OGE
Published on 05/19/2025 at 16:43
IN THE MATTER OF THE APPLICATION OF )
OKLAHOMA GAS AND ELECTRIC COMPANY ) Case No. PUD2025-000038 FOR COMMISSION PREAPPROVAL OF NEW )
GENERATION CAPACITY PURSUANT TO ) 17 O.S. § 286(C) AND RIDER COST RECOVERY )
Direct Testimony of
Gwin Cash on behalf of
Oklahoma Gas and Electric Company
May 19, 2025
Direct Testimony of Gwin Cash Page 1 of 5
Gwin Cash
Direct Testimony
Q. Please state your name, position, by whom you are employed, and your business
A. My name is Gwin Cash. I am the Manager of Pricing and Rate Administration for
Oklahoma Gas and Electric Company ("OG&E" or "Company"). My business address is
321 N. Harvey, Oklahoma City, Oklahoma, 73102.
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Q. Please summarize your professional qualifications and educational background.
A. I have worked for OG&E in various capacities for over 21 years. I joined the Company's
regulatory department in January 2015 as the Rate Administration Manager and in July of
2017 I assumed additional responsibilities as the manager of Cost of Service. In May of
2023 I became the manager of Pricing and Rate Administration. My Pricing
responsibilities include oversight of the department's development of rates and charges in
the Company's retail electric tariffs. My Rate Administration responsibilities include
maintaining OG&E's tariffs on file with the regulatory commissions and ensuring
consistent application of these tariffs in the manner in which they are intended. Additional
duties include computing rider factors and monthly retail revenue reporting. Prior to
joining OG&E's regulatory department, I worked as a Senior Business Analyst in OG&E's
Sales and Customer Support department and as a Workforce Analyst in OG&E's Customer
Service department. I received a Bachelor of Science in Applied Mathematics with a
Specialization in Computing from the University of California, Los Angeles in 1999. 21
Q. Have you previously testified before the Oklahoma Corporation Commission
A. Yes. I have testified before the OCC in the following Cases: PUD 2023-000087, PUD
25 2023-000038, PUD 2021-000164, PUD 2021-000072, PUD 2020-000021, PUD 2018-
000140, PUD 2017-000496, and PUD 2015-000273. I have also testified in multiple cases
before the Arkansas Public Service Commission.
Q. What is the purpose of your testimony?
A. The purpose of my testimony is to support updates to the Generation Capacity Rider that
will accommodate the specific capacity resources requested in this Case. 4
Q. Please give a brief overview of this tariff.
A. This tariff, named the Generation Capacity Rider ("GCR") was previously approved in
Case No. PUD 2023-000038 and currently allows for recovery of Company-owned
capacity projects approved by the Commission. 9
Q. What updates to the GCR is the Company proposing at this time?
A. The Company is requesting to update the GCR to allow for cost recovery of the following
additional items:
construction work in progress ("CWIP") and recovery of the annual revenue
requirement for new natural gas fired generation capacity projects,
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Q.
In what sections of the GCR tariff are the updates reflected?
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A.
These changes necessitated updates to the PURPOSE, TERM, and GCR FACTOR
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CALCULATION sections. These changes to the tariff can be viewed in Exhibit GC-1 and
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a clean version of the tariff is attached as Exhibit GC-2.
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Q.
Please summarize the updates to the PURPOSE section of the GCR rider?
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A.
The PURPOSE section was updated to reflect the Company's request for additional cost
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recovery items in this case, specifically the request for CWIP, the request for CPA costs,
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and the request for a return on each CPA.
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Q.
Please summarize the updates to the TERM section of the GCR rider?
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A.
The TERM section was updated to clarify the different term lengths for the different cost
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items requested for recovery. For Company-owned natural gas-fired generation capacity
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projects, recovery of CWIP will commence the first billing cycle of the month after the
capacity purchase agreement ("CPA") payments, and
return on the CPAs.
Commission authorizes the GCR. Recovery of CWIP will continue (with annual factor
updates to reflect increasing CWIP) until such time that the natural gas-fired generation
capacity projects are placed in service, at which time recovery of CWIP will cease and the
GCR will begin recovery of the annual revenue requirement for the Company-owned
natural gas generation facilities. Recovery of the annual revenue requirement will continue
until the natural gas-fired generation capacity projects are included in base rates. The
recovery term was updated to begin as soon as the amended GCR is approved to reflect
CWIP recovery. The cost recovery term length of Company owned facilities will remain
unchanged.
Additionally, the TERM section is updated to reflect that cost recovery of CPA
contracts, including a return, will begin and end with the term of the CPA contracts.
OG&E is not proposing any changes to the recovery of Horseshoe Lake units 11 &
12. OG&E has added language to clarify the distinction between what was approved by
the Commission for Horseshoe Lake units 11 & 12 in Case No. PUD 2023-000038 and
what is being requested in this case for Horseshoe Lake units 13 & 14. 16
Q. Please summarize the updates to the GCR FACTOR CALCULATION section of the
A. This section provides the formula that is the calculation of the GCR factors themselves. In
this formula the description of the Oklahoma Jurisdiction GCR Annual Revenue
Requirement component was updated to include the additional cost items requested. 22
Q. Are there any other updates to the GCR rider?
A. There is one minor, yet noteworthy, item to be discussed. As recovery has not yet begun
through the GCR rider the Company does not consider it as having become effective,
although already having been previously authorized by the Commission in a previous Case.
Therefore the Company is proposing to continue to reflect the rider sheets as Original
instead of first revised.
Q. What is your recommendation to the Commission?
A. I recommend the Commission approve the updates to "PURPOSE," "TERM," and "GCR
FACTOR CALCULATION" sections of the GCR tariff that reflect the Company's request
for recovery of the additional cost items associated with new natural gas fired generation
capacity projects (both CWIP recovery and the inclusion of the annual revenue requirement
after the units are placed in service), and the CPA contracts including a return on those
contracts.
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Q. Does this conclude your testimony?
A. Yes.
Disclaimer
OGE Energy Corporation published this content on May 19, 2025, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 19, 2025 at 20:42 UTC.