[il_npa] rebuttal testimony - #191
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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.
…r in the wrong branch
…ta/reports2 into il_npa-report-draft
…gy section + chart refactor)
… 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
…ta/reports2 into il_npa-report-draft
…ta/reports2 into il_npa-report-draft
Co-authored-by: Cursor <cursoragent@cursor.com>
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Working draft of Juan-Pablo Velez's intervenor rebuttal testimony to PGL's own rebuttal.