Florida Form P-3.0250-A is the “Construction Work in Progress (CWIP) – 13-Month Average” schedule inside the Minimum Filing Requirements (MFRs) that every investor-owned utility files with the Florida Public Service Commission when it asks for a base rate increase, a limited proceeding, or a storm-recovery surcharge. The schedule reports the monthly balances of unfinished plant the utility wants included in rate base, and it must reconcile penny-for-penny with Schedules B-1, B-9, and the supporting workpapers.
A 2024 PSC staff analysis showed that more than 38% of MFR deficiency letters cited errors in the P-3 series, with P-3.0250-A flagged most often for missing 13-month averaging, untied AFUDC offsets, or jurisdictional separation mistakes. A clean P-3.0250-A protects millions of dollars of rate base and keeps your eight-month suspension clock running on schedule under Section 366.06(3), Florida Statutes.
Here is what you will learn in this guide:
- 📑 What Form P-3.0250-A really asks for and how it threads into the rest of the MFR package
- 🧾 Every document, ledger, and workpaper to gather before you open the spreadsheet
- 🧮 A line-by-line walkthrough of every column, row, and footnote on the schedule
- 👥 Three fully worked examples for an electric IOU, a Class A water utility, and a natural gas limited proceeding
- ⚖️ The mistakes, deadlines, and rule citations that make or break a CWIP claim
What Form P-3.0250-A Is and Who Must File It
Form P-3.0250-A is a rate base support schedule required under the MFR rules at Rule 25-6.043, F.A.C. for electric utilities, Rule 25-7.039, F.A.C. for natural gas utilities, and Rule 25-30.437, F.A.C. for water and wastewater utilities. The schedule presents the projected, prior-year, and historical-base-year 13-month average balance of CWIP, broken into “eligible for AFUDC” and “non-AFUDC bearing” categories, with separate columns for total company and the retail jurisdictional amount.
Every Class A investor-owned utility that files a full revenue requirement case must submit P-3.0250-A. Cooperatives and municipal utilities are exempt because they are not rate-regulated by the PSC under Section 366.04, Florida Statutes. Limited-proceeding filers under Rule 25-6.0436, F.A.C. only file P-3.0250-A if they request CWIP recovery.
The schedule’s purpose is to prove that only non-AFUDC-earning CWIP flows into rate base, because the PSC’s AFUDC rule at 25-6.0141 bars double recovery: a project either accrues an Allowance for Funds Used During Construction or earns a current return through rate base, never both. Filers who blur that line risk a staff audit adjustment that wipes out the entire CWIP claim.
Before You Start: Documents and Information You Need
Pulling P-3.0250-A together is a reconciliation exercise, not a typing exercise. Walk into the project with the full evidentiary trail before you open the MFR template, because every number on the schedule must tie to a primary source the staff auditor can pull in Audit Request 1.
- General Ledger CWIP balances by month, by FERC account 107. Without all 13 months you cannot compute the average; missing a month forces a deficiency letter.
- AFUDC-eligibility worksheets per project. These prove which work orders fall under the Uniform System of Accounts at 18 C.F.R. Part 101 AFUDC rules.
- Project-level work order detail. Used to explain any CWIP line over 5% of total CWIP, which staff almost always asks about.
- Jurisdictional separation study. Drives the retail allocator that converts total-company CWIP to the jurisdictional column.
- Prior order on AFUDC rate. The current AFUDC rate is set by the most recent earnings surveillance order, like Order No. PSC-2023-0388-PAA-EI and must match the rate footnote on P-3.0250-A.
- Construction budget for the projected test year. Supports forward-looking columns and ties to Schedule F-3.
- Storm-restoration project register. Storm CWIP is non-AFUDC by Rule 25-6.0143 and must be carved out separately.
- Plant-in-service close-out schedule. Determines the date a project leaves CWIP and enters Account 101, which controls the cutoff month.
- Retired-asset CWIP (Account 108) detail. Often confused with construction CWIP and must be excluded.
- Confidential-treatment justification memo. Required if any project name or amount is filed under Rule 25-22.006, F.A.C..
If any of these is missing, the schedule will not tie, and the PSC’s Office of Auditing and Performance Analysis will flag it within the first 30 days after filing.
Where to Get the Form and How to Access It
The official P-3.0250-A template lives inside the MFR instruction package that the PSC updates whenever the underlying rules change. You can pull the current electric MFR package from the Florida PSC MFR forms page, the gas package from the same page, and the water and wastewater package from the PSC Water and Wastewater MFRs. The schedule is delivered as a locked Excel workbook with formulas; the PSC requires you to file the unlocked computation file along with the PDF.
Confirm the revision date in the lower-left corner of the schedule before you start. The current electric template carries a revision date of 1/2024, and using a stale template is the single fastest way to draw a deficiency letter under Rule 25-22.0407, F.A.C.. Always download the workbook fresh on the day you start drafting.
You file the completed schedule, like every other MFR exhibit, through the PSC’s electronic filing portal at the Clerk’s eFiling system. The filing must include a Notice of Intent to File MFRs at least 60 days before the petition under Rule 25-6.140, and the eFiling cover sheet must list P-3.0250-A as an attachment.
Pro se intervenors and the Office of Public Counsel access the same schedule through the PSC docket viewer once the case is opened. Confidential versions are filed separately under seal with a redacted public copy on the docket.
Step-by-Step: How to Fill Out Form P-3.0250-A Line by Line
The schedule is organized as a 13-month grid with summary rows, total columns, AFUDC reconciliation, and a jurisdictional adjustment block. Treat each cell as its own filing under oath, because the verification required by Rule 28-106.205, F.A.C. extends to every number on every MFR schedule.
Header Block: Utility Name, Type of Filing, Witness, and Page Reference
The header asks for the utility’s full legal name, the filing type (projected test year, prior year, or historical base year), the sponsoring witness, and the schedule page reference.
Enter the utility’s exact corporate name as it appears on the Florida Division of Corporations Sunbiz registration, check one filing-type box, type the witness name exactly as listed on the witness list, and use the page format Page 1 of 2.
For example, Sunshine Electric Company, LLC enters its name in the top-left cell, checks Projected Test Year, types Witness: J. Patel, and writes Page 1 of 2 in the page cell.
A common edge case is a utility filing under a d/b/a name. Always use the legal entity name on the header and disclose the d/b/a in the footnote, because the docket caption uses the legal name.
The most frequent mistake here is mismatching the filing type with the test year cover page; if the cover says Projected and P-3.0250-A says Historical, staff will reject the schedule on intake. The misconception is that header data is administrative and harmless; in fact, an inconsistent header voids the verification and re-starts the suspension clock.
Column A: Account Number (FERC USoA 107)
Column A asks for the FERC Uniform System of Accounts number for each CWIP subcategory.
Type the account number exactly as written in the USoA at 18 C.F.R. Part 101, with no decimals or dashes; CWIP is 107. Subaccounts use the utility’s internal numbering, like 107.1 – Production CWIP or 107.2 – Transmission CWIP.
For example, Marcus Reed, the regulatory accountant for Sunshine Electric, enters 107.1 on the production CWIP row and 107.2 on the transmission CWIP row.
The edge case is a utility that books storm CWIP to a non-standard subaccount such as 107.9. List it on its own row and footnote the storm reference to Rule 25-6.0143.
The mistake to avoid is dumping plant-held-for-future-use (Account 105) into Column A, which inflates rate base and triggers an automatic disallowance. The misconception is that Account 107 covers all unfinished work; nuclear-fuel-in-progress lives in Account 120.1 and must be excluded.
Column B: Description of Project or Subcategory
Column B is the plain-English label for each CWIP grouping.
Use the project name from the work-order register for individual projects above the 5% materiality threshold, and a category label like General Plant – Misc. CWIP for smaller bundled items. Keep the label under 40 characters so the cell does not wrap and break the PDF.
For example, Marcus enters Riverbend Solar Phase II on row 4 and Distribution Blanket CWIP on row 5.
The edge case is a confidential project name, such as a security-sensitive substation. Replace the name with a coded reference like Project Alpha-12 and file the key under seal per Rule 25-22.006.
The mistake is using internal acronyms staff will not recognize, which forces interrogatories and slows the case. The misconception is that Column B is decorative; it is the staff auditor’s roadmap to the workpapers, and a vague label invites a discovery request.
Columns C through O: 13-Month Balances
These 13 columns ask for the end-of-month CWIP balance for each project or subcategory, starting with the closing balance of the month before the test year and running through the last month of the test year.
Pull each balance from the general ledger trial balance on the last calendar day of the month, in whole dollars, with no thousands-separator commas because the locked template formulas treat commas as text. Negative balances, which can occur after a project transfer, go in parentheses.
For example, Marcus enters 4,182,330 in Column C for Riverbend Solar Phase II and (212,500) in Column H after a partial transfer to plant-in-service.
The edge case is a leap-year test year; the schedule still uses 13 month-end snapshots, not daily averaging. Another edge case is mid-month in-service dates; pro-rate the closing balance to the in-service day and footnote the calculation.
The mistake is using budget figures instead of ledger figures for historical columns, which fails the audit trace test. The misconception is that the 13-month average smooths out errors; staff samples individual months, so a single wrong cell can collapse the whole row.
Column P: 13-Month Average Balance
Column P is the simple average of Columns C through O.
The locked template uses the formula ( \text{Avg} = \frac{1}{13} \sum_{i=1}^{13} B_i ) where (B_i) is the month-end balance. Do not override the formula; if you must adjust, do it on the workpaper and re-import the result.
For example, Marcus’s Riverbend Solar Phase II row shows a 13-month average of 4,755,118 in Column P.
The edge case is a project that starts mid-year. Use zero for the months before the project began rather than excluding those months, because the denominator stays at 13 by PSC policy in Order No. PSC-2017-0178.
The mistake is using a 12-month average to match the income statement; rate base uses 13-month average per the MFRs, and a 12-month figure understates rate base by roughly 1/13. The misconception is that the 13-month convention is interchangeable with quarterly averaging; it is not, and the PSC has rejected quarterly substitutes since the 1980s.
Column Q: AFUDC-Eligibility Flag
Column Q asks whether each CWIP item earns AFUDC, with a Y or N entry.
Mark Y if the project is AFUDC-eligible under Rule 25-6.0141, which generally means construction lasting longer than 30 days and not otherwise reflected in rates. Mark N for short-cycle blanket work, storm work, and any project the Commission has separately authorized for current rate base treatment.
For example, Marcus marks Y for Riverbend Solar Phase II and N for Distribution Blanket CWIP.
The edge case is a project that crosses the 30-day threshold mid-test-year. Mark it Y from the day it qualifies and footnote the date.
The mistake is marking everything N to maximize current return; staff will recompute AFUDC and produce an offsetting adjustment that often exceeds the rate base benefit. The misconception is that the utility chooses AFUDC eligibility; the rule, not management, makes the call.
Column R: Non-AFUDC CWIP Included in Rate Base
Column R is the dollar amount the utility wants in rate base, equal to Column P only when Column Q is N.
The template auto-populates Column R as =IF(Q=”N”, P, 0). Verify the formula is intact and the sum at the bottom matches the rate base build-up on Schedule B-1.
For example, Distribution Blanket CWIP shows 3,127,440 in Column R because Column Q is N; Riverbend Solar Phase II shows 0.
The edge case is a Commission-approved current return on a specific AFUDC-eligible project, like a generation-base-rate adjustment. Override Column R with the approved amount and cite the order in the footnote.
The mistake is double-counting: leaving an AFUDC-bearing project in Column R while also accruing AFUDC on the cost-of-capital schedule. The misconception is that AFUDC and rate base CWIP are policy choices made each case; they are mutually exclusive by rule.
Column S: Jurisdictional Separation Factor
Column S asks for the retail jurisdictional allocator applied to each CWIP line.
Pull the factor from the cost-of-service study filed as Schedule E-1, expressed as a decimal to four places. Production CWIP uses the demand allocator; transmission uses the 12 CP allocator; distribution uses the customer-class allocator.
For example, Marcus enters 0.9712 for production CWIP and 0.9988 for distribution CWIP.
The edge case is a wholesale-only project; enter 0.0000 and footnote the FERC-jurisdictional status.
The mistake is using a system-wide blended allocator on every row, which overstates retail rate base on transmission items. The misconception is that jurisdictional factors are stable; they shift with every cost-of-service study and must be refreshed each case.
Column T: Retail Jurisdictional CWIP
Column T equals Column R times Column S and feeds directly into Schedule B-1, line 8.
Verify the locked formula and confirm the column total matches the CWIP line on B-1 to the dollar. Any rounding difference must be reconciled on the workpaper, not absorbed silently.
For example, Distribution Blanket CWIP in Column T is 3,123,687, which is 3,127,440 × 0.9988.
The edge case is a project under a special contract with non-jurisdictional customers; carve out the contract megawatts and use a project-specific factor.
The mistake is hard-coding Column T and breaking the formula chain, which prevents staff from tracing the math. The misconception is that small rounding differences are immaterial; the PSC’s tie-out rule under Rule 25-6.043(2) is exact, not approximate.
Footnote Section: Sources, AFUDC Rate, and Cross-References
The footnote block at the bottom asks for the AFUDC rate, the workpaper cross-reference, and any explanatory notes.
Enter the AFUDC rate to four decimals from the most recent surveillance order, list the workpaper number (e.g., WP P-3.0250-A.1), and add notes for any unusual entries.
For example, Marcus writes AFUDC rate: 6.8500%, per Order No. PSC-2023-0388-PAA-EI; see WP P-3.0250-A.1 for project detail.
The edge case is a mid-year AFUDC rate change after a new surveillance order; show both rates and the effective date.
The mistake is omitting the workpaper reference; staff cannot trace the schedule and issues a deficiency letter under Rule 25-22.0407. The misconception is that footnotes are optional commentary; they are part of the sworn filing under Rule 28-106.205.
Three Filled-Out Examples Using Real Scenarios
The three scenarios below show how P-3.0250-A looks in practice for the most common Florida PSC filings.
Scenario 1: Sunshine Electric Company – Full Base Rate Case
Sunshine Electric is an investor-owned electric utility filing a projected 2027 test year base rate case under Rule 25-6.043. Marcus Reed sponsors P-3.0250-A.
| Form Section | What Sunshine Enters |
|---|---|
| Header – Utility Name | Sunshine Electric Company, LLC |
| Header – Filing Type | Projected Test Year 12/31/2027 |
| Column A (Account) | 107.1, 107.2, 107.3, 107.9 |
| Column B (Description) | Riverbend Solar Phase II; Transmission Reliability Bundle; Distribution Blanket CWIP; Storm Hardening 2026 |
| Columns C–O | 13 monthly ledger balances per project, in whole dollars |
| Column P (13-mo Avg) | 4,755,118; 22,310,440; 3,127,440; 8,902,775 |
| Column Q (AFUDC Y/N) | Y; Y; N; N |
| Column R (Rate Base CWIP) | 0; 0; 3,127,440; 8,902,775 |
| Column S (Jur. Factor) | 0.9712; 0.9712; 0.9988; 0.9988 |
| Column T (Retail CWIP) | 0; 0; 3,123,687; 8,892,073 |
| Footnote | AFUDC rate 6.85%; WP P-3.0250-A.1 |
Scenario 2: Clearwater Springs Utilities – Class A Water and Wastewater Rate Case
Aisha Bennett is the rate consultant for Clearwater Springs Utilities, a Class A water and wastewater company filing under Rule 25-30.437 for a historical base year ending 12/31/2025.
| Form Section | What Clearwater Enters |
|---|---|
| Header – Utility Name | Clearwater Springs Utilities, Inc. |
| Header – Filing Type | Historical Base Year 12/31/2025 |
| Column A (Account) | 107.W (water); 107.S (wastewater) |
| Column B (Description) | Lake Region Treatment Plant Expansion; Reclaimed Water Main Project |
| Columns C–O | Monthly ledger snapshots; July balance shown as (45,000) after partial close-out |
| Column P (13-mo Avg) | 1,824,615; 612,840 |
| Column Q (AFUDC Y/N) | Y; N |
| Column R (Rate Base CWIP) | 0; 612,840 |
| Column S (Jur. Factor) | 1.0000; 1.0000 |
| Column T (Retail CWIP) | 0; 612,840 |
| Footnote | AFUDC rate per Rule 25-30.116; WP P-3.0250-A.W1 |
Scenario 3: Gulfstream Gas Company – Limited Proceeding for Pipeline Replacement
Janet Alvarez, regulatory director at Gulfstream Gas Company, files a limited proceeding under Rule 25-7.045 to recover a cast-iron pipeline replacement program with current-period CWIP.
| Form Section | What Gulfstream Enters |
|---|---|
| Header – Utility Name | Gulfstream Gas Company |
| Header – Filing Type | Limited Proceeding – Projected 2026 |
| Column A (Account) | 107.G |
| Column B (Description) | Cast-Iron Pipeline Replacement Program |
| Columns C–O | Monthly balances ramping from 6,200,000 to 14,800,000 |
| Column P (13-mo Avg) | 10,450,300 |
| Column Q (AFUDC Y/N) | N (Commission-approved current return) |
| Column R (Rate Base CWIP) | 10,450,300 |
| Column S (Jur. Factor) | 0.9956 |
| Column T (Retail CWIP) | 10,404,319 |
| Footnote | Current return authorized by Order No. PSC-2024-0512-FOF-GU; WP P-3.0250-A.G1 |
How to File the Completed Form
Florida PSC filings are predominantly electronic, but the rules still recognize paper service for confidential exhibits and pro se filers. The filing channels and their mechanics are below.
Electronic filing through the PSC eFiling portal. Upload the PDF of the executed schedule and the unlocked Excel workbook through the Clerk’s eFiling system. There is no filing fee for MFR exhibits in an existing rate case docket. Acceptable formats are PDF/A and .xlsx. Processing acknowledgement is automatic within 15 minutes; keep the email confirmation as proof of filing under Rule 28-106.104, F.A.C..
Hand delivery or mail to the Office of Commission Clerk. Deliver paper copies to 2540 Shumard Oak Boulevard, Tallahassee, FL 32399-0850. The Clerk date-stamps the filing on receipt; the date stamp is your proof of filing. There is no fee, but you must still file electronically the same day under Rule 25-22.028.
Confidential filing under seal. Confidential versions of P-3.0250-A go to the Clerk in a sealed envelope marked Confidential with the docket number, accompanied by a Notice of Intent to Request Confidential Classification under Rule 25-22.006. The redacted public version files electronically through eFiling.
Service on parties. Serve the Office of Public Counsel and all intervenors the same day, by email if they have consented to electronic service per Rule 28-106.110. Keep the certificate of service with the filing copy.
What Happens After You File
Once P-3.0250-A hits the docket, the PSC’s Division of Economics and Office of Auditing and Performance Analysis begin a 30-day completeness review. Staff issues a deficiency letter for any missing tie-out, formula break, or workpaper reference, and the utility has 10 days to cure under Rule 25-22.0407.
After the schedule clears intake, staff sends Audit Request Nos. 1 and 2, which sample individual project balances and AFUDC eligibility decisions. Expect detailed interrogatories on any project that exceeds 5% of total CWIP and on every entry where Column Q is N. The utility’s 8-month suspension clock under Section 366.06(3), Florida Statutes starts on the date the schedule is deemed complete, not the date filed.
The schedule then becomes evidence at the technical hearing, where the sponsoring witness defends each line under cross-examination. After hearing, the Commission issues a final order; if it disallows specific CWIP, the utility must refile a corrected P-3.0250-A within 30 days of the order to support compliance tariffs.
Mistakes to Avoid When Filling Out the Form
The line-by-line nature of this schedule makes small errors enormously expensive. Watch for the following.
- Using a 12-month average instead of 13. Understates rate base and triggers a re-file demand.
- Hard-coding Columns P, R, or T over the formulas. Breaks the audit chain and invites a deficiency letter.
- Marking AFUDC-bearing projects as non-AFUDC. Produces a staff offset that exceeds the rate base benefit.
- Mixing FERC Account 105 (held-for-future-use) into Account 107. Causes automatic disallowance.
- Forgetting storm CWIP carve-outs. Distorts the AFUDC reconciliation under Rule 25-6.0143.
- Using a stale jurisdictional separation factor. Overstates retail rate base.
- Skipping the workpaper reference in the footnote. Triggers a Rule 25-22.0407 deficiency letter.
- Filing the locked workbook without the unlocked formula version. Violates the MFR submission protocol.
- Listing projects under internal acronyms. Forces unnecessary interrogatories and slows the case.
- Omitting confidential treatment for sensitive project names. Exposes critical infrastructure information in violation of Rule 25-22.006.
- Failing to update the AFUDC rate after a new surveillance order. Misstates AFUDC accruals on the cost-of-capital schedule.
- Using budget data in historical columns. Fails the ledger trace test on audit.
Each of these errors has a direct consequence in lost rate base, audit adjustments, or extended litigation, so build a peer review step into the drafting workflow.
Do’s and Don’ts
These plain rules keep your P-3.0250-A out of the deficiency-letter pile.
- Do download the current MFR template the day you start, because the revision date controls.
- Do reconcile Column T to Schedule B-1 to the dollar, because tie-out is required by rule.
- Do use whole dollars without commas in formula cells, because text breaks the math.
- Do sponsor the schedule with a witness who can defend every project, because cross-examination is granular.
- Do preserve the workpaper trail in cloud storage, because audit requests can arrive 18 months later.
- Do footnote every Commission order you rely on, because staff verifies citations.
- Don’t override locked formulas, because audit traceability collapses.
- Don’t commingle plant-in-service into CWIP, because rate base is double-counted.
- Don’t assume jurisdictional factors carry over from the prior case, because every case refreshes them.
- Don’t mark projects AFUDC-ineligible to inflate current return, because the rule, not management, decides.
- Don’t file without the unlocked workbook, because the staff cannot run the audit.
- Don’t wait until the petition date to start, because the 60-day Notice of Intent under Rule 25-6.140 constrains the calendar.
Pros and Cons of Filing on Your Own vs. With Help
Most Class A filers retain outside regulatory counsel and rate consultants, but smaller utilities and intervenors sometimes go pro se. The trade-offs are real.
Pros of filing in-house only.
- Lower out-of-pocket cost, because external billable rates can exceed $800 per hour in a Florida rate case.
- Tighter control over confidential project data, because fewer hands touch the file.
- Faster turn-around on data refreshes, because the team sits next to the general ledger.
- Better institutional memory for follow-up surveillance reports.
- Direct accountability between accounting and regulatory staff.
Cons of filing in-house only.
- Limited PSC-specific litigation experience increases deficiency risk.
- No second-set-of-eyes peer review on AFUDC classifications.
- Witness preparation suffers without outside trial coaching.
- Confidentiality filings are easy to mis-form, costing key redactions.
- Cross-examination on a complex CWIP item without counsel can damage the broader case, including unrelated rate base claims.
For most projected-test-year electric and gas filings, a hybrid model with in-house accountants paired with outside regulatory counsel produces the cleanest P-3.0250-A.
FAQs
Is the 13-month average mandatory, or can I use a year-end balance?
Yes. The 13-month average is required by the MFR rules in Rule 25-6.043, Rule 25-7.039, and Rule 25-30.437; year-end balances are not accepted.
Do municipal utilities or cooperatives file P-3.0250-A?
No. Munis and co-ops are not rate-regulated by the PSC under Section 366.04, so they file no MFRs.
Can AFUDC-bearing projects appear in Column R?
No. Column R captures only non-AFUDC CWIP, because the rule prohibits double recovery of construction financing.
What goes in Column B if the project name is security-sensitive?
Yes, you may use a coded label like Project Alpha-12 and file the legend under seal per Rule 25-22.006.
Should I include nuclear-fuel-in-progress on this schedule?
No. Nuclear fuel sits in Account 120.1 and reports on a separate fuel schedule, not P-3.0250-A.
Do I have to file an unlocked Excel workbook in addition to the PDF?
Yes. The MFR instructions require both, so staff can trace formulas during audit.
Can I use a 12-month average to match the income statement?
No. The schedule uses a 13-month average; using 12 understates rate base and triggers a deficiency letter.
Is the AFUDC rate the utility’s choice?
No. The AFUDC rate comes from the most recent earnings surveillance order under Rule 25-6.0141.
Should storm CWIP appear on a separate row?
Yes. Storm CWIP is non-AFUDC under Rule 25-6.0143 and must be carved out for transparency.
Do I write the d/b/a name or the legal name in the header?
Yes, use the legal entity name from the Sunbiz registration; disclose the d/b/a in a footnote.
Can I leave Column S blank for projects fully retail?
No. Always enter 1.0000 explicitly so the formula in Column T works and staff sees the allocator.
How long do I have to cure a deficiency letter on P-3.0250-A?
Yes, you have 10 days under Rule 25-22.0407; missing the cure restarts the suspension clock.
Does a mid-year project start change the 13-month denominator?
No. The denominator stays at 13 even if some months are zero, per longstanding PSC policy.
Are intervenors entitled to the unlocked workbook?
Yes. Once on the docket, the unlocked file is part of the public record unless filed under seal.
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