. | | 8 | Having only operational targets could encourage utilities to overspend in some areas and would result in an incomplete, unbalanced incentive | | 9 | program that would be atypical when compared with American industry in general and does not create a reasonable mix of incentives. | | 10 | Further, to the extent that the total compensation levels are within market range, it should be at the reasonable discretion of the Entergy | | 11 | Companies to determine how best to pay their employees, and it is common practice for a company to emphasize one form of compensation | | 12 | over another form depending on its circumstances. It would not be appropriate to conclude that, for example, all of the compensation paid to | | 13 | ETI employees is reasonable, so long as it is all paid in the form of base salary, but that it becomes unreasonable when that same level is partially | | 14 | paid out in the form of incentive pay. | | 16 | Finally, the Commission should also reconsider its precedent regarding incentive compensation tied to financial performance because | | 17 | increasing company profitability is a legitimate end for public utilities. |

| 1 | Investor-owned utilities are authorized by statute to earn a reasonable return on invested capital, and thus trying to achieve financial targets that support the utility's ability to achieve the authorized return is properly viewed as a legitimate performance goal for a regulated utility. Utilities are allowed and expected to operate at a profit. It is not reasonable to disallow such expenditures as per se unreasonable simply because they are tied to company profitability. | | :--: | :--: | | 8 | | | 9 | C. Benefit Plans | | 10 | 1. Description of the Entergy Companies' Benefit Plans | | 11 | Q. PLEASE DESCRIBE THE BENEFIT PLANS PROVIDED BY THE ENTERGY COMPANIES TO THEIR EMPLOYEES. | | 13 | A. The benefit plans consist of: (1) medical and dental plans; (2) employee disability insurance; (3) employee life insurance as well as accidental death and dismemberment insurance; (4) retirement plans, consisting of both a defined benefit pension plan and a 401(k) Savings Plan; and (5) | | 15 | Executive Retirement Benefit Programs. | | 16 | The costs of providing many of these programs are shared between the Entergy Companies and their employees. The cost sharing allows the Entergy Companies to provide competitive benefits programs to employees while maintaining total compensation costs that were comparable with industry medians. |

Entergy Texas, Inc. Page 34 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 Q. YOU HAVE LISTED FIVE CATEGORIES OF BENEFIT PLANS. PLEASE DESCRIBE THOSE PLANS. 3 A. The following summary describes the various plans offered during the Test Year. ^[10]

5 6 Medical Plan. The Entergy Companies use managed doctor and hospital networks, which reduce claims costs. The BenefitsPlus Medical Plan provides employees and their dependents comprehensive medical coverage. The medical plan offers three Preferred Provider Organization ("PPO") Plans. The PPO has different deductible levels. All three plans are provided through a network of health service providers managed by Aetna. The Entergy Companies and their employees share premium costs under this plan.

Dental Plan. The BenefitsPlus dental plan offers coverage for four types of services: diagnostic and preventive care; basic restorative care; major restorative care; and orthodontics. The plan pays $100\%$ of diagnostic and preventive care, $80\%$ of basic restorative care, and $50\%$ of both major restorative care and orthodontics services. The Entergy Companies and their employees share premium costs under this plan.

Entergy Texas, Inc. Page 35 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 2. Long-Term Disability Benefit Plan The long-term disability program provides a monthly income for eligible employees who become disabled while actively employed by the Entergy Companies. The plan provides either $65\%$ or $40\%$ of the employees' monthly income, depending on the option elected by the employee, and is reduced by any amounts received by the employee from Worker's Compensation, Social Security, and other income benefit sources. The Entergy Companies and their employees share in the cost of this plan. In the past, an employee had the option to decline coverage under the plan and instead apply the Entergy Companies' cost contribution to other benefit plans that the employee selects. As of 2011, employees no longer can decline long-term disability coverage, subject to collective bargaining agreements as applicable.

3. Life Insurance Benefit Plans

The Entergy Companies offer eligible employees choices in Life Insurance and in Accidental Death and Dismemberment Insurance. Benefit levels range from one-half times base pay to four times annual base pay. The Entergy Companies pay the premium for the one-half and one times annual base pay options. For plans that provide greater benefits, the employee pays the additional premium.

In addition to basic employee life coverage, employees may elect Survivor Income Insurance and Dependent Life Insurance. These

programs are provided to allow employees to take advantage of group rates. Employees pay 100 percent of the cost for these programs.

4. Retirement Benefit Plans

The Entergy Companies offers a defined benefit retirement program and a defined contribution savings plan (a 401(k) savings plan).

The defined benefit retirement program provides monthly benefits to retired employees and their contingent annuitants who qualify under the plan(s). The Entergy Companies pay the entire cost of the program.

The 401(k) Savings Plan encourages employees to save regularly for their retirement. During the Test Year, the Entergy Companies matched employee contributions seventy cents per dollar up to the first six percent of eligible earnings.

Other Post Employment Benefits ("OPEB") are benefits, excluding the retirement benefit plans mentioned above, offered to retired employees such as medical, dental, vision, and life insurance coverage. Except for life insurance premiums, the Entergy Companies share the costs of these programs with its retired employees. The Company's treatment of OPEB for ratemaking purposes is addressed by Company witness Considine.

5. Executive Retirement Benefit Programs

The Entergy Companies' executives participate in the same benefit programs in which most non-bargaining employees participate. In addition to participating in the same benefit programs available to other

| 1 | utility industry offer benefit programs. ^[11] | For example, 100\% of the peer | | :--: | :--: | :--: | | 2 | group of utility companies in the survey offered medical benefits, life | | | 3 | insurance benefits, defined contribution savings benefits, short-term | | | 4 | disability benefits and long-term disability benefits to active employees | | | 5 | and $90\%$ offered defined benefit retirement benefits to active employees. | | | 6 | For retirees, $75\%$ offered medical benefits and $70\%$ offered life insurance | | | 7 | benefits. | | | 8 | | | | 9 | Q. | HAVE THE ENTERGY COMPANIES TAKEN ANY STEPS TO REDUCE | | 10 | | THE COST OF THEIR BENEFITS PLANS? | | 11 | A. | Yes. The Entergy Companies have taken action to reduce the rate of | | 12 | | growth in the cost of their benefit plans. In all likelihood, however, benefits | | 13 | | costs will continue to increase, but at a slower rate than would otherwise | | 14 | | be the case without these actions. | | 15 | | The following list provides several examples of actions taken in | | 16 | | recent years to limit the overall cost increases associated with benefits | | 17 | | programs: | | 18 | | - To promote employee welfare, to increase productivity and | | 19 | | reduce sick leave, and to reduce the rate of cost increases | | 20 | | for medical, disability, and life insurance benefit plans, the | | 21 | | Entergy Companies established the Entergy Wellness |

Program. This Program helps employees eat healthier diets, get more exercise, reduce and maintain weight, stop smoking, and otherwise improve and maintain their physical and psychological health.

• Effective January 1, 2007, the Entergy Companies implemented a consumer directed approach to providing medical benefits by introducing: (a) a High Deductible Health Plan ("HDHP") option, which allows eligible employees to deposit pre-tax dollars into a Health Savings Account; and (b) other medical plan options with higher deductible and copayment levels for office visits and prescription drugs.
• Effective as of January 2007, the employee premium costs for the Aetna $\backslash$ 500 $PPOand$ \ $1000$ PPO coverage options are based on the "buy-up" methodology, which means medical plan costs above the cost of the HDHP plan option are paid by the employee.
• In 2011, the Entergy Companies consolidated the Retiree Medical plan options. The $\backslash$ 500$ PPO plan and Managed Choice Plan were eliminated for retirees of the regulated utilities. These retirees now have the same medical plan options as active employees. non-qualified restoration benefit plans and non-qualified supplement benefit plans are common among general industry as surveyed by Towers Watson.

Entergy Texas, Inc. Page 40 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1

• The Entergy Companies continue to outsource the administration of its $401(k)$ savings plan, with attendant cost savings.

In addition, plan costs were monitored on a monthly basis and the costs for providing the various benefit programs were compared against targets in the budget.

7 Q. DURING THE TEST YEAR, WERE THE ENTERGY COMPANIES' BENEFIT PROGRAMS REASONABLE? A. Yes. This is shown in the 2011 Towers Watson BenVal Report, which compares the Entergy Companies with a peer group of twenty utility companies and with a group of Fortune 500 companies from general industry. These comparisons recognize that the Entergy Companies' employees may pursue employment opportunities in either the utility market or general industry, and therefore benefit levels needs to be competitive with both labor markets. These comparisons assisted management in monitoring benefit costs to ensure that the Entergy Companies' benefit programs were reasonable and competitive with the market.

| 1 | Q. | IN COMPARING ONE COMPANY'S BENEFITS VALUES TO THE | | :--: | :--: | :--: | | 2 | | BENEFITS VALUES PROVIDED BY COMPARABLE COMPANIES, HOW | | 3 | | SHOULD ONE DEFINE THE "MARKET LEVEL" OF BENEFITS? | | 4 | A. | As I explained with regard to compensation levels, the market level of benefits values is reasonably viewed as a range of plus or minus 10\% of the median benefit values offered by comparable companies. Market pricing of benefits values is an inexact science. Thus, the market value is defined as a range rather than as a single, specific point. | | 7 | | | | 8 | | | | 9 | Q. | HOW DO THE ENTERGY COMPANIES' BENEFIT VALUES COMPARE | | 11 | | WITH THE BENEFITS VALUES OFFERED BY THE PEER GROUP OF | | 12 | | UTILITY COMPANIES AND WITH GENERAL INDUSTRY (FORTUNE | | 13 | | 500)? | | 14 | A. | Based upon the 2011 BenVal Report, the value of the Entergy Companies' total benefit program was at market when compared with the total value of benefit programs offered by the peer group of utility companies of similar revenue size. As shown on the following Table 6, the Entergy Companies' total benefit value versus the utility peer group was 101\% for 2011. The Entergy Companies' total benefit program was slightly higher than market when compared with the total value of benefit programs offered by general industry (Fortune 500). As shown on Table 6, the Entergy Companies' total benefit value versus the Fortune 500 companies was 114\% for 2011. |

Table 6

Entergy Companies

2011 Values of Benefit Plans Compared With Peer Group of Utility Companies and General Industry (Fortune 500)

| Benefit Plans | Entergy
Companies
Compared
With
Fortune 500
Companies | Entergy
Companies
Compared
With Peer
Group of
Utility
Companies | | :--: | :--: | :--: | | Defined Benefit &; Defined Contribution Plans | 2011 | 2011 | | Retirement &; Savings Plans Combined | $140\%$ | $103\%$ | | Health &; Welfare Plans (Active Only) Life Insurance | $84\%$ | $103\%$ | | Medical | $95\%$ | $93\%$ | | Dental | $107\%$ | $94\%$ | | Short &; Long Term Disability Combined | $101\%$ | $98\%$ | | Entire Benefit Program (Active and Retiree Combined) | $114\%$ | $101\%$ |

While individual components of their benefits programs may be higher or lower than market median, the Entergy Companies design their programs to be at market median for the overall package of benefits.

2 Q. DO THE ENTERGY COMPANIES PROVIDE THEIR EMPLOYEES WITH 3 PAID TIME OFF? 4 A. Yes. All of the utility companies surveyed by the Towers Watson 2011 5 BenVal Report offered paid time off. ^[12] 6 My Exhibit KGG-6 shows a representative group of the Entergy 7 Companies' policies that provide paid time off to employees. These paid 8 time off policies are: Absenteeism; Short-term Disability; Military Leaves 9 of Absence; Holidays; and Vacation. These policies are described in the 10 following list:

• Absenteeism Permits 40 hours of paid time off a year for compelling reasons, e.g., employee illness or spouse, child, or parent illness.
• Short-term Disability Permits paid time off, based on years of employee service, for more than 40 consecutive hours of personal illness.
• Military Leaves Permits pay differential and the continuation of of Absence benefits in the case of emergency active duty.
• Holidays
• We Permits 10 paid holidays per year to ESI and ETI employees.
• Vacation Permits vacation, based on years of employment service, up to five weeks per year.

Entergy Texas, Inc. Page 44 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 Q. HOW ARE THE COSTS OF THE ENTERGY COMPANIES' PAID TIME 2 OFF POLICIES REFLECTED IN TEST YEAR COSTS? A. There is no explicit charge for paid time off. Instead, the costs for paid time off are subsumed within base pay.

5 Q. FOR THE TEST YEAR, WERE THE COSTS OF THE PAID TIME OFF POLICIES INCLUDED WITHIN BASE PAY REASONABLE?

8 A. Yes. As I demonstrated earlier, the total annual compensation (base pay plus annual incentive compensation) during the Test Year was reasonable. Given that the costs of paid time off are subsumed within the base pay component of total annual compensation, the costs of the paid time off policies during the Test Year were reasonable as well. In addition, the 2011 BenVal Report shows that the Entergy Companies' vacation and holiday policies are reasonable because they are valued at $90\%$ of the market versus the peer group and at $93\%$ of the market versus the Fortune 500 group (please see Exhibit KGG-5). ^[13]

Entergy Texas, Inc. Page 45 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 Q. DO THE ENTERGY COMPANIES HAVE RELOCATION ASSISTANCE 2 POLICIES? A. Yes. In order to be competitive in the employment market, it is necessary to provide relocation assistance to certain categories of employees. The Entergy Companies' relocation policies are summarized in the following Table 7:

Table 7

Summary of Relocation Policies

| Policy | | Eligibility | | :--: | :--: | :--: | | - Relocation Assistance Policy for
Entry-Level New Hires | Offered to newly-hired, entry-level,
exempt employees | | | - Relocation Assistance Policy for
Mid-Level New Hires | Offered to newly-hired, mid-level,
exempt employees | | | - Relocation Assistance Policy for
Exempt Internal Transfers &; High
Level New Hires | Offered to internal exempt
employees and newly-hired, high
level, exempt employees | |

7 8 Q. ARE THE ENTERGY COMPANIES' RELOCATION ASSISTANCE 9 POLICIES AND COSTS REASONABLE? 10 A. Yes. Based upon my professional experience and knowledge of recruitment and personnel practices, the Entergy Companies' relocation assistance policies are consistent with general industry practice. Without these programs, the total package of compensation and benefits would be less competitive. In addition, the Entergy Companies' average relocation

| 1 | Q. | HOW ARE ESI'S BENEFITS AND COMPENSATION EXPENSES | | :--: | :--: | :--: | | 2 | | CHARGED TO ETI? | | 3 | A. | ESI employees are responsible for recording their time to project codes | | 4 | | that are representative of the services being provided. Each ESI project | | 5 | | code is assigned one billing method which determines which of the | | 6 | | Entergy Companies will be billed for the labor charges. Payroll-related | | 7 | | costs such as payroll taxes, employee benefits, certain employee | | 8 | | compensation, and paid time off are loaded to the projects that each | | 9 | | individual charges so that each project is fully-loaded with both the direct | | 10 | | costs assigned to the project as well as ESI's payroll-related overhead | | 11 | | costs. Company witness Tumminello discusses the Payroll Loader and | | 12 | | Allocation processes in her testimony. | | 13 | | V. AFFILIATE EXPENSES FOR THE HUMAN RESOURCES CLASS | | 15 | | A. Summary of Affiliate Expenses for the HR Class | | 16 | Q. | WHICH AFFILIATE CLASS DO YOU SPONSOR? | | 17 | A. | I sponsor the HR Class of affiliate services and expenses. | | 18 | | | | 19 | Q. | WHERE DOES THE HR CLASS FIT INTO THE OVERALL AFFILIATE | | 20 | | STRUCTURE? | | 21 | A. | My Exhibit KGG-7 is a diagram that displays the two affiliate families and | | 22 | | the functions within each family providing services to ETI. The HR Class |

1 is found within the Corporate Support family, under the Human Resources 2 &; Administration function.

3 Q. EARLIER IN YOUR TESTIMONY YOU DISCUSSED THE ENTERGY

5 COMPANIES' BENEFITS AND COMPENSATION PROGRAMS AND 6 COSTS. HOW DOES THAT EARLIER TESTIMONY RELATE TO YOUR 7 DISCUSSION HERE ABOUT THE HR CLASS? 8 A. In this section of my testimony, I discuss the costs specifically associated 9 with the HR Class described below. Earlier in my testimony (Section IV), I 10 demonstrated that the compensation rates and benefits programs for the 11 Entergy Companies' employees are necessary and the costs of those 12 programs are reasonable.

13 Q. WHAT HR SERVICES DOES THE HR CLASS PROVIDE? 15 A. The HR department provides the following seven sub-functions for the 16 Entergy Companies:

17

• Total Rewards;

18

• Network Operations;

19

• Labor Relations/HR Support;
• Talent Management and Inclusion;

20

• HR Compliance;

21

• Field HR Groups; and

Entergy Texas, Inc. Page 49 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1

• Other HR&;A (Human Resources &; Administration)

2 Management. 3 These sub-functions are described later in my testimony.

4 Q. ARE THERE ANY COSTS, OTHER THAN THE COSTS ASSOCIATED WITH THE SEVEN HR SUB-FUNCTIONS LISTED ABOVE, THAT ARE INCLUDED IN THE HR CLASS?

8 A. Yes. The other predominant costs for the HR Class include the costs (or credits) of the long-term incentives, pensions, OPEB, and executive retirement benefit programs.

11 Q. WHAT IS THE TOTAL ETI ADJUSTED AMOUNT FOR THE HR CLASS OF SERVICES?

14 A. The total ETI adjusted amount for this class of services is $\backslash$ 9,365,982$. The following Table 8 summarizes the following information for the HR Class:

Total Billings

Total ETI Adjusted

Amount

\% Direct Billed \% Allocated

Dollar amount of total Test Year billings from ESI to all Entergy companies, plus the dollar amount of all other affiliate charges that originated from any Entergy company. This is the amount from Column (C) of the cost exhibits KGG-A, KGG-B, and KGG-C.

The percentage of the ETI adjusted Test Year amount that was allocated to ETI.

Table 9

| | | Total ETI Adjusted | | | | :-- | :-- | :--: | :--: | :--: | | Class | Total Billings | Amount | \% Direct
Billed | \% Allocated | | HR | $\backslash$ 126,624,423 $|$ \ $9,365,982$ | $17.9\%$ | $82.1\%$ |

1 2 Q. PLEASE DESCRIBE THE EXHIBITS THAT SUPPORT THE 3 INFORMATION REFLECTED IN TABLE 9. 4 A. Attached to my testimony are exhibits showing the calculation of the total 5 ETI adjusted amount for the HR Class. In my Exhibit KGG-A, the 6 information is shown broken down by the departments comprising the class. My Exhibit KGG-B shows the same information broken down by

| 1 | project code and the billing method assigned to each project code. My | | :--: | :--: | | 2 | Exhibit KGG-C shows the information by class, department, project code, | | 3 | and billing method. For each exhibit, the amounts in the columns | | 4 | represent the following information: | | Column (A) -
Support | Dollar amount of total Test Year billings and charges from ESI to all Entergy Business Units, plus the dollar amount of all other affiliate charges to ETI that originated from any Entergy Business Unit. | | Column (B) -
Service Company
Recipient | Dollar amount that was included in the service company recipient allocation. Service company recipient charges are the cost of services that ESI provides to itself, which in turn are charged to affiliates that receive those services. The service company recipient allocation process is described in the testimony of Company witness Tumminello. | | Column (C) -
Total | Represents the sum of Columns (A) and (B). | | Column (D) -
All Other Business Units | That portion of Column (C) that was billed and charged to Business Units other than ETI. | | Column (E) -
ETI Per Books | Represents the difference between Columns (C) and (D). | | Column (F) -
Exclusions | Represents amounts that are excluded from ETI electric cost of service. The exclusions are described in the testimony of Company witness Tumminello. | | Column (G) -
Pro Forma Amount | Pro Forma Amounts include adjustments for known and measurable changes, and corrections. | | Column (H) -
Total ETI Adjusted | ETI adjusted amount requested for recovery in this case for this class (Column (E) plus Columns (F) and (G)). |

Entergy Texas, Inc. Page 52 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 In her direct testimony, Company witness Tumminello describes the calculations that take the dollars of support services in Column A to the

3 Total ETI Adjusted numbers shown on Column H.

4

5 Q. ARE THERE ANY PRO FORMA ADJUSTMENTS TO THIS CLASS? 6 A. Yes. The pro forma adjustments for the HR Class are shown on Exhibit 7 KGG-D, which also indicates the Company witnesses who sponsor those pro forma adjustments.

9 10 Q. WHAT ARE THE MAJOR COST COMPONENTS OF THE CHARGES FOR THE HR CLASS?

12 A. As shown on Exhibit KGG-A, the total ETI adjusted amount for the HR 13 Class during the Test Year was $\backslash$ 9,365,982$. The major cost components of those charges are as follows:

Table 10

| Cost Component | $\backslash$ $|$ \%$ of Total | | :-- | --: | --: | | Payroll &; Employee Benefits | $\backslash$ 9,067,246 $|$ 96.8 \%$ | | Service Company Recipient | $\backslash$ 126,292 $|$ 1.3 \%$ | | Outside Services | $\backslash$ 89,393 $|$ 1.0 \%$ | | Office and Employee Expenses | $\backslash$ 73,746 $|$ 0.8 \%$ | | Other | $\backslash$ 9,305 $|$ 0.1 \%$ | | | $\backslash$ 9,365,982 $|$ 100.0 \%$ |

| 1 | Q. | WHAT IS THE SIGNIFICANCE OF THESE COST CATEGORIES? | | :--: | :--: | :--: | | 2 | A. | Cost components provide a second way of viewing the charges for the HR | | 3 | | Class. As Table 10 shows, 96.8\% of the costs are labor costs. I have | | 4 | | already discussed the reasonableness and necessity of the Entergy | | 5 | | Companies' compensation and benefits costs. Other ETI witnesses | | 6 | | provide support for the other cost categories in Table 10 and, thus, | | 7 | | indirectly help to support the charges for the HR class. In addition to the | | 8 | | labor costs, $1.3\%$ of the costs are service company recipient costs, which | | 9 | | are for services that ESI provides to itself, which in turn are billed to the | | 10 | | affiliates that receive ESI services. Company witness Tumminello | | 11 | | explains the service company recipient billing process. Two other cost | | 12 | | components are outside services and office and employee expenses, at | | 13 | | $1.0\%$ and $0.8\%$ respectively. | | 14 | | | | 15 | Q. | WHAT PORTION OF THE TOTAL ETI ADJUSTED AMOUNT RELATES | | 16 | | TO THE SEVEN HR SUB-FUNCTIONS YOU LISTED ABOVE? | | 17 | A. | Of the $\backslash$ 9,365,982$ that is the Total ETI Adjusted Amount for the HR Class, | | 18 | | $\backslash$ 1,229,121$ is related to the seven HR sub-functions I listed above. The | | 19 | | remainder is related to the other programs I described above that are | | 20 | | included in the HR Class, including the long-term incentives, pensions, | | 21 | | OPEB, and executive retirement benefit programs. |

1 Q. WHAT IS THE BREAKDOWN OF THE REQUESTED COSTS AMONG THE SEVEN SPECIFIC HR SUB-FUNCTIONS YOU LISTED ABOVE? A. The following table provides a breakdown of the requested costs among the seven HR sub-functions, which I describe in more detail later in my testimony:

Table 11

| SUB-FUNCTION | COST \$ | | :-- | :--: | | Field HR Groups (excluding nuclear) | $\backslash$ 505,593$ | | Total Rewards | $\backslash$ 214,147$ | | Talent Management and Inclusion | $\backslash$ 207,998$ | | Network Operations | $\backslash$ 99,023$ | | Other HR&;A Management | $\backslash$ 95,555$ | | Labor Relations/HR Support | $\backslash$ 56,094$ | | HR Compliance | $\backslash$ 50,710$ | | TOTAL for the HR CLASS | $\mathbf{\backslash }$ 1 , 2 2 9 , 1 2 1}$ |

6

7 B. The HR Class Provides Necessary Services

8 Q. ARE THE HR SERVICES PROVIDED BY THE HR CLASS 9 NECESSARY?

10 A. Yes. HR services are among the most critical functions in business. 11 Without this function, ETI would be unable to provide service to customers. Unless it has a skilled and motivated workforce, no business

can succeed. HR management is the business function that focuses on the effective management, direction, and use of employees. The HR department, along with line management, is responsible for activities such as recruiting, selecting, assigning, motivating, compensating, training, developing, and promoting the employees of the Entergy Companies, including ETI and ESI.

The HR department is responsible for handling a large number of employment and personnel issues such as:

• cultural and workforce demographic changes;
• improving productivity;
• implementing effective compensation, benefits, and rewards systems;
• ensuring employee participation in organizational decision-making;
• controlling health care costs;
• developing and retaining employee loyalty to customers and to the Entergy Companies;
• maintaining and managing a racial, ethnic, and gender diverse workforce; and
• managing complex legal and regulatory issues related to employment and labor law compliance and litigation.

21 22 Q. WHAT ARE SOME OF THE SPECIFIC SERVICES THAT THE HR CLASS PROVIDES TO ETI?

24 A. The HR services provided to ETI by these classes can be grouped into major activities. On a daily basis, HR employees are involved in

| 1 | - Total Rewards | | :--: | :--: | | 2 | The Total Rewards group provides: | | 3 | - compensation plan design: develop compensation strategies; develop pay plans; consult on incentive plan | | 4 | development; | | 5 | - compensation plan analysis: research compensation trends; compare compensation and incentive plans to other peer | | 6 | companies; consult on compensation issues; analyze | | 7 | internal compensation equity; | | 8 | - plan administration: administer management stock option, incentive, and merit processes; develop market reference | | 9 | data; interpret rules governing compensation plans; | | 10 | - benefit plan design: develop benefit strategies; develop pricing for benefit programs; evaluate vendor bids; monitor | | 11 | compliance of benefits plans with laws and regulations; | | 12 | - benefit plan analysis: evaluate current plan design against the plans of other employers; research benefit trends; | | 13 | consult on benefit issues; analyze benefit costs; and | | 14 | - benefit plan administration: administer compliance activities for all benefit programs; interpret rules governing benefit | | 15 | programs. | | 16 | - Talent Management and Inclusion | | 17 | System Staffing provides support for identifying, recruiting, and | | 18 | selecting candidates to fill vacant positions. This support includes: | | 20 | developing recruitment strategies; supporting the School Relations | | 21 | Program; administering the job posting process; administering applicant | | 22 | testing; and maintaining records on applicants and new hires. | | 23 | Inclusion and Leadership Planning provides employee training to | | 24 | support an inclusive work environment. In addition, this group provides support to the various Diversity Councils as well as provides reports and |

consulting regarding the diversity of the Entergy Companies' workforce. This group also supports management in identifying candidates for leadership positions through the development and administration of the succession planning process.

Employee Development provides employee and leadership training and development opportunities and performance management processes to most employees within all business units. Employee and leadership training and development activities range from new employee orientation to programs focused on enhancing upper management's leadership skills. In this role, the Employee Development group works with employees and management throughout the Entergy Companies to analyze and provide training and development solutions.

Exhibit KGG-8 contains the lists of formal training programs and computer-based training courses available to all employees for 2010 and 2011. I am also providing a copy of the Educational Reimbursement Program policies in place during the Test Year, which outline the eligibility requirements and the process to participate in the Program. See Exhibit KGG-9.

• Network Operations

Network Operations through the HR Service Center administers new hire orientation, merit support, mass mailings, administrative support to computer applications, records management, the interactive voice response system, service awards, benefits billing support, flexible

spending account data, and processing of family status changes. In addition, the HR Service Center provides employees and managers with information about the Entergy Companies' HR policies and answers inquiries about those policies.

• Other HR&;A Management

This function covers general and miscellaneous activities necessary to the management and operation of the HR&;A department. The HR&;A department encompasses the HR functions that I discuss as well as the administration functions discussed by Company witness Thomas C. Plauché.

• Labor Relations/HR Support

The Labor Relations/HR Support group ensures employment policies and practices comply with the applicable labor laws and supports the subsidiaries in ensuring that their employees act within these laws. These activities include: training employees and supervisors regarding applicable federal and state regulations; preparing affirmative action plans and research; participating in Office of Federal Contract Compliance Programs audits; and participating in Equal Employment Opportunity Commission compliance activities.

This group supports the negotiation and administration of labor agreements by providing labor related consulting and assisting in preparing for and negotiating labor contracts.

Entergy Texas, Inc. Page 60 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

- HR Compliance

The HR Compliance group assists HR management and employees with implementing and administering HR risk management activities and process controls. This support includes activities such as: documenting processes; identifying risks and developing effective control mechanisms to minimize them; working with the Entergy Companies' vendors to help them minimize errors and maximize data quality; and managing HR&;A's Sarbanes-Oxley certification process.

Q. ARE ANY OF THE HR SERVICES PROVIDED BY THE HR CLASS

DUPLICATED ANYWHERE ELSE IN ESI OR IN ANY OTHER OF THE ENTERGY COMPANIES?

No. The HR department is organized on the principle of maintaining centralized policies and management over personnel issues throughout the Entergy Companies.

DO ETI RATEPAYERS BENEFIT FROM THE HR CLASS OF SERVICES? A. Yes. ETI ratepayers benefit from the services provided by the HR Class because effective HR programs have a direct effect upon ETI's and ESI's ability to obtain and maintain an efficient, productive, and effective workforce. The HR services provided by this class are designed to attract, develop, and retain top-talented and highly productive employees. The

1 HR policies and programs supported by this class are instrumental in achieving this goal. Q. PLEASE DESCRIBE THE LONG-TERM INCENTIVES COSTS INCLUDED IN THE TOTAL ETI ADJUSTED AMOUNT. A. I describe the long-term incentives in Section IV.B of my testimony above. For the reasons described in Section IV.B above, these costs are reasonable and necessary. Q. PLEASE DESCRIBE THE PENSIONS, OPEB, AND EXECUTIVE RETIREMENT BENEFIT PROGRAMS COSTS INCLUDED IN THE TOTAL ETI ADJUSTED AMOUNT. A. The Entergy Companies' pensions, OPEB, and executive retirement benefit programs are described in Section IV.C. 1 of my testimony above. The costs included in the HR Class of costs include interest, expected return on plan assets, amortization of transition obligations (OPEB and executive retirement benefit programs only), amortization of prior service cost, and amortization of gains and losses. For the reasons described in Section IV.C.1, the costs of these programs are reasonable and necessary.

2 Q. ARE THE COSTS OF THE HR CLASS OF SERVICES REASONABLE? A. Yes. The costs for the HR class of services are reasonable. By having a central HR department establishing and administering key HR policy and management functions while also having field groups that provide more tailored service to the business units, the Entergy Companies are able to operate more efficiently through economies of scale than would otherwise be the case. Charges incurred for administration of the various HR programs are minimized within the Entergy Companies by the creation of one corporate department rather than each legal entity having a separate department, with separate programs. ETI's HR services can be provided with less equivalent employees and without duplication of expertise. ETI also gets the benefit of buying major items, such as its benefit programs, as part of a larger group. Another example is that the expense of developing infrastructure, such as the HR Service Center, is shared, allowing ETI to pay only a portion of the cost.

1. Objective Evidence Q. IS THERE ANY OBJECTIVE EVIDENCE THAT SUPPORTS YOUR OPINION THAT THE COSTS OF THE HR CLASS IS REASONABLE? A. Yes. The HR department regularly assesses its performance as part of its management and planning processes. The most recent benchmark was produced by the Saratoga Institute and published in 2011 for calendar

year 2010. A summary of the results is provided in Exhibit KGG-10. The Saratoga Institute specializes in providing managers with data to assess how personnel and compensation practices contribute to a business's operations.

Q. WHAT IS YOUR CONCLUSION FROM THE SARATOGA INSTITUTE BENCHMARKING STUDY?

A. The HR department's costs are reasonable. As demonstrated in Exhibit KGG-10, the Entergy Companies' HR Headcount Ratio, which is the total employee headcount divided by the total HR department employee headcount, is higher than the median (again, median being the 50\% percentile) for utility companies and for all companies surveyed, and about the same as the median for companies of the Entergy Companies' collective size ( 10,000 to 25,000 employees). For this survey, a higher number indicates greater efficiency. The Entergy Companies' HR Headcount Ratio is 101, versus Headcount Ratios for the median for utility companies of 88 , for all companies surveyed of 90 , and for companies of the Entergy Companies' size of 102. Thus, the Entergy Companies' HR Headcount is $13\%$ better than the median of the utility companies, $11\%$ better than the median of all companies surveyed, and about the same as median for companies of the Entergy Companies' size. This indicates that the Entergy Companies' HR department is operating with fewer employees than are other companies.

This exhibit also shows that the Entergy Companies' HR cost per employee is at the median for the utility industry and for all companies surveyed. For 2010, the Entergy Companies' cost per employee is \ $1,548ascomparedwiththemedianforutilitycompaniesof$ \ $1,548$ , and for all companies surveyed of $\backslash$ 1,495$. Therefore, the Entergy Companies' expenditure per employee is the same as the median of the utility companies and about the same as the median for all companies surveyed.

8 Q. IS THERE ANY MORE GENERAL BENCHMARKING SUPPORT IN THE COMPANY'S FILING? A. Yes. Although it does not apply explicitly to my class, Company witnesses Jeanne J. Kenney and Stephanie B. Tumminello address benchmarking studies that apply to ETI's costs, which include the cost of HR services. Ms. Kenney addresses benchmarking applicable to ETI total company costs, and Ms. Tumminello addresses benchmarking that applies at the service company (ESI) level.

17 18 Q. DOES THE HR DEPARTMENT HAVE A BUDGETING PROCESS TO CONTROL COSTS? A. Yes. Initial proposed budgets are developed at the manager level within each HR sub-function. Potential budget increases or decreases due to changes in business plans are incorporated into the proposed budgets. A

consolidated draft budget is prepared, including a comparison to the HR functional spending target and recommendations of items for further review. Following a series of budget reviews, a level of funding is determined for each department in the HR organization that enables HR to meet its functional spending target. Each department manager prepares a detailed budget based on the approved funding level which is then entered into the budget system. Company witness Donna S. Doucet also discusses the Entergy Companies' budgeting process.

Q. DURING A FISCAL YEAR, DOES THE HR DEPARTMENT MONITOR ITS ACTUAL EXPENDITURES VERSUS ITS BUDGET? A. Yes. Reports are distributed to department management and meetings are held to review actual and budgeted spending on a monthly and year-to-date basis. Spending performance relative to budget is also reviewed and discussed at departmental staff meetings. Variance reports are reviewed monthly and appropriate actions are taken if errors are discovered or actual expenses are greater than budgeted amounts. Major spending variances to budget are investigated and presented to senior management. The HR department also manages its budget on a daily basis. HR department managers and directors review all expense reports and invoices submitted for payment by their employees in their respective organizations. Company witness Doucet also discusses the Entergy Companies' cost reporting and monitoring process.

Entergy Texas, Inc. Page 66 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 Q. ARE HR DEPARTMENT EMPLOYEES HELD ACCOUNTABLE FOR DEVIATIONS FROM THE BUDGET? A. Yes. Each department manager is held accountable for his or her department's budget and must explain variances between actual charges and budgeted amounts. Employees' performance objectives include goals for compliance with budgets and control of expenditures.

7

8 Q. PLEASE DISCUSS RECENT TRENDS IN ACTUAL ETI COSTS INCURRED WITHIN THE HR CLASS. A. Total affiliate O&;M charges to ETI for each of the past three calendar years and the Test Year for this class of services are shown in Table 12 below. These charges have been adjusted to remove costs billed to ETI from nuclear, gas, and "spin off" department codes. Charges to ETI from these departments have also been removed from ETI's Test Year cost of service.

Table 12 (Excludes pro forma adjustments)

| Class | 2008
(\$000s) | 2009
(\$000s) | 2010
(\$000s) | Test Year
(\$000s) | | :-- | :--: | :--: | :--: | :--: | | HR | $\backslash$ 9,836 $|$ \ $9,030$ | $\backslash$ 10,541 $|$ \ $9,497$ |

1 Q. WHAT EXPLAINS THE VARIATIONS IN THE COSTS FROM YEAR TO YEAR FOR THE HR CLASS? 3 A. The majority ( $87\%$ ) of the costs for the HR Class are for the long-term incentives, executive equity awards, pension and OPEB. The primary drivers for the cost trend are long-term incentives and equity awards. These costs are impacted by Entergy Corporation's stock price and total shareholder return, which can fluctuate.

8

9 Q. PLEASE PROVIDE THE STAFFING LEVELS FOR THE HR DEPARTMENT FOR 2008-2010 AND THE TEST YEAR. 12 A. The following table shows, as of December 31st for each of the past three years and as of June ${30}^{\text{th}}$ for the Test Year, the staffing levels for the HR Department:

Table 13

| | $\underset{―}{2008}$ | $\underset{―}{2009}$ | $\underset{―}{2010}$ | Test Year | | :-- | :--: | :--: | :--: | :--: | | HR Dept | 102 | 98 | 111 | 119 |

15 16 Q. WHAT ARE THE REASONS FOR THIS TREND? 17 A. Over the past several years, the HR department has been adding staff to help with increasingly complex regulatory and legislative requirements associated with employment matters such as healthcare and pensions.

This included staff to educate employees about these benefits and encourage healthy lifestyles.

5. Cost Control and Process Improvement Initiatives

Q. SEPARATE FROM THE BUDGETING PLANNING PROCESS, DOES

6

THE HR DEPARTMENT TAKE ANY STEPS TO CONTROL ITS COSTS OR TO IMPROVE ITS SERVICES?

A. Yes. The HR department has outsourced many of the administrative functions supporting the Entergy Companies' benefits programs. Some of the functions outsourced include $401(k)$ and pension services, stock option administration, and medical claims processing. The HR department periodically re-bids various contracts for outsourced services to ensure that the Entergy Companies are receiving competitive prices from their suppliers.

In regard to the costs of the benefits programs themselves that the HR department administers, the department continues to look for ways to decrease benefits costs, such as promoting consumer-driven healthcare, reviewing benefit levels, implementing the Entergy Wellness Program, and the measures I described in Section IV.

ENtergy Texas, Inc. Page 69 of 77 Direct Testimony of Kevin G. Gardner 2011 Rate Case

1 D. The "Not Higher Than" and "At Cost" Standards 2 Q. FOR THOSE COSTS THAT ESI BILLS (EITHER DIRECTLY OR 3 THROUGH USE OF AN ALLOCATION) TO ETI FOR THE HR CLASS OF 4 SERVICES, DOES ETI PAY ANY MORE FOR THE SAME OR SIMILAR 5 SERVICES THAN DOES ANY OTHER AFFILIATE? 6 A. No. The price charged to ETI is no higher than the price charged to the 7 other affiliates. The costs billed for particular services are the actual costs 8 that ESI incurred for providing those services to ETI. As detailed below, 9 allocation methods are uniformly applied to each project code and are 10 rationally selected to link to cost drivers.

11 12 E. Billing Allocation Methodology 13 Q. PLEASE DISTINGUISH BETWEEN COSTS THAT ARE "DIRECT"

14 BILLED VERSUS COSTS THAT ARE "ALLOCATED." 15 A. Whenever appropriate, costs are direct billed to ETI and other affiliates. 16 This means the services provided (and associated costs) are caused by, 17 and benefit, only ETI or whatever entity is the sole cause of the services 18 and associated costs. Only when costs are incurred that are caused by 19 ETI and one or more of the other Entergy Companies are such costs billed 20 by ESI to ETI using an allocation method.

1 Q. HOW ARE THE COSTS RELATED TO THE SEVEN HR SUB-

2 FUNCTIONS BILLED TO ETI?

3 A. Approximately $93\%$ of the costs related to the seven HR sub-functions ^[14] were billed using one of the following six billing methods:

Table 14

| Billing Method | \% of Total ETI
Adjusted | \$ of Total ETI
Adjusted | | :-- | :--: | :--: | | EMPLOYAL | $50\%$ | $\backslash$ 612,796$ | | EMPLFRAN | $19\%$ | $\backslash$ 236,184$ | | DIRECTTX | $10\%$ | $\backslash$ 120,321$ | | EMPLOREG | $6\%$ | $\backslash$ 73,987$ | | EMPLOCSS | $4\%$ | $\backslash$ 53,035$ | | EMPLPRES | $4\%$ | $\backslash$ 50,683$ |

5 Q. WHY IS BILLING METHOD EMPLOYAL APPROPRIATE TO USE FOR 6 THESE COSTS? 7 A. For the project codes assigned this billing method, the cost driver is the 8 number of full and part-time employees corporate-wide. For example, 9 project code F3PCHRSALL (HR Services - All Companies) assigns costs 10 using billing method EMPLOYAL. This project code captures and 11 manages costs associated with providing HR services to all Entergy

| 1 | Companies. The cost of the services provided by project code | | :--: | :--: | | 2 | F3PCHRSALL is driven by the number of employees. The billing method | | 3 | that reflects this cost driver is EMPLOYAL - Number of Full and Part-Time | | 4 | Employees. For the project codes that assign costs based upon this | | 5 | billing method, the unit amounts billed to ETI as a result of the application | | 6 | of this billing method are no higher than the unit amounts billed to other | | 7 | affiliates for the same or similar service and represent the actual costs of | | 8 | the services. | | 9 | | | 10 | WUY IS BILLING METHOD EMPLFRAN APPROPRIATE TO USE FOR | | 11 | THESE COSTS? | | 12 | For the project codes assigned this billing method, the cost driver is the | | 13 | number of full and part-time employees in the franchise operation support | | 14 | function. For example, project code F3PCHRDCSS (HR - Franchise | | 15 | Opns (Dist) Supt - All) assigns costs using billing method EMPLFRAN - | | 16 | Employees Franchise Operations. This project code is used to capture | | 17 | costs for HR services provided for the benefit of the franchise function. | | 18 | The cost of the services provided by project code F3PCHRDCSS is tied to | | 19 | the number of employees in the franchise operation support function. | | 20 | Thus, billing method EMPLFRAN is appropriate because it allocates costs | | 21 | based upon the number of full and part-time employees in the franchise | | 22 | support function. For the project codes that assign costs based upon this | | 23 | billing method, the unit amounts billed to ETI as a result of the application |

of this billing method are no higher than the unit amounts billed to other affiliates for the same or similar service and represent the actual costs of the services.

Q. WHY IS BILLING METHOD DIRECTTX APPROPRIATE TO USE FOR THESE COSTS?

7 A. Billing method DIRECTTX indicates that the work is being billed directly to ETI (that is, 100 percent of the charges go to ETI). When ESI establishes a project code to perform work being done only for ETI, the project code is assigned billing method DIRECTTX. For the project codes assigned a company specific billing method (such as billing method DIRECTTX), the cost driver is the company that is billed. For example, project code F3PCHRFEGT (HR - EGSI (TX)) uses direct billing method DIRECTTX. The costs of project code F3PCHRFEGT are driven by the services specifically for ETI. The billing method that reflects this cost driver is DIRECTTX - 100 percent billing to ETI.

18 Q. WHY IS BILLING METHOD EMPLOREG APPROPRIATE TO USE FOR THESE COSTS?

20 A. For the project codes assigned this billing method, the cost driver is based on the number of full and part-time employees at period end for Entergy's regulated companies (the regulated utilities such as the EOCs, as well as the ESI and EOI service companies). For example, project code

| 1 | F3PCHRSREG (HR Services - Regulated Companies) assigns costs | | :--: | :--: | | 2 | using billing method EMPLOREG - Full and Part-Time Employees - | | 3 | Regulated Companies. This project code is used to capture costs | | 4 | associated with providing HR services for Entergy's regulated companies. | | 5 | Services provided under this project code are driven by the number of | | 6 | employees at Entergy's regulated companies. Therefore, billing method | | 7 | EMPLOREG, which allocates these costs based upon the number of full | | 8 | and part-time employees of Entergy's regulated companies, is the most | | 9 | appropriate. For the project codes that assign costs based upon this | | 10 | billing method, the unit amounts billed to ETI as a result of the application | | 11 | of this billing method are no higher than the unit amounts billed to other | | 12 | affiliates for the same or similar service and represent the actual costs of | | 13 | the services. | | 14 | | | 15 | Q. WHY IS BILLING METHOD EMPLOCSS APPROPRIATE TO USE FOR | | 16 | THESE COSTS? | | 17 | A. For the project codes assigned this billing method, the cost driver is based | | 18 | on the number of full and part-time employees within Customer Support | | 19 | Service. For example, project code F3PCHRCALL (HR) assigns costs | | 20 | using billing method EMPLOCSS - Employees Customer Support | | 21 | Services. This project code is used to capture costs associated with | | 22 | providing HR services for the Entergy Companies' customer service | | 23 | support function. Services provided under this project code are driven by |

| 1 | the number of employees at the Entergy Customers' customer support | | :--: | :--: | | 2 | functions. Therefore, billing method EMPLOCSS, which allocates these | | 3 | costs based upon the number of full and part-time employees of the | | 4 | Entergy Companies' customer support function, is the most appropriate. | | 5 | For the project codes that assign costs based upon this billing method, the | | 6 | unit amounts billed to ETI as a result of the application of this billing | | 7 | method are no higher than the unit amounts billed to other affiliates for the | | 8 | same or similar service and represent the actual costs of the services. | | 9 | | | 10 | WHY IS BILLING METHOD EMPLPRES APPROPRIATE TO USE FOR | | 11 | THESE COSTS? | | 12 | For the project codes assigned this billing method, the costs are driven by | | 13 | the number of full and part-time employees in the state president/CEO | | 14 | function for Entergy's regulated utilities. For example, project code | | 15 | F3PCHRPRES (HR/CEO) assigns costs using billing method | | 16 | EMPLPRES - Employees - State President. This project code is used to | | 17 | capture costs associated with providing HR services for the state | | 18 | president/CEO functions for Entergy's regulated utilities. Services | | 19 | provided under this project code are driven by the number of employees | | 20 | that report to the State Presidents at the regulated companies. Therefore, | | 21 | billing method EMPLPRES, which allocates these costs based upon the | | 22 | number of full and part-time employees reporting to the State Presidents, | | 23 | is the most appropriate. For the project codes that assign costs based |

| 1 | Q. | HAVE YOU DETERMINED THAT THE COSTS REFLECTED IN THE | | :--: | :--: | :--: | | 2 | | REMAINING 7\% OF COSTS ASSOCIATED WITH THE SEVEN HR SUB- | | 3 | | FUNCTIONS HAVE BEEN BILLED APPROPRIATELY? | | 4 | A. | Yes. I have reviewed each of the project codes and the associated billing | | 5 | | methods used to bill the remaining 7\% of the costs. The cost drivers | | 6 | | reflected in the billing method used to bill the costs of each project code is | | 7 | | consistent with and reflects the cost drivers of the services captured in | | 8 | | each respective project code. Therefore, the costs billed to ETI | | 9 | | reasonably reflect the costs of the services received by ETI and are no | | 10 | | higher than the per unit costs charged to other affiliates for the same or | | 11 | | similar types of services. | | 12 | | | | 13 | Q. | HOW ARE THE COSTS OF THE LONG-TERM INCENTIVES IN THE HR | | 14 | | CLASS BILLED TO ETI? | | 15 | A. | The long-term incentives costs are allocated to ETI using billing method | | 16 | | LBRBILAL - ESI Labor Dollars Billed to Each Company. Thus, these | | 17 | | benefits costs are allocated to the legal entities based on total labor | | 18 | | dollars billed to each legal entity because benefits are part of the | | 19 | | employees' total compensation package and should be allocated in the | | 20 | | same manner as payroll. Billing method LBRBILAL is appropriate | | 21 | | because it allocates costs based on the total labor dollars that ESI bills to | | 22 | | each company. For the project codes that assign costs based upon this | | 23 | | billing method, the unit amounts billed to ETI as a result of the application |

of this billing method are no higher than the unit amounts billed to other affiliates for the same or similar service and represent the actual costs of the services.

Q. HOW ARE THE COSTS OF PENSIONS, OPEB, AND EXECUTIVE RETIREMENT BENEFITS IN THE HR CLASS OF SERVICES BILLED TO ETI?

8 A. The costs of pensions, OPEB, and executive retirement benefits are loaded and allocated like other benefit costs as described above in Section IV.E. As noted above, Company witness Tumminello discusses the Payroll Loader and Allocation processes in her testimony.

12 Q. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?

14 A. Yes.

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Executive Annual Incentive Awards (EAIP)

Compendium

2010 Program

Objectives &; Governance of Entergy's Funded / EAM based Incentive Plans

• Entergy's funded incentive compensation payments are available only when Entergy creates shareholder and customer value. Annual incentive payout is NOT GUARANTEED. It is dependent on the financial successes of the Company each year and the achievement of executive goals that benefit customers
• Ensures Entergy has sufficient funding level to payout earned incentives
• Link interests of participants to those of shareholders and customers
• Reinforce company strategy and key goals
• Provide incentives to improve results
• Rewards employees for achieving Entergy, Line of Business (LOB), and workgroup goals
• Provide a competitive total compensation package
• Pay awards to Executives no later than March 15th following the plan year end

Entergy's Funded Incentive Plans

Executive Annual Incentive Plan (EAIP) Entergy System Officers (ML 1-4)

Plan Eligibility

• To be eligible for an award, an employee must meet the following criteria:

  Regular active (full-time) employee &; Active on December ${31}^{\text{st}}$ payroll of plan year &; Hired prior to October $1^{\text{st}}$ of plan year OR Employed by Entergy for a minimum of 3 months during plan year Physically work AT LEAST 1 BUSINESS DAY during plan year

• Retired, deceased, and disabled employees eligible to participate in an incentive plan who are employed during plan year are eligible for a prorated award

  Participant will be eligible for prorated payout covering the last day physically worked Deceased's estate will receive the prorated payout

• Payout is based on one system incentive plan for each year
• Award is based on system incentive plan at December ${31}^{\text{st}}$ of plan year

Incentive Goals &; Weighting

• Incentive Goals for Executives (excluding OCE members) may include workgroup of individual goals:

  Minimum of $25\%$ weighting for cost-control measures Maximum of $75\%$ weighting for other measures such as safety, operational, Entergy's Continuous Improvement (ECI), etc. Executives in the Finance organization continue to use the Entergy Achievement Multiplier (EAM) as their incentive goal These workgroup or individual goals may be geared toward Entergy achieving top quartile status in reliability, customer service, cost control, plant production, etc. Executive goals may be one or more of the above or some combination of workgroup goals

• Incentive Goals for OCE members:

  Entergy Achievement Multiplier (EAM) - further defined on slide 9

• Personnel Committee approves goals and results for Office of Chief Executive (OCE)
• Goal results for all others are approved by the Office of Chief Executive (OCE)

Incentive Awards

• EAIP Incentive target range and maximum funded:

  ML 4-40\%-50\% $\>$ ML $3-50\%-60\%$ $\>$ ML $2-60\%-70\%$ $\>$ ML $1-120\%$

• Individuals generally receive an award within the range of 0 to $200\%$ of target
• With the exception of the Office of the Chief Executive (OCE), while it is an unusual occurrence, an individual may receive an award up to a maximum of $300\%$ of target (funding limits apply).
• The EAIP awards for the OCE will be in accordance with the Management Effectiveness Program
• Awards are based on an employee's incentive plan, incentive target, and base pay on December ${31}^{\text{st}}$ of the plan year
• EAIP participants have the option to defer their incentive award

Achievement Levels

• Performance is measured relative to individual achievement levels (goal results)
• Achievement levels can be achieved at minimum, target, maximum, or anywhere in between
• Goal results achieved below the minimum level receive $0\%$ and goal results achieved beyond the maximum level receive that particular plan's maximum
• Total achievement level is relative to minimum, target and maximum and will vary by plan

Incentive Award Calculation Components

$◻$ Total awards cannot exceed the Board approved funding level (The sum of all funded incentive awards is limited to the funding level) $◻$ All EAIP awards 100\% discretionary as determined by the Board of Directors (for OCE members) or via OCE discretion (for all other EAIP participants)

Funding Level

Incentive Funding Level (Pool)

Starts at the Corporate Level...

• The total pool of funds available for funded incentive awards is approved by the Finance and Personnel Committees of the Entergy Board of Directors
• With the exception of their own level, the OCE has the authority to adjust the funding level downward; however, the OCE does not have the authority to increase beyond the Board's approved total fund
• The funding level (pool) is based on corporate EAM
• The corporate EAM has equal weighting of Earnings Per Share (EPS) and Operating Cash Flow (OCF) for the year
• Performance is assessed relative to minimum, target and maximum achievement levels; this is the same method used to calculate workgroup goal achievement

2009 EAM Goals

| Entergy Achievement Multiplier (EAM) | Min | Target | Max | | :--: | :--: | :--: | :--: | | Earnings Per Share (EPS) | $\backslash$ 6.30 $|$ \ $7.00$ | $\backslash$ 7.70$ | | Operating Cash Flow (OCF) billions | $\backslash$ 2.52 $|$ \ $2.88$ | $\backslash$ 3.24$ |

EAM and EAM Funding

EAM calculation funds total incentive pool for funded plans EPS $=\backslash$ 6.91$ ${\mathrm{O}\mathrm{C}\mathrm{F}}_{\text{(Billion)}}=\backslash$ 3.02$

| EAM | Min | Target | Max | Actual | Weight | Achievement as \%
of Base Salary | Achievement as \%
of Target | | :-- | :-- | :-- | :-- | :-- | :-- | :-- | :-- | | EPS | $\backslash$ 6.30 $|$ \ $7.00$ | $\backslash$ 7.70 $|$ \ $6.91$ | $50\%$ | $9.0\%*50\%=4.5\%$ | $90.4\%*50\%=45.2\%$ | | OCF
Billions | $\backslash$ 2.52 $|$ \ $2.88$ | $\backslash$ 3.24 $|$ \ $3.02$ | $50\%$ | $13.8\%*50\%=6.9\%$ | $137.8\%*50\%=68.9\%$ |

Incentive Funding Level*

• The amount of money in the incentive pool is referred to as the funding level total incentive funding level $=\Sigma$ (base salary * incentive target $\%$ * Board of Director's approved EAM) for all participants
• Total incentive awards at target is the dollar amount needed to award every participant at their target level total incentive awards at target $=\Sigma$ (base salary * incentive target $\%$ ) for all participants
• The funding level is usually expressed as a percentage of total incentive awards at target

EAIP Funding

• The total pool available for EAIP incentive awards will range from $25\%$ to $200\%$ of target, which for EAIP participants with $40\%$ targets translates as $10\%$ to $80\%$ of base salaries. (Achievement level below minimum results in zero payout).

| | Min | Target | Max | | :--: | :--: | :--: | :--: | | Achievement Level (\% of Base Pay) | $10\%$ | $40\%$ | $80\%$ | | Funding Level (\% of Target) | $25\%$ | $100\%$ | $200\%$ |

• TIP: To convert \% of base pay into \% of target, divide by incentive target \% (for example, EAIP minimum is $10\%$ divided by $40\%=25\%$

Entergy's Funded Incentive Plans

Exemnt Incentive Plan (EXIP)

• Professional (exenpt) Employees
• Supervisory Employees (who are not eligible for SMIP) Sistem Management Incentive Plan (SMIP)
• High Level Professionals
• Supervisors (eligible for SMIP)
• Managers
• Directors

Executive Annual Incentive Plan (EATP) Entergy System Officers (ML 1-4) Not included in this presentation

Plan Eligibility

• To be eligible for an award an employee must meet the following criteria:
• Regular active (full-time, part-time, or phased retirement) employee &;
• Active on December 31st payroll of plan year &;
• Hired prior to October 1st of plan year OR
• Employed by Entergy for a minimum of 3 months during plan year
• Physically work AT LEAST 1 BUSINESS DAY during the plan year
• Retired, deceased, and disabled employees eligible to participate in an incentive plan who are employed during plan year are eligible for a pro-
• rated award*
• Participant will be eligible for prorated payout covering the last day physically worked
• Deceased's estate will receive the prorated payout
• Payout is based on one system incentive plan for each year
• Award is based on system incentive plan at December 31st of plan year

Inactive Employee Eligibility &; Award Calculation

If an employee is on a leave of absence, including short term disability (STD) or Family Medical protected leave (FMLA), has retired, or is deceased, to be considered eligible for an incentive payment, they must:

• Have worked at least 1 business day in the plan year and
• For those on a leave of absence, must be on a PAID leave of absence
• If an employee is on a leave of absence, including STD or FMLA, has retired, or is deceased, they are not eligible for a prorated incentive payment if they are:
• Participating in a previous Voluntary Severance Pay Program (VSP) or bridging to retirement
• On STD to either long term disability (LTD) or death without having returned to work for one business day in plan year
• On unpaid leave of absence at 12/31 of plan year
• If paid leave of absence is less than 60 days, award is NOT prorated and employee is eligible for the entire year's payout as long as all other requirements have been met
• If leave of absence is greater than 60 days, an annual decision is made by the Total Rewards Director to determine if unproration will occur
• Any unpaid leave time will still be prorated
• Any time on STD does not count toward award payout unless the employee worked at least one business day before going on LTD
• Award Calculation for Funded Incentive Plans:
• Salary * EAM * Incentive target * \% of year worked

Military Leave Eligibility &; Award Calculation

Employees on military leave must have worked one business day in the plan year and must have returned to work by $12/31$ to be eligible for incentive payment The incentive calculation is computed the same as other eligible funded plan inactive participants:

• Salary * EAM * incentive target * \% of year worked

Employees on unpaid military leave (not receiving military differentials) at 12/31 will be considered inactive employees and those employees will not be included in the 12/31 actives snapshot

• Once the individual returns to work:
• The employee is eligible to receive their incentive payment from the previous incentive year given the employee had actual business days worked in that plan year
• Payment is not automatically generated &; must be requested via PCA by the individual's management
• Payment is calculated using the formula as stated above but the payment will be paid out of the business unit's budget because once the final reconciliation is completed, the incentives season is considered finished and earn codes are no longer open for use
• If the individual returns from military leave after missing a full year's incentive cycle, they are NOT eligible for payout since they did not physically work at least one business day in the plan year

Incensive Goals &; Weighting

- Inicensive Goals must include:

• Minimum of $25\%$ weighting for cost-control measures

Source View OSM Capital spending Maximum of $75\%$ weighting for other measures such as safety, operational, and customer service

Notes: Most functions are including Entergy's Continuous Improvement measures that are appropriate for their organizations

Workgroup or individual goals

Departmental/workgroup specific

• May bageared toward Entergy achieving top quartile status in reliability, customer service, financial achievement, plant production, etc

Govtly are approved by Line of Business (LOB) head All coal results are approved by the Office of Chief Executive (OCE)

Incentive Award Targets &; Funding

Incentives of the new and maximum funding:

• $200\%$ of target

Maximum funded at $157\%$ of target

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• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
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• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
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• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $10\%$ of target
• $20\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target
• $10\%$ of target

Exhibit KGG-1 2011 TX Rate Case Page 26 of 54

Incentive Funding Level (Pool)

Starts at the Corporate Level...

The total pool of funds available for EXIP and SWIP incentive awards is approved by the Finance and Personnel Committees of the Entergy Board of Directors The OCE has the authority to adjust the funding level downward; however, the OCE does not have the authority to increase beyond the Board's total approved funding The funding level (pool) is based on corporate EAM (overall company performance) The corporate EAM has equal weighting of Earnings Per Share (EPS) and Operating Cash Flow (OCF) for the year Performance is assessed relative to minimum, target and maximum achievement levels; this is the same method used to calculate workgroup goal achievement

2009 EAM Goals

Entergy Achievement Multiplier (EAM)

Min

Target

Max

Earnings Per Share (EPS) $\backslash$ 6.30$ $\backslash$ 7.00$ $\backslash$ 7.70$

Operating Cash Flow (OCF) Billions $\backslash$ 2.52$ $\backslash$ 2.88$ $\backslash$ 3.24$

The 00 Business (100) Funding

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Office of Chief Executives (OCE)

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and the 00000000000000 is 00 and the 0000000000000000 is 00 and the 000000000000000000 is 00 and the 00000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000

Incentive Funding Allocation

Incentive Funding Level*

• The total amount of money in the incentive pool which may be spent on funded incentive plans is referred to as the EAM funding level total EAM funding level = 2 (base salary * incentive target \% * Board of Director's approved EAM) for all participants
• Total incentive awards at target is the dollar amount needed to award every participant at their target level total incentive awards at target $=\Sigma$ (base salary * incentive target \%) for all participants
• The funding level is usually expressed as a percentage of total incentive awards at target

EXTIP &; SWIP Funding

The total pool available for EXTIP incentive awards will range from 0\% to 100000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000

Exhibit KGG-1 2011 TX Rate Case Page 33 of 54

EAM and EAM Funding

EAM calculation funds total incentive pool for SMIP &; EXIP participants EPS $\approx \backslash$ 6.91$ OCF (BIIIIG) $\backslash$ 3.02$

EAM Funding Level (Pool)

• Assume the sum of salaries for EXIP is $\backslash$ 600,000 $andforMEPis$ \ $600,000$

| | EAM
(see page 21) | Incentive
target | Total Incentive Funding | | :--: | :--: | :--: | :--: | | EXIP | $107.1\%$ | $7\%$ | 107.1\% 7\% $\backslash$ 600,000$ (base
salary) $=\backslash$ 44,382$ | | SMIP | $114.1\%$ | $10\%$ | 114.1\% 10\% $\backslash$ 600,000$ (base
salary) $=\backslash$ 68,460$ |

• Funding level equals to $\backslash$ 113,442$
• Awards may not exceed the funding level set by the Board
• The following example (next page) assumes the EAM funding pool &; LOBM allocation funding are equal. Plus, management only allocates funding to cover the actual goal results

Workgroup / Individual Achievement

EXIP Example

Exhibit KGG-1 2011 TX Rate Case Page 39 of 54

Glossary

Achievement Level - The extent to which an incentive goal is attained relative to minimum, target and maximum performance objectives Award Methodology - Based on the premise that all employees do not contribute equally to goal achievement Baroaining Unit - A group of employees represented by a union who collectively negotiate the terms of their employment FAM (Entergy Achievement Multiplier) - Company's EPS and OCF used to determine funding pool EPS (Earnings Per Share) - A company's net profit divided by the number of shares outstanding Funding Level - The amount of funds available for EIP and MIP awards expressed as a percentage of awards at target Incentive Pool - The total amount of funds available for MIP and EIP incentive awards Incentive Target - An employee's annual incentive opportunity expressed as a percentage of their base pay LOB (Line of Business) - Specific lines of the business throughout the organization OCE (Office of the Chief Executive) - consists of Entergy's CEO and his direct reports OCF (Operating Cash Flow) - The amount of cash produced by day-to-day operations Management Discretion - Management's ability to exercise its own judgment as to the level of incentive awards allocated. Management uses discretion to distribute incentive funding and awards to EIP and MIP participants Workgroup - A team of employees in the same incentive plan with the same incentive goals Workgroup Goal - A performance measure with established minimum, target and maximum achievement levels

TSIP and TSPB Annual Incentive Awards

Compendium

2010 Program

Objectives &; Governance of Entergy's Teamsharing Incentive Plans

• Develop workgroup goals that focus on providing safe, costeffective, and reliable service to customers
• Reward employees for achieving Entergy Line of Business (LOB) &; workgroup goals
• Link interests of participants to those of shareholders and customers
• Reinforce company strategy and key goals
• Provide incentives to improve results
• The teamsharing incentive programs are governed by the achievement of teamsharing goals
• Pay awards to employees no later than March ${15}^{\text{th}}$ following the plan year

Entergy's Teamsharing Incentive Plans

Teamshare Incentive Plan (TSIP)

• Non-Bargaining Non-Exempt Employees
• River Bend Bargaining Employees

Teamshare Incentive Plan (TSPB)*

• Bargaining Employees

Note:

Customer Service Incentive Plan (CSIP)

• Department specific incentive plan
• Covers Customer Service non-exempt employees
• Administered by Customer Service Department
• Provides a year end true-up with TSIP
• Specific details are not included in this presentation *Details of the TSPB plan may vary from contract to contract. For more information, check specific bargaining unit contracts or contact your local HR Field Support

Plan Eligibility

• To be eligible for an award an employee must meet the following criteria:
• Regular active (full-time, part-time, or phased retirement) employee &;
• Active on December 31st payroll of plan year &;
• Hired prior to October $1^{\text{st}}$ of plan year OR
• Employed by Entergy for a minimum of 3 months during plan year
• Physically work AT LEAST 1 BUSINESS DAY during the plan year
• Retiree, deceased, and disabled employees eligible to participate in an incentive plan who are employed during plan year are eligible for a prorated award ${}^{+}$
• Participant will be eligible for prorated payout covering the last day physically worked
• Deceased's estate will receive the prorated payout
• Payout is based on one system incentive plan for each year
• Award is based on incentive plan at December 31st of plan year

Inactive Employee Eligibility &; Award Calculation

• If an employee is on a leave of absence, including short term disability (STD) or Family Medical protected leave (FMLA), has retired, or is deceased, to be considered eligible for an incentive payment, they must:
• Have worked at least 1 business day in the plan year and
• For those on a leave of absence, must be on a PAID leave of absence
• If an employee is on a leave of absence, including STD or FMLA, has retired, or is deceased, they are not eligible for a prorated incentive payment if they are:
• Participating in a previous Voluntary Severance Pay Program (VSP) or bridging to retirement
• On STD to either long term disability (LTD) or death without having returned to work for one business day in plan year
• On unpaid leave of absence at 12/31 of plan year
• If paid leave of absence is less than 60 days, award is NOT prorated and employee is eligible for the entire year's payout as long as all other requirements have been met
• If leave of absence is greater than 60 days, an annual decision is made by the Total Rewards Director to determine if unproration will occur
• Any unpaid leave time will still be prorated
• Any time on STD does not count toward award payout unless the employee worked at least one business day before going on LTD
• Award Calculation for Teamsharing Incentive Plans:
• Salary * \% of year worked * workgroup achievement level

Military Leave Eligibility &; Award Calculation

• Employees on military leave must have worked one business day in the plan year and must have returned to work by $12/31$ to be eligible for incentive payment
• The incentive calculation is computed the same as other eligible tearnsharing plan inactive participants:
• Salary * \% of year worked * workgroup achievement level
• Employees on unpaid military leave (not receiving military differentials) at 12/31 will be considered inactive employees and those employees will not be included in the 12/31 actives snapshot
• Once the individual returns to work:
• The employee is eligible to receive their incentive payment from the previous incentive year given the employee had actual business days worked in that plan year
• Payment is not automatically generated &; must be requested via PCA by the individual's management
• Payment is calculated using the formula as stated above but the payment will be paid out of the business unit's budget because once the final reconciliation is completed, the incentive season is considered finished and earn codes are no longer open for use
• If the individual returns from military leave after missing a full year's incentive cycle, they are NOT eligible for payout since they did not physically work at least one business day in the plan year

Incentive Workgroup Goals &; Weighting

• Incentive workgroups are comprised of teams of employees that share the same incentive goals
• Workgroups should generally have 4-6 incentive goals established by their functional leadership at the beginning of the year
• Incentive goals must include:
• Minimum of $25\%$ weighting for cost-control measures
• Source view O&;M
• Capital spending
• Maximum of $75\%$ weighting for other measures such as safety, operational, and customer service

Note: Most functions include Entergy's Continuous Improvement measures that are appropriate for their organizations

• Workgroup or individual goals
• Departmental / workgroup specific
• May be geared toward Entergy achieving top quartile status in customer service, financial achievement, plant production, etc.
• All goal results are approved by the Office of Chief Executive (OCE)

Incentive Award Targets

• TSIP incentive target ranges:
• Minimum (0-3\%)
• Target (5\%)
• Maximum (7\%)
• TSPB incentive target ranges:
• Minimum (0-.5\%)
• Target (2.1\%)
• Maximum (3\%)
• Depending on goal achievement level, target payout may range between minimum and maximum
• Awards are based on an employee's incentive plan, incentive target, and base pay on December ${31}^{\text{st}}$ of the plan year

Workgroup Achievement Levels

• Performance is measured relative to workgroup's achievement level (goal results)
• Goal results achieved below the minimum level receive $0\%$ and goal results achieved beyond the maximum level receive that particular plan's maximum $\%$
• Total workgroup achievement level is relative to goal achievement level and may pay out at minimum, target, maximum or somewhere in between

Status Change &; Pro rata Formula

Employees are eligible for a prorated award if:

• Eligible participant changing from full-time (FT) to parttime (PT) status or vice versa
• New hire or Rehire* prior to October $1^{\text{st}}$ of plan year
• Retiree, long-term disability, or deceased employee prior to end of plan year (as discussed on pg 5)
• Participant must physically work at least one business day during plan year

Formula based on PT/FT status or FT status

Formula for PT anytime during plan year: total regular hours worked * December ${31}^{\text{st}}$ hourly rate * achievement level Formula for FT entire plan year (employee cannot be PT at any point during year): total days worked * 12/31 base salary * achievement level

Employee Status Change &; its effects on awards

If an employee is:

• Transferred or promoted during the plan year to a position that affects a change of incentive plan, not workgroup
• Award is based on incentive plan at December 31st
• Transferred or promoted resulting in change of incentive workgroup, not incentive plan
• Award is based on the workgroup the employee was in the longest
• Transferred or promoted resulting in change of incentive plan and workgroup
• Award is based on the December 31st incentive plan with the longest associated workgroup in that particular incentive plan

Workgroup Achievement

TSIP Example

| Workgroup Goals | Weight | Min | Target | Max | Result | Achievement | Calculation | | :-- | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Cost-Control | $25\%$ | 25 | 100 | 200 | $62.5\%$ | $4\%$ | $1.00\%$ | | Safety | $25\%$ | 2 | 1 | 0 | 1 | $5\%$ | $1.25\%$ | | Operational | $30\%$ | 3 | 5 | 7 | 8 | $7\%$ | $2.10\%$ | | Customer
Satisfaction | $20\%$ | 2 | 4 | 6 | 4 | $5\%$ | $1.00\%$ | | | | | | Achievement Level as \% of base pay | | | $5.35\%$ |

• Based on workgroup achievement level, TSIP participants can receive an award payout between $0\%$ and $7\%$ of base pay
• Based on workgroup achievement level example from above, the TSIP incentive award would be $5.35\%$ of 12/31 base pay
• \ $35,000basepay$ X 5.35 \% $achievement$ =\ $1,872.50$
• Questions or concerns regarding award calculation should be directed to your supervisor

Glossary

Achievement Level - The extent to which an incentive goal is attained relative to minimum, target and maximum performance objectives Bargaining Unit - A group of employees represented by a union who collectively negotiate the terms of their employment Cost-Control Measures - Include measures such as source view O&;M, capital/kwh, capital spending, expense spending, etc. Incentive Target - An employee's annual incentive opportunity expressed as a percentage of their base pay OCE (Office of the Chief Executive) - Consists of Entergy's CEO and his direct reports Workgroup - A team of employees in the same incentive plan with the same incentive goals Workgroup Goal - A performance measure with established minimum, target and maximum achievement levels

2007 EQUITY OWNERSHIP AND LONG TERM CASH INCENTIVE PLAN OF
ENTERGY CORPORATION AND SUBSIDIARIES
(Effective for Grants and Elections On or After January 1, 2007)

ARTICLE I

PURPOSE

The purposes of this 2007 Equity Ownership and Long Term Cash Incentive Plan of Entergy Corporation and Subsidiaries are to promote the interests of Entergy (as defined in Section 2.12) and its shareholders by (i) attracting and retaining executive personnel and other key employees and directors of outstanding ability; (ii) motivating executive personnel and other key employees and directors by means of performance-related incentives, to achieve longer-range performance goals; and (iii) enabling such individuals to participate in the long-term growth and financial success of Entergy.

ARTICLE II

DEFINITIONS

The following words and phrases shall have the respective meanings under the Plan as hereinafter set forth unless the context clearly requires a different meaning: 2.1 "Award" shall mean the beneficial interest in or right to any Option, Restricted Share, Equity Award, Other Stock-Based Award or Performance Award granted from time to time under the Plan by the Committee, subject to such restrictions, terms and conditions as the Committee may determine. 2.2 "Board" shall mean the Board of Directors of Entergy. 2.3 "Cause" shall mean (a) the continued failure of a Participant to perform substantially all of his or her duties (other than a ny s uch failure resulting from incapacity due to physical or mental illness); (b) the willful engaging by a Participant in gross misconduct that is materially and demonstrably injurious to Entergy; or (c) the conviction of, or plea of guilty or nolo contendere to, a felony or other crime which has or may have a material adverse affect on a Participant's ability to carry out the Participant's duties or upon the reputation of any System Company. 2.4 "Change in Control" shall mean: (a) the purchase or other acquisition by any person, entity or group of persons, acting in concert within the meaning of Sections 13(d) or 14(d) of the Securities Exchange Act of 1934 ("Act"), or any comparable successor provisions, of beneficial ownership (within the meaning of Rule 13d-3 promulgated under the Act) of 25 percent or more of either the shares of common stock outstanding immediately following such acquisition or the combined voting power of Entergy Corporation's voting securities entitled to vote generally and outstanding immediately following such acquisition, other than any such purchase or acquisition in connection with a Non-CIC Merger (defined in subsection (b) below); (b) the consummation of a merger or consolidation of Entergy Corporation, or any direct or indirect subsidiary of Entergy Corporation with any other corporation, other than a Non-CIC Merger, which shall mean a merger or consolidation immediately following which the individuals who comprise the B oard i mmediately prior thereto c onstitute at least a m ajority of the B oard, or the board of directors of the entity surviving such merger or consolidation, or the board of directors of any parent thereof,

(c) the stockholders of Entergy Corporation approve a plan of complete liquidation or dissolution of Entergy Corporation or there is consummated an agreement for the sale or disposition by Entergy Corporation of all or substantially all of Entergy Corporation's assets; or (d) any change in the composition of the Board such that individuals who on the Effective Date constitute the Board and any new director (other than a director whose initial assumption of office is in connection with an actual or threatened election contest, including but not limited to a consent solicitation, relating to the election of directors of Entergy Corporation) whose appointment or election by the Board or nomination for election by Entergy Corporation's stockholders was approved or recommended by a vote of at least two-thirds ( $2/3$ ) of the directors then still in office who either were directors on such Effective Date or whose appointment, election or nomination for election was previously so approved or recommended, cease for any reason to constitute at least a majority thereof.

Provided, however, that no Change in Control shall be deemed to occur solely by virtue of (i) the insolvency or bankruptcy of Entergy Corporation; or (ii) the transfer of assets of Entergy Corporation to an affiliate of Entergy Corporation, provided such affiliate assumes the obligations of the Plan and agrees to continue uninterrupted the rights of the Participants under the Plan; or (iii) the consummation of any transaction or series of integrated transactions immediately following which the record holders of the common stock of Entergy Corporation immediately prior to such transaction or series of transactions continue to have substantially the same proportionate ownership in an entity which owns all or substantially all of the assets of Entergy Corporation immediately following such transaction or series of transactions. 2.5 "Change in Control Period" shall mean the period commencing ninety (90) days prior to and ending twentyfour (24) calendar months following a Change in Control. 2.6 "Code" shall mean the Internal Revenue Code of 1986, as amended. Reference in the Plan to any section of the Code shall be deemed to include any amendment or successor provisions to such section and any regulation under such section. 2.7 "Committee" shall mean the duly designated Personnel Committee of the Board, comprised solely of two or more outside directors of the Board who are non-employee directors under Rule 16b-3 promulgated under the Exchange Act, and successor rules and, with respect to Covered Participants, outside directors under Code Section 162(m). With respect to Awards granted to Outside Directors, the term "Committee" shall mean the Board. 2.8 "Common Stock" shall mean any authorized share of ownership of Entergy represented by a common stock certificate, with par value of $\backslash$ 0.01$ per share, or any other appropriate instrument evidencing same. 2.9 "Covered Participant" shall mean a Participant who is a "covered employee" as defined in Code Section $162(\mathrm{m})(3)$ , or who the Committee believes will be such a covered employee for a Plan Year. 2.10 "Effective Date" shall mean the effective date of this Plan, as described in Section 3.1. 2.11 "Employer" shall, except as otherwise determined by the Committee, mean, with respect to a given Participant and a given Award, the System Company for whom such Participant is employed at the time an Award is granted under this Plan. 2.12 "Entergy" shall mean Entergy Corporation, a Delaware corporation, and any successor of such corporation as a result of any reorganization or merger. 2.13 "Equity Award" shall mean an Award of a unit whose value is related to the value of shares of Common Stock but does not represent actual shares of Common Stock at the time such an Award is granted. 2.14 "Equity Award Account" shall mean the record of Equity Awards granted to a Participant under the Plan solely for accounting purposes, and shall not require a segregation of any Entergy System assets.

Exhibit KGG-2 2011 TX Rate Case Page 3 of 14 2.15 "Exchange Act" shall mean the Securities Exchange Act of 1934, as amended from time to time, and interpretive rulings and regulations. 2.16 "Fair Market Value" shall mean, as of any date with respect to a share of Common Stock, the closing price at which the Common Stock shall have been sold on the applicable date as reported on the New York Stock Exchange Composite Transactions Report for that date, or on the preceding trading date if that date was not a trading date. The Committee may designate a different time or method of determining the Fair Market Value, if a ppropriate, b ecause of c hanges in the hours a nd m ethods of trading on the New York Stock Exchange. If the Common Stock ceases to be listed on the New York Stock Exchange, the Committee shall designate an alternative exchange, stock market or method of determining the Fair Market Value of the Common Stock. 2.17 "Grant Date" shall mean the date specified by the Committee on which a grant of an Award shall become effective, which date shall not be earlier than the date on which the Committee acts with respect to such grant. 2.18 "Operating Cash Flow" shall mean the amount of operating cash flow for any given Performance Period, as determined by the Committee based on Entergy Corporation's financial statements and in accordance with generally accepted accounting principles. 2.19 "Options" shall mean incentive stock options or nonstatutory stock options, or both, all as described in Article VI of the Plan. 2.20 "Option Price" shall mean, with respect to each share of Common Stock subject to an Option, the price fixed by the Committee at which the share may be purchased pursuant to the exercise of the Option. 2.21 "Other Stock-Based Award" shall mean an Award other than an Option, Restricted Share, or Equity Award, granted from time to time under the Plan by the Committee subject to such restrictions, terms and conditions as the Committee may determine and denominated or payable in, valued in whole or in part by reference to, or otherwise based on or related to, shares of Common Stock. 2.22 "Outside Director" shall mean a member of the Board who is not an employee of a System Company. 2.23 "Participant" shall mean a person who is selected for an Award under this Plan, in accordance with Article V. 2.24 "Performance Goals" shall mean the goals for a Performance Period as established by the Committee and against which performance will be measured. 2.25 "Performance Period" shall mean the period designated by the Committee during which Performance Goals must be attained and generally shall not be less than one year in duration. 2.26 "Performance Award" shall mean an Award awarded subject to attainment of Performance Goals during the applicable Performance Period, as more fully described in Article IX. 2.27 "Plan" shall mean this 2007 Equity Ownership and Long Term Cash Incentive Plan of Entergy Corporation and Subsidiaries, as from time to time amended. 2.28 "Potential Change in Control" shall be deemed to have occurred if the event set forth in any one of the following paragraphs shall have occurred: (a) Entergy Corporation or any affiliate or subsidiary company enters into an agreement, the consummation of which would result in the occurrence of a Change in Control; or (b) the Board adopts a resolution to the effect that, for purposes of this Plan, a Potential Change in Control has occurred; or

(c) any System Company or any person or entity publicly announces an intention to take or to consider taking actions which, if consummated, would constitute a Change in Control; or (d) any person or entity becomes the beneficial owner (as that term is defined in Rule 13d-3 under the Securities Exchange Act of 1934, as amended from time to time), either directly or indirectly, of securities of Entergy Corporation representing $20\%$ or more of either the then outstanding shares of common stock of Entergy Corporation or the combined voting power of Entergy Corporation's then outstanding securities (not including in the calculation of the securities beneficially owned by such person or entity any securities acquired directly from Entergy Corporation or its affiliates).

2.29 "Restriction Period" shall meant the period designated by the Committee during which Restricted Shares or Restricted Share Units shall be subject to a substantial risk of forfeiture and may not be sold, exchanged, assigned, transferred, pledged, hypothecated or otherwise encumbered or disposed of, except as otherwise provided in the Plan and as the Committee may determine. 2.30 "Restricted Shares" shall mean shares of Common Stock of Entergy Corporation which are awarded subject to restrictions on the holder's right to sell, transfer, pledge or assign such shares and with such other restrictions as the Committee may determine, all as described in Article VII of the Plan. 2.31 "Restricted Share Units" shall mean an Equity Award that is subject to such restrictions on transfer and such forfeiture conditions as the Committee deems appropriate, all as described in Article VIII of the Plan. 2.32 "Retirement" shall mean retirement directly from the service of a System Company in accordance with the terms of the Entergy Corporation sponsored qualified defined benefit pension plan in which the Participant participates and where the Participant immediately thereafter commences retirement income benefits under such plan. 2.33 "System" shall mean Entergy Corporation and all System Companies and, except in determining whether a Change in Control has occurred, shall include any successor thereto. 2.34 "System Company" shall mean Entergy Corporation and any corporation $80\%$ or more of whose stock (based on voting power) or value is owned, directly or indirectly, by Entergy Corporation and any partnership or trade or business which is $80\%$ or more controlled, directly or indirectly, by Entergy Corporation, and, except in determining whether a Change in Control has occurred, shall include any successor thereto. 2.35 "Total Disability" and "Totally Disabled" shall have such meaning as defined under the Entergy Corporation sponsored group insurance plan covering total disability, and determinations of Total Disability shall be made by the insurance company providing such coverage on the date on which the Participant, whether or not eligible for benefits under such insurance plan, becomes Totally Disabled. However, in the absence of such insurance plan or in the event the individual is an Outside Director, the Committee shall make such determination.

ARTICLE III

EFFECTIVE DATE AND SCOPE

3.1 Effective Date and Duration. The Plan shall become effective as of January 1, 2007, subject to the approval of Entergy shareholders at Entergy's 2006 annual meeting of shareholders and receipt of a ny necessary governmental approvals. The Plan shall terminate on the ${10}^{\text{th}}$ anniversary of the Effective Date. The Plan shall only govern Awards made on or after its Effective Date. 3.2 Scope of Awards. Awards under this Plan may be granted in the following forms: (a) Options, all as described in Article VI; (b) Restricted Shares, as provided in Article VII; (c) Equity Awards and related benefits, including Performance Unit Awards and Restricted Unit Awards, all as described in Article VIII; (d) Performance Awards, as provided in Article IX; and (e) Other Stock-Based Awards, as provided in Article X. 3.3 Stock Subject to Plan. The stock to be issued, transferred or sold under the Plan shall be Common Stock. Subject to Section 12.1, the maximum aggregate of 7 million shares of Common Stock shall be available for delivery pursuant to Awards of Options, Restricted Shares, Equity Awards or Other Stock-Based Awards granted from time to time under the Plan, of which no more than 2 million shares shall be granted as other than Options or stock appreciation rights. Any Award, or portion thereof, which is settled in cash shall not be applied against the maximum allocation of shares. Shares of Common Stock delivered under this Plan shall be authorized but unissued shares or open market shares of Entergy. Shares of Common Stock covered by Awards which are not earned, or which are forfeited or terminated for any reason, and Options which expire unexercised or which are exchanged for other Awards, shall again be available for subsequent Awards under the Plan. Shares received in connection with the exercise of Options by delivery of other shares of Common Stock, and shares related to that portion of an Award utilized for the payment of withholding taxes shall not again be available for Awards under the Plan.

ARTICLE IV

ADMINISTRATION

4.1 Administration of Plan. The Committee shall operate and administer the Plan and shall have the authority to exercise the powers and discretion conferred on it by the Plan, including the right to delegate any function to a specified person or persons. The Committee shall have membership composition which enables (i) Awards to Section 16 Persons to qualify as exempt from liability under Section 16(b) of the Exchange Act and (ii) Awards to Covered Employees to qualify as performance-based compensation as provided under Code Section 162(m). 4.2 Powers of the Committee. The Committee shall administer the Plan in accordance with its terms and shall have all powers, authority, and discretion necessary or proper for such purpose. By way of illustration, the Committee shall have the following powers: (a) The Committee shall have the sole and exclusive power and discretion to grant Awards to Participants under the Plan, to select the Participants to receive Awards, to determine the type, size, terms and conditions of the Awards to be made to each Participant selected, to determine the time when Awards to Participants will be granted, and to prescribe the form of the agreements embodying Awards made under the Plan. (b) The Committee shall determine all questions arising in the administration of the Plan including, but not limited to, the power and discretion to determine eligibility and participation of any individual.

(c) The Committee shall make factual determinations, construe and interpret the Plan, including the intent of the Plan and any ambiguous, disputed or doubtful provisions of the Plan. (d) The Committee may adopt such rules and regulations as it shall deem desirable or necessary for the administration of the Plan.

Notwithstanding the foregoing, the Plan shall be administered by the Board with respect to a ny A ward granted to an Outside Director. 4.3 Committee Actions. All findings, decisions, or determinations of any type made by the Committee pursuant to the Plan, including factual determinations, any interpretation or construction of the Plan, and the specific conditions and provisions of the Awards granted under the Plan, shall be final and conclusive and shall be binding upon all persons including, without limitation, each Participant, beneficiary, legal representative, and any other interested parties. To the maximum extent permitted by applicable law, each member of the Committee and the Board shall be indemnified and held harmless by Entergy against and from (i) any loss, cost, liability, or expense that may be imposed upon or reasonably incurred by him or her in connection with or resulting from any claim, action, suit, or proceeding to which he or she may be a party or in which he or she may be involved by reason of any action taken or failure to act under the Plan or any Award agreement, and (ii) any and all amounts paid by him or her in settlement thereof, with Entergy's approval, or paid by him or her in satisfaction of any judgment in any such claim, action, suit, or proceeding against him or her, provided he or she shall give Entergy an opportunity, at its own expense, to handle and defend the same before he or she undertakes to handle and defend it on his or her own behalf. The foregoing right of indemnification shall not be exclusive of any other rights of indemnification to which such persons may be entitled under Entergy's Articles of Incorporation or Bylaws, by contract, as a matter of law, or otherwise, or under any power that Entergy may have to indemnify them or hold them harmless. 4.4 Delegation of Duties. With the exception of the authority to grant Awards to persons subject to Sections 16(a) and 16(b) of the Exchange Act, to persons who are Covered Participants, or to make other determinations regarding such persons, the Committee may delegate to one or more of its members or to one or more agents such administrative duties as it may deem advisable, and the Committee or any person to whom it has delegated duties as aforesaid may employ one or more persons to render advice with respect to any responsibility the Committee or such person may have under the Plan. 4.5 Reliance on Reports. The Committee may employ attorneys, consultants, accountants or other persons, and the Committee, Entergy and its officers and directors shall be entitled to rely upon the advice, opinions or evaluations of any such persons. 4.6 Non-Uniform Determinations. The Committee's determinations under the Plan, including without limitation, determinations as to the key employees or outside directors to receive Awards, the terms and provisions of such Awards and the agreement(s) evidencing the same, need not be uniform and may be made by it selectively among the key employees or outside directors who receive or are eligible to receive Awards under the Plan, whether or not such key employees or outside directors are similarly situated. 4.7 Effect of Code Section 409A. The Committee shall determine the manner and the extent to which certain designated Participants may defer the receipt of certain Awards granted under this Plan to such Participants. The terms and conditions of such deferral opportunities shall be set forth in the Participant's Award Agreement. To the extent that any Award under this Plan is or may be considered to involve a nonqualified deferred compensation plan or deferral subject to Section 409A of the Code, the terms and administration of such Award shall comply with the provisions of such Section, applicable IRS guidance and good faith reasonable interpretations thereof and, to the extent necessary, shall be modified, replaced, or terminated in the discretion of the Committee. Notwithstanding any provision of the Plan or any Award Agreement to the contrary, in the event that the Committee determines that any Award may be or become subject to Code Section 409A, Entergy may adopt such amendments to the Plan and the affected Award Agreement (without Participant consent) or adopt other policies and procedures (including amendments, policies and procedures with retroactive effect), or take any other actions, that the Committee determines are necessary or appropriate to (i) exclude or exempt the Plan and any Award Agreement from the application of Code

Section 409A and/or preserve the intended tax treatment of the benefits provided with respect to Award, or (ii) comply with the requirements of Code Section 409A. 4.8 Deferral under the Executive Deferred Compensation Plan. Subject to the terms and conditions, and according to the procedures, of the Executive Deferred Compensation Plan of Entergy Corporation and Subsidiaries or a successor plan or program ("EDCP"), and in accordance with the terms of the applicable Equity Award agreement, Equity Awards otherwise payable to Participants under this Plan may be deferred under the EDCP.

ARTICLE V

ELIGIBILITY AND PARTICIPATION

5.1 Eligibility. Those individuals eligible for Awards under the Plan are (a) Outside Directors and (b) those key employees of a System Company determined to have significant responsibility for the continued growth, development and financial success of the Companies. 5.2 Participation. Subject to the provisions of the Plan, and with the exception of grants to Outside Directors as determined by the Board, the Committee shall from time to time select from such eligible persons those to whom Awards shall be granted and determine the amount of such Award, and such individuals shall become Participants.

ARTICLE VI

STOCK OPTIONS

6.1 General Provisions. Options shall be subject to such terms and conditions, shall be exercisable at such time or times, and shall be evidenced by such form of Award agreement between the Participant and the Employer, as the Committee shall determine; provided, that such determinations are not inconsistent with the other provisions of the Plan, including those set forth in this Article. 6.2 Types of Options. Options may be in the form of either an incentive stock option within the meaning of Code Section 422; or a nonstatutory stock option, which are those options that do not constitute an incentive stock option within the meaning of Code Section 422. (a) If the Award agreement evidencing an Option does not contain a specific designation that it is an incentive stock option, it shall be a nonstatutory stock option award. (b) To the extent the Committee elects to grant incentive stock options under the Plan, such incentive stock options shall be subject to the limitations under Section 422 of the Code including, without limitation, the applicable time limitations. The aggregate fair market value (determined in each instance on the Date of Grant of an incentive stock option) of the Common Stock with respect to which an incentive stock option is first exercisable by any Participant in any calendar year shall not exceed $\backslash$ 100,000 $oranyotherlimitprescribedintheCodefortheParticipant.Totheextentsuchfairmarketvalueexceeds$ \ $100,000$ , such Option shall be treated, for federal income tax purposes, as a nonstatutory stock option. (c) As provided in Section 3.3 above, the maximum aggregate number of incentive stock options that may be granted under the Plan shall not exceed two million. 6.3 Option Price. The Option Price determined by the Committee shall not be less than the Fair Market Value on the date the Option is granted. Once determined by the Committee, no price of any Option shall be decreased unless that change is authorized by a majority vote of the shareholders of Entergy Corporation.

6.4 Term of Options. Options shall vest and be exercisable in the time-frame determined by the Committee, which shall be set forth in the Award agreement, and generally shall have a minimum three-year graded vesting period. No Option shall be exercisable after ten years from the date such Option is granted. 6.5 Payment of Option Price. The purchase price of the shares as to which an Option is exercised shall be paid in accordance with such terms and conditions and by such means as the Committee shall determine. 6.6 Exercise of Options. The specified number of shares with respect to which an Option is exercised shall, subject to applicable tax withholding, be issued following receipt by Entergy of (i) notice of the exercise of an Option (in accordance with procedures that the Committee shall have specified in the Award agreement or otherwise) delivered to Entergy's Secretary or his or her designee, and (ii) payment, as provided in the Plan, of the Option Price. The Committee may, in its discretion, accelerate the ability to exercise any Option in whole or in part at any time. The Committee may also permit Participants, either on a selective or aggregate basis, simultaneously to exercise Options and sell the shares of Common Stock thereby acquired pursuant to a brokerage or similar arrangement, approved in advance by the Committee, and use the proceeds from such sale as payment of the purchase price of such shares. 6.7 Payment. To the extent permitted under applicable law and the relevant Option Award Agreement, the exercise price of an Option shall be paid to Entergy in full at the time of exercise at the election of the Participant (1) in cash, (2) in shares of Common Stock having a Fair Market Value on the exercise date equal to the aggregate exercise price of the Option and satisfying such other requirements as may be imposed by the Committee, (3) partly in cash and partly in such shares of Common Stock, (4) to the extent permitted by the Committee, through the withholding of shares of Common Stock (which would otherwise be delivered to the Participant) with an aggregate Fair Market Value on the exercise date equal to the aggregate exercise price of the Option, (5) through the delivery of irrevocable instructions to a broker to deliver promptly to Entergy an amount equal to the aggregate exercise price of the Option, or (6) any other legal consideration that the Committee may deem appropriate. T he Committee may limit the extent to which shares of Common Stock may be used in exercising Options. No Participant shall have any rights to dividends or other rights of a stockholder with respect to shares of Common Stock subject to an Option until the Participant has given written notice of exercise of the Option, paid in full for such shares of Common Stock and, if applicable, has satisfied any other conditions imposed by the Committee pursuant to the Plan. 6.8 Non-Transferability of Options. Options granted under the Plan shall not be transferable other than by will or by the laws of descent and distribution, or pursuant to a qualified domestic relations order as defined in the Code, and Options and rights may be exercised during the lifetime of the Participant only by the Participant or by the Participant's guardian or legal representative. Any attempted assignment, transfer, pledge, hypothecation or other disposition of an option, or levy of attachment or similar process upon the Option not specifically permitted herein shall be null and void and without effect. 6.9 Beneficiaries. The Participant may designate one or more beneficiaries who shall be entitled to exercise the Participant's rights hereunder following the death of the Participant. Such designation shall be made on a form supplied by the Committee. In the absence of a valid beneficiary designation, the Participant's rights hereunder shall pass pursuant to the Participant's will or by the laws of descent and distribution. 6.10 Maximum Number of Shares. The total number of shares of Common Stock which any single Participant may be allowed to purchase pursuant to the exercise of Options or stock appreciation rights granted under this Plan shall not exceed 1.75 million shares, subject to adjustment in the same manner as provided in Section 12.1 .

6.11 Termination of Service. Unless a Participant's Award Agreement provides otherwise: (a) an Option shall terminate and may no longer be exercised 90 days after the Participant ceases to be a System Company employee for any reason other than termination for Cause, Total Disability, death or Retirement; (b) all Options shall terminate and may no longer be exercised upon a System Company employee Participant's termination for Cause; (c) if a System Company employee's employment is terminated by reason of Total Disability or Retirement, or an Outside Director separates from the Board, all Options held by the Participant will vest and may be exercised within the remaining term of the Option Award; and (d) if the Participant dies while in the employ of a System Company or while serving as an Outside Director, the vesting provisions of an Option held by such Participant will vest, and such Option may, within the remaining term of the Option award, be exercised by the legal representative of the Participant's estate, or if it has been distributed as part of the estate, by the person or persons to whom the Participant's rights under the Option shall pass by will or by the applicable laws of descent and distribution.

In no event may an Option be exercised to any extent by anyone after the expiration or termination of the Option.

ARTICLE VII

RESTRICTED SHARE AWARDS

7.1 Grant of Restricted Shares. The Committee may award Restricted Shares to such key employees and Outside Directors whom the Committee determines to be eligible pursuant to the terms of Article V. An Award of Restricted Shares may be subject to restrictions on transfer and forfeitability provisions, all as the Committee may determine. Such Restricted Shares shall be awarded based on such other terms and conditions as the Committee shall from time to time determine subject to the provisions of the Plan; provided, however, the Participant shall be entitled to any voting rights relative to such Restricted Shares during the Restricted Period as defined below. 7.2 Award and Delivery of Restricted Shares. At the time an Award of Restricted Shares is made, the Committee shall establish the Restricted Period applicable to such an Award. Generally the Restricted Period shall not be less than three years from date of grant. Each Award of Restricted Shares may have a different Restricted Period. The Committee may, in its sole discretion, at the time an Award is made, prescribe conditions for the incremental lapse of restrictions during the Restricted Period and for the lapse or termination of restrictions upon the satisfaction of other conditions in addition to or other than the expiration of the Restricted Period with respect to all or any portion of the Restricted Shares. 7.3 Dividends on Restricted Shares. Any and all cash and stock dividends paid with respect to the Restricted Shares shall be subject to any restrictions on transfer, forfeitability provisions or reinvestment requirements (including, without limitation, the reinvestment of such dividends in the form of Equity Awards) as the Committee may, in its discretion, determine. 7.4 Forfeiture. Upon the forfeiture of any Restricted Shares (including any additional Restricted Shares which may result from the reinvestment of cash and stock dividends in accordance with such rules as the Committee may establish pursuant to Section 7.3), such forfeited shares shall be surrendered. The Participant shall have the same rights and privileges, and be subject to the same restrictions, with respect to any additional shares received pursuant to Section 12.1 due to recapitalization, mergers, or the like. 7.5 Expiration of Restricted Period. Upon the expiration or termination of the Restricted Period and the satisfaction of any other conditions prescribed by the Committee or at such earlier time as provided for in Section 7.2, the restrictions applicable to the Restricted Shares shall lapse and a stock certificate for the number of Restricted Shares with respect to which the restrictions have lapsed shall be delivered, free of all

such restrictions, except any that may be imposed by law, to the Participant or the Participant's beneficiary or estate, as the case may be.

ARTICLE VIII

EQUITY AWARDS

8.1 Issuance of Equity Awards. An Equity Award may be granted to key employees and Outside Directors pursuant to the terms of Article V. Equity Awards shall be allocated to a Participant's respective Equity Award Account at such time or times, in such amounts, subject to such restrictions and in accordance with such terms and conditions as the Committee, in its discretion, may determine. 8.2 Funding. In the case of Equity Awards granted under the Plan, no shares of Common Stock shall be issued at the time the Award is made, and Entergy, the Employer and Plan, or any one of them, shall not be required to set aside a fund for the payment of any such Award. 8.3 Maturity of Equity Awards. All Equity Awards granted to a Participant shall become fully matured at time or times or under such circumstances as the Committee shall from time to time determine and specify in the Agreement. 8.4 Payment of Equity Awards. A Participant who has received an Equity Award allocated to his Equity Award Account shall be entitled to receive a distribution from the Employer with respect to each then mature Equity Award allocated to his Equity Award Account at such time as any such Equity Award has been earned and vested and is no longer subject to a timely and binding deferral election as may be specified in the Agreement. All Equity Awards shall be payable in cash. 8.5 Non-Transferability. Equity Awards granted under the Plan, and any rights and privileges pertaining thereto, may not be transferred, assigned, pledged or hypothecated in any manner, by operation of law or otherwise, other than by will or by the laws of descent and distribution, and shall not be subject to execution, attachment or similar process. The Participant may designate one or more beneficiaries who shall be entitled to exercise the Participant's rights hereunder following the death of the Participant. Such designation shall be made on a form supplied by the Committee. In the absence of a valid beneficiary designation, the Participant's rights hereunder shall pass pursuant to the Participant's will or by the laws of descent and distribution. 8.6 Restricted Share Units. In the discretion of the Committee, the Committee may award a Participant Equity Awards in the form of Restricted Share Units, which shall be subject to such terms, restrictions on transfer and such forfeiture conditions as the Committee deems appropriate.

ARTICLE IX

PERFORMANCE AWARDS

9.1 Performance Awards. The Committee may award Performance Awards in the form of (a) performance shares or units valued by reference to shares of Common Stock or (b) performance units, which are units valued by reference to financial measures or property other than Common Stock, all of which shall be subject to such terms and conditions and other restrictions as the Committee shall assign. At the time of making grants of Performance Awards, the Committee shall establish such terms and conditions as it shall determine applicable to such Awards. Performance Awards may be paid out in cash, Common Stock, Restricted Shares, other property or a combination thereof. Recipients of Performance Awards are not required to provide consideration other than the rendering of service. 9.2 Performance Goals. The Committee may determine that an Award shall be subject to the satisfaction of such performance goals as established by the Committee. As determined by the Committee, achievement of the performance goals may be measured (a) individually, alternatively or in any combination, (b) with

respect to Entergy, a subsidiary, division, business unit, product line, product, or any combination of the foregoing, or (c) on an absolute basis, or relative to a target, to a designated comparison group, to results in other periods, to an index, or to other external measures. In determining whether a performance goal is met, the Committee may exclude the impact of any event or occurrence which the Committee determines should appropriately be excluded, such as a restructuring or other nonrecurring charge, an event either not directly related to the operations of Entergy or not within the reasonable control of Entergy's management, or a change in accounting standards required by U.S. generally accepted accounting principles. 9.3 Performance-Based Compensation. For an Award that is subject to performance goals and that is intended to qualify as "performance-based compensation" under Code Section 162(m), the following additional provisions shall apply: (a) the applicable performance goals will be based upon or may relate to one or any combination of business criteria such as the performance, efficiency, or profitability measured by specified levels or of growth in one or more of the following business criteria as the Committee may determine: EBITDA, EBIT, stock price, total shareholder return, market share, sales, earnings per share, costs, operating income, net income, operating cash flow, cash flow, net cash flow, fuel cost per million BTU, costs per kilowatt hour, retained earnings, budget achievement, return on equity, return on assets, return on capital employed, return on invested capital, productivity, return on sales, completion of acquisitions, cash available to parent, net operating profit after taxes (NOPAT), economic value added (EVA), expense spending, O&;M expense, expense, O&;M or capital/kwh, capital spending, gross margin, net margin, market capitalization, market value, debt ratio, equity ratio, return on assets, profit margin, customer growth, or customer satisfaction. The Performance Goals may be stated in terms of absolute levels or relative to another company or companies or to an index or indices; (b) the Committee may adjust downwards, but not upwards, the amount payable pursuant to such Award upon attainment of the performance goals; (c) the Committee may not waive the achievement of the applicable performance goals except in the case of the death or disability of the grantee, or under such other conditions where such waiver will not jeopardize the treatment of other Awards as "performance-based compensation" under Section 162(m); (d) the Award shall otherwise comply with the requirements of Code Section 162(m), or any successor provision thereto, and the regulations thereunder; (e) the Award and payment of any Award under this Plan with respect to a relevant Performance Period shall be contingent upon the attainment of the applicable Performance Goals. The Committee shall certify in writing prior to payment any such Award that such applicable Performance Goals relating to the Award are satisfied. Approved minutes of the Committee may be used for this purpose. All Awards to Covered Participants under this Plan shall be further subject to such other conditions, restrictions, and requirements as the Committee may determine to be necessary or appropriate. The value of Performance Units payable to a single Covered Participant pursuant to this Plan shall not exceed $\mathrm{.5}\%$ of Operating Cash Flow during any applicable Performance Period.

ARTICLE X

OTHER STOCK-BASED AWARDS

10.1 Terms of Award. Subject to the limits described in Section 3.3 of this Plan, the Committee may make Other Stock-Based Awards as it deems appropriate. The terms and conditions of any Other Award shall be set forth in the applicable Award agreement or otherwise by the Committee. The circumstances (including any applicable Performance Measures) under which, and the number, if any, of, shares of Common Stock or the amount of c ash that shall then become p ayable to the holder of the A ward shall be set forth in the applicable agreement or otherwise. The Committee shall in its discretion determine the timing of payment of the Award. 10.2 Dividend Equivalent. The C ommittee m ay grant an A ward that c onfers u pon the P articipant a right to receive cash, Common Stock, other Awards or other property equal in value to dividends paid with respect to a specified number of shares of Common Stock.

ARTICLE XI

TERMINATION OR AMENDMENT OF THE PLAN

11.1 Termination or Amendment. The Committee shall have the right, a uthority a nd power to a lter, a mend, modify, suspend, revoke or terminate the Plan in whole or in part at any time, including the adoption of amendments deemed necessary or desirable to qualify the Awards under the laws of various states and under rules and regulations promulgated by the Securities and Exchange Commission with respect to officers and directors who are subject to the provisions of Section 16 of the 1934 Act, to comply with any applicable provisions of the Code, including Code Section 162(m), or to correct any defect or supply any omission or reconcile any inconsistency in the Plan or in any Award granted under the Plan, without the approval of Entergy's shareholders. However, no action shall be taken without the approval of Entergy's shareholders that (a) would cause the Plan to no longer comply with Rule 16b-3, or any other regulatory requirements; or (b) materially increase the benefits accruing to participants under the Plan, materially increase the number of securities that may be issued under the Plan, or materially modify the requirements for participation in the Plan. In addition, if exemption from Code Section 162(m) deduction limits is to be continued, any such amendment shall be made with Board and shareholder approval if necessary to comply with the requirements for the qualified performance-based compensation exception under Code Section 162(m). Unless authorized by a majority vote of the shareholders of Entergy Corporation, once determined by the Committee, no price of any Option shall be decreased. 11.2 Restrictions on Amendment or Termination. Except as provided in Section 4.7 of the Plan, no amendment or termination or modification of the Plan shall in any manner adversely affect any Award previously granted without the consent of the Participant, except that prior to a Change in Control, the Committee may amend or modify the Plan in a manner that does adversely affect Awards previously granted upon a finding by the Committee that the amendment or modification is in the best interest of holders of outstanding Awards affected by the amendment or modification.

ARTICLE XII

GENERAL PROVISIONS

12.1 Adjustments Upon Changes in Capitalization. Notwithstanding any other provision of the Plan, the Committee may, at any time, make or provide for such adjustments to the Plan, to the number and class of shares available thereunder or to any outstanding Options, Restricted Shares, Equity Awards or Other Stock-Based Awards as it shall deem appropriate to prevent dilution or enlargement of rights, including adjustments in the event of distributions to holders of Common Stock other than a normal cash dividend, changes in the outstanding Common Stock by reason of stock dividends, stock splits, recapitalizations, mergers, consolidations, combinations or e xchanges of shares, separations, reorganizations, liquidations and the like. Any such determination by the Committee shall be conclusive. 12.2 Fractional Shares. The Employer shall not be required to deliver any fractional share of Common Stock but may pay, in lieu thereof, the Fair Market Value of such fractional share to the Participant or the Participant's beneficiary or estate, as the case may be. For purposes of this Section 12.2, the Fair Market Value shall be determined as of the following dates: (i) the date on which restrictions lapse for Restricted Shares or Restricted Share Units, (ii) the date of delivery of Performance Units, (iii) the maturity date for Equity Awards other than Restricted Share Units or Performance Units, or (iv) in any case, such other dates the Committee may determine. 12.3 Tax Withholdings. Subject to such terms and conditions as may be established by the Committee, the Participant shall pay to Entergy any amount necessary to satisfy applicable federal, state or local tax withholding requirements attributable to an Award of Options, Restricted Shares, Performance Units or Equity Awards under this Plan promptly upon notification of the amounts due. The Committee may permit such amount to be paid by the Participants to be withheld from the shares of Common Stock that otherwise

would be distributed to such Participant upon the exercise of an Option, the lapse of restrictions applicable to Restricted Shares, the payment of Performance Units or the maturity of Equity Awards, as applicable, or a combination of cash and shares of such Common Stock. Shares related to that portion of an Award utilized for the payment of withholding taxes shall not again be available for Awards under the Plan. 12.4 Legal and Other Requirements. The obligation to sell and deliver Common Stock under the Plan shall be subject to all applicable laws, regulations, rules and approvals, including, but not by way of limitation, the effectiveness of a registration statement under the Securities Act of 1933 if deemed necessary or appropriate by Entergy. Certificates for shares of Common Stock issued hereunder may be legended as the Committee shall deem appropriate. Entergy and the Committee reserve the right to restrict, in whole or in part, the delivery of Common Stock or other securities pursuant to any Award prior to the satisfaction of all legal requirements relating to the issuance of such Common Stock or other securities, to their registration, qualification or listing or to an exemption from registration, qualification or listing. 12.5 Award Agreements. All Awards shall be documented in a written or electronic agreement in a form approved by the Committee, which shall include the terms and conditions of the Award. 12.6 Effect on Other Plans. Awards may be granted singly, in combination or in tandem (except where prohibited by applicable law) and may be made in combination or tandem with or as alternatives to, awards or grants under any other employee plan maintained by a System Company; provided that the adoption of the Plan shall have no effect on awards made or to be made pursuant to other stock plans covering the employees of any System Company or successors thereto. Awards under the Plan shall not constitute earnings for purposes of any pension plan covering employees of any System Company except as otherwise expressly provided in any such pension plan. 12.7 No Entitlements. A Participant's rights, if any, in respect of or in connection with any Award are derived solely from the discretionary decision to permit the individual to participate in the Plan and to benefit from a discretionary Award. By accepting an Award under the Plan, a Participant expressly acknowledges that there is no obligation on the part of Entergy, the Committee, or any other entity or individual to continue the Plan and/or grant any additional Awards. Any Award granted hereunder is not intended to be compensation of a continuing or recurring nature, or part of a Participant's normal or expected compensation, and in no way represents any portion of a Participant's salary, compensation, or other remuneration for purposes of pension benefits, severance, redundancy, resignation or any other purpose. 12.8 No Right to Employment or Service. N either the P lan nor a ny Award granted under the P lan shall be deemed to give any individual a right to remain an employee, consultant or director of Entergy or a ny System Company. Entergy and any System Company reserves the right to terminate the service of any person at any time, and for any reason, subject to applicable laws, Entergy's Articles of Incorporation and Bylaws and a written employment agreement (if any), and such terminated person shall be deemed irrevocably to have waived any claim to damages or specific performance for breach of contract or dismissal, compensation for loss of office, tort or otherwise with respect to the Plan or any outstanding Award that is forfeited and/or is terminated by its terms or to any future Award. 12.9 Notices. Every direction, revocation or notice authorized or required by the Plan shall be deemed delivered to Entergy on the date it is personally delivered to the Secretary of Entergy at its principal executive offices or three business days after it is sent by registered or certified mail, postage prepaid, addressed to the Secretary at such offices, and shall be deemed delivered to a Participant on the date it is personally delivered to him or three business days after it is sent by registered or certificate mail, postage prepaid, addressed to him at the last address shown for him on the records of Entergy and its Subsidiaries. 12.10 Applicable Law. All questions pertaining to the validity, construction and administration of the Plan and rights and benefits granted hereunder shall be determined in conformity with the laws of the State of Delaware, to the extent not preempted or controlled by the laws of the United States and regulations thereunder.

12.11 Funding. The Plan shall be totally unfunded. No Participant shall have any interest in any fund or specific asset of an Employer by reason of the Plan.

ARTICLE XIII

CHANGE IN CONTROL

13.1 Accelerated Vesting. Notwithstanding anything stated herein to the contrary, but subject to any federal securities law restrictions on sale and exercise, in the event of a Change in Control: (a) with respect to Restricted Shares or other Awards subject to restrictions and issued under the Plan, all restrictions imposed hereunder shall lapse effective as of the date of the Change in Control; (b) if during a Performance Period(s) applicable to a Performance Award granted under the Plan, a Participant shall earn the number of performance shares or performance units which the Participant would have earned as if target performance under the Award was obtained; and (c) any outstanding Options that are not vested shall become vested and exercisable effective as of the date of a Change in Control. If a Participant's employment or service is terminated within 24 months following the effective date of a Change in Control, any such vested and exercisable Options may be exercised within the remaining term of the Option Award. 13.2 Source of Payments. Within thirty (30) days following the date of a Change in Control, or at such other time as the System Company may determine in its complete discretion, a System Company may make a single irrevocable lump sum contribution to the Trust for Deferred Payments of Entergy Corporation and Subsidiaries ("Trust") pursuant to the terms and conditions described in such Trust. To the extent such a Trust is created, it shall be a "grantor" trust under the Internal Revenue Code, and the establishment and funding of such Trust is not intended to cause Participants to realize current income on amounts contributed thereto, and the Trust shall be so interpreted.

2008 - 2010 PERFORMANCE UNIT PROGRAM SUMMARY

1. OBJECTIVES

• The Performance Unit Program is designed to strengthen the link between executive compensation and long term shareholder value.
• The Performance Unit Program complements the Executive Annual Incentive Plan by tying payouts to the total return to shareholders over a three-year performance period.

2. WHAT ARE PERFORMANCE UNITS?

• Performance Units are phantom shares of Entergy Corporation common stock. Each Performance Unit equals the cash value of one share of Entergy common stock. Each Unit also earns the cash equivalent of the dividends paid during the three-year performance period.
• Participants earn Performance Units based on their performance relative to corporate performance measures and goals.
• At the end of the performance period, restrictions are lifted on Units earned and their corresponding cash dividends, as determined by the performance measures. The cash value of those earned Units plus accrued dividends is either paid to participants in early 2011 or deferred in that same time period, if so elected.

3. KEY DESIGN FEATURES

• Participants will earn Performance Units as follows: $\>0\%$ of "Target" for achieving less than "Minimum" performance. $\>10\%$ of "Target" for achieving "Minimum" performance. $\>100\%$ of "Target" for achieving "Target" performance. $\>250\%$ of "Target" for achieving "Maximum" performance.
• Performance Units earned will be calculated by using the actual performance level achieved between "Minimum" (10\%), "Target" (100\%) and "Maximum" (250\%) performance - rounded to the nearest whole Unit. In no case, however, may a participant payout exceed $250\%$ of the target.
• The value associated with the Units earned and their accrued dividends will be paid in early 2011 (following the three-year performance period) or deferred -- based upon each participant's election.
• Dividends will be accrued only on the Performance Units earned during the 2008 -2010 performance period.
• Executives may elect to defer up to $100\%$ of the value associated with the Units earned including accrued dividends under either the Executive Deferred Compensation Plan (EDCP) or the Equity Ownership Plan (EOP). The plan selected will determine how the executive's deferral is invested.

2008 - 2010 PERFORMANCE UNIT PROGRAM SUMMARY

• Each participant must provide his/her irrevocable deferral election (to either receive the earned Units and dividends in early 2011 or to defer payment) in accordance with Entergy's deferral process. Otherwise, the value of the accrued Performance Units and dividends will be paid in cash in early 2011.
• To earn Performance Units, participants must be active employees at the end of the Performance Period (12/31/2010) unless retirement, death or disability occurs. $\>$ Participants include all Entergy System management level 1-4 employees. $\>$ Retirement, death or disability will cause the Performance Units earned to be prorated for the number of full months of participation. $\>$ Participants added to the Program after the beginning of the performance period will have their Performance Units prorated to reflect the number of full months as a participant. To receive an award, participation must commence no later than January 1, 2010. $\>$ Participants whose Management Level changes during the performance period will have their Performance Units prorated to reflect the number of full months as a participant in each of those levels. $\>$ Participants demoted below an eligible System Management Level during the performance period will have their Performance Units prorated to reflect the number of full months at an eligible System Management Level.
• No single participant may be granted Performance Units whose total value exceeds .5\% of Entergy's operating cash flow, and the total value of performance units granted to all of the named executive officers in Entergy's proxy statement may not exceed 1\% of operating cash flow.

4. 2008 - 2010 PERFORMANCE UNIT PROGRAM GOALS AND PEER GROUP

As the following chart illustrates, performance is measured by Entergy's Total Shareholder Return (TSR) relative to the other companies that comprise the Philadelphia Utilities Index over the three-year performance period. Minimum, Target and Maximum performance levels are set in terms of Entergy's TSR performance against the Philadelphia Utilities Index quartiles.

| Quartiles: | 4 | 3 | 2 | 1 | | :--: | :--: | :--: | :--: | :--: | | Performance
Levels: | Zero | Minimum | Target | Maximum | | TSR Ranges: | 25th percentile and below | 25th to 50th percentiles | 50th to 75th percentiles | 75th percentile and above | | Payouts: | No Payout | Interpolate between Minimum and Target (10\% to 100\% of Target) | Interpolate between Target and Maximum (100\% to 250\% of | Maximum Payout (250\% of Target) |

Exhibit KGG-3 2011 TX Rate Case Page 3 of 23 Exhibit KGG-3 Texas Rate Case

2008 - 2010 PERFORMANCE UNIT PROGRAM SUMMARY

Target)

2008 - 2010 PERFORMANCE UNIT PROGRAM SUMMARY

• A TSR ranking anywhere in the first quartile gains a maximum award of $250\%$ of Target.
• A TSR ranking in the fourth quartile (bottom) quartile is below the minimum performance level resulting in no award (zero pay out).
• A TSR ranking in the second and third quartiles is calculated linearly based on where Entergy ranks between the minimum and the median (target), or the median (target) and the maximum. $\>$ The company ranking last in the 3rd quartile defines minimum performance. $\>$ Target performance is defined as the median TSR $\>$ The company ranking first in the 1st quartile defines maximum performance.
• The current listing of companies in the Philadelphia Utilities Index includes the following 20 companies:*

| Ameren Corp. | Entergy Corp. | | :-- | :-- | | American Electric Power | Exelon Corp. | | AES Corp. | Firstenergy Corp. | | Constellation Energy Group | FPL Group, Inc. | | CenterPoint Energy | Northeast Utilities | | Dominion Resources | PG&;E Corp | | DTE Energy Holding Co. | Public Service Enterprise | | Duke Energy Corp. | Progress Energy, Inc. | | Consolidated Edison | Southern Co. | | Edison International | XCEL Energy, Inc. |

• as of January 2, 2008
• Total shareholder return is the difference between the market price of Entergy Corporation common stock at the beginning from the market price at the end of the performance period, plus the dividends received during the same period, plus the investment return on those reinvested dividends divided by the share price at the beginning of the performance period.

- Example:

| Date | Closing Stock Price | | | :-- | :-- | :-- | | 12/31/07 (Beginning of Period) | $\backslash$ 116.50$ | (actual) | | 12/31/10 (End of Period) | $\backslash$ 136.50$ | (estimated) | | Difference in Market Price | $\backslash$ 20.00$ | (estimated) |

Assume also that dividends paid to shareholders during the three-year performance period are $\backslash$ 0.75 $perquarteror$ \ $9.00$ for the three-year period. For the purposes of the Total

2008 - 2010 PERFORMANCE UNIT PROGRAM SUMMARY

Return calculation, we further assume that dividends are immediately reinvested in Entergy Corporation common stock, as they are paid, producing a reinvestment return of $\backslash$ 0.69$ per share.

Total Return during the three-year Performance Period $=$ (Difference in Market Price + Dividends Paid + Reinvestment Return on Dividends) divided by the Beginning Stock Price and would be calculated as follows: $\diamond$ Total Return $=(\backslash$ 20.00+\ $9.00+\backslash$ 0.69) $dividedby$ \ $116.50$ $\diamond$ Total Return $=25.48\%$

5. TAX TREATMENT EXAMPLE (Please consult your tax advisor)

• The Company is obligated to withhold taxes on the value of the Performance Units and dividends earned by participants. The following is an example of a typical situation encountered by a participant. Individual tax circumstance may vary.

  The participant's "taxable event" should occur at the time of payment; i.e. either in early 2011, following the three-year performance period, or at the end of the deferral period, if so elected.

• If immediate distribution is elected, then a Participant's tax withholding requirements are satisfied as described in the following example:

Restrictions lifted on 1,000 Units Market value (at a price of $\backslash$ 136.50 $perUnit)$ \ $136,500.00$ Dividend equivalent cash on 1,000 Units (\$9.00 per share per year for 3 years) 9,000.00

Total reportable W-2 taxable income $\backslash$ 145,500.00$

Tax Withholding Applied to Reportable Income Federal income tax (at the supplemental 25\% rate) \$ 36,375.00 State income tax (e.g., Arkansas @ 7\%) 10,185.00 FICA tax (6.20\%) 9,021.00 Medicare tax (1.45\%) 2,109.75 Total tax withholding \$ 57,690.75

Participant receives net cash payment of $\backslash$ 87,809.25$

• If deferral is elected, then the FICA and Medicare tax amounts indicated above are withheld in early 2011. Federal and state income taxes are deferred until the payment is made.

Exhibit KGG-3 2011 TX Rate Case Page 6 of 23 Exhibit KGG-3 Texas Rate Case 2008 - 2010 PERFORMANCE UNIT PROGRAM SUMMARY

2009 - 2011 PERFORMANCE UNIT PROGRAM SUMMARY

1. OBJECTIVES

• The Performance Unit Program is designed to strengthen the link between executive compensation and long term shareholder value.
• The Performance Unit Program complements the Executive Annual Incentive Plan by tying payouts to the total return to shareholders over a three-year performance period.

2. WHAT ARE PERFORMANCE UNITS?

• Performance Units are phantom shares of Entergy Corporation common stock. Each Performance Unit equals the cash value of one share of Entergy common stock. Each Unit also earns the cash equivalent of the dividends paid during the period of your active participation in the Plan. (Note: You will only be eligible to receive dividends paid during the time you were an active participant.)
• Participants earn Performance Units based on Entergy's performance relative the financial performance of a select group of Utility peers.
• At the end of the performance period, restrictions are lifted on Units earned and their corresponding cash dividends, as determined by the performance measures. The cash value of those earned Units plus accrued dividends is either paid to participants in early 2012 or deferred in that same time period, if so elected.

3. KEY DESIGN FEATURES

• Participants will earn Performance Units as follows: $\>0\%$ of "Target" for achieving less than "Minimum" performance. $\>10\%$ of "Target" for achieving "Minimum" performance. $\>100\%$ of "Target" for achieving "Target" performance. $\>250\%$ of "Target" for achieving "Maximum" performance.
• Performance Units earned will be calculated by using the actual performance level achieved between "Minimum" (10\%), "Target" (100\%) and "Maximum" (250\%) performance - rounded to the nearest whole Unit. In no case, however, may a participant payout exceed $250\%$ of the target.
• The value associated with the Units earned and their accrued dividends (earned for the period of participation only) will be paid in early 2012 (following the three-year performance period) or deferred -- based upon each participant's election.
• Dividends will be accrued only on the Performance Units earned during the 2009 -2011 performance period and only for the period of participation.
• Executives may elect to defer up to $100\%$ of the value associated with the Units earned including accrued dividends under either the Executive Deferred Compensation Plan

Exhibit KGG-3 2011 TX Rate Case Page 8 of 23 Exhibit KGG-3 Texas Rate Case

2009 - 2011 PERFORMANCE UNIT PROGRAM SUMMARY

(EDCP) or the Equity Ownership Plan (EOP). The plan selected will determine how the executive's deferral is invested.

2009 - 2011 PERFORMANCE UNIT PROGRAM SUMMARY

• Each participant must provide his/her irrevocable deferral election in order to defer payment in accordance with Entergy's deferral process. Otherwise, the value of the accrued Performance Units and dividends will be paid in cash in early 2012.
• To earn Performance Units, participants must be active employees at the end of the Performance Period (12/31/2011) unless retirement, death or disability occurs. $\>$ Participants include all Entergy System management level 1-4 employees.

  A Retiree must have been an Active Participant for a minimum of twelve months in order to receive a payout. Eligible Retirees will be entitled to a pro-rated payout for the number of full months of participation. $\>$ Participants who retire prior to the completion of twelve months of participation will not be eligible for a payout. Eligible Retirees will receive dividends only for the period of time in which they are an Active Participant. For example if you Retire on January 1, 2010, you will be eligible for pro-rated units for the twelve months in 2009 plus dividends earned only in 2009. $\>$ Death or disability will cause the Performance Units earned while employed as an eligible participant to be prorated for the number of full months of participation. $\>$ Participants added to the Program after the beginning of the performance period will have their Performance Units prorated to reflect the number of full months as a participant. Participants added to the program during the eligible performance cycle will be eligible for dividends paid only during the period in which they are active Participants. $\>$ To receive an award, participation must commence no later than January 1, 2011. That is a participant who becomes eligible for the Performance Unit Program will not be added to an existing program after January $1^{\text{st}}$ of the final year of the program. $\>$ Participants whose Management Level changes during the performance period will have their Performance Units prorated to reflect the number of full months as a participant in each of those levels.

• Participants demoted below an eligible System Management Level during the performance period will have their Performance Units prorated to reflect the number of full months at an eligible System Management Level No single participant may be granted Performance Units whose total value exceeds $\mathrm{.5}\%$ of Entergy's operating cash flow, and the total value of performance units granted to all of the named executive officers in Entergy's proxy statement may not exceed 1\% of operating cash flow.

2009 - 2011 PERFORMANCE UNIT PROGRAM SUMMARY

4. 2009 - 2011 PERFORMANCE UNIT PROGRAM GOALS AND PEER GROUP

As the following chart illustrates, performance is measured by Entergy's Total Shareholder Return (TSR) relative to the other companies that comprise the Philadelphia Utilities Index over the three-year performance period. Minimum, Target and Maximum performance levels are set in terms of Entergy's TSR performance against the Philadelphia Utilities Index quartiles.

| Quartiles: | $\mathbf{4}$ | $\mathbf{3}$ | $\mathbf{2}$ | $\mathbf{1}$ | | :-- | :--: | :--: | :--: | :--: | | Performance
Levels: | Zero | Minimum | Target | Maximum | | TSR Ranges: | 25th percentile and
below | 25th to 50th
percentiles | 50th to 75th
percentiles | 75th percentile and
above | | Payouts: | No Payout | Interpolate between
Minimum and Target
(10\% to 100\% of
Target) | Interpolate between
Target and
Maximum
(100\% to 250\% of
Target) | Maximum Payout
(250\% of Target) |

• A TSR ranking anywhere in the first quartile gains a maximum award of $250\%$ of Target.
• A TSR ranking in the fourth quartile (bottom) quartile is below the minimum performance level resulting in no award (zero pay out).
• A TSR ranking in the second and third quartiles is calculated linearly based on where Entergy ranks between the minimum and the median (target), or the median (target) and the maximum. $\>$ The company ranking last in the 3rd quartile defines minimum performance. $\>$ Target performance is defined as the median TSR $\>$ The company ranking first in the 1st quartile defines maximum performance.
• The current listing of companies in the Philadelphia Utilities Index includes the following 20 companies:* Ameren Corp. American Electric Power AES Corp. Constellation Energy Group CenterPoint Energy Dominion Resources DTE Energy Holding Co. Duke Energy Corp. Consolidated Edison Edison International

Entergy Corp. Exelon Corp. Firstenergy Corp. FPL Group, Inc. Northeast Utilities PG&;E Corp Public Service Enterprise Progress Energy, Inc. Southern Co. XCEL Energy, Inc.

2009 - 2011 PERFORMANCE UNIT PROGRAM SUMMARY

• as of January 2, 2008
• Total shareholder return is the difference between the market price of Entergy Corporation common stock at the beginning from the market price at the end of the performance period, plus the dividends received during the same period, plus the investment return on those reinvested dividends divided by the share price at the beginning of the performance period.

- Example:

| Date | Closing Stock Price | | :-- | :-- | | 01/01/09 (Beginning of Period) | $\backslash$ 83.13$ (actual closing price on 12/31/208) | | 12/31/11 (End of Period) | $\backslash$ 103.13$ (estimated) | | Difference in Market Price | $\backslash$ 20.00$ (estimated) |

Assume also that dividends paid to shareholders during the three-year performance period are $\backslash$ 0.75 $perquarteror$ \ $9.00$ for the three-year period. For the purposes of the Total Return calculation, we further assume that dividends are immediately reinvested in Entergy Corporation common stock, as they are paid, producing a reinvestment return of $\backslash$ 0.95$ per share.

Total Return during the three-year Performance Period $=$ (Difference in Market Price + Dividends Paid + Reinvestment Return on Dividends) divided by the Beginning Stock Price and would be calculated as follows: $\diamond$ Total Return $=(\backslash$ 20.00+\ $9.00+\backslash$ 0.95) $dividedby$ \ $83.13$ $\diamond$ Total Return $=36.03\%$

5. TAX TREATMENT EXAMPLE (Please consult your tax advisor)

• The Company is obligated to withhold taxes on the value of the Performance Units and dividends earned by participants. The following is an example of a typical situation encountered by a participant. Individual tax circumstance may vary.

  The participant's "taxable event" should occur at the time of payment; i.e. either in early 2012, following the three-year performance period, or at the end of the deferral period, if so elected.

2009 - 2011 PERFORMANCE UNIT PROGRAM SUMMARY

• If immediate distribution is elected, then a Participant's tax withholding requirements are satisfied as described in the following example:

Restrictions lifted on 1,000 Units Market value (at a price of $\backslash$ 103.13 $perUnit)$ \ $103,130.00$ Dividend equivalent cash on 1,000 Units (\$9.00 per share per year for 3 years) Total reportable W-2 taxable income $\backslash$ 112,130.00$

Tax Withholding Applied to Reportable Income Federal income tax (at the supplemental 25\% rate) \$ 28,032.50 State income tax (e.g., Arkansas @ 7\%) 7,849.10 FICA tax (6.20\%) 6,952.06 Medicare tax (1.45\%) $\underset{―}{1,625.89}$ Total tax withholding $\backslash$ 44,459.55$

Participant receives net cash payment of $\backslash$ 67,670.46$

• If deferral is elected, then the FICA and Medicare tax amounts indicated above are withheld in early 2012. Federal and state income taxes are deferred until the payment is made.

2011-2013

Performance Unit Program Summary

TABLE OF CONTENTS

Program Objectives, 1 What are Performance Units?, ..... 1 Key Design Features, ..... 2 Performance Unit Goals and Peer Group, ..... 4 Example of Calculation of Total Shareholder Return, ..... 5 Tax Treatment and Example, ..... 6

PROGRAM OBJECTIVES

The Performance Unit Program is designed to strengthen the link between executive compensation and long term shareholder value.

The Performance Unit Program complements the Executive Annual Incentive Plan by linking payouts to the total return to shareholders over a three-year performance period.

WHAT ARE PERFORMANCE UNITS?

Performance Units are phantom shares of Entergy Corporation common stock. Each Performance Unit equals the cash value of one share of Entergy common stock at the end of a three-year performance cycle. Each Unit also earns the cash equivalent of the dividends paid during the period of your active participation in the Plan. (Note: You will be eligible to receive dividends paid only for the time you were an active participant.)

Participants earn Performance Units based on Entergy's performance relative to the financial performance of a select group of Utility peers.

At the end of the performance period, as determined by the performance measures and subject to Personnel Committee approval, the cash value of the earned Units plus accrued dividends are either paid to participants soon after the end of the performance cycle or deferred in that same time period, if so elected.

KEY DESIGN FEATURES

Eligibility to Participate

Participants include all Entergy System management level 1 through 4 employees. Performance units are being granted for the 2011-2013 three year performance cycle. To earn Performance Units, you must be an active employee at the end of the Performance Period $(12/31/2013)$ unless you retire, become disabled or die during the performance period.

A Retiree must have been an active participant for a minimum of twelve months in order to receive a prorated payout. Participants who retire prior to the completion of twelve months of participation will not be eligible for a payout.

Participants can enter the plan, during the performance cycle, however to receive an award, participation must commence no later than January 1, 2013. That is, a participant who becomes eligible for the Performance Unit Program will not be added to an existing program after January $1^{\text{st}}$ of the final year of the program.

No single participant may be granted Performance Units whose total value exceeds .5\% of Entergy's operating cash flow, and the total value of performance units granted to all of the named executive officers in Entergy's proxy statement may not exceed $1\%$ of operating cash flow.

How Performance Units Payouts are Calculated

Participants will earn Performance Units as follows: $\>0\%$ of "Target" for achieving less than "Minimum" performance. $\>25\%$ of "Target" for achieving "Minimum" performance. $\>100\%$ of "Target" for achieving "Target" performance. $\>200\%$ of "Target" for achieving "Maximum" performance. Performance Units earned are calculated by using the actual performance level achieved between "Minimum" (25\%), "Target" (100\%) and "Maximum" (200\%) performance, rounded to the nearest whole Unit. In no case, however, may a participant payout exceed $200\%$ of the target.

Dividends accrue only on the Performance Units earned during the 2011-2013 performance period and only for the period of active participation.

The value associated with the Units earned and their accrued dividends (earned for the period of participation only) will be paid in early 2014 (following the three-year performance period) or deferred based upon each participant's election.

KEY DESIGN FEATURES CONTINUED

Pro-rated Payouts for Partial Program Participation

Retirees with at least 12 months of participation in the program will be entitled to a prorated payout for the number of full months of participation.

Eligible Retirees will receive dividends only for the period of time in which they are an Active Participant. For example if you retire on January 1, 2012, you will be eligible for pro-rated units for the twelve months in 2011 plus dividends earned only in 2011.

Death or disability will cause the Performance Units earned while employed as an eligible participant to be prorated for the number of full months of participation.

Participants whose Management Level changes during the performance period will have their Performance Units prorated to reflect the number of full months as a participant in each of those levels.

Participants added to the Program after the beginning of the performance period will have their Performance Units prorated to reflect the number of full months as a participant. Participants demoted below an eligible System Management Level during the performance period will have their Performance Units prorated to reflect the number of full months at an eligible System Management Level

Deferral Election

You may elect to defer up to $100\%$ of the value associated with the Units earned including accrued dividend equivalents under either the Executive Deferred Compensation Plan (EDCP) or the Equity Ownership Plan (EOP). The plan selected will determine how your elected deferral is invested.

You must provide an irrevocable deferral election in order to defer payment in accordance with Entergy's deferral process. Otherwise, the value of the accrued Performance Units and dividends will be paid to you in cash in early 2014.

PERFORMANCE UNIT PROGRAM GOALS AND PEER GROUP

As the following chart illustrates, performance is measured by Entergy's Total Shareholder Return (TSR) relative to the other companies that comprise the Philadelphia Utilities Index over the three-year performance period. Minimum, Target and Maximum performance levels are set in terms of Entergy's TSR performance against the Philadelphia Utilities Index quartiles.

| Quartiles: | 4 | 3 | 2 | 1 | | :--: | :--: | :--: | :--: | :--: | | Performance
Levels: | Zero | Minimum | Target | Maximum | | TSR Ranges: | 25th percentile and below | 25th to 50th percentiles | 50th to 75th percentiles | 75th percentile and above | | Payouts: | No Payout | Interpolate between Minimum and Target ( $25\%-100\%$ of Target) | Interpolate between Target and Maximum ( $100\%-200\%$ of Target) | Maximum Payout (200\% of Target) |

Entergy ranking in the first 1st quartile defines maximum performance. Target performance is defined as Entergy earning the median TSR. Entergy ranking last in the 3rd quartile defines minimum performance level. Entergy TSR ranking anywhere in the first quartile earns a maximum award of 200\% of Target. Entergy TSR ranking in the second and third quartiles is calculated linearly based on where Entergy ranks between the minimum and the median (target), or the median (target) and the maximum.

Entergy TSR ranking in the fourth quartile (bottom) quartile is below the minimum performance level resulting in no award (zero pay out).

The current listing of companies in the Philadelphia Utilities Index includes the following 19 companies:

Ameren Corp. American Electric Power AES Corp. Constellation Energy Group CenterPoint Energy DTE Energy Holding Co. Duke Energy Corp. Consolidated Edison Edison International

Entergy Corp. Eselon Corp. FirstEnergy Corp. Northeast Utilities NextEra Energy PG&;E Corp Public Service Enterprise Group Progress Energy, Inc. Southern Company Xcel Energy, Inc.

PERFORMANCE UNIT PROGRAM GOALS AND PEER GROUP CONTINUED

Total Shareholder Return (TSR) is the difference between the market price of Entergy Corporation common stock at the beginning from the market price at the end of the performance period, plus the dividends received during the same period, plus the investment return on those reinvested dividends divided by the share price at the beginning of the performance period.

Example:

| Date | Closing Stock Price | | :-- | :-- | | 01/01/11 (Beginning of Period) | $\backslash$ 70.83$ (actual closing price on 12/31/2010) | | 12/31/13 (End of Period) | $\backslash$ 82.03$ (estimated) | | Difference in Market Price | $\backslash$ 12.00$ (estimated) |

Assume also that dividends paid to shareholders during the three-year performance period are $\backslash$ 0.83 $perquarteror$ \ $9.96$ for the three-year period. For the purposes of the Total Return calculation, we further assume that dividends are immediately reinvested in Entergy Corporation common stock, as they are paid, producing a reinvestment return of $\backslash$ 0.76$ per share.

Total Return during the three-year Performance Period $=$ (Difference in Market Price + Dividends Paid + Reinvestment Return on Dividends) divided by the Beginning Stock Price and would be calculated as follows: $\Rightarrow$ Total Return $=(\backslash$ 12.00+\ $9.96+\backslash$ 0.76) $dividedby$ \ $70.83$ $\Rightarrow$ Total Return $=32.08\%$

TAXES AND PERFORMANCE UNITS (Please consult your tax advisor)

The Company is obligated to withhold taxes on the value of the Performance Units and dividends earned by participants. The following is an example of a typical situation encountered by a participant. Individual tax circumstance may vary.

The participant's "taxable event" should occur at the time of payment; i.e. either in early 2014, following the three-year performance period, or at the end of the deferral period, if so elected.

TAX TREATMENT EXAMPLE (Please consult your tax advisor)

If immediate distribution is elected, then a Participant's tax withholding requirements are satisfied as described in the following example:

Restrictions lifted on 1,000 Units Market value (at a price of $\backslash$ 82.03 $perUnit)$ \ $82,030.00$ Dividend equivalent cash on 1,000 Units (\ $9.96pershareperyearfor3years)\backslash$ 9,960.00 Total reportable W-2 taxable income \$91,990.00 Tax Withholding Applied to Reportable Income Federal income tax (at the supplemental 25\% rate) \$ 22,997.50 State income tax (e.g., Arkansas @ 7\%) 6,439.30 FICA tax (6.20\%) 5,703.38 Medicare tax (1.45\%) 1,333.86 Total tax withholding \$ 36,474.04 Participant receives net cash payment of \$55,515.97

If you elect to defer your Performance Unit payout, then the FICA and Medicare tax amounts indicated above are withheld in early 2014. Federal and state income taxes would be deferred until the deferred amount is paid out.

ML6 Annual Operational Incentive Plan (January 2010)

Plan Objectives:

The Operational Incentive Plan is designed to recognize key Management Level 6 ("ML6") leaders for their superior leadership and performance in successful operation of the business. Primary areas of focus for outstanding performance include contributions to increased reliability, plant operations, employee and public safety, cost control, customer service, and other critical corporate support functions including finance, legal, human resources, communications, procurement, IT, etc.

Eligible Employees:

All ML6 leaders who are active, full-time employees on December ${31}^{\text{st}}$ of each calendar year are eligible participants in the Operational Incentive Plan. The annual year-end snapshot will identify all eligible ML6 employees. The actual number of employees allowed to receive an award is limited to $20\%$ of the eligible population to ensure that those key employees contributing to successful operations are recognized for their efforts.

Targeted Compensation Opportunity:

The dollars used to fund the Operational Incentive Plan will be determined each year in conjunction with the development of the annual Compensation Model, with targeted dollar values based on comparable market values. $✓$ Comparable market value is defined as the ${50}^{\text{th}}$ percentile of the long term component of the total target compensation package for ML6 leaders, as surveyed by the company's external compensation consultant, when comparing to companies of comparable size and scope. $✓$ The OCE will make the final determination on the available operational incentive pool based on this market data along with overall company performance.

Participant Limits and Maximum Payouts:

$✓$ The maximum allowable spending each year is determined by the total funding authorized for the Operational Incentive Plan- this funding is based on market data and OCE approval. $✓$ Each OCE members pool is funded based on 15\% of their ML6 population. The total authorized funding is then allocated to each OCE member based on their proportion of target participants relative to the total number of ML 6 target participants system wide. This determines the percentage of the total funded pool made available for them to distribute to their key contributors.

• Example Only:

| OCE
Member | Total ML6
Population | Target # of
Participants | \% of total
Target
Participants | Allocated
Dollars | | :--: | :--: | :--: | :--: | :--: | | 1 | 340 | 51 | $20.00\%$ | $\backslash$ 600,000$ | | 2 | 49 | 7 | $2.75\%$ | $\backslash$ 82,353$ | | 3 | 500 | 75 | $29.41\%$ | $\backslash$ 882,353$ | | 4 | 180 | 27 | $10.59\%$ | $\backslash$ 317,646$ | | 5 | 633 | 95 | $37.25\%$ | $\backslash$ 1,117,647$ | | | $\mathbf{1}\mathbf{,}\mathbf{7}\mathbf{0}\mathbf{2}$ | $\mathbf{2}\mathbf{5}\mathbf{5}$ | $\mathbf{1}\mathbf{0}\mathbf{0}\mathbf{\%}$ | $\mathbf{\backslash }$ 3 , 0 0 0 , 0 0 0}$ |

$✓$ A per participant target can be calculated by dividing the total funded pool by the number of target participants.

• For example: $\backslash$ 3,000,000 / 255=\ $11,764$ $✓$ Although each OCE member's funded pool is based on 15\% of their ML6 population, the maximum number of their ML6 employees that may receive an incentive award each cycle is $20\%$ of their total ML6 population based on the 12/31 population snapshot.
• This rule has no exceptions.
• Allocation to less than $20\%$ of eligible participants is allowed. $✓$ The maximum payout that an individual participant may receive is $15\%$ of the employee's snapshot salary (based on the 12/31 snapshot).
• This rule has no exceptions. $✓$ Minimum recommended individual payout that a participant may receive is $5\%$ of the employee's salary (based on the 12/31 snapshot).
• This is a recommendation. Individual payouts may fall below minimum due to unique circumstances. (However 20\% of the OCE's ML6 population is still the maximum number of participants who may receive an award.) $✓$ Individual awards should be based on the employee's superior leadership and contribution to the success of the company's operations (as described above), as well as the desire to retain the employee.
• Any employee with an "Improvement Required" PP&;R rating is not eligible to receive a payout. $✓$ Unused dollars are not available for future use during the year $✓$ Incentive pool dollars are only to be used to allocate incentives to eligible ML6 employees.

Process and Timeline

| Timeline | Activity | Responsible Parties | | :--: | :--: | :--: | | October | Assess market and develop target compensation value | - External compensation consultant (Towers Perrin) | | December | Present recommended incentive pool to OCE for approval
Capture snapshot of eligible ML6 leaders | - Total Rewards - based on data and input from compensation consultant
- Total Rewards | | January 11 | Develop incentive pool dollar amounts and eligible population listings and disseminate to line management | - Total Rewards in conjunction with Field HR | | January 11-
February 19 | Develop recommendations on individual awards to selected employees | - Field HR to facilitate process
- Line management to make participant and award recommendations | | February 26 | Finalize and approve recommended payouts for participants | - Field HR to facilitate process
- OCE member approves recommended roster and payouts to employees | | March 1 | Management may start to notify participants of award | - Total Rewards to provide award notification forms
- Field HR to facilitate process
- Line Management to communicate to participants | | On or around $1^{\text{st}}$ week in April | Awards are processed and paid as normal on-cycle checks for most participants, some participants may receive a paper check
- Normal on-cycle check allows for direct deposit
- Any participants whose checks must be cut using the off-cycle process will receive a paper check | - Payroll |

How It Works

1. External compensation consultant surveys the market to determine the median targeted long term compensation for similar ML6 employees in companies of comparable size. Using the target value identified, Total Rewards models the incentive pool based on the eligible population and presents a recommendation to the OCE for consideration.
2. Plan is funded when the OCE approves a pool of dollars based on market data for ML6 employees (provided by the third party independent consultant) and operational performance of the Company. Assume - Pool is equal to \$3,000,000 and Total ML6 population is 1,702.
3. In our example each OCE member is provided with a pool of dollars based on their proportion of target participants to the total number of target participants system wide.

| OCE
Member | Eligible
ML6
Employees | Target # of
Participants
(15\% of Eligible
ML6 Employees) | \% of Total
Target
Participants | Total
Funded
Pool | | :--: | :--: | :--: | :--: | :--: | | 1 | 340 | 51 | $20.00\%$ | $\backslash$ 600,000$ | | 2 | 49 | 7 | $2.75\%$ | $\backslash$ 82,353$ | | 3 | 500 | 75 | $29.41\%$ | $\backslash$ 882,353$ | | 4 | 180 | 27 | $10.59\%$ | $\backslash$ 317,646$ | | 5 | 633 | 95 | $37.25\%$ | $\backslash$ 1,117,647$ | | | $\mathbf{1}\mathbf{,}\mathbf{7}\mathbf{0}\mathbf{2}$ | $\mathbf{2}\mathbf{5}\mathbf{5}$ | $\mathbf{1}\mathbf{0}\mathbf{0}\mathbf{\%}$ | $\mathbf{\backslash }$ 3 , 0 0 0 , 0 0 0}$ |

1. An average per participant amount can be determined by dividing the total funded pool by the target number of participants. Per participant amount - \ $3,000,000/25=\backslash$ 11,764
2. Each OCE member may allocate Plan dollars to a maximum of $20\%$ of their ML6 employees. Selected employee may not receive more than $15\%$ of their December 31 (end of the year snap shot) base salary. It is recommended that selected employee receive no less that $5\%$ of their base pay.

| | Eligible
ML6
Employees | $20\%$ of Eligible
ML6
Employees | | :--: | :--: | :--: | | 1 | 340 | 68 | | 2 | 49 | 10 | | 3 | 500 | 100 | | 4 | 180 | 36 | | 5 | 633 | 127 |

Exhibit KGG-3 2011 TX Rate Case Page 23 of 23 Exhibit KGG-3 Texas Rate Case 6. Line Mgmt allocates available Plan dollars to selected ML 6 employees.

| OCE 2 Allocates Assigned Pool of Dollars - \$82,353.00 | | | | | | :--: | :--: | :--: | :--: | :--: | | Employee | Base Salary | 15\% of Base
Salary
(Maximum
Allowed) | Recommended
Payment | Percent
of
Salary | | 1 | \ $121,000|\backslash$ 18,150 | \ $16,830|$ 13.9 \%$ | | 2 | \ $113,000|\backslash$ 16,950 | \ $10,700|$ 9.5 \%$ | | 3 | \ $134,000|\backslash$ 20,100 | \ $0|$ 0.0 \%$ | | 4 | \ $97,000|\backslash$ 14,550 | \ $0|$ 0.0 \%$ | | 5 | \ $105,000|\backslash$ 15,750 | \ $9,330|$ 8.9 \%$ | | 6 | \ $106,000|\backslash$ 15,900 | \ $7,500|$ 7.1 \%$ | | 7 | \ $109,000|\backslash$ 16,350 | \ $11,830|$ 10.9 \%$ | | 8 | \ $117,000|\backslash$ 17,550 | \ $9,330|$ 8.0 \%$ | | 9 | \ $111,000|\backslash$ 16,650 | \ $8,000|$ 7.2 \%$ | | 10 | \ $125,000|\backslash$ 18,750 | \ $8,830|$ 7.1 \%$ | | Totals | | | \$82,350 | |

1. OCE member approves the recommended payment to ML6 employees.
2. Approved allocation spreadsheet sent to Compensation for review.
3. Compensation reviews the approved spreadsheets for compliance with Plan.
4. Once reviewed Compensation submits the spreadsheet to Payroll for processing.

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This exhibit contains information that is highly sensitive and will be provided under the terms of the Protective Order (Confidentiality Disclosure Agreement) entered in this case.

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This exhibit contains information that is highly sensitive and will be provided under the terms of the Protective Order (Confidentiality Disclosure Agreement) entered in this case.

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This exhibit contains voluminous information that will be provided on a separate DVD accompanying this filing.

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Families and Functions

Corporate Support Functions &; Classes (\$ Total ETI Adjusted)

Operations Functions &; Classes (\$ Total ETI Adjusted)

Domestic Regulated Utility Operations Group

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Entergy Corporation Employee Development 2010 Workshops

| Workshop | Target Audience | Target # of
Participants | # of days | | :-- | :-- | :--: | :--: | | Advanced Labor Relations | HR professionals or mid- to upper-level
managers with collective bargaining and
contract maintenance responsibilities.
Supervisor approval required. Not
mandatory. | 30 per class | 2 days |

This two-day intensive training program will address the very basic foundation of labor law to the more complex subjects of unfair labor practices, negotiations, strikes and just cause terminations. Participants will receive advanced training that will further strengthen their labor relations knowledge and skills through traditional classroom instruction, case analysis and role playing. The program will be taught by in house Labor Relations experts who come to the classroom with well over 40 years of combined labor relations experience.

During this program, participants will:

• Learn employee, employer and labor organization's rights and obligations under the National Labor Relations Act.
• Receive practical advice on how to avoid interfering with employee rights.
• Gain an understanding of the National Labor Relations Board and its jurisdiction.
• Learn what an unfair labor practice is and how they are filed with and processed by the National Labor Relations Board.
• Be instructed on how a union becomes the official representative of the employees for purposes of collective bargaining.
• Be instructed on the employer's duty to bargain and the various subjects of bargaining.
• Build skills on how to prepare for the collective bargaining process and to conduct yourself at and away from the table.
• Study the tools available to the union and to management.
• Study the seven elements of just cause, round out techniques for dealing with grievances, and prepare for arbitrations

| Advanced Management
Program | Select managers and above. By invitation
only. | 45 per class | 5 days | | :-- | :-- | :-- | :--: | | Applying Strategic Thinking
to Employee Actions | Supervisor approval required. Mandatory
for supervisors and above. | 30 per class | 1 days |

Participants will learn to develop business strategies for both departments and functions at Entergy and will develop a working knowledge of scenario planning. Also, through in depth case study analysis, participants will evaluate the lessons learned from both the successful and unsuccessful strategic initiatives of utility based companies. The evaluation of case studies, lecture, team activities, and discussion are effectively utilized to maximize this learning experience.

| Behavioral Interviewing | Supervisor approval required. Mandatory
for supervisors and above with hiring
authority. | 30 per class | 2 days | | :-- | :-- | :-- | :-- | | During this two day workshop participants learn a new way to hire that will provide them with a set of skills to more
accurately select the right candidate for the job at all levels (craft, non-exempt, and exempt level positions). By | | | |

employing Behavioral interviewing techniques, participants ensure that our company interviews applicants, in an effective, consistent, and legally defensible manner.

During this session the participant will learn:

• How to select the right person: Planning for the success of both the candidate and the organization.
• The Behavioral Interviewing approach: Illustrating the importance of gaining behavioral examples to predict performance versus reliance on gut feelings.
• To plan for Selection: Determining both the job-specific and organizational needs for a candidate and the appropriate methods for prescreening and interviewing.
• To conduct the Interview: Practicing skills to conduct a legally defensible interview.
• To sell both Entergy and the Opportunity: Emphasizing the importance of promoting the job and the opportunity to attract the best candidates.
• To make the Decision: Rating job skills objectively (from entry level apprentice to management level openings) to make informed hiring decisions.

| Building Your Business
Case: Getting Your Project
Approved | Supervisor approval required. Mandatory
for supervisors and above. | 30 per class | 1.5 days | | :-- | :-- | :-- | :-- | :-- |

Participants will learn more in depth financial analysis techniques and business case analysis techniques utilized by electric companies today. Furthermore, participants will learn to stay within budget constraints while selecting projects and options that will create the greatest value to Entergy. During this high impact workshop, participants will be exposed to various project evaluation models, the impact of Capital/O&;M expenditures to earnings per share, key measurements, and how to present projects to senior management.

Career Planning: Positioning Yourself for Advancement

Available to all employees. Supervisor approval required. Not mandatory.

| 25 per class | 1 day | | :-- | :-- | | | | | | |

This workshop will help participants learn how to:

• Identify and implement preparation strategies that will position them for greater responsibility
• Effectively identify their personal strengths and areas of needed improvement for career advancement
• Effectively position themselves as the best candidate in highly competitive promotional opportunities
• The workshop includes self-assessment activities, one-on-one coaching, and role-play oriented interviews. Activities are designed to help participants identify their strengths and weaknesses and to be better prepared to seize promotional opportunities in their future.

| Coaching for Outstanding
Job Performance | Supervisor approval required. Mandatory
for supervisors and above. | 25 per class | 2 days | | :-- | :-- | :-- | :-- | :-- |

In this 2-day course, supervisors and managers learn how to keep their employee's productivity up through effective coaching. Participants discover the essential components of coaching for performance management as well as how to customize coaching styles for individual employees. Through role plays and case studies, participants leave this course with an understanding of the step by step approach to coaching and are able to implement the concepts learned in their own working environments.

| Communicating Up, Down,
and Across the
Organization | Available to all employees. Supervisor
approval required. Mandatory for
supervisors and above. | 25 per class. | 2 days | | :-- | :-- | :-- | :-- | :-- |

This 2-day course will enable participants to break down the cross organizational barriers and have their voice

heard. Participants learn to use listening and communication skills to create high impact messages. They also learn techniques to communicate ideas and projects for the listening audience.

| Conflict Management | Teaches how to handle difficult situations;
how to keep conflicts, disagreements, and
emotions from harming important work
relationships Supervisor approval required.
Not mandatory. | 25 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day program teaches participants how to handle difficult situations with poise and confidence. Participants discover how to keep unmanaged conflicts, disagreements and out-of-control emotions from harming their important working and personal relationships. Participants learn:

• To practice everyday conflict resolution skills
• To overcome personal stumbling blocks to agreement
• To use conflict as a positive motivator
• How your personality affects the way you deal with conflict
• How to express yourself without accusation, sarcasm or hostility
• Effective strategies for defusing an escalating argument
• How to avoid words that act as emotional triggers when you're dealing with someone who is upset

| Creating a Culture of Trust | Supervisor approval required. Mandatory
for supervisors and above | 25 per class. | 2 days | | :-- | :-- | :-- | :-- |

In this course, managers learn and develop the skills necessary to establish and maintain trust with team members and colleagues. Participants will begin by evaluating their level of trust towards others, identify key behaviors for developing trusting relationships, and learn specific strategies to create increased trust. Through activities, role plays, and group discussions, managers will leave this class better prepared to demonstrate managerial influence and maximize team effectiveness.

| Customer Service
Excellence | Designed to increase customer and
employee satisfaction, enhance
professionalism, and sharpen listening
skills. Available to all employees.
Supervisor approval required. Not
mandatory. | 25 per class. | 2 days | | :-- | :-- | :-- | :-- |

This 2-day interactive training is designed to increase customer and employee satisfaction, enhance professionalism, and sharpen listening skills. After completing this training, participants are able to:

• Work more collaboratively with customers and coworkers to resolve concerns
• Defuse customers' anger and focus them on solutions
• Communicate positively, even negative news
• Personalize service to customers
• Recover quickly after difficult customer interactions
• Increase morale and reduce burnout

| Developing Your Emotional
Intelligence | Learn how to manage ourselves and
others around us through personal
leadership. Available to all employees.
Supervisor approval required. Not
mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

Emotional Intelligence, which is our ability to manage ourselves and others around us-is the single greatest

contributor to personal excellence and leadership. In this session, participants learn and assess how well they are managing their emotions in key relationships. Additionally, participants learn how to leverage emotions for greater purpose and performance in all aspects of their professional life.

| Effective Business
Communications | Participants will learn how to effectively
communicate, both written and orally, in
their daily interactions with co-workers and
customers. Available to all employees.
Supervisor approval required. Not
mandatory. | 25 per class | 2 days | | :-- | :-- | :-- | :-- |

This 2-day class provides essential tools of how to speak and write with skill and polish. At the completion of the course, employees will be able to:

• Communicate clearly, effectively, and efficiently in writing and face-to-face.
• Deliver negative news with diplomacy and professionalism
• Demonstrate techniques to make written communications quick, concise and productive

| Effective Performance
Management | Provides supervisors and above the
theory and tools to most effectively
manage their teams. Supervisor approval
required. Mandatory for supervisors and
above. | 25 per class | 2 days | | :-- | :-- | :-- | :-- |

This 2-day course is designed to provide managers at all levels with the theory and tools to most effectively manage their teams. This course focuses on the philosophy behind performance management and what the manager's role is in this process. Participants will discuss what the Return On Investment is for performance management and review Entergy specific tools used to aid in the Performance Management process. The subject will be further explored by practical application of the concepts through activities such as performance conversation role plays, sample PPR reviews, and role plays dealing with difficult employee reactions.

| Essentials of Budgeting | Participants learn the fundamentals of
budgeting with an emphasis on planning a
reasonable budget and staying within
budget. Supervisor approval required.
Mandatory for supervisors and above. | 25 per class. | 1 day | | :-- | :-- | :-- | :-- |

In this session participants learn the fundamentals of budgeting with an emphasis on planning a reasonable budget and staying within the budget. This course enables participants to be successful by energizing them to help their company and their jobs thrive in the competitive environment.

| Four Generations in the
Workplace | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class. | 1 day | | :-- | :-- | :-- | :-- |

Generational-based conflict in the workplace translates into lost productivity, and has adverse effects on motivation and morale. This program is designed to educate and stimulate positive interaction among team members of all ages. It will also dramatically reduce workplace conflict and provide employees with strategies for working with each other more effectively by using the generational differences in positive ways.

| High Performance Team
Building | Participants will identify their formal and
informal roles on the team and how
personal accountability for results is critical
to team and personal effectiveness.
Available to all employees. Supervisory
approval required. Not mandatory. | 25 per class. | 2 days | | :-- | :-- | :-- | :-- |

This 2-day course focuses on skills needed to affect the success of a team at an individual level. This session offers insight and understanding into the characteristics of high performing teams. Participants will learn about the 5 Elements of a Successful Team, the 4 stages teams go through and as importantly how they personally interact, problem solve and contribute relative to the overall team's dynamic.

| How Entergy Makes
Money | Available to all employees. Mandatory for
supervisors and above. Supervisor
approval required. | 25 per class. | 1.5 days | | :-- | :-- | :-- | :-- |

Teaches the key fundamentals of financial management and applications to both Entergy specific issues and utility markets in general. Participants learn the relationship between key Wall Street benchmarks to those of Entergy's financial and operating performance. Other topics covered include the interpretation of financial statements, asset recovery, financial problem solving, advanced rate making, financial spending strategies, and balance sheet/financial ratio analysis.

| Leadership I (Emerging
Leader Forum) | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 2.5 days | | :-- | :-- | :-- | :-- |

This 2 1/2 day program is a forum for learning about leadership and your role as a leader. You will learn how to become an effective leader, influence those around you more effectively and deal with situations regarding conflict and differences of opinion. Leadership I is designed for individuals who are preparing for a management role and for employees who act in a leadership role on a project or a team. This course is designed to increase awareness of skills, tools, and techniques that can be used today to prepare for future leadership or supervisory roles.

| Leadership II (Advanced
Leader Forum) | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 3 days | | :-- | :-- | :-- | :-- |

This 3-day program will build on and add to the concepts introduced during Leadership I/ Emerging Leader Forum. Participants will learn about leadership through a variety of simulations and exciting experiential activities. Leadership I primarily focuses on impacting the individual follower, while Leadership II focuses on leading to impact a team or group.

| Leadership Foundations | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 2 days | | :-- | :-- | :-- | :-- |

Participants in this workshop will be able to Improve trust and influence with peers and superiors, Link their work to a clear and compelling team purpose, Implement a system for executing on critical priorities and Leverage the talents of peers and co-workers to achieve unprecedented results

| LSU Executive Education
Training | Select managers and above. By invitation
only. | 30 per class | 5 days | | :-- | :-- | :-- | :-- |

Program Objectives:

1. To teach participants how to develop a mindset for strategic thinking and leadership - Transferring their thought and work processes from the tactical to the strategic
2. To expose and educate participants to Systems Thinking.
3. To enhance the interpersonal and strategic effectiveness of our current and future leaders to get business results.
4. Relationship building with other high potential professionals at Entergy
5. To provide new perspective in participant's current positions and take actions differently than one might otherwise.

| Making the Transition into
Management | Mandatory for New supervisors who have
assumed their new role within the past 6
months. Supervisor approval required. | 25 per class | 3 days | | :-- | :-- | :-- | :-- |

Participants will discuss and gain a better understanding on how their role changes in going from an individual contributor to a supervisor or manager and what challenges may lay ahead in their new role. Emphasis will be placed on leadership skills, emotional intelligence, and team and group dynamics.

| Managing Multiple
Projects, Objectives, and
Deadlines | Available to all employees. Supervisor
approval required. Mandatory for
supervisors and above. | 25 per class | 2 days | | :-- | :-- | :-- | :-- | | This 2-day training is designed for the busy employee who juggles deadlines, projects, and multiple demands and
has little time to waste. This class will provide you with organizational skills to help get more accomplished faster
and with better results than ever before. Participants will learn to: | | | | | - Prioritize competing activities for successful completion
- Better organize daily tasks and activities
- Identify and eliminate "time wasters" through the day | | | |

| Managing People Fair,
Square &; Legal | Mandatory for All HR employees and
supervisors and above. Supervisor
approval required. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

The content focuses on managing people in a way that adheres to employment law and treating people in a way that is consistent with our Entergy Shared Values. The workshop is highly interactive and utilizes lecture and case studies to accelerate learning.

| MARC Labor Relations | Supervisors of bargaining employees who
want to enhance labor relations and
standardize supervisory practices.
Supervisor approval required. Mandatory
for Supervisors and above | 25 per class | 3 days | | :-- | :-- | :-- | :-- |

The Management Associated Results Company (MARC) program enables all levels of management to carry out their labor-relations responsibilities with confidence. The methods in this program provide a responsible and a responsive approach for dealing with employment-related issues. It is responsive in that it provides proven tools for the supervisor to use in a hands-on fashion when dealing with the three major areas of:

• Grievance handling
• Job performance improvement counseling
• Administering stepwise discipline or corrective action

| Maximizing Interpersonal
Effectiveness I | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

In this 1-day workshop, participants will learn practical, proven strategies to improve communications skills, interpersonal effectiveness, and stress management in the workplace. Topics covered include:

• Fundamentals of Effective Interpersonal Communication
• Stress and It's Impact
• Workplace Performance &; Emotional/Physical health
• Effective Time Management

Various tools will be utilized to evaluate participants' level of stress, anxiety, and anger, and other behavioral areas in which to improve interpersonal effectiveness. Approximately 2 weeks prior to the workshop, participants will complete a pre-assessment survey to assess their needs relative to interpersonal effectiveness.

| Maximizing Interpersonal
Effectiveness II | Supervisors and above. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

The scope of the challenges to be covered in this 1-day workshop include difficult management-employee relationships, confrontation, communications and the recognition/handling of employees at risk for workplace violence. Special attention will be given to the most difficult management challenges regarding these issues. Approximately 2 weeks prior to the workshop, participants will complete a pre-assessment survey in order to gather information regarding particular problem areas within his/her area.

| Microinequities | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

This workshop This class gets to the DNA of culture change and is the new paradigm for diversity. This program effects major changes in the cultural landscape of organizational diversity by addressing the small, yet powerful, biases communicated in the workplace. It focuses on one of the most hidden barriers to success; the subtle, usually subconscious messages we all send that can devalue, discourage and ultimately impair performance in the workplace at all levels of an organization.

| Microsoft - Excel I | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This course equips employees with the skills necessary to create, edit, format, and print basic worksheets.

| Microsoft - Excel II | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This course is designed for those who already possess a basic knowledge of Excel. This course teaches how to create templates, import and export data, analyze data, and work with Excel on the web. In addition, this course helps prepare students preparing for the Microsoft Office Specialist exam in Excel.

| Negotiation Skills -
Mastering the Art of
Negotiations | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

This workshop teaches stronger negotiating tactics and strategies that will give participants the confidence to negotiate for what you want and need. During this session, participants will learn to:

• Understand the essential elements of negotiations
• PREPARE: The single most important key in negotiation success
• Establish negotiation goals and determine your bottom line
• Handle common haggling tactics
• Overcome those universal negotiation bargaining obstacles
• Negotiating tips to use with long-term vendors &; contractors

| Poised and Powerful Public
Speaking | Available to all employees. Supervisor
approval required. Not mandatory. | 15 per class | 2 days | | :-- | :-- | :-- | :-- |

This course will walk participants through step-by-step principles, methods, and strategies to perfect their speaking skills. This 2-day program is designed to help participants:

• Organize their thoughts into a flawless presentation
• Develop a relationship with the audience
• Develop their own "WINNING" speaking style
• Handle every challenge without missing a beat

| Presentation Skills
(Executive) | Geared towards supervisors and above
who make business presentations.
Supervisor approval required. Not
mandatory. | 15 per class | 2 days | | :-- | :-- | :-- | :-- |

This training is geared toward individuals who make business presentations and would like to enhance their communication skills. In this training, participants learn guaranteed techniques to help them become an effective communicator and presenter. This training is designed to develop skills that make a presentation clear, interesting and effective in leading to action. During this session, participants will learn and practice skills on their feet, organize ideas quickly and logically and deliver them persuasively.

| Project Management
(Technical) | Project managers and team members who
need to acquire additional tools to
effectively manage their people, budgets,
suppliers, and schedules. Supervisor
approval required. Not mandatory. | 25 per class | 2 day | | :-- | :-- | :-- | :-- | | This 2-day training is designed to provide basic yet challenging and inclusive treatment of how to manage
projects. The scope of this training will include project integration, project scope, cost and time allocation, quality,
human resources, communications, procurement (including contracts) and risk assessment and management.
Furthermore, the scope will encompass the widely accepted concepts, tools and techniques within the field of
project management based on The Guide to The Project Management Body of Knowledge (PMBOK) principles. | | | |

| Safety Leadership | Designed to improve employee and
contractor safety. Mandatory for
supervisors and above | 25 per class | $1/2$ day | | :-- | :-- | :-- | :-- |

This $1/2$ day session is designed to provide leaders with the interpersonal skills to assist with improvement of employee and contractor safety. Special attention will be focused on Entergy's 12 Safety Principles:

1. All injuries are preventable
2. People are the most critical element
3. Line organizations are responsible for safety
4. All operating exposures can be controlled
5. Management is responsible for establishing a safe work environment and clear expectations for safety performance
6. Safety is good business
7. Management must audit performance
8. Our work is never so urgent or important that we cannot take time to do it safely
9. Deficiencies must be corrected promptly
10. Employees must be trained to safely perform all assigned tasks and accountable for applying these skills on the job
11. Safety is a condition of employment
12. Off-the-job safety is an important part of overall safety efforts

| Strategic Thinking
Principles | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

Participants will learn to develop operational goals and to select projects that are aligned with Entergy's business strategy. Furthermore, participants will learn the rationale and underlying assumptions for both historic and current strategies within Entergy and the utility industry in general. Case Studies, lecture, team activities, and discussion are very effectively utilized to maximize this learning experience. During this session participants learn:

• The fundamentals of business strategy
• The relevance of strategic thinking to the organization
• The negative consequences of poor strategic thinking
• To align operational goals &; financial measurements with Entergy's business strategy

| Stress Management | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

This session teaches participants practical skills to identify and manage the different sources of stress. As a positive influence, stress can help compel us to action; it can result in a new awareness and an exciting new perspective. As a negative influence, it can result in feelings of distrust, rejection, anger &; depression, which in turn can lead to potential health problems. During this session, participants will learn:

• To identify your particular stressors
• To understand stress and your stressors
• To manage performance stress
• How to reduce co-worker and team stress
• How to build defenses against stress
• How to avoid and/or recover from burnout

• How to take stress out of working relationships
• How to maintain work/life balance
• Simple relaxation techniques that you can do on the job

| Visio Professional - Level I | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class | 1 day | | :-- | :-- | :-- | :-- |

This session teaches participants to:

• Identify the various types of drawings you can create using Visio and navigate in a Visio document. - Drag shapes from Visio stencils and resize, rotate, align, and transform them. - Increase your productivity with smart features, such as numbering shapes automatically, duplicating shapes quickly, and grouping and aligning. Create a flowchart or a cross-functional flowchart. - Create an organization chart manually or generate one from a text file. - Create an office floor plan to scale.

Entergy Corporation Employee Development 2011 Workshops

| Workshop | Target Audience | Target # of
Participants | # of days | | :-- | :-- | :--: | :--: | | Advanced Management
Program | Select managers and above. By invitation
only. | 45 per class | 5 days |

Applying Strategic Thinking to Employee Actions | Supervisor approval required. Mandatory for supervisors and above. | 30 per class | 1 days | | :--: | :--: | :--: | :--: |

Participants will learn to develop business strategies for both departments and functions at Entergy and will develop a working knowledge of scenario planning. Also, through in depth case study analysis, participants will evaluate the lessons learned from both the successful and unsuccessful strategic initiatives of utility based companies. The evaluation of case studies, lecture, team activities, and discussion are effectively utilized to maximize this learning experience.

| Behavioral Interviewing | Supervisor approval required. Mandatory
for supervisors and above with hiring
authority. | 30 per class | 2 days | | :-- | :-- | :-- | :-- |

During this two day workshop participants learn a new way to hire that will provide them with a set of skills to more accurately select the right candidate for the job at all levels (craft, non-exempt, and exempt level positions). By employing Behavioral interviewing techniques, participants ensure that our company interviews applicants, in an effective, consistent, and legally defensible manner.

During this session the participant will learn:

• How to select the right person: Planning for the success of both the candidate and the organization.
• The Behavioral Interviewing approach: Illustrating the importance of gaining behavioral examples to predict performance versus reliance on gut feelings.
• To plan for Selection: Determining both the job-specific and organizational needs for a candidate and the appropriate methods for prescreening and interviewing.
• To conduct the Interview: Practicing skills to conduct a legally defensible interview.
• To sell both Entergy and the Opportunity: Emphasizing the importance of promoting the job and the opportunity to attract the best candidates.
• To make the Decision: Rating job skills objectively (from entry level apprentice to management level openings) to make informed hiring decisions.

| Building Your Business
Case: Getting Your Project
Approved | Supervisor approval required. Mandatory
for supervisors and above. | 30 per class | 1.5 days | | :-- | :-- | :-- | :-- | | Participants will learn more in depth financial analysis techniques and business case analysis techniques utilized
by electric companies today. Furthermore, participants will learn to stay within budget constraints while selecting
projects and options that will create the greatest value to Entergy. During this high impact workshop, participants
will be exposed to various project evaluation models, the impact of Capital/O&;M expenditures to earnings per
share, key measurements, and how to present projects to senior management. | | | |

| Career Planning: | Available to all employees. Supervisor

Positioning Yourself for | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

| Advancement | | | | | :-- | :-- | :-- | :-- |

This workshop will help participants learn how to:

• Identify and implement preparation strategies that will position them for greater responsibility
• Effectively identify their personal strengths and areas of needed improvement for career advancement
• Effectively position themselves as the best candidate in highly competitive promotional opportunities
• The workshop includes self-assessment activities, one-on-one coaching, and role-play oriented interviews. Activities are designed to help participants identify their strengths and weaknesses and to be better prepared to seize promotional opportunities in their future.

| Coaching for Outstanding
Job Performance | Supervisor approval required. Mandatory
for supervisors and above. | 25 per class | 2 days | | :-- | :-- | :-- | :-- |

In this 2-day course, supervisors and managers learn how to keep their employee's productivity up through effective coaching. Participants discover the essential components of coaching for performance management as well as how to customize coaching styles for individual employees. Through role plays and case studies, participants leave this course with an understanding of the step by step approach to coaching and are able to implement the concepts learned in their own working environments.

| Communicating Up, Down,
and Across the
Organization | Available to all employees. Supervisor
approval required. Mandatory for
supervisors and above. | 25 per class. | 2 days | | :-- | :-- | :-- | :-- |

This 2-day course will enable participants to break down the cross organizational barriers and have their voice heard. Participants learn to use listening and communication skills to create high impact messages. They also learn techniques to communicate ideas and projects for the listening audience.

| Conflict Management | Teaches how to handle difficult situations;
how to keep conflicts, disagreements, and
emotions from harming important work
relationships Supervisor approval required.
Not mandatory. | 25 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day program teaches participants how to handle difficult situations with poise and confidence. Participants discover how to keep unmanaged conflicts, disagreements and out-of-control emotions from harming their important working and personal relationships. Participants learn:

• To practice everyday conflict resolution skills
• To overcome personal stumbling blocks to agreement
• To use conflict as a positive motivator
• How your personality affects the way you deal with conflict
• How to express yourself without accusation, sarcasm or hostility
• Effective strategies for defusing an escalating argument
• How to avoid words that act as emotional triggers when you're dealing with someone who is upset

| Creating a Culture of Trust | Supervisor approval required. Mandatory
for supervisors and above | 25 per class. | 2 days | | :-- | :-- | :-- | :-- |

In this course, managers learn and develop the skills necessary to establish and maintain trust with team members and colleagues. Participants will begin by evaluating their level of trust towards others, identify key behaviors for developing trusting relationships, and learn specific strategies to create increased trust. Through activities, role plays, and group discussions, managers will leave this class better prepared to demonstrate managerial influence and maximize team effectiveness.

| Customer Experience | Designed to increase customer and | 25 per class. | 2 days | | :-- | :-- | :-- | :-- |

| Training | employee satisfaction, enhance professionalism, and sharpen listening skills. Available to all employees. Supervisor approval required. Not mandatory. | | | | :--: | :--: | :--: | :--: | | This 2-day interactive training is designed to increase customer and employee satisfaction, enhance professionalism, and sharpen listening skills. After completing this training, participants are able to:
- Work more collaboratively with customers and coworkers to resolve concerns
- Defuse customers' anger and focus them on solutions
- Communicate positively, even negative news
- Personalize service to customers
- Recover quickly after difficult customer interactions
- Increase morale and reduce burnout | | | | | Developing Your Emotional Intelligence | Learn how to manage ourselves and others around us through personal leadership. Available to all employees. Supervisor approval required. Not mandatory. | 25 per class | 1 day | | Emotional Intelligence, which is our ability to manage ourselves and others around us-is the single greatest contributor to personal excellence and leadership. In this session, participants learn and assess how well they are managing their emotions in key relationships. Additionally, participants learn how to leverage emotions for greater purpose and performance in all aspects of their professional life. | | | | | Effective Business Communications | Participants will learn how to effectively communicate, both written and orally, in their daily interactions with co-workers and customers. Available to all employees. Supervisor approval required. Not mandatory. | 25 per class | 2 days | | This 2-day class provides essential tools of how to speak and write with skill and polish. At the completion of the course, employees will be able to:
- Communicate clearly, effectively, and efficiently in writing and face-to-face.
- Deliver negative news with diplomacy and professionalism
- Demonstrate techniques to make written communications quick, concise and productive | | | | | Effective Performance Management | Provides supervisors and above the theory and tools to most effectively manage their teams. Supervisor approval required. Mandatory for supervisors and above. | 25 per class | 2 days | | This 2-day course is designed to provide managers at all levels with the theory and tools to most effectively manage their teams. This course focuses on the philosophy behind performance management and what the manager's role is in this process. Participants will discuss what the Return On Investment is for performance management and review Entergy specific tools used to aid in the Performance Management process. The subject will be further explored by practical application of the concepts through activities such as performance conversation role plays, sample PPR reviews, and role plays dealing with difficult employee reactions. | | | |

| Essentials of Budgeting | Participants learn the fundamentals of
budgeting with an emphasis on planning a
reasonable budget and staying within
budget. Supervisor approval required.
Mandatory for supervisors and above. | 25 per class. | 1 day | | :-- | :-- | :-- | :-- | | In this session participants learn the fundamentals of budgeting with an emphasis on planning a reasonable
budget and staying within the budget. This course enables participants to be successful by energizing them to
help their company and their jobs thrive in the competitive environment. | | | | | Four Generations in the
Workplace | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class. | 1 day | | Generational-based conflict in the workplace translates into lost productivity, and has adverse effects on
motivation and morale. This program is designed to educate and stimulate positive interaction among team
members of all ages. It will also dramatically reduce workplace conflict and provide employees with strategies for
working with each other more effectively by using the generational differences in positive ways. | | | |

| High Performance Team
Building | Participants will identify their formal and
informal roles on the team and how
personal accountability for results is critical
to team and personal effectiveness.
Available to all employees. Supervisory
approval required. Not mandatory. | 25 per class. | 2 days | | :-- | :-- | :-- | :-- | | This 2-day course focuses on skills needed to affect the success of a team at an individual level. This session
offers insight and understanding into the characteristics of high performing teams. Participants will learn about the
5 Elements of a Successful Team, the 4 stages teams go through and as importantly how they personally interact,
problem solve and contribute relative to the overall team's dynamic. | | | |

| How Entergy Makes
Money | Available to all employees. Mandatory for
supervisors and above. Supervisor
approval required. | 25 per class. | 1.5 days | | :-- | :-- | :-- | :-- | | Teaches the key fundamentals of financial management and applications to both Entergy specific issues and
utility markets in general. Participants learn the relationship between key Wall Street benchmarks to those of
Entergy's financial and operating performance. Other topics covered include the interpretation of financial
statements, asset recovery, financial problem solving, advanced rate making, financial spending strategies, and
balance sheet/financial ratio analysis. | | | |

| Leadership I (Emerging
Leader Forum) | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 2.5 days | | :-- | :-- | :-- | :-- | | This 2 1/2 day program is a forum for learning about leadership and your role as a leader. You will learn how to
become an effective leader, influence those around you more effectively and deal with situations regarding conflict
and differences of opinion. Leadership I is designed for individuals who are preparing for a management role and
for employees who act in a leadership role on a project or a team. This course is designed to increase awareness
of skills, tools, and techniques that can be used today to prepare for future leadership or supervisory roles. | | | |

| Leadership II (Advanced
Leader Forum) | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 3 days | | :-- | :-- | :-- | :-- | | This 3-day program will build on and add to the concepts introduced during Leadership I/ Emerging Leader Forum.
Participants will learn about leadership through a variety of simulations and exciting experiential activities.
Leadership I primarily focuses on impacting the individual follower, while Leadership II focuses on leading to
impact a team or group. | | | |

| Leadership Foundations | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 2 days | | :-- | :-- | :-- | :-- |

Participants in this workshop will be able to Improve trust and influence with peers and superiors, Link their work to a clear and compelling team purpose, Implement a system for executing on critical priorities and Leverage the talents of peers and co-workers to achieve unprecedented results

| LSU Executive Education
Training | Select managers and above. By invitation
only. | 30 per class | 5 days | | :-- | :-- | :-- | :-- |

Program Objectives:

1. To teach participants how to develop a mindset for strategic thinking and leadership - Transferring their thought and work processes from the tactical to the strategic
2. To expose and educate participants to Systems Thinking.
3. To enhance the interpersonal and strategic effectiveness of our current and future leaders to get business results.
4. Relationship building with other high potential professionals at Entergy
5. To provide new perspective in participant's current positions and take actions differently than one might otherwise.

| Making the Transition into
Management | Mandatory for New supervisors who have
assumed their new role within the past 6
months. Supervisor approval required. | 25 per class | 3 days | | :-- | :-- | :-- | :-- |

Participants will discuss and gain a better understanding on how their role changes in going from an individual contributor to a supervisor or manager and what challenges may lay ahead in their new role. Emphasis will be placed on leadership skills, emotional intelligence, and team and group dynamics.

| Managing Multiple
Projects, Objectives, and
Deadlines | Available to all employees. Supervisor
approval required. Mandatory for
supervisors and above. | 25 per class | 2 days | | :-- | :-- | :-- | :-- |

This 2-day training is designed for the busy employee who juggles deadlines, projects, and multiple demands and has little time to waste. This class will provide you with organizational skills to help get more accomplished faster and with better results than ever before. Participants will learn to:

• Prioritize competing activities for successful completion
• Better organize daily tasks and activities
• Identify and eliminate "time wasters" through the day

| Managing People Fair,
Square &; Legal | Mandatory for All HR employees and
supervisors and above. Supervisor
approval required. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

The content focuses on managing people in a way that adheres to employment law and treating people in a way that is consistent with our Entergy Shared Values. The workshop is highly interactive and utilizes lecture and case studies to accelerate learning.

| MARC Labor Relations | Supervisors of bargaining employees who
want to enhance labor relations and
standardize supervisory practices.
Supervisor approval required. Mandatory
for Supervisors and above | 25 per class | 3 days | | :-- | :-- | :-- | :-- |

The Management Associated Results Company (MARC) program enables all levels of management to carry out their labor-relations responsibilities with confidence. The methods in this program provide a responsible and a responsive approach for dealing with employment-related issues. It is responsive in that it provides proven tools for the supervisor to use in a hands-on fashion when dealing with the three major areas of:

• Grievance handling
• Job performance improvement counseling
• Administering stepwise discipline or corrective action

| Maximizing Interpersonal
Effectiveness I | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

In this 1-day workshop, participants will learn practical, proven strategies to improve communications skills, interpersonal effectiveness, and stress management in the workplace. Topics covered include:

• Fundamentals of Effective Interpersonal Communication
• Stress and It's Impact
• Workplace Performance &; Emotional/Physical health
• Effective Time Management

Various tools will be utilized to evaluate participants' level of stress, anxiety, and anger, and other behavioral areas in which to improve interpersonal effectiveness. Approximately 2 weeks prior to the workshop, participants will complete a pre-assessment survey to assess their needs relative to interpersonal effectiveness.

| Microinequities | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

This workshop This class gets to the DNA of culture change and is the new paradigm for diversity. This program effects major changes in the cultural landscape of organizational diversity by addressing the small, yet powerful, biases communicated in the workplace. It focuses on one of the most hidden barriers to success; the subtle, usually subconscious messages we all send that can devalue, discourage and ultimately impair performance in the workplace at all levels of an organization.

| Microsoft - Access I | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 2 day | | :-- | :-- | :-- | :-- |

This 2-day course is designed for individuals who wish to learn the basic and intermediate-level operations of the Microsoft Access Database program to perform their day to day responsibilities, and to understand the advantages that using a relational database program can bring to their business processes. Participants will learn how to design and create a new Access database.

| Microsoft - Access II | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 2 day | | :-- | :-- | :-- | :-- |

This 2-day course is designed for individuals who wish to learn intermediate and advanced operations of the Microsoft Access Database program. In this course, participants will extend their knowledge into some of the more specialized and advanced capabilities.

| Microsoft - Access III | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for individuals who have a thorough understanding of the basic and advanced user features of Microsoft Office Access and are interested in learning introductory level administrator skill sets. This course is also for individuals who may be working in a web-based environment and may need to adapt Access applications to the environment.

| Microsoft - Excel I | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This course equips employees with the skills necessary to create, edit, format, and print basic worksheets.

| Microsoft - Excel II | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This course is designed for those who already possess a basic knowledge of Excel. This course teaches how to create templates, import and export data, analyze data, and work with Excel on the web. In addition, this course

helps prepare students preparing for the Microsoft Office Specialist exam in Excel.

| Microsoft - Excel III | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for students desiring to gain the skills necessary to create macros, collaborate with others, audit and analyze worksheet data, create PivotTables and PivotCharts, incorporate multiple data sources, and import and export data

| Microsoft - PowerPoint II | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for individuals who want to gain the skills necessary to work with design templates, various types of diagrams, special effects, custom slide shows, collaboration functionality, and advanced presentation delivery.

| Microsoft - Project I | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for individuals who have an understanding of project management concepts, who are responsible for creating and modifying project plans, and who need a tool to manage these project plans.

| Microsoft - Project II | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for individuals who have an understanding of project management concepts, who are responsible for creating and modifying project plans, and who need a tool to manage these project plans.

| Microsoft - Word II | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for individuals who can create and modify standard business documents in Microsoft Word 2007 and who need to learn to use Microsoft Word 2007 to create and modify complex business documents as well as customized Word efficiency tools.

| Microsoft - Word III | Available to all employees. Supervisor
approval required. Not mandatory. | 10 per class. | 1 day | | :-- | :-- | :-- | :-- |

This 1-day course is designed for individuals who want to gain skills necessary to manage long documents, collaborate with others, and secure documents. Participants in this course will learn how to use Word to create, manage, revise, and distribute long documents/forms.

| Negotiation Skills Mastering the Art of Negotiations | Available to all employees. Supervisor approval required. Not mandatory. | 25 per class | 1 day | | :--: | :--: | :--: | :--: |

This workshop teaches stronger negotiating tactics and strategies that will give participants the confidence to negotiate for what you want and need. During this session, participants will learn to:

• Understand the essential elements of negotiations
• PREPARE: The single most important key in negotiation success
• Establish negotiation goals and determine your bottom line
• Handle common haggling tactics
• Overcome those universal negotiation bargaining obstacles
• Negotiating tips to use with long-term vendors &; contractors

| Poised and Powerful Public
Speaking | Available to all employees. Supervisor
approval required. Not mandatory. | 15 per class | 2 days | | :-- | :-- | :-- | :-- | | This course will walk participants through step-by-step principles, methods, and strategies to perfect their
speaking skills. This 2-day program is designed to help participants: | | | | | - Organize their thoughts into a flawless presentation
- Develop a relationship with the audience
- Develop their own "WINNING" speaking style
- Handle every challenge without missing a beat | | | |

| Project Management
(Technical) | Project managers and team members who
need to acquire additional tools to
effectively manage their people, budgets,
suppliers, and schedules. Supervisor
approval required. Not mandatory. | 25 per class | 2 day | | :-- | :-- | :-- | :-- |

This 2-day training is designed to provide basic yet challenging and inclusive treatment of how to manage projects. The scope of this training will include project integration, project scope, cost and time allocation, quality, human resources, communications, procurement (including contracts) and risk assessment and management. Furthermore, the scope will encompass the widely accepted concepts, tools and techniques within the field of project management based on The Guide to The Project Management Body of Knowledge (PMBOK) principles.

| Safety Leadership | Designed to improve employee and
contractor safety. Mandatory for
supervisors and above | 25 per class | $1/2$ day | | :-- | :-- | :-- | :-- |

This $1/2$ day session is designed to provide leaders with the interpersonal skills to assist with improvement of employee and contractor safety. Special attention will be focused on Entergy's 12 Safety Principles:

1. All injuries are preventable
2. People are the most critical element
3. Line organizations are responsible for safety
4. All operating exposures can be controlled
5. Management is responsible for establishing a safe work environment and clear expectations for safety performance
6. Safety is good business
7. Management must audit performance
8. Our work is never so urgent or important that we cannot take time to do it safely
9. Deficiencies must be corrected promptly
10. Employees must be trained to safely perform all assigned tasks and accountable for applying these skills on the job
11. Safety is a condition of employment
12. Off-the-job safety is an important part of overall safety efforts

| Strategic Thinking
Principles | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 1 day | | :-- | :-- | :-- | :-- |

Participants will learn to develop operational goals and to select projects that are aligned with Entergy's business strategy. Furthermore, participants will learn the rationale and underlying assumptions for both historic and current strategies within Entergy and the utility industry in general. Case Studies, lecture, team activities, and discussion are very effectively utilized to maximize this learning experience. During this session participants learn:

• The fundamentals of business strategy
• The relevance of strategic thinking to the organization
• The negative consequences of poor strategic thinking
• To align operational goals &; financial measurements with Entergy's business strategy

| Utility Ratemaking | Available to all employees. Supervisor
approval required. Not mandatory. | 25 per class | 2 days | | :-- | :-- | :-- | :-- | | Participants will gain an understanding of all the key concepts important to utility employees at all levels.
Participants will learn about:
- Rate Case Basics
- Ratemaking Issues
- Rate Case Financial Concepts
- Utility Spending Strategies
- State Commission Rules | | | |

ENTERGY SYSTEM POLICIES &; PROCEDURES

Page 1 of 9

| Title: EDUCATIONAL REIMBURSEMENT PROGRAM | | | Last Revision: 9/14/2009 | Rev. 1 | | :--: | :--: | :--: | :--: | :--: | | Subject Matter Expert:
Danielle Lombard-Sims | Responsible Officer: Terry Seamons | Approved By:
Corporate Compliance Committee | | |

I. POLICY SUMMARY

• Eligible Employees can apply for reimbursement for approved Eligible Courses.
• All Eligible Employees must receive written course approval from appropriate management as specified in this Policy and then subsequently from the HRSC to be eligible for reimbursement.
• Upon successful completion of each approved Eligible Course, the employee will be reimbursed for the following expenses up to a maximum annual reimbursement of $\backslash$ 5,250$ :
• Registration fees at $100\%$ for a grade of $C$ or better;
• Tuition, required book costs, and required course fees according to the following schedule:
• $A=100\%$ ;
• $B=90\%$ ;
• $C=80\%$ ;
• D, F, or Withdrawal $=0\%$ ; and
• Courses which are only Pass/Fail will be reimbursed at $100\%$ for a passing grade.
• Courses that do not provide a grade will be reimbursed at $100\%$ with a certification of completion from the organization providing the course.
• All Entergy employees shall immediately report known, suspected or potential violations of this Policy by following the procedures described in the Reporting Violations policy.
• Entergy is an equal opportunity employer that promotes the development of all employees and encourages each individual to achieve as much success as their talents and initiative will allow.
• Please refer to the following detailed Policy for further information.

ENTERGY SYSTEM POLICIES &; PROCEDURES

Page 2 of 9

| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

II. DETAILED POLICY

1.0 PURPOSE AND APPLICABILITY

The purpose of the Educational Reimbursement Program is to encourage Eligible Employees to seek self-improvement and development. This Policy provides specific information necessary for employees to obtain course approval and reimbursement for completed course work. Entergy will reimburse expenses of Eligible Employees who undertake approved outside study that enables them to improve their skill set and qualifications in their present positions or would lead to degrees received from Accredited institutions where such degrees are considered to be of value to Entergy.

THIS POLICY APPLIES TO ANY AND ALL EMPLOYEES OF ANY ENTERGY SYSTEM COMPANY, UNLESS OTHERWISE EXPRESSLY EXCLUDED.

THE EXTENT TO WHICH ANY SPECIFIC PROVISION IN THIS POLICY COVERS EMPLOYEES WHO ARE REPRESENTED BY A UNION MAY DEPEND ON NEGOTIATIONS WITH AND/OR A COLLECTIVE BARGAINING AGREEMENT WITH THAT UNION.

NOTHING CONTAINED IN THIS POLICY SHOULD BE CONSTRUED TO SUGGEST THAT EMPLOYEES OF A PARTICULAR SUBSIDIARY OR AFFILIATE OF ENTERGY CORPORATION ARE ALSO EMPLOYEES OF ENTERGY CORPORATION OR ANY OTHER AFFILIATE OR SUBSIDIARY OF ENTERGY CORPORATION. MOREOVER, THIS POLICY DOES NOT CREATE ANY EMPLOYMENT RELATIONSHIP BETWEEN ANY PERSON AND ANY ENTERGY SYSTEM COMPANY, NOR DOES THIS POLICY CONFER ANY CONTRACTUAL RIGHT TO ANY PERSON TO BECOME OR REMAIN AN EMPLOYEE OF ANY ENTERGY SYSTEM COMPANY.

2.0 REFERENCES AND CROSS REFERENCES

2.1 Entergy System Policies and Procedures:

• Reimbursement of Business Expenses
• Reporting Violations 2.2 U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs

2.3 EntergyNET - Human Resources Forms

• Course Approval and Reimbursement Form
• Student Worksheet

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

3.0 DEFINITIONS

3.1 Accredited means the status granted by the United States Department of Education to a qualified institution of higher learning, and includes the following requirements:

• such status has been in effect for at least one year; and
• the institution must appear in the US Department of Education's Database of Accredited Programs and Institutions (please reference Section 2.2 of this Policy or the Employee Development Website). 3.2 Eligible Courses are those courses described in Section 5.1 that are not ineligible under Section 5.2. 3.3 Eligible Employee is defined as a regular, active, full-time employee. Eligibility to begin the course approval process using the requirements of Policy Section 6.1 (which must occur prior to course enrollment in order to qualify for reimbursement per Section 5.3) begins upon date of hire. 3.4 Entergy, Entergy System Company, or Company is defined as Entergy Corporation and all of its subsidiaries and affiliates in which Entergy Corporation has a direct or indirect majority ownership interest. 3.5 Policy is defined as this Educational Reimbursement Program policy.

4.0 RESPONSIBILITY

4.1 Entergy Management is responsible for ensuring that courses and degree programs relate directly to the Eligible Employee's job or are an appropriate future investment for the Company and for the Eligible Employees that they directly supervise. They are also responsible for approving reimbursements covered by this Policy. 4.2 The Director, Talent Management and Inclusion is responsible for interpretation of this Policy. 4.3 The Director, Total Rewards is responsible for administering this Policy. 4.4 The Senior Vice President, Human Resources &; Administration is responsible for approving any deviations from this Policy. 4.5 All Entergy employees shall immediately report known, suspected or potential violations of this Policy by following the procedures described in the Reporting Violations policy.

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

5.1 Eligible Courses. The following courses are Eligible Courses if (a) they either enable Eligible Employees to meet the qualifications for positions within Entergy or enable them to improve their skills set or qualifications in their present positions and (b) any further conditions specified below are satisfied. 5.1.1 Eligible Undergraduate Courses are Accredited college degree programs, Accredited college level courses, and courses offered by area vocational and technical institutions. 5.1.2 Eligible Graduate Level Courses are courses in masters programs offered by Accredited institutions. Such programs include the Master of Science in Electrical Engineering and the Master of Business Administration, including an Executive Master of Business Administration (EMBA). For information regarding PhD and JD level courses, please refer to Sections 5.1.8 and 5.1.9.

The EMBA program, as referred to in this Policy, is different from the Entergy-sponsored EMBA program, which is not covered by this Policy. For information on the Entergy-sponsored EMBA program contact Employee Development or refer to the EntergyNet's Employee Development page. 5.1.3 Distance Learning Courses (including correspondence courses) are courses within graduate and undergraduate programs offered by Accredited institutions. In order to be eligible under Section 5.1, distance learning programs must be included in the U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs, referenced at Section 2.2 of this Policy and at the Employee Development website. 5.1.4 Preparatory Courses in preparation for professional certification examinations (as noted in section 5.1.5). 5.1.5 Professional Exams such as the Certified Public Accountant exam, Professional Engineer Certification, State Bar exam, etc., are eligible provided they are needed to obtain or maintain a professional license and such license is required in the performance of the Eligible Employee's current job classification responsibilities. 5.1.6 College Level Examination Programs (CLEP) if the examination applies to fulfilling requirements of a degree program. 5.1.7 "Credit for Life Experiences" if approved by the school in question and if it applies to fulfilling requirements of a degree program. 5.1.8 Law Degree Courses - Costs associated with courses within a law degree curriculum are eligible for educational assistance. Law courses are eligible

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

only if the course relates directly to the Eligible Employee's job responsibilities at the time of enrollment in the course. 5.1.9 Ph.D. Programs Courses - Costs associated with courses within a Ph.D. program are eligible for educational assistance. Ph.D. courses are eligible only if the course relates directly to the Eligible Employee's job responsibilities at the time of enrollment in the course.

5.2 Ineligible Courses and Expenses

5.2.1 Conferences, Seminars and Workshops - Reimbursement under this Policy does not cover the costs of conferences, seminars, workshops, and other non-credit courses such as computer software courses. Refer to Entergy System Policies and Procedures, Reimbursement of Business Expenses, for guidance. 5.2.2 Ineligible Expenses - Late charges, travel expenses, graduation fees, instruments, computers, finance charges, ID cards, parking expenses, insurance fees and auto decal fees are not eligible for reimbursement under this Policy. Costs related to preparing and/or sitting for educationprogram admission examinations (e.g., GMAT, LSAT) are also ineligible for reimbursement.

5.3 Conditions for Reimbursement

Approval to enroll in an Eligible Course must be obtained prior to enrollment, following the process specified in Section 6.1, in order to qualify for reimbursement under this Policy. The maximum reimbursement of allowable expenses is $\backslash$ 5,250$ per calendar year (Note: This maximum allowable amount takes into consideration IRS implications). These expenses must be reimbursed in either the year they occurred or the following year only. In order for costs to be reflected in a particular year, employees must follow end-of-year expense recording protocols specified by the Finance Operations Center. Department charge codes are required for course approval and can be obtained from the Eligible Employee's business unit budget coordinator. Upon completion of each approved Eligible Course, the employee will be reimbursed for the following expenses, subject to Section 5.5 and the annual limit: 5.3.1 Registration Fees - 100\% of registration fees not tied to specific courses, if all semester grades are C or better. 5.3.2 Tuition, Required Book Costs, and Required Course Fees - No reimbursement will be allowed for any expenses related to a course from which an employee has withdrawn or received a grade below C. Tuition, required book costs, and required course fees will be reimbursed according to the following schedule:

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

$A=100\%;$ $B=90\%;$ $C=80\%$ ; and Courses that are only Pass/Fail will be reimbursed at $100\%$ for a passing grade. Courses that do not provide a grade will be reimbursed at $100\%$ with a certificate of completion from the organization providing the course. 5.3.3 Preparatory Courses/Professional Exams - Preparatory courses for professional exams are subject to the same approval requirements as other courses eligible for reimbursement under this policy and will only be paid one time; the cost for sitting for professional exams may be paid up to two times during the employee's tenure with Entergy. Fees for the preparatory courses and professional exams will be paid at $100\%$ , but only after the exam has been successfully completed. 5.3.4 CLEP Exams - Successfully completed CLEP exams are reimbursed at $100\%$ when the exam is taken to fulfill requirements of a degree program. 5.3.5 "Credit for Life Experiences" - "Credit for Life Experiences" is reimbursed at $100\%$ when applied toward a degree program. 5.3.6 Compensation Under Another Program - If the employee received compensation under any other program (e.g., the Veterans Readjustment Benefits Act), only those expenses in excess of the total compensation received will be considered under this Policy. 5.4 Class Attendance - Time necessary for attending classes or completing distance learning courses shall be during the employee's off-duty hours. Class attendance and study time cannot interfere with job responsibilities, including any necessary travel or emergency and overtime work.

5.5 Resignation, Discharge or Termination

5.5.1 If an employee resigns or is discharged for cause prior to the completion of approved Eligible Course work, reimbursement will not be made. However, if an employee is terminated due to a reduction in work force (not including Voluntary Severance), reimbursement will be made (per Section 5.3) for any approved Eligible Course(s) underway at the time of notification of termination if the course(s) is/are successfully completed. 5.5.2 All Eligible Employees entering a JD or PhD program will be required to submit a repayment agreement during the tuition approval process. If an employee voluntarily resigns from Entergy within three years after

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

completion of a JD or PhD program course, the employee agrees to pay to Entergy 100\% of the total reimbursement for costs associated with the course. 5.6 Equal Opportunity Employer - Entergy is an equal opportunity employer that promotes the development of all employees and encourages each individual to achieve as much success as their talents and initiative will allow.

6.0 PROCEDURES

6.1 Course Approval Process

6.1.1 Discuss with Immediate Supervisor - An Eligible Employee desiring to apply for educational assistance should contact his or her immediate supervisor to discuss the proposed course(s) and to establish the potential benefits to the Eligible Employee and Entergy. 6.1.2 Request for Educational Assistance: Course Approval and Reimbursement Form - The Eligible Employee should complete the Request for Course Approval section of the Course Approval and Reimbursement Form (Refer to Section 2.3) and seek the immediate supervisor's written approval thereon; see Section 6.1.4 regarding approval. If an employee changes schools, degrees, certifications, or majors, a new application must be submitted. 6.1.3 Non-Degree or Non-Certification Courses - Employees enrolled in courses not leading to specific degrees or certifications must gain approval for each enrollment. 6.1.4 Approvals - Approval is required for all courses, degree programs or certification programs. 6.1.4.1 The Eligible Employee's immediate supervisor reviews the Request for Course Approval section of the Course Approval and Reimbursement Form (Refer to Section 2.3), and approves the request in writing or denies the request. 6.1.4.2 Courses within JD and PhD programs require further approval by a member of System Management Levels 1 through 4 within the Eligible Employee's chain of command. Further, JD and PhD course approval requests must include additional documentation, in a format specified by Human Resources, where employee and his/her management describe how the JD or PhD course will relate directly to the employee's job responsibilities at the time of enrollment in the course and the anticipated benefits to Entergy. Finally, JD and PhD program courses also require approval by the Senior Vice President, Human Resources &; Administration.

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

6.1.5 Forward Completed Request for Educational Assistance: Course Approval Section - The Request for Course Approval Section of the Course Approval and Reimbursement Form (Refer to Section 2.3) is then forwarded to the Human Resources Service Center for review to ensure that Policy requirements are met. The Human Resources Service Center will approve the request if all Policy conditions have been met. Eligible Employees should not attend a course/class until they have received approval from the Human Resources Service Center. If an Eligible Employee begins a course/class before receiving approval, their reimbursement request may be denied. 6.1.6 Approval Notification - The Human Resources Service Center will return the original approved form to the requesting Eligible Employee as notification to proceed with enrollment.

6.2 Reimbursement Request Process

6.2.1 Completion of Approved Course/Reimbursement - Upon successful completion of an approved course, the employee must complete the Request for Reimbursement section of the Course Approval and Reimbursement Form (Refer to Section 2.3) and have it approved by his/her supervisor. The employee must use the Student Worksheet (Refer to Section 2.3) to calculate reimbursable cost and review the worksheet with his/her immediate supervisor. 6.2.2 Reimbursement Approval - The employee's immediate supervisor will review the request for reimbursement. If all conditions of this Policy have been met, the immediate supervisor will approve the reimbursement. The immediate supervisor approving the reimbursement must ensure that all the original statements or receipts are included with the supporting documentation. This is necessary to prevent reuse of statements or receipts and duplicate reimbursements to the employee. The employee sends the approved form and worksheet (Refer to Section 2.3) and the following items to the Accounts Payable Department for reimbursement. This reimbursement should not be processed through the Expense Account Reporting Log System (EARL). 6.2.2.1 An original statement or certificate showing that the employee has successfully completed the course(s) with a satisfactory grade(s) which shows the final credit hours earned; and 6.2.2.2 Original paid statements or receipts documenting total costs for tuition, books, and fees for each course. 6.2.3 Reimbursement Check - Accounts Payable will send the reimbursement check directly to the employee.

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 9/14/2009 | Rev. 1 | | :-- | :-- | :-- | :-- |

7.0 ATTACHMENTS

None Note: Consult the HR Forms Web site (Referenced at Section 2.3) to access Course Approval and Reimbursement Form and Student Worksheet Form referenced in this policy.

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: EDUCATIONAL REIMBURSEMENT | | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- | :-- | | PROGRAM | | Approved By: | | | Subject Matter Expert: | Responsible Officer: | | | | Danielle Lombard-Sims | Renae Conley | Corporate Compliance Committee | |

I. POLICY SUMMARY

• Eligible Employees can apply for reimbursement for approved Eligible Courses.
• All Eligible Employees must receive written course approval from appropriate management as specified in this Policy and then subsequently from the HRSC to be eligible for reimbursement.
• Upon successful completion of each approved Eligible Course, the employee will be reimbursed for the following expenses up to a maximum annual reimbursement of $\backslash$ 5,250$ :
• Registration fees at $100\%$ for a grade of C or better;
• Tuition, required book costs, and required course fees according to the following schedule:
• $A=100\%$ ;
• $B=90\%$ ;
• $C=80\%$ ;
• D, F, or Withdrawal $=0\%$ ; and
• Courses which are only Pass/Fail will be reimbursed at $100\%$ for a passing grade.
• Courses that do not provide a grade will be reimbursed at $100\%$ with a certification of completion from the organization providing the course.
• All Entergy employees shall immediately report known, suspected or potential violations of this Policy by following the procedures described in the Reporting Violations policy.
• Entergy is an equal opportunity employer that promotes the development of all employees and encourages each individual to achieve as much success as their talents and initiative will allow.
• Please refer to the following detailed Policy for further information.

ENTERGY SYSTEM POLICIES &; PROCEDURES

Page 2 of 9

| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- | :-- |

II. DETAILED POLICY

1.0 PURPOSE AND APPLICABILITY

The purpose of the Educational Reimbursement Program is to encourage Eligible Employees to seek self-improvement and development. This Policy provides specific information necessary for employees to obtain course approval and reimbursement for completed course work. Entergy will reimburse expenses of Eligible Employees who undertake approved outside study that enables them to improve their skill set and qualifications in their present positions or would lead to degrees received from Accredited institutions where such degrees are considered to be of value to Entergy.

THIS POLICY APPLIES TO ANY AND ALL EMPLOYEES OF ANY ENTERGY SYSTEM COMPANY, UNLESS OTHERWISE EXPRESSLY EXCLUDED.

THE EXTENT TO WHICH ANY SPECIFIC PROVISION IN THIS POLICY COVERS EMPLOYEES WHO ARE REPRESENTED BY A UNION MAY DEPEND ON NEGOTIATIONS WITH AND/OR A COLLECTIVE BARGAINING AGREEMENT WITH THAT UNION.

NOTHING CONTAINED IN THIS POLICY SHOULD BE CONSTRUED TO SUGGEST THAT EMPLOYEES OF A PARTICULAR SUBSIDIARY OR AFFILIATE OF ENTERGY CORPORATION ARE ALSO EMPLOYEES OF ENTERGY CORPORATION OR ANY OTHER AFFILIATE OR SUBSIDIARY OF ENTERGY CORPORATION. MOREOVER, THIS POLICY DOES NOT CREATE ANY EMPLOYMENT RELATIONSHIP BETWEEN ANY PERSON AND ANY ENTERGY SYSTEM COMPANY, NOR DOES THIS POLICY CONFER ANY CONTRACTUAL RIGHT TO ANY PERSON TO BECOME OR REMAIN AN EMPLOYEE OF ANY ENTERGY SYSTEM COMPANY.

2.0 REFERENCES AND CROSS REFERENCES

2.1 Entergy System Policies and Procedures:

• Reimbursement of Business Expenses
• Reporting Violations 2.2 U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs 2.3 EntergyNET - Human Resources Forms
• Course Approval and Reimbursement Form
• Student Worksheet

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- | :-- |

3.0 DEFINITIONS

3.1 Accredited means the status granted by the United States Department of Education to a qualified institution of higher learning, and includes the following requirements:

• such status has been in effect for at least one year; and
• the institution must appear in the US Department of Education's Database of Accredited Programs and Institutions (please reference Section 2.2 of this Policy or the Employee Development Website). 3.2 Eligible Courses are those courses described in Section 5.1 that are not ineligible under Section 5.2. 3.3 Eligible Employee is defined as a regular, active, full-time employee. Eligibility to begin the course approval process using the requirements of Policy Section 6.1 (which must occur prior to course enrollment in order to qualify for reimbursement per Section 5.3) begins upon date of hire. 3.4 Entergy, Entergy System Company, or Company is defined as Entergy Corporation and all of its subsidiaries and affiliates in which Entergy Corporation has a direct or indirect majority ownership interest. 3.5 Policy is defined as this Educational Reimbursement Program policy.

4.0 RESPONSIBILITY

4.1 Entergy Management is responsible for ensuring that courses and degree programs relate directly to the Eligible Employee's job or are an appropriate future investment for the Company and for the Eligible Employees that they directly supervise. They are also responsible for approving reimbursements covered by this Policy. 4.2 The Director, Talent Management and Inclusion is responsible for interpretation of this Policy. 4.3 The Director, Total Rewards is responsible for administering this Policy. 4.4 The Executive Vice President, Human Resources &; Administration is responsible for approving any deviations from this Policy. 4.5 All Entergy employees shall immediately report known, suspected or potential violations of this Policy by following the procedures described in the Reporting Violations policy.

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- | :-- |

5.1 Eligible Courses. The following courses are Eligible Courses if (a) they either enable Eligible Employees to meet the qualifications for positions within Entergy or enable them to improve their skills set or qualifications in their present positions and (b) any further conditions specified below are satisfied. 5.1.1 Eligible Undergraduate Courses are Accredited college degree programs, Accredited college level courses, and courses offered by area vocational and technical institutions. 5.1.2 Eligible Graduate Level Courses are courses in masters programs offered by Accredited institutions. Such programs include the Master of Science in Electrical Engineering and the Master of Business Administration, including an Executive Master of Business Administration (EMBA). For information regarding PhD and JD level courses, please refer to Sections 5.1.8 and 5.1.9.

The EMBA program, as referred to in this Policy, is different from the Entergy-sponsored EMBA program, which is not covered by this Policy. For information on the Entergy-sponsored EMBA program contact Employee Development or refer to the EntergyNet's Employee Development page. 5.1.3 Distance Learning Courses (including correspondence courses) are courses within graduate and undergraduate programs offered by Accredited institutions. In order to be eligible under Section 5.1, distance learning programs must be included in the U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs, referenced at Section 2.2 of this Policy and at the Employee Development website. 5.1.4 Preparatory Courses in preparation for professional certification examinations (as noted in section 5.1.5). 5.1.5 Professional Exams such as the Certified Public Accountant exam, Professional Engineer Certification, State Bar exam, etc., are eligible provided they are needed to obtain or maintain a professional license and such license is required in the performance of the Eligible Employee's current job classification responsibilities. 5.1.6 College Level Examination Programs (CLEP) if the examination applies to fulfilling requirements of a degree program. 5.1.7 "Credit for Life Experiences" if approved by the school in question and if it applies to fulfilling requirements of a degree program. 5.1.8 Law Degree Courses - Costs associated with courses within a law degree curriculum are eligible for educational assistance. Law courses are eligible

| Title: | EDUCATIONAL REIMBURSEMENT PROGRAM | Last Revision: 3/04/2011 | Rev. 2 | | :--: | :--: | :--: | :--: |

only if the course relates directly to the Eligible Employee's job responsibilities at the time of enrollment in the course. 5.1.9 Ph.D. Programs Courses - Costs associated with courses within a Ph.D. program are eligible for educational assistance. Ph.D. courses are eligible only if the course relates directly to the Eligible Employee's job responsibilities at the time of enrollment in the course.

5.2 Ineligible Courses and Expenses

5.2.1 Conferences, Seminars and Workshops - Reimbursement under this Policy does not cover the costs of conferences, seminars, workshops, and other non-credit courses such as computer software courses. Refer to Entergy System Policies and Procedures, Reimbursement of Business Expenses, for guidance. 5.2.2 Ineligible Expenses - Late charges, travel expenses, graduation fees, instruments, computers, finance charges, ID cards, parking expenses, insurance fees and auto decal fees are not eligible for reimbursement under this Policy. Costs related to preparing and/or sitting for educationprogram admission examinations (e.g., GMAT, LSAT) are also ineligible for reimbursement.

5.3 Conditions for Reimbursement

Approval to enroll in an Eligible Course must be obtained prior to enrollment, following the process specified in Section 6.1, in order to qualify for reimbursement under this Policy. The maximum reimbursement of allowable expenses is $\backslash$ 5,250$ per calendar year (Note: This maximum allowable amount takes into consideration IRS implications). These expenses must be reimbursed in either the year they occurred or the following year only. In order for costs to be reflected in a particular year, employees must follow end-of-year expense recording protocols specified by the Finance Operations Center. Department charge codes are required for course approval and can be obtained from the Eligible Employee's business unit budget coordinator. Upon completion of each approved Eligible Course, the employee will be reimbursed for the following expenses, subject to Section 5.5 and the annual limit: 5.3.1 Registration Fees - 100\% of registration fees not tied to specific courses, if all semester grades are C or better. 5.3.2 Tuition, Required Book Costs, and Required Course Fees - No reimbursement will be allowed for any expenses related to a course from which an employee has withdrawn or received a grade below C. Tuition, required book costs, and required course fees will be reimbursed according to the following schedule:

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| Title: EDUCATIONAL REIMBURSEMENT | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- | | PROGRAM | | |

$A=100\%;$ $B=90\%;$ $C=80\%$ ; and Courses that are only Pass/Fail will be reimbursed at $100\%$ for a passing grade. Courses that do not provide a grade will be reimbursed at $100\%$ with a certificate of completion from the organization providing the course. 5.3.3 Preparatory Courses/Professional Exams - Preparatory courses for professional exams are subject to the same approval requirements as other courses eligible for reimbursement under this policy and will only be paid one time; the cost for sitting for professional exams may be paid up to two times during the employee's tenure with Entergy. Fees for the preparatory courses and professional exams will be paid at $100\%$ , but only after the exam has been successfully completed. 5.3.4 CLEP Exams - Successfully completed CLEP exams are reimbursed at $100\%$ when the exam is taken to fulfill requirements of a degree program. 5.3.5 "Credit for Life Experiences" - "Credit for Life Experiences" is reimbursed at $100\%$ when applied toward a degree program. 5.3.6 Compensation Under Another Program - If the employee received compensation under any other program (e.g., the Veterans Readjustment Benefits Act), only those expenses in excess of the total compensation received will be considered under this Policy. 5.4 Class Attendance - Time necessary for attending classes or completing distance learning courses shall be during the employee's off-duty hours. Class attendance and study time cannot interfere with job responsibilities, including any necessary travel or emergency and overtime work.

5.5 Resignation, Discharge or Termination

5.5.1 If an employee resigns or is discharged for cause prior to the completion of approved Eligible Course work, reimbursement will not be made. However, if an employee is terminated due to a reduction in work force (not including Voluntary Severance), reimbursement will be made (per Section 5.3) for any approved Eligible Course(s) underway at the time of notification of termination if the course(s) is/are successfully completed. 5.5.2 All Eligible Employees entering a JD or PhD program will be required to submit a repayment agreement during the tuition approval process. If an employee voluntarily resigns from Entergy within three years after

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| Title: | EDUCATIONAL REIMBURSEMENT PROGRAM | Last Revision: 3/04/2011 | Rev. 2 | | :--: | :--: | :--: | :--: |

completion of a JD or PhD program course, the employee agrees to pay to Entergy $100\%$ of the total reimbursement for costs associated with the course. 5.6 Equal Opportunity Employer - Entergy is an equal opportunity employer that promotes the development of all employees and encourages each individual to achieve as much success as their talents and initiative will allow.

6.0 PROCEDURES

6.1 Course Approval Process

6.1.1 Discuss with Immediate Supervisor - An Eligible Employee desiring to apply for educational assistance should contact his or her immediate supervisor to discuss the proposed course(s) and to establish the potential benefits to the Eligible Employee and Entergy. 6.1.2 Request for Educational Assistance: Course Approval and Reimbursement Form - The Eligible Employee should complete the Request for Course Approval section of the Course Approval and Reimbursement Form (Refer to Section 2.3) and seek the immediate supervisor's written approval thereon; see Section 6.1.4 regarding approval. If an employee changes schools, degrees, certifications, or majors, a new application must be submitted. 6.1.3 Non-Degree or Non-Certification Courses - Employees enrolled in courses not leading to specific degrees or certifications must gain approval for each enrollment. 6.1.4 Approvals - Approval is required for all courses, degree programs or certification programs. 6.1.4.1 The Eligible Employee's immediate supervisor reviews the Request for Course Approval section of the Course Approval and Reimbursement Form (Refer to Section 2.3), and approves the request in writing or denies the request. 6.1.4.2 Courses within JD and PhD programs require further approval by a member of System Management Levels 1 through 4 within the Eligible Employee's chain of command. Further, JD and PhD course approval requests must include additional documentation, in a format specified by Human Resources, where employee and his/her management describe how the JD or PhD course will relate directly to the employee's job responsibilities at the time of enrollment in the course and the anticipated benefits to Entergy. Finally, JD and PhD program courses also require approval by the Executive Vice President, Human Resources &; Administration.

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- | :-- |

6.1.5 Forward Completed Request for Educational Assistance: Course Approval Section - The Request for Course Approval Section of the Course Approval and Reimbursement Form (Refer to Section 2.3) is then forwarded to the Human Resources Service Center for review to ensure that Policy requirements are met. The Human Resources Service Center will approve the request if all Policy conditions have been met. Eligible Employees should not attend a course/class until they have received approval from the Human Resources Service Center. If an Eligible Employee begins a course/class before receiving approval, their reimbursement request may be denied. 6.1.6 Approval Notification - The Human Resources Service Center will return the original approved form to the requesting Eligible Employee as notification to proceed with enrollment.

6.2 Reimbursement Request Process

6.2.1 Completion of Approved Course/Reimbursement - Upon successful completion of an approved course, the employee must complete the Request for Reimbursement section of the Course Approval and Reimbursement Form (Refer to Section 2.3) and have it approved by his/her supervisor. The employee must use the Student Worksheet (Refer to Section 2.3) to calculate reimbursable cost and review the worksheet with his/her immediate supervisor. 6.2.2 Reimbursement Approval - The employee's immediate supervisor will review the request for reimbursement. If all conditions of this Policy have been met, the immediate supervisor will approve the reimbursement. The immediate supervisor approving the reimbursement must ensure that all the original statements or receipts are included with the supporting documentation. This is necessary to prevent reuse of statements or receipts and duplicate reimbursements to the employee. The employee sends the approved form and worksheet (Refer to Section 2.3) and the following items to the Accounts Payable Department for reimbursement. This reimbursement should not be processed through the Expense Account Reporting Log System (EARL). 6.2.2.1 An original statement or certificate showing that the employee has successfully completed the course(s) with a satisfactory grade(s) which shows the final credit hours earned; and 6.2.2.2 Original paid statements or receipts documenting total costs for tuition, books, and fees for each course. 6.2.3 Reimbursement Check - Accounts Payable will send the reimbursement check directly to the employee.

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| Title: EDUCATIONAL REIMBURSEMENT | Last Revision: 3/04/2011 | Rev. 2 | | :-- | :-- | :-- |

7.0 ATTACHMENTS

None Note: Consult the HR Forms Web site (Referenced at Section 2.3) to access Course Approval and Reimbursement Form and Student Worksheet Form referenced in this policy.

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: EDUCATIONAL REIMBURSEMENT | | | Last Revision: 5/09/2011 | Rev. 3 | | :-- | :-- | :-- | :-- | :-- | | PROGRAM | | Approved By:
Corporate Compliance Committee | | | | Subject Matter Expert:
Mark Antoine | Responsible Officer:
Renae Conley | | | |

I. POLICY SUMMARY

• Eligible Employees can apply for reimbursement for approved Eligible Courses.
• All Eligible Employees must receive written course approval from appropriate management as specified in this Policy and then subsequently from the HRSC to be eligible for reimbursement.
• Upon successful completion of each approved Eligible Course, the employee will be reimbursed for the following expenses up to a maximum annual reimbursement of $\backslash$ 5,250$ :
• Registration fees at $100\%$ for a grade of C or better;
• Tuition, required book costs, and required course fees according to the following schedule:
• $A=100\%$ ;
• $B=90\%$ ;
• $C=80\%$ ;
• D, F, or Withdrawal $=0\%$ ; and
• Courses which are only Pass/Fail will be reimbursed at $100\%$ for a passing grade.
• Courses that do not provide a grade will be reimbursed at $100\%$ with a certification of completion from the organization providing the course.
• All Entergy employees shall immediately report known, suspected or potential violations of this Policy by following the procedures described in the Reporting Violations policy.
• Entergy is an equal opportunity employer that promotes the development of all employees and encourages each individual to achieve as much success as their talents and initiative will allow.
• Please refer to the following detailed Policy for further information.

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :-- | :-- | :-- | :-- |

II. DETAILED POLICY

1.0 PURPOSE AND APPLICABILITY

The purpose of the Educational Reimbursement Program is to encourage Eligible Employees to seek self-improvement and development. This Policy provides specific information necessary for employees to obtain course approval and reimbursement for completed course work. Entergy will reimburse expenses of Eligible Employees who undertake approved outside study that enables them to improve their skill set and qualifications in their present positions or would lead to degrees received from Accredited institutions where such degrees are considered to be of value to Entergy.

THIS POLICY APPLIES TO ANY AND ALL EMPLOYEES OF ANY ENTERGY SYSTEM COMPANY, UNLESS OTHERWISE EXPRESSLY EXCLUDED.

THE EXTENT TO WHICH ANY SPECIFIC PROVISION IN THIS POLICY COVERS EMPLOYEES WHO ARE REPRESENTED BY A UNION MAY DEPEND ON NEGOTIATIONS WITH AND/OR A COLLECTIVE BARGAINING AGREEMENT WITH THAT UNION.

NOTHING CONTAINED IN THIS POLICY SHOULD BE CONSTRUED TO SUGGEST THAT EMPLOYEES OF A PARTICULAR SUBSIDIARY OR AFFILIATE OF ENTERGY CORPORATION ARE ALSO EMPLOYEES OF ENTERGY CORPORATION OR ANY OTHER AFFILIATE OR SUBSIDIARY OF ENTERGY CORPORATION. MOREOVER, THIS POLICY DOES NOT CREATE ANY EMPLOYMENT RELATIONSHIP BETWEEN ANY PERSON AND ANY ENTERGY SYSTEM COMPANY, NOR DOES THIS POLICY CONFER ANY CONTRACTUAL RIGHT TO ANY PERSON TO BECOME OR REMAIN AN EMPLOYEE OF ANY ENTERGY SYSTEM COMPANY.

2.0 REFERENCES AND CROSS REFERENCES

2.1 Entergy System Policies and Procedures:

• Reimbursement of Business Expenses
• Reporting Violations 2.2 U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs

2.3 EntergyNET - Human Resources Forms

• Course Approval and Reimbursement Form
• Student Worksheet

ENTERGY SYSTEM POLICIES &; PROCEDURES

Page 3 of 9

| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :-- | :-- | :-- | :-- |

3.0 DEFINITIONS

3.1 Accredited means the status granted by the United States Department of Education to a qualified institution of higher learning, and includes the following requirements:

• such status has been in effect for at least one year; and
• the institution must appear in the US Department of Education's Database of Accredited Programs and Institutions (please reference Section 2.2 of this Policy or the Employee Development Website). 3.2 Eligible Courses are those courses described in Section 5.1 that are not ineligible under Section 5.2. 3.3 Eligible Employee is defined as a regular, active, full-time employee. Eligibility to begin the course approval process using the requirements of Policy Section 6.1 (which must occur prior to course enrollment in order to qualify for reimbursement per Section 5.3) begins upon date of hire. 3.4 Entergy, Entergy System Company, or Company is defined as Entergy Corporation and all of its subsidiaries and affiliates in which Entergy Corporation has a direct or indirect majority ownership interest. 3.5 Policy is defined as this Educational Reimbursement Program policy.

4.0 RESPONSIBILITY

4.1 Entergy Management is responsible for ensuring that courses and degree programs relate directly to the Eligible Employee's job or are an appropriate future investment for the Company and for the Eligible Employees that they directly supervise. They are also responsible for approving reimbursements covered by this Policy. 4.2 The Director, Talent Management and Inclusion is responsible for interpretation of this Policy. 4.3 The Director, Total Rewards is responsible for administering this Policy. 4.4 The Executive Vice President, Human Resources &; Administration is responsible for approving any deviations from this Policy. 4.5 All Entergy employees shall immediately report known, suspected or potential violations of this Policy by following the procedures described in the Reporting Violations policy.

5.0 DETAILS

| Title: | EDUCATIONAL REIMBURSEMENT PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :--: | :--: | :--: | :--: |

5.1 Eligible Courses. The following courses are Eligible Courses if (a) they either enable Eligible Employees to meet the qualifications for positions within Entergy or enable them to improve their skills set or qualifications in their present positions and (b) any further conditions specified below are satisfied. 5.1.1 Eligible Undergraduate Courses are Accredited college degree programs, Accredited college level courses, and courses offered by area vocational and technical institutions. 5.1.2 Eligible Graduate Level Courses are courses in masters programs offered by Accredited institutions. Such programs include the Master of Science in Electrical Engineering and the Master of Business Administration, including an Executive Master of Business Administration (EMBA). For information regarding PhD and JD level courses, please refer to Sections 5.1.8 and 5.1.9.

The EMBA program, as referred to in this Policy, is different from the Entergy-sponsored EMBA program, which is not covered by this Policy. For information on the Entergy-sponsored EMBA program contact Employee Development or refer to the EntergyNet's Employee Development page. 5.1.3 Distance Learning Courses (including correspondence courses) are courses within graduate and undergraduate programs offered by Accredited institutions. In order to be eligible under Section 5.1, distance learning programs must be included in the U.S. Department of Education Database of Accredited Postsecondary Institutions and Programs, referenced at Section 2.2 of this Policy and at the Employee Development website. 5.1.4 Preparatory Courses in preparation for professional certification examinations (as noted in section 5.1.5). 5.1.5 Professional Exams such as the Certified Public Accountant exam, Professional Engineer Certification, State Bar exam, etc., are eligible provided they are needed to obtain or maintain a professional license and such license is required in the performance of the Eligible Employee's current job classification responsibilities. 5.1.6 College Level Examination Programs (CLEP) if the examination applies to fulfilling requirements of a degree program. 5.1.7 "Credit for Life Experiences" if approved by the school in question and if it applies to fulfilling requirements of a degree program. 5.1.8 Law Degree Courses - Costs associated with courses within a law degree curriculum are eligible for educational assistance. Law courses are eligible

| Title: | EDUCATIONAL REIMBURSEMENT PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :--: | :--: | :--: | :--: |

only if the course relates directly to the Eligible Employee's job responsibilities at the time of enrollment in the course. 5.1.9 Ph.D. Programs Courses - Costs associated with courses within a Ph.D. program are eligible for educational assistance. Ph.D. courses are eligible only if the course relates directly to the Eligible Employee's job responsibilities at the time of enrollment in the course.

5.2 Ineligible Courses and Expenses

5.2.1 Conferences, Seminars and Workshops - Reimbursement under this Policy does not cover the costs of conferences, seminars, workshops, and other non-credit courses such as computer software courses. Refer to Entergy System Policies and Procedures, Reimbursement of Business Expenses, for guidance. 5.2.2 Ineligible Expenses - Late charges, travel expenses, graduation fees, instruments, computers, finance charges, ID cards, parking expenses, insurance fees and auto decal fees are not eligible for reimbursement under this Policy. Costs related to preparing and/or sitting for educationprogram admission examinations (e.g., GMAT, LSAT) are also ineligible for reimbursement.

5.3 Conditions for Reimbursement

Approval to enroll in an Eligible Course must be obtained prior to enrollment, following the process specified in Section 6.1, in order to qualify for reimbursement under this Policy. The maximum reimbursement of allowable expenses is $\backslash$ 5,250$ per calendar year (Note: This maximum allowable amount takes into consideration IRS implications). Paid receipts for allowable expenses must be submitted for reimbursement within 6 months of completion of the Eligible Course for which such expenses were incurred. Paid receipts for allowable expenses (tuition, required book costs, and required course fees) for an Eligible Course must be submitted together as a single reimbursement and can only be submitted one time for reimbursement. In order for costs to be reflected in a particular year, employees must follow end-of-year expense recording protocols specified by the Finance Operations Center. Department charge codes are required for course approval and can be obtained from the Eligible Employee's business unit budget coordinator. Upon completion of each approved Eligible Course, the employee will be reimbursed for the following expenses, subject to Section 5.5 and the annual limit: 5.3.1 Registration Fees - 100\% of registration fees not tied to specific courses, if all semester grades are C or better.

ENTERGY SYSTEM POLICIES &; PROCEDURES

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :-- | :-- | :-- | :-- |

5.3.2 Tuition, Required Book Costs, and Required Course Fees - No reimbursement will be allowed for any expenses related to a course from which an employee has withdrawn or received a grade below C. Tuition, required book costs, and required course fees will be reimbursed according to the following schedule: $A=100\%;$ $B=90\%;$ $C=80\%$ ; and Courses that are only Pass/Fail will be reimbursed at 100\% for a passing grade. Courses that do not provide a grade will be reimbursed at 100\% with a certificate of completion from the organization providing the course. 5.3.3 Preparatory Courses/Professional Exams - Preparatory courses for professional exams are subject to the same approval requirements as other courses eligible for reimbursement under this policy and will only be paid one time; the cost for sitting for professional exams may be paid up to two times during the employee's tenure with Entergy. Fees for the preparatory courses and professional exams will be paid at $100\%$ , but only after the exam has been successfully completed. 5.3.4 CLEP Exams - Successfully completed CLEP exams are reimbursed at $100\%$ when the exam is taken to fulfill requirements of a degree program. 5.3.5 "Credit for Life Experiences" - "Credit for Life Experiences" is reimbursed at $100\%$ when applied toward a degree program. 5.3.6 Compensation Under Another Program - If the employee received compensation under any other program (e.g., the Veterans Readjustment Benefits Act), only those expenses in excess of the total compensation received will be considered under this Policy. 5.4 Class Attendance - Time necessary for attending classes or completing distance learning courses shall be during the employee's off-duty hours. Class attendance and study time cannot interfere with job responsibilities, including any necessary travel or emergency and overtime work.

5.5 Resignation, Discharge or Termination

5.5.1 If an employee resigns or is discharged for cause prior to the completion of approved Eligible Course work, reimbursement will not be made. However, if an employee is terminated due to a reduction in work force (not including Voluntary Severance), reimbursement will be made (per

| | | ENTERGY SYSTEM
POLICIES &; PROCEDURES
Page 7 of 9 | | | :-- | :-- | :-- | :-- | | Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 5/09/2011 | Rev. 3 |

Section 5.3) for any approved Eligible Course(s) underway at the time of notification of termination if the course(s) is/are successfully completed. 5.5.2 All Eligible Employees entering a JD or PhD program will be required to submit a repayment agreement during the tuition approval process. If an employee voluntarily resigns from Entergy within three years after completion of a JD or PhD program course, the employee agrees to pay to Entergy 100\% of the total reimbursement for costs associated with the course. 5.6 Equal Opportunity Employer - Entergy is an equal opportunity employer that promotes the development of all employees and encourages each individual to achieve as much success as their talents and initiative will allow.

6.0 PROCEDURES

6.1 Course Approval Process

6.1.1 Discuss with Immediate Supervisor - An Eligible Employee desiring to apply for educational assistance should contact his or her immediate supervisor to discuss the proposed course(s) and to establish the potential benefits to the Eligible Employee and Entergy. 6.1.2 Request for Educational Assistance: Course Approval and Reimbursement Form - The Eligible Employee should complete the Request for Course Approval section of the Course Approval and Reimbursement Form (Refer to Section 2.3) and seek the immediate supervisor's written approval thereon; see Section 6.1.4 regarding approval. If an employee changes schools, degrees, certifications, or majors, a new application must be submitted. 6.1.3 Non-Degree or Non-Certification Courses - Employees enrolled in courses not leading to specific degrees or certifications must gain approval for each enrollment. 6.1.4 Approvals - Approval is required for all courses, degree programs or certification programs. 6.1.4.1 The Eligible Employee's immediate supervisor reviews the Request for Course Approval section of the Course Approval and Reimbursement Form (Refer to Section 2.3), and approves the request in writing or denies the request. 6.1.4.2 Courses within JD and PhD programs require further approval by a member of System Management Levels 1 through 4 within the Eligible Employee's chain of command. Further, JD and PhD course approval requests must include additional documentation, in a format specified by Human Resources, where employee and

| Title: | EDUCATIONAL REIMBURSEMENT PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :--: | :--: | :--: | :--: |

his/her management describe how the JD or PhD course will relate directly to the employee's job responsibilities at the time of enrollment in the course and the anticipated benefits to Entergy. Finally, JD and PhD program courses also require approval by the Executive Vice President, Human Resources &; Administration. 6.1.5 Forward Completed Request for Educational Assistance: Course Approval Section - The Request for Course Approval Section of the Course Approval and Reimbursement Form (Refer to Section 2.3) is then forwarded to the Human Resources Service Center for review to ensure that Policy requirements are met. The Human Resources Service Center will approve the request if all Policy conditions have been met. Eligible Employees should not attend a course/class until they have received approval from the Human Resources Service Center. If an Eligible Employee begins a course/class before receiving approval, their reimbursement request may be denied. 6.1.6 Approval Notification - The Human Resources Service Center will return the original approved form to the requesting Eligible Employee as notification to proceed with enrollment.

6.2 Reimbursement Request Process

6.2.1 Completion of Approved Course/Reimbursement - Upon successful completion of an approved course, the employee must complete the Request for Reimbursement section of the Course Approval and Reimbursement Form (Refer to Section 2.3) and have it approved by his/her supervisor. The employee must use the Student Worksheet (Refer to Section 2.3) to calculate reimbursable cost and review the worksheet with his/her immediate supervisor. 6.2.2 Reimbursement Approval - The employee's immediate supervisor will review the request for reimbursement. If all conditions of this Policy have been met, the immediate supervisor will approve the reimbursement. The immediate supervisor approving the reimbursement must ensure that all the original statements or receipts are included with the supporting documentation. This is necessary to prevent reuse of statements or receipts and duplicate reimbursements to the employee. The employee sends the approved form and worksheet (Refer to Section 2.3) and the following items to the Accounts Payable Department for reimbursement. This reimbursement should not be processed through the Expense Account Reporting Log System (EARL). 6.2.2.1 An original statement or certificate showing that the employee has successfully completed the course(s) with a satisfactory grade(s) which shows the final credit hours earned; and

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| Title: | EDUCATIONAL REIMBURSEMENT
PROGRAM | Last Revision: 5/09/2011 | Rev. 3 | | :-- | :-- | :-- | :-- |

6.2.2.2 Original paid statements or receipts documenting total costs for tuition, books, and fees for each course. 6.2.3 Reimbursement Check - Accounts Payable will send the reimbursement check directly to the employee.

7.0 ATTACHMENTS

None Note: Consult the HR Forms Web site (Referenced at Section 2.3) to access Course Approval and Reimbursement Form and Student Worksheet Form referenced in this policy.

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| Class | Billing Entity | Activity / Project | Activity / Project Description | ESI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | Service Company | Total | All Other BLI | ETI Pair | | | | | | | | | | | Receptor | | | | | | | | | | | Activity / Project Description | | Support | Receptor | | | | | | Adjustment | | HUMAN RESOURCES | EA | FSPCCS506L | USO, war-500 naved ideas to LE | DIRECT | $(8,092)$ | $(8,092)$ | | $(8,092)$ | | | 66 | $(7,996)$ | | HUMAN RESOURCES | EA | FSPCMAATC23M | MATTERALS TESTING AND COMPLAIN | DIRECT | $(1,311)$ | $(1,311)$ | | $(1,311)$ | | 11 | $(1,306)$ | | | HUMAN RESOURCES | EA | FSPCSCSMMCM | SUPPLY CHAIN MATTERALS MORRIT O | DIRECT | $(147)$ | $(147)$ | | $(147)$ | 147 | | | | | HUMAN RESOURCES | EA | FSPCCDJBDNF | BENEFITS | DIRECT | $(292)$ | $(292)$ | | $(292)$ | | | 2 | $(299)$ | | HUMAN RESOURCES | EA | SAPCP25910 | PCaR OVERHEAD POOL CHARGES | DIRECT | $(66)$ | $(66)$ | | $(66)$ | 66 | | | | | HUMAN RESOURCES | Total EA | | | | $(9,868)$ | | $(9,868)$ | | $(9,868)$ | 213 | 79 | $(9,576)$ | | HUMAN RESOURCES | EGSLA | C6PPT526308 | upgrade ZEIN-Exo déit Courts | DIRECT | 155 | | 155 | | 155 | (155) | | | | HUMAN RESOURCES | EGSLA | FSPCRB6245 | BILLING &; PAYMENT SOLUTIONS | DIRECT | 569 | | 569 | | 569 | | (7) | 563 | | HUMAN RESOURCES | EGSLA | FSPCCDJBDNF | BENEFITS | DIRECT | 2,174 | | 2,174 | | 2,174 | | (25) | 2,148 | | HUMAN RESOURCES | EGSLA | SAPCP25910 | PCaR OVERHEAD POOL CHARGES | DIRECT | 14 | | 14 | | 14 | (14) | | | | HUMAN RESOURCES | Total EGSL | | | | 2,913 | | 2,913 | | 2,913 | (170) | (32) | 2,711 | | HUMAN RESOURCES | ELL | C6PPSHOPTX | Capture Transformer Shop Cost | DIRECT | (194) | | (194) | | (194) | 194 | | | | HUMAN RESOURCES | ELL | FSPCCDJBDNF | BENEFITS | DIRECT | (124) | | (124) | | (124) | | 1 | (123) | | HUMAN RESOURCES | ELL | SAPCP25910 | PCaR OVERHEAD POOL CHARGES | DIRECT | (147) | | (147) | | (147) | 147 | | | | HUMAN RESOURCES | Total ELL | | | | (465) | | (465) | | (465) | 341 | 1 | (123) | | HUMAN RESOURCES | EMI | FSPCCDJBDNF | BENEFITS | DIRECT | 5 | | 5 | | 5 | | (0) | 5 | | HUMAN RESOURCES | EMI | SAPCP25910 | PCaR OVERHEAD POOL CHARGES | DIRECT | 63 | | 63 | | 63 | (63) | | | | HUMAN RESOURCES | Total EMI | | | | 68 | | 68 | | 68 | (63) | (0) | 5 | | HUMAN RESOURCES | ESI | C1PQ946310 | SPIT FUEL STORAGE - ESI | DIRECTECS | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPEQAPPY | Equation Software Replication E | DIRECTNI | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPEQFWH | Equation Freezeal Enhancements | DIRECTNI | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPEQFRSK | Equation FPR System Enhancements | DIRECTNI | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF92205 | eSediment Eval Reveals Sert | SCPSIPALL | $(8,273)$ | $(8,993)$ | $(1,285)$ | | 429 | | 851 | | | HUMAN RESOURCES | ESI | C1PPP25C20 | eSediment Services Solution | SCPSIPALL | (160) | (160) | (135) | | 8 | | 17 | | | HUMAN RESOURCES | ESI | C1PPPAAF147 | Infrastructure Emerging Pro | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPAIF148 | Infrastructure Emerging Pro | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF9215 | Change My Cost Bank Partner I | BRAFACCTA | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF0001 | Regulatory Regulatory Enhancerse | CLISTEGOP | 2,016 | | 2,016 | 1,738 | 278 | (278) | | | | HUMAN RESOURCES | ESI | C1PPPF0003 | EOI TIMIL &; LIBOR (EOI) | DIRECTECS | 77,057 | | 77,057 | 77,057 | | | | | | HUMAN RESOURCES | ESI | C1PPPF0207 | Piezo/ Time &; Labor - Power I | EMPLOYAL | 57,474 | 135 | 57,609 | 54,843 | 2,765 | (2,837) | | 72 | | HUMAN RESOURCES | ESI | C1PPPF0263 | ARSALLSCOSETRO TIMIFu (EOS) | | 11 | | 11 | 10 | 1 | (1) | | | | HUMAN RESOURCES | ESI | C1PPPF0283 | PII GL Enhancements - 2007 | GEIN,EDAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF0288 | Cost Replenemeasures Pay Iron | GEIN,EDAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF0307 | Compliance Software System - 4 | ASSTSALL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF7243 | Utility Operations Graphical C | CLISTEGOP | 13,771 | | 13,771 | 11,870 | 1,901 | (1,901) | | | | HUMAN RESOURCES | ESI | C1PPPF7249 | WISI 40 -Year W.O. Poverty, EoI | CLISTEGOP | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF7263 | NA Utilize EPIRRODIN Geospillabh | CLISTEGOP | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8603 | Uspo/ CENADE Partner -PA Net 1 | GEIN,EDAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8219 | SABRIS S.O.OSpack (259) | ASSTSALL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8288 | EPN ALLCCATICN EXPAN - 2598 | GEIN,EDAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8283 | PII GL Enhancements - 2008 | GEIN,EDAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8606 | Wired Network | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF88118 | Wired SW Network &; Longhorn C | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF88120 | EoI App big PENV App (Mapkin) | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF88146 | SQL and Check Cippeler | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8615 | Identity Management | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF8643 | Resicate Cornea Tidescent Hub | PCNUMALL | 3,228 | | 3,228 | 3,104 | 124 | (124) | | | | HUMAN RESOURCES | ESI | C1PAP01172 | UFU -Dealing EPI Improvements | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PAP0119A | UFU Computing Fair Impr Plygn Mg | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PAP019C | UFU Life Post-P Equipment | APPSUPPAL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PAP0200 | UFruxation-17 Equipment | APPSUPPAL | (1,352) | | (1,352) | (1,148) | (204) | 204 | | | | HUMAN RESOURCES | ESI | C1PAP0260 | SWEM Engineering | PCNUMALL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF689P | UFU Jackson Teleconfigure Cell C | CLISTCALL | - | | - | | - | | - | | | HUMAN RESOURCES | ESI | C1PPPF987TL | Heating Time C4R &; Reserve Open | DIRECTENA) | 87,059 | 87,059 | | | | | | |

| | | | | | | (A) | | (B) | | (C) | | (D) | | (E) | | (F) | | (G) | | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | | | | | | | | | | | | | | | | | | | | | | | | | | | | Service Company | | Total | All Other BUS | E11 Pair Binds | | Exclusions | | Pro Forms | | | | | | | | | | | | Recipient | | | | | | | | | Amount | | | | nol | | | | | | | | | | | | | | | | | | | | | | nol | | | C1PPFIRG13 | SC Electronic Signature & Rete | | | | | | | | 13 | 135 | 135 | 704 | 121,862 | 11,865 | | (11,865) | | | | | C1PPFIRG13 | | Transformer Bar Code (bar (BB) | | | | | | | | 14 | | 14 | 14 | | | | | | | | | | C1PPFIRG14 | Transformer Bar Code (bar (BB) | | | | | | | | | | | | | | | | | | | | | C1PPFITEO3 | ECV TME & LABOR (EV) | | | | | | | | | | | | | | | | | | | | | C1PPFITMO8 | 2668 Telecom Capital Nat-Met | | | | | | | | | | | | | | | | | | | | | C1PPFTT226 | 8th Print Optimization Forest | | | | | | | | | | | | | | | | | | | | | C1PPFHT6004 | HR Diagnostic - 2006 | | | | | | | | | | | | | | | | | | | | | C1PPHR8800 | PX HOM (Former Cap Agent) (dapt) | | | | | | | | | | | | | | | | | | | | | C1PPHR8800 | HR Readhouse Reporting - 2006 | | | | | | | | | | | | | | | | | | | | | C1PPLQIPCAP | ECG JSP Cap kit Transition Coo | | | | | | | | | | | | | | | | | | | | | C1PPNXPQR1 | Phase 2 transition in full run | | | | | | | | | | | | | | | | | | | | | C1PPRNG301 | New Nus Consortium - Ongoing | | | | | | | | | | | | | | | | | | | | | C1PPRNG302 | New Nuclear Energy - Ongoing | | | | | | | | | | | | | | | | | | | | | C1PPRNG310 | New Nuclear - Regulatory F ring | | | | | | | | | | | | | | | | | | | | | C1PPRNG310 | New Nuclear - Regulatory F ring | | | | | | | | | | | | | | | | | | | | | C1PPRTC20OF | P70 Implement Software ALLCO5 | | | | | | | | | | | | | | | | | | | | | C1PPPSF0801 | Safety Information Agent System | | | | | | | | | | | | | | | | | | | | | C1PPSPG008 | SPG ECu &PAO Furniture Option | | | | | | | | | | | | | | | | | | | | | C1PPTPD2608 | EMCC Cap Database | | | | | | | | | | | | | | | | | | | | | C1PPPTD2603 | EMCOCASM Host Spot Record | | | | | | | | | | | | | | | | | | | | | C1PPPTD2603 | EMCOCASM Host Spot Record | | | | | | | | | | | | | | | | | | | | | C1PPTDD2632 | APU Systems Capable by Project | | | | | | | | | | | | | | | | | | | | | C1PPTD2637 | 19th Phase 2 | | | | | | | | | | | | | | | | | | | nol | | C1PPTD2647 | Phase Angle Difference Phase I | | | | | | | | | | | | | | | | | | | | | C1PPTD2647 | Phase Angle Difference Phase I | | | | | | | | | | | | | | | | | | | | | C2PPQP79742 | Ph.D.NM4519 LCCN100 | | | | | | | | | | | | | | | | | | | | | C2PPQP79742 | Ph.D.NM4519 LCCN100 | | | | | | | | | | | | | | | | | | | | | C2PPQP79742 | Ph.D.LLLoose Research | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | | | | | C2PPPQQ7774 | 813-933-69 Farm - Engineering | | | | | | | | | | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLIQ | EPI Plan Biodis | Exclusions | Pro Postop Amount | Total EPI Adjustment | | | | | | Activity / Project Description | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 305 | 305 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 2,241 | 2,241 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 500 | 500 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 1,708 | 1,708 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLIQ | EPI Plan Blooks | Exclusions | Pro Posting Amount | Total EPI Adjustment | | | | | | | | | Periphery | | | | | | | | $0$ | | | | Activity / Project Description | | | 10 | 10 | | | | | | | $1$ | | | | | | | 6 | 6 | | | | | | | 2 | | | | | | | 8 | 8 | | | | | | | 3 | | | | | | | 8 | 8 | | | | | | | 4 | | | | | | | 417 | 417 | | | | | | | 5 | | | | | | | 731 | 731 | | | | | | | 6 | | | | | | | 7 | 7 | | | | | | | 7 | | | | | | | 7 | 7 | | | | | | | 8 | | | | | | | 7 | 7 | | | | | | | 9 | | | | | | | 7 | 7 | | | | | | | 10 | | | | | | | 7 | 7 | | | | | | | 11 | | | | | | | 421 | 421 | | | | | | | 12 | | | | | | | 60 | 60 | | | | | | | 13 | | | | | | | 624 | 624 | | | | | | | 14 | | | | | | | 956 | 956 | | | | | | | 15 | | | | | | | 6 | 6 | | | | | | | 16 | | | | | | | 6 | 6 | | | | | | | 17 | | | | | | | | | | | | | | | 18 | | | | | | | | | | | | | | | 19 | | | | | | | | | | | | | | | 20 | | | | | | | | | | | | | | | 21 | | | | | | | | | | | | | | | 22 | | | | | | | | | | | | | | | 23 | | | | | | | | | | | | | | | 24 | | | | | | | | | | | | | | | 25 | | | | | | | | | | | | | | | 26 | | | | | | | | | | | | | | | 27 | | | | | | | | | | | | | | | 28 | | | | | | | | | | | | | | | 29 | | | | | | | | | | | | | | | 30 | | | | | | | | | | | | | | | 31 | | | | | | | | | | | | | | | 32 | | | | | | | | | | | | | | | 33 | | | | | | | | | | | | | | | 34 | | | | | | | | | | | | | | | 35 | | | | | | | | | | | | | | | 36 | | | | | | | | | | | | | | | 37 | | | | | | | | | | | | | | | 38 | | | | | | | | | | | | | | | 39 | | | | | | | | | | | | | | | 40 | | | | | | | | | | | | | | | 41 | | | | | | | | | | | | | | | 42 | | | | | | | | | | | | | | | 43 | | | | | | | | | | | | | | | 44 | | | | | | | | | | | | | | | 45 | | | | | | | | | | | | | | | 46 | | | | | | | | | | | | | | | 47 | | | | | | | | | | | | | | | 48 | | | | | | | | | | | | | | | 49 | | | | | | | | | | | | | | | 50 | | | | | | | | | | | | | | | 51 | | | | | | | | | | | | | | | 52 | | | | | | | | | | | | | | | 53 | | | | | | | | | | | | | | | 54 | | | | | | | | | | | | | | | 55 | | | | | | | | | | | | | | | 56 | | | | | | | | | | | | | | | 57 | | | | | | | | | | | | | | | 58 | | | | | | | | | | | | | | | 59 | | | | | | | | | | | | | | | 60 | | | | | | | | | | | | | | | 61 | | | | | | | | | | | | | | | 62 | | | | | | | | | | | | | | | 63 | | | | | | | | | | | | | | | 64 | | | | | | | | | | | | | | | 65 | | | | | | | | | | | | | | | 66 | | | | | | | | | | | | | | | 67 | | | | | | | | | | | | | | | 68 | | | | | | | | | | | | | | | 69 | | | | | | | | | | | | | | | 70 | | | | | | | | | | | | | | | 71 | | | | | | | | | | | | | | | 72 | | | | | | | | | | | | | | | 73 | | | | | | | | | | | | | | | 74 | | | | | | | | | | | | | | | 75 | | | | | | | | | | | | | | | 76 | | | | | | | | | | | | | | | 77 | | | | | | | | | | | | | | | 78 | | | | | | | | | | | | | | | 79 | | | | | | | | | | | | | | | 80 | | | | | | | | | | | | | | | 81 | | | | | | | | | | | | | | | 82 | | | | | | | | | | | | | | | 83 | | | | | | | | | | | | | | | 84 | | | | | | | | | | | | | | | 85 | | | | | | | | | | | | | | | 86 | | | | | | | | | | | | | | | 87 | | | | | | | | | | | | | | | 88 | | | | | | | | | | | | | | | 89 | | | | | | | | | | | | | | | 90 | | | | | | | | | | | | | | | 91 | | | | | | | | | | | | | | | 92 | | | | | | | | | | | | | | | 93 | | | | | | | | | | | | | | | 94 | | | | | | | | | | | | | | | 95 | | | | | | | | | | | | | | | 96 | | | | | | | | | | | | | | | 97 | | | | | | | | | | | | | | | 98 | | | | | | | | | | | | | | | 99 | | | | | | | | | | | | | | | 100 | | | | | | | | | | | | | | | 101 | | | | | | | | | | | | | | | 102 | | | | | | | | | | | | | | | 103 | | | | | | | | | | | | | | | 104 | | | | | | | | | | | | | | | 105 | | | | | | | | | | | | | | | 106 | | | | | | | | | | | | | | | 107 | | | | | | | | | | | | | | | 108 | | | | | | | | | | | | | | | 109 | | | | | | | | | | | | | | | 110 | | | | | | | | | | | | | | | 111 | | | | | | | | | | | | | | | 112 | | | | | | | | | | | | | | | 113 | | | | | | | | | | | | | | | 114 | | | | | | | | | | | | | | | 115 | | | | | | | | | | | | | | | 116 | | | | | | | | | | | | | | | 117 | | | | | | | | | | | | | | | 118 | | | | | | | | | | | | | | | 119 | | | | | | | | | | | | | | | 120 | | | | | | | | | | | | | | | 121 | | | | | | | | | | | | | | | 122 | | | | | | | | | | | | | | | 123 | | | | | | | | | | | | | | | 124 | | | | | | | | | | | | | | | 125 | | | | | | | | | | | | | | | 126 | | | | | | | | | | | | | | | 127 | | | | | | | | | | | | | | | 128 | | | | | | | | | | | | | | | 129 | | | | | | | | | | | | | | | 130 | | | | | | | | | | | | | | | 131 | | | | | | | | | | | | | | | 132 | | | | | | | | | | | | | | | 133 | | | | | | | | | | | | | | | 134 | | | | | | | | | | | | | | | 135 | | | | | | | | | | | | | | | 136 | | | | | | | | | | | | | | | 137 | | | | | | | | | | | | | | | 138 | | | | | | | | | | | | | | | 139 | | | | | | | | | | | | | | | 140 | | | | | | | | | | | | | | | 141 | | | | | | | | | | | | | | | 142 | | | | | | | | | | | | | | | 143 | | | | | | | | | | | | | | | 144 | | | | | | | | | | | | | | | 145 | | | | | | | | | | | | | | | 146 | | | | | | | | | | | | | | | 147 | | | | | | | | | | | | | | | 148 | | | | | | | | | | | | | | | 149 | | | | | | | | | | | | | | | 150 | | | | | | | | | | | | | | | 151 | | | | | | | | | | | | | | | 152 | | | | | | | | | | | | | | | 153 | | | | | | | | | | | | | | | 154 | | | | | | | | | | | | | | | 155 | | | | | | | | | | | | | | | 156 | | | | | | | | | | | | | | | 157 | | | | | | | | | | | | | | | 158 | | | | | | | | | | | | | | | 159 | | | | | | | | | | | | | | | 160 | | | | | | | | | | | | | | | 161 | | | | | | | | | | | | | | | 162 | | | | | | | | | | | | | | | 163 | | | | | | | | | | | | | | | 164 | | | | | | | | | | | | | | | 165 | | | | | | | | | | | | | | | 166 | | | | | | | | | | | | | | | 167 | | | | | | | | | | | | | | | 168 | | | | | | | | | | | | | | | 169 | | | | | | | | | | | | | | | 170 | | | | | | | | | | | | | | | 171 | | | | | | | | | | | | | | | 172 | | | | | | | | | | | | | | | 173 | | | | | | | | | | | | | | | 174 | | | | | | | | | | | | | | | 175 | | | | | | | | | | | | | | | 176 | | | | | | | | | | | | | | | 177 | | | | | | | | | | | | | | | 178 | | | | | | | | | | | | | | | 179 | | | | | | | | | | | | | | | 180 | | | | | | | | | | | | | | | 181 | | | | | | | | | | | | | | | 182 | | | | | | | | | | | | | | | 183 | | | | | | | | | | | | | | | 184 | | | | | | | | | | | | | | | 185 | | | | | | | | | | | | | | | 186 | | | | | | | | | | | | | | | 187 | | | | | | | | | | | | | | | 188 | | | | | | | | | | | | | | | 189 | | | | | | | | | | | | | | | 190 | | | | | | | | | | | | | | | 191 | | | | | | | | | | | | | | | 192 | | | | | | | | | | | | | | | 193 | | | | | | | | | | | | | | | 194 | | | | | | | | | | | | | | | 195 | | | | | | | | | | | | | | | 196 | | | | | | | | | | | | | | | 197 | | | | | | | | | | | | | | | 198 | | | | | | | | | | | | | | | 199 | | | | | | | | | | | | | | | 200 | | | | | | | | | | | | | | | 201 | | | | | | | | | | | | | | | 202 | | | | | | | | | | | | | | | 203 | | | | | | | | | | | | | | | 204 | | | | | | | | | | | | | | | 205 | | | | | | | | | | | | | | | 206 | | | | | | | | | | | | | | | 207 | | | | | | | | | | | | | | | 208 | | | | | | | | | | | | | | | 209 | | | | | | | | | | | | | | | 210 | | | | | | | | | | | | | | | 211 | | | | | | | | | | | | | | | 212 | | | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | | 214 | | | | | | | | | | | | | | | 215 | | | | | | | | | | | | | | | 216 | | | | | | | | | | | | | | | 217 | | | | | | | | | | | | | | | 218 | | | | | | | | | | | | | | | 219 | | | | | | | | | | | | | | | 220 | | | | | | | | | | | | | | | 221 | | | | | | | | | | | | | | | 222 | | | | | | | | | | | | | | | 223 | | | | | | | | | | | | | | | 224 | | | | | | | | | | | | | | | 225 | | | | | | | | | | | | | | | 226 | | | | | | | | | | | | | | | 227 | | | | | | | | | | | | | | | 228 | | | | | | | | | | | | | | | 229 | | | | | | | | | | | | | | | 230 | | | | | | | | | | | | | | | 231 | | | | | | | | | | | | | | | 232 | | | | | | | | | | | | | | | 233 | | | | | | | | | | | | | | | 234 | | | | | | | | | | | | | | | 235 | | | | | | | | | | | | | | | 236 | | | | | | | | | | | | | | | 237 | | | | | | | | | | | | | | | 238 | | | | | | | | | | | | | | | 239 | | | | | | | | | | | | | | | 240 | | | | | | | | | | | | | | | 241 | | | | | | | | | | | | | | | 242 | | | | | | | | | | | | | | | 243 | | | | | | | | | | | | | | | 244 | | | | | | | | | | | | | | | 245 | | | | | | | | | | | | | | | 246 | | | | | | | | | | | | | | | 247 | | | | | | | | | | | | | | | 248 | | | | | | | | | | | | | | | 249 | | | | | | | | | | | | | | | 250 | | | | | | | | | | | | | | | 251 | | | | | | | | | | | | | | | 252 | | | | | | | | | | | | | | | 253 | | | | | | | | | | | | | | | 254 | | | | | | | | | | | | | | | 255 | | | | | | | | | | | | | | | 256 | | | | | | | | | | | | | | | 257 | | | | | | | | | | | | | | | 258 | | | | | | | | | | | | | | | 259 | | | | | | | | | | | | | | | 260 | | | | | | | | | | | | | | | 261 | | | | | | | | | | | | | | | 262 | | | | | | | | | | | | | | | 263 | | | | | | | | | | | | | | | 264 | | | | | | | | | | | | | | | 265 | | | | | | | | | | | | | | | 266 | | | | | | | | | | | | | | | 267 | | | | | | | | | | | | | | | 268 | | | | | | | | | | | | | | | 269 | | | | | | | | | | | | | | | 270 | | | | | | | | | | | | | | | 271 | | | | | | | | | | | | | | | 272 | | | | | | | | | | | | | | | 273 | | | | | | | | | | | | | | | 274 | | | | | | | | | | | | | | | 275 | | | | | | | | | | | | | | | 276 | | | | | | | | | | | | | | | 277 | | | | | | | | | | | | | | | 278 | | | | | | | | | | | | | | | 279 | | | | | | | | | | | | | | | 280 | | | | | | | | | | | | | | | 281 | | | | | | | | | | | | | | | 282 | | | | | | | | | | | | | | | 283 | | | | | | | | | | | | | | | 284 | | | | | | | | | | | | | | | 285 | | | | | | | | | | | | | | | 286 | | | | | | | | | | | | | | | 287 | | | | | | | | | | | | | | | 288 | | | | | | | | | | | | | | | 289 | | | | | | | | | | | | | | | 290 | | | | | | | | | | | | | | | 291 | | | | | | | | | | | | | | | 292 | | | | | | | | | | | | | | | 293 | | | | | | | | | | | | | | | 294 | | | | | | | | | | | | | | | 295 | | | | | | | | | | | | | | | 296 | | | | | | | | | | | | | | | 297 | | | | | | | | | | | | | | | 298 | | | | | | | | | | | | | | | 299 | | | | | | | | | | | | | | | 299 | | | | | | | | | | | | | | | 200 | | | | | | | | | | | | | | | 201 | | | | | | | | | | | | | | | 202 | | | | | | | | | | | | | | | 203 | | | | | | | | | | | | | | | 204 | | | | | | | | | | | | | | | 205 | | | | | | | | | | | | | | | 206 | | | | | | | | | | | | | | | 207 | | | | | | | | | | | | | | | 208 | | | | | | | | | | | | | | | 209 | | | | | | | | | | | | | | | 210 | | | | | | | | | | | | | | | 211 | | | | | | | | | | | | | | | 212 | | | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | | 214 | | | | | | | | | | | | | | | 215 | | | | | | | | | | | | | | | 216 | | | | | | | | | | | | | | | 217 | | | | | | | | | | | | | | | 218 | | | | | | | | | | | | | | | 219 | | | | | | | | | | | | | | | 220 | | | | | | | | | | | | | | | 222 | | | | | | | | | | | | | | | 221 | | | | | | | | | | | | | | | 223 | | | | | | | | | | | | | | | 224 | | | | | | | | | | | | | | | 225 | | | | | | | | | | | | | | 226 | | | | | | | | | | | | | | 226 | | | | | | | | | | | | | | 227 | | | | | | | | | | | | | | 228 | | | | | | | | | | | | | | 229 | | | | | | | | | | | | | | | 230 | | | | | | | | | | | | | | 231 | | | | | | | | | | | | | | 232 | | | | | | | | | | | | | | 232 | | | | | | | | | | | | | | 233 | | | | | | | | | | | | | | 233 | | | | | | | | | | | | | | 234 | | | | | | | | | | | | | | 235 | | | | | | | | | | | | | | 235 | | | | | | | | | | | | | | 236 | | | | | | | | | | | | | | 236 | | | | | | | | | | | | | | 237 | | | | | | | | | | | | | | 238 | | | | | | | | | | | | | | 239 | | | | | | | | | | | | | | 240 | | | | | | | | | | | | | | 241 | | | | | | | | | | | | | | 241 | | | | | | | | | | | | | | 242 | | | | | | | | | | | | | | 242 | | | | | | | | | | | | | | 243 | | | | | | | | | | | | | | 244 | | | | | | | | | | | | | | 244 | | | | | | | | | | | | | | 245 | | | | | | | | | | | | | | 246 | | | | | | | | | | | | | | 246 | | | | | | | | | | | | | | 247 | | | | | | | | | | | | | | 248 | | | | | | | | | | | | | | 249 | | | | | | | | | | | | | | 250 | | | | | | | | | | | | | | 251 | | | | | | | | | | | | | | 252 | | | | | | | | | | | | | | 253 | | | | | | | | | | | | | | 254 | | | | | | | | | | | | | | 255 | | | | | | | | | | | | | | 255 | | | | | | | | | | | | | | 256 | | | | | | | | | | | | | | 256 | | | | | | | | | | | | | | 257 | | | | | | | | | | | | | | 258 | | | | | | | | | | | | | | 259 | | | | | | | | | | | | | | 260 | | | | | | | | | | | | | | 261 | | | | | | | | | | | | | | 262 | | | | | | | | | | | | | | 262 | | | | | | | | | | | | | | 263 | | | | | | | | | | | | | 264 | | | | | | | | | | | | | 265 | | | | | | | | | | | | | 265 | | | | | | | | | | | | | 266 | | | | | | | | | | | | 267 | | | | | | | | | | | | 268 | | | | | | | | | | | | 268 | | | | | | | | | | | | 269 | | | | | | | | | | | | 270 | | | | | | | | | | | 271 | | | | | | | | | | | 272 | | | | | | | | | | | 273 | | | | | | | | | | 274 | | | | | | | | | | | 274 | | | | | | | | | | 275 | | | | | | | | | | 276 | | | | | | | | | | 276 | | | | | | | | | | | 28 | | | | | | | | | | | 28 | | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | | 29 | | | | | | | | | | | 29 | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 29 | | | | | | | | | | 2

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | E71 mai | | | | | | | | | | | | Service Company | Total | | | | | | | | | | | | | Recipient | | Recipient | | | | Adjustment | | | | | | | | | 4 | 4 | | | | Adjustment | | | | | | | | | 4 | 4 | | | | | | | | | | | | | 934 | 934 | | | | | | | | | | | | | 374 | 374 | | | | | | | | | | | | | 374 | | | | | | | | | | | | | | 456 | | | 456 | (456) | | | | | | | | | | 456 | | | | | | | | | | | | | | 14 | 14 | | | | | | | | | | | | | 14 | 14 | | | | | | | | | | | | | 2,585 | | | | | | | | | | | | | | 2,585 | | | | | | | | | | | | | | 2,585 | | | | | | | | | | | | | | 2582 | | | | | | | | | | | | | | 2582 | | | | | | | | | | | | | | | | | | | |

Amounts may not add or tie to other schedules due to rounding. Gardner, Kevin

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | EPI-Pair Binds | Exclusions | Pro Postop Amount | Total EPI Adjustment | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | | | | | | | | | | | | | Periphery | | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2728 | Balance of Peer Systems Gaps | DIRECTSER | 8,375 | 8,375 | 8,375 | 8,375 | | | | | nolחות | NOGCHICES | EGI | CMPPNG2729 | Improve Bus Duct &; Men IHmm | DIRECTSER | 2,674 | 2,674 | 2,674 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2730 | Measure Separate Planeteers | DIRECTSER | 23,804 | 23,804 | 23,804 | 23,804 | | | | | nolחות | NOGCHICES | EGI | CMPPNG2731 | 'EPU - Radial Well Addition (4 | DIRECTSER | 18,254 | 18,254 | 18,254 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2732 | CCW Heat Exchange Tube Clean | DIRECTSER | 2,458 | 2,458 | 2,458 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2733 | Turbine Generator Auxiliaries | DIRECTSER | 10,613 | 10,613 | 10,613 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2742 | Multiple Sensitive Operation (4) | DIRECTSER | 966 | 966 | 966 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2745 | GCW Radiological Ployng Proper | DIRECTSER | 2,722 | 2,722 | 2,722 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG2778 | Standby Tann. Water Capacity M | DIRECTSER | 1,892 | 1,892 | 1,892 | 1,892 | | | | | nolחות | NOGCHICES | EGI | CMPPNG6372 | INFRA. AND PC Reפרel 2015 | DIRCANOC | 890 | 890 | 890 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6387 | AND C Cyber Secure ty | DIRCANOC | 198 | 198 | 198 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6391 | GCMS Cyber Security | DIRECTSER | 198 | 198 | 198 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6392 | RIBS Cyber Security | DIRECTSER | 198 | 198 | 198 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG3393 | WFS Cyber Security | DIRECTSKF3 | 198 | 198 | 198 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6394 | INFRA. AND PC Reפרel 2011 | DIRCANOC | 428 | 428 | 428 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6417 | Steam Generator Replacement | DIRECTSKF3 | 90,113 | 90,113 | 90,113 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6436 | Repl Reactor Vessel Closure He | DIRECTSKF3 | 1,739 | 1,739 | 1,739 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6489 | Herrup Five Rings | DIRECTSKF3 | 703 | 703 | 703 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6702 | CEA Repl | DIRECTSKF3 | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6785 | 10CPKTV Fleet Security Project | DIRECTSKF3 | 2,313 | 2,313 | 2,313 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6799 | Remote Operated Weapons | DIRECTSKF3 | 2,050 | 2,050 | 2,050 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6800 | Misa Security Mode | DIRECTSKF3 | 14,266 | 14,266 | 14,266 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6828 | NFPA 805 Phase 2 | DIRECTSKF3 | 22,581 | 22,581 | 22,581 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6836 | Radiological Ployng Project | DIRECTSKF3 | 2,718 | 2,718 | 2,718 | | | | | | nolחות | NOGCHICES | EGI | CMPPNG6876 | Cladding Future Fleet Cause 8 | DIRECTSKF3 | 27,636 | 27,636 | 27,636 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71015 | MIRA STAYSYN TRANSPLORMEN (W76) | DIRECTRBS | (630) | (630) | (630) | | | | | | nolחות | NOGCHICES | EGI | CMPPN71159 | STA TRANSPLORMEN RAPLORMANNENT | DIRECTRBS | 412 | 412 | 412 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71165 | ENOR CODE PROG &; MUC SAFTY AMA | DIRECTRBS | 46 | 46 | 46 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71499 | SECURITY. STUDY/FARA LOTANAG | DIRECTRBS | 737 | 737 | 737 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71532 | SECURITY. WOMITRAG/SEITECTNALA | DIRECTRBS | 1,574 | 1,574 | 1,574 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71534 | SECURITY. WEMOTE CIRONITED WEAP | DIRECTRBS | 2,049 | 2,049 | 2,049 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71535 | SECURITY. WISC, SECURITY WOOS | DIRECTRBS | 17,458 | 17,458 | 17,458 | | | | | | nolחות | NOGCHICES | EGI | CMPPN71555 | MULTIPLE IPLOROUS CIRONITERAS | DIRECTRBS | (193) | (193) | (193) | | | | | | nolחות | NOGCHICES | EGI | CMPPN71574 | RADIOLOSICIA, PIPPAS PROJICOT | DIRECTRBS | 2,721 | 2,721 | 2,721 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7125 | ANCE Monitoring Detection CIRD | DIRECTANOC | 18,346 | 18,346 | 18,346 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7127 | ANCE Remote Operated Weapons 6 | DIRCANOC | 2,563 | 2,563 | 2,563 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7240 | ANCE RV Vessel Head Flail Mpr5 | DIRCANOC | 695 | 695 | 695 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7267 | ANCE CEOM Purchase | DIRCANOC | 53 | 53 | 53 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7421 | ANCI Mass Generator Evaler | DIRCANOC | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7464 | ANCI Mass Generator Stake New | DIRCANOC | 1,208 | 1,208 | 1,208 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7584 | Replace Inadequate Security Eq | DIRCANOC | 37 | 37 | 37 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7613 | ANCI Risk Based Fire Prev.IVFP | DIRCANOC | 15,032 | 15,032 | 15,032 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7701 | Replace LIA 1 HIPP Governor VG | DIRCANOC | 3,049 | 3,049 | 3,049 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7734 | ANCE Risk Based Fire Prev.IVFP | DIRCANOC | 4,391 | 4,391 | 4,391 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7845 | ANCI LIAI Acc Transformer Repl | DIRCANOC | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNB7867 | ANCI NCR Pro Vaccino Allergy RF | DIRCANOC | 664 | 664 | 664 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB8085 | SCCA Hearing &; VBS | DIRCANOC | 706 | 706 | 706 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB8087 | ANCI Implement Corona Perника | DIRCANOC | 6,297 | 6,297 | 6,297 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB8097 | ANCI Alloy 600 Station Mounted | DIRCANOC | 1,541 | 1,541 | 1,541 | | | | | | nolחות | NOGCHICES | EGI | CMPPNB8110 | ANCI Radiologist Ployng Proper | DIRCANOC | 2,684 | 2,684 | 2,684 | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1204 | Goose Replace Cap Bank Pared | DIRECTEU | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1205 | Hymniont Matrix Fused TV VPMR | DIRECTEU | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1241 | Jubie Replace 2011-6 | DIRECTEAC | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1242 | Jubie Replace 2012-4 | DIRECTEAC | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1243 | Triboideur Replace 10015 | DIRECTEU | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1244 | Resident Replace 03315 | DIRECTEU | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1245 | Transborne Replace 09148 | DIRECTEU | 111 | 111 | 111 | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1246 | On- James. Replace 66006 | DIRECTEU | | | | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1248 | Pseudo Replace CHIR Resident | DIRECTEU | 608 | 608 | 608 | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1250 | J. Gypsy. Relationship Line Per | DIRECTEU | 2,501 | 2,501 | 2,501 | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1253 | Ammoneter Replace 671-5. | DIRECTEAC | 814 | 814 | 814 | | | | | | nolחות | NOGCHICES | EGI | CMPPNA1254 | Ammoneter Replace 672-6. | DIRECTEAC | 349 | 349 | 349 | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLVs | ETV Pair | | | | | | | | | | | | | | | Business | | | | | | | | | | | | | | Amount | Adjusting | | nol | | CMPPRA1255 | Trous Reptore 2314-5 | DIRECTEND | 922 | | 922 | 922 | | | | | | | | CMPPRA1260 | Market Upgrade Ontigny Line P | DIRECTEND | 2,857 | | 2,857 | 2,857 | | | | | | | | CMPPRA1261 | Ontigny Upgrade Material Line P | DIRECTEND | 1,504 | | 1,504 | 1,504 | | | | | | | | CMPPRA1263 | Market Upgrade Delta Line Req | DIRECTEND | 1,645 | | 2,521 | 2,521 | | | | | | | | CMPPRA1264 | Delta Upgrade Material Line Req | DIRECTEND | 1,645 | | 1,645 | 1,645 | | | | | | | | CMPPRA1265 | Market Upgrade Minerva Requt | DIRECTEND | 1,438 | | 1,438 | 1,438 | | | | | | | | CMPPRA1266 | Ontigny Minerville Requt Upgrad | DIRECTEND | 1,068 | | 1,068 | 1,068 | | | | | | | | CMPPRA1267 | Mersev Feeder Fault Locator P1 | DIRECTELI | 13 | | 13 | 13 | | | | | | | | CMPPRA1268 | Estelle Feeder Fault Locator | DIRECTELI | 39 | | 39 | 39 | | | | | | | | CMPPRA1269 | Peters Rd. Feeder Fault Locator | DIRECTELI | 260 | | 260 | 260 | | | | | | | | CMPPRA1270 | Market 220 Fault Locator Feed | DIRECTEND | 224 | | 234 | 234 | | | | | | | | CMPPRA1271 | S. Forest Feeder Fault Locator | DIRECTEND | 13 | | 13 | 13 | | | | | | | | CMPPRA1272 | Trous Feeder Fault Locator P1 | DIRECTEND | 13 | | 13 | 13 | | | | | | | | CMPPRA1273 | G. Outlet Feeder Fault Locator | DIRECTEND | 172 | | 172 | 172 | | | | | | | | CMPPRA1274 | Peterson Feeder Fault Locator | DIRECTEND | 13 | | 13 | 13 | | | | | | | | CMPPRA1277 | Ammonster Feeder Fault Locator | DIRECTEND | 39 | | 39 | 39 | | | | | | | | CMPPRA1283 | Evergreen Reptore CCB 61102 | DIRECTELI | | | | | | | | | | | | CMPPRA1296 | Trous Feeders CNF 2325 Insta | DIRECTEND | 305 | | 305 | 305 | | | | | | | | CMPPRA1297 | Tansborne 11 A 72 Different | DIRECTELI | 206 | | 206 | 206 | | | | | | | | CMPPRA1304 | Beratana Minerville Requt Panel | DIRECTELI | 1,528 | | 1,528 | 1,528 | | | | | | | | CMPPRA1305 | Minerville Beratana Line Requt | DIRECTELI | 1,469 | | 1,469 | 1,469 | | | | | | | | CMPPRA1306 | Beratana G Meadane Line Panel | DIRECTELI | 1,129 | | 1,129 | 1,129 | | | | | | | | CMPPRA1307 | G Meadane Beratana Line Panel | DIRECTELI | 1,720 | | 1,720 | 1,720 | | | | | | | | CMPPRA1308 | Golden Meadow Valsmoke Panel | DIRECTELI | 2,210 | | 2,210 | 2,210 | | | | | | | | CMPPRA1309 | Valsmoke Golden Meadow Panel | DIRECTELI | 2,251 | | 2,251 | 2,251 | | | | | | | | CMPPRA1311 | Trous Add Feeder Breaker (2)A | DIRECTEND | 42 | | 42 | 42 | | | | | | | | CMPPRA1312 | Rascerec Uappeside Feeder Bire | DIRECTELI | 1,369 | | 1,369 | 1,369 | | | | | | | | CMPPRA1315 | Cloudly, Instad Insta Trap | DIRECTELI | 461 | | 461 | 461 | | | | | | | | CMPPRA1316 | Minerville Reptore Line Trap | DIRECTELI | 32 | | 32 | 32 | | | | | | | | CMPPRA1320 | Megapense Feeder Fault Locator | DIRECTELI | 33 | | 33 | 33 | | | | | | | | CMPPRA1321 | McIntosh, Reptore 99403 | DIRECTEND | 119 | | 119 | 119 | | | | | | | | CMPPRA1322 | Atlantic Reptore 91123 | DIRECTELI | 76 | | 76 | 76 | | | | | | | | CMPPRA1323 | Source. Reptore 96132 | DIRECTELI | 83 | | 83 | 83 | | | | | | | | CMPPRA1324 | Minerville Reptore Watertank Pair | DIRECTELI | 543 | | 543 | 543 | | | | | | | | CMPPRA1325 | Betty Point Reptore C645 | DIRECTELI | 442 | | 442 | 442 | | | | | | | | CMPPRA1326 | Golden Meadow Reptore 43732 | DIRECTELI | 378 | | 378 | 378 | | | | | | | | CMPPRA1327 | Vacherm Reptore 49504 | DIRECTELI | 30 | | 30 | 30 | | | | | | | | CMPPRA1332 | Deuterium. Reptore 83915 | DIRECTELI | 76 | | 76 | 76 | | | | | | | | CMPPRA1333 | History Reptore 10011 A 11912 | DIRECTELI | 566 | | 566 | 566 | | | | | | | | CMPPRA6001 | New Nuclear Consortium | DIRECTR1 | | | | | | | | | | | | CMPPRA6002 | New Nuclear. Eirtingy | DIRECTR1 | | | | | | | | | | | | CMPPRA6010 | New Nuclear. Reputator, Fi in | DIRECTR1 | | | | | | | | | | | | CMPPRNA602 | New Nuclear Eirir. Ongoing 603 | DIRECTE66 | | | | | | | | | | | | CMPPRNA604 | New Nuclear Eirir. Ongoing 1633 (1) | DIRECTE66 | 337 | | 337 | 337 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Shiga Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Shiga Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Shiga Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Shiga Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | Capture Transformer. Coat | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | | | | | CMPPRAVOPAR | CMPR 125505 | DIRECTELI | 1,832 | | 1,832 | 1,832 | | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS0091 | Tyreissen -9R38 8/4. Replavement | DIRECTESE | 126 | | | 126 | 126 | | | | | incisies NCSCURICE | ESI | CSIPPTS0155 | the Bera -Ugraphe Line Bay | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS0166 | Canton, South -Ins Dist Pan1 | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS0167 | Geneet -Ins Dist Paul Loc | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS0168 | Northport -Ins Dist Paul Loc | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS0169 | Baxter Wilson -Rp J/AR1 Reqol | DIRECTESE | 213 | | | 213 | 213 | | | | | incisies NCSCURICE | ESI | CSIPPTS0173 | Vividravg E Add TOC controls A | DIRECTESE | 4,324 | | | 4,324 | 4,324 | | | | | incisies NCSCURICE | ESI | CSIPPTS0185 | Vividravg -Rp Ray Braweel Loc | DIRECTESE | 129 | | | 129 | 129 | | | | | incisies NCSCURICE | ESI | CSIPPTS0187 | Ray Braweel -Rp Vividravg Ln | DIRECTESE | 865 | | | 865 | 865 | | | | | incisies NCSCURICE | ESI | CSIPPTS0208 | BMSES -Rp MGAR5 E1 Dt Dt 37 | DIRECTESE | 195 | | | 195 | 195 | | | | | incisies NCSCURICE | ESI | CSIPPTS0206 | Tunica ESt -Rp Horn Lake Ln P | DIRECTESE | 290 | | | 290 | 290 | | | | | incisies NCSCURICE | ESI | CSIPPTS0267 | Horn Lake -Rp Tunica Line Pan | DIRECTESE | 612 | | | 612 | 612 | | | | | incisies NCSCURICE | ESI | CSIPPTS2009 | Greenwood Substation -Ugraphe | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3016 | EMS Host Plan-Expenses Erreop | DIRECTEAL | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3151 | Oxy Regulation Service | DIRECTELI | 16 | | | 16 | 16 | | | | | incisies NCSCURICE | ESI | CSIPPTS3168 | South Jackson-Sub RTU-Ugraphe | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3169 | SCADA Memorations Jackson -D0 | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3175 | Purchase Generator for SOC | DIRECTEAL | 2,212 | | | 2,212 | 2,212 | | | | | incisies NCSCURICE | ESI | CSIPPTS3182 | 5 Beaumont PMS Inseal DOE 500 | DIRECTT7A | 991 | | | 991 | | 991 | | | | incisies NCSCURICE | ESI | CSIPPTS3183 | Dayton Bulk PMS Inseal DOE 500 | DIRECTT7A | 1,891 | | | 1,891 | | 1,891 | (1,891) | | | incisies NCSCURICE | ESI | CSIPPTS3184 | Green Sulk PMS Inseal DOE 500 | DIRECTT7A | 1,185 | | | 1,185 | | 1,185 | (1,185) | | | incisies NCSCURICE | ESI | CSIPPTS3185 | Grenes Sulk PMS Inseal DOE 500 | DIRECTT7A | 1,043 | | | 1,043 | | 1,043 | (1,043) | | | incisies NCSCURICE | ESI | CSIPPTS3186 | Neches Sta. Sub PMS Inseal 500 | DIRECTT7A | 801 | | | 801 | | 801 | | | | incisies NCSCURICE | ESI | CSIPPTS3187 | Cinna Sulk PMS Inseal DOE 500G | DIRECTT7A | 801 | | | 801 | | 801 | | | | incisies NCSCURICE | ESI | CSIPPTS3188 | Nelson Sulk PMS Inseal DOE 500 | DIRECTTLI3 | 1,160 | | | 1,160 | 1,160 | | | | | incisies NCSCURICE | ESI | CSIPPTS3191 | New Security Over Design TOC-S | DIRECTELI | 549 | | | 549 | 549 | | | | | incisies NCSCURICE | ESI | CSIPPTS3192 | Addibone Voice Recorder Cree | DIRECTLQ | 40 | | | 40 | 40 | | | | | incisies NCSCURICE | ESI | CSIPPTS3193 | ANO Sub PMS Insealtator-DOE 5 | DIRECTEAL | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3194 | El Dorado Sulk PMS Inseal DOE | DIRECTEAL | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3195 | San-Sue PMS Inseal DOE 5000 | DIRECTEAL | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3196 | Mabecata Sulk PMS Inseal DOE | DIRECTEAL | 186 | | | 186 | 186 | | | | | incisies NCSCURICE | ESI | CSIPPTS3197 | Ray Braweel PMS Inseal DOE 5 | DIRECTESE | 204 | | | 204 | 204 | | | | | incisies NCSCURICE | ESI | CSIPPTS3198 | Rev Brown PMS Inseal DOE 5000 | DIRECTESE | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3199 | Grand Gulf PMS Inseal DOE 500 | DIRECTESE | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3200 | Farny Point PMS Inseal DOE 500 | DIRECTLQ | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3201 | California State PMS Inseal DOE | DIRECTEAL | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3202 | Voice Recorder -Bouymont DOC | DIRECTT7A | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3203 | Voice Recorder -Bouymont TOC | DIRECTT7A | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3208 | Voice Recorder -Graters DOC | DIRECTELL | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3209 | Voice Recorder -Graters DOC | DIRECTEER | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3210 | Voice Recorder -Jackson TOC | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3211 | Voice Recorder -Jackson TOC | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3212 | Voice Recorder -Wexillamod TOC | DIRECTEL | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3213 | US TOC Replaced Design (PVC) | DIRECTEAL | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3224 | US TOC Replaced Design (PVC) | DIRECTEAL | 1,906 | | | 1,906 | 1,906 | | | | | incisies NCSCURICE | ESI | CSIPPTS3226 | SMP FRONTING ECLIP MA110-AC6-DE | DIRECTLQ | 1,906 | | | 1,906 | 1,906 | | | | | incisies NCSCURICE | ESI | CSIPPTS3227 | US TOC PCUADUS 00PLU1490H7 | DIRECTEAL | 7,729 | | | 7,729 | 7,729 | | | | | incisies NCSCURICE | ESI | CSIPPTS3231 | SMP SCADA ALPPHAY 06/CV6/AC62-DE | DIRECTELL | 11,135 | | | 11,135 | 11,135 | | | | | incisies NCSCURICE | ESI | CSIPPTS3232 | BEALMONY SOC PSP MOLU0668H1 | DIRECTT7A | 372 | | | 372 | | 372 | | | | incisies NCSCURICE | ESI | CSIPPTS3234 | BEALMONY SOC REP MOLU0668H1 | DIRECTT7A | 480 | | | 480 | | 480 | | | | incisies NCSCURICE | ESI | CSIPPTS3400 | Novartis Sub PMS Inseal DOE 5 | DIRECTELI | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3401 | Novartis PMS Inseal DOE 5000 | DIRECTELI | 335 | | | 335 | 335 | | | | | incisies NCSCURICE | ESI | CSIPPTS3402 | Sterilogon PMS Inseal DOE 50 | DIRECTELI | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3403 | Microval Sup PMS Inseal DOE 500 | DIRECTEW2 | 167 | | | 167 | 167 | | | | | incisies NCSCURICE | ESI | CSIPPTS3404 | Mictow Topal New Frieed | DIRECTELI | 167 | | | 167 | | | | | | incisies NCSCURICE | ESI | CSIPPTS3423 | Sterilogon -1Vin1 PMS Inseale | DIRECTELI | 82 | | | 82 | 82 | | | | | incisies NCSCURICE | ESI | CSIPPTS3427 | Porter Sub PMS Inseal DOE 500 | DIRECTT7A | 82 | | | 82 | | 82 | (82) | | | incisies NCSCURICE | ESI | CSIPPTS3428 | Jacinto Sulc PMS Inseal DOE 50 | DIRECTT7A | 82 | | | 82 | | 82 | (82) | | | incisies NCSCURICE | ESI | CSIPPTS3570 | 5-Formate Add T Mateler Lh Rsa | DIRECTESE | 15,898 | | | 15,898 | 15,898 | | | | | incisies NCSCURICE | ESI | CSIPPTS3429 | Schraier Sub -Add Capacitor Ise | DIRECTESE | | | | | | | | | | incisies NCSCURICE | ESI | CSIPPTS3440 | Winona Sub -Add Capacitor Illees | DIRECTESE | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLSs | ETC Plan Binds | Exclusions | Pro Posting Amount | Total ETC Adjudices | | | | | | | | | Receptor | | | | | | | | nolחות RESOURCES | ESt | CSPIPTFRSAA | Capture Transformer Slope Coat | DIRCTEAI | | 2,320 | | 2,320 | 2,320 | | | | | nolחות RESOURCES | ESt | CSPIPTFRSOA | Capture Transformer Slope Coat | DIRCCTLL | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTFRSMO | Capture Transformer Coat MII | DIRCTEMI | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTFRSMO | Capture Transformer Slope Coat | DIRCTEMO | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTFRSTX | Capture Transformer Slope Coat | DIRCCTTX | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTGA063 | Shredder. Pearl 90 10KX we 6-1 | DIRCTEAI | | 164 | | 164 | 164 | | | | | nolחות RESOURCES | ESt | CSPIPTGA079 | Amity Y351 q4s 90 Y351 a6ac | DIRCTEAI | | 82 | | 82 | 82 | | | | | nolחות RESOURCES | ESt | CSPIPTGA086 | Stollgart R, Japp CCB C211 8-C | DIRCTEAI | | 930 | | 930 | 930 | | | | | nolחות RESOURCES | ESt | CSPIPTGA095 | L.R.Chour, Pearl Failed 41 XPW | DIRCTEAI | | 846 | | 846 | 846 | | | | | nolחות RESOURCES | ESt | CSPIPTGA110 | Deri EPH. Pup failed carrier 9 | DIRCTEAI | | 311 | | 311 | 311 | | | | | nolחות RESOURCES | ESt | CSPIPTGA111 | 0003 Pup failed carrier 8 5cm | DIRCTEAI | | 419 | | 419 | 419 | | | | | nolחות RESOURCES | ESt | CSPIPTGA113 | Elaine, Pearl 90 E9000 w 005 | DIRCTEAI | | 44 | | 44 | 44 | | | | | nolחות RESOURCES | ESt | CSPIPTGA133 | Sherrill, Instar Animal Mibg | DIRCTEAI | | 51 | | 51 | 51 | | | | | nolחות RESOURCES | ESt | CSPIPTGA143 | Evender Mir. Pup 5d 7PQ w 38 | DIRCTEAI | | 330 | | 330 | 330 | | | | | nolחות RESOURCES | ESt | CSPIPTGA146 | Antishrone, q4s carrierin rel | DIRCTEAI | | 86 | | 86 | 86 | | | | | nolחות RESOURCES | ESt | CSPIPTGA147 | Carpenter Gem, q4s line relay | DIRCTEAI | | 94 | | 94 | 94 | | | | | nolחות RESOURCES | ESt | CSPIPTGA155 | Amity SS, Relay. Hipwormia Am8 | DIRCTEAI | | 916 | | 916 | 916 | | | | | nolחות RESOURCES | ESt | CSPIPTGA162 | Syman Hilly, Pearl 80012 CCB | DIRCTEAI | | 1,371 | | 1,371 | 1,371 | | | | | nolחות RESOURCES | ESt | CSPIPTGA163 | Syman Hilly, Pearl 80005 CCB | DIRCTEAI | | 1,538 | | 1,538 | 1,538 | | | | | nolחות RESOURCES | ESt | CSPIPTGA170 | Studth SS, Aad CM2 on 80001A | DIRCTEAI | | 6 | | 6 | 6 | | | | | nolחות RESOURCES | ESt | CSPIPTGA171 | FoxCryph SS, Aad CM2 @ 80017A | DIRCTEAI | | 3 | | 3 | 3 | | | | | nolחות RESOURCES | ESt | CSPIPTGA173 | Fisher, Aad CM2 o 80156 | DIRCTEAI | | 9 | | 9 | 9 | | | | | nolחות RESOURCES | ESt | CSPIPTGA179 | McNe1, Pearl 90 110kV CCB 802 | DIRCTEAI | | 1,502 | | 1,502 | 1,502 | | | | | nolחות RESOURCES | ESt | CSPIPTGA180 | Fortipye, 72 Chour Switch Gpp | DIRCTEAI | | 572 | | 572 | 572 | | | | | nolחות RESOURCES | ESt | CSPIPTGA190 | Hamburg, Uggreble Or Sw 80/777 | DIRCTEAI | | 1,109 | | 1,109 | 1,109 | | | | | nolחות RESOURCES | ESt | CSPIPTGA191 | McGelrew, Uggreble Or Sw 80029 | DIRCTEAI | | 768 | | 768 | 768 | | | | | nolחות RESOURCES | ESt | CSPIPTGA206 | PR Whirter, Pearl Israel 97Cr | DIRCTEAI | | 68 | | 68 | 68 | | | | | nolחות RESOURCES | ESt | CSPIPTGA211 | W.Mengetic 8.HV, Pearl Fade 161 | DIRCTEAI | | 9 | | 9 | 9 | | | | | nolחות RESOURCES | ESt | CSPIPTGA217 | Quitman 16 Rev q4s/three 80021 | DIRCTEAI | | 878 | | 878 | 878 | | | | | nolחות RESOURCES | ESt | CSPIPTGA222 | Eng WG 5s Top Cat Minimum | DIRCTEAI | | 607 | | 607 | 607 | | | | | nolחות RESOURCES | ESt | CSPIPTL1144 | LDBLOLLY HAMMOND 483W LMB 200 | DIRSCTLL | | 5,648 | | 5,648 | 5,648 | | | | | nolחות RESOURCES | ESt | CSPIPTL1147 | Gelsville, Wiersma Build 206VJ | DIRCTEL | | 4,197 | | 4,197 | 4,197 | | | | | nolחות RESOURCES | ESt | CSPIPTL1212 | COLY-LDBLOLLY, build new 80kV | DIRSCTLL | | 2,512 | | 2,512 | 2,512 | | | | | nolחות RESOURCES | ESt | CSPIPTL1227 | Leftsdon Thomas, Motely L514 | DIRSCTLL | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTL1228 | Leftsdon-McKoon, 80kV Cut In | DIRSCTLL | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTL1298 | Bermwater-Low L-112 Cut In | DIRSCTTX | | 47 | | 47 | | 47 | (47) | | | nolחות RESOURCES | ESt | CSPIPTL2583 | DSG, NW-Bilagator-Walkle 110kV In | DIRCTEL | | 186 | | 186 | 186 | | | | | nolחות RESOURCES | ESt | CSPIPTL2602 | Line 274 Bu 4t New 20001 Line | DIRCTEL | | 5,720 | | 5,720 | 5,720 | | | | | nolחות RESOURCES | ESt | CSPIPTL2624 | DSG, Gpp Newber River Company | DIRCTEL | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTL2644 | Lu-Ag Amer Cyan 110kV Line II | DIRCTEL | | 360 | | 360 | 360 | | | | | nolחות RESOURCES | ESt | CSPIPTL2803 | Leeuillier Function 5.228c 7-LI | DIRCTEL | | 1,768 | | 1,768 | 1,768 | | | | | nolחות RESOURCES | ESt | CSPIPTL2804 | Western Meadow Leavelle 2.145 | DIRCTEL | | 1,538 | | 1,538 | 1,538 | | | | | nolחות RESOURCES | ESt | CSPIPTL2853 | Line 175, Hylow - Blue 800m | DIRSCTTX | (2,788) | (2,788) | | | | (2,788) | 2,788 | | | nolחות RESOURCES | ESt | CSPIPTL2899 | Omer lo Cayon 80ek Line 88 | DIRSCTTX | | 1,141 | | 1,141 | | 1,141 | (1,141) | | | nolחות RESOURCES | ESt | CSPIPTL4200 | Lincoln-Lewis Creek 23001 Line | DIRSCTTX | | 2,788 | | 2,788 | | 2,788 | (2,788) | | | nolחות RESOURCES | ESt | CSPIPTL4450 | Tormen to Hemsbury, Tag 191KV | DIRCTEAI | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTL4462 | Tworkstone, CA, 8d, Build New | DIRCTEMI | | 3,073 | | 3,073 | 3,073 | | | | | nolחות RESOURCES | ESt | CSPIPTL4485 | 110kV 1-Low 1 P. In Surrealism | DIRCTEMI | | 11,716 | | 11,716 | | | | | | nolחות RESOURCES | ESt | CSPIPTL4487 | Alidos-Carlingel in Our For Open | DIRCTEMI | | 210 | | 210 | 210 | | | | | nolחות RESOURCES | ESt | CSPIPTL4488 | Giedifolge Defin Cut In to Center | DIRCTEL | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTL4489 | Horn-Lane 7t/49w, Rebuted 101KV | DIRCTEMI | | (142) | | (142) | | | | | | nolחות RESOURCES | ESt | CSPIPTL4490 | Wadenswail E. Hockesay Line I2p | DIRCTEMI | | 9,755 | | 9,755 | 9,755 | | | | | nolחות RESOURCES | ESt | CSPIPTL4491 | General Secondary Build New L | DIRCTEMI | | 391 | | 391 | 391 | | | | | nolחות RESOURCES | ESt | CSPIPTL4492 | Calhoun Build new 115 kV line | DIRCTEL | | 3,527 | | 3,527 | 3,527 | | | | | nolחות RESOURCES | ESt | CSPIPTL4493 | Church-Rel General Build New L | DIRCTEMI | | 12,005 | | 12,005 | 12,005 | | | | | nolחות RESOURCES | ESt | CSPIPTL4498 | Nelson to Missa Bluff New 200kV | DIRSCTLL | | 3,239 | | 3,239 | 3,239 | | | | | nolחות RESOURCES | ESt | CSPIPTL4499 | New 200kV line - Bedeos | DIRCTEL | | (2,852) | | (2,852) | (2,852) | | | | | nolחות RESOURCES | ESt | CSPIPTL4533 | Line 827 -RON Frontouse | DIRSCTTX | | | | | | | | | | nolחות RESOURCES | ESt | CSPIPTL4587 | Cypress - Leavine New Line 835t | DIRSCTTX | | (31,421) | | (31,421) | | (31,421) | 10,438 | 20,962 | | nolחות RESOURCES | ESt | CSPIPTL4588 | Frontier - Glimeer, New Line 835 | DIRSCTTX | | (8,046) | | (8,046) | | (8,046) | 1,621 | 6,425 | | nolחות RESOURCES | ESt | CSPIPTL4813 | Line 740 - Remona Avenue | DIRSCTTX | | | | | | | | |

| | | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Eneld | Activity / Project Code | Activity / Project Description | ESt Billing Method | $\frac{\text{Cold Billing}}{\text{Support}}$ | $\text{Tension Company}\text{Recipient}$ | Total | All Other BLPs | ETT-Per Binds | Exclusions | Pro Postep Amount | Total ETT Adjudices | | incense NCSCURGES | ESt | CSPIPTL5099 | Yellow Glen Conway New 2000 r.l. | DIRECTS (I) | 7,570 | | 7,570 | 7,570 | | | | | | incense NCSCURGES | ESt | CSPIPTL5400 | Merito L17. Bush tr.Cox River | DIRECTT (I) | 5,200 | | 5,200 | | 5,200 | | | | | incense NCSCURGES | ESt | CSPIPTL5430 | -Lover's - Line Relocation | DIRECTS (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL5552 | Line 552 - Ugarate Line | DIRECTT (I) | 119 | | 119 | | 119 | | (119) | | | incense NCSCURGES | ESt | CSPIPTL5563 | Line 563 - Ugarate Line | DIRECTT (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL5591 | Line 591 - Ugarate Line | DIRECTT (I) | 156 | | 156 | | 156 | | (156) | | | incense NCSCURGES | ESt | CSPIPTL7133 | D5S2. RM-Wag Washi 115 to 2000 V | DIRECTS (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL7160 | Prise Dirt Oant. Med Los at Good | DIRECTS (I) | 2,238 | | 2,238 | 2,238 | | | | | | incense NCSCURGES | ESt | CSPIPTL7175 | Steritogion (PCG) 115 -Ugarate | DIRECTS (I) | 4,117 | | 4,117 | 4,117 | | | | | | incense NCSCURGES | ESt | CSPIPTL7176 | (PCG) Baseline 175 -Ugarate Line | DIRECTS (I) | 5,063 | | 5,063 | 5,063 | | | | | | incense NCSCURGES | ESt | CSPIPTL7177 | Beering-Lug Cukm 115 -Ugar L | DIRECTS (I) | 3,573 | | 3,573 | 3,573 | | | | | | incense NCSCURGES | ESt | CSPIPTL7178 | Welma'Drove Geach 115 -Ugar L | DIRECTS (I) | 2,746 | | 6,746 | 6,746 | | | | | | incense NCSCURGES | ESt | CSPIPTL7179 | Froahivift-Riba 115 -Ugar LII | DIRECTS (I) | 602 | | 602 | 602 | | | | | | incense NCSCURGES | ESt | CSPIPTL7181 | Steritogion -Aula 82 Tse Lo Up | DIRECTS (I) | 2,019 | | 2,019 | 2,019 | | | | | | incense NCSCURGES | ESt | CSPIPTL7184 | Carsoni'fft-Dem 115 -Reese at D | DIRECTS (I) | 107 | | 107 | 107 | | | | | | incense NCSCURGES | ESt | CSPIPTL7191 | Stri-Crew -Reese Lo at Seating | DIRECTS (I) | 1,210 | | 1,210 | 1,210 | | | | | | incense NCSCURGES | ESt | CSPIPTL7192 | Stri-Gen Tash. Rancate Line | DIRECTS (I) | 1,306 | | 1,306 | 1,306 | | | | | | incense NCSCURGES | ESt | CSPIPTL7198 | Barnet Wilson -Aula 82 Tse Lo | DIRECTE (M) | 750 | | 750 | 750 | | | | | | incense NCSCURGES | ESt | CSPIPTL7202 | InonBen-Tecours -Bu 65 New LII | DIRECTS (I) | 8,599 | | 8,599 | 8,599 | | | | | | incense NCSCURGES | ESt | CSPIPTL7244 | Waterford-Tecours (2004) -Madii | DIRECTS (I) | 423 | | 423 | 423 | | | | | | incense NCSCURGES | ESt | CSPIPTL7299 | Tescuno-Bio te-Port -Rancate | DIRECTS (I) | 188 | | 188 | 188 | | | | | | incense NCSCURGES | ESt | CSPIPTL7311 | L. Dappy Bayou 30 -InonBen-Cui | DIRECTS (I) | 242 | | 242 | 242 | | | | | | incense NCSCURGES | ESt | CSPIPTL7396 | AUTO11 -Champagne-Bu 1 Knot-S | DIRECTS (I) | 69 | | 69 | 69 | | | | | | incense NCSCURGES | ESt | CSPIPTL7397 | AUTO11 -Cottonal Lansing | DIRECTS (I) | 70 | | 70 | 70 | | | | | | incense NCSCURGES | ESt | CSPIPTL7500 | Line 186 -Cui in Bayou-Lakotte | DIRECTS (I) | 4,896 | | 4,896 | 4,896 | | | | | | incense NCSCURGES | ESt | CSPIPTL7502 | Line 266 -Bu 66 New 2000 V | DIRECTS (I) | 3,428 | | 3,428 | 3,428 | | | | | | incense NCSCURGES | ESt | CSPIPTL7504 | Line 730 -Rancade 2000 V Line | DIRECTS (I) | 3,821 | | 3,821 | 3,821 | | | | | | incense NCSCURGES | ESt | CSPIPTL7505 | Line 740 -Rancade 2000 V Line | DIRECTS (I) | 3,387 | | 3,387 | 3,387 | | | | | | incense NCSCURGES | ESt | CSPIPTL7506 | Line 186 -Rancade deadend, B | DIRECTS (I) | 30 | | 30 | 30 | | | | | | incense NCSCURGES | ESt | CSPIPTL8269 | JNEC - I -user of 690 V-Line 30 | DIRECTT (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL8275 | SHSKE &; KHRI New -Rancadon-J | DIRECTT (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL8321 | Jamninga Lansing -Ugarit 106-66/A | DIRECTS (I) | (9,073) | | (9,073) | | | | | | | incense NCSCURGES | ESt | CSPIPTL8457 | L385 Rancade Gux Str. 66 | DIRECTT (I) | 30 | | 30 | | | 30 | (30) | | | incense NCSCURGES | ESt | CSPIPTL8507 | Коларол-And-NICO-hr -Sелюмод | DIRECTT (I) | 752 | | 752 | | | 752 | (752) | | | incense NCSCURGES | ESt | CSPIPTL8508 | Hacharine-And-NICO-hr-Sелюмод | DIRECTT (I) | 322 | | 322 | | | 322 | (322) | | | incense NCSCURGES | ESt | CSPIPTL8509 | Baydrove And-NICO-hr-Sелюмод | DIRECTT (I) | 284 | | 284 | | | 284 | (284) | | | incense NCSCURGES | ESt | CSPIPTL8511 | Sponteya-And-NICO-hr-Sелюмод | DIRECTT (I) | 90 | | 90 | | | 90 | (90) | | | incense NCSCURGES | ESt | CSPIPTL8512 | Siddon-And-NICO-hr-Sелюмод | DIRECTT (I) | 156 | | 156 | | | 156 | (156) | | | incense NCSCURGES | ESt | CSPIPTL8834 | Juneabore St to Juneabore Line | DIRECTE(A) | 55 | | 55 | 55 | | | | | | incense NCSCURGES | ESt | CSPIPTL8835 | Mavilla-NICO-hr-24d Line Ugar | DIRECTE(A) | 1,190 | | 1,190 | 1,190 | | | | | | incense NCSCURGES | ESt | CSPIPTL8851 | AHTO-Year 18181 | DIRECTE(A) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL8866 | South Beaurivort to Creole Line A | DIRECTT (I) | 2,590 | | 2,590 | | | 2,590 | (2,590) | | | incense NCSCURGES | ESt | CSPIPTL8873 | Line 196 Inqiat New 250-24 V-D | DIRECTT (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL8888 | Quarta to Prishn-Live 801-5/S | DIRECTT (I) | | | | | | 27,833) | 3,374 | 24,458 | | incense NCSCURGES | ESt | CSPIPTL8980 | T-bottlea South Oatlands -Raisa | DIRECTE (M) | 4,087 | | 4,087 | 4,087 | | | | | | incense NCSCURGES | ESt | CSPIPTL8990 | T-bottlea S.Chimacabbi New 2/S | DIRECTE (M) | 4,002 | | 4,002 | 4,002 | | | | | | incense NCSCURGES | ESt | CSPIPTL9008 | Siddon-Moselme St-Fourchon - Bg | DIRECTS (I) | 334 | | 334 | 334 | | | | | | incense NCSCURGES | ESt | CSPIPTL9378 | El Dirt Longant -Cui in Samgale | DIRECTS (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL9379 | Samgale-Samgale -Bu 65 New 175 | DIRECTS (I) | 125 | | 125 | 125 | | | | | | incense NCSCURGES | ESt | CSPIPTL9394 | Laksonne-Northeast -Bu3d 11/Bv | DIRECTE (M) | 7,824 | | 7,824 | 7,824 | | | | | | incense NCSCURGES | ESt | CSPIPTL9397 | Maylhowerit-Bysen -Bu 3d 11/Bv | DIRECTE (M) | 10,519 | | 10,519 | 10,519 | | | | | | incense NCSCURGES | ESt | CSPIPTL9407 | Laksonne-NICoar -Raisad 1150/ | DIRECTE (M) | 8,041 | | 8,041 | 8,041 | | | | | | incense NCSCURGES | ESt | CSPIPTL9408 | Laksonne-Pace -Raisade Line | DIRECTE (M) | 2,652 | | 2,652 | 2,652 | | | | | | incense NCSCURGES | ESt | CSPIPTL9409 | Nortlqoph-Lusimoy -Inqiat New | DIRECTE (M) | 342 | | 342 | 342 | | | | | | incense NCSCURGES | ESt | CSPIPTL9410 | Laksonne-NICoar -Lir 53-Cui in-I | DIRECTE (M) | 1,520 | | 1,520 | 1,520 | | | | | | incense NCSCURGES | ESt | CSPIPTL9498 | (Montmorabio) Line 499 Uqqrad | DIRECTT (I) | 80 | | 80 | | 80 | (80) | | | | incense NCSCURGES | ESt | CSPIPTL9575 | (Sor Crooaat N. Cui in to Xofje) | DIRECTS (I) | 1,108 | | 1,108 | 1,108 | | | | | | incense NCSCURGES | ESt | CSPIPTL9582 | N-Bonma-Tap Line -Uqqrade | DIRECTS (I) | 494 | | 494 | 494 | | | | | | incense NCSCURGES | ESt | CSPIPTL9599 | Courcateau-Vire-Lal in | DIRECTS (I) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL9713 | SHSKE-Cotton Ind. river in V | DIRECTE (M) | | | | | | | | | | incense NCSCURGES | ESt | CSPIPTL9821 | Tsimine - Ceste 190 -Uqqrade L | DIRECTT (I) | 14,464 | | 14,464 | | | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | incident RESOURCES | ESI | CSPIPTL8967 | LIS Biops (SeeL Pionule Other) | DIRECTELI | | | | | | | | | | incident RESOURCES | ESI | CSPIPTL8962 | LIS Beile Point, Pionule (Other) | DIRECTELI | | | | | | | | | | incident RESOURCES | ESI | CSPIPTL8963 | LIS Lump, Pionule 11501 Cirio | DIRECTELI | | | | | | | | | | incident RESOURCES | ESI | CSPIPTL8964 | LIS Lint 2 Circuit Pionule | DIRECTELI | | | | | | | | | | incident RESOURCES | ESI | CSPIPTL8966 | Waterfront Willow (See SIDU1 Pte | DIRECTELI | | | | | | | | | | incident RESOURCES | ESI | CSPIPTL8967 | Broadroom McCurtie, Raludit 115 | DIRECTE5M | (16B) | | (16B) | (16B) | | | | | | incident RESOURCES | ESI | CSPIPTLA161 | Harrier to He land Bottom 161 | DIRECTE34 | 13,986 | | 13,986 | 13,986 | | | | | | incident RESOURCES | ESI | CSPIPTLA202 | AhC to Ruppelle he North Line | DIRECTE34 | 629 | | 629 | 629 | | | | | | incident RESOURCES | ESI | CSPIPTLA204 | Grandview to Osage Creek, New | DIRECTE34 | 12,522 | | 12,522 | 12,522 | | | | | | incident RESOURCES | ESI | CSPIPTLA205 | Hot Spray to Bismarck - Uppol | DIRECTE34 | 3,416 | | 3,416 | 3,416 | | | | | | incident RESOURCES | ESI | CSPIPTLA206 | Bismarck to Andy Tap | DIRECTE34 | 5,804 | | 5,804 | 5,804 | | | | | | incident RESOURCES | ESI | CSPIPTLA207 | Rausch E - Mashill St. Line U | DIRECTE34 | 49 | | 49 | 49 | | | | | | incident RESOURCES | ESI | CSPIPTLA208 | Lift Gaines to NUT Westgate Ln 7t | DIRECTE34 | 2,464 | | 2,464 | 2,464 | | | | | | incident RESOURCES | ESI | CSPIPTLA209 | Benton N. to Benton S. - New L | DIRECTE34 | 19,389 | | 19,389 | 19,389 | | | | | | incident RESOURCES | ESI | CSPIPTLA210 | AICCC Cothersville Line Cut In | DIRECTE34 | 675 | | 675 | 675 | | | | | | incident RESOURCES | ESI | CSPIPTLA211 | Melbourne to Sage Line Records | DIRECTE34 | 3,556 | | 3,556 | 3,556 | | | | | | incident RESOURCES | ESI | CSPIPTLA273 | Tap Line No. 360 to Barnestone | DIRECTELI | 1,467 | | 1,467 | 1,467 | | | | | | incident RESOURCES | ESI | CSPIPTLA854 | Heiland Bottom/HCO SIDU1 Curl | DIRECTE34 | 950 | | 950 | 950 | | | | | | incident RESOURCES | ESI | CSPIPTLA855 | Independent/Philland Bottom 50 | DIRECTE34 | 755 | | 755 | 755 | | | | | | incident RESOURCES | ESI | CSPIPTLA856 | Heiland Bottom/Jashuendle H | DIRECTE34 | 823 | | 823 | 823 | | | | | | incident RESOURCES | ESI | CSPIPTLA857 | Heiland Bottom/Staovy 110 Cut | DIRECTE34 | 754 | | 754 | 754 | | | | | | incident RESOURCES | ESI | CSPIPTLA858 | LiftM. Pionule Women فالat A L | DIRECTE34 | 21 | | 21 | 21 | | | | | | incident RESOURCES | ESI | CSPIPTLACJ1 | Upgrade Addis to Cajuni line xx | DIRECTELS | 6,011 | | 6,011 | 6,011 | | | | | | incident RESOURCES | ESI | CSPIPTLB001 | Harrier 16101 Swichiyand Inside | DIRECTE34 | 4,803 | | 4,803 | 4,803 | | | | | | incident RESOURCES | ESI | CSPIPTLB995 | Eureles Spring/Osage Creek 161 | DIRECTE34 | 414 | | 414 | 414 | | | | | | incident RESOURCES | ESI | CSPIPTLB996 | Harrison East/Osage Creek 161 | DIRECTE34 | 385 | | 385 | 385 | | | | | | incident RESOURCES | ESI | CSPIPTLB997 | Conway West/Norner Pte Fluke | DIRECTE34 | 551 | | 551 | 551 | | | | | | incident RESOURCES | ESI | CSPIPTLB998 | Gold Creek/Synser H to Pte Flos | DIRECTE34 | 556 | | 556 | 556 | | | | | | incident RESOURCES | ESI | CSPIPTLB999 | Gold Creek/Sulmon Pte rivale 60 | DIRECTE34 | 559 | | 559 | 559 | | | | | | incident RESOURCES | ESI | CSPIPTLP001 | Coarse-Cornistand, Cut In Case | DIRECTELS | 333 | | 333 | 333 | | | | | | incident RESOURCES | ESI | CSPIPTLP002 | Coarse Lake Street, Cut In Case | DIRECTELS | 312 | | 312 | 312 | | | | | | incident RESOURCES | ESI | CSPIPTLP003 | Wino St Gabriel In

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLMI002 | Deep Line. Evoxoflexite (MeVPL) | DIRECTTЭ | 5,058 | | 5,058 | | 5,058 | (5,058) | | | | incandes RESOURCES | ESI | CSPIPTLMI003 | 2010 Tevox2077D Phase Effect line | DIRECTTЭ | 927 | | 927 | | 927 | 927 | | | | incandes RESOURCES | ESI | CSPIPTLMI004 | 071.75057110 noise Effect line | DIRECTTЭ | 1,683 | | 1,683 | | 1,683 | (1,683) | | | | incandes RESOURCES | ESI | CSPIPTLMI005 | Glideps - Line 1+6 New Effect PDD | DIRECTTЭ | 4,893 | | 4,893 | | 4,893 | (4,893) | | | | incandes RESOURCES | ESI | CSPIPTLMA9R1 | Hill Top - Maximal -Cell in 3u | DIRECTEAC | 3,554 | | 3,554 | 3,554 | | | | | | incandes RESOURCES | ESI | CSPIPTLP083 | L83. Inseal Cell in its College | DIRECTTЭ | 836 | | 836 | | 836 | 836 | | | | incandes RESOURCES | ESI | CSPIPTLP085 | L85 (Reverse Cohort - Upside L) | DIRECTTЭ | 4,056 | | 4,056 | | 4,056 | (4,056) | | | | incandes RESOURCES | ESI | CSPIPTLP183 | L183. Inseal Cell in its College | DIRECTTЭ | 824 | | 824 | | 824 | 824 | | | | incandes RESOURCES | ESI | CSPIPTLP490 | L490. Inseal Cell in its College | DIRECTTЭ | 925 | | 925 | | 925 | (925) | | | | incandes RESOURCES | ESI | CSPIPTLP991 | Inseal OS Structure - AAC 00 | DIRECTTLG | 618 | | 618 | 618 | | | | | | incandes RESOURCES | ESI | CSPIPTLP993 | Svolt - Hathesis spati - Rhadmit | DIRECTTLG | 97 | | 97 | 97 | | | | | | incandes RESOURCES | ESI | CSPIPTLP997 | Pleopros/Deforment - GP Line I | DIRECTTLG | 866 | | 866 | 866 | | | | | | incandes RESOURCES | ESI | CSPIPTLP998 | Port H/Farray Pt E81 - GP ratio | DIRECTTLG | 511 | | 511 | 511 | | | | | | incandes RESOURCES | ESI | CSPIPTLP999 | Erasy/Farray Pt E81 - GP line I | DIRECTTLG | 316 | | 316 | 316 | | | | | | incandes RESOURCES | ESI | CSPIPTLQ999 | Pot S to Star/Clam -Ligust to 37 | DIRECTEAC | 323 | | 323 | 323 | | | | | | incandes RESOURCES | ESI | CSPIPTLR001 | Sweets to Star Ridge -Sense New | DIRECTELI | 10,931 | | 10,931 | 10,931 | | | | | | incandes RESOURCES | ESI | CSPIPTLRP911 | Pleopros/Port H+GP Line Network | DIRECTLGI | 3,435 | | 3,435 | 3,435 | | | | | | incandes RESOURCES | ESI | CSPIPTLS999 | Broadviewer-Ryover -Cell in the | DIRECTEM | 15 | | 15 | 15 | | | | | | incandes RESOURCES | ESI | CSPIPTLSUF1 | S station - Pheonest L Lagiatele | DIRECTEM | 56 | | 56 | 56 | | | | | | incandes RESOURCES | ESI | CSPIPTLSW801 | Line 1+II in the Baselin 8/5 SLA | DIRECTELI | 1,289 | | 1,289 | 1,289 | | | | | | incandes RESOURCES | ESI | CSPIPTLT831 | Sative-China Build Tubewood C | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT834 | Tubewood Clants's Island Build | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT835 | Tubewood Clants's Island Corma | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT836 | Hardway-Hadley Bu-04 L189 Cor | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT838 | Hardway New Sick -Corma/2 CCH 5 | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT839 | China-Annette Corma/2 CCH Study | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT840 | Tubewood Clants Island (Bld New | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT841 | Harvard New Sick -Build New E80 | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT842 | China-Annette Build New 2004/1 L | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLT843 | | DIRECTTЭ | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTLX001 | Aruba Pt30 T Line 1+II In | DIRECTEAC | 1,117 | | 1,117 | 1,117 | | | | | | incandes RESOURCES | ESI | CSPIPTLX094 | L94. Add the -soluble Neospora | DIRECTTЭ | 41 | | 41 | | 41 | | | | | incandes RESOURCES | ESI | CSPIPTLV096 | L96. Inseal Polyp &; UPFDR | DIRECTTЭ | 50 | | 50 | | 50 | | | | | incandes RESOURCES | ESI | CSPIPTLV111 | L490. Inseal New 070C/37 As L1 | DIRECTTЭ | 299 | | 299 | | 299 | | | | | incandes RESOURCES | ESI | CSPIPTLV998 | Prometheus Monitoring Device | DIRECTEAC | 1,255 | | 1,255 | 1,255 | | | | | | incandes RESOURCES | ESI | CSPIPTLV999 | Hergoth annularis/T Line Lligust | DIRECTEAC | 3,543 | | 3,543 | 3,543 | | | | | | incandes RESOURCES | ESI | CSPIPTLV999 | Desert T Line Relaxation | DIRECTEAC | 4,105 | | 4,105 | 4,105 | | | | | | incandes RESOURCES | ESI | CSPIPTLV001 | Uspוד | DIRECTTЭ | 10,907 | | 10,907 | | 10,907 | | | | | incandes RESOURCES | ESI | CSPIPTLV002 | Build Iun in structure I-387 | DIRECTTЭ | 885 | | 885 | | 885 | | | | | incandes RESOURCES | ESI | CSPIPTLV003 | Build Isopore canopy onetie sun | DIRECTTЭ | 6,410 | | 6,410 | | 6,410 | | | | | incandes RESOURCES | ESI | CSPIPTLV004 | T-LAM 707 TIB E/007/PAS ANE NEW | DIRECTTЭ | 5,950 | | 5,950 | | 5,950 | | | | | incandes RESOURCES | ESI | CSPIPTLV005 | Up Rate L-488 Sative-Soladen | DIRECTTЭ | 670 | | 670 | | 670 | | | | | incandes RESOURCES | ESI | CSPIPTLV101 | McKelens-Pickens Ln Ligin -Ln -2 | DIRECTEM | 5,097 | | 5,097 | 5,097 | | | | | | incandes RESOURCES | ESI | CSPIPTLV102 | Lafrance-McKearn Mean to new no | DIRECTEM | 1,252 | | 1,252 | 1,252 | | | | | | incandes RESOURCES | ESI | CSPIPTLV001 | Mountain Days -Mycoelucitor 13 | DIRECTTLG | 9,892 | | 9,892 | 9,892 | | | | | | incandes RESOURCES | ESI | CSPIPTLV002 | Jackson to Topic -Mycoelucitor | DIRECTTLG | 441 | | 441 | 441 | | | | | | incandes RESOURCES | ESI | CSPIPTLT001 | Slackwater -Releasin (Sor 47) | DIRECTELI | 764 | | 764 | 764 | | | | | | incandes RESOURCES | ESI | CSPIPTLT002 | Hardway-McLanter -Uppודile to 7 | DIRECTTЭ | 18,515 | | 18,515 | | 18,515 | | | | | incandes RESOURCES | ESI | CSPIPTLT005 | Jackson-McLeay (201) -Uppודile 275 | DIRECTTLG | 7,525 | | 7,525 | 7,525 | | | | | | incandes RESOURCES | ESI | CSPIPTLT006 | Men Joint-Pine -Uppודile to 179d | DIRECTEAC | 3,043 | | 3,043 | 3,043 | | | | | | incandes RESOURCES | ESI | CSPIPTSTL403 | Imitland Bottom-Level Purchaser 6 | DIRECTEAC | 3,853 | | 3,853 | 3,853 | | | | | | incandes RESOURCES | ESI | CSPIPTSTL403 | Blue Water Sick -Inseal 11WVA | DIRECTTЭ | (10,917) | | (10,917) | | (10,917) | | | | | incandes RESOURCES | ESI | CSPIPTSTL408 | Imitland Bottom-500 W-V/I Sick | DIRECTTLG | 31,179 | | 31,179 | 31,179 | | | | | | incandes RESOURCES | ESI | CSPIPTSTL423 | Beasympect-Uppודile 73 to 20WVA | DIRECTLGI | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTSTL526 | Glendle -Inseal 2004/1 Shorter | DIRECTELI | | | 1,730 | 1,730 | | | | | | incandes RESOURCES | ESI | CSPIPTSTL540 | Alliance -Inseal 23011W/V As | DIRECTELI | 11,165 | | 11,165 | 11,165 | | | | | | incandes RESOURCES | ESI | CSPIPTSTL574 | Star Substation | DIRECTEM | 486 | | 486 | 486 | | | | | | incandes RESOURCES | ESI | CSPIPTS2069 | Coly sub-madity - new 03WV V | DIRECTTLG | 6,553 | | 6,553 | 6,553 | | | | | | incandes RESOURCES | ESI | CSPIPTS2089 | McCVCG -build new 03WV outside | DIRECTELI | | | | | | | | | | incandes RESOURCES | ESI | CSPIPTS2095 | Laborers -Inseal Superconducts | DIRECTELI | (4,828) | | (4,828) | (4,828) | | | | | | incandes RESOURCES | ESI | CSPIPTS2096 | Mature Inseal Superconductor | DIRECTELI | (1,927) | | (1,927) | (1,927) | | | | | | incandes RESOURCES | ESI | CSPIPTS2097 | Peters Road -Inseal 2004/1 Bre | DIRECTELI | 1,105 | | 1,105 | 1,105 | | | | | | incandes RESOURCES | ESI | CSPIPTS2192 | Pexett Creek Substation Corrosion | DIRECTTЭ | 513 | | 513 | | 513 | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project
Code | Activity / Project Description | ESt Billing Method | Total Billing | | | E11-Pair Blocks | | | | | | | | | | | | Service Company | Total | | | | | Adjustment | | | | | | | | | Recipient | | All Other BLPs | E11-Pair Blocks | Exclusions | | | | NEB | | | | | | | | | | | Adjustment | | | NEB | CMPFTS2193 | Camp Creek Substation Corriere | DIRECTTA | 8 | | | 8 | | 8 | (8) | | | | | CMPFTS2194 | Lewis Creek Instat Transition | DIRECTTA | 7,374 | | | 7,374 | | 7,374 | $(7,374)$ | | | | CMPFTS4731 | ETEC Copress Bulk Texas | DIRECTTA | | | | | | | | | | | | CMPFTS4772 | ETEC Copress BulkTexas | DIRECTTA | | | | | | | | | | | | CMPFTS4836 | Robie Att Sub MRCIP A30 Ouvolog | DIRECTTA | | | | | | | | | | | | CMPFTS5552 | Lynch -Uganda Live Relay Farm | DIRECTEAI | 137 | | | 137 | 137 | | | | | | | CMPFTS5553 | NCR Dose uganda Live Relay P | DIRECTEAI | 458 | | | 458 | 458 | | | | | | | CMPFTS5960 | Pedestrian Convert to 220H Km | DIRECTEU | | | | | | | | | | | | CMPFTS6764 | DISG Waggonen Fella Far New Bus | DIRECTEU | 134 | | | 134 | 134 | | | | | | | CMPFTS6824 | Snake Fm 220H Add 6d A6Vh | DIRECTEU | | | | | | | | | | | | CMPFTS6838 | DISG Anon Cyanianist Trap &; Bus | DIRECTEU | | | | | | | | | | | | CMPFTS6839 | DISG Lulug. Remove Waggonen Li | DIRECTEU | | | | | | | | | | | | CMPFTS6840 | DISG Waterford Relayer for line | DIRECTEU | | | | | | | | | | | | CMPFTS6886 | Hammond, modify for new 220H7 | DIRECTEU | 4,233 | | | 4,233 | 4,233 | | | | | | | CMPFTS6887 | Leboly Mudty for new 220H7 | DIRECTCU | 820 | | | 820 | 820 | | | | | | | CMPFTS7338 | Deli Reactor Replacement | DIRECTEAI | 1,950 | | | 1,950 | 1,950 | | | | | | | CMPFTS7369 | Johnstown Substation Frontieee | DIRECTTA | | | | | | | | | | | | CMPFTS7390 | ANG 3009 | DIRECTEAI | 1,718 | | | 1,718 | 1,718 | | | | | | | CMPFTS7511 | DISG Hunter New Iraq- patent G | DIRECTEU | | | | | | | | | | | | CMPFTS7616 | Total Petrochemicals - Go Reay | DIRECTTA | | | | | | | | | | | | CMPFTS7618 | Total Petrochemicals-Saline 5w | DIRECTTA | | | | | | | | | | | | CMPFTS7636 | Foxet Uganda Autotransformer | DIRECTTA | 99 | | | 99 | | 99 | | (99) | | | | CMPFTS7745 | South Nerva 220 Geocmmsssst | DIRECTEU | 52 | | | 52 | 52 | | | | | | | CMPFTS7806 | Fancy Point L302 relay uganda | DIRECTCU | | | | | | | | | | | | CMPFTS7820 | Devil Swamp, La. Repkea HCR I | DIRECTCU | | | | | | | | | | | | CMPFTS7821 | Grantsiux. Repkea HCR relay | DIRECTCU | | | | | | | | | | | | CMPFTS8872 | Dayan Repkea PT Dithermint | DIRECTTA | 10 | | | 10 | | 10 | | (10) | | | | CMPFTS8959 | Northpark Instat 110kH Ring | DIRECTEM | 4,176 | | | 4,176 | 4,176 | | | | | | | CMPFTS8994 | 7 Modes Bus Eccuse Add 5 G | DIRECTEM | 1,936 | | | 1,936 | 1,936 | | | | | | | CMPFTS9343 | Sabine 5E5l. Ins. monitoring era | DIRECTTA | | | | | | | | | | | | CMPFTS9348 | Keir Instat monitoring evapm | DIRECTEAI | | | | | | | | | | | | CMPFTS9370 | Spagata 940H/ Bulk New Sw. 5 | DIRECTEU | 12,294 | | | 12,294 | 12,294 | | | | | | | CMPFTS9371 | Bulk Surruptrode Substation | DIRECTEM | 1,588 | | | 1,588 | 1,588 | | | | | | | CMPFTS9375 | Emerson Instat 10.8 WhWH Cap | DIRECTEAI | | | | | | | | | | | | CMPFTS9376 | El Dorado Uganda Reseong | DIRECTEU | 10,360 | | | 10,360 | 10,360 | | | | | | | CMPFTS9377 | Spagata 110kH Instat New Lin | DIRECTEU | 6,519 | | | 6,519 | 6,519 | | | | | | | CMPFTS9387 | Bystin Repkea Reseong | DIRECTEM | 367 | | | 367 | 367 | | | | | | | CMPFTS9391 | Medison Run Substation | DIRECTEM | 230 | | | 230 | 230 | | | | | | | CMPFTS9397 | Hertsjate Energize Autocorr | DIRECTEM | (3,952) | | | (3,952) | (3,952) | | | | | | | CMPFTS9955 | KI Basque Per Colee Reseong | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9987 | Barude (200k) Sux Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTS9988 | Haram 110kH Sub- Uganda Rv | DIRECTEAI | | | | | | | | | | | | CMPFTSA348 | Hacvati Sul, Instat Uroo 2R | DIRECTEAI | | | | | | | | | | | | CMPFTSA356 | El Dorado Uganda Reseon | DIRECTEAI | | | | | | | | | | | | CMPFTSA368 | El Dorado Uganda Reseon | DIRECTEAI | | | | | | | | | | | | CMPFTSA369 | Hacvati Sul, Instat Uroo 2R | DIRECTEAI | | | | | | | | | | | | CMPFTSA380 | El Dorado Uganda Reseon | DIRECTEAI | | | | | | | | | | | | CMPFTSA387 | Wroa Bu5l EHU Aus et. Rep | DIRECTEAI | | | | | | | | | | | | CMPFTSA377 | Jorestation Sick Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA378 | ANG 110kH Sub-180H Rv | DIRECTEAI | | | | | | | | | | | | CMPFTSA382 | Granite Insta Sub- Insta | DIRECTEAI | | | | | | | | | | | | CMPFTSA388 | Bornero 110kH Sub- Uganda Rv | DIRECTEAI | | | | | | | | | | | | CMPFTSA390 | Ruseetrink It Sub. Uganda Rv | DIRECTEAI | | | | | | | | | | | | CMPFTSA397 | Wroa Bu5l EHU Aus et. Rep | DIRECTEAI | | | | | | | | | | | | CMPFTSA377 | Jorestation Sick Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA378 | ANG 110kH Sub-180H Rv | DIRECTEAI | | | | | | | | | | | | CMPFTSA388 | Granite Insta Sub- Insta | DIRECTEAI | | | | | | | | | | | | CMPFTSA392 | Wroa Bu5l EHU Aus et. Rep | DIRECTEAI | | | | | | | | | | | | CMPFTSA397 | Jorestation Sick Ugandan | DIRECTEU | | | | | | | | | | | | CMPFTSA379 | ANG 120kH Sub- Rve Mew | DIRECTEU | | | | | | | | | | | | CMPFTSA381 | Urban Uganda Live Relaying | DIRECTEAI | | | | | | | | | | | | CMPFTSA387 | Slotey Park Usp. Instat Uroo 1R | DIRECTEAI | | | | | | | | | | | | CMPFTSA392 | Slotey Park Usp. Insta Rv | DIRECTEAI | | | | | | | | | | | | CMPFTSA398 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Hacvati Sul, Instat Uroo 2R | DIRECTEAI | | | | | | | | | | | | CMPFTSA398 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | | | | CMPFTSA399 | Ruseetrink It Sub. Ugandan | DIRECTEAI | | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLIQ | EPI Plan Bلب | Exclusions | Pro Forms | Total EPI | | | | | | | | Receptor | Receptor | | | | | Amount | Adjudices | | Holistic | | | | | | | | | | | | | | | Holistic | NOCCURCES | EBI | CMPFTSA400 | Russellville II Sub. Upposite Sw | DIRECTEAL | 37 | | 37 | 37 | | | | | | | EBI | CMPFTSA401 | Dancille Sub. Upposite Box II Jul | | DIRECTEAL | (476) | | (476) | (476) | | | | | | | EBI | CMPFTSA404 | ANCI EPIF Sub. Upposite Swicin | DIRECTEAL | | 137 | | 137 | | | | | | | | EBI | CMPFTSA421 | Crouseit III. Star Line Relay Mr. | DIRECTEAL | 3,583 | | | 3,583 | 3,583 | | | | | | | EBI | CMPFTSA430 | ANCC Blotker Air North Submit | DIRECTEAL | 433 | | | 433 | 433 | | | | | | | EBI | CMPFTSA460 | P.6 East Sub. Repl Velvet Boo I | DIRECTEAL | 134 | | | 134 | 134 | | | | | | | EBI | CMPFTSA465 | Mason Sub. Repl Velvet MS-30 | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA551 | Rameer Sub. Repl "Pupied-cui" | DIRECTEAL | 410 | | | 410 | 410 | | | | | | | EBI | CMPFTSA566 | Emerson Sub. Repl Velvet relay | DIRECTEAL | 2,226 | | | 2,226 | 2,226 | | | | | | | EBI | CMPFTSA567 | McNer Sub. Repl Velvet relay | DIRECTEAL | 1,792 | | | 1,792 | 1,792 | | | | | | | EBI | CMPFTSA568 | NcR Line Sub. Upposite weldries | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA576 | Emerson Sub. Repl Velvet 11WV | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA582 | Or Whistle Sub. InetRepl R | DIRECTEAL | 175 | | | 175 | 175 | | | | | | | EBI | CMPFTSA584 | Hetero Central Sub. InetRepl | DIRECTEAL | 140 | | | 140 | 140 | | | | | | | EBI | CMPFTSA585 | Newport Kittleer Sub. InetRepl | DIRECTEAL | 18 | | | 18 | 18 | | | | | | | EBI | CMPFTSA587 | Pine Bluff East Sub. InetRepl | DIRECTEAL | 212 | | | 212 | 212 | | | | | | | EBI | CMPFTSA588 | W Memphis Park Sub. InetRepl | DIRECTEAL | 55 | | | 55 | 55 | | | | | | | EBI | CMPFTSA589 | Shendee Sub. Inetrepl RTU | DIRECTEAL | 277 | | | 277 | 277 | | | | | | | EBI | CMPFTSA600 | L/R South Sub. Inet Onion Corner | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA601 | Antartoma Sub. Inet Onion Corner | DIRECTEAL | 19 | | | 19 | 19 | | | | | | | EBI | CMPFTSA602 | Binkley II. Sub. Inet Onion Co | DIRECTEAL | 150 | | | 150 | 150 | | | | | | | EBI | CMPFTSA604 | E.0 EPIF Sub. Inet (2) Onion Co | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA614 | Furdura O. Sub. Inet Oil Wr | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA631 | Russellville IV. Sub. Inet Omi | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA658 | ANCC Collaterile Substation | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA668 | Conway II Sub. ReplUpposite Swi | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA669 | Conway II Sub. Incept' Wild Swi | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA671 | Wrightville Sub. Replover Fsre | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA672 | Magorola II Sub. Repl Breaker 4 | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA674 | Montan Wess. Repl 161KV CS | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA677 | Blotterville I-65. Relay Replac | DIRECTEAL | 331 | | | 331 | 331 | | | | | | | EBI | CMPFTSA680 | Woodward Sub. Repl Velvet BRWR | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA687 | Antartoma Sub. Relay Humourite | DIRECTEAL | 2,160 | | | 2,160 | 2,160 | | | | | | | EBI | CMPFTSA691 | Hot Spring Village. Relay Ines | DIRECTEAL | 1,206 | | | 1,206 | 1,206 | | | | | | | EBI | CMPFTSA697 | 00LL EPIF. Incept new carrier | DIRECTEAL | 295 | | | 295 | 295 | | | | | | | EBI | CMPFTSA698 | Blotterville EPI St. Repl Isite | DIRECTEAL | 347 | | | 347 | 347 | | | | | | | EBI | CMPFTSA701 | L.R. Galvest Sub. Grounding Wr | DIRECTEAL | 29 | | | 29 | 29 | | | | | | | EBI | CMPFTSA704 | Ir.S. EPIF. Woodward. Relay Llear | DIRECTEAL | 5,327 | | | 5,327 | 5,327 | | | | | | | EBI | CMPFTSA707 | L.R. West. Repl Breakers vV.11 | DIRECTEAL | 4,801 | | | 4,801 | 4,801 | | | | | | | EBI | CMPFTSA708 | L.R. West Sub. Repl Breakers v | DIRECTEAL | 62 | | | 62 | 62 | | | | | | | EBI | CMPFTSA709 | L.R. Peers St. Incept Foul Lo | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA710 | Amura Sub. Incept Transrupts | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA712 | Woodward Sub. Relay Upposite | DIRECTEAL | 3,061 | | | 3,061 | 3,061 | | | | | | | EBI | CMPFTSA713 | L.R. Inocente. Incept Foul | DIRECTEAL | 13 | | | 13 | 13 | | | | | | | EBI | CMPFTSA714 | AICC Aridiv FTD | DIRECTEAL | 3,882 | | | 3,882 | 3,882 | | | | | | | EBI | CMPFTSA715 | E.0. Pivoure. Incept Foul L | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA716 | Ruxiw Sub. Incept Transrupts | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA717 | Orangewot Sub. Relay Upposite | DIRECTEAL | 2,061 | | | 2,061 | 2,061 | | | | | | | EBI | CMPFTSA718 | Cepenter Darn. Intext Foul-L | DIRECTEAL | 38 | | | 38 | 38 | | | | | | | EBI | CMPFTSA720 | L.R. November. Incept Foul | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA729 | Russellville South. Incept Fs | DIRECTEAL | 27 | | | 27 | 27 | | | | | | | EBI | CMPFTSA730 | England Sub. Incept Foul Loo | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA731 | Waine Ridge North. Incept RT | DIRECTEAL | 66 | | | 66 | 66 | | | | | | | EBI | CMPFTSA735 | Rector. Incept RTU | DIRECTEAL | 15 | | | 15 | 15 | | | | | | | EBI | CMPFTSA733 | Poudronras North. Incept RTU | DIRECTEAL | 15 | | | 15 | 15 | | | | | | | EBI | CMPFTSA737 | Bichonville Northwest. Incept | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA737 | Wilson Sub. Incept Foul Loo | DIRECTEAL | 136 | | | 136 | 136 | | | | | | | EBI | CMPFTSA738 | Bryant Sub. Incept Foul Loo | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA739 | H6 WV-10-40. Incept Cenar Sub. Incept F | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA740 | III Smoke Cenar Sub. Incept F | DIRECTEAL | | | | | | | | | | | | EBI | CMPFTSA741 | L.R. South Sub. Incept Foul | DIRECTEAL | 58 | | | 58 | 58 | | | | | | | EBI | CMPFTSA742 | Zornes Sub. Incept Foul Loo S | DIRECTEAL | 154 | | | 154 | 154 | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Support | Total Billing | | ETT Pair Binds | Exclusions | Pro Forms | Total ETT Adjudices | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | | | | | | | | | | | | | Periphert | | | | | | noderes RESOURCES | ESt | CSPIFTSA743 | St Torve's Archont Sub. Instat | DIRECTEAL | | | | | | | | | noderes RESOURCES | ESt | CSPIFTSA744 | L.R. West Morfomet Sub. Instat | DIRECTEAL | 48 | | 48 | 48 | | | | | noderes RESOURCES | ESt | CSPIFTSA757 | Huttig pat. 9d others rp. 73 | DIRECTEAL | | | | | | | | | noderes RESOURCES | ESt | CSPIFTSA758 | Htt West. Uppod Bobrid Cnr. Sw | DIRECTEAL | 68 | | 68 | 68 | | | | | noderes RESOURCES | ESt | CSPIFTSA762 | Des Arc. Through Fund Merron | DIRECTEAL | 131 | | 131 | 131 | | | | | noderes RESOURCES | ESt | CSPIFTSA770 | Elaine. Rgr 6d 11001 Cn Sw. 8 | DIRECTEAL | 135 | | 135 | 135 | | | | | noderes RESOURCES | ESt | CSPIFTSA777 | Beebe Sub. Instat (2004)49 Cap | DIRECTEAL | 16 | | 16 | 16 | | | | | noderes RESOURCES | ESt | CSPIFTSA778 | Bastonille, Instat Chron | DIRECTEAL | | | | | | | | | noderes RESOURCES | ESt | CSPIFTSA779 | L.R.Phersale, Through Fund Me | DIRECTEAL | 806 | | 806 | 806 | | | | | noderes RESOURCES | ESt | CSPIFTSA780 | N.L.R.Dove. Through Fund Mer | DIRECTEAL | 454 | | 454 | 454 | | | | | noderes RESOURCES | ESt | CSPIFTSA781 | L.R.Rash Creek, Through Fund | DIRECTEAL | 721 | | 721 | 721 | | | | | noderes RESOURCES | ESt | CSPIFTSA783 | Jacksonville North, Rotay Inay | DIRECTEAL | 1,202 | | 1,202 | 1,202 | | | | | noderes RESOURCES | ESt | CSPIFTSA800 | Osage Creek (AECC) Upposite | DIRECTEAL | 7,913 | | 7,913 | 7,913 | | | | | noderes RESOURCES | ESt | CSPIFTSA807 | Parmen. Rapt 6d 11001 Switch | DIRECTEAL | 489 | | 489 | 489 | | | | | noderes RESOURCES | ESt | CSPIFTSA813 | L.R.d7n 4 Woodrow. Add Tronchi | DIRECTEAL | 317 | | 317 | 317 | | | | | noderes RESOURCES | ESt | CSPIFTSA814 | L.R. South, Add Tronchet Trip | DIRECTEAL | 846 | | 846 | 846 | | | | | noderes RESOURCES | ESt | CSPIFTSA815 | Elaine. Rgr 6d 1003 buccae n | DIRECTEAL | 58 | | 58 | 58 | | | | | noderes RESOURCES | ESt | CSPIFTSA841 | L.R.Cammack, Instat Fund Loc | DIRECTEAL | 19 | | 19 | 19 | | | | | noderes RESOURCES | ESt | CSPIFTSA850 | Steary Price Upposite Rotay Se | DIRECTEAL | 2,396 | | 2,396 | 2,396 | | | | | noderes RESOURCES | ESt | CSPIFTSA851 | Jacksonville N Upposite Rotay N | DIRECTEAL | 3,302 | | 3,302 | 3,302 | | | | | noderes RESOURCES | ESt | CSPIFTSA852 | HCC Upposite Rotay Ter Ho land | DIRECTEAL | 2,602 | | 2,602 | 2,602 | | | | | noderes RESOURCES | ESt | CSPIFTSA853 | Independence Upposite Rotay H8 | DIRECTEAL | 3,162 | | 3,162 | 3,162 | | | | | noderes RESOURCES | ESt | CSPIFTSA858 | Syiram Hills, Pippock 11001 BS | DIRECTEAL | 1,199 | | 1,199 | 1,199 | | | | | noderes RESOURCES | ESt | CSPIFTSA867 | L.R.South, Uppy Bus &; Satish on | DIRECTEAL | 231 | | 231 | 231 | | | | | noderes RESOURCES | ESt | CSPIFTSA876 | P8 East, Rgr 6d SEL2020 w 10 | DIRECTEAL | 276 | | 276 | 276 | | | | | noderes RESOURCES | ESt | CSPIFTSA877 | Devalle Bluff, Rgr F5t Regular | DIRECTEAL | 48 | | 48 | 48 | | | | | noderes RESOURCES | ESt | CSPIFTSA886 | L.R.Jillm &; Spring, Rapt Fabel | DIRECTEAL | 183 | | 183 | 183 | | | | | noderes RESOURCES | ESt | CSPIFTSA889 | Lynch, Rotay Inay on Anderson | DIRECTEAL | 5,065 | | 5,065 | 5,065 | | | | | noderes RESOURCES | ESt | CSPIFTSA893 | Newport 101th Reaper growing | DIRECTEAL | 1,033 | | 1,033 | 1,033 | | | | | noderes RESOURCES | ESt | CSPIFTSA900 | 9d stp. opt. babel 7006 020 RT | DIRECTEAL | 133 | | 133 | 133 | | | | | noderes RESOURCES | ESt | CSPIFTSA912 | Gibell, Rgr F5t Gap &; 1001 CA | DIRECTEAL | 148 | | 148 | 148 | | | | | noderes RESOURCES | ESt | CSPIFTSA914 | Balsomille 101th Rgr 5d VCB | DIRECTEAL | 81 | | 81 | 81 | | | | | noderes RESOURCES | ESt | CSPIFTSA916 | ELD Press Odp cash. 660 sub. | DIRECTEAL | 835 | | 835 | 835 | | | | | noderes RESOURCES | ESt | CSPIFTSA937 | SheaEml Rgr 6d pr rotay 9l6ag | DIRECTEAL | 1,354 | | 1,354 | 1,354 | | | | | noderes RESOURCES | ESt | CSPIFTSA938 | Mace 3, Rapt babel 870 L | DIRECTEAL | 68 | | 68 | 68 | | | | | noderes RESOURCES | ESt | CSPIFTSA942 | W6t Eml. Upposite 870 Lb 020 | DIRECTEAL | 1,697 | | 1,697 | 1,697 | | | | | noderes RESOURCES | ESt | CSPIFTSA950 | Hughes, Rgr babel 0060 006 02RQ | DIRECTEAL | 183 | | 183 | 183 | | | | | noderes RESOURCES | ESt | CSPIFTSA951 | Am Dorc Tralier 10th Mbea Bp | DIRECTEAL | 286 | | 286 | 286 | | | | | noderes RESOURCES | ESt | CSPIFTSA953 | H.S. 30th, opt. (2) 5b CCVTp 8 | DIRECTEAL | 442 | | 442 | 442 | | | | | noderes RESOURCES | ESt | CSPIFTSA964 | Stoney, opt. E 6d 13.8 Mmp | DIRECTEAL | 46 | | 46 | 46 | | | | | noderes RESOURCES | ESt | CSPIFTSA967 | Hughes 14c Rpo God 6a 4c 0c | DIRECTEAL | 115 | | 115 | 115 | | | | | noderes RESOURCES | ESt | CSPIFTSA989 | Helpend Bottom 600 001 Phase | DIRECTEAL | 69 | | 69 | 69 | | | | | noderes RESOURCES | ESt | CSPIFTSA992 | W6t Eml. Uppd 6000m B86h k &; Ter | DIRECTEAL | 2,871 | | 2,871 | 2,871 | | | | | noderes RESOURCES | ESt | CSPIFTSA993 | Eudora, Rgr 6d 1001 sub.aw.m. | DIRECTEAL | 166 | | 166 | 166 | | | | | noderes RESOURCES | ESt | CSPIFTSA999 | Warren Suss Instat 1100 005 Cap | DIRECTEAL | 242 | | 242 | 242 | | | | | noderes RESOURCES | ESt | CSPIFTSA920 | L8/20th Seabugger-Muntr. Inat | DIRECTELL | 4,157 | | 4,157 | 4,157 | | | | | noderes RESOURCES | ESt | CSPIFTSA922 | Seabugger 11001 023, Rgr. Fw | DIRECTELL | 2,089 | | 2,089 | 2,089 | | | | | noderes RESOURCES | ESt | CSPIFTSA923 | Burchamman, Instat 5800p Pter | DIRECTELL | 2,708 | | 2,708 | 2,708 | | | | | noderes RESOURCES | ESt | CSPIFTSA920 | Anoly 30c Upposite Switch 80017 | DIRECTEAL | 5,893 | | 5,893 | 5,893 | | | | | noderes RESOURCES | ESt | CSPIFTSA922 | Harmer Suls Manifcarence | DIRECTEAL | 194 | | 194 | 194 | | | | | noderes RESOURCES | ESt | CSPIFTSB003 | Syiram Hills Upposite Rotay | DIRECTEAL | 297 | | 297 | 297 | | | | | noderes RESOURCES | ESt | CSPIFTSB005 | Quimnet Upposite Rotay | DIRECTEAL | 48 | | 48 | 48 | | | | | noderes RESOURCES | ESt | CSPIFTSB006 | Conway West Upposite Rotay | DIRECTEAL | 52 | | 52 | 52 | | | | | noderes RESOURCES | ESt | CSPIFTSB007 | Harrison Euel Upposite Rotay | DIRECTEAL | 641 | | 641 | 641 | | | | | noderes RESOURCES | ESt | CSPIFTSC001 | Mboon, Madiby Communications | DIRECTELL | 35 | | 35 | 35 | | | | | noderes RESOURCES | ESt | CSPIFTSC002 | Leeselle 11001, Rose Equipment | DIRECTELL | 413 | | 413 | 413 | | | | | noderes RESOURCES | ESt | CSPIFTSF087 | Goncalves add 6PD T1 13.73 | DIRECTCLG | 546 | | 546 | 546 | | | | | noderes RESOURCES | ESt | CSPIFTSF149 | Woboe Ober Upposite L7 M Reale | DIRECTCLG | 374 | | 374 | 374 | | | | | noderes RESOURCES | ESt | CSPIFTSF150 | St Gabriel Upposite White Line | DIRECTCLG | 50 | | 50 | 50 | | | | | noderes RESOURCES | ESt | CSPIFTSF210 | Oin, Satavakam 870 L equipment | DIRECTCLG | 260 | | 260 | 260 | | | | | noderes RESOURCES | ESt | CSPIFTSF211 | Overspagne 870 L equipment | DIRECTCLG | 15 | | 15 | 15 | | | | | noderes RESOURCES | ESt | CSPIFTSF212 | Mowoc 6e rapport Bus 4 d 8 p | DIRECTCLG | 3,229 | | 3,229 | 3,229 | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLS | ETT-Pair | | | | | | | | | | Peripent | Peripent | | | | Exclusions | Total ETT | | | | | | | | | | | | | | Adjustes | | Holistic | | 030 | CSPIPTSF213 | Mission to rep 69 PA Capacitor | DIRECTS Q | 826 | 826 | 826 | | | | | | Holistic | 030 | CSPIPTSF214 | Mission to rep69 PA Capacitor | DIRECTS Q | 405 | 405 | 405 | | | | | | | Holistic | 030 | CSPIPTSF215 | Mission to rep69 COI1 1800 | DIRECTS Q | 74 | 74 | 74 | | | | | | | Holistic | 030 | CSPIPTSF220 | Carryps (Jigsale) Line Reseping | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF226 | Tiger rep6ase Greater 1400 | DIRECTS Q | 1,233 | 1,233 | 1,233 | | | | | | | Holistic | 030 | CSPIPTSF236 | Thomas rep6ase capacitor bank | DIRECTS Q | 1,795 | 1,795 | 1,795 | | | | | | | Holistic | 030 | CSPIPTSF237 | William rep6ase capacitor bank | DIRECTS Q | 2,406 | 2,406 | 2,406 | | | | | | | Holistic | 030 | CSPIPTSF247 | Carter Sub rep leader breaker | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF248 | Solus Sub rep6ase (COI 1141) | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF249 | Solus Sub rep6ase (COI 1899) | DIRECTS Q | 863 | 863 | 863 | | | | | | | Holistic | 030 | CSPIPTSF254 | Addis L265 rep6ase listed piece | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF255 | William listed relay piece | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF256 | William rep6ase R70 | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF257 | Mission model O20 | DIRECTS Q | 3,224 | 3,224 | 3,224 | | | | | | | Holistic | 030 | CSPIPTSF258 | Evron T14 74 Melting Addition | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF259 | Atsuka 282F rep6ase SPU | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF260 | Pincus rep6ase SPU breaker K10F | DIRECTS Q | 45 | 45 | 45 | | | | | | | Holistic | 030 | CSPIPTSF261 | Pincus SPU rep6ase T31F | DIRECTS Q | 24 | 24 | 24 | | | | | | | Holistic | 030 | CSPIPTSF262 | Pincus Rep6ase SPU T32F | DIRECTS Q | 127 | 127 | 127 | | | | | | | Holistic | 030 | CSPIPTSF263 | Pincus Rep6ase SPU T33F | DIRECTS Q | 24 | 24 | 24 | | | | | | | Holistic | 030 | CSPIPTSF264 | Capitan Rep6ase SPU W60F | DIRECTS Q | 274 | 274 | 274 | | | | | | | Holistic | 030 | CSPIPTSF265 | Colton Rep6ase SPU T10F | DIRECTS Q | 196 | 196 | 196 | | | | | | | Holistic | 030 | CSPIPTSF267 | Colton Rep6ase SPU T37F | DIRECTS Q | 280 | 280 | 280 | | | | | | | Holistic | 030 | CSPIPTSF268 | Dawson Colton Rep6ase SPU K52F | DIRECTS Q | 462 | 462 | 462 | | | | | | | Holistic | 030 | CSPIPTSF269 | Gencotex Rep6ase SPU K88F | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF270 | Highland Rep6ase SPU N8F | DIRECTS Q | 510 | 510 | 510 | | | | | | | Holistic | 030 | CSPIPTSF273 | Colly L440 rep6ase Primary rate | DIRECTS Q | 3,719 | 3,719 | 3,719 | | | | | | | Holistic | 030 | CSPIPTSF274 | Wobee Glen L450rep6asePH rat | DIRECTS Q | 4,598 | 4,598 | 4,598 | | | | | | | Holistic | 030 | CSPIPTSF275 | Michigan L734 rep6ase PH rat | DIRECTS Q | 7,255 | 7,255 | 7,255 | | | | | | | Holistic | 030 | CSPIPTSF277 | Oats Down rep6ase SPU T07F | DIRECTS Q | 263 | 263 | 263 | | | | | | | Holistic | 030 | CSPIPTSF278 | Oats Down rep6ase SPU T88F | DIRECTS Q | 104 | 104 | 104 | | | | | | | Holistic | 030 | CSPIPTSF279 | Wazd Creek rep6ase SPU L66F | DIRECTS Q | 472 | 472 | 472 | | | | | | | Holistic | 030 | CSPIPTSF281 | Wazd Creek rep6ase SPU L66F | DIRECTS Q | 481 | 481 | 481 | | | | | | | Holistic | 030 | CSPIPTSF282 | Wazd Creek L67F rep6ase SPU | DIRECTS Q | 332 | 332 | 332 | | | | | | | Holistic | 030 | CSPIPTSF284 | Zoar T18F rep6ase SPU vitia | DIRECTS Q | 243 | 243 | 243 | | | | | | | Holistic | 030 | CSPIPTSF285 | Sease (C9F rep6ase SPU | DIRECTS Q | 331 | 331 | 331 | | | | | | | Holistic | 030 | CSPIPTSF309 | Sudoin L222 index index piece | DIRECTS Q | 2,445 | 2,445 | 2,445 | | | | | | | Holistic | 030 | CSPIPTSF310 | Sudoin Sub rep6ase Greater 830 | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF311 | Mewes Sub Rep6ase Breaker K040 | DIRECTS Q | 570 | 570 | 570 | | | | | | | Holistic | 030 | CSPIPTSF312 | Merd W641 cap bank 6 vireg pe | DIRECTS Q | 3,346 | 3,346 | 3,346 | | | | | | | Holistic | 030 | CSPIPTSF313 | Smith rep6ase header breaker F | DIRECTS Q | 603 | 603 | 603 | | | | | | | Holistic | 030 | CSPIPTSF314 | Regan rep6ase breaker 18040 | DIRECTS Q | 975 | 975 | 975 | | | | | | | Holistic | 030 | CSPIPTSF325 | Moutour Subregion - 1220 L4 | DIRECTS Q | 128 | 128 | 128 | | | | | | | Holistic | 030 | CSPIPTSF340 | Common Lose Optical opposite | DIRECTS Q | 36 | 36 | 36 | | | | | | | Holistic | 030 | CSPIPTSF360 | Essai L789 add 051211C | DIRECTS Q | 37 | 37 | 37 | | | | | | | Holistic | 030 | CSPIPTSF361 | Oats 764 L302 add 051211C | DIRECTS Q | 1,911 | 1,911 | 1,911 | | | | | | | Holistic | 030 | CSPIPTSF364 | Ellon Fieeler Fault Location TU | DIRECTS Q | 41 | 41 | 41 | | | | | | | Holistic | 030 | CSPIPTSF365 | Contratateral Fieeler Fault Local | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF366 | Sulphur Fieeler Fault Location | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF367 | Solon Fieeler Fault Location TU | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF370 | Tiger rep6ase cap bank end rat | DIRECTS Q | 3,023 | 3,023 | | | | | | | | Holistic | 030 | CSPIPTSF371 | Geckner rep6ase cap bank end | DIRECTS Q | 1,014 | 1,014 | 1,014 | | | | | | | Holistic | 030 | CSPIPTSF372 | Rep6ase Erlengris R70 us Plant | DIRECTS Q | 433 | 433 | 433 | | | | | | | Holistic | 030 | CSPIPTSF378 | Jefferson model D4005 R70J | DIRECTS Q | 30 | 30 | 30 | | | | | | | Holistic | 030 | CSPIPTSF379 | Demont model D4005 R70J | DIRECTS Q | 616 | 616 | 616 | | | | | | | Holistic | 030 | CSPIPTSF385 | Wibow Glen L790 retag opposite | DIRECTS Q | 490 | 490 | 490 | | | | | | | Holistic | 030 | CSPIPTSF386 | Tiger L790 rep6ase retaging | DIRECTS Q | 634 | 634 | 634 | | | | | | | Holistic | 030 | CSPIPTSF390 | Geckner Fieeler Fault location | DIRECTS Q | 38 | 38 | 38 | | | | | | | Holistic | 030 | CSPIPTSF391 | Broomment Fieeler Fault Fad | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF392 | Heard model CCVT L726 | DIRECTS Q | | | | | | | | | | Holistic | 030 | CSPIPTSF393 | McVernac Compassy Rengagerit | Total | All Other BLS | | | | | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | | | | | | | Service Company | Total | All Other BUS | ETT/PIal Binds | Exclusions | Pro Posting | Total ETT | | | | | | | | Recipient | | | | | Amount | Adjudices | | Isolates RESOURCES | ESt | CSPIPTSF394 | Digitized, Indef | DIRECTS, | | | | | | | | | | | ESt | CSPIPTSF397 | Digitized, Indef | DIRECTS, | | | | 10 | 10 | | | | | | ESt | CSPIPTSF401 | 807.5ap1d4ef,plsf,win.vt | DIRECTS, | | | 477 | 477 | | | | | | | ESt | CSPIPTSF402 | PCI. 1ap1d4ef,plsf,win.vt | DIRECTS, | | 319 | 319 | 319 | | | | | | | ESt | CSPIPTSF403 | OLS. 1ap1d4ef,plsf,win.vt | DIRECTS, | | 214 | 214 | | | | | | | | ESt | CSPIPTSF404 | Carluys T1. 1envt | Se extens | DIRECTS, | 227 | 227 | 227 | | | | | | | ESt | CSPIPTSF406 | Freezone replace, p1st win. | DIRECTS, | 377 | | 377 | 377 | | | | | | | ESt | CSPIPTSF410 | Port Hudson Replace PH L117 | DIRECTS, | 1,274 | | 1,274 | 1,274 | | | | | | | ESt | CSPIPTSF411 | Repace Replace LT17 relaring | DIRECTS, | 1,104 | | 1,104 | 1,104 | | | | | | | ESt | CSPIPTSF422 | Meaux replace failed invader 8 | DIRECTS, | | | | | | | | | | | ESt | CSPIPTSF429 | Only LT41 Replace relaring | DIRECTS, | 1,510 | | 1,510 | 1,510 | | | | | | | ESt | CSPIPTSF430 | McKnight LT41 replace relaring | DIRECTS, | 2,401 | | 2,401 | 2,401 | | | | | | | ESt | CSPIPTSF448 | Carluys replace failed DOB 179 | DIRECTS, | 541 | | 541 | 541 | | | | | | | ESt | CSPIPTSF454 | Freezone replace RTU | DIRECTS, | 1,294 | | 1,294 | 1,294 | | | | | | | ESt | CSPIPTSF458 | Meaux le Barbuq Generator | DIRECTS, | 162 | | 162 | 162 | | | | | | | ESt | CSPIPTSF461 | Tourney rep1keder Invader 202 | DIRECTS, | 1,543 | | 1,543 | 1,543 | | | | | | | ESt | CSPIPTSF475 | Legion Sub Replace battery ten | DIRECTS, | 1,220 | | 1,220 | 1,220 | | | | | | | ESt | CSPIPTSF476 | Cecelle Sub T2 Circuit Definite | DIRECTS, | 950 | | 950 | 950 | | | | | | | ESt | CSPIPTSF499 | New Iberia BT1F bud location | DIRECTS, | 305 | | 305 | 305 | | | | | | | ESt | CSPIPTSF528 | Mean add mocs to line exit | DIRECTS, | 47 | | 47 | 47 | | | | | | | ESt | CSPIPTSF535 | Clade add mocs to line vehicle | DIRECTS, | 62 | | 62 | 62 | | | | | | | ESt | CSPIPTSF536 | Nothitide add mocs to line exit | DIRECTS, | 121 | | 121 | 121 | | | | | | | ESt | CSPIPTSF537 | severity around add mocs to line | DIRECTS, | 59 | | 59 | 59 | | | | | | | ESt | CSPIPTSF538 | Ellender add MOOS to line sw | DIRECTS, | 69 | | 69 | 69 | | | | | | | ESt | CSPIPTSF570 | Wrist replace failed bundom | DIRECTS, | 1,123 | | 1,123 | 1,123 | | | | | | | ESt | CSPIPTSF575 | Diva Be replace deadbundom | DIRECTS, | 410 | | 410 | 410 | | | | | | | ESt | CSPIPTSF580 | East replace invader 995 | DIRECTS, | 550 | | 550 | 550 | | | | | | | ESt | CSPIPTSF581 | Goodchace replace invader 590 | DIRECTS, | 502 | | 502 | 502 | | | | | | | ESt | CSPIPTSF582 | Jute replace invader 224 | DIRECTS, | 260 | | 260 | 260 | | | | | | | ESt | CSPIPTSF583 | Head replace invader 346 | DIRECTS, | 8 | | 8 | 8 | | | | | | | ESt | CSPIPTSF584 | Head replace invader 347 | DIRECTS, | 8 | | 8 | 8 | | | | | | | ESt | CSPIPTSF587 | Thomas replace failed S&;C swl | DIRECTS, | 444 | | 1,444 | 1,444 | | | | | | | ESt | CSPIPTSF588 | Highland replace disc and hypn | DIRECTS, | 457 | | 457 | 457 | | | | | | | ESt | CSPIPTSF606 | Sherandradt replace RTU | DIRECTS, | 253 | | 253 | 253 | | | | | | | ESt | CSPIPTSF608 | Lincoln T1 replace OT relays | DIRECTS, | 22 | | 22 | 22 | | | | | | | ESt | CSPIPTSF619 | Gima T1a T2 SP labor | DIRECTS, | 258 | | 258 | 258 | | | | | | | ESt | CSPIPTSF700 | Carcours 110F Feeder Fluid Lpl | DIRECTS, | 41 | | 41 | 41 | | | | | | | ESt | CSPIPTSF701 | Repat 60f&;01f heder fault 6 | DIRECTS, | 53 | | 53 | 53 | | | | | | | ESt | CSPIPTSF702 | Audite 844F heder fault load | DIRECTS, | 908 | | 908 | 908 | | | | | | | ESt | CSPIPTSF704 | Meaux 862F heder fault load | DIRECTS, | 87 | | 87 | 87 | | | | | | | ESt | CSPIPTSF705 | Leong 582F heder fsu.1 load | DIRECTS, | 103 | | 103 | 103 | | | | | | | ESt | CSPIPTSF706 | Scott 600f&;666f fault location | DIRECTS, | 41 | | 41 | 41 | | | | | | | ESt | CSPIPTSF707 | UNman 877 heder fault Lpl | DIRECTS, | 128 | | 128 | 128 | | | | | | | ESt | CSPIPTSF708 | Lifes 110F heder fault load | DIRECTS, | 53 | | 53 | 53 | | | | | | | ESt | CSPIPTSF714 | Meaux le Bus 3 C/80midir | DIRECTS, | 99 | | 99 | 99 | | | | | | | ESt | CSPIPTSF720 | Toucaybe failed DOB 4012 | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF803 | Furigourate rep1k6d 15nuf | DIRECTS, | 103 | | 103 | 103 | | | | | | | ESt | CSPIPTSF807 | Hicor 60f&;666f fault location | DIRECTS, | 5 | | 5 | 5 | | | | | | | ESt | CSPIPTSF807 | Hicor 60f&;666f fault load | DIRECTS, | 291 | | 291 | 291 | | | | | | | ESt | CSPIPTSF811 | Tiger replace failed battery a | DIRECTS, | 2 | | 2 | 2 | | | | | | | ESt | CSPIPTSF813 | Worrer replace forrel 5403ry | DIRECTS, | 14 | | 14 | 14 | | | | | | | ESt | CSPIPTSF815 | Shade 60f&;666f fault location | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF816 | Strain 100f heder fault load | DIRECTS, | 14 | | 14 | 14 | | | | | | | ESt | CSPIPTSF817 | Shade 60f&;666f fault location | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF818 | Shade 60f&;666f fault load | DIRECTS, | 14 | | 14 | 14 | | | | | | | ESt | CSPIPTSF819 | Shade 60f&;666f fault location | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF820 | Furigourate rep 340, Abia n. | DIRECTS, | 103 | | 103 | 103 | | | | | | | ESt | CSPIPTSF821 | Heart replace force with Vintap | DIRECTS, | 291 | | 291 | 291 | | | | | | | ESt | CSPIPTSF811 | Tiger replace failed battery a | DIRECTS, | 2 | | 2 | 2 | | | | | | | ESt | CSPIPTSF813 | Worrer replace forrel battery a | DIRECTS, | 14 | | 14 | 14 | | | | | | | ESt | CSPIPTSF815 | Shade 60f&;666f fault location | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF816 | Nocimade rep1k6d 10nuf | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF817 | Goemestep 100f 4012 | DIRECTS, | 594 | | 594 | 594 | | | | | | | ESt | CSPIPTSF818 | Goemestep rep1k6d 10nuf | DIRECTS, | 15 | | 15 | 15 | | | | | | | ESt | CSPIPTSF849 | Furigourate rep1k6d 10nuf | DIRECTS, | 6 | | 6 | 6 | | | | | | | ESt | CSPIPTSF850 | Amine Sub 200H 200401 PG0 | DIRECTS, | 1 | | 1 | 1 | | | | | | | ESt | CSPIPTSF851 | | DIRECTS, | 1,147 | | 1,147 | 1,147 | | | | | | | ESt | CSPIPTSF852 | Meaux, Instat 400404 AutoPHth | DIRECTS, | 18,237 | | 18,237 | 18,237 | | | | | | | ESt | CSPIPTSF853 | Meaux, Instat 108H 10nuf | DIRECTS, | 594 | | 594 | 594 | | | | | | | ESt | CSPIPTSF854 | Nicted Sub 1n2d 000H PG0 | DIRECTS, | 5 | | 5 | 5 | | | | | | | ESt | CSPIPTSF855 | Meaux, Sub 200H 200401 PG0 | DIRECTS, | 6 | | 6 | 6 | | | | | | | ESt | CSPIPTSF856 | Meaux, Sub 200H 200401 PG0 | DIRECTS, | 1 | | 1 | 1 | | | | | | | ESt | CSPIPTSF857 | Meaux, Instat 000H 10n7mal | DIRECTS, | 4,640 | | 4,640 | 4,640 | | | | | | | ESt | CSPIPTSF858 | Meat Sub 10ppvde 0901 0m.4 | DIRECTS, | 339 | | 339 | 339 | | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | ETT-Per | | | | | | | | | | | | Service Company | Total | | | | | | | | | | | | | Periphery | | | | | | | | | | | | | | | 4,469 | 4,469 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Entit | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLI's | ETT-Per | | | | | | | | | | | | | | | | | | | | | | Activity / Project Description | | Support | | | | | | Adjustment | | | | | | | | | | | | | | | | | | | | | | | | 3,319 | 3,319 | | | | | | | | | | | | | 1,170 | 1,170 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 4,052 | 4,052 | | | | | | | | | | | | | 130 | 130 | | | | | | | | | | | | | 21,131 | 21,131 | | | | | | | | | | | | | | | | | | | | | | | | | | | 8,880 | 8,880 | | | | | | | | | | | | | 435 | 435 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| | | | | | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | | | | | | | Service Company | Total | All Other BUS | ETT-Per | | | | | | | | | | | Periphery | | | | Exclusions | Pro Postop | Total ETT | | | | | | | | | | | | | Amount | Adjusting | | | | | | | | | | | | | | | | | NCCL | CSPIPTSP208 | Storage's Load: 126H Live-R | DIRECTTS | 5,979 | | 5,979 | | 5,979 | (5,979) | | | | | | CSPIPTSP232 | Death: Live Ranging L-605 | DIRECTTS | 2,080 | | 2,080 | | 2,080 | (2,080) | | | | | | CSPIPTSP223 | Course: Live Ranging L-605 | DIRECTTS | 1,296 | | 1,296 | | 1,296 | (1,296) | | | | | | CSPIPTSP234 | Course: Trans. No. 2 Ranging | DIRECTTS | 3,460 | | 3,460 | | 3,460 | (3,460) | | | | | | CSPIPTSP228 | Trade: Berel: Peptace Sex-Int-54 | DIRECTTS | 647 | | 647 | | 647 | (647) | | | | | | CSPIPTSP261 | Shepherd: Underused CTs | DIRECTTS | 81 | | 81 | | 81 | (81) | | | | | | CSPIPTSP400 | 74 Gram-Ben-Sub. Bin-New 500s | DIRECTTS | | | | | | | | | | | | CSPIPTSP420 | Larvar Sub. Remove Assets | DIRECTTS | | | | | | | | | | | NCCL | CSPIPTSP421 | Mel County, Inosit Ranging | DIRECTTS | 2,699 | | 2,699 | | 2,699 | (2,699) | | | | | | CSPIPTSP450 | Noverde 230 Waterford-bay app | DIRECTELI | 1,276 | | 1,276 | 1,276 | | | | | | | | CSPIPTSP452 | Fancy Point - Gippade L204 nap | DIRECTLIL | 141 | | 141 | 141 | | | | | | | | CSPIPTSP454 | Carlyss 230 - Peptace Sex-8 jp | DIRECTLIL | 4,222 | | 4,222 | 4,222 | | | | | | | | CSPIPTSP472 | Hoston 230 - neptace purpose | DIRECTELI | 35 | | 35 | | | | | | | | | CSPIPTSP500 | Gennes Sub. Inosit Risky Flap | DIRECTTS | 6,276 | | 6,276 | | 6,276 | (6,276) | | | | | | CSPIPTSP533 | Oridon Peptace Basic-RTU | DIRECTTS | 83 | | 83 | | 83 | (83) | | | | | | CSPIPTSP536 | Hunter-in Peptace Basic-RTU | DIRECTTS | 74 | | 74 | | 74 | (74) | | | | | | CSPIPTSP537 | Oseriage Peptace Basic-RTU | DIRECTTS | 46 | | 46 | | 46 | (46) | | | | | | CSPIPTSP540 | St Gabriel - rep'Inir relayy | DIRECTLIL | 741 | | 741 | 741 | | | | | | | | CSPIPTSP546 | Entebin. Peptace Basic-RTU | DIRECTTS | 229 | | 229 | | 229 | (229) | | | | | | CSPIPTSP548 | Clinton - neptace extortive | DIRECTEM | 13 | | 13 | 13 | | | | | | | | CSPIPTSP549 | Weber Own 500 ml | DIRECTLIL | 1,532 | | 1,532 | 1,532 | | | | | | | | CSPIPTSP552 | Jasper Circuit Switchers 50626 | DIRECTTS | 213 | | 213 | | 213 | (213) | | | | | | CSPIPTSP555 | Symerotle Sub. Inosit Cap-5e | DIRECTTS | 4,737 | | 4,737 | | 4,737 | (4,737) | | | | | | CSPIPTSP567 | Inisrot Orange: Inisol-18stern | DIRECTTS | 3,341 | | 3,341 | | 3,341 | (3,341) | | | | | | CSPIPTSP588 | Navasola -1200 Kray Bin -14455 | DIRECTTS | 264 | | 264 | | 264 | (264) | | | | | | CSPIPTSP589 | Corrigan: Peptace Breaker-5065 | DIRECTTS | 304 | | 304 | | 304 | (304) | | | | | | CSPIPTSP605 | Long John Engineering Study | DIRECTTS | 288 | | 288 | | 288 | (288) | | | | | | CSPIPTSP666 | Tyrone Sub. Inosit 108w-Bin | DIRECTTS | 7,670 | | 7,670 | | 7,670 | (7,670) | | | | | | CSPIPTSP700 | Navasola -inosit Reley Flusom | DIRECTTS | 5,393 | | 5,393 | | 5,393 | (5,393) | | | | | | CSPIPTSP800 | Bryan Sub. Inosit Risky Flap | DIRECTTS | 4,396 | | 4,396 | | 4,396 | (4,396) | | | | | | CSPIPTSP911 | U. St. ponton - Inosit 108m | DIRECTTS | 7,829 | | 7,829 | | 7,829 | (7,829) | | | | | | CSPIPTSP987 | Merth sub. Inosit new sub | DIRECTTS | 15,345 | | 15,345 | | 15,345 | (15,345) | | | | | | CSPIPTSP999 | Cortigo Station ponton - 3lu1 | DIRECTTS | 16,273 | | 16,273 | | 16,273 | (16,273) | | | | | | CSPIPTSP2001 | FOLWI NH L4H2, BULO 33.6 WVA | DIRECTLIN | 3,977 | | 3,977 | 3,977 | | | | | | | | CSPIPTSQ202 | Elonzi 50 Cornea in 5 Weaker-R | DIRECTLIN | 9,917 | | 9,917 | 9,917 | | | | | | | | CSPIPTSQ203 | Palo Sub. Uppati Switch 66670 | DIRECTLIN | 1,937 | | 1,937 | 1,937 | | | | | | | | CSPIPTSQ204 | Fluvit 5 Sub. Uppati Switch 66160 | DIRECTLIN | 1,604 | | 1,604 | 1,604 | | | | | | | | CSPIPTSQ207 | Pendium: Move 58M-HR Cap-Sank | DIRECTLIN | 3,409 | | 3,409 | 3,409 | | | | | | | | CSPIPTSR100 | Pacedent Sub. Uppatii Equipment | DIRECTELI | 474 | | 474 | 474 | | | | | | | | CSPIPTSR101 | Coteau Substantin: Uppatiie Úst | DIRECTELI | 457 | | 457 | 457 | | | | | | | | CSPIPTSS201 | Worriske -Inosit New 116m Sqe | DIRECTEMI | 364 | | 364 | 364 | | | | | | | | CSPIPTSS202 | Spongfridge Kit -Suck New Line | DIRECTEM | 93 | | 93 | 93 | | | | | | | | CSPIPTSS203 | Ruythowell 116m Peptace Rel | DIRECTEM | 15 | | 15 | 15 | | | | | | | | CSPIPTSS204 | Bivalirivore: Peptace Ranging | DIRECTEM | 15 | | 15 | 15 | | | | | | | | CSPIPTSS205 | Botkin Inosit 116m Bex | DIRECTEM | 161 | | 161 | 161 | | | | | | | | CSPIPTST201 | Nelson Term New 206m2 Line 1 | DIRECTELIL | 1,487 | | 1,487 | 1,487 | | | | | | | | CSPIPTST204 | Tackeved Backhawk 230 Kr Suls | DIRECTETS | | | | | | | | | | | | CSPIPTSST204 | Tackeved Purchase Substantiv | DIRECTT | | | | | | | | | | | | CSPIPTSST206 | Tackeved Bush Krase Nt-bi 8s | DIRECTT | | | | | | | | | | | | CSPIPTSST207 | Clantus Stove: Bulld New 228s | DIRECTT | | | | | | | | | | | | CSPIPTSST208 | Clantus Stove: Bulld New 228s | DIRECTT | | | | | | | | | | | | CSPIPTSST209 | Clantus Stove: Bulld New 228s | DIRECTT | | | | | | | | | | | | CSPIPTSST210 | Nettore Sub. Aopatii Equipment | DIRECTELI | | | | | | | | | | | | CSPIPTSST211 | Harleau Substantiv: Uppatiie Úst | DIRECTELI | | | | | | | | | | | | CSPIPTSST212 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST213 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST214 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST215 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST216 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST217 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST218 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST219 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST220 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST221 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST222 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST223 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST224 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST225 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST226 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST227 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST228 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST229 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST301 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST302 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST303 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST304 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST305 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST306 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST307 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST308 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST309 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST310 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST311 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST312 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST313 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST314 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST315 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST316 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST317 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST318 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST319 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST320 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST321 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST322 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST323 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST324 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST325 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST326 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST327 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST328 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST329 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST330 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST331 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST332 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST333 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST334 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST335 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST336 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST337 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST338 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST339 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST401 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST402 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST403 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST404 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST405 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST406 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST407 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST408 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST409 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST410 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST411 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST412 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST413 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST414 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST415 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST416 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST417 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST418 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST419 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST420 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST421 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST422 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST423 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST424 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST425 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST426 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST427 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST428 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST429 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST430 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST431 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST432 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST433 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST434 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST435 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST436 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST437 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST438 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST439 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST440 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST441 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST442 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST443 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST444 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST445 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | | | | | CSPIPTSST45 | Harleau Substantiv: Harleau | DIRECTT | | | | | | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | incisies NCSCURCES | ESI | CSPIPTSU100 | Moderate 119H1 Repbox Swin | DIRCTEXi | 16 | | 16 | 16 | | | | | | incisies NCSCURCES | ESI | CSPIPTSU102 | Moutre-le Eser SS. Repbox Swi | DIRCTEXi | 532 | | 532 | 532 | | | | | | incisies NCSCURCES | ESI | CSPIPTSU105 | L.P. Alexander St. Burde Bus | DIRCTEXi | 463 | | 463 | 463 | | | | | | incisies NCSCURCES | ESI | CSPIPTSU110 | P.B.Watson Chopp - Repbox Bv | DIRCTEXi | 544 | | 544 | 544 | | | | | | incisies NCSCURCES | ESI | CSPIPTSU120 | Orange Repbox Bus | DIRECTTX | 821 | | 821 | | 821 | | | | | incisies NCSCURCES | ESI | CSPIPTSU121 | Lewis Creek Repbox Bus | DIRECTTX | 936 | | 936 | | 936 | | | | | incisies NCSCURCES | ESI | CSPIPTSU122 | Alden Repbox Bus &; Inosit 5 | DIRECTTX | 1,292 | | 1,292 | 1,292 | 1,292 | | | | | incisies NCSCURCES | ESI | CSPIPTSU123 | Cornea Bulk Repbox Bus &; DI | DIRECTTX | 5,426 | | 5,426 | 5,426 | 5,426 | | | | | incisies NCSCURCES | ESI | CSPIPTSU124 | Ocean Repbox Bv. Swinina | DIRECTTX | - | | - | - | - | | | | | incisies NCSCURCES | ESI | CSPIPTSU125 | Dupont-Saline 40 Repbox CTs | DIRECTTX | - | | - | - | - | | | | | incisies NCSCURCES | ESI | CSPIPTSU126 | Cypress Repbox Bus | DIRECTTX | 436 | | 436 | | 436 | | | | | incisies NCSCURCES | ESI | CSPIPTSU127 | Lumberton Repbox Bus | DIRECTTX | 296 | | 296 | | 296 | | | | | incisies NCSCURCES | ESI | CSPIPTSU129 | Port Noring Bulk - Inosit Aus | DIRECTTX | 1,005 | | 1,005 | 1,005 | 1,005 | | | | | incisies NCSCURCES | ESI | CSPIPTSU130 | Tinkett Berol. Repbox Breatons | DIRECTTX | 1,244 | | 1,244 | | 1,244 | | | | | incisies NCSCURCES | ESI | CSPIPTSU131 | Navasole Inosit CTs | DIRECTTX | 40 | | 40 | | 40 | | | | | incisies NCSCURCES | ESI | CSPIPTSU132 | Tinkett Berol. Repbox Low Bq | DIRECTTX | 27 | | 27 | | 27 | | | | | incisies NCSCURCES | ESI | CSPIPTSV001 | ANG PHAR J2010 | DIRCTEXi | 9,654 | | 9,654 | 9,654 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV002 | Ardu POD: Property Purchase | DIRCTEXi | 4 | | 4 | 4 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV003 | Harrier XPBR (jaguate | DIRCTEXi | 6,330 | | 6,330 | 6,330 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV005 | Galloway New 119H1 Substance | DIRCTEXi | 3,856 | | 3,856 | 3,856 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV100 | Lewis Creek Sulc Inosit Retay | DIRECTTX | 828 | | 828 | | 828 | | | | | incisies NCSCURCES | ESI | CSPIPTSV200 | Longmine Sulc Inosit Retays &; | DIRECTTX | 1,787 | | 1,787 | | 1,787 | | | | | incisies NCSCURCES | ESI | CSPIPTSV400 | Navasole Sulc Inosit Retays &; | DIRECTTX | 63 | | 63 | | 63 | | | | | incisies NCSCURCES | ESI | CSPIPTSV500 | Ormes Sulc Inosit Retays | DIRECTTX | 38 | | 38 | | 38 | | | | | incisies NCSCURCES | ESI | CSPIPTSV600 | Rhonn Sulc Inosit Retays | DIRECTTX | 634 | | 634 | | 634 | | | | | incisies NCSCURCES | ESI | CSPIPTSV8001 | Desert AND 3300A A Former | DIRCTEXi | 19,871 | | 19,871 | 19,871 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV8001 | Wrken Sulc -Aldra 8C-331 L6q | DIRECTS,Q | 421 | | 421 | 421 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV601 | Repbox Translormon or Wrinkler | DIRCTELi | 5,752 | | 5,752 | 5,752 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV6042 | Ino 2000A Asle &; 2 Fraden Bv | DIRCTELi | 5,053 | | 5,053 | 5,053 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV001 | Dayton 109H1 Repbox Breakfast | DIRECTTX | 637 | | 637 | | 637 | | | | | incisies NCSCURCES | ESI | CSPIPTSV002 | Onset 109H1 Repbox Breatons | DIRECTTX | 716 | | 716 | | 716 | | | | | incisies NCSCURCES | ESI | CSPIPTSV003 | 539F7 109H1 Repbox Breatons &; | DIRECTTX | 3,408 | | 3,408 | | 3,408 | | | | | incisies NCSCURCES | ESI | CSPIPTSV004 | Lewis Creek 109H1 Inosit Ion | DIRECTTX | 8,451 | | 8,451 | | 8,451 | | | | | incisies NCSCURCES | ESI | CSPIPTSV005 | Uppsala Cornea Bulk | DIRECTTX | 1,534 | | 1,534 | | 1,534 | | | | | incisies NCSCURCES | ESI | CSPIPTSV006 | Inosit non 230H1 Rep Journ | DIRECTTX | 3,314 | | 3,314 | | 3,314 | | | | | incisies NCSCURCES | ESI | CSPIPTSV007 | Inosit protection Cornea Sulc | DIRECTTX | 148 | | 148 | | 148 | | | | | incisies NCSCURCES | ESI | CSPIPTSV008 | Jaguate 230H-Just 604 Courts | DIRECTTX | 231 | | 231 | | 231 | | | | | incisies NCSCURCES | ESI | CSPIPTSV010 | Holium Ridge New Substance 5 | DIRECTTX | 2,594 | | 2,594 | | 2,594 | | | | | incisies NCSCURCES | ESI | CSPIPTSV100 | McKelinn A60 End Asin | DIRCTESiR | 16,653 | | 16,653 | 16,653 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV101 | Wasa Substance: Restless Lire | DIRCTESiR | 3,585 | | 3,585 | 3,585 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV102 | Laksoner Nervous Lire Trap | DIRCTESiR | 1,266 | | 1,266 | 1,266 | | | | | | incisies NCSCURCES | ESI | CSPIPTSV103 | Winona Add line panel Is 5, 0c | DIRCTESiR | 19 | | 19 | 19 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ001 | Pay Braveret Tab Bravered,Sim | DIRCTESiR | 532 | | 532 | 532 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ002 | Bacon Wilson - Bar Breakx &; 3 | DIRCTESiR | 621 | | 621 | 621 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ003 | Slestinger-Hessian 1C in Bus | DIRCTELi | 7,081 | | 7,081 | 7,081 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ004 | Medium Red Line In Bus Rlore | DIRECTTX | 656 | | 656 | | 656 | | | | | incisies NCSCURCES | ESI | CSPIPTSQ005 | Inland Orange - Bar Bus Line Rl | DIRECTTX | 84 | | 84 | | 84 | | | | | incisies NCSCURCES | ESI | CSPIPTSQ006 | McLown - Bar Serratine &; Rhonn | DIRECTTX | 2,590 | | 2,590 | 2,590 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ007 | Reting Fork Inosit 21 W100 C | DIRCTESiR | 3,059 | | 3,059 | 3,059 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ008 | Yisone C's Plan - Red 21 W100 C | DIRCTESiR | 550 | | 550 | 550 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ009 | Cartilage 115 H1 Ino 21W100 C | DIRCTESiR | 4,880 | | 4,880 | 4,880 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ010 | Typosper 119H1 Ino 21W100 C | DIRCTESiR | 5,322 | | 5,322 | 5,322 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ011 | Mapper 115 H1 Ino 32-4 W14 Cw | DIRCTESiR | 761 | | 761 | 761 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ012 | McCune 119H1 Ino 34-2W14W Cw | DIRCTESiR | 431 | | 431 | 431 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ014 | Herrando119H1-Spirt 32-4 Cap | DIRCTESiR | 6,443 | | 6,443 | 6,443 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ015 | Heliandate119H1-SH 32-4 Ca | DIRCTESiR | 6,841 | | 4,841 | 4,841 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ016 | PlumPunch119H1-Spirt 32-4 Ca | DIRCTESiR | 4,967 | | 4,967 | 4,967 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ017 | Port55sucr119H1-Spirt 32-4Ca | DIRCTESiR | 2,935 | | 2,935 | 2,935 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ018 | Synadose119h1 Inslc121.6 Ca | DIRCTESiR | 4,946 | | 5,946 | 5,946 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ019 | Fayette119H1-Spirt 32-4 Cap | DIRCTESiR | 4,526 | | 4,526 | 4,526 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ020 | Rishand 109H1 Cornea New Gene | DIRECTS,Q | 804 | | 804 | 804 | | | | | | incisies NCSCURCES | ESI | CSPIPTSQ026 | Coomer Cue Control House Park | DIRECTS,Q | 1,109 | | 1,109 | 1,109 | | | | |

| Class | Billing Entit | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLIQ | ETC Plan | | | | | | | | | | Respect | Respect | | | | | | | nolatin N05OJH025 | | | CSPIPTV0531 | Nevi Alert Litter - Mesaloper | DIRECTEMI | 473 | | 473 | | 279 | | | | nolatin N05OJH025 | | CSPIPTV0532 | Nevi Alert Litter - Tevob | DIRECTTX | 279 | | | 279 | | 279 | | | | nolatin N05OJH025 | | CSPIPTV0533 | Nevi Alert Litter - ELL - South | DIRECTELI | 223 | | | 223 | | 223 | | | | nolatin N05OJH025 | | CSPIPTV0534 | Nevi Alert Litter - ELL - North | DIRECTELI | 249 | | | 249 | 249 | | | | | nolatin N05OJH025 | | CSPIPTV0535 | Nevi Alert Litter - EDSLA - Eos | DIRECTLLG | 136 | | | 136 | 136 | | | | | nolatin N05OJH025 | | CSPIPTV0536 | Nevi Alert Litter - EDSLA - Wos | DIRECTLLG | 223 | | | 223 | 223 | | | | | nolatin N05OJH025 | | CSPIPTV0537 | Nevi Alert Litter - ENO | DIRECTENO | 110 | | | 110 | 110 | | | | | nolatin N05OJH025 | | CSPIPTV0538 | Nevi Alert Litter - Amaraob | DIRECTEAI | 1,827 | | | 1,827 | 1,827 | | | | | nolatin N05OJH025 | | CSPIPTX1085 | Elizabeth Repique (MA1 DOLIN) | DIRECTTX | 82 | | | 82 | | 82 | (82) | | | nolatin N05OJH025 | | CSPIPTX1169 | Meeker -MM1 Low DOLIN05 | DIRECTTX | | | | | | | | | | nolatin N05OJH025 | | CSPIPTX1170 | Eneides -MM1 Cap Bank DOLIN4 | DIRECTTX | 229 | | | 229 | | 229 | | | | nolatin N05OJH025 | | CSPIPTX1179 | Fort Worth - Repique Basic RTU | DIRECTTX | 50 | | | 50 | | 50 | (50) | | | nolatin N05OJH025 | | CSPIPTX1180 | McKivunty Repique Basic RTU | DIRECTTX | | | | | | | | | | nolatin N05OJH025 | | CSPIPTV51002 | CLAMORNE -11001 CAP RILLAY UPS | DIRECTENO | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB044 | COC Clay Stem - DOLPS & General | DIRECTEXI | 1,648 | | | 1,648 | 1,648 | | | | | nolatin N05OJH025 | | CSPIPINFAB335 | INC 2 series post-mixic tender | DIRECTEAI | 2,340 | | | 2,340 | 2,340 | | | | | nolatin N05OJH025 | | CSPIPINFAB623 | RevClare-Repique Stange Transfer | DIRECTEAI | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB635 | RevClare-RepClareLightSupport | DIRECTEAI | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB641 | RDC-DOLPS & Operating Eye Sol | DIRECTEAI | 1,845 | | | 1,845 | 1,845 | | | | | nolatin N05OJH025 | | CSPIPINFAB644 | RCH Xcdegar Regulator Repiaxum | DIRECTEAI | 653 | | | 653 | 653 | | | | | nolatin N05OJH025 | | CSPIPINFAB645 | RCO Xcdegar Regulator Repiaxum | DIRECTEAI | 526 | | | 526 | 526 | | | | | nolatin N05OJH025 | | CSPIPINFAB646 | RCO Xcdegar Regulator Repiaxum | DIRECTEAI | 583 | | | 583 | 583 | | | | | nolatin N05OJH025 | | CSPIPINFAB530 | WM1 CAHR Scrudeer Drank Burner | DIRECTEAI | (114) | | | (114) | (114) | | | | | nolatin N05OJH025 | | CSPIPINFAB508 | WM2 CAHR Scrudeer Drank Burner | DIRECTEAI | (117) | | | (117) | (117) | | | | | nolatin N05OJH025 | | CSPIPINFAB577 | Seabadaary Order for WB Stock | DIRECTEAI | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB582 | WM1 HP Turbine Upgrade | DIRECTEAI | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB583 | WM2 HP Turbine Upgrade | DIRECTEAI | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB585 | WM2 IP Turbine Stage 8 Settleak | DIRECTEAI | 883 | | | 883 | 883 | | | | | nolatin N05OJH025 | | CSPIPINFAB408 | WM2 RH Custer Reader Terminal | DIRECTEAI | 1,087 | | | 1,087 | 1,087 | | | | | nolatin N05OJH025 | | CSPIPINFAB420 | WMC AFSK & AFSB Faxter Repique | DIRECTEAI | 2,235 | | | 2,235 | 2,235 | | | | | nolatin N05OJH025 | | CSPIPINFAB421 | WM2 Repique C Site et L / Bial | DIRECTEAI | 483 | | | 483 | 483 | | | | | nolatin N05OJH025 | | CSPIPINFAB432 | WM2 Alarner Resitter Repique | DIRECTEAI | 2,401 | | | 2,401 | 2,401 | | | | | nolatin N05OJH025 | | CSPIPINFAB444 | WM2 Pad Condensate Fiberion | DIRECTEAI | 147 | | | 147 | 147 | | | | | nolatin N05OJH025 | | CSPIPINFAB451 | WM2 LPA L2 Bucket Repiaxament | DIRECTEAI | 450 | | | 450 | 450 | | | | | nolatin N05OJH025 | | CSPIPINFAB452 | WMC Repique Magazzin Depositor | DIRECTEAI | 562 | | | 562 | 562 | | | | | nolatin N05OJH025 | | CSPIPINFAB455 | WMC AFAA Faxeter Repiaxament | DIRECTEAI | 865 | | | 865 | 865 | | | | | nolatin N05OJH025 | | CSPIPINFAB458 | WMC Faxeter Intel Spies AFAILSA | DIRECTEAI | 373 | | | 373 | 373 | | | | | nolatin N05OJH025 | | CSPIPINFAB472 | WM2 LTSH (Rear) Bider Tubes | DIRECTEAI | 1,709 | | | 1,709 | 1,709 | | | | | nolatin N05OJH025 | | CSPIPINFAB473 | WMC RCO Predictor Ver. Trend | DIRECTEAI | 944 | | | 944 | 944 | | | | | nolatin N05OJH025 | | CSPIPINFAB495 | WM1 Alarner Resitter Upgrade | DIRECTEAI | 251 | | | 251 | 251 | | | | | nolatin N05OJH025 | | CSPIPINFAB526 | AY Flax Master development | DIRECTEMI | 1,412 | | | 1,412 | 1,412 | | | | | nolatin N05OJH025 | | CSPIPINFAB537 | AY Aad-Level Bider Flaxe Pump | DIRECTEMI | 847 | | | 847 | 847 | | | | | nolatin N05OJH025 | | CSPIPINFAB559 | Atops Secrevator Positive Tin | DIRECTEMI | 46,705 | | | 46,705 | 46,705 | | | | | nolatin N05OJH025 | | CSPIPINFAB525 | DUSI09 - DPC - Plant Breeding | DIRECTEAI | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB200 | DPC-DUSI09-HP Thin to Open Stor | DIRECTEAI | (4,994) | | (4,994) | (4,994) | | | | | | nolatin N05OJH025 | | CSPIPINFAB244 | DPC-DUSI10-012 HIN02 An Allergy | DIRECTEAI | 4,495 | | | 4,495 | 4,495 | | | | | nolatin N05OJH025 | | CSPIPINFAB245 | DPC-DUSI10-015 HIN02 An Allergy | DIRECTEAI | 5,797 | | | 5,797 | 5,797 | | | | | nolatin N05OJH025 | | CSPIPINFAB269 | DPC-DUSI01 002 - 02 Seeds Uge | DIRECTEAI | 556 | | | 556 | 556 | | | | | nolatin N05OJH025 | | CSPIPINFAB73 | DUSI01-011aDPC - Fuel Gas Heat | DIRECTEAI | 2,524 | | | 2,524 | 2,524 | | | | | nolatin N05OJH025 | | CSPIPINFAB735 | DUSI01-011b DPC-Fuel Gas Men | DIRECTEAI | 331 | | | 331 | 331 | | | | | nolatin N05OJH025 | | CSPIPINFAB736 | DUSI01-011c DPC-Fuel Gas Men | DIRECTEAI | 399 | | | 399 | 399 | | | | | nolatin N05OJH025 | | CSPIPINFAB280 | DPC-Hyd Oil Pump Add to Essen | DIRECTEAI | 175 | | | 175 | | | | | | nolatin N05OJH025 | | CSPIPINFAB81 | DPC-Hyd Oil Pump Add to Essen | DIRECTEAI | 20 | | | 20 | 20 | | | | | nolatin N05OJH025 | | CSPIPINFAB84 | DPC-Curing Ter Vibration Eye | DIRECTEAI | 238 | | | 238 | 238 | | | | | nolatin N05OJH025 | | CSPIPINFAB85 | DPC-Curing Ter Vibration Eye | DIRECTEAI | 238 | | | 238 | 238 | | | | | nolatin N05OJH025 | | CSPIPINFAB185 | LNS MH Tub &; TIPP Cointe Life | DIRECTTTA | | | | | | | | | | nolatin N05OJH025 | | CSPIPINFAB200 | TIL-LWC Purchase Spent Transfer | DIRECTTTA | 4,934 | | | 4,934 | | | | | | nolatin N05OJH025 | | CSPIPINFAB220 | LNS Supermaster Repiaxament | DIRECTTTA | 14,759 | | | 14,759 | | 14,759 | | | | nolatin N05OJH025 | | CSPIPINFAB230 | LNS Nanoser Repiaxament | DIRECTTTA | 12,245 | | | 12,245 | | 12,245 | | | | nolatin N05OJH025 | | CSPIPINFAB231 | LNS Seeds Excider | DIRECTTTA | 2,674 | | | 2,674 | | 2,674 | | | | nolatin N05OJH025 | | CSPIPINFAB232 | LNS Secrevator Water Reator | DIRECTTTA | 2,654 | | | 2,654 | | 2,654 | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | (A) Billing Method | (B) Support | (C) Billing Method | (D) Support | (E) Billing Method | (F) Billing Method | (G) Support | (H) Billing Method | (I) Billing Method | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | Service Company | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | All Other BLS | E11 | (E) | (F) | | | Billing | | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | (A) Billing Method | (B) Support | Service Company | Total | All Other BLS | E11 Pair B | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | (A) Billing Method | EPI Billing Method | EPI Control Method | All Other BLH | EPI Plan Binds | Exclusions | Pro Forms | Total EPI Adjustment | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | 1,522 | | 1,522 | | | | nistein RESOURCES | EBI | CBPPML1285 | WF1 -41 South Custer side box | DIRECTELI | | | | 1,522 | | 1,522 | | | | | nistein RESOURCES | EBI | CBPPML1090 | PYC Gas Yard Expanser | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CBPPML1090 | PYC -Wheat system for Custer | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CBPPML1097 | PYC Cooling Tower Side Stress | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CBPPML1076 | PYC Repetition Gen Broader Force | DIRECTELI | | 896 | | | 896 | | 896 | | | | nistein RESOURCES | EBI | CBPPML1256 | LSU Duation Migration 6 corner | DIRECTELI | | 694 | | | 694 | | 694 | | | | nistein RESOURCES | EBI | CBPPML1237 | LSU 870 Buses Consolidation te | DIRECTELI | | 302 | | | 302 | | 302 | | | | nistein RESOURCES | EBI | CBPPML1304 | LSU 4801 Station Service Short | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CBPPML1308 | LSU 4801 Station Service Freak | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CBPPML1314 | LSU -CAR - CARTHL PROJECT | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CBPPML1331 | LSU City Water Separator at D1 | DIRECTELI | | 6,737 | | | 6,737 | | 6,737 | | | | nistein RESOURCES | EBI | CBPPML1336 | LSU Boiler Penthouse Root Add | DIRECTELI | | 194 | | | 194 | | 194 | | | | nistein RESOURCES | EBI | CBPPML1344 | LSU Tushing Superstory Month | DIRECTELI | | 596 | | | 596 | | 596 | | | | nistein RESOURCES | EBI | CBPPML1346 | LSU Cooling Water Heat Evicting | DIRECTELI | | 164 | | | 164 | | 164 | | | | nistein RESOURCES | EBI | CBPPML1364 | LSU Tushing Lake Oil Custer Rd | DIRECTELI | | 391 | | | 391 | | 391 | | | | nistein RESOURCES | EBI | CBPPMMAS57 | BMS Standby Transformer 41 | DIRECTEMi | | | | | | | | | | | nistein RESOURCES | EBI | CBPPMMAS00 | BMS - CAR - CARTHL PROJECT | DIRECTEMi | | | | | | | | | | | nistein RESOURCES | EBI | CBPPMMAS12 | BMS FISH Project | DIRECTEMi | | 249 | | | 249 | | 249 | | | | nistein RESOURCES | EBI | CBPPMMAS26 | BW1 Fuel & Bus for CHEK Add | DIRECTEMi | | 6,022 | | | 6,022 | | 6,022 | | | | nistein RESOURCES | EBI | CBPPMMD155 | GA CARI Project Phase 2 | DIRECTEMi | | | | | | | | | | | nistein RESOURCES | EBI | CBPPMMD164 | GA1 Revenue Climate Purchased | DIRECTEMi | | 137 | | | 137 | | 137 | | | | nistein RESOURCES | EBI | CBPPMM194 | MC3 Steam Sea Regulator Repio | DIRECTENCI | | 1,643 | | | 1,643 | | 1,643 | | | | nistein RESOURCES | EBI | CBPPMMK205 | MC3 Repioat C ${}^{\text{TH}}$ Valieta | DIRECTENCI | | 425 | | | 425 | | 425 | | | | nistein RESOURCES | EBI | CBPPMMK236 | MC3 Replace Main Transformer F | DIRECTENCI | | 747 | | | 747 | | 747 | | | | nistein RESOURCES | EBI | CBPPMMK238 | MC3 Turbine Vibration Monitor | DIRECTENCI | | 1,768 | | | 1,768 | | 1,768 | | | | nistein RESOURCES | EBI | CBPPMMK240 | MC1 Repioat Bearing Transfom | DIRECTENCI | | 691 | | | 691 | | 691 | | | | nistein RESOURCES | EBI | CBPPMMK241 | MC1 Repioat Bus Transformer F1 | DIRECTENCI | | 615 | | | 615 | | 615 | | | | nistein RESOURCES | EBI | CBPPMMK242 | MC3 Repioat Main Transformer F | DIRECTENCI | | 837 | | | 837 | | 837 | | | | nistein RESOURCES | EBI | CBPPMMK243 | MC3 Aus Seelen Manual Repeat | DIRECTENCI | | 561 | | | 561 | | 561 | | | | nistein RESOURCES | EBI | CBPPMMZ015 | PYC Reine & Demeteri Paterno | DIRECTENCI | | 3,046 | | | 3,046 | | 3,046 | | | | nistein RESOURCES | EBI | CBPPMS0534 | System Planning Per Coke Repose | DIRECTELI | | 6,603 | | | 6,603 | | 6,603 | | | | nistein RESOURCES | EBI | CBPPMS0616 | WF4 Brace Start Project | DIRECTELI | | 1,223 | | | 1,223 | | 1,223 | | | | nistein RESOURCES | EBI | CBPPMS0628 | SPO 50 WGTAB CT Development Spe | DIRECTT/E | | | | | | | | | | | nistein RESOURCES | EBI | CBPPMS0783 | Novartis 6 Development | DIRECTELI | | 216,441 | | | 216,441 | | 216,441 | | | | nistein RESOURCES | EBI | CBPPMS0880 | SPO Cokusato F20L | DIRECTLIS | | | | | | | | | | | nistein RESOURCES | EBI | CBPPMS0984 | SPO 5335, Purchase of Coat/His | DIRECTLIS | | 241 | | | 241 | | 241 | | | | nistein RESOURCES | EBI | CBPPMLIAG52 | OPG COJ/010 Plant Seaways | DIRECTEXi | | 4,240 | | | 4,240 | | 4,240 | | | | nistein RESOURCES | EBI | CBPPMLIAG53 | COJ/012 -COJ/017A ITTELCON UP | DIRECTEXi | | 342 | | | 342 | | 342 | | | | nistein RESOURCES | EBI | CBPPMLIAG56 | OPG COJ/019 MIC Erect Reveartate | DIRECTEXi | | 8,446 | | | 8,446 | | 8,446 | | | | nistein RESOURCES | EBI | CBPPMLIAG10 | COJ/014 Coarctite Water Pheir Lb | DIRECTEXi | | 3,260 | | | 3,260 | | 3,260 | | | | nistein RESOURCES | EBI | CTPPSU1214 | WAF005 STORM DL EAI 0007 0106 | DIRECTEXi | | 980 | | | 980 | | 980 | | | | nistein RESOURCES | EBI | CTPPSU1218 | WAF005 STORM DL EAI 0007 0208 | DIRECTEXi | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU1222 | STORM DL A9N 0007 EAI 062210 | DIRECTEXi | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU1226 | TORMDOES DL A9N 0007 EAI1672 | DIRECTEXi | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU1227 | STORM DL A9N 0007 EAI 061410 | DIRECTEXi | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU1244 | STORM DL A9N 0007 EAI 17111 | DIRECTEXi | | 702 | | | 702 | | 702 | | | | nistein RESOURCES | EBI | CTPPSU1248 | STORM DL A9N 0007 EAI 4311 | DIRECTEXi | | 137 | | | 137 | | 137 | | | | nistein RESOURCES | EBI | CTPPSU1249 | TORMDOES DL EAI 0007 A1411 | DIRECTEXi | | 157 | | | 157 | | 157 | | | | nistein RESOURCES | EBI | CTPPSU1250 | STORM DL EAI 0007 A1811-A29 | DIRECTEXi | | 1,911 | | | 1,911 | | 1,911 | | | | nistein RESOURCES | EBI | CTPPSU1251 | TORMDOES DL EAI 0007 A2811 | DIRECTEXi | | 15,966 | | | 15,966 | | 15,966 | | | | nistein RESOURCES | EBI | CTPPSU2452 | STORM DMD ELI 1/4 - 1/510 | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU2477 | Stone-ding La ELI 21213 Street | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU2441 | N La Tornado & Sterne 633-43 | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU2443 | STORM DMD ELI 31-34a 3/319 | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU2444 | STAPDMS 75 Berries LA 0007 OPG | DIRECTELI | | 385 | | | 385 | | 385 | | | | nistein RESOURCES | EBI | CTPPSU2445 | ELL 0007 STORM 0010 - 00111 | DIRECTELI | | | | | | | | | | | nistein RESOURCES | EBI | CTPPSU2458 | ELL 0007 SR11112 TROPICAL DEP | DIRECTELI | | 581 | | | 581 | | 581 | | | | nistein RESOURCES | EBI | CTPPSU2462 | STORM DMD LA 0007 ELI 140111 | DIRECTELI | | 8,530 | | | 8,530 | | 8,530 | | | | nistein RESOURCES | EBI | CTPPSU2463 | STORM DMD LA 21111 | DIRECTELI | | 436 | | | 436 | | 436 | | | | nistein RESOURCES | EBI | CTPPSU2467 | STORM DMD LA 0007 ASUED 04/1 | DIRECTELI | | 22 | | | 22 | | 22 | | | | nistein RESOURCES | EBI | CTPPSU2469 | STORM DMD LA 0007 ELL 002-3/21 | DIRECTELI | | 2,261 | | | 2,261 | | 2,261 | | | | nistein RESOURCES | EBI | CTPPSU2470 | STORM DMD LA 0007 ELL 4-4 | DIRECTELI | | 1,180 | | | 1,180 | | 1,180 | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | (A) Service Company Recipient | Total | All Other BLS | ETF Pair Books | Exclusions | Pro Postna Amount | Total ETF Adjudices | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | | | | | | Incisely RESCURGES | ESI | CTPPSJ2471 | 3/12RM DMS LA ELL 470/11- A1 | DIRECTELI | 113 | | 113 | 113 | | | | | | Incisely RESCURGES | ESI | CTPPSJ2474 | 3/12RM Drug ELL 400 to A37/11 | DIRECTELI | 11,003 | | 11,003 | 11,003 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3179 | EMI 01-06-12 Winter Storm Star | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ3180 | EMI 02-11-12 Winter Storm Star | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ3183 | EMI 04-04-12 Turnabies Star 0 | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ3185 | EMI 06-11-12 True Depwadz Dsr | DIRECTEM | 302 | | 302 | 302 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3186 | EMI MAY 2012 Storm Star Opa 485 | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ3189 | EMI June 2012 Storm Star Opa 48 | DIRECTEM | 142 | | 142 | 142 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3190 | EMI July 2012 Storm Star Opa 48 | DIRECTEM | 417 | | 417 | 417 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3196 | EMI November 2012 Storm Star 0 | DIRECTEM | 85 | | 85 | 85 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3197 | EMI Storm Died'ga 1231/10 Tor | DIRECTEM | 177 | | 177 | 177 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3198 | EMI Storm Star Opa 1/7-11/Mos | DIRECTEM | 18,400 | | 18,400 | 18,400 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3199 | EMI February 2011 Storm Died 0 | DIRECTEM | 164 | | 164 | 164 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3202 | EMI APMS 2011 Storm Star Opa | DIRECTEM | 511 | | 511 | 511 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3203 | EMI Storm Star Opa 4/15/11 | DIRECTEM | 73 | | 73 | 73 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3204 | EMI StormTornabies Died'ga 4/ | DIRECTEM | 7,956 | | 7,956 | 7,956 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3205 | EMIStormM09/waf Died'ga4 | DIRECTEM | 400 | | 400 | 400 | | | | | | Incisely RESCURGES | ESI | CTPPSJ3207 | EMI MAY 2011 Storm Star Opa 48 | DIRECTEM | 100 | | 100 | 100 | | | | | | Incisely RESCURGES | ESI | CTPPSJ4084 | 3/12RM DMS LA 2337 OPG ENS 6/1 | DIRECTENO | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ4085 | 3/18 DMS 70 BDMM2 LA 2927 OPG | DIRECTENO | 181 | | 181 | 181 | | | | | | Incisely RESCURGES | ESI | CTPPSJ4086 | ENS3 DIST 06-11-12 TROPICAL 02 | DIRECTENO | 31 | | 31 | 31 | | | | | | Incisely RESCURGES | ESI | CTPPSJ4088 | 3/12RM DMS LA 2337 OPG ENS 2-002 | DIRECTENO | 465 | | 465 | 465 | | | | | | Incisely RESCURGES | ESI | CTPPSJ4089 | 3/12RM DMS LA 2337 OPG ENS 2-002 | DIRECTENO | 197 | | 197 | 197 | | | | | | Incisely RESCURGES | ESI | CTPPSJ7207 | Storm Drug Star 72 h-like KH06 | DIRECT77A | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ7210 | Storm Drug Star 870-01410 | DIRECT77A | - | | - | - | | | | | | Incisely RESCURGES | ESI | CTPPSJ7231 | Storm Drug Star 870-19/11 | DIRECT77A | 111 | | 111 | | 111 | $-111(-111)$ | | | | Incisely RESCURGES | ESI | CTPPSJ7232 | Storm Drug Star 870-21/11 | DIRECT77A | 111 | | 111 | | 111 | $-111(-111)$ | | | | Incisely RESCURGES | ESI | CTPPSJ7234 | Storm Drug Star 870-426/11 | DIRECT77A | 355 | | 355 | | 355 | $-355(-355)$ | | | | Incisely RESCURGES | ESI | CTPPSJ8399 | 3/18 DMS 70 BDMM2 LA 2927 OPG | DIRECTS.G | 208 | | 208 | 208 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8406 | EGS3 DIST 06-11-12 TROPICAL 02 | DIRECTS.G | 237 | | 237 | 237 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8409 | WM1005 072998 DMS LA 2/3 TLI 25 | DIRECTS.G | 1,101 | | 1,101 | 1,101 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8410 | EGSL -Gold Front 25/11- 3/9 | DIRECTS.G | 8 | | 8 | 8 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8412 | 3/12RM DMS LA EGSL 328 - 3/21 | DIRECTS.G | 658 | | 658 | 658 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8413 | 3/12RM DMS LA 2927 EGSL 4-4 -4 | DIRECTS.G | 1,558 | | 1,558 | 1,558 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8414 | 3/12RM DMS LA EGSL 4/15/11- 4 | DIRECTS.G | 4 | | 4 | 4 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8415 | 3/18 DMS LA EGSL 403 - 4/27/11 | DIRECTS.G | 787 | | 787 | 787 | | | | | | Incisely RESCURGES | ESI | CTPPSJ8417 | 3/18 DMS EGSL 04/11 - 0/9/11 | DIRECTS.G | 222 | | 222 | 222 | | | | | | Incisely RESCURGES | ESI | CBPPD40233 | E Jackson Read 62/04/08 Select | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPD51037 | Line 701 Index to Ray Gajon | DIRECTS.G | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPD51046 | Hounra Antisand Chavon Storm Re | DIRECTELI | 134 | | 134 | 134 | | | | | | Incisely RESCURGES | ESI | CBPPD51076 | Line 362 Index to Wilson | DIRECTS.G | 88 | | 88 | 88 | | | | | | Incisely RESCURGES | ESI | CBPPTG6428 | Hetero South, Inset Environment | DIRECTEM | 197 | | 197 | 197 | | | | | | Incisely RESCURGES | ESI | CBPPTG6429 | Western Ray Gajon Apengye 8525 | DIRECTEM | 336 | | 336 | 336 | | | | | | Incisely RESCURGES | ESI | CBPPTG6472 | Reckt La Storm L181 Permol | DIRECTELI | 323 | | 323 | 323 | | | | | | Incisely RESCURGES | ESI | CBPPTG6473 | NLA Storm10 -L212 Tubbish Dsr | DIRECTELI | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTG6496 | Restore Storm Yamages | DIRECTEM | 7,603 | | 7,603 | 7,603 | | | | | | Incisely RESCURGES | ESI | CBPPTL6220 | Storm Repair Hapt South -Jlrs | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTS2584 | Boheme Sulk, Kalima - remoor | DIRECTELI | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTS2586 | Enopre Sulk, Remove Transformer | DIRECTELI | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTS4428 | Hapt Siv Orange Buil Note | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTS4698 | PR Western Chag Sulu, Ray Forfin St | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTS4673 | Shuttner Sulu, Rayo 161 Buil 4-5 | DIRECTEM | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTSJ002 | Kashi Lake - Nakashii | DIRECT77A | - | | - | - | | | | | | Incisely RESCURGES | ESI | CBPPTSIP119 | Quince-Hinley L403LAC Dkr | DIRECT77A | 2,086 | | 2,086 | | 2,086 | (2,086) | | | | Incisely RESCURGES | ESI | CBPPTSIP164 | Heches Station Switishpant Bre | DIRECT77A | 11,754 | | 11,754 | | 11,754 | (11,754) | | | | Incisely RESCURGES | ESI | E1PC210064 | DIS79 945 603M7 SUBSIT 402WCOB-NF | CLOSEOPCD | 69 | | 69 | 59 | 10 | - | (O) | 10 | | Incisely RESCURGES | ESI | E1PCM01811 | U1 General Outage Support | DIERCANOC | - | | - | - | | | | | | Incisely RESCURGES | ESI | E1PCM01837 | U1 to Coi Processing | DIERCANOC | - | | - | - | | | | | | Incisely RESCURGES | ESI | E1PCM01838 | U1 Maintenance Support | DIERCANOC | - | | - | - | | | | | | Incisely RESCURGES | ESI | E1PCM01701 | U2 General Outage Support | DIERCANOC | 1,345 | | 1,345 | 1,345 | | | | | | Incisely RESCURGES | ESI | E1PCM01702 | U2 Relaxing &; Fuel Handling | DIERCANOC | 397 | | 397 | 397 | | | | | | Incisely RESCURGES | ESI | E1PCM01727 | U2 toCoi Processing | DIERCANOC | 849 | | 849 | 849 | | | | |

| Class | Billing Entit | Activity / Project
Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | EPI-Pair Billing | | Exclusions | Pro Points Amount | Total EPI Adjudices | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | | | | | | | | | | | | | | | | | All Other BLIQ | | | | | nolens RESOURCES | EBI | EPICN07533 | US-Bey BBI Project | DIRCANOC | 403 | | 403 | 403 | | | | | | | nolens RESOURCES | EBI | EPICN07533 | FLOW ACCELENATED CORROSION | DIRECTRBS | 629 | | 629 | 629 | | | | | | | nolens RESOURCES | EBI | EPICN07540 | OUTAGE INTACT PROCESSING | DIRECTRBS | 539 | | 539 | 539 | | | | | | | nolens RESOURCES | EBI | EPICN07552 | REFUELNGYLQG_HANDLNG | DIRECTRBS | 1,904 | | 1,904 | 1,904 | | | | | | | nolens RESOURCES | EBI | EPICN07564 | OUTAGE SUPPORT ACTIVITIES | DIRECTRBS | 3,289 | | 3,289 | 3,289 | | | | | | | nolens RESOURCES | EBI | EPICN07575 | HEAT EXCHANGEER-MANTENANCEITES | DIRECTRBS | 888 | | 888 | 888 | | | | | | | nolens RESOURCES | EBI | EPICN07578 | ASSINOCE MAINSTREAMERAR | DIRECTRBS | 1,461 | | 1,461 | 1,461 | | | | | | | nolens RESOURCES | EBI | EPICN08322 | OUTAGE IN PROCESS OUT PROCES | DIRECTWFS | 435 | | 435 | 435 | | | | | | | nolens RESOURCES | EBI | EPICN08323 | OUTAGE SUPPORT ACTIVITIES | DIRECTWFS | (254) | | (254) | (254) | | | | | | | nolens RESOURCES | EBI | EPICN08358 | ALLOY BBI PROJECT | DIRECTWF3 | 3,791 | | 3,791 | 3,791 | | | | | | | nolens RESOURCES | EBI | EPICN25040 | NUCLEAR BLOXNESS DEVELOPMENT | DIRECT14 | | | | | | | | | | | nolens RESOURCES | EBI | EPICN95413 | NUCLEAR BLOXNESS DEVELOPMENT | DIRECT14 | 230,952 | | 230,952 | 230,952 | | | | | | | nolens RESOURCES | EBI | EPICN95015 | CUSTOM SALES &; SERVICE UNIT | CLOSESCAIT | 232,321 | | 232,321 | 232,321 | | | | | | | nolens RESOURCES | EBI | EPICN95025 | CUSTOM SALES &; SERVICE UNIT-M | DIRECTELI | 25,721 | | 25,721 | 25,721 | | | | | | | nolens RESOURCES | EBI | EPICN95220 | Sales &; Mkg. EAI | DIRECTEAI | 3,882 | | 3,882 | 3,882 | | | | | | | nolens RESOURCES | EBI | EPICN95221 | Sales &; Mkg. EAI | DIRECTE5K | 5,591 | | 5,591 | 5,591 | | | | | | | nolens RESOURCES | EBI | EPICN95222 | Sales &; Mkg. ELL | DIRECTELI | 8,879 | | 8,879 | 8,879 | | | | | | | nolens RESOURCES | EBI | EPICN95223 | Sales &; Mkg. EAI3 | DIRECTENO | 6,183 | | 6,183 | 6,183 | | | | | | | nolens RESOURCES | EBI | EPICN95224 | Sales &; Mkg. EOIX 13 | DIRECTT9 | 3,623 | | 3,623 | | | 3,623 | | (7) | 3,616 | | nolens RESOURCES | EBI | EPICN95225 | Sales &; Mkg. EOIX -LA | DIRECTTLS | 3,565 | | 3,565 | 3,565 | | | | | | | nolens RESOURCES | EBI | EPICN95226 | Sales &; Mkg. ALL-JUNS | MACCCTALL | 521,740 | 383 | 522,122 | 448,095 | | 74,027 | | (157) | 73,870 | | nolens RESOURCES | EBI | EPICN95020 | DIETALNK - EAI | DIRECTEAI | | | | | | | | | | | nolens RESOURCES | EBI | EPICN95024 | DIETALNK - EAI | DIRECTE5K | 72 | | 72 | | | | | | | | nolens RESOURCES | EBI | EPICN95025 | DIETALNK - EOILA | DIRECTTLS | | | | | | | | | | | nolens RESOURCES | EBI | EPICN95026 | DIETALNK - ALL JUNSOECTEING | MACCCTATX | 784 | | 784 | | 784 | | | | | | nolens RESOURCES | EBI | EPICN73451 | TRANNIG &; PROCESS IMPROVEMENT | DIRECTEAI | | | | | | | | | | | nolens RESOURCES | EBI | EPICN73457 | TRANNIG &; PROCESS IMPROVEMENT | CLUSTCALL | 281,993 | | 281,993 | 251,199 | | 30,794 | | (71) | 30,723 | | nolens RESOURCES | EBI | EPICN95010 | JENNNADS MANUFACTURED GAS PLAN | DIRECTTLS | 394 | | 394 | | 394 | | | | | | nolens RESOURCES | EBI | EPIPCZ965581 | LA 37A GIGI ROAD NERVAS &; WE | DIRECTTLS | 1,344 | | 1,344 | 1,344 | | | | | | | nolens RESOURCES | EBI | EPIP591954 | Reactor Vessel Inspection | DIRECTTTA | | | | | | | | | | | nolens RESOURCES | EBI | EPIP591949 | Vessel Resonance | DIRECTTTA | | | | | | | | | | | nolens RESOURCES | EBI | EPIP4294EAM | Reactor/Derstein Support EAM | DIRECTTIG | 1,216 | | 1,216 | 1,216 | | | | | | | nolens RESOURCES | EBI | EPIP4434NG | Marage Avarr Purgizer Eay EIS | CLOSEOPCO | 1,388 | | 1,388 | 1,388 | | 206 | | (0) | 206 | | nolens RESOURCES | EBI | EPIPEFFF003 | EXCHMENCY EPIONCY NON-NORBME | DIRECTEAI | 12,471 | | 12,471 | 12,471 | | | | | | | nolens RESOURCES | EBI | EPIPEFFF014 | EXCHMENCY EPIONCYNar-might | DIRECTEAI | 3,842 | | 3,842 | 3,842 | | | | | | | nolens RESOURCES | EBI | EPIPEFFF015 | EXCHMENCY EPIONCYNar-mig1 | DIRECTEAI | 472 | | 472 | 472 | | | | | | | nolens RESOURCES | EBI | EPIP961744 | US Genicyard Translontics +13 | DIRCANOC | 283 | | 283 | | 283 | | | | | | nolens RESOURCES | EBI | EPIP9659152 | SWITCHYARDS TRANSFORMERS +154 | DIRECTRBS | 386 | | 386 | | 386 | | | | | | nolens RESOURCES | EBI | EPIP9658772 | OUTAGE JEDMERA, SUPPORT | DIRECTSER | | | | | | | | | | | nolens RESOURCES | EBI | EPIP9658774 | OUTAGE TRANNIG AND NIPROCESS | DIRECTSER | | | | | | | | | | | nolens RESOURCES | EBI | EPIP9658789 | OUTAGE NIPLIGL &; PLIG HANDLNG | DIRECTSER | | | | | | | | | | | nolens RESOURCES | EBI | EPIP9658794 | OUTAGE NDE NON-DEFINUTIVE TE | DIRECTSER | | | | | | | | | | | nolens RESOURCES | EBI | EPIP9658830 | OUTAGE TURNING JEDMARKTON MANT | DIRECTSER | | | | | | | | | | | nolens RESOURCES | EBI | EPIP9658832 | OUTAGE METAMINICAL MANT/FARKES | DIRECTSER | | | | | | | | | | | nolens RESOURCES | EBI | EPIP965CRP1 | Univrot - Eratoxine | DIRECTTNI | 8,981 | | 8,981 | | | | | | | | nolens RESOURCES | EBI | EPIP965CRP2 | Univrot - office | DIRECTTNI | 1,519 | | 1,519 | 1,519 | | | | | | | nolens RESOURCES | EBI | EPIP965027 | Sales &; Mkg. All and TV | MACCCTATX | 2,574 | | 2,574 | | | | | | | | nolens RESOURCES | EBI | ESPP1 C21104 | Liquiritis Jan 2011 DIST-84 | DIRECTEAI | 20 | | 20 | | 20 | | | | | | nolens RESOURCES | EBI | ESPP1 C21105 | Liquiritis Jan 2011 DIST-ELL | DIRECTELI | 135 | | 135 | | 135 | | | | | | nolens RESOURCES | EBI | ESPP1 C21106 | Liquiritis Jan 2011 DIST-84 | DIRECTEAI | 213 | | 213 | | 213 | | | | | | nolens RESOURCES | EBI | ESPP1 C21176 | Liquiritis Jan 2011 TIPST-84 | DIRECTEAI | 6 | | 6 | | 6 | | | | | | nolens RESOURCES | EBI | ESPP1 C21178 | Liquiritis Jan 2011 TIPST-ELL | DIRECTEAI | | | | | | | | | | | nolens RESOURCES | EBI | ESPP1 C21221 | T-Gold Storm Damage EAI 126-1 | DIRECTEAI | | | | | | | | | | | nolens RESOURCES | EBI | ESPP1 C2253 | T-Gold Storm Over-LEAK EAI 1-4 | DIRECTEAI | 485 | | 485 | | 485 | | | | | | nolens RESOURCES | EBI | ESPP1 C255 | T-Gold Storm Tornadoes EAI 42 | DIRECTEAI | 2,822 | | 2,822 | | | | | | | | nolens RESOURCES | EBI | ESPP1 C2647 | T-Gold Storm GMA ELL 17/20-1 | DIRECTELI | 892 | | 892 | | 892 | | | | | | nolens RESOURCES | EBI | ESPP1 C2678 | T-Gold Storm 422 A20 - 427 | DIRECTELI | 1,147 | | 1,147 | | 1,147 | | | | | | nolens RESOURCES | EBI | ESPP1 C2683 | T-Gold Storm 416 ELL 61/20 | DIRECTELI | 151 | | 151 | | 151 | | | | | | nolens RESOURCES | EBI | ESPP1 C2784 | T-Gold ASN15 Tornadoes EMI | DIRECTE5K | | | | | | | | | | | nolens RESOURCES | EBI | ESPP1 C2788 | T-Gold Storm Damage EAI 17/11 | DIRECTE5K | 2,117 | | 2,117 | | 2,117 | | | | | | nolens RESOURCES | EBI | ESPP1 C2806 | T-Gold Storm Tornadoes EMI 42 | DIRECTE5K | 1,734 | | 1,734 | | 1,734 | | | | | | nolens RESOURCES | EBI | ESPP1 C2808 | T-Gold Storm MERIverPupation | DIRECTE5K | 5,079 | | 5,079 | | 5,079 | | | | |

Amounts may not add or tie to other schedules due to rounding. Gardner, Kevin

| Class | Billing Entit | Activity / Project | Activity / Project Description | ESt Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLS | ETT-Per | | | | | | | | | | | Periphery | | | | | | | nubens RESOURCES | ESI | FSPOTZ0990 | UNEINSTITIES ECCS OF a CHJ | ASSTTALL | 176,258 | 176,258 | 108,723 | 17,538 | - | (45) | 17,490 | - | | nubens RESOURCES | ESI | FSPOTZ1600 | CORP RPTS ANALYSIS A POLICYAL | GEINLEDAL | 556,312 | 556,312 | 523,472 | 32,840 | - | (75) | 32,785 | - | | nubens RESOURCES | ESI | FSPOTZ2310 | EAI FRANCIN, PLANNING | DIRECTEAL | 16,061 | 16,061 | 16,061 | - | | | | | | nubens RESOURCES | ESI | FSPOTZ2320 | ELI FRANCIN, PLANNING | DIRECTEAL | 22,213 | 22,213 | 22,213 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2330 | EMF FRANCIN, PLANNING | DIRECTEML | 5,231 | 5,231 | 5,231 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2340 | ENCH FRANCIN, PLANNING | DIRECTENO | 3,405 | 3,405 | 3,405 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2350 | SEX FRANCIN, PLANNING | DIRECTEOI | 5,660 | 5,660 | 5,660 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2485 | ENTERGY COMBINS ETOCO ADMIN | DIRECTETR | 8,415 | 8,415 | 8,415 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2511 | IN - DEMONIC, INDUPIES A MAIL | DIRECTETR | 248,218 | 248,218 | 248,218 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2514 | MEETNES ANALYSTICHNESTORICSH | DIRECTETR | 14,834 | 14,834 | 14,834 | | | | | | | nubens RESOURCES | ESI | FSPOTZ2522 | GENEINA, ACCOUNTING- ESI | LYLSVCAL | 174,456 | 174,456 | 157,865 | 16,591 | | | | | | nubens RESOURCES | ESI | FSPOTZ3273 | GA -SH - FUEL OIL | CIMINSPI | 12,541 | 12,541 | 12,541 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3425 | ACCOUNTS PHYSILO PHOSCOSING | APTTINVAL | 336,883 | 336,883 | 308,654 | 28,229 | (364) | (67) | 27,798 | - | | nubens RESOURCES | ESI | FSPOTZ3428 | TREASURY SYSTEMS | BRAFACCTA | 8,457 | 8,457 | 8,255 | 202 | | (0) | 201 | - | | nubens RESOURCES | ESI | FSPOTZ3442 | PAYROLL PHOSCOSING | PROVICAL | 200,204 | 200,204 | 190,461 | 9,714 | - | (22) | 9,691 | - | | nubens RESOURCES | ESI | FSPOTZ3600 | BUSINESS EVERIT PHOSCOSING-ENIC | DIRECTEALI | 2,073 | 2,073 | 2,073 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3915 | CORP REPORTING ANALYSIS A POLI | DIRECTEAI | 58,790 | 58,790 | 58,790 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3916 | EAI BUSINSS EVERIT DATA PHOSCING | DIRECTEAI | 12,340 | 12,340 | 12,340 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3917 | EAI CO-OPRED-SELINGS | DIRECTEAI | 2,248 | 2,248 | 2,248 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3920 | CORP REPORTING ANALYSIS A POLI | DIRECTELI | 11,072 | 11,072 | 11,072 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3921 | ELI BUSINS EVERIT DATA PHOSCING | DIRECTELI | 31,054 | 31,054 | 31,054 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3922 | EMF BUSINSS EVERIT DATA PHOSCING | DIRECTEML | 8,687 | 8,687 | 8,687 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3923 | ENICZ BUSINS EVERIT DATA PHOSCIN | DIRECTEIT | 888 | 889 | 889 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3925 | CORP REPORTING ANALYSIS A POLI | DIRECTEML | 43,492 | 43,492 | 43,492 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3926 | ENCI BDSG EVERIT DATA PHOSCING | DIRECTENO | 9,066 | 9,066 | 9,066 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3928 | SYSTEMS-ENERGY GENES QLAT CO-OW | DIRECTEOI | 1,768 | 1,768 | 1,768 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3960 | CORP REPORTING ANALYSIS A POLI | DIRECTENO | 33,107 | 33,107 | 33,107 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3931 | MEC ACCOUNTS RECIPL - PROFLES | ARTFINALL | 145,420 | 145,420 | 129,442 | 15,978 | | (37) | 15,942 | - | | nubens RESOURCES | ESI | FSPOTZ3935 | CORP REPORTING ANALYSIS A POLI | DIRECTETR | 3,989 | 3,989 | 3,989 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3936 | MANAGE EVERIT PHOSCOSING | BNAACCTA | 94,832 | 92,821 | 2,011 | | (5) | | 2,007 | - | | nubens RESOURCES | ESI | FSPOTZ3941 | BUSINESS EVERIT PHOSCOSING-ACCT | APTTINVAL | 15,089 | 15,089 | 13,829 | 1,260 | 52 | (3) | 1,308 | - | | nubens RESOURCES | ESI | FSPOTZ3942 | BUSINESS EVERIT PHOSCOSING- PA | PROVICAL | 28,658 | 28,658 | 27,267 | 1,260 | | (3) | 1,287 | - | | nubens RESOURCES | ESI | FSPOTZ3943 | BUSINESS EVERIT PHOSCOS- EAI | DIRECTEAI | 2,000 | 2,000 | 2,000 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3944 | BUSINESS EVERIT PHOSCOS- ELI | DIRECTELI | 1,889 | 1,889 | 1,889 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3945 | ACCOUNTING SERVICE- EOI | DIRECTEOI | 94 | 94 | 94 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3946 | BUSINESS EVERIT PHOSCOSING- EO | DIRECTEOI | 749 | 749 | 749 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3947 | BUSINESS EVERIT PHOSCOS- EM | DIRECTEML | 1,783 | 1,783 | 1,783 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3948 | BUSINESS EVERIT PHOSCOS- ENO | DIRECTENO | 2,012 | 2,012 | 2,012 | | | | | | | nubens RESOURCES | ESI | FSPOTZ394L | BUSINESS EVERIT PHOSCOSING- EW | DIRECTAL | 6,498 | 6,498 | 6,498 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3950 | CORP REPORTING ANALYSIS A POLI | DIRECTS9 | 51 | 51 | 51 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3951 | BUSINESS EVERIT PHOSCOS- REF.N | DIRECTEAI | 13,978 | 13,978 | 13,978 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3952 | BUSINESS EVERIT PHOSCOS- REF.N | DIRECTELI | 15,003 | 15,003 | 15,003 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3953 | BUSINESS EVERIT PHOSCOS- REF.N | DIRECTEML | 7,296 | 7,296 | 7,296 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3954 | BUSINESS EVERIT PHOSCOS- REF.N | DIRECTEOI | 11,588 | 11,588 | 11,588 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3957 | BUSINESS EVERIT PHOSCOSING- ES | LYLSVCAL | 9,922 | 9,922 | 8,978 | 944 | | (2) | 942 | - | | nubens RESOURCES | ESI | FSPOTZ3958 | BUSINESS EVERIT PHOSCOSING- ER | DIRECTS9 | 12,034 | 12,034 | 12,034 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3959 | BUSINESS EVERIT PHOSCOSING- EE | DIRECTESO | 1,434 | 1,434 | 1,434 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3961 | BUSINESS EVERIT PHOSCOSING- SE | CIMINSRT | - | - | - | | | | | | | nubens RESOURCES | ESI | FSPOTZ3962 | BUSINESS EVERIT PHOSCOSING- ET | DIRECTETR | - | - | - | | | | | | | nubens RESOURCES | ESI | FSPOTZ3964 | CORP REPORTING ANALYSIS A POLI | DIRECTEOI | 605 | 605 | 605 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3965 | ACCOUNTING SERVICE-SEX | DIRECTEOI | 6,234 | 6,234 | 6,234 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3966 | CORP REPORTING ANALYSIS A POLI | DIRECTEOI | 192 | 192 | 192 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3967 | BUSINESS EVERIT PHOSCOSING- AL | GEINLEDAL | 65,174 | 65,174 | 61,324 | 3,850 | | (9) | 3,841 | - | | nubens RESOURCES | ESI | FSPOTZ3968 | REPORTING TOTALS DATA ANALYSIS | GEINLEDAL | 3,008 | 3,008 | 2,829 | 178 | | (0) | 178 | - | | nubens RESOURCES | ESI | FSPOTZ3970 | ACCOUNTING SERVICE- ME | DIRECTEOI | 4,141 | 4,141 | 4,141 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3972 | ACCOUNTING SERVICE- AND | DIRECTEOI | 1,028 | 1,028 | 1,028 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3977 | BUSINESS DATA EVERIT PHOSCOS- I | DIRECTT7 | 579 | 579 | 579 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3978 | BUSINESS DATA EVERIT PHOSCOS | DIRECTT8 | 587 | 587 | 587 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3979 | BUSINESS EVERIT PHOSCOSING- EN | DIRECTT9 | 205 | 205 | 205 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3970 | BUSINESS EVERIT PHOSCOSING- ER | DIRECTEALI | 3 | 3 | 3 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3980 | ACCOUNTING SERVICE- NRT | DIRECTESO | 1,291 | 1,291 | 1,291 | | | | | | | nubens RESOURCES | ESI | FSPOTZ3986 | BUSINESS EVERIT PHOSCOSING- EN | DIRECTEALI | 16 | 16 | 16 | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLIQ | EPI Per | | | | | | | | | | | Recepent | | | | | | | | | | Activity / Project Description | | | Support | | | | | | | | | | | | | | | Service Company | | | | | | | | | | | | | | Recepent | Total | All Other BLIQ | EPI Per | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLS | ETL Pair | | | | | | | | | | | Recepent | | | | | | | indoles RESOURCES | ESI | FSPPE10158 | CCS Agent Core Support | CUSEOSTA | 16,200 | | 16,200 | 16,200 | | | | | | indoles RESOURCES | ESI | FSPPE10160 | May Gen &; Admin Report/epidemi | CUSTEGOP | 24,145 | | 24,145 | 20,810 | 3,335 | | (8) | 3,328 | | indoles RESOURCES | ESI | FSPPE10161 | office office Self Service/ Supp | CUSTEGOP | 5,797 | | 5,797 | 4,998 | 799 | | (2) | 797 | | indoles RESOURCES | ESI | FSPPE10163 | Economic Development Support | CUSTEGOP | 11 | | 11 | 3 | 2 | | (0) | | | indoles RESOURCES | ESI | FSPPE10165 | Trans Work Agent App Support | TRSBILNDP | 46,310 | | 46,310 | 40,860 | 5,450 | | (12) | 5,438 | | indoles RESOURCES | ESI | FSPPE10166 | Gen &; Admin - Customer Agent S | CUSTEGOP | 18,179 | | 18,179 | 15,658 | 2,521 | | (4) | 2,516 | | indoles RESOURCES | ESI | FSPPE089/AT | General Based These Version 4+ | EMPLOYAL | 2,785 | | 2,785 | 2,655 | 130 | | | 130 | | indoles RESOURCES | ESI | FSPPE099/NG | Nuclear NE Derivative Compds | DIRECTEAL | 13,306 | | 13,306 | 13,306 | | | | | | indoles RESOURCES | ESI | FSPPE088/ARA | SAH MSW Energy Control Negp | DIRECTEAL | 86,920 | 7,450 | 93,970 | 93,970 | | | | | | indoles RESOURCES | ESI | FSPPE098/PPA | Dose $t$ Year PPA (2011-2014) | DIRECTILG | 977 | | 977 | 977 | | | | | | indoles RESOURCES | ESI | FSPPE098/ALL | 0094 Energy Efficiency All-Jor | CUSTEGOP | 518 | | 518 | 446 | 72 | | (72) | | | indoles RESOURCES | ESI | FSPPE01600 | FERIC Compliance Plan | LOADOPCO | 5,228 | | 5,228 | 4,435 | 793 | | (2) | 792 | | indoles RESOURCES | ESI | FSPPE13807 | General Legal Services - EAM | DIRECTAL | 19,994 | | 19,994 | 19,994 | | | | | | indoles RESOURCES | ESI | FSPPE14430 | EAS United Way Meeting Expense | | 178 | | 178 | 178 | | | | | | indoles RESOURCES | ESI | FSPPE14432 | EAS SEP XYO Study | DIRECTEAL | 1,067 | | 1,067 | 1,067 | | | | | | indoles RESOURCES | ESI | FSPPE14434 | EAS POST SYS ASSET INCROBENTSAL | DIRECTEAL | 11,053 | | 11,053 | 11,053 | | | | | | indoles RESOURCES | ESI | FSPPE14435 | EAS POST SYS ASSET NON INCROBENTS | DIRECTEAL | 532 | | 532 | 532 | | | | | | indoles RESOURCES | ESI | FSPPE14436 | EAS MSO XYO STLEY | DIRECTEAL | 175 | | 175 | 175 | | | | | | indoles RESOURCES | ESI | FSPPE080/2AN | Integrated Energy Agent ENOi Ga | DIRECTENO | 1,790 | | 1,790 | 1,790 | | | | | | indoles RESOURCES | ESI | FSPPE087/AN | UK ECI Continuing Improve ENO | DIRECTENO | 5,455 | | 5,455 | 5,455 | | | | | | indoles RESOURCES | ESI | FSPPE087AS | UK ECI Continuing Improve ESI | CUSEOPCO | 157,065 | | 157,065 | 122,863 | 23,202 | | (53) | 23,149 | | indoles RESOURCES | ESI | FSPPE087LA | ECI Continue Improve LA (E.L.A | CUSTELLA | 60,898 | | 60,898 | 60,898 | | | | | | indoles RESOURCES | ESI | FSPPE0881A | Integrated Energy Agent EAI | DIRECTEAL | 165 | | 165 | 165 | | | | | | indoles RESOURCES | ESI | FSPPE0881G | Integrated Energy Agent EOGL | DIRECTILG | 1,209 | | 1,209 | 1,209 | | | | | | indoles RESOURCES | ESI | FSPPE0881L | Integrated Energy Agent ELL | DIRECTELI | 1,162 | | 1,162 | 1,162 | | | | | | indoles RESOURCES | ESI | FSPPE0881M | Integrated Energy Agent EMI | DIRECTEAL | 89 | | 89 | 89 | | | | | | indoles RESOURCES | ESI | FSPPE0881N | Integrated Energy Agent ENOi ni | DIRECTENO | 12,268 | | 12,268 | 12,268 | | | | | | indoles RESOURCES | ESI | FSPPE0881S | Integrated Energy Agent ESI | CUSEOPCO | 248,314 | | 248,314 | 211,647 | 36,667 | | (89) | 36,578 | | indoles RESOURCES | ESI | FSPPE0881T | Integrated Energy Agent ESI | DIRECTTX | 13 | | 13 | | | | | | | indoles RESOURCES | ESI | FSPPE085SAS | UK ECI Continuing Improve GAS | CLOSEOPCO | 564 | | 564 | 564 | | | | | | indoles RESOURCES | ESI | FSPPE04011 | EAS 2011 Peak Firing | DIRECTEAL | 9,572 | | 9,572 | 9,572 | | | | | | indoles RESOURCES | ESI | FSPPE049/RS | MSO Transition EAI Path 1 (see | DIRECTEAL | 8,875 | | 8,875 | 8,875 | | | | | | indoles RESOURCES | ESI | FSPPE049FAT | Maintain EAI Paths 2 and 3 (FIT) | DIRECTEAL | 841 | | 841 | 841 | | | | | | indoles RESOURCES | ESI | FSPPE049DZ2 | EAM ADMINISTRATIVE SUPPORT | DIRECTXLI | 16,553 | | 16,553 | 16,553 | | | | | | indoles RESOURCES | ESI | FSPPE048D22 | EAM - Project White Deer | DIRECTXLI | 94 | | 94 | 94 | | | | | | indoles RESOURCES | ESI | FSPPE0427IN | Wheat Eastin etal | LYLSVICAL | 705 | | 705 | 638 | 67 | | (0) | 67 | | indoles RESOURCES | ESI | FSPPE030/WA | Energy District Energy Health | DIRECTBIL | 1,186 | | 1,186 | 1,186 | | | | | | indoles RESOURCES | ESI | FSPPE032/FRP | EOID LITIG Formula Rater Plan FI | DIRECTILG | 15,471 | | 15,471 | 15,471 | | | | | | indoles RESOURCES | ESI | FSPPE032L/DP | EOID Separation Plan Subtraction | DIRECTILG | | | | | | | | | | indoles RESOURCES | ESI | FSPPE032LMI | MSO Transition EOGL code | DIRECTILG | 25 | | 25 | 25 | | | | | | indoles RESOURCES | ESI | FSPPE032SAS | EMO EIee &; ENO EOID One Expense | CUSENLOIS | 5,451 | | 5,451 | 5,451 | | | | | | indoles RESOURCES | ESI | FSPPE032/FRP | EOID Energy Efficiency Project | DIRECTENO | | | | | | | | | | indoles RESOURCES | ESI | FSPPE060SMT | OXID Energy Efficiency Project | DIRECTENO | 11 | | 11 | 11 | | | | | | indoles RESOURCES | ESI | FSPPE01,SEC | ELL, Securification in Suspicion | DIRECTELI | 13,890 | | 13,890 | 13,890 | | | | | | indoles RESOURCES | ESI | FSPPE060SII | EAM EOID PART Europe 2006-2013B | DIRECTEML | 1,327 | | 1,327 | 1,327 | | | | | | indoles RESOURCES | ESI | FSPPE060SMI | EMO EOID FRP Europe 2006-2013B | DIRECTEML | 7,596 | | 7,596 | 7,596 | | | | | | indoles RESOURCES | ESI | FSPPE060SMA | EAM EOID ECP Europe 2006-2013B | DIRECTEML | 10,431 | | 10,431 | 10,431 | | | | | | indoles RESOURCES | ESI | FSPPE060MIS | MSO Transition EMI code | DIRECTEML | 1,017 | | 1,017 | 1,017 | | | | | | indoles RESOURCES | ESI | FSPPE060SAM | Metre Speed Above Structure | DIRECTEML | 1,983 | | 1,983 | 1,983 | | | | | | indoles RESOURCES | ESI | FSPPE060SEP | ENO Energy Efficiency Project | DIRECTENO | 29 | | 29 | 29 | | | | | | indoles RESOURCES | ESI | FSPPE060SMT | OXID Energy Efficiency Project | DIRECTENO | 5,252 | | 5,252 | 5,252 | | | | | | indoles RESOURCES | ESI | FSPPE060SVA | Energy Routine Network, LLC | DIRECTXTL | 3,723 | | 3,723 | 3,723 | | | | | | indoles RESOURCES | ESI | FSPPE060IFRP | ENO Annual FWP Firing (2012-12 | DIRECTENO | 54,863 | | 54,863 | 54,863 | | | | | | indoles RESOURCES | ESI | FSPPE062MA | MSO Transition EMO code | DIRECTENO | 30 | | 30 | 30 | | | | | | indoles RESOURCES | ESI | FSPPE062MPR | Energy Smart Programs | DIRECTENO | 1,693 | | 1,693 | 1,693 | | | | | | indoles RESOURCES | ESI | FSPPEP02C04 | EAM Restructuring | DIRECTXS | 770 | | 770 | 770 | | | | | | indoles RESOURCES | ESI | FSPPEP0201 | Environmental Programs &; Inha | CAPACIPCO | 2,245 | | 2,245 | 2,002 | 243 | | (2) | 241 | | indoles RESOURCES | ESI | FSPPE020PBO | HP - EOLA0204 | DIRECTENU | 6,731 | | 6,731 | 6,731 | | | | | | indoles RESOURCES | ESI | FSPPE097/CKQ | Electronic Request for X | SCPSPALL | 12,491 | | 12,491 | 10,996 | 1,495 | (47) | (3) | 1,445 | | indoles RESOURCES | ESI | FSPPE03L0AMR | EAL, Nus Northeast Retail | DIRECTSIS | 7,568 | | 7,568 | 7,568 | | | | | | indoles RESOURCES | ESI | FSPPE75C0DL | Executive Tenseliness, EOGL | DIRECTEIS | 728 | | 728 | 728 | | | | | | indoles RESOURCES | ESI | FSPPE75CNDL | Executive Tenseliness, EOGL | DIRECTENO | 3,578 | | 3,578 | 3,578 | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | Service Company | | | | | | | | | | | | | | | | | | | All Other BDS | | | | | | | | | | | | 80,043 | 76,241 | 5,803 | | | | | | | | | | | | | 2,029 | | | | | | | | | | | | | | | | | | | | | | | | | | | MISO Transition ETI code | DIRECTTX | 2,029 | | 2,029 | | 2,029 | | | | | | | | | | | | | | | | | | | | | | | | Erecune Time and Expenses E | DIRECTXA | 5,980 | | 4,090 | 4,090 | | | | | | | | | | | | | | 5,980 | 5,980 | | | | | | | | | | DIRECTEL | Erecune Time | 5,390 | | 5,390 | | | | | | | | | | | DIRECTXS | Erecune Time | 5,390 | | 5,390 | | | | | | | | | | | DIRECTXS | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | | | | | | | DIRECTX | Erecune Time and Expenses E | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLIQ | EPI Pair | Exclusions | Pro Postop Amount | Total EPI | | | | | | | | Receptor | Receptor | | | | | | Adjustment | | Holistic ROGCHICES | EBI | FSPPP30248 | EGSL 8 | BM-TUN | \% due | DIRECTLQ | 65 | | 65 | 65 | | | | | Holistic ROGCHICES | EBI | FSPPP30249 | ENI B309W/ FMB 5.77n due 0110 | DIRECTLK | | | | | 2,776 | 2,776 | | | | | Holistic ROGCHICES | EBI | FSPPP30250 | ENSI B259W FMB3.5.17n due 1011 | DIRECTLNG | | | | | 5,981 | 5,981 | | | | | Holistic ROGCHICES | EBI | FSPPP30251 | EWI B109W/ FMB9.6.07n due 011 | DIRECTLMI | | | | | 4,070 | 4,070 | | | | | Holistic ROGCHICES | EBI | FSPPP30252 | EGSL 8 | BM FMBs | $\%$ due | DIRECTLQ | 226 | | 226 | 226 | | | | | Holistic ROGCHICES | EBI | FSPPP30253 | ELL 8 | BM FMBs | $\%$ due | DIRECTLLI | 1,455 | | 1,455 | 1,455 | | | | | Holistic ROGCHICES | EBI | FSPPP30254 | EMI 4 | BM FMBs | $\%$ due | DIRECTLMI | 230 | | 230 | 230 | | | | | Holistic ROGCHICES | EBI | FSPPP30255 | ENI 8 | BM FMBs | $\%$ due | DIRECTLKI | 581 | | 581 | 581 | | | | | Holistic ROGCHICES | EBI | FSPPP30257 | ELL B209W/ FMB 4.81n due 01101 | DIRECTELI | | | | | 1,125 | 1,125 | | | | | Holistic ROGCHICES | EBI | FSPPP30258 | EWI B129W/ FMB5.5.27n Due 011 | DIRECTLMI | | | | | 1,153 | 1,153 | | | | | Holistic ROGCHICES | EBI | FSPPP46770 | ENI Nio. Nebraska Penace 6 (VP) | DIRECTTYT | | | | | 260,558 | 260,558 | | | | | Holistic ROGCHICES | EBI | FSPPP46771 | EGSCL 3R4 | Penace 6 (VP)B Ex. | DIRECTSIN | 58,632 | | | 58,632 | 58,632 | | | | | Holistic ROGCHICES | EBI | FSPPP46772 | ENI Power Ope UK | DIRECTSID | | | | | 22,658() | 22,658() | | | | | Holistic ROGCHICES | EBI | FSPPP46774 | EPU Penace 6 (VP)B Expenses | DIRECTSIM | | | | | 69,996 | 69,996 | | | | | Holistic ROGCHICES | EBI | FSPPP61999 | ENI Pier Spendens Crop Tier 5c | DIRECTSYH | | | | | 272 | 272 | | | | | Holistic ROGCHICES | EBI | FSPPP62001 | EPDC- Tax Services | DIRECTSYH | | | | | 15,031 | 15,031 | | | | | Holistic ROGCHICES | EBI | FSPPP62443 | EEI- Earnings Coven Tax Service | DIRECTSYH | | | | | 4,722 | 4,722 | | | | | Holistic ROGCHICES | EBI | FSPPP62445 | EEI- Maribai- Tax Services | DIRECTSYH | | | | | | | | | | | Holistic ROGCHICES | EBI | FSPPP62450 | EP Ideopt- Tax Service | DIRECTSYH | | | | | 1,382 | 1,382 | | | | | Holistic ROGCHICES | EBI | FSPPP62471 | EPDC- General Tax Advisory | DIRECTYIQ | | | | | 582 | 582 | | | | | Holistic ROGCHICES | EBI | FSPPP62580 | ENT NCC FOMER MARKS TNG, LLC T | DIRIKGI000 | | | | | 38,793 | 38,793 | | | | | Holistic ROGCHICES | EBI | FSPPP62599 | RN CogentPPIS Lake Charles Tax | DIRECTXIS | | | | | 1,184 | 1,184 | | | | | Holistic ROGCHICES | EBI | FSPPP72875 | PR EPM Precursors Support | GESK.EDIAL | | | | | 18,016 | 18,957 | 1,059 | | | | Holistic ROGCHICES | EBI | FSPPP72885 | PR P Coot Support | APTYRWALL | | | | | 10,582 | 9,702 | 880 | | | | Holistic ROGCHICES | EBI | FSPPP72700 | Cogera Phaeirring Support | GESK.EDIAL | | | | | 71,736 | 67,501 | 4,220 | | | | Holistic ROGCHICES | EBI | FSPPP72701 | Regulatory Phaeirring Support | CLISTEGOIP | | | | | 22,559 | 18,434 | 3,125 | | | | Holistic ROGCHICES | EBI | FSPPP69470 | Records Management (Why Ops | CLIDEOPCO | | | | | 13 | 11 | 2 | | | | Holistic ROGCHICES | EBI | FSPPP86COP | Records Management Competitor | DIRECTEID | | | | | 147 | 147 | | | | | Holistic ROGCHICES | EBI | FSPPP86COF | Records Management Corporate S | GESK.EDIAL | | | | | 16 | 15 | 1 | | | | Holistic ROGCHICES | EBI | FSPPP86CGS | Records Management CS5 | CLISTEGOIP | | | | | 2,076 | 1,789 | 287 | | | | Holistic ROGCHICES | EBI | FSPPP86CA1 | Records Management EAI | DIRECTLKI | | | | | 152 | 152 | | | | | Holistic ROGCHICES | EBI | FSPPP86CL | Records Management ELI | DIRECTELI | | | | | 230 | 230 | | | | | Holistic ROGCHICES | EBI | FSPPP86CM | Records Management EW | DIRECTEMI | | | | | 111 | 111 | | | | | Holistic ROGCHICES | EBI | FSPPP86CNO | Records Management ENO | DIRECTENO | | | | | 54 | 54 | | | | | Holistic ROGCHICES | EBI | FSPPP86CTX | Records Management- ETA | DIRECTTYX | | | | | 176 | 176 | | | | | Holistic ROGCHICES | EBI | FSPPP86CWC | INV- Wholesale Commodity Brain | SENUCALL | | | | | 84 | 84 | | | | | Holistic ROGCHICES | EBI | FSPPP86CXT | Records Management Science W | GESK.EDIAL | | | | | 8 | 1 | | | | | Holistic ROGCHICES | EBI | FSPPP86CC5 | Records Management FACS | GESK.EDIAL | | | | | 451 | 424 | 27 | | | | Holistic ROGCHICES | EBI | FSPPP86CCS | Records Management Fixed | CAPACIPCO | | | | | 279 | 249 | 30 | | | | Holistic ROGCHICES | EBI | FSPPP86HRA | Records Management- HPAA leave | GESK.EDIAL | | | | | 586 | 551 | 34 | | | | Holistic ROGCHICES | EBI | FSPPP86EM | Records Management- EM | GESK.EDIAL | | | | | | | | | | | Holistic ROGCHICES | EBI | FSPPP86LES | Records Management Legal favor | GESK.EDIAL | | | | | 150 | 141 | 9 | | | | Holistic ROGCHICES | EBI | FSPPP86MRT | Records Management Marketing | CLISTEGOIP | | | | | 22 | 19 | 3 | | | | Holistic ROGCHICES | EBI | FSPPP86MJC | Records Management- Nichele | DIRECTEOS | | | | | 17 | 17 | | | | | Holistic ROGCHICES | EBI | FSPPP86PMG | Records Management Port Marital | GESK.EDIAL | | | | | 3 | 3 | | | | | Holistic ROGCHICES | EBI | FSPPP86MFO | Records Management Negotiary | CLISTEGOIP | | | | | 5 | 5 | | | | | Holistic ROGCHICES | EBI | FSPPP86MCH | Records Management- Kappa US | GESK.EDIAL | | | | | 73 | 69 | 4 | | | | Holistic ROGCHICES | EBI | FSPPP86MFO | Records Management- UPIS | LCMOOPCO | | | | | 120 | 102 | 19 | | | | Holistic ROGCHICES | EBI | FSPPP86TNA | Records Management- Tanumasa | TPSIBLHOP | | | | | 545 | 481 | 64 | | | | Holistic ROGCHICES | EBI | FSPPP86VGS | Records Management- Ushijika S | GESK.EDIAL | | | | | 7 | 7 | | | | | Holistic ROGCHICES | EBI | FSPPP87MOB | Implement FEPIC Origo ETE M4030 | LCMOOPCO | | | | | 15,787() | 14,923() | 884() | 7 | | | Holistic ROGCHICES | EBI | FSPPP87O729 | Implement FEPIC Origo TEM M290 | LCMOOPCO | | | | | 13,374() | 13,870() | 554() | 4 | | | Holistic ROGCHICES | EBI | FSPPP87O729 | FMSC Origo Prior of Failure A | TPMIDUBOP | | | | | | | | | | | Holistic ROGCHICES | EBI | FSPPP87JD10 | Fleet Income Process Audit SE | VITACLALL | | | | | 2,939 | 2,573 | 366 | | | | Holistic ROGCHICES | EBI | FSPPP88DW5 | RM Strategy Thermal LLC | DIRECTSIS | | | | | 2,440 | 2,440 | | | | | Holistic ROGCHICES | EBI | FSPPP88E11 | CCMP RISK MEAMT SHCR ENTERGY N | DIRECTEALI | | | | | 37,193 | 37,193 | | | | | Holistic ROGCHICES | EBI | FSPPP88F1A | Corp Risk Mymnt Socic- EAI | DIRECTLKI | | | | | 551 | 551 | | | | | Holistic ROGCHICES | EBI | FSPPP88F1G | Corp Risk Mymnt Socic- ELL | DIRECTELI | | | | | 948 | 948 | | | | | Holistic ROGCHICES | EBI | FSPPP88F1M | Corp Risk Mymnt Socic- EMI | DIRECTEMI | | | | | 337 | 337 | | | | | Holistic ROGCHICES | EBI | FSPPP88F1W | Corp Risk Mymnt Socic- EMO | DIRECTENO | | | | | 884 | 884 | | | | | Holistic ROGCHICES | EBI | FSPPP88F127 | UCRU- Bus Cont Plan Management | LBPBALAL | | | | | 26,551 | 1,742 | 28,293 | 25,564 | 2,729 | | 2,727 | | Holistic ROGCHICES | EBI | FSPPP88F1LQ | Corp Risk Mymnt Socic- EML | DIRECTLQ | | | | | 248 | 248 | | | |

| | | | | | | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | ESt Billing
Support | Total Billing | | | | | | | | | incense RESOURCES | ESI | FSPPPF6ATTX | Gray Real Agent Qual. STI | DIRECTTX | 623 | | 623 | | 623 | | (1) | 631 | | incense RESOURCES | ESI | FSPPPX3259 | Inventory Planning System Supp. | SCTDSPAL | -3,138 | | 3,138 | 2,159 | 979 | | (2) | 976 | | incense RESOURCES | ESI | FSPPPX3261 | F is Shared Services Suplh | SCPSPAL | 114 | | 114 | 97 | 18 | | (0) | 18 | | incense RESOURCES | ESI | FSPPPX3298 | Process Control Cyber Security | CLISECIPCO | 137 | | 137 | 117 | 20 | | (0) | 20 | | incense RESOURCES | ESI | FSPPPX3685 | Supply Chain Applications Supp. | SCMATRAN | 2,334 | | 2,334 | 1,988 | 346 | | (1) | 346 | | incense RESOURCES | ESI | FSPPPX3702 | IF Vander Management Ofice Su | ITSPENDA | 50,066 | | 50,066 | 46,841 | 3,125 | | (6) | 3,119 | | incense RESOURCES | ESI | FSPPPX3703 | SmearsingIntermittentRigmt | ITSPENDA | 16,917 | | 16,917 | 15,874 | 1,043 | | (2) | 1,041 | | incense RESOURCES | ESI | FSPPPX3307 | Compliance Software System Sup | ASSTSALL | 12,344 | | 12,344 | 11,109 | 1,236 | | (3) | 1,233 | | incense RESOURCES | ESI | FSPPPX3212 | Automated Account Rec. (AM) Su | GENLEDAIL | 1,111 | | 1,111 | 1,039 | 72 | | (0) | 72 | | incense RESOURCES | ESI | FSPPPX376SP | Evaluated Managis Settlement | SCPSPAL | -8,433 | | 8,433 | 7,128 | 1,305 | | (11) | 1,294 | | incense RESOURCES | ESI | FSPPPXCPMO | IF Eraseptoe Project Management | ITSPENDA | 30,342 | | 30,342 | 28,469 | 1,873 | | (4) | 1,869 | | incense RESOURCES | ESI | FSPPPXTVVRM | Thermal IT Support | DIRECTS6 | 1,178 | | 1,178 | 1,178 | | | | | | incense RESOURCES | ESI | FSPPGFRP10 | EGSL LP02 Furnace Rate Plan TV | DIRECTLQ | 16,072 | | 16,072 | 16,072 | | | | | | incense RESOURCES | ESI | FSPPQLASEC | EGSLA Securitization H Quateck | DIRECTLQ | 13,501 | | 13,501 | 13,501 | | | | | | incense RESOURCES | ESI | FSPPGRGIP10 | EGSL RATE STABLIZATION TY 2006 | DIRECTLQ | 15,253 | | 15,253 | 15,253 | | | | | | incense RESOURCES | ESI | FSPPHSA075 | BUSINESS DEVELOPMENT - TX | DIRECTTX | 11,725 | | 11,725 | | 11,725 | (3,452) | (16) | 8,257 | | incense RESOURCES | ESI | FSPPHAPPCO | Project II | DIRECTETR | 60,959 | | 60,959 | 60,959 | | | | | | incense RESOURCES | ESI | FSPPHRAHTM | All Haves Meeting for HRSA | EMPLOYAL | 66,060 | (193) | 65,867 | 62,708 | 3,159 | | (114) | 3,045 | | incense RESOURCES | ESI | FSPPHHRANSC | HRSA RICOLA POPP. SUPPORT | EMPLOREQ | 184,974 | 12,766 | 187,740 | 184,787 | 12,842 | | 309 | 13,202 | | incense RESOURCES | ESI | FSPPHRIBEINE | Benefra diagnostic project | EMPLOYAL | 138,927 | | 138,927 | 132,384 | 6,543 | | (1) | 6,542 | | incense RESOURCES | ESI | FSPPHRIEAH | Leave Of Reserve Coassessing P | EMPLOYAL | | | | | | | | | | incense RESOURCES | ESI | FSPPHRIRAPAL | HR SEPHCES - PALDADES | DIRECTNA | 2,827 | | 2,827 | 2,827 | | | | | | incense RESOURCES | ESI | FSPPHRISEMP | HR Smo. System Planning | DIRECTESI | 108,841 | | 108,841 | 108,841 | | | | | | incense RESOURCES | ESI | FSPPHRISSPQ | HR EVS - EIS SUPPLY CHAN | DIRECTESI | 75,019 | | 75,019 | 75,019 | | | | | | incense RESOURCES | ESI | FSPPHRTFMR | HR Transformation | DIM Cools | EMPLOYAL | 1,610,586 | 145,664 | 1,756,250 | 1,672,080 | 84,170 | | (2,357) | 81,613 | | incense RESOURCES | ESI | FSPPHIGUPP | INDUSTRIAL HYSENSE EQUIP &; SUP | EMPLOYAL | 3,085 | | 3,085 | 2,941 | 145 | | (0) | 144 | | incense RESOURCES | ESI | FSPPHITALID | Internet Audit Services | ASSTSALL | 322,152 | | 322,152 | 290,119 | 32,032 | | (73) | 31,959 | | incense RESOURCES | ESI | FSPPINVOCU | OCU Anti Trust Investigation | CLISECIPCO | 84,634 | | 84,634 | 72,122 | 12,512 | | (25) | 12,487 | | incense RESOURCES | ESI | FSPPINS001 | ST JSTRAIGHT TAKL PAVRIAL - 1 | DIRECTENU | 4,544 | | 4,544 | 4,544 | | | | | | incense RESOURCES | ESI | FSPPISP717 | Integration Planning Studies 1 | LOADCIPCO | 16,474 | | 16,474 | 13,952 | 2,522 | | (7) | 2,516 | | incense RESOURCES | ESI | FSPPL10425 | EGS LA Tar Services | DIRECTLQ | 110,462 | | 110,462 | 110,462 | | | | | | incense RESOURCES | ESI | FSPPL10443 | EGS LA Tar Services Below the | DIRECTLQ | 711 | | 711 | 711 | | | | | | incense RESOURCES | ESI | FSPPL23946 | BUSINESS EVERY PROCESS - EGSL | DIRECTLQ | 1,881 | | 1,881 | 1,881 | | | | | | incense RESOURCES | ESI | FSPPL23956 | BCE EVERY PROCESS - REFVA, EGS | DIRECTLQ | 13,386 | | 13,386 | 13,386 | | | | | | incense RESOURCES | ESI | FSPPL82368 | EGS LA MTW | DIRECTLQ | 397 | | 397 | 397 | | | | | | incense RESOURCES | ESI | FSPPLEGIPAL | LEDAIL SEPHICEE - PALDADES | DIRECTNA | 4,986 | | 4,986 | 4,986 | | | | | | incense RESOURCES | ESI | FSPPLEGISTM | NationalRip Insurance Reserve | DIRECTETR | 47,217 | | 47,217 | 47,217 | | | | | | incense RESOURCES | ESI | FSPPLEGUTL | Legal Services - Regulated UK | LOADCIPCO | 293,022 | | 293,022 | 247,593 | 45,429 | | (101) | 45,326 | | incense RESOURCES | ESI | FSPPLFNP10 | SLL LITSC Furnace Rate Plan TV | DIRECTELL | 14,146 | | 14,146 | 14,146 | | | | | | incense RESOURCES | ESI | FSPPLGYPXY | Little Guays Seauclination | DIRECTELL | 18,447 | | 18,447 | 18,447 | | | | | | incense RESOURCES | ESI | FSPPLESHTN | Project Luphning | ASSTEWCB | 323 | | 323 | 323 | | | | | | incense RESOURCES | ESI | FSPPLTTX10 | 2012 Winter Lijshing Printer Tex | DIRECTTX | 2,222 | | 2,222 | | 2,222 | | (5) | 2,217 | | incense RESOURCES | ESI | FSPPNAB800 | WATENPORO E-DEVERAL SUPPORT | DIRECTWF3 | 22,187 | | 22,187 | 22,187 | | | | | | incense RESOURCES | ESI | FSPPNAB8225 | SECLANTY SEPHICEE &; F WATENPORO | DIRECTWF3 | 150,597 | | 150,597 | 150,597 | | | | | | incense RESOURCES | ESI | FSPPNANALLZ | Middle National Min Dev - Mi Ju | MACCTALL | 25,987 | | 25,987 | 22,249 | 3,738 | | (9) | 3,729 | | incense RESOURCES | ESI | FSPPNASEX10 | WILTONWOTCH &CO EYEe EPIc | DIRECTESE | | | | | | | | | | incense RESOURCES | ESI | FSPPNASEX12 | 2012 SW-Trait Audit | DIRECTESE | 14,876 | | 14,876 | 14,876 | | | | | | incense RESOURCES | ESI | FSPPNASRSLE | MPSC Confidentiality Rule Main | DIRECTESE | 39 | | 39 | 39 | | | | | | incense RESOURCES | ESI | FSPPNAB831 | MPSC Transient Force on Force E | DIRECTWF3 | 24,416 | | 24,416 | 24,416 | | | | | | incense RESOURCES | ESI | FSPPNAB8325 | INVER FLOODING PRISPS | DIRECTR80 | 133 | | 133 | 133 | | | | | | incense RESOURCES | ESI | FSPPNAB8665 | MPO KTY Team | DIRECTWF3 | | | | | | | | | | incense RESOURCES | ESI | FSPPNAB8773 | Decor's Working Shock Review | DIRECTWF3 | 1,772 | | 1,772 | 1,772 | | | | | | incense RESOURCES | ESI | FSPPNAB874 | WFS Planned Union Campaign | DIRECTWF3 | 2,726 | 323 | 4,050 | 4,050 | | | | | | incense RESOURCES | ESI | FSPPNAB8778 | SOP Grading foruse Recovery | DIRECTWF3 | 140 | | 140 | 140 | | | | | | incense RESOURCES | ESI | FSPPNAB8880 | 2011 Fixed Prep &; Response | DIRECTWF3 | 133 | | 133 | 133 | | | | | | incense RESOURCES | ESI | FSPPNA18198 | 14 Box AICC Power Line | DIRECTSER | | | | | | | | | | incense RESOURCES | ESI | FSPPNA18209 | GENE FLOOD PRISPS &; OUTWOE COST | DIRECTSER | 53 | | 53 | 53 | | | | | | incense RESOURCES | ESI | FSPPNA18211 | School Gulf Strike Contingency | DIRECTSER | 128 | | 128 | 128 | | | | | | incense RESOURCES | ESI | FSPPNA20236 | WATENPORO E COCLE 16 RELOAD | DIRECTWF3 | | | | | | | | | | incense RESOURCES | ESI | FSPPNA20239 | WAT-1 Cycle 21 Revasc | DIRECTWFS | | | | | | | | | | incense RESOURCES | ESI | FSPPNA20245 | WATENPORO E COCLE 16 RELOAD | DIRECTWF3 | 12,961 | | 12,961 | 12,961 | | | | | | incense RESOURCES | ESI | FSPPNA20246 | WAT-2 Cycle 20 Revasc | DIRECTWFS | | | | 2,032 | 2,032 | | | |

| | | | | | $(A)$ | $(B)$ | $(C)$ | $(D)$ | $(E)$ | $(F)$ | $(G)$ | $(H)$ | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | ETT/Per Blooks | Exclusions | Pro Postop Amount | Total EPI Adjudices | | | | | | | | | Service Company | | | | | | | | | | | | | | Receptor | | | | | | | | | | | | DIRCTECS | 8 | | 8 | 8 | | | | | | | | | | DIRCTECS | 1,364 | | 1,364 | 1,364 | | | | | | | | | | DIRCTECS | 10,500 | | 10,500 | 10,500 | | | | | | | | | | DIRCTECS | 10,500 | | 10,500 | 10,500 | | | | | | | | | | DIRCTECS | 55,699 | | 55,699 | 55,699 | | | | | | | | | | DIRCTECS | 6,033,748 | | 6,033,748 | 6,033,748 | | | | | | | | | | DIRFDS | 125,415 | | 125,415 | 125,415 | | | | | | | | | | DIRFDS | 33,477 | | 33,477 | 33,477 | | | | | | | | | | DIRFDS | 33,477 | | 33,477 | 33,477 | | | | | | | | | | DIRFDS | 20,016 | | 20,016 | 21,016 | | | | | | | | | | DIRCANDC | 20,016 | 1,200 | 21,016 | 21,016 | | | | | | | | | | DIRCANDC | 2,226 | | 2,226 | 2,226 | | | | | | | | | | DIRCANDC | 5,040 | | 5,040 | 5,040 | | | | | | | | | | DIRCANICC | 5,040 | | 5,040 | 5,040 | | | | | | | | | | DIRCANICC | 4,649 | | 4,649 | 4,649 | | | | | | | | | | DIRSCTNI | | | | | | | | | | | | | | DIRSCTNI | 25,496 | 364 | 25,860 | 25,860 | | | | | | | | | | DIRSCT1A | | | | | | | | | | | | | | DIRSCT1A | 54,397 | | 54,397 | 54,397 | | | | | | | | | | DIRSCT1A | 2,981 | | 2,981 | 2,981 | | | | | | | | | | DIRCANDC | 56,4 | | 5,757 | 5,757 | | | | | | | | | | DIRCANDC | 10,500 | | 10,500 | 10,500 | | | | | | | | | | DIRCANDC | 2,226 | | 2,226 | 2,226 | | | | | | | | | | DIRCANDC | 3,040 | | 3,040 | 3,040 | | | | | | | | | | DIRCANDC | 4,649 | | 4,649 | 4,649 | | | | | | | | | | DIRSCTNI | | | | | | | | | | | | | | DIRSCTNI | 25,496 | 364 | 25,860 | 25,860 | | | | | | | | | | DIRSCT1A | | | | | | | | | | | | | | DIRSCT1A | 54,397 | | 54,397 | 54,397 | | | | | | | | | | DIRSCT1A | 2,981 | | 2,981 | 2,981 | | | | | | | | | | DIRCANDC | 56,4 Implants Hazard Assesment | | 5,757 | 5,757 | | | | | | | | | | DIRSCT1A | 3,939 | | 3,939 | 3,939 | | | | | | | | | | DIRSCT1A | 2,437 | | 2,437 | 2,437 | | | | | | | | | | DIRSCT1A | 146 | | 146 | 146 | | | | | | | | | | DIRSCT1A | 1,159 | | 1,159 | 1,159 | | | | | | | | | | DIRSCT1A | 13,419 | | 13,419 | 13,419 | | | | | | | | | | DIRSCT1A | 425 | | 425 | 425 | | | | | | | | | | DIRSCT1A | 425 | | 425 | 425 | | | | | | | | | | DIRSCT1A | 5,620 | | 5,620 | 5,620 | | | | | | | | | | DIRSCT1A | 7,882 | | 7,882 | 7,882 | | | | | | | | | | DIRSCT1A | 14,377 | | 14,377 | 14,377 | | | | | | | | | | DIRSCT1A | 3,579 | | 3,579 | 3,579 | | | | | | | | | | DIRSCT1A | 229 | | 229 | 229 | | | | | | | | | | DIRCCT1A | 229 | | 229 | 229 | | | | | | | | | | DIRSCT1A | 157 | | 157 | 157 | | | | | | | | | | DIRSCT1A | 157 | | 157 | 157 | | | | | | | | | | DIRSCT1A | 2,399 | | 2,399 | 2,399 | | | | | | | | | | DIRSCT1A | 26,999 | | 26,999 | 26,999 | | | | | | | | | | DIRSCT1A | 425 | | 425 | 425 | | | | | | | | | | DIRSCT1A | 7,609 | | 7,609 | 7,609 | | | | | | | | | | DIRSCT1A | 1,378 | | 1,378 | 1,378 | | | | | | | | | | DIRSCT1A | 117 | | 117 | 117 | | | | | | | | | | DIRSCT1A | 2,101 | | 2,101 | 2,101 | | | | | | | | | | DIRSCT2A | 13,955 | | 13,955 | 13,955 | | | | | | | | | | DIRCCT2A | 13,955 | | 13,955 | 13,955 | | | | | | | | | | DIRCCT2A | 23,742 | | 23,742 | 23,742 | | | | | | | | | | DIRCCT2A | 144 | | 144 | 144 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | | | | | | | | DIRCCT3B | 162 | | 162 | 162 | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | EBI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | Service Company | Total | All Other BLVs | EPI-Per | Exclusions | Pro Postep | Total EPI | | | | | | | | Receptor | | | | | Amount | Adjudices | | nolores | NOLORICES | EGI | FSPPRF10CCS | COS CLISTUMER ACCOLATING | CLOSEDATX | 113,171 | 113,171 | 113,171 | | | | | | | | EGI | FSPPRF10HAM | CLIST ACCOLATING EGI HAMMOND | CLISTEXTA | 24,657 | 24,657 | 24,657 | | | | | | | | EGI | FSPPRMODS | EOD Louisiana Communications | DIRECTLG | | | | | | | | | | | EGI | FSPPRM1133 | TEXAS COMMUNICATION | DIRECTTX | 885 | 885 | | 885 | | (2) | 883 | | | | EGI | FSPPR96820 | WHO-ESALE - EAI | DIRECTEAI | 56,587 | 56,587 | 56,587 | | | | | | | | EGI | FSPPR96422 | Wholesale - Fort Pulk Project | DIRECTELI | 65 | 65 | 65 | | | | | | | | EGI | FSPPR96620 | WHO-ESALE - EOD-LK | DIRECTLG | 24,574 | 24,574 | 24,574 | | | | | | | | EGI | FSPPR96640 | WHO-ESALE - EOD-TK | DIRECTTX | 27,447 | 27,447 | | 27,447 | | (64) | 27,383 | | | | EGI | FSPPR96720 | WHO-ESALE - EMI | DIRECTEM | 7,953 | 7,953 | | | | | | | | | EGI | FSPPR96920 | Wholesale - All Jurisdictions | MACCTALL | | | | | | | | | | | EGI | FSPPRP23BMI | Beaumont Customer Service Card | CLISTCALL | (2,035) | (2,035) | (1,809) | (226) | | 2 | (224) | | | | EGI | FSPPRP23BIR | Basic Rouge Customer Service C | CLISTCALL | 132,659 | 132,659 | 118,156 | 14,503 | | (34) | 14,469 | | | | EGI | FSPPRP23CA | Central Administration Code | CLISTCALL | 47,419 | 47,419 | 42,238 | 5,180 | | (18) | 5,162 | | | | EGI | FSPPRP23LR | Little Rock Customer Service C | CLISTCALL | 279 | 279 | 249 | 30 | | (5) | 30 | | | | EGI | FSPPRP23NO | New Orleans Customer Service C | CLISTCALL | 147,230 | 147,230 | 131,147 | 16,083 | | (38) | 16,046 | | | | EGI | FSPPRP23TX | COLING System Support EOD-TK | DIRECTTX | 7,356 | 7,356 | | 7,356 | | (15) | 7,341 | | | | EGI | FSPPRP2407 | NCI ASOLRIMES EPI TEXAS | DIRECTTX | 4,093 | 4,093 | | 4,093 | | (9) | 4,084 | | | | EGI | FSPPRC2008 | ENOI EMB RATE CASE | DIRECTEND | 11,200 | 779 | 11,979 | 11,979 | | | | | | | EGI | FSPPRPACALL | Residential Market Dev - ALL-L | CLISTEODIP | 66,479 | 66,479 | 57,293 | 9,184 | | (21) | 9,164 | | | | EGI | FSPPRPEDSLE | Residential Market Develop - E | DIRECTLG | 680 | 680 | 680 | | | | | | | | EGI | FSPPRPEDSKE | Residential Market Develop - E | DIRECTEM | 29 | 29 | 29 | | | | | | | | EGI | FSPPRPED001 | Regulated GYly Electric Per | CLOSEOPCO | 118,585 | 118,585 | 101,070 | 17,515 | | (40) | 17,475 | | | | EGI | FSPPRPED002 | New Reg Post Electric Perkin | SENUCALL | 8,275 | 8,275 | 8,275 | | | | | | | | EGI | FSPPRPED003 | EAM Electric Perkab by Stand | DIRECTOC | 2,850 | 2,850 | 2,850 | | | | | | | | EGI | FSPPRM10SL | AUDIT EOD-LS | DIRECTLG | 4,815 | 4,815 | 4,815 | | | | | | | | EGI | FSPPRM103T | AUDIT EOD-TK | DIRECTTX | 5,345 | 5,345 | | 5,345 | | (12) | 5,333 | | | | EGI | FSPPRM1349 | Wall Management - EAM | DIRECTOU | 2,210 | 2,210 | 2,210 | | | | | | | | EGI | FSPPRN1ACA | Nat'l Acity Sales & Még - EGS | DIRECTTX | | | | | | | | | | | EGI | FSPPRTAMSAR | Texas Municipal Powerlight Au | DIRECTTX | 2,820 | 2,820 | | 2,820 | | (6) | 2,814 | | | | EGI | FSPPSSAMT11 | Severe Accident Management Test | SINUCENTE | 3,404 | 3,404 | 3,404 | | | | | | | | EGI | FSPPSSMLL2 | Small Business Mit Dev - ALL-L | CLISTEODIP | 2,975 | 2,975 | 2,563 | 412 | | (1) | 411 | | | | EGI | FSPPSBEAG | Small Business Mit Dev - EAI | DIRECTEAI | 7,459 | 7,459 | 7,459 | | | | | | | | EGI | FSPPSBEOL2 | Small Business Mit Dev - EOG-L | DIRECTLG | 3,923 | 3,923 | 3,923 | | | | | | | | EGI | FSPPSBEDLT2 | Small Business Mit Dev - EOG-T | DIRECTTX | 4,147 | 4,147 | 4,147 | | (8) | 4,139 | | | | | EGI | FSPPSBEDL2 | Small Business Mit Dev - ELL | DIRECTELI | 7,254 | 7,254 | 7,254 | | | | | | | | EGI | FSPPSBEDL2 | Small Business Mit Dev - EMI | DIRECTEMI | 4,500 | 4,500 | 4,500 | | | | | | | | EGI | FSPPSBEDKOL | Small Business Mit Dev - ENO | DIRECTEND | 1,688 | 1,688 | 1,688 | | | | | | | | EGI | FSPPSCOLIT1 | Project Stock UP/ Lifespan A | DIRECTTX | 32,194 | 32,194 | | | | | | | | | EGI | FSPPSCOLCCC | Supply Chain South Cited | SCPSPPINC | 46 | 46 | 36 | 10 | | (0) | 10 | | | | EGI | FSPPSMARTQ | Smart Grid Traction | TRSBILNOP | | | | | | | | | | | EGI | FSPPSMORBID | Smart Grid Business Over Exp | CLOSEOPCO | 883 | 883 | 753 | 130 | | (0) | 130 | | | | EGI | FSPPSPC2006 | CSU Specialty Deals | CLISTCALL | 222,480 | 222,480 | 198,164 | 24,316 | | (57) | 24,259 | | | | EGI | FSPPSPED01 | SPU NEOCLIOPOR MRNASENDIF EAP | DIRECTLG | 590 | 590 | 590 | | | | | | | | EGI | FSPPSPED02 | SPU OXM Renewable RF/ Essence | LCMOOPCO | 7,394 | 3,394 | 2,887 | 507 | | (1) | 506 | | | | EGI | FSPPSPED03 | SPU Summer 2006 RF/ Expense | LCMOOPCO | 51,423 | 53 | 51,478 | 43,750 | 7,728 | | (21) | 7,707 | | | | EGI | FSPPSPED06 | SPU HES Miners Asset Contract | DIRECTEAI | 896 | | 896 | 896 | | | | | | | | EGI | FSPPSPED07 | SPU July 2004 Feeble Balance | LCMOOPCO | 9 | 9 | 9 | | | | | | | | EGI | FSPPSPED10 | SPU Overlap h-Value | LCMOOPCO | 478 | 478 | 405 | 73 | | (0) | 73 | | | | EGI | FSPPSPED11 | SPU NEECC Coroner | DIRECTLG | 10,902 | 10,902 | | | | | | | | | EGI | FSPPSPED12 | SPU White Buet Go Forgellors | DIRECTEAI | | | | | | | | | | | EGI | FSPPSPED15 | SPU Complete and Business Su | LCMOOPCO | 149,726 | 149,726 | 126,428 | 23,297 | | (51) | 23,247 | | | | EGI | FSPPSPED17 | SPU UFO Renewable RF | CLOSEOPCO | 12,995 | 12,995 | 11,055 | 1,945 | | (5) | 1,936 | | | | EGI | FSPPSPED18 | SPU SP at Strategic Initiative | LCMOOPCO | 72,270 | 72,270 | 61,302 | 11,068 | | (25) | 11,044 | | | | EGI | FSPPSPED24 | SPU Power Delivery & Tech Seer | LCMOOPCO | 55,970 | 55,970 | 47,282 | 8,687 | | (18) | 8,655 | | | | EGI | FSPPSPED25 | SPU SP10 Renewable RFP - LA on | CLOSELQLA | 77,695 | 77,695 | 77,695 | | | | | | | | EGI | FSPPSPED26 | SPU Project Houston PPA | DIRECTLG | 31 | 31 | 31 | | | | | | | | EGI | FSPPSPED27 | SPU E3I Project Houston PPA | DIRECTLGI | 53 | 53 | 53 | | | | | | | | EGI | FSPPSPED34 | SPU Expense EEEA Purchaser Zeit | CMMOOCG | 54,091 | 54,091 | 54,091 | | | | | | | | EGI | FSPPSPED45 | PMU Support Initiative - EAI | DIRECTEAI | 1,027 | 1,027 | 1,027 | | | | | | | | EGI | FSPPSPED48 | SPU Columnwork Expense | LCMOOPCO | 44 | 44 | 37 | 7 | | (0) | | | | | EGI | FSPPSPED49 | SPU 2011 EAI RFP | DIRECTEAI | 382 | 382 | 382 | | | | | | | | EGI | FSPPSPSE54 | Strategic Planning SOCIUM | DIRECTEINJ | 121 | 121 | 121 | | | | |

| Class | Billing Entity | Activity / Project Description | Activity / Project Description | ESt Billing Method | (A) DIMIG | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | Total Billing | | | | | | | | | | | | | | Service Company | Total | All Other BLS | E11-Pair | | | | | | | | | | | Reagent | | | | Exclusions | Pro Posters | Total E11 | | nolores NCSCUROC5 | ESI | PSPPWEO202 | System Planning Asset Management | LOADOPOO | 51,724 | | 51,724 | 43,646 | 8,078 | | | 8,059 | | nolores NCSCUROC5 | ESI | PSPPWEO205 | Food IT: EAI Support | DIRECTLIN | 7,760 | | 7,760 | 7,760 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO206 | Food IT: EU Support | DIRECTLIL | 1,004 | | 1,004 | 1,004 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO207 | Food IT: EAI Support | DIRECTEM | 6,669 | | 6,669 | 6,669 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO209 | Virtual Resource Center: SUS | CAPADPOO | 45,830 | | 45,830 | 40,875 | 4,955 | | | 4,943 | | nolores NCSCUROC5 | ESI | PSPPWEO310 | Food IT: ENO Support | DIRECTEND | 60 | | 60 | 60 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO315 | Dr. Southeast Region FXY ELI | CAPASTHN | 70,261 | | 70,261 | 70,261 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO326 | LAS14 Comply Supermarket: EU | DIRECTLQ | 35,548 | | 35,548 | 35,548 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO380 | Self Supply Project Team Admin | LOADOPOO | 47,517 | | 47,517 | 42,239 | 7,278 | | | 7,259 | | nolores NCSCUROC5 | ESI | PSPPWEO381 | CNACOMP-NCvMercury Center III | CAPADPOO | 1,864 | | 1,864 | 1,662 | 201 | | | 201 | | nolores NCSCUROC5 | ESI | PSPPWEO385 | Monroe ACW clean up ELRA | DIRECTLLI | 657 | | 657 | 657 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO372 | EWI Union Neighbour Food | DIRECTEM | 2,844 | 124 | 2,968 | 2,968 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO375 | SAIC Designated Do-To-Food | CAPADPOO | 6,629 | | 6,629 | 5,912 | 717 | | | 714 | | nolores NCSCUROC5 | ESI | PSPPWEO376 | Food Taxon Pygmas Process | CAPADPOO | 6,092 | | 6,092 | 5,433 | 659 | | | 657 | | nolores NCSCUROC5 | ESI | PSPPWEO383 | Dr. Capital Property 57B | CAPADPOO | 84,156 | | 84,156 | 75,058 | 9,098 | | | 8,078 | | nolores NCSCUROC5 | ESI | PSPPWEO402 | SPG Repatriory Competence | LOADOPOO | 92,249 | | 92,249 | 77,559 | 14,310 | | | 7,021 | | nolores NCSCUROC5 | ESI | PSPPWEO403 | SPG Performance Migrant/Special | LOADOPOO | 70,815 | | 70,815 | 59,829 | 10,986 | | | 7,091 | | nolores NCSCUROC5 | ESI | PSPPWEO409 | Business Support: SPF EAI | DIRECTLIN | 3,098 | | 3,098 | 3,098 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO410 | Business Support: SPF ELI | DIRECTLLI | 1,736 | | 1,736 | 1,736 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO411 | Business Support: SPF EM | DIRECTEM | 2,682 | | 2,682 | 2,682 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO412 | Business Support: SPF ENO | DIRECTEND | | | | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO420 | SPG ESSL Supply/Procurett/Roast | DIRECTLQ | 771 | | 771 | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO427 | Dr. Northwest Region EAI 6 EO | CAPAMWES | 71,387 | | 71,387 | 51,233 | 20,154 | | | 20,157 | | nolores NCSCUROC5 | ESI | PSPPWEO429 | Dr. Central Region EO5 LA 6 E | CAPACENT | 45,319 | | 45,319 | 45,319 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO431 | Director: Capital Property | CAPADPOO | 818 | | 818 | 730 | 88 | | | 88 | | nolores NCSCUROC5 | ESI | PSPPWEO432 | SPG/Management Eye RP Adv | LOADOPOO | 230 | | 230 | 195 | 35 | | | 35 | | nolores NCSCUROC5 | ESI | PSPPWEO437 | SPG Expense KGen Hindu | DIRECTEM | | | | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO438 | SPG Expense KGen Hit Springi | DIRECTLIN | | | | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO446 | Mgr. Business Processes: SINI EA | DIRECTLIN | 3,537 | | 3,537 | 3,537 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO447 | Mgr. Business Processes: SINI EL | DIRECTLLI | 6,768 | | 6,768 | 6,768 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO448 | Mgr. Business Processes: SINI EW | DIRECTEM | 4,876 | | 4,876 | 4,876 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO449 | Mgr. Business Processes: SINI EN | DIRECTEND | 6,079 | | 6,079 | 6,079 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO453 | White Bull Shoulder AV 210 F | DIRECTLIN | | | | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO469 | FWT/N-EAI Fuel Fearing Development | DIRECTLIN | 7,179 | | 7,179 | 7,179 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO470 | FWT/N-ELL Fuel Fearing Development | DIRECTLLI | 15,682 | | 15,682 | 15,682 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO471 | FWT/N-EAI Fuel Fearing Development | DIRECTEM | 5,495 | | 5,495 | 5,495 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO472 | FWT/N-ENO/Fuel Fearing Development | DIRECTEND | 2,181 | | 2,181 | 2,181 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO477 | SPA Diver and Fuel Serving | DIRECTEM | | | | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO486 | Director: Peer Maintenance: EU | CAPADPOO | 132,571 | | 132,571 | 118,239 | 14,332 | | | 14,302 | | nolores NCSCUROC5 | ESI | PSPPWEO487 | Manager: Performance Members | CAPADPOO | 147,602 | | 147,602 | 131,644 | 15,957 | | | 15,921 | | nolores NCSCUROC5 | ESI | PSPPWEO490 | Laka Cattarina e Baitamem 5L | DIRECTLIN | 17,215 | | 17,215 | 17,215 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO491 | Director: Competence 6 Op Supa | CAPADPOO | 225,075 | | 225,075 | 200,742 | 24,333 | | | 24,292 | | nolores NCSCUROC5 | ESI | PSPPWEO497 | National Peer Assessment | DIRECTEND | 4,283 | | 4,283 | 4,283 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO498 | Weanish Peer Assessment | DIRECTLLI | 4,229 | | 4,229 | 4,229 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO504 | WISSE - CIP Wabituen | DIRECTEND | 1,060 | | 1,060 | 1,060 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO505 | WISSE - CIP Wabituen | DIRECTEND | 340 | | 340 | 340 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO506 | WISSE - CIP Wabituen | DIRECTEXi | 450 | | 450 | 450 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO507 | LASIS - CIP Wabituen | DIRECTLLI | 1,464 | | 1,464 | 1,464 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO508 | EAI Protection System Equip L | DIRECTEXi | 3,132 | | 3,132 | 3,132 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO509 | SLL Protection System Equip L | DIRECTLLI | 3,661 | | 3,661 | 3,661 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO510 | ESSL Protection System Equip L | DIRECTLQ | 1,160 | | 3,505 | 3,505 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO511 | EAI Protection System Equip L | DIRECTEM | 39 | | 39 | 39 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO512 | ENO Protection System Equip L | DIRECTSNO | 284 | | 284 | 284 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO513 | E1I Protection System Equip L | DIRECTTX | 2,016 | | 2,016 | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO514 | EIU - Protection System Equip | CAPADPOO | 80 | | 80 | 81 | 8 | | | 81 | | nolores NCSCUROC5 | ESI | PSPPWEO515 | EIU Competence Culture Traism | CAPADPOO | 925 | | 925 | 834 | 101 | | | 101 | | nolores NCSCUROC5 | ESI | PSPPWEO516 | SPA Section 11A Request for In | DIRECTLIN | 15,091 | | 15,091 | 15,091 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO,003 | Food IT Support: FIT L/2005 | DIRECTLQ | 658 | | 658 | 658 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO,008 | Business Support: SPF L/S | DIRECTLQ | | | | | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO,011 | Union 8809 2286 LA NON: 9006B | DIRECTLQ | 9,193 | 1,022 | 10,214 | 10,214 | | | | | | nolores NCSCUROC5 | ESI | PSPPWEO,014 | Mgr. Business Processes: SINI EG | DIRECTLQ | | | | | | | | |

| | | | | | | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | ESt Billing
Support | Total Billing | | | | | | | | | incisions NCSCURICE | ESI | FSPPNECS19 | FSPTN-ESN, FscTraining Develey | DIRECTLQ | 2,018 | 2,018 | 2,018 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECS20 | EPX Strain and Fuel Sampling | DIRECTLQ | 434 | 434 | 434 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECSQM | ESD, Tash Services Supp. USWI | DIRECTLQ | 157,772 | 157,772 | 157,772 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECS4QN | Esh Engineering Tash Support | DIRECTEAI | 370,742 | 370,742 | 370,742 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECSQM | ESD TV Engineering Tash Support | DIRECTEX | 108,251 | 108,251 | | 108,251 | | | (306) | | 107,944 | | incisions NCSCURICE | ESI | FSPPNECSQM | ELI Engineering Tash Support | DIRECTELI | 423,969 | 423,969 | 423,969 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECS4QN | EMi Engineering Tash Support | DIRECTEM | 221,897 | 221,897 | 221,897 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECS4QN | EMD Engineering Tash Support | DIRECTENO | 100,454 | 100,454 | 100,454 | | | | | | | | incisions NCSCURICE | ESI | FSPPNECS5DN | General System WNS Tash Support | CAPACIPCQ | 114,259 | 114,259 | 101,906 | | 12,302 | | (46) | | 12,307 | | incisions NCSCURICE | ESI | FSPPNECT004 | Food IT Support / FIT TAND | DIRECTTX | 973 | 973 | | 973 | | (2) | | (2) | 970 | | incisions NCSCURICE | ESI | FSPPNECT007 | Business Support /IPP TV | DIRECTTX | 3,154 | 3,154 | | 3,154 | | (3) | | 3,149 | | | incisions NCSCURICE | ESI | FSPPNECT012 | Union WEW 2286 TX NON WOWB | DIRECTTX | 6,224 | 553 | 6,776 | | 6,776 | | (2) | | 6,900 | | incisions NCSCURICE | ESI | FSPPNECT014 | Mp. Business Processes, SIN TV | DIRECTTX | 3,094 | | 3,094 | | 3,094 | | (7) | | 3,088 | | incisions NCSCURICE | ESI | FSPPNECT015 | LIHC Long Term Reliability Eng. | DIRECTTX | (19,129) | | (19,129) | | (19,129) | | (4) | | (19,096) | | incisions NCSCURICE | ESI | FSPPNECT017 | FSPTN-ETI Fuel training Develeym | DIRECTTX | 3,616 | | 3,616 | | 3,616 | | (8) | | 3,608 | | incisions NCSCURICE | ESI | FSPPNECT300 | SPIS 2008 Western Region RFP TV | DIRECTTX | 96 | | 96 | | 96 | | (0) | | 96 | | incisions NCSCURICE | ESI | FSPPNECT301 | SPIS ETI Supply/Procurementkept | DIRECTTX | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPNECT302 | SPIS 2008 Winter Western Region | DIRECTTX | 1,320 | | 1,320 | | 1,320 | | (2) | | 1,318 | | incisions NCSCURICE | ESI | FSPPNEC304 | SPIS Frontier 10 Year PPA | DIRECTTX | (256) | | (256) | | (256) | | 1 | | (255) | | incisions NCSCURICE | ESI | FSPPNECT305 | SPIS WWCFAR Express | DIRECTTX | | | | | | | (520) | | (520) | | incisions NCSCURICE | ESI | FSPPNECT304 | SPIS 2011 Western Region RPR | DIRECTTX | 10,033 | | 10,033 | | 10,033 | | (15) | | 10,018 | | incisions NCSCURICE | ESI | FSPPNECT308 | SPIS Copper PPA/Project House | DIRECTTX | 37,798 | 38 | 37,837 | | 37,837 | | 37,837 | | (67) | | incisions NCSCURICE | ESI | FSPPNECT0226 | ETI Tash Services Sup. TAND | DIRECTTX | 195,092 | | 195,092 | | 195,092 | | (226) | | 194,482 | | incisions NCSCURICE | ESI | FSPPNEN0098 | LILHLE-CAR Environmental Supp. | DIRECTLQ | 319 | | 319 | | 319 | | | | | | incisions NCSCURICE | ESI | FSPPNEN0103 | LILHLECCA N-1t Lethality Tester | DIRECTLQ | 1,759 | | 1,759 | | | | | | | | incisions NCSCURICE | ESI | FSPPNEN0104 | NISCO 2010 Outage Support OptE | DIRECTLQ | 25,340 | | 25,340 | | 25,340 | | | | | | incisions NCSCURICE | ESI | FSPPNEN0106 | NLE-NISCO Unit Performance Tex. | DIRECTLQ | 1,331 | | 1,331 | | 1,331 | | | | | | incisions NCSCURICE | ESI | FSPPNEN0107 | NLE-NISCO Unit Outage Support | DIRECTLQ | 17 | | 17 | | 17 | | | | | | incisions NCSCURICE | ESI | FSPPNENRNTY | Waxomy/Keon Waxomant | AGSTSALL | 6,701 | | 6,701 | | 6,701 | | 668 | | (1) | | incisions NCSCURICE | ESI | FSPPX10425 | EGS TX Tash Services | DIRECTTX | 96,143 | | 96,143 | | 96,143 | | (216) | | 95,928 | | incisions NCSCURICE | ESI | FSPPZB0092 | MCC Plant Support Non Cipp Lobe | DIRECTENO | 727 | | 727 | | 727 | | | | | | incisions NCSCURICE | ESI | FSPPZB0161 | Arkansas Food IT Support | DIRECTEAI | 1,514 | | 1,514 | | 1,514 | | | | | | incisions NCSCURICE | ESI | FSPPZB0212 | LAT-24 XTO Generator (Brooker 0) | DIRECTLQ | 637 | | 637 | | 637 | | | | | | incisions NCSCURICE | ESI | FSPPZG1493 | LGS Boiler Reports 11 | DIRECTELI | 548 | | 548 | | 548 | | | | | | incisions NCSCURICE | ESI | FSPPZG1695 | MC2 Turbine HP /P1LP LP Imp. | DIRECTENO | 2,848 | | 2,848 | | 2,848 | | | | | | incisions NCSCURICE | ESI | FSPPZG1876 | WF1 Aust-ipic Outage | DIRECTELI | 174 | | 174 | | 174 | | | | | | incisions NCSCURICE | ESI | FSPPZG1915 | LEC-2H C.PR Ruc Spring Oats | DIRECTTX | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG1938 | MC2 Boiler Outage 2011 | DIRECTENO | 6,754 | | 6,754 | | 6,754 | | | | | | incisions NCSCURICE | ESI | FSPPZG1991 | WF1 Boiler/Auntheme Outage | DIRECTEM | 6,600 | | 6,600 | | 6,600 | | | | | | incisions NCSCURICE | ESI | FSPPZG1996 | WMI Boiler/Auntheme Outage | DIRECTEM | 7,810 | | 7,810 | | 7,810 | | | | | | incisions NCSCURICE | ESI | FSPPZG2082 | 2008 Spring Boiler Outage | DIRECTEM | 331 | | 331 | | 331 | | | | | | incisions NCSCURICE | ESI | FSPPZG2146 | WF2 Turbine HP/P Inspection | DIRECTELI | 10,163 | | 10,163 | | 10,163 | | | | | | incisions NCSCURICE | ESI | FSPPZG2162 | TASM HP/P Turbine Outage | DIRECTTX | 1,401 | | 1,401 | | 1,401 | | (3) | | 1,398 | | incisions NCSCURICE | ESI | FSPPZG2200 | TASM Major Outage Schedule PI | DIRECTTX | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG2203 | TASM 2010 Pre-Summer Run Oats | DIRECTTX | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG2216 | LCL Boiler Reports | DIRECTELI | 1,131 | | 1,131 | | 1,131 | | | | | | incisions NCSCURICE | ESI | FSPPZG2221 | PV1 Spring Reliability Outage | DIRECTELI | 3,112 | | 3,112 | | 3,112 | | | | | | incisions NCSCURICE | ESI | FSPPZG2257 | PV1 Spring Reliability Outage | DIRECTELI | 428 | | 428 | | 428 | | | | | | incisions NCSCURICE | ESI | FSPPZG2281 | CIP1-07/Spring Reliability Outage | DIRECTEAI | 3,856 | | 3,856 | | 3,856 | | | | | | incisions NCSCURICE | ESI | FSPPZG2295 | CIP2-07 Reliability Use Fair 20 | DIRECTEAI | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG2272 | CIP2-07/Spring Reliability Outage | DIRECTENO | 2,800 | | 2,800 | | 2,800 | | | | | | incisions NCSCURICE | ESI | FSPPZG2294 | LCC Turbine Vehired Generator 0 | DIRECTELI | 10,427 | | 10,427 | | 10,427 | | | | | | incisions NCSCURICE | ESI | FSPPZG2374 | WMI Aust-ipic Posture Outage 2 | DIRECTEAI | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG2378 | TASM 2012 Pre-Summer Run Oats | DIRECTTX | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG2384 | DL1 WLVE CV7AS6 | DIRECTEM | 565 | | 565 | | 565 | | | | | | incisions NCSCURICE | ESI | FSPPZG2385 | DL2 WLVE CV7AS6 | DIRECTEM | 689 | | 689 | | 689 | | | | | | incisions NCSCURICE | ESI | FSPPZG2397 | ATC Major Outage | DIRECTEM | 5,877 | | 5,877 | | 5,877 | | | | | | incisions NCSCURICE | ESI | FSPPZG2412 | WF1 Maintain 4-PP Control Veh. | DIRECTELI | 757 | | 757 | | 757 | | | | | | incisions NCSCURICE | ESI | FSPPZG2419 | LGS EAM Forced Draft Fair Veh. | DIRECTELI | 1,415 | | 1,415 | | 1,415 | | | | | | incisions NCSCURICE | ESI | FSPPZG2440 | WMI Unplanned Funter Outage | DIRECTELI | | | | | | | | | | | incisions NCSCURICE | ESI | FSPPZG2451 | LGE Boiler Reports | DIRECTELI | 443 | | 443 | | 443 | | | | | | incisions NCSCURICE | ESI | FSPPZG2498 | WMI Seven Process Outage 2015 | DIRECTEAI | 141 | | 141 | | 141 | | | | |

| | | | | | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | Class | Billing Entity | Activity / Project Code | Activity / Project Description | ESt Billing Method | Total Billing | | | | | | | | | | | | | | | Service Company | Total | All Other BDS | ETT/Pre | | | | | | | | | | | Recipient | | | | Exclusions | Pro Postna | Total ETT Adjudices | | Holistic | | | | | | | | | | | Amount | | | Holistic | 000 | FSPPZQ2515 | LK1 34 CT Mays Outage 2015 | DIRECTLQ | 170 | | 170 | 170 | | | | | | Holistic | 000 | FSPPZQ2535 | UPG 07 Fall Religiality Outage | DIRECTLQ | 70 | | 70 | 70 | | | | | | Holistic | 000 | FSPPZQ2581 | 077 Spring Outage -11 | DIRECTELI | 1,337 | | 1,337 | 1,337 | | | | | | Holistic | 000 | FSPPZQ2607 | L02 Auxiliary Outage Repairs 1 | DIRECTELI | 654 | | 654 | 654 | | | | | | Holistic | 000 | FSPPZQ2610 | 065 Tucking Generation Fall T1e | DIRECTT3 | 8,836 | | 9,836 | | 9,836 | | | | | Holistic | 000 | FSPPZQ2653 | W82 Auxiliary Process Spring 0 | DIRECTEAI | 266 | | 266 | 266 | | | | | | Holistic | 000 | FSPPZQ2658 | W82 Energy Conversion Fall Out | DIRECTEAI | 111 | | 111 | 111 | | | | | | Holistic | 000 | FSPPZQ2663 | W82 Energy Conversion Outage | DIRECTEAI | 1,491 | | 1,491 | 1,491 | | | | | | Holistic | 000 | FSPPZQ2670 | W81 Energy Conversion Spring 0 | DIRECTEAI | 1,332 | | 1,332 | 1,332 | | | | | | Holistic | 000 | FSPPZQ2684 | W81 Steam Process Outage | DIRECTEAI | 1,290 | | 1,290 | 1,290 | | | | | | Holistic | 000 | FSPPZQ2688 | W82 Steam Process Outage | DIRECTEAI | 1,175 | | 1,175 | 1,175 | | | | | | Holistic | 000 | FSPPZQ2742 | LK1 44 CT CI Outage (2011) | DIRECTLQ | 2,055 | | 2,055 | 2,055 | | | | | | Holistic | 000 | FSPPZQ2743 | LK1 44 Heat Recovery Steam Start | DIRECTLQ | 168 | | 168 | 168 | | | | | | Holistic | 000 | FSPPZQ2786 | Multi-Forced Outage | DIRECTELI | 7,606 | | 7,606 | 7,606 | | | | | | Holistic | 000 | FSPPZQ2790 | W69 Main Transformer Repairs | DIRECTELI | 8,371 | | 8,371 | 8,371 | | | | | | Holistic | 000 | FSPPZQ2791 | LK1 56 Tucking Lube Oil Leak | DIRECTLQ | 1,193 | | 1,193 | 1,193 | | | | | | Holistic | 000 | FSPPZQ2792 | L03 Generation Terminal

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BLS | ETC mai | | | | | | | | | | | Periphery | | | | | | | | | | Activity / Project | Activity / Project Description | 230 Billing Method | Support | Support | | | | | | | | | | | | | | Service Company | | | | | | | | | | | | | | Periphery | Total | All Other BLS | Exclusions | | | | | | | | | | | | | | | | Adjustment | | | | | | | | | | 259 | | | | | | | | | | | | | | 447 | | 447 | | | | | | | | | | | | 52 | | 52 | | 52 | | | | | | | | | 52 | 52 | | 52 | | 52 | | | | | | | | | 999 | | | 999 | | | | | | | | | | | | 999 | | | | | | | | | | | | | 1,651 | 1,651 | 1,651 | | | | | | | | | | | | 2,742 | 2,742 | | | | | | | | | | | | | 1,69 | 1,69 | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | 213 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Entity | Activity / Project Code | Activity / Project Description | IOI Billing Method | Support | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | | | | | | | | | | | | | | | Periphery | Total | All Other BLS | ETO Par
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| Class | Billing Entit | Activity / Project Code | Activity / Project Description | ESt Billing Method | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | Total Billing | | | | | | | | | | | | | | Service Company | Total | All Other BLS | ETO Per | | | | | | | | | | | Peripent | | | Books | Exclusions | Pro Forms | Total ETO | | | | | | | | | | | | | Amount | Adjusted | | nolents RECOURCES | ESt | SAPOPS910 | Kraft cret/Herbal mols. cremizEs | | 1,964,657 | | 1,964,657 | 1,736,463 | 228,194 | (227,385) | (809) | | | nolents RECOURCES | ESt | SAPOPS9911 | Kraft cret/Herbal mols. cremizEs | DIRCTEINU | | 13 | | 13 | | | | | | nolents RECOURCES | ESt | SAPOPCPLEO | Kraft cret/Herbal mols. ECH | DIRCTECII | | | | | | | | | | nolents RECOURCES | ESt | SAPOPCPLSL | Kraft cret/Herbal mols. ECH- EL | | (5) | | (5) | | | | | | | nolents RECOURCES | ESt | SAPOPCPLLP | Kraft cret/Herbal mols. | | 50 | | 50 | | | | | | | nolents RECOURCES | ESt | SAPPPT1000 | Ultra- 4 the ESt Cap or Soap | ITEPENIDA | 207,575 | | 207,575 | 104,849 | 12,726 | (12,726) | | | | nolents RECOURCES | ESt | SDPCE29004 | carr1te, scotmoed, cret1t-embe | DIRCTEAI | 11,795 | | 11,795 | 11,795 | | | | | | nolents RECOURCES | ESt | SDPCL79005 | carr scotmoed, cret1t-EsL LA-L | CLISTELLA | 421,874 | | 421,874 | 421,874 | | | | | | nolents RECOURCES | ESt | SDPCM79005 | carr scotmoed, cret1t-EsL ME1WJ | CLOSEMETR | 69,984 | | 69,984 | 59,984 | | | | | | nolents RECOURCES | ESt | SDPCP60007 | carr1te, scotmoed, cret1meb/1t2h | DIRCTEIM | 20,187 | | 20,187 | 20,187 | | | | | | nolents RECOURCES | ESt | SDPCR79005 | carr1te, scotmoed, cret1t-EsL LLA | DIRECTLQ | 167,141 | | 167,141 | 167,141 | | | | | | nolents RECOURCES | ESt | SDPCS79005 | carr scotmoed, cret1t-EsL L0L1H | CLOSEOUT | 8,798 | | 8,798 | 8,798 | | | | | | nolents RECOURCES | ESt | SDPCT30070 | carr1te, scotmoed, cret1t-embeL | DIRCTELI | 111,603 | | 111,603 | 111,603 | | | | | | nolents RECOURCES | ESt | SDPCT59005 | carr1te, scotmoed, ELEC cret1me | DIRCTENO | 27,015 | | 27,015 | 27,015 | | | | | | nolents RECOURCES | ESt | SDPCT79005 | carr1te, scotmoed, ELEC cret1me | DIRECTT9 | 30,481 | | 30,481 | | 30,481 | (26,347) | (4,134) | | | nolents RECOURCES | ESt | SDPCT40028 | cret1meb/1t2e-Care1tA, scotmoed | CLOSEDPOO | 622,921 | | 622,921 | 530,570 | 91,951 | (92,020) | 69 | | | nolents RECOURCES | ESt | SPPCE29000 | rctods, carr1te, scotmoed. EeL | DIRCTEAI | 992 | | 992 | 992 | | | | | | nolents RECOURCES | ESt | SPPCR79002 | rctods, carr1te, scotmoed. E11 | DIRECTT9 | 2,723 | | 2,723 | | 2,723 | (2,723) | | | | nolents RECOURCES | ESt | SPPCW30010 | rctods, carr1te, scotmoed. EL | DIRCTELI | 2,055 | | 2,055 | 2,055 | | | | | | nolents RECOURCES | ESt | SPPCW59003 | rctods, carr1te, scotmoed. Ee3 | DIRCTENO | 1,694 | | 1,694 | 1,694 | | | | | | nolents RECOURCES | ESt | SPPCW60005 | rctods, carr1te, scotmoed. EeL | DIRCTEIM | 1,870 | | 1,870 | 1,870 | | | | | | nolents RECOURCES | ESt | SPPCW50059 | rctods, carr1te, scotmoed. E3 | CAPAGPOO | 214,328 | | 214,328 | 191,156 | 23,171 | (23,171) | | | | nolents RECOURCES | ESt | SPPPL79002 | rctods, carr1te, scotmoed. E3SL | DIRECTLQ | 2,074 | | 2,074 | 2,074 | | | | | | nolents RECOURCES | ESt | SGPCG59006 | oes cret1meb/1t2e-En2c CH-LMA | DIRCTENO | 129,108 | | 129,108 | 129,108 | | | | | | nolents RECOURCES | ESt | SGPCR79008 | oes cret1meb/1t2e-Es2c CH-LVwM | DIRECTLQ | 83,750 | | 83,750 | 83,750 | | | | | | nolents RECOURCES | ESt | SNPCCCGUSP | carr1te, scotmoed. E11 | DIRECT7A | 9,705 | | 9,705 | 9,705 | | | | | | nolents RECOURCES | ESt | SNPCW30001 | Caprae Guernaea - Grave Gaf | DIRCTECII | 9,851 | | 9,851 | 9,851 | | | | | | nolents RECOURCES | ESt | SNPCN60237 | carr1te, scotmoed. ECnELON | DIRCTECII | 277,229 | | 277,229 | 277,229 | | | | | | nolents RECOURCES | ESt | SNPCN60000 | cret/Herbal3-MFS M15 Ee3LLA SuHER | DIRCTMFS | 12,360 | | 12,360 | 12,360 | | | | | | nolents RECOURCES | ESt | SNPCN79003 | mol/Rehic2 M15 cret/Herbal Ee3LLA | DIRCTRBS | 7,261 | | 7,261 | 7,261 | | | | | | nolents RECOURCES | ESt | SNPCN85001 | eko2 M15 cret/Herbal3 Ee3LLA SuHER | DIRCANOC | 24,346 | | 24,346 | 24,346 | | | | | | nolents RECOURCES | ESt | SNPCP83LISP | carr1te, scotmoed. ENCICL60 | DIRCTENO | 291,285 | | 291,285 | 291,285 | | | | | | nolents RECOURCES | ESt | SNPPCGUSP | carr1te, scotmoed. Pseudea N | DIRECTRIA | 11,554 | | 11,554 | 11,554 | | | | | | nolents RECOURCES | ESt | STPCE29002 | Arkansas Cap Suspense Torrentis | DIRCTEAI | 166,300 | | 166,300 | 166,300 | | | | | | nolents RECOURCES | ESt | STPCT30030 | ELL Capra Suspense Torrentis | DIRCTELI | 292,868 | | 292,868 | 292,868 | | | | | | nolents RECOURCES | ESt | STPCT59004 | Ee33 Caprae Suspense Torrentis | DIRCTENO | 41,944 | | 41,944 | 41,944 | | | | | | nolents RECOURCES | ESt | STPCT60006 | Ee33 Caprae Suspense Torrentis | DIRCTEIM | 246,668 | | 246,668 | 246,668 | | | | | | nolents RECOURCES | ESt | STPCTA0527 | TRANSMEDICK (CERT1A, SCERC60)E | TRANSPND | 2,071,214 | | 2,071,214 | 1,797,688 | 273,526 | (273,526) | | | | nolents RECOURCES | ESt | STPR5L7900 | Gulf States LA Transn Cap Soap | DIRECTLQ | 260,976 | | 260,976 | 260,976 | | | | | | nolents RECOURCES | ESt | STPPTD05LA | Caprae Suspense T60 Ee3-ESL | CLISTELLA | 60,723 | | 60,723 | 60,723 | | | | | | nolents RECOURCES | ESt | STPPTD06EA | Caprae Suspense T60 Ee3-ESL | DIRCTENI | 63 | | 63 | 63 | | | | | | nolents RECOURCES | ESt | STPPTD0ELL | Caprae Suspense T60 Ee3-ELL | DIRCTELI | 11,502 | | 11,502 | 11,502 | | | | | | nolents RECOURCES | ESt | STPPTD0E04 | Caprae Suspense T60 Ee3-094 | DIRCTEIM | 959 | | 959 | 959 | | | | | | nolents RECOURCES | ESt | STPPTD0E71 | Caprae Suspense T60 Ee3-E71 | DIRECTT9 | 341 | | 341 | 341 | 341 | (341) | | | | nolents RECOURCES | ESt | STPPTD033SL | Caprae Suspense T60 Ee3-ESUL | DIRECTLQ | 11,287 | | 11,287 | 11,287 | | | | | | nolents RECOURCES | ESt | STPPTD074CK | Caprae Suspense T60 Ee3-E74CK | DIRCTENO | 7,367 | | 7,367 | 7,367 | | | | | | nolents RECOURCES | ESt | STPPTD0927 | Caprae Suspense T60 Ee3-E927 | CUSEOPOO | 137,814 | | 137,814 | 117,454 | 25,359 | 25,359) | | | | nolents RECOURCES | ESt | STPPTX7900 | Texas Trans Caprae Suspense | DIRECTT9 | 274,459 | | 274,459 | | 274,459 | (274,459) | | | | nolents RECOURCES | Total ESt | | | | 124,995,535 | 1,632,240 | 126,631,775 | 115,390,709 | 11,241,066 | (1,728,946) | (139,153) | 9,372,996 | | Total HUMAN RECOURCES | | | | | 124,992,183 | 1,632,240 | 126,624,423 | 115,390,709 | 11,233,713 | (1,728,625) | (139,106) | 9,365,982 | | Total Gardner, Kevin | | | | | 124,992,183 | 1,632,240 | 126,624,423 | 115,390,709 | 11,233,713 | (1,728,625) | (139,106) | 9,365,982 |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BILLS | ETS Plan Books | Evaluations | Pro Forma Amount | Total ETS Adjudice | | | | | | | | | | Periphery | | | | | | | | | | | | | | | | | | | | | | | | | | | CPI | CPI | Activity / Project | 10CPF/3 Plant Security Project | DIRECT7.5 | 8,500 | 8,500 | 8,500 | | | | | | | | | CPI | CPI | Local 10CPF/3 Plant Security Project | DIRECT7.5 | 1,023 | 1,023 | 1,023 | 1,023 | | | | | | | | | CPI | CPI | CIPPISCA20B | Plant Cover - Analysis - Forest | DIRECT7.5 | 820 | 820 | 820 | | | | | | | | | CPI | CPI | CIPPISCA20C | Installation of Spore Transitor | DIRECT7.5 | 1,017 | 1,017 | 1,017 | | | | | | | | | CPI | CPI | CIPPISCA52A | Radiological Plung Project | DIRECT7.5 | 1,239 | 1,239 | 1,239 | | | | | | | | | CPI | CPI | CIPPISCA53A | Evacuate Peering - PPP Head file | DIRECT7.5 | 971 | 971 | 971 | | | | | | | | | CPI | CPI | CIPPISCU100 | Unit 1 -100 | DIRECT7.5 | 22,285 | 22,285 | 22,285 | | | | | | | | | CPI | CPI | CIPPISC233A | Unit 3 Loomer Removal | DIRECT7.7 | 22,927 | 22,927 | 22,927 | | | | | | | | | CPI | CPI | CIPPISC277A | IPU IPU/EV Parent - Engineering | DIRECT7.7 | | | | | | | | | | | | CPI | CPI | CIPPISC347A | 10CPF/3 Plant Security Project | DIRECT7.7 | 8,274 | 8,274 | 8,274 | | | | | | | | | CPI | CPI | CIPPISC447D | Local 10CPF/3 system | DIRECT7.7 | 1,524 | 1,524 | 1,524 | | | | | | | | | CPI | CPI | CIPPISCA45A | Radiological Plung Project | DIRECT7.7 | 1,239 | 1,239 | 1,239 | | | | | | | | | CPI | CPI | CIPPISCA43A | Evacuate Peering - PPP Head file | DIRECT7.7 | 871 | 871 | 871 | | | | | | | | | CPI | CPI | CIPPISC218A | Rupture Clearable UFQ Inverter | DIRECT7.8 | | | | | | | | | | | | CPI | CPI | CIPPISC273A | Rupture 1 Film Station Reserve | DIRECT7.8 | 494 | 494 | 494 | | | | | | | | | CPI | CPI | CIPPISC274A | Ear Power Update Peptide by 5 | DIRECT7.8 | $(56,254)$ | $(56,254)$ | $(56,254)$ | | | | | | | | | CPI | CPI | CIPPISC212A | Plant Security Project 10CPF/3 | DIRECT7.8 | 17,488 | 17,488 | 17,488 | | | | | | | | | CPI | CPI | CIPPISC312C | Monitoring Detection Informi Up | DIRECT7.8 | 1,574 | 1,574 | 1,574 | | | | | | | | | CPI | CPI | CIPPISC215A | 46PA 403 - Parent PC/504746_194469P | DIRECT7.8 | 309 | 309 | 309 | | | | | | | | | CPI | CPI | CIPPISC330A | Radiological Plung Project | DIRECT7.8 | 2,241 | 2,241 | 2,241 | | | | | | | | | CPI | CPI | CIPPI479920 | Lumen-Meam Coating Upgrade | DIRECT7.8 | 550 | 550 | 550 | | | | | | | | | CPI | CPI | CIPPI483030 | Our Fuel Storage | DIRECT7.8 | | | | | | | | | | | | CPI | CPI | CIPPI480080 | 10CPF/3 Security - 32CA-P294C65 | DIRECT7.8 | 2,620 | 2,620 | 2,620 | | | | | | | | | CPI | CPI | CIPPI480120 | Radiological Plung - 5 Type | DIRECT7.8 | 2,241 | 2,241 | 2,241 | | | | | | | | | CPI | CPI | CIPPI880080 | Insect Security Detection Ego | DIRECT7.8 | 1,630 | 1,630 | 1,630 | | | | | | | | | CPI | CPI | CIPPI7C210B | 10PA 403 Implementation | DIRECT7.8A | 528 | 528 | 528 | | | | | | | | | CPI | CPI | CIPPI7C221A | Flu-Ways-Mitigation | DIRECT7AA | 1,708 | 1,708 | 1,708 | | | | | | | | | CPI | CPI | CIPPI7C233A | Radiological Plung Project | DIRECT7AA | 2,241 | 2,241 | 2,241 | | | | | | | | | CPI | CPI | CIPPI479920 | Lumen-Meam Coating Upgrade | DIRECT7.8 | 550 | 550 | 550 | | | | | | | | | CPI | CPI | CIPPI480030 | Our Fuel Storage | DIRECT7.8 | | | | | | | | | | | | CPI | CPI | CIPPI480080 | 10CPF/3 Security - 32CA-P294C65 | DIRECT7.8 | 2,620 | 2,620 | 2,620 | | | | | | | | | CPI | CPI | CIPPI480120 | Radiological Plung - 5 Type | DIRECT7.8 | 1,240 | 1,240 | 1,240 | | | | | | | | | CPI | CPI | CIPPI880080 | Insect Security Detection Ego | DIRECT7.8 | 1,630 | 1,630 | 1,630 | | | | | | | | | CPI | CPI | CIPPI7C210B | 10PA 403 Implementation | DIRECT7AA | 528 | 528 | 528 | | | | | | | | | CPI | CPI | CIPPI7C221A | Flu-Ways-Mitigation | DIRECT7AA | 1,708 | 1,708 | 1,708 | | | | | | | | | CPI | CPI | CIPPI7C233A | Radiological Plung Project | DIRECT7AA | 2,241 | 2,241 | 2,241 | | | | | | | | | CPI | CPI | CIPPI7C242A | X-ray 600 Phase 2 | DIRECT7AA | 1,848 | 1,848 | 1,848 | | | | | | | | | CPI | CPI | CIPPI7C256A | Rupture-600Rv | DIRECT7AA | 1,240 | 1,240 | 1,240 | | | | | | | | | CPI | CPI | CIPPI7C265A | Souvenir-600Rv | DIRECT7AA | 847 | 847 | 847 | | | | | | | | | CPI | CPI | CIPPI7C278A | 300X | DIRECT7AA | 4,736 | 4,736 | 4,736 | | | | | | | | | CPI | CPI | CIPPI7C279B | ActonE | DIRECT7AA | 2,048 | 2,048 | 2,048 | | | | | | | | | CPI | CPI | CIPPI7C278D | Wax | DIRECT7AA | 10,344 | 10,344 | 10,344 | | | | | | | | | CPI | CPI | CIPPI7C283A | Mass Station Transformer study | DIRECT7AA | | | | | | | | | | | | CPI | CPI | CIPPIWC10PG | Size of 5-gene Switchport | DIRECT7.8 | | | | | | | | | | | | CPI | CPI | CIPPIWC117A | Rupture-3N Plant Process Comp | DIRECT7.7 | 1,411 | 1,411 | 1,411 | | | | | | | | | CPI | CPI | CIPPIWC119A | Rupture Pityine Plant Process | DIRECT7.8 | 13,873 | 13,873 | 13,873 | | | | | | | | | CPI | CPI | CIPPIWC127A | 300 software opposite | DIRECT7.8 | | | | | | | | | | | | CPI | CPI | CIPPIWC140A | 30905 Revonite Alip opposite | DIRECT7.8 | 1,837 | 1,837 | 1,837 | | | | | | | | | CPI | CPI | CIPPIWC166A | 3090 Oxyme Butage-Massor | DIRECT7.8 | | | | | | | | | | | | CPI | CPI | CIPPIWC173D | 101 opposite for 10 scaffold | DIRECT7.87 | 1481) | 1481) | 1481) | | | | | | | | | CPI | CPI | CIPPIWC184A | Outage in Processing System | DIRECT7.8 | 9,853 | 9,853 | 9,853 | | | | | | | | | CPI | CPI | CIPPIWC220A | IPU Cyber Security | DIRECT7.8 | 181 | 181 | 181 | | | | | | | | | CPI | CPI | CIPPIWC221A | IPU Cyber Security | DIRECT7.7 | 181 | 181 | 181 | | | | | | | | | CPI | CPI | CIPPIWC222A | J4P Cyber Security | DIRECT7.8 | 1,078 | 1,078 | 1,078 | | | | | | | | | CPI | CPI | CIPPIWC223A | 5-gene Cyber Security | DIRECT7.8 | 489 | 489 | 489 | | | | | | | | | CPI | CPI | CIPPIWC234A | Foliander Cyber Security | DIRECT7AA | 181 | 181 | 181 | | | | | | | | | CPI | CPI | CIPPIWC235A | 1P Cyber Security | DIRECT7.8 | 181 | 181 | 181 | | | | | | | | | CPI | CPI | CIPPIW60277 | 4PP 3010 Red Feet Application | DIRECT7.4 | 180 | 180 | 180 | | | | | | | | | CPI | CPI | CIPPI448606 | Star-Tam Storm Field of Repieon | DIRECTENO | 20,706 | 20,706 | 20,706 | | | | | | | | | CPI | CPI | C628275151 | 8707666 - 980059 1007 16CUE57 | DIRECTELI | | | | | | | | | | | | CPI | CPI | C628276087 | 8707666 - 980059 1007 16CUE57 | DIRECTELI | | | | | | | | | | | | CPI | CPI | C628474506 | 96U-460 EI-511 507 2045 2046 1R | DIRECTENO | 1,934 | 1,934 | 1,934 | | | | | | | | | CPI | CPI | C6PC148000 | 30078 UAKS 90/656UE 8L/664CT 961 | DIRECTELK | 329 | 329 | 329 | | | | | | | | | CPI | CPI | C6PC249000 | 3007 UAKS 90/656UE 8L/664CT 961 | DIRECTELI | 8,896 | 8,896 | 8,896 | | | | | | | | | CPI | CPI | C6PC249103 | 30078 UAKS 90P 8L/664CT CTN67I | DIRECTELI | 849 | 849 | 849 | | | | | | | | | CPI | CPI | C6PC249106 | 3776371 U307962 66697 8L/66437 | DIRECTELI | 508 | 508 | 508 | | | | | | | | | CPI | CPI | C6PC249107 | 3955472 32CURP11 12047962 66691 | DIRECTELI | 391 | 391 | 391 | | | | | | | | | CPI | CPI | C6PC249108 | 4054-68660475D-96L/2C47C99E 0LL | DIRECTELI | 892 | 892 | 892 | | | | | | | | | CPI | CPI | C6PC249708 | 74C7E3- 74R5875D-ORCUT54705 | DIRECTELI | | | | | | | | | | | | CPI | CPI | C6PC249800 | 3008 UAKS 90/656UE 8L/66437 961 | DIRECTELK | 742 | 742 | 742 | | | | | | | | | CPI | CPI | C6PC249800 | 3007 UAKS 90/656UE 8L/66437 961 | DIRECTELK | 820 | 820 | 820 | | | | | | | | | CPI | CPI | C6PC249800 | 3007 UAKS 90/656UE 8L/66437 | DIRECTELI | 8,896 | 8,896 | 8,896 | | | | | | | | | CPI | CPI | C6PC249103 | 30078 UAKS 90P 8L/66437 CTN67I | DIRECTELI | 849 | 849 | 849 | | | | | | | | | CPI | CPI | C6PC249106 | 3776371 U307962 66697 8L/66437 | DIRECTELI | 508 | 508 | 508 | | | | | | | | | CPI | CPI | C6PC249107 | 3955472 32CURP11 12047962 66691 | DIRECTELI | 391 | 391 | 391 | | | | | | | | | CPI | CPI | C6PC249108 | 4054-68660475D-96L/2C47C99E 0LL | DIRECTELI | 892 | 892 | 892 | | | | | | | | | CPI | CPI | C6PC249708 | 74C7E3- 74R5875D-ORCUT54705 | DIRECTELI | | | | | | | | | | | | CPI | CPI | C6PC249800 | 3008 UAKS 90/656UE 8L/66437 961 | DIRECTENA | 742 | 742 | 742 | | | | | | | | | CPI | CPI | C6PC249800 | 3007 UAKS 90/656UE 8L/66437 | DIRECTENO | 7,818 | 7,818 | 7,818 | | | | | | | | | CPI | CPI | C6PC249800 | 3007 UAKS 90/656UE 8L/66437 | DIRECTENO | 7,818 | 7,818 | 7,818 | | | | | | | | | CPI | CPI | C6PC249800 | 30078 UAKS 90/656UE 8L/66437 | DIRECTENO | 808 | 808 | 808 | | | | |

Amourits may not add or tie to other schedules due to rounding. Gardner, Kevin

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BILLS | ETS Plan Books | Evaluations | Pro Forma Amount | Total ETS Adjudice | | | | | | | | | | Peripheral | | | | | | | | | 00 | CPNIBI | CMPPSI46289 | Non Lake Nat 1865 Fdr | | DIRECTE66 | 317 | | 317 | 317 | | | | | | | 00 | CPNIBI | CMPPSI46290 | Bynan Nat 434 Mwn | | DIRECTE66 | 31 | | 31 | 31 | | | | | | | 00 | CPNIBI | CMPPSI46291 | Colerator Nat 1035 Fdr | | DIRECTE66 | 344 | | 344 | 344 | | | | | | | 00 | CPNIBI | CMPPSI46292 | Common South Nat 3591 Fdr | | DIRECTE66 | 403 | | 403 | 403 | | | | | | | 00 | CPNIBI | CMPPSI46293 | Aspect Nat 4661 Fdr | | DIRECTE66 | 511 | | 511 | 511 | | | | | | | 00 | CPNIBI | CMPPSI46294 | Aspect Nat 4663 Fdr | | DIRECTE66 | 584 | | 584 | 584 | | | | | | | 00 | CPNIBI | CMPPSI46295 | Aspect Nat 4665 Fdr | | DIRECTE66 | 541 | | 541 | 541 | | | | | | | 00 | CPNIBI | CMPPSI46296 | Cawnland Np 2011 Fdr | | DIRECTE66 | 174 | | 174 | 174 | | | | | | | 00 | CPNIBI | CMPPSI46297 | Crown Hw. Np 41401 Fdr | | DIRECTE66 | 485 | | 485 | 485 | | | | | | | 00 | CIPNIBI | CMPPSI46298 | McConte Np15450 Fdr | | DIRECTE66 | 505 | | 505 | 505 | | | | | | | 00 | CPNIBI | CMPPSI46299 | Common Np 9496 Fdr | | DIRECTE66 | 411 | | 411 | 411 | | | | | | | 00 | CPNIBI | CMPPSI46300 | Crown Np 6452 Fdr | | DIRECTE66 | 584 | | 584 | 584 | | | | | | | 00 | CPNIBI | CMPPSI46315 | Gloster Np11062.1 (residue J | | DIRECTE66 | 10 | | 10 | 10 | | | | | | | 00 | CPNIBI | CMPPSI46317 | Gloster Fony Np1414 (residue J) | | DIRECTE66 | 6 | | 6 | 6 | | | | | | | 00 | CPNIBI | CMPPSI46325 | Ringwood Np 414 (residue J) | | DIRECTE66 | 8 | | 8 | 8 | | | | | | | 00 | CPNIBI | CMPPSI46326 | Ringwood Np 414 (residue J) | | DIRECTE66 | 8 | | 8 | 8 | | | | | | | 00 | CPNIBI | CMPPSI46327 | Mendelsafl Np 1462 Fdr | | DIRECTE66 | 417 | | 417 | 417 | | | | | | | 00 | CPNIBI | CMPPSI46328 | Woodville Np 8460 Mwn | | DIRECTE66 | 731 | | 731 | 731 | | | | | | | 00 | CPNIBI | CMPPSI46327 | Raymond Np 414 (residue J) | | DIRECTE66 | 1 | | 1 | 1 | | | | | | | 00 | CPNIBI | CMPPSI46328 | Raymond Np 1414 (residue J) | | DIRECTE66 | 1 | | 1 | 1 | | | | | | | 00 | CPNIBI | CMPPSI46329 | Ringwood Np 8460 Mwn | | DIRECTE66 | 471 | | 471 | 471 | | | | | | | 00 | CPNIBI | CMPPSI46330 | Ringwood Np 8460 Mwn | | DIRECTE66 | 624 | | 624 | 624 | | | | | | | 00 | CPNIBI | CMPPSI46331 | Leaves Np 4601 Fdr | | DIRECTE66 | 866 | | 866 | 866 | | | | | | | 00 | CPNIBI | CMPPSI46332 | Raymond Np 414 (residue J) | | DIRECTE66 | 1 | | 1 | 1 | | | | | | | 00 | CPNIBI | CMPPSI46333 | Raymond Np 414 (residue J) | | DIRECTE66 | 401 | | 401 | 401 | | | | | | | 00 | CPNIBI | CMPPSI46341 | Cawnland South Np 2452 Fdr | | DIRECTE66 | 60 | | 60 | 60 | | | | | | | 00 | CPNIBI | CMPPSI46342 | Nectara Np 8693 Fdr | | DIRECTE66 | 624 | | 624 | 624 | | | | | | | 00 | CPNIBI | CMPPSI46351 | Leaves Np 4601 Fdr | | DIRECTE66 | 866 | | 866 | 866 | | | | | | | 00 | CPNIBI | CMPPSI46361 | Grenada 5 Np 6 (Nectade 266) | | DIRECTE66 | 6 | | 6 | 6 | | | | | | | 00 | CPNIBI | CMPPSI46368 | Hot Springe Mfron 48 (kneeb) | | DIRECTE34 | | | | | | | | | | | 00 | CPNIBI | CMPPSI46369 | Mayo Owe Soil Insec 4 230 470J | | DIRECTE34 | | | | | | | | | | | 00 | CPNIBI | CMPPSI46330 | Uash - Mepasa 470J | | DIRECTE34 | | | | | | | | | | | 00 | CIPNIBI | CMPPSI46313 | Little Plain Arch 80 - 44 970J | | DIRECTE34 | 81 | | 81 | 81 | | | | | | | 00 | CPNIBI | CMPPSI46331 | Jerusalem - 42 (kneebos) | | DIRECTE34 | | | | | | | | | | | 00 | CPNIBI | CMPPSI46341 | El Dor Jastra Np 4 F (kneeb Bie | | DIRECTE34 | | | | | | | | | | | 00 | CPNIBI | CMPPSI46342 | Mesmin 5 Np 1 (Nec 4 2 F) | | DIRECTE34 | | | | | | | | | | | 00 | CPNIBI | CMPPSI46344 | Ecotest - 1 (Eten and 2 Feeders | | DIRECTE34 | 125 | | 125 | 125 | | | | | | | 00 | CPNIBI | CMPPSI50342 | Henderson Road Purchase Rub 5 | | DIRECTE66 | 714 | | 714 | 714 | | | | | | | 00 | CPNIBI | CMPPSI51140 | Angelina Bude New 34 904 Sub | | DIRECTELI | | | | | | | | | | | 00 | CPNIBI | CMPPSI51332 | Valencia Bush 20641 (kneebs) | | DIRECTELI | 10,696 | | 10,696 | 10,696 | | | | | | | 00 | CPNIBI | CMPPSI53378 | Colored Glenn Road Site Practice | | DIRECTE34 | 86 | | 86 | 86 | | | | | | | 00 | CPNIBI | CMPPSI58484 | Bayview Land Purchase | | DIRECTLLS | | | | | | | | | | | 00 | CPNIBI | CMPPSI58330 | Church Hill Scale New (kneebs) | | DIRECTE66 | 8,987 | | 8,987 | 8,987 | | | | | | | 00 | CPNIBI | CMPPSI58398 | Calhoun Bude New 11804 Sub | | DIRECTELI | 1,298 | | 1,298 | 1,298 | | | | | | | 00 | CPNIBI | CMPPSI58646 | Cuomo Bush 68112 801 Sub 835 | | DIRECTLLS | 1,584 | | 1,584 | 1,584 | | | | | | | 00 | CPNIBI | CMPPSI58657 | Mexican Buddleas 464 1800 Sub | | DIRECTLLS | | | | | | | | | | | 00 | CPNIBI | CMPPSI58889 | Gezeman 10636 904 Sub 10636 | | DIRECTLLS | | | | | | | | | | | 00 | CPNIBI | CMPPSI58971 | Stor White New 20634.5 6506 A | | DIRECTLLS | 1,898 | | 1,898 | 1,898 | | | | | | | 00 | CPNIBI | CMPPSI58972 | Stor Branwood 20639 904 Sub | | DIRECTLLS | 7,614 | | 7,614 | 7,614 | | | | | | | 00 | CPNIBI | CMPPSI5F001 | Lake Bob Gigades Line Comm 8355 | | DIRECTLLS | 83 | | 83 | 83 | | | | | | | 00 | CPNIBI | CMPPSI5F002 | Contraband Gigades Line Comm10 | | DIRECTLLS | 56 | | 56 | 56 | | | | | | | 00 | CPNIBI | CMPPSI5F010 | Youngsville Park Land Purchase | | DIRECTLLS | 2,133 | | 2,133 | 2,133 | | | | | | | 00 | CPNIBI | CMPPSI5F011 | Youngsville New 10613 904 Sub | | DIRECTLLS | 26,089 | | 26,089 | 26,089 | | | | | | | 00 | CPNIBI | CMPPSI5G042 | Colton Sun 80a Purchase 6 Bce | | DIRECTLLS | 6,150 | | 6,150 | 6,150 | | | | | | | 00 | CPNIBI | CMPPSI5L001 | Ringold Mepasa 4914 | | DIRECTELI | 96 | | 96 | 96 | | | | | | | 00 | CPNIBI | CMPPSI5L002 | Oak Ridge Road 90m 6.55m | | DIRECTELI | 4,324 | | 4,324 | 4,324 | | | | | | | 00 | CPNIBI | CMPPSI5L003 | Rays St. Inesat 1235 4545 F | | DIRECTELI | 305 | | 305 | 305 | | | | | | | 00 | CPNIBI | CMPPSI940395 | Fort Ht 4 Feas801p 6 May 7p | | DIRECTELI | 4,451 | | 4,451 | 4,451 | | | | | | | 00 | CPNIBI | CMPPSI96048P | Add 630 Irrigation U. Pilot | | DIRECTE34 | 1,081 | | 1,081 | 1,081 | | | | | | | 00 | CPNIBI | CMPPSI96051B | 961 North (Bod 13 010) Corredor | | DIRECTLLS | 1,738 | | 1,738 | 1,738 | | | | | | | 00 | CPNIBI | CMPPSI96051P | Add 630 Irrigation U. Software | | DIRECTE34 | 2,186 | | 2,186 | 2,186 | | | | | | | 00 | CPNIBI | CMPPSIAA967 | 3701 Inspirment Meters E45 | | DIRECTE34 | 89 | | 89 | 89 | | | | | | | 00 | CPNIBI | CMPPF47308 | 3010 COS Regulatory Comp 4616 | | DIRECTE34 | | | | | | | | | | | 00 | CPNIBI | CMPPF483207 | Erit Time 6 Labor | | DIRECTE34 | 4 | | 4 | 4 | | | | | | | 00 | CPNIBI | CMPPF527308 | 3010 COS Regulatory Comp 6300 | | DIRECTLLS | | | | | | | | | | | 00 | CPNIBI | CMPPF528207 | 3335, Time 6 Labor | | DIRECTLLS | 224 | | 224 | 224 | | | | | | | 00 | CPNIBI | CMPPF58147 | Microwave Replacement Tissue 20 | | DIRECTTTA | 4,501 | | 4,501 | 4,501 | | | | | | | 00 | CPNIBI | CMPPF58205 | 06,4660 cmneorestone Gigades | | DIRECTA50C | 173 | | 173 | 173 | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BDS | ETS Plan | Evaluations | Pro Forma Amount | Total ETS Adjusted | | | | | | | | | Periphery | Periphery | | | | | | | | | | | | | | | | | | | | | | | | | | | CPI/BD | CMP/P/BD2C | NS AND PBP | | DIRC/ANCC | 158 | | 158 | 158 | | | | | | | ESI | CPI/BD | CMP/P/BD25 | Flow Backbone North Bind Flow | | DIRCT/ELI | (188) | | (188) | (188) | | | | | | | ESI | CPI/BD | CMP/P/BD2G | Flow Backbone North Bind Flow | | DIRR/CTLG | 188 | | 188 | 188 | | | | | | | ESI | CPI/BD | CMP/P/TCLS | 2000 Toleconic Capital Replacem | | DIRCT/ELI | | | | | | | | | | | ESI | CPI/BD | CMP/P/TE589 | 2000 Toleconic Capital Replacem | | DIRCT/E58 | | | | | | | | | | | ESI | CPI/BD | CMP/PL7308 | 2010 COS Regulatory Comp-ience | | DIRCT/ELI | | | | | | | | | | | ESI | CPI/BD | CMP/PL8207 | 3LL Time &; Labor | | DIRCT/ELI | 100 | | 100 | | | | | | | | ESI | CPI/BD | CMP/PM7308 | 2010 COS Regulatory Comp-ience | | DIRCT/E58 | | | | | | | | | | | ESI | CPI/BD | CMP/PM8207 | 200 Time &; Labor | | DIRCT/E58 | 4 | | 4 | 4 | | | | | | | ESI | CPI/BD | CMP/PN7308 | 2010 COS Regulatory Comp-ENO | | DIRCT/ENG | | | | | | | | | | | ESI | CPI/BD | CMP/PP68207 | 2003 Time &; Labor | | DIRCT/ENG | 4 | | 4 | 4 | | | | | | | ESI | CPI/BD | CMP/PPC410 | PC Inside for EAI- 2010 | | DIRCT/EAI | 934 | | 934 | 934 | | | | | | | ESI | CPI/BD | CMP/PPC411 | PC Inside for EAI- 2011 | | DIRCT/EAI | 374 | | 374 | 374 | | | | | | | ESI | CPI/BD | CMP/PT3001 | Regulatory Rgt Burn Rgt Times | | DIRR/CT73 | 7,175 | | 7,175 | | 7,175 | (7,175) | | | | | ESI | CPI/BD | CMP/PT3001 | 311 Time &; Labor | | DIRR/CT73 | 499 | | 499 | | 499 | (499) | | | | | ESI | CPI/BD | CMP/PTCL10 | 2010 Toleconic Capital Replacem | | DIRCT/ELI | 14 | | 14 | 14 | | | | | | | ESI | CPI/BD | CMP/PQ0001 | 2010 Toleconic Capital Replacem | | DIRCT/ELI | 240 | | 2,482 | 2,482 | | | | | | | ESI | CPI/BD | CMP/PT53411 | 2011 Toleconic Capital Replacem | | DIRCT/E58 | 282 | | 282 | 282 | | | | | | | ESI | CPI/BD | CMP/PT73440 | HMO Inactivated Device Refined 15 | | DIRR/CT73 | 330 | | 330 | | 335 | (335) | | | | | ESI | CPI/BD | CMP/PGG5048 | Evergreen Subl Imiped Repair 8 | | DIRCT/ELI | (192) | | (192) | (192) | | | | | | | ESI | CPI/BD | CMP/PGG5059 | Transposable Capsule content | | DIRCT/ELI | | | | | | | | | | | ESI | CPI/BD | CMP/PGG5073 | 10 James Replace 80/30 | | DIRCT/ELI | 81 | | 81 | | | | | | | | ESI | CPI/BD | CMP/PGG5074 | Lumen Avoid Backpost | | DIRCT/ELI | 202 | | 202 | 202 | | | | | | | ESI | CPI/BD | CMP/PGG5075 | McGull Gapsule UnderPreparacy | | DIRCT/ELI | | | | | | | | | | | ESI | CPI/BD | CMP/PGG5076 | Golden Member Gapsule (Listerin) | | DIRCT/ELI | | | | | | | | | | | ESI | CPI/BD | CMP/PGG5077 | Standard Replace Cation Panel | | DIRCT/ELI | 809 | | 809 | | | | | | | | ESI | CPI/BD | CMP/PGG5078 | Cation Replace Replacem Panel | | DIRCT/ELI | (1,708 | | 1,708 | 1,708 | | | | | | | ESI | CPI/BD | CMP/PGG5097 | Styro Form Replace 4H/02 | | DIRCT/ELI | 33 | | 33 | | | | | | | | ESI | CPI/BD | CMP/PGN0020 | New Nuclear Reg Freg 0020, On | | DIRR/CTLG | 7,311 | | 7,311 | | | | | | | | ESI | CPI/BD | CMP/PN80002 | Flour 100 New Service Center | | DIRR/CTLG | 1,642 | | 1,642 | 1,642 | | | | | | | ESI | CPI/BD | CMP/PL66020 | New Nuclear Reg Freg 0LL, Ong | | DIRCT/ELI | 7,796 | | 7,796 | 7,796 | | | | | | | ESI | CPI/BD | CMP/PMA2434 | Meso Add. Pre-OR 0064 | | DIRCT/ELI | 114 | | 114 | 114 | | | | | | | ESI | CPI/BD | CMP/PMA7355 | MINOR 400C Additional Ompg 15 | | DIRR/CT73 | 400 | | 400 | | 400 | (400) | | | | | ESI | CPI/BD | CMP/PMA9225 | Meso Add Flour 00mm Add. | | DIRCT/E56 | 1,520 | | 1,520 | 1,520 | | | | | | | ESI | CPI/BD | CMP/PN90020 | New Nuclear Reg Freg 00M Ong | | DIRCT/E56 | 2,178 | | 2,178 | 2,178 | | | | | | | ESI | CPI/BD | CMP/PN900775 | Regipenter Replace centir add | | DIRCT/ELI | 119 | | 119 | 119 | | | | | | | ESI | CPI/BD | CMP/PN903787 | Gorno replace failed meters | | DIRCT/ELI | | | | | | | | | | | ESI | CPI/BD | CMP/PN903802 | Exotic rep Ribo and Quad - | | DIRCT/ELI | 630 | | 630 | 630 | | | | | | | ESI | CPI/BD | CMP/PN903804 | Holiday model H0007 retyping | | DIRCT/ELI | 623 | | 623 | 623 | | | | | | | ESI | CPI/BD | CMP/PN903805 | Lung replace 115 P/I Smoker | | DIRCT/ELI | 12 | | 12 | 12 | | | | | | | ESI | CPI/BD | CMP/PN903807 | Weanepo model H0005 retyping | | DIRCT/ELI | 434 | | 434 | 434 | | | | | | | ESI | CPI/BD | CMP/PN903808 | Exotic rep Ribo/Cuad Help | | DIRCT/ELI | 520 | | 520 | 520 | | | | | | | ESI | CPI/BD | CMP/PN903809 | Holiday rep Slope centir ed | | DIRCT/ELI | 409 | | 409 | 409 | | | | | | | ESI | CPI/BD | CMP/PN903813 | Bionator, rep 110 Kxz 9x s | | DIRCT/ELI | 696 | | 696 | 696 | | | | | | | ESI | CPI/BD | CMP/PN903822 | Axial sol. replace failed met | | DIRCT/ELI | 275 | | 275 | 275 | | | | | | | ESI | CPI/BD | CMP/PN903826 | Holiday replace 02100 m-9 s | | DIRCT/ELI | 1,218 | | 1,218 | 1,218 | | | | | | | ESI | CPI/BD | CMP/PN922459 | Replace Freshwater Healer 3C-3T | | DIRCT/SER | 3,432 | | 3,432 | 3,432 | | | | | | | ESI | CPI/BD | CMP/PN32465 | 3H North Fuel Cycle | | DIRCT/SER | 1,071 | | 1,071 | 1,071 | | | | | | | ESI | CPI/BD | CMP/PN32518 | Stored Gurl Lianna Remed | | DIRCT/SER | 71,155 | | 71,155 | 71,155 | | | | | | | ESI | CPI/BD | CMP/PN32578 | Freshwater Healer Gable Real | | DIRCT/SER | | | | | | | | | | | ESI | CPI/BD | CMP/PN32593 | Siemens High Pressure Turbine | | DIRCT/SER | 12,458 | | 12,458 | 12,458 | | | | | | | ESI | CPI/BD | CMP/PN32595 | Nasal third malnourentator tip | | DIRCT/SER | 10,149 | | 10,149 | 10,149 | | | | | | | ESI | CPI/BD | CMP/PN32634 | McGHC PUMP RSPLAC000017 (PP17) | | DIRCT/SER | | | | | | | | | | | ESI | CPI/BD | CMP/PN32644 | 5004 Cooling Towels 8 | | DIRCT/SER | 943 | | 943 | 943 | | | | | | | ESI | CPI/BD | CMP/PN32645 | 10CFR15 Plant Specific Project | | DIRCT/SER | | | | | | | | | | | ESI | CPI/BD | CMP/PN32647 | Power Range Neutron Mini-boring | | DIRCT/SER | 20,838 | | 20,838 | 20,838 | | | | | | | ESI | CPI/BD | CMP/PN32663 | Au-Vac Corrig Tower System | | DIRCT/SER | 3,768 | | 3,768 | 3,768 | | | | | | | ESI | CPI/BD | CMP/PN32672 | PUSAR Loeime International Reg | | DIRCT/SER | 40,353 | | 40,353 | 40,353 | | | | | | | ESI | CPI/BD | CMP/PN32676 | Cunabimate Full Flow 7 Inlets | | DIRCT/SER | 3,167 | | 3,167 | 3,167 | | | | | | | ESI | CPI/BD | CMP/PN32685 | MIRAY Replacement (PP11) | | DIRCT/SER | | | | | | | | | | | ESI | CPI/BD | CMP/PN32686 | Remote Operated Reapprox System | | DIRCT/SER | 2,049 | | 2,049 | 2,049 | | | | | | | ESI | CPI/BD | CMP/PN32688 | Security Placing Repair &; Civil | | DIRCT/SER | | | | | | | | | | | ESI | CPI/BD | CMP/PN32689 | Security 50/CR Corresia Video Sps | | DIRCT/SER | 20,335 | | 20,335 | | | | | | | | ESI | CPI/BD | CMP/PN32713 | 201c Direct Outer Anal &; Replace | | DIRCT/SER | 3,034 | | 3,034 | 3,034 | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Lose and Compass | Total | All Other BDS | ETS Plan Books | Evaluations | Pro Fiammy Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | | | | | | | | | | | | | | | Service Company | | | | | | | | | | | | | | | Pension Company | Total | All Other BDS | ETS Plan Books | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BILS | ETS Plan | Evaluations | Pro Forma Amount | Total ETS Adjudice | | | | | | | | | Periphery | Periphery | | | | | | | | | | | | | | | | | | | | | | | | | ESS | CPNIBI | CMPP750155 | the Bone, Gapped, Low Bay | | | | | | | | | | | | | ESS | CPNIBI | CMPP750166 | Carbon Starch, Ind Dirt Pack | | | | | | | | | | | | | ESS | CPNIBI | CMPP750167 | Gamed, Ind Dirt Pack Lint | | | | | | | | | | | | | ESS | CPNIBI | CMPP750168 | Nontpant, Ind Dirt Pack Lint | | | | | | | | | | | | | ESS | CPNIBI | CMPP750169 | Barrier Worm, Flat dint1 Head | | | | | 213 | 213 | | | | | | | ESS | CPNIBI | CMPP750173 | Inceating 8 Aad TOC controls-R | | | | | 4,160 | 4,160 | | | | | | | ESS | CPNIBI | CMPP750185 | Inceating, Flat Day Banned-Lit | | | | | 129 | 129 | | | | | | | ESS | CPNIBI | CMPP750187 | Ray B named, Flat Volatomy Lit | | | | 865 | 865 | | | | | | | | ESS | CPNIBI | CMPP750258 | 84KSO, Flat HdU460 C1 21.5127 | | | | 195 | 195 | | | | | | | | ESS | CPNIBI | CMPP750266 | Tunica 293, Flat Hant Late Lit-R | | | | 290 | 290 | | | | | | | | ESS | CPNIBI | CMPP750267 | Hant Late, Flat Tunica Line Part | | | | 612 | 612 | | | | | | | | ESS | CPNIBI | CMPP722009 | Downward Subsistent, Gappede | | | | | | | | | | | | | ESS | CPNIBI | CMPP722016 | 2000 Ind Plant Plan Experience Ertling | | | | | | | | | | | | | ESS | CPNIBI | CMPP7220151 | Oxy Regulation Service | | | | 16 | 16 | | | | | | | | ESS | CPNIBI | CMPP722168 | South Jackson Soil RTU Gappede | | | | | | | | | | | | | ESS | CPNIBI | CMPP722169 | SCASA Mometaphoro Jackson, 333 | | | | | | | | | | | | | ESS | CPNIBI | CMPP722170 | Purchase Reminder for SCG | | | | 2,212 | 2,212 | | | | | | | | ESS | CPNIBI | CMPP722182 | E-Beau-mant PML1 Head SCG 333 | | | | 991 | | 991 | | 80 | | (801) | | | ESS | CPNIBI | CMPP722183 | South Alce PML1 Head SCG 333 | | | | 1,891 | | 1,891 | | | | | | | ESS | CPNIBI | CMPP722184 | South Alce PML1 Head SCG 333 | | | | 1,173 | | 1,173 | | | | | | | ESS | CPNIBI | CMPP722185 | Green Sea PML1 Head SCG 333 | | | | 1,043 | | 1,043 | | | | | | | ESS | CPNIBI | CMPP722186 | Nuclear Sea PML1 Head SCG 333 | | | | 801 | | 801 | | 801 | | (801) | | | ESS | CPNIBI | CMPP722187 | China Sea PML1 Head SCG 333 | | | | 801 | | 801 | | 801 | | (801) | | | ESS | CPNIBI | CMPP722188 | New Jersey PML1 Head SCG 333 | | | | 1,160 | | 1,160 | | | | | | | ESS | CPNIBI | CMPP722189 | New Jersey PML1 Head SCG 333 | | | | 1,160 | | 1,160 | | | | | | | ESS | CPNIBI | CMPP722190 | New Jersey PML1 Head SCG 333 | | | | 1,160 | | 1,160 | | | | | | | ESS | CPNIBI | CMPP722191 | China Sea PML1 Head SCG 333 | | | | 801 | | 801 | | 801 | | (801) | | | ESS | CPNIBI | CMPP722192 | China Sea PML1 Head SCG 333 | | | | 801 | | 801 | | 801 | | (801) | | | ESS | CPNIBI | CMPP722193 | New Jersey Cane Deeper (Cd) 3 | | | | 1,160 | | 1,160 | | | | | | | ESS | CPNIBI | CMPP722194 | New Jersey Cane Deeper (Cd) 3 | | | | 349 | | 349 | | | | | | | ESS | CPNIBI | CMPP722195 | Red Sea PML1 Head SCG 333 | | | | 1,167 | | 1,167 | | | | | | | ESS | CPNIBI | CMPP722196 | Red Sea PML1 Head SCG 333 | | | | 1,167 | | 1,167 | | | | | | | ESS | CPNIBI | CMPP722197 | Red Sea PML1 Head SCG 333 | | | | 1,167 | | 1,167 | | | | | | | ESS | CPNIBI | CMPP722198 | Meamate Sea PML1 Head SCG | | | | 186 | | 186 | | | | | | | ESS | CPNIBI | CMPP722197 | Ray B named PML1 Head SCG 3 | | | | 204 | | 204 | | | | | | | ESS | CPNIBI | CMPP722198 | Red Beach PML1 Head SCG 3330 | | | | 204 | | 204 | | | | | | | ESS | CPNIBI | CMPP722199 | Black Sea PML1 Head SCG 333 | | | | 167 | | 167 | | | | | | | ESS | CPNIBI | CMPP722200 | Fancy Point PML1 Head SCG 333 | | | | 167 | | 167 | | | | | | | ESS | CPNIBI | CMPP722201 | Fancy Point PML1 Head SCG 333 | | | | 167 | | 167 | | | | | | | ESS | CPNIBI | CMPP722202 | Fancy Recciner - Baron Rouge 2 | | | | | | | | | | | | | ESS | CPNIBI | CMPP722203 | Fancy Recciner - Beau-mant SCG | | | | | | | | | | | | | ESS | CPNIBI | CMPP722204 | Fancy Recciner - Beau-mant TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722205 | Fancy Recciner - Sickow TOC3 | | | | | | | | | | | | | ESS | CPNIBI | CMPP722206 | Fancy Recciner - Jackson TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722207 | Fancy Recciner - Jackson TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722208 | Fancy Recciner - Jackson TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722209 | Fancy Recciner - Jackson TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722210 | Fancy Recciner - Jackson TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722211 | Fancy Recciner - Lift TOC3330 | | | | | | | | | | | | | ESS | CPNIBI | CMPP722212 | Fancy Recciner - Westflemmel TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722213 | Fancy Recciner - Westflemmel TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722214 | Fancy Recciner - Deville's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722215 | Fancy Recciner - Deville's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722216 | Fancy Recciner - Deville's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722217 | Fancy Recciner - Deville's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722218 | Fancy Recciner - Westflemmel TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP722219 | Fancy Recciner - Capsa's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP7222204 | Lift TOC Depleted Display (PHC) | | | | | | | | | | | | | ESS | CPNIBI | CMPP7222205 | Fancy Recciner - Deville's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP7222206 | Fancy Recciner - Jackson TOC3 | | | | | | | | | | | | | ESS | CPNIBI | CMPP7222207 | Fancy Recciner - Jackson TOC | | | | | | | | | | | | | ESS | CPNIBI | CMPP7222211 | Fancy Recciner - Deville's PHC | | | | | | | | | | | | | ESS | CPNIBI | CMPP7222212 | McAdenDirt TOC, PDF KIDa LSM46047 | | | | 15,655 | 15,655 | | | | | | | | ESS | CPNIBI | CMPP7222214 | McAdenDirt TOC, PDF KIDa LSM46047 | | | | 15,655 | | | | | | | | | ESS | CPNIBI | CMPP7222215 | Schroler Sick -Mell Capacitor-Ex | | | | 15,655 | | | | | | | | | ESS | CPNIBI | CMPP7224000 | Shorette Sick PML1 Head SCG 3 | | | | 167 | 167 | | | | | | | | ESS | CPNIBI | CMPP722401 | Water Sick A 420 C 33300 | | | | 335 | 335 | | | | | | | | ESS | CPNIBI | CMPP722402 | Darington PML1 Head SCG 33 | | | | 167 | 167 | | | | | | | | ESS | CPNIBI | CMPP722403 | Wichita Yumel DUE 333 | | | | 167 | 167 | | | | | | | | ESS | CPNIBI | CMPP722404 | West Morrow Incalal New Forest | | | | 4,459 | 4,459 | | | | | | | | ESS | CPNIBI | CMPP722405 | Darington YUMel PML1 Head | | | | 82 | 82 | | | | | | | | ESS | CPNIBI | CMPP722406 | Forter Sick PML1 Head | | | | 82 | 82 | | | | | | | | ESS | CPNIBI | CMPP722407 | Forter Sick PML1 Head SCG 333 | | | | 82 | 82 | | | | | | | | ESS | CPNIBI | CMPP722408 | Jaccro Sick PML1 Head SCG 333 | | | | 82 | 82 | | | | | | | | ESS | CPNIBI | CMPP722409 | Ciervada Sick A420 T 33300 | | | | 218 | 218 | | | | | | | | ESS | CPNIBI | CMPP722410 | S420 C 33300 | | | | 218 | 218 | | | | | | | | ESS | CPNIBI | CMPP722411 | S420 C 33300 | | | | 15,655 | 15,655 | | | | | | | | ESS | CPNIBI | CMPP724250 | Schroler Sick -Mell Capacitor-Ex | | | | 15,655 | 15,655 | | | | | | | | ESS | CPNIBI | CMPP724400 | Minerva Sick -Mell Capacitor Bank | | | | 167 | 167 | | | | | | | | ESS | CPNIBI | CMPP724402 | Sermon Sick -Mell Head SCG 333 | | | | 2,320 | 2,320 | | | | | | | | ESS | CPNIBI | CMPP724502 | Capsura Transformation Caste G33 | | | | | | | | | | | | | ESS | CPNIBI | CMPP724504 | Capsura Transformation Caste G33 | | | | | | | | | | | | | ESS | CPNIBI | CMPP724505 | Capsura Transformation Caste G33 | | | | | | | | | | | | | ESS | CPNIBI | CMPP724506 | Capsura Transformation Caste G33 | | | | | | | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BLFs | ETS Plan | Evaluations | Pro Forma | | | | | | | | | | Peripent | | | | | Amount | Adjust | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | CPI | CPI/BD | CMPPT/PRSMO | Capron Transformer Cest MS | | | | | | | | | | | | | CPI/BD | CMPPT/PRSMO | Capron Transformer Strep Cest | ORRCTEAK | | | | | | | | | | | | | CPI/BD | CMPPT/PRSFA | Capron Transformer Strep Cest | ORRCTTEK | | | | | | | | | | | | | CPI/BD | CMPPT/FASTA | Capron Transformer Strep Cest | ORRCTT | | | | | | | | | | | | | CPI/BD | CMPPT/FASTA | | | | | | | | | | | | | | | CPI/BD | CMPPT/FASTB | Antis 1001-300 50 1001 assn. | ORRCTEAK | 82 | | | 82 | 82 | | | | | | | | CPI/BD | CMPPT/FASTB | Antis 1001-300 50 1001 assn. | ORRCTEAK | 83 | | | 83 | 82 | | | | | | | | CPI/BD | CMPPT/FASTB | | | | | | | | | | | | | | | CPI/BD | CMPPT/FASTB | L R Chron. Nept Federal 979 | ORRCTEAK | 846 | | | 846 | 846 | | | | | | | | CPI/BD | CMPPT/FASTB | | | | | | | | | | | | | | | CPI/BD | CMPPT/FAST17 | 1003 Np latest carrier 8 son | ORRCTEAK | 419 | | | 419 | 419 | | | | | | | | CPI/BD | CMPPT/FAST17 | 1003 Np latest carrier 8 son | ORRCTEAK | 44 | | | 44 | 44 | | | | | | | | CPI/BD | CMPPT/FAST23 | 35amh. Inosit Animal Milg. | ORRCTEAK | 51 | | | 51 | 51 | | | | | | | | CPI/BD | CMPPT/FA143 | 55amh. Fibr. Pap 82000-10.0 | ORRCTEAK | 230 | | | 230 | 230 | | | | | | | | CPI/BD | CMPPT/FA146 | Antistromy. 300 carrier31-94 | ORRCTEAK | 88 | | | 88 | 88 | | | | | | | | CPI/BD | CMPPT/FA147 | Copperon Oant. 300. 5e delay | ORRCTEAK | 94 | | | 94 | 94 | | | | | | | | CPI/BD | CMPPT/FA150 | Antip 50. Relay improvents 4nd | ORRCTEAK | 916 | | | 916 | 916 | | | | | | | | CPI/BD | CMPPT/FA162 | Syncer Hike. Pap 82000-10.0 | ORRCTEAK | 1,371 | | | 1,371 | 1,371 | | | | | | | | CPI/BD | CMPPT/FA163 | Syncer Hike. Pap 82000-10.0 | ORRCTEAK | 1,538 | | | 1,538 | 1,538 | | | | | | | | CPI/BD | CMPPT/FA170 | 55amh. Fibr. Pap 82000-10.0 | ORRCTEAK | 6 | | | 6 | 6 | | | | | | | | CPI/BD | CMPPT/FA171 | 55amh. Fibr. App 2400-94 80019.8 | ORRCTEAK | 9 | | | 9 | 9 | | | | | | | | CPI/BD | CMPPT/FA173 | 55amh. Med 2400-94 8019.8 | ORRCTEAK | 9 | | | 9 | 9 | | | | | | | | CPI/BD | CMPPT/FA175 | 55amh. Med 2400-94 8020.8 | ORRCTEAK | 1,502 | | | 1,502 | 1,502 | | | | | | | | CPI/BD | CMPPT/FA180 | 75mhzw. 75 school 54600 1dq | ORRCTEAK | 572 | | | 572 | 572 | | | | | | | | CPI/BD | CMPPT/FA190 | 75mhzw. 75 school 54600 1dq | ORRCTEAK | 1,129 | | | 1,129 | 1,129 | | | | | | | | CPI/BD | CMPPT/FA191 | 75mhzw. 75 school 54600 1dq | ORRCTEAK | 788 | | | 788 | 788 | | | | | | | | CPI/BD | CMPPT/FA206 | 78i terminal. Nept I46000 1dq | ORRCTEAK | 68 | | | 68 | 68 | | | | | | | | CPI/BD | CMPPT/FA211 | 78i terminal. 6th. Pap 7500 1d | ORRCTEAK | 9 | | | 9 | 9 | | | | | | | | CPI/BD | CMPPT/FA217 | 78i terminal. 6th. 7th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6th. 6

| Class | Billing End(s) | Dept | Activity / Project
Code | Activity / Project Description | ESS Billing Method | Support | Level | Total | All Other Bli/s | ETS Plan Books | Exclusions | Pro Fishing Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | | | | | | | | | | | | | | | Peripier | | | | | | | | | | | CAPPTL3563 | Live 501 (Ligasek Live | | DIRECTT | | | | | | | | | | | CAPBEL3591 | Live 591 (Ligasek Live | | DIRECTT | 156 | | | 156 | | 156 | | | | | | CAPBEL7133 | 3551 NK-Mag Mark 115 to 2064 | DIRECTEL | | | | | | | | | | | | | CAPBEL7160 | Preo OH Oxal. West Loa at Good | DIRECTEL | 2.238 | | | 2,238 | | 2,238 | | | | | | | CAPBEL7175 | Sermagion 4102 115 (Ligasek | DIRECTEL | 4.117 | | | 4,117 | 4,117 | 4,117 | | | | | | | CAPBEL7176 | 3102 Bauma 115 (Ligasek Live | DIRECTEL | 4.942 | | | 4,942 | 4,942 | | | | | | | | CAPBEL7177 | Sermag-Log Cater 115 (Ligay L) | DIRECTEL | 3.460 | | | 3,460 | 3,460 | | | | | | | | CAPBEL7178 | WalrudSowe Seeds 115 (Ligay L) | DIRECTEL | 5.658 | | | 5,658 | 5,658 | | | | | | | | CAPBEL7179 | Froshed-48Le 115 (Ligay L) | DIRECTEL | 602 | | | 602 | 602 | | | | | | | | CAPBEL7181 | Sermagion Auto 82 To L+ Up | DIRECTEL | 2.019 | | | 2,019 | 2,019 | | | | | | | | CAPBEL7184 | Canoville Doth 115 (Nasa A12) | DIRECTEL | 107 | | | 107 | 107 | | | | | | | | CAPBEL7191 | Stc Groe. Need Loa at Earning | DIRECTEL | 1.210 | | | 1,210 | 1,210 | | | | | | | | CAPBEL7192 | Stc San Toh. Remote Loa | DIRECTEL | 1.306 | | | 1,306 | 1,306 | | | | | | | | CAPBEL7198 | Bacteri Wilson. Auto 82 To Ln | DIRECTE&K | 750 | | | 750 | 750 | | | | | | | | CAPBEL7202 | Feinfeiler Toccum. Build New Lo | DIRECTEL | 7.820 | | | 7,820 | 7,820 | | | | | | | | CAPBEL7244 | Watertont Toccum 20641 Madi | DIRECTEL | 423 | | | 423 | 423 | | | | | | | | CAPBEL7209 | Toccum Mede Poon. Remote | DIRECTEL | 188 | | | 188 | 188 | | | | | | | | CAPBEL7211 | L-Supra Baura 301 KmRder Col | DIRECTEL | 242 | | | 242 | 242 | | | | | | | | CAPBEL7206 | Ac7511 (Champagne-2u4 Kroto 9) | DIRECTTLS | 301 | | | 301 | 301 | | | | | | | | CAPBEL7207 | Ac7511 (Champagne-2u4 Kroto 9) | DIRECTTLS | 70 | | | 70 | 70 | | | | | | | | CAPBEL7208 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7209 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7210 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7211 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7220 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7221 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7222 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7223 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7224 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7225 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7226 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7227 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7228 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7229 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7230 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7231 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7232 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7233 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7234 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7235 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7236 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7237 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7238 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7239 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7240 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7241 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7242 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7243 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7244 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7245 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7246 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7247 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7248 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7249 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7250 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7251 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7252 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7253 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7254 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7255 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7256 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7257 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7258 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7259 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7260 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7261 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7262 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7263 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7264 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7265 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7266 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7267 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7268 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7269 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7270 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7271 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7272 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7273 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7274 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7275 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7276 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7277 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7278 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7279 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7280 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7281 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7282 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7283 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7284 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7285 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7286 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7287 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7288 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7289 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7290 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7291 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7292 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7293 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7294 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7295 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7296 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7297 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7298 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7299 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7200 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7210 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7211 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7212 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7213 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7214 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7215 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | CAPBEL7216 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7217 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7218 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | CAPBEL7220 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL72219 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7222223 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7223 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | CAPBEL7224 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL724 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL725 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL725 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL726 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL726 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL727 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | CAPBEL728 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL729 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL730 | | DIRECTEL | 70 | | | 70 | 70 | | | | | | | | CAPBEL7310 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL7311 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | CAPBEL7312 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL732 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL733 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | CAPBEL734 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL735 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL736 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | CAPBEL737 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL738 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL739 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | CAPBEL740 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL741 | | DIRECTEL | 70 | | 70 | 70 | | | | | | | | | CAPBEL742 | | DIRECTEL | 70 | 70 | 70 | 70 | | | | | | | | CAPBEL743 | | DIRECTEL | 70 | | 70 | 70 | 70 | | | | | | | | CAPBEL7444 | | DIRECTEL | 70 | | 70 | 70 | 70 | | | | | | | CAPBEL7450 | | DIRECTEL | 70 | | 70 | 70 | 70 | | | | | | | CAPBEL7451 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | | | | | | CAPBEL7452 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | | | | | | CAPBEL7453 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | | CAPBEL7460 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | | CAPBEL747 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | | CAPBEL7480 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | | CAPBEL750 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | | CAPBEL7510 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL7520 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL7530 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL7540 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL75550 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL7560 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL75610 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL75620 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL75630 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL75640 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | CAPBEL75650 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL75660 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL7670 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL7670 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL70 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL70 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL70 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL70 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL70 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | | CAPBEL70 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | CAPBEL710 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | CAPBEL710 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | CAPBEL710 | | DIRECTEL | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | 70 | | | CAPBEL720 | | DIRECTEL | 70 | 70 | 70 | 70 |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing Support | Support | Total | All Other Bli/s | ETS Plan Books | Evolutions | Pro Fiamme Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | | 618 | 618 | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/P881 | Insect D5 Structure - AAC 55 | | DIRECTL/3 | 618 | | 618 | 618 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/P883 | Starch - первые ярои - Кюаньн | | DIRECTL/3 | 97 | | 97 | 97 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/P887 | Repapore/Unknown - OP Link+ | | DIRECTL/3 | 866 | | 866 | 866 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/P888 | Port-tail'aing-Pt-25K - OP ratio | | DIRECTL/3 | 511 | | 511 | 511 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/P889 | Ectpo/Taing-Pt-25K - OP mix+ | | DIRECTL/3 | 316 | | 316 | 316 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2899 | Pin-ti to Cen Gen - Uppati to 37 | | DIRECTE/4 | 323 | | 323 | 323 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9001 | Seeds to Cen Phage - Some New | | DIRECTE/4 | 5,780 | | 5,780 | 10,780 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/RPH1 | Repapore/Port-ti-OP Link Release | | DIRECTL/3 | 5,435 | | 5,435 | 3,426 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2899 | Amochoaon Bipolar -Cui-to-Ye Mix | | DIRECTE/6 | 15 | | 15 | 15 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T834 | Telonexal Cnatic Insect Bud4 | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T835 | Telonexal Cnatic Insect Com6oc | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T836 | Hachong-Heliog Bud4 LYM Cui | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T838 | Hachong New Sur - Com6oc CCN-5 | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T839 | China Anxious Com6oc CCN-3hcep | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T810 | Telonexal Cbok Insect Bbk New | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T811 | Hachong New Sur - Bbk New 250 | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/T812 | China Anxious Bud4 New 250st t. | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2001 | Aula 600 T.3. Low Cui-ti | | DIRECTE/6 | 1,117 | | 1,117 | 1,117 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2004 | L3h Aidi Sin -nobelle Nectar25 | | DIRECTT/5 | 41 | | 41 | | | 41 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2006 | L3h Aidisin/New A 200stk | | DIRECTT/5 | 50 | | 50 | | 50 | | 50 | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2111 | L48k Anadi New 200C07 Ta-Li | | DIRECTT/5 | 288 | | 288 | | | 288 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2888 | Prometheus Mendaong Deesse | | DIRECTE/6 | 1,205 | | 1,205 | 1,205 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2889 | Hengelo anondosn T-Line Ueqim | | DIRECTE/6 | 3,543 | | 3,543 | 3,543 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/8699 | Devel T-Line Relaxation | | DIRECTE/6 | 3,997 | | 3,997 | 3,997 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9001 | Uppati to 10st | | DIRECTT/5 | 10,562 | | 10,562 | | | 10,562 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9002 | Bud4/sin-ti-otodcintis-L-58T | | DIRECTT/5 | 885 | | 885 | | 885 | | 885 | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9003 | Bud4/sappoo-cerey-inte6-sab | | DIRECTT/5 | 6,179 | | 6,179 | | | 6,179 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9004 | T-Linkl Tt2 16L0/AS1N6A A6Q-565# | | DIRECTT/5 | 5,751 | | 5,751 | | | 5,751 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9005 | Up Ratic L460 Gallee Ectodee | | DIRECTT/5 | 670 | | 670 | | | 670 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9101 | Mchidono-Potwino Lo Uppi Ln-3 | | DIRECTE/6 | 4,917 | | 4,917 | | 4,917 | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/9102 | unknown Mchidoni New to new-tw | | DIRECTE/6 | 1,202 | | 1,202 | 1,202 | | 1,202 | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/1001 | Mectateo Tepo -Resortoceler 12 | | DIRECTL/3 | 9,579 | | 9,579 | 9,579 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/1002 | Jannas to Tepo -Resortoceler | | DIRECTL/3 | 441 | | 441 | 441 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2001 | Eeemigon -Retsuole-Gen 67c | | DIRECTE/ | 764 | | 764 | 764 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2002 | Hachong-Micaese - Uppati to 1 | | DIRECTT/5 | 18,073 | | 18,073 | | 18,073 | (18,073) | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2005 | Alchem-Monod 2811 -Uppati to 275 | | DIRECTL/3 | 7,249 | | 7,249 | 7,249 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTL/2006 | Men June Plant -Uppati to 170# | | DIRECTE/6 | 3,043 | | 3,043 | 3,043 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1402 | Hokore/Botom Land-Portidee 5 | | DIRECTE/6 | 2,976 | | 2,976 | 2,976 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1403 | Blue Water Sur -Insect 1149/A | | DIRECTT/5 | (10,917) | | (10,917) | | 10,917 | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1408 | Hokore/Botom 600-VI-VV-3Lab | | DIRECTE/4 | 26,154 | | 26,154 | | 26,154 | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1470 | Resorapant Uppatei T1A-2980A | | DIRECTL/3 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1539 | Galenda -Insect 23901 Breake | | DIRECTE/ | 1,730 | | 1,730 | 1,730 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1540 | A-lance -Insect 23011901-Ao | | DIRECTE/ | 10,934 | | 10,934 | 10,934 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS1577R - Star Substrator | | | DIRECTE/ | 486 | | 486 | 486 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2099 | Usta avil-madly - rose 2064-1 | | DIRECTL/3 | 5,474 | | 5,474 | 5,474 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2099 | BIOACU -bulb new 20641 autotis | | DIRECTE/ | 7 | | | 7 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2095 | Laburn -Insect Supercentorim | | DIRECTE/ | 4,828 | | 4,828 | (4,828) | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2096 | Nescens Insect Supercentorim | | DIRECTE/ | (1,927) | | (1,927) | (1,927) | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2097 | Prano Road -Insect 23001 Bte | | DIRECTE/ | 1,105 | | 1,105 | 1,105 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2192 | Peach Creek Substrator Convent | | DIRECTT/5 | 513 | | 513 | | 513 | | 513 | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2193 | Coney Creek Substrator Convent | | DIRECTT/5 | 6 | | 6 | | 6 | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS2194 | Loew Creek -Insect -Translorm | | DIRECTT/5 | 6,182 | | 6,182 | | 6,182 | (6,182) | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS4731 | ETEC Cypress Bulk Terase -Wete | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS4772 | ETEC Cypress BulkTerase | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS4836 | Nose No Sun 9990/R 4022 Ovenip | | DIRECTT/5 | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS5552 | Lyum -Uppati to Line Ratu-Pane | | DIRECTE/6 | 137 | | 137 | | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS5553 | NLP Chino-uppati to Line Ratu-P | | DIRECTE/6 | 458 | | 458 | 458 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS5980 | Pashanham Convent to 20040 Rio | | DIRECTE/ | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS6754 | 2001 Maggantor - Filos For New Bie | | DIRECTE/ | 134 | | 134 | 134 | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS6824 | Stable Fin -20001 A60-64-6 640A | | DIRECTE/ | - | | - | - | | | | | | nubens NEG/cirUS5 | ESI | CPNIB | CBPPTS6838 | 2000 Amer Cyanarent -Trap 8 Box | | DIRECTE/ | - | | - | - | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing Support | Support | Total | All Other Bli/s | ETS Plan Books | Evaluations | Pro Fiamme Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | Service Company | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | All | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Willing Ending | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billings | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | | | | | | | | | | | | | | | Pervise Company | Total | All Other Bs/ss | ETS Plan | | | | | | | | | | | | Pervised | | | | | | | | | | | | | | | Pervised | | | | | | | | | | | | | | | Pervised | | | | | | | | | | | | | | | | 140 | 140 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 212 | 212 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 35 | 35 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 277 | 277 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 19 | 19 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Service Company | Total | All Other BDS | ETS Plan Books | Evaluations | Pro Fiamme Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA814 | J. R. South. Wall Tractite Tile | | | 946 | | 946 | 946 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA815 | Stamp. Rgr16 10m1/sucane in | | | 58 | | 58 | 58 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA841 | J. R. Leerwood. Inlet21/carl Lco | | | 19 | | 19 | 19 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA850 | Scanty Price Upposite Retay for | | | 2,396 | | 2,396 | 2,396 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA851 | Janusovode K Upposite Retay in | | | 3,302 | | 3,302 | 3,302 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA852 | NCCl Upposite Retay for Incident | | | 2,602 | | 2,602 | 2,602 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA853 | Independenter Upposite Retay H8 | | | 3,162 | | 3,162 | 3,162 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA858 | Syncer Hite. Repetex 110013D | | | 1,189 | | 1,189 | 1,189 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA857 | J. R South. Upp Siuo 6 Sire2 in | | | 231 | | 231 | 231 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA876 | Phi Euc. Rgr16 50C/2029 w Cp | | | 276 | | 276 | 276 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA877 | Devade Bolf. Rgr Fst Repede | | | 48 | | 48 | 48 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA886 | J. R. Ede 6 Spring. Near Fadent | | | 183 | | 183 | 183 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA889 | Lurch. Retay Inter on Jastesom | | | 4,866 | | 4,866 | 4,866 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA893 | Newport 10 No. Report ground gr | | | 1,033 | | 1,033 | 1,033 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA900 | Mt lee. syn Sepol 7RW 020 RT | | | 133 | | 133 | 133 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA912 | Orient. Rgr Fst Capo 6 19m1 Ck | | | 148 | | 148 | 148 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA914 | Reston to 10 No. Rep V28 | | | 51 | | 51 | 51 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA916 | N.J. Press Clop syn teel-cud | | | 835 | | 835 | 835 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA927 | Overfost Rep Strain away J868 | | | 1,304 | | 1,304 | 1,304 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA928 | Mont D. Near Seep RTU in 020 | | | 48 | | 48 | 48 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA942 | 4842 N.J. Upposite RTU in 020 | | | 1,667 | | 1,667 | 1,667 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA950 | Hughes. Rgr Seep K400 040 Q9Q | | | 183 | | 183 | 183 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA951 | Am Stat. Tucke. Hlac Mew 06 | | | 279 | | 279 | 279 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA953 | In it. Eme. calc. (C) 6C/2275-4 | | | 442 | | 442 | 442 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA964 | Stoney. seo. E 6c/14 6 blimp | | | 46 | | 46 | 46 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA987 | Hughes 101 Rep. God See Ac C6 | | | 115 | | 115 | 115 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA989 | Hadund Botism 600101 Project | | | 69 | | 69 | 69 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA992 | 946 Eme. Upp 009/4 88814 A 1w | | | 2,871 | | 2,871 | 2,871 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA993 | Ecotone. Rgr16 19m1 cals eet on | | | 166 | | 166 | 166 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA999 | Wavera Euee head-1 040/40 Cap | | | 242 | | 242 | 242 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA903 | L40209 Steritogon chiari, mid | | | 4,038 | | 4,038 | 4,038 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA9022 | Steritogon 110e1 003, Rgr. 9a | | | 3,099 | | 3,099 | 3,099 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA9023 | Borthotmesn. Insect Mews Flor | | | 2,708 | | 2,708 | 2,708 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSA921 | Army 03. Upposite Seesm 80017 | | | 194 | | 194 | 194 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSB002 | Harmit Sux Work locations | | | 194 | | 194 | 194 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSB003 | Syncer Hite. Upposite Retay | | | 297 | | 297 | 297 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSB005 | Summer Upposite Retay | | | 48 | | 48 | 48 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSB006 | Conway West Upposite Retay | | | 52 | | 52 | 52 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSB007 | Harrison Eoel Upposite Retay | | | 641 | | 641 | 641 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSC001 | Mexico. Motilly Communication | | | 35 | | 35 | 35 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSC002 | Lamelle 119/0. Rasex Equipment | | | 413 | | 413 | 413 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF087 | Sevcales add 0P2 71 72 15 | | | 546 | | 546 | 546 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF148 | W.love Glenc Upposite J 7d Retay | | | 374 | | 374 | 374 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF150 | St Gament Upposite 8010 Lme | | | 50 | | 50 | 50 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF210 | Omi Substanton RTU replacement | | | 293 | | 293 | 293 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF211 | Champagne RTU replacement | | | 293 | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF212 | Mosuelle replace Bus 4 of fr. | | | 3,229 | | 3,229 | 3,229 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF213 | Mosuelle rep’d 8-Fri Capacitor | | | 828 | | 828 | 828 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF214 | Mosuelle replace L800 relay a | | | 405 | | 405 | 405 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF215 | Mosuelle replace CC6 18001 | | | 74 | | 74 | 74 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF220 | Corpus Upposite Line Ramping | | | 863 | | 863 | 863 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF226 | Tiger replace bivalver 14201 | | | 1,233 | | 1,233 | 1,233 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF236 | Thomas replace capacitor teeth | | | 1,795 | | 1,795 | 1,795 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF237 | W.bert replace capacitor teeth | | | 2,408 | | 2,408 | 2,408 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF247 | Cunty Sick nap beckle bivalver | | | | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF248 | Sciex Sick replace CC6 17410 | | | 863 | | 863 | 863 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF249 | Sciex Sick replace CC6 18380 | | | 863 | | 863 | 863 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF254 | Aedes L001 replace Weld peen | | | | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF255 | W.bert failed relay geind | | | | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF256 | W.bert replace RTU | | | | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF257 | Weiner natal 020 | | | 3,200 | | 3,200 | 3,200 | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF258 | Evoon 71d 71i 98ring Addition | | | | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF259 | Akaela 2807 replace OTU | | | | | | | | | | | student NCSCURCES | ESD | CPRBD | CMPPTSF260 | Pecan replace 0P10 bivalver 414F | | | 45 | | 45 | 45 | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other Billing | ETS Plan | | | | | | | | | | | | | | | Books | | | | | | | | | | | | | | | Pro. Panna | | | | | | | Activity / Project Description | | Support | | | | Amount | Total ETS | | | | | | | | | | Service Company | | | | | | | | | | | | | | | | | | Adjusted | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Ending | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other Billing | ETS Plan Books | Evaluations | Pro Forma Amount | Total ETS Adjudice | | | | | | | | | | Periphery | | | | | | | | | | | | | | | | | | | | | | | | | | | CPI/BD | CMP/TSF535 | Open add man to live sentitre | | DIRECTLUS | 92 | | 92 | | | | | | | | ESI | CPI/BD | CMP/TSF536 | Northside add man to live sent | | DIRECTLUS | 74 | | 74 | 74 | | | | | | | ESI | CPI/BD | CMP/TSF537 | severely second add man to live | | DIRECTLUS | 12 | | 12 | 12 | | | | | | | ESI | CPI/BD | CMP/TSF538 | 3 tender add MC6's to live aer | | DIRECTLUS | 69 | | 69 | 69 | | | | | | | ESI | CPI/BD | CMP/TSF570 | Wrist replace to test foradom | | DIRECTLUS | 1,133 | | 1,133 | 1,123 | | | | | | | ESI | CPI/BD | CMP/TSF575 | Ecuelle replace disobligation 1 | | DIRECTLUS | 410 | | 410 | 410 | | | | | | | ESI | CPI/BD | CMP/TSF580 | East replace breaker 995 | | DIRECTLUS | 550 | | 550 | 550 | | | | | | | ESI | CPI/BD | CMP/TSF581 | Spouttman replace breaker 596 | | DIRECTLUS | 502 | | 502 | 502 | | | | | | | ESI | CPI/BD | CMP/TSF582 | post replace breaker 534 | | DIRECTLUS | 280 | | 280 | 280 | | | | | | | ESI | CPI/BD | CMP/TSF583 | Hural replace breaker 346 | | DIRECTLUS | 8 | | 8 | 8 | | | | | | | ESI | CPI/BD | CMP/TSF584 | Hural replace breaker 347 | | DIRECTLUS | 8 | | 8 | 8 | | | | | | | ESI | CPI/BD | CMP/TSF587 | Thomas replace lided 592 3941 | | DIRECTLUS | 1,444 | | 1,444 | 1,444 | | | | | | | ESI | CPI/BD | CMP/TSF588 | Highland replace disc end-type | | DIRECTLUS | 457 | | 457 | 457 | | | | | | | ESI | CPI/BD | CMP/TSF606 | Shenevalent replace P7/2 | | DIRECTLUS | 253 | | 253 | 253 | | | | | | | ESI | CPI/BD | CMP/TSF608 | Lnoma T1 replace ST-relaps | | DIRECTLUS | 33 | | 33 | 33 | | | | | | | ESI | CPI/BD | CMP/TSF619 | Slama T1a T2 SP seer | | DIRECTLUS | 258 | | 258 | 258 | | | | | | | ESI | CPI/BD | CMP/TSF700 | Common T4/7 Fender Four LV6 | | DIRECTLUS | 41 | | 41 | 41 | | | | | | | ESI | CPI/BD | CMP/TSF701 | Respir 60 Rall 7 header ravit to | | DIRECTLUS | 53 | | 53 | 53 | | | | | | | ESI | CPI/BD | CMP/TSF702 | Auralis slant healer ravit toat | | DIRECTLUS | 508 | | 508 | 508 | | | | | | | ESI | CPI/BD | CMP/TSF704 | Mesas 8607 header ravit tocat | | DIRECTLUS | 87 | | 87 | 87 | | | | | | | ESI | CPI/BD | CMP/TSF705 | Lnoma 9965 header ravit toat | | DIRECTLUS | 103 | | 103 | 103 | | | | | | | ESI | CPI/BD | CMP/TSF708 | Sunt 90/9 WWT ravit toadom | | DIRECTLUS | 41 | | 41 | 41 | | | | | | | ESI | CPI/BD | CMP/TSF707 | Chroma7/17 header ravit toat | | DIRECTLUS | 128 | | 128 | 128 | | | | | | | ESI | CPI/BD | CMP/TSF708 | Lake 1197 header ravit toadom | | DIRECTLUS | 53 | | 53 | 53 | | | | | | | ESI | CPI/BD | CMP/TSF714 | Mesorille Box 3 Othmand | | DIRECTLUS | 99 | | 99 | 99 | | | | | | | ESI | CPI/BD | CMP/TSF735 | Trovadas lided 5108 4617 | | DIRECTLUS | 91 | | 91 | 91 | | | | | | | ESI | CPI/BD | CMP/TSF803 | Faryonumio root 56/2 Alibyrro | | DIRECTLUS | 103 | | 103 | 103 | | | | | | | ESI | CPI/BD | CMP/TSF807 | Hural replace lense with Faryo | | DIRECTLUS | 291 | | 291 | 291 | | | | | | | ESI | CPI/BD | CMP/TSF811 | Tiger replace lided laden 4 | | DIRECTLUS | 2 | | 2 | 2 | | | | | | | ESI | CPI/BD | CMP/TSF813 | Weiner replace lided ladenu | | DIRECTLUS | 14 | | 14 | 14 | | | | | | | ESI | CPI/BD | CMP/TSF815 | Shrap replace lided ladenu a | | DIRECTLUS | 15 | | 15 | 15 | | | | | | | ESI | CPI/BD | CMP/TSF816 | Northside repl ladenhead/ring | | DIRECTLUS | 14 | | 14 | 14 | | | | | | | ESI | CPI/BD | CMP/TSF817 | Greenero rigrigo repl lardabil | | DIRECTLUS | 15 | | 15 | 15 | | | | | | | ESI | CPI/BD | CMP/TSF849 | Faryonumio rep laded seer | | DIRECTLUS | 6 | | 6 | 6 | | | | | | | ESI | CPI/BD | CMP/TSG002 | Arrive Sur. 20041 DEMCO PC6 | | DIRECTLUS | | | | | | | | | | | ESI | CPI/BD | CMP/TSG003 | Thompson Creek model Com. 6a | | DIRECTLUS | 1,147 | | 1,147 | 1,147 | | | | | | | ESI | CPI/BD | CMP/TSG102 | Mesas. model 400404 AusolTM4 | | DIRECTLUS | 16,625 | | 16,625 | 16,625 | | | | | | | ESI | CPI/BD | CMP/TSG103 | Mer. Sub. model 1864 Termi | | DIRECTLUS | 594 | | 594 | 594 | | | | | | | ESI | CPI/BD | CMP/TSG104 | Richard Sub. hires 10061 PC6 | | DIRECTLUS | 5,562 | | 5,562 | 5,562 | | | | | | | ESI | CPI/BD | CMP/TSG105 | Mesas Subsidiaro Esqueram Pro | | DIRECTLUS | 6 | | 6 | 6 | | | | | | | ESI | CPI/BD | CMP/TSG202 | Arrive Sur. 20041 DEMCO PC6 | | DIRECTLUS | | | | | | | | | | | ESI | CPI/BD | CMP/TSG203 | Thompson Creek model Com. 6a | | DIRECTLUS | 1,147 | | 1,147 | 1,147 | | | | | | | ESI | CPI/BD | CMP/TSG102 | Mesas. model 400404 AusolTM4 | | DIRECTLUS | 16,625 | | 16,625 | 16,625 | | | | | | | ESI | CPI/BD | CMP/TSG103 | Mer. Sub. model 1864 Termi | | DIRECTLUS | 594 | | 594 | 594 | | | | | | | ESI | CPI/BD | CMP/TSG104 | Richard Sub. hires 10061 PC6 | | DIRECTLUS | 5,562 | | 5,562 | 5,562 | | | | | | | ESI | CPI/BD | CMP/TSG105 | Mesas Subsidiaro Esqueram Pro | | DIRECTLUS | 6 | | 6 | 6 | | | | | | | ESI | CPI/BD | CMP/TSG202 | Wells. model 60641 Tammac | | DIRECTLUS | 4,470 | | 4,470 | 4,470 | | | | | | | ESI | CPI/BD | CMP/TSG203 | Mer. Sub. Uggrade 8841 84-a | | DIRECTLUS | 339 | | 339 | 339 | | | | | | | ESI | CPI/BD | CMP/TSG204 | Sunt Sub. Uggrade 8841 Breathe | | DIRECTLUS | 4,469 | | 4,469 | 4,469 | | | | | | | ESI | CPI/BD | CMP/TSG200 | 3 ter. Uggrade Cap 8a Mlagn | | DIRECTLUS | | | | | | | | | | | ESI | CPI/BD | CMP/TSG301 | Thomas. Kline Ugrade for Slugge | | DIRECTLUS | | | | | | | | | | | ESI | CPI/BD | CMP/TSG302 | Arrive Glen Ugrade Relya | | DIRECTLUS | 77 | | 77 | 77 | | | | | | | ESI | CPI/BD | CMP/TSG303 | Heintann Ugrade Relya 964h | | DIRECTLUS | 78 | | 78 | 78 | | | | | | | ESI | CPI/BD | CMP/TSG204 | Saanen Creek Ugrade Fleur | | DIRECTLUS | 82 | | 82 | 82 | | | | | | | ESI | CPI/BD | CMP/TSG305 | Carter Ugradea Cap Bank | | DIRECTLUS | 1,381 | | 1,381 | 1,381 | | | | | | | ESI | CPI/BD | CMP/TSH001 | Carter BraithMan 19613 845 5v | | DIRECTLUS | 817 | | 817 | 817 | | | | | | | ESI | CPI/BD | CMP/TSHOPA | Capinin Transformer Stray Coat | | DIRECTEAI | 323 | | 323 | 323 | | | | | | | ESI | CPI/BD | CMP/TSHOPG | Capinin Transformer Coats Lt5 | | DIRECTLUS | 323 | | 323 | 323 | | | | | | | ESI | CPI/BD | CMP/TSHOPL | Capinin Transformer Coats Lt5 | | DIRECTELI | 323 | | 323 | 323 | | | | | | | ESI | CPI/BD | CMP/TSHOPN | Capinin Transformer Coat 99i | | DIRECTEMI | 323 | | 323 | 323 | | | | | | | ESI | CPI/BD | CMP/TSHOPN | Capinin Transformer Stray Coat | | DIRECTENO | 323 | | 323 | 323 | | | | | | | ESI | CPI/BD | CMP/TSHOPT | Capinin Transformer Stray Coat | | DIRECTTTA | 303 | | 303 | | | | | | | | ESI | CPI/BD | CMP/TSL601 | Lake Chama Bum. model 4P | | DIRECTLUS | | | | | | | | | | | ESI | CPI/BD | CMP/TSL603 | Bernecker. Burst 106 341 5v6 | | DIRECTTTA | 118 | | 118 | | 118 | | | | | | ESI | CPI/BD | CMP/TSL604 | Hariburg Decomestremove Act | | DIRECTTTA | 202 | | 202 | | 202 | | | | | | ESI | CPI/BD | CMP/TSL605 | Potency 20041 Sux Plenison line | | DIRECTEMI | 1,201 | | 1,201 | 1,201 | | | | | | | ESI | CPI/BD | CMP/TSN057 | Lurley. model 22 460/491 Cap 8a | | DIRECTELI | | | | | | | | | | | ESI | CPI/BD | CMP/TSN058 | Hanna. model 32 460/491 Cap 8 | | DIRECTELI | | | | | | | | | | | ESI | CPI/BD | CMP/TSH102 | Sural Hype. Rakuing Vasein | | DIRECTELI | 10,521 | | 10,521 | | | | | | | | ESI | CPI/BD | CMP/TSN103 | Prosper. Med 041-Lire Relaying | | DIRECTELI | 3,739 | | 3,739 | 3,739 | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Newize Company | Total | All Other BkUs | ETS Plan Books | Evolutions | Pro Fiammy Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | | | | | | | | | | | | | | | | Service Company | | | | | | | | | | CPIBID | CBPPT06107 | Sterngen 115. Bus SpA18ag | | 31,817 | 31,817 | 31,817 | 31,817 | | | | | | | ESI | CPIBID | CBPPT06108 | Sterngen 600. Repieus Auto | | 2,848 | 2,848 | 2,848 | | | | | | | | ESI | CPIBID | CBPPT06109 | Seampi 115. MerVerfway Usp | | 13,269 | 13,269 | 13,269 | 13,269 | | | | | | | ESI | CPIBID | CBPPT06110 | Walnut Grove 115. Marily Flex | | 51 | 51 | | | | | | | | | ESI | CPIBID | CBPPT06111 | River 11641. Well Cap Save | | 1,212 | 1,212 | 1,212 | 1,212 | | | | | | | ESI | CPIBID | CBPPT06112 | Swartz 115. Str Lv Relay &; Ste | | 2,213 | 2,213 | 2,213 | 2,213 | | | | | | | ESI | CPIBID | CBPPT06113 | R1e 115. Rep Geest 01496 | | 27 | 27 | | | | | | | | | ESI | CPIBID | CBPPT06117 | Oak Grove 115. Beetow Lv 794k | | 145 | 6,145 | 6,145 | | | | | | | | ESI | CPIBID | CBPPT06131 | Teth 115. Instat Reasons | | 657 | 657 | 657 | 657 | | | | | | | ESI | CPIBID | CBPPT06143 | Frockurt. Upg Ster Lv Flexul | | 6,775 | 2,775 | 2,775 | | | | | | | | ESI | CPIBID | CBPPT06152 | "Jalvair 115. Upp 990 Line Rel | | 240 | 240 | 240 | | | | | | | | ESI | CPIBID | CBPPT06164 | Iver Viter 230. Bush New Stales | | 12,427 | 12,427 | 12,427 | 12,427 | | | | | | | ESI | CPIBID | CBPPT06172 | Repieus 800.Expeet Station | | | | | | | | | | | | ESI | CPIBID | CBPPT06183 | Bogue Chitry - Bush 500 watt | | 282 | 282 | | | | | | | | | ESI | CPIBID | CBPPT06194 | Serrowe Bush new 230 subval | | 2,938 | 2,938 | 2,938 | 2,938 | | | | | | | ESI | CPIBID | CBPPT06192 | N2RTH BACFROP 660,0402R | | 53 | 53 | | | | | | | | | ESI | CPIBID | CBPPT06195 | UNIVUUR KIGG 971 Lv 6500000 | | 53 | 53 | | | | | | | | | ESI | CPIBID | CBPPT06197 | INVERTOR ATC Lv 6500000 | | | | | | | | | | | | ESI | CPIBID | CBPPT06198 | UNIVUUR KIGG Lv 6500000 | | | | | | | | | | | | ESI | CPIBID | CBPPT06199 | Reapace Repieus Ber 9200E | | | | | | | | | | | | ESI | CPIBID | CBPPT06200 | Swartz 115. Bus SpA18ag | | 86 | 86 | | | | | | | | | ESI | CPIBID | CBPPT06205 | Iver 66,004,L/LV 7940000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06212 | Lk8600 Lk86000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06213 | Swartz 2 Lk 86000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06214 | BL400 000000 Lk 86000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06215 | USLv9 Reads 860,0400R | | | | | | | | | | | | ESI | CPIBID | CBPPT06216 | AL10 00100 Lk 86000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06218 | H200202000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06219 | N20020200000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06220 | Wr8000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06221 | Lk8600 Lk8600000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06222 | Lk8600 Lk8600000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06224 | BL400 000000 Lk 8600000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06225 | USLv9 Reads 860,0400R | | | | | | | | | | | | ESI | CPIBID | CBPPT06226 | AL10 00100 Lk 8600000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06229 | H20020200000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06231 | 0000000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06232 | B400000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06233 | B40000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06234 | BL400 000000 Lk 8600000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06235 | 0001000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06236 | Wr80000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06237 | 000000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06240 | H2002020000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06241 | 00000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06242 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06243 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06244 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06245 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06246 | 00000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06247 | ALK FALK 1 L00,00100 | | | | | | | | | | | | ESI | CPIBID | CBPPT06248 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06250 | Repro Latente. Bus &; 900001000 | | | | | | | | | | | | ESI | CPIBID | CBPPT06251 | New 8e. A60 03041 Live Bus | | | | | | | | | | | | ESI | CPIBID | CBPPT06252 | Evergreen Repieus 90000 Btr. | | | | | | | | | | | | ESI | CPIBID | CBPPT06253 | Websurve Repieus 90000000 | | | | | | | | | | | | ESI | CPIBID | CBPPT06253 | Websurve Repieus 90000000 | | | | | | | | | | | | ESI | CPIBID | CBPPT06254 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06255 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06256 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06257 | 00010000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06260 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06261 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06262 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06263 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06264 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06265 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06266 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06267 | INVERTOR A 70000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06268 | 00000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06272 | Berincan sub. Motifs station1 | | | | | | | | | | | | ESI | CPIBID | CBPPT06280 | Motive. Repieus Live Trap | | | | | | | | | | | | ESI | CPIBID | CBPPT06281 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06282 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06283 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06284 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06285 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06286 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06287 | INVERTOR A 7000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06288 | Evergreen - perform onside end | | | | | | | | | | | | ESI | CPIBID | CBPPT06290 | Evergreen - perform onside end | | | | | | | | | | | | ESI | CPIBID | CBPPT06303 | Remote end with for Point Phe | | | | | | | | | | | | ESI | CPIBID | CBPPT06309 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06314 | L 0q2sq230. Inmitter Lv 694q | | | | | | | | | | | | ESI | CPIBID | CBPPT06320 | Lung Gas - Add two heaters1 | | | | | | | | | | | | ESI | CPIBID | CBPPT06324 | Trap - Build new substation | | | | | | | | | | | | ESI | CPIBID | CBPPT06325 | Wr80000,000000,000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06326 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06328 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06329 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06330 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06331 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06332 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06333 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06334 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06335 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06336 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06337 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06338 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06339 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06340 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06341 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06342 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06343 | 000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06344 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06345 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06346 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06347 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06348 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06349 | 0000000000000 Fie | | | | | | | | | | | | ESI | CPIBID | CBPPT06350 | 0000000000000 Fie | | | | | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BILLS | ETS Plan | | | | | | | | | | | | | | | | Books | | | | | | | | | | | | | | | | Adjusted | | | | CPI/BD | CAPPITSB386 | Weiser. Replace E Residue | | | | 5,463 | 5,463 | | | | | | | | ESI | CPI/BD | CAPPITSB4001 | Little Gypsy Connect New Aov II | | | | | | | | | | | | ESI | CPI/BD | CAPPITSB4002 | Lactation Upgrade i 3M Resun | | | | | | | | | | | | ESI | CPI/BD | CAPPITSB4003 | Kaiser MKH Uppside i 3M Pelop | | | | | | | | | | | | ESI | CPI/BD | CAPPITSB4004 | Jesus Size. Knowledge MKHP105 | | | 8,898 | | | 9,898 | | | | | | ESI | CPI/BD | CAPPITSB4004 | Stor Mero Replace Tenofrenie | | | 11 | | 11 | | 11 | | | | | ESI | CPI/BD | CAPPITSB4005 | Glaeys. Size Silke P102 | | | 10,350 | | 10,350 | | 10,350 | | | | | ESI | CPI/BD | CAPPITSB4002 | AECC Resolve - Initial Swish | | | 3,296 | | | | | | | | | ESI | CPI/BD | CAPPITSB4003 | Mouton - For FU Cadre 6 Pro | | | 1,129 | 1,129 | | | | | | | | ESI | CPI/BD | CAPPITSB47N1 | Menor Subsidiar | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP518 | Describe model 2 Crucified | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP5277 | Gancage i SBH Crucif CenitCc | | | 258 | | 258 | | 258 | | | | | ESI | CPI/BD | CAPPITSP578 | Gancage i SBH Crucif Ceno 3i | | | 202 | | 202 | | 202 | | | | | ESI | CPI/BD | CAPPITSP579 | Goni Uppside irefhelogy i SBH | | | 207 | | 207 | | 207 | | | | | ESI | CPI/BD | CAPPITSP590 | Sterigidam i.mv Relaying 30AH | | | 82 | | | | | | | | | ESI | CPI/BD | CAPPITSP591 | Sadere Relay i SBH 5 iA92 30AH | | | 82 | | 82 | | 82 | | | | | ESI | CPI/BD | CAPPITSP592 | Cathedi Replace R73 | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP5205 | iManibandelle Indice 30AH Sule | | | 186 | | 186 | | 186 | | | | | ESI | CPI/BD | CAPPITSP5227 | Corcra Blok. Base 7A Breaker | | | 2,921 | | 2,921 | | 2,921 | | | | | ESI | CPI/BD | CAPPITSP5259 | Neosolve Replace Breaker 10H | | | 1,541 | | 1,541 | | 1,541 | | | | | ESI | CPI/BD | CAPPITSP5300 | Corcra Replace Prepare 30H | | | 1,901 | | 1,901 | | 1,901 | | | | | ESI | CPI/BD | CAPPITSP5350 | McGonal MDS 6 iSBH 5m 6W2A | | | 659 | | 659 | | 659 | | | | | ESI | CPI/BD | CAPPITSP5304 | Melon Upgrade Line Relaying L | | | 114 | | 114 | | 114 | | | | | ESI | CPI/BD | CAPPITSP5355 | Gawage iSphe 3300 1000 5m 6W2A | | | 824 | | 824 | | 824 | | | | | ESI | CPI/BD | CAPPITSP5356 | Gawage iSphe Line Relaying L | | | 824 | | 824 | | 824 | | | | | ESI | CPI/BD | CAPPITSP5369 | Lalevade Fuel London 7am | | | 82 | | 82 | | 82 | | | | | ESI | CPI/BD | CAPPITSP5383 | Salance 6 MDS 6 iSBH 5m 6W2A | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP5394 | Jsimnane Fuel London 7am | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP5395 | Egalyt Fuel London 7ad | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP5396 | Memorial Fuel London 7ad | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP5398 | Geachie iLeaders 7ad | | | 75 | | 75 | | 75 | | | | | ESI | CPI/BD | CAPPITSP5399 | Double Uppside Relaying L-90 | | | 234 | | 234 | | 234 | | | | | ESI | CPI/BD | CAPPITSP5301 | Geach Uppside Line Relaying L | | | 30 | | 30 | | 30 | | | | | ESI | CPI/BD | CAPPITSP5302 | Geach Uppside Line Relaying L | | | 2,112 | | 2,112 | | 2,112 | | | | | ESI | CPI/BD | CAPPITSP5303 | Mero Uppside Line Relaying L | | | 2,103 | | 2,103 | | 2,103 | | | | | ESI | CPI/BD | CAPPITSP5304 | Mero Uppside Line Relaying L | | | 1,726 | | 1,726 | | 1,726 | | | | | ESI | CPI/BD | CAPPITSP5305 | Gawage Uppside Line Relaying L | | | 2,218 | | 2,218 | | 2,218 | | | | | ESI | CPI/BD | CAPPITSP5307 | Salance Uppside Line Relaying L | | | 3,111 | | 3,111 | | 3,111 | | | | | ESI | CPI/BD | CAPPITSP5308 | Storage Speaks Line Relaying L | | | 3,111 | | 3,111 | | 3,111 | | | | | ESI | CPI/BD | CAPPITSP5307 | Salance Uppside Line Relaying L | | | 3,111 | | 3,111 | | 3,111 | | | | | ESI | CPI/BD | CAPPITSP5309 | Storage Speak 10BH Line R | | | 1,299 | | 1,299 | | 1,299 | | | | | ESI | CPI/BD | CAPPITSP5332 | Geachi Line Relaying L 403 | | | 1,296 | | 1,296 | | 1,296 | | | | | ESI | CPI/BD | CAPPITSP5333 | Corcra Line Relaying L 403 | | | 1,296 | | 1,296 | | 1,296 | | | | | ESI | CPI/BD | CAPPITSP5334 | Corcra 200- 1000 5m 5W2A | | | 35 | | 35 | | 35 | | | | | ESI | CPI/BD | CAPPITSP5335 | Tensile Bond Replace Swish 04 | | | 647 | | 647 | | 647 | | | | | ESI | CPI/BD | CAPPITSP5361 | Snepient Undercoat CTs | | | 81 | | 81 | | 81 | | | | | ESI | CPI/BD | CAPPITSP400 | Tri-Duam Bint Soir 8m Pap 3005 | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP430 | Lance Soir. Remove Assets | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP431 | Mel Cuvate. Install Relaying | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP4321 | Mel Cuvate. Install Relaying | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP4350 | Nivertine 200 Widestickbay 069 | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP4352 | Geachi Line Relaying L 403 | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP454 | Corcra 200- Replace Swis 8 Jo | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP4554 | Corcra 200- Replace Jintam | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP472 | Homec 200. Replace Jintam | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP472 | Homec 200. Replace Jintam | | | | | | | | | | | | ESI | CPI/BD | CAPPITSP4800 | Corrigan Replace Binser 6900 | | | 304 | | | | | | | | | ESI | CPI/BD | CAPPITSP5000 | Corrigan Replace Bunsit R7U | | | 83 | | 83 | | 83 | | | | | ESI | CPI/BD | CAPPITSP536 | Humanite Replace Bunsit R7U | | | 83 | | 83 | | 83 | | | | | ESI | CPI/BD | CAPPITSP5364 | Humanite Replace Bunsit R7U | | | 74 | | 74 | | 74 | | | | | ESI | CPI/BD | CAPPITSP537 | Gancage Replace Baus R7U | | | 46 | | 46 | | 46 | | | | | ESI | CPI/BD | CAPPITSP540 | St Dabras - not line relays | | | 741 | 741 | | | | | | | | ESI | CPI/BD | CAPPITSP546 | Evaside Replace Bains R7U | | | 239 | | 239 | | 239 | | | | | ESI | CPI/BD | CAPPITSP548 | Olinion Replace swish04 | | | 13 | 13 | | | | | | | | ESI | CPI/BD | CAPPITSP549 | 455m Gen 500 H1 | | | 1,532 | 1,532 | | | | | | | | ESI | CPI/BD | CAPPITSP552 | Jauper Circu Cientrimes 53604 | | | 213 | | 213 | | | | | | | ESI | CPI/BD | CAPPITSP5555 | Simmerite Soir. Install Cap 8a | | | 4,737 | 4,737 | 4,737 | | 4,737 | | | | | ESI | CPI/BD | CAPPITSP567 | Intend Orange. Install Meteori | | | 3,341 | | 3,341 | | 3,341 | | | | | ESI | CPI/BD | CAPPITSP588 | Nivertine 1200 Kms 8hr 14000 | | | 264 | | 264 | | 264 | | | | | ESI | CPI/BD | CAPPITSP589 | Corrigan Replace Binsiber 6000 | | | 264 | | 264 | | 264 | | | | | ESI | CPI/BD | CAPPITSP600 | Long-John Engineering 264k | | | 304 | | 304 | | | | | | | ESI | CPI/BD | CAPPITSP6000 | Long-John Engineering 264k | | | 288 | | 288 | | 288 | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BSUs | ETS Plan | Evaluations | Pro. Pumps | Total ETS Adjudices | | | | | | | | | Periphery | | | | | | | | | | | CAPPT/SP686 | Terms Sub. install 108m Bm | DIRECTTX | 1,427 | | 1,427 | | 7,427 | | (7,427) | | | | | | CAPPT/SP750 | Navarate. Install Pelay Dayarm | DIRECTTX | 5,154 | | 5,154 | | 5,154 | (5,154) | | | | | | | CAPPT/SP800 | River Sub. Install Pelay Giyip | DIRECTTX | 4,222 | | 4,222 | | 4,222 | | 4,222) | | | | | | CAPPT/SP911 | U. St. junction. Install 108m | DIRECTTX | 7,829 | | 7,829 | | 7,829 | (7,829) | | | | | | | CAPPT/SP987 | Min-t sub. hold new sub. | DIRECTTX | 13,873 | | 13,873 | | 13,872 | (13,872) | | | | | | | CAPPT/SP999 | College Station junction. Bull. | DIRECTTX | 13,077 | | 13,077 | | 13,077 | (13,077) | | | | | | | CAPPT/SC2031 | YOJ/FOV0-LAND. BUL2/ DULWHA | DIRECTEAC | 3,077 | | 3,077 | 3,077 | | | | | | | | | CAPPT/SC2032 | Elamy 30/ Comer/iv S Slender R | DIRECTEAC | 9,917 | | 9,917 | 9,917 | | | | | | | | | CAPPT/SC2033 | Yigit Sub. Uygid Sw on 99473 | DIRECTEAC | 1,937 | | 1,937 | 1,937 | 1,937 | | | | | | | | CAPPT/SC2034 | Ruvin 5 Sub. Uygid Swon 98144 | DIRECTEAC | 1,804 | | 1,804 | 1,804 | | | | | | | | | CAPPT/SC2037 | Paragonn. Move 3040/4th Day 994R | DIRECTEAC | 2,409 | | 2,409 | 2,409 | 3,409 | | | | | | | | CAPPT/SP100 | Rausland Sub. Uygidae Gyujimen | DIRECTELI | 474 | | 474 | 474 | | | | | | | | | CAPPT/SP101 | Coteau Substantin. Uygidae Cm | DIRECTELI | 457 | | 457 | 457 | | | | | | | | | CAPPT/SS001 | Warvidae. Build New 116V1 Sub. | DIRECTEBA | 364 | | 364 | 364 | | | | | | | | | CAPPT/SS002 | Spongfilings My. Build New Line | DIRECTEBA | 93 | | 93 | 93 | | | | | | | | | CAPPT/SS003 | Rayfinaseer 115V1. Reptase Pbr. | DIRECTEBA | 15 | | 15 | 15 | | | | | | | | | CAPPT/SS004 | Broadwater. Reptase Respiray | DIRECTEBA | 19 | | 19 | 19 | | | | | | | | | CAPPT/SS005 | Belkin. Install 110V1 Sibs | DIRECTEBA | 141 | | 141 | 141 | | | | | | | | | CAPPT/ST001 | Nettam. Dune New 107V1 I vB 2 | DIRECTLQ | 1,487 | | 1,487 | 1,487 | | | | | | | | | CAPPT/ST004 | Nettamest Bud/ New 20V14 Sub. | DIRECTTX | | | | | | | | | | | | | CAPPT/ST005 | Tallowing Purchase Substanton | DIRECTTX | | | | | | | | | | | | | CAPPT/ST006 | Tallowing Purchase Substanton | DIRECTTX | | | | | | | | | | | | | CAPPT/ST007 | Cloth's Island. Build New 106 | DIRECTTX | | | | | | | | | | | | | CAPPT/ST008 | Cloth's Island. Rupee Sub 30 | DIRECTTX | | | | | | | | | | | | | CAPPT/ST010 | N23. Aoyang Substanton Site | DIRECTTX | | | | | | | | | | | | | CAPPT/ST011 | Herdway 9000 Insect Aun 7i | DIRECTTX | | | | | | | | | | | | | CAPPT/ST012 | Bovvet Mhom. Build New 10 | DIRECTTX | | | | | | | | | | | | | CAPPT/ST013 | Herdway 110. Hap Bm b Ln R | DIRECTTX | | | | | | | | | | | | | CAPPT/ST014 | Herdway 110. Hap Bm b Ln R | DIRECTEBA | 352 | | 352 | 352 | | | | | | | | | CAPPT/ST015 | Tallowing Purchase Substanton | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST020 | Tallowing Purchase Substanton | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST021 | Soweon's Lime. Build Species | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST026 | NC Jackson. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST028 | Funnish 6000 Intrepid | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST029 | Funnish 6000 Intrepid | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST030 | Gierm A64m. Reptase Sub 30 | DIRECTTX | | | | | | | | | | | | | CAPPT/ST031 | N23. Aoyang Substanton Site | DIRECTTX | | | | | | | | | | | | | CAPPT/ST032 | N23. Aoyang Substanton | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST034 | N23. Aoyang Substanton | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST035 | Tallowing Purchase Substanton | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST036 | Tallowing Purchase Substanton | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST037 | Soweon's Lime. Build Species | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST038 | NC Jackson. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST039 | Funnish 6000 Intrepid | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST040 | S24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST041 | N23. Aoyang Substanton Site | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST042 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST043 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST044 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST045 | S24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST046 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST047 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST048 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST049 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST050 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST051 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST052 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST053 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST054 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST055 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST056 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST057 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST058 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST059 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST060 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST061 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST062 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST063 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST064 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST065 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST066 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST067 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST068 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST069 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST070 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST071 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST072 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST073 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST074 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST075 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST076 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST077 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST078 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST079 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST080 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST081 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST082 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST083 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST084 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST085 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST086 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST087 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST088 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST089 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST090 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST091 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST092 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST093 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST094 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST095 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST096 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST097 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST098 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST099 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST100 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST101 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST102 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST103 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST104 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST105 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST106 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST107 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST108 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST109 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST110 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST111 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST112 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST113 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST114 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST115 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST116 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST117 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST118 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST119 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST120 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST121 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST122 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST123 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST124 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST125 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST126 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST127 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST128 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST129 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST130 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST131 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST132 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST133 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST134 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST135 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST136 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST137 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST138 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST139 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST140 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST141 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST142 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST143 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST144 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST145 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST146 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST147 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST148 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST149 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST150 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST151 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST152 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST153 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST154 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST155 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST156 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST157 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST158 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST159 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST160 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST161 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST162 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST163 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST164 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST165 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST166 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST167 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST168 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST169 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST170 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST171 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST172 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST173 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST174 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST175 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST176 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST177 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST178 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST179 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST180 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST181 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST182 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST183 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST184 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST185 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST186 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST187 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST188 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST189 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST190 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST191 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST192 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST193 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST194 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST195 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST196 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST197 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST198 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST199 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST1100 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST1101 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST1112 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST1113 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST1114 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST115 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST116 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST117 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST18 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST19 | N23. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST20 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST201 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST202 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST203 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST204 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST205 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST206 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST207 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST208 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST209 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST210 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST211 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST222 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST230 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST231 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | CAPPT/ST232 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | CAPPT/ST233 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | CAPPT/ST24 | N24. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | CAPPT/ST25 | N25. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST26 | N25. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST26 | N26. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST27 | N27. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST28 | N28. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST29 | N29. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST30 | N29. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | CAPPT/ST31 | N310. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST320 | N320. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | | CAPPT/ST330 | N30. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | | CAPPT/ST31 | N310. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | CAPPT/ST32 | N310. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | | CAPPT/ST330 | N310. Aoyang Sub. Reptase Ramping | DIRECTEBA | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BSUs | ETS Plan | Evaluations | Pro. Pumps Amount | Total ETS Adjusted | | | | | | | | | Peripher | Peripher | | | | | | | | | 00 | CP080 | CBPPTSAS01 | Deptor: 10611 Papiest Breakbar | DIRECTTX | 637 | | 637 | | | 637 | | (637) | | | | 00 | CP080 | CBPPTSAS02 | Green: 10611 Papiest Breakers a | DIRECTTX | 716 | | 716 | | | 716 | | (716) | | | | 00 | CP080 | CBPPTSAS03 | 5 MH7 10611 Papiest Breakers a | DIRECTTX | 3,279 | | 3,279 | | | 3,279 | | (3,279) | | | | 00 | CP080 | CBPPTSAS04 | Lees Coats: 10611 /1000 /VA | DIRECTTX | 7,585 | | 7,585 | | | 7,585 | | (7,585) | | | | 00 | CP080 | CBPPTSAS05 | Aspirate Cornea Bulk | DIRECTTX | 1,521 | | 1,521 | | | 1,521 | | (1,521) | | | | 00 | CP080 | CBPPTSAS06 | Insect tree: 030155sp Javinte | DIRECTTX | 2,479 | | 2,479 | | | 2,479 | | (2,479) | | | | 00 | CP080 | CBPPTSAS07 | Insect protection Center Sub | DIRECTTX | 148 | | 148 | | | 148 | | (148) | | | | 00 | CP080 | CBPPTSAS08 | aspirate: 030m bus 560. County | DIRECTTX | 231 | | 231 | | | 231 | | (231) | | | | 00 | CP080 | CBPPTSAS10 | History Ridge New Subsidiary 0 | DIRECTTX | 2,594 | | 2,594 | | | 2,594 | | (2,594) | | | | 00 | CP080 | CBPPTSAS100 | McKelens Aad 2nd Auto | DIRECTE&K | 15,267 | | 15,267 | | | 15,267 | | | | | | 00 | CP080 | CBPPTSAS101 | Vitale Subsidiary Papiest Line | DIRECTE&K | 3,585 | | 3,585 | | | 3,585 | | | | | | 00 | CP080 | CBPPTSAS102 | Labourer Remove Line Trap | DIRECTE&K | 1,266 | | 1,266 | | | 1,266 | | | | | | 00 | CP080 | CBPPTSAS103 | Minora Add line penetrin 5. SV | DIRECTE&K | 18 | | 18 | | | 18 | | | | | | 00 | CP080 | CBPPTSZS01 | Ray Strained Ray Breakers&;Dev | DIRECTE&K | 532 | | 532 | | | 532 | | | | | | 00 | CP080 | CBPPTSZS02 | Burner Wilson. Ray Shadow 4.5 | DIRECTE&K | 631 | | 631 | | | 631 | | | | | | 00 | CP080 | CBPPTSZS03 | Dormygon Ranculo 10. In Box | DIRECTELI | 7,581 | | 7,581 | | | 7,581 | | | | | | 00 | CP080 | CBPPTSZS04 | Herfing: Ray Line in May Paper | DIRECTTX | 659 | | 659 | | | 656 | | (656) | | | | 00 | CP080 | CBPPTSZS05 | Insect Orange. Ray Bus Line 15 | DIRECTTX | 84 | | 84 | | | 84 | | (84) | | | | 00 | CBPPTSZS06 | 100 and. Ray Deprived A. Reary | DIRECTTTE | 2,538 | | | 2,538 | | | 2,538 | | (2,538) | | | | 00 | CP080 | CBPPTSZS07 | Riding from Lead 21 M/400 C | DIRECTE&K | 6,058 | | 6,058 | | | 3,058 | | | | | | 00 | CP080 | CBPPTSZS08 | 10 and 20 H&K 400 C | DIRECTE&K | 550 | | 550 | | | 550 | | | | | | 00 | CP080 | CBPPTSZS09 | Carried On the. and 21 M/400 C | DIRECTE&K | 4,880 | | 4,880 | | | 4,880 | | | | | | 00 | CP080 | CBPPTSZS10 | Common 11041. Aus 21M/400 C | DIRECTE&K | 4,222 | | 4,222 | | | 4,222 | | | | | | 00 | CP080 | CBPPTSZS11 | Helper 11041. Aus 22 H/404 Ga | DIRECTE&K | 797 | | 797 | | | 797 | | | | | | 00 | CP080 | CBPPTSZS12 | Red and 11041. Aus 24 M/404 Ga | DIRECTE&K | 431 | | 431 | | | 431 | | | | | | 00 | CP080 | CBPPTSZS14 | Ferrovirus/11041. Satt 324 Cap | DIRECTE&K | 8,161 | | 8,161 | | | 8,161 | | | | | | 00 | CP080 | CBPPTSZS15 | Helixwater/11041. Sitt 324 Ga | DIRECTE&K | 4,841 | | 4,841 | | | 4,841 | | | | | | 00 | CP080 | CBPPTSZS16 | Pouchure/11041. Sitt 324 Ga | DIRECTE&K | 4,789 | | 4,789 | | | 4,789 | | | | | | 00 | CP080 | CBPPTSZS17 | Purchipion/11041. Sitt 324 Ga | DIRECTE&K | 2,935 | | 2,935 | | | 2,935 | | | | | | 00 | CP080 | CBPPTSZS18 | Seawater/11041. Sitt 324 Ga | DIRECTE&K | 5,946 | | 5,946 | | | 5,946 | | | | | | 00 | CP080 | CBPPTSZS19 | Fayettec/11041. Sitt 324 Ga | DIRECTE&K | 4,526 | | 4,526 | | | 4,526 | | | | | | 00 | CP080 | CBPPTSZS20 | Ricted 10611 Cornea New Gene | DIRECTLLS | 804 | | 804 | | | 804 | | | | | | 00 | CP080 | CBPPTSZS21 | Coarse Cust Comfort House Rate | DIRECTLLS | 1,109 | | 1,109 | | | 1,109 | | | | | | 00 | CP080 | CBPPTV0S31 | New Aent Lab. Mississippi | DIRECTE&K | 473 | | 473 | | | 473 | | | | | | 00 | CP080 | CBPPTV0S32 | New Aent Lab. Texas | DIRECTTX | 279 | | 279 | | | 279 | | (279) | | | | 00 | CP080 | CBPPTV0S33 | New Aent Lab. ULL. South | DIRECTELI | 223 | | 223 | | | 223 | | | | | | 00 | CP080 | CBPPTV0S34 | New Aent Lab. ULL. North | DIRECTELI | 249 | | 249 | | | 249 | | | | | | 00 | CP080 | CBPPTV0S35 | New Aent Lab. 5500.A. East | DIRECTLLS | 136 | | 136 | | | 136 | | | | | | 00 | CP080 | CBPPTV0S36 | New Aent Lab. 5500.A. West | DIRECTLLS | 223 | | 223 | | | 223 | | | | | | 00 | CP080 | CBPPTV0S37 | New Aent Lab. 5500 | DIRECTEKD | 110 | | 110 | | | 110 | | | | | | 00 | CP080 | CBPPTV0S38 | New Aent Lab. Arkansas | DIRECTEAL | 1,827 | | 1,827 | | | 1,827 | | | | | | 00 | CP080 | CBPPTX1085 | 5 current Mapper RAV 1000 090 | DIRECTTX | 82 | | 82 | | | 82 | | (82) | | | | 00 | CP080 | CBPPTX1168 | Meeker 06h0 Line 000 0905 | DIRECTTX | | | | | | | | | | | | 00 | CP080 | CBPPTX1176 | Evasker 06h1 Cap Rank 000 094 | DIRECTTX | 239 | | 239 | | | 239 | | (239) | | | | 00 | CP080 | CBPPTX1179 | Fort Worth. Papiest Basic 8702 | DIRECTTX | 50 | | 50 | | | 50 | | (50) | | | | 00 | CP080 | CBPPTX1180 | MedLorris Papiest Basic 8702 | DIRECTTX | | | | | | | | | | | | 00 | CP080 | CBPPTX51002 | CLASERINE 11010. CAP RELAT 1270 | DIRECTEKD | | | | | | | | | | | | 00 | CP080 | CBPPTWAB044 | COC Citya Dam. 000 010 A. Opera | DIRECTEAL | 1,848 | | 1,848 | | | 1,848 | | | | | | 00 | CP080 | CBPPTWAB035 | INC 2 centre pointwork leader | DIRECTEAL | 2,340 | | 2,340 | | | 2,340 | | | | | | 00 | CP080 | CBPPTWAN023 | Purchipen Papiest Mappe 7Hm0m | DIRECTEAL | | | | | | | | | | | | 00 | CP080 | CBPPTWAN035 | Purchipen RybicoutraffetPapiest 0 | DIRECTEAL | | | | | | | | | | | | 00 | CP080 | CBPPTWAN041 | RIO 3C0 812. Operating Day 5W | DIRECTEAL | 1,845 | | 1,845 | | | 1,845 | | | | | | 00 | CP080 | CBPPTWAN044 | RIO 1n40age Regulator Papiestem | DIRECTEAL | 653 | | 653 | | | 653 | | | | | | 00 | CP080 | CBPPTWAN045 | RIO 1n40age Regulator Papiestem | DIRECTEAL | 538 | | 538 | | | 538 | | | | | | 00 | CP080 | CBPPTWAN046 | RIO 1n40age Regulator Papiestem | DIRECTEAL | 583 | | 583 | | | 583 | | | | | | 00 | CP080 | CBPPTWAR042 | 1000. AT3A A A730 Reader Papiest | DIRECTEAL | 1,087 | | 1,087 | | | 1,087 | | | | | | 00 | CP080 | CBPPTWAR062 | 1000. Repetion 2 June 21,1 100m | DIRECTEAL | 483 | | 483 | | | 483 | | | |

Amourits may not add or tie to other schedules due to rounding. Gardner, Kevin

| Class | Billing Ending | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | Service Company | Total | All Other BILS | ETS Plan | Evaluations | Pro அத | Total Adjudices | | | | | | | | | Periphery | | | | | | | | | | | | | Activity / Project | Activity / Project Description | | | | | | | | | | | | | Code | Method | | | 374 | | 374 | | 374 | | | | | | | | | | | | | | | | | | | | | | | | | | | | 167 | | 167 | | | | | | | | | | | | | | | | | | | | | | | | | | 810 | | 810 | | 810 | | | | | | | | | | | 84 | | 84 | | 84 | | | | | | | | | | | 9,350 | | 9,350 | | 9,350 | | | | | | | | | | | 9,350 | | 9,350 | | 9,350 | | | | | | | | | | | 498 | | 498 | | 498 | | | | | | | | | | | 498 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 845 | | 845 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Ending | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing Support | Dept | All Other Billing Books | ETS Plan
Books | Evaluations | Pro Fiamme Amount | Total ETS Adjusted | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | | | | | | | | | | | | | | | 61 | 61 | | | | | | | | | | | | | 61 | 61 | | | | | | | | | | | | | | 47 | 47 | | | | | | | | | | | | | | 4,218 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | 6,639 | | | | | | | | | | | | | | | 6,639 | | | | | | | | | | | | | | | 1,579 | | | | | | | | | | | | | | | 1,579 | | | | | | | | | | | | | | | 1,991 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing Eval(s) | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other BILLS | ETS Plan Books | Evaluations | Pro Forma Amount | Total ETS Adjudice | | | | | | | | | | Periphery | | | | | | | | | EO | CPNB | FSPPZG2257 | PH1 Spring No 66 Nc Cueper | | | | 428 | 428 | | | | | | | | EO | CPNB | FSPPZG2281 | OP1-07Spring Netadilly (Cueper) | | | | 3,856 | 3,856 | | | | | | | | EO | CPNB | FSPPZG2285 | OP4-07 Redaddy (So F4410) | | | | | | | | | | | | | EO | CPNB | FSPPZG2272 | OP5-07Spring Netadilly (Cueper) | | | | 2,800 | | 2,800 | | | | | | | EO | CPNB | FSPPZG2281 | LG2 Turbine Gaseak Generator (1) | | | | 8,765 | 8,765 | | | | | | | | EO | CPNB | FSPPZG2274 | W82 Auxiliary Process (Cueper) | | | | | | | | | | | | | EO | CPNB | FSPPZG2278 | T1005 D111 Pre Summer (Net Cice) | | | | | | | | | | | | | EO | CPNB | FSPPZG2284 | SL1 VALIX (SCPAG) | | | | | | | | | | | | | EO | CPNB | FSPPZG2385 | SL2 VALIX (SCPAG) | | | | 689 | 689 | | | | | | | | EO | CPNB | FSPPZG2397 | ATC Major (Cueper) | | | | 5,877 | 5,877 | | | | | | | | EO | CPNB | FSPPZG2412 | WH1 Mayrgan e HP Central Tree | | | | 757 | 757 | | | | | | | | EO | CPNB | FSPPZG2419 | LG2 6360 Fronzel Endt Fen Tree | | | | 1,415 | 1,415 | | | | | | | | EO | CPNB | FSPPZG2445 | W85 Unplanned Evalite (Cueper) | | | | | | | | | | | | | EO | CPNB | FSPPZG2451 | LG2 Boter Neporo | | | | 443 | 443 | | | | | | | | EO | CPNB | FSPPZG2498 | W82 Steam Process (Cueper 2015) | | | | 161 | 161 | | | | | | | | EO | CPNB | FSPPZG2515 | L41 64 C7 Major (Cueper 2015) | | | | 170 | 170 | | | | | | | | EO | CPNB | FSPPZG2530 | OP4-07 Fall Preadults (Cueper) | | | | 70 | 70 | | | | | | | | EO | CPNB | FSPPZG2581 | ST7-Spring (Cueper 1) | | | | 1,357 | 1,357 | | | | | | | | EO | CPNB | FSPPZG2607 | LG3 Auxiliary Cueper (Neporo 1) | | | | 654 | 654 | | | | | | | | EO | CPNB | FSPPZG2616 | W81 Turbine Generator Fall Tire | | | | 2,005 | 2,005 | | | | | | | | EO | CPNB | FSPPZG2622 | W81 Auxiliary Process (Perone C) | | | | 266 | 266 | | | | | | | | EO | CPNB | FSPPZG2658 | W81 Energy Consensus Full Cut | | | | 111 | 111 | | | | | | | | EO | CPNB | FSPPZG2663 | W82 Energy Consensus Fullcap | | | | 1,481 | 1,481 | | | | | | | | EO | CPNB | FSPPZG2670 | W81 Energy Consensus Spring (1) | | | | 1,332 | 1,332 | | | | | | | | EO | CPNB | FSPPZG2684 | W81 Sleeves Process (Gareg) | | | | 1,280 | 1,280 | | | | | | | | EO | CPNB | FSPPZG2688 | W82 Steam Process (Cueper) | | | | 70 | 70 | | | | | | | | EO | CPNB | FSPPZG2690 | W82 Energy Consensus Spring (1) | | | | 1,175 | 1,175 | | | | | | | | EO | CPNB | FSPPZG2742 | L41 44 C7 C1 (Cueper 2011) | | | | 2,055 | 2,055 | | | | | | | | EO | CPNB | FSPPZG2743 | L41 44 Heat Recovery Steam Cam | | | | 168 | 168 | | | | | | | | EO | CPNB | FSPPZG2786 | B0.8 Fronzel (Cueper) | | | | 1,320 | 1,320 | | | | | | | | EO | CPNB | FSPPZG2790 | W84 Viber Translomer Heparin | | | | 8,040 | 8,040 | | | | | | | | EO | CPNB | FSPPZG2791 | L41 54 Turbine Lube C6 Leak | | | | 1,169 | 1,169 | | | | | | | | EO | CPNB | FSPPZG2792 | LG3 Generator Terminal (Nepor)1) | | | | 70 | 70 | | | | | | | | EO | CPNB | FSPPZG2801 | LG3 Turbine (Cueper Fall Tire) | | | | 2,556 | 2,556 | | | | | | | | EO | CPNB | FSPPZG2804 | LG3 Water Chemical (Deering) | | | | 1,449 | 1,449 | | | | | | | | EO | CPNB | FSPPZG2811 | W02 Turbine (Cueper Gish) | | | | 9,737 | 9,737 | | | | | | | | EO | CPNB | FSPPZG2816 | PH1-12 Cook Retreat Tires (Cueper) | | | | 1,137 | 1,137 | | | | | | | | EO | CPNB | FSPPZG2828 | W01 Pre Summer (Cueper) | | | | 381 | 381 | | | | | | | | EO | CPNB | FSPPZG2832 | W01 Rump Turbine (Beating Cice) | | | | 2,733 | 2,733 | | | | | | | | EO | CPNB | FSPPZG2847 | L41 54 Evalite (Cueper) | | | | 2,917 | 2,917 | | | | | | | | EO | CPNB | FSPPZG2848 | S41 2011 EPHW2 (SCPAG) | | | | 5,358 | 5,358 | | | | | | | | EO | CPNB | FSPPZG2855 | L41 44 Preheater Look | | | | 432 | 432 | | | | | | | | EO | CPNB | FSPPZG2897 | W81 Steam Process Fall (Cueper) | | | | 111 | 111 | | | | | | | | EO | CPNB | FSPPZG28987 | L41 64 C5 C6 Maternal Fuse (Cueper) | | | | 791 | 791 | | | | | | | | EO | CPNB | FSPPZG2900 | W02 Prerain (Cueper) | | | | 155 | 155 | | | | | | | | EO | CPNB | FSPPZW4656 | Symmetry Size Storage Feath | | | | 15,441 | 15,441 | | | | | | | | EO | CPNB | FSPPZW6675 | T1002 Vabion - Nepor | | | | | | | | | | | | | EO | CPNB | FSPPZW6797 | T4-LAB Turbine Impedion 6 Ple | | | | | | | | | | | | | EO | CPNB | FSPPZW6891 | NLA FC PA O' Funtriernal flip | | | | 385 | 385 | | | | | | | | EO | CPNB | FSPPZW7054 | T705M Add Fronzel Draft Per Flip | | | | 67 | 67 | | | | | | | | EO | CPNB | FSPPZW7073 | W40 Viber Tilt Alignment 6 Repair | | | | 3,429 | 3,429 | | | | | | | | EO | CPNB | FSPPZW7125 | L01 Yibish and Translort (Cueper) | | | | 1,209 | 1,209 | | | | | | | | EO | CPNB | FSPPZW7143 | PH1-903 of VP -VIP6 6 CPH Flip | | | | | | | | | | | | | EO | CPNB | FSPPZW7158 | LG3 - CO45 - C640 PROVE11 | | | | | | | | | | | | | EO | CPNB | FSPPZW7159 | LG3 - CO45 - C640 PROVE11 | | | | | | | | | | | | | EO | CPNB | FSPPZW7168 | LG3 - CO45 - C640 PROVE11 | | | | | | | | | | |

| Class | Billing Ending | Dept | Activity / Project Code | Activity / Project Description | ESS Billing Method | Support | Total Billing | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | | | Service Company | Total | All Other ROIs | ETS Plan | | | | | | | | | | | Pension | | | | Books | | | | | | | | | | | | | | Amount | Total ETS Adjusted | | | | HIR416 | CMPPTLX001 | Upposite L 804 | | DIRECTTX | 340 | | 340 | | 340 | | | | | | | | | | | | | | | | 340 | | | | | HIR416 | CMPPTLX003 | Burit Upposicamoy smelt sub | | DIRECTTX | 231 | | 231 | | 231 | | | | | | | | | | | | | | | | 199 | | | | | CMPPTLX101 | McAlaino-Palomo Lo Upp 1/2 3 | | DIRECTEW | 180 | | 180 | 180 | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTLY001 | Mesalain Topo. Necrotositio 11 | | DIRECTLCL | 313 | | 313 | 313 | | | | | | | | | | | | | | | | 442 | | | | | | CMPPTLZ005 | Herfora-Meculati1 | | DIRECTLCL | 278 | | 278 | 278 | | | | | | | | HIR416 | CMPPTS1402 | Herfora Botum Land Purchase 5 | | DIRECTEW | 877 | | 877 | 877 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS1458 | Herfora Botum 400/1/2/41 Sub | | DIRECTEW | 2,028 | | 2,028 | 2,028 | | | | | | | | | | | | | | | | 2,029 | | | | | | HIR416 | CMPPTS1540 | A bock. Instat 250/17/64 Av | | DIRECTEL | 231 | | 231 | 231 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS2069 | Uda sidi mediy. sida 230/41 | | DIRECTLCL | 1,079 | | 1,079 | 1,079 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS2080 | Pedestrian Convert to E500/74h | | DIRECTELI | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS7745 | South Korea 200. Decommission | | DIRECTELI | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8859 | Nambane. Instat 1704/4 Aug | | DIRECTEW | 872 | | 872 | 872 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS9370 | Suragita 3/60/1. Burit New Eo. 5 | | DIRECTELI | 1,526 | | 1,526 | 1,526 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS9370 | St Omatis. Upposite Pelopony | | DIRECTEW | 338 | | 338 | 338 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS9377 | Suragita 1704/ Instat New Ut | | DIRECTELI | 183 | | 183 | 183 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS9375 | A Burit. Instat Super Eo. 6 | | DIRECTELI | 1,282 | | 1,282 | 1,282 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS9460 | Uda Uppos Pot Lobe Recavity | | DIRECTELI | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS9480 | Gromtane. Instat New Eo. 6 | | DIRECTEW | 1,776 | | 1,776 | 1,776 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4704 | H.S. 6/10. Mosleaves. Polay Upp | | DIRECTEW | 208 | | 208 | 208 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4707 | A. West. Alag Residues us 11 | | DIRECTEW | 159 | | 159 | 159 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4712 | Mosleaves Sida. Polay Upposite | | DIRECTEW | 115 | | 115 | 115 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4814 | AECC Aofe P202 | | DIRECTEW | 1,204 | | 1,204 | 1,204 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4800 | Unspo Green AECCC Upposite | | DIRECTEW | 210 | | 210 | 210 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4889 | Lymin. Polay Inter on darkness | | DIRECTEW | 199 | | 199 | 199 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4900 | Lh5000 Eemngon church. mar | | DIRECTELI | 119 | | 119 | 119 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS4921 | Aves 65. Upposite Sarcot 804/11 | | DIRECTEW | 202 | | 202 | 202 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8123 | Uda Lobi. Helices Primary mits | | DIRECTELI | 148 | | 148 | 148 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8124 | Aves 66. Oth. Bushthete Sesto | | DIRECTELI | 182 | | 182 | 182 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8205 | Cume Upposite Cup Book | | DIRECTELI | 2,297 | | 2,297 | 2,297 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8251 | Aves 66. Aidi (Othri) Lobe | | DIRECTELI | 253 | | 253 | 253 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8109 | Beetwai. Sidi. Moth Fleshty Upp | | DIRECTELI | 140 | | 140 | 140 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8108 | Aves 66. Oth. Bushthete Sesto | | DIRECTELI | 273 | | 273 | 273 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8107 | Oat/Grow 115. Basoga Lo Pede | | DIRECTELI | 782 | | 782 | 782 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8109 | Stony Lodi. Holst new sub | | DIRECTELI | 229 | | 229 | 229 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8124 | Aves 66. Oth. Bushthete Sesto | | DIRECTELI | 127 | | 127 | 127 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8200 | Aves. Instat 600/64. Aural/999 | | DIRECTELI | 1,492 | | 1,492 | 1,492 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8201 | Aves 66. Aidi (Othri) Lobe | | DIRECTELI | 1,492 | | 1,492 | 1,492 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8251 | Aves 66. Aidi (Othri) Lobe | | DIRECTELI | 253 | | 253 | 253 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8252 | Eomgoun. Papisse 90000 Bhr. | | DIRECTELI | 119 | | 119 | 119 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8272 | Behrman sub. Motify station1 | | DIRECTELI | 140 | | 140 | 140 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8281 | Atriver. Oon. Papisse Breakers | | DIRECTLCL | 1,204 | | 1,204 | 1,204 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8283 | Frum Plesant design coverage | | DIRECTELI | 273 | | 273 | 273 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8386 | Mroate. Papisse 3 Breakers | | DIRECTELI | 782 | | 782 | 782 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8404 | Stony Sidi. Bushthete 999/P030 | | DIRECTTX | 1,013 | | 1,013 | 1,013 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8499 | Stony. Sidi.0901/100 | | DIRECTTX | 319 | | 319 | 319 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8507 | Salimo (Japoside Lore Relaying.) | | DIRECTTX | 127 | | 127 | 127 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8508 | Stony Lodi. Instat Polay Elast | | DIRECTTX | 229 | | 229 | 229 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8534 | Comias. Trans. No. 2 Relaying. | | DIRECTTX | 107 | | 107 | 107 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8535 | Sörmau Sidi. Instat Polay Elast | | DIRECTTX | 789 | | 789 | 789 | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8566 | Taimou Sidi. Instat 10800 Bhr | | DIRECTTX | 243 | | 243 | 243 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8569 | Mroate. Papisse 3 Breakers | | DIRECTELI | 209 | | 209 | 209 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8604 | Stony Sidi. Instat Polay Elast | | DIRECTTX | 1,013 | | 1,013 | 1,013 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | HIR416 | CMPPTS8609 | Sörmau Sidi. Instat Polay Elast | | DIRECTTX | 1,473 | | 1,473 | 1,473 | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

| Class | Billing End(s) | Dept | Activity / Project Code | Activity / Project Description | EGI Billing Method | (A) | (B) | (C) | (D) | (E) | (F) | (G) | (H) | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | | | Service Company | | | | | | | | | HUMAN RESOURCES | EGI | HR498P | PSPPNS0713 | EI/Active - Site Spot | DISCOUTE | 269 | | 269 | 269 | | | | | | HUMAN RESOURCES | EGI | HR498P | PSPPNS0022 | WIC Security Investigation | DIRCAROC | 60 | | 60 | 60 | | | | | | HUMAN RESOURCES | EGI | HR498P | PSPPNS0068 | Carbon Capture Study | CARACIPCC | 5 | | 5 | 4 | | | (1) | | | HUMAN RESOURCES | EGI | HR498P | SNPCPNSUSP | (UAPTA, SUPPING - ENASC) 80 | DIRCTENG | 35 | | 35 | 35 | | | | | | HUMAN RESOURCES | EGI | HR498P | Total | | | 4,981 | | 4,981 | 4,981 | 1 | | (1) | | | HUMAN RESOURCES | EGI | HR691 | C1PPP/SQ07 | Peptid Time &; Labor - Phase I | EMPLOYAL | 1,282 | 135 | 1,417 | 1,347 | 70 | (70) | - | | | HUMAN RESOURCES | EGI | HR691 | C1PPPHR880E | PV HOR (Human Cap Reject) (sight | EMPLOYAL | 547 | 53 | 601 | 560 | 20 | (20) | - | | | HUMAN RESOURCES | EGI | HR691 | PSPCPACALL | FACILITIES EICO. ALL COS | SQPTALLC | 557 | | 557 | 495 | 62 | | - | 62 | | HUMAN RESOURCES | EGI | HR691 | PSPCHREDA | HR 5/CQ - PLORW (ENEC) | DIRECTST | - | | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPCHRENUC | HR 50FICES - ENASC - ALL | DIRCTENG | 35,522 | 5,431 | 40,953 | 40,953 | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPCHRSALL | HR 50FICES - ALL COMPANES | EMPLOYAL | 1,310,092 | 134,283 | 1,444,375 | 1,374,435 | 69,941 | - | 1,308 | 71,248 | | HUMAN RESOURCES | EGI | HR691 | PSPCHRSRESO | HR 50FICES - RECULATES COMPAR | EMPLOPRO | 35,415 | 3,867 | 39,283 | 36,683 | 2,599 | - | 52 | 2,652 | | HUMAN RESOURCES | EGI | HR691 | PSPCRT2374 | Jackson Customer Service Center | CUSTICAL | 409 | 58 | 513 | 499 | 57 | - | 1 | 58 | | HUMAN RESOURCES | EGI | HR691 | PSPCRT0380 | West Riverse Customer Service C | CUSTICAL | 341 | 43 | 385 | 342 | 42 | - | 1 | 43 | | HUMAN RESOURCES | EGI | HR691 | PSPRNR447M | 4 -needs Reading for HRak | EMPLOYAL | 2,074 | - | 2,074 | 1,975 | 100 | - | - | 100 | | HUMAN RESOURCES | EGI | HR691 | PSPPNRTFRW | HR Transformation - Odd Code | EMPLOYAL | 37,058 | 3,768 | 40,856 | 38,894 | 1,972 | - | 39 | 2,012 | | HUMAN RESOURCES | EGI | HR691 | PSPPNS0522 | Service Group Analysis | DIRCTECS | 9,400 | 1,000 | 9,400 | 9,400 | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPCQVCANED - SONICO. ANVERS | | DIRCTES | 297 | - | 297 | 297 | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPCCEDSPF | SUPPING/Use &; SUPPORT - COMPOR | DIRECTRFP | 313 | - | 313 | 304 | 9 | - | - | 9 | | HUMAN RESOURCES | EGI | HR691 | PSPCCEMOTI | MPHCT ANVROS | DIRCTES | 86 | - | 86 | 86 | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPPFRS5100 | Symptomate Ergonomic Model | EMPLOYAL | - | - | - | - | - | - | (80) | 80 | | HUMAN RESOURCES | EGI | HR691 | PSPPET3009 | 30W Texas Rate Case Support | DIRECTTX | - | - | - | - | - | - | (80) | 80 | | HUMAN RESOURCES | EGI | HR691 | PSPPFALCON | Project Falson | DIRECTNI | 22,598 | 2,713 | 25,311 | 25,311 | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPPGST007 | 3001 Texas Rate Case Support | DIRECTTX | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | HR691 | PSPPHPELEV2 | Leave of Absence Colourning P | EMPLOYAL | 98,404 | 10,490 | 108,893 | 103,634 | 5,259 | - | 108 | 5,367 | | HUMAN RESOURCES | EGI | HR691 | PSPPZUWELL | Energy Wexiness Program | EMPLOYAL | 974 | 106 | 1,081 | 1,028 | 53 | - | 1 | 54 | | HUMAN RESOURCES | EGI | HR691 | Total | | | 1,554,465 | 161,979 | 1,716,443 | 1,636,260 | 80,183 | (170) | 1,590 | 81,603 | | HUMAN RESOURCES | EGI | NEM3N | PSPCHRANICA | HUMAN RESOURCS SONICES - ANV | DIRCAROC | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPCHREDOX | HUMAN RESOURCS SONICES - EOI | DIRCTECS | 435,726 | 57,634 | 493,360 | 493,360 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPCHRRVRW | HUMAN RESOURCS SONICES - RYR | DIRCTRES | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPCHRSALL | HR 50FICES ALL COMPANES | EMPLOYAL | 76,119 | 8,719 | 84,838 | 80,777 | 4,061 | - | (4,061) | - | | HUMAN RESOURCES | EGI | NEM3N | PSPPNRANITM | 4 -needs Reading for HRak | EMPLOYAL | 137 | - | 137 | 131 | 7 | - | (7) | - | | HUMAN RESOURCES | EGI | NEM3N | PSPPNARCEL | Riding Readiness | DIRECTNI | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPPNARBCER | Exeous Recruiting | DIRECTNI | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPPWEODTI | 30W Union Negotiation Project | DIRCTE&;K | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPCQVCANED | SONICO. ANVROS | DIRCTES | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPCZNDEPY | SUPPING/Use &; SUPPORT - NUCLEA | DIRCTES | 696 | - | 696 | 696 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | PSPPZUWELL | Energy Wexiness Program | EMPLOYAL | - | - | - | - | - | - | - | - | | HUMAN RESOURCES | EGI | NEM3N | Total | | | 512,679 | 66,353 | 579,032 | 574,964 | 4,068 | - | (4,068) | - | | HUMAN RESOURCES | EGI | NEM7S | C1PPPHR880E | PV HOR (Human Cap Reject) (sight | EMPLOYAL | 15,835 | 1,871 | 17,706 | 16,858 | 848 | (848) | - | - | | HUMAN RESOURCES | EGI | NEM7S | PSPCHRENUC | HR 50FICES - ENASC - ALL | DIRCTENG | 68,298 | 9,407 | 77,705 | 77,705 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM7S | PSPCHREDAX | HUMAN RESOURCS SONICES - EOI | DIRCTECS | 59,924 | 9,405 | 79,330 | 79,330 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM7S | PSPCHRSALL | HR 50FICES ALL COMPANES | EMPLOYAL | 6,861 | - | 6,861 | 6,541 | 320 | - | (320) | - | | HUMAN RESOURCES | EGI | NEM7S | PSPPEQWK91 | HR - EQUINSIX | DIRCTENG | 6,731 | - | 6,731 | 6,731 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM7S | PSPPWRTFRW | HR Transformation - Odd Code | EMPLOYAL | 71,756 | 8,206 | 79,961 | 76,134 | 3,828 | - | (3,828) | - | | HUMAN RESOURCES | EGI | NEM7S | PSPPFALCON | Project Falson | DIRECTNI | 477 | - | 477 | 477 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM7S | PSPPWRYPPTN | Project Program | DIRECT14 | 27,646 | 4,404 | 32,050 | 32,050 | - | - | - | - | | HUMAN RESOURCES | EGI | NEM7S | Total | | | 267,526 | 33,294 | 300,820 | 295,824 | 4,996 | (848) | (4,147) | - | | HUMAN RESOURCES | EGI | NEM50 | PSPCHRSALL | HR 50FICES ALL COMPANES | EMPLOYAL | 307 | - | 307 | 292 | 14 | - | (14) | - | | HUMAN RESOURCES | EGI | NEM50 | Total | | | 307 | - | 307 | 292 | 14 | - | (14) | - | | HUMAN RESOURCES | Total EGI | | | | | 124,999,535 | 1,632,240 | 126,631,775 | 115,390,709 | 11,241,066 | (1,728,946) | (139,153) | 9,372,966 | | Total HUMAN RESOURCES | | | | | | 124,992,183 | 1,632,240 | 126,624,423 | 115,390,709 | 11,233,713 | (1,728,625) | (139,106) | 9,365,982 |

ENTERGY TEXAS, INC.

Affiliate Billings - by Witness, Class, Department and Project For the Twelve Months Ended June 30, 2011 Amounts in Dollars

| Class | Billing
Entity | Pro Forma Number | Pro Forma Description | Supporting Witness | Pro Forma | | :--: | :--: | :--: | :--: | :--: | :--: | | HUMAN RESOURCES | EAI | AJ22 | Affiliate Portion of Employee Changes and Wage Increases | Considine, Michael P | 79 | | | EAI | | | | 79 | | HUMAN RESOURCES | EGSLA | AJ22 | Affiliate Portion of Employee Changes and Wage Increases | Considine, Michael P | (32) | | | EGSLA | | | | (32) | | HUMAN RESOURCES | ELL | AJ22 | Affiliate Portion of Employee Changes and Wage Increases | Considine, Michael P | 1 | | | ELL | | | | 1 | | HUMAN RESOURCES | EMI | AJ22 | Affiliate Portion of Employee Changes and Wage Increases | Considine, Michael P | (0) | | | EMI | | | | (0) | | HUMAN RESOURCES | ESI | AJ16 | Remove MI50 Costs | Considine, Michael P | $(17,878)$ | | HUMAN RESOURCES | ESI | AJ18 | Affiliate Portion of Interest Expense | Considine, Michael P | - | | HUMAN RESOURCES | ESI | AJ21-03 | Remove Rate Case Support Costs | Considine, Michael P | $(162,558)$ | | HUMAN RESOURCES | ESI | AJ21-04 | PwC - Changes in Billing Methods | Tumminello, Stephanie B | 388 | | HUMAN RESOURCES | ESI | AJ21-05 | Remove Toilet Costs | Barrilleaux, Chris | $(1,677)$ | | HUMAN RESOURCES | ESI | AJ21-07 | Remove Non-Recoverable Costs | Barrilleaux, Chris | $(5,394)$ | | HUMAN RESOURCES | ESI | AJ21-10 | Remove Nuclear Costs | Barrilleaux, Chris | $(8,230)$ | | HUMAN RESOURCES | ESI | AJ21-11 | Correct Capital Projects | Tumminello, Stephanie B | 47,902 | | HUMAN RESOURCES | ESI | AJ21-14 | Billing Method change for Project F3PCTDOR01 | Tumminello, Stephanie B | 988 | | HUMAN RESOURCES | ESI | AJ22 | Affiliate Portion of Employee Changes and Wage Increases | Considine, Michael P | 7,307 | | | ESI | | | | $(139,153)$ | | HUMAN RESOURCES | Total | | | | $(139,106)$ | | Total | | | | | $(139,106)$ |

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SOAH DOCKET NO. 473-12-2979 PUC DOCKET No. 39896

APPLICATION OF ENTERGY ..... § TEXAS, INC. FOR AUTHORITY TO ..... § CHANGE RATES, RECONCILE ..... § FUEL COSTS, AND OBTAIN ..... § DEFERRED ACCOUNTING ..... § TREATMENT ..... §

REBUTTAL TESTIMONY OF KEVIN G. GARDNER ON BEHALF OF ENTERGY TEXAS, INC.

ENTERGY TEXAS, INC.
REBUTTAL TESTIMONY OF KEVIN G. GARDNER PUC DOCKET NO. 39896

TABLE OF CONTENTS

| | | Page | | :-- | :-- | --: | | I. | Introduction | 1 | | II. | Incentive Compensation | 2 | | III. | Allegations Regarding Base Pay and Benefits Levels | 10 | | IV. | Supplemental Executive Retirement Benefits Plans | 14 | | V. | Relocation Costs | 17 |

Entergy Texas, Inc. Page 1 of 18 Rebuttal Testimony of Kevin G. Gardner Docket No. 39896 I. INTRODUCTION 2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 3 A. My name is Kevin G. Gardner. My business address is 639 Loyola 4 Avenue, New Orleans, Louisiana 70113. 5 6 Q. DID YOU PREVIOUSLY FILE DIRECT TESTIMONY ON BEHALF OF ENTERGY TEXAS, INC. ("ETI" OR "THE COMPANY") IN THIS 8 PROCEEDING? 9 A. Yes, I did. 10 11 Q. WHAT IS THE PURPOSE OF YOUR REBUTTAL TESTIMONY? 12 A. The purpose of my rebuttal testimony is to address issues raised in the Direct Testimonies of Public Utility Commission of Texas ("Commission" or "PUCT") Staff witness Anna Givens, Cities witness Mark Garrett, and Texas Industrial Energy Consumers ("TIEC") witness Jeffry Pollock regarding ETI's requested recovery of its incentive compensation costs. I also address Mr. Garrett's recommendations to disallow amounts associated with allegedly above-market base pay and employee benefits. Finally, I address the recommendations of Mr. Garrett and Office of Public Utility Counsel ("OPUC") witness Carol Szerszen to disallow the supplemental retirement benefits costs included in ETI's cost of service.

Entergy Texas, Inc. Page 2 of 18 Rebuttal Testimony of Kevin G. Gardner Docket No. 39896 II. INCENTIVE COMPENSATION Q. DO YOU HAVE ANY OVERALL OBSERVATIONS ON THE PROPOSED

3 TREATMENT OF THE COMPANY'S INCENTIVE COMPENSATION BY 4 OTHER PARTIES? A. Yes. The Staff, Cities, and TIEC propose significant disallowances for the 6 Company's incentive compensation programs. In some instances, their 7 recommendations exceed the treatment of these types of costs in prior 8 PUCT proceedings. The Company's incentive programs play an important 9 role in serving ETI's customers. Primarily, the Company's incentive 10 programs achieve the following indispensable goals:

11 1. Allow the Company to attract and retain reliable, experienced, and 12 highly trained employees who ensure that ETI provides safe and 13 reliable electric service to our customers. 2. Maintain compensation within reasonable market levels by 15 establishing a balanced portfolio of "at risk" incentives to be paid 16 only when established customer-focused goals are met. 3. Ensure "at risk" compensation is only delivered when performance 18 goals are met and allow the Company's total compensation costs to 19 be more directly tied to performance. 20 4. Create safety, operational, customer, and cost control goals that 21 help establish a clear line of sight between employees and the 22 customers they serve.

For these reasons and as detailed in my direct testimony, the Commission should further evaluate its stance in general on incentive compensation. The Company has attempted to resolve many of the concerns raised in those prior proceedings by changing the annual incentive program for the majority of employees to be even more customer focused. This "line of sight" between employees and current annual incentive goals, which focus on safety, operational, and cost control, provide an increased benefit to its customers. My direct testimony and that of Company witness Dr. Jay Hartzell explained these changes and provided additional evidence on the customer benefits of all incentive compensation.

| 13 | Q. | PLEASE SUMMARIZE STAFF AND INTERVENOR WITNESS | | :--: | :--: | :--: | | 14 | | RECOMMENDATIONS FOR ETI'S INCENTIVE COMPENSATION | | 15 | | COSTS. | | 16 | A. | In her pages 15-22, Staff witness Givens recommends that portions of the annual and long-term incentive compensation costs tied to financial goals should be disallowed. She calculates a total of $\backslash$ 5,609,093$ in such costs. | | 19 | | As summarized on his page 45, TIEC witness Pollock recommends a $\backslash$ 6.2$ million disallowance for costs related to annual and long-term incentive compensation plan goals that are tied to financial measures. | | 21 | | Mr. Pollock bases his proposed disallowance on Commission precedent of disallowing incentive compensation based on financial measures. |

| 1 | As detailed in Table 3 on his page 49, Cities witness Garrett | | :--: | :--: | | 2 | recommends removing 100\% of ETI's costs related to the Company's | | 3 | long-term incentive compensation because all of these programs are tied | | 4 | to "financial" goals. He also recommends removing 35\% of the costs of | | 5 | each of the Company's annual incentive plans based on his determination | | 6 | that $35\%$ of the goals used in these plans are "financial" in nature. | | 7 | Further, he recommends on his pages 52-53 that the pro forma rate base | | 8 | should be decreased by $\backslash$ 9,835,111$ for capitalized annual and long-term | | 9 | incentive compensation costs going back as far as January 2008 related | | 10 | to "financial" goals. Finally, Mr. Garrett asserts on his pages 50-51 that | | 11 | the Commission might consider disallowing all of ETI's incentive | | 12 | compensation costs because the Company uses the Entergy Achievement | | 13 | Multiplier ("EAM") as a funding mechanism as part of its annual incentive | | 14 | compensation plans. | | 15 | | | 16 | Q. DO YOU AGREE THAT INCENTIVE COMPENSATION COSTS | | 17 | RELATED TO FINANCIAL GOALS SUCH AS PROFITIBILITY AND | | 18 | STOCK PRICE SHOULD BE DISALLOWED BY THE COMMISSION? | | 19 | A. No. The Company should be able to recover its financially related | | 20 | incentive compensation costs because (1) customers benefit from these | | 21 | costs and goals, (2) such costs are a necessary business expense, and | | 22 | (3) the Company's level of such costs was reasonable. Because they are | | 23 | necessary, reasonable, and benefit customers, the Company's financially |

| 1 | related incentive compensation costs should be recoverable whether such | | :--: | :--: | | 2 | costs are related to the Company's annual incentive plans, long-term | | 3 | incentive plans, or the Company's capital costs. | | 4 | | | Q. | HOW DO CUSTOMERS BENEFIT FROM FINANCIALLY BASED GOALS | | 6 | SUCH AS PROFITIBILITY AND STOCK PRICE? | | 7 | Having incentive compensation related to financial goals is standard for | | 8 | companies such the Entergy Companies, and the Entergy Companies | | 9 | must offer competitive incentive compensation programs in order to | | 10 | compete and retain talented employees. Customers benefit from a utility | | 11 | that attracts and retains qualified personnel. Further, having only | | 12 | operational and safety goals in the incentive compensation plans could | | 13 | encourage utility personnel to overspend in some areas and would result | | 14 | in an unbalanced incentive compensation program. Customers benefit by | | 15 | having the utility personnel balance the operational/safety goals with | | 16 | financial goals. The direct testimony of Company witness Hartzell | | 17 | identifies other important benefits to customers. |

Entergy Texas, Inc. Page 6 of 18 Rebuttal Testimony of Kevin G. Gardner Docket No. 39896 1 Q. ON HIS PAGES 47-48, MR. GARRETT RECOMMENDS DISALLOWANCE OF ALL INCENTIVE COMPENSATION EXPENSES THAT ARE BASED ON COST CONTROL MEASURES. DO YOU AGREE WITH THIS RECOMMENDATION? A. No, rejecting incentive compensation linked to cost control measures is short-sighted and ignores the benefits to customers that result from these measures. It is difficult to accept that the Commission would penalize a utility's efforts to foster cost control as a goal. Neither TIEC witness Pollock nor Staff witness Givens seeks to disallow incentive costs tied to cost control measures. Mr. Garrett even admits on his page 31, line 6 that incentive plans that motivate employees to achieve increased cost control efficiencies should be encouraged. The Commission should encourage cost control efficiencies by allowing the Company to recover its incentive compensation costs related to cost control goals. Q. PLEASE EXPLAIN THE NATURE OF THE COST CONTROL MEASURES AND HOW CUSTOMERS BENEFIT FROM THOSE GOALS. A. The Entergy Companies' cost control goals focus on the customer by encouraging increased productivity and improved efficiencies in operational performance. Almost every business, non-profit organization, governmental agency, and household uses a budget as a tool to meet its cost control objectives. Customers benefit from cost control goals in multiple ways:

| 1 | When the cost control efforts affect fuel, purchased power | | :--: | :--: | | 2 | energy, and energy efficiency costs, customers are directly | | 3 | benefited through the periodic adjustment of the rates that | | 4 | recover these costs and the Commission-prescribed | | 5 | reconciliations of those costs. | | 6 | When the cost control efforts relate to capital projects, | | 7 | customers are directly benefitted when those costs are | | 8 | incorporated into the utility's rate base. | | 9 | When cost control measures relate to other O&;M costs during a | | 10 | test year, customers are directly benefitted in the rates set | | 11 | based upon that test year's costs. | | 12 | Cost controls measures related to non-test-year O&;M costs | | 13 | directly benefit customers because savings achieved in a | | 14 | particular year often carry over for several years, any one of | | 15 | which may be a test year. | | 16 | To exclude annual incentive costs based on cost control measures | | 17 | because of a difference in the timing of when a portion of these efforts | | 18 | may benefit shareholders versus customers is an extreme position that | | 19 | should be rejected. To the contrary, creating an environment where cost | | 20 | control by employees is encouraged every year is exactly what utilities | | 21 | should be doing. | | 22 | Further, the operational focus of cost control is directly linked to the | | 23 | customer. This is one reason why the Company has a major focus on |

| 1 | continuous improvement. This continuous improvement model energizes | | :--: | :--: | | 2 | the workforce to continually look for better ways to run the business more | | 3 | efficiently, which results in lower costs and customer bills. Our | | 4 | employees' focus is directed on the customer, not the shareholder, as the | | 5 | beneficiary of their cost savings, improved efficiencies, and process | | 6 | improvements. | | 7 | | | 8 | PLEASE DESCRIBE HOW THE CONTINOUS IMPROVEMENT MODEL | | 9 | IS IMPLEMENTED AT ETI AND HOW IT TIES COST CONTROL TO | | 10 | CUSTOMER INTEREST. | | 11 | Entergy's continuous improvement model encourages employees to look | | 12 | at their daily activities and implement changes to streamline processes | | 13 | and eliminate unnecessary processes. The intent is that these improved | | 14 | activities will result in increased productivity and efficiencies that will | | 15 | ultimately benefit our customers. | | 16 | | | 17 | ON PAGE 39, MR. GARRETT PURPOSETS TO EXPLAIN THE | | 18 | IMPORTANCE OF THE DISTINCTION BETWEEN FINANCIAL | | 19 | PERFORMANCE MEASURES AND OPERATIONAL MEASURES. DO | | 20 | YOU AGREE WITH HIS ANALYSIS? | | 21 | No. In terms of their benefit to customers, I firmly disagree with the | | 22 | position that there is a meaningful distinction between "financial" | | 23 | performance incentive targets and "operational" incentive performance |

| 1 | targets. The earnings or net income encouraged by financial targets are specifically and directly the product of employee efforts to control or manage costs, operate efficiently and improve efficiency, and to provide strong customer service. Improved earnings are achieved by better margins - i.e., more efficient operations, by improved performance and cost management. The critical goal of incentives is to obtain these improved margins without sacrificing quality of service. That is what a balanced incentive program achieves. | | :--: | :--: | | 9 | | | 10 | Q. WHAT DOES MR. GARRETT RECOMMEND IN HIS ANALYSIS OF THE EAM AND THE ANNUAL INCENTIVE PLANS? | | 12 | A. On his pages 50-51, Mr. Garrett's relies on the use of the EAM as the basis for the possible disallowance of all annual incentive payments. | | 14 | | | 15 | Q. IS IT REASONABLE TO DISALLOW INCENTIVE COMPENSATION COSTS BECAUSE THE OVERALL FUNDING MECHANISM (THE EAM) IS FINANCIAL IN NATURE? | | 18 | A. No. It only makes common sense, from the Company's and customers' perspective, to ensure that the Company is able to afford to pay out the annual incentive payments before it does so. Funding mechanisms within incentive plans such as the EAM simply support the Company's financial capacity to pay for operational performance-based programs. The benefits that the ratepayers receive from the operational-based goals in |

the incentive compensation plans are in no way diminished by the fact that the Company requires a funding mechanism to ensure its capability to pay out incentives.

Lack of prudent financial controls would not be in the best interest of the Company's customers, employees, or shareholders. All companies, whether categorized as regulated utilities or general industries, must employ sound financial management.

Q. DO YOU AGREE WITH MR. GARRETT'S STATEMENTS ON HIS

PAGES 49-50 AND 52 THAT AN EVEN LARGER DISALLOWANCE OF INCENTIVE COMPENSATION COSTS MAY BE MERITED BY THE COMPANY'S LEVELS OF CUSTOMER SATISFACTION? A. No, as explained in the rebuttal testimony of Company witness Vernon Pierce, the facts support the exact opposite result.

III. ALLEGATIONS REGARDING BASE PAY AND BENEFITS LEVELS Q. PLEASE DESCRIBE THE TESTIMONY OF MR. GARRETT REGARDING ABOVE-MARKET BASE PAY. A. On his pages 25-27, Mr. Garrett alleges that the Company's base pay levels are $2\%$ above market. He then asserts that ratepayers should only be asked to pay the necessary market-based price for employee pay, and he recommends a $2\%$ downward adjustment to base pay costs to "bring the Company's base pay down to a market-based level."

Entergy Texas, Inc. Page 11 of 18 Rebuttal Testimony of Kevin G. Gardner Docket No. 39896 Q. DO YOU AGREE WITH HIS ALLEGATIONS AND RECOMMENDATION? A. No. The Company's base pay is not $2\%$ above market. The Company's test year base pay was $2\%$ above market median. For the reasons explained below, being "at market" means being within a reasonable range, such as $+/-10\%$ , of the market median; therefore, the Company's base pay levels are at market. ^[1] As indicated in my direct testimony, the Entergy Companies have established a pay philosophy that is competitive with the market. The Entergy Companies focus wages on a reasonable range around the ${50}^{\text{th}}$ percentile of the market. That is the point at which half the companies in the surveys pay total annual compensation that exceeds the market's total annual compensation midpoint and half the companies in the surveys pay less than the market's total annual compensation midpoint. The Entergy Companies consider this to be a competitive but reasonable pay philosophy. To obtain market data, the Entergy Companies participate in well- established and highly-regarded surveys from providers such as Towers Watson, Mercer and AON Hewitt (formerly, Hewitt Associates). However, no two jobs, even within the same organization, are likely to be identical, much less between organizations. There are many jobs that cannot be matched at all and must be slotted internally. The details of the survey

| 1 | data can vary among participating organizations. As a result, | | :--: | :--: | | 2 | benchmarking jobs to the market is an inexact science. | | 3 | Although benchmarking has its place in compensation analyses, | | 4 | and is commonly used by HR departments and professionals, there are | | 5 | differences in how companies match job responsibilities with job titles and | | 6 | in how companies complete the compensation survey information. These | | 7 | limitations do not invalidate benchmark comparisons of compensation | | 8 | levels, but they do add an element of imprecision to any comparison of | | 9 | compensation by job title. | | 10 | With this in mind, when using a benchmark analysis to compare | | 11 | companies' levels of compensation, it is advisable to view the market level | | 12 | of compensation as a range (e.g., $+/-10\%$ of a mid-point) rather than a | | 13 | precise, single point. Market data for numerous positions move from year | | 14 | to year, so the Entergy Companies see annual compensation of $+/-10\%$ of | | 15 | market median as both a reasonable and necessary expense to provide | | 16 | service to the public. This approach is not just an Entergy Companies' | | 17 | point of view, but one commonly used by compensation consultants. |

| 1 | Q. | PLEASE | DESCRIBE | THE | ALLEGATIONS | OF | MR. | GARRETT | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | 2 | | REGARDING | ABOVE-MARKET | BENEFITS. | | | | | | 3 | A. | On his pages | 58-59, Mr. Gar | t states that the value of the Company's | | | | | | 4 | | employment benefit plans is | $14\%$ above market when compared to a peer group of Fortune 500 companies. He then asserts that ratepayers should | | | | | | | 6 | | only be asked to pay the market-based price for employee costs, and | | | | | | | | 7 | | recommends a 14\% downward adjustment to the Company's employee benefits expense. | | | | | | | | 9 | | | | | | | | | | 10 | Q. | DO | YOU AGREE | WITH MR. | GARRETT'S | ALLEGATIONS AND | | | | 11 | | | | | | | | | | 12 | A. | No. The value of the Company's benefits plans is not 14\% above market. | | | | | | | | 13 | | Table 6 on page 42 of my direct testimony shows that the value of the | | | | | | | | 14 | | Entergy Companies' benefits plans is only 1\% above the market median of | | | | | | | | 15 | | the peer group of utility companies. As noted with regard to base pay, | | | | | | | | 16 | | being "at market" means being within 10\% of the market median; therefore | | | | | | | | 17 | | the Company's benefits levels are at market with regard to its peer group | | | | | | | | 18 | | of utility companies. ^[2] Even if one gives equal weight to the reported | | | | | | | | 19 | | benefits plan values of the Fortune 500 companies and the peer utilities, | | | | | | | | 20 | | the value of the Company's benefit plans is at market. Moreover, the peer | | | | | | | | 21 | | group of utility companies provides a more appropriate comparison for the | | | | | | | | 22 | | Company's benefits plans because utilities often need to attract more | | | | | | |

| 1 | long-term employees than Fortune 500 companies, such as the nation's | | :--: | :--: | | 2 | large retail companies. Experienced, long-term employees are needed to | | 3 | operate and manage the utility infrastructure. Employee retention is thus | | 4 | a particularly important issue for utilities, and benefits plans play an | | 5 | important role in achieving strong retention rates. Accordingly, the | | 6 | Company's benefit plan levels are well within a reasonable range, and no | | 7 | disallowance should be required. | | 8 | | | 9 | IV. SUPPLEMENTAL EXECUTIVE RETIREMENT BENEFITS PLANS | | 10 | Q. PLEASE DESCRIBE THE ISSUE RAISED BY THE STAFF, CITIES AND | | 11 | OPUC WITNESSES REGARDING SUPPLEMENTAL EXECUTIVE | | 12 | RETIREMENT PLANS. | | 13 | A. The Company provides three types of supplemental executive retirement | | 14 | plans that are addressed by Staff witness Givens, Cities witness Garrett | | 15 | and OPUC witness Szerszen. The plans include the Pension Equalization | | 16 | Plan, the Supplemental Retirement Plan, and the System Executive | | 17 | Retirement Plan. The plans are further described in Schedule G-2 to the | | 18 | Company's Rate Filing Package. Ms. Givens recommends, on her pages | | 19 | 22-23, and Mr. Garrett recommends, on his page 55, a disallowance of | | 20 | both ETI and ESI-billed costs for these programs, quantifying the total | | 21 | amount as $\backslash$ 2,114,931 .{ }^{3}$ Dr. Szerszen recommends a disallowance of the |

| 1 | portion of these costs allocated from ESI to ETI, which she quantifies at $\backslash$ 1,391,861 .{ }^{4}$ Mr. Garrett argues that these costs are not necessary to provide utility service but are instead discretionary payments that should be funded by shareholders. Dr. Szerszen contends that ETI has not shown that these costs are necessary to provide utility service, and that the ESI allocation method is unjustified. Ms. Givens describes the payments as excessive. I disagree with each of these contentions. | | :--: | :--: | | 8 | | | 9 | Q. WHY ARE THE COSTS OF THESE PLANS REASONABLE AND NECESSARY? | | 11 | A. Supplemental executive retirement plans are established for the purpose of attracting, retaining, and motivating highly competent and qualified leaders. In particular, the Pension Equalization Plan provides supplemental retirement benefits to account for the fact that Internal Revenue Code regulations limit the level of retirement benefits that qualify for tax treatment favorable to ETI and Entergy Corporation. The existence of this supplemental benefit program allows the Company to pay retirement benefits to these employees that are proportionate to the compensation they receive while active in their employment. | | 20 | In addition, the Supplemental Retirement Plan and the System Executive Retirement Plan provide supplemental benefits beyond the |

| 1 | amounts restricted in the qualified plan to some participants to attract, | | :--: | :--: | | 2 | retain, and motivate employees. | | 3 | These retirement benefits are widely provided by companies within | | 4 | the utility business sector. Accordingly, ETI needs to offer them in order to | | 5 | be competitive in the employment market with peer companies, and | | 6 | thereby to retain and adequately compensate these employees in terms of | | 7 | future retirement benefits. For these reasons, I conclude that the costs to | | 8 | ETI of these plans are reasonable and necessary. | | 9 | | | 10 | Q. OPUC WITNESS SZERSZEN SUGGESTS THAT AN ADDITIONAL | | 11 | REASON TO DENY RECOVERY OF ESI AFFILIATE CHARGES FOR | | 12 | SUPPLEMENTAL RETIREMENT BENEFITS IS THAT THERE IS NO | | 13 | CAUSAL RELATIONSHIP BETWEEN THESE TYPES OF COSTS AND | | 14 | THE ALLOCATION METHOD USED TO BILL ETI ITS SHARE. WHICH | | 15 | COMPANY WITNESSES ADDRESSES THIS ISSUE? | | 16 | A. Company witness Stephanie B. Tumminello addresses this issue. |

Entergy Texas, Inc. Page 17 of 18 Rebuttal Testimony of Kevin G. Gardner Docket No. 39896

1 V. RELOCATION COSTS

2 Q. WHAT IS MS. GIVENS' POSITION ON EMPLOYEE RELOCATION ASSISTANCE, AND DO YOU AGREE WITH HER 4 RECOMMENDATION? A. On her page 24, Staff witness Givens recommends that this type of expense be disallowed based on their removal from cost of service in Lower Colorado River Authority Docket No. 28906 and the level of ETI's annual compensation. I disagree with her recommendation. Finding of Fact No. 86 in the Commission's final order in Docket No. 28906 states that "LCRA's wages are competitive, thus a bonus or moving allowance is not necessary to attract quality personnel." For the employee market in which ETI operates, however, most peer companies offer moving assistance. Such assistance is expected by employees, and the Company would be placed at a competitive disadvantage if it did not offer it.

Further, though Ms. Givens points to the Company's level of annual compensation as a basis for disallowing this benefit cost, she sought to disallow no other benefits costs. Just as the Company's level of compensation does not merit disallowing medical and dental benefits costs, it does not merit disallowing relocation cost benefits if the level of such costs is reasonable. Ms. Givens does not dispute the reasonableness of the amount. In fact, as I indicated by my direct

Entergy Texas, Inc. Rebuttal Testimony of Kevin G. Gardner Docket No. 39896

1 testimony on page 46, the Entergy Companies' average relocation assistance amounts during the test year were reasonable when compared to 2010 industry average relocation costs as reported by the

4 Employee Relocation Council. Recovery of this expense should be authorized. ^[1]

6

7 Q. DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY? 8 A. Yes.

DOCKET NO. 39896

APPLICATION OF ENTERGY TEXAS, INC. FOR AUTHORITY TO CHANGE RATES AND RECONCILE FUEL COSTS § PUBLIC UTILITY COMMISSION $\S$ $\S$ $\S$

DIRECT TESTIMONY

OF

JAY C. HARTZELL, Ph.D.

ON BEHALF OF

ENTERGY TEXAS, INC.

NOVEMBER 2011

ENTERGY TEXAS, INC.
DIRECT TESTIMONY OF JAY C. HARTZELL, Ph.D. 2011 RATE CASE

TABLE OF CONTENTS

| | | Page | | :--: | :--: | :--: | | I. | Background and Introduction | 1 | | II. | Overview of the Issues Surrounding Incentive Compensation | 3 | | III. | The False Dichotomy Between Compensation Tied to "Financial" Measures and Compensation Tied to "Operational" Measures; and the Benefits of Cost Control, Profitability, and Stock Price Measures | 9 | | IV. | Costs to Customers of Discouraging the Use of Incentive Compensation That is Linked to Cost Control, Profitability and Stock Prices | 22 | | V. | Response to Common Arguments Against Incentive Compensation Linked to Cost Control, Profitability and Stock Prices from the Customers' Perspective | 28 | | VI. | Conclusion | 31 |

EXHIBITS

EXHIBIT JCH-1 Curriculum Vitae of Jay C. Hartzell

Entergy Texas, Inc. Page 1 of 31 Direct Testimony of Jay C. Hartzell, PhD. 2011 Rate Case

1 I. BACKGROUND AND INTRODUCTION Q. PLEASE STATE YOUR NAME, TITLE, AND BUSINESS ADDRESS. A. My name is Jay C. Hartzell. I am the Chair of the Finance Department, Professor of Finance, and the Allied Bancshares Centennial Fellow at the McCombs School of Business at the University of Texas at Austin. My business address is Department of Finance, The University of Texas at Austin, 1 University Station B6600, Austin, Texas 78712.

8 Q. ON WHOSE BEHALF ARE YOU TESTIFYING? A. I am testifying on behalf of Entergy Texas, Inc. ("ETI" or the "Company"). Q. PLEASE STATE YOUR EDUCATION, PROFESSIONAL AND WORK EXPERIENCE. A. I obtained a Bachelor of Science degree (cum laude) from Trinity University in May 1991, with majors in Business Administration and Economics. After graduating, I went to work as a consultant for Hewitt Associates in The Woodlands, Texas. Hewitt is a consulting firm that specializes in benefits and compensation. While there, I specialized in the area of defined contribution plans. I left Hewitt to go to graduate school at the University of Texas at Austin in 1993. I completed my PhD in finance there in May 1998. Upon graduating, I took a job as an Assistant Professor of Finance at New York University's Stern School of Business, where I worked until 2001. At that time, the University of Texas at Austin

hired me as an Assistant Professor at the McCombs School of Business ("McCombs School"), where I have worked since. I was promoted to the rank of Associate Professor (with tenure), effective in the fall of 2006. Beginning in the fall of 2008, I was given the title of Allied Bancshares Centennial Fellow. I also now serve as the Executive Director of the Real Estate Finance and Investment Center at the McCombs School. As of September 2011, I was promoted to Professor and assumed the duties of the Chair of the Finance Department. My current curriculum vitae is attached as Exhibit JCH-1.

11 Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE A REGULATORY COMMISSION?

13 A. Yes. I have submitted written testimony on incentive compensation issues and testified on behalf of the Company before the Public Utility Commission of Texas ("Commission" or "PUCT") in PUCT Docket Nos. 34800 and 37744, and on behalf of Entergy Louisiana, LLC before the Louisiana Public Service Commission on incentive compensation issues in Docket No. U-20925. I have also submitted written testimony on behalf of Entergy Arkansas, Inc. before the Arkansas Public Service Commission on incentive compensation issues in Docket No. 09-084-U.

| 1 | II. OVERVIEW OF THE ISSUES SURROUNDING INCENTIVE COMPENSATION | | :--: | :--: | | 3 | Q. WHAT FORMS OF INCENTIVE COMPENSATION DO YOU FOCUS ON IN YOUR TESTIMONY? | | 5 | A. The focus of my testimony is on incentive compensation that is linked to | | 6 | cost control measures (for operating costs and capital expenditures), | | 7 | profitability measures (including earnings and operating cash flow), and | | 8 | stock prices. Compensation that is linked to these sorts of measures - for | | 9 | companies generally and for ETI in particular - include annual incentive | | 10 | plans, long-term incentive plans, restricted stock grants, and stock option | | 11 | grants. The compensation could come in the form of cash (as in annual | | 12 | incentive plans), stock or stock-based units (as in ETI's long-term | | 13 | incentive plan, or "LTIP"), or options. | | 14 | | | 15 | Q. WHAT IS YOUR UNDERSTANDING OF HOW COMPENSATION BASED | | 16 | ON COST CONTROLS, PROFITABILITY AND STOCK PRICES HAS | | 17 | BEEN CHARACTERIZED IN RECENT PUCT RATE DECISIONS? | | 18 | A. In such cases, compensation that is linked to cost controls, profitability | | 19 | and stock prices as discussed in the previous question has commonly | | 20 | been referred to as incentive compensation that is based on "financial | | 21 | measures." This category of incentives has been distinguished from | | 22 | incentive compensation that is based on measures that are not | | 23 | denominated in dollars, such as customer satisfaction, reliability, and |

safety metrics, which has commonly been categorized as incentive compensation based on "operational measures." As I discuss later in my testimony, I view this as a false dichotomy for the purposes of assessing whether customers benefit from a particular form of incentive compensation.

Q. WHY DO FIRMS USE INCENTIVE COMPENSATION IN GENERAL, AND COMPENSATION BASED ON COST CONTROLS, PROFITABILITY AND STOCK PRICES MORE SPECIFICALLY?

A. Incentive compensation is a prevalent tool used to attract, motivate, and retain the qualified and talented employees needed to ensure that a business can continue to operate successfully. To understand why it is so widely used, it is first useful to draw a distinction between the level and form of compensation. The level of compensation can be thought of as the total dollar value of compensation received by an employee from all sources, including salary, cash incentive-based pay, the value of long-term incentives such as stock performance units and options granted, and the value of benefits. In order to attract and retain employees, this level needs to be in line with the labor market for a particular type of employee, whether it is an engineer, a maintenance worker, or a chief executive officer. Otherwise, all things equal, that same employee will take a job with a company that is offering the more attractive level of pay

and benefits. Company witness Kevin G. Gardner discusses the overall reasonableness of ETI's level of compensation in his direct testimony.

Q. HOW DOES THE FORM OF COMPENSATION DIFFER FROM THE LEVEL OF COMPENSATION?

A. The form of compensation can be thought of as the split of total compensation across these components - for example, how much is paid via salary versus annual incentive-based compensation. Holding the total level of compensation fixed at the proper market level, the form of compensation is important because it can help motivate employees to engage in behaviors that positively impact the operational efficiency of the firm, or positively affect its cost structure. At the same time, the form of compensation is important to attract and retain certain types of employees that offer a skill set or a particular talent that is important to the company's operations. For example, if a compensation plan provides for incentive payments if goals are met - such as controlling costs at some level - then according to basic economic theory, employees will be motivated to work harder toward those goals. More subtly, such incentive pay will tend to attract and retain employees who believe that they are especially good at controlling costs because they will expect higher compensation under such a plan. This implies that a firm seeking to manage costs will find it valuable to institute such an incentive compensation plan as part of the

design of the form of compensation, while keeping the level of compensation at a competitive market-based amount.

Q. WHAT IS YOUR UNDERSTANDING OF THE COMMISSION'S

PREVIOUS VIEW ON ALLOWING THE RECOVERY OF INCENTIVE COMPENSATION EXPENSE THROUGH RATES? A. My understanding of the Commission's recent rulings on this issue is that the Commission has distinguished between compensation tied to what it has termed operational measures and compensation tied to what it has termed financial measures. Generally, the Commission has not allowed for the recovery of incentive compensation tied to financial measures through rates, but has allowed for the recovery of incentive compensation tied to operational measures. The core rationale for this distinction has been that it has not been sufficiently demonstrated that incentive compensation linked to financial measures is in the public interest or of direct benefit to customers. The decisions in those previous cases, however, do not reflect a review or consideration of the relevant literature or other matters I discuss below, all of which support a conclusion that allowing utilities to use incentive pay based on cost control, profitability, and stock prices is properly viewed as in the public interest and is expected to be of direct benefit to customers.

| 1 | Q. | HOW WOULD YOU SUMMARIZE YOUR OPINION ON THE ISSUE OF | | :--: | :--: | :--: | | 2 | | WHETHER INCENTIVE COMPENSATION BASED ON COST | | 3 | | CONTROLS, PROFITABILITY, AND STOCK PRICES BENEFITS | | 4 | | CUSTOMERS? | | 5 | A. | In my opinion, a well-designed compensation plan that includes incentive | | 6 | | compensation tied to cost controls, profitability, and stock prices would | | 7 | | tend to provide greater benefits to customers than an otherwise similar | | 8 | | compensation plan that did not include any such incentive compensation. | | 9 | | I discuss the details below, but the overarching basis for my opinion is as | | 10 | | stated above: incentive compensation based on cost control, profitability, | | 11 | | and stock prices helps companies attract, motivate, and retain talented | | 12 | | employees, and by doing so, both customers and shareholders directly | | 13 | | benefit. Moreover, if ETI's incentive compensation were only based on | | 14 | | non-dollar-based measures such as safety and reliability, customers | | 15 | | would tend to be worse off, because such a plan would not provide | | 16 | | employees with incentives to look after the financial health of the | | 17 | | Company. The important point is that customers and shareholders both | | 18 | | benefit from well-designed, balanced compensation plans that provide | | 19 | | employees with the appropriate level of compensation and that include | | 20 | | incentives based on cost control, profitability, stock prices, and | | 21 | | non-dollar-based measures such as reliability, safety and customer | | 22 | | satisfaction. |

| 1 | Q. | IS YOUR OPINION THAT CUSTOMERS WILL TEND TO BENEFIT FROM INCENTIVE COMPENSATION TIED TO COST CONTROLS, PROFITABILITY AND STOCK PRICES SUPPORTED BY EMPIRICAL EVIDENCE? | | :--: | :--: | :--: | | 5 | A. | Yes. As I discuss in more detail below, there are multiple studies published in peer-reviewed journals that report evidence that is consistent with my testimony. Published empirical research has shown that workers respond to incentive plans in a manner consistent with the intent behind the plans' design. Thus, if a company adopts a compensation plan that includes incentives based on customer welfare and stock price, one can expect managers to take actions to improve customer welfare and maximize stock price (holding all else equal). There is also empirical evidence that following the adoption of long-term incentive plans that provide for stock-based compensation, managers' interests appear more closely aligned with those of the firms' customers. In addition, there is evidence that stockholders' and customers' interests tend to be aligned, rather than opposed, suggesting that incentive compensation linked to stock prices is likely to improve customer satisfaction rather than detract from it. | | 6 | | |

| 1 | III. | THE FALSE DICHOTOMY BETWEEN COMPENSATION TIED TO "FINANCIAL" MEASURES AND COMPENSATION TIED TO "OPERATIONAL" MEASURES; AND THE BENEFITS OF COST CONTROL, PROFITABILITY, AND STOCK PRICE MEASURES | | :--: | :--: | :--: | | 5 | Q. | DO YOU AGREE WITH THE OPINION THAT INCENTIVE COMPENSATION LINKED TO WHAT THE COMMISSION HAS TERMED "FINANCIAL MEASURES" DOES NOT PROVIDE DIRECT BENEFITS TO CUSTOMERS? | | 9 | A. | No. Based on its previous rulings, the Commission appears to be categorizing as "financial" all incentive performance measures that have been labeled as such by the utility and that are based on dollar amounts. | | 11 | | These include not only measures such as earnings per share, but also measures designed to promote cost containment. ^[1] In reading these decisions and the debates among the parties discussed therein, much of the discussion seems to take it as given that incentives linked to financial (or dollar-based) measures, regardless of their specific characteristics, do | | 13 | | not benefit customers. As a result, the competing viewpoints reflected in these decisions seem to address mainly whether to label particular | | 16 | | measures as operational or financial. ^[2] | | 18 | | Instead of focusing on whether a particular measure is dollar-based or not - and therefore, whether incentives linked to that measure are "financial" or "operational" based on the above dichotomy - I think it is |

more worthwhile to return to the primary question: whether specific incentives linked to dollar-based measures (including cost control, profitability, and stock prices) are of benefit to customers.

Q. WHY WOULD INCENTIVE COMPENSATION LINKED TO COST CONTROL, PROFITABILITY, AND STOCK PRICE MEASURES BE OF DIRECT BENEFIT TO CUSTOMERS? A. This is the case because these measures provide a necessary and important incentive to managers to improve service and control costs. Perhaps the easiest example of a dollar-based measure that could be used in an incentive compensation plan that would benefit customers directly is cost containment. As an example, consider an incentive compensation plan that pays corporate managers an incentive award if costs are suitably contained. On the one hand, such an incentive is likely to benefit shareholders to some extent - managers who work under such a compensation plan will work to control costs in order to achieve their incentive compensation, and to the extent that they are successful, the company will generate greater profits, benefiting shareholders. But customers also directly benefit, because the company has lower costs, and through the regulatory process, customers will ultimately pay lower rates than they otherwise would have paid in the absence of such cost controls.

| 1 | Q. | WHAT IS THE ROLE OF THE REGULATORY PROCESS IN ENSURING | | :--: | :--: | :--: | | 2 | | THAT INCENTIVES LINKED TO COST CONTROL BENEFIT | | 3 | | CUSTOMERS? | | 4 | A. | To understand the role of the regulatory process in linking cost control to | | 5 | | customer benefit, first consider an extreme example where there is no | | 6 | | regulatory lag and rates adjust instantaneously so that any change in a | | 7 | | utility's costs is immediately passed through to customers. In this case, a | | 8 | | cost-containment incentive clearly directly benefits customers and does | | 9 | | not benefit shareholders at all because customers reap the entire benefit | | 10 | | of any cost-saving innovations. In the other extreme, if rates never adjust | | 11 | | to changes in costs, then a cost-containment incentive benefits | | 12 | | shareholders but not customers. Thus, the regulatory process plays the | | 13 | | critical role of sharing the gains from cost controls brought about by | | 14 | | managerial incentive compensation between customers and shareholders. | | 15 | | | | 16 | Q. | IS THIS POINT THAT CUSTOMERS BENEFIT FROM MANAGERIAL | | 17 | | EFFICIENCY A COMMONLY ACCEPTED TENANT OF UTILITY RATE | | 18 | | ECONOMICS? | | 19 | A. | Yes. This idea of a win-win scenario, where both shareholders and | | 20 | | customers benefit from managerial efficiency, is not new and is a core | | 21 | | idea at the heart of well-established principles of regulatory economics. | | 22 | | For example, James C. Bonbright discusses it in his seminal 1961 treatise | | 23 | | on utility economics, Principles of Public Utility Rates. |

| 1 | Q. | DO THESE PRINCIPLES APPLY TO OTHER FORMS OF INCENTIVE COMPENSATION THAT ARE LINKED TO PROFITABILITY AND STOCK | | :--: | :--: | :--: | | 2 | | | | 3 | | PRICE MEASURES? | | 4 | A. | Yes. While I think that cost containment measures are the most obvious example of incentives that have in some past PUCT cases been | | 5 | | | | 6 | | categorized as "financial" and yet directly benefit customers, these principles apply to other dollar-based or financial measures as well, such | | 7 | | | | 8 | | as incentive awards tied to corporate profitability and stock prices. | | 9 | | | | 10 | Q. | CAN YOU PLEASE FURTHER ELABORATE ON WHY CUSTOMERS ARE LIKELY TO BENEFIT FROM COMPENSATION THAT IS LINKED | | 11 | | ARE LIKELY TO BENEFIT FROM COMPENSATION THAT IS LINKED TO PROFITABILITY? | | 13 | A. | Yes. There is a direct link between cost containment and company earnings, especially for a regulated utility. Managers with an incentive to | | 14 | | | | 15 | | increase earnings will focus on controlling or cutting costs in a regulated | | 16 | | industry because it is more difficult to grow revenues. Additionally, the | | 17 | | same type of reasoning that supports a linkage between cost containment and customer benefit also applies to incentive measures that focus on | | 18 | | | | 19 | | containing capital expenditures. If managers can offer the same service | | 20 | | while cutting back on capital expenditures by investing more efficiently, | | 21 | | then shareholders benefit due to greater short-run cash flows for the company, and customers benefit through the regulatory process through | | 23 | | lower recovery for the cost of capital due to a lower capital base. |

| 1 | Q. | WHAT TYPE OF INCENTIVE COMPENSATION DO YOU INCLUDE | | :--: | :--: | :--: | | 2 | | WITHIN THE CATEGORY OF COMPENSATION THAT IS LINKED TO | | 3 | | STOCK PRICES? | | 4 | A. | This category would include most long-term incentive plans (including | | 5 | | ETI's) that use performance units that are based on stock prices, as well | | 6 | | as stock options. | | 7 | | | | 8 | Q. | CAN YOU BRIEFLY SUMMARIZE WHY YOU BELIEVE THAT | | 9 | | COMPENSATION THAT IS LINKED TO STOCK PRICES BENEFITS | | 10 | | CUSTOMERS? | | 11 | A. | Compensation that is linked to stock prices has several advantages for | | 12 | | customers as long as it is part of a reasonable, well-designed | | 13 | | compensation plan - in other words, as long as the total level of | | 14 | | compensation is reasonable compared to the market for similar positions | | 15 | | and the form of compensation is well balanced across dollar-based and | | 16 | | non-dollar-based measures. First, compensation that is linked to stock | | 17 | | prices helps ensure that managers will consider the financial health of the | | 18 | | company when they make decisions, and it is in customers' interests to | | 19 | | have the company continue to be financially healthy. Second, | | 20 | | stock-based compensation provides an incentive for managers and | | 21 | | employees to ensure that the company operates efficiently, and via the | | 22 | | regulatory process, lower costs result in lower rates than would otherwise | | 23 | | occur. Third, stock-based compensation provides a monitoring |

mechanism for managerial decision making and the overall quality of management. Fourth, there is an interaction between these effects, as the capital markets will tend to reward efficient long-term investments or capital expenditures that will also lead to lower costs for customers.

Q. DO THESE REASONS THAT COMPENSATION THAT IS LINKED TO STOCK PRICES BENEFITS CUSTOMERS ALSO APPLY TO COMPENSATION THAT IS LINKED TO COST CONTROL AND PROFITABILITY? A. In general, yes. Stock prices are driven in part by cost control and profitability, so to the extent that managers have an incentive to increase the stock price, they will also have an incentive to control costs and increase profits and cash flows, and vice versa. Of the reasons listed in the previous answer, the first two reasons - incentives to ensure that the company is financially healthy and that it operates efficiently - are the ones that are most closely shared by compensation based on cost control and profitability.

| 1 | Q. | STARTING WITH THE FIRST REASON YOU MENTIONED, WHY DOES | | :--: | :--: | :--: | | 2 | | COMPENSATION THAT IS LINKED TO PROFITABILITY AND STOCK | | 3 | | PRICES BENEFIT CUSTOMERS BY IMPROVING A COMPANY'S | | 4 | | FINANCIAL HEALTH? | | 5 | A. | If compensation that is linked to profitability and stock prices gives | | 6 | | managers an incentive to increase their company's earnings, cash flows, | | 7 | | and stock price, then this will also provide them with an incentive to | | 8 | | ensure that the company remains financially healthy. Stock prices of firms | | 9 | | that are in poor financial condition - for example, that have high debt | | 10 | | relative to the value of their assets - tend to be lower, all else being equal. | | 11 | | Similarly, firms in poor financial condition tend to have lower earnings and | | 12 | | operating cash flows. A stronger financial condition will also benefit | | 13 | | customers. If a company maintains a financially healthy position, it will | | 14 | | tend to have a lower cost of capital that will in turn benefit customers | | 15 | | through lower rates. For a discussion of this effect, see Chapter 15 of | | 16 | | Investment Valuation, by Aswath Damodaran. ^[3] In addition, the costs of | | 17 | | doing business with suppliers (of both goods and services, including labor) | | 18 | | will remain lower. For example, if a company was not in a financially | | 19 | | stable condition, suppliers would tend to demand higher prices or more | | 20 | | onerous credit terms, resulting in higher costs that would lead to higher |

1 rates than would otherwise occur. These are often termed "indirect costs of financial distress," and are a commonly accepted concept in finance.

3 Q. DOES EXISTING EMPIRICAL EVIDENCE SUPPORT THE OPINION THAT FINANCIALLY HEALTHY FIRMS WILL TEND TO FACE LOWER COSTS, WHICH WOULD BENEFIT CUSTOMERS OF A REGULATED UTILITY?

8 A. Yes. There is empirical evidence that firms with lower stock prices (or that are less financially healthy) face higher costs and greater risks. This includes work by researchers who have shown how less financially healthy companies have trouble responding to external shocks, and face higher costs of doing business (through higher wages or worse terms from suppliers, for example). ^[4] These results support the financial-health channel, by which stock-based incentive compensation should provide direct benefits to customers. Stock-based incentive compensation encourages managers to maintain a company's financial health, thus leading to more efficient operations and greater cost control than would otherwise occur.

Entergy Texas, Inc. Page 17 of 31 Direct Testimony of Jay C. Hartzell, PhD. 2011 Rate Case

1 Q. ARE THERE EXAMPLES OF EXTERNAL SHOCKS IN THE UTILITY 2 INDUSTRY THAT COULD MATERIALSY IMPACT A COMPANY'S 3 FINANCIAL HEALTH? A. One example of a large external shock is a severe storm or hurricane, such as Hurricanes Rita and Ike that, to my understanding, had significant financial impact on Entergy Companies. For example, Hurricane Ike was estimated to cause ETI to incur restoration costs between $\backslash$ 435 $millionand$ \ $510$ million. ^[5] The ability of a company to absorb such a shock without suffering from costs of distress depends on its financial health (e.g., their stock price, liquidity, and debt capacity). In this way, customers benefit from compensation that provides incentives for management to improve the firm's financial condition, because such incentives would tend to improve the firm's ability to withstand sizable negative events such as hurricanes, without incurring excessive additional costs of financial distress.

17 Q. CAN YOU FURTHER EXPLAIN HOW INCENTIVE COMPENSATION THAT IS LINKED TO PROFITABILITY AND STOCK PRICES CAN TEND TO LEAD TO LOWER COSTS FOR CUSTOMERS? A. The first step is to understand that compensation linked to profitability and stock prices will provide managers with an incentive to operate efficiently

| 1 | because, by doing so, a company's profitability (including earnings and | | :-- | :-- | | 2 | cash flow) and stock price will be higher than it would otherwise be. To | | 3 | increase stock price, management tries to maximize the present value of a | | 4 | company's expected cash flows by minimizing expenses and the cost of | | 5 | capital. The role of incentive compensation in motivating managers to | | 6 | minimize the cost of capital component and the associated benefits to | | 7 | customers were discussed earlier. A second channel provided by | | 8 | incentive compensation that can benefit customers is the incentive to | | 9 | maximize the company's cash flows. In a regulated environment, | | 10 | particularly one in which promotion of sales growth is discouraged, it is | | 11 | likely to be more difficult to increase cash flows or profits by growing | | 12 | revenues, so management will tend to focus on efficient operations and | | 13 | investment. | | 14 | These lower costs will benefit shareholders in the short run, but | | 15 | customers over the long run. This is due to the regulatory process that | | 16 | directly links operating costs to rates. | | 17 | | | 18 | Q. DO PUBLISHED EMPIRICAL STUDIES SUPPORT THE OPINION THAT | | 19 | FINANCIAL PERFORMANCE, INCLUDING STOCK PRICE, IS | | 20 | POSITIVELY RELATED TO CUSTOMER SATISFACTION GENERALLY, | | 21 | AND FOR UTILITY FIRMS IN PARTICULAR? | | 22 | A. Yes. There is empirical evidence in the literature that firms with higher | | 23 | market values tend to also have higher customer satisfaction, supporting |

the conclusion that the goals of financial success and customer satisfaction are interrelated. ^[6] This result has been shown for a broad sample of firms, but also for utilities in particular. This empirical finding is inconsistent with the idea that the most profitable or valuable firms become that way by cutting customer service, and instead suggests that there exists positive feedback between a firm's financial performance (stock price) and customers' welfare, even in the utility industry.

Q. HOW DOES COMPENSATION THAT IS LINKED TO STOCK PRICES

BENEFIT CUSTOMERS VIA THE MONITORING OF MANAGERIAL DECISIONS? A. One of the functions of the stock market and its various participants is to monitor companies' management. In their efforts to properly value stocks, analysts, portfolio managers, and traders follow companies and continually assess the various decisions, announcements, and pieces of information they produce. In doing so, they act as a monitoring device, ensuring that poor decisions would be punished by a falling stock price, so managers have incentives to invest the shareholders' financial resources efficiently. In this manner, managers help keep customers' costs lower

| 1 | short-term profit. ^[8] | Stock prices are based not just on a company's performance in the current year, but also on the market's expectations about a company's future performance over many years. This ensures that good investments tend to increase stock prices, even though those investments use cash today in order to produce greater cash flows in the future. This is a critical advantage of stock-based compensation over annual incentive plans that are based on a particular year's (or a few years') performance. Stock-based compensation can help overcome managerial myopia and provide managers with an incentive to make efficient, long-term investments that benefit both customers (due to efficient investments that lead to lower costs) and shareholders (due to higher cash flows). In this case, the testimony of Company witnesses Joseph F. Domino and Chris E. Barrilleaux addressing the Company's expected future capital investments, and that of Company witness Robert R. Cooper regarding long-term resource planning, provide examples of such consideration. | | :--: | :--: | :--: |

| 1 | IV. | COSTS TO CUSTOMERS OF DISCOURAGING THE USE OF | | :--: | :--: | :--: | | 2 | | INCENTIVE COMPENSATION THAT IS LINKED TO COST CONTROL, | | 3 | | PROFITABILITY AND STOCK PRICES | | 4 | Q. | WHILE YOUR EARLIER TESTIMONY DISCUSSED THE BENEFITS TO | | 5 | | CUSTOMERS OF USING INCENTIVE COMPENSATION THAT IS | | 6 | | LINKED TO COST CONTROL, PROFITABILITY AND STOCK PRICES, | | 7 | | ARE THERE ALSO NEGATIVE IMPACTS TO CUSTOMERS OF NOT | | 8 | | USING STOCK-BASED COMPENSATION? | | 9 | A. | Yes. In my opinion customers would be adversely affected if ETI did not | | 10 | | include such incentive compensation in its overall compensation policy. | | 11 | | | | 12 | Q. | STARTING WITH AN EXTREME EXAMPLE OF A COMPENSATION | | 13 | | POLICY WHERE ALL EMPLOYEES WERE ONLY PAID WITH | | 14 | | SALARIES, CAN YOU HIGHLIGHT THE IMPACT TO CUSTOMERS OF | | 15 | | SUCH A POLICY? | | 16 | A. | Yes. First, it is useful to note that if employees did not receive any | | 17 | | incentive compensation, salaries would have to be much higher to attract | | 18 | | and retain the same quality of talent. Second, costs would likely rise and | | 19 | | employee performance would likely suffer, as it would be difficult to | | 20 | | effectively and efficiently motivate employees to take actions that would | | 21 | | benefit shareholders and customers. In my opinion, customers would be | | 22 | | worse off under such a policy. This is supported by the principle that | | 23 | | individuals respond to incentives (a basic tenet of economics), and by |

| 1 | consisted only of salaries and incentive payments linked to operational incentives - would have to be similar to what the total compensation | | :--: | :--: | | 2 | would be if the firm also offered incentive compensation linked to cost control, profitability and stock prices. | | 4 | Second, such a compensation plan would not provide any incentives for employees and managers to control costs. If employees | | 6 | only had incentives to improve non-cash measures of performance, such as safety and reliability, then they would likely over-invest in these | | 8 | measures relative to what customers might prefer, at the expense of alternative, contemporaneous investments that would produce lower costs | | 10 | for customers. | | 12 | Relatedly, a compensation plan consisting of salary and incentives based solely on annual measures of operational performance could likely | | 13 | lead to "horizon problems." By horizon problems, I mean that managers tend to have a natural tendency, absent incentives, to focus on the short | | 15 | run at the expense of the long run. Stock prices by their nature are forward looking. Taken together, a compensation plan that included | | 16 | incentives based on annual measures such as reliability and customer satisfaction, but not incentives based on cost controls, profitability and | | 17 | especially stock prices, could provide incentives for managers to maximize |

their immediate compensation at the expense of longer-run benefits that the customer could have enjoyed. ^[10]

For example, consider a manager facing a decision whether to hire additional staff to answer phones in a call center (and bring down phone wait times) or to invest the same amount in a capital investment to put in place a new, more centralized call center that would produce significantly lower costs several years in the future. If the manager is paid purely in cash compensation including an incentive payment based on current-year customer satisfaction surveys (that would include phone wait times), then the manager would be more likely to forgo the long-term investment project and increase payroll by hiring additional employees in order to maximize his or her incentive pay by implementing the short-term solution today. But, at some point, customers are better off by having slightly longer waits on the phone now but reaping the benefits of lower overall costs in the future. A well-designed compensation plan that includes incentives linked to both customer satisfaction (in this example) and cost control, profitability and stock prices would provide incentives for the manager in this example to properly consider the benefits of such a longterm investment without sacrificing current customer satisfaction.

Entergy Texas, Inc. Page 26 of 31 Direct Testimony of Jay C. Hartzell, PhD. 2011 Rate Case

1 Q. IS THERE PUBLISHED EMPIRICAL EVIDENCE THAT SUPPORTS THE 2 OPINION THAT COMPENSATION BASED ON STOCK PRICE COULD 3 CURTAIL SUCH EXCESSIVE SHORT-TERM INVESTMENTS? A. Yes. Empirical evidence exists that some firms hurt their financial performance (stock price) by overinvesting in customer service. ^[11] This result suggests that including stock price in the compensation plan will help ensure against myopic investments in short-term service that would come at the expense of investments that would produce greater long-term benefits to customers. It also points toward the conclusion that basing incentive compensation for purposes of setting rates solely on operational goals could well be harmful to customers' interests in the long run.

12 Q. HOW DOES THE INCLUSION OF INCENTIVE COMPENSATION THAT

14 IS LINKED TO COST CONTROLS, PROFITABILITY AND STOCK 15 PRICES HELP AVOID THESE NEGATIVE OUTCOMES FOR 16 CUSTOMERS? 17 A. If a company adds compensation that is linked to cost controls, profitability, and stock prices to a compensation plan that includes base salary and incentives based on non-cash based measures in a reasonable way, customers are likely to be better off. Such incentive compensation

| 1 | helps a company attract, motivate, and retain talented employees and | | :--: | :--: | | 2 | gives managers a reason to focus on the long run in addition to the current | | 3 | year's performance, costs, customer service, and the like. | | 4 | This focus on the longer run is evident in the design of ETI's LTIP, | | 5 | stock option and restricted stock plans. For example, ETI's LTIP bases its | | 6 | payments in a particular year on the achievement of goals over the | | 7 | previous three years, encouraging managers to consider consistent and | | 8 | long-term success as key objectives. Plus, options granted vest over a | | 9 | three-year period, forcing managers to think about future years and how | | 10 | the firm will be viewed several years into the future. The stock options | | 11 | also have a life of ten years, which provides an additional incentive to | | 12 | focus on the long term. Such a focus on maximizing stock price over a | | 13 | ten-year period is beneficial for all stakeholders. As stock options may be | | 14 | awarded annually, option grants present a rolling ten-year window for | | 15 | those employees who receive them, reinforcing that long-term view. | | 16 | Similar to stock options, restricted stock is also awarded annually and | | 17 | vests over a three-year period. The fact that the ultimate value realized | | 18 | from restricted stock grants (once they vest) depends on the stock price at | | 19 | that time again provides a focus on maximizing stock price which is likely | | 20 | to be of benefit to all stakeholders for the reasons discussed above. | | 21 | Finally, the provision that requires senior managers to continue to hold | | 22 | stock received via exercising option grants or through the vesting of | | 23 | restricted stock up to a multiple of their salary further encourages longer- |

run thinking and incentive alignment, as senior managers cannot exercise all their options for cash or cash out their restricted stock positions and be immune to declines in the firm's financial health.

V. RESPONSE TO COMMON ARGUMENTS AGAINST INCENTIVE COMPENSATION LINKED TO COST CONTROL, PROFITABILITY AND STOCK PRICES FROM THE CUSTOMERS' PERSPECTIVE

Q. HOW DO YOU RESPOND TO THE ARGUMENT THAT INCENTIVE COMPENSATION THAT IS LINKED TO COST CONTROL, PROFITABILITY, AND STOCK PRICES WILL BE DETRIMENTAL TO CUSTOMERS BECAUSE IT WILL CAUSE MANAGERS TO CUT CUSTOMER SERVICE-RELATED EXPENSES TO INCREASE PROFITS?

A. This argument underscores the importance of a well-balanced compensation plan. By including both incentives based on non-dollar based measures such as customer service, reliability and safety, and incentives based on cost control, profitability and stock price, as does ETI, management will not want to cut one in order to increase the other, but will instead look for balanced decisions that help both.

Entergy Texas, Inc. Page 29 of 31 Direct Testimony of Jay C. Hartzell, PhD. 2011 Rate Case

1 Q. IS THERE EMPIRICAL EVIDENCE THAT THE ADOPTION OF 2 INCENTIVE COMPENSATION WITH TARGETS BASED ON STOCK OR 3 EARNINGS PERFORMANCE BENEFITS CUSTOMERS RATHER THAN 4 HARMS THEM? A. Yes. There is a published study that examines the adoption of long-term incentive plans that reward managers with stock or stock-based compensation, where the stock grants are based on long-run profitability. ^[12] The study finds that after the adoption of such plans, managerial compensation is more closely linked to the interests of managers and stakeholders, including customers. This is also consistent with the studies I discuss above in my testimony, such as one that links market value with customer satisfaction.

Another published study examines the impact of an incentive plan on the performance of a particular regulated utility. ^[13] This study compared the performance of two divisions within the utility company - one that added an incentive compensation plan with payouts based on financial measures such as sales, costs, and investments, plus employee absenteeism, and a second division that served as a control group because it did not take part in the incentive plan. The authors found for

the division that added the incentive plan, performance was significantly better along several dimensions, including operational measures (e.g., reliability) and employee health and safety. This evidence is particularly relevant in that it demonstrates a link between the adoption of an incentive compensation plan with payouts based on financial performance metrics and positive changes in a much broader set of stakeholder measures.

Q. IS THERE REASON TO BE CONCERNED FROM THE CUSTOMERS'

PERSPECTIVE BECAUSE STOCK PRICES AND PROFITS ARE DRIVEN BY MANY OTHER FACTORS IN ADDITION TO COST CONTROLS, OR HAVING A LOW COST OF CAPITAL? A. No. Avoiding this concern is why firms generally do not use compensation plans that consist solely of stock- or profit-based incentive pay - to do so would be too risky for the employees and would lead to larger overall compensation expense because risk-averse individuals would demand higher compensation levels in order to compensate them for bearing the risk of such a hypothetical plan. This is also why stock- and profit-based incentive compensation is more important at the top of the organization. Senior management can more clearly see (and anticipate) the impact of their actions on the firm's stock price, so stock-based compensation is a more efficient compensation tool for this level of management.

Entergy Texas, Inc. Page 31 of 31 Direct Testimony of Jay C. Hartzell, PhD. 2011 Rate Case

1 VI. CONCLUSION

2 Q. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? 3 A. Yes, at this time.

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Jay C. Hartzell

Department of Finance McCombs School of Business The University of Texas at Austin 1 University Station B6600 Austin, TX 78712 (512) 471-6779; jhartzell@mail.utexas.edu

Academic Positions Held

McCombs School of Business, The University of Texas at Austin Professor of Finance 2011 to present Chair, Department of Finance 2011 to present Allied Bancshares Centennial Fellow in Finance 2008 to present Executive Director, Real Estate Finance and Investment Center (REFIC) 2007 to present Associate Professor of Finance 2006 to 2011 Associate Director, REFIC 2005 to 2007 Assistant Professor of Finance 2001 to 2006 Stern School of Business, New York University Assistant Professor of Finance 1998 to 2001

Education

Ph.D. in Finance, The University of Texas at Austin, 1998 Minors: Real Estate, Economics. B.S. in Business Administration and Economics, Trinity University, 1991

Graduated Cum Laude. National Merit Scholar.

Publications

"Incentive Compensation and the Likelihood of Termination: Theory and Evidence from Real Estate Organizations" with Greg Hallman and Chris Parsons. 2011. Real Estate Economics 39, 507-546. "Is a Higher Calling Enough? Incentive Compensation in the Church" with Chris Parsons and David Yermack. 2010. Journal of Labor Economics 28, 509-539. "Alternative Benchmarks for Evaluating Mutual Fund Performance" with Tobias Mühlhofer and Sheridan Titman. 2010. Real Estate Economics 38, 121-154. "Explicit vs. Implicit Contracts: Evidence from CEO Employment Agreements" with Stuart Gillan and Robert Parrino. 2009. Journal of Finance 64, 1629-1655. "The Role of Corporate Governance in Initial Public Offerings: Evidence from Real Estate Investment Trusts" with Jarl Kallberg and Crocker Liu. 2008. Journal of Law and Economics 51, 539-562. "Why Do Firms Hold So Much Cash? A Tax-Based Explanation" with Fritz Foley, Sheridan Titman and Garry Twite. 2007. Journal of Financial Economics 86, 579-607 (Lead article).

"The Effect of Corporate Governance on Investment: Evidence from Real Estate Investment Trusts" with Libo Sun and Sheridan Titman. 2006. Real Estate Economics 34, 343-376 (Lead article). Winner of the 2006 Edwin S. Mills Real Estate Economics Best Paper Award. "Active Institutional Shareholders and Costs of Monitoring: Evidence from Executive Compensation" with Andres Almazan and Laura T. Starks. 2005. Financial Management 34(4), 5-34 (Lead article). "The Impact of CEO Turnover on Equity Volatility" with Matthew J. Clayton and Joshua Rosenberg. 2005. Journal of Business 78, 1779-1808. "The Role of the Underlying Real Asset Market in REIT IPOs" with Jarl G. Kallberg and Crocker H. Liu. 2005. Real Estate Economics 33, 27-50. "What's In It For Me? Private Benefits Obtained by CEOs Whose Companies are Acquired" with Eli Ofek and David Yermack. 2004. Review of Financial Studies 17, 37-61. "Institutional Investors and Executive Compensation" with Laura T. Starks. 2003. Journal of Finance 58, 2351-2374. "Market Reaction to Public Information: The Atypical Case of the Boston Celtics" with Gregory W. Brown. 2001. Journal of Financial Economics 60, 333-370.

Research Papers

"On the Optimality of Shareholder Control: Evidence from the Dodd-Frank Financial Reform Act" with Jonathan Cohn and Stuart Gillan. "Is There a Disposition Effect in Corporate Investment Decisions? Evidence from Real Estate Investment Trusts" with Alan Crane. "Trade-offs in Corporate Governance: Evidence from Board Structures and Charter Provisions" with Stuart Gillan and Laura Starks. "Institutional Investors as Monitors of Corporate Diversification Decisions: Evidence from Real Estate Investment Trusts" with Libo Sun and Sheridan Titman.

Professional and Academic Activities and Service

Associate Editor, Review of Financial Studies, 2009-present. Editorial Board, Real Estate Economics, 2007-present. American Real Estate and Urban Economics Association (AREUEA), Board of Directors, 2009-present. Member, 1998-present.

Urban Land Institute. Advisory Board (previously known as Executive Committee), Austin District Council, 2010-present. Member, Industrial &; Office Park Development Council (Gold), 2009-present. Full member, 2008-present.

National Council of Real Estate Investment Fiduciaries. Data Products Council, 2009. Member, 2008-present.

Financial Management Association. Track chair, real estate, annual meeting, 2007. Program committee, European meeting, 2006. Program committee, annual meeting, 2004, 2005. Corporate finance awards committee, annual meeting, 2003. Member, 1998-present.

Western Finance Association. Program committee, annual meeting, 2006, 2010, 2011. Member, 1998-present.

Conference on Financial Economics and Accounting. Co-organizer, Finance, 19th Annual Meeting, 2008.

American Finance Association. Member, 1998-present. Ad Hoc Referee for the following journals: The Accounting Review; American Economic Review; Financial Management; International Journal of Managerial Finance; International Journal of Manpower; International Review of Finance; Journal of Banking and Finance; Journal of Corporate Finance; Journal of Economics, Management, and Strategy; Journal of Economic Behavior and Organization; Journal of Finance; Journal of Financial and Quantitative Analysis; Journal of Financial Economics; Journal of Financial Intermediation; Journal of Financial Markets, Instruments and Institutions; Journal of Institutional and Theoretical Economics; Journal of Law, Economics, and Organizations; Journal of Real Estate Research; Journal of Risk and Insurance; Journal of Urban Economics; Management Science; Public Finance Review; Quarterly Review of Economics and Finance; Real Estate Economics; Review of Economic Studies; Review of Financial Studies.

Service for the University of Texas at Austin

Executive Director, Real Estate Finance and Investment Center (REFIC), 2007-present. Associate Director, REFIC, 2005-2007. Member, Finance Department Executive Committee, 2006-present. Member, Graduate Assembly (University wide), 2009-present. Member, Finance Department PhD Committee, 2003-present. Member, University Outstanding Graduate Thesis Award Committee, 2010. Guest speaker, MBA Alumni Network, El Paso, 2010; Seattle and Austin, 2009. Guest speaker, UT LAMP program, 2009. Speaker on Real Estate Valuation, VALCON 2009, Co-sponsored by UT School of Law. Member, Planning Committee, 2009 Mortgage Lending Institute, Sponsored by UT School of Law. Speaker, 2009 Mortgage Lending Institute (Austin and Dallas), Sponsored by UT School of Law. Guest speaker, Austin Bar Association Real Estate Section meeting, 2010. Speaker, 2009 Land Use Conference, Sponsored by UT School of Law. Judge, MBA Finance Tournament, 2001-2006, 2008-2009. Assistant Graduate Advisor and Minority Liaison, Finance Department, 2005-2008. Member, McCombs Option I Policy Committee, 2006-2008. Panel Chair, $I{C}^2$ Conference on Corporate Governance in Early-Stage Companies, 2005, 2006. Member, Plus Program Committee, 2003-2005. Judge, MBA Consulting Challenge, 2002, 2003, 2004. Member, MBA Scholarship Committee, 2002.

PhD Dissertation Committees

UT-Austin: Jennifer Brown (accounting), Alan Crane (co-chair), Ayla Kayhan, Andreas Lawson, Jie Lian, Andras Marosi, Bill Mayew (accounting), Thomas Moeller, Carlos Molina, Saumya Mohan (co-chair), Chris Parsons (co-chair), Lorenzo Preve, Casey Schwab (accounting), Zekiye Selvili, Nate Sharp (accounting), Stephanie Sikes (accounting), Libo Sun (co-chair), Vahap Uysal, Malcolm

Wardlaw, Peggy Weber (accounting), Li Yong. NYU: Eliezer Fich (economics), Charu Raheja, Jayanthi Sunder.

Academic Presentations (includes presentations made by co-authors at major conferences) 2011 Indian School of Business Summer Research Conference, National Bureau of Economic Research (NBER) Program on Law and Economics, Society for Financial Studies Finance Cavalcade, University of Michigan.

2010 American Real Estate and Urban Economics Association (AREUEA) annual meeting, Homer Hoyt Institute/Weimer School of Advanced Studies in Real Estate and Land Economics Spring Conference, UC-Irvine Commercial Real Estate Academic Symposium, Indiana University, University of Colorado at Boulder, University of Florida.

2009 AREUEA annual meeting, Association for the Study of Religion Economics and Culture (ASREC) annual meeting, National Bureau of Economic Research (NBER) Economics of Religion conference, Western Finance Association (WFA) annual meeting, National University of Singapore, Ohio State University, Singapore Management University, University of Alabama, University of Cincinnati, University of Washington.

2008 AREUEA annual meeting, Real Estate Research Institute (RERI) Conference, McGill University, University of California - Los Angeles.

2007 American Finance Association (AFA) annual meeting, Hong Kong University of Science and Technology Symposium, Real Estate Research Institute (RERI) Conference, Australian National University, Baylor University, Penn State University, Texas Tech University, University of California - Berkeley, University of Delaware, University of Oklahoma, University of South Florida.

2006 AFA annual meeting (two papers), University of Texas at Dallas. 2005 AREUEA annual meeting, NBER Corporate Governance meeting, Ohio State University, Penn State University, Southern Methodist University, University of North Carolina at Chapel Hill Tax Symposium, University of Texas at San Antonio.

2004 Association of Financial Economists (AFE) annual meeting, AREUEA annual meeting, Financial Management Association (FMA) annual meeting, NBER Summer Institute: Corporate Governance Workshop, College of William and Mary.

2003 AFA annual meeting, AREUEA/AFA joint session at annual meeting, University of British Columbia, University of Delaware Corporate Governance Symposium, University of Minnesota, University of North Carolina at Chapel Hill, WFA annual meeting.

2002 Babson College, Oklahoma State University, University of Oklahoma, Real Estate Research Confer-

ence (Vail, CO), University of Southern California.

2001

Arizona State University, University of Oregon.

2000

Dartmouth Center for Corporate Governance/Journal of Financial Economics (JFE) Conference on Contemporary Governance Issues, Marquette University, NYU-Columbia Joint Seminar, Southern Methodist University, University of Illinois at Urbana-Champaign, University of Texas at Austin.

1999

AFA annual meeting, Harvard Business School/JFE Conference on Complementary Research Methodologies.

1998

AFA annual meeting, FMA annual meeting, University of Alberta, University of Florida, Georgia State University, University of Michigan Ann Arbor, New York University, University of North Carolina Chapel Hill, Penn State University, Rice University, Southern Methodist University, Stanford University, and Tulane University.

1997

FMA annual meeting.

Other Participation in Academic Conferences

Discussant

AFA annual meeting, 2002, 2009, 2010. AFA / AFE joint session at annual meeting, 2003. AFE annual meeting, 1999, 2007. AREUEA annual meeting, 1999, 2000, 2004, 2007, 2008. AREUEA mid-year meeting, 2009, 2010. Conference, Financial Economics and Accounting, 1999. Financial Research Association, 2010. FMA annual meeting, 1999, 2002, 2003, 2004, 2006. FMA annual meeting - Tutorial on empirical methodology, 2009. FMA annual meeting - Panel discussion, 2008. Mitsui Symposium at the University of Michigan, 2005. Real Estate Research Institute Conference, 2011. Texas Finance Festival, 2000, 2007. WFA annual meeting, 2001, 2010, 2011.

Session Chair

AREUEA annual meeting, 2010. AREUEA mid-year meeting, 2009. FMA annual meeting, 2004, 2005. WFA annual meeting, 2006, 2010.

Teaching Experience

The University of Texas at Austin

Current PhD Course: Empirical Corporate Finance. Doctoral course in research methodology and

topics. Current MBA courses: Real Estate Markets. Elective in real estate asset and capital markets. Financial Management. Core MBA course, Houston MBA program.

Current BBA course: Real Estate Finance and Syndication. Elective in real estate capital markets.

Previous courses: Financial Management. Core MBA course, also taught in UT's Executive MBA and Professional MBA programs. Real Estate Analysis. MBA elective in real estate debt markets. Seminar in Real Estate Finance. MBA elective in real estate equity markets. Business Finance. Undergraduate required course.

Teaching honors and awards: Twice voted the "Outstanding Core Instructor" by graduating MBA classes. Named to the Honor Roll for teaching for both the MBA and Executive MBA programs.

New York University

Taught Corporate Finance and Corporate Finance Topics. MBA elective and undergraduate elective, respectively.

Honors and Awards

Best Paper Award, Indian School of Business Summer Research Conference, 2011. Outstanding Editorial Board Member, Real Estate Economics, 2010. Post Doctoral Award, Weimer School of Advanced Studies in Real Estate and Land Economics, Homer Hoyt Institute, 2010. Real Estate Research Institute (RERI) Grant Recipient (with Alan Crane), 2007. RERI Grant Recipient (with Tobias Mühlhofer and Sheridan Titman), 2006. CBA Foundation Research Excellence Award for Assistant Professors, 2006. (Finance Department nominee, 2003, 2005.) Finance Department nominee for Assistant Professor Teaching Award, 2003, 2004. University Preemptive Fellowship, UT-Austin, 1993-1995. University Continuing Fellowship, UT-Austin, 1995-1997. Austin Mortgage Bankers Association Scholarship, 1995. Lola Wright Foundation Scholarship, 1995-1997.

Non-Academic Experience

Consulting practice, Austin, Texas. Expert witness and financial consulting. 2007 to present Provided expert witness testimony and served as a consulting expert. Retained as expert witness in multiple cases involving real estate transactions, valuation, contracting issues and market conditions. Experience includes depositions and testimony on multiple occasions. Retained as expert witness for several cases regarding incentive compensation for regulated utilities. Retained as consulting expert by multiple clients for matters involving corporate governance, valuation, and mortgage issues (commercial and subprime). Deposed in matter before Superior Court of the State of California (trial pending). Provided (written and oral) testimony and was deposed on behalf of Entergy Louisiana LLC (Docket No. U-20925), 2008. Provided (written and oral) testimony on behalf of Entergy Gulf States, Inc. (Docket No. 34800), 2008. Provided written testimony on behalf of Entergy Arkansas, Inc. (Docket No. 09-084-U), 2009. Provided written testimony on behalf of Entergy Texas, Inc. (Docket No. 37744), 2010.

Hewitt Associates, The Woodlands, Texas. Benefits Consultant. 1991 to 1993 Consulted with clients on administration and ongoing design of defined contribution retirement plans. Earned Certified Employee Benefits Specialist (CEBS) designation.

Lola Wright Foundation, Austin, Texas. Investment Performance Consultant. 1995 to 1997 While in graduate school, analyzed performance of foundation's investment managers.

References

Furnished upon request.

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SOAH DOCKET NO. 473-12-2979 PUC DOCKET No. 39896 ETI 2011 Rate Case ETI EXHIBIT NO. 53 SOAH DOCKET NO. 473-12-2979 PUC DOCKET NO. 39896

| APPLICATION OF ENTERGY | § | | :-- | --: | | TEXAS, INC. FOR AUTHORITY TO | § | | CHANGE RATES, RECONCILE | § | | FUEL COSTS, AND OBTAIN | § | | DEFERRED ACCOUNTING | § | | TREATMENT | § |

REBUTTAL TESTIMONY

OF

JAY C. HARTZELL, Ph.D.

ON BEHALF OF

ENTERGY TEXAS, INC.

APRIL 2012

ENTERGY TEXAS, INC.
REBUTTAL TESTIMONY OF JAY C. HARTZELL, Ph.D. DOCKET NO. 39896

TABLE OF CONTENTS

Page I. Introduction and Qualifications ..... 1 II. Purpose of Rebuttal Testimony ..... 1 III. Response to Mr. Garrett's Policy Arguments Opposing Inclusion of "Financially" Related Incentive Compensation in Rates ..... 2 IV. Response to Mr. Pollock's and Ms. Givens' Policy Arguments Opposing Inclusion of "Financially" Related Incentive Compensation in Rates ..... 13 V. Conclusion ..... 15

Entergy Texas, Inc. Page 1 of 15 Rebuttal Testimony of Jay C. Hartzell, Ph.D. Docket No. 39896 I. INTRODUCTION AND QUALIFICATIONS Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Jay C. Hartzell. I am the Chair of the Finance Department, Professor of Finance, and the Allied Bancshares Centennial Fellow at the McCombs School of Business at the University of Texas at Austin. My business address is Department of Finance, The University of Texas at Austin, 1 University Station B6600, Austin, Texas 78712.

8 Q. DID YOU PREVIOUSLY FILE DIRECT TESTIMONY ON BEHALF OF ENTERGY TEXAS, INC. ("ETI" OR "THE COMPANY") IN THIS PROCEEDING? A. Yes, I did. II. PURPOSE OF REBUTTAL TESTIMONY Q. WHAT IS THE PURPOSE OF YOUR REBUTTAL TESTIMONY? A. My Rebuttal Testimony addresses certain arguments raised by Cities witness Garrett, by Staff witness Givens, and by TIEC witness Pollock in opposition to inclusion in rates of what has been termed "financially" related incentive compensation.

| 1 | III. RESPONSE TO MR. GARRETT'S POLICY ARGUMENTS OPPOSING INCLUSION OF "FINANCIALLY" RELATED INCENTIVE COMPENSATION IN RATES | | :--: | :--: | | 4 | Q. WHAT PORTIONS OF MR. GARRETT'S TESTIMONY ARE YOU ADDRESSING? | | 6 | A. Mr. Garrett makes several arguments as to why "financially" based incentive compensation should be excluded from rates. Specifically, he argues that: | | 9 | 1) Payment is uncertain. | | 10 | 2) Incentive plans tied to company earnings performance are held in general disfavor because many factors that significantly impact earnings are outside the control of most company employees and have limited value to customers. | | 11 | 3) Earnings-based incentive plans can discourage conservation. | | 12 | 4) The utility and its stockholders assume none of the financial risks associated with financially based incentive payments. | | 13 | 5) Incentive payments based on financial performance measures should be made out of increased earnings. | | 14 | 6) Financially based incentive payments embedded in rates shelter the utility against the risk of earnings erosion through attrition. | | 20 | Mr. Garrett goes on to argue that financial incentives differ from operational incentives because ratepayers have no stake in an incentive plan design based on financial performance measures, while they do have a stake in such a plan to the extent it is based on operational performance |

| 1 | measures. There are logical and theoretical problems with these | | :--: | :--: | | 2 | arguments, as I discuss below. Company witness Kevin G. Gardner also | | 3 | addresses the flaws in Mr. Garrett's analysis. | | 4 | | | 5 Q. | PLEASE ADDRESS MR. GARRETT'S ARGUMENT THAT FUTURE | | 6 | PAYMENT OF FINANCIALLY BASED INCENTIVE COMPENSATION IS | | 7 | UNCERTAIN. | | 8 A. | It is true that payment of incentive compensation in the future is designed | | 9 | to be uncertain. Indeed, this is a key aspect of the effectiveness of | | 10 | incentive compensation, because the risk associated with the level of | | 11 | future compensation provides incentives for positive employee | | 12 | performance. However, this uncertainty does not imply that such incentive | | 13 | compensation is an unreasonable, unnecessary, or non-recurring | | 14 | business expense. If Mr. Garrett's argument were valid, no incentive | | 15 | compensation, whether it is financially or operationally based, would be a | | 16 | candidate for inclusion in rates, which is a position already considered and | | 17 | rejected by the Commission. ^[1] At some level, many future costs of doing | | 18 | business are uncertain at the time rates are set. I understand that by | | 19 | using a "test year," the Commission has a sample data point that, despite |

| 1 | this inherent level of uncertainty, becomes the starting point for setting | | :--: | :--: | | 2 | rates. ETI's incentive compensation plan design provides the potential for | | 3 | payment of incentive compensation at varying levels dependent on the | | 4 | degree of financial success. This potential variation is consistent with the | | 5 | use of the test-year level of incentive compensation payments as the basis | | 6 | for setting rates. | | 7 | | | 8 Q. | WHAT IS YOUR RESPONSE TO MR. GARRETT'S POSITION THAT | | 9 | INCENTIVE PLANS BASED ON COMPANY EARNINGS ARE HELD IN | | 10 | GENERAL DISFAVOR BECAUSE MANY FACTORS THAT | | 11 | SIGNIFICANTLY IMPACT EARNINGS ARE OUTSIDE THE CONTROL | | 12 | OF MOST COMPANY EMPLOYEES AND HAVE LIMITED VALUE TO | | 13 | CUSTOMERS? | | 14 A. | Here, Mr. Garrett uses examples of "good luck" to argue that because | | 15 | random chance can influence whether employees make targets or not, | | 16 | this possibility somehow leads to the conclusion that such compensation | | 17 | plans are held in disfavor. Mr. Garrett, however, conveniently ignores the | | 18 | fact that the luck might be bad - e.g., an unseasonably mild summer might | | 19 | weaken the firm's financial performance and make it less likely that the | | 20 | firm hits some financial targets. Moreover, the impact of such events can | | 21 | also affect the level of performance on operational measures such as | | 22 | reliability, such that Mr. Garrett's argument raises no meaningful |

distinction from the types of incentive payments that the Commission currently allows in rates.

The effect of random chance - both positive and negative surprises - is why nearly every overall compensation package provides some component of safe pay, such as salary, instead of consisting of only incentive-based pay. An incentive-only pay package would be too risky from the employee's perspective and too expensive from the firm's perspective due to this greater risk. A balanced approach, however, that includes some incentive compensation, adds the possibility of a reward to the negative of risk. Moreover, that possibility of reward motivates employees to take actions that are in the shareholders' and ratepayers' best interests.

The uncertainty of payment of a portion of their compensation provides incentives for employees to take actions that are in the best interest of shareholders and ratepayers alike. The nature of the workplace is such that it is impossible to perfectly observe and verify the employees' actions. Instead, one must rely on signals or indications. These signals or indications will include some element of luck or chance. Ultimately, by properly balancing such incentive compensation with fixed salaries, all parties can be better off - employees, shareholders, and customers.

Entergy Texas, Inc. Page 6 of 15 Rebuttal Testimony of Jay C. Hartzell, Ph.D. Docket No. 39896 1 Q. WHAT IS YOUR RESPONSE TO MR. GARRETT'S CONTENTION THAT 2 EARNINGS-BASED INCENTIVE PLANS CAN DISCOURAGE 3 CONSERVATION? A. Mr. Garrett hypothesizes that an earnings-based performance target will improperly motivate employees to disregard beneficial programs such as demand side management, if they perceive that such programs may depress earnings. Mr. Garrett offers no evidence that any such incentive is created by ETI's incentive plan. Moreover, to the extent that an incentive plan encourages the attraction of incremental customers - such as in connection with an economic development program - it may have the positive result of spreading the Company's fixed costs among a larger customer base, to the benefit of all customers. More fundamentally, an appropriate balance of performance incentives in the incentive plan design will avoid the result hypothesized. For example, when an incentive plan design balances both earnings targets and cost control performance through budget and process efficiency targets, the design should lead managers to reduce costs, which in the long run will directly benefit customers. At the same time, including performance targets related to reliable service and customer satisfaction helps ensure that cost-cutting does not erode customer service.

| 1 | Q. | IS MR. GARRETT CORRECT THAT THE UTILITY AND ITS | | :--: | :--: | :--: | | 2 | | STOCKHOLDERS ASSUME NONE OF THE FINANCIAL RISKS | | 3 | | ASSOCIATED WITH INCENTIVE PAYMENTS? | | 4 | A. | Based on my understanding of the ratemaking process, this statement is false. If the exact level of incentive compensation for every year was | | 6 | | included in rates in that year, then it might be true. However, by using a test year and setting the appropriate incentive compensation level based | | 8 | | on that year's data, an expected level of incentive compensation is included in future rates. The utility and shareholders still face financial risk | | 9 | | or variation due to fluctuations around that expected level. If incentive compensation is above the amount put in rates, shareholders of the firm | | 11 | | will pay that extra amount. | | 12 | | In addition, Mr. Garrett's claim here misses the whole point of incentive compensation. The reason incentive compensation is effective | | 14 | | is that it puts a portion of the employees' pay at risk. The goal is not to put more risk on the shareholders - they are already bearing the risk of the | | 16 | | employees' actions that affect the firms' profitability. By exposing employees' pay to risk or variation, employees have an increased | | 18 | | incentive to take actions that are in both shareholders' and ratepayers' best interests. |

| 1 | Q. | IS THERE ANY MERIT TO MR. GARRETT'S CLAIM THAT INCENTIVE | | :--: | :--: | :--: | | 2 | | PAYMENTS BASED ON FINANCIAL PERFORMANCE MEASURES | | 3 | | SHOULD BE MADE OUT OF INCREASED EARNINGS? | | 4 | A. | I do not understand Mr. Garrett's claim or objection here. The test year | | 5 | | provides a measure of "expected" or "normal" compensation, including | | 6 | | both salaries and reasonable or customary incentive compensation. It is | | 7 | | this expected level that is recovered through rates, and thus, shareholders | | 8 | | do indeed bear the cost of any additional - or, better than expected - | | 9 | | compensation. Thus, what Mr. Garrett claims should happen is exactly | | 10 | | what does happen; shareholders pay for compensation that is greater than | | 11 | | expectations out of increased earnings. | | 12 | | | | 13 | Q. | IS MR. GARRETT'S VIEW CORRECT THAT INCENTIVE PAYMENTS | | 14 | | EMBEDDED IN RATES SHELTER THE UTILITY AGAINST THE RISK OF | | 15 | | EARNINGS EROSION THROUGH ATTRITION? | | 16 | A. | No. Including a representative level of incentive compensation in rates | | 17 | | does not act as a typical financial hedge, unlike the characterization put | | 18 | | forth by Mr. Garrett. Hedges act as insurance and pay off more if the | | 19 | | firm's performance weakens. Recovering incentive compensation through | | 20 | | rates would provide a level cash flow to the utility, holding revenues | | 21 | | constant. If the firm's performance weakens due to shocks to its cost | | 22 | | structure, then this level cash flow would indeed improve its financial | | 23 | | stability, but no more so than other cost components of the rates in place. |

| 1 | However, if the performance weakens due to a drop in revenues (for example, due to a drop in electricity consumption), then the cash flow traced to the inclusion of incentive compensation in rates would drop as well (because it is part of the costs that go into establishing the per-unit price). Even if the additional cash flow improves the financial health of the utility, however, a financially healthy utility is in the customers' best interest. As I pointed out in my Direct Testimony, a utility that is financially unhealthy would likely incur greater costs in the future that would be borne by customers. | | :--: | :--: | | 10 | This last point brings up another problem with Mr. Garrett's testimony. He states: | | 12 | When incentive compensation payments are based on financial performance measures, the compensation agreement between shareholders and employees could be loosely stated in this manner: "if you increase shareholder earnings, we will pay you a bonus." The intended beneficiaries to this agreement are the shareholders and the employees. Ratepayers have no stake in this agreement; therefore, they should bear none of the costs that result from such an agreement. If, instead, the agreement were stated in this manner: "if you will help increase reliability and quality of service to the customers, and reduce fuel and purchased power costs, we will pay you a bonus," then, ratepayers would have a stake in the agreement, and could share in a portion of the costs. (See page 39.) | | 13 | Mr. Garrett's statement that ratepayers have no stake in the first agreement he references is false in my opinion. Ratepayers are likely to | | 14 | Benefit from a financially healthy utility for the many reasons discussed in my Direct Testimony. In addition, a well-balanced incentive plan that |

| 1 | rewards employees based on operational measures in addition to financial | | :--: | :--: | | 2 | measures will help ensure that improvements in shareholders' welfare do | | 3 | not come at the expense of ratepayers' welfare. | | 4 | | | 5 | Q. IS MR. GARRETT'S STATEMENT THAT RATEPAYERS HAVE NO | | 6 | STAKE IN INCENTIVE COMPENSATION AGREEMENTS BASED ON | | 7 | FINANCIAL PERFORMANCE MEASURES LOGICAL AND CONSISTENT | | 8 | WITH HIS OTHER STATEMENTS? | | 9 | No. In addition to the benefits that ratepayers experience from a | | 10 | financially healthy utility (as discussed in my Direct Testimony), perhaps | | 11 | the easiest way to see the error in Mr. Garrett's argument that ratepayers | | 12 | have no stake in such incentive compensation plans is to consider an | | 13 | incentive plan that motivates employees to achieve increased efficiencies | | 14 | or control costs. Because of the regulatory process, the benefits of any | | 15 | cost controls would be passed along to ratepayers through lower rates in | | 16 | the future. Thus, it seems obvious that it is in the ratepayers' interests that | | 17 | the utility implements a fair and reasonable incentive compensation plan | | 18 | that motivates employees to control costs. | | 19 | Mr. Garrett admits this point on page 31 of his testimony, where he | | 20 | states: "To the contrary, incentive plans that motivate employees to | | 21 | achieve increased efficiencies (i.e., cost control) should be encouraged." | | 22 | He goes on to argue that because the utility retains such cost savings | | 23 | between rate cases, the utility should pay for the incentive compensation |

| 1 | rather than the ratepayers. Based on this discussion, it is clear that | | :--: | :--: | | 2 | Mr. Garrett understands that ratepayers ultimately benefit from incentive | | 3 | compensation plans that lead to greater cost control, via the regulatory | | 4 | process. Thus, Mr. Garrett contradicts his later statement on page 39 that | | 5 | ratepayers have no stake in these types of agreements. | | 6 | | | 7 | D. IN ADDITION TO THESE INTERNAL INCONSISTENCIES, DOES MR. | | 8 | GARRETT'S POSITION ALSO CONTRADICT THOSE OF MR. | | 9 | POLLOCK AND MS. GIVENS? | | 10 | Yes. Mr. Pollock and Ms. Givens do not object to the inclusion of | | 11 | compensation based on cost controls. In fact, Mr. Pollock acknowledges | | 12 | in his deposition that compensation based on cost controls will tend to | | 13 | benefit ratepayers. ^[2] In contrast, Mr. Garrett includes compensation based | | 14 | on cost controls as financially-based, and then argues that it should be | | 15 | excluded, in spite of his admission that it benefits ratepayers and should | | 16 | be encouraged. |

| 1 | Q. | CAN YOU GIVE A SIMPLE EXAMPLE TO ILLUSTRATE THE BENEFIT | | :--: | :--: | :--: | | 2 | | TO RATEPAYERS OF COST CONTROLS AS PART OF THE | | 3 | | REGULATORY PROCESS? | | 4 | A. | Yes. Consider a simple example where, due to an incentive | | 5 | | compensation plan that rewards cost controls, an employee comes up | | 6 | | with an idea that reduces the cost of delivering service by $\backslash$ 1$ per year, in | | 7 | | perpetuity. In order to convert this stream of cost savings into a value | | 8 | | today, one needs to use an interest (or discount) rate that captures | | 9 | | ratepayers' and shareholders' preferences for cash today relative to cash | | 10 | | in the future. To use round but plausible numbers, consider the case | | 11 | | where ratepayers and shareholders are willing to accept a 10 percent | | 12 | | return on their investments. In this case, the $\backslash$ 1$ annual cost saving would | | 13 | | generate $\backslash$ 10 $ofvalueorwealth(calculatedas$ \ $10=\backslash$ 1 / 0.10$ ). ^[3] | | 14 | | Next, assume that the time between the cost savings and the next | | 15 | | rate case is three years. In this example, shareholders receive the benefit | | 16 | | of the first three years of cost savings, while ratepayers receive the | | 17 | | savings for year four and beyond. Using the 10 percent discount rate, the | | 18 | | value of the cost savings that is captured by the shareholders is about | | 19 | | $\backslash$ 2.49 $,whiletheremaining$ \ $7.51$ accrues to the ratepayers. ^[4] Thus, about | | 20 | | 25 percent of the value of cost savings is passed to the shareholders, |

| 1 | while 75 percent goes to the ratepayers. Clearly, the ratepayers have a | | :--: | :--: | | 2 | stake in the agreement that provided the employee with the incentive to | | 3 | control costs. In fact, in this scenario, the ratepayers' stake is even more | | 4 | significant than that of the shareholders. | | 5 | | | 6 | IV. RESPONSE TO MR. POLLOCK'S AND MS. GIVENS' | | 7 | POLICY ARGUMENTS OPPOSING INCLUSION OF | | 8 | "FINANCIALLY" RELATED INCENTIVE | | 9 | COMPENSATION IN RATES |

10 Q. WHAT PORTIONS OF MR. POLLOCK'S AND MS. GIVENS' TESTIMONY 11 ARE YOU ADDRESSING? 12 A. Mr. Pollock and Ms. Givens both discuss incentive compensation, and assert that compensation expense related to achieving financial objectives should be disallowed. 15 16 Q. DO YOU AGREE WITH MR. POLLOCK'S STATEMENT THAT INCENTIVE COMPENSATION BASED ON ACHIEVING CERTAIN 18 FINANCIAL GOALS OF ENTERGY SHOULD BE DISALLOWED ON THE 19 BASIS THAT IT BENEFITS ONLY SHAREHOLDERS NOT CUSTOMERS? 21 A. No. Mr. Pollock makes this statement on pages 41-42 of his testimony. 22 As discussed earlier in this Rebuttal Testimony and in my Direct 23 Testimony, there are several reasons why ratepayers benefit from a 24 financially healthy utility. Incentive compensation based on financial

| 1 | measures is an important tool used to promote financial health, which in turn tends to benefit ratepayers. | | :--: | :--: | | 3 | | | 4 | Q. DOES MR. POLLOCK OFFER ANY ADDITIONAL SUPPORT FOR HIS CLAIM THAT INCENTIVE COMPENSATION EXPENSE LINKED TO FINANCIAL PERFORMANCE SHOULD BE EXCLUDED? | | 7 | A. Beyond his assertion that ratepayers do not benefit from a financially healthy utility or from cost controls, Mr. Pollock's recommendation appears to be based solely on past precedent. On page 44, in response to the question, "What is the basis for your recommendation?" he states, "My recommendation is consistent with past precedent," and goes on to discuss previous Commission findings. He does not present additional analysis of his own in support of his recommendation. | | 10 | | | 11 | | | 12 | | | 13 | | | 14 | | | 15 | Q. DOES MS. GIVENS OFFER ANY ADDITIONAL SUPPORT FOR HER CLAIM THAT INCENTIVE COMPENSATION EXPENSE LINKED TO FINANCIAL PERFORMANCE SHOULD BE EXCLUDED? | | 18 | A. Like Mr. Pollock, Ms. Givens' recommendation appears to be based solely on past precedent. She discusses this history on pages 16-18 of her testimony, but she does not present additional analysis of her own in support of her recommendation. |

Entergy Texas, Inc. Page 15 of 15 Rebuttal Testimony of Jay C. Hartzell, Ph.D. Docket No. 39896

1 V. CONCLUSION

2 Q. DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY? 3 A. Yes.

SOAH DOCKET NO. 473-12-2979 PUC DOCKET No. 40295

APPLICATION OF ENTERGY TEXAS, INC. FOR RATE CASE EXPENSES PERTAINING TO PUC DOCKET NO. 39896 § BEFORE THE STATE OFFICE OF $\S$ ADMINISTRATIVE HEARINGS

REBUTTAL TESTIMONY

OF

STEPHEN F. MORRIS

ON BEHALF OF

ENTERGY TEXAS, INC.

NOVEMBER 15, 2012

ENTERGY TEXAS, INC. REBUTTAL TESTIMONY OF STEPHEN F. MORRIS PUCT DOCKET NO. 40295

TABLE OF CONTENTS

| I. INTRODUCTION &; PURPOSE | 1 | | :-- | :-- | | II. REBUTTAL OF PROPOSED DISALLOWANCES | 1 |

EXHIBITS

| Exhibit SFM-R-1 | Open Meeting Excerpts Regarding Recovery of
Incentive Compensation | | :-- | :-- | | Exhibit SFM-R-2 | Resume of Gerald Tucker | | Exhibit SFM-R-3 | ETI's Response to Staff RFI 13-7 |

Entergy Texas, Inc. Page 1 of 14 Rebuttal Testimony of Stephen F. Morris PUCT Docket No. 40295 I. INTRODUCTION &; PURPOSE 2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 3 A. My name is Stephen F. Morris. My business address is 8310 N. Capital of 4 Texas Highway, Suite 490, Austin, Texas 78731. 5 6 Q. ARE YOU THE SAME STEPHEN F. MORRIS WHO FILED DIRECT AND 7 SUPPLEMENTAL DIRECT TESTIMONY IN DOCKET NO. 39896 AND IN 8 THIS DOCKET ON BEHALF OF ENTERGY TEXAS, INC. ("ETI" OR "THE 9 COMPANY")? 10 A. Yes, I am. 11 12 Q. WHAT IS THE PURPOSE OF THIS REBUTTAL TESTIMONY? 13 A. This rebuttal testimony addresses certain aspects of the direct testimony 14 of Office of Public Utility Counsel ("OPUC") witness Nathan A. Benedict 15 and the "recommendations" of the Staff of the Public Utility Commission of 16 Texas ("Staff"), OPUC, and the State of Texas' agencies and institutions 17 of higher education ("State Agencies"). 18 19 II. REBUTTAL OF PROPOSED DISALLOWANCES 20 Q. HAVE CERTAIN PARTIES RECOMMENDED THAT RATE CASE 21 EXPENSES ASSOCIATED WITH ETI'S REQUEST TO RECOVER 22 FINANCIAL-BASED INCENTIVE COMPENSATION BE DISALLOWED? 23 A. Yes.

Entergy Texas, Inc. Rebuttal Testimony of Stephen F. Morris PUCT Docket No. 40295 Q. WHAT RATIONALE IS PROVIDED BY THE PARTIES PROPOSING SUCH A DISALLOWANCE? A. Staff did not provide a rationale. ^[1] OPUC and State Agencies both contend rate case expenses associated with attempts to recover financial-based incentive compensation should be disallowed on the grounds that long- 6 standing Commission precedent prohibits the recovery of such costs. ^[2] 7 8 Q. DO YOU AGREE WITH THIS RATIONALE OR THE PROPOSED DISALLOWANCE? 10 A. No, I do not. The Commission has not foreclosed the possibility of recovering any costs associated with what has been termed "financialbased" incentive compensation or prohibited utilities from seeking such costs. 14 In fact, the Commission approved ETI's request in Docket No. 39896 to recover costs associated with incentive compensation tied to cost controls, ^[3] which have been grouped with financial-based incentive compensation in several prior cases. ^[4] ETI's recovery of these costs was supported by rate case expenses related to the testimony and exhibits of

| 1 | Dr. Jay Hartzell ^[5] and the efforts of outside counsel. This result highlights not only the reasonableness of litigating this issue, but also the continuing evolution of how various types of incentive compensation are characterized and categorized. | | :--: | :--: | | 5 | Moreover, the notion that the Commission has prohibited utilities from seeking recovery of costs associated with financial-based incentive compensation is belied by the fact that other utilities routinely seek recovery of such costs. ^[6] Thus, it is incorrect to suggest that the Company was somehow forewarned against incurring rate case expenses in pursuit of costs associated with financial-based incentive compensation. | | 10 | Finally, in Open Meeting discussions, Commissioners have expressed some concern with the Commission's historical approach to the recovery of incentive compensation and intimated that the recovery of such costs may turn on a "properly organized and evidenced" case on the |

| 1 | issue. ^[7] Accordingly, in Docket No. 39896, it was reasonable for ETI to attempt to organize and present evidence regarding the benefits of its incentive compensation programs in a manner that would result in Commission approval of such costs. | | :--: | :--: | | 5 | | | 6 | Q. HAS OPUC RECOMMENDED OTHER DISALLOWANCES TO ETI'S RATE CASE EXPENSE REQUEST BASED ON THE THEORY THAT ETI | | 8 | UNREASONABLY INCURRED COSTS LITIGATING AN ISSUE? | | 9 | Yes. OPUC recommended that the Commission disallow rate case expenses associated with ETI's request for: (1) a post-test year adjustment ("PTYA") to its MSS-2 (transmission equalization) expense, based on the theory that ETI's position was contrary to the established "known and measurable" standard for PTYAs; and (2) a purchased capacity rider, due to the existence of a related rulemaking. ^[8] | | 15 | | | 16 | Q. DO YOU AGREE WITH OPUC'S RECOMMENDED DISALLOWANCE OF RATE CASE EXPENSES ASSOCIATED WITH ETI'S PROPOSED PTYA | | 18 | TO ITS TEST YEAR MSS-2 EXPENSE? | | 19 | No, I do not. OPUC's disallowance is based on a flawed and unworkable premise: that a party that fails to persuade the Commission that a particular standard of recovery has been met (e.g., "known and |

| Entergy Texas, Inc. | Page 5 of 14 | | :--: | :--: | | Rebuttal Testimony of Stephen F. Morris | | | PUCT Docket No. 40295 | | | 1 | measureable" or "reasonable and necessary") has necessarily and | | 2 | unreasonably taken a position contrary to established precedent. | | 3 | ETI did not incur rate case expenses in pursuit of a position | | 4 | contrary to the well-established "known and measurable" standard for | | 5 | PTYAs. Rather, the Commission disagreed that the evidence put forth by | | 6 | ETI met that standard. ^[9] This is a very important distinction. Finding that | | 7 | evidence put forth by a utility did not meet an established standard does | | 8 | not equate to a finding that the utility unreasonably contested the | | 9 | applicability of such standard or was unreasonable in contending that such | | 10 | standard had been met. Despite good faith arguments that all requested | | 11 | costs are "reasonable and necessary," it is unusual for a Texas utility to | | 12 | recover 100\% of its Operations &; Maintenance or Administrative &; | | 13 | General costs increases requested in base rate cases. This does not | | 14 | mean, as OPUC's position implies, that every utility that has ever filed a | | 15 | base rate case with the Commission has taken a position contrary to | | 16 | settled precedent. | | 17 | In addition, ETI was not alone in its view that an upward PTYA to | | 18 | the Company's MSS-2 expense would be reasonable. The direct | | 19 | testimonies of Cities witness Dennis W. Goins and TIEC witness Jeffry | | 20 | Pollock each addressed the reasonableness of positive PTYAs to ETI's |

| Entergy Texas, Inc. | | | :--: | :--: | | 1 | test year MSS-2 expense. ^[10] The fact that the Commission ultimately | | 2 | rejected these adjustments does not suggest that ETI or any other party | | 3 | took an unreasonable position contrary to Commission precedent. | | 4 | Accordingly, OPUC's recommendation to disallow rate case expenses | | 5 | related to ETI's request for an MSS-2 PTYA should be rejected. | | 6 | | | 7 | DO YOU AGREE WITH OPUC'S RECOMMENDED DISALLOWANCE OF | | 8 | RATE CASE EXPENSES ASSOCIATED WITH ETI'S PROPOSED | | 9 | PURCHASED CAPACITY RIDER? | | 10 | No, I do not. The fact that the Commission has opened a rulemaking | | 11 | related to purchased capacity riders does not suggest that ETI was | | 12 | unreasonable to request a purchase capacity rider through its rate filing. | | 13 | Project No. 39246 was initiated by the Commission on March 10, 2011. At | | 14 | the time ETI filed its rate application, the Commission had taken no action | | 15 | and there had been no filings in Project No. 39246 for over 4 months and | | 16 | there was no activity whatsoever in the Project from July 11, 2011 through | | 17 | September 28, 2012 (more than 14 months). In their December 19, 2011 | | 18 | responses to request for briefing on the issue of whether a purchased | | 19 | capacity rider should be considered in this docket, both Texas Industrial | | 20 | Energy Consumers and State Agencies took the position that there was |

^0

Docket No. 39896, Direct Testimony of Dennis W. Goins at 19-22 (discussing a post-test year adjustment from $\backslash$ 1.84$millionto$\$4.1$ million) and Direct Testimony of Jeffry Pollock at 32-33 (discussing a post-test year adjustment to $\backslash$ 2.7$ million).

| Entergy Texas, Inc. | | | :--: | :--: | | 7 | the-fact request for disallowance of these costs. | | 8 | | | 9 Q. | WHAT IS YOUR REACTION TO OPUC'S GLOBAL RECOMMENDATION | | 10 | TO DISALLOW BETWEEN 14.5\% (\ $1.3MILLION)AND73.6\%(\backslash$ 6.4 | | 11 | MILLION) OF ETI'S REQUESTED RATE CASE EXPENSES? | | 12 A. | OPUC's recommendation should be rejected. OPUC's rationale for | | 13 | disallowing $14.8\%$ of ETI's rate case expenses is that $14.9\%$ of ETI's initial | | 14 | rate request is comprised of costs that, according to OPUC, ETI should | | 15 | not have pursued in the first instance. ^[13] For the reasons explained above, | | 16 | ETI was not unreasonable in pursuing recovery of the costs identified by | | 17 | OPUC. In any event, the methodology underlying OPUC's proposed | | 18 | disallowance is flawed because the ratio of the underlying costs OPUC | | 19 | identifies relative to ETI's overall request does not correspond to the | | 20 | amount of rate case expenses incurred to litigate such issues. In lieu of | | 21 | identifying the level of rate case expenses actually related to such issues |

| 1 | (i.e., the amount it was unreasonable to incur under OPUC's theory), | | :--: | :--: | | 2 | OPUC has arbitrarily tied its proposed disallowance to the level of the | | 3 | underlying costs relative to ETI's overall request. | | 4 | OPUC's rationale for disallowing $73.6\%$ of ETI's rate case | | 5 | expenses is equally simplistic and contrary to Commission precedent. In | | 6 | essence, OPUC contends that utilities' rate case expense recovery should | | 7 | be tied to their success in achieving their initial rate request. ^[14] In other | | 8 | words, OPUC asserts that because ETI was only awarded approximately | | 9 | $26\%$ of its requested rate increase, it should only be awarded $26\%$ of its | | 10 | rate case expenses. Not surprisingly, OPUC fails to identify any instance | | 11 | in which the Commission has taken such an approach to determining the | | 12 | reasonableness of rate case expenses. OPUC's proposal runs afoul of | | 13 | fundamental ratemaking principles in that it relies on a punitive and | | 14 | hindsight-driven approach to cost recovery, rather than basing cost | | 15 | recovery on whether a utility acted reasonably at the time it incurred such | | 16 | costs. | | 17 | For these reasons, the Commission should reject OPUC's global | | 18 | proposals and continue to base rate case expense recovery on the | | 19 | reasonableness of the actual expenses being requested. | | 20 | | | Q. | DOES STATE AGENCIES' TAKE A SIMILARLY GLOBAL APPROACH IN | | 22 | RECOMMENDING A DISALLOWANCE OF RATE CASE EXPENSES? |

| 1 A. | Yes. Although it identifies only $\backslash$ 357,210$ in actual rate case expenses that | | :--: | :--: | | 2 | it claims were unreasonably incurred, State Agencies recommends | | 3 | alternative global disallowances of either $50\%$ ( $\backslash$ 4.35 $million)or$ 73 \%$ | | 4 | (\$6.38 million) of ETI's rate case expenses. ^[15] | | 5 | | | 6 Q. | DO YOU AGREE WITH THOSE RECOMMENDATIONS? | | 7 A. | No. I do not. Both of State Agencies' proposed alternative global | | 8 | disallowances represent a departure from Commission practice and bad | | 9 | public policy. | | 10 | First, State Agencies argues that the Commission should disallow | | 11 | $50\%$ (\$4.35 million) of ETI's rate case expenses simply because | | 12 | shareholders derive benefit from rate cases. ^[16] ETI is not aware of, and | | 13 | State Agencies fails to identify, any instance in which the Commission has | | 14 | taken such an approach to determining the reasonableness of rate case | | 15 | expenses. Moreover, such practice would constitute bad policy because | | 16 | rate case expenses are a necessary component of the traditional | | 17 | ratemaking paradigm set out in the Public Utility Regulatory Act | | 18 | ("PURA"). ^[17] |

As an alternative theory, and consistent with OPUC's proposal, State proposes that the Commission globally disallow 73\% (\$6.38 million) of ETI's requested rate case expenses by tying ETI's recovery of rate case expenses to its success in obtaining the relief requested in its application. ^[18] In other words, like OPUC, State Agencies insists that utilities seek recovery of costs through base rate cases but contends, in essence, that they should litigate such cases on a contingency basis. Again, however, the Commission has never adopted such an approach to determining the reasonableness of rate case expenses and such a position ignores the fact that the incurrence of rate case expenses is a necessary component of the ratemaking paradigm endorsed by State Agencies. As with OPUC's position, adopting a disallowance based on the percentage of the ultimate base rate increase as compared to the requested increase has no, and makes no, connection to whether the rate case expenses were reasonable.

For these reasons, the Commission should reject State Agencies' indiscriminate new approach to rate case expense recovery.

| 1 | Q. | APART FROM ITS PROPOSED GLOBAL DISALLOWANCES, DOES | | :--: | :--: | :--: | | 2 | | STATE AGENCIES IDENTIFY SPECIFIC RATE CASE EXPENSES THAT | | 3 | | IT CONTENDS WERE UNREASONABLY INCURRED? | | 4 | A. | Yes. State Agencies specifically recommends that the Commission | | 5 | | disallow rate case expenses totaling $\backslash$ 357,209.59$ associated with: (1) the | | 6 | | recovery of financial-based incentive compensation (\$27,256); (2) the | | 7 | | services of Mr. Gerald Tucker (\$116,119); (3) the "lessons learned" | | 8 | | analysis conducted by ETI (\$5,744); and (4) the depreciation and | | 9 | | amortization loader that follows Entergy Services, Inc. ("ESI") labor | | 10 | | expense billed to the rate case (\$207,683). ^[19] I will address the first three | | 11 | | proposed disallowances below. Mr. Considine also addresses the Gerald | | 12 | | Tucker expenses, and the fourth proposed disallowance relating to | | 13 | | depreciation in his rebuttal testimony. | | 14 | | | | 15 | Q. | PLEASE ADDRESS STATE AGENCIES' RECOMMENDATION TO | | 16 | | DISALLOW RATE CASE EXPENSES ASSOCIATED WITH INCENTIVE | | 17 | | COMPENSATION. | | 18 | A. | Like OPUC, State Agencies recommends that ETI rate case expenses | | 19 | | associated with the recovery of financial-based incentive compensation be | | 20 | | disallowed. ^[20] For the reasons explained above, this recommendation | | 21 | | should be rejected. |

| 1 | Q. | PLEASE ADDRESS STATE AGENCIES' RECOMMENDATION TO | | :--: | :--: | :--: | | 2 | | DISALLOW RATE CASE EXPENSES ASSOCIATED WITH THE | | 3 | | SERVICES OF GERALD TUCKER. | | 4 | A. | State Agencies bases this recommendation, generally, on the contention | | 5 | | that Gerald Tucker's services were not described in sufficient detail and | | 6 | | appear to be duplicative of services provided by other ETI consultants or | | 7 | | employees. ^[21] | | 8 | | As explained in my direct and supplemental direct testimonies, ^[22] | | 9 | | Gerald Tucker was engaged to assist the Company with the rate case, | | 10 | | including proving up its affiliate expenses, consistent with the burden of | | 11 | | proof set out by the Commission in Docket No. 16705 and in subsequent | | 12 | | guidelines. Mr. Tucker, who reviewed all affiliate cost testimony and | | 13 | | exhibits, has been engaged in a similar role in every ETI base rate case | | 14 | | since Docket No. 16705. State Agencies in effect makes ETI's point | | 15 | | regarding the value of Mr. Tucker's services by noting that the Company | | 16 | | has not incurred the affiliate cost-related disallowances experienced in | | 17 | | Docket No. 16705 since utilizing the services of Mr. Tucker in this | | 18 | | capacity. ^[23] | | 19 | | State Agencies suggests that, because Mr. Tucker's billings point to | | 20 | | issues also addressed and types of tasks also performed by Duggins | | 21 | | Wren attorneys, Mr. Tucker's services are duplicative. However, the | | 21 | | State Agencies' Recommendations at 4-5. | | 22 | | Direct Testimony of Stephen F. Morris at 16-17; Supplemental Direct Testimony (Oct. 5, | | 23 | | 2012) at 10-11. | | 23 | | State Agencies' Recommendations at 5. |

| Entergy Texas, Inc. | Page 13 of 14 | | :--: | :--: | | 1 | notion that multiple people with varied backgrounds and expertise cannot | | 2 | provide valuable input on a topic as complex and important as affiliate | | 3 | expenses, especially considering the burden ETI bears to prove up such | | 4 | expenses, is overly simplistic and wrong. Mr. Tucker provides the | | 5 | perspective of a CPA (as opposed that of an attorney), as State Agencies | | 6 | itself notes, as well as that of someone whose lengthy history with the | | 7 | Company has resulted in an intimate familiarity with ETI's affiliate costs | | 8 | and the process of allocating such costs. ^[24] | | 9 | The types of services provided by Mr. Tucker are critically important | | 10 | to the overall effective preparation and presentation of ETI's rate cases | | 11 | and, specifically, its success in recovering affiliate expenses since Docket | | 12 | No. 16705. Mr. Tucker's hourly rate of $\backslash$ 250$ is quite reasonable | | 13 | considering his substantial experience and expertise in a niche field. The | | 14 | Commission should reject State Agencies' generalized argument that Mr. | | 15 | Tucker's services are merely duplicative of those provided by others. | | 16 | | | 17 | PLEASE ADDRESS STATE AGENCIES' RECOMMENDATION TO | | 18 | DISALLOW RATE CASE EXPENSES ASSOCIATED WITH THE | | 19 | "LESSONS LEARNED" ANALYSIS PERFORMED BY THE COMPANY? | | 20 | This recommendation is illogical and should be rejected. The Company | | 21 | provided a detailed description of the content and purpose of its "lessons |

| 1 | learned" memorandum in its response to Staff RFI 13-7, ^[25] despite the | | :--: | :--: | | 2 | privileged nature of the document and analysis at issue. The Company's | | 3 | response supports recovery of the costs at issue. Rate case expenses | | 4 | related to ETI's "lessons learned" analysis and memorandum reflect the | | 5 | Company's attempt to identify areas of potential improvement in the | | 6 | presentation of its case, and address criticisms levied in prior rate cases | | 7 | by the Commission and other parties. The review associated with these | | 8 | costs included consideration not only of ETI's prior rate cases but also four | | 9 | other recent PUCT cases that had taken place since ETI's last rate case. | | 10 | Incurring these costs to analyze lessons learned from litigating prior rate | | 11 | cases and important aspects of non-ETI Commission precedent, if | | 12 | anything, reduces overall rate case expenses by supporting a more | | 13 | efficient case presentation and avoiding prior issues that lead to | | 14 | contention among the parties. The Commission should reject State | | 15 | Agencies' attempt to penalize ETI for learning from the past. | | 16 | | | 17 | Q. DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY? | | 18 | A. Yes, it does. |

ORIGINAL

KENNEDY REPORTING SERVICE

POC OPEN MEETING $2/3/2011$

COMM. NELSON: And I would uphold it on the one you just talked about, Barry. CHAIRMAN SMITHERMAN: So the next issue is the long-term incentive expenses issue. COMM. NELSON: I agree with the PFD, because I think there's a long-standing policy of denying requests to include long-term incentives as a component of rates. CHAIRMAN SMITHERMAN: Agreed. Ken, are you okay with -- COMM. ANDERSON: I am, based on precedent. I still think, as I think I expressed in the oncor case, that a properly organized and evidenced -- and I'm not criticizing anybody. You know, I think incentive compensation is a good thing. I will agree with my colleagues, but based entirely on -- that it's been long-standing Commission precedent. so adopt the PFD on long-term incentive expenses. Then we've got short-term incentive expenses where I would also adopt the PFD. COMM. NELSON: Yes. COMM. ANDERSON: I would, too. One of the questions I had initially, Mr. Chairman, is, was the PFD consistent with our precedent, but I note that there's KENNEDY REPORTING SERVICE, INC. 512.474 .2233

TRANSCRIPT OF PROCEEDINGS BEFORE THE PUBLIC UTILITY COMMISSION OF TEXAS AUSTIN, TEXAS IN THE MATTER OF THE OPEN MEETING) OF THURSDAY, JULY 2, 2009

OPEN MEETING

THURSDAY, JULY 2, 2009

BE IT REMEMBERED THAT AT approximately 9:33 a.m., on Thursday, the 2nd day of July 2009, the above-entitled matter came on for hearing at the Public Utility Commission of Texas, 1701 North Congress Avenue, William B. Travis Building, Austin, Texas, before BARRY T. SMITHERMAN, CHAIRMAN, DONNA L. NELSON AND KENNETH W. ANDERSON, JR., COMMISSIONERS; and the following proceedings were reported by Lou Ray and William C. Beardmore, Certified Shorthand Reporters of:

1 The home loan or the loan purchase is a little 2 different issue in my mind. It's wrapped up in my analysis on an 4 issue later on in the financial incentives - 5 basically bonuses -- for the distinction between 6 operational and financial metrics. I will probably as 7 we get there say that I probably will agree to adopt 8 the PFD but only because I think Commission precedent 9 almost compels the decision. I personally -- I'm not sure that in 11 today's business environment that's how I would come 12 out if it were a case of first impression, which is 13 why then going back to the home purchase loan program, 14 while it's different I want to reflect on it more. 15 CHAIRMAN SMITHERMAN: Okay. The next 16 item is the sale of the accounts receivable. On this 17 one, I thought that oncor demonstrated that they had 18 legitimate reasons for doing that and articulated a 19 number of reasons why they stopped doing it. So I 20 think that means I'm upholding the ALJ's decision in 21 that regard. COMM. ANDERSON: I agree with you, 23 Mr. Chairman, in that regard. That's one where I am 24 fine with what the Judges decided. CHAIRMAN SMITHERMAN: Well, as you know, RENNEDY REPORTING SERVICE, INC. 512.474 .2233

TRANSCRIPT OF PROCEEDINGS

BEFORE THE

PUBLIC UTILITY COMMISSION OF TEXAS AUSTIN, TEXAS

IN THE MATTER OF THE OPEN MEETING OF THURSDAY, JULY 30, 2009

OPEN MEETING

THURSDAY, JULY 30, 2009

BE IT REMEMBERED THAT AT approximately 9:30 a.m., on Thursday, the 30th day of July 2009, the above-entitled matter was heard at the offices of the Public Utility Commission of Texas, 1701 North Congress Avenue, William B. Travis Building, Commissioners' Hearing Room, Austin, Texas 78701, before BARRY T. SMITHERMAN, Chairman, DONNA L. NELSON and KEN W. ANDERSON, Commissioners; and the following proceedings were reported by William C. Beardmore and Lou Ray, Certified Shorthand Reporters of:

KENNEDY REPORTING SERVICE, INC. 512.474 .2233

| 1 | say every time there's an up-tick in the market, I'm a seller. | | :--: | :--: | | 3 | Moving on to incentive comp -- | | 4 | COMM. ANDERSON: Yes, because I'm afraid | | 5 | we're looking at a more decade of the seventies -- | | 6 | (Laughter) | | 7 | COMM. ANDERSON: -- than we are a turn | | 8 | around from the early -- from the drop in the -- | | 9 | COMM. NELSON: And you could be right | | 10 | and it could be -- | | 11 | COMM. ANDERSON: I hope I'm wrong. So | | 12 | does my $401(k)$ . | | 13 | CHAIRMAN SMITHERMAN: Incentive comp. I | | 14 | think we're in agreement -- Ken, you said you were | | 15 | inclined to adopt but you wanted to spend some time on this issue -- | | 17 | COMM. ANDERSON: Yeah. And where I came | | 18 | down is -- is I believe -- I'm voting to adopt the PFD | | 19 | both here and in -- in another place, but really only | | 20 | because -- only because I think precedent -- the | | 21 | precedent of this Commission, I think, compels it. | | 22 | Where I -- I think the distinction between reliability | | 23 | incentives and -- or operational incentives and | | 24 | financial are sort of artificial and not particularly | | 25 | what you want in place anyway to incent your |

KENNEDY REPORTING SERVICE, INC. 512.474 .2233

RESUME OF GERALD W. TUCKER

Education BSBA, Accounting, University of Arkansas - 1968 Memberships American Institute of Certified Public Accountants Texas Society of Certified Public Accountants

Jan. 1993 to Current Independent consultant providing assistance in accounting and financial matters for regulated utilities, management audit services for utility systems and cost damage quantification services. Served as arbitrator on dispute regarding utility accounting issue. Regulated utility services include supporting multi-jurisdictional utility systems that are members of holding company systems. Areas of support are: cost of service development; rate base development; lead/lag studies; affiliate transactions analysis and support; unbundling analysis and implementation for retail access; and, regulatory proceedings necessary to establish Regional Transmission Organizations.

Prior Experience Vice President and CFO, The Nielsen-Wurster Group January 1990 to Dec. 1992 Duties included overall responsibility for accounting, personnel and financial areas of management consulting firm located in Princeton, NJ. Responsible also for management consulting in accounting and financial matters for regulated utilities and technical expertise in litigation support services on construction disputes.

August 1986 - Jan. 1990 Controller of Central Power and Light Company (CPL), Corpus Christi, Texas. CPL was a member of the American Electric Power Company. System (AEP) (formerly Central and South West Corp. (CSW)) and served approximately 600,000 customers in a 44,000 square mile service territory in South Texas. CPL was part owner of the two-unit South Texas Project nuclear power plant.

Responsible for all accounting functions including: tax, property, general and financial, budgets and payroll. Duties included reporting to the Securities and Exchange Commission, the Federal Energy Regulatory Commission (FERC) and primary responsibility for all rate filings in the retail and wholesale jurisdictions. The Controllers department included approximately 80 professional and clerical employees.

July 1974 - 1986

Southwestern Electric Power Company (SWEPCO), Shreveport, LA.

Duties at SWEPCO, which is also a member of the AEP System, were primarily related to regulatory accounting matters. Most recent position was as Manager of Accounting Services with responsibility for regulatory accounting, budgets, financial reporting and property accounting functions.

Previous position was Supervisor of Regulatory Accounting with responsibility for all financial issues in rate filings before three state utility commissions and the FERC. During this five year period the regulatory accounting area was staffed and provided support for 15 rate filings. Other duties included negotiation of power contracts and the sale of power production facilities to other public and private utilities.

1968 - 1974

Testimony Experience as witness in regulatory proceedings in Texas, Arkansas, Louisiana, Georgia, Oklahoma and FERC jurisdictions. Served as expert witness in various construction disputes.

Testimony Filed By Gerald W. Tucker in All Proceedings

| Jurisdiction | Docket No. | Date | Utility | Party Represented | Topics Addressed | | :--: | :--: | :--: | :--: | :--: | :--: | | Federal Energy Regulatory Commission | ER85-194 | 1985 | Southwestern Electric Power Company | Utility | Cost of Service, Jurisdictional Separation, Working Capital, Rate Base | | Federal Energy Regulatory Commission | ER85-424 | 1985 | Southwestern Electric Power Company | Utility | Formula Rates | | Arkansas Public Service Commission | 85-231-U | 1985 | Southwestern Electric Power Company | Utility | Cost of Service, Jurisdictional Separation, Working Capital, Rate Base | | Public Utility Commission of Texas | 7560 | 1988 | Central Power and Light Company | Utility | Deferred Accounting | | Public Utility Commission of Texas | 8646 | 1989 | Central Power and Light Company | Utility | Cost of Service, Rate Base, Deferred Accounting, Phase in Plan | | US District Court Southern District of New York | CV-91-2894 | 1993 | LILCO vs. Stone and Webster | Contractor | Damages Claim in Construction Litigation | | Georgia Public Service Commission | 14311-U | 2002 | Atlanta Gas Light Company | Utility | Affiliate Transactions | | Railroad Commission of Texas | GUD 9400 | 2003 | TXU Gas Company | Allied Coalition of Cities | Taxes Other Than Income Taxes, Regulatory Assets, Cash Working Capital | | Public Utility Commission of Texas | 28840 | 2004 | AEP Texas Central Company | Cities | Cash Working Capital, Affiliate Transactions | | Oklahoma Corporation Commission | $\&\text{PUD}\&200400187$ | 2004 | CenterPoint Energy Arkla | Utility | Cash Working Capital | | Public Utility Commission of Texas | 28813 | 2004 | Cap Rock Electric Corporation | Utility | Cost of Service, Taxes, Executive Compensation, Rate Case Expenses | | Railroad Commission of Texas | GUD 9533 | 2004 | CenterPoint Energy Entex South Texas Division | Utility | Cash Working Capital |

Testimony Filed By Gerald W. Tucker in All Proceedings

| Jurisdiction | Docket No. | Date | Utility | Party Represented | Topics Addressed | | :--: | :--: | :--: | :--: | :--: | :--: | | ${361}^{\text{st}}$ District Court of Brazos County, Texas | Cause No. 05-003360-CV-361 | 2007 | Saquib Ejaz, et al. vs. Texas A&;M University, et al | Plaintiff | Appropriate Accounting for Fixed Assets | | Public Utility Commission of Texas | 33309 | 2007 | AEP TCC | Cities | Cash Working Capital and Affiliate Costs | | Public Utility Commission of Texas | 33310 | 2007 | AEP TNC | Cities | Cash Working Capital and Affiliate Costs | | Public Utility Commission of Texas | 37690 | 2009 | El Paso Electric | Utility | Cost of Service and Pro Forma Adjustments | | Public Utility Commission of Texas | 40094 | 2112 | El Paso Electric | Utility | Cash Working Capital |

Non-Testifying Cases in Which Gerald W. Tucker Participated

| Jurisdiction | Docket No. | Date | Utility | Party Represented | Topics Addressed | | :--: | :--: | :--: | :--: | :--: | :--: | | Public Utility Commission of Texas | 12820 | 1994 | Central Power and Light Company | Utility | Cost of Service, Assistance to Counsel | | Public Utility Commission of Texas | 13650 | 1994 | Central Power and Light Company | Utility | Fuel Reconciliation | | Public Utility Commission of Texas | 13126 | 1994 | Central Power and Light Company | Utility | STP Outage Prudence | | Public Utility Commission of Texas | 13369 | 1994 | West Texas Utilities Company | Utility | Cost of Service, Affiliate Transactions, Assistance to Counsel | | Public Utility Commission of Texas | 14965 | 1995 | Central Power and Light Company | Utility | Cost of Service, Affiliate Issues, Assistance to Counsel | | Oklahoma Corporation Commission | 9600214 | 1997 | Public Service Company of Oklahoma | Utility | Cost of Service, Assistance to Counsel | | Public Utility Commission of Texas | 16705 | 1997 | Entergy Gulf States Inc. | Utility | Cost of Service, Affiliate
Transactions, Assistance to Counsel | | Public Utility Commission of Texas | 20150 | 1998 | Entergy Gulf States Inc. | Utility | Affiliate Transactions, Assistance to Counsel | | Missouri Public Service Commission | GR-98-140 | 1998 | Missouri Gas Energy | Utility | Working Capital | | Louisiana Public Service Commission | U-23358 | 1999 | Entergy Gulf States Inc. | Utility | Cost of Service, Assistance to Counsel | | Public Utility Commission of Texas | 21111 | 1999 | Entergy Gulf States Inc. | Utility | Fuel Reconciliation, Assistance to Counsel | | Public Utility Commission of Texas | 21957 | 1999 | Entergy Gulf States Inc. | Utility | Cost of Service, Affiliate
Transactions, Assistance to Counsel | | Public Utility Commission of Texas | 21441 | 1999 | Central and South West Services | Utility | Assistance to Counsel | | Public Utility Commission of Texas | 30123 | 2004 | Entergy Gulf States Inc. | Utility | Affiliate Transactions, Assistance to Counsel | | Public Utility Commission of | 31544 | 2005 | Entergy Gulf States Inc. | Utility | Affiliate Transactions, Assistance to |

Non-Testifying Cases in Which Gerald W. Tucker Participated

| Jurisdiction | Docket No. | Date | Utility | Party Represented | Topics Addressed | | :--: | :--: | :--: | :--: | :--: | :--: | | Texas | | | | | Counsel | | Louisiana Public Service Commission | U-23327-A | 2006 | Southwestern Electric Power Company | Utility | Analysis of filing | | Public Utility Commission of Texas | 32766 | 2006 | Southwestern Public Service Company | Utility | Affiliate Transactions, Assistance to Counsel | | Public Utility Commission of Texas | 35763 | 2007 | Southwestern Public Service Company | Utility | Affiliate Transactions, Assistance to Counsel | | Public Utility Commission of Texas | 34800 | 2007 | Entergy Gulf States Inc. | Utility | Affiliate Transactions, Assistance to Counsel | | Louisiana Public Service Commission | U-30689 | 2007 | CLECO | Utility | Cost of Service | | Georgia Public Service Commission | 27800 | 2008 | Georgia Power | Utility | Prudence of Construction Program | | Missouri Public Service Commission | ER-2009-0089 | 2008 | Kansas City Power and Light | Utility | Prudence of Construction Program | | Kansas Corporation Commission | 09-KCPE-246RTS | 2008 | Kansas City Power and Light | Utility | Prudence of Construction Program | | New Mexico Public Regulation Commission | 08-00354-UT | 2008 | Southwestern Public Service Company | Utility | Assistance to Counsel | | Public Utility Commission of Texas | 37744 | 2009 | Entergy Texas Inc. | Utility | Affiliate Transactions, Assistance to Counsel | | Kansas Corporation Commission | 10-KCPE-415RTS | 2009 | Kansas City Power and Light | Utility | Prudence of Construction Program | | Missouri Public Service Commission | ER-2010-0355 | 2009 | Kansas City Power and Light | Utility | Prudence of Construction Program | | Public Utility Commission of Texas | 38147 | 2010 | Southwestern Public Service Company | Utility | Affiliate Transactions, Assistance to Counsel | | New Mexico Public Regulation Commission | 10-00395-UT | 2011 | Southwestern Public Service Company | Utility | Affiliate Transactions, Assistance to Counsel | | Indiana Utility Regulatory | 43114 IGCC-4 | 2011 | Duke Energy Indiana | Utility | Prudence of Construction Program |

Non-Testifying Cases in Which Gerald W. Tucker Participated

| Jurisdiction | Docket No. | Date | Utility | Party Represented | Topics Addressed | | :--: | :--: | :--: | :--: | :--: | :--: | | Commission | &; 4S1 | | | | | | Indiana Utility Regulatory Commission | 43114 IGCC-4
&; 4S1 | 2011 | Duke Energy Indiana | Utility | Investigation of Fraud,
Mismanagement and Concealment | | Public Utility Commission of Texas | 39896 | 2011 | Entergy Texas Inc. | Utility | Affiliate Transactions, Assistance to Counsel | | Public Utility Commission of Texas | 40824 | 2012 | Southwestern Public Service Company | Utility | Affiliate Transactions, Assistance to Counsel | | New Mexico Public Regulation Commission | 10-00395-UT | 2012 | Southwestern Public Service Company | Utility | Affiliate Transactions, Assistance to Counsel |

ENTERGY TEXAS, INC.
PUBLIC UTILITY COMMISSION OF TEXAS
SOAH DOCKET NO. 473-12-2979
PUC DOCKET NO. 39896 - 2011 ETI Rate Case

Response of: Entergy Texas, Inc. to the Thirteenth Set of Data Requests of Requesting Party: Commission Staff

Prepared By: Counsel Sponsoring Witness: Robert D. Sloan Beginning Sequence No. Ending Sequence No.

Question No.: Staff 13-7 Part No.: Addendum:

Question:

Reference the Duggins Wren July 26, 2011 invoice provided in response to Staff's 9-1, page 3 of 8 . Please provide the "lessons learned issues from/since last rate case" memo referenced in the Description of Services section of the invoice.

Response:

To address ETI objections that the memo requested in this RFI is subject to attorneyclient and work product privileges, and based on discussions between counsel for ETI and counsel for Staff, ETI responds to the question by providing a description of the memo at issue as follows:

The "lessons learned" memo provided a detailed analysis of developments in ETI's last rate case as well as developments in four recent pertinent cases at the PUCT that had taken place since the last ETI rate case. The memo also addressed certain recent cases in the Texas courts. The memo was prepared primarily by Everett Britt, a partner at Duggins Wren Mann &; Romero, LLP, for and at the request of Steve Neinast, Assistant General Counsel at Entergy Services. Inc. (and lead counsel for ETI in this proceeding), and Barry Howell, Manager of Texas Regulatory Affairs for ETI. The memo described and identified both procedural and substantive issues in those cases for ETI to consider in assembling a new rate case in the second half of 2011 . The research and analysis underlying the memo included identifying pertinent recent cases and then reviewing all of the interim and final orders in the various cases, a lengthy proposal for decision, and testimony, discovery, and other pleadings in each of the cases as needed for a full understanding of the issues that arose in each case. The resulting memo was thirteen pages, single-spaced, and it included over 100 individually numbered or bulleted items/issues. The first part of the memo focused on ETI's last rate case and presented issues for the Company's consideration in filing a new rate case, while the second part of the memo provided detailed descriptions of the other four recent pertinent cases. The July 26, 2011 invoice indicates that the primary billing attorney spent 16.1 hours on this project while two other partners spent a total of 5.6 hours on the project. The primary

Chapter 2

Question No.: Staff 13-7

billing attorney on the project is one of the more junior partners at the law firm, and his billing rate on the project was $\backslash$ 255 $perhourfor16.1hours,whichisamongthelowestratesofthepartnersatthefirmandiswellbelowtheaveragemarketbillingratesforlawfirmpartnersidentifiedintheDirectTestimonyofCompanywitnessStephenMorris.Thebillingofthetwomoreseniorpartnerswhoworkedonthisprojectwas4.9hoursat$ \ $330$ per hour and .7 hours at $\backslash$ 350$ per hour, which are also below the average market billing rates for partners described in Mr. Morris's testimony. In particular, Mr. Morris's testimony states on his pages 11-12:

The rates of DWMR range from $\backslash$ 195-385 $perhourforpartnersand$ \ $170-215$ per hour for associates. I compared these rates against the average hourly rates of firms of the size that typically represent utilities in rate applications before the Commission. The average rates were taken from the Texas Lawyer 2011 Hourly Billing Rate Survey. That survey indicates that the average partner rate of a firm with over 100 lawyers ranges from $\backslash$ 447 $to$ \ $570$ per hour. That survey also indicates that the average associate rate of a firm with over 100 lawyers ranges from $\backslash$ 273 $to$ \ $393$ per hour. The firms that typically represent investor-owned utilities before the PUCT in rate applications often have more than 100 lawyers.

DOCKET NO. 39896

APPLICATION OF ENTERGY TEXAS, INC. FOR AUTHORITY TO CHANGE RATES AND RECONCILE FUEL COSTS § PUBLIC UTILITY COMMISSION $\S$ $\S$ $\S$

DIRECT TESTIMONY

OF

STEPHANIE B. TUMMINELLO

ON BEHALF OF

ENTERGY TEXAS, INC.

NOVEMBER 2011

Entergy Texas, Inc. Page 1 of 98 Direct Testimony of Stephanie B. Tumminello 2011 Rate Case

1 I. NAME AND QUALIFICATIONS Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Stephanie B. Tumminello. During the Commission's last review in Docket No. 37744 and during the test period in this case through June 24, 2011, my name was Stephanie B. Neyland. My business address is 639 Loyola Avenue, New Orleans, LA 70113.

7 Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? A. I am employed by Entergy Services, Inc. ("ESI" or "Entergy Services") as

10 Manager of Affiliate Accounting and Allocations, which was formerly 11 Intrasystem Affiliate Billing ("ISABill"). ^[1] Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING? A. I am testifying on behalf of Entergy Texas, Inc. ("ETI" or the "Company"). Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND. A. I have a Bachelor of Science degree in Accounting from the University of New Orleans. I am a Certified Public Accountant licensed in the State of

Louisiana.

| 1 | Q. | PLEASE BRIEFLY DESCRIBE YOUR PROFESSIONAL EXPERIENCE. | | :--: | :--: | :--: | | 2 | A. | I have been employed by ESI for approximately 15 years and have held various positions in the Accounting and Finance organizations. ESI is one of the service companies providing services to Entergy Corporation and its subsidiaries. ^[2] My work experience is described in more detail in Exhibit SBT-1. | | 7 | | | | 8 | Q. | WHAT ARE THE PRINCIPAL AREAS OF YOUR RESPONSIBILITY AS | | 9 | | MANAGER OF AFFILIATE ACCOUNTING AND ALLOCATIONS? | | 10 | A. | I am responsible for the intrasystem affiliate billing processes of the | | 11 | | Entergy Service Companies: ESI, Entergy Operations, Inc. ("EOI"), | | 12 | | Entergy Enterprises, Inc. ("EEI"), and Entergy Nuclear Operations, Inc. | | 13 | | ("ENUC"). I oversee these companies' billing processes and procedures | | 14 | | to ensure they are in compliance with applicable requirements of the retail regulators of the Entergy Operating Companies, ^[3] the Public Utility Holding | | 15 | | Company Act of 2005 ("PUHCA 2005"), and Federal Energy Regulatory Commission ("FERC") regulations. ^[4] |

My responsibilities also include billings, allocations, approval of billing method assignments on project codes, and updating and maintaining processes for allocations related to the affiliates. I have overall responsibility for all affiliate billing functions. my responsibilities include oversight for the review of the elements of billable project code ("PC") requests and the approval of each billable PC. I am also responsible for analyzing the amounts billed to affiliates to ensure that the billing process is efficient and effective. In addition, I have oversight for the provision of advice and training for ESI employees regarding affiliate billing issues. My accounting responsibility for ESI as a business unit ("BU"; also known as "legal entity" or "LE") includes providing information required for the preparation of the ESI FERC Form 60, Annual Report of Centralized Service Companies, as well as the FERC Form 60 reports for EOI, EEI and ENUC.

II. INTRODUCTION

Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? A. The primary purpose of my testimony is to provide an overview of ETI's affiliate case. I also discuss the regulation of affiliate transactions. In addition, I explain how the affiliate portion of the Company's filing is organized. I address several affiliate transaction-related issues, such as the affiliate billing processes used by ESI, the Operating Companies, other

| 1 | regulated affiliates, ^[5] and non-regulated affiliates to collect and bill costs to | | :--: | :--: | | 2 | their affiliates, including ETI, for services rendered. A more detailed | | 3 | discussion of the purpose of my testimony is provided below. | | 4 | Affiliate Case Layout: In the Affiliate Case Layout section of my | | 5 | testimony, I describe how affiliate charges to ETI have been organized | | 6 | into classes, explain how the affiliate case is organized and how it ties to | | 7 | the G-6 schedules and supporting workpapers, ^[6] and introduce the other | | 8 | affiliate witnesses. I describe how the information in this filing is presented | | 9 | for the purpose of showing: | | 10 | - affiliate costs charged to ETI are necessary; | | 11 | - affiliate costs charged to ETI are reasonable; | | 12 | - the prices charged to ETI for each class of items are no | | 13 | higher than the prices charged to other affiliates, or to | | 14 | non-affiliates, for the same or similar class of items; and | | 15 | - the allocated amounts represent the actual cost of services | | 16 | to ETI. | | 17 | I also explain why the affiliate costs charged to ETI do not include | | 18 | prohibited expenses and that the services provided to ETI by affiliates are | | 19 | not duplicative of services provided internally by ETI or other affiliates. | | 20 | Each affiliate cost witness will provide testimony supporting the | | 21 | reasonableness and necessity of the specific affiliate classes that he or |

| 1 | she sponsors. | These affiliate witnesses will also support the appropriateness of the billing methods that are used for the classes that they address. Exhibits that show, in consistent formats, the affiliate expenses for each class accompany each witness's testimony. As the affiliate overview witness, my testimony collects and assembles all of those individual class exhibits into one exhibit for ease of review. | | :--: | :--: | :--: | | 7 | Affiliate Transaction-Related Issues: | In connection with my discussion of the affiliate billing processes, I will: | | 8 | (a) | provide background information regarding Entergy Corporation and its regulated and non-regulated subsidiaries; | | 10 | | (b) describe the affiliate billing process, including discussions regarding project billings, loaned resource billings, co-owner billings, and controls; | | 11 | | (c) discuss the ESI service billings, including an overview of the billing process, a summary of ESI charges to affiliated companies, the service company recipient allocation process, billing methods, and allocation rates and statistics; | | 12 | | (d) discuss billings to ETI during the test year; and | | 13 | | (e) describe the pro forma adjustments associated with the affiliate billings to ETI included in this filing and discuss those pro forma adjustments that I sponsor. | | 14 | | | | 15 | | (c) Depreciation (which pertains to depreciation and amortization of ESI assets used in providing services); (2) Service | | 16 | | Company Recipient Offsets (sometimes referred to as "Shared Services | | 17 | | | | 18 | | | | 19 | | | | 20 | | (3) Other Expenses. | | 21 | | | | 22 | | | | 23 | | |

1 Q. WHAT EXHIBITS ARE YOU INCLUDING AS PART OF YOUR TESTIMONY? A. The exhibits that I am including as part of my testimony appear in the list following the Table of Contents. Because these exhibits are voluminous and include a number of spreadsheets, I have provided all of my exhibits, workpapers, and schedule information on the attached CD, labeled Exhibit SBT-F, rather than in paper form.

8 Q. DO YOU SPONSOR OR CO-SPONSOR ANY SCHEDULES IN THE RATE FILING PACKAGE? A. Yes, I co-sponsor several Rate Filing Package ("RFP") schedules filed in this proceeding. I am co-sponsoring with other witnesses the following schedules:

• Schedule G-6
• Schedule G-6.1
• Schedule G-6.2

17 I am also co-sponsoring the following workpapers included in support of Schedule G-6 of the RFP:

| | G-6 WPs | G-6.1 WPs | G-6.2 WPs | | :--: | :--: | :--: | :--: | | 20 | WP/G-6 (set 1) | WP/G-6.1 (set 1) | WP/G-6.2 (set 1) | | 21 | WP/G-6 (set 2) | WP/G-6.1 (set 2) | WP/G-6.2 (set 2) | | 22 | WP/G-6 (set 3) | WP/G-6.1 (set 3) | WP/G-6.2 (set 3) | | 23 | WP/G-6 (set 4) | WP/G-6.1 (set 4) | WP/G-6.2 (set 4) |

| 1 | WP/G-6 (set 5) | WP/G-6.1 (set 5) | WP/G-6.2 (set 5) | | :--: | :--: | :--: | :--: | | 2 | WP/G-6 (set 6) | WP/G-6.1 (set 6) | WP/G-6.2 (set 6) | | 3 | | These schedules and supporting workpapers were prepared by me | | | 4 | | or under my direct supervision. | | | 5 | | | | | 6 | Q. | ON WHAT BASIS WERE THE SCHEDULES THAT YOU JUST | | | 7 | | MENTIONED PREPARED? | | | 8 | A. | They were prepared from the books and records of ESI and its affiliates | | | 9 | | and are accurate summaries of the business records on which they are | | | 10 | | based. Deloitte &; Touche LLP ("D&;T"), the independent auditor for | | | 11 | | Entergy Corporation and subsidiaries, has performed a review of the | | | 12 | | historical financial information included in Schedules A through W | | | 13 | | (excluding L and R ) of the RFP, and have reported its findings in | | | 14 | | Schedule S. | | | 15 | | | | | 16 | Q. | WHAT TEST YEAR IS ETI USING IN THIS FILING? | | | 17 | A. | The test year in this case is the twelve months ended June 30, 2011. | | | 18 | | | | | 19 | Q. | WHAT IS THE DOLLAR AMOUNT OF AFFILIATE CHARGES THAT ETI | | | 20 | | HAS INCLUDED IN THE TEST YEAR COST OF SERVICE? | | | 21 | A. | RFP Schedule G-6 shows that the Company's "Total ETI Adjusted" | | | 22 | | amount for affiliate charges for the test year is $\backslash$ 78,998,777$. | |

subsidiaries. Exhibit SBT-3 is an organization chart for Entergy Corporation and its subsidiaries, including both regulated and direct nonregulated companies, as of June 30, 2011.

Q. PLEASE BRIEFLY DESCRIBE ENTERGY CORPORATION AND ITS

WHOLLY-OWNED REGULATED SUBSIDIARIES.

A. Entergy Corporation owns all of the outstanding common stock of six retail Operating Company subsidiaries: ETI, EAI, EGSL, ELL, EMI, and ENOI. As of June 30, 2011, these Operating Companies provided electric service to approximately 2.7 million customers in the states of Arkansas, Louisiana, Mississippi, and Texas.

Entergy Corporation also owns all of the outstanding common stock of System Energy, ESI, and EOI, which are regulated by the Nuclear Regulatory Commission ("NRC") and/or the FERC. System Energy is a nuclear generating company that sells the generating capacity and energy from its $90\%$ interest in the Grand Gulf nuclear plant at wholesale to its only customers: EAI, ELL, EMI, and ENOI. ESI is a service company established to provide professional services primarily to Entergy's regulated utilities or Operating Companies.

EOI is also a service company, and was established to provide nuclear management and operations and maintenance services to Entergy's regulated nuclear plants: Arkansas Nuclear One; River Bend;

Waterford 3; and Grand Gulf. Although these plants are operated by EOI, they are owned by: EAI; EGSL; ELL; and System Energy, respectively.

PLEASE PROVIDE AN OVERVIEW OF ENTERGY'S NON-REGULATED SUBSIDIARIES. A. Entergy's non-regulated subsidiaries include, among others, EEI, Entergy Power, LLC ("EPL"), a wholesale power producer that is a subsidiary of Entergy Asset Management, Inc., and ENUC, a service company established to provide nuclear management and operations services to Entergy's non-regulated nuclear plants. For a more detailed discussion of Entergy's direct non-regulated affiliates, please refer to Exhibit SBT-2. Q. FROM WHICH OF THE ENTERGY SUBSIDIARIES DOES ETI RECEIVE THE MOST SIGNIFICANT LEVEL OF AFFILIATE CHARGES? A. ETI receives the most significant level of affiliate charges from ESI. In addition to affiliate charges from ESI, ETI receives charges from the other Operating Companies, EOI, and from certain non-regulated affiliates. Q. WHY IS ESI THE SOURCE OF MOST OF ETI'S AFFILIATE CHARGES? A. Centralization of activities through the creation of service companies results in economies of scale and provides a pool of centralized expertise for Entergy Corporation's regulated utility affiliates. As noted previously, ESI, EOI, EEI, and ENUC are the four primary service companies. EOI

provides services to the regulated nuclear plants, and EEI and ENUC provide services to non-regulated affiliates, as more fully described in Exhibit SBT-2. I provide an overview of the services provided by ESI.

Q. PLEASE DESCRIBE THE PURPOSE AND FUNCTION OF ESI.

A. ESI is authorized to conduct business as a service company by a temporary order issued by the Securities and Exchange Commission ("SEC") in March 1963, which was made permanent in March 1965. ESI was formed as, and continues to be, primarily a service company for the Operating Companies. Costs incurred by ESI to provide services to all regulated companies, including ETI, are billed at cost and do not produce a profit. ESI also performs services for some of Entergy's non-regulated companies through ESI's Service Agreement with EEI. These services are billed at cost plus 5\%. Exhibit SBT-2 provides a more detailed discussion of ESI's purpose and function.

Q. WHAT TYPES OF SERVICES DOES ESI PROVIDE?

A. The services ESI provides to its affiliates include general executive, management, advisory, administrative, human resources, accounting, legal, regulatory, and engineering services. These services are provided in accordance with Service Agreements entered into by ESI and the respective affiliates to which it provides services. The Service Agreements between ESI and its affiliates are included as Exhibits SBT-

4A through SBT-4P. These Service Agreements outline the general types of services that ESI provides.

ESI provides services according to functional groupings that reflect the way ESI is organized. See Exhibits SBT-5 and SBT-6 for details, which I discuss in more detail later in my testimony. These groupings are reflected in the presentation of ETI's affiliate expenses in this filing and represent a compilation of the services that are provided to ETI by ESI.

The types of services outlined in the Service Agreements between ESI and the affiliates that it serves have been grouped in classes that are discussed later in my testimony for the purpose of presentation in this filing. Exhibit SBT-7 shows the affiliates that receive services from ESI. Q. IS THE SERVICE AGREEMENT BETWEEN ESI AND ETI DIFFERENT IN SUBSTANCE FROM THE SERVICE AGREEMENTS ESI HAS WITH THE OTHER AFFILIATED COMPANIES? A. No. The Service Agreements between ESI and each of the other Entergy affiliates discussed previously are the same in substance. However, the types and amounts of services vary among the companies. Q. ARE ALL NON-REGULATED ENTERGY COMPANIES PARTIES TO SERVICE AGREEMENTS WITH ESI? A. No. ESI does not directly provide services to all of the non-regulated affiliates. ESI, however, does provide services directly to EPL and EEI,

| 1 | Q. | ARE THERE ANY PRO FORMA ADJUSTMENTS TO THIS CLASS? | | :--: | :--: | :--: | | 2 | A. | Yes. The pro forma adjustments for the Depreciation Class are shown on | | 3 | | Exhibit SBT-D, which also indicates the Company witnesses who sponsor | | 4 | | those pro forma adjustments, and lists the pro forma adjustments by | | 5 | | account. As indicated on Exhibit SBT-D, I sponsor three pro forma | | 6 | | adjustments to the Depreciation Class. Exhibit SBT-12 describes the pro | | 7 | | forma adjustments to the Depreciation Class in greater detail. | | 8 | | | | 9 | | 2. Necessity | | 10 | Q. | WHAT KINDS OF ASSETS ARE OWNED BY ESI THAT RESULT IN THE | | 11 | | DEPRECIATION THAT IS THEN CHARGED TO THE AFFILIATE | | 12 | | COMPANIES? | | 13 | A. | In order to provide services to its affiliate companies, ESI must invest in | | 14 | | certain depreciable assets to support its operations. These assets consist | | 15 | | primarily of computer equipment, computer software systems, | | 16 | | communications equipment, furniture, fixtures, leasehold improvements, | | 17 | | and aircraft. However, a pro forma adjustment was made to remove | | 18 | | Company aircraft costs, including depreciation on aircraft, from the | | 19 | | Company's cost of service. |

| 1 | Q. | PLEASE DESCRIBE HOW THE DEPRECIATION OF ESI'S ASSETS IS | | :--: | :--: | :--: | | 2 | | CALCULATED. | | 3 | A. | The purpose of depreciation is to distribute the cost of an asset over its expected useful life. Total depreciation expense over the life of an asset | | 4 | | is equal to the asset's cost (less any proceeds realized upon disposal). | | 6 | | ESI uses the straight-line method to calculate the annual depreciation expense for its assets. Use of this depreciation method results in the cost | | 7 | | of an asset being distributed evenly over the expected useful life of the asset. For example, an asset costing $\backslash$ 1,000$ that has an expected service | | 8 | | life of 10 years would result in depreciation expense for this asset of $\backslash$ 100$ | | 9 | | per year for a period of 10 years ( $\backslash$ 1,000 $dividedby10years$ =\ $100$ per | | 10 | | year or $10\%$ a year). This method of calculating depreciation is | | 11 | | appropriate under generally accepted accounting principles. The straightline method is also the most commonly used and accepted depreciation | | 12 | | method. According to an American Institute of Certified Public | | 14 | | Accountants survey of 544 companies in 2009, 89\% use the straight-line | | 15 | | method of depreciation versus other methods, which are primarily accelerated methods of depreciation. ^[16] Exhibit SBT-26 is a summary of | | 16 | | ESI's assets, including plant in service, accumulated depreciation, net plant, and the service life used to calculate depreciation. |

| 1 | Q. | PLEASE EXPLAIN WHY THE DEPRECIATION COSTS BILLED TO ETI | | :--: | :--: | :--: | | 2 | | ARE NECESSARY. | | 3 | A. | ESI requires certain assets to support the operations that provide services | | 4 | | to its affiliates, including ETI. The depreciation cost is the result of | | 5 | | distributing the cost of these assets over their expected service lives to the | | 6 | | recipients of the services provided by ESI. These assets enable ESI to | | 7 | | provide the services required by its affiliates, including ETI, in the most | | 8 | | efficient, effective, and reliable manner possible. Without such assets to | | 9 | | support its operations, ESI could not provide the services that are required | | 10 | | by its affiliates, including ETI. Depreciation of those assets is a necessary | | 11 | | and proper component of the cost of owning and using the assets to | | 12 | | provide services. | | 13 | | | | 14 | | 3. Reasonableness | | 15 | Q. | HAVE YOU REVIEWED THE DEPRECIATION EXPENSE TO | | 16 | | DETERMINE WHETHER THE CHARGES WERE REASONABLE? | | 17 | A. | Yes. The charges to ETI for the costs I sponsor are reasonable for the | | 18 | | operation of ETI because the method of calculating depreciation | | 19 | | (straight-line method) is appropriate under generally accepted accounting | | 20 | | principles and is the most common method used. In addition, the price | | 21 | | charged by ESI to ETI for this item represents the actual cost of this item. |

| 1 | Q. | WHAT OBJECTIVE SOURCES SUPPORT YOUR OPINION THAT THE | | :--: | :--: | :--: | | 2 | | DEPRECIATION COSTS BILLED BY ENTERGY SERVICES TO ETI ARE | | 3 | | REASONABLE? | | 4 | A. | Exhibit SBT-27 is a benchmarking study prepared under my supervision | | 5 | | that compares the dollar amount of assets per employee for ESI to the | | 6 | | dollar amount of assets per employee for other PUHCA 2005 service | | 7 | | companies. This measure, cost of assets per employee, is appropriate | | 8 | | because employees drive the need for assets in service companies. | | 9 | | Because the number of employees would be the primary determinant of | | 10 | | the level of the assets that would be required, assets per employee is a | | 11 | | valid measure. Exhibit SBT-27 compares the service company property | | 12 | | per employee of ESI to the service company property per employee of six | | 13 | | other PUHCA 2005 service companies with at least $\backslash$ 100$ million of service | | 14 | | company property as of December 31, 2010. This exhibit shows ESI's | | 15 | | cost of assets per employee, while slightly higher than the average, is | | 16 | | reasonable compared to that of the other PUHCA 2005 service | | 17 | | companies. This comparison is based on service company headcount | | 18 | | information contained in the respective corporate Forms 10-K and service | | 19 | | company property information contained in each service company's FERC | | 20 | | Form 60 Annual Report for the period ending December 31, 2010. | | 21 | | However, the service company property for Southern Company | | 22 | | Services, Inc., Entergy Services, Inc., Exelon Business Services | | 23 | | Company, and American Electric Power Service Corporation on Exhibit |

| 1 | SBT-27 differs from what was reported on the companies' 2010 FERC | | :--: | :--: | | 2 | Form 60s. These were the only companies that included Transportation | | 3 | Equipment in their Service Company Property. Beginning with the FERC | | 4 | Form 60 Annual Report for the period ending December 31, 2008, the | | 5 | service company property category "Aircraft and Airport Equipment" was eliminated and included in "Transportation Equipment." A pro forma | | 6 | adjusted in "Transportation Equipment." A pro forma adjustment was made (AJ21-01) to remove Company aircraft costs from | | 8 | the Company's cost of service. Therefore, to be consistent with the costs | | 9 | included in this case, the Transportation Equipment was removed from the | | 10 | total Service Company Property for all companies before the | | 11 | benchmarking study was completed. Because the benchmarking study | | 12 | supports the reasonableness of the level of assets being depreciated, and | | 13 | the procedures used to depreciate the assets are appropriate and | | 14 | consistent with well accepted accounting practices, the ultimate level of depreciation is likewise reasonable. | | 15 | With the exception of depreciation on aircraft, ESI distributes the | | 16 | costs associated with the depreciation and amortization of ESI assets | | 17 | based on the labor cost billed to each affiliate. Distributing ESI's depreciation and amortization costs in this manner is an appropriate | | 18 | allocation of these costs because ESI employee labor is a reasonable | | 20 | measure of the level of services provided by ESI employees to affiliates, and employees and the services they provide drive the need for the assets | | 21 | utilized by ESI in its operations. Depreciation on aircraft is included as a |

| 1 | component of total flight costs of ESI aircraft. Flight costs are charged to | | :--: | :--: | | 2 | specific PCs based on the PC(s) associated with the ridership and | | 3 | purpose of a particular flight. However, as noted above, a pro forma | | 4 | adjustment was made to remove Company aircraft costs, including depreciation on aircraft, from the Company's cost of service. | | 6 | | | 7 | 4. How Costs are Charged | | 8 Q. | DO THE DEPRECIATION COSTS CHARGED BY ENTERGY SERVICES | | 9 | TO ETI UNDER THIS CLASS REASONABLY APPROXIMATE THE | | 10 | COSTS OF THOSE ITEMS? | | 11 A. | Yes. The depreciation costs charged are based on the actual costs of the | | 12 | assets supporting ESI's operations and do not include any profit or markup. | | 13 | Q. IS THE PRICE CHARGED TO ETI FOR DEPRECIATION NO HIGHER | | 16 | THAN THE PRICE CHARGED TO OTHER AFFILIATES? | | 17 A. | Yes. The price charged to ETI is no higher than the price charged by ESI | | 18 | to the other affiliates for depreciation on a per unit basis. With the | | 19 | exception of depreciation on aircraft, ESI depreciation expense is loaded onto each ESI labor dollar, and then billed out to affiliates. The depreciation loader is assigned the same PC as labor, so that it properly follows the same billing distribution as the labor dollars on which it is | | 20 | based. As explained in my testimony, each PC is assigned one billing |

method that will most appropriately allocate the charges to the companies receiving the services based on cost-causation principles. Thus, depreciation cost is billed to each affiliate at the same rate for each dollar of labor charged, ensuring that costs are equitably distributed to each affiliate.

HOW ARE THE COSTS OF THIS CLASS CAPTURED AND BILLED TO ETI?

With the exception of depreciation on aircraft, the cost associated with this class is initially captured in Project Code F5PCZUDEPX, Depreciation and Amortization, and then these costs are distributed directly to ESI PCs based on the labor charged to the project codes. The receiving PCs then bill the depreciation costs (along with all other costs charged to the PC) to ESI's affiliates based on the assigned billing method for each project. During the test year, projects receiving depreciation costs billed $\backslash$ 1,777,986$ Total ETI Adjusted, which includes pro forma adjustments, to ETI. Exhibit SBT-B shows the costs included in this class by project code.

WHAT BILLING METHOD IS USED TO ALLOCATE THIS EXPENSE ITEM TO THE VARIOUS ENTITIES THAT RECEIVE SERVICES FROM ESI?

As noted, with the exception of depreciation on aircraft, ESI assigned depreciation costs to projects based on labor charged to projects and then

DOCKET NO. 39836

APPLICATION OF ENTERGY TEXAS, INC. FOR AUTHORITY TO CHANGE RATES AND RECONCILE FUEL COSTS § PUBLIC UTILITY COMMISSION $\S$ $\S$ $\S$

DIRECT TESTIMONY

OF

DANE A. WATSON

ON BEHALF OF

ENTERGY TEXAS, INC.

NOVEMBER 2011

ENTERGY TEXAS, INC.

ELECTRIC PLANT

DEPRECIATION RATE STUDY AT DECEMBER 31, 2010

ENTERGY TEXAS
ELECTRIC PLANT
DEPRECIATION RATE STUDY
EXECUTIVE SUMMARY

Entergy Texas, Incorporated ("ETI" or "Company") engaged Alliance Consulting Group to conduct a depreciation study of the Company's Electric Texas utility plant depreciable assets as of December 31, 2010.

This study was conducted under a traditional depreciation study approach for life and net salvage. The broad group, average life, remaining life depreciation system was used. This methodology has been adopted by numerous state commissions and FERC.

Currently utilized depreciation rates were approved in the 1990s and have been adopted in subsequent stipulations before the Texas PUC.

This study recommends an overall increase of $\backslash$ 16.2 $millioninannualdepreciationexpenseforallaccountscomparedtoratescurrentlyineffect.Thisconsistsofthefollowingchanges:anincreaseof$ \ $1.1$ million for Production Assets, a decrease of $\backslash$ 7 $thousandinannualdepreciationexpenseforHydroaccounts,withanincreaseof$ \ $4.1$ million in depreciation expense for transmission accounts, an increase of $\backslash$ 9.4 $millionfordistributionplantaccounts,adecreaseof$ \ $2.3$ million for general plant accounts that are depreciated, and an increase of $\backslash$ 1.8 $millionforgeneralplantamortizedaccounts,andanadditional$ \ $2.1$ million for the reserve deficiency amortization for assets that are moving to general plant amortization. Appendix A shows the computation of the proposed depreciation rates. Appendix B demonstrates the change in depreciation expense for the various accounts.

FERC Account 397.2 Other Communication Equipment (25 S5)

This account consists of other communication equipment such as microwave equipment and fiber optic equipment used in general utility service. There is approximately $\backslash$ 40.5$ million in this account. This account currently has an S3 curve and life of 19 years. Given that these assets are different in scope than account 397.1 that contains smaller components like telephone systems and portable radios, the assets are best suited to depreciation rather than general plant amortization. There has been limited retirement activity in this account. Based on the life characteristics of the assets in this account, this study recommends moving to a 25 S5 dispersion for this account.

GENERAL PLANT

General Accounts Amortized, FERC Accounts 391.1-397.1 and 398.0

FERC Account 391.1 Office Furniture and Equipment (15 year amortization)

This account consists of miscellaneous office furniture such as desks, chairs, filing cabinets, and tables used for general utility service. There is approximately $\backslash$ 940$ thousand in this account. This account currently has a life of 26 years with an R2.5 dispersion. This study recommends general plant amortization for this account. After performing actuarial analysis, a shorter life than is currently approved was shown. The Company provided a recommended schedule for amortization periods for this account. The Company's recommendation of 15 years is consistent with shorter lives shown in actuarial analysis. Thus, this study recommends moving to a 15 year amortization period for this account.

FERC Account 391.2 Computer Equipment (5 year amortization)

This account consists of computer equipment used for general utility service. There is approximately $\backslash$ 22.5$ million in this account. The account has an approved life of 10 years with an R2.5 dispersion. This study recommends general plant amortization for this account. After performing actuarial analysis, a shorter life than is currently approved was shown. The Company provided a recommended schedule for amortization periods for this account. The Company's recommendation of 5 years is consistent with shorter lives shown in actuarial analysis. Thus, this study recommends moving to a 5 year amortization period for this account.

PUC DOCKET NO. 39896
2012NOV -2 A:t 9:24
SOAH DOCKET NO. 473-12-2979
P.

APPLICATION OF ENTERGY TEXAS, INC. FOR AUTHORITY TO CHANGE RATES, RECONCILE FUEL COSTS, AND OBTAIN DEFERRED ACCOUNTING TREATMENT

PUBLIC UTILITY COMMISSION OF TEXAS

ORDER ON REHEARING

This Order addresses the application of Entergy Texas, Inc. for authority to change rates, reconcile fuel costs, and defer costs for the transition to the Midwest Independent System Operator (MISO). In its application, Entergy requested approval of an increase in annual baserate revenues of approximately $\backslash$ 111.8 $million(laterloweredto$ \ $104.8$ million), proposed tariff schedules, including new riders to recover costs related to purchased-power capacity and renewable-energy credit requirements, requested final reconciliation of its fuel costs, and requested waivers to the rate-filing package requirements.

On July 6, 2012, the State Office of Administrative Hearings (SOAH) administrative law judges (ALJs) issued a proposal for decision in which they recommended an overall rate increase for Entergy of $\backslash$ 28.3 $millionresultinginatotalrevenuerequirementofapproximately$ \ $781$ million. The ALJs also recommended approving total fuel costs of approximately $\backslash$ 1.3$ billion. The ALJs did not recommend approving the renewable-energy credit rider and the Commission earlier removed the purchased-power capacity rider as an issue to be addressed in this docket. ^[1] On August 8, 2012, the ALJs filed corrections to the proposal for decision based on the exceptions and replies of the parties. ^[2] Except as discussed in this Order, the Commission adopts the proposal for decision, as corrected, including findings of fact and conclusions of law.

Parties filed motions for rehearing on September 25 and October 4, 2012 and filed replies to the motions for rehearing on October 15, 2012. The Commission considered the motions for

rehearing at the October 25, 2012 open meeting. The Commission granted Commission Staff's motion for rehearing that requested technical corrections to reflect the rates that resulted from the Commission Staff number-running memo that was filed on August 28, 2012. The Commission modifies findings of fact 205, 206, 208, and 210 as requested by Commission Staff and attaches Commission schedules I through V to reflects its decisions. The Commission granted the Department of Energy's motion for rehearing requesting that finding of fact 198 be modified to reflect the applicable off-season for the schedulable intermittent pumping service. Finding of fact 198 is modified to reflect that the off-season is October through May. In its motion for rehearing, Entergy noted that findings of fact 17 B and 17 D should be modified to more accurately reflect the procedural history. The Commission modifies findings of fact 17B and 17D to state that Entergy agreed to extend time to provide the Commission sufficient time to consider the issues in this proceeding on two occasions-at the July 27 and August 30, 2012 open meetings.

I. Discussion

A. Prepaid Pension Asset Balance

Entergy included in rate base an approximately $\backslash$ 56$ million item named Unfunded Pension. ^[3] This amount represents the accumulated difference between the annual pension costs calculated in accordance with the Statement of Financial Accounting Standards (SFAS) No. 87 and the actual contributions made by Entergy to the pension fund-Entergy contributed nearly $\backslash$ 56 $millionmoretoitspensionfundthantheminimumrequiredbySFASNo.$ 87 .{ }^{4}$

In Docket No. 33309, the Commission allowed a pension prepayment asset, excluding the portion of the asset that is capitalized to construction work in progress (CWIP), less accrued deferred federal income taxes (ADFIT) to be included in rate base. ^[5] For the excluded portion, the Commission allowed the accrual of an allowance for funds used during construction

(AFUDC). ^[6] The ALJs concluded that this approach was sound and should be followed in this case. ^[7] Thus, the ALJs recommended that the CWIP-related portion of Entergy's prepaid pension asset $(\backslash$ 25,311,236)$ should be excluded from the asset and should accrue AFUDC. ^[8] However, the ALJs did not address ADFIT.

The Commission agrees that the CWIP-related portion of Entergy's pension asset should be excluded from the asset and that this excluded portion should accrue AFUDC. However, the Commission also finds that the impact of this exclusion on Entergy's ADFIT should be reflected. When items are excluded from rate base, the related ADFIT should also be excluded. The adjusted ADFIT for the prepaid pension asset remaining in Entergy's rate base should be reduced by $\backslash$ 8,858,933 $,thedeferredtaxesrelatedtotheexcluded$ \ $25$ million. The Commission adds new finding of fact 28 A to reflect this modification to Entergy's ADFIT.

B. FIN 48

The Financial Accounting Standards Board's Interpretation No. 48 (FIN 48) prescribes the way in which a company must analyze, quantify, and disclose the potential consequences of tax positions that the company has taken that are legally uncertain. Entergy reported that its uncertain tax positions totaled $\backslash$ 5,916,461 $.FIN48requiresthatthisamountberecordedonEnterg{y}^{\prime }sbalancesheetasataxliability.EntergyalsoreportedthatitmadeacashdepositwiththeIRSintheamountof$ \ $1,294,683$ associated with its FIN 48 liability. ^[9]

The ALJs concluded that Entergy's FIN 48 liability should be included in its ADFIT balance, but the amount of the cash deposit made by Entergy to the IRS attributable to Entergy's FIN 48 liability should not be included in Entergy's ADFIT balance. Accordingly, the ALJs recommended that $\backslash$ 4,621,778 $(Enterg{y}^{\prime }sFIN48liabilityof$ \ $5,916,461$ less the $\backslash$ 1,294,683$ cash deposit Entergy has already made with the IRS) be added to Entergy's ADFIT balance and thus

be used to offset Entergy's rate base. ^[10] The ALJs did not recommend the addition of a deferred-tax-account rider because no party expressly advocated the addition of such a rider. ^[11]

The Commission adopts the proposal for decision regarding the adjustment to Entergy's ADFIT for the amount attributable to Entergy's FIN 48 liability. However, the Commission also follows its precedent regarding the creation of a deferred-tax-account tracker and modifies the proposal for decision on this point. In CenterPoint's Electric Delivery Company's last rate case, Docket No. 38339, ^[12] the Commission found that tax schedule UTP-on which companies must describe, list, and rank each uncertain tax position-would provide the IRS auditors sufficient information to quickly determine which uncertain tax positions are of a magnitude worth investigating and that an IRS audit would be more likely to occur on some uncertain tax positions. If an IRS audit of a FIN 48 uncertain tax position results in an unfavorable outcome, the utility would not be able to earn a return on the amount paid to the IRS until the next rate case.

Accordingly, the Commission authorizes Entergy to establish a rider to track unfavorable FIN-48 rulings by the IRS. The rider will also allow Entergy to recover on a prospective basis an after-tax return of $8.27\%$ on the amounts paid to the IRS that result from an unfavorable FIN48 unfavorable-tax-position audit. The return will be applied prospectively to FIN-48 amounts disallowed by an IRS audit after such amounts are actually paid to the federal government. If Entergy subsequently prevails in an appeal of an unfavorable FIN-48 unfavorable-tax-position decision by the IRS, then any amounts collected under rider related to that overturned decision shall be credited back to ratepayers.

The Commission adds new finding of fact 40A and deletes finding of fact 41 consistent with its decision to authorize the deferred-tax-account tracker.

C. Capitalized Incentive Compensation

Entergy capitalized into plant-in-service accounts some of the incentive payments made to employees and sought to include those amounts in rate base. The ALJs determined that Entergy should not be able to recover its financially based incentive-compensation costs. ^[13] Therefore, the portion of Entergy's incentive-compensation costs capitalized during the period July 1, 2009 through June 30, 2010 that were financially based was excluded from Entergy's rate base. The ALJs also determined that the actual percentages should be used to determine the amount that is financially based. ^[14]

In discussing Entergy's incentive compensation as a component of operating expenses, the ALJs adopted the method advocated by Texas Industrial Energy Consumers (TIEC) for calculating the amount of the financially based incentive costs. This method uses the actual percentage reductions applicable to each of the annual incentive programs that included a component of financially-based costs. ^[15]

In its exceptions regarding capitalized incentive compensation, Entergy advocated for the use of TIEC's methodology to also calculate the amount of capitalized incentive compensation that is financially based. Entergy also noted that the amount of the disallowance reflected in the schedules, $\backslash$ 1,333,352$, was calculated using a disallowance factor that included incentive compensation tied to cost-control measures, which the ALJs found to be recoverable in the operating-cost incentive-compensation calculation. ^[16] When the TIEC methodology is applied to the capitalized incentive-compensation costs in rate base, the net result under TIEC's methodology is that only $\backslash$ 335,752.96$ should be disallowed from capital costs. ^[17]

The Commission agrees that capitalized incentive compensation that is financially based should be excluded from rate base and that the exclusion only applies to incentive costs that Entergy capitalized during the period from July 1, 2009 through June 30, 2010. However, the Commission finds that a consistent methodology should be used to calculate the amount to be

excluded and therefore that TIEC's methodology should also be used for calculating the amount of capitalized financially based incentive-compensation costs that should be excluded from rate base. Accordingly, the total amount of capitalized incentive-compensation costs that should be disallowed from rate base is $\backslash$ 335,752.96$. Finding of fact 61 is modified to reflect this determination.

As noted by Commission Staff, this disallowance to plant-in-service alters the expense for ad valorem taxes. Accounting for this disallowance, the appropriate expense amount for ad valorem taxes is $\backslash$ 24,921,022,{ }^{18} $anadjustmentof$ \ $1,222,106$ to Entergy's test year amount. Finding of fact 151 is modified to reflect this adjustment to property taxes.

D. Rate of Return and Cost of Capital

The ALJs found the proper range of an acceptable return on equity for Entergy would be from 9.3 percent to 10.0 percent. ^[19] The mid-point of the range is 9.65 percent. The ALJs found that the effect of unsettled economic conditions facing utilities on the appropriate return on equity should be taken into account and that the effect would be to move the ultimate return on equity towards the upper limits of the range that was determined to be reasonable. ^[20] The ALJs found that the reasonable adjustment would be 15 basis points, moving the reasonable return on equity to 9.80 percent. ^[21]

The Commission must establish a reasonable return for a utility and must consider applicable factors. ^[22] The Commission disagrees with the ALJs that a utility's return on equity should be determined using an adder to reflect unsettled economic conditions facing utilities. The Commission agrees with the ALJs, however, that a return on equity of 9.80 percent will allow Entergy a reasonable opportunity to earn a reasonable return on its invested capital, but finds this rate appropriate independent of the 15 -point adder recommended by the ALJs. A return on equity of 9.80 percent is within the range of an acceptable return on equity found by

the ALJs. Accordingly, the Commission adds new finding of fact 65 A to reflect the Commission's decision on this point.

E. Purchased-Power Capacity Expense

The ALJs rejected Entergy's request to recover $\backslash$ 31$ million more in purchased-power capacity costs than its actual test-year expenses because Entergy had failed to prove that the adjustment was known and measurable, ^[23] and because the request violated the matching principle. ^[24] Consequently, the ALJs recommended that Entergy's test-year expenses of $\backslash$ 245,432,884$ be used to set rates in this docket. ^[25]

Entergy pointed to an additional $\backslash$ 533,002$ of purchased-power capacity expenses that were properly included in Entergy's rate-filing package, but not provided for in the proposal for decision. ^[26] The Commission finds that an additional $\backslash$ 533,002 $($ \ $6,132$ for test-year expenses for Southwest Power Pool fees, $\backslash$ 654,082 $forToledoBendhydrofixed-charges,and$ -\ $127,212$ for an Entergy intra-system billing adjustment that were all recorded in FERC account 555) of purchased-power capacity costs were incurred during the test-year and should be added to the purchased-power capacity costs in Entergy's revenue requirement. The Commission modifies findings of fact 72 and 86 to reflect the inclusion of the additional $\backslash$ 533,002 $oftest-yearpurchased-powercapacitycosts,increasingthetotalamountto$ \ $245,965,886$ .

F. Labor Costs - Incentive Compensation

The ALJs found that $\backslash$ 6,196,037$, representing Entergy's financially-based incentives paid in the test-year, should be removed from Entergy's O&;M expenses. ^[27] The ALJs agreed with Commission Staff and Cities that an additional reduction should be made to account for the FICA taxes that Entergy would have paid for those costs, ^[28] but did not include this reduction in a finding of fact.

The Commission agrees with the ALJs, but modifies finding of fact 133 to specifically include the decision that an additional reduction should be made to account for the FICA taxes Entergy would have paid on the disallowed financially-based incentive compensation. The Commission notes that this reduction for FICA taxes is reflected in the schedules attached to this Order. ^[29]

G. Affiliate Transactions

OPUC argued that Entergy's sales and marketing expenses exclusively benefit the larger commercial and industrial customers, but the majority of the sales, marketing, and customer service expenses are allocated to the operating companies based on customer counts. Therefore, the majority of these expenses are allocated to residential and small business customers. OPUC argued that it is inappropriate for residential and small business customers to pay for these expenses. ^[30] The ALJs did not adopt OPUC's position on this issue.

The Commission agrees with OPUC and reverses the proposal for decision regarding allocation of Entergy's sales and marketing expense and finds that $\backslash$ 2.086$ million of sales and marketing expense should be reallocated using direct assignment. The Commission has previously expressed its preference for direct assignment of affiliate expenses. ^[31] The Commission finds that the following amounts should be allocated based on a total-number-ofcustomers basis: (1) $\backslash$ 46,490 $forProjectE10PCR56224-SalesandMarketing-EGSITexas;(2)$ \ $17,013$ for Project F3PCD10049 - Regulated Retail Systems O&;M and (3) \ $30,167forProjectF3PPMMALI2-MiddleMarketMkt.Development.Theremainder,\backslash$ 1,992,475, should be assigned to (1) General Service, (2) Large General Service and (3) Large Industrial Power Service. ^[32] The reallocation has the effect of increasing the revenue requirement allocated to the large business class customers and reduces the revenue requirement for small business and residential customers. New finding of fact 164A is added to reflect the proper allocation of these affiliate transactions.

H. Fuel Reconciliation

Entergy proposed to allocate costs for the fuel reconciliation to customers using a lineloss study performed in 1997. Entergy conducted a line-loss study for the year ending December 31, 2010, which falls in the middle of the two year fuel reconciliation period—July 2009 through June 2011—and therefore reflects the actual line losses experienced by the customer classes during the reconciliation period. Cities argued that the allocation of fuel costs incurred over the reconciliation period should reflect the current line-loss study performed by Entergy for this case and recommended approval on a going-forward basis. Fuel factors under P.U.C. Subst. R. 25.237(a)(3) are temporary rates subject to revision in a reconciliation proceeding described in P.U.C. Subst. R. 25.236. P.U.C. Subst. R. 25.236(d)(2) defines the scope of a fuel reconciliation proceeding to include any issue related to the reasonableness of a utility's fuel expenses and whether the utility has over- or under-recovered its reasonable fuel expenses. ^[33] Cities calculated a $\backslash$ 3,981,271$ reduction to the Texas retail fuel expenses incurred over the reconciliation period using the current line-losses. The ALJs rejected Cities' proposed adjustment finding that the P.U.C. Subst. R. 25.237(c)(2)(B) requires the use of Commissionapproved line losses that were in effect at the time fuel costs were billed to customers in a fuel reconciliation. ^[34]

The Commission agrees with Cities and reverses the proposal for decision regarding which line-loss factors should be used in Entergy's fuel reconciliation. Entergy used the 2010 study line-loss calculations to calculate the demand- and energy-related allocations in its cost of service analysis supporting its requested base rates. These same currently available line-loss factors should have been utilized in Entergy's fuel reconciliation. The Commission finds that Entergy's 2010 line-loss factors should be used to calculate Entergy's fuel reconciliation over-recovery. As a result, Entergy's fuel reconciliation over-recovery should be reduced by $\backslash$ 3,981,271$. Finding of fact 246 A and conclusions of law 19 A and 19 B are added to reflect the Commission's finding that the 2010 line-loss factors be used to reconcile Entergy's fuel costs.

I. MISO Transition Expenses

During the Commission's consideration of the proposal for decision, the parties that contested the amount of Entergy's MISO transition expenses and how the transition expenses should be accounted for reached announced on the record that they had reached an agreement on these issues. ^[35] Those parties agreed that the MISO transition expenses would not be deferred and that Entergy's base rates should include $\backslash$ 1.6$ million for MISO transition expense. ^[36] The Commission adopts the agreement of the parties and accordingly modifies finding of fact 251 and deletes finding of fact 252 .

J. Purchased-Power Capacity Cost Baseline

The Commission modified the amount of purchased-power capacity expense in the test-year to be $\backslash$ 245,965,886$ (see section E above). Finding of fact 255 is modified to reflect the change to the proper test-year purchased-power capacity expense.

K. Other Issues

New findings of fact $17\mathrm{A},17\mathrm{B},17C,17D$ , and 17 E are added to reflect procedural aspects of the case after issuance of the proposal for decision.

In addition, to reflect corrections recommended by the ALJs, findings of fact 116, 123, 192, 194, and 202 are modified; and new finding of fact 182A is added.

The Commission adopts the following findings of fact and conclusions of law:

II. Findings of Fact

Procedural History

1. Entergy Texas, Inc. (ETI or the company) is an investor-owned electric utility with a retail service area located in southeastern Texas. [^0] [^0]: ^[35] Open Meeting Tr. at 138 (Aug. 17, 2012). ${}^{36}\mathrm{I}\mathrm{d}$ .

1. ETI serves retail and wholesale electric customers in Texas. As of June 30, 2011, ETI served approximately 412,000 Texas retail customers. The Federal Energy Regulatory Commission (FERC) regulates ETI's wholesale electric operations.
2. On November 28, 2011, ETI filed an application requesting approval of: (1) a proposed increase in annual base rate revenues of approximately $\backslash$ 111.8$ million over adjusted testyear revenues; (2) a set of proposed tariff schedules presented in the Electric Utility Rate Filing Package for Generating Utilities (RFP) accompanying ETI's application and including new riders for recovery of costs related to purchased-power capacity and renewable energy credit requirements; (3) a request for final reconciliation of ETI's fuel and purchased-power costs for the reconciliation period from July 1, 2009 to June 30, 2011; and (4) certain waivers to the instructions in RFP Schedule V accompanying ETI's application.
3. The 12-month test-year employed in ETI's filing ended on June 30, 2011 (test-year).
4. ETI provided notice by publication for four consecutive weeks before the effective date of the proposed rate change in newspapers having general circulation in each county of ETI's Texas service territory. ETI also mailed notice of its proposed rate change to all of its customers. Additionally, ETI timely served notice of its statement of intent to change rates on all municipalities retaining original jurisdiction over its rates and services.
5. The following parties were granted intervenor status in this docket: Office of Public Utility Counsel; the cities of Anahuac, Beaumont, Bridge City, Cleveland, Conroe, Dayton, Groves, Houston, Huntsville, Montgomery, Navasota, Nederland, Oak Ridge North, Orange, Pine Forest, Rose City, Pinehurst, Port Arthur, Port Neches, Shenandoah, Silsbee, Sour Lake, Splendora, Vidor, and West Orange (Cities), the Kroger Co. (Kroger); State Agencies; Texas Industrial Energy Consumers; East Texas Electric Cooperative, Inc.; the United States Department of Energy (DOE); and Wal-Mart Stores Texas, LLC, and Sam's East, Inc. (Wal-Mart). The Staff (Staff) of the Public Utility Commission of Texas (Commission or PUC) was also a participant in this docket.
6. On November 29, 2011, the Commission referred this case to the State Office of Administrative Hearings (SOAH).

1. On December 7, 2011, the Commission issued its order requesting briefing on threshold legal/policy issues.
2. On December 19, 2011, the Commission issued its Preliminary Order, identifying 31 issues to be addressed in this proceeding.
3. On December 20, 2011, the Administrative Law Judges (ALJs) issued SOAH Order No. 2, which approved an agreement among the parties to establish a June 30, 2012 effective date for the company's new rates resulting from this case pursuant to certain agreed language and consolidate Application of Entergy Texas, Inc. for Authority to Defer Expenses Related to its Proposed Transition to Membership in the Midwest Independent System Operator, Docket No. 39741 (pending) into this proceeding. Although it did not agree, Staff did not oppose the consolidation.
4. On January 13, 2012, the ALJs issued SOAH Order No. 4 granting the motions for admission pro hac vice filed by Kurt J. Boehm and Jody M. Kyler to appear and participate as counsel for Kroger and the motion for admission pro hac vice filed by Rick D. Chamberlain to appear and participate as counsel for Wal-Mart.
5. On January 19, 2012, the Commission issued a supplemental preliminary order identifying two additional issues to be addressed in this case and concluding that the company's proposed purchased-power capacity rider should not be addressed in this case and that such costs should be recovered through base rates.
6. ETI timely filed with the Commission petitions for review of the rate ordinances of the municipalities exercising original jurisdiction within its service territory. All such appeals were consolidated for determination in this proceeding.
7. On April 4, 2012, the ALJs issued SOAH Order No. 13 severing rate case expense issues into Application of Entergy Texas, Inc. for Rate Case Expenses Severed from PUC Docket No. 39896, Docket No. 40295 (pending).
8. On April 13, 2012, ETI adjusted its request for a proposed increase in annual base rate revenues to approximately $\backslash$ 104.8$ million over adjusted test-year revenues.
9. The hearing on the merits commenced on April 24 and concluded on May 4, 2012.

1. Initial post-hearing briefs were filed on May 18 and reply briefs were filed on May 30, 2012. 17A. On August 7, 2012, the SOAH ALJs filed a letter with the Commission recommending changes to the PFD.

17B At the July 27, 2012 open meeting, ETI agreed to extend time to August 31, 2012 to provide the Commission sufficient time to consider the issues in this proceeding. 17C. The Commission considered the proposal for decision at the August 17, 2012 and August 30, 2012 open meetings. 17D. At the August 30, 2012 open meeting, ETI agreed to extend time to September 14, 2012 to provide the Commission sufficient time to consider the issues in this proceeding. 17E. At the August 17, 2012 open meeting, parties announced on the record a settlement of the amount of costs for the transition to MISO.

Rate Base

1. Capital additions that were closed to ETI's plant-in-service between July 1, 2009 and June 30, 2011, are used and useful in providing service to the public and were prudently incurred.
2. ETI's proposed Hurricane Rita regulatory asset was an issue resolved by the black-box settlement in Application of Entergy Texas, Inc. for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 37744 (Dec. 13, 2010).
3. Accrual of carrying charges on the Hurricane Rita regulatory asset should have ceased when Docket No. 37744 concluded because the asset would have then begun earning a rate of return as part of rate base.
4. The appropriate calculation of the Hurricane Rita regulatory asset should begin with the amount claimed by ETI in Docket No. 37744, less amortization accruals to the end of the test-year in the present case, and less the amount of additional insurance proceeds received by ETI after the conclusion of Docket No. 37744.
5. A Test-Year-end balance of $\backslash$ 15,175,563$ for the Hurricane Rita regulatory asset should remain in rate base, applying a five-year amortization rate beginning August 15, 2010.

1. The Hurricane Rita regulatory asset should not be moved to the storm damage insurance reserve.
2. The company requested in rate base its prepaid pension assets balance of $\backslash$ 55,973,545$, which represents the accumulated difference between the Statement of Financial Accounting Standards (SFAS) No. 87 calculated pension costs each year and the actual contributions made by the company to the pension fund.
3. The prepaid pension assets balance includes $\backslash$ 25,311,236$ capitalized to construction work in progress (CWIP).
4. It is not necessary to the financial integrity of ETI to include CWIP in rate base, and there was insufficient evidence showing that major projects under construction were efficiently and prudently managed.
5. The portion of the prepaid pension assets balance that is capitalized to CWIP should not be included in ETI's rate base.
6. The remainder of the prepaid pension assets balance should be included in ETI's rate base. 28A. When items are excluded from rate base, the related ADFIT should also be excluded. The amount of ADFIT associated with the $\backslash$ 25 $millioncapitalizedtoCWIPandexcludedfromratebaseis$ \ $8,858,933$ . The adjusted ADFIT for the prepaid pension asset remaining in Entergy's rate base should be reduced by $\backslash$ 8,858,933$.
7. ETI should be permitted to accrue an allowance for funds used during construction on the portion of ETI's Prepaid Pension Assets Balance capitalized to CWIP.
8. The Financial Accounting Standard Board (FASB) Financial Interpretation No. 48 (FIN 48), "Accounting for Uncertainty in Income Taxes," requires ETI to identify each of its uncertain tax positions by evaluating the tax position on its technical merits to determine whether the position, and the corresponding deduction, is more-likely-than-not to be sustained by the Internal Revenue Service (IRS) if audited.
9. FIN 48 requires ETI to remove the amount of its uncertain tax positions from its Accumulated Deferred Federal Income Tax (ADFIT) balance for financial reporting

purposes and record it as a potential liability with interest to better reflect the company's financial condition. 32. At test-year-end, ETI had $\backslash$ 5,916,461 $inFIN48liabilities,meaningETIhas,thusfar,avoidedpayingtotheIRS$ \ $5,916,461$ in tax dollars (the FIN 48 liability) in reliance upon tax positions that the company believes will not prevail in the event the positions are challenged, via an audit, by the IRS. 33. ETI has deposited $\backslash$ 1,294,683$ with the IRS in connection with the FIN 48 liability. 34. The IRS may never audit ETI as to its uncertain tax positions creating the FIN 48 liability. 35. Even if ETI is audited, ETI might prevail on its uncertain tax positions. 36. ETI may never have to pay the IRS the FIN 48 liability. 37. Other than the amount of its deposit with the IRS, ETI has current use of the FIN 48 liability funds. 38. Until actually paid to the IRS, the FIN 48 liability represents cost-free capital and should be deducted from rate base. 39. The amount of $\backslash$ 4,621,778 $(representingET{I}^{\prime }sfullFIN48liabilityof$ \ $5,916,461$ less the $\backslash$ 1,294,683$ cash deposit ETI has made with the IRS for the FIN 48 liability) should be added to ETI's ADFIT and thus be used to reduce ETI's rate base. 40. ETI's application and proposed tariffs do not include a request for a tracking mechanism or rider to collect a return on the FIN 48 liability. 40A. It is appropriate for ETI to create a deferred-tax-account tracker in the form of a rider to recover on a prospective basis an after-tax return of $8.27\%$ on the amounts paid to the IRS that result from an unfavorable FIN 48 audit. The rider will track unfavorable FIN 48 rulings and the return will be applied prospectively to FIN 48 amounts disallowed by an IRS audit after such amounts are actually paid to the federal government. If ETI prevails in an appeal of a FIN 48 decision, then any amounts collected under the rider related to that decision should be credited back to ratepayers.

1. Deleted.
2. Investor-owned electric utilities may include a reasonable allowance for cash working capital in rate base as determined by a lead-lag study conducted in accordance with the Commission's rules.
3. Cash working capital represents the amount of working capital, not specifically addressed in other rate base items, that is necessary to fund the gap between the time expenditures are made and the time corresponding revenues are received.
4. The lead-lag study conducted by ETI considered the actual operations of ETI, adjusted for known and measurable changes, and is consistent with P.U.C. Subst. R. $25.231(c)(2)(B)($ iii $)$ .
5. It is reasonable to establish ETI's cash working capital requirement based on ETI's leadlag study as updated in Jay Joyce's rebuttal testimony and on the cost of service approved for ETI in this case.
6. As a result of the black-box settlements in Application of Entergy Gulf States, Inc. for Authority to Change Rates and to Reconcile Fuel Costs, Docket No. 34800 (Nov. 7, 2008) and Docket No. 37744, the Commission did not approve ETI's storm damage expenses since 1996 and its storm damage reserve balance.
7. ETI established a prima facie case concerning the prudence of its storm damage expenses incurred since 1996.
8. Adjustments to the storm damage reserve balance proposed by intervenors should be denied.
9. The Hurricane Rita regulatory asset should not be moved to the storm damage insurance reserve.
10. ETI's appropriate Test-Year-end storm reserve balance was negative $\backslash$ 59,799,744$.
11. The amount of $\backslash$ 9,846,037$, representing the value of the average coal inventory maintained at ETI's coal-burning facilities, is reasonable, necessary, and should be included in rate base.

1. The Spindletop gas storage facility (Spindletop facility) is used and useful in providing reliable and flexible natural gas supplies to ETI's Sabine Station and Lewis Creek generating plants.
2. The Spindletop facility is critical to the economic, reliable operation of the Sabine Station and Lewis Creek generating plants due to their geographic location in the far western region of the Entergy system.
3. It is reasonable and appropriate to include ETI's share of the costs to operate the Spindletop facility in rate base.
4. Staff recommended updating ETI's balance amounts for short-term assets to the 13month period ending December 2011, which was the most recent information available. Staff's proposed adjustments should be incorporated into the calculation of ETI's rate base.
5. The following short-term asset amounts should be included in rate base: prepayments at $\backslash$ 8,134,351 $;materialsandsuppliesat$ \ $29,285,421$ ; and fuel inventory at $\backslash$ 52,693,485$.
6. The amount of $\backslash$ 1,127,778$, representing costs incurred by ETI when it acquired the Spindletop facility, represent actual costs incurred to process and close the acquisition, not mere mark-up costs.
7. ETI's $\backslash$ 1,127,778$ in capitalized acquisition costs should be included in rate base because ETI incurred these costs in conjunction with the purchase of a viable asset that benefits its retail customers.
8. In its application, ETI capitalized into plant in service accounts some of the incentive payments ETI made to its employees. ETI seeks to include those amounts in rate base.
9. A portion of those capitalized incentive accounts represent payments made by ETI for incentive compensation tied to financial goals.
10. The portion of ETI's incentive payments that are capitalized and that are financiallybased should be excluded from ETI's rate base because the benefits of such payments inure most immediately and predominantly to ETI's shareholders, rather than its electric

customers. ETI's capitalized incentive compensation that is financially based is $\backslash$ 335,752.96$ and should be removed for rate base. 62. The test-year for ETI's prior ratemaking proceeding ended on June 30, 2009, and the reasonableness of ETI's capital costs (including capitalized incentive compensation) for that prior period was dealt with by the Commission in that proceeding and is not at issue in this proceeding. 63. In this proceeding, ETI's capitalized incentive compensation that is financially-based should be excluded from rate base, but only for incentive costs that ETI capitalized during the period from July 1, 2009 (the end of the prior test-year) through June 30, 2010 (the commencement of the current test-year).

Rate of Return and Cost of Capital

1. A return on common equity (ROE) of 9.80 percent will allow ETI a reasonable opportunity to earn a reasonable return on its invested capital.
2. The results of the discounted cash flow model and risk premium approach support a ROE of 9.80 percent.

65A. It is not appropriate to add 15 points to the ROE due to unsettled economic conditions facing utilities. 66. A 9.80 percent ROE is consistent with ETI's business and regulatory risk. 67. ETI's proposed 6.74 percent embedded cost of debt is reasonable. 68. The appropriate capital structure for ETI is 50.08 percent long-term debt and 49.92 percent common equity. 69. A capital structure composed of 50.08 percent debt and 49.92 percent equity is reasonable in light of ETI's business and regulatory risks. 70. A capital structure composed of 50.08 percent debt and 49.92 percent equity will help ETI attract capital from investors.

1. ETI's overall rate of return should be set as follows:

| COMPONENT | CAPITAL
STRUCTURE | COST OF CAPITAL | WEIGHTED AVG
COST OF CAPITAL | | :--: | :-- | :-- | :-- | | LONG-TERM DEBT | $50.08\%$ | $6.74\%$ | $3.38\%$ | | COMMON EQUITY | $49.92\%$ | $9.80\%$ | $4.89\%$ | | TOTAL | $100.00\%$ | | $8.27\%$ |

Operating Expenses

1. ETI's test-year purchased capacity expenses were $\backslash$ 245,965,886$.
2. ETI requested an upward adjustment of $\backslash$ 30,809,355$ as a post-test-year adjustment to its purchased capacity costs. This request was based on ETI's projections of its purchased capacity expenses during a period beginning June 1, 2012 and ending May 31, 2013 (the rate-year).
3. ETI's purchased capacity expense projections were based on estimates of rate-year expenses for: (a) reserve equalization payments under Schedule MSS-1; (b) payments under third-party capacity contracts; and (c) payments under affiliate contracts.
4. ETI's projection of its rate-year reserve equalization payments under Schedule MSS-1 is based on numerous assumptions, including load growths for ETI and its affiliates, future capacity contracts for ETI and its affiliates, and future values of the generation assets of ETI and its affiliates.
5. There is substantial uncertainty with regard to ETI's projection of its rate-year reserve equalization payments under Schedule MSS-1.
6. ETI's projection of its rate-year third-party capacity contract payments includes numerous assumptions, one of which is that every single third-party supplier will perform at the maximum level under the contract, even though that assumption is inconsistent with ETI's historical experience.
7. There is substantial uncertainty with regard to ETI's projection of its rate-year third-party capacity-contract payments.
8. ETI's estimates of its rate-year purchases under affiliate contracts are based on a mathematical formula set out in Schedule MSS-4.

1. The MSS-4 formula for rate-year affiliate capacity payments reflects that these payments will be based on ratios and costs that cannot be determined until the month that the payments are to be made.
2. Over $\backslash$ 11$ million of ETI's affiliate transactions were based on a 2013 contract (the EAI WBL Contract) that was not signed until April 11, 2012.
3. There is uncertainty about whether the EAI WBL Contract will ever go into effect.
4. ETI projects purchasing over 300 megawatts (MW) more in purchased capacity in the rate-year than it purchased in the test-year.
5. ETI experienced substantial load growth in the two years before the test-year, and it continues to project similar load growth in the future.
6. ETI did not meet its burden of proof to demonstrate that a known and measurable adjustment of $\backslash$ 30,809,355$ should be made to its test-year purchased capacity expenses.
7. ETI's purchased capacity expense in this case should be based on the test-year level of $\backslash$ 245,965,886$.
8. ETI incurred $\backslash$ 1,753,797$ of transmission equalization expense during the test-year.
9. ETI proposed an upward adjustment of $\backslash$ 8,942,785$ for its transmission equalization expense. This request was based on ETI's projections of its transmission equalization expenses during the rate-year.
10. The transmission equalization expense that ETI will pay in the rate-year will depend on future costs and loads for each of the Entergy operating companies.
11. ETI's projection of its rate-year transmission equalization expenses is uncertain and speculative because it depends on a number of variables, including future transmission investments, deferred taxes, depreciation reserves, costs of capital, tax rates, operating expenses, and loads of each of the Entergy operating companies.
12. ETI seeks increased transmission equalization expenses for transmission projects that are not currently used and useful in providing electric service. ETI's post-test-year adjustment is based on the assumption that certain planned transmission projects will go

into service after the test-year. At the close of the hearing, none of the planned transmission projects had been fully completed and some were still in the planning phase. 92. It is not reasonable for ETI to charge its retail ratepayers for transmission equalization expenses related to projects that are not yet in-service. 93. ETI's request for a post-test-year adjustment of $\backslash$ 8,942,785$ for rate-year transmission equalization expenses should be denied because those expenses are not known and measurable. ETI's post-test-year adjustment does not with reasonable certainty reflect what ETI's transmission equalization expense will be when rates are in effect. 94. ETI's transmission equalization expense in this case should be based on the test-year level of $\backslash$ 1,753,797$. 95. P.U.C. Subst. R. 25.231(c)(2)(ii) states that the reserve for depreciation is the accumulation of recognized allocations of original cost, representing the recovery of initial investment over the estimated useful life of the asset. 96. Except in the case of the amortization of the general plant deficiency, the use of the remaining life depreciation method to recover differences between theoretical and actual depreciation reserves is the most appropriate method and should be continued. 97. It is reasonable for ETI to calculate depreciation reserve allocations on a straight-line basis over the remaining, expected useful life of the item or facility. 98. Except as described below, the service lives and net salvage rates proposed by the company are reasonable, and these service lives and net salvage rates should be used in calculating depreciation rates for the company's production, transmission, distribution, and general plant assets. 99. A 60-year life for Sabine Units 4 and 5 is reasonable for purposes of establishing production plant depreciation rates. 100. The retirement (actuarial) rate method, rather than the interim retirement method, should be used in the development of production plant depreciation rates. 101. Production plant net salvage is reasonably based on the negative five percent net salvage in existing rates.

1. The net salvage rate of negative 10 percent for ETI's transmission structures and improvements (FERC Account 352) is the most reasonable of those proposed and should be adopted.
2. The net salvage rate of negative 20 percent for ETI's transmission station equipment (FERC Account 353) is the most reasonable of those proposed and should be adopted.
3. The net salvage rate of negative five percent for ETI's transmission towers and fixtures (FERC Account 354) is the most reasonable of those proposed and should be adopted.
4. The net salvage rate of negative 30 percent for ETI's transmission poles and fixtures (FERC Account 355) is the most reasonable of those proposed and should be adopted.
5. The net salvage rate of negative 30 percent for ETI's transmission overhead conductors and devices (FERC Account 356) is the most reasonable of those proposed and should be adopted.
6. A service life of 65 years and a dispersion curve of R3 for ETI's distribution structures and improvements (FERC Account 361) are the most reasonable of those proposed and should be approved.
7. A service life of 40 years and a dispersion curve of R1 for ETI's distribution poles, towers, and fixtures (FERC Account 364) are the most reasonable of those proposed and should be approved.
8. A service life of 39 years and a dispersion curve of R0.5 for ETI's distribution overhead conductors and devices (FERC Account 365) are the most reasonable of those proposed and should be approved.
9. A service life of 35 years and a dispersion curve of R1.5 for ETI's distribution underground conductors and devices (FERC Account 367) are the most reasonable of those proposed and should be approved.
10. A service life of 33 years and a dispersion curve of L0.5 for ETI's distribution line transformers (FERC Account 368) are the most reasonable of those proposed and should be approved.

1. A service life of 26 years and a dispersion curve of L4 for ETI's distribution overhead service (FERC Account 369.1) are the most reasonable of those proposed and should be approved.
2. The net salvage rate of negative five percent for ETI's distribution structures and improvements (FERC Account 361) is the most reasonable of those proposed and should be adopted.
3. The net salvage rate of negative 10 percent for ETI's distribution station equipment (FERC Account 362) is the most reasonable of those proposed and should be adopted.
4. The net salvage rate of negative seven percent for ETI's distribution overhead conductors and devices (FERC Account 365) is the most reasonable of those proposed and should be adopted.
5. The net salvage rate of positive five percent for ETI's distribution line transformers (FERC Account 368) is the most reasonable of those proposed and should be adopted.
6. The net salvage rate of negative 10 percent for ETI's distribution overhead services (FERC Account 369.1) is the most reasonable of those proposed and should be adopted.
7. The net salvage rate of negative 10 percent for ETI's distribution underground services (FERC Account 369.2) is the most reasonable of those proposed and should be adopted.
8. A service life of 45 years and a dispersion curve of R2 for ETI's general structures and improvements (FERC Account 390) are the most reasonable of those proposed and should be approved.
9. The net salvage rate of negative 10 percent for ETI's general structures and improvements (FERC Account 390) is the most reasonable of those proposed and should be adopted.
10. It is reasonable to convert the $\backslash$ 21.3$ million deficit that has developed over time in the reserve for general plant accounts to General Plant Amortization.
11. A ten-year amortization of the deficit in the reserve for general plant accounts is reasonable and should be adopted.

1. FERC pronouncement AR-15 requires amortization over the same life as recommended based on standard life analysis. A standard life analysis determined that a five-year life was appropriate for general plant computer equipment (FERC Account 391.2). Therefore, a five year amortization for this account is reasonable and should be adopted.
2. ETI proposed adjustments to its test-year payroll costs to reflect: (a) changes to employee headcount levels at ETI and Entergy Services, Inc. (ESI); and (b) approved wage increases set to go into effect after the end of the test-year.
3. The proposed payroll adjustments are reasonable but should be updated to reflect the most recent available information on headcount levels as proposed by Commission Staff. In addition to adjusting payroll expense levels, the more recent headcount numbers should be used to adjust the level of payroll tax expense, benefits expense, and savings plan expense.
4. Staff has appropriately updated headcount levels to the most recent available data but errors made by Staff should be corrected. The corrections related to: (a) a double counting of three ETI and one ESI employee; (b) inadvertent use of the ETI benefits cost percentage in the calculation of ESI benefits costs; (c) an inappropriate reduction of savings plan costs when such costs were already included in the benefits percentage adjustments; and (d) corrections for full-time equivalents calculations. Staff's ETI headcount adjustment (AG-7) overstated operation and maintenance (O&;M) payroll reduction by $\backslash$ 224,217 $,andESIheadcountadjustment(AG-7)understatedO\&Mpayrollincreaseby$ \ $37,531$ .
5. ETI included $\backslash$ 14,187,744$ for incentive compensation expenses in its cost of service.
6. The compensation packages that ETI offers its employees include a base payroll amount, annual incentive programs, and long-term incentive programs. The majority of the compensation is for operational measures, but some is for financial measures.
7. Incentive compensation that is based on financial measures is of more immediate and predominant benefit to shareholders, whereas incentive compensation based on operational measures is of more immediate and predominant benefit to ratepayers.

1. Incentives to achieve operational measures are necessary and reasonable to provide utility services but those to achieve financial measures are not.
2. The $\backslash$ 5,376,975$ that was paid for long term incentive programs was tied to financial measures and, therefore, should not be included in ETI's cost of service.
3. Of the amounts that were paid pursuant to the Executive Annual Incentive Plan, $\backslash$ 819,062$ was tied to financial measures and, therefore, should be disallowed.
4. In total, the amount of incentive compensation that should be disallowed is $\backslash$ 6,196,037$ because it was related to financial measures that are not reasonable and necessary for the provision of electric service. An additional reduction should be made to account for the FICA taxes ETI would have paid on the disallowed financially based incentive compensation.
5. The amount of incentive compensation that should be included in the cost of service is $\backslash$ 7,991,707$.
6. To attract and retain highly qualified employees, the Entergy companies provide a total package of compensation and benefits that is equivalent in scope and cost with what other comparable companies within the utility business and other industries provide for their employees.
7. When using a benchmark analysis to compare companies' levels of compensation, it is reasonable to view the market level of compensation as a range rather than a precise, single point.
8. ETI's base pay levels are at market.
9. ETI's benefits plan levels are within a reasonable range of market levels.
10. ETI's level of compensation and benefits expense is reasonable and necessary.
11. ETI provides non-qualified supplemental executive retirement plans for highly compensated individuals such as key managerial employees and executives that, because of limitations imposed under the Internal Revenue Code, would otherwise not receive retirement benefits on their annual compensation over $\backslash$ 245,000$ per year.

1. ETI's non-qualified supplemental executive retirement plans are discretionary costs designed to attract, retain, and reward highly compensated employees whose interests are more closely aligned with those of the shareholders than the customers.
2. ETI's non-qualified executive retirement benefits in the amount of $\backslash$ 2,114,931$ are not reasonable or necessary to provide utility service to the public, not in the public interest, and should not be included in ETI's cost of service.
3. For the employee market in which ETI operates, most peer companies offer moving assistance. Such assistance is expected by employees, and ETI would be placed at a competitive disadvantage if it did not offer relocation expenses.
4. ETI's relocation expenses were reasonable and necessary.
5. The company's requested operating expenses should be reduced by $\backslash$ 40,620$ to reflect the removal of certain executive prerequisites proposed by Staff.
6. Staff properly adjusted the company's requested interest expense of $\backslash$ 68,985 $byremoving$ \ $25,938$ from FERC account 431 (using the interest rate of 0.12 percent for calendar year 2012), leaving a recommended interest expense of $\backslash$ 43,047$.
7. During the test-year, ETI's property tax expense equaled $\backslash$ 23,708,829$.
8. ETI requested an upward pro forma adjustment of $\backslash$ 2,592,420$, to account for the property tax expenses ETI estimates it will pay in the rate-year.
9. ETI's requested pro forma adjustment is not reasonable because it is based, in part, upon the prediction that ETI's property tax rate will be increased in 2012, a change that is speculative is not known and measurable.
10. Staff's recommendation to increase ETI's test-year property tax expenses by $\backslash$ 1,214,688$ is based on the historical effective tax rate applied to the known test-year-end plant in service value, consistent with Commission precedent, and based upon known and measurable changes.
11. ETI's test-year property tax burden should be adjusted upward by $\backslash$ 1,222,106 $foratotalexpenseof$ \ $24,921,022$ .

1. Staff recommended reducing ETI's advertising, dues, and contributions expenses by $\backslash$ 12,800$. The recommendation, which no party contested, should be adopted.
2. The final cost of service should reflect changes to cost of service that affect other components of the revenue requirement such as the calculation of the Texas state gross receipts tax, the local gross receipts tax, the PUC Assessment Tax and the Uncollectible Expenses.
3. The company's requested Federal income tax expense is reasonable and necessary.
4. ETI's request for $\backslash$ 2,019,000 $tobeincludedinitscostofservicetoaccountforthecompan{y}^{\prime }sannualdecommissioningexpensesassociatedwithRiverBendisnotreasonablebecauseitisnotbasedupon"themostcurrentinformationreasonablyavailableregardingthecostofdecommissioning"asrequiredbyP.U.C.Subst.R.$ 25.231(\mathrm{~b})(1)(\mathrm{F})(\mathrm{i})$
5. Based on the most current information reasonably available, the appropriate level of decommissioning costs to be included in ETI's cost of service is $\backslash$ 1,126,000$.
6. ETI's appropriate total annual self-insurance storm damage reserve expense is $\backslash$ 8,270,000 $,comprisedofanannualaccrualof$ \ $4,400,000$ to provide for average annual expected storm losses, plus an annual accrual of $\backslash$ 3,870,000$ for 20 years to restore the reserve from its current deficit.
7. ETI's appropriate target self-insurance storm damage reserve is $\backslash$ 17,595,000$.
8. ETI should continue recording its annual storm damage reserve accrual until modified by a Commission order.
9. The operating costs of the Spindletop facility are reasonable and necessary.
10. The operating costs of the Spindletop facility paid to PB Energy Storage Services are eligible fuel expenses.

Affiliate Transactions

1. ETI affiliates charged ETI $\backslash$ 78,998,777 $forservicesduringthetest-year.ThemajorityoftheseO\&Mexpenses-$ \ $69,098,041$ -were charged to ETI by ESI. The remaining affiliate services were charged (or credited) to ETI by: Entergy Gulf States Louisiana,

L.L.C.; Entergy Arkansas, Inc.; Entergy Louisiana, LLC; Entergy Mississippi, Inc.; Entergy Operations, Inc.; and non-regulated affiliates. 163. ESI follows a number of processes to ensure that affiliate charges are reasonable and necessary and that ETI and its affiliates are charged the same rate for similar services. These processes include: (a) the use of service agreements to define the level of service required and the cost of those services; (b) direct billing of affiliate expenses where possible; (c) reasonable allocation methodologies for costs that cannot be directly billed; (d) budgeting processes and controls to provide budgeted costs that are reasonable and necessary to ensure appropriate levels of service to its customers; and (e) oversight controls by ETI's Affiliate Accounting and Allocations Department. 164. Affiliates charged expenses to ETI through 1292 project codes during the test-year.

164A. The $\backslash$ 2,086,145 $inaffiliatetransactionsrelatedtosalesandmarketingexpensesshouldbereallocatedusingdirectassignment.Thefollowingamountsshouldbeallocatedtoallretailclassesinproportiontonumberofcustomers:(1)$ \ $46,490$ for Project E10PCR56224 - Sales and Marketing - EGSI Texas; (2) $\backslash$ 17,013 $forProjectF3PCD10049-RegulatedRetailSystemsO\&Mand(3)$ \ $30,167$ for Project F3PPMMALI2 - Middle Market Mkt. Development. The remainder, $\backslash$ 1,992,475$, should be assigned to (1) General Service, (2) Large General Service and (3) Large Industrial Power Service. 165. ETI agreed to remove the following affiliate transactions from its application: (1) Project F3PPCASHCT (Contractual Alternative/Cashpo) in the amount of \ $2,553;(2)ProjectF3PCSPETEI(Entergy-TulaneEnergyInstitute)intheamountof$ \ $14,288$ ; and (3) Project F5PPKATRPT (Storm Cost Processing &; Review) in the amount of $\backslash$ 929$. 166. The $\backslash$ 356,151 $(whichfigureincludesthe$ \ $112,531$ agreed to by ETI) of costs associated with Projects F5PCZUBENQ (Non-Qualified Post Retirement) and F5PPZNQBDU (Non Qual Pension/Benf Dom Utl) are costs that are not reasonable and necessary for the provision of electric utility service and are not in the public interest. 167. The $\backslash$ 10,279$ of costs associated with Project F3PPFXERSP (Evaluated Receipts Settlement) are not normally-recurring costs and should not be recoverable.

1. The $\backslash$ 19,714$ of costs associated with Project F3PPEASTIN (Willard Eastin et al) are related to ESI's operations, it is more immediately related to Entergy Louisiana, Inc. and Entergy New Orleans, Inc. As such, they are not recoverable from Texas ratepayers.
2. The $\backslash$ 171,032$ of costs associated with Project F3PPE9981S (Integrated Energy Management for ESI) are research and development costs related to energy efficiency programs. As such, they should be recovered through the energy efficiency cost recovery factor rather than base rates.
3. Except as noted in the above findings of fact Nos. 162-169, all remaining affiliate transactions were reasonable and necessary, were allowable, were charged to ETI at a price no higher than was charged by the supplying affiliate to other affiliates, and the rate charged is a reasonable approximation of the cost of providing service.

Jurisdictional Cost Allocation

1. ETI has one full or partial requirements wholesale customer - East Texas Electric Cooperative, Inc.
2. ETI proposes that 150 MW be set as the wholesale load for developing retail rates in this docket. Using 150 MW to set the wholesale load is reasonable. The 150 MW used to set the wholesale load results in a retail production demand allocation factor of 95.3838 percent.
3. The 12 Coincident Peak ( 12 CP ) allocation method is consistent with the approach used by the FERC to allocate between jurisdictions.
4. Using 12CP methodology to allocate production costs between the wholesale and retail jurisdictions is the best method to reflect cost responsibility and is appropriate based on ETI's reliance on capacity purchases.

Class Cost Allocation and Rate Design

1. There is no express statutory authorization for ETI's proposed Renewable Energy Credits rider (REC rider).
2. REC rider constitutes improper piecemeal ratemaking and should be rejected.

1. ETI's test-year expense for renewable energy credits, $\backslash$ 623,303$, is reasonable and necessary and should be included in base rates.
2. Municipal Franchise Fees (MFF) is a rental expense paid by utilities for the right to use public rights-of-way to locate its facilities within municipal limits.
3. ETI is an integrated utility system. ETI's facilities located within municipal limits benefit all customers, whether the customers are located inside or outside of the municipal limits.
4. Because all customers benefit from ETI's rental of municipal right-of-way, municipal franchise fees should be charged to all customers in ETI's service area, regardless of geographic location.
5. It is reasonable and consistent with the Public Utility Regulatory Act (PURA) $\S 33.008$ (b) that MFF be allocated to each customer class on the basis of in-city kilowatt hour ( kWh ) sales, without an adjustment for the MFF rate in the municipality in which a given kWh sale occurred.
6. The same reasons for allocating and collecting MFF as set out in Finding of Fact Nos. 178-181 also apply to the allocation and collection of Miscellaneous Gross Receipts Taxes. The company's proposed allocation of these costs to all retail customer classes based on customer class revenues relative to total revenues is appropriate.

182A. ETI's proposed gross plant-based allocator is an appropriate method for allocating the Texas franchise tax. 183. The Average and Excess (A&;E) 4CP method for allocating capacity-related production costs, including reserve equalization payments, to the retail classes is a standard methodology and the most reasonable methodology. 184. The A&;E 4CP method for allocating transmission costs to the retail classes is standard and the most reasonable methodology. 185. ETI appropriately followed the rate class revenue requirements from its cost of service study to allocate costs among customer classes. ETI's revenue allocation properly sets rates at each class's cost of service.

1. It is reasonable for ETI to eliminate the service condition for Rate Groups A and C in Schedule SHL [Street and Highway Lighting Service] that charges a $\backslash$ 50$ fee for any replacement of a functioning light with a lower-wattage bulb.
2. It is appropriate to require ETI to prepare and file, as part of its next base rate case, a study regarding the feasibility of instituting LED-based rates and, if the study shows that such rates are feasible, ETI should file proposals for LED-based lighting and traffic signal rates in its next rate case.
3. An agreement was reached by the parties and approved by the Commission in Docket No. 37744 that directed ETI to exclude, in its next rate case, the life-of-contract demand ratchet for existing customers in the Large Industrial Power Service (LIPS), Large Industrial Power Service-Time of Day, General Service, General Service-Time of Day, Large General Service, and Large General Service-Time of Day rate schedules.
4. ETI's proposed tariffs in this case did not remove the life-of-contract demand ratchet from these rate schedules consistent with the parties' agreement in Docket No. 37744.
5. A perpetual billing obligation based on a life-of-contract demand ratchet, as ETI proposed, is not reasonable.
6. ETI's proposed LIPS and LIPS Time of Day tariffs should be modified to reflect the agreement that was adopted by the Commission as just and reasonable in Docket No. 37744. Accordingly, these tariffs should be modified as set out in Findings of Fact No. 192-194.
7. ETI's Schedule LIPS and LIPS Time of Day § VI should be changed to read:

DETERMINATION OF BILLING LOAD The kW of Billing Load will be the greatest of the following: (A) The Customer's maximum measured 30-minute demand during any 30 -minute interval of the current billing month, subject to $\S \S$ III, IV and V above; or (B) $75\%$ of Contract Power as defined in $\S$ VII; or (C) $2,500\mathrm{k}\mathrm{W}$ .

1. ETI's Schedule LIPS and LIPS Time of Day § VII should be changed to read:

DETERMINATION OF CONTRACT POWER

Unless Company gives customer written notice to the contrary, Contract Power will be defined as below:

Contract Power - the highest load established under $\S \mathrm{V}\mathrm{I}(A)$ above during the 12 months ending with the current month. For the initial 12 months of Customer's service under the currently effective contract, the Contract Power shall be the kW specified in the currently effective contract unless exceeded in any month during the initial 12 -month period. 194. The Large General Service, Large General Service-Time of Day, General Service, and General Service-Time of Day schedules should be similarly revised to eliminate ETI's life-of-contract demand ratchet. 195. In its proposed rate design for the LIPS class, the company took a conservative approach and increased the current rates by an equal percentage. This minimized customer bill impacts while maintaining cost causation principles on a rate class basis. 196. It is a reasonable move towards cost of service to add a customer charge of $\backslash$ 630$ to the LIPS rate schedule with subsequent increases to be considered in subsequent base rate cases. 197. It is a reasonable move towards cost of service to slightly decrease the LIPS energy charges and increase the demand charges as proposed by Staff witness William B. Abbott. 198. DOE proposed a new Schedule LIPS rider-Schedule "Schedulable Intermittent Pumping Service" (SIPS) for load schedulable at least four weeks in advance, that occurs in the off-season (October through May), that can be cancelled at any time, and for load not lasting more than 80 hours in a year. For customers whose loads match these SIPS characteristics (for example, DOE's Strategic Petroleum Reserve), the 12-month demand ratchet provision of Schedule LIPS does not apply to demands set under the provisions of the SIPS rider. The monthly demand set under the SIPS provisions would be applicable for billing purposes only in the month in which it occurred. In short, if a customer set a

12-month ratchet demand in that month, it would be forgiven and not applicable in the succeeding 12 months. 199. DOE's proposed Schedule SIPS is not restricted solely to the DOE and should be adopted. It more closely addresses specific customer characteristics and provides for cost-based rates, as does another ETI rider applicable to Pipeline Pumping Service. 200. Standby Maintenance Service (SMS) is available to customers who have their own generation equipment and who contract for this service from ETI. 201. P.U.C. Subst. R. $25.242(k)(1)$ provides that rates for sales of standby and maintenance power to qualifying facilities should recognize system wide costing principles and should not be discriminatory. 202. It is reasonable to move Schedule SMS toward cost of service by: (a) adding a customer charge equivalent to that of the LIPS rate schedule only for SMS customers not purchasing supplementary power under another applicable rate; and (b) revising the tariff as follows:

| Charge | Distribution
(less than 69KV) | Transmission
(69KV and greater) | | :-- | :--: | :--: | | Billing Load Charge (\ $/kW):|$ \ $0.79$ | | | Standby | $\backslash$ 2.46 $|$ \ $0.60$ | | Maintenance | $\backslash$ 2.27$ | | | Non-Fuel Energy Charge ( $\varphi /\mathrm{k}\mathrm{W}\mathrm{h}$ ) | | | | On-Peak | $4.245\notin$ | $4.074\notin$ | | Off-Peak | $0.575\notin$ | $0.552\notin$ |

1. ETI's Additional Facilities Charge rider (Schedule AFC) prescribes the monthly rental charge paid by a customer when ETI installs facilities for that customer that would not normally be supplied, such as line extensions, transformers, or dual feeds.
2. ETI existing Schedule AFC provides two pricing options. Option A is a monthly charge. Option B, which applies when a customer elects to amortize the directly-assigned facilities over a shorter term ranging from one to ten years, has a variable monthly charge. There is also a term charge that applies after the facility has been fully depreciated.

1. It is reasonable and cost-based to reduce the Schedule AFC Option A rate to 1.11 percent per month of the installed cost of all facilities included in the agreement for additional facilities.
2. It is reasonable and cost-based to reduce the Schedule AFC Option B monthly rate and the Post Term Recovery Charge as follows:

| Selected Recovery Term | Recovery Term Charge | Post Recovery Term Charge | | :--: | :--: | :--: | | 1 | $9.52\%$ | $0.28\%$ | | 2 | $5.14\%$ | $0.28\%$ | | 3 | $3.68\%$ | $0.28\%$ | | 4 | $2.95\%$ | $0.28\%$ | | 5 | $2.52\%$ | $0.28\%$ | | 6 | $2.23\%$ | $0.28\%$ | | 7 | $2.03\%$ | $0.28\%$ | | 8 | $1.88\%$ | $0.28\%$ | | 9 | $1.76\%$ | $0.28\%$ | | 10 | $1.67\%$ | $0.28\%$ |

1. The revisions in the above findings of fact to Schedule AFC rates reasonably reflect the costs of running, operating, and maintaining the directly-assigned facilities.
2. It is reasonable to modify the Large General Service rate schedule by increasing the demand charge from $\backslash$ 8.56 $to$ \ $11.43$ ; decreasing the energy charge from $\backslash$ .00854 $to$ \ $\mathrm{.00458}$ ; and reducing the customer charge to $\backslash$ 260.00$.
3. Staff's proposed change to the General Service (GS) rate schedule to gradually move GS customers towards their cost of service by recommending a decrease in the customer charge from the current rate of $\backslash$ 41.09 $to$ \ $39.91$ , and a decrease in the energy charges is reasonable and should be adopted.
4. ETI's Residential Service (RS) rate schedule is composed of two elements: a customer charge and a consumption-based energy charge. In the months November through April (winter), the rates are structured as a declining block, in which the price of each unit is reduced after a defined level of usage. ETI's proposed increase in the RS customer charge to $\backslash$ 6$ per month is reasonable and should be adopted. For the RS summer rate and

the first winter block rate, the $6.296\notin$ per kWh energy charge resulting from the increased revenue requirement for residential customers is reasonable and should be adopted. 211. ETI's Schedule RS declining block rate structure is contrary to energy-efficiency efforts and the Legislature's goal of reducing both energy demand and energy consumption in Texas, as stated in PURA § 39.905 . 212. Schedule RS winter block rates should be modified consistent with the goal set out in PURA $\S 39.905$ , with the initial phase-in of a 20 percent reduction in the block differential proposed by ETI and subsequent reductions should be reviewed for consideration at the occurrence of each rate case filing. 213. Other elements of Schedule RS are just and reasonable.

Fuel Reconciliation

1. ETI incurred $\backslash$ 616,248,686$ in natural-gas expenses during the reconciliation period, which is from July 2009 through June 2011.
2. ETI purchased natural gas in the monthly and daily markets and pursuant to a long-term contract with Enbridge Inc. pipeline. ETI also transported gas on its own account and negotiated operational balancing agreements with various pipeline companies.
3. ETI employed a diversified portfolio of gas supply and transportation agreements to meet its natural-gas requirements, and ETI prudently managed its gas-supply contracts.
4. ETI's natural gas expenses were reasonable and necessary expenses incurred to provide reliable electric service to retail customers.
5. ETI incurred $\backslash$ 90,821,317$ in coal expenses during the reconciliation period.
6. ETI prudently managed its coal and coal-related contracts during the reconciliation period.
7. ETI monitored and audited coal invoices from Louisiana Generating, LLC for coal burned at the Big Cajun II, Unit 3 facility.
8. ETI's coal expenses were reasonable and necessary expenses incurred to provide reliable electric service to retail customers.

1. ETI incurred $\backslash$ 990,041,434$ in purchased-energy expenses during the reconciliation period.
2. The Entergy System's planning and procurement processes for purchased-power produced a reasonable mix of purchased resources at a reasonable price.
3. During the reconciliation period, ETI took advantage of opportunities in the fuel and purchased-power markets to reduce costs and to mitigate against price volatility.
4. ETI's purchased-energy expenses were reasonable and necessary expenses incurred to provide reliable electric service to retail customers.
5. ETI provided sufficient contemporaneous documentation to support the reasonableness of its purchased-power planning and procurement processes and its actual power purchases during the reconciliation period.
6. The Entergy system sold power off system when the revenues were expected to be more than the incremental cost of supplying generation for the sale, subject to maintaining adequate reserves.
7. The System Agreement is the tariff approved by the FERC that provides the basis for the operation and planning of the Entergy system, including the six operating companies. The System Agreement governs the wholesale-power transactions among the operating companies by providing for joint operation and establishing the bases for equalization among the operating companies, including the costs associated with the construction, ownership, and operation of the Entergy system facilities.
8. Under the terms of the Entergy System Agreement, ETI was allocated its share of revenues and expenses from off-system sales.
9. During the reconciliation period, ETI recorded off-system sales revenue in the amount of $\backslash$ 376,671,969$ in FERC Account 447 and credited 100 percent of off-system sales revenues and margins from off-system sales to eligible fuel expenses.
10. ETI properly recorded revenues from off-system sales and credited those revenues to eligible fuel costs.

1. The Entergy system consists of six operating companies, including ETI, which are planned and operated as a single, integrated electric system under the terms of the System Agreement.
2. Service schedule MSS-1 of the System Agreement determines how the capability and ownership costs of reserves for the Entergy system are equalized among the operating companies. These inter-system "reserve equalization" payments are the result of a formula rate related to the Entergy system's reserve capability that is applied on a monthly basis.
3. Reserve capability under service schedule MSS-1 is capability in excess of the Entergy system's actual or planned load built or acquired to ensure the reliable, efficient operation of the electric system.
4. By approving service schedule MSS-1, the FERC has approved the method by which the operating companies share the cost of maintaining sufficient reserves to provide reliability for the Entergy system as a whole.
5. Service schedule MSS-3 of the System Agreement determines the pricing and exchange of energy among the operating companies. By approving service schedule MSS-3, the FERC has approved the method by which the operating companies are reimbursed for energy sold to the exchange energy pool and how that energy is purchased.
6. Service schedule MSS-4 of the System Agreement sets forth the method for determining the payment for unit power purchases between operating companies. By approving service schedule MSS-4, the FERC has approved the methodology for pricing inter-operating company unit power purchases.
7. The Entergy system is planned using multi-year, annual, seasonal, monthly, and next-day horizons. Once the planning process has identified the most economical resources that can be used to reliably meet the aggregate Entergy system demand, the next step is to procure the fuel necessary to operate the generating units as planned and acquire wholesale power from the market.

1. Once resources are procured to meet forecasted load, the Entergy system is operated during the current day using all the resources available to meet the total Entergy system demand.
2. After current-day operation, the System Agreement prescribes an accounting protocol to bill the costs of operating the system to the individual operating companies. This protocol is implemented via the intra-system bill to each operating company on a monthly basis.
3. ETI purchased power from affiliated operating companies per the terms of service schedule MSS-3 of the System Agreement. The payments made under Schedule MSS-3 to affiliated operating companies are reasonable and necessary, and the FERC has approved the pricing formula and the obligation to purchase the energy. ETI pays the same price per megawatt hour for energy under service schedule MSS-3 as does any other operating company purchasing energy under service schedule MSS-3 during the same hour.
4. The Spindletop facility is used primarily to ensure gas-supply reliability and guard against gas-supply curtailments that can occur as a result of extreme weather or other unusual events.
5. The Spindletop facility provides a secondary benefit of flexibility in gas supply. ETI can back down gas-fired generation to take advantage of more economical wholesale power, or use gas from storage to supplement gas-fired generation when load increases during the day and thereby avoid more expensive intra-day gas purchases.
6. ETI's customers received benefits from the Spindletop facility during the reconciliation period through reliable gas supplies and ETI's monthly and daily storage activity.
7. ETI prudently managed the Spindletop facility to provide reliability and flexibility of gas supply for the benefit of customers.
8. ETI proposed new loss factors, based on a December 2010 line-loss study, to be applied for the purpose of allocating its costs to its wholesale customers and retail customer classes.

246A. ETI's 2010 line-loss factors should be used to reconcile ETI's fuel costs. Therefore, ETI's fuel reconciliation over-recovery should be reduced by $\backslash$ 3,981,271$. 247. ETI's proposed loss factors are reasonable and shall be implemented on a prospective basis as a result of this final order. 248. ETI seeks a special-circumstances exception to recover $\backslash$ 99,715$ resulting from the FERC's reallocation of rough production equalization costs in FERC Order No. 720-A, and to treat such costs as eligible fuel expense. 249. Special circumstances exist and it is appropriate for ETI to_recover the rough production cost equalization costs reallocated to ETI as a result of the FERC's decision in Order No. 720-A.

Other Issues

1. A deferred accounting of ETI's Midwest Independent Transmission System Operator (MISO) transition expenses is not necessary to carry out any requirement of PURA.
2. ETI should include $\backslash$ 1.6$ million in base rates for MISO transition expense.
3. Deleted.
4. Transmission Cost Recovery Factor baseline values should be set during the compliance phase of this docket, after the Commission makes final rulings on the various contested issues that may affect this calculation.
5. Distribution Cost Recovery Factor baseline values should be set during the compliance phase of this docket, after the Commission makes final rulings on the various contested issues that may affect this calculation.
6. The appropriate amount for ETI's purchased-power capacity expense to be included in base rates is $\backslash$ 245,965,886$.
7. The amount of ETI's purchased-power capacity expense includes third-party contracts, legacy affiliate contracts, other affiliate contracts, and reserve equalization. Whether the amounts for all contracts should be included in the baseline for a purchased-capacity rider that may be approved in Project No. 39246 is an issue that should be decided in that project.

III. Conclusions of Law

1. ETI is a "public utility" as that term is defined in PURA § 11.004(1) and an "electric utility" as that term is defined in PURA § 31.002(6).
2. The Commission exercises regulatory authority over ETI and jurisdiction over the subject matter of this application pursuant to PURA §§ 14.001, 32.001, 32.101, 33.002, 33.051, $36.101-\mathrm{.111}$ , and 36.203 .
3. SOAH has jurisdiction over matters related to the conduct of the hearing and the preparation of a proposal for decision in this docket, pursuant to PURA § 14.053 and Tex. Gov't Code Ann. § 2003.049.
4. This docket was processed in accordance with the requirements of PURA and the Texas Administrative Procedure Act, Tex. Gov't Code Ann. Chapter 2001.
5. ETI provided notice of its application in compliance with PURA § 36.103, P.U.C. Proc. R. 22.51(a), and P.U.C. Subst. R. 25.235(b)(1)-(3).
6. Pursuant to PURA § 33.001, each municipality in ETI's service area that has not ceded jurisdiction to the Commission has jurisdiction over the company's application, which seeks to change rates for distribution services within each municipality.
7. Pursuant to PURA § 33.051, the Commission has jurisdiction over an appeal from a municipality's rate proceeding.
8. ETI has the burden of proving that the rate change it is requesting is just and reasonable pursuant to PURA § 36.006 .
9. In compliance with PURA § 36.051, ETI's overall revenues approved in this proceeding permit ETI a reasonable opportunity to earn a reasonable return on its invested capital used and useful in providing service to the public in excess of its reasonable and necessary operating expenses.
10. Consistent with PURA § 36.053, the rates approved in this proceeding are based on original cost, less depreciation, of property used and useful to ETI in providing service.
11. The ADFIT adjustments approved in this proceeding are consistent with PURA § 36.059 and P.U.C. Subst. R. 25.231(c)(2)(C)(i).

1. Including the cash working capital approved in this proceeding in ETI's rate base is consistent with P.U.C. Subst. R. $25.231(c)(2)(B)(\mathrm{i}\mathrm{i}\mathrm{i})(\mathrm{I}\mathrm{V})$ , which allows a reasonable allowance for cash working capital to be included in rate base.
2. The ROE and overall rate of return authorized in this proceeding are consistent with the requirements of PURA $\S \S 36.051$ and 36.052 .
3. The affiliate expenses approved in this proceeding and included in ETI's rates meet the affiliate payment standards articulated in PURA §§ 36.051, 36.058, and Railroad Commission of Texas v. Rio Grande Valley Gas Co., 683 S.W.2d 783 (Tex. App.Austin 1984, no writ).
4. The ADFIT adjustments approved in this proceeding are consistent with PURA § 36.059 and P.U.C. SUbSt. R. $25.231(c)(2)(C)(i)$ .
5. Pursuant to P.U.C. Subst. R. 25.231(b)(1)(F), the decommissioning expense approved in this case is based on the most current information reasonably available regarding the cost of decommissioning, the balance of funds in the decommissioning trust, anticipated escalation rates, the anticipated return on the funds in the decommissioning trust, and other relevant factors.
6. ETI has demonstrated that its eligible fuel expenses during the reconciliation period were reasonable and necessary expenses incurred to provide reliable electric service to retail customers as required by P.U.C. SUbSt. R. 25.236(d)(1)(A). ETI has properly accounted for the amount of fuel-related revenues collected pursuant to the fuel factor during the reconciliation period as required by P.U.C. SUbSt. R. 25.236(d)(1)(C).
7. ETI prudently managed the dispatch, operations, and maintenance of its fossil plants during the reconciliation period.
8. The reconciliation period level operating and maintenance expenses for the Spindletop facility are eligible fuel expenses pursuant to P.U.C. SUbSt. R. 25.236(a). 19A. Fuel factors under P.U.C. SUBST. R. 25.237(a)(3) are temporary rates subject to revision in a reconciliation proceeding.

19B. P.U.C. Subst. R. 25.236(d)(2) defines the scope of a fuel reconciliation proceeding to include any issue related to the reasonableness of a utility's fuel expenses and whether the utility has over- or under-recovered its reasonable fuel expenses. It is proper to use the new line-loss study to calculate Entergy's fuel reconciliation and over-recovery. 20. Special circumstances are warranted pursuant to P.U.C. Subst. R. 25.236(a)(6) to recover rough production equalization payments reallocated to ETI by the FERC. 21. ETI's rates, as approved in this proceeding, are just and reasonable in accordance with PURA § 36.003 .

IV. Ordering Paragraphs

In accordance with these findings of fact and conclusions of law, the Commission issues the following orders:

1. The proposal for decision prepared by the SOAH ALJs is adopted to the extent consistent with this Order.
2. ETI's application is granted to the extent consistent with this Order.
3. ETI shall file in Tariff Control No. 40742 Compliance Tariff Pursuant to Final Order in Docket No. 39896 (Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment) tariffs consistent with this Order within 20 days of the date of this Order. No later than ten days after the date of the tariff filings, Staff shall file its comments recommending approval, modification, or rejection of the individual sheets of the tariff proposal. Responses to the Staff's recommendation shall be filed no later than 15 days after the filing of the tariff. The Commission shall by letter approve, modify, or reject each tariff sheet, effective the date of the letter.
4. The tariff sheets shall be deemed approved and shall become effective on the expiration of 20 days from the date of filing, in the absence of written notification of modification or rejection by the Commission. If any sheets are modified or rejected, ETI shall file proposed revisions of those sheets in accordance with the Commission's letter within ten

days of the date of that letter, and the review procedure set out above shall apply to the revised sheets. 5. Copies of all tariff-related filings shall be served on all parties of record. 6. ETI shall prepare and file as part of its next base rate case a study regarding the feasibility of instituting LED-based rates and, if the study shows that such rates are feasible, ETI should file proposals for LED-based lighting and traffic signal rates in that case. If ETI has LED lighting customers taking service, the study shall include detailed information regarding differences in the cost of serving LED and non-LED lighting customers. ETI shall provide the results of this study to Cities and interested parties as soon as practicable, but no later than the filing of its next rate case. 7. All other motions, requests for entry of specific findings of fact and conclusions of law, and any other requests for general or specific relief, if not expressly granted, are denied.

PUBLIC UTILITY COMMISSION OF TEXAS

ROLANDO PABLOS, COMMISSIONER

I respectfully dissent regarding the utility- and executive-management-class affiliate transactions. To be consistent with Commission precedent in Docket No. 14965, ^[37] the indirect costs of the management of Entergy's ultimate parent should not be borne by Texas ratepayers. Therefore, I would disallow the following: $\backslash$ 173,867 $forProjectNo.F3PCCPM001(CorporatePerformanceManagement);$ \ $372,919$ for Project No. F3PCC31255 (Operations-Office of the CEO); and $\backslash$ 74,485$ for Project No. F3PPCOO001 (Chief Operating Officer). I join the Commission in all other respects for this Order.

q. cadmiorders/ifinaf/39000:39896o on reh docx

| | | | | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | | Company | Company | | Commission | | | | | | | | Adjustments | | | Adjustments | | | | | | | | To Test Year | Total Electric | | To Company | | | | | | | | (a) | (b) | | (a) | | (b) | (a) + (b) + (c) |

REVEIVUE REQUIREMENT

Plus: Addback: Purchased Power Rider 555.00 Addback: Interruptible Services 555.00 Total Addbacks $\begin{array}{ccc}\text{Total}555.00\hfill & amp;555.00\hfill & amp;555.00\hfill \end{array}$ $\begin{array}{ccc}\text{Total}555.00\hfill & amp;555.00\hfill & amp;555.00\hfill \end{array}$ $\begin{array}{ccc}\text{Total}555.00\hfill & amp;555.00\hfill & amp;555.00\hfill \end{array}$

| COMPANY NAME | $30-Jun-11$ | | | | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | TEAT YEAR END | | | | Company
Adjustments
To Test Year | | Company
Requested
Test Year
Total Stocks | Commission
Adjustments
To Compary
Request | | Commission
Adjusted
Total Stocks | | | OPERATIONS AND MAINTENANCE EXPENSE | | Test Year | | | | | | | | | | | Total | | | (a) | | (b) | | (d) | | (e) $+(n)+(\sigma )$ | | Operations &; Maintenance | | | | | | | | | | | | Prod Operation and Supr | 500 | \ $|5,338,227|\backslash$ | 52,215 | \ $|5,380,442|\backslash$ | (86,382) | \$ | 5,294,080 | | Fuel | 501 | \ $|(255,242)|\backslash$ | | \ $|(358,242)|\backslash$ | | \$ | (259,242) | | Fuel-Of | 501 | \ $|864,746|\backslash$ | (663,861) | \ $|654|\backslash$ | | \$ | 654 | | Fuel-Related Gas | 501 | \ $|320,038,868|\backslash$ | (330,038,868) | \ $||\backslash$ | | \$ | | | Fuel-Coal | 501 | \ $|48,170,084|\backslash$ | (48,618,748) | \ $|2,561,348|\backslash$ | (1,488) | \$ | 2,548,880 | | Steam Expenses | 502 | \ $|3,600,803|\backslash$ | 40,845 | \ $|3,841,745|\backslash$ | (61,223) | \$ | 3,860,820 | | Electric Expenses | 506 | \ $|2,529,473|\backslash$ | 6,516 | \ $|2,538,989|\backslash$ | 684 | \$ | 2,538,873 | | Misc. Steam Power Expenses | 508 | \ $|8,135,921|\backslash$ | 31,297 | \ $|8,167,218|\backslash$ | (74,347) | \$ | 8,092,871 | | Rents | 507 | \ $|131,131|\backslash$ | | \ $|131,131|\backslash$ | | \$ | 131,131 | | NCX Emmissions Allowance Expenses | 509 | \ $|(43,244)|\backslash$ | | 43,244 | \ $|\backslash$ | | \$ | | | NCX Seasonal Allowance Expenses | 509 | \ $|11,904|\backslash$ | | (11,904) | \ $||\backslash$ | | \$ | | Maintenance Supr and Eng | 510 | \ $|1,188,588|\backslash$ | | 21,037 | \ $|1,187,633|\backslash$ | (19,303) | \$ | 1,188,330 | | Maintenance of structures | 511 | \ $|3,104,221|\backslash$ | | 4,583 | \ $|3,108,794|\backslash$ | (6,872) | \$ | 3,101,822 | | Maintenance of noise plant | 512 | \ $|12,582,212|\backslash$ | | 21,742 | \ $|12,613,964|\backslash$ | (17,587) | \$ | 12,588,387 | | Maintenance of electric plant | 513 | \ $|5,461,510|\backslash$ | | 739,761 | \ $|6,221,301|\backslash$ | (27,580) | \$ | 6,183,751 | | Maintenance of heat, steam plant | 514 | \ $|1,314,017|\backslash$ | | (16,801) | \ $|1,298,116|\backslash$ | (15,888) | \$ | 1,280,227 | | Hydraulic Operating Supr and Eng | 535 | \ $|(541)|\backslash$ | | (27) | \ $|(969)|\backslash$ | | \$ | (956) | | Misc. Hydro Power Generation | 538 | \ $|(12)|\backslash$ | | \ $|(12)|\backslash$ | | \$ | | | | 541 | \ $|(1,339)|\backslash$ | | (32) | \ $|(1,361)|\backslash$ | 14 | \$ | (1,277) | | Maintenance of electric plant | 544 | \ $|1,303|\backslash$ | | 13 | \ $|1,316|\backslash$ | (26) | \$ | 1,290 | | Maintenance of Misc. hydraulic plant | 548 | \ $|543|\backslash$ | | | \ $|543|\backslash$ | | 543 | 543 | | Operation Supr and Eng | 549 | \ $|(1,338)|\backslash$ | | (12) | \ $|(1,300)|\backslash$ | 23 | \$ | (1,277) | | Misc. Other Power Gen Exp | 548 | \ $|(51)|\backslash$ | | | \ $|(91)|\backslash$ | | \$ | (91) | | Purchased Power-Explant Companies | 558 | \ $|111,253,482|\backslash$ | | (111,253,482) | \ $||\backslash$ | | \$ | | | Purchased Power-Non others | 558 | \ $|166,634,737|\backslash$ | | (166,634,737) | \ $||\backslash$ | 533,002 | --- | \$ | 533,002 | | Co-Generation | 559 | \ $|148,658,961|\backslash$ | | (148,658,961) | \ $||\backslash$ | | \$ | | | Rens Plan-Purfive-Affluent | 558 | \ $|306,888,788|\backslash$ | | (306,888,788) | \ $||\backslash$ | | \$ | | | Purchased Power Energy Afflntes | 559 | \ $|25,558,973|\backslash$ | | (25,558,973) | \ $||\backslash$ | | \$ | | | Renewable Energy Credit | 558 | \ $||\backslash$ | | | \ $||\backslash$ | 523,303 | \$ | 523,303 | | System Control &; Load Depetish | 558 | \ $|951,891|\backslash$ | | 16,688 | \ $|971,377|\backslash$ | (19,111) | \$ | 952,288 | | System Control &; Depetish Other | 557 | \ $|321,456|\backslash$ | | 4,301 | \ $|325,758|\backslash$ | (6,361) | \$ | 319,366 | | Defented Electric Fuel Cost | 557 | \ $|(52,121,822)|\backslash$ | | 52,121,822 | \ $||\backslash$ | | \$ | | | Defented TV capacity Inter | 557 | \ $|(12,446)|\backslash$ | | 12,446 | \ $||\backslash$ | | \$ | | | Transmission Gas Supr &; Engr | 560 | \ $|5,588,076|\backslash$ | | (117,600) | \ $|5,450,278|\backslash$ | (31,048) | \$ | 5,418,231 | | Load Disputching | 561 | \ $|642,630|\backslash$ | | 8,967 | \ $|651,807|\backslash$ | (79,413) | \$ | 772,184 | | Load Disputching-reliability | 561 | \ $|231,424|\backslash$ | | 3,608 | \ $|237,032|\backslash$ | 1,181 | \$ | 238,223 | | Load Disputching-Intermission system | 561 | \ $|1,422,924|\backslash$ | | 31,690 | \ $|1,454,814|\backslash$ | 6,368 | \$ | 1,461,179 | | Load Disputching-Trans Serv &; Sch | 561 | \ $|577,866|\backslash$ | | 12,984 | \ $|590,888|\backslash$ | 2,888 | \$ | 593,746 | | System Planning &; Standards Dev | 561 | \ $|385,684|\backslash$ | | 7,877 | \ $|393,581|\backslash$ | 1,758 | \$ | 396,316 | | Transmission Service Studies | 561 | \ $|52,780|\backslash$ | | 1,139 | \ $|53,918|\backslash$ | 242 | \$ | 54,181 | | Transmission Station Equipment | 562 | \ $|142,628|\backslash$ | | 925 | \ $|143,581|\backslash$ | (1,813) | \$ | 141,736 | | Trans OH Line Expenses | 563 | \ $|483,388|\backslash$ | | 66 | \ $|493,461|\backslash$ | (129) | \$ | 483,322 | | Transmission Equatization | 566 | \ $|1,377,103|\backslash$ | | 9,318,479 | \ $|10,898,582|\backslash$ | (8,842,788) | \$ | 1,753,787 | | Misc. Transmission Expenses | 566 | \ $|924,738|\backslash$ | | (16,401) | \ $|905,838|\backslash$ | (11,518) | \$ | 893,817 | | Rents | 567 | \ $|967,823|\backslash$ | | | \ $|967,823|\backslash$ | | \$ | 967,823 | | Mainl. Supr. And Eng | 568 | \ $|3,041,227|\backslash$ | | 313,098 | \ $|3,354,323|\backslash$ | (26,656) | \$ | 3,334,464 | | Mainl. Of Structures | 569 | \ $|108,642|\backslash$ | | 42 | \ $|108,664|\backslash$ | (6,216) | \$ | 100,486 | | Mainl. Trans Computer &; Telecom | 569 | \ $|446,842|\backslash$ | | 8,218 | \ $|455,057|\backslash$ | 155 | \$ | 455,212 | | Transmission Mainl Station Equip | 570 | \ $|1,662,713|\backslash$ | | 7,266 | \ $|1,666,979|\backslash$ | (14,177) | \$ | 1,665,802 | | Transmission Mainl OH Line Exp | 571 | \ $|1,790,447|\backslash$ | | 40 | \ $|1,790,487|\backslash$ | (76) | \$ | 1,790,408 | | Mainl. Of Misc. Transmission | 573 | \ $|52,814|\backslash$ | | | \ $|52,814|\backslash$ | | \$ | 52,814 | | Regional Energy Miss-Oper Supr | 575 | \ $|18,868|\backslash$ | | 4,034,420 | \ $|4,063,418|\backslash$ | (2,482,988) | --- | \$ | 1,800,428 | | Deprlmed &; Real Time Miss Hdhr | 575 | \ $|37,069|\backslash$ | | 810 | \ $|37,878|\backslash$ | (387) | \$ | 37,482 | | Mainl of Computer Software Hdhr | 576 | \ $|3,188|\backslash$ | | | \ $|3,188|\backslash$ | | \$ | 3,188 | | Distribution One Supr &; Snor | 580 | \ $|5,387,006|\backslash$ | | 28,983 | \ $|5,383,988|\backslash$ | (86,787) | \$ | 5,317,191 | | Distribution Load Disputching | 581 | \ $|448,718|\backslash$ | | 4,387 | \ $|453,088|\backslash$ | (8,488) | \$ | 444,587 | | Distribution Station Expenses | 582 | \ $|471,978|\backslash$ | | 2,931 | \ $|474,908|\backslash$ | (5,715) | \$ | 469,184 | | Distribution OH Line Expenses | 583 | \ $|103,332|\backslash$ | | 771 | \ $|104,103|\backslash$ | (1,511) | \$ | 103,592 | | Underground Line Expenses | 584 | \ $|746,888|\backslash$ | | 2,638 | \ $|748,524|\backslash$ | (5,173) | \$ | 744,381 | | Street Latching &; Signal Sys | 586 | \ $|288,809|\backslash$ | | 2,288 | \ $|288,108|\backslash$ | (4,182) | \$ | 284,663 | | Metal Expenses | 588 | \ $|2,088,788|\backslash$ | | 13,563 | \ $|2,102,348|\backslash$ | (25,176) | \$ | 2,077,173 | | Customer Indications | 587 | \ $|470,236|\backslash$ | | 3,787 | \ $|474,023|\backslash$ | (7,349) | \$ | 469,674 | | Miscellaneous Distribution Exp | 588 | \ $|1,903,004|\backslash$ | | 4,505 | \ $|1,907,509|\backslash$ | (16,425) | \$ | 1,498,064 | | Rents | 588 | \ $|3,605,626|\backslash$ | | | \ $|3,605,826|\backslash$ | | \$ | 3,605,626 | | Distribution Mainl Supr &; Engr | 590 | \ $|1,456,811|\backslash$ | | (4,009) | \ $|1,451,802|\backslash$ | (23,447) | \$ | 1,428,156 | | Mainl. Of Structures | 591 | \ $|180,488|\backslash$ | | | \ $|180,488|\backslash$ | | \$ | 180,488 | | Distribution Mainl Station Equip | 592 | \ $|880,084|\backslash$ | | 5,188 | \ $|886,270|\backslash$ | (11,078) | \$ | 855,192 | | Distribution Mainl OH lines | 593 | \ $|10,544,185|\backslash$ | | 20,914 | \ $|10,556,079|\backslash$ | (43,524) | \$ | 10,521,556 | | Underground Line Expenses | 594 | \ $|902,466|\backslash$ | | 5,393 | \ $|907,758|\backslash$ | (10,702) | \$ | 797,026 | | Dist Mainl Line TnV, Regulatory | 596 | \ $|15,651|\backslash$ | | 51 | \ $|15,902|\backslash$ | (36) | \$ | 15,688 | | MainlStreet Light &; Signal Sys | 598 | \ $|635,208|\backslash$ | | 4,176 | \ $|636,388|\backslash$ | (8,188) | \$ | 631,197 | | Maintenance-Non Roadway Sea Lig | 598 | \ $|382,358|\backslash$ | | 2,678 | \ $|396,036|\backslash$ | (5,202) | \$ | 386,784 | | Maintenance of Matters | 597 | \ $|156,188|\backslash$ | | 1,388 | \ $|160,582|\backslash$ | (2,878) | \$ | 157,874 | | Mainl of Misc. Depr. Plant | 598 | \ $|449,888|\backslash$ | | 1,928 | \ $|451,794|\backslash$ | (3,038) | \$ | 448,758 | | Supervision -Customer Acids | 601 | \ $|258,834|\backslash$ | | 2,458 | \ $|261,392|\backslash$ | (4,882) | \$ | 258,840 | | Motor Reading Exp | 602 | \ $|3,843,502|\backslash$ | | 8,762 | \ $|3,852,264|\backslash$ | (6,388) | \$ | 3,842,898 | | Customer Records | 603 | \ $|5,280,781|\backslash$ | | 71,989 | \ $|5,322,750|\backslash$ | (86,377) | \$ | 5,288,373 | | Customer Collection | 603 | \ $|4,746,821|\backslash$ | | 38,181 | \ $|4,784,002|\backslash$ | | \$ | 4,784,002 | | Customer Deposit Interest | 603.2 | \ $||\backslash$ | | | \ $||\backslash$ | | \$ | | | Uncollectible Accounts | 604 | \ $|2,535,831|\backslash$ | | 2,051,289 | \ $|4,687,120|\backslash$ | (459,280) | \$ | 4,427,970 | | Effective Rate | 0 | 0 | 0000000000000 | | | | 0 008238108888 | | | | 0 008238108888 | | | Uncollectible Accounts-revenue adj | | \ $||\backslash$ | | (307,648) | \ $|(307,648)|\backslash$ | 307,648 | \$ | | | Uncollectible Accounts Easd-Wrhs Off | 604 | | (1,106,887) | \ $||||1,106,887)|\backslash$ | | \$ | (1,106,887) | | Miscellaneous | 605 | \ $|33,149|\backslash$ | | 810 | \ $|33,789|\backslash$ | (670) | \$ | 33,089 | | Fackering Expenses | 426.6 | \ $||\backslash$ | | | \ $||\backslash$ | | \$ | | | Fackering Factor | | | | | | | | | | | | | Supervision | | 0 | 00000000000000 | | | | 0 0000000000000 | | | | 0 000000000000 | | Supervision | 907 | \ $|392,505|\backslash$ | | (2,721) | \ $|389,784|\backslash$ | (5,628) | \$ | 384,155 |

| SOAN DOCKET NO. | 473-12-2879 | | | | | | | COMM Schedule 9 | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | PUG DOCKET NO. | 38888 | | | | | | | OAMI | | | COMPANY NAME | Entergy Texas, Inc. | | | | | | | | | | TEST YEAR END | 38-Jun-11 | | | | | | | | | | OPERATIONS AND MAINTENANCE EXPENSE | | | | | | | | | | | | | | | | | | | | Admit | | | | | | | Test Year | Company | Company | Committe | Committe | | | | | | | (a) | (b) | (c) | (d) | (e) $=80+90$ | | Admireatative &; General | | | | | | | | | | | Admire &; General Salaries | 000 | 8 | 16.406.632 | 8 | (1.460,140) | 8 | 16.946.762 | 8 | (5.773,708) | 8 | 11.172.064 | | Office Supplies &; Exp | 021 | 8 | 1.580,183 | 8 | (456,336) | 8 | 1.130,884 | 8 | (5.400) | 8 | 1.125,484 | | Admire Expenses Transferred | 022 | 8 | 1.059,841 | 8 | 1.008 | 8 | 1.080,847 | 8 | 214 | 8 | 1.081,161 | | Cutside Services | 023 | 8 | 14.921.588 | 8 | (5.431,183) | 8 | 6.480,408 | 8 | (56,762) | 8 | 6.400,844 | | Property Insurance | 024 | 8 | 1.134.432 | 8 | 1.287 | 8 | 1.138,718 | 8 | | 8 | 1.135,719 | | Provision for Property Insurance | 024 | 8 | 3.669.886 | 8 | 5.080,004 | 8 | 6.760,000 | 8 | (491,172) | 8 | 6.288,928 | | Environmental Reserve Accrual | 024 | 8 | 1.153.576 | 8 | | 8 | 1.153,576 | 8 | | 8 | 1.153,576 | | Injuries &; Damages | 025 | 8 | 1.659.858 | 8 | 7.424 | 8 | 1.867,082 | 8 | (5.437) | 8 | 1.861,946 | | Employee Pensions &; Benefits | 026 | 8 | 27.027.097 | 8 | (17,991) | 8 | 27.008,068 | 8 | (2.678,308) | 8 | 24.331.391 | | Regulatory Commission Exp | 028 | 8 | 7.708.535 | 8 | (1.984,403) | 8 | 5.723,832 | 8 | (4.150,717) | 8 | 1.573,215 | | General Advertising Exp | 0301 | 8 | 52,040 | 8 | (55) | 8 | 61,875 | 8 | (343) | 8 | 61,832 | | Miscellaneous | 0302 | 8 | 796,138 | 8 | 224.312 | 8 | 1.020,460 | 8 | (8,181) | 8 | 1.011,389 | | Active Development Expenses | 0302 | 8 | 21 | 8 | | 8 | 21 | 8 | - | 8 | 21 | | Directors' Fees and Expenses | 0302 | 8 | 79.478 | 8 | (79.478) | 8 | | 8 | - | | | | Rents | 031 | 8 | 3.284.425 | 8 | 1.164 | 8 | 3.265,589 | 8 | | 8 | 3.265,589 | | Mane. Of General Plant | 036 | 8 | 1.667,322 | 8 | 2.978 | 8 | 1.980,301 | 8 | (3.940) | 8 | 1.656,361 | | TOTAL Administrative &; General | | | 84.420.631 | | (4.134,391) | | 90.286,240 | | (13.207,751) | | 67.078,489 | | TOTAL O &; M EXPENSE | | | 1,291,884,714 | | (1,078,148,117) | | 216,836,887 | | (24,886,469) | 8 | 191,886,107 |

| SOAHI DOCKET MO. PUC DOCKET MO. 30000 COMPANY NAME | Entergy Texas, Inc. 30-Jun-11 | | | Company | Company | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | | | | Company | | | | | | | | | | | Adjustments | | | | | | | | | | | To Test Year | | | | | | | | | | | (a) | (b) | (c) | (d) | (e) | (c) + (d) + (d) | | | WVESTED CAPITAL | | | | | | | | | | | Plant in Service | | 5 | 3,321,308,187 | 5 | (251,512,491) | 5 | 3,209,858,098 | 5 | (338,753) | 5 | 3,209,519,943 | | Accumulated Depreciation | | 5 | (1,417,940,172) | 5 | (49,061,290 | 5 | (1,209,884,992) | 5 | - | - | 5 | (1,209,884,992) | | Net Plant in Service | | 5 | 2,103,422,018 | 5 | (103,481,201) | 5 | 1,996,970,814 | 5 | (336,753) | 5 | 1,996,936,081 | | Construction Work in Progress | | 5 | - | 5 | - | 5 | - | 5 | - | 5 | - | | Plant Held for Future Use | | 5 | - | 5 | - | 5 | - | 5 | - | 5 | - | | Working Cash Allowance | | 5 | - | 5 | (2,013,921) | 5 | (2,009,275) | 5 | (3,097,998) | 5 | (6,367,234) | | Fuel Inventories | | 5 | 53,759,975 | 5 | - | 5 | 53,759,975 | 5 | (1,088,498) | 5 | 52,993,468 | | Materials and Supplies | | 5 | 29,252,574 | 5 | - | 5 | 29,252,574 | 5 | 32,947 | 5 | 29,265,421 | | Prepayments | | 5 | 7,386,433 | 5 | (146,398) | 5 | 7,219,037 | 5 | 916,313 | 5 | 8,134,390 | | Property Insurance Reserve | | 5 | - | 5 | 56,790,744 | 5 | 56,790,744 | 5 | - | 5 | 56,790,744 | | Injuries and Damages Reserve | | 5 | (5,509,243) | 5 | - | 5 | (5,509,243) | 5 | - | 5 | (5,509,243) | | Coal Car Maintenance Reserve | | 5 | 1,400,380 | 5 | - | 5 | 1,400,380 | 5 | - | 5 | 1,400,380 | | Unfunded Pension | | 5 | (53,715,941) | 5 | 109,699,386 | 5 | 55,973,949 | 5 | (25,311,238) | 5 | 30,892,309 | | Allowances | | 5 | 99,814 | 5 | - | 5 | 98,914 | 5 | - | 5 | 98,914 | | Environmental Resources | | 5 | 3,412,379 | 5 | (4,474,589) | 5 | (1,062,190) | 5 | - | 5 | (1,062,190) | | Customer Deposits | | 5 | (30,672,476) | 5 | - | 5 | (30,672,476) | 5 | - | 5 | (30,672,476) | | Regulatory Assets and Liabilities | | 5 | - | 5 | 26,386,959 | 5 | 26,386,959 | 5 | (11,054,084) | 5 | 15,312,198 | | Accumulated DFIT | | 5 | (634,339,891) | 5 | 309,987,144 | 5 | (494,371,547) | 5 | 6,396,408 | 5 | (447,973,142) | | Rate Case Expenses | | 5 | - | 5 | 6,175,000 | 5 | 6,175,000 | 5 | (6,175,000) | 5 | - | | | | 5 | - | 5 | - | 5 | - | 5 | - | 5 | - | | TOTAL WVESTED CAPITAL (RATE BASE) | | 5 | 1,279,196,380 | 5 | 461,910,940 | 5 | 1,740,421,001 | 5 | (40,293,937) | 5 | 1,706,128,144 | | RATE OF RETURN | | | 5.140\% | | | | 6.82\% | | | | 8.2700\% | | RETURN ON WVESTED CAPITAL | | 5 | - | 5 | 150,182,991 | 5 | 150,182,991 | 5 | (14,562,393) | 5 | 140,000,000 |

| RO4H DOCKET NO. | 473-12-2979 | | | | | | | | | COMM Bolevluke WA Electric Plant in Service | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | COMPANY NAME | Ent | | | | | | | | | | | | Entergy Texas, Inc. | | | | | | | | | | | | | TEST YEAR END | $30-Jun-11$ | | | | | | | | | | | | $30-Jun-11$ | | | | | | | | | | | | | Electric Plant in Service | | | | | | | | | | | | | Intangible Plant | | | | | | | | | | | | | Organization | 301 | $X$ | 1,346,596 | $X$ | 4,908,233 | $X$ | 6,305,132 | $X$ | - | $X$ | 6,305,132 | | Mac Intangible Plant | 303 | $X$ | 96,199,717 | $X$ | 4,189,696 | $X$ | 102,965,408 | $X$ | - | $X$ | 100,965,408 | | Total Intangible Plant | | $X$ | 98,133,818 | $X$ | 8,137,622 | $X$ | 107,281,538 | $X$ | - | $X$ | 107,281,538 | | Production Plant-Steem | | | | | | | | | | | | | Land and Land Rights | 310 | $X$ | 4,512,873 | $X$ | - | $X$ | 4,512,873 | $X$ | - | $X$ | 4,512,873 | | Structure and Improve | 311 | $X$ | 172,930,826 | $X$ | 1,006,019 | $X$ | 174,026,848 | $X$ | - | $X$ | 174,026,848 | | Other Plant Equipment | 312 | $X$ | 388,477,042 | $X$ | 10,838,417 | $X$ | 388,316,458 | $X$ | - | $X$ | 388,316,458 | | Tuttagemeaters | 314 | $X$ | 166,175,111 | $X$ | 6,197,916 | $X$ | 167,983,030 | $X$ | - | $X$ | 167,983,030 | | Accessory Equipment | 316 | $X$ | 96,272,189 | $X$ | 10,150,419 | $X$ | 107,022,608 | $X$ | - | $X$ | 107,022,608 | | Mac. Power Plant Equip | 318 | $X$ | 10,848,083 | $X$ | 1,664,464 | $X$ | 12,712,547 | $X$ | - | $X$ | 12,712,547 | | Asset Retire Costs | 317 | $X$ | 419,211 | $X$ | (419,211) | $X$ | - | $X$ | - | $X$ | - | | Accessory Eac Equip | 324 | $X$ | 218,538 | $X$ | - | $X$ | 218,538 | $X$ | - | $X$ | 218,538 | | Mac. Power Plant Equip | 326 | $X$ | 37,269 | $X$ | - | $X$ | 37,269 | $X$ | - | $X$ | 37,269 | | Total Production Plant | | $X$ | 662,880,942 | $X$ | 32,821,027 | $X$ | 666,811,989 | $X$ | - | $X$ | 666,811,989 | | Transmission Plant | | | | | | | | | | | | | Land | 350 | | $X$ | 6,676,879 | $X$ | 4,247,242 | $X$ | 13,827,121 | $X$ | - | $X$ | 13,827,121 | | Exeements | 350 | | $X$ | 33,822,986 | $X$ | 356,736 | $X$ | 33,876,623 | $X$ | - | $X$ | 33,876,623 | | Structure and Improve | 352 | $X$ | 21,808,777 | $X$ | 668,862 | $X$ | 22,576,628 | $X$ | - | $X$ | 22,576,628 | | Station Equipment | 353 | $X$ | 344,866,139 | $X$ | 10,426,483 | $X$ | 355,298,802 | $X$ | - | $X$ | 355,298,802 | | Townes &; Fielures | 354 | $X$ | 25,360,394 | $X$ | 64,266 | $X$ | 25,424,489 | $X$ | - | $X$ | 25,424,489 | | Poles &; Fielures | 356 | $X$ | 166,963,323 | $X$ | 13,724,724 | $X$ | 160,296,047 | $X$ | - | $X$ | 160,296,047 | | Overhead Conductors AD | 358 | $X$ | 166,098,991 | $X$ | 12,570,240 | $X$ | 178,669,231 | $X$ | - | $X$ | 178,669,231 | | Underground Conduct | 357 | $X$ | - | $X$ | - | $X$ | - | $X$ | - | $X$ | - | | Underground Conductor | 358 | $X$ | 321,717 | $X$ | - | $X$ | 321,717 | $X$ | - | $X$ | 321,717 | | Roads and Trails | 359 | $X$ | 202,786 | $X$ | - | $X$ | 202,786 | $X$ | - | $X$ | 202,786 | | Total Transmission Plant | | $X$ | 756,526,693 | $X$ | 42,062,342 | $X$ | 610,561,239 | $X$ | - | $X$ | 610,561,239 | | Distribution Plant | | | | | | | | | | | | | Land | 360 | | 4,178,956 | | | $X$ | 4,178,956 | $X$ | - | $X$ | 4,178,956 | | Exeements | 360 | | 11,759,529 | | | $X$ | 11,759,529 | $X$ | - | $X$ | 11,759,529 | | Structure and Improve | 361 | $X$ | 7,667,617 | $X$ | 157,068 | $X$ | 8,014,908 | $X$ | - | $X$ | 8,014,908 | | Station Equipment | 362 | $X$ | 158,704,939 | $X$ | 7,566,199 | $X$ | 164,269,178 | $X$ | - | $X$ | 164,269,178 | | Poles, Townes &; Fielures | 364 | $X$ | 185,114,784 | $X$ | 36,287,318 | $X$ | 221,402,103 | $X$ | - | $X$ | 221,402,103 | | Oil Conductors &; Devices | 366 | $X$ | 170,541,014 | $X$ | 44,147,419 | $X$ | 214,669,432 | $X$ | - | $X$ | 214,669,432 | | Underground Conduct | 369 | $X$ | 73,087,428 | $X$ | 1,103,810 | $X$ | 23,171,298 | $X$ | - | $X$ | 23,171,298 | | Oil Use &; Devices | 367 | $X$ | 54,321,923 | $X$ | 7,121,997 | $X$ | 61,343,590 | $X$ | - | $X$ | 61,343,590 | | Use Transformers | 368 | $X$ | 255,307,338 | $X$ | 73,111,167 | $X$ | 358,466,376 | $X$ | - | $X$ | 358,466,376 | | Services-Overhead | 369 | | 41,093,559 | $X$ | 13,092,741 | $X$ | 54,196,300 | $X$ | - | $X$ | 54,196,300 | | Services-Underground | 369 | $X$ | 32,113,168 | $X$ | 4,314,468 | $X$ | 36,427,624 | $X$ | - | $X$ | 36,427,624 | | Waters | 370 | $X$ | 30,110,288 | $X$ | (1,906,468) | $X$ | 28,301,619 | $X$ | - | $X$ | 28,301,619 | | Interlations on Gas Fire | 371 | $X$ | 16,132,486 | $X$ | 2,316,592 | $X$ | 16,461,078 | $X$ | - | $X$ | 16,461,078 | | Street Lights | 373 | $X$ | (226,906) | $X$ | 2,376,038 | $X$ | 2,151,130 | $X$ | - | $X$ | 2,151,130 | | Non-Redentary Lighting | 373 | $X$ | (21,554) | $X$ | (621,392) | $X$ | 1623,045 | $X$ | - | $X$ | 1623,045 | | Total Distribution Plant | | $X$ | 1,047,003,608 | $X$ | 166,367,866 | $X$ | 1,236,361,370 | $X$ | - | $X$ | 1,236,361,370 | | Computer Hardware | 382 | $X$ | 50,623 | $X$ | - | $X$ | 60,623 | $X$ | - | $X$ | 60,623 | | Computer Software | 383 | $X$ | 1,366,130 | $X$ | - | $X$ | 1,366,130 | $X$ | - | $X$ | 1,366,130 | | Total Computer | | $X$ | 3,426,753 | $X$ | - | $X$ | 3,426,753 | $X$ | - | $X$ | 3,426,753 | | General Plant | | | | | | | | | | | | | Land &; Land Rights | 389 | $X$ | 5,147,438 | $X$ | (90,256) | $X$ | 5,067,177 | $X$ | - | $X$ | 5,067,177 | | Structure &; Improvene | 390 | $X$ | 53,909,613 | $X$ | 3,034,857 | $X$ | 56,944,470 | $X$ | - | $X$ | 56,944,470 | | Office Furniture &; Equip | 391 | $X$ | 694,536 | $X$ | (56,226) | $X$ | 636,310 | $X$ | - | $X$ | 636,310 | | Information System | 391 | $X$ | 17,646,603 | $X$ | 1,223,820 | $X$ | 16,870,723 | $X$ | - | $X$ | 16,870,723 | | Data Handling Equip | 391 | $X$ | 617,640 | $X$ | 602 | $X$ | 616,922 | $X$ | - | $X$ | 616,922 | | Transportation Equip | 392 | $X$ | 61,988 | $X$ | (61,477) | $X$ | 10,511 | $X$ | - | $X$ | 10,511 | | Stores Equipment | 393 | $X$ | 3,226,653 | $X$ | - | $X$ | 3,226,653 | $X$ | - | $X$ | 3,226,653 | | Tools, Shop &; Garage E | 394 | $X$ | 7,656,626 | $X$ | 451,356 | $X$ | 8,307,964 | $X$ | - | $X$ | 8,307,964 | | Laboratory Equipment | 395 | $X$ | 600,637 | $X$ | (300,163) | $X$ | 300,448 | $X$ | - | $X$ | 300,448 | | Power Operating Equip | 396 | $X$ | 526,699 | $X$ | - | $X$ | 526,699 | $X$ | - | $X$ | 526,699 | | Mac Comm Equipment | 397 | $X$ | 5,107,445 | $X$ | 252,692 | $X$ | 5,350,425 | $X$ | - | $X$ | 5,350,425 | | Comm &; Microwave Equ | 397 | $X$ | 40,163,821 | $X$ | 233,697 | $X$ | 40,416,318 | $X$ | - | $X$ | 40,416,318 | | Mac Equipment | 398 | $X$ | 966,421 | $X$ | (26,332) | $X$ | 943,069 | $X$ | - | $X$ | 943,069 | | Total General Plant | | $X$ | 137,176,318 | $X$ | 4,641,529 | $X$ | 141,616,529 | $X$ | - | $X$ | 141,616,529 | | Electric Contre AFUDC | | $X$ | (8,382,462) | $X$ | - | $X$ | (8,382,462) | $X$ | - | $X$ | (8,382,462) | | Comet Elso Cash Flow Reclase | | $X$ | 246,427,657 | $X$ | (246,427,658) | $X$ | - | $-11$ | $X$ | - | $X$ | $-11$ | | Immediate Computation on Class | 301 | $X$ | 64,360 | $X$ | (52,768) | $X$ | 11,482 | $X$ | - | $X$ | 11,482 | | Computed Computation on Class | 301-04 | $X$ | 23,532,587 | $X$ | (20,940,477) | $X$ | 2,562,110 | $X$ | - | $X$ | 2,562,110 | | Computed Computation on Class | 301-09 | $X$ | 37,517,589 | $X$ | 14,319,309 | $X$ | 51,636,798 | $X$ | - | $X$ | 51,636,798 | | Computed Computation on Class | 301-01 | $X$ | 153,103,936 | $X$ | (129,701,676) | $X$ | 22,401,060 | $X$ | - | $X$ | 22,401,060 | | Computed Computation on Class | 301-04 | $X$ | 5,714,246 | $X$ | (777,624) | $X$ | 4,636,622 | $X$ | - | $X$ | 4,636,622 | | Plant Acquisition Adjustment | 311 | $X$ | 1,127,778 | $X$ | - | $X$ | 1,127,778 | $X$ | - | $X$ | 1,127,778 | | | | $X$ | 460,104,601 | $X$ | (365,561,394) | $X$ | 74,523,407 | $X$ | - | $X$ | 74,523,407 | | Total Electric PS | | $X$ | 3,377,356,938 | $X$ | (197,411,236) | $X$ | 3,366,856,666 | $X$ | (336,753) | $X$ | 3,366,816,946 |

| ROAN DOCKET NO. | 473-12-2079 | | | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | PUC DOCKET NO. | 35666 | | | | | | | | | | COMPANY NAME | Entergy Texas, Inc. | | | | | | | | | | TEST YEAR END | 30-Jun-11 | | | | | | | | |

| SOAN SOCIETY | 475-12-2878 | | | | | | | | | | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | :--: | | PUC SOCIETY NO. | 38888 | | | | | | | | | | COMPANY NAME | Entergy Texas, Inc. | | | | | | | | | | TEST YEAR END | $30-Jun-11$ | | | | | | | | | | | | | | | | | | | (H) $ $(H)$ $ (H) | | TAKES OTHER THAN FIT | | | | | | | | | | | Non Revenue Related | | | | | | | | | | | Ad Vatorem Taxes-Taxes | 6 | 21,831,938 | 5 | 2,592,420 | 5 | 24,224,388 | 5 | (1,380,227) | - | 5 | 22,844,129 | | Ad Vatorem Taxes-Other States | 5 | 2,075,883 | 5 | - | 5 | 2,075,883 | 5 | | | 5 | 2,075,883 | | Total Property | 5 | 23,708,829 | 5 | 2,592,420 | 5 | 26,301,248 | 5 | (1,380,227) | | 5 | 24,921,022 | | Payroll Taxes | | | | | | | | | | | | P/CN | 5 | 2,287,010 | 5 | (122,814) | 5 | 2,184,098 | 5 | (57,923) | | 5 | 2,108,173 | | P/ITA | 5 | 20,530 | 5 | - | 5 | 20,530 | 5 | (518) | | 5 | 20,011 | | S/ITA | 5 | 33,897 | 5 | - | 5 | 33,897 | 5 | (5,878) | | 5 | 37,518 | | Total Payroll | 5 | 2,341,437 | 5 | (122,814) | 5 | 2,218,523 | 5 | (69,120) | | 5 | 2,153,403 | | Franchise Taxes | | | | | | | | | | | | Taxes | 408.33 | 5 | - | 5 | - | 5 | - | 5 | | 5 | - | | Other States | 5 | - | 5 | - | 5 | - | 5 | - | | 5 | - | | | 5 | - | 5 | - | 5 | - | 5 | - | | 5 | - | | Other Taxes | | | | | | | | | | | | ESI Ad Vatorem | 5 | 266,308 | - | - | 5 | 266,308 | - | - | | 5 | 266,308 | | ESI Payroll Taxes | 5 | 1,813,808 | 5 | 115,382 | 5 | 1,728,218 | 5 | (121,549) | | 5 | 1,607,889 | | ESI Franchise Taxes | 5 | 40,220 | 5 | - | 5 | 40,220 | 5 | - | | 5 | 40,220 | | ESI Other | 5 | 180 | 5 | - | 5 | 180 | 5 | - | | 5 | 180 | | Entergy Arkansas Payroll Taxes | 5 | 28,399 | - | - | 5 | 28,399 | - | - | | 5 | 28,399 | | Entergy Mississippi Payroll Taxes | 5 | 488 | - | - | 5 | 488 | - | - | | 5 | 488 | | Entergy New Orleans Payroll Taxes | 5 | 12 | - | - | 5 | 12 | - | - | | 5 | 12 | | Entergy Gulf States Louisiana Payroll | 5 | 127,081 | - | - | 5 | 127,081 | - | - | | 5 | 127,081 | | Total Other | 5 | 2,086,530 | 5 | 115,382 | 5 | 2,001,690 | 5 | (121,549) | | 5 | 2,086,530 | | Revenue Related | | | | | | | | | | | | State Gross Receipts - Taxes | 5 | 13,427,784 | 5 | (1,536,790) | 5 | 11,891,004 | 5 | (1,117,416) | | 5 | 10,773,588 | | Effective Rate | | | | | | 0.009400949 | | | | | 0.02003803279 | | State Gross Receipts - Taxes | 5 | - | 5 | (1,398,664) | 5 | (1,398,664) | 5 | 1,398,664 | | 5 | - | | Effective Rate | 5 | 18,832,527 | 5 | (2,257,408) | 5 | 17,675,122 | 5 | (1,860,988) | | 5 | 18,014,184 | | Local Gross Receipts - Other | 5 | 0.0000000000000 | | | | 0.0207301812847 | | | | | 0.02976732378 | | State Gross Margins - Taxes | 5 | - | 5 | (76,933) | 5 | (76,933) | 5 | 76,933 | | 5 | - | | Effective Rate | | | | | | | | | | 5 | - | | PUC Assessment - Taxes | 5 | 1,528,786 | 5 | (3,227,792) | 5 | 28,132,529 | 5 | (1,344,777) | | 5 | 28,787,752 | | PUC Assessment Effective Rate | 5 | 1,528,786 | 5 | 320,528 | 5 | 1,647,317 | 5 | (173,098) | | 5 | 1,673,722 | | PUC Assessment - Other | 5 | | 5 | | 5 | 0.001687 | | | | | 0.00311322488 | | PUC Assessment - Other | 5 | | 5 | (215,753) | 5 | (215,753) | 5 | 215,753 | | 5 | - | | | 5 | 1,528,786 | 5 | 108,788 | 5 | 1,636,584 | 5 | 37,188 | | 5 | 1,673,722 | | TOTAL TAKES OTHER THAN | | | | | | | | | | | | INCOME TAKES | 6 | 63,833,866 | 5 | (3,833,168) | 5 | 66,466,747 | 5 | (2,874,886) | 5 | 67,916,341 |

| SCHAIDOCKET NO. 473-12-2879 | | | | COMM Schedule V | | :--: | :--: | :--: | :--: | :--: | | PUG DOCKET NO. 38696 | | | | Federal Income Taxes | | COMPANY NAME | Entergy Texas, Inc. | | | | | TEST YEAR END | 30-Jun-11 | | | | | 30-Jun-11 | | | | | | PEDERAL INCOME TAXES - METHOD 1 | | Requested | Com | | | | | AI Proposed | Adjustments | | | | | Test Year | To Company | Commission | | | | (a) | Request | Total Electric | | | | | (a) | | | Return | Total | | | 140,500,598 | | Lease | | | | | | Interest Included in Return | | | | 57,409,530 | | Amortization of ITC | | | | 1,042,948 | | Amortization of DPT (Excess) | | | | 236,870 | | Consolidated Tax Savings | | | | | | Plos | | | | | | AFI/EC | | | | 15,544,523 | | Other Permanent Differences | | | | (1,720,971) | | Non-Normalized Timing Differences | | | | | | ECHESI Taxes | | | | 436,748 | | Current State Income Tax | | | | (37,732) | | Deferred State Income Tax | | | | 84,347 | | FAS 109 | | | | | | Amortization of Excess DPT-Depreciation | | | | | | | | | | | | TAXABLE COMPONENT OF RETURN | | | | 95,618,465 | | TAX FACTOR (1/1-30) 30) | | 0.53846150 | | 0.53846150 | | TOTAL FIT BEFORE ADJUSTMENTS | | 0 | | 51,498,962 | | Adjustments: | | | | | | Amortization of ITC | | | | 1,642,848) | | Amortization of Excess DPT - Depreciation | | | | (236,870) | | Prior Years Current FIT | | | | | | Prior Years Deferred FIT | | | | | | ECHESI Taxes | | | | 463,748 | | FAS 109 | | | | | | Other - Consolidated Tax Savings | | | | | | | | | | | | TOTAL PEDERAL INCOME TAXES | | | | 65,971,862 |

NOTES

${}^1$ Clerk's Record ("CR") 3-15.

${}^2$ CR 232-34.

${}^3$ See Tex. Util. Code Ann. §§ 11.01, et seq.

${}^4$ Reporter's Record Joint Exh. 1 (Administrative Record or "AR" Part I, Binder 2, Item 55 (May 21, 2013, Final Order at FOF 3)).

${}^5$ Id. at FOF 10.

${}^6$ Id. at 1 .

${}^7$ AR Part I, Binder 1, Item 1 (SOAH Order No. 1); AR Part I, Binder 2, Item 55 (Final Order at FOF 4).

${}^8$ AR Part I, Binder 2, Item 55 (Final Order at FOF 12).

${}^9$ Several parties, including ETI, the Commission, and the Office of Public Utility Counsel ("OPUC"), appealed the Commission's decision in Docket No. 39896. That appeal is currently pending before this Court as Case No. 03-14-00735-CV. None of the issues raised in that appeal pertain to the issues raised in this appeal.

${}^{10}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket No. 39896, ETI Exh. 13 (Watson Direct at Exh. DAW-1). The Administrative Law Judge in the docket underlying this appeal took official notice of the record in Docket No. 39896. See AR Part III, Vol. A (Transcript of Hearing on the Merits at 16). Public filings in Docket No. 39896 and other Commission dockets may be accessed at the Commission's interchange: http://interchange.puc.texas.gov/WebApp/Interchange/application/dbapps/filings/pgSearch.asp by entering the docket number in the "Control Number" field.

${}^{11}$ Id., ETI Exh. 41 (Tumminello Direct at 9 of 98).

${}^{12}$ Id. at $79\&81$ of 98 .

${}^{13}$ Id. at $80\&83$ of 98 .

${}^{14}$ Id. at 84 of 98 .

${}^{15}$ Id. (Nov. 2, 2012, Order on Rehearing at FOFs 162-70 &; COL 14).

${}^{16}$ Id., ETI Exh. 36 (Gardner Direct at 6-7 of 77) &; ETI Exh. 50 (Gardner Rebuttal at 2 of 18).

${}^{17}$ Id. (Gardner Direct at 29 of 77).

${}^{18}$ Dr. Hartzell is the Chair of the Finance Department, and Professor of Finance, at the University of Texas at Austin School of Business. Id., ETI Exh. 15 (Hartzell Direct at 1 of 31).

${}^{19}$ Id. at 3 of 31.

${}^{20}$ Id., ETI Exh. 36 (Gardner Direct at 30).

${}^{21}$ Id. at 30-31; ETI Exh. 50 (Gardner Rebuttal at 5 &; 8-9 of 18); ETI Exh. 15 (Hartzell Direct at 6-8 of 31); ETI Exh. 53 (Hartzell Rebuttal at 4-10 of 15).

${}^{22}$ Id., ETI Exh. 50 (Gardner Rebuttal at p. 6-8 of 18); ETI Exh. 15 (Hartzell Direct at 9-12 of 31); ETI Exh. 53 (Hartzell Rebuttal 10-13 of 15).

${}^{23}$ Id. (Proposal for Decision at 166-176).

${}^{24}$ Id. at 175 .

${}^{25}$ Id. (Nov. 2, 2012, Order on Rehearing at FOFs 127-34).

${}^{26}$ AR Part I, Binder 1, Items 5 &; 10 (SOAH Order Nos. 2 &; 4).

${}^{27}$ AR Part I, Binder 2, Item 55 (Final Order at 1).

${}^{28}$ AR Part II, Binder 3, ETI Exh. 6 (Considine Supp. Direct at 3-4); ETI Exh. 7 (Considine Rebuttal at 11).

${}^{29}$ AR Part I, Binder 2, Item 32 (Proposal for Decision at 34).

${}^{30}$ Id. at 11-12.

${}^{31}$ Id. at 23.

${}^{32}$ Id. at 32-34.

${}^{33}$ See AR Part I, Binder 2, Item 55 (Final Order at 3).

${}^{34}$ Id. at FOF 18(a).

${}^{35}$ Id. at 2 &; FOF 18(f).

${}^{36}$ AR Part I, Binder 2, Item 56 (ETI's Motion for Rehearing).

${}^{37}$ CR 3-15.

${}^{38}$ Id. 16-17, 19-23, &; 27-29.

${}^{39}$ Id. 232-34.

${}^{40}$ AR Part I, Binder 2, Item 55 (Final Order at pp. 5-6, FOF 18(f)).

${}^{41}$ Id. at 2 (footnote omitted).

${}^{42}$ AR Part II, Binder 3, ETI Exh. 12 (Morris Rebuttal at 2 of 14).

${}^{43}$ See Application of AEP Texas Central Co. for Authority to Change Rates, Docket No. 28840 (Aug. 15, 2005, Final Order at FOFs 164-70), cited in Docket No. 39896, supra, (Proposal for Decision at 175) (Appendix C).

${}^{44}$ Docket No. 39896, supra, (Proposal for Decision at 175; Nov. 2, 2012, Order on Rehearing at FOFs 127-34) (Appendix C).

${}^{45}$ Docket No. 39896, supra, (Proposal for Decision at 166-72; Nov. 2, 2012, Order on Rehearing at FOFs 127-34) (Appendix C).

${}^{46}$ Application of Southwestern Electric Power Co. for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 40443 (Mar. 6, 2014, Order on Rehearing at 11 &; FOF 220) (Appendix C).

${}^{47}$ AR Part II, Binder 3, ETI Exh. 12 (Morris Rebuttal at 3 of 14) (citing Application of Southwestern Electric Power Company for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 40443 (Direct Testimony of Andrew R. Carlin at 5); Application of El Paso Electric Company to Change Rates, to Reconcile Fuel Costs, to Establish Formula-Based Fuel Factors, and to Establish an Energy Efficiency Cost Recovery Factor, Docket No. 37690 (Direct Testimony of Michael D. Feuerbacher at 5), Order (July 30, 2010); Application of Southwestern Electric Power Company for Authority to Change Rates, Docket No. 37364 (Direct Testimony of David A. Jolley at 13-30), Order (Apr. 16, 2010); Application of Southwestern Public Service Company Authority to Change Rates, to Reconcile Fuel and Purchased Power Costs for 2006 and 2007 and to Provide a Credit for Fuel Cost Savings, Docket No. 35763 (Direct Testimony of Marvin E. McDaniel, Jr. at 12), Order (June 2, 2009); Application of Oncor Electric Delivery Company, LLC for Authority to Change Rates, Docket No. 35717 (Direct Testimony of James A.

Greer at 43-44), Final Order (Aug. 31, 2009); Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309 (Direct Testimony of David A. Jolley at 12), Order (Dec. 13, 2007)).

${}^{48}$ AR Part II, Binder 3, ETI Exh. 12 (Morris Rebuttal at 3-4 of 14 &; Exh. SFM-R-1).

${}^{49}$ Application of CenterPoint Energy Houston Electric, LLC for Authority to Change Rates, Docket No. 38339 (Jun. 23, 2011, Order on Rehearing at FOFs 81-83) (Appendix D).

${}^{50}$ Requests for Rate Case Expenses Severed from Docket No. 38339, Docket No. 39127 (Jun. 6, 2011, Order at FOFs 6, 12, &; 20) (Appendix D).

${}^{51}$ Application of AEP TCC for Authority to Change Rates, Docket No. 33309 (Mar. 4, 2008, Order on Rehearing at FOF 82) (Appendix D).

${}^{52}$ Proceeding to Consider Rate Case Expenses Severed from Docket No. 33310 and Docket No. 33309, Docket No. 34301 (May 23, 2008, Final Order at FOFs 18, 20, &; 21) (Appendix D).

${}^{53}$ Application of AEP Central for Authority to Change Rates, Docket No. 28840 (Aug. 15, 2005, Final Order at FOFs 164-70) (Appendix D).

${}^{54}$ Proceeding to Consider Rate Case Expenses Severed from Docket No. 28840, Docket No. 31433 (Mar. 3, 2006, Order at FOF 26) (Appendix D).

${}^{55}$ April 11, 2013, Transcript at 7:25-8:14 (emphasis added) (Appendix E).

${}^{56}$ AR Part I, Binder 2, Item 55 (Final Order at 2).

${}^{57}$ April 11, 2013, Transcript at 7:25-8:14 (emphasis added) (Appendix E).

${}^{58}$ See Appendix D.

${}^{59}$ AR Part I, Binder 2, Item 32 (Proposal for Decision at 24).

${}^{60}$ Id.

${}^{61}$ Id. at 32-33.

${}^{62}$ Id. at 33-34.

${}^{63}$ AR Part I, Binder 2, Item 55 (Final Order at FOF 18(f)).

${}^{64}$ AR Part I, Binder 2, Item 32 (Proposal for Decision at 32).

${}^{65}$ In re El Paso Electric Co., Docket No. 9945, 18 P.U.C. Bull. 9, 576 (Feb. 6, 1992 Order on Rehearing at FOF 197); Proceeding to Consider Rate Case Expenses Severed from Docket No.

28840 (Application of AEP Texas Central Co. for Authority to Change Rates), Docket No. 31433 (Mar. 3, 2006 Order at 3).

${}^{66}$ Docket No. 9945, supra, 18 P.U.C. Bull. 9, 576 (Feb. 6, 1992 Order on Rehearing at FOF 197).

${}^{67}$ Docket No. 31433, supra (Mar. 3, 2006 Order at 3).

${}^{68}$ AR Part II, Binder 3, ETI Exh. 10 (Morris Supp. Direct at 13-14 of 24).

${}^{69}$ AR Part II, Binder 3, ETI Exh. 6 (Considine Supp. Direct, Exh. MPC-SD-6).

${}^{70}$ See Docket No. 39896, supra, (Nov. 2, 2012, Order on Rehearing at FOFs 162-70 &; COL 14).

${}^{71}$ AR Part I, Binder 2, Item 32 (Proposal for Decision at 12); AR Part I, Binder 2, Item 55 (Final Order at 1).

${}^{72}$ AR Part II, Binder 3, ETI Exh. 1 (Considine Direct at 61 of 62); AR Part II, Binder 3, ETI Exh. 6 (Considine Supp. Direct at 4 of 5); AR Part II, Binder 3, ETI Exh. 7 (Considine Rebuttal at 11 of 11 ).

${}^{73}$ AR Part II, Binder 3, ETI Exh. 7 (Considine Rebuttal at 10 of 11 &; MPC-R-1).

${}^{74}$ AR Part II, Binder 3, ETI Exh. 7 (Considine Rebuttal at 11).

${}^{75}$ AR Part III, Vol. A (Transcript of Hearing on the Merits at 16).

${}^{76}$ Docket No. 39896, supra, ETI Exh. 41 (Tumminello Direct at 79 of 98).

${}^{77}$ Id. at 84 of 98 .

${}^{78}$ Id. at 81 of 98.

${}^{79}$ AR Part I, Binder 2, Item 32 (Proposal for Decision at 12).

${}^{80}$ See Docket No. 39896, supra, ETI Exh. 41 (Tumminello Direct at 11 of 98).

${}^{81}$ AR Part II, Binder 3, ETI Exh. 6 (Considine Supp. Direct at p. 4 of 5).

${}^{82}$ See Docket No. 39896, supra (Nov. 2, 2012, Order on Rehearing at 170).

${}^{83}$ AR Part III, Vol. A (Transcript of Hearing on the Merits at 16).

${}^1$ The Cities are: the Cities of Anahuac, Beaumont, Bridge City, Cleveland, Conroe, Dayton, Groves, Houston, Huntsville, Montgomery, Navasota, Nederland, Oak Ridge North, Orange, Pine Forest, Rose City, Pinehurst, Port Arthur, Port Neches, Shenandoah, Silsbee, Sour Lake, Splendora, Vidor, and West Orange.

${}^2$ Multiple second motions for rehearing were denied by the Commission on December 4, 2012.

${}^3$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Proposal for Decision (July 6, 2012).

${}^4$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Order on Rehearing (November 1, 2012).

${}^5$ ETI Ex. 1 (Considine Direct) at 62.

${}^6$ Initially, ETI sought recovery of $\backslash$ 8,752,576 $.Initsbriefing,however,ETIexplainsthatitisreducingtheamountitseeksto$ \ $8,752,545$ (a reduction of $\backslash$ 31$ ) to account for two excessive charges for meals. ETI Init. Br. at 1 n .1.

${}^7$ ETI Ex. 6 (Considine Supp.) at 1.

${}^8$ ETI Ex. 6 (Considine Supp.) at 3, 5, and attachment MPC-SD-5. The $\backslash$ 1,117,309$ in expenses incurred by Cities is included as part of ETI's "internal" expenses.

${}^9$ ETI Ex. 6 (Considine Supp.) at 7.

${}^{10}$ ETI Ex. 8 (Morris Direct) at 18.

${}^{11}$ ETI Ex. 8 (Morris Direct) at 1-2.

${}^{12}$ Transcript from Hearing on the Merits (Tr.) at 17.

${}^{13}$ Cities Init. Br. at 2.

${}^{14}$ Cities Init. Br. at 5.

${}^{15}$ See Cities Ex. No. 1 (Hodgins Direct) and Ex. No. 2 (Hodgins Supp.).

${}^{16}$ Cities Ex. 2 (Hodgins Supp.) at n. 6.

${}^{17}$ Cities Ex. 2 (Hodgins Supp.) at 13-14.

${}^{18}$ Cities Ex. 1 (Hodgins Direct) at 6-7; citing Application of CenterPoint Energy Houston Electric, LLC for Competition Transition Charge, Docket No. 30706, Order at 31 and FOFs 72-74 (Jul. 14, 2005)(Docket 30706).

${}^{19}$ Staff Init. Br. at 6.

${}^{20}$ Application of Southwestern Electric Power Company for Rate Case Expenses Pertaining to Docket No. 37364, Docket 37772, Order at 1-2 (Oct. 21, 2010)(emphasis in original)(Docket 37772).

${}^{21}$ Staff Init. Br. at 7.

${}^{22}$ Indeed, the ALJ notes that Cities attached to their Reply Brief an affidavit from Ms. Hodgins attesting to the fact that, from September through November 2012, Cities actually incurred expenses of $\backslash$ 43,525.45 $(or$ 57 \% $oftheestimated$ \ $75,800$ ). Cities Reply Br. at $4-5$ , and attached affidavit.

${}^{23}$ ETI Ex. 8 (Morris Direct) at 29-30.

${}^{24}$ State Agencies Init. Br. at 18-19.

${}^{25}$ ETI Init. Br. at 10-11; ETI Ex. 7 (Considine Supp.) at 9-10.

${}^{26}$ ETI Ex. 8 (Morris Direct) at 29-30.

${}^{27}$ ETI Ex. 12 (Morris Rebuttal) at 28-29 (Attachment SFM-R-3).

${}^{28}$ ETI Ex. 12 (Morris Rebuttal) at 28-29 (Attachment SFM-R-3).

${}^{29}$ State Agencies Init. Br. at 19.

${}^{30}$ ETI Init. Br. at 13.

${}^{31}$ ETI Ex. 7 (Considine Rebuttal) at 9-11 and Attachment MPC-R-1.

${}^{32}$ ETI Ex. 7 (Considine Rebuttal) at 11.

${}^{33}$ ETI Ex. 7 (Considine Rebuttal) at 11.

${}^{34}$ State Agencies Init. Br. at 20.

${}^{35}$ ETI Init. Br. at 12.

${}^{36}683$ S.W.2d 783, 786 (Tex. App.—Austin 1985, no pet.).

${}^{37}$ ETI Ex. 7 (Considine Rebuttal) at Attachment MPC-R-1.

${}^{38}$ ETI Ex. 7 (Considine Rebuttal) at Attachment MPC-R-1; see also State Agencies Init. Br. at 21.

${}^{39}$ ETI Reply Br. at 23-24.

${}^{40}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Proposal for Decision at 236 (July 6, 2012).

${}^{41}$ Application of Entergy Texas, Inc. for Rate Case Expenses Pertaining to PUC Docket No. 39896, Docket 40295, OPUC's Recommendation and Request for Hearing at 2-3 (November 6, 2012).

${}^{42}$ State Agencies Reply Br. at 20.

${}^{43}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Proposal for Decision at 236 (July 6, 2012).

${}^{44}$ ETI Ex. 7 (Considine Rebuttal) at 7-9.

${}^{45}$ State Agencies Init. Br. at 7.

${}^{46}$ State Agencies Reply Br. at 9.

${}^{47}$ Staff Init. Br. at 12.

${}^{48}$ Staff Init. Br. at 12.

${}^{49}$ Staff Reply Br. at 9.

${}^{50}$ OPUC Init. Br. at 1.

${}^{51}$ ETI Ex. 7 (Considine Rebuttal) at Attachment MPC-R-1.

${}^{52}$ ETI Ex. 8 (Morris Direct) at 2.

${}^{53}$ State Agencies Init. Br. at 10.

${}^{54}$ Staff Reply Br. at 9.

${}^{55}$ State Agencies Init. Br. at 10.

${}^{56}$ State Agencies Init. Br. at 12.

${}^{57}$ State Agencies Init. Br. at 9.

${}^{58}$ State Agencies Init. Br. at 13.

${}^{59}$ ETI Reply Br. at 19; ETI Ex. 6 (Considine Supp.) at 8.

${}^{60}$ ETI Reply Br. at 19.

${}^{61}$ State Agencies Init. Br. at 14-15.

${}^{62}$ State Agencies Ex. 15 at. 3.

${}^{63}$ State Agencies Init. Br. at 14.

${}^{64}$ ETI Reply Br. at 20.

${}^{65}$ State Agencies Init. Br. at 16-17.

${}^{66}$ State Agencies Ex. 15 at 4.

${}^{67}$ State Agencies Init. Br. at 16.

${}^{68}$ ETI Reply Br. at 20.

${}^{69}$ State Agencies Ex. 5.

${}^{70}$ State Agencies Exs. 1, 12; State Agencies Reply Br. at Atts. 3, 6.

${}^{71}\mathrm{T}\mathrm{r}$ . at 40 .

${}^{72}$ State Agencies Ex. 17 at 20.

${}^{73}$ OPUC Init. Br. at 1-2.

${}^{74}$ Tr. at 43.

${}^{75}$ ETI Reply Br. at 22.

${}^{76}$ Tr. at 67-68.

${}^{77}$ State Agencies Reply Br. at 11-12.

${}^{78}$ State Agencies Reply Br. at 13-14.

${}^{79}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Proposal for Decision at 236 (July 6, 2012).

${}^{80}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Order on Rehearing at 17-18, 24-25 (November 1, 2012)

${}^{81}$ Staff Reply Br. at 5; see also Staff Init. Br. at 7-10.

${}^{82}$ Staff Init. Br. at 8.

${}^{83}$ State Agencies Init. Br. at 7-8.

${}^{84}$ ETI Init. Br. at 7.

${}^{85}$ ETI Init. Br. at 7; ETI Ex. 12 (Morris Rebuttal) at 5-6.

${}^{86}$ Application of Southwestern Electric Power Company for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 40443, SOAH Order No. 17 (Dec. 13, 2012).

${}^{87}$ The ALJ in the present case was also one of the presiding ALJs in Docket 39896.

${}^{88}$ Staff Reply Br. at 6; OPUC Ex. 3; Open Meeting Tr. at 190 (July 30, 2009).

${}^{89}$ ETI Ex. 10 (Morris Supp. Direct) at 15-16; State Agencies Ex. 3.

${}^{90}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Proposal for Decision at 116 (July 6, 2012).

${}^{91}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Order on Rehearing at 20-21, FOFs 87-94 (November 1, 2012).

${}^{92}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Order on Rehearing at 20, FOF 90 (November 1, 2012).

${}^{93}$ OPUC Init. Br. at 9-10, 12; Staff Init. Br. at 13; State Agencies Reply Br. at 17.

${}^{94}$ Staff Init. Br. at 13.

${}^{95}$ OPUC Ex. 1 (Benedict Direct) at 7-8.

${}^{96}$ ETI Init. Br. at 8 (emphasis in original, footnotes omitted).

${}^{97}$ ETI Reply Br. at 16.

${}^{98}\mathrm{T}\mathrm{r}$ . at $45-46$ .

${}^{99}$ Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Supplemental Preliminary Order at 2 (Jan. 9, 2012).

${}^{100}$ OPUC Init. Br. at 10; Staff Init. Br. at 14 and Reply Br. at 8-9; State Agencies Reply Br. at 17.

${}^{101}$ ETI Reply Br. at 16-17.

${}^{102}$ State Agencies Init. Br. at 1-2.

${}^{103}$ Staff Reply Br. at 13.

${}^{104}$ State Agencies Init. Br. at 1-2.

${}^{105}$ State Agencies Init. Br. at 5.

${}^{106}$ OPUC Init. Br. at 8.

${}^{107}$ Staff Init. Br. at 3; OPUC Init. Br. at 2-3, 7-8.

${}^{108}$ Staff Init. Br. at 4; OPUC Init. Br. at 7.

${}^{109}$ See, e.g., Staff Reply Br. at 13.

${}^{110}$ State Agencies Init. Br. at 3,

${}^{111}$ State Agencies Init. Br. at 3, 22.

${}^{112}$ OPUC Init. Br. at 11.

${}^{113}$ OPUC Init. Br. at 12; Staff Reply Br. at 3. OPUC identifies the reduction factor as $14.5\%$ . However, the ALJ believes this is in error. OPUC witness Benedict testified that the financially-based incentive payments were $\backslash$ 6.2 $millionandthetransmissionequalizationpaymentswere$ \ $9$ million, for a total of $\backslash$ 15.2 $million.Tr.at$ 85-86 $.Bydividing$ \ $15.2$ million by $\backslash$ 104.8 $million,onearrivesatareductionfactorof$ 14.5 \% $.However,theCommissiondisallowed$ \ $6.2$ million in financially-based incentive compensation, plus $\backslash$ 336,000 $ofET{I}^{\prime }scapitalizedfinancially-basedincentivecompensation,foratotalof$ \ $6.5$ million in disallowances related to financially-based incentive payments. Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket 39896, Order on Rehearing at 17-18, 24-25 (November 1, 2012).

${}^{114}$ City of El Paso v. Public Util. Comm'n, 916 S.W.2d 515, 522 (Tex. App.-Austin 1995, writ dism'd by agr.).

${}^{115}$ City of Amarillo v. Railroad Comm'n of Texas, 894 S.W.2d 491, 495 (Tex. App.-Austin 1995, writ den.).

${}^{116}$ City of Port Neches v. Railroad Comm'n of Texas, 212 S.W.3d 565, 581 (Tex. App.-Austin 2006, no pet.)

${}^{117}$ OPUC Init. Br. at 11.

${}^{118}$ City of El Paso, 916 S.W.2d at 522.

${}^{119}$ ETI Ex. 8 (Morris Direct) at 18-19.

${}^{120}$ Staff Init. Br. at 10; ETI Init. Br. at 19-20.

${}^{121}$ ETI Init. Br. at 14.

${}^{122}$ Staff Init. Br. at 10.

${}^{123}$ Staff Init. Br. at 12.

${}^{124}$ Staff Init. Br. at 11.

${}^{125}$ ETI Init. Br. at 17.

${}^{126}$ ETI Init. Br. at 19.

${}^{127}$ Staff Init. Br. at 14.

${}^{128}$ ETI Init. Br. at 18.

${}^{129}$ Staff Init. Br. at 15.

${}^{130}$ ETI Init. Br. at 18.

${}^{131}$ Staff Reply Br. at 12; OPUC Reply Br. at 4-5.

${}^{132}$ Emphasis added.

${}^{133}$ Staff Init. Br. at 17; Staff Ex. 1 (Murphy Direct) at 4-5.

${}^{134}$ Staff Ex. 1 (Murphy Direct) at 5.

${}^{135}$ Staff Ex. 1 (Murphy Direct) at 5.

${}^{136}$ ETI Ex. 7 (Considine Rebuttal) at 5.

${}^{137}$ Staff Init. Br. at 18.

${}^{138}$ ETI Ex. 5 (Considine Rebuttal) at 7.

${}^{139}$ Staff's Init. Br., pp. 5-6.

${}^{140}$ State Agencies' Reply Br., pp. 3, 16.

${}^{141}$ ETI's Reply Br., pp. 23-24.

${}^1$ Ipphication of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Order on Rehearing, Docket No. 39896 (Nov. 2, 2012).

${}^2$ Proposal for Decision at 4-8 (Feb. 19, 2013).

${}^3$ Application of Southwestern Electric Power Company for Rate Case Expenses Pertaining to Docket No. 37364, Order at 1-2, Docket No. 37772 (Oct. 21, 2010).

${}^4$ Proposal for Decision at 29-30.

${}^5\mathrm{I}\mathrm{d}$ . at $32-34$ .

${}^6$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Proposal for Decision at 92-97, Findings of Fact Nos. 164-170, Order at 35 (Aug. 15, 2005); Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309, Proposal for Decision at 116-121, Finding of Fact No. 82, Order on Rehearing at 12 (March 4, 2008); Application of Oncor Electric Delivery Company, LLC, for Authority to Change Rates, Docket No. 35717, Proposal for Decision at 96-100, Finding of Fact No. 93, Order on Rehearing at 22 (Nov. 30, 2009); and Application of CenterPoint Electric Delivery Company, LLC, for Authority to Change Rates, Docket No. 38339, Proposal for Decision at 66-67, Findings of Fact Nos. 81-83, Order on Rehearing at 22 (June 23, 2011).

${}^7$ Docket No. 39896, Order on Rehearing at 5-6, 7-8 (Nov. 2, 2012).

${}^8$ Proposal for Decision at 33-34.

${}^9\mathrm{L}/$ . at $25-27$ .

${}^1$ TCC Ex. 4 at 6-7; TSLC/ROSE Ex. 8 at 2.

${}^2$ TCC Ex. 4 at 5; Application of Central and South West Corporation and American Electric Power Company, Inc. Regarding Proposed Business Combination, Docket No. 19265, Final Order (Nov. 18, 1999).

${}^3$ References in this proposal for decision to the REP will be to "CPL" or "CPL Retail." References in this proposal for decision to the former name of the Applicant will be to "Central Power and Light Co."

${}^{264}$ TCC Ex. 87 at 4. Of this amount, $\backslash$ 3,852,568 $isallocatedtodistributionand$ \ $570,369$ to transmission. Cities Ex. 2 at $25-27$ .

${}^{265}$ TCC Initial Brief at 80.

${}^{266}\mathrm{M}\mathrm{r}$ . Jolley also explained that there was substantial variance in the percentage of incentive compensation to the complete compensation package. The variance depended upon whether the employees were non-exempt (5\%), exempt ( $5-10\%$ ), exempt management ( $25-30\%$ ), or executive level ( $30-100\%$ ). TCC Ex. 87 at 5.

${}^{267}$ Cities Ex. 31 at 121.

${}^{268}$ CCR Ex. 5 at 151.

${}^{269}$ Tr. at 3051.

${}^{270}$ Tr. at 3053; Tr. at 3054.

${}^{271}$ Tr. at 3054; Tr. at 3055.

${}^{272}$ Tr. at 3055.

${}^{273}\mathrm{I}\mathrm{d}$ .

${}^{274}$ CCR Ex. 5 at 151.

${}^{275}\mathrm{T}\mathrm{r}$ . at 3056 .

${}^{276}\mathrm{I}\mathrm{d}$ .

${}^{277}\mathrm{T}\mathrm{r}$ . at 3058 .

${}^{278}\mathrm{T}\mathrm{r}$ . at 3059 .

${}^{279}\mathrm{T}\mathrm{r}$ . at 3065 . One could argue that each employee's performance affects the performance of the company as a whole.

${}^{280}$ Tr. at 3048 .

${}^{281}$ Tr. at 3049 .

${}^{282}$ PURA § 36.062 .

${}^{283}$ P.U.C. SUNST. R. 25.231(b)

${}^{284}$ CCR Initial Brief at 25. See, U.S. West Communications, Inc. v. Public Service Comm'n, 901 P.2d 270, 276-77 (Utah 1995); Central Illinois Public Service Company Proposed General Increase In Natural Gas Rates, Docket No. 02-0798 (Cons.), 2003 III. PUC LEXIS 824, p. 115 (Illinois Commerce Comm'n 2003); Application of Wisconsin Power and Light Company as an Electric, Natural Gas and Water Utility for Authority to Change Electric, Natural Gas, and Water Rates, Docket No. 6680-UR-113, 2003 Wisc. PUC LEXIS 822, pp. 40-41 (Wisconsin Public Service Comm'n 2003); Petition of Northern States Power Company's Gas Utility for Authority to Change its Schedule of Gas Rates for Retail Customers Within the State of Minnesota, 146 P.U.R.4th 1, pp. 40-43 (Minnesota Public Util. Comm'n 1993); Application of Minnegasco, a Division of NorAm Energy Corp., for Authority to Increase its Natural Gas Rates in Minnesota, 170 P.U.R.4th 193, pp. 69-77 (Minnesota Public Util. Comm'n 1996).

${}^{285}$ CCR Initial Brief at 26.

${}^{286}$ Cities Reply Brief at 46.

${}^{287}$ Applicant's Initial Brief at 81.

${}^{288}$ Tr. at 271; TCC Ex. 2.1, Schedule II-D-2, Attachment at 3. 289 "Plan years" appear to coincide with calendar years. See, TCC Ex. 20 at 11.

${}^1$ During the hearing the parties used the term "Rate Year" to refer to the period June 2012 through May 2013. This was intended to represent the first 12 months of the rates adopted in this case. However, the rates in this case will not go into effect (as temporary rates) until at least June 30, 2012. Nevertheless, for purposes of this PFD, Rate Year will refer to the period June 2012 through May 2013.

${}^{567}$ Id. at 34 .

${}^{568}$ Id. at MPC-R-5, and MPC-R-6.

${}^{569}$ See, e.g., TIEC Initial Brief at 51-52; see also AEP Application of AEP Texas Central Company for Authority to Change Rates, See Docket No. 33309, Order on Rehearing at FoF 82 (Mar. 4, 2007); Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Order at FoF 164-170 (Aug. 15, 2005).

${}^{570}\mathrm{T}\mathrm{r}$ . at 1726 .

${}^{571}$ ETI Initial Brief at 129 .

${}^{572}$ ETI Ex. 36 (Gardner Direct) at 31.

${}^{573}\mathrm{I}\mathrm{d}$ . at 32 .

${}^{574}$ ETI Ex. 15 (Hartzell Direct) at 3-4, 6, and 9-10.

${}^{575}\mathrm{I}\mathrm{d}$ . at 7 .

${}^{576}$ Id. at 13-14.

${}^{577}$ ETI Ex. 15 (Hartzell Direct) at 15-21.

${}^{578}\mathrm{I}\mathrm{d}$ . at $22-25$ .

${}^{379}$ TIEC Reply Brief at 35; State Agencies Initial Brief at 14; OPC Reply Brief at 12; Staff Initial Brief at 56; Cities Initial Brief at 67; see also, Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309, Order on Rehearing at FoF 82 (Mar. 4, 2007); Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Order at FoF 164-170 (Aug. 15, 2005).

${}^{580}$ Staff Reply Brief at 44, quoting Application of Oncor Electric Delivery Company for Authority to Change Rates, Docket No. 35717, Order on Rehearing at FoF 92 (Nov. 30, 2009).

${}^{581}$ Cities Ex. 2 (Garrett Direct) at 29-30

${}^{582}$ Id. at 32-38.

${}^{583}$ Id. at 45-46.

${}^{584}$ ETI Ex. 15 (Hartzell Direct) at 7 (emphasis added).

${}^{585}$ See, e.g., ETI Ex. 15 (Hartzell Direct) at 13.

${}^{586}\mathrm{T}\mathrm{r}$ . at 484.

${}^{587}\mathrm{T}\mathrm{r}$ . at 478 .

${}^{588}\mathrm{T}\mathrm{r}$ . at 480 .

${}^{589}\mathrm{T}\mathrm{r}$ . at 481-82.

590 Staff Initial Brief at 56. (As discussed more below, Staff's original estimate was roughly $\backslash$ 5.6$ million. The estimate was reduced, however, in response to supplemental payroll tax information supplied to Staff by ETI.) 591 TIEC Initial Brief at 53-54. 592 Cities Initial Brief at 70. 593 ETI Ex. 36 (Gardner Direct) at 30.

${}^{594}$ ETI Ex. 46 (Considine Rebuttal).

${}^{595}$ Staff Ex. 1 (Givens Direct) at 15-22; Staff Initial Brief at 56-63.

${}^{596}$ ETI Ex. 36 (Gardner Direct) at 30 and KGG-4.

${}^{597}$ TIEC Ex. 1 (Pollock Direct) at 41-45 and JP-7; TIEC Initial Brief at 51-54.

${}^{598}$ ETI Ex. 36 (Gardner Direct) at 30 and KGG-4.

${}^{599}$ Cities Ex. 2 (Garrett Direct) at 39-40, 46-50, MG2.10.

${}^{600}$ Cities Initial Brief at 68, Application of AEP Texas Central Company for Authority to Change Rages, Docket No. 28840, Final Order (August 15, 2005).

${}^{601}$ Cities Ex. 1 (Garrett Direct) at 51-52 and MG2.10; Cities Initial Brief at 70.

${}^{602}$ Cities Ex. 1 (Garrett Direct) at 53.

${}^{603}\mathrm{T}\mathrm{r}$ . at 1528 .

${}^{604}$ ETI Ex. 50 (Gardner Rebuttal) at 6-7, ETI Initial Brief at 137-38.

${}^{605}$ Cities Ex. 2 (Garrett Direct) at 25, MG2.8, and MG2.9.

${}^{606}$ Id.

${}^{607}$ Id. at 25 and MG2.8.

${}^1$ Supplemental Preliminary Order at 2, 3 (Jan. 19, 2012).

${}^2$ Letter from SOAH judges to PUC (Aug. 8, 2012).

${}^{23}$ PFD at 108-09.

${}^{24}$ Id. at 109 .

${}^{25}\mathrm{I}\mathrm{d}$ .

${}^{26}$ Entergy's Exceptions to the Proposal for Decision at 51.

${}^{27}$ PFD at 175 .

${}^{28}$ Id. at 175-76.

${}^{29}$ See Commission Number Run-Memorandum at 3 (Aug. 28, 2012).

${}^{30}$ Direct Testimony of Carol Szerszen, OPUC Ex. 1 at 44-45.

${}^{31}$ Application of Central Power and Light Company for Authority to Change Rates, Docket No. 14965, Second Order on Rehearing at 87, COL 29 (Oct. 16, 1997).

${}^{32}$ Direct Testimony of Carol Szerszen, OPUC Ex. 1 at Schedule CAS-7.

${}^1$ Rebuttal Testimony of Jennifer L. Jackson, SWEPCO Ex. 88, JLJ-1R at 2.

${}^1$ Petition by Commission Staff for a Review of CenterPoint Energy Houston Electric, LLC Pursuant to PURA § 36.151, Docket No. 32093, Order (Sept. 5, 2006).

257 Id. at 9. 258 CEHE Ex. 28 (Fitzgerald Direct) at 14. 259 Staff Ex. 8 (Jacobs Direct) at 9. 260 Id. at 7; GCCC Ex. 1B (Errata to Kollen Direct) at 54. 261 Id. at 22-24, 26-29.

262 Id. at 23 and 28. 263 OPC Ex. 3 (Dively Direct) at 15; GCCC Ex. 1 (Kollen Direct) at 54; Staff Ex. 8 (Jacobs Direct) at 7-8. 264 CEHE Ex. 23 (Woods Direct) at 27. 265 Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Findings of Fact Nos. 164-170, Order at 35 (Aug. 15, 2005).

${}^{266}$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Proposal for Decision at 78 (July 2, 2004).

${}^{267}$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Findings of Fact Nos. 169-170, Order at 35 (Aug. 15, 2005). The Commission determined that operational measures such as reliability and safety "are of more immediate benefit to ratepayers" and thus qualify as "necessary and reasonable to provide T&;D service."

${}^{268}$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309, Finding of Fact No. 82, Order on Rehearing at 12 (Mar. 14, 2008).

${}^{269}$ Application of Oncor Electric Delivery Company, LLC, for Authority to Change Rates, Docket No. 35717, Finding of Fact No. 93, Order on Rehearing at 22 (Nov. 30, 2009).

${}^{270}$ CEHE Ex. 65 (Woods Rebuttal) at 12 (citing the Final Order in GUD No. 9902 at Finding of Fact No. 63).

${}^{271}$ CEHE Ex. 23 (Woods Direct) at 24.

${}^{272}$ Id. at Ex. CDW-5.

${}^{273}$ CEHE Reply Brief at 32-33.

${}^1$ Proposal for Decision (PFD), Attachment ALJ-3 at 1, line 10, column 2 "Difference between ALJs' Rec. and CNP, current revenues." (Dec. 3, 2010).

${}^2$ Revised Number Runs and Associated Workpapers, Attachment Comm-3 AFTER Postage Stamp Update, at 1, line 10, column 2 (Feb. 18, 2011).

${}^1$ Public Utility Regulatory Act, TEX. UTIL. CODE ANN. §§ 11.001 - 64.158 (Vernon Supp. 2007) (PURA).

${}^2$ TCC Ex. 78, RWH-1R.

${}^3$ See Application of Central and Southwest Corporation and American Electric Power Company, Inc. Regarding Proposed Business Combination, Docket No. 19365, Integrated Stipulation and Agreement (Nov. 18, 1999).

${}^4$ AEP Central Company's Exceptions to the Proposal for Decision and Request for Number Running Corrections, Attachment E at 87-91(Sept. 20, 2007).

${}^1$ TCC Cities that intervened in TCC's previous rate case proceeding, Docket No. 33309, include: Alamo, Alice, Alton, Asherton, Bay City, Bayview, Beeville, Big Wells, Bishop, Brackettville, Brownsville, Carrizo Springs, Charlotte, Combes, Corpus Christi, Crystal City, Del Rio, Devine, Dilley, Donna, Eagle Lake, Eagle Pass, Edinburg, Edna, El Campo, Freer, Ganado, George West, Goliad, Harlingen, Hidalgo, Ingleside, Engleside on the Bay, Karnes City, Kenedy, Kingsville, La Feria, La Joya, Laguna Vista, Laredo, Los Fresnos, Los Indios, Lyford, Lytle, Mathis, McAllen, Mercedes, Mission, Nordheim, Odem, Orange Grove, Palm Valley, Penitas, Pharr, Pleasanton, Point Comfort, Port Aransas, Port Isabel, Portland, Port Lavaca, Poteet, Primera, Rancho Viejo, Raymondville, Refugio, Rio Grande City, Rio Hondo, Rockport, Roma-Los Saenz, Runge, Sabinal, San Benito, San Juan, Santa Rosa, Sinton, Smiley, South Padre Island, Sullivan City, Taft, Uvalde, Victoria, Weslaco, and Woodsboro.

${}^2$ TNC Cities that intervened in TNC's previous rate case proceeding, Docket No. 33310, include: Abilene, Cisco, San Angelo, Sonora, Vernon, and Wellington.

${}^3$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309, Order on Rehearing (Mar. 4, 2008); Application of AEP Texas North Company for Authority to Change Rates, Docket No. 33310, Order (May 29, 2007).

${}^4$ The other proceedings referenced include: Application of Central Power and Light Company for Authority to Reconcile Fuel Costs, Docket No. 27035; Proceeding to Consider Rate Case Expenses Severed from Docket No. 28840 (Application of AEP Texas Central Company for Authority to Change Rates), Docket No. 31433; Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840; Application of AEP Texas Central Company and CPL Retail Energy, LP to Determine True-Up Balances Pursuant to PURA § 39.262 and Petition to Determine Amount of Excess Mitigation Credits to Be Refunded and Recovered, Docket No. 31056; and Application of AEP Texas Central Company for a Competition Transition Charge Pursuant to PUC Subst. R. 25.263(n), Docket No. 32758.

${}^1$ Alice, Aransas Pass, Carrizo Springs, Dilley, Donna, Eagle Lake, Freer, Ganado, George West, Ingleside, Kingsville, LaFeria, Laguna Vista, La Joya, Leakey, Los Fresnos, Lyford, Lytle, McAllen, Mercedes, Mission, Nordheim, Odem, Pharr, Port Aransas, Portland, Port Lavaca, Poteet, Rancho Viejo, Refugio, Rio Hondo, Runge, San Benito, San Juan, Sinton, Uvalde, and Weslaco (collectively, Cities).

${}^2$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Order (Aug. 15,2005 ).

${}^3$ Docket No. 28840, Proposal for Decision at 121-127, 205 (FOF 210-216), 209 (FOF 256) (Jul. 1, 2004).

${}^1$ This results in a recommended disallowance ranging from $\backslash$ 1,269,123 $to$ \ $6,441,896$ .

${}^2$ Docket No. 39896, Schedule P-5 at 41-42.

${}^3$ Compliance Tariff of AEP Texas Central Company Pursuant to Final Order in Docket No. 31433 Severed from Docket No. 28840, Docket No. 32385, Compliance Rider, Attachment B at 3.

${}^4$ Supplemental Direct Testimony of Michael P. Considine, Exhibit MPC-SD-5 at 1 (October 25, 2012).

${}^5$ Aside from base rate cases, ETI can also update its EECRF and TCRF on an annual basis, and may soon have a PCRF mechanism available to it.

${}^6$ Docket No. 39896, ETI's Letter to Commissioners Regarding Corrections to Commission's Final Order in Docket No. 39896.

${}^7$ The $\backslash$ 8.75 $millionfiguredoesnotincludeGitie{s}^{\prime }ratecaseexpensesofapproximately$ \ $1.2$ million.

${}^8$ The rider appeared on bills during 2009, 2010, and 2011.

${}^9$ Application of Entergy Gulf States, Inc. for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 34800, Order at 5, (Findings of Fact Nos. 24 and 27) (March 16, 2009).

${}^{10}$ Application of Entergy Texas, Inc. for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 37744, Order at 5, (Findings of Fact Nos. 16 and 18) (December 13, 2010).

${}^{11}$ Docket No. 39896, Proposal for Decision at 166.

${}^{12}$ Docket No. 39896, Order at 24-25, (Findings of Fact Nos. 127-134) (September 14, 2012).

${}^{13}$ Docket No. 39896, Proposal for Decision at 116.

${}^{14}$ Docket No. 39896, Order at 20, (Findings of Fact Nos. 87 - 94) (September 14, 2012).

${}^{15}$ Docket No. 39896, Supplemental Preliminary Order at 2 (January 19, 2012).

${}^1$ Alice, Aransas Pass, Carrizo Springs, Dilley, Donna, Eagle Lake, Freer, Ganado, George West, Ingleside, Kingsville, LaFeria, Laguna Vista, La Joya, Leakey, Los Fresnos, Lyford, Lytle, McAllen, Mercedes, Mission, Nordheim, Odem, Pharr, Port Aransas, Portland, Port Lavaca, Poteet, Rancho Viejo, Refugio, Rio Hondo, Runge, San Benito, San Juan, Sinton, Uvalde, and Weslaco (collectively, Cities).

${}^2$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Order (Aug. 15, 2005).

${}^3$ Docket No. 28840, Proposal for Decision at 121-127, 205 (FOF 210-216), 209 (FOF 256) (Jul. 1, 2004).

${}^4$ Docket No. 28840, Order at 60 (Ordering 95 ) (Aug. 15, 2005).

${}^5$ Open Meeting Tr. at 54-62 (July 29, 2005).

${}^6$ See Docket No. 28840, Proposal for Decision at 121-127, 205 (FOF 212) (Jul. 1, 2004).

${}^7$ Id. at 125 .

${}^8$ See Open Meeting Tr. at 62 (Jul. 29, 2005).

${}^9$ Open Meeting Tr. at 196-198 (January 13, 2005).

${}^{10}$ Docket No. 28840, Proposal for Decision at 125 (Jul. 1, 2004).

${}^{11}$ Application of CenterPoint Energy Houston Electric, LLC for a Competition Transition Charge, Docket No. 30706, Order at 28-29, 47 (COL 28) (Jul. 14, 2005).

${}^1$ The Rate Case Expense allocated to Retail Customers is $64.63\%$ of the total approved rate case expenses in Docket No. 31433 (severed from Docket No. 28840). The Rate Case Expense allocated to Wholesale Transmission Customers is $35.37\%$ of the total approved rate case expense in Docket No. 31433.

${}^1$ Application of Entergy Texas, Inc. for Authority to Implement New Rough Production Cost Equalization Adjustment (RPCEA) Rate.

convenience and necessity for its Texas retail jurisdiction. For continuity and ease of reference, EGSI, Commission Staff, and intervenors have continued to make reference to EGSI for purposes of pleadings in this docket.

${}^2$ OPC, ARM, Cities, Kroger Company, Stale, and TIEC were granted party status on October 22, 2007. See Prehearing Conference Tr. at 6.

${}^3$ The EGSI NUS was subsequently amended on June 27, 2008.

${}^4$ EGSI letter filed February 18, 2009.

${}^5$ Application of Entergy Texas, Inc. for Approval of an Energy Efficiency Cost Recovery Factor (EECRF) Pursuant to PURA § 39.905(b) and P.U.C. Subst. R. 25.181(f), Docket No. 35626, Order (Aug. 14, 2008).

${}^1$ Steering Committee of Cities is comprised of the Cities of Anahuac, Beaumont, Bridge City, Cleveland, Conroe, Groves, Houston, Huntsville, Montgomery, Navasota, Nederland, Oak Ridge North, Orange, Pine Forest, Pinehurst, Port Arthur, Port Neches, Rose City, Shenandoah, Silsbee, Sour Lake, Splendora, Vidor, and West Orange.

${}^2$ Application of Entergy Texas, Inc. for Approval of Competitive Generation Service Tariff (Issues Severed From Docket No. 37744), Docket No. 38951.

${}^3$ Application of Entergy Texas, Inc. for Rate Case Expenses Severed from PUC Docket No. 37744, Docket No. 38346 .

${}^5$ Application of Entergy Texas, Inc. to Implement an Interim Fuel Refund, Docket No. 38403, Order (Sept. 16, 2010).

${}^6$ Compliance Filing of Entergy Texas, Inc. Regarding Jurisdictional Allocation of 2007 System Agreement Payments, Docket No. 35269, Order (Jan. 7, 2009).

${}^7$ Application of Entergy Texas, Inc. for Authority to Implement New RPCEA Rate, Docket No. 38098, Order (July 1, 2010).

${}^1$ Application at 5 (Nov. 28, 2011).

${}^2$ Public Utility Regulatory Act, Tex. Util. Code Ann. §§ 11.001-66.016 (Vernon 2007 &; Supp. 2011) (PURA).

${}^1$ Murphy Direct at 4.

${}^2\mathrm{I}\mathrm{d}$ . at 5 .

${}^3$ Requests for Rate Case Expenses Severed From Docket No. 38339 (Application of CenterPoint Energy Houston Electric, LLC for Authority to Change Rates), Docket No. 39127, Order, Finding of Fact 26 (Jun. 6, 2011).

${}^4$ Moreover, on pages 43-44 of her direct testimony in Docket. No. 39896, Company witness Tumminello provided a detailed description of the controls and review process in affiliate billing that ensure actual costs are reflected, and the Commission disallowed no costs due to duplicative charges.

${}^5$ In Docket No. 16705, all of Entergy Services, Inc.'s affiliate charges to EGSI were disallowed.

${}^6$ A copy of Mr. Tucker's resume is attached to the rebuttal testimony of Stephen F. Morris as Exhibit SFM-R-2.

${}^7$ ETI's Response to Staff RFI 9-1, Addendum 3 is cumulative and includes the original response to Staff RFI 9-1, Addendum 1, Addendum 2, and Addendum 3. The roadmap spreadsheet was first included in Addendum 1 and was then entitled "Guide to Internal Rate Case Expense Invoices." The same spreadsheet was updated in Addendum 2 and retitled "Roadmap to Internal Rate Case Expenses" to more accurately reflect its purpose and contents. Again, every document and piece of detail provided by the Company in response to Staff RFI 9-1 was cumulatively included in Addendum 3, which State Agencies cites as lacking sufficient detail, including the original and updated version of the roadmap spreadsheet.

1 ESI is a subsidiary of Entergy Corporation that provides technical and administrative services to all the Entergy Operating Companies ("EOCs").

2 The EOCs are ETI; Entergy Arkansas, Inc.; Entergy Gulf States Louisiana, L.L.C.; Entergy Louisiana, LLC; Entergy Mississippi, Inc.; and Entergy New Orleans, Inc.

3 I use the name "the Entergy Companies" to mean Entergy Corporation and its subsidiaries including ESI, ETI, and the other EOCs. Each of these subsidiaries is a separate legal entity. All of the Entergy Companies employ the same approach to compensation and benefits that I describe in this testimony.

4 Exempt employees are employees who are paid a salary and are exempt from the overtime provisions under the federal wage and hour law.

9 Developed from Towers Watson's 2010 Executive Compensation Database - General Industry (companies with revenue between $\backslash$ 10 $and$ \ $20$ billion) and Towers Watson 2010 Executive Compensation Database - Energy Services Industry (companies with revenue greater than $\backslash$ 6$ billion). "Entergy at Target" developed by averaging targets for all incumbents in Management Level 6 (Middle Managers), Management Level 5 (Directors) and Management Level 1 thru 4 (Executives).

${}^{10}$ As with my discussion of the compensation programs, although I may describe the benefit plans using the present tense, my testimony describes the offerings and practices during the Test Year.

11 Please see Exhibit KGG-5 for the Towers Watson 2011 BenVal Report showing the prevalence of benefit programs among companies in the utility industry. In addition,

12 Please see Exhibit KGG-5, p.4, showing the prevalence of paid time off policies.

13 The value of the Entergy Companies' vacation policy versus the peer group was $93\%$ and for the holiday policy was $85\%$ . The combined value of the vacation and holiday policies was $90\%$ . The value of the Entergy Companies' vacation policy versus the Fortune 500 group was $94\%$ and for the holiday policy was $93\%$ . The combined value of the vacation and holiday policies was $93\%$ .

14 As explained previously, of the $\backslash$ 9,365,982 $thatistheTotalETIAdjustedAmountfortheHRClass,$ \ $1,229,121$ is related to the seven HR sub-functions I listed in Table 14.

*Rehires are also eligible if they were previously employed by Entergy as a regular active employee for a minimum of 3 months during plan year (months do not need to be worked consecutively)

1 Further, as I indicated on page 23 of my direct testimony, some compensation consultants would even use a $+/-15$ percent range for pay levels. At this point, the Entergy Companies continue to target $+/-10$ percent in establishing compensation levels.

2 Nowhere did I purport to identify a "peer group of Fortune 500 companies."

3 Company witness Tumminello identifies $\backslash$ 112,531$ of these ESI costs that should not have been charged to ETI.

4 Company witness Tumminello identifies $\backslash$ 112,531$ of these costs that should not have been charged to ETI.

1 Staff witness Givens also recommends a disallowance related to certain executive perquisites; the Company is not opposing that adjustment.

1 For example, see PUCT Docket No. 28840, PFD at 78. 2 For example, see PUCT Docket No. 35717, PFD at 98.

3 Aswath Damodaran, Investment Valuation (John Wiley &; Sons, 2d ed. 2002).

4 Chris Parsons and Sheridan Titman, Capital Structure and Corporate Strategy (January 2007). The article is available at http://ssrn.com/abstract=983553.

5 See http://investor.shareholder.com/entergy/releasesdetail.cfm?ReleaseID=337564

6 Christopher D. Ittner and David F. Larcker, Are Nonfinancial Measures Leading Indicators of Financial Performance? An Analysis of Customer Satisfaction, 36 JOURNAL OF ACCOUNTING RESEARCH, Supplement 1998 at $1-35$ .

8 For example, see M.P. Narayanan, Form of Compensation and Managerial Decision Horizon, 31 JOURNAL OF FINANCIAL AND QUANTITATIVE ANALYSIS, 4 at 467-491 (1996).

10 See M.P. Narayanan, Form of Compensation and Managerial Decision Horizon, 31 JOURNAL OF FinANCIAL AND Quantitative ANALYSIS, 4 at 467-491 (1996).

11 Christopher D. Ittner and David F. Larcker, Are Nonfinancial Measures Leading Indicators of Financial Performance? An Analysis of Customer Satisfaction, 36 JOURNAL OF ACCOUNTING RESEARCH, Supplement 1998 at 1 - 35.

12 Alka Arora and Pervaiz Alam, CEO Compensation and Stakeholders' Claims, 22 CONTEMPORARY ACCOUNTING RESEARCH, 3 at 519-547 (Fall 2005). 13 M.M. Petty, Bart Singleton, and David W. Connell, An Experimental Evaluation of an Organizational Incentive Plan in the Electric Utility Industry, 77 JOURNAL OF APPLIED PSYCHOLOGY, 4 at 427-436 (1992).

1 See Application of Oncor Electric Delivery Company for Authority to Change Rates, Docket No. 35717, Proposal for Decision at 100 (Jun 2, 2009) (stating that, despite the fact that incentive compensation plans are conditional by nature, the Commission has allowed recovery based on operational measures) and Order on Rehearing Findings of Fact 91-93 and Ordering Paragraph 1 (Nov. 30, 2009) (adopting the PFD to the degree consistent with the order on rehearing).

${}^2$ See pages 39-40 of Mr. Pollock's deposition, dated April 9, 2012.

3 Intuitively, this is the value because one could invest $\backslash$ 10 $ata10percentrateofreturnandgeneratetheequivalent$ \ $1$ per year, forever. 4 This is calculated as $1/1.1+1/\left({1.1}^{\wedge }2\right)+1/\left({1.1}^{\wedge }3\right)=2.49$ , and $10-2.49=7.51$ .

Commission Staff's Recommendation at 1. 2 Direct Testimony of Nathan A. Benedict (OPUC) at 7-8; State Agencies' Recommendations at 4. 3 Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting Treatment, Docket No. 39896, Final Order at 5. 4 See e.g., Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 28840, Proposal for Decision at 93 and Final Order at 35 (Finding of Fact 167).

5 Direct Testimony of Dr. Jay C. Hartzell at 11 and 24 (though nearly all of Dr. Hartzell's testimony addresses the benefits of cost control-based incentive compensation in tandem with other types of incentive compensation). 6 See e.g., Application of Southwestern Electric Power Company for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 40443, Direct Testimony of Andrew R. Carlin at 5; Application of El Paso Electric Company to Change Rates, to Reconcile Fuel Costs, to Establish Formula-Based Fuel Factors, and to Establish an Energy Efficiency Cost Recovery Factor, Docket No. 37690, Direct Testimony of Michael D. Feuerbacher at 5, Order (July 30, 2010); Application of Southwestern Electric Power Company for Authority to Change Rates, Docket No. 37364, Direct Testimony of David A. Jolley at 13-30, Order (Apr. 16, 2010); Application of Southwestern Public Service Company Authority to Change Rates, to Reconcile Fuel and Purchased Power Costs for 2006 and 2007 and to Provide a Credit for Fuel Cost Savings, Docket No. 35783, Direct Testimony of Marvin E. McDaniel, Jr. at 12, Order (June 2, 2009); Application of Oncor Electric Delivery Company, LLC for Authority to Change Rates, Docket No. 35717, Direct Testimony of James A. Greer at 43-44, Final Order (Aug. 31, 2009); Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309, Direct Testimony of David A. Jolley at 12, Order (Dec. 13, 2007).

See Exhibit SFM-R-1. 8 Direct Testimony of Nathan A. Benedict (OPUC) at 8-9.

9 Final Order at 20.

11 Texas Industrial Energy Consumers' Response to Order Requesting Briefing on Threshold Legal/Policy Issues at 2; State Agencies' Brief on Threshold Legal/Policy Issues at 2. 12 Commission Staff's Brief on Threshold Legal and Policy Issues at 1. 13 Direct Testimony of Nathan A. Benedict (OPUC) at 10-11.

14 Id. at 10 .

15 State Agencies' Recommendations at 1-3. 16 Id. 17 As discussed in the rebuttal testimony of Michael Considine, it is ironic that State Agencies would recommend a global disallowance of rate case expenses, in part, based on a generalized complaint regarding the frequency of traditional base rate cases, while consistently taking positions against ETI proposals that would lessen the need for such cases (e.g., formula rates, rate riders, and PTYAs). State Agencies routinely cites the benefits of the traditional, comprehensive base rate approach to ratemaking as a reason to reject ETI's proposals to streamline the ratemaking process. Application of Entergy Texas, Inc. for Authority to Change Rates, Reconcile Fuel Costs, and Obtain Deferred Accounting

Treatment, Docket No. 39896, Direct Testimony of Kit Pevoto at 4-5 (Mar. 27, 2012); Application of Entergy Texas, Inc. for Authority to Change Rates and Reconcile Fuel Costs, Docket No. 37744, Direct Testimony of Kit Pevoto at 5 and 30 (June 9, 2010); Application of Entergy Gulf States, Inc. for Authority to Change Rates and to Reconcile Fuel Costs, Docket No. 34800, Direct Testimony of Kit Pevoto at 6 and 15-16 (Apr. 11, 2008). 18 State Agencies' Recommendations at 1-3.

19 State Agencies' Recommendations at 3-6. 20 State Agencies' Recommendations at 4.

${}^{24}$ Exhibit SFM-R-2 (Resume of Gerald Tucker).

${}^{25}$ Exhibit SFM-R-3.

1 This is distinct from the intra-system bill invoicing process discussed by Company witness Patrick J. Cicio.

2 Each of these subsidiaries is a separate legal entity. 3 I use the name "Entergy" or "Entergy Companies" to mean, collectively, Entergy Corporation and its direct and indirect subsidiaries. Each of these subsidiaries is a separate legal entity. The Entergy Operating Companies ("Operating Companies") are: ETI; Entergy Arkansas, Inc. ("EAI" or "Entergy Arkansas"); Entergy Gulf States Louisiana, L.L.C. ("EGSL," "EGSLA," or "Entergy Gulf States Louisiana"); Entergy Louisiana, LLC ("ELL" or "Entergy Louisiana"); Entergy Mississippi, Inc. ("EMI" or "Entergy Mississippi"); and Entergy New Orleans, Inc. ("ENOI" or "Entergy New Orleans"). 4 See Exhibit SBT-2 for a discussion of the regulation of Entergy Corporation's subsidiaries.

5 Entergy's regulated affiliates include the Operating Companies as well as System Fuels, Inc. ("SFI" or "System Fuels"); EOI; ESI; System Energy Resources, Inc. ("SERI" or "System Energy"); and Entergy New Nuclear Utility Development, LLC. 6 Schedule G-6 is a section within the Public Utility Commission of Texas' ("Commission's") Rate Filing Package ("RFP"). It includes a summary of test year affiliate transactions.

16 American Institute of Certified Public Accountants (AICPA); Accounting Trends &; Techniques - 2010.

${}^1$ Supplemental Preliminary Order at 2, 3 (Jan. 19, 2012).

${}^2$ Letter from SOAH judges to PUC (Aug. 8, 2012).

${}^3$ Proposal for Decision at 23 (July 6, 2012) (PFD).

${}^4$ PFD at 23-24.

${}^5$ Application of AEP Texas Central Company for Authority to Change Rates, Docket No. 33309, Order on Rehearing (March 4, 2008).

${}^6$ Remand of Docket No. 33309 (Application of AEP Texas Central Company for Authority to Change Rates), Docket No. 38772, Order on Remand (Jan. 20, 2011).

${}^7$ PFD at 26.

${}^8\mathrm{d}$ . at $24-26$ .

${}^9$ PFD at 26-27 (citing Rebuttal Testimony of Roberts, Entergy Ex. 64 at 6), 29 (citing Rebuttal Testimony of Roberts, Entergy Ex. 64 at 8).

${}^{10}$ PFD at 29.

${}^{11}\mathrm{I}\mathrm{d}$ . at 29.

${}^{12}$ Application of CenterPoint Electric Delivery Company, LLC for Authority to Change Rates, Docket No. 38339, Order on Rehearing at 3-4 (June 23, 2011).

${}^{13}$ PFD at 171 .

${}^{14}\mathrm{I}\mathrm{d}$ . at 72 .

${}^{15}$ Id. at 174; see also Entergy's Exceptions to the Proposal for Decision at 25-26 (July 23, 2012).

${}^{16}$ Entergy's Exceptions to the Proposal for Decision at 25-26.

${}^{17}$ Id. at $25-26$ .

${}^{18}$ Commission Number-Run Memorandum at 2 (Aug. 28, 2012).

${}^{19}$ PFD at 94.

${}^{20}/d$ .

${}^{21}/d$ . at 94 .

${}^{22}$ PURA §§ 36.051, .052.

${}^{23}$ PFD at 108-09.

${}^{24}\mathrm{J}/$ at 109 .

${}^{25}\mathrm{J}/$ .

${}^{26}$ Entergy's Exceptions to the Proposal for Decision at 51.

${}^{27}$ PFD at 175 .

${}^{28}\mathrm{J}/$ . at $175-76$ .

${}^{29}$ See Commission Number Run-Memorandum at 3 (Aug. 28, 2012).

${}^{30}$ Direct Testimony of Carol Szerszen, OPUC Ex. 1 at 44-45.

${}^{31}$ Application of Central Power and Light Company for Authority to Change Rates, Docket No. 14965, Second Order on Rehearing at 87, COL 29 (Oct. 16, 1997).

${}^{32}$ Direct Testimony of Carol Szerszen, OPUC Ex. 1 at Schedule CAS-7.

${}^{33}$ Cities' Exceptions to the Proposal for Decision at 20-21 (July 23, 2012).

${}^{34}$ PFD at 327-328.

${}^{37}$ Application of Central Power and Light Company for Authority to Change Rates, Docket No. 14965, Second Order on Rehearing (Oct. 16, 1997).

Case Details

Case Name: Entergy Texas, Inc. v. Public Utility Commission of Texas, Office of Public Utility Counsel, and State of Texas Agencies and Institutions of Higher Education

Court Name: Court of Appeals of Texas

Date Published: Feb 6, 2015

Docket Number: 03-14-00706-CV

Court Abbreviation: Tex. App.