EXHIBIT 24 

Case:17-03283-LTS Doc#:24535-24 Filed:06/12/23 Entered:06/12/23 21:36:46 Desc:

Exhibit AHG Ex 24 2023-05-30 Excerpted Estrada (LUMA)_FULL Page 1 of 9
1

2 IN THE UNITED STATES DISTRICT COURT

 FOR THE DISTRICT OF PUERTO RICO

3

4 In re: )

 )

5 THE FINANCIAL OVERSIGHT )

 AND MANAGEMENT BOARD )Case No.

6 FOR PUERTO RICO, )17 BK 3283-LTS

 )

7 as representative of )

 )

8 THE COMMONWEALTH OF )

 PUERTO RICO, et al., )

9 )

 Debtors. )

1 0 _______________________ )

 In re: )

1 1 )

 THE FINANCIAL OVERSIGHT )Case No.

1 2 AND MANAGEMENT BOARD )17 BK 4780-LTS

 FOR PUERTO RICO, )

1 3 )

 as representative of )

1 4 )

 THE PUERTO RICO )

1 5 ELECTRIC POWER )

 AUTHORITY, )

1 6 )

 Debtor. )

1 7 _______________________ )

1 8

1 9 REMOTE VIDEOTAPED 30(b)(6) DEPOSITION OF

2 0 JOSELINE NAVEL ESTRADA RIVERA

2 1 San Juan, Puerto Rico

2 2 Tuesday, May 30, 2023

2 3

2 4 Reported By:

2 5 CATHI IRISH, RPR, CRR, CLVS

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Case:17-03283-LTS Doc#:24535-24 Filed:06/12/23 Entered:06/12/23 21:36:46 Desc:

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1 ESTRADA

2 asking about the 2022 PREPA fiscal plan.

3 Was there any assessment

4 performed of whether it was realistic that

5 there would be a reduction in electricity 03:17:50PM

6 consumption of 30 percent by 2040?

7 MR. INGERMAN: Objection to the

8 form. You can answer.

9 THE WITNESS: The projections we

10 prepared for the fiscal plan are in 03:18:25PM

11 accordance with current laws and

12 regulations.

13 BY MR. MAYRELL:

14 Q. Was there any assessment of

15 whether the 30 percent reduction was, in 03:18:42PM

16 fact, likely to be achievable?

17 MR. INGERMAN: Objection, form.

18 THE WITNESS: In the case, well

19 in the work I performed such

20 assessment was not performed. 03:19:16PM

21 BY MR. MAYRELL:

22 Q. Did LUMA perform any such

23 assessment?

24 MR. INGERMAN: Objection -- hold

25 on, objection, form, foundation. 03:19:24PM

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2 THE WITNESS: I have no knowledge

3 of that matter.

4 BY MR. MAYRELL:

5 Q. Are there others at LUMA who 03:19:43PM

6 perform or create load forecasts in

7 connection with the fiscal plan process?

8 MR. INGERMAN: Objection, form,

9 foundation. You may answer.

10 THE WITNESS: Those responsible 03:20:08PM

11 at LUMA for preparing any projections

12 for the fiscal plan are under my

13 supervision and there were other

14 departments involved in preparing

15 projections of distributed generation. 03:20:39PM

16 BY MR. MAYRELL:

17 Q. Does LUMA have any view on

18 whether the 30 percent reduction in

19 electricity consumption by 2040 as set

20 forth in Act 17-2019 is realistic? 03:21:05PM

21 MR. INGERMAN: Objection, form,

22 scope, foundation. You may answer.

23 THE INTERPRETER: The law again

24 20.

25 MR. MAYRELL: Act 17-2019. 03:21:23PM

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1 ESTRADA

2 THE INTERPRETER: Thank you.

3 THE WITNESS: From my standpoint,

4 I cannot answer that question because

5 personally I did not perform an 03:22:04PM

6 analysis as to whether this is

7 realistic or not and I do not know

8 whether any other area has done so.

9 BY MR. MAYRELL:

10 Q. You indicated that another load 03:22:20PM

11 modifier concerned the adoption of

12 electric vehicles; is that right?

13 A. Yes, that is correct.

14 Q. And base case load forecast that

15 was prepared for the 2022 fiscal plan, is 03:22:49PM

16 there a point at which there is no

17 additional adoption of electric vehicles?

18 MR. INGERMAN: Objection to the

19 form. You can answer.

20 THE WITNESS: The projections 03:23:38PM

21 regarding EVs was very similar to the

22 model used for the IRP, reached out

23 the year 2040 and from that point on,

24 we did not have a conceptual framework

25 to carry out any projections beyond 03:24:07PM

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1 ESTRADA

2 2040.

3 BY MR. MAYRELL:

4 Q. Does the base case nonetheless

5 include forecasted amounts of load 03:24:20PM

6 attributable to the adoption of electric

7 vehicles after 2040?

8 A. Beyond 2040, the amount was set,

9 there was a fixed amount beyond 2040.

10 Q. Was there any assessment 03:25:04PM

11 performed of whether it was realistic that

12 the amount of load attributable to

13 electric vehicle adoption would be fixed

14 after 2040?

15 MR. INGERMAN: Objection, scope, 03:25:22PM

16 form. You can answer.

17 THE WITNESS: No, sir, no

18 assessment was performed.

19 BY MR. MAYRELL:

20 Q. Is it realistic to assume there 03:25:52PM

21 would be no additional adoption of

22 electric vehicles after 2040?

23 MR. INGERMAN: Objection, scope,

24 form, foundation. You can answer.

25 THE WITNESS: As I stated before, 03:26:24PM

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1 ESTRADA

2 a site translation when you're done

3 reading the paragraph. If it's not

4 going to be word for word --

5 MR. MAYRELL: It is going to be 03:44:03PM

6 word for word so I'll do that now.

7 BY MR. MAYRELL:

8 Q. "An alternative forecast based on

9 a bottom-up approach, that uses the

10 current situation in Puerto Rico as the 03:44:09PM

11 starting point, that is not constrained by

12 Act 17, that incorporates the latest data

13 available on current and future costs, and

14 that is supported by driver specific

15 models provides a perspective on a 03:44:21PM

16 potentially different load forecast (the

17 alternative forecast)."

18 So I read the first paragraph.

19 Have you -- are you familiar with

20 what's referred to here as the alternative 03:45:36PM

21 forecast?

22 MR. INGERMAN: Objection,

23 foundation, asked and answered. You

24 can answer it again.

25 THE WITNESS: No, sir. 03:45:53PM

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2 BY MR. MAYRELL:

3 Q. So is it fair to say then you

4 don't know whether anyone at LUMA

5 contributed to the preparation of this 03:46:04PM

6 alternative forecast?

7 MR. INGERMAN: Objection, form,

8 foundation. You can answer.

9 THE WITNESS: No, I have no

10 knowledge, sir. 03:46:20PM

11 BY MR. MAYRELL:

12 Q. In preparing to testify today,

13 did you ask anyone at LUMA whether they

14 contributed to the preparation of this

15 alternative forecast? 03:46:32PM

16 A. No, sir.

17 Q. At any point, did LUMA receive

18 any communication from the oversight board

19 stating a view on the accuracy of the base

20 forecast? 03:47:26PM

21 MR. INGERMAN: Objection, form.

22 You can answer.

23 THE WITNESS: It is usual for

24 discussions to be held with FOMB

25 personnel with regard to modifiers and 03:48:05PM

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1 ESTRADA

2 on this occasion, I believe, I am not

3 sure, I believe that we had -- that I

4 was involved in two or three meetings,

5 I'm not sure, to discuss the 03:48:41PM

6 projections, not only this one but

7 also the modifiers and what was

8 discussed in the meetings was more, it

9 was more a matter of to indicate, to

10 explain the methodology used by LUMA 03:49:14PM

11 to draw up the projections but I'm

12 not -- we were not required, at least

13 me directly, I was not required any

14 other modification.

15 BY MR. MAYRELL: 03:49:44PM

16 Q. Besides the information that you

17 were conveying to the oversight board

18 regarding the base case model, did the

19 oversight board tell you anything about

20 their views of the base case or the load 03:49:59PM

21 modifiers?

22 MR. INGERMAN: Objection to --

23 THE INTERPRETER: Sorry.

24 MR. INGERMAN: That's okay.

25 THE INTERPRETER: Views of the 03:50:13PM

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