[il_npa] Draft v1 and updates to context/ by griffinsharps · Pull Request #159 · switchbox-data/reports2

griffinsharps · 2026-04-29T18:59:19Z

This branch contains the first draft of the il_npa memo (soon to be used as the skeleton for expert testimony) as well associated updates to context/. The latter are meant to assist in providing Illinois-specific context for agentic work on this project.

…bility table

jpvelez · 2026-04-29T19:44:36Z

+
+## Verification status
+
+This document combines outputs from three NotebookLM queries (run 2026-04-29) with targeted spot-check verification as well as Claude Opus 4.7 web research against the cited source PDFs.


jpvelez · 2026-04-29T19:44:54Z

+
+PGL's request has three layers.
+
+1. The headline rate increase, which would flow through to customer bills as both higher fixed monthly charges (the residential heating customer charge would rise from about $25.81 to $29.36) and higher per-therm volumetric charges.


How is the volumetric rate changing?

jpvelez · 2026-04-29T19:46:18Z

+
+1. The headline rate increase, which would flow through to customer bills as both higher fixed monthly charges (the residential heating customer charge would rise from about $25.81 to $29.36) and higher per-therm volumetric charges.
+2. Approval of the pipe retirement program itself.
+   - Its scope (about 1,020 miles of pipe across 179 distinct projects)


Is this all remaining miles? How does it compare with the figure I use in my deck of remaining miles?

If it is all remaining miles, does this mean 179 projects = all remaining projects have been planned already?

jpvelez · 2026-04-29T19:47:52Z

+1. The headline rate increase, which would flow through to customer bills as both higher fixed monthly charges (the residential heating customer charge would rise from about $25.81 to $29.36) and higher per-therm volumetric charges.
+2. Approval of the pipe retirement program itself.
+   - Its scope (about 1,020 miles of pipe across 179 distinct projects)
+   - Its pacing through 2035


Curious to see this. Do they have a table that says what percent they're doing each year, or any data that coudl be turned into such a percent-by-year table?

jpvelez · 2026-04-29T19:48:35Z

+2. Approval of the pipe retirement program itself.
+   - Its scope (about 1,020 miles of pipe across 179 distinct projects)
+   - Its pacing through 2035
+   - Its proposed funding through ordinary base rates rather than through the standalone surcharge mechanism that funded the predecessor program.


Oh does this mean they killed the cost-tracker / rider? Was that part of the investigation order?

jpvelez · 2026-04-29T19:51:07Z

+PGL's request has three layers.
+
+1. The headline rate increase, which would flow through to customer bills as both higher fixed monthly charges (the residential heating customer charge would rise from about $25.81 to $29.36) and higher per-therm volumetric charges.
+2. Approval of the pipe retirement program itself.


I didn't realized this was on the table. This is going to be our main hook that, since the design and approval of the program is still up for grabs.

jpvelez · 2026-04-29T19:51:43Z

+
+PGL justifies the increase in 4 ways.
+
+1. The largest is regulatory compliance: a 2024 state order requires the company to retire all old cast and ductile iron pipe under Chicago by 2035, and PGL frames the pipe retirement program as the only realistic path to meet that deadline.


Is this the investigation order?

Also, do they outright say that they don't expect any meaningful levels of alternatives like pipe lining, repair, and targeted electrification?

jpvelez · 2026-04-29T19:53:03Z

+1. The largest is regulatory compliance: a 2024 state order requires the company to retire all old cast and ductile iron pipe under Chicago by 2035, and PGL frames the pipe retirement program as the only realistic path to meet that deadline.
+2. Safety: PGL describes the existing pipe as "more than 100 years" old in many cases, and characterizes the leak risk as "imminent."
+3. Cost growth: PGL forecasts its day-to-day operating costs to grow about 5.4% per year through 2027 — faster than projected inflation of about 3% — driven primarily by rising contractor and insurance prices.
+4. PGL itself projects that residential gas sales on its system will fall nearly 5% by 2027 versus 2024, which leaves the company under-collecting under its current rate structure unless the Commission resets rates upward. This fourth point is doubly useful for our case because PGL is acknowledging on the record that demand on its system is contracting.


This is a huge deal. This is the start of the death spiral.

jpvelez · 2026-04-29T19:54:27Z

+3. Cost growth: PGL forecasts its day-to-day operating costs to grow about 5.4% per year through 2027 — faster than projected inflation of about 3% — driven primarily by rising contractor and insurance prices.
+4. PGL itself projects that residential gas sales on its system will fall nearly 5% by 2027 versus 2024, which leaves the company under-collecting under its current rate structure unless the Commission resets rates upward. This fourth point is doubly useful for our case because PGL is acknowledging on the record that demand on its system is contracting.
+
+The picture on the other side of the case is incomplete at this stage. Nine third-party organizations have filed petitions to intervene. These establish their right to participate but do not yet contain substantive arguments. Those come later in pre-filed intervener testimony that has not yet been submitted in this docket. The intervening parties span residential customer advocacy (CUB), low-income and poverty advocacy (Legal Action Chicago), environmental groups (Environmental Law and Policy Center, Environmental Defense Fund, Illinois PIRG), industrial customers (Illinois Industrial Energy Consumers), commercial real estate (Building Owners and Managers Association of Chicago), labor (a local of the Utility Workers Union of America representing ~1,000 PGL employees), and competitive gas suppliers (Retail Energy Supply Association). Statutory parties (the Illinois Attorney General and the Commission's own Staff) have automatic standing to participate without filing a petition. The City of Chicago (which participated heavily in the prior PGL rate case) may yet appear as well. Until intervener testimony is filed, the substantive arguments these parties will raise are not visible.


Does this mean that intervenors don't have to say what issues they want to intervene about in their petitions to intervene?

jpvelez · 2026-04-29T20:14:10Z

+
+| Driver                                                    | Value  | Source page |
+| --------------------------------------------------------- | ------ | ----------- |
+| Pipe Retirement Program (first tranche)                   | $38.8M | p. 18       |


So this would be on top of the $360M in Total PRP spending they forecast for 2027? Or would this be the shortfall within that $360M?

jpvelez · 2026-04-29T20:16:15Z

+| Project regions                                   | North, Central, South                                                    | part13of15.pdf p. 114      |
+| Total PRP spending — 2026                         | ~$214M                                                                   | part1of15.pdf p. 13        |
+| Total PRP spending — 2027                         | ~$360M                                                                   | part1of15.pdf p. 13        |
+| Project-level spending — 2026 (excl. contingency) | ~$188.0M                                                                 | part13of15.pdf pp. 106–107 |


Still curious about the timing of this: when will the 1,020 miles of new pipe be done by? Presumably not 2027? If so, when is the forecasted spending for years after 2027?

jpvelez · 2026-04-29T20:24:00Z

+
+The single most strategically important sentence in PGL's filings, found in the Graves/Figueroa/Sreenath testimony, opens a sequenced argument for why decarbonization-oriented proposals cannot be entertained in this rate case:
+
+> "First, we believe it is neither feasible nor realistic for PGL to present material resource or service design plans in the current rate case that call for decarbonization or that would affect the execution of the PRP in 2027 or beyond in a cost-effective manner." (PART_5 part1of68.pdf p. 8 — verbatim verified)


lol wtf does this even mean

jpvelez · 2026-04-29T20:28:05Z

+| ------------------------------------------ | -------- | -------- |
+| SC-1 Non-Heating customer charge (monthly) | $18.57   | $21.12   |
+| SC-1 Heating customer charge (monthly)     | $25.81   | $29.36   |
+| Distribution charge (per therm)            | $0.18671 | $0.21488 |


Clarification: the way they do their heating vs. non-heating rates is via the fixed charge? Both groups have the same volumetric? (I ask cause everywhere else I've seen heating gas rates, it's done through volumetric.)

jpvelez · 2026-04-29T20:30:24Z

+
+## Open items and follow-ups
+
+- Pull the rest of the Graves/Figueroa/Sreenath sequenced argument. The "First, we believe..." quote in Section 3 is item one of a multi-part argument; items two and beyond are the rest of PGL's case for foreclosing decarbonization-oriented proposals. Open PART_5 part1of68.pdf and pull the subsequent paragraphs.


Yes let's quote all of it and see some evaluation of what they're up to here.

Updated terminology and clarified analysis on cost-effective electrification opportunities within the PRP scope, emphasizing the importance of density and hydraulic feasibility in decision-making.

…r in the wrong branch

…ta/reports2 into il_npa-report-draft

…gy section + chart refactor)

…ock chunks

… and a few other tweaks.

- Split 179 Phase I projects from 1,020-mile retirement directive in §II, §III, §VI, and §X (179 are the projects PGL filed in this rate case; 1,020 is the Commission's full retirement scope through 2034). - Replace SMP-derived $4.96M/mile replacement-cost citation with the rate-case-derived figure now in the cost-assumptions sheet: $4.318B PRP capital trajectory (Eidukas, NSG-PGL Ex. 1.0 at 5-6) divided by ~1,020 miles (Eldringhoff/Dickson, NSG-PGL Ex. 3.0 at 8) ~= $4.23M/mile. Rename footnote smp-replacement-cost -> prp-replacement-cost. Decommissioning footnote unchanged (still SMP-derived). Co-authored-by: Cursor <cursoragent@cursor.com>

Rewrite the Pipeline Replacement Program (PRP) cost-per-mile prose and the [^cost-per-mile] footnote to reflect the rate-case-derived $4.23M/mile figure now in the cost-assumptions sheet: - Numerator: $4.318B PRP capital trajectory through 2034 from Eidukas direct testimony, NSG-PGL Ex. 1.0 at 5-6. - Denominator: ~1,020 miles from the Commission's retirement directive, Eldringhoff/Dickson direct testimony, NSG-PGL Ex. 3.0 at 8. Drop the now-orphaned [^program-3] footnote (was specific to the SMP's Program Option 3 derivation, which we no longer use). Co-authored-by: Cursor <cursoragent@cursor.com>

The §V single-block walkthrough cited 0.17 mi of "mains in PRP scope" for the East 87th Place example block from a hardcoded `sample_total_pipe = 0.1726` (commented "both-sides total length on this block"). That value was actually 2 × the per-block street_miles allocation — not a measured length — and under-counted the actual street centerline by ~10%. Verified against streets_in_construction.geojson (UTM 16N): the street centerline running along the block's borders is 0.195 mi (E 87th Pl 0.125 + S Langley 0.021 + S St Lawrence 0.040), which matches the 0.19 mi label baked into street_outline.png. Update the hardcoded value to 0.1949 with provenance, and reframe the caption, the walkthrough prose, and the figure-inventory entry so the number is honestly described as miles of street centerline used as a proxy for miles of CI/DI gas main beneath the streets (per notebooks/geo_data_cleaning.qmd). Downstream cost numbers (sample_prp_cost, sample_attributed_pipe ≈ 0.086 mi) come from sample_block\$street_miles in the data and are unaffected. Co-authored-by: Cursor <cursoragent@cursor.com>

The two single-block walkthrough chunks (fig-single-block-eg and fig-single-block-eg-ss) hardcode total_pipe_touching for the East 87th Place example block. The value was 0.1726 — actually 2 × the per-block street_miles allocation, not a measured length — and under-counted the actual street centerline by ~10%. Verified against streets_in_construction.geojson (UTM 16N): the street centerline running along the block's borders is 0.195 mi (E 87th Pl 0.125 + S Langley 0.021 + S St Lawrence 0.040). Update both occurrences to 0.1949 with a provenance comment that points back to geo_data_cleaning.qmd's street-miles-as-pipeline-proxy methodology, mirroring the testimony fix in 6e6a7c7. Note: total_pipe_touching only flows into total_prp_cost_ex, which is not used in either rendered chart (the bars use prp_cost from data), so the figure outputs are unaffected by this fix. Co-authored-by: Cursor <cursoragent@cursor.com>

Adds `just draft --testimony` flag and supporting infrastructure (lib/just/draft.py, lib/just/templates/) that renders ICC-style expert testimony: Times New Roman 12pt, double-spaced body, line numbering with per-section restarts, witness header, static TOC, Q/A styling with multi-paragraph continuation indent, and figure labels with witness initials (e.g. "Figure JPV-1"). Pins the il_npa analysis notebook's showtext DPI to 96 so chart labels render at the intended size on Quarto's 96-DPI chart device (the shared theme leaves it at 300 for retina raster output, which oversized every label by ~3x in the DOCX render). Adds reports/il_npa/working_draft_testimony_docx1.qmd as the working testimony draft for the ICC 26-0065/26-0066 docket. Co-authored-by: Cursor <cursoragent@cursor.com>

…ta/reports2 into il_npa-report-draft

Appends the Data and Methods content from index.qmd to the working draft testimony as CUB Ex. 1.2 - Analysis Methodology, filling the exhibit slot already declared in the Section II exhibit list. The methodology covers data sources, geospatial preprocessing, cost calculations (PRP, NPA, grid upgrades, decommissioning, scattershot), and analysis assumptions. Co-authored-by: Cursor <cursoragent@cursor.com>

…ta/reports2 into il_npa-report-draft

Griffin Sharps added 3 commits April 26, 2026 16:26

Fix table 1 footnote; rotate Figure 2 axis labels; shrink data availa…

f951911

…bility table

Add il_pgl_rate_case context files; update README

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[il_npa] Memo draft v1

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griffinsharps self-assigned this Apr 29, 2026

griffinsharps requested a review from jpvelez April 29, 2026 18:59

[il_npa] Corrected il_pgl_rate_case directory location to sources/

6c65af2

jpvelez reviewed Apr 29, 2026

View reviewed changes

Comment thread context/sources/il_pgl_rate_case/curtain_raise_pgl_rate_case.md

jpvelez reviewed Apr 29, 2026

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jpvelez and others added 9 commits April 29, 2026 22:09

LLM generation of ask and argument

015a452

Refine analysis on electrification cost-effectiveness

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Updated terminology and clarified analysis on cost-effective electrification opportunities within the PRP scope, emphasizing the importance of density and hydraulic feasibility in decision-making.

[il_npa] Figures to distillation document and expert sources to context

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[il_npa] Distillation doc updated, sources updated

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[il_npa] testimony skeleton

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Random WA back of the envelope analysis stored in the wrong report di…

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…r in the wrong branch

Merge branch 'il_npa-report-draft' of https://github.com/switchbox-da…

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…ta/reports2 into il_npa-report-draft

[il_npa] pull analysis.qmd from 163-il_npa-methods-section (methodolo…

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…gy section + chart refactor)

[il_npa] analysis.qmd: 1020-mile PRP total + fig- prefix on single-bl…

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…ock chunks

Griffin Sharps and others added 28 commits May 3, 2026 15:04

[il_npa] analysis.qmd: fix caption on fig-prp-spending-by-year-all

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[il_npa] add working draft testimony

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[il_npa] analysis.qmd: fix caption on fig-prp-spending-by-year-all

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[il_npa] testimony full draft

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[il_npa] testimony full draft v2.0 updates to citations and variables…

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… and a few other tweaks.

[il_npa] img folder with updates

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Merge branch 'main' into il_npa-report-draft

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Pin pandas 2.X to unbreak il_npa geo work

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Add exert testimony to render list

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Add brs to expert testimony

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Edit through Section III

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Crop imgs

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Add citywide projects img

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WIP testimony

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WIP testimony

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Add figures to Appendix 1

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[il_npa] updated Justfile

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Copy edot

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Merge branch 'il_npa-report-draft' of https://github.com/switchbox-da…

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…ta/reports2 into il_npa-report-draft

[il_npa] updated citations

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Update neighborhood maps

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Merge branch 'il_npa-report-draft' of https://github.com/switchbox-da…

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…ta/reports2 into il_npa-report-draft


		## Verification status

		This document combines outputs from three NotebookLM queries (run 2026-04-29) with targeted spot-check verification as well as Claude Opus 4.7 web research against the cited source PDFs.


		PGL's request has three layers.

		1. The headline rate increase, which would flow through to customer bills as both higher fixed monthly charges (the residential heating customer charge would rise from about $25.81 to $29.36) and higher per-therm volumetric charges.


		PGL justifies the increase in 4 ways.

		1. The largest is regulatory compliance: a 2024 state order requires the company to retire all old cast and ductile iron pipe under Chicago by 2035, and PGL frames the pipe retirement program as the only realistic path to meet that deadline.


		The single most strategically important sentence in PGL's filings, found in the Graves/Figueroa/Sreenath testimony, opens a sequenced argument for why decarbonization-oriented proposals cannot be entertained in this rate case:

		> "First, we believe it is neither feasible nor realistic for PGL to present material resource or service design plans in the current rate case that call for decarbonization or that would affect the execution of the PRP in 2027 or beyond in a cost-effective manner." (PART_5 part1of68.pdf p. 8 — verbatim verified)


		## Open items and follow-ups

		- Pull the rest of the Graves/Figueroa/Sreenath sequenced argument. The "First, we believe..." quote in Section 3 is item one of a multi-part argument; items two and beyond are the rest of PGL's case for foreclosing decarbonization-oriented proposals. Open PART_5 part1of68.pdf and pull the subsequent paragraphs.

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griffinsharps commented Apr 29, 2026

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