NiSource Inc

Good morning. My name is Rob and I will be your conference operator today. At this time, I would like to welcome everyone to the NYSource first quarter 2022 earnings conference call. All lines have been placed on mute to prevent any background noise. After the speaker's remarks, there will be a question and answer session. If you would like to ask a question during this time, simply press star followed by the number one on your telephone keypad. If you would like to withdraw your question, again, just press star one. Thank you. Chris Turnier, Director of Investor Relations, you may begin your conference.

Good morning, and welcome to the NYSource First Quarter 2022 Investor Call. Joining me today are Lloyd Yates, our Chief Executive Officer, Donald Brown, our Chief Financial Officer, Sean Anderson, our Chief Strategy and Risk Officer, Pablo Vegas, our Chief Operating Officer, and Randy Hewlin, our VP of Investor Relations and Treasurer. The purpose of this presentation is to review NiceHorse's financial performance for the first quarter of 2022, as well as provide an update on our operations and growth drivers. Following our prepared remarks, we'll open the call to your questions. Slides for today's call are available on NiceHorse.com. Before turning the call over to Lloyd, Donald, and Sean, a quick reminder. Some of the statements made during this presentation will be forward-looking. These statements are subject to risks and uncertainties that could cause actual results to differ materially from those expressed in the statements. Information concerning such risks and uncertainties is included in the MD&A and risk factors sections of our periodic SEC filings. Additionally, some of the statements made on this call relate to non-GAAP measures. For additional information on the most comparable GAAP measure and a reconciliation of these measures, please refer to the supplemental slides and segment information including our full financial schedules, available at NYSource.com. With all of that out of the way, I'd like to turn the call over to Lloyd.

Thanks, Chris. Good morning, everyone, and thank you for joining us. Hopefully, you've all had a chance to read our first quarter's earnings release, which we issued earlier today. NYSource's first quarter shows continued strong execution on our plans for growth and sustainability while providing reliable service to our customers. The resiliency and flexibility of our business plan continues to support our commitment to deliver 79% compound annual growth in NOEPS non-GAAP from 2021 through 2024. First of all, I want to thank the employees and contractors of NYSource for their continued commitment to safely serving our customers. Now let's turn to slide three and take a closer look at our key takeaways. While we are committed to completing our generation transition from coal by 2028, we expect delays in most of the solar and storage projects intended for completion in 2022 and 2023. These are due to the uncertainty hanging over the solar panel market as a result of the Commerce Department investigation. As a result of the projected delays, We now expect to retire the remaining two coal units at Schaefer Generating Station by the end of 2025. Despite those delays, we are confident in reaffirming our 2022 guidance of $1.42 to $1.48 diluted non-GAAP NOEPS. And we are reaffirming our forecast for the 79% compound annual growth rate from 2021 through 2024. including near-term annual growth of 5% to 7% through 2023. We will exercise flexibility in our business plan by pulling forward modernization projects in our gas and electric business and employ O&M expense agility to support our plan. NYSERCH will host an investor day in the fall where we expect to have more clarity on our business review and solar project completions. we intend to provide you with a definitive long-term plan beyond 2024. We continue to make strong progress in our regulatory agenda with a settlement in NIPSCO's gas rate case and new cases filed in Pennsylvania and Virginia. And NYSOR has posted non-GAAP diluted net operating earnings per share, or NOEPS, of 75 cents in the first quarter versus 77 cents last year. We have a lot to discuss this morning, but I would like to take a few moments to share some observations from my first few months here at NYSource. I've had the opportunity to meet with employees, leaders, customers, regulators, policymakers, and many others. I see some real strengths, and I also see opportunities for improvement. Here are some areas we will be focusing on. First and foremost, we will continue to focus on enhancing safely. This allows us to provide the best possible service to our customers. We are intent on maintaining our regulatory excellence. We have completed several rate cases in the past year. We have a number of cases pending. Together, they will provide additional visibility underpinning our rate-based growth forecast. We will relentlessly pursue operational excellence across the businesses to ensure safety, reliability, and enhance customers' experience and organizational productivity and efficiency. Our focus on these areas will help us build on the core strengths of our business, our investment-driven growth plan, and the opportunities we see in the NYSource footprint. Now, we want to update you on how the government solar panel investigation is affecting our renewable generation plan. I'd like to turn it over to Shawn Anderson.

Shawn? Thank you, Lloyd, and good morning, everyone. As most of you are aware, the investigation by the U.S. Commerce Department related to the import of solar components from certain countries has brought uncertainty and delays to the solar panel market. We, along with others in the industry, continue to advocate for an expeditious resolution to this investigation. The uncertainty that this investigation has introduced underscores the need for continued development of the domestic clean energy supply chain which NYSource is very much supportive of. The NYSource team has been in constant contact with our diverse renewable generation developers. We've worked hard to gain a better understanding the potential project delays might have on our plans and our generating portfolio. Our renewable generation plans include 10 solar projects, which are intended to replace the retiring capacity at Schaefer Generating Station. including two projects currently under construction. Indiana Crossroads Solar and Dunn's Bridge One broke ground in fourth quarter 2021. We are shifting the anticipated in-service date from the end of 2022 to reflect a mid-2023 targeted date reflective of an anticipated delay associated with the Department's investigation. These projects and most of our other solar projects at various stages of the development process are expected to be delayed by approximately six to 18 months from the originally targeted completion across 2022 and 2023. It is important to note that this is a broad timeframe given the uncertainty, but ultimately each project will be impacted differently. We are working with our developer partners to refine our assessments on the expected impact. Given these delays, we now expect to retire Schaefer's remaining two coal units by the end of 2025. However, we continue to expect Michigan City Generating Station to retire on schedule between 2026 and 2028. These retirements project NYSORCE to eliminate all coal-fired generation by 2028 and continue to track toward our targeted 90% reduction in greenhouse gas emissions by 2030. It is important to underscore the potential unintended consequences for our customers. As we demonstrated in our 2018 and 2021 IRP, the renewable resources we are adding to the portfolio drive significant cost savings to our customers and help insulate them against high commodity and energy prices. Our focus has been to accelerate savings for our customers to benefit from the renewable transition, and delays resulting from this investigation may ultimately delay the timing of when our customers can begin receiving these benefits, especially in the current energy cost inflationary environment. As the investigation relates to our capital investment plan, we believe the primary impact is timing. and continue to expect renewable investments to total approximately $2 billion, primarily between 2022 and 2024, with any remainder expected in 2025. At the beginning of our discussion today, Lloyd mentioned the flexibility in NYSource's financial plan, and this is where the diversification of our operating companies can support our long-term commitments. We expect to adjust our modernization investments to account for the timing changes in renewable energy project investments to remain on track to make capital investments totaling approximately $10 billion during the 2021 and 2024 period. These capital investments are expected to drive compound annual base rate growth of 10 to 12% for each of the company's businesses through 2024. Now I'd like to turn the call over to Donald, who will discuss our investor day and financial performance in more detail.

Thanks, Sean, and good morning, everyone. I'd like to start with that we have moved the timing to hold an Investor Day event to this fall. We believe shifting the timing of our Investor Day will allow us to gain a clearer line of sight into the solar project timing and provide more details around the business review so that we can provide a definitive long-term plan beyond 2024. During this fall event, we intend to provide an extension to our capital investment and growth plan, a detailed update on our generation transition and ESG profile, as well as give you an opportunity to hear from the leaders of our businesses. Now, turning to our first quarter 2022 results on slide four, we had non-GAAP net operating earnings of about $329 million. or 75 cents per diluted share compared to non-GAAP net operating earnings of about $305 million or 77 cents per diluted share in the first quarter of 2021. These first quarter 2022 results represent a solid start to the year. And as Lloyd mentioned a few minutes ago, we have reaffirmed our 2022 guidance of $1.42 to $1.48 in all of our long-term diluted non-GAAP net operating earnings per share growth rates. Taking a closer look at our segment non-GAAP results on slide five, gas distribution operating earnings were about $405 million for Q1 of 2022, representing an increase of approximately $31 million versus the same quarter last year. Operating revenues, net of the cost of energy and tract expenses, were higher by approximately $66 million, mainly due to new rates resulting from base rate cases and regulatory capital programs. Operating expenses, again, net cost of energy and tract expenses were higher by approximately $35 million. In our electric segment, non-gas operating earnings for the first quarter were about $99 million, which was about $8 million higher than 2021. Operating revenues net of the cost of energy and tract expenses increased by approximately $9 million due largely to revenue from regulated investments, and other operating expenses were essentially flat to 2021 levels. Now, turning to slide six, I'd like to briefly touch on our debt and credit profile. Our debt level as of March 31 was about $9.8 billion, of which $9.2 billion with long-term debt with a weighted average maturity of approximately 14 years and a weighted average interest rate of approximately 3.7%. At the end of the first quarter, we maintained net available liquidity of about $1.9 billion, consisting of cash and available capacity under our credit facility and our accounts receivable securitization programs. We also continue our commitment to retaining our current investment credit ratings And I would note that Fitch has completed their 2022 annual credit review with no change to our rating or outlook. Our debt and credit profile continue to represent a solid financial foundation to support our long-term safety and infrastructure investments. As you can see on slides 7 and 8, we are in the process of making some adjustments to our financial plan to reflect expected delays in solar generation projects, that will help mitigate the earnings impact of these delays and enable us to maintain our 2024 EPS growth commitment. Both the long-term visibility of our capital plan and the flexibility in our regulatory mechanisms illustrates the resiliency and strength of our business and provides us confidence to maintain all of our commitments, including EPS growth. Taking a quick look at slide nine, which highlights our financing plan, The only slight change to our financing plan is to extend the potential timing related to the debt financing of the renewable generation investments, which, as we indicated on slide 8, provides incremental interest savings to mitigate the renewable project delays. Again, this balanced financing plan is consistent with all of our earnings growth and credit commitments. Now, I'll turn it over to Lloyd, who will discuss our utilities highlights.

Thanks, Donald. Let's look at the NYSource gas distribution highlights for the first quarter, starting on slide 10. Columbia Gas of Virginia filed a rate case on April 29th to continue its safety and modernization investments. The case seeks an increase in annual revenues of approximately $58 million. Columbia Gas of Ohio is preparing its response to the report from the staff of the Public Utilities Commission of Ohio. Once that is filed, we look forward to beginning settlement discussions. Columbia Gas of Pennsylvania filed a rate case on March 18th. It focuses on upgrading and replacing gas lines for the long-term safety of customers and communities. The case requests additional revenues of about $82 million. It also seeks to provide additional energy efficiency options while balancing costs. NIPSCO has filed a proposed settlement in its gas rate case. the agreement would provide a revenue increase of approximately $72 million annually. In addition to infrastructure modernization, the proposal would enable NIPSCO to continue to serve customers with a safe, reliable supply of natural gas while remaining in compliance with state and federal safety requirements. NIPSCO also filed a petition on April 1st seeking approval of federally mandated pipeline safety costs, including nearly $229 million of capital costs and about $34 million of operating and maintenance programs. In addition, I'd like to mention that Nisource has joined the Coalition for Renewable Natural Gas. We believe natural gas infrastructure will play an important role in America's energy future, potentially carrying renewable natural gases as well as other low-carbon fuels, such as hydrogen. As Nisource explores opportunities to further decarbonize its natural gas system, Its local distribution companies are pursuing programs that will allow customers to reduce the carbon intensity of their natural gas usage through the renewable natural gas and carbon offset. Regulatory filings seeking approval of these programs are underway in Pennsylvania and Virginia, similar to NPSCO Green Power Rate Program that has been in place for several years. Let's turn now to our electric operations on slide 11. Analysis continues on new generation investments resulting from the 2021 Integrated Resource Plan. NIPSCO filed a petition with the Indiana Utility Regulatory Commission seeking approval of NIPSCO's federally mandated calls for remediation of the coal combustion residual ash pond at Michigan City Generating Station. We will be removing coal combustion residuals and replacing them with clean fill. The federally mandated costs include a total estimate $40 million of retirement costs. Before we take your questions, I'd like to highlight our safety progress. Safety continues to be the foundation of everything we do at Nisource. To give stakeholders a view of our strategy and achievement, we have published our inaugural annual safety report. Highlights include our risk management and continuous improvement activities, continue safety investments in technology integration to enhance safety. The report is available on the NISource website, and I would encourage everyone to take a look. One very significant item in the report is the launch of the Natural Gas Safety Management System Collaborative, an effort among safety-focused energy companies. Its aim is to drive progress and maturity of safety management systems at member companies. NYSource will benefit from sharing information and learning from the experiences of others. I want to thank you all for participating today and for your ongoing interest and support of NYSource. We're now ready to take your questions.

At this time, I would like to remind everyone, in order to ask a question, press star, then the number one on your telephone keypad. Your first question comes from the line of Nicholas Campanella from Credit Suisse. Your line is open.

Hey, good morning, everyone. Thanks for taking my question. Lots of good detail on the deck. I guess just to kick it off, on the $1 billion of renewable investments in service by 23, I know you talked about the six-month, the 13-month window. Can you just kind of give us a little bit more detail on what's given you confidence in being able to get these projects done in the 23 window? I guess just the risk would be that the $1 billion would slip to 24, and Are these 23 projects just on that six-month side of the window, of the six to 13-month window, or just what can you kind of tell us there?

Thanks, Lloyd.

Appreciate that. Nick, appreciate the question. So first off, I think you said six to 13. I just want to make sure it's clear. We have a are projecting a six to 18 month delay at this time for all projects. It will vary by project and to your point, the reasons that we might see a different duration of delay for the projects that are currently under construction are because we began the construction process for those projects in 2021. And they're simply further along in the process to have a better understanding of the timing to complete despite the disruption that we've witnessed more recently. So for these projects, we're comfortable advancing them to completion, giving the compelling economics, and they provide great line of sight to what it would take to complete at this point. The team's very active in that process. For the 2023 projects, so the other projects, we simply haven't started the construction process yet, which gives us the ability to assess the impacts of the tariffs and the timing associated with the investigation to better inform what the timelines might be. And to your other point, with the billion dollars, we've got approximately $400 million of that already constructed and operational. Those are operating assets today. Likewise, we see low risk in the transmission-related projects, which is another $150 million of high-confidence projects. The projects that are limited in scope here to the DOC investigated risks are just those two projects that amount for the balance of the billion dollars. So that 440 on the two projects currently under construction. I'd also note as well, we do have wind projects that you wouldn't be subject to the same DOC related risk. Some operational, of course, also included without a delay in 2023.

So it's really just, to clarify, it's really just the $400 million to $500 million that's in this six to 18 months delay window in terms of 23 capital?

No. No, it's $440 million associated with the two existing projects that are going to continue construction during the conclusion of this investigation. The delays could also apply to the balance of projects. meaning most of our projects could experience a delay of six to 18 months, we would need clarity from the investigation to better inform the duration of delay associated with all of the other projects.

Okay, that's helpful. I appreciate that. And then I guess just a question for Lloyd on strategy. You know, you've been in the seat for a few months now. Last call, you kind of talked about being open to buying and selling assets. Just How has your kind of thinking evolved at all here? If you could just update us, please.

So we're still in the midst of our strategic business review. We have a group of senior executives in the company and board members, and we're walking down a specific process to do those evaluations. We have an outline and a timeline we're operating on. And I expect to reveal that information in the fall when we do our investor day.

Thanks a lot. I'll go back in the queue.

Your next question comes from the line of Shar Perez from Guggenheim Partners. Your line is open.

Hey, good morning, guys. Morning, Shar. Lloyd, let me just fine-tune the prior question. Just as far as strategy and the analyst day, I'm curious if, you know, since it was pushed off from, you know, obviously the tenant of this month till the fall, are you going to be in a position to actually announce some strategic moves with the utilities, meaning transactions with defined closing dates? or would you just sort of highlight which utilities could be under a strategic review and that you'll continue to update us as time goes on? So maybe taking a playbook from one of your Texas peers.

I'm not far enough along in the process to determine that right now, Char, of specifically what I'm going to announce. I think that, you know, I think the question you're getting at, will we have answers in the fall, and the answer to that will be yes. I'm not going to foreshadow announcing any kind of transactions or anything on this phone call. What I'm going to foreshadow is we'll have answers in the fall, and we expect definitive announcements in terms of where we're taking the business. Got it.

That's helpful. And then just one more on the prior question is just on sort of the DOC investigations. I mean, hopefully we'll get a proposed decision in August, but then there's going to be a 150-day comment period. So, I mean, you can actually have some pricing uncertainty that'll carry beyond sort of what you guys are thinking. So what's the level of confidence that when you guys have the Annals Day, you're going to have enough information to be able to provide a longer-term CapEx number, and we don't see incremental projects kind of being shifted out?

I'll start it, and I'll turn it over to Sean. You know, I think... By the time we get to Investor Day, we're running different scenarios and alternatives in our integrated resource plan. And those scenarios and alternatives do include further delay on this commerce investigation. Now, we have, I'll say, a diverse set of utilities with significant modernization projects and other capital opportunities that we believe we can pull forward and continue to execute our plan until this investigation is done. But Sean, you want to weigh in on anything else there?

Thanks. Well, I appreciate it, Char. Char, thanks for the question. Good morning. I think that at a minimum, I'd expect we'd have a range or an idea of where the projects could potentially grow, if you will. Although I'd say that anything the DOC can do to help refine and narrow the scope would be helpful for us to understand how it could possibly apply to our specific projects. What seems to be unique about this investigation is that It can be very component-specific in how it's applied and thus how it impacts your specific supply chain. So it's hard to look at a headline, so to speak, and then apply it directly to your situation. You really have to look at things on a project-by-project basis, how it's financed and what efficiencies we might already have being somewhat earlier in the queue on some of these projects, like Dunn's one in Indiana Crossroads. So I think our focus for the next few months is going to be understanding from our developer partners the range of outcomes that could grow and also look to the Department of Commerce to hopefully refine the scope of the investigation to help us better inform the very answer to your question.

Got it, got it. And then just real quick lastly for me is, you know, on slide eight you guys show sort of the impacts of the delayed renewable investment and how you're able to pull forward, track APEX and sort of other investments in 22 and 23 to help offset the impact in 24, right? But you also do kind of highlight that sort of that annual CapEx timing and amounts can shift. So if we're sort of thinking about your 7% to 9%, you know, CAGR, are you now kind of more back-end loaded? So we should be modeling maybe bottom-end in the near term. I guess how do we think about the shaping in light of the CapEx shuffling, the delays shifting? seem a little bit more impactful versus what you can track forward?

No, I wouldn't do any shaping of that. You think about our capital programs and the tracker mechanisms we've got in place, it really does allow us to get earnings and cash flows on average about 12 months after we make those investments. We'll start that in 2022 and go into 2023. And so it really does support that. our annual guidance as well as our long-term CAGR.

Terrific. Thanks, Donald. Thanks, Lloyd and Sean. Talk to you guys soon.

Yep. Your next question comes from the line of Richard Sunderland from J.P. Morgan. Your line is open.

Hi. Good morning. Thanks for the time today. I'm going to turn to the Schaefer update. Do you need any approvals, whether MISO or Indiana, on the extension there? Are there any EPA implications with the change in the retirement?

I'll turn to Sean for specifics, but we do not need any specific EPA approvals to move that retirement date on Schaefer.

That's right, Lloyd, and we've begun discussions with key stakeholders, including MISO, the IORC, as well as our team there to understand the ramifications with that.

Understood. And then you've talked about timing around the renewables capex, but just curious on the cost side if you're seeing any potential ramifications here. I know you reiterated the $2 billion, but just thinking about the risk maybe as you move further out, any considerations or thoughts there?

I think yes. The answer is that we do, I mean, especially around labor costs on some of these projects. I mean, just like the rest of the world, I mean, everybody's seeing inflation everywhere. So just like the labor costs on these projects are going up, I mean, so is the price of our commodity natural gas and the overall price of energy. So I think when you think about investing or continuing to invest in renewable projects, I think you have to look at it holistically and understand how that compares with the price increases. on other forms of energy and decide which ones you want to continue to invest in to provide reliable service to the customers.

I'd say a follow-up. It's too early. As we are in the process, we're working with our developers for us to update any estimates on the individual projects. As we get more clarity and negotiate and work with those developers. We'll update the amounts as appropriate or if appropriate.

That's very clear. Thank you for the time.

Your next question comes from the line of Brian Lee from Goldman Sachs. Your line is open. Brian Lee from Goldman Sachs. Your line is open. Your next question comes from the line of Travis Miller from Morningstar.

Your line is open.

Good morning, everyone. Thank you. Just wanted to be crystal clear here. These are anticipated or potential delays on those projects, right? Or have you actually heard from suppliers that they won't be able to deliver on those projects? Just wanted to be sure I understand that.

The question you're asking, are these about projects that we have started, that Sean mentioned started in 2021, or the projects that have not started at all? I'm just trying to clarify the question. Yeah, the ones that haven't.

That's the 440 that you're referring to, right?

That's correct. Go on. Yeah, the projects that have not begun the construction process, to your point, are projected Delays of 6 to 18 months and that's the updated in-service date that we are estimating on the slide in the supplemental materials. The projects currently under construction is our best line of sight to what it would take to conclude construction and have those become COD. So those would be a little bit more definitive in the terms of how the delay would impact an in-service date in contrast to the ones that haven't begun the construction process and are still just estimated. Okay.

So if something were to resolve quickly around just any of this uncertainty, it's possible that you'd still be on track for the CapEx budget that you laid out before.

Yes.

Okay. I just want to clarify that. Second, just thinking about where gas prices have gone and your cadence of rate increases and rate filings, any thoughts on how customer bill might impact? I know you've got the two rate cases going here, but any future, either later this year or next year?

Thanks for asking that question. And we're always thinking about customer rate impact and customer bill. I think part of this is we try and put CapEx in the system to drive value for customers. We're also trying to drive productivity and efficiency to offset some of those customer increases. But in answer to your question, we are thinking about customer bill impact and continuously having It's the conversation with regulators about what that means. Okay. Great. Thanks so much. That's all I have.

Your next question comes from the line of Brian Lee from Goldman Sachs. Your line is open.

Hey, can you guys hear me okay?

Yes, Brian. Good morning.

Hey, I apologize. This is Intu. I don't know why my colleague put on the call, but it's Intu here. Thanks for taking my question. My first question is on, you know, your commentary on how the, you know, how the solar installs on the Schaefer retirement, if that had gone on the original timeline, would have, you know, helped meaningfully lower customer bills. You know, now that it's delayed and with the plan that you've laid out in place to replace all of that CapEx with other items as well as O&M, just how confident are you that, you know, the customer bill impact from this revised plan you know, won't face potential regulatory hurdles. I know part of that is supported by, you know, tracker-related CapEx, but just wanted to see your confidence, color on confidence that the 24 earnings power should remain unchanged.

Pablo, why don't you take that?

Yeah. Hi, Insu. Great question. And I'd say that I'd point to kind of the diverse portfolio across the companies that we're going to be leveraging. So it won't necessarily fall solely in the Indiana jurisdiction where we would be making investments to help pull forward some of those capital opportunities. So we would be spreading that to the extent that we can across our companies where we have those investment needs and we've got the capacity to do that. So that would help to moderate the impacts on any one customer group. And then, of course, we'll continue to look for opportunities to, you know, refine efficiencies and productivity savings, you know, across all the jurisdictions to help offset that as well.

Okay. Got it. That's helpful. My second question, just looking at the quarterly results, unless I missed something, it seems like on the gas ONM side, there was a meaningful, you know, decent amount of increase there. And I think you've laid out on the supplemental forms, the labor, materials inflation. I don't know if that was more directed towards gas only, and I didn't see it really on electric, but is there anything on the gas side that was having more of an inflationary impact and just related to that, you know, how, you know, uh, just commentary on, you know, how you think you would be able to manage that, um, and, you know, be at the, the, at least the middle of that 22 guidance range for the year.

Yep. So I'll start that in probably or Donald, Donald can wait. And we, we look at our gas business, especially this winter, we had a very challenging winter. And when you do gas work, you know, you're doing a lot of digging in the ground and you're dealing with weather, weather incidents, your productivity levels, are typically not where you need them to be. The ground's harder, a lot harder to get to some of our leaks. Over time, as the weather clears up, we expect to get those productivity gains back. So I think it's more of a weather issue that we can turn around here in the near term.

Pablo? Yeah, I agree with that. It's been an extremely wet start to the season, which delays some of our construction work, which then puts folks working on other types of compliance and operations work that shifts that capital O and MX a bit. So we saw that shift happen in the first quarter. We expect to see that shift back and have the ability with the work out there to make up that difference as we look at the balance of 2022.

And then I'd follow up on inflation. We are seeing higher inflation on materials and fleet and some outside services for We're seeing ranges of 6% to 10% this year. We're actively managing that and looking to lock in some multi-year contracts so that we can limit those increases and at least have predictability around those increases. However, I'll go back to all of this is included in our guidance. for this year in our long-term plan. So, you know, we're comfortable with our guidance. We're comfortable with the expenses we're seeing, but we're also actively managing going back to thinking about long-term customer affordability of our programs.

Okay, got it. So this was largely known. Okay, that's helpful. Thank you so much.

Your next question comes from the line of Julian DeMolin-Smith from Bank of America. Your line is open.

Hey, good morning, team. Thanks for the time. Appreciate it. Hey, I hope you guys are doing well. So maybe just to kick things off a little bit here, I'm going back to that last question on the 6% to 10% cost inflation. What metric were you quoting there on that 6% to 10%? But more germane, if I can, the real question I wanted to throw in there was, can you touch on your cost reduction measures specifically in NYSERDA's next what are the costs that are being pulled out against the backdrop of that inflationary environment? And maybe to be more specific, are these sustainable cost-cutting measures on the three to four cents, or are they more one-timish in nature? And what kind of latitude are you seeing, given this inflationary environment, to potentially lean in and find more than three to four cents of opportunity here, as we look at the business, to more than offset some of these impacts?

Yeah, so if You've got a couple parts to your question. Take your time. So the first question was around inflation, what we're seeing. So we're tracking each, I'd say, category of spend across the business, electric and gas. looking at year-over-year impacts, looking at contracts to really understand what we're seeing and how to best manage those. So that's where we're seeing kind of the 6 to 10 across certain categories. In some places it's flat because we've got multi-year contracts already in place, but certainly seeing some inflation there. Other question, I think you were referring to the 4 to 5 cents In 2024, we've got line of sight to that. And we think about both from a, I'd say, NYSource Next to your point. Those would be costs that would go out over time. And to get back to Lloyd and Pablo's point around productivity, NYSource Next really is designed to increase productivity across our business, especially in the field. And so that's the long-term savings. But certainly we've got levers on a year-over-year basis to ensure that we're hitting our targets. So it's really all of the above.

Just to clarify there, 3% to 4% from the slides here on the O&M, and that is an ongoing savings opportunity, but we still got to wait for what you guys have to say in the fall here for more?

That's right. Yeah, that is right.

So part of this is we're developing, I'll say, an O&M agility methodology. As we build our O&M budgets every year, we'll have a plus or minus 2% agility in there that we can flex. And then the other part, as Donald talked about, with nice horse necks and gaining productivity, it's more structural, focused on continuously building more productivity and efficiency into the business as we go along. And we'll have more detail in the fall on both of those.

Got it. All right. Excellent. Thank you, guys.

And then just super quick, if I can, on Ohio. I know that that's in flight here, but can you discuss a little bit more specifically the delta between your ask and staff's rec? You know, obviously, you know, there's some obvious ones, but, you know, the percent of ask was low. Can you reconcile that a little bit? But even more critically, you know, not looking to front-run the rebuttal here, but what is the opportunity to potentially address some of these discrepancies here more formally?

Hey, Julian, this is Pablo. So I'll say first off, we've had and expect to continue to have constructive regulatory outcomes in Ohio over the last many years between our capital expenditure program and our IOP programs. And so we're working constructively on this issue as well. So certainly the staff report and the delta between our application and their recommendation is meaningful. We are taking the opportunity, since we've seen that report, to help clarify some of the elements inside of ours. Some of the specific elements are certainly O&M assumptions. There are some plant in service assumptions that drive some differences, and there's some liabilities and items along those lines, along environmental and such that we're working on. So we're working to clarify where we think some of the differences have been. We think that in our response to their staff report and our rebuttal, which we're gonna file this week still, we'll have an opportunity to do that, and then we're gonna file supplemental testimony by Friday of next week. And during that time, we're going to also work to initiate settlement discussions. So we still fully expect that a settlement is possible. We'll be working towards that. We think that there's a reasonable settlement out there that's going to benefit all of the stakeholders in this. And we're going to be tracking towards that, Julian.

Wish you the best of luck, Pablo. Talk to you guys soon, all right?

Thanks. Your next question comes from a line of Steve Fleischman from Wolf Research. Your line is open.

Yeah, hi, good morning. Thanks for the details that you provided this morning on the solar issue and offsets and such. So one question following up on the cost, if there are cost increases for the projects, can you give more clarity of how – how the relationship is between your developer partners and yourself in terms of who's kind of on the hook for cost increases? Is it? Yeah.

Yeah, Steve, this is Sean. So the cost of the project itself is on the build transfer agreements fully contracted for at a known price. The cost increases themselves are on the side of the developer to construct those projects. To the extent that tariffs are applied, we'd have to evaluate what the application of those tariffs are to understand that cost pressure and risk and where that lives.

Okay. So it's not clear where the tariffs, if it's tariff related, who's kind of got to deal with that issue?

That's correct.

Okay. And is it Are the contracts consistent or do they vary on that topic?

Each contract's unique, Steve, but certainly there's some components that are consistent. That particular element has the entire construct itself and how it's financed can vary and would come into consideration. So I'd describe it as each contract's unique. But the application of that itself, we'd have to evaluate as the project steps closer.

Okay. And I know you just announced this today, but the idea that an investigation is causing delays in solar projects, forcing you to extend the life of a coal plant, seems like kind of a meaningful policy issue for the same administration that's actually doing this investigation. I know it seems like it's been so far a very technical process, but there's obviously a political aspect to this. I'm just curious if you're getting any sense whether that's resonating at all or not.

Yes, Steve. I mean, I would highlight, as I did in my comments, that we're disappointed that a disruption in the solar chain is going to constitute potential delays for customers to realize benefits and some cost certainty related to fuel price volatility. That's the premise by which these projects really were born, and it's disappointing that that might occur. That said, we're optimistic the Department of Commerce can work expeditiously to provide some refinements in its investigation that can enable these projects to move through as quickly as possible. At the core of what we do, it's about reliability for our customers and the communities we serve. And that's a critical component that we are focused on, which is part of what Schaefer can deliver and has delivered for many years, which is part of the decision that we've laid out here today. But we're optimistic that even with recent refinements the DOC has provided, it can give us enough information to get clarity through the conversations with our developers to advance our specific projects as expeditiously as practical to get to, I think, what you alluded to, which is really a lower-cost energy solution with more price certainty for customers.

Great. Thank you very much.

Your next question comes from a line of Ryan Levine from Citigroup. Your line is open.

Good morning. If there are any cost overruns for solar that Nisource is responsible for, can you speak to the recovery mechanisms for these cost overruns and if the delays trigger any legal rights for the company with its counterparties on these projects? And then somewhat related, given the announced delay expectations, how are you looking at these delays impacting financing plans that relate to the ATM and other sources of funds?

I think you had a footnote in your slide on that front.

Go ahead. I think the first part of your question, I think it's too early to speculate on if the tariffs would be applied, how it would be, what the circumstances would be. By nature, the CPCNs give us the regulatory approval to move forward with these projects. We'd address that it costs variance from the projects that would be different than the existing CPCNs through the regulatory process with the IORC. So I think the question on that front end is addressed through the regulatory process itself with the IORC against the existing CPCNs to move forward.

But let me ask a clarifying question. When you talk about cost overruns, you mean there's general cost overruns of the project or cost overruns just with respect to the tariffs? Which question are you asking? More of the first, but it's both of the same. I think when you talk about general cost overruns, I think those are covered in the contract with the developer. With respect to the tariffs, I don't think those are contemplated in the contracts. Therefore, we have to work with the developer and or the regulator to decide who bears that risk.

And with regard to the financing plan, certainly we expect that if there's delays, it's going to impact, it's going to delay the any debt financing that we do on the projects. That's where we expect we'd see some savings from deferring some of that debt issuance. With regard to ATM, No changes to our financing plan now. You see the ranges that we've got outlined here. Certainly no ATM in 2023 is possible, and that's certainly taking into account both our overall business as well as those renewable projects.

Thank you. And then one unrelated question for Lloyd with the business review process. Are there certain areas of the review that has been decided to evaluate more comprehensively? And is that part of the reason for the delay in timing of the analyst day? I think you could share on that. We appreciate it.

Let me be clear. I was never – the delay in the investor day is primarily focused on the delay in the solar projects. I was never – I didn't believe I would be finished a review by a May or spring investor day. I think the level of review that we're taking, looking hard at just each of the utilities, how they contribute to the overall business, what our corporate services are, what productivity looks like in the organization, how we benchmark, all that's ongoing. And it just so happens, I believe, in that target, making sure that we're finished in the fall in conjunction with these projects so that we can give what I call a comprehensive review of strategy at NYSource in terms of how we'll grow after 2024. Appreciate the call.

Thank you.

And there are no further questions at this time. Mr. Lloyd Yates, our CEO, I turn the call back over to you for some closing remarks.

So first of all, thank you for your questions. I'd like to close by reiterating a few key takeaways. One, NYSERDA expects the Commerce Department solar panel investigation to delay solar projects. We are developing and implementing a mitigation plan to maintain our 2024 growth commitments. We're reaffirming our 2022 guidance of $1.42 to $1.48 diluted non-gap NOEPS. We are reaffirming our forecast for 79% compound annual growth rate from 2021 through 2024 including near-term annual growth of 5% to 7% through 2023. We continue to make strong progress in our regulatory agenda with a settlement in NIPSCO's gas rate case and new cases filed in Pennsylvania and Virginia. And NYSource will host the Investor Day in the fall. We intend to provide you with a definitive long-term plan beyond 2024. Thank you. We appreciate you joining us this morning.

This concludes today's conference call. Thank you for your participation. You may now disconnect.