Control N mber: Item Number: 136. Addendum StartPage: 0

Transcription

1 Control N mber: Item Number: 136 Addendum StartPage: 0

2 PUC DOCKET NO SOAR DOCKET NO DEC -9 Pil 2: 3 7 JOINT REPORT AND APPLICATION OF ONCOR ELECTRIC DELIVERY' COMPANY LLC AND NEXTERA ENERGY, INC. FOR REGULATORY APPROVALS PURSUANT TO PURA , AND FHLif, UiILiÏÏ EUNG CLERK BEFORE THE PUBLIC UTILITY COMMISION 'OF TEXAS ONCOR ELECTRIC DELIVERY COMPANY LLC'S STATEMENT REGARIMNG PROTECTED MATERIALS FOR COMMISSION STAFF'S SECOND REQUESTS FOR INFORMATION Oncor Electric Delivery Company LLC (Oncor" or "Company") submits this Statement Regarding Protected Materials for Commission Staff s Second Requests for Information ("Statement"). I. On November 29, 2016, Commission Staff (Staff") filècl its Second Requests for Information ("RFIs") to Oncor. In response to Staff RFI 'Set No. 2, Question Nos. 2-01, 2-03, 2-04, 2-11, 2-12, 2-13, 2-14, and 2-18, Oncor has designated certain responsive documents as "Protected Materials" and has indicated it will produce those documents subject to the Protective' Order entered in this docket. Accordingly, Oncor submits this Statement to comply with paragraph 4 of the Protective Oider. Staff RFI Set No. 2, OuestionNo The documents responiive to this RFI have been designated Protected Materials as detailed in-the Voluminous Confidential Index included as Attachment 1 to Oncor's response, and they are exempt from public disclosure, consistent with the Texas Public Information Act (TPIA"). These documents---2quarter1y performance' measures reports filed with the Public Utility Commission of Texas during 2010 through 2016 contain confidentiai and commercially sensitive business operations infdrmation. Public disclosure of this information would cause, or cause an unreasonable risk of, substantial financial and competitive harm 'to the Company. ' TEX. GOV'T CODE ANN (West 2012 & Supp. 2016). 3(t

3 Therefore, under Sections and of the TPIA and the terms of the Protective Order, these documents are exempt from public disclosure under the TPIA and are šubject to treatment as Protected Materials in this pixiceeding. Staff RFI Set No. 2, Question No The document responsive to this RFI has been designated Protected Materials as detailed in the Non-Voluminous Confidential Index included as Attachment 1 to Oncor's response, and it is exempt from public disclosure; consistent with the TPIA.2 This document the annual performance metrics as reported to the Oncor Board---contains confidential and comrnercially sensitive business operations information. Public disclosure of this information would cause, or cause an unthasonable risk of, substantial financial and competitive harm to the Company. Therefore, under Sections and of the TPIA and the terms of the Protective Order, this document is exempt from public disclosure under the TPIA and is -subject to treatment as Protected Materials in this proceeding. Staff RFI Set No. 2, Ouestion No The documents responsive to this RFI have been designated Protected Materials as detailed in the Voluminous Cortfidential Index included as Attachment 1 to Oncor's response; and they are exempt from public disclosure, consistent with the TPIA.3 These documents monthly summaries of operations and maintetiance and selling, general and administrative expenses and performance indicators for the last five years contain confidential and commercially sensitive business operations and financial information. Public disclostire ofthis information would cause, or cause an unreasonable risk of, substantial financial and competitive harm to the Company. Therefóre, under Sections and of the TPIA and the terms of the Protective Order, these documents are exempt from public disclosure under the TPIA and are subject to treatment as Protected Materials in this proceeding. Staff RFI Set No. 2. Question No The documents responsive to this RFI have' been designated Piptected Materials as, detailed in the Non-Voluminous Highly Sensitive Confidential Index included as Attachment 1 to Oncor's response, and they are exeinpt from public disclosure, consistent with the TPIA.4 These documents long-term debt savings analyses and calculations contain confidential and 1ct 3 Id. 4 Id. 2 2

4 commercially sensitive business opefations and financial inforrnation. Public disclosure of this information would cause, or cause an unreasonable risk of, substantial financial and competitive harm to the Company. Therefore, under Sections and of the TPIA and the terms of the Protective Order, these documents are exempt from public distlosure under the TPIA and are subject to treatment as Protected Matèrials in this proceeding. Staff RFI Set No. 2, Question No The documents responsive to this RFI have been designated Protected Materials as detailed in the Voluminous Confidential Index included as Attachment 1 to Oncor' s response, and they are exempt from public disclosure, consistent with the TPIA.5 These documents quarterly operating reports and monthly asset plan reports for 2011 through 2016-contain confidential and commercially sensitive business operations and financial information. Public disclosure of this information would cause, or cause an unreasonable risk of, substantial financial and competitive harm to the Company. Therefore, under Sections and of the TPIA and the terms of the Protective Order, these documefits are exempt from public disclosure under the TPIA and are subject to treatment as Protected Materials in this proceeding. Staff RFI Set No. 2. Ouestion No The document responsive to this RFI has been designated Protected Materials as detailed in the Non-Voluminous Confidential Index included as Attachment 1 to Oncor's response, and it is exempt from public disclostire, consistent 'with the tpia.6 This document a benchmarking review of reliability performance data contains confidential and commercially sensitive business operations" information. Public disclosure of this information would cause, or cause an unreasonable risk of, substantial financial and cornpetitive harm to the Company. Therefore, under Sections and of the TPIA and the terms of the, Protective Order, this document is exempt from public disclosure under the ti31a and is subject to treatment as ttotected Materials in this proceeding. Staff RFI Set No. 2. Question No The document responsive to this RFI has been designated Protected Materials as detailed in the Non-Voluminous Confidential Index iucluded as Attachinent 1 to Oncor's response, and it 5 1d. 6 1d. 3 3

5 is exempt from public disclosure, consistent with the TPIA.7 This document a list of participating utilities included in the yearly SAIDI performance comparisons contains confidential and conunercially sensitive business operations information. Public disclosure of this information would cause, or cause an unreasonable risk of, substantial financial and competitive harm to the Company. Therefore, under Sedtions and of the TPIA, and the terms of the Protective Order, this document is exempt from public disclosure under the TPIA and is subject to treatment as Protected Materials in this proceeding. Staff RFI Set No. 2, Question No The document responsive to this RFI has been designated Protected Materials as detailed in the Non-Voluminous Confidential Index included as Attachment 1 to Oncor's response, and it is exempt from public disclosure, consistent with the TPIA.8 This document Oncor's safety Metrics contains confidential and commercially sensitive business operations information. Public disclosure of this information would cause, or cause an unreasonable risk of, substantial firiancial and competitive harm to the Company. Therefore, under Sections and of the TPIA and the terms of the Protective Order, this document is exempt from public disclosure under the TPIA and is subject to treatment as Protected Materials in this proceeding. Undersigned counsel for Oncor has reviewed the above-described information sufficiently to state in good faith that the information is exempt from disclosure under the TPIA and merits the PrOtected Materials designation pursuant to the Protective 'Order entered in this docket. 7 Id. 8 1d, 4 4

6 Respectfully submitted, By: Matthe C. Henry State Bar No Richard L. Adams State Bar No Jo Ann Biggs State Bar No yinson & Elkins LLP 2001 Rbss Avenue, Suite 3700 Dallas, Texas Telephone: (214) Facsimile: (214) E. Allen Nye, Jr. Senior Vice President, General Counsel and Secretary Oncoi Electric Delivery Company LLC 1616 Woodall Rodgers Freeway Dallas, Texas ATTORNEYS FOR ONCOR ELECTRIC DELIVERY COMPANY LLC CERTIFICATE OF SERVICE It is hereby certified that a copy of the foregoing has been'hatid delivered or sent via courier service, , fax, overnight delivery, or first class United States mail, postage prepaid, to the requesting party and filed with the Commission, on this the 9th day of December,