Capital Structure Review
Is the requested financing allowance justified, or could customers pay less while EPCOR retains adequate access to capital?
1. What EPCOR says—and what to test
| Company evidence | Question for review |
|---|---|
| Boizelle: proposes 60% equity / 40% debt instead of roughly 64% actual EWNM equity, describing it as a more typical mix without issuing additional debt. Debt cost is 4.61%, including issuance-cost amortization, on parent-held notes. Direct, printed p. 10. | Why should customers fund this equity allowance rather than a lower one? Test the allowance separately from a change in actual borrowing. |
| Howard: supports 60% against a 60.56% five-year actual average. His proxy equity range is 39.31%–56.93%. He applies a −32-bp financial-risk adjustment and +50-bp size adjustment in supporting 10.50% ROE. Direct, printed pp. 11–12, 45–49. | Evaluate equity and ROE together. Revisit his risk adjustment at an alternative mix; do not assume his 10.50% recommendation transfers unchanged. |
| Loquvam: reports estimated Clovis ROE of 3.13% versus the previously authorized 9.30%, and attributes the need for relief to cost and investment pressures. Direct, printed pp. 7–8. | Verify the earnings calculation and causes of the shortfall. Existing under-earning does not establish that every component of the new request is reasonable. |
These are company positions, not Commission findings. The testimony has now been checked directly; the native revenue-requirement workbook has not been reconciled.
2. Test an alternative
First isolate the mix. Then allow for a supported change in ROE or debt cost and see whether the customer benefit remains. The buttons are tests, not recommendations.
Company reference selected. Choose an alternative or edit the inputs below.
Alternative assumptions
Reference: 60% equity, 10.50% ROE, 4.61% debt cost. Edit an alternative below. Other case items stay fixed to isolate the financing allowance.
Deductible share: 100% updates the interest deduction with modeled debt return; 0% holds it fixed. Confirm the filing’s tax treatment. Inspect calculations.
Baseline inputs and tax conversion
Edits are analytical overrides. The capital reference stays at 60% / 10.50% / 4.61%; changing rate base applies the same rate base to both capital structures. Revenue and return anchors are held as entered.
Calculation bridge, driver attribution and sensitivity grid
Explain the change
Exact Shapley attribution averages all six orders of changing equity share, ROE and debt cost. It allocates interaction effects without choosing an arbitrary sequence. These are mathematical contributions, not independent causal estimates.
| Driver | Annual revenue contribution |
|---|
Equity × ROE sensitivity
Annual change vs reference, with the selected debt cost and tax settings. Click a cell to use that scenario. Green means lower than the proposal; amber means higher. The grid does not identify an economically optimal structure.
Calculation and reconciliation
K = B × [e × r + (1 − e) × d] ΔI = q × B × [(1 − e) × d − 0.40 × 0.0461] t = s + (1 − s) × f ΔR = F × (ΔK − t × ΔI) Computed F = 1 / [(1 − u − v) × (1 − t)] Scenario requirement = entered filed requirement + ΔR All rates in formulas are decimal fractions. No intermediate rounding.
Scenario notes and portable records
Scenario record
Snapshots persist in this browser when local storage is available. Export JSON for a portable record. Imported results are recalculated, never trusted as supplied.
3. What does the result establish?
If the allowance is too high
Customers fund more capital compensation than a supported, adequately financed alternative requires. The difference is a potential adjustment to the request; it is not proof that EPCOR has already collected excess revenue.
If the allowance is too low
Persistent insufficient cash generation can weaken credit, raise financing costs or constrain investment. A smaller allowance is not better if its financing consequences outweigh the customer benefit.
Actual over- or under-earning is a separate test: compare normalized jurisdictional earnings with the applicable authorized return on a consistent basis, then explain the drivers. A rider’s over- or undercollection is yet another reconciliation.
Excess earnings, if established, may support review of rates or a mechanism-specific reconciliation. A shortfall may support prospective relief if justified. Neither automatically means a refund, a surcharge, or a guaranteed return: check the applicable tariff, order and law.
Test recorded earnings against the authorized ROE
Use the same jurisdiction, period and regulatory accounting basis. This calculation diagnoses an earnings gap; it does not attribute it to the capital mix or determine a legal remedy.
Not assessed: enter comparable earnings, equity, authorized ROE and the source basis.
Earned ROE = net income available to common equity ÷ corresponding equity base. Earnings gap = net income − equity base × authorized ROE. This is an after-tax equity-earnings difference, not a revenue refund or revenue deficiency. Investigate sales, costs, rate base, lag, allocations and one-time items before drawing conclusions.
Scenario-specific testimony draft and save/export controls
The full conditional draft updates in the supporting analysis. The concise finding below can be exported with the current scenario.
Supporting analysis, definitions, benchmarks and original source audit
EPCOR Clovis Capital Structure Analysis
The question is whether an alternative financing allowance lowers customers’ revenue requirement while preserving a reasonable opportunity to earn a risk-appropriate return and finance utility service. This tool measures the revenue side. The evidence and risk steps below address what it takes to support a recommendation.
1. What decision are we testing?
A ratemaking capital structure allocates the allowed return between debt and common equity. More equity usually raises the allowance because equity has a higher required return and lacks an interest tax deduction. More debt can lower the allowance, but increases fixed payment obligations if the utility actually borrows more. An assumed regulatory mix does not itself refinance the company.
Translate the inputs
Rate base is the net investment recognized for earning a return. It is neither total utility assets nor the actual outstanding debt balance.
Equity ratio is the common-equity share of the modeled capital mix. Debt is the remainder in this two-component model.
ROE is the annual allowed return on the equity-financed part of rate base. It is an opportunity to earn, not a guarantee of realized profit.
Debt cost is the embedded annual cost of the debt component. A new bond’s coupon is not automatically the cost of all outstanding debt.
Read the result correctly
WACC is the weighted return allowance before the model’s interest-tax adjustment. The income-tax calculation is separate.
Annual revenue change compares the scenario with the company reference. A negative value means less than the proposal. It may still leave a substantial increase over current revenue.
Revenue-neutral ROE is the ROE at which this scenario has the same annual revenue requirement as the reference. It is a mathematical crossover, not an estimate of a fair ROE or a credit-risk boundary.
1 basis point = 0.01 percentage point. Moving ROE from 10.50% to 11.50% adds 100 basis points.
Why some items move and others stay fixed
| Item | Treatment and economic reason | When it must be investigated separately |
|---|---|---|
| Equity and debt return | Included: changing their weights or costs directly changes the allowed return on the same rate base. | Confirm actual, parent, subsidiary and proposed regulatory mixes; preferred stock and short-term debt require a broader capital model if material. |
| Interest tax deduction | Included as a change from baseline: deductible interest lowers taxable income. Leaving it fixed can misstate the consequence of a different debt allowance. | Confirm tax synchronization, consolidated tax treatment, allocation, and deductible issuance costs. The deductible-share control is a sensitivity, not a tax opinion. |
| Income-tax gross-up and revenue-related expenses | Included: collecting an extra dollar produces less than a dollar after modeled taxes, uncollectibles and utility tax. The conversion factor bridges that difference. | Confirm the filed factor’s exact components and precision. Changing tax assumptions here changes marginal effects; it does not rebuild baseline tax expense. |
| O&M, depreciation, rate base and deferred taxes | Held constant to isolate the capital-structure question. They do not automatically change just because the allowed financing mix changes. | A full case includes these items. Plant, working capital, ADIT, tax normalization or operating-cost adjustments need their own schedules; rebuild all linked effects rather than stacking an unexplained lump sum. |
| Principal repayment, capex and dividends | No separate add-on in this revenue sensitivity. Debt principal is not interest expense; investment recovery and future financing must be analyzed through the appropriate depreciation, rate-base and cash-flow schedules. | Cash requirements still matter for financing: forecast maturities, capital spending, internal cash, dividends and external funding. Do not infer liquidity from revenue requirement alone. |
| Customer bills and credit ratings | No rating or tariff is inferred. Aggregate revenue does not specify class allocations or a rating-agency cash-flow metric. | Rerun rate design for bills; prepare entity-specific financial forecasts and agency adjustments for credit conclusions. |
Method context: NARUC, Ratemaking Fundamentals and Principles. These model-design explanations are analytical judgments; the case record determines the accepted treatment.
Use it in this order
- Reproduce the reference. Run the company case: the change must be zero. Inspect the separate return-anchor residual; zero delta does not establish that native filed precision is reproduced.
- Isolate a question. Change only equity, only ROE, or only debt cost before combining them.
- Test an adverse response. Add a supported ROE premium or debt-cost change. Identify when the claimed revenue benefit disappears.
- Check financeability at the correct entity. Forecast cash flow, actual debt, liquidity and maturities. An allowed equity percentage is not a credit rating.
- Write the conditional finding. Save the scenario, assumptions, sources and unresolved issues. A policy recommendation needs evidence beyond this calculation.
2. Choose a question, then run its test
Each button resets the upper workbench to the inherited filing inputs and applies the stated test. The numerical examples are screening choices, not recommended allowances. Saved snapshots remain available.
What does the current scenario tell us?
How much adverse repricing could erase the benefit?
These are revenue-neutral economic crossovers. They answer how far the assumed ROE or embedded debt cost could move before the modeled customer benefit is gone. They do not measure the utility’s ability to pay debt. Each crossover varies only one cost while holding the other settings fixed.
Worked example: why the tax treatment changes the answer
At 50% equity, 10.50% ROE and 4.61% debt cost, the modeled equity-return component falls about $477,478, while debt return rises about $209,636. The net return decrease is about $267,843. If all of the added debt return is deductible, the incremental tax effect is about −$53,795 before conversion. Multiplying the combined gap by 1.3632 gives approximately −$438,456 annually. Holding interest fixed instead gives approximately −$365,123.
This is why selecting a tax treatment matters. Neither result, by itself, establishes which treatment the Commission should adopt. Check the H-9 synchronization formula and deductible debt-cost components in the native workbook.
4. Would the alternative put financing at risk?
Answer at present: not established by this calculator. The workbench calculates an allowed revenue change. Financeability requires a forecast for the borrowing entity, including actual financing, recovery timing and rating-agency adjustments. Use the following separate screen after preparing that forecast.
| Risk / when it matters | Mechanism | Evidence to test |
|---|---|---|
| More actual debt / lower actual equity | Interest and maturities become a larger fixed claim; less equity absorbs adverse operating outcomes. | Operating-company and parent debt schedules, actual capitalization, structural subordination and guarantees. An assumed regulatory mix may reduce cash recovery without changing actual obligations. |
| Refinancing / floating-rate exposure | Market rates or spreads change at repricing, maturity or new issuance. Existing fixed-rate debt is not automatically repriced. | Debt maturities, floating-rate balance, hedges, new funding needs and actual issue terms. Translate affected debt into a weighted embedded cost; do not apply a new coupon to the entire stock without support. |
| Regulatory lag / under-earning | Cash spending or investment occurs before recovery; authorized ROE may exceed earned ROE. | Monthly/annual cash forecast, riders, decoupling, rate effective dates, earned-return bridge and capex timing. |
| Drought, sales loss, cost or construction shock | Cash flow weakens, investment funding rises, or operating costs precede recovery. | Document local exposure, recovery mechanisms, construction contingencies, insurance and combined downside forecasts. |
| Rating, covenant and liquidity pressure | Persistent weak credit metrics can constrain funding; contractual limits may trigger different remedies; a near-term cash shortage can occur even with an acceptable annual ratio. | Current entity-specific rating report, covenant definitions and cure provisions, committed liquidity, cash restrictions and a maturity calendar. |
EPCOR’s April 30, 2026 Q1 MD&A describes rating-related borrowing and funding risks at the consolidated group level. It also describes new U.S. notes with 5.61% and 5.97% coupons. Those are group issuance terms, not the embedded debt cost of the Clovis district. EPCOR Q1 2026 MD&A, subsequent event and financial risk discussion.
Optional: calculate FFO/debt headroom from your financial forecast
FFO means funds from operations, as adjusted under the selected agency’s methodology. Moody’s CFO before working capital is a different defined metric: do not substitute it into an S&P FFO/debt threshold. Use one entity, currency, period and agency definition throughout.
All fields are intentionally blank. Enter zero explicitly for no cushion or no stress. The rate-case revenue change is not transferred dollar-for-dollar into FFO: collections, cash taxes, interest, noncash adjustments and the entity boundary require reconciliation. This screen does not infer additional debt from the regulatory equity ratio. Its forecast remains independent when you change a revenue scenario; verify that the forecast workpaper matches the scenario you discuss.
FFO/debt = annual agency-adjusted FFO / agency-adjusted debt Cash-flow headroom at trigger = FFO − debt × trigger Target ratio = trigger + analyst-selected cushion Stressed ratio = (FFO − additional FFO loss) / (debt + additional debt) Trigger and cushion are decimal fractions in these formulas.
What is the threshold? Use the right comparison.
There is no demonstrated single “best practice” equity percentage or FFO/debt cutoff for EPCOR Clovis. A defensible recommendation evaluates comparable water utilities, the borrowing entity’s actual financing, regulatory protections, and forward cash-flow resilience. The examples below are reference points for designing tests, not a statistical peer range or an NMPRC rule.
| Evidence and date | What it shows | How to use it / what it does not prove |
|---|---|---|
| California Water Service disclosure, Nov. 20, 2025 | 53.40% equity / 46.60% debt; 10.27% ROE and 4.23% debt cost maintained following postponement of its cost-of-capital application. | A water-utility regulatory comparison. Investigate differences in size, business risk and recovery mechanisms before proposing the same mix for EPCOR. |
| Suburban Water Systems, Jan. 2, 2026 application, §11.1 | Reports 62% common equity and 9.46% ROE under D.24-12-007; its structure also includes 1.31% preferred stock. | Shows that water-utility allowances can pair a higher equity share with a lower ROE. It is applicant reporting of a prior decision, not a newly verified NMPRC comparable. |
| Missouri PSC Staff report, Jan. 29, 2026, financial analysis | Staff recounts S&P’s 2025–2027 American Water expectation of 12%–14% FFO/debt and sustained-below-12% downgrade pressure. | A water-parent credit example reported by regulatory Staff, not an EPCOR trigger, contractual covenant, investment-grade boundary or direct review of the underlying rating report. |
| Exelon investor presentation, Oct. 30, 2026, credit metrics | Describes forecast headroom of about 100 bp above its S&P trigger and 200 bp above its Moody’s trigger, using different agency metrics. | An electric-utility example of managing a cushion above a trigger. It supports considering headroom; it does not establish a required cushion for a water utility. |
| FPC v. Hope Natural Gas Co., 320 U.S. 591, 602–603 (1944) | Frames the overall result around financial integrity, credit, attracting capital and returns commensurate with risk. | A legal framework, not a numerical ratio test. Counsel should connect it to the applicable New Mexico record and authorities. |
A practical decision rule for this case
- Customer-cost screen: Does the benefit persist under supported ROE, embedded debt-cost and tax assumptions? A benefit that disappears under a small plausible response is less robust.
- Financeability screen: Does an entity-specific multi-year forecast retain appropriate headroom under documented downside conditions? A single ratio above a trigger is insufficient if liquidity or covenants fail.
- Evidentiary screen: Can the witness explain why the comparators and proposed assumptions fit EPCOR? A peer’s authorized ratio is context; it is not a self-proving recommendation.
A rating trigger signals possible rating pressure, often on a sustained basis; crossing it does not mechanically produce a downgrade. A loan covenant is a contractual test with its own definitions and dates. The revenue-neutral crossover is neither one. Obtain EPCOR’s actual rating reports and debt covenants before asserting a credit threshold.
5. What can the economist say in testimony?
The text below follows the current upper-workbench scenario. It distinguishes the calculation from the unproven financing conclusion. Copy it into a draft with the supporting exhibit references; the paragraph is not an expert recommendation generated from peer averages.
Questions to answer before recommending an allowance
| Likely question | Defensible response / evidence required |
|---|---|
| Why did you lower the equity share? | State the hypothesis and actual peer/financing evidence. The model alone supplies the revenue consequence, not the appropriate capital mix. |
| Did you keep ROE too low when adding leverage? | Show a separately supported ROE range and the revenue-neutral crossover. A 12-bp slope is an illustration, not an empirical leverage premium; generic beta relevering is not a substitute for selecting a comparable risk and capital structure. |
| Why not apply the newest debt coupon to everything? | Show which issues mature or float, new issuance, balances and amortization. Most existing fixed debt does not reprice immediately; recalculate the weighted embedded rate. |
| Does the result imply the utility can borrow safely? | No financing conclusion follows automatically. Present the borrowing-entity cash forecast, adjusted metrics, headroom, liquidity, covenants and sensitivities before drawing that conclusion. |
| Did you double count savings? | Walk through the equity-return decrease, debt-return change, interest-tax effect and conversion. Shapley attribution allocates interactions among three inputs; it is not an additional saving to add to the bridge. |
| Why exclude depreciation, principal or capex? | They are outside the isolated financing-allowance change; depreciation and rate base remain in the filed anchor. Demonstrate cash funding separately. A full revenue-requirement recommendation must reconcile all adjustments in a common workbook. |
| Will customers’ bills fall by this percentage? | The result is an aggregate annual revenue change. Use class allocation and tariffs to calculate bills; no uniform percentage follows from this test. |
Targeted discovery / workpaper requests
- Native A-1, A-4, A-5, G-3 and H-9 schedules with formulas, precision and all revised versions; bridge each filed anchor and interest deduction.
- Actual and proposed capitalization for Clovis, EPCOR Water New Mexico, relevant intermediate parents and the ultimate funding entity; explain intercompany pricing, allocation and any hypothetical structure.
- Issue-level debt balances, net proceeds, coupons, issuance-cost amortization, maturities, floating exposure, hedges and planned funding; reconcile embedded debt cost and deductible interest.
- Current borrower-specific agency reports, forecast adjusted ratios, downside triggers, covenant calculations, cash restrictions, committed facilities and equity-support obligations.
- At least a multi-year financing forecast spanning rate effectiveness, major capex and maturities: earned return, FFO reconciliation, cash taxes, working capital, capex, dividends, borrowing and equity contributions under base and downside cases.
- Comparable water-utility allowed/actual equity, ROE and debt cost on consistent dates; match size, jurisdiction, recovery mechanisms, capital plans and entity level. Identify selection criteria and exclusions.
Verification: 801 numerical, boundary, attribution, reconciliation, earnings-gap, cross-engine and script-structure checks passed. Interactive rendering, downloads and print layout could not be verified because the browser tool blocked the local file and the preview timed out. Research checked November 8, 2026. Linked peer evidence is separate from the inherited initial EPCOR filing inputs. No later EPCOR rate-case revision has been incorporated. The tool is immediately usable for discovery, sensitivity exhibits and conditional drafting; a final allowance or financeability opinion requires the supporting case evidence identified above.
Original calculator and inherited filing source audit
Reference appendix with independent controls. Use the upper workbench for the guided analysis.
Original calculator and filing source audit
The retained calculator below uses its own displayed settings. Workbench overrides above do not change it. Use it to cross-check the original model and inspect the inherited source references.
Capital Structure Sensitivity
Change equity, debt cost and the assumed return on equity. Compare the annual revenue effect, including the modeled change in the income-tax interest deduction.
Working model, not a Staff recommendation. Based on the supplied August 31 / September 1, 2026 filing. It does not reproduce EPCOR’s native workbook or determine approved rates.
1. Set a scenario
Company reference: 60% equity, 40% debt, 10.50% ROE and reported 4.61% debt cost. Requested rate base: $45,474,118. Annual revenue increase requested: $2,775,370. [S1, S2]
Model settings Tax treatment, precision and local settings
Rate base, operating costs, depreciation, other revenues, tax credits and deferred-tax adjustments remain fixed. The model is anchored to the filed $14,898,175 annual revenue requirement. It is not a forecast of debt issuance or a full rate-case calculation.
2. Result for the selected scenario
A negative change means a lower annual revenue requirement than EPCOR’s proposal. It does not mean bills fall below current levels. Results are conditional on the displayed assumptions; they are not an optimized capital structure.
3. Compare equity ratios
| Equity | Fixed ROE | Fixed WACC | Fixed annual revenue change | Illustrative ROE | Illustrative WACC | Illustrative annual revenue change | Revenue-neutral ROE |
|---|
WACC = weighted average cost of capital before an interest tax adjustment. Revenue-neutral ROE means the ROE that makes this model’s annual revenue change zero, not a reasonable or approved ROE. Click an equity ratio to use it. The selected row is bold.
Saved scenarios
Snapshots preserve the settings used when saved. They last only in this open tab; export before closing.
| Scenario | Equity | ROE | Debt cost | Tax method | Annual revenue change |
|---|
Calculation bridge See the dollars behind the result
| Item | Annual amount / factor | Meaning |
|---|
Residential bill illustration Optional assumption, not a tariff result
ILLUSTRATION ONLY. These are not calculated customer rates. The model assumes every listed bill’s proposed increase changes in the same proportion as the total revenue deficiency. It does not rerun class allocations, meter charges, usage blocks, surcharges or tariff rounding.
Source: the petition’s 5/8-inch residential base-bill examples, Exhibit A p. 4 (PDF p. 14). Separate riders, taxes and franchise charges are not modeled. [S5]
| Monthly gallons | Filed current base bill | Filed proposed base bill | Illustrative scenario bill | Change versus proposed bill |
|---|
Formulas and limits What is calculated and what is assumed
Let B be rate base, e the equity share, r the ROE, d the debt cost, and subscript 0 the company reference. Rates below are decimal fractions.
Under the default assumption, added debt changes both the return component and the income-tax interest deduction. The original script’s formula, F × ΔK, is retained as the fixed-interest comparison. It does not update that deduction when the capital mix changes.
Tax assumption: the default uses the change in rate-base debt return as the change in deductible ratemaking interest, while preserving the filed baseline interest amount. H-9 shows an interest deduction in calculating state and federal taxes; Boizelle states the embedded debt cost also includes issuance-cost amortization. Confirm the synchronization basis and deductible cost components with accounting before using the results in testimony. [S3, S4, S6]
There are several assumptions, not just the ROE slope: the ROE response, the debt-cost response, the tax synchronization basis, unchanged non-capital items, and the allocation of changes to customer bills. None is established merely by running the calculator. The fixed-ROE path is not a demonstrated maximum saving.
The main display rounds dollars for readability. Exports retain additional precision. The browser uses standard floating-point arithmetic; the included Python version uses Decimal and independently tests the same formulas. Printed filing inputs themselves are rounded.
Method context only: NARUC’s Ratemaking Fundamentals and Principles distinguishes revenue requirement from cost allocation and rate design. A Florida PSC staff memorandum (September 2008), Interest Synchronization discussion illustrates recalculating taxes when capital-structure interest changes. Neither establishes the NMPRC treatment for this case. These links require internet; the calculator does not.
Source audit Filed inputs, calculated reconstructions and assumptions
All case references below refer to the supplied initial filing. “PDF page” is the page shown by a PDF viewer. No later order or revised workbook is incorporated. The source excerpts are embedded and can be viewed offline.
| Reference | Input / treatment | Source and qualification |
|---|---|---|
| S1 | Deficiency $2,775,370; conversion factor 1.3632; current adjusted revenue $12,122,805; requested return $3,702,604. | Volume III, Schedule A-1, lines 1 and 8–11; factor calculation below, PDF p. 6 / printed p. 2. Uncollectibles 0.0073 and utility tax 0.0059 are printed rates. |
| S2 | Rate base $45,474,118; 60% equity / 40% debt; ROE 10.50%; reported debt cost 4.61%. | Volume III, A-4 and A-5, PDF pp. 9–10 / printed pp. 5–6. Total requested revenue $14,898,175 is stated in the Petition, pp. 1–2 (PDF pp. 3–4), and equals $12,122,805 + $2,775,370. |
| S3 | Optional reconstructed debt rate: $873,573 annualized cost ÷ $18,967,800 net proceeds = approximately 4.60555784%. | Volume III, G-3, line 4, PDF p. 41 / printed p. 37. The quotient reproduces the filed requested return to the nearest dollar. Native precision and formula have not been verified. |
| S4 | State tax 5.90%; federal tax 21%; adjusted interest deduction $837,735. | Volume III, H-9, lines 4, 6 and 9, PDF p. 59 / printed p. 55. Federal tax is calculated after the state-tax deduction. Combined t = 25.661%, calculated here. |
| S5 | Current and proposed residential 5/8-inch base bills. | Petition, Exhibit A p. 4, PDF p. 14. These are copied rounded examples, not a newly reconstructed tariff. No gallons/ccf conversion is performed by this calculator. |
| S6 | Debt cost includes interest and issuance-cost amortization. | Jon P. Boizelle direct testimony, printed p. 10, lines 13–16 (PDF p. 14). This matters when confirming the tax-deduction assumption. |
| Assumed | 12-basis-point leverage slope; optional symmetry; manual ROE; scenario debt cost; tax synchronization; proportional bill-increase scaling. | Model assumptions, not Commission findings or a cost-of-capital witness’s conclusions. Revenue and return anchors are held fixed while calculating marginal changes. |
Original A-1 excerpt
Volume III, PDF p. 6. Cropped only to remove blank margins.
Original G-3 excerpt
Volume III, PDF p. 41. Cropped only to remove blank margins.
Original H-9 excerpt
Volume III, PDF p. 59. Cropped only to remove blank margins.
Original residential bill excerpt
Petition, PDF p. 14 / Exhibit A p. 4.
Run the Python version No third-party packages
Use “Download Python” above to save the same model as epcor_sensitivity.py. Python 3.9 or later is required only for this optional version.
On systems using the python3 command, replace python with python3. No escaped backslashes or HTML entities from the pasted example are included in the downloaded script.