- Before
- 1,284 questions in and 61 due this week, tracked in a spreadsheet log. “I can live with a late answer. I can't live with two different numbers.”
- Now
- Opens the binder on every open request, sees each number conflict before it is served and resolves it one of two drafted ways.
One data request, from the inbox to served — a week early
Lumina Utilities is in its 2026 Electric General Rate Case, Docket E-26-0418 before the Arden Public Utility Commission: filed 14 Aug, $186.4M asked. It is Tue 13 Oct. Commission Staff Set 14 arrived on 6 Oct; its responses are due Tue 20 Oct. Here is what happens to Staff 14-07, screen by screen, in the working solution.
- 01Morning
The binder opens on the whole case
Dana Whitfield · Rate case managerDana owns the rate case. The strip across the top reads 1,284 questions in, 1,031 served, 253 open, 61 due this week, 4 at risk and 3 number conflicts. The inbox tray shows each set as it arrived, with its due and objection clocks, and two new sets — City of Westmere Set 2 and Staff Set 15 — wait to be filed. Down the right edge, eight coloured topic tabs: Revenue requirement & O&M holds 58 open.
“Staff 14-09 objection due today 17:00 · Helen Szabo”
- 026 Oct to 10:16 today
Staff 14-07 was split, routed and drafted
Request reader, Router, Response drafterThe request reader split Staff Set 14 into 11 questions; 14-07 has three parts — by FERC account, reconcile to Schedule C-2, explain any difference. The router filed it under Revenue requirement & O&M with owner Tom Reyes and witness Priya Raman, due Tue 20 Oct. The drafter found three earlier answers — OCA 3-12, Staff 9-04 and Staff 6-11 from the 2022 case — and pulled the 2025 amounts by account from the ledger extract of 9 Oct.
Tom Reyes, 11:02: “593 includes the ice-storm reclass.”
- 0310:15
22 numbers checked — and two conflict
Consistency checkerThe draft gives test-year distribution O&M, excluding vegetation, of $412.0 million. The checker reads every number in the draft and compares it with 27 places in the filing. Raman Direct, page 34, line 12 says $409.0 million; so do Schedule C-2, line 18 and the response to OCA 3-12, served 9 Sep. Sign-off is blocked until a person resolves it.
Margin note: “Conflicts with testimony page 34 — draft says $412.0M; Raman Direct p.34 l.12, Schedule C-2 l.18 and OCA 3-12 say $409.0M.”
- 04One click
Every place the number appears
Dana Whitfield · Rate case managerDana clicks the underlined $412.0 million and sees its trail: the testimony, Schedule C-2, workpaper WP-C2-4 and the responses to OCA 3-12 and Staff 9-04 all say $409.0M. Only the ledger extract of 9 Oct and the new draft say $412.0M — and the ledger includes JE 26-09-0147, posted 22 Sep, after the filing.
“Draft response to Staff 14-07 · $412.0M · Conflicts with the five places above”
- 05The cause
A $3.0M entry posted after the filing
Consistency checkerThe checker finds the cause in the ledger: journal entry JE 26-09-0147, approved by Aisha Grant, controller, reclassified $3.0 million of February 2025 ice-storm restoration from capital to account 593, maintenance of overhead lines. The number register keeps all 12 key figures of the case and their 295 places; distribution O&M shows “Conflict in a draft”.
Agent limit: the consistency checker never changes a filed number — it flags and proposes; people decide.
- 0612:44
Answer as filed, and disclose the entry
Dana Whitfield · Rate case managerTwo ways out are drafted. A: answer as filed, $409.0M, disclose the $3.0M entry and address it in rebuttal — recommended, the same as OCA 3-12. B: answer $412.0M and file errata to testimony page 34 and Schedule C-2, and supplement OCA 3-12. Dana picks A. The drafter rewrites the answer, puts account 593 back to $61.3M and adds the disclosure paragraph; the checker reads 23 numbers, all matching.
“Answered as filed · Dana Whitfield · 12:44”
- 0712:48 · a week early
The witness confirms, counsel signs and serves
Priya Raman, then Helen SzaboThe response goes to Priya Raman with the margin notes and the disclosure paragraph. She confirms it as witness at 12:46 and Dana approves. Helen Szabo, regulatory counsel, signs, and the response assembler serves it on the 14-party service list at 12:48, files the public version and logs it — a week before it is due.
“Served on 14 parties 12:48”
- 08Before 17:00
A partial objection, drafted for counsel
Objection screener · Helen SzaboStaff 14-09 asks for all materials presented to the Board on the 2026 rate case. The objection screener drafts a partial objection: one of three documents is counsel's memo of 2 July, which is privileged; the Board presentations of 18 June and 23 July can be produced as Confidential under the protective order, by 20 October. Helen decides — sign and serve the objection, or answer in full.
Agent limit: the objection screener never files or serves an objection; counsel decides every one.
- 09Today 08:40
A new set, split and filed in one step
Kofi Mensah · Regulatory analystCity of Westmere Set 2 arrived by email at 08:40: three pages, five questions. Kofi runs Split and file. Each question gets a topic, an owner and a witness, with responses due Tue 27 Oct and objections Tue 20 Oct. Question 2-04 asks for the names and addresses of customers disconnected for non-payment — it is held for Helen Szabo, with counts by month proposed instead.
“Objection screen: customer names and addresses are confidential — propose counts by month”
- 10This week
What is due, and what is at risk
RouterThe deadlines view lays out 219 responses due between 13 and 30 Oct, by party and business day, against the procedural schedule: intervenor testimony on 9 Nov, after which discovery shortens to 5 business days; rebuttal on 1 Dec; the hearing 7–11 Dec. Four requests are at risk — no draft yet and due within 3 business days — and their experts were reminded at 08:00.
At risk: Staff 13-08 and CGA 2-05 (Carlos Duarte), OCA 6-09 (Ruth Adeyemi), AIEU 3-04 (Graham Holt).