HEATHER 6. HARLAN ATTORNEY AT LAW PO BOX 1791 CHARLESTON, WV 25326 CHARLESTON OFFICE (304) 344-5800 DIRECT DIAL (304) 347-8323 FACSIMILE (304) 344-9566 E-MAIL hghiprnlan corn October 10,20 1 8 BY HAND DELIVERY Ingrid Ferrell, Executive Secretary Public Service Commission of West Virginia 201 Brooks Street Charleston. WV 25301 RE: Appalachian Power Company and Wheeling Power Company Application to Change Depreciation Rates Case No. 18-0645-E-0 Rule 42T Application to Increase Rates and Charges Case No. 18-0646-E-42T Dear Ms. Ferrell: I enclose herewith the Commission’s copy of the responses of Appalachian Power Company and Wheeling Power Company (collectively “the Companies”) to CAD’S sixth set of requests for information, Questions B-36, C-29, D-8, D-9, D-10, and E-44, in the above- referenced proceeding. Very truly yours, Heather G. Harlan (W.Va. State Bar #2943) [email protected]Counsel for Appalachian Power Company and Wheeling Power Company HGH:sr Enclosures cc: Service List
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HEATHER 6. HARLAN ATTORNEY AT LAW
P O BOX 1791 CHARLESTON, WV 25326
CHARLESTON OFFICE (304) 344-5800 DIRECT DIAL (304) 347-8323
FACSIMILE (304) 344-9566 E-MAIL hghiprnlan corn
October 10,20 1 8
BY HAND DELIVERY Ingrid Ferrell, Executive Secretary Public Service Commission of West Virginia 201 Brooks Street Charleston. WV 25301
RE: Appalachian Power Company and Wheeling Power Company Application to Change Depreciation Rates Case No. 18-0645-E-0 Rule 42T Application to Increase Rates and Charges Case No. 18-0646-E-42T
Dear Ms. Ferrell:
I enclose herewith the Commission’s copy of the responses of Appalachian Power Company and Wheeling Power Company (collectively “the Companies”) to CAD’S sixth set of requests for information, Questions B-36, C-29, D-8, D-9, D-10, and E-44, in the above- referenced proceeding.
CASE NO. 18-0645-E-D APPALACHIAN POWER COMPANY and WHEELING POWER COMPANY, public utilities.
Application to Change Depreciation Rates.
CASE NO. 18-0646-E-42T APPALACHIAN POWER COMPANY and WHEELING POWER COMPANY, public utilities.
Rule 42 application to increase rates and charges.
CERTIFICATE OF SERVICE
I, Heather G. Harlan, counsel for Appalachian Power Company and Wheeling Power
Company, do hereby certify that true copies of the foregoing discovery responses were served by
hand delivery or U.S. mail on this loth day of October, 2018, addressed to the following:
Wendy Braswell, Esquire Linda Bouvette, Esquire Public Service Commission 201 Brooks Street Charleston, West Virginia 25301 Counsel for Staff of West Virginia Charleston, West Virginia 25301
Jacqueline Lake Roberts, Esquire Heather Osborn, Esquire Thomas White, Esquire Consumer Advocate Division 700 Union Building, 723 Kanawha Blvd. East
Counsel for Consumer Advocate Division Public Service Commission
Susan J. Riggs, Esquire Jason C. Pizatella, Esquire Spilman Thomas & Battle, PLLC 300 Kanawha Blvd., East Charleston, WV 25301 Counsel for WVEUG
Derrick P. Williamson, Esquire Barry A. Naum, Esquire Spilman Thomas & Battle, PLLC 1100 Bent Creek Blvd., Suite 101 Mechanicsburg, PA 17050 Counsel for WVEUG
Thomas E. Scarr, Esquire Charles K. Gould, Esquire Jenkins Fenstermaker PLLC 325 8th Street, 2"d Floor Huntington, WV 25701 Counsel for SWVA
{ R 1366082 1 }
Kurt J. Boehm, Esquire Jody Kyler Cohn, Esquire Boehm, Kurtz, and Lowry 36 E. Seventh St., Suite 1510 Cincinnati, OH 45202 Counsel for The Kroger Company
Kristina Thomas Whiteaker, Esquire The Grubb Law Group 1 1 14 Kanawha Boulevard East Charleston, WV Counsel.for The Kroger Company
Mandi Kay Carter, Esquire Paul D. Ellis, Esquire City of Charleston 501 Virginia Street E Charleston, WV 25301 Counsel for City of Charleston
Ralph Smith Larkin & Associates 15728 Farmington Road Livonia, MI 48154 Consultant for Consumer Advocate Division
Jonathan Wallach, Vice President Resource Insight, Inc. 5 Water Street ##I0 1 Arlington, MA 02476 Consullant~for Consumer Advocate Division
Andrew T. Gunnoe, Esquire Mark J. Slotnick, Esquire PO Box 3627 Charleston, WV 25336 Counsel for KCCA
Richard Gottlieb, Esquire Spencer D. Elliott, Esquire Lewis Glasser PLLC PO Box 1746 Charleston, WV 25326 Counsel for Walmart
Stephen J. Baron J. Kennedy & Associates, Inc. 570 Colonial Park Drive, Suite 305 Roswell, GA 30075 Consultant for WVE UC
Kevin Higgins Energy Strategies, LLC Parkside Towers 21 5 South State Street, Suite 200 Salt Lake City, Utah 841 11 Consultant for The Kroger Company
Heaeher G. Harla<(WV State Bar ID No. 8986)
(R1366082 1 )
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR INFORMATION - CAD
Request B-36
Accumulated Depreciation. Refer to the direct testimony of Company witness Allen and Statement G, Adjustment No. 85-AD. On page 18 (lines 12-18)' Mr. Allen states that Adjustment No. 85-AD reduces APCo's West Virginia share of accumulated depreciation for the period January 1993 through December 2016 in order to recognize the difference in accumulated depreciation allocated to West Virginia based on the recorded book amounts using the higher total APCo composite of all jurisdictional book depreciation rates versus the depreciation rates approved by the Commission. In the Companies last rate case (Case No. 14-1152-E-42T), a similar adjustment was proposed (Accounting Adjustment 5-AD) by the Companies which reduced accumulated depreciation by $37,068,156 for the period January 1993 through December 2012. This adjustment from the 2014 rate case was approved by the Commission in its Order dated May 26, 201 5.
a. Since the Companies accounting adjustment 5-AD was approved by the Commission in its Order from Case No. 14-1 152-E-42T for the period January 1993 through December 2012, please explain fully and in detail why the Companies proposed adjustment 85-AD in the current proceeding relates to the period January 1993 through December 2016 and not January 2013 through December 2016.
b. Pursuant to part "a", please reconcile the $61,459,323 reflected in Adjustment 85-AD in the current proceeding to accounting adjustment 5-AD of $37,068,156 from Case No. 14-1 152-E- 42T.
Response B-36
a. The Companies' Adjustment 85-AD is appropriate since the per books 2017 cost of service as provided in Statement E in this current proceeding includes an allocation ofAPCo's total Company accumulated depreciation calculated using the total Company composite of all jurisdictional book depreciation rates to the West Virginia jurisdiction. The per books allocated West Virginia jurisdictional accumulated depreciation is based on APCo's composite book depreciation rates that reflect differences in commission approved rates in Virginia and West Virginia since 1 993. This accumulation of total Company differences between depreciation calculated using the composite book depreciation rates and depreciation that would have been calculated using only Commission approved depreciation rates grows over time since the PSC of WV approved rates are lower than the VA SCC approved rates.
The Commission's approval of the $37,068,156 decrease to accumulated depreciation in Case No. 14-1 152-E-42T related to the period January I993 through December 2012 was appropriate since December 2012 was the beginning of the test year in that case. Similarly, the Companies' Adjustment 85-AD that reduces accumulated depreciation by $61,459,323 related to the period
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR INFORMATION - CAD
January 1 993 through December 20 16 is appropriate in the current proceeding since December 2016 is the beginning of the test year in this case (the test year impact of the differences in accumulated depreciation between book rates and WV approved rates is separately reflected in Adjustment 86-AD as explained in Company witness Allen's testimony).
The Commission's approval of Adjustment 5-AD from the last base rate case did not impact the amount or calculation of accumulated depreciation recorded on the Companies' books or how accumulated depreciation is allocated to the West Virginia jurisdiction in the per books cost of service, but was necessary to reflect Commission approved depreciation rates for ratemaking purposes. In a similar manner, Adjustment 85-AD is necessary in the current proceeding.
b. The two referenced adjustments were calculated in the same manner with Adjustment 85-AD containing 48 months of additional monthly differences between composite book depreciation rates and PSC of WV approved depreciation rates as compared to Adjustment 5-AD. Refer to Statement G-1, Adjustment 85-AD, for the computation of the $61,459,323 adjustment. See CAD 6 B-36 Attachment 1 for the calculation of the $37,068,156 adjustment from Case No. 14- 1 152-E-42T.
Appalachian Power Company Statement G-1 Detail of Adjustment 5-AD - Accumulated Provision for Depreciation & Amortization Test Year Ended December 31,2013
Case No. 18-0646-E-42T
Attachment 1 Page 1 of 4
CAD 6 9-36
Reason, basis and derivation of adjustment: This adjustment decreases the accumulated provision for depreciation and amortization by $37,068,156 for the period January 1993 to December 2012 to recognize the difference in accumulated depreciation recorded on the books using composite WV, VA and FERC approved depreciation rates versus the amount that would have been recorded using only depreciation rates approved by the WV PSC. The adjustment is through December 2012 since the Company makes a separate adjustment (I-DP and 6-AD) for the 2013 test year depreciation expense and the related effect on accumulated depreciation.
EFFECT ON ACCUMULATED DEPRECIATION OF APPLYING WV JURIS. APPROVED DEPRECIATION RATES INSTEAD OF PER BOOK RATES ON BEGINNING OF TEST YEAR BALANCE
CUMULATIVE EFFECT JANUARY 1993 THROUGH DECEMBER 2012
Production Transmission Distribution-WV Distribution-VA 81 TN General Total Cumulative Effect on Accum. Deor. Balance (77.71 1.787) (8,607557) (697,823) 51 1,629 3,002,437 (83,503,101) Accumulated Affect of Depr. Billed to Others (253,679) (253,679)
Net Cumulative Effect (77,458,108) (8,607,557) (697,823) 51 1,629 3,002,437 (83,249,422)
Tennessee Virginia Virginia Virginia Virginia Virginia Virginia Virginia Virginia Virginia Virginia Virginia Virginia
West Virginia West Virginia West Virginia West Virginia West Virginia West Virginia West Virginia West Virginia West Virginia West Virginia West Virginia
General General General General General General General General General
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR I N F O R ~ T I O N - CAD
Request (2-29
Refer to Attachment 1 from the response to CAD-C-14.
a. Are the APCo regulatory assets (and related ADIT totaling $23 1,724,155) and liabilities listed on Attachment 1 which total $662,734,669 and $838,265,899, respectively, total Company amounts? If so, for each APCo regulatory asset (and related ADIT) and liability listed, provide the West Virginia jurisdictional amount.
b. Are the WPCo regulatory assets (and related ADIT totaling $16,942,279) and liabilities listed on Attachment 1 which total $48,406,5 1 1 and $73,085,985, respectively, total Company amounts? If so, for each WPCo regulatory asset (and related ADIT) and liability listed, provide the West Virginia jurisdictional amount.
c. Are all of a portion of the APCo regulatory assets and related ADIT which total $662,734,669 and $23 1,724,155, respectively, included in the Companies' 13-month average rate base in the current proceeding? If so, provide a breakout of the regulatory assets and related ADIT that are included in rate base on a total Company and West Virginia jurisdictional basis.
d. Are all of a portion of the WPCo regulatory assets and related ADIT which total $48,406,5 I 1 and $ 1 6,942,279, respectively, included in the Companies' 13-month average rate base in the current proceeding? If so, provide a breakout of the regulatory assets and related ADIT that are included in rate base on a total Company and West Virginia jurisdictional basis.
e. Are all of a portion of the APCo regulatory liabilities which total $838,265,899 included in the Companies' 13-month average rate base in the current proceeding? If so, provide a breakout of the regulatory assets that are included in rate base on a total Company and West Virginia jurisdictional basis.
f. Are all of a portion of the WPCo regulatory liabilities which total $73,085,985 included in the Companies' 13-month average rate base in the current proceeding? If so, provide a breakout of the regulatory liabilities that are included in rate base on a total Company and West Virginia jurisdictional basis.
g. For APCo, does the Companies filing reflect the amortization expense that is associated with any of the regulatory assets and liabilities listed on Attachment l? If so, list and quantify the amounts included in the Companies' filing on a West Virginia jurisdictional basis.
h. Pursuant to part "f', for each regulatory asset and/or liability for which amortization expense is reflected in the Companies' filing, please provide the unamortized balance as of the test year ended December 31, 2017. In addition, provide the remaining amortization period for each regulatory asset and liability.
i. For WPCo, does the Companies filing reflect the amortization expense that is associated with any of the regulatory assets and liabilities listed on Attachment l ? If so, list and quantify the amounts included in the Companies' filing on a West Virginia jurisdictional basis.
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR I N F O R ~ T I O N - C
j. Pursuant to part "i", for each regulatory asset and/or liability for which amortization expense is reflected in the Companies' filing, please provide the unamortized balance as of the test year ended December 31, 2017. In addition, provide the remaining amortization period for each regulatory asset and liability.
Response C-29
a. - b. - Yes. See CAD 6 C-29 Attachment 1 for the West Virginia jurisdictional amounts as shown under columns marked Item a and Item b for APCo and WPCo, respectively.
c. - d. - See CAD 6 C-29 Attachment 1 for the West Virginia jurisdictional regulatory asset amounts for APCo and WPCo that are included in rate base in the current proceeding in columns marked Item c and Item d, respectively.
e. - f. - None of the regulatory liability amounts for APCo and WPCo are included in rate base.
g. - h. - Yes. See CAD 6 C-29 Attachment 1 for the APCo West Virginia jurisdictional test year amortization expense included in the Companies' filing and West Virginia unamortized regulatory asset balancehemaining amortization period as of December 3 1, 201 7, in columns marked Item g and Item h. Note that certain test year amortization expenses related to severance expenses and 2009 storm costs were removed through going-level adjustments as shown on Statement G of the Companies' filing.
i. - j . - Yes. See CAD 6 C-29 Attachment 1 for the WPCo West Virginia jurisdictional test year amortization expense included in the Companies' filing and West Virginia unamortized regulatory asset balancehemaining amortization period as of December 3 1, 20 17, in columns marked Item i and Item j . Note that certain test year amortization expenses related to severance expenses were removed through going-level adjustments as shown on Statement G of the Companies' filing.
Case No 18-0646-E-427 CAD 6C-2Y Armchchmcni I
Page I o r 5
Appalachian Power Company Regulatory Asets Deeember31,ZOI? Case No. 184U6-E-42T
Regulatory Asset West Virginia Amount Included in ADIT Amount W’est Virginis Remsining West
West Virginia Total Company Jurisdictional Share West Virginia 13- Included in West Annual Werl Unamortized Balance Virginia Total Company Jurisdictional Sham ADIT Related of ADIT Related to month Avenge Rate Virginia 13-month Virginia Re~nil or Regulatory A ~ x t Amortization Period
RPglllPfory of Reg~1nto.y to Regulatory Regulatory Base in Cumnt Average Rate Base in Jurisdictional 2~ of December 31, as d December 31, Account Regulatory AsseURegulatory Liability Assetnisbilily Assetniability Assetniabilily ,\Ssetniability Proceeding Cumnt Prafrcding Amortization 2017 2017
R e ~ b t a w Assets
1821nin 1823152, Under-recovered Fud Cos\ - West Virginia 67,331,556 67.331.556 23.566.045 23,566,045 18232?8. 1823396 1823377 Piant Rciimmeni Coils . Asra Retirement Obligaeon Costs 39.694.892 16.476.278 13.893.212 5.766.697
IX233S6. 1821347. Vcgefnlion Managemcnr Program - Wcsr Viigtnia 13,4i8.177 13.458.177 11.710.362 I 1.710.362
I :::E: I I I I I I I I I I 1823399 1823304 Under-Rccevered Transmsrsm Rate- Adpstmcnt Ciaus. Vuginia 32,63x,n61 - 11.423.321 1823078 Storm UelaBd Costs - Wcsi Virp ia 31,516.344 31.516.144 I i.o~o.7~11 I i.030.7211 1~.653,0s4 31.516.344 3 y r ; m
182325 I Virsma Demand Response Program Costs 12.822.270 4.487.798 1823378 Pianr Rmrcmmt Costs - Materials and Supplies ~.094.1138 3,774.690 3.l82.913 1,321.141 1823392. Delayed Cusramci Rillmg - West Virginia 7,802,923 7.802,~23 2.731.023 2,731,1121 10.6~9.322 7,002,923 I year 1823393.
I82321 I IUndrr-Recovered tkkrred Wind Power Cosrs - Vigrnia 1,974,773 I I 691.171 1 I I I I I 1823389 IUincollected Coal Company Accounis - West V q p m 1,909,167 I l.909.167 I 668,208 I 668.208 I 790,000 1 1.909.167 I 3 yean 1823532 IIlcak Ikmand ReductionEnergy Effhcncy - W a r Virginia I 1,468,253 1 . 4 6 8 , ~ ~ I st3.889 I 513.889 I 1 I ! I
1 I823000 !Under-Recovered Ohm-Related Cortr I I 431,570 I I I I I I
Case No IX-0646-E-427 CAD 6 C-29 Aiiachmcnr I
rage 2 of5
1823137, IX23I3X. 1823139 1 821000 1823381
Appalachian Power Campan) Regulatory A s @ December31,2017 Care No. 18-0646-E42T
Errraordinaiy I'ropcrry lusseb - W E I ~ Virginia 79,122 79,122 27.693 21.691 Under-recovered Fi,el Costs - Commonwealrh of Virginia 67,809 23.733
c-29. I I Item 8. I I Item*. I Iterne. 1 Item E . I Itenp. I Item h. 1 Itemh. 1
Regulatory Arset Wemt Virginia Amaunt Included in ADIT Amount Wert Virginia Remaining West
West Virginia Total Company Jurisdictional Sham West Virginia 13- Included in West Anniial West Unnmrtimd Balance Virginia Total Company Jurisdictional Sham ADIT Related of ADIT Related to month Average Rate Virginia 13-month Virginia Retail of Regulatory Asset Amortization Period
Reg~latary of Regulatory to Regalalory Regulatory Bare in Current Aversgc Rate B s x in Jurisdictional BS of Decemhrr 31. 8s af December 31, Regulatory AsseURegulatory Liability Asetniability ArseULisbility AsseULiLiability Ansetnisbility Proceeding CurrentPraceeding Amnrtization 2017 2011
I I I I I I
'roliii ~eguiatoiy AWLS $ 662.734.669 $ 187,500,415 6 231.724.155 I 135.597.453 S R6.312,98O 5 30.209543 $ 36,677.016 $ 139.068.256
Income Taxes, Net 5 66,549,324 $ 66,549,324 I - $ - 6 , I - 5 s
Pccak Demand Reduciion/I.:neqyEfacirncg 4,238.93h 4.23R.936 Vrgelarian Managrmeni Program 1,283,547 1,283,547 , Unrealized Gain on Fowdrd Cammilmenis i . n i 4 . 1 7 ~ l,OI4.17X I
Tirial Regulatory 1.iahilitte.i P 73.085.985 I 73.085.985 I $ - 5 - $ - 6 I
A P P ~ A C H I ~ POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR INFORMATION - CAD
Request D-8
Has APCo or WPCo added any large commercial or industrial customers since December 31, 20 17?
a. If so, list the customers (can be by code to address confidentiality concerns) and identify the metered sales and revenues related with such customer additions.
Response D-8
No.
a.) NA
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH MQUEST FOR I N F O R ~ T I O N - CAD
Request D-9
Have any of APCo's or WPCo's large commercial or industrial customers told the Companies about expanding operations or increasing electric purchases during 20 17 or in 20 18 to date?
a. If so, list the customers (can be by code to address confidentiality concerns) and identify the metered sales and revenues related with such customer increases in demand or usage.
Response D-9
Yes.
a. One LCP Transmission voltage customer has identified a kW demand increase of between 13,000 and 17,000 kW in the summer of 2018. To date an increase of approximately 14,500 kW of metered demand has been observed for this customer. The customer's average load factor has been 86%. The applicable base rate tariffs for calculating the potential base rate revenue increase are publicly available.
One IP Transmission voltage customer who went bankrupt during the test year, and was sold, has recently increased its usage in July and August of 2018 to 6,104,000 kWh and 8,904,000 kWh, respectively. This customer had been using on average 2,000,000 kWh per month after it entered bankruptcy. The applicable base rate tariffs for calculating the potential base rate revenue increase are publicly available.
Please also refer to the Companies' response to Staff 1-8.
APPALACHIAN POWER COMPANY & W H ~ E ~ I N G POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR I N F O R ~ T I O N - CAD
Request D-10
Have any of APCo's or WPCo's large commercial or industrial customers told the Companies about closing operations or decreasing water purchases during 20 17 or in 20 1 8 to date?
a. If so, list the customers (can be by code to address confidentiality concerns) and identify the metered sales and revenues related with such customer changes in demand and/or usage.
Response D- 10
Yes.
a. Special Contract Letter Designation-G. Please see Staff 1-006, Attachment 1, for the requested load reduction information.
Additionally, a General Service Subtransmission voltage customer terminated its service in July of 2018. Its average usage was 9,300,000 kWh annually and 1,870 kW of monthly on-peak billing demand. The applicable base rate tariffs for calculating the potential base rate revenue increase are publicly available.
APPALACHIAN POWER COMPANY & WHEELING POWER COMPANY
WEST VIRGINIA CASE NO. 18-0646-E-42T SIXTH REQUEST FOR I N F O R ~ T I O N - CAD
Request E-44
Amortization Expense. Refer to Attachment 1 from the response to CAD-2-E-38 and Statement G, Adjustment No. 16-TD from the Companies filing.
a. For WPCo, please explain fully and in detail what the Delayed Customer Billing relates to and state why it had an unamortized balance of negative $4,298 negative unamortized balance as of July 31,2018.
b. Pursuant to part "a", what was the unamortized balance related to WPCo's Delayed Customer Billing as of December 3 1,201 7?
c. Regarding the APCo storm costs, please reconcile the test year amortization amount of $15,653,054 shown on Attachment 1 to the $2,611,808 that APCo removed from test year cost of service with Statement G, Adjustment No. 16-TD. Identify, quantify and explain each reconciling item.
Response E-44
a. The Delayed Customer Billing regulatory asset is the $25 million deferred residential rate increase plus carrying charges that the Commission approved in Case No. 14-1 152-E-42T to be amortized and collected over 24 months beginning July 1,2016. The negative $4,298 balance at July 3 1, 201 8 reflects a slight over-recovery of the WPCo portion of this regulatory asset in which the 24-month recovery and amortization period was completed on June 30, 2018. Also as shown on CAD 2 E-38 Attachment 1, APCo had an under-recovery balance of $570,865 related to this same $25 million deferred residential rate increase plus carrying charges at July 3 1, 201 8. The Commission determined in Case No. 16-0179-E-T-PC that at the end of the 24-month amortization period, any over- or under-recovery of the deferred rate increase should be trued up in a future ENEC proceeding.
b. Refer to the Companies' response to CAD 6 C-29 Attachment 1 for WPCo's unamortized balance related to the Delayed Customer Billing regulatory asset at December 3 1,201 7.
c. The $15,653,054 of test year amortization of deferred storm costs for APCo as shown on CAD 2 E-38 Attachment 1 consists of $2,611,808 of deferred 2009 storm costs and $13,041,246 of deferred 2012 storm costs. As shown in Statement G for Adjustment 16-TD, the $2,611,808 of deferred 2009 storm costs has been removed from the requested cost of service since the 7 year amortization of such deferred costs ended in March 20 18. Also, Statement E workpapers, page 10 of 131, line no. 455, shows that the $2,611,808 of deferred 2009 storm costs is adjusted out and no amortization of such costs is being requested in the going-level cost of service.