Rate Case Testimony Preparation
Prepare expert witness testimony for utility rate proceedings with regulatory compliance
What You Can Do
You can structure comprehensive expert witness testimony that withstands regulatory scrutiny, legal discovery, and cross-examination in state PSC filings and FERC proceedings. This skill helps you balance technical rigor with accessibility for non-engineering commissioners, anticipate opposing counsel's challenges, establish clear methodological foundations, and create testimony that becomes part of the permanent regulatory record. You'll develop direct testimony, rebuttal testimony, surrebuttal testimony, and supplemental testimony across multiple jurisdictions with consistent quality and strategic presentation.
Features
organize technical analysis into sworn statements with clear findings, methodological support, and exhibit references for filing
identify vulnerabilities in your positions and preempt challenges from opposing counsel with robust supporting documentation
ensure testimony meets PSC filing requirements, FERC standards, and quasi-judicial hearing protocols for your specific jurisdiction
systematically address competing rate proposals and other parties' testimony with point-by-point technical rebuttals
link testimony statements to supporting schedules, work papers, and data with clear evidentiary trails
document technical choices, precedent support, and industry standards to establish regulatory defensibility
maintain consistency across simultaneous rate cases while adapting testimony to jurisdiction-specific procedural requirements
incorporate discovery answers and procedural ruling responses into supplemental or amended testimony
Example Output
Direct Testimony Opening:
The Company proposes a revenue requirement of $152.3 million based on a 9.5% return on equity and 48.2% equity capitalization. My testimony supports this figure through three methodological approaches: (1) DCF analysis yielding 9.3–9.7% ROE range, (2) comparable company analysis supporting 9.4–9.6% ROE, and (3) CAPM analysis indicating 9.5% ROE. The Company's capital structure reflects investment-grade bond ratings and operational stability consistent with peer utilities.
Rebuttal Response to Competing Proposal:
Intervenor ABC's proposed 8.2% ROE understates market risk premium by 1.8 percentage points. Their comparable company sample excludes two utilities with similar credit metrics (Moody's Baa1/S&P BBB+), artificially suppressing peer ROE averages. Using the full peer dataset, median ROE reaches 9.4%, supporting the Company's 9.5% proposal.
Exhibit Reference Structure:
Schedule JDM-1 presents the DCF analysis with 10-year growth rate derivations by customer class. Schedule JDM-2 documents comparable company financial metrics. Schedule JDM-3 reconciles capital structure to audited balance sheet figures as of [date].
What's Included
- SKILL.md instruction file with testimony preparation methodology and regulatory compliance guidance:
- Direct Testimony Template: structured outline with sections for findings, methodological support, and exhibit integration
- Cross-Examination Defense Checklist: vulnerability assessment framework and preemptive documentation requirements
- Regulatory Compliance Matrix: PSC filing requirements, FERC standards, and quasi-judicial hearing protocols by jurisdiction
- Exhibit Documentation Framework: schedule linkage system connecting testimony statements to supporting data and work papers
- Rebuttal Strategy Worksheet: point-by-point response template for addressing competing rate proposals
Who It's For
- Rate analysts preparing expert witness testimony in utility regulatory proceedings
- Utility regulatory counsel coordinating testimony development across multiple rate cases
- Regulatory consultants supporting utility companies in PSC and FERC filings
- Utility company finance teams managing rate case documentation and compliance
- Energy industry expert witnesses establishing methodological credibility across jurisdictions
Best For
- Preparing direct testimony for initial rate case filings with technical documentation
- Developing rebuttal and surrebuttal testimony responding to competing proposals
- Creating supplemental testimony addressing discovery responses or procedural rulings
- Managing simultaneous rate cases across multiple jurisdictions with consistent testimony quality
- Anticipating and defending against cross-examination challenges from opposing counsel
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