[{"_1":2,"_87":-5,"_88":-5},"loaderData",{"_3":4,"_26":27},"root",{"_5":6,"_17":10,"_18":19,"_20":21,"_22":10,"_23":-5,"_24":-5,"_25":10},"user",{"_7":8,"_9":10,"_11":10,"_12":-5,"_13":-5,"_14":15,"_16":-5},"roles",[],"isAuthenticated",false,"isPremium","planName","subscriptionStatus","featureFlags",{},"insightsBudget","isDevelopmentHost","userPreferences",{},"recaptchaSiteKey","6LcvOJcUAAAAAHsB-gPGfGktcRlKpH7OTIU_dMTD","isImpersonating","impersonation","affiliateStatus","isFreedomPortal","routes/v2/article/layout",{"_28":29,"_30":31},"notFound",true,"relatedArticles",[32,75],{"_33":34,"_35":36,"_37":38,"_39":40,"_41":42,"_43":44,"_45":46,"_47":48,"_49":50,"_51":52,"_53":54,"_55":56,"_57":58,"_59":60,"_61":62,"_63":64,"_65":66,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},"mediaId",6195044,"mediaKeyId","3862924-6ed9c493b934c4392d9fc341ee1c439a","parentId",3862924,"title","Company witness: weaker commercial sales and delayed oil-and-gas electrification drove 2024 forecast miss","audioSeconds",4004,"startMs",2642000,"endMs",6646000,"viewUrl","/Search/View?dp=1&key=3862924-6ed9c493b934c4392d9fc341ee1c439a&start=2642&end=6646","thumbnailUrl","https://assets.pipeline.soar.com/3862924-6ed9c493b934c4392d9fc341ee1c439a/thumbnail_2642000.jpg","articleUrl","/articles/6195044/Colorado/Company-witness-weaker-commercial-sales-and-delayed-oil-and-gas-electrification-drove-2024-forecast-miss","mediaUrl","https://secure.pipeline.soar.com/6195044-d804ed1e0e9f692114da5d137e763b21/orig.mp4?Expires=1771063112&Signature=Vf2XyQW~7hZiFzvbHkG5HqrZ5BBHzvLJT3R~4lf8veJpSvCLY2peLBxNowEmM7sDHf7T2ZV4tKCLUSiOqsjwcG46H5W~732Cl7D~X7G5jWSvKeylXcAQb8nbsC2QOnvFWuAigj~JHP2IpNikJCOiQtgP9-4L5Qw7FSlirpITYNb-LSKTOlIesmP0WqGEELmYVP0eJ7YOwiNPmD~-KzJ~udX~i2ColO5DwOM5deYPCd1ZiUppQP94IaXFhk9TtM~NRCZy~RHY6DLtHPFnuLWGmDe3orBQmoK16zJw838nH7x2L1Ustvbe~0alSHdrttQSuWfr28-COSsuSbDzFaWWqg__&Key-Pair-Id=KUT5TJCACFTXG","author","","date","2025-06-19T01:12:40Z","article","Mister Goodenough, the company's forecasting witness, told the Public Utilities Commission he believes a shortfall in commercial sales and delayed oil-and-gas electrification explain why 2024 retail energy growth was lower than the company's earlier forecast.

\"There really were, a couple of drivers in 2024. The first was, quite based on weakness in commercial sales that we had not expected, when we developed the JTS forecast...and then we had also projected, the beginning of oil and gas electrification to in 2024 that did not materialize in 2024,\" Mister Goodenough said during cross-examination.

The discrepancy matters because the company uses its base load forecast as an input to resource planning, requests for proposals and reliability studies. Commissioners and intervenors pressed the witness about how short-term variance changes longer-term resource needs and the implication for ratepayer costs.

Goodenough said the company's technical appendix projected 2024 retail energy growth of 1.4 percent, while the utility's Q4 2024 public numbers showed weather- and leap-year-adjusted electric sales growth of minus 0.7 percent. He attributed most of the difference to (1) weaker-than-expected small commercial sales and (2) planned oil-and-gas electrification that did not begin in 2024.

The witness also outlined the utility's assumptions on electric vehicles and charging behavior, describing the EV forecast and the way managed charging shapes were treated in modeling. Goodenough said the company counts about 140,000 EVs in its territory at the end of 2024 and that the registration data include both plug-in hybrids and full battery EVs. \"It does,\" he said when asked whether the EV count included plug-in hybrids.

On adoption scenarios, Goodenough testified the company's high-case EV scenario is developed by the risk team and is incorporated into the base forecast. He gave the high-case magnitude for the company's territory as roughly 830,000 vehicles by 2031. He also testified that residential electrification projected in the forecast for 2024 did not materialize to the expected extent.

Managed charging and peak impact

Goodenough explained how the company modeled managed charging. The company used observed behavior from its customers enrolled in a charging-perks program as a basis for a managed shape; that shape, he said, can be peakier than unmanaged charging because many enrolled customers begin charging at the same window start. \"The one thing I'll note on here is that that is the only, shape on this graph that is actually based on actual data, because it is the customers that are enrolled in our charging perks program,\" he said.

To avoid a scenario in which unmanaged or incentive-driven charging causes EVs to set system peak hours, the company applied a \"trunching\" approach: when EV charging begins to drive the system peak, the forecast shifts charging into different hours to mimic how future rate or program changes might move load. Goodenough said the company currently models roughly 10 percent of EV customers in managed charging (an increase from an earlier 5 percent assumption), ramping later in the decade to a substantially higher share; the company used a simplified tranche approach rather than an optimized, highly dynamic managed-charging model.

Forecast details and numbers mentioned on the record

- Company technical appendix projected 2024 retail energy growth of 1.4 percent; company Q4 2024 adjusted sales showed -0.7 percent.
- The utility's EV registration count at end of 2024: described as roughly 140,000 (including plug-in hybrids).
- Company high-case EV adoption cited in testimony: roughly 830,000 vehicles in the service territory by 2031 (Goodenough described that as \"on par with the governor's EV goals\").
- Typical vehicle miles per year used in modeling: roughly 12,000 miles per vehicle (the witness said the number is based on US DOT estimates rather than EV-specific data).
- Oil-and-gas electrification cited as a notable future driver of load that did not materialize in 2024; the witness described several large-customer categories (data centers, strategic economic development customers) separately.

On uncertainty and modeling updates

Goodenough said the company plans a full forecast update before phase 2 of the resource solicitation process and again before a supplemental RFP. \"The intent is for that to be a full forecast update,\" he testified, describing updates to history, economic outlook and tax-policy assumptions. He told commissioners the forecast update will incorporate new information about large loads and tax policy changes if those are known in time.

Commissioners pressed him about how forecast assumptions would be shared and whether stakeholders could see updated inputs before the company used them to set procurement or RFP timing; Goodenough said timing and stale assumptions are a concern but acknowledged mechanisms exist to include updated assumptions in subsequent modeling steps.

Exhibits and evidentiary items

Parties stipulated to admission of several exhibits during the session: UCA exhibits 3-14 and 3-15 were offered and admitted as discovery responses, and company exhibits including model ESA and interconnection agreement files (referred to on the record as exhibits 137 and 138) were produced in discovery and discussed by counsel.

Why this matters

Forecast variance affects reserve-planning assumptions, the timing and sizing of solicitations for new resources, and potential near-term resource adequacy positions. Commissioners repeatedly pressed forecasting staff about how much of the 2024 variance reflects short-term timing versus a durable change in economic or electrification trends and whether those shifts should change procurement schedules.

Ending

Goodenough told the commission he and the company would make further forecast updates and could incorporate commission direction about EV adoption or charging patterns into the next forecast refresh. He and other witnesses said some supplemental technical materials (including a highly-confidential table identifying large-customer ramps) were available to commissioners and parties under protective orders and could be used in the upcoming forecast work.","mediaType","Video","parentTitle","24A-0442E, Public Service Company - 2024 JTS - 06.18.25 - HRA (6 of 9)","oneSentenceSummary","Mister Goodenough, the company's forecasting witness, said weaker-than-expected commercial sales and delayed oil-and-gas electrification explain why 2024 retail energy growth fell well short of the company's earlier projection, testimony at a Public Utilities Commission hearing showed.","taxTitle","Public Utilities Commission, Governor's Boards and Commissions, Organizations, Executive, Colorado","taxId",28165,"location","Colorado","headline","shortSummary",{"_33":76,"_35":36,"_37":38,"_39":77,"_41":78,"_43":79,"_45":80,"_47":81,"_49":82,"_51":83,"_53":84,"_55":56,"_57":58,"_59":85,"_61":62,"_63":64,"_65":86,"_67":68,"_69":70,"_71":72,"_73":56,"_74":56},6195038,"Company witness: will use agreed \"commercial principles\" and file large-load tariff by Jan. 31, 2026",4349,6864000,11213000,"/Search/View?dp=1&key=3862924-6ed9c493b934c4392d9fc341ee1c439a&start=6864&end=11213","https://assets.pipeline.soar.com/3862924-6ed9c493b934c4392d9fc341ee1c439a/thumbnail_6864000.jpg","/articles/6195038/Colorado/Company-witness-will-use-agreed-commercial-principles-and-file-large-load-tariff-by-Jan-31-2026","https://secure.pipeline.soar.com/6195038-b9a02d6429adaee36344b0a3875e20e5/orig.mp4?Expires=1771063112&Signature=Z1BUxruUhXQuZ73xStonZHbUUuaovcHGd7GImxrZz7p6~Hc8wz8CVPQai3bXGaqOohJuwWL4u6tkPnQbPbG0-qOMuXSGvr6~ZkkW4PN1QmSsHzIg8Kl9UH-7Y9HTx6pStoQoyx-FOLLAVLs8zpRQsnazVOXyGCgNdz8j0mhexvhVN0sFvbLDRwBPtNNZRkp6TUdq9MMDb-HVyH~ZlISG5pFFse2sWUCrZIu53kYnytIC1IEYtEcJe-EIoGmsDBUQa8zTTbTmqHvH82oifoCGpHv7sc6DNTzqOOhLqHJ3~izb8HzlF1wRKLvgAEAekuctBzcl84PqSRUfGEH~wm9Lcg__&Key-Pair-Id=KUT5TJCACFTXG","Thomas L. Bailey, the company's area vice president for commercial and industrial solutions, told the Public Utilities Commission the utility will apply a set of \"large load commercial principles\" in negotiations with major customers and will file a large-load tariff no later than Jan. 31, 2026, under a tri-party framework discussed on the record.

\"We will use utilize the principles that I outlined, in in my testimony,\" Bailey said when asked whether the company intended to follow the commercial principles described in his rebuttal. He added the company will use those principles while continuing to negotiate commercially with customers in an \"interim period\" before a formal tariff is in place.

What the company told commissioners

Bailey described three strands of the company's large-load strategy: (1) a two-stage RFP process intended to match generation to incremental need, (2) an updated base forecast that incorporates large-customer ramps, and (3) commercial principles and procedural recommendations the company intends to implement now and fold into a future tariff. On the timing question, Bailey confirmed the tri-party framework captured on the record directs the company to file a large-load tariff by Jan. 31, 2026.

The commercial principles Bailey summarized (listed in his rebuttal testimony and displayed in a table on the record) include requirements such as higher interconnection deposits, exit fees or contract minimums, securitization or other financial commitments, and commercial flexibility in negotiations. Bailey said the objective is to \"ensure that new large load customers have sufficient skin in the game\" to reduce the risk that the utility would procure generation for speculative or non‑materialized load.

Strategic economic development customers and forecast inclusion

Bailey said the company's updated base forecast includes two categories of large loads: (1) data centers and other large customers that the company considers highly likely to connect; and (2) a set the company calls \"strategic economic development customers,\" which are current or nearby customers whose expansion the company believes is likely. He said the forecast includes the entire quantity the customers requested (the forecast figures were provided in confidential material on the record).

On the question of thresholds, Bailey and several commissioners discussed whether a \"large-load\" threshold should be 100 megawatts, 75 megawatts or another level; Bailey declined to accept UCA's proposal to lower the threshold to 75 megawatts on the record, saying he would not agree to that specific change.

Contracts, evidence and tariff transition

Bailey described how the company expects to use electric service agreements (ESAs) and interconnection agreements (IAs) to formalize customer commitments. He said many large customers have signed an IA and that ESAs will incorporate the commercial principles during the interim negotiation period. He also said the company is not planning to \"grandfather\" existing customers into the new tariff framework for new expanded load requirements and that customers signing ESAs now would be expected to adhere to applicable tariff rates.

On risk allocation, intervenors repeatedly asked who bears the financial risk if the utility procures generation for an expected large customer and the customer withdraws or moves projects to another jurisdiction. Bailey said commercial provisions such as exit fees, upfront payments and other contract terms are designed to mitigate that risk but acknowledged there is not a complete transfer of all risk away from ratepayers in every scenario.

Why this matters

The tri-party framework placed on the record and Bailey's testimony define a transition path for how the utility will match generation procurement to large-customer demand, how financial commitments and protections will be structured, and when a formal tariff will be proposed. Those issues affect who pays for transmission and generation upgrades, how quickly customers can come online and the timing of future procurements.

Ending

Bailey said company staff are negotiating with customers now and will continue to do so in the interim period, and the company will file its large-load tariff no later than Jan. 31, 2026, as contemplated in the tri-party framework. Commissioners and intervenors signaled they will press on thresholds, cost-allocation and contract transparency as that tariff and associated filings move forward.","At the Public Utilities Commission hearing Thomas L. Bailey, the utility's area vice president for commercial and industrial solutions, said the company plans to use a set of commercial principles when negotiating large-customer contracts, will pursue an incremental need pool and expects to file a large-load tariff by Jan. 31, 2026; commissioners","actionData","errors"]

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Company witness: weaker commercial sales and delayed oil-and-gas electrification drove 2024 forecast miss

Company witness: will use agreed "commercial principles" and file large-load tariff by Jan. 31, 2026