SystemRegulatory Affairs & Rates

Performance-Based Regulation Reporting

Performance-based regulation reporting with every reward and penalty traced to its source records

Every reward and penalty traced to its source records, and explained to the regulator.

See one case, screen by screen ↓
target100%of scorecard metrics traced to their source records, in the filing and in every answer to staff
demo$7.1Mswing in the net incentive found by one trace — from −$2.35M as calculated to +$4.75M after three corrections
demo94sentencesin the drafted discussion of results, every one cited to a step of its metric's trace
target5daysfrom data freeze to a reviewed scorecard and narrative, so the filing date holds
The problem

Why a PBR scorecard takes weeks and still can't be proven

Under performance-based regulation every standing metric — outage minutes and frequency, calls answered, complaints, estimated bills, solar and battery connection times, energy savings, lost water — carries a target, a deadband, a dollar rate and a cap set in the tariff. The data behind them sits in ten systems: the outage management system, the smart-meter head-end, the network model, billing, the call platform, the interconnection portal, programme tracking, water balance, the lab system and the ledger. The regulatory team pulls a year of it into spreadsheets and rebuilds each calculation by hand.

The methods live in personal workbooks and drift from year to year. The explanation for the regulator is written last, in Word, and cites nothing — so when staff ask where a number came from, the team reverse-engineers its own workbooks. And the incentive rides on decimals: one storm day assigned to the wrong date, one outage entered twice or a sustained outage logged as momentary moves the reliability index, and with it a reward or a penalty.

typical~40metricsand scorecards approved under Hawaii's performance-based regulation in 2021
typical±24bpof allowed return on equity riding on seven metrics in one Illinois multi-year rate plan order (2023)
demo$1.5Mper outage minute at the demo utility's tariff rate — one decimal of SAIDI is real earnings
Where a scorecard's working days goestimated
By hand32 days
With the solution5 days
  • Pulling the year's data from ten systems8 → 0.5 d
  • Rebuilding each metric's calculation in workbooks8 → 0.5 d
  • Cross-checking sources — storm days, duplicates, momentaries5 → 1 d
  • Pricing each reward and penalty against the tariff2 → 0.5 d
  • Writing the discussion of results6 → 1.5 d
  • Owner review, Director sign-off and CFO attestation3 → 1 d

Estimated split for one performance year's scorecard and narrative, in working days, by hand and with the solution.

How it works

How a scorecard is made

Six specialist agents collect, calculate, reconcile, price and explain every metric; the metric owner decides each correction and the Director signs.

What comes in
Data in10 systems · outages, meters, billing, calls, connections, water
Agents at work
Source collectorevery month checked
Then
Metric calculatoreach step recorded
Reconcilersources cross-checked
Then
Incentive calculatorreward or penalty
Then
Narrative writerevery sentence cited
Filing assembler
A person decides
Metric owner and Directordecide and sign
What comes out
Traced scorecard
Cited explanation
Filed on time
One case, step by step

One scorecard, from a penalty to a signed filing

Lumina Utilities, electricity and water, serves 612,400 electric customers. Its performance year 2026 report is due to the Halvern Utilities Commission on Dec 1, under Docket 26-PBR-0417 and tariff Schedule PBR-1. On Oct 13, 2026, the morning run leaves reliability in penalty. Here is what happens next, screen by screen, in the working solution.

  1. 0106:00

    Ten systems pulled, every month checked

    Source collector

    The daily 06:00 run starts. The source collector takes the extracts at the Oct 10, 06:00 cut-off from ten systems — 2.94M records — and checks each month of each system for completeness. Six items are flagged for their owners, none of which blocks the calculation: storm interruptions restored after midnight in August, 1.3 % of water reads still estimated at data freeze, a 2-day call platform outage backfilled from the carrier's call records.

    The source collector never fills a gap with an estimate; it reports it to the owner.

  2. 0209:40

    The scorecard opens in penalty

    Tomás Reyes · PBR reporting lead

    Filing is due Dec 1 — 49 days — with data freeze on Nov 3. The run computed all 13 metrics, 10 with money at stake: net incentive −$2.35M, rewards +$1.75M against penalties −$4.10M. Outage minutes per customer (SAIDI, excluding major event days) came out at 121.4 min against a 118.0 target and a ±2.0 deadband: 1.4 minutes past the penalty edge, at $1.5M a minute, −$2.10M.

    “3 corrections waiting on E1, E2 · +$4.75M if accepted”

  3. 03One switch

    What the corrections would do, before anyone decides

    Tomás Reyes · PBR reporting lead

    Every bar runs from the penalty cap on the left, through the grey deadband around the target, to the reward cap on the right. A dashed marker shows where SAIDI and SAIFI would land if the open corrections were accepted. Tomás switches to With proposed corrections: SAIDI 113.2 min, SAIFI 1.01, net +$4.75M — marked “Preview — not decided”.

    “Preview: E1 and E2 with the 3 proposed corrections — nothing is changed until Grace Liu decides”

  4. 04The trace

    How the number is made, step by step

    Metric calculator

    Tomás opens E1. Four sources feed it: 14,812 outage records, 2,310,450 smart-meter power-off and power-on events, the major event day register (5 days, T_MED 6.84) and 612,400 customers served. Four tariff steps follow — keep sustained interruptions (§3.1), remove duplicates (§3.4), assign each interruption to the day it begins (§3.2), exclude major event days (§3.3) — down to 74,345,360 customer minutes, 121.4 min and −$2.10M under §4.1.

    Click any step to see its records — every step names its tariff section and its record count.

  5. 0506:14

    Storm outages on the wrong day, a duplicate, three mislabelled

    Reconciler

    The reconciler cross-checked the outage records against the meter events and the major event day register, and proposes three corrections, each with both records side by side. 1,214 interruptions began on Aug 23, a major event day, were restored after midnight and were counted on Aug 24 (−7.5 min). Feeder F-22 outage OMS-26-118842 was entered again as OMS-26-118867 on a crew re-dispatch (−0.8 min). Three recloser events on F-07, F-31 and F-44, logged as momentary, show 7,870 meters off for 7.2 to 8.4 minutes — sustained (+0.1 min).

    “+0.1 min · against Lumina” — the reconciler reports corrections that raise a penalty, not only those that lower it.

  6. 0609:52

    The metric owner decides, with her reason on the record

    Grace Liu · Reliability engineer

    Grace owns E1 to E3. She accepts all three corrections in one step, signing as the metric owner, and her reason goes into the audit trail. In the same step she marks the E1–E3 explanations reviewed. No correction changes a metric until its owner accepts it.

    Reason: “Checked against the Aug 23 storm log and the F-22 crew tickets; matches Schedule PBR-1 §3.1–3.4.”

  7. 07Seconds later

    The explanation for the Commission rewrites itself

    Narrative writer

    SAIDI is now 113.2 min — 69,323,680 customer minutes over 612,400 customers — 2.8 minutes beyond the reward edge, +$4.20M. The paragraph for the Commission says so, adds a sentence on the three corrections with each one cited to its step, and adds a method-change note: PY2025 assigned interruptions to the day they were restored; restated on the PY2026 basis, PY2025 SAIDI is 119.6 min against 124.1 filed.

    “Method change · disclosed” — the narrative writer can never remove a method-change disclosure.

  8. 08Back on the scorecard

    Reliability crosses from penalty into reward

    Tomás Reyes · PBR reporting lead

    E1 moves to +$4.20M, and E2 from $0 inside its deadband to +$0.80M at 1.01. Net incentive +$4.75M: rewards +$6.75M, penalties −$2.00M. The penalties that stand are traced as well — calls answered within 30 seconds at 76.4 % (−$0.40M), small solar and battery applications approved in 15 business days at 82.0 % (−$1.00M), lost water at 14.4 % (−$0.60M).

    “Reliability moved from penalty into reward: E1 113.2 min, +$4.20M”

  9. 09Staff questions

    Answering the Commission from the same trace

    Narrative writer

    Commission staff sent four questions ahead of the technical conference on Nov 5. HUC-DR-3-12, due Oct 27, asks for the workpapers behind SAIDI and SAIFI and the interruptions removed on each major event day. The draft answer names the five days — Dec 11, Jan 17, Mar 4, Jun 28 and Aug 23 — and the 2,388 interruptions excluded, and attaches workpaper tabs 1–6, Appendix C and the E1 trace export. It goes to Elena Marsh for review.

    “Staff will see the attachments and the answer; the trace stays internal unless it is attached.”

  10. 10Signed · 10:24

    Signed by the Director, attested by the CFO

    Elena Marsh · Director, Regulatory Affairs

    The filing assembler checks 8 of 8 items ready: the scorecard table, 13 workbooks with every figure linked to its records, the major event days appendix, the discussion of results with 13 of 13 sections reviewed by their owners, two method-change disclosures and the data dictionary. Elena signs at 10:24. Marcus Hale, the CFO, attests the net incentive of +$4.75M at 10:31, and the report is filed under Docket 26-PBR-0417.

    The filing assembler never submits — the Director signs and the CFO attests.

Who it’s for

Built for everyone who answers for the scorecard.

The same performance year, seen by the five people who own it — what reporting season looked like, and what it looks like now.

TR
Tomás ReyesPBR reporting lead, Regulatory Affairs · owns the annual scorecard
PBR reporting lead
Before
Owns 13 metrics from 10 source systems, due Dec 1. “I can tell you the number. Proving where it came from takes me a week per metric.”
Now
Opens any metric's trace — sources, tariff steps, record counts, the dollar result — with the explanation for the Commission written beside it.
GL
Grace LiuReliability engineer · owner of SAIDI, SAIFI and CAIDI
Metric owner
Before
Runs the outage data and confirms storm days. “If the storm-day rule is wrong, everything downstream is wrong.”
Now
Sees each proposed correction with the outage record and the meter events side by side, and accepts or rejects it with her reason recorded.
EM
Elena MarshDirector, Regulatory Affairs · signs the filing and staff answers
Director, Regulatory Affairs
Before
Faces the Commission's staff. “Every sentence we file, staff will ask us to prove.”
Now
Reads a discussion of results with 94 sentences and 94 citations, method changes disclosed, and every owner's review marked before she signs.
MH
Marcus HaleChief Financial Officer · attests the net incentive
CFO
Before
Attests the incentive booked in earnings. “Four million either way is a quarter's guidance.”
Now
Sees how far each priced metric sits from its deadband edges, what one step either way is worth, and attests a net traced to the records.
KA
Ken AbaraCustomer operations analyst · owner of calls answered, complaints and estimated bills
Metric owner
Before
Owns the customer service metrics. “The call platform and the billing system never agree on the month-end.”
Now
Gets each month of the call platform and billing extracts checked, with every gap flagged to him and its status recorded — explained, or accepted as estimated.
Built on the engine

6 agents. Each with one job, and hard limits.

Six specialist agents collect, calculate, reconcile, price and explain every metric; the metric owner decides each correction and the Director signs.

Source collector

Pulls the performance year's data from the ten source systems, counts the records and checks every month is complete, flagging any month that is missing, partial or late.

  • Read-only access to source systems
  • Never fills a gap with an estimate
  • Every extract keeps its timestamp
Metric calculator

Computes each metric exactly as the tariff defines it and records every step — the rule and its section, the records in and out, and a sample — as the metric's trace.

  • Only rules approved in Settings
  • Every step recorded with its records
  • Never changes a definition
Reconciler

Cross-checks the sources against each other — outage records against smart meters, duplicates, day assignment, customer counts against billing — and proposes corrections with evidence.

  • Proposes — the metric owner accepts
  • Reports corrections that hurt as well as help
  • Shows the evidence for each
Incentive calculator

Applies each metric's target, deadband, rate and cap and prices the reward or penalty and the net, again whenever a metric value changes.

  • Never changes a target, rate or cap
  • Shows the working for every dollar
Narrative writer

Drafts the explanation for each metric and the answers to staff questions; every sentence cites the trace and every number is bound to it.

  • No sentence without a citation
  • Never states a cause not in the evidence
  • Never removes a method-change disclosure
Filing assembler

Builds the filing — scorecard, workpapers, narrative, disclosures, attestation — checks every number in the narrative against the scorecard and the workpapers, and checks it against the Commission's filing requirements.

  • Never submits — the Director signs, the CFO attests
Metric owner · Director · CFO

Accept, sign and attest. The agents propose; a named person decides.

Ask in plain words

Ask about any metric, in plain words

Ask about any metric, its calculation or its explanation — or say what to change. Every answer points to the step of the trace it came from.

Why would reliability move from penalty to reward?

Three corrections, all found by tracing SAIDI to its records. 1,214 storm interruptions that began on Aug 23, a major event day, were counted on Aug 24; the tariff assigns them to the day they begin. One F-22 outage was recorded twice, and three outages logged as momentary lasted 7–8 minutes on the meters, which adds 0.1 minutes. Net: 121.4 → 113.2 minutes, from −$2.10M to +$4.20M.

Which metrics are closest to a deadband edge?

Four are within one rate step of an edge: E2 Outages per customer, 1.01 with the open corrections — 0.01 past the reward edge, worth $0.8M; W1 Lost water at 14.4 %, 0.1 past the penalty edge (−$0.6M); P2 Peak demand reduction at 97 MW, 3 MW from the reward edge; and C2 Complaints at 0.36, 0.01 past the reward edge.

Draft the answer to staff on method changes

Drafted HUC-DR-3-14 from the method change register. Two changes from PY2025: interruptions assigned to the day they begin (E1, E2), and the water balance v6 counting flushing water as authorised use (W1). PY2025 restated on the PY2026 basis: SAIDI 119.6 (filed 124.1). It is in Data requests for Elena Marsh to review.

Hold any explanation that has no owner review

Done. New filing rule: an explanation goes into the filing only after its metric owner marks it reviewed. Today that holds 3 of 13 sections, E1, E2 and E3, all waiting for Grace Liu. You can change it in Settings.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The reward-and-penalty scorecardThirteen metrics in four groups, each on a bar from penalty cap to reward cap, the net incentive, the filing clock and the morning's calculation run.
With proposed correctionsA preview of where reliability would land if the open corrections were accepted — nothing changes until the metric owner decides.
How the number is madeThe SAIDI trace: four sources, four tariff steps with their record counts, customer minutes, the index and the penalty, beside the explanation for the Commission.
Corrections proposed by the reconcilerThree corrections with both records side by side and the tariff rule behind each, including one that counts against the utility.
The metric owner decidesThe reliability engineer accepts the corrections as metric owner, with her reason recorded in the audit trail.
The explanation rewrittenSAIDI at 113.2 min and a +$4.20M reward, the paragraph rewritten with each correction cited, and the method change disclosed.
From penalty into rewardReliability now in reward, the net incentive at +$4.75M, and the corrections marked decided by their owner.
The discussion of resultsThirteen sections drafted from the metric traces, every number checked against the scorecard and each owner's review in the margin.
Ten source systemsMonthly coverage for every system, with record counts, owners and the six items flagged for review.
Earnings at riskEach priced metric's distance to its nearest deadband edge, what one step is worth, and what-if sliders that change nothing in the filing.
Staff data requestsThe Commission staff's questions with due dates, and an answer drafted from the trace with its workpapers attached.
Signed and filedEight of eight filing items ready, the Director's signature and the CFO's attestation of the net incentive, in order.
Your tariff's rulesEvery metric's target, deadband, rate, cap, owner and tariff section, the major event day method, reconciliation checks, approvals and clocks.
Governance

Built for the regulator: traced, disclosed, signed.

Every number goes back to its recordsEach metric opens a trace from the source systems through every tariff step to the dollar result, each step with its record count and a sample of its records. The same trace backs the workpapers and the answers to staff.
The metric owner accepts every correctionAgents propose; a correction changes a metric only after its named owner accepts it, with the reason recorded in the audit trail. Grace Liu decides for reliability, Ken Abara for customer service, Aisha Bello for water.
Corrections in both directionsThe reconciler reports corrections that raise a penalty as well as those that lower it, and that setting is always on. In the sample case it flagged three outages logged as momentary that add 0.1 minutes against Lumina.
Method changes disclosed, alwaysWhen a calculation differs from the previous report, the change is disclosed in the narrative with the prior year restated, and no agent can remove the disclosure. Every sentence of an explanation cites a step of the metric's trace.
The Director signs, the CFO attestsThe filing assembler checks the filing against the Commission's requirements but never submits it. The Director of Regulatory Affairs signs the filing and staff answers; the CFO attests the net incentive.
Read-only on source systemsThe agents read the outage, meter, billing and other systems and never change them. Rule changes need the Director's approval and apply from the next run, and a what-if on earnings changes nothing in the filing.
Configuration

Your tariff's rules, not ours

Every metric rule comes from your tariff, and the reconciliation checks, approvers and clocks are settings. Changes need the Director's approval and apply from the next run.

SettingDefaultChoose from
Metric rules13 metrics · Schedule PBR-1 §4–§5Per metric: better when lower, higher or reporting only, target, deadband, rate, cap, owner and tariff section
Major event daysIEEE 1366, 2.5βBase period: daily SAIDI, five years to Sep 30, 2025 · threshold T_MED 6.84 min
An interruption belongs toThe day it begins (§3.2)Momentary below 5 min
Outage records vs smart metersOnOn · Off — flags a duration that differs by more than 2 min
DuplicatesOnOn · Off — same device, windows overlap more than 30 min
Customers served vs billingOnOn · Off — flags a difference above 0.5 %; complaints are matched to the Commission's log
Report corrections that raise a penaltyAlways onOn — the reconciler reports corrections in both directions, those that raise a penalty as well as those that lower it
Approvals and clocksCorrection: metric owner · filing: Elena Marsh · net incentive: Marcus HaleData freeze Nov 3 · filing due Dec 1, warn 14 days before
Connections

Works with the systems your scorecard already runs on

Outage management systeminterruption records, feeders, devices, start and restoration times
Smart-meter head-end and network modelpower-off and power-on events, customers per transformer
Billing system and call platformbills, reads and accounts; calls offered and answered
Interconnection portal and programme trackingsolar and battery applications and approvals; efficiency measures and demand response events
Water balance and laboratory systemzone and production meters; drinking-water samples
General ledgerrevenue requirement and the incentive accrual
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of scorecard metrics traced to their source records
13 of 13 metrics
each with its records
estimated
$7.1M
swing found on two metrics by one trace, at Lumina's tariff rates
As calculated−$2.35M
Traced and corrected+$4.75M
target
5days
from data freeze to a reviewed scorecard and narrative
By hand≈ 6 weeks
With agents5 days

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate of where a scorecard's working days go · “typical” = published figures (RMI, Shining a light on utility performance in Hawaii, 2021 — almost 40 metrics and scorecards; Illinois multi-year rate plan order, 2023 — seven metrics worth ±24 basis points of ROE). Context: IEEE 1366 (major event days); OEB electricity distributor scorecard; Hawaiian Electric performance scorecards and metrics. Lumina Utilities, the Halvern Utilities Commission, Docket 26-PBR-0417, Schedule PBR-1 and the people and records named on this page are fictional — characters and sample data in the working solution.

Questions

What regulatory teams ask us.

What is performance-based regulation reporting?

Under performance-based regulation a utility earns a reward or pays a penalty on a set of standing metrics, each with a target, deadband, rate and cap in its tariff, and reports the results to its regulator every year with an explanation. Performance-Based Regulation Reporting computes every metric from the source systems, traces each reward and penalty to its records, and drafts the cited explanation; people decide, sign and attest.

How does PBR scorecard software work?

Six agents collect the year's data from ten systems, compute each metric exactly as the tariff defines it with every step recorded, cross-check the sources against each other, price each reward or penalty, draft the explanation for the regulator and assemble the filing. The scorecard shows every metric on a bar from penalty to reward, and each one opens its trace.

How does it calculate SAIDI and SAIFI with major event days excluded?

It follows the method set in Settings — in the sample, IEEE 1366 with the 2.5 beta method on five years of daily SAIDI, giving a threshold of 6.84 minutes. Interruptions are kept if sustained (over 5 minutes), de-duplicated, assigned to the day they begin and excluded on major event days, and each step shows its record count.

Does it only find corrections that help the utility?

No. Reporting corrections that raise a penalty is always on. In the sample case the reconciler found two corrections that lowered SAIDI and one — three sustained outages logged as momentary — that raised it by 0.1 minutes against the utility.

Can it answer the commission's data requests?

Yes. Staff questions sit in Data requests with their due dates, and the narrative writer drafts each answer from the same trace that produced the number, with the workpapers and appendices attached. The Director of Regulatory Affairs reviews and signs every answer.

Do people stay in control of the filing?

Yes. The agents have read-only access to the source systems; they calculate, propose and draft but never accept, sign or file. Each correction needs its metric owner, the filing needs the Director's signature and the net incentive the CFO's attestation.

Can we use our own tariff's metrics and rules?

Yes. Each metric's direction, target, deadband, rate, cap, owner and tariff section, the major event day method, the momentary threshold, the reconciliation checks, the approvers and the filing clocks are settings. Rule changes need the Director's approval and apply from the next run.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your tariff, the commission's filing requirements and last year's scorecard and workpapers — and it goes live once every quality gate has passed. We will walk you through it on your own performance year first.

See it on
your scorecard.

We'll run Performance-Based Regulation Reporting on last year's metrics, under your own tariff.