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Improving Procedural Efficiencies

The Indiana Utility Regulatory Commission (“Commission”) and its staff are continuing to evaluate how to improve procedural efficiencies in the Commission’s docketed proceedings and we would like your input and feedback, with the goal of ensuring each case record is as robust as possible for decision-making.

2022 Improving Procedural Efficiencies (IPE) Initiative

This year’s initiative will focus on the Minimum Standard Filing Requirements rulemaking. Information about the process, comments submitted by stakeholders, and any upcoming workshops or meetings, can be found here.

Additionally, an updated DSM technical resource manual is being worked on.

2021 Improving Procedural Efficiencies (IPE) Initiative

The 2021 Issues List focused on updating the Minimum Standard Filing Requirements (“MSFR”) rule and Demand Side Management (“DSM”) and Energy Efficiency (“EE”) proceedings.  Note that the existing MSFR rule was readopted this year, in order to provide sufficient time for the rulemaking to amend it.

Comments submitted:

  • Citizens Action Coalition | PDF
  • Indiana Energy Association | PDF
  • Indiana Industrial Energy Consumers, Inc. (INDIEC) | PDF
  • Indiana Office of Utility Consumer Counselor (OUCC) | PDF

The Commission hosted workshops regarding updating its MSFR rule, 170 IAC 1-5, in IURC Judicial Courtroom 222, 101 W. Washington Street, in downtown Indianapolis.  It held workshops on Tuesday, Sept. 21, 2021, and Thursday, Oct. 21, 2021.

  • 2021-09-21 Pre-workshop MSFR Strawman Draft - Word Doc | PDF
  • 2021-09-21 MSFR Update – Workshop Comments re: Strawman Draft-  Word Doc | PDF
  • 2021-10-20 MSFR Revised Strawman Draft - Word Doc | PDF
  • IEA Comments on the first MSFR Workshop - PDF
  • INDIEC Comments on MSFRs Strawman - PDF

2020 Improving Procedural Efficiencies (IPE) Initiative

On Dec. 29, 2020, the Commission issued GAO 2020-05 on Improving Procedural Efficiencies; the GAO can be found here.

Feedback on Strawman GAO

Following the submission of feedback from stakeholders over the last several months, Commission staff has created a Strawman Draft GAO and Strawman Draft GAO Appendix. These drafts can be found below.

Strawman Draft GAO | Word doc | PDF
Strawman Draft GAO Appendix | Word doc | PDF

Comments submitted:

Second Round of Stakeholder Feedback

On Sept. 9, 2020, the Commission opened up the next round of comments on the improving procedural efficiencies project. Commission staff finalized a list of possible improvements based on the comments submitted to the Commission in June.

  • 2020 IPE Issues List | PDF
  • Municipality Strawman Accounting Schedules | Excel sheet
  • Investor-owned Strawman Accounting Schedules | Excel sheet
  • Standard Rate Accounting Overview | PDF

The comments that were submitted by Oct. 9, 2020, for this round of feedback can be found below. As a reminder, we expect to eventually issue General Administrative Orders ("GAOs"), as well as start a rulemaking to amend the Minimum Standard Filing Requirements ("MSFRs" - 170 IAC 1-5).

  • Indiana-American Water Company, Inc. | PDF
  • Indiana Industrial Energy Consumers, Inc. (INDIEC) | PDF
  • Joint Utilities - Citizens Energy Group, Duke Energy Indiana, Indiana Michigan Power Company (I&M), Indianapolis Power & Light (IPL), Northern Indiana Public Service Company, LLC (NIPSCO), and Vectren/Centerpoint | PDF
  • Office of Utility Consumer Counselor (OUCC) | PDF

Preliminary Areas of Discussion & Comments Due by June 5, 2020

In its first round of discussions, Commission staff identified two general areas of focus, with more specific items for consideration under each area. These areas, as well as comments submitted by the June 5, 2020, deadline, can be found below.

Improve the information provided in initial filings and petitions to ensure better education and background on issues being presented

  • Detail needed in case-in-chief and direct testimony: Getting more information up front, rather than waiting for rebuttal
  • Improved pilot program requests: Creating standard for information necessary in pilot program requests
  • Amendment to 170 IAC 1-5 Minimum Standard Filing Requirements, or MSFRs (likely including changing the name of the rule): Updating MSFRs to reflect Ind. Code ยง 8-1-2-42.7 requirements and options (such as forward-looking test year) and evaluating current MSFRs for outdated requirements

Improve the organization of information in docketed cases to ensure consistency from all parties

  • Indexing of issues: Providing indexes of all issues addressed in petitions, direct testimony, and rebuttal
  • Consistent accounting schedules: Adopting a standard IURC presentation for select rate accounting schedules
  • Proper proposed orders: Drafting proposed orders consistent with the record and from the Commission's perspective

This list was only preliminary; the Commission invited all interested stakeholders to provide additional items that they believe should be considered by the Commission. They did not necessarily have to fall into the above two categories; that is just how Commission staff had organized current suggestions.

Comments that were received in the first round of feedback can be found below:

  • Citizens Action Coalition (CAC) | PDF | Excel spreadsheet
  • Duke Energy Indiana, Indianapolis Power & Light (IPL), Vectren Energy Delivery, and Citizens Energy Group Joint Comments | PDF
  • Indiana American Water Company | PDF
  • Indiana Michigan Power Company (I&M) | PDF
  • Indiana Office of Utility Consumer Counselor (OUCC) | PDF | Supplement | Water/Wastewater | Natural Gas | Electric
  • Northern Indiana Public Service Company (NIPSCO) | PDF