EXHIBIT B

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UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO RICO, et al., 

Debtors.1

PROMESA 

Title III 

No. 17-BK-3283-LTS 

(Jointly Administered) 

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO RICO, 

as representative of 

PUERTO RICO ELECTRIC POWER AUTHORITY,

Debtor. 

PROMESA 

Title III 

No. 17-BK-4780-LTS 

(Jointly Administered) 

EXPERT REBUTTAL REPORT OF ANDREW WOLFE 

1. I submit this report in response to the Expert Report of Prof. Sebastian Edwards 

dated April 28, 2023 which expresses opinions on certain methodologies and macroeconomic 

1

 The Debtors in these Title III Cases, along with each Debtor’s respective Title III case number 

and the last four (4) digits of each Debtor’s federal tax identification number, as applicable, are 

the (i) Commonwealth of Puerto Rico (Bankruptcy Case No. 17-BK-3283-LTS) (Last Four Digits 

of Federal Tax ID: 3481); (ii) Puerto Rico Sales Tax Financing Corporation (“COFINA”) 

(Bankruptcy Case No. 17-BK-3284-LTS) (Last Four Digits of Federal Tax ID: 8474); (iii) Puerto 

Rico Highways and Transportation Authority (“HTA”) (Bankruptcy Case No. 17-BK-3567-LTS) 

(Last Four Digits of Federal Tax ID: 3808); (iv) Employees Retirement System of the Government 

of the Commonwealth of Puerto Rico (“ERS”) (Bankruptcy Case No. 17-BK-3566-LTS) (Last 

Four Digits of Federal Tax ID: 9686); (v) Puerto Rico Electric Power Authority (“PREPA”) 

(Bankruptcy Case No. 17- BK-4780-LTS) (Last Four Digits of Federal Tax ID: 3747); and (vi) 

Puerto Rico Public Buildings Authority (“PBA”) (Bankruptcy Case No. 19- BK-5523-LTS) (Last 

Four Digits of Federal Tax ID: 3801) (Title III case numbers are listed as Bankruptcy Case 

numbers due to software limitations). 

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2 

assumptions and inputs that underlie the electricity load projection used in PREPA’s Plan of 

Adjustment, and the Expert Reports of Dr. Susan Tierney and Dr. Maureen Chakraborty, both 

dated April 28, 2023, to the extent Dr. Tierney’s and Dr. Chakraborty’s reports utilize economic 

assumptions. 

I. Qualifications 

2. I have served as an economic advisor to the Financial Oversight and Management 

Board for Puerto Rico (the “Oversight Board”) and to the Government Development Bank for 

Puerto Rico, a Fiscal Consultant for the Inter‐American Development Bank, and as an Adjunct 

Professorial Lecturer at both the School of International Service at American University in 

Washington, D.C. and the Baker Institute for Public Policy at Rice University in Houston, Texas. 

3. Prior to the foregoing roles, I worked at the International Monetary Fund (“IMF”) 

for 27 years. When I left the IMF in 2014, I was the Head of the IMF Human Resource Strategy 

Unit, and, immediately before that, I was the Senior Personnel and Budget Manager of the 

Western Hemisphere Department. During my years at the IMF, I was IMF Mission Chief to El 

Salvador, Colombia, the Dominican Republic, Uruguay and Peru and IMF Resident 

Representative in Uruguay, Argentina and Peru. My responsibilities in those positions included 

leading negotiations on IMF‐supported programs, monitoring fiscal deficits in those countries as 

well as examining whether IMF financial and economic projections were met. While at the IMF, 

I set policy reform agendas for lending programs in coordination with senior advisors at the IMF 

and senior financial officials for the governments in question. I also oversaw the IMF teams that 

monitored performance of those countries pursuant to such lending programs and whether those 

countries adhered to agreed‐upon structural reforms and fiscal and monetary programs. 

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3 

4. I received my Ph.D. in Economics from the University of Wisconsin in 1985, and 

my B.S.E. in Economics and B.A.S. in Engineering from the University of Pennsylvania in 1978. 

5. A full resume is attached as Exhibit A. A list of my testimony in other cases is 

attached as Exhibit B. 

6. I am paid $850 per hour for my time. 

II. Documents and Data Sources 

7. The documents and data on which I relied in forming the opinions expressed in 

this report are (i) those identified in Prof. Edwards’, Dr. Chakraborty’s and Dr. Tierney’s reports; 

and (ii) those cited in this report, including the documents and data identified in Exhibit C.

III. Summary 

8. I was asked to opine on the Expert Report of Prof. Sebastian Edwards dated April 

28, 2023, as well as the Expert Reports of Dr. Susan Tierney and Dr. Maureen Chakraborty, both 

dated April 28, 2023, to the extent those latter reports utilize macroeconomic assumptions. This 

rebuttal report has two principal sections: a response to Prof. Edwards’ report and a response to 

Drs. Tierney’s and Chakraborty’s reports. 

9. Prof. Edwards contends the accepted methodology for projecting economic 

growth is to estimate the “Potential Output” by relying upon the Solow Growth Model. However, 

contrary to Prof. Edwards’ critique, the Oversight Board was correct to use its linear regression 

methodology to project the growth of Puerto Rico’s gross national product (“GNP”). The linear 

regression was carried out on a growth model using a vector autoregression (“VAR”) 

methodology and a seemingly unrelated regression (“SUR”) analysis to understand the 

interactions of labor and output growth in Puerto Rico in the wake of Hurricane Maria. VARs 

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4 

are a standard methodological tool for forecasting purposes and, unlike Solow growth models 

(“SGM”), are useful for short- and medium-term forecasting. 

10. The results of the SUR underscored that labor in Puerto Rico is not exogenous in 

determining output growth, but rather labor supply decisions are impacted by growth. In the 

context of a shrinking economy that means labor will migrate off the Island. In the VAR, labor 

as an input to production is captured in the lagged factor of the previous period’s GNP growth. 

The Oversight Board’s regression model was therefore appropriate and an SGM, which takes 

labor as an independent variable, would have been inappropriate to project Puerto Rico’s GNP. 

11. Because Puerto Rico’s labor force is highly mobile—and can and does outmigrate in the event of a downturn—Prof. Edwards’ comparison of Puerto Rico to sovereign 

nations is inappropriate. Residents of Puerto Rico are citizens of the United States and can and 

do relocate to the mainland United States, with a higher number of Puerto Ricans living stateside 

than on the island.2

 The comparison is also inappropriate because, unlike a nation, Puerto Rico 

does not have access to international sources of financing to help it recover in the event of a 

prolonged period of economic decline that typically would require structural reform. 

12. Prof. Edwards also argues that the Board’s economic projections are too 

pessimistic. Even if an SGM were appropriate in this circumstance—which it is not—the 

parameters and assumptions of Prof. Edwards’ SGM are far too optimistic. Setting these to 

realistic values yields GNP growth projections, even utilizing an SGM, that are very similar to 

those projected by the Oversight Board’s regression model. 

2

 Bureau, United States Census. HISPANIC OR LATINO ORIGIN BY SPECIFIC ORIGIN - 

United States - 2019 American Community Survey 1-Year Estimates, 1 July 2019, 

http://www.data.census.gov/table?q=B03001%3A%2BHISPANIC%2BOR%2BLATINO%2BOR

IGIN%2BBY%2BSPECIFIC%2BORIGIN&tid=ACSDT1Y2019.B03001. 

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13. Prof. Edwards misstates the effect of a reduction in the value of PREPA 

bondholders’ debt. The Oversight Board’s proposed reduction is appropriate and in any event 

does not threaten unexpected social and market costs. 

14. The reports of Dr. Chakraborty and Dr. Tierney contain several flaws, including a 

misplaced reliance on income attributable to the informal economy, an overly optimistic view of 

the affordability and effects of marginal additional electricity charges, and an overly skeptical 

view of the attractiveness of solar power for household electricity generation. 

IV. Response to Prof. Edwards’ Report 

A. The Oversight Board’s regression appropriately projected GNP. 

15. The Oversight Board built a regression model to project Puerto Rico’s future GNP 

growth. That model, the current version of which Prof. Edwards has reviewed, was built 

following Hurricane Maria. At that time, a vector autoregression (VAR) model was adapted as 

there was no known relationship between concurrent and lagged effects of labor movements on 

output, nor output changes on labor movements. When faced with a set of factors where most 

variables are considered exogenous, but two or more variables are thought to affect each other, 

with no known relationship between concurrent and lagged effects, an appropriate tool is a VAR. 

This is because a VAR tests the relationship between two or more variables that may affect each 

other, including the lagged effects of the variables on each other (i.e., how one variable in time t 

- n might affect another variable at time t). The Oversight Board’s VAR in effect tested whether 

population flows (and hence labor inputs) were endogenous or exogenous, i.e., whether the 

outflow of labor drives down real GNP growth or, instead, real GNP growth outcomes (or lack 

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6 

thereof) drive labor mobility decisions.3

 In a regional economy within national borders this is a 

salient consideration. 

16. The seemingly unrelated regression (SUR) results, reflected in the current 

Commonwealth fiscal plan, do not show labor as an independent variable because, having tested 

(i) whether GNP growth caused population (hence labor) movements and (ii) whether population 

movements caused changes in GNP growth, the Oversight Board found that the latter was not 

statistically significant. At first this might seem counterintuitive, but it actually makes sense. It 

makes sense because the structure of the model is saying that people do not leave the Island for 

factors outside the model and then GNP falls. Rather, the opposite is true: GNP falls and then 

people leave the Island. In other words, Puerto Rico migration is not exogenous. People do not 

simply decide to leave and then GNP growth is affected. Rather, GNP growth conditions are 

poor and that leads to decisions to leave the Island. Indeed, although the Oversight Board’s 

model shows a steadily shrinking economy, a far more troubling scenario is possible: declining 

GNP could reach a tipping point that would cause a mass exodus off the Island, causing severe 

economic collapse, which in turn would cause a vicious downward spiral and complete collapse. 

17. The result of this analysis is the Oversight Board’s Commonwealth growth 

forecast model, which is the basis for PREPA’s GNP growth projection. 

18. The regression is superior to the SGM that Prof. Edwards advocates because the 

regression is useful as both a longer-term trend-analysis tool, and also for shorter- and mediumterm trend forecasting (i.e., over the next five years), something to which an SGM, which is 

intended for long-term projections only, is unsuited. In addition, the regression, unlike Prof. 

3

 While VAR models are not the only valid technique for growth forecasting, they are widely 

used. See for example, Robertson and Tallman (1999); Sims (1992) and (1998), and Keating 

(1992). 

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Edwards’ SGM, has the advantage of being explicitly linked to mainland U.S. growth—a very 

strong predictor of Puerto Rico GNP.4

 

19. To the regression’s baseline modeling of GNP are added three principal growth 

factors—(i) the expansionary impact of Federal Emergency Management Agency (“FEMA”) 

spending and COVID relief programs; (ii) the contractionary impact of fiscal consolidation; and 

(iii) the permanent increase in growth owing to structural reform of the economy. These are all 

appropriately estimated in the growth forecast of the Oversight Board. 

20. In this connection, Prof. Edwards overstates the impact of the structural reform 

agenda in the 2022 Commonwealth Fiscal Plan. The 2022 Commonwealth Fiscal Plan contains 

only relatively modest efforts to reform the Puerto Rico economy. Most notably, in the labor 

market, the Fiscal Plan’s sole reform is the introduction of an earned-income tax credit; the 

Fiscal Plan includes no measures to increase the demand for labor. Overall, the 2022 

Commonwealth Fiscal Plan’s proposed changes, individually or collectively, will only have 

limited transformative potential. Thus, when the effects of stimulus spending wear off, the 

economy will return to the negative trend forecasted in the Oversight Board’s baseline 

projection, contrary to Prof. Edwards’ suggestion that recent economic trends indicate upward 

growth (which on a permanent basis they do not). 

21. Other aspects of the regression that Prof. Edwards questions are likewise 

appropriate: 

4

 A study by Brown (2017) finds that “[o]n average, the non-energy-producing states were 

synchronized with the United States 77 percent of the time.” In my work with Dr. Anne Krueger 

on the “Krueger Report,” we found historically there had been a strong co-movement of 

economic activity between Puerto Rico and the mainland (Krueger (2015) Report, p. 5). 

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a. The model’s time-interaction with previous year’s GNP—the “structural break” 

variable—accounts for the phasing out of the Tax Code’s Section 936 incentives 

starting in 1996 and full elimination in 2006. 

b. The PREPA Plan of Adjustment uses the non-income-adjusted GNP growth series 

because this series appropriately projects the demand for electricity from 

industrial and commercial producers whose activity was curtailed during COVID. 

c. The data used in the regression model is sufficiently accurate and the best 

available. Alternative data used by Prof. Edwards in his SGM (e.g., from the 

World Bank) is not appropriate as it contains estimates of the highly uncertain 

parameters of the informal sector in Puerto Rico. 

d. In the regression model, all the inputs to production (e.g., capital) and other 

factors considered (e.g., mainland GDP growth) are consistent with the model’s 

growth forecast. 

B. The Oversight Board’s projected decline is not unusual and is consistent with 

Puerto Rico’s status as a regional economy with fluid labor. 

22. Prof. Edwards is wrong to claim that the secular contraction in economic activity 

forecast by the Oversight Board’s regression model is counter to experience and would set 

Puerto Rico apart from the rest of the world. Puerto Rico is a region within the United States and 

not a sovereign nation. As such, comparing Puerto Rico to other nations, as does Prof. Edwards, 

is inappropriate, especially when regional data exists. 

23. Unlike labor confined within national borders, labor in Puerto Rico is free to 

move to another region where economic prospects are better. Even in the European Union, 

where borders are technically open, labor mobility is hampered by cultural factors and 

nationality change. Not so in Puerto Rico. Among other things, there are many mainland Puerto 

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Rican communities that can and do make migration smoother and more attractive than crossborder migration within Europe. 

24. This is in contrast to, say, a Greek national out-migrating following the 2009 

financial crisis. While legally free to move to another European country, the cultural and 

community-loss costs for a Greek emigree evidently prevented high levels of migration, as the 

table below shows: 

25. Regional economies can experience long-term secular declines, particularly where 

there is outmigration. Counties within West Virginia are an example: 

Labor Mobility Comparison: Greece Under Crisis and Puerto Rico Under Long‐term Economic Decline

Greece

GDP real

growth Population % change Puerto Rico

GDP real

growth Population % change

2009 11,107,017 FY11 3,691,261

2010 ‐3.5% 11,121,341 0.1% FY12 0.54% 3,679,154 ‐0.3%

2011 ‐9.1% 11,104,899 ‐0.1% FY13 ‐0.13% 3,669,197 ‐0.3%

2012 ‐7.3% 11,045,011 ‐0.5% FY14 ‐1.76% 3,626,289 ‐1.2%

2013 ‐3.2% 10,965,211 ‐0.7% FY15 ‐0.81% 3,561,312 ‐1.8%

Cumulative

  change ‐23.1% ‐1.3% ‐2.2% ‐3.5%

Source: data for Greece's GDP is: https://www.imf.org/en/Countries/GRC#countrydata.

Source: For Puerto Rico the FY23 fiscal plan of the Commonwealth and the Statistical Appendix for growth.

Source: data for Greek population is: https://data.worldbank.org/indicator/SP.POP.TOTL?locations=GR.

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West Virgina Regional Decline

County Real GDP 2002 Population 2002 Real GDP 2021 Population 2021 % change GDP % change pop

South

  Mingo 1,311,181                        27,442           452,236              ‐ 23,005 65.5% ‐16.2%

  Wyoming 716,508                           23,005           591,307              ‐ 21,051 17.5% ‐8.5%

Central

  Clay 332,437                           10,284           119,183                ‐ 7,892 64.1% ‐23.3%

  Nicholas 769,177                           26,120           578,676              ‐ 26,006 24.8% ‐0.4%

  Webster 360,628                             9,665           141,270                ‐ 8,249 60.8% ‐14.7%

East

  Grant 507,719                           11,262           400,347              ‐ 10,983 21.1% ‐2.5%

  Pendleton 194,800                             7,925           137,151                ‐ 6,142 29.6% ‐22.5%

Source: FRED. Data available starting in 2002 and last year is 2021.

Real GDP in 1000's of chained 2012 US dollars.

26. A long-term projected decline in a region (unlike a nation) also makes sense 

because a region does not have access to lenders such as the World Bank or the IMF to finance 

reforms to reverse the long-term downturn. 

27. In short, Puerto Rico’s projected long-term decline in GNP—combined with 

(modest) long-term per capita GNP growth and outmigration—is not unexpected or 

unprecedented for a regional economy with geographically fluid labor. 

C. Prof. Edwards’ SGM is flawed by overly optimistic assumptions and, if 

properly parameterized, would lead to a GNP growth projection path similar 

to that forecasted by the Oversight Board. 

28. The SGM is a standard tool for analyzing long-run growth trends. But as 

discussed above, it is more appropriate for the study of national economies or sovereigns as 

opposed to regional economies. Furthermore, it is an analysis of potential, and an underlying 

assumption of the model is that the economy is at full employment—a situation that has rarely 

existed in Puerto Rico in recent times. Notwithstanding this general critique, I show below that 

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using historical rates of growth of total factor productivity (TFP)—instead of the unrealistic TFP 

growth rates that Prof. Edwards utilized (that begin at 0.5% growth and reach 1% per year in 

2051)—would result in Prof. Edwards’ SGM generating a growth scenario very similar to the 

one in the Commonwealth growth model. 

29. For Prof. Edwards’ SGM model to produce positive growth over the long run, he 

has to make overly optimistic assumptions regarding the growth rate of TFP. Specifically, Prof. 

Edwards assumes that that TFP will start growing at 0.5% in year 1 and this growth rate will rise 

linearly to 1% by 2051—making for an average (geometric) annual TFP growth rate of 0.82%. 

Prof. Edwards’ defense of this assumption is based in part on noting that 1% is associated in 

World Bank studies with a “moderate” growth scenario.5

 However, Prof. Edwards’ SGM model, 

while generating positive GNP growth over the long term, is generating an average annual GNP 

growth rate, from 2027-2051, of only 0.23%. The World Bank would never consider this GNP 

growth rate to be “moderate.”6 

30. Moreover, looking at the experience of Japan (a country mired for more than a 

decade in a low-growth trap), as well as the United States and Germany, two countries with far 

more dynamic economies than Puerto Rico, reveals a relationship between TFP growth and 

output growth that is much more contained than assumed by Prof. Edwards for Puerto Rico. 

5

 Specifically, Prof. Edwards states in paragraph 116 of his Report: “The CBO assumes a TFP 

growth rate of above one percent for the U.S., and the World Bank attributes a one percent TFP 

growth rate assumption to a ‘moderate’ growth scenario. Other studies have also assumed growth 

rates in TFP above one percent over long time horizons, and given Puerto Rico’s future plans, a 

higher TFP growth rate would be warranted.” 

6

 See Excel file Wolfe Master Data.xlsx, tab Edwards v FP TFP correction. 

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Furthermore, Prof. Edwards’ assumed rates of growth of TFP are far in excess of what Puerto 

Rico experienced between 1996 and 2017.7

31. In a cross-country productivity study among the US, Germany and Japan, Baily, 

Bosworth and Doshi (2020) find that: 

Strong economic growth, in turn, comes from two sources, the growth in the workforce 

and the growth in output per worker (that is, labor productivity). The demographic trend 

in advanced economies has been towards lower birth rates leading to slower growth in the 

population and in the labor force, with the population aging as its growth slows. 

Immigration can supplement the growth of the domestic population, but this can generate 

social stresses and political problems. In the advanced economies, labor force growth is 

much slower than in past, particularly in Japan but also in Germany and the United 

States, with a negative impact on the rate of increase of national incomes. With slower 

labor force growth, that leaves productivity as the main driver of overall economic 

growth and, unfortunately, it too has slowed. Figure 1 shows the pattern of trend growth 

in output per employed person as calculated by the Conference Board for the United 

States, Japan, Europe, and the World Total. Productivity growth in the United States has 

been slow since the early 1970s, except for a period in the late 1990s and early 2000s. 

Japan and Germany had much faster growth in the 1970s, but their growth rates have 

declined sharply since then.8

32. The table below shows the average annual TFP and real GDP growth rates of 

Germany, the United States and Japan over the 25-year period 1992-2016; and, for comparison, 

the average annual TFP and real GNP growth rates of Puerto Rico over the 25-year forecast 

period 2027-2051, as projected by Prof. Edwards:9

7

 See Excel file, Wolfe Master Data.xlsx, tab SGM Study 011819. 

8

 Baily, M.N., Bosworth, B. and Doshi, S. “Productivity comparisons: Lessons from Japan, the 

United States, and Germany,” Brookings Institution, January 2020. 

9

 See Excel file Wolfe Master Data.xlsx, tab, WB Growth and TFP Comp. 

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33. What is clear from this table is that in the three large nation-state economies the 

rate of TFP growth is either about the same as the country’s overall growth rate; or below the 

country’s overall growth rate; in the case of the United States, where real output growth was 

significantly higher than in the other two countries, TFP growth lagged that rate by almost half. 

34. It is unreasonable to project that Puerto Rico could have an average rate of growth 

of TFP almost 4 times its average GNP growth rate. This projection is especially unreasonable 

in light of the fact that in an SGM model that I had previously developed, I found an average 

growth for Puerto Rico in TFP of only 0.19% from 1996-2017, well below the 0.82% average 

rate assumed by Prof. Edwards.10 

35. I adjusted for the unjustified optimism in Prof. Edwards’ model by making Prof. 

Edwards’ model’s TFP growth rate comparable to the TFP growth rate observed in the period 

1996-2017. Making this adjustment brings Prof. Edwards’ model’s projection of GNP much 

10 See Excel file Wolfe Master Data.xlsx, tabs Full Edwards v FP proj Summary and Edwards v 

FP TFP Correction. 

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closer to that of the Commonwealth fiscal plan.11 Notably, the adjusted model is characterized 

by a negative growth every year starting in 2031 (except in one year when growth is 0.1%).12

Thus, even if an SGM is used, as Prof. Edwards advocates, an SGM produces a GNP growth rate 

projection path similar to that of the Oversight Board’s growth model so long as it is 

parametrized with reasonable underlying assumptions. 

11 I also adjusted Prof. Edwards’ SGM by using the Oversight Board’s GNP projections for 2022-

26, not Prof. Edwards’ original SGM’s projections for this period. The SGM is not appropriate 

for near-term projections. 

12 For details see Excel file Wolfe Master Data.xlsx, tab Edwards v FP TFP correction. 

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D. Prof. Edwards’ SGM has additional flaws and errors. 

36. In addition to its overestimation of TFP, Prof. Edwards’ model suffers from other 

problems: 

a) Prof. Edwards states that the investment rate for non-disaster-relief (“DRF”) capital 

starts at 27.3% in FY2021 (and then declines, etc.). (Edwards Report Ex. 18, 

parameter 3.) In fact, the material Prof. Edwards relies on for the 27.3% figure 

Baseline Solow GNP

projection (using

Oversight Board figures

for FY2022‐26 and

Edwards' growth‐rate

projections thereafter)

Baseline Solow GNP

projection year‐over‐

year growth rate

Edwards'

year‐over‐

year TFP

growth rate

Revised Solow GNP growth‐

rate projection (using

Oversight Board figures for

FY2022‐26 and historical

0.19% TFP growth rate

thereafter)

Revised Solow GNP

projection (using

historical 0.19% TFP

growth rate)

Original GNP

projection

(using

Oversight Board

figures)

Difference between

Revised Solow GNP

projetion and

original GNP

Projection

2021 5,760,878,829                    

2022 5,912,790,676                     2.64% 0.50% 2.64% 5,912,790,676            5,912,790,676 0.00%

2023 5,967,676,184                     0.93% 0.52% 0.93% 5,967,676,184            5,967,676,184 0.00%

2024 5,927,451,827                     ‐0.67% 0.53% ‐0.67% 5,927,451,827            5,927,451,827 0.00%

2025 5,927,833,098                     0.01% 0.55% 0.01% 5,927,833,098            5,927,833,098 0.00%

2026 5,946,563,741                     0.32% 0.57% 0.32% 5,946,563,741            5,946,563,741 0.00%

2027 6,045,545,781                     1.66% 0.59% 1.27% 6,021,993,476            6,004,570,633 0.29%

2028 6,128,916,048                     1.38% 0.60% 0.97% 6,080,149,618            6,033,336,186 0.77%

2029 6,182,561,710                     0.88% 0.62% 0.44% 6,107,190,436            6,027,947,612 1.30%

2030 6,213,043,213                     0.49% 0.64% 0.05% 6,109,952,957            6,008,053,246 1.67%

2031 6,234,250,502                     0.34% 0.66% ‐0.12% 6,102,395,169            5,997,839,019 1.71%

2032 6,225,534,413                     ‐0.14% 0.67% ‐0.62% 6,064,433,241            5,953,869,873 1.82%

2033 6,210,345,929                     ‐0.24% 0.69% ‐0.74% 6,019,345,100            5,911,662,684 1.79%

2034 6,192,364,187                     ‐0.29% 0.71% ‐0.81% 5,970,811,097            5,863,973,453 1.79%

2035 6,179,319,554                     ‐0.21% 0.72% ‐0.74% 5,926,349,239            5,814,983,655 1.88%

2036 6,141,622,096                     ‐0.61% 0.74% ‐1.16% 5,857,526,746            5,731,494,272 2.15%

2037 6,120,971,740                     ‐0.34% 0.76% ‐0.90% 5,804,532,778            5,672,307,517 2.28%

2038 6,112,543,301                     ‐0.14% 0.78% ‐0.72% 5,762,541,703            5,625,242,754 2.38%

2039 6,113,298,772                     0.01% 0.79% ‐0.59% 5,728,507,959            5,587,315,795 2.46%

2040 6,120,355,040                     0.12% 0.81% ‐0.50% 5,699,591,663            5,556,545,289 2.51%

2041 6,165,587,620                     0.74% 0.83% 0.10% 5,705,382,817            5,557,554,115 2.59%

2042 6,135,805,344                     ‐0.48% 0.84% ‐1.14% 5,640,471,146            5,501,183,077 2.47%

2043 6,146,455,461                     0.17% 0.86% ‐0.50% 5,612,361,598            5,477,108,324 2.41%

2044 6,156,063,470                     0.16% 0.88% ‐0.53% 5,582,456,052            5,454,676,489 2.29%

2045 6,164,507,313                     0.14% 0.90% ‐0.57% 5,550,678,056            5,433,729,428 2.11%

2046 6,174,416,255                     0.16% 0.91% ‐0.56% 5,519,432,724            5,414,703,337 1.90%

2047 6,195,068,007                     0.33% 0.93% ‐0.41% 5,497,000,622            5,402,407,844 1.72%

2048 6,213,425,025                     0.30% 0.95% ‐0.46% 5,471,614,477            5,386,704,991 1.55%

2049 6,235,663,219                     0.36% 0.97% ‐0.42% 5,448,772,097            5,372,304,326 1.40%

2050 6,260,499,042                     0.40% 0.98% ‐0.39% 5,427,285,915            5,360,776,403 1.23%

2051 6,281,745,397                     0.34% 1.00% ‐0.47% 5,401,751,223            5,350,534,622 0.95%

Simple average 2027‐2051 0.22% 0.79%

Geometric average 2027‐2051 0.23% 0.83%

Revised Edwards SGM, using Historical TFP Growth Rate

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16 

clearly applies to all capital, not just non-DRF capital. Thus, Prof. Edwards’ analysis 

double counts the amount of the capital stock in the Puerto Rican economy going 

forward; this would inflate his model’s GNP numbers over time. Moreover, the postFY2026 parameter of 23% non-DRF investment trend that Prof. Edwards assumes is 

somewhat elevated; the average investment rate in the years 2012-2017 is 21.8%. 

b) Prof. Edwards calculates the labor share of income in Puerto Rico to be 78.8%. 

(Report Ex. 18, parameter 11.) It is not clear from the materials Prof. Edwards has 

provided how he calculates this figure from the source he identifies (Statistical 

Appendix 2021).13 The figure for the labor share of income provided in at least one 

source cited by Prof. Edwards is considerably lower than 78.8%.14

c) Prof. Edwards’ model seems to project that the amount of capital per worker (K/L) 

will continually increase through FY2051. Under standard theory, this ratio ought to 

stabilize at an equilibrium level as the economy reaches its potential. Although Prof. 

Edwards has not provided the actual series of capital and labor (i.e., the year-by-year 

time series that shows annual capital and labor figures), I have endeavored to 

construct the data set based on the descriptions provided in Prof. Edwards’ Report 

(particularly Exhibit 18).15 My estimate of Prof. Edwards’ numbers shows that the 

K/L ratio continues to rise every year from 2027 to 2051 by an average of 0.7% per 

13 According to Prof. Edwards’ provided coding notes, he calculates the labor share of income as: 

Employees_Compensation_2021/ (Nominal_GNP_2021 - Statistical_Discrepancy_2021 -

Indirect_Business_Tax_2021 -Proprietors_Income_2021). This formula does not give the 78.8% 

figure. 

14 Acemoglu (2009), at p. 97, uses a labor share of income of 2/3 (67%). 

15 Information provided includes codes and sources but not the exact data for labor and capital. 

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17 

year and a cumulative growth of almost 20%.16 In other words, year after year each 

worker has more capital to work with—which would mean an ever declining 

marginal productivity of capital that at some point should slow investment, although 

investment never slows in Prof. Edwards’ SGM. 

E. Prof. Edwards misstates the effects of a reduction of PREPA’s debt. 

37. Prof. Edwards speaks to the effects of an “unjustifiably large” haircut on 

PREPA’s debt. That discussion is therefore irrelevant to the extent the amount of the 

contemplated “haircut” is appropriate and reasonable (which it is). 

38. Moreover, Prof. Edwards’ comparison of PREPA’s Title III case to debt 

restructurings of sovereign nations is inapt. 

39. Even a sovereign that is restructuring debt might have the option of securing 

financing through official lenders (e.g., the IMF), if the sovereign is willing to take certain 

actions typically made a condition of such loans. For a sub-sovereign entity (such as a 

municipality) the options are different. 

40. For a municipality, if funding is urgently needed during the period when the entity 

cannot access capital markets, the state can step in to guarantee the new loans or even directly 

borrow on behalf of the municipality. 

16 See my estimates of the labor force series in the Edwards model and in the Commonwealth FP 

2022 model in the Excel file, Wolfe Master Data.xlsx, tab Labor Force growth comp, and my 

estimates of the capital stock in the same file, tab K accum & TFP growth Edwards. These results 

are then used to calculate K/L ratios in the same excel file in the Full Edwards v FP proj 

summary, columns Q-V. 

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18 

41. Detroit is a prime example of a positive outcome from municipal bankruptcy 

proceedings.17 In July 2013 Detroit filed its bankruptcy petition and around a year later it had 

reduced its debt by $7 billion or about 40% of the city’s pre-bankruptcy debt. By the end of 

2018, Detroit was back borrowing in the municipal bond market. In the interim, it used the 

savings from the restructuring its obligations to, in part, spend on economic development. While 

there were costs to many involved in the bankruptcy, one would be hard-pressed to find critics of 

Detroit’s evolution since 2014. 

42. No macroeconomic forecast is perfect. But the social and market costs of 

precipitating another PREPA bankruptcy as a result of overestimating future growth (as Prof. 

Edwards’ projection certainly does) are far greater than the hypothetical costs of underestimating 

growth, which in any event will be to some degree mitigated by contingent value instruments 

(CVIs). 

V. Response to Drs. Tierney and Chakraborty’s Reports. 

43. In this section I offer responses to the expert reports of Drs. Tierney and 

Chakraborty, to the extent those reports touch on macroeconomic concepts. As an initial matter, 

I note that the 2023 Commonwealth Fiscal Plan is in some respects different than the previous 

year’s Fiscal Plan. This makes sense and is to be expected. Each year the fiscal plan is changed 

to incorporate the latest information on Puerto Rico’s economy. The new fiscal plan also reflects 

any revisions to fiscal policy stances made by Puerto Rico or the federal government; updates the 

structural reform agenda of the Puerto Rican government (both in terms of scope of the reforms 

and the timing of their implementation); and incorporates the latest projection of external 

17 For a full discussion of the Detroit bankruptcy case, see Tatum III, J.L. “Detroit’s Bankruptcy 

and Market Reentry”, Emory Bankruptcy Developments Journal, Vol. 37, Issue 1, 2020. 

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19 

economic factors that affect Puerto Rico (including the CBO’s forecast of real growth and 

inflation in the overall US economy, the outlook for world oil and food prices, and the amount of 

disaster relief funding, which in the 2023 fiscal plan is a cumulative $3 billion less than was 

forecast in 2022). Over time since the first fiscal plan for the Commonwealth was approved by 

the Oversight Board in early 2017, there have been many changes; for example, the successive 

plans have had a weakening structural reform agenda that has reduced the projected permanent 

impact on growth by more than half and, because of Hurricanes Irma, María, and Fiona, the 

earthquakes in 2019 and 2020, and COVID-19, there has been an ever-changing projection on 

federal assistance. 

44. Per capita income. It merits further clarification that, contrary to Dr. 

Chakraborty’s contention that the Oversight Board projects declining median income, the 

Oversight Board in fact implicitly projects a change in nominal household income that is 

modestly positive. This is evident from the Commonwealth fiscal plan’s projected population 

and GNP figures, the ratio of which increases over time.18 Although the Oversight Board 

projects that Puerto Rico’s overall real output will fall, that decline will be distributed among a 

declining number of workers (because the Island’s working population is forecast to shrink). 

The Oversight Board projects that both real and nominal income per capita will rise starting 

FY25 through to FY51. (This pattern of rising income per capita is consistent with one of the 

basic tenets of migration theory, namely that labor flows over the long run will tend to even out 

per capita incomes across regions.) 

45. The informal sector. In this connection, Dr. Chakraborty attempts to show that 

households have more income than reported, if one takes into account income from the informal 

18 See the FY2022 Commonwealth Fiscal Plan Excel file, macroforecast tab, lines 35-36. 

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20 

sector. The informal sector pays minimal levels of taxes, and therefore is not included in the 

Commonwealth Fiscal Plan model. To add the informal sector into the resource envelope of 

households in an additive manner is dangerous. Estimates of the size of the informal sector 

overall are tenuous and quite variable. These estimates are too uncertain to base decisions on 

how much debt is repayable. Moreover, it is not necessarily the case that inclusion of the 

informal sector would raise the calculated median household income; in fact, it is more likely 

that inclusion of the informal sector would lower the calculated median household income, as 

informal workers presumably earn less than formal workers, and it is likely not the case that 

most households have both formal and informal incomes.19 In any event, in my years at the IMF, 

we never included estimates of informal income in assessing economic program viability 

because data on the size of the informal economy is unreliable. 20 Furthermore, to the extent 

income data is based on the American Community Survey, which asks respondents to report total 

income from all jobs, that data already includes income from the informal economy.21 Thus 

making additional adjustments to reported income to account for informal wages could doublecount income from informal employment. 

19 The few examples from published literature that describe the structure of informal-sector 

households suggest that these do not tend to be mixed formal/informal households. See Estudios 

Economicos (2010), p. 15, where the authors note a 1988 study that found that the probability of 

participating in the informal labor sector is greater among young men, persons with little 

education, and those living in rural areas. 

20 Also, see for example World Bank, Poverty Data: Latin America and Caribbean, 2020 

https://databank.worldbank.org/data/download/poverty/33EF03BB-9722-4AE2-ABC7-

AA2972D68AFE/Global_POVEQ_LAC.pdf (World Bank estimates of poverty levels in Latin 

American and Caribbean countries make no adjustments for potential income from the informal 

economy). 

 17 US Census Bureau, American Community Survey, Question 43: 

https://www2.census.gov/programs-surveys/acs/methodology/questionnaires/2020/quest20.pdf. 

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21 

46. Share of wallet. Dr. Chakraborty critiques the 6% share-of-wallet (“SOW”). 

However, 6% SOW is substantial, and, as shown in Exhibit 8 in the FY2022 PREPA Fiscal Plan, 

such a level of SOW in Puerto Rico would increase the SOW gap between Puerto Rico and all 

electricity consumers in the US. 

47. Feasibility of raising rates. Dr. Chakraborty calls for raising rates to higher 

income earners and to industrial and commercial consumers. This would be unwise and 

inappropriate. 

 For the residential consumer: already facing a SOW that is roughly double of 

what it is on the mainland, higher rates would be another reason to leave the 

Island, especially given Puerto Rico’s dim prospects of growth for the next 30 

years. 

 For the commercial and industrial consumer: already at a huge disadvantage on 

the cost structure of inputs because of minimum wage requirements that are on 

the order of 250% higher in Puerto Rico than in Jamaica and a minimum 200% 

higher than in the Dominican Republic, Puerto Rico’s main Caribbean 

competitors for tourism, additional costs to electricity consumption could have 

serious consequences, especially on low-profit margin businesses.22

48. Solar panels attractive. Dr. Tierney seems to have a one-sided view of the 

economic decision by households whether to purchase solar panels. Dr. Tierney suggests that 

because incomes are low in Puerto Rico, demand for solar panels will be depressed. But it is 

also the case that the demand for solar panels depends on the expected savings from using less 

22 For minimum wages in Jamaica see: https://www.jamaicaobserver.com/latest-news/nationalminimum-wage-up-44-to-13000-weekly-holness/. For the Dominican Republic see 

https://www.sys.do/en/blog/minimum-wage-2021. 

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22 

energy from the grid. With costs and SOW at least double that of mainland areas, the significant 

cost saving from solar could be especially attractive and prompt adoption of solar. Dr. Tierney 

also ignores the other incentives for households to switch it solar, such as the poor service and 

reliability of PREPA, and the desire to generate clean energy rather than depend on fossil fuels 

for energy. 

49. Dr. Tierney overstates load. Dr. Tierney, in following Prof. Edwards’ growth 

path, overstates the base load forecast. As discussed, Prof. Edwards’ model produces an 

unrealistic outlook for growth on the Island under current polices. To bolster her position, Dr. 

Tierney makes comparisons to forecasts for base load demand in previous fiscal plans—plans 

that generally fell short of projections as presented in Figure 12 of her report. But 2017-2020 

was a difficult period for forecasting due to the impact of Hurricanes Irma and María, and 

COVID. Notably, the FY 2021 forecast actually overestimated demand in 2022, also as shown 

in Figure 12. 

50. Alternative load demand. Dr. Tierney argues for calculating load using the 

alternative load-demand scenario in the PREPA fiscal plan. This would be inconsistent with 

current law. The PREPA plan of adjustment ought to be consistent with the current legal 

framework and not anticipate falling short of standards required by law. 

* * * 

I reserve the right to supplement my opinions. I declare under penalty of perjury under 28 

U.S.C. § 1746 that the foregoing is true and correct. 

/s/ Andrew Wolfe 

Andrew Wolfe 

May 15, 2023 

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23 

Exhibit A 

CURRICULUM VITAE 

Andrew M. Wolfe 

107 Lakeside Drive 

Windham, Maine, 04062 

NATIONAL OF: United States 

CURRENT POSITION: Fiscal Consultant for the Inter-American Development Bank 

EDUCATION: 

1978 B.S.E., Economics, University of Pennsylvania 

1978 B.A.S., Engineering, University of Pennsylvania 

1985 Ph.D., Economics, University of Wisconsin 

LANGUAGES: 

English-Native 

Spanish-Fluent 

CONSULTING EXPERIENCE 

2022-present Macroeconomic Consultant for the IADB in Honduras. 

2016-2022 Macroeconomist for the Puerto Rico Financial Control Board. 

 2021-2022 Head of USAID project to design a manual for State Department staff 

involved in civil service reform 

 2021 Analysis of the Fiscal Consequences of Public Expenditure Reforms in 

Costa Rica (IADB project) 

2018 Fiscal Savings from Civil Service Reform in Cost Rica (IADB project) 

 2017 Sovereign debt analysis for the Government of Guatemala (IADB project) 

 2016 Debt Sustainability Analysis for the Government of Nicaragua (IADB 

project) 

 2016 Presentation of IMF programming process for the Government of 

Honduras (IADB project) 

UINIVERSITY EXPERIENCE: 

2017 - 2022 Rice University, Adjunct Faculty in the James Baker School of Public 

Policy 

2013 - 2021 American University, Adjunct Faculty in the School of International 

Studies 

1983 - 1986 Bowdoin College, Assistant Professor 

IMF CAREER: 

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24 

1987-1992 Economist, Western Hemisphere Department (WHD) 

1992-1995 Resident Representative, Uruguay (1992-95) and Argentina (1994-95) 

1995-1997 Senior Economist, Fiscal Affairs Department 

1997-2000 Resident Representative, Peru 

2001-2002 IMF Mission Chief, Peru 

2002-2005 IMF Mission Chief, Uruguay 

2005-2006 Senior Resident Representative, Argentina 

2006-2009 IMF Mission Chief, Dominican Republic 

2009-2011 IMF Mission Chief, El Salvador and Colombia 

2011-2014 Senior Personnel and Budget Manager, WHD, Head of IMF Human 

Resource Strategy Unit 

PUBLICATIONS: 

"Fiscal Accounting of Bank Restructuring". With James Daniel and Jeffrey Davis. IMF Paper on 

Policy Analysis and Assessment (PPAA/97/5), 1997. 

“Las Orígenes, las Políticas, la Recuperación, y las Lecciones Aprendidas”. Uruguay: Qué 

Aprendimos de la Crisis Financiera de 2002?. World Bank (May 29, 2007). 

“A Primer on Currency Unification and Exchange Rate Policy in Cuba: Lessons from Exchange 

Rate Unification in Transition Economies”. Co-author with Gabriel DiBella (IMF), Presented at 

the 2009 American Economics Association Meetings. 

“Recession and Policy Transmission to International Tourism: Does Expanded Travel to Cuba 

offset Crisis Spillovers? Co-author with Rafael Romeu (IMF), ASCE 2010. 

“Cuba: An approximation of the Output Gap”. Co-author with Gabriel DiBella and Rafael 

Romeu (IMF), Presented at the 2011 American Economics Association Meetings. 

“Puerto Rico—A Way Forward”. With Anne O. Krueger and Ranjit Teja. Report written for the 

Government Development Bank of Puerto Rico, June 2015. 

“Puerto Rico—Diagnosis of the Problem”. With Anne O. Kruger. Chapter in upcoming book on 

the economic crisis in Puerto Rico (manuscript in draft). 

 

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25 

Exhibit B 

Previous Expert Testimony 

Peaje Investments LLC, v. Puerto Rico Highways and Transportation Authority, U.S. District 

Court for the District of Puerto Rico (Adv. Proc. No. 17-151-LTS in 17 BK 3567-LTS; Adv. 

Proc. No. 17-152-LTS in 17 BK 3283-LTS) 

 Deposition, July 2017 

 Hearing, August 2017 

In re: The Financial Oversight and Management Board for Puerto Rico, as representative of The 

Commonwealth of Puerto Rico, et al., U.S. District Court for the District of Puerto Rico (17 BK 

3283-LTS) and In re The Financial Oversight and Management Board for Puerto Rico, as 

representative of Puerto Rico Electric Power Authority, U.S. District Court for the District of 

Puerto Rico (17 BK 4780-LTS) 

 Stipulated hearing testimony, February 2018 

Union de Trabajadores de la Industria Electria y Riego, Inc. (UTIER) v. The Financial Oversight 

and Management Board for Puerto Rico as Representative of Puerto Rico Electric Power 

Authority (PREPA), U.S. District Court for the District of Puerto Rico (Adv. Proc. No. 17-0229-

LTS in 17 BK 4780-LTS) 

 

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26 

Exhibit C 

ARTICLES and REPORTS 

Acemoglu, D., “The Solow Growth Model”, Introduction to Modern Economic Growth. 

(Princeton University Press: Princeton, 2009). 

Baily, M.N., Bosworth, B. and Doshi, S. “Productivity comparisons: Lessons from Japan, the 

United States, and Germany,” Brookings Institution, January 2020. 

Brown, J.P. “Identifying State-Level Recessions,” Federal Reserve Bank of Kansas City, 

February 22, 2017, available at 

https://www.kansascityfed.org/search/?query=Jason%20Brown&sorting=relevant&pagenumber=1&perpage=10. 

Buschsbaum, J. “Long-run price elasticities and mechanisms: Empirical evidence from 

residential electricity consumers” University of California at Berkeley, Unpublished Job Market 

Paper, February 9, 2022. 

Chisari, O., Estache, A., and Romero, C. “Winners and Losers from the Privatization and 

Regulation of Utilities: Lessons from a General Equilibrium Model of Argentina,” The World 

Bank Economic Review, Vol. 13, No. 2, pp.357-78. 

Diaz-Bautista, A. and González-Andrade S.. “The Debate of the Modern Theories of Regional 

Economic Growth,” Journal Rai Ximhai, Vol. 10, No. 6, July-December 2014, pp. 187-206. 

Edelberg, W. and Werling, J. “How CBO Develops the Economic Projections Underlying Its 

Long-Term Budget Projections,” Congressional Budget Office, February 15, 2019. 

Estudios Técnicos Inc., “Estudio sobre la Economía Informal en Puerto Rico,” August 3, 2010. 

Expert Report of Dr. Glenn R. George and support files. 

Expert Report of Dr. Maureen Chakraborty and support files. 

Expert Report of Dr. Ramón Cao. 

Expert Report of Professor Sebastian Edwards and support files. 

Expert Report of Dr. Susan Tierney and support files. 

Expert Report of Mr. Gary Struymeyer and support files. 

Fiscal Plan of the Commonwealth June 2022. 

Fiscal Plan of the Commonwealth March/April 2017. 

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27 

Fiscal Plan of the Commonwealth April 2023, Vol.1. 

Fiscal Plan of the Commonwealth April 2023, Vol.2. 

Fiscal Plan of the Commonwealth April 2023, Vol.3. 

Fiscal Plan of PREPA, April 2017. 

Fiscal Plan of PREPA, May 2021. 

Fiscal Plan of PREPA, June 2022. 

IMF Investment And Capital Stock Dataset (ICSD) 2021: Manual & FAQ - Estimating Public, 

Private, and PPP Capital Stocks. 

Jeffers, R.F., et.al. “Analysis of Microgrid Locations Benefitting Community Resilience for 

Puerto Rico,” Sandia National Laboratories, SAND2018-11145, September 30, 2018. 

Keating, J. W. “Structural Approaches to Vector Autoregressions”, Federal Reserve Bank of St. 

Louis, Sep/Oct 1992, pp.37-57. 

Krueger, A.O., Teja, R. and Wolfe, A. “Puerto Rico: A Way Forward,” (Krueger Report) June 29, 

2015 and July 13, 2015 update, available at, respectively, http://www.gdbpur.com/documents/PuertoRicoAWayForward.pdf and http://www.gdbpur.com/documents/PuertoRicoReport-Update.pdf. 

Mose, N.G. “Determinants of regional economic growth in Kenya,” African Journal of Business 

Management, Vol. 15 No. 1 , January 2021, pp. 1-12. 

Robertson, J. and Tallman, E. “Vector Autoregressions: Forecasting and Reality”, Federal 

Reserve Bank of Atlanta, Economic Review, Q1, 1999. 

Shackleton, R. “Estimating and Projecting Potential Output Using CBO’s Forecasting Growth 

Model,” Congressional Budget Office, WP 2018-03, February 2018. 

Sims, Christopher A. “A Nine-Variable Probabilistic Macroeconomic Forecasting Model.” In 

Business Cycles, Indicators, and Forecasting, edited by James H. Stock and Mark W. Watson. 

Chicago: University of Chicago Press 1992. 

Sims, Christopher A., and Tao A. Zha. “Bayesian Methods for Dynamic Multivariate Models”, 

International Economic Review 39, no. 4:949–68, 1998. 

Solow, R.M. “A Contribution to the Theory of Economic Growth,” Quarterly Journal of 

Economics, Vol. 70, No. 1, February 1956, pp. 65-94. 

Case:17-04780-LTS Doc#:3504-2 Filed:05/16/23 Entered:05/16/23 00:27:39 Desc:

Exhibit B Page 28 of 30

Case:17-03283-LTS Doc#:24530-11 Filed:06/12/23 Entered:06/12/23 17:45:09 Desc:

Exhibit 11 Page 28 of 30
28 

Tatum III, J.L. “Detroit’s Bankruptcy and Market Reentry”, Emory Bankruptcy Developments 

Journal, Vol. 37, Issue 1, 2020. 

DATA SOURCES 

April 2023 Fiscal Plan Model vShare (Dataroom).xlsx. 

https://data.worldbank.org/indicator/ST.INT.RCPT.CD 

https://data.census.gov/cedsci/table?d=ACS%205-

Year%20Estimates%20Data%20Profiles&table=DP05&tid=ACSDP5Y2017.DP05&g=0400000

US72&vintage=2017&hidePreview=true 

https://databank.worldbank.org/source/world-development-indicators# 

https://fred.stlouisfed.org/categories/27332. 

IMF World Economic Outlook (various years). 

https://www.imf.org/en/Publications/WEO/Issues/YEAR/. 

January 2022 Fiscal Plan Model Certified (Dataroom).xlsx. 

PREPA 2022 Fiscal Plan Model.xlsx. 

P_Data_Extract_From_World_Development_Indicators.xlxs. 

LEGAL FILINGS 

Disclosure Statement for Modified Second Amended Title III Plan of Adjustment of the Puerto 

Rico Electric Power Authority, 003297.00 [2023-03-01]. 

Modified Second Amended Title III Plan of Adjustment of the Puerto Rico Electric Power 

Authority, 003297.00 [2023-03-01]. 

Motion Of The Ad Hoc Group Of PREPA Bondholders, Assured Guaranty Corp., Assured 

Guaranty Municipal Corp., National Public Finance Guarantee Corporation, And SYNCORA 

Guarantee, Inc. To Dismiss PREPA’S Title iii Case, Or For Relief From The Automatic Stay To 

Enforce Their Right To A Receiver, Case:17-04780-LTS Doc#:2973 Filed:09/19/22. 

Objection Of SYNCORA Guarantee, Inc. To The Motion Of Puerto Rico Electric Power 

Authority For An Order (i) Approving Disclosure Statement, (ii) Fixing Voting Record Date, (iii) 

Approving Confirmation Hearing Notice And Confirmation Schedule, (Iv) Approving 

Solicitation Packages And Distribution Procedures, (v) Approving Forms Of Ballots And Voting 

Procedures, (vi) Approving Notice Of Non-Voting Status, (vii) Fixing Voting And Confirmation 

Deadlines, and (viii) Approving Vote Tabulation Procedures Case:17-03283-LTS Doc#:23480 

Filed:02/03/23. 

Case:17-04780-LTS Doc#:3504-2 Filed:05/16/23 Entered:05/16/23 00:27:39 Desc:

Exhibit B Page 29 of 30

Case:17-03283-LTS Doc#:24530-11 Filed:06/12/23 Entered:06/12/23 17:45:09 Desc:

Exhibit 11 Page 29 of 30
29 

Omnibus Objections Of The Ad Hoc Group Of PREPA Bondholders To The Disclosure 

Statement For The Title III Plan Of Adjustment Of The PUERTO RICO ELECTRIC POWER 

AUTHORITY [ECF NO. 3111], and Related Procedural Motions Related To The Disclosure 

Statement And Plan Confirmation [ECF NOS. 3113, 3114], Case:17-03283-LTS Doc#:23481 

Filed:02/03/23. 

Urgent Motion Of The Ad Hoc Group Of PREPA Bondholders Pursuant To Section 312 Of 

PROMESA And Section 105 Of The Bankruptcy Code To Compel Mediation And Impose 

Deadlines For A PREPA Plan Of Adjustment, Case:17-04780-LTS Doc#:2716 Filed:02/18/22. 

Case:17-04780-LTS Doc#:3504-2 Filed:05/16/23 Entered:05/16/23 00:27:39 Desc:

Exhibit B Page 30 of 30

Case:17-03283-LTS Doc#:24530-11 Filed:06/12/23 Entered:06/12/23 17:45:09 Desc:

Exhibit 11 Page 30 of 30