Scope of Work. The Independent Contractor will be fully responsible for the review, analysis and evaluation of all materials filed by the Utility (“Enbridge””) and any other parties in the proceeding relating to the cost-of-service studies, the revenue allocation among customer classes, and rate design submitted by Enbridge and the PUCO Staff (“Staff”) in Case No. 25-1097-GA-AIR, et al., 25-1098-GA-ALT, 25-1099- GA-AAM, and 25-1100-GA-ATA. The Independent Contractor will analyze and evaluate the cost-of-service studies presented in this proceeding and is expected to propose alternative and appropriate cost of service study and revenue allocation results for residential customers as needed. The Independent Contractor will also be responsible for the analysis and evaluation of background materials as may be provided by OCC or identified by the Independent Contractor during the course of its review regarding the rate structure and rates for residential customers including, but not limited, to customer charges and flat rates. The Independent Contractor will be expected to bring to its analysis substantial experience in evaluating all issues related to cost of service, revenue allocation, and rate design in this proceeding. Summary. On December 31, 2025, Enbridge filed an application for an increase in its rates in Case No. 25-1097-GA-AIR, et al. Supporting testimonies will be filed at a later date, typically within 14 days of the Application. In its Application, Enbridge is asking for an increase of $130 million in base distribution revenue (from $943.6 million to $1,106.7 million) with a proposed rate of return of 7.46%. Enbridge’s last rate case was decided by the PUCO in June 2025 in Case No. 23-894-GA-AIR, et al. In that case, the PUCO approved a $26.3 million Enbridge distribution revenue decrease, with an authorized rate of return of 6.60%. Work Requirements and Deliverables. The Independent Contractor shall undertake the following work and activities, as requested and approved by OCC, for the identification, analysis and development of issues related to the cost of service, revenue allocation, and rate design, including those related to the CEP and PIR riders, proposed by the Utility, the PUCO and other parties and the recommendation of appropriate revenue allocation and rate design for the residential customers of the Utility (Enbridge) in the proceeding. Deliverable 1 1. Review and prepare an analysis and critique of the Utility’s proposed cost of service study, revenue allocation and rate design including a review of the Utility’s Application, schedules, work papers and supporting testimonies. 2. Provide technical support regarding the cost of service, revenue allocation, and rate design for the discovery process in the proceeding, including: a. Prepare discovery (interrogatories and requests for production of documents); b. Review responses to OCC's discovery; c. Attend depositions scheduled as required by OCC's Lead Attorney; d. As required, give deposition testimony; and e. Review discovery requests served upon the OCC by other parties and assistance in preparing OCC’s responses to such discovery. Deliverable 2 Review and prepare an analysis and critique of the PUCO Staff's proposed cost of service, revenue allocation, and rate design in its Staff Report of Investigation, work papers and supporting testimony, including preparation of objections to the Staff Report on the same or related issues. It is estimated that the Staff Report will be issued approximately five months after the Utility files its application. Objections to the Staff Report, along with testimony, are due thirty days from the date the Staff Report is issued. Deliverable 3 1. Recommend and calculate an appropriate revenue allocation and rate design for residential customers of Enbridge: i. Prepare written, direct and, if needed, rebuttal testimony and presentation of that testimony at the hearing; ii. Testimony shall include the appropriate revenue allocation and rate design for residential customers of Enbridge and supporting schedules. 2. Review the information developed by, and the testimony of, any other consultants retained by OCC in order to coordinate the OCC's development of issues in this proceeding. Deliverable 4 1. Provide technical support, as identified by OCC's Lead Attorney, for the legal preparation involved in the proceeding including an analysis of written and oral testimony of other witnesses (Utility, PUCO Staff and other parties) to assist with cross-examination.
