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TYPE
Original Research
PAGE NO.
178-192
10.37547/tajet/Volume07Issue06-20
OPEN ACCESS
SUBMITED
17 April 2025
ACCEPTED
24 May 2025
PUBLISHED
26 June 2025
VOLUME
Vol.07 Issue 06 2025
CITATION
Naveen Nischal Vaduguru. (2025). Automating the Capital General Rate
Case Filing Process Using SAP HANA: A Digital Transformation Approach for
Regulatory Compliance. The American Journal of Engineering and
Technology, 7(06), 178
–
192.
https://doi.org/10.37547/tajet/Volume07Issue06-20
COPYRIGHT
© 2025 Original content from this work may be used under the terms
of the creative commons attributes 4.0 License.
Automating the Capital
General Rate Case Filing
Process Using SAP HANA:
A Digital Transformation
Approach for Regulatory
Compliance
Naveen Nischal Vaduguru
“SAP HANA Data Engineer” Missouri City, Texas, USA
Abstract:
A General Rate Case (GRC) is a formal
regulatory process where a utility company requests
approval from a regulatory div
—
such as the California
Public Utilities Commission (CPUC)
—
to adjust customer
rates based on projected costs and revenues. Utilities
typically submit GRC filings every three years, presenting
detailed financial, operational, and capital data. The goal
is to justify rate changes needed to support
infrastructure, operations, and returns for investors. The
process includes public hearings, stakeholder input, and
regulatory review before rates are approved, modified,
or denied. GRC filings are complex and labour-intensive,
often requiring manual data extraction, analysis, and
documentation. Automation tools such as SAP HANA
can significantly streamline this process by consolidating
data from multiple sources, performing cost allocations,
validating inputs, and generating regulatory reports.
Automation reduces errors, saves time, and ensures
better compliance. Key components of GRC preparation
include capital data (financial, physical, human, and
intellectual), budget codes for tracking expenditures,
and workpaper groups that organize supporting
documents. Witness areas define expert testimony
topics, while special remaps update compliance
programs. GRC tools facilitate risk assessment, policy
management, and reporting, supporting both GRC-
specific filings and broader utility compliance efforts.
Automating GRC processes enhances transparency,
accuracy, and regulatory responsiveness.
KEYWORDS
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GRC, SAP HANA, Regulatory Compliance, Automation,
Data Integration, ETL, SAP Analytics Cloud, Rate Case,
Regulatory Filing, Efficiency
INTRODUCTION
The General Rate Case (GRC) is a comprehensive
regulatory process through which public utilities request
approval to adjust customer rates to cover costs, invest
in infrastructure, and earn a fair return, while ensuring
rates remain fair for consumers. The process begins with
a detailed application by the utility, followed by rigorous
review by regulatory staff, public input, discovery,
expert testimony, and evidentiary hearings. After legal
briefs are submitted, an Administrative Law Judge may
issue a recommendation, with the final decision made
by the regulatory commission. Post-decision, new rates
are implemented, and appeals may follow. Key factors
in a GRC include cost of service, rate base, rate of return,
test year data, fairness, service quality, efficiency, public
interest, and environmental impacts. The process is
detailed and time-intensive but crucial for balancing
utility needs with consumer protections.
The California Public Utilities Commission (CPUC) is a
vital regulatory agency responsible for overseeing
investor-owned utilities that provide electricity, natural
gas, water, and telecommunications services in the
state. Its core mission is to ensure access to safe, clean,
reliable, and affordable utility services while balancing
the interests of consumers, the environment, and the
economy. The CPUC enforces safety regulations,
protects consumers through rate regulation and dispute
resolution, and advances California’s environmental
goals by promoting renewable energy and climate
initiatives.
Additionally,
it
supports
economic
development by ensuring infrastructure reliability,
promoting fair competition, and managing programs for
small businesses and diverse suppliers. Through
licensing, enforcement, and policymaking, the CPUC
plays a central role in shaping California’s utility
landscape and public welfare.
Traditional, manual General Rate Case (GRC) filings face
significant challenges in today’s complex regulatory
environment, leading to inefficiencies, higher costs, and
potential inaccuracies. The process is time-consuming
due to manual data collection, spreadsheet errors, and
cumbersome document management. It is prone to data
inaccuracies from manual entry and lacks robust
validation, especially when data is siloed across systems.
Managing regulatory complexity, large datasets, and
operational interdependencies is difficult without
automation. Manual filings also hinder transparency,
collaboration, and public participation due to the
absence of centralized platforms and efficient
communication tools. These inefficiencies result in
increased labour costs, potential rework, and scalability
issues, especially for larger utilities or multiple filings.
Additionally, traditional methods lack real-time insights
and advanced analytics, limiting proactive decision-
making. Overall, these limitations underscore the need
for automated, integrated GRC solutions to enhance
accuracy, efficiency, and regulatory responsiveness.
SAP HANA (High-Performance Analytic Appliance) is an
in-memory computing platform developed by SAP that
revolutionizes how organizations process and analyse
large volumes of data. Unlike traditional databases that
store data on disk, SAP HANA stores data in memory,
enabling real-time data access, processing, and
analytics. This architecture delivers unprecedented
speed, scalability, and agility, making it a transformative
IT tool for both private and public sector organizations.
In the context of complex, data-intensive processes
—
such as regulatory filings, enterprise reporting, and
operational analytics
—
SAP HANA offers a unified
platform that integrates transactional and analytical
workloads. It enables organizations to consolidate
disparate data sources, perform complex calculations
instantly, and generate insights that support faster and
more informed decision-making. Key capabilities include
advanced analytics, real-time reporting, predictive
modelling, and seamless integration with other SAP and
non-SAP systems.
SAP HANA’s impact is particularly profound in sectors
like utilities, finance, and government, where timely,
accurate, and transparent data is critical for compliance,
service delivery, and strategic planning. By automating
repetitive tasks, eliminating data silos, and enhancing
data
integrity,
SAP
HANA
supports
digital
transformation initiatives and empowers organizations
to respond more effectively to evolving regulatory,
operational, and customer demands.
The primary objective of a paper on automating General
Rate Case (GRC) filings using SAP HANA XSA is to
demonstrate how this technology can enhance the
efficiency, accuracy, and transparency of a traditionally
manual, complex process. The paper aims to identify the
limitations of conventional GRC methods and showcase
SAP HANA XSA’s capabilities [11]—
such as in-memory
processing,
advanced
analytics,
application
development, and secure system integration
—
as key
enablers of automation. It proposes a conceptual system
architecture; highlights benefit like cost savings and
improved data accuracy and emphasizes enhanced
collaboration and regulatory insight. Additionally, the
paper addresses the scalability of the solution and
potential
implementation
challenges,
offering
mitigation strategies to support a successful digital
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transformation of the GRC process.
2. Problem Statement
2.1 Detailed explanation of inefficiencies in the legacy
GRC filing process
The legacy General Rate Case (GRC) filing process suffers
from significant inefficiencies due to its reliance on
manual workflows, spreadsheets, and siloed systems.
This leads to challenges in data management (labour-
intensive collection from disparate sources, slow
turnaround), high risk of human error (spreadsheet
mistakes, transcription issues), lack of real-time visibility
and
limited
analytics,
cumbersome
document
management (version control, difficult collaboration),
inefficient review and approval workflows, poor
stakeholder engagement and transparency, scalability
and adaptability limitations, and increased operational
costs (high labour, costly rework). These issues hinder
timely,
accurate,
and
transparent
regulatory
submissions,
making
the
traditional
process
unsustainable in the current environment. Automation
using integrated platforms like SAP HANA XSA is
presented as a solution for modernization and
regulatory excellence.
2.2 Common issues: data silos, manual effort,
inconsistent reporting, compliance risks
The traditional General Rate Case (GRC) filing process
faces several key challenges, including data silos, manual
effort, inconsistent reporting, and compliance risks.
Data silos arise from isolated systems across
departments, making data collection and integration
difficult, leading to inconsistencies and delays in the
filing process. Manual effort in data entry, calculations,
and document management is time-consuming, error-
prone, and inefficient, while lack of automation
exacerbates these issues. Inconsistent reporting across
different sections of the GRC filing complicates data
verification, reducing transparency and increasing
scrutiny. Furthermore, the evolving regulatory
landscape adds compliance risks, with the potential for
missed deadlines, inaccurate filings, and non-
compliance with new regulations. Addressing these
interconnected challenges through automation and
integrated platforms is essential to improving efficiency,
accuracy, and regulatory compliance in the GRC process.
2.3
Need for automation and integration in the utility
sector
The need for automation and integration in the utility
sector, particularly for the General Rate Case (GRC) filing
process, is driven by the increasing complexity and
inefficiencies of traditional, manual methods. Utility
companies often face challenges with data silos,
fragmented systems, and time-consuming manual
processes, all of which hinder the speed and accuracy of
GRC filings. Automation and integration can streamline
data collection, analysis, and reporting by providing a
centralized platform that allows for seamless data flow
between different departments and systems. This would
significantly reduce the manual effort required for tasks
such as data entry, document management, and
calculations, minimizing human errors and improving
data consistency. Furthermore, automation would help
utilities meet regulatory deadlines more easily, ensure
compliance with evolving regulations, and provide
better transparency and collaboration between
stakeholders. By integrating advanced tools like SAP
HANA XSA, utilities can enhance the efficiency of the
GRC process, reduce operational costs, and ultimately
create a more accurate and reliable foundation for
regulatory decision-making.
3. Literature Review
3.1 Government process automation
Previous government-led automation efforts in the
General Rate Case (GRC) filing process primarily focused
on digitization and basic automation, transitioning from
paper-based
systems
to
electronic
document
management and standardized templates. These early
stages included the implementation of rule-based
systems for automated data validation and workflow
automation for internal review. Additionally, centralized
databases and online filing portals were introduced to
improve data access and public transparency. While
these initiatives improved basic organization and
reduced manual effort, challenges persisted, such as
siloed systems, limited advanced analytics, and the
inability to handle large, complex datasets in real-time.
These limitations underscored the need for more
advanced solutions, like SAP HANA XSA, which can
provide the integration, real-time capabilities, and
sophisticated data analysis required to address the
inefficiencies in the GRC process.
3.2 Use of enterprise IT systems (like SAP) in utilities
The adoption of enterprise IT systems like SAP offers
significant advantages for utilities in managing General
Rate Case (GRC) filings. SAP's integrated solutions
streamline data management by breaking down data
silos, automating routine tasks to reduce manual effort
and errors, and enhancing collaboration among
stakeholders through a centralized platform. Key
benefits include improved data integration, advanced
analytics for data-driven justifications, enhanced
compliance and reporting capabilities, and increased
transparency throughout the GRC process. Ultimately,
leveraging SAP modernizes the filing process, leading to
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greater efficiency, accuracy, and better regulatory
outcomes.
3.3
Regulatory compliance technologies
The evolution of regulatory compliance technologies has
seen a progression from basic digitization and workflow
automation to sophisticated RegTech platforms
leveraging data analytics, AI, and blockchain to
streamline compliance processes across various
industries. While these advancements have improved
efficiency and reduced errors, limitations such as data
silos and the challenge of adapting to dynamic
regulations persist, highlighting the need for more
advanced, integrated solutions like SAP HANA XSA to
further automate workflows, unify data, and enable
real-time monitoring for enhanced compliance
capabilities in today's complex regulatory landscape.
3.4
Identify gaps in current automation approaches
related to GRC filings
Current automation approaches for General Rate Case
(GRC) filings, while offering improvements over manual
methods, still have significant gaps. Many solutions
focus on automating specific stages, such as data
collection or report generation, without fully integrating
the entire GRC lifecycle, leading to disconnects between
different
phases.
Automation
struggles
with
unstructured data, like legal documents and textual
justifications, and lacks advanced analytics, AI, and
predictive capabilities for proactive risk identification
and trend analysis. Furthermore, current systems often
lack real-time monitoring, adaptability to regulatory
changes, and robust collaboration features for
stakeholders, hampering transparency and efficiency.
Automation tools also fail to provide deep contextual
understanding of business processes and may struggle
to integrate with legacy systems, creating data silos.
Additionally, many solutions focus on automating
repetitive tasks rather than supporting strategic insights
and decision-making, while also lacking comprehensive
audit trails and transparency required for regulatory
scrutiny.
4. METHODOLOGY
4.1
Research type: Case study or implementation
analysis
A notable case study in automating the General Rate
Case (GRC) filing process involves Pacific Gas and Electric
(PG&E) and their 2023
–
2026 GRC application. PG&E's
filing, submitted in June 2021, requested a $15.4 billion
increase for 2023, primarily to fund safety and reliability
initiatives, including undergrounding 1,230 miles of
powerlines to mitigate wildfire risks. The California
Public Utilities Commission (CPUC) approved an 11%
increase, allocating funds for grid modernization and
climate resiliency projects.
To streamline the GRC process, PG&E implemented
advanced technology platforms that digitize documents,
automate data processing, and utilize artificial
intelligence (AI) for business intelligence. These
platforms enable real-time project updates, efficient
data capture, and long-term data archiving, facilitating
the justification of rate cases years after project
completion.
Additionally, utilities are exploring the use of generative
AI (GenAI) to enhance the GRC process. GenAI can
analyse historical rate case data, predict regulatory
outcomes, and assist in drafting and refining content for
cost-of-service studies and supporting documentation.
This approach not only accelerates the preparation
phase but also improves the quality and consistency of
filings.
Furthermore, consulting firms like Celerity have assisted
utilities in auditing and coding initiatives to support their
analysis for GRC hearings. By streamlining data
management and ensuring compliance, these efforts
contribute to more efficient and accurate rate case
proceedings [1].
Collectively, these case studies demonstrate the
transformative impact of automation and advanced
technologies in modernizing the GRC filing process,
leading to increased efficiency, accuracy, and regulatory
compliance.
4.2
Tools used: SAP HANA, SAP Business Intelligence
SAP HANA and SAP Business Intelligence (BI) together
offer a comprehensive and powerful platform to
modernize and streamline the General Rate Case (GRC)
filing process for utilities. SAP HANA enhances
performance through its in-memory computing
capabilities, enabling rapid data processing, real-time
integration across systems, advanced analytics, and
secure, compliant data handling. It also supports the
creation of custom applications tailored to GRC
workflows. Meanwhile, SAP BI provides robust tools for
data visualization, reporting, dashboard creation, and
mobile access, making complex GRC data more
understandable and transparent for stakeholders. When
integrated, HANA serves as the high-performance data
foundation, while BI tools transform this data into
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insightful, interactive reports and dashboards,
improving the speed, accuracy, and communication of
filings. This integrated approach significantly addresses
the shortcomings of traditional GRC processes by
enabling real-time insights, enhancing collaboration,
and ensuring regulatory compliance.
4.3 Data sources: Utility financial systems, billing
systems, capital project databases
Utility financial systems serve as the central repository
for all financial transactions, providing the necessary
data on revenues, expenses, assets, and liabilities crucial
for determining the cost of service and overall financial
health presented in a GRC filing. Billing systems contain
detailed customer consumption data, rate structure
application, and revenue collection information, which
is essential for analysing revenue requirements and the
impact of proposed rate changes on different customer
classes. Capital project databases track investments in
infrastructure, including project costs, timelines, and
asset details, forming the basis for justifying capital
expenditure requests and the inclusion of the rate base
in the GRC.
4.4 Automation techniques: ETL (Extract, Transform,
Load), dashboarding, scripting for repetitive tasks
Automation techniques within an SAP HANA-centric
GRC filing process leverage ETL processes to extract data
from source systems like utility financial systems, billing
systems, and SAP S/4HANA capital data, transform it
into a consistent format, and load it into SAP HANA flow
graphs for analysis. Dashboarding tools, potentially built
with SAP UI5, provide interactive visualizations of key
GRC data and metrics for both utility personnel and
regulatory reviewers. Scripting, within the SAP HANA
environment or leveraging external tools, automates
repetitive tasks such as data validation, report
generation, and the movement of information between
platforms like SharePoint for document management
and SAP HANA for processing and business posting. This
integrated automation aims to streamline data flow,
reduce manual effort, and enhance the accuracy and
transparency of the GRC filing process.
5. System Design and Architecture
5.1 Architecture of the SAP HANA-based GRC
automation system
5.1.1 Data pipeline (source systems to HANA)
For General Rate Case (GRC) filing, SAP Landscape
Transformation (SLT) Replication Server enables the
efficient and timely extraction of crucial capital project
data from the utility's SAP ECC system into SAP HANA.
SLT's trigger-based replication captures both initial data
and ongoing changes in ECC, ensuring that the capital
expenditure information needed for rate base
calculations and justification within the GRC is
consistently up-to-date and readily available in the high-
performance HANA environment for analysis and
reporting. This facilitates a more accurate and
streamlined
preparation
of
the capital-related
components of the GRC filing.
Capital data originating from TM1 is first exported to
files stored in a SharePoint folder. To make this data
accessible in SAP HANA for GRC filing, virtual tables are
created in HANA that point directly to these SharePoint
files. This allows for real-time or near real-time querying
and analysis of the TM1-sourced capital data within
HANA without immediate physical replication.
Subsequently, for enhanced performance and data
management within HANA, the relevant data accessed
through these virtual tables can then be selectively
loaded and stored into physical tables within SAP HANA.
This approach provides flexibility in accessing external
data while also leveraging HANA's in-memory
capabilities for efficient processing and integration with
other GRC-related data.
In the General Rate Case (GRC) process, SAP UI5
applications enable business users to input and manage
data through user-friendly interfaces, which is then
stored directly in SAP HANA. The process begins with
users entering data into a UI5 app, which is transmitted
to a backend service
—
typically via OData
—
for
validation and processing. After ensuring data integrity,
the backend service writes the data into SAP HANA’s
physical tables using SQL or stored procedures. Once
stored, the data becomes available for reporting and
analysis in the GRC process. Users receive real-time
feedback on the success or failure of their submissions,
allowing for corrections if needed. This streamlined
approach replaces manual spreadsheet workflows,
improving data accuracy, timeliness, and accessibility.
5.1.2
Data model (e.g., cost allocation model)
To report Capital Data for the General Rate Case (GRC)
to the California Public Utilities Commission (CPUC), the
process begins at the foundational data level and moves
upwards through several mapping and categorization
steps. At the base, the Capital (Transaction Data) Table
contains millions of records, each with a Budget Code
field.
This data is then mapped using the Budget Code to
Workpaper Group Master Data Mapping Table, which
includes only a few hundred records, as show in “Fig.1.”
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Fig.1. Budget Code to Workpaper Group mapping
Concurrently, the Workpaper Group to Witness Area Mapping Table is prepared as show in “Fig.2.”
Fig.2.Workpaper Group to Witness Area Mapping
Using these resources, Capital Transaction Data is enhanced by assigning Workpaper Groups based on Budget Code.
This augmented data is then further refined to include Witness Area Mapping based on Workpaper, forming a more
detailed dataset.
Subsequently, Special Remapped Workpaper Groups and their corresponding Witness Areas are integrated, using
the Special Remaps Rules Table to reassign new Workpaper Groups where necessary as shown in “Fig.3.”
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Fig.3.Special Remap of Workpaper group
The data now comprises Capital Transaction Data with Workpaper Group Assignment (Budget Code), Witness Area
Mapping (Workpaper), and Special Remapped Workpaper Group and New Witness Area based on New Workpaper
group as shown in “Fig.4.”
Fig.4. Witness Area Remap of Special remap Workpaper group
This enriched dataset is used to generate a version for non-GRC Rules and another set using the Workpaper Group
to Witness Area Remapping Table for precise witness mapping. The final output combines all elements: Transaction
Data categorized into GRC/Non-GRC, and detailed Workpaper and Witness Area mappings, culminating in the
Reporting of General Rate Case Data to the CPUC as shown in “Fig.5.”
Fig.5. Classification of GRC/Non- GRC Records
5.1.3 Reporting tools (e.g., SAP Analytics Cloud or SAP
BusinessObjects)
The reporting process starts with extracting Capital
Transaction Data from SAP BW or a Data Warehouse,
covering millions of records with fields like Budget Code,
Transaction Amounts, Hours Worked, Employee ID or
Labor Category, and Vacation/Sick Time. This data is
brought into SAP Analysis for Office, Power BI, or Web
Intelligence for analysis and reporting. Budget Codes are
mapped to Workpaper Groups via a master mapping
table using tool-specific methods such as lookups or
relationships. These Workpaper Groups are then linked
to Witness Areas through a dedicated mapping table,
with exceptions handled using Special Remap Rules. The
enriched dataset includes Workpaper Groups, Witness
Areas, Labor/Non-Labor categorization, calculated FTEs
(adjusted for Vacation and Sick Time), and GRC/Non-
GRC classifications. Final reports are created using
Power BI for visual insights, SAP Analysis for Office for
Excel-based charts, and Web Intelligence for structured,
schedulable outputs. The completed report to the CPUC
presents Capital Data segmented by Labor Type, FTE,
Budget Code, Workpaper Group, Witness Area, and
applicable adjustments.
5.1.4
Workflow diagram
End to architecture of General Rate Case as shown in “Fig.6.”
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Fig.6. Step by Step architecture of Capital General Rate Case Filing Architecture
6. Implementation Process
6.1 Data extraction and consolidation
The data extraction and consolidation process for
General Rate Case filing begins with pulling data from
SAP ECC into SAP HANA, leveraging virtual tables to
connect and access transactional data without
duplication. Simultaneously, data from TM1 is exported
to SharePoint, and from there, it is integrated into SAP
HANA again using virtual table technology. Once
accessible in HANA via virtual tables, the data is then
loaded into physical tables to enable performance-
optimized storage and querying. A third data source
involves SAP UI5 application postings, which are
captured directly into SAP HANA physical tables,
ensuring that all necessary operational and planning
data is consolidated into a central, high-performance
environment for downstream reporting and GRC
analysis.
6.2 Cost allocation and modelling
The process begins with extracting Capital Transaction
Data containing millions of records, including key fields
like Budget Code, which is used to map each transaction
to a Workpaper Group through the Budget Code to
Workpaper Group Master Data Mapping Table. This
forms the foundation for associating Capital Data with
Workpaper Groups. The dataset is then enhanced by
linking Workpaper Groups to Witness Areas using a
separate mapping table, aligning the data with
regulatory structures. Special Remap Rules are applied
as needed to handle exceptions by reassigning
transactions to alternative Workpaper Groups. Through
these steps, the dataset evolves to reflect accurate
Workpaper Group assignments (including remaps),
Witness Area mappings, and Special Remapped
Workpaper Groups. Further refinement categorizes
transactions by GRC (General Rate Case) and Non-GRC
using established rules. The final, fully enriched and
categorized data is compiled and submitted to the
California Public Utilities Commission (CPUC) as part of
the General Rate Case reporting, ensuring regulatory
accuracy and compliance.
Identify or Extract Capital data of the utility organization
into a Table. Write extraction procedures to load
daily/monthly/quarterly/yearly data. Transaction Data
will not have attributes like Work paper group, Witness
Area Code. This process will assign them Step by Step.
Some of the Special scenarios of transaction data will be
assigned with a new Workpaper group based on specific
criteria called Special Remaps. Once Special Remaps are
done, categorize all the Capital transaction data into
GRC and Non GRC based on some business rules
maintained in a table. Exclude Non GRC records and
report only General Rate Case records categorized into
Labor and Non-Labor to Regulatory bodies. Practically
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Capital data will be huge, approximately multiple
millions of records. Doing Special remaps & GRC/Non
GRC mapping for each record in a million records will be
equivalent to finding a needle in a haystack. We can
achieve this complex scenario with the following
approaches.
6.2.1 Special Remap:
Special remaps of millions of data can be approached using the solution as shown in “
Fig.7.”
Fig.7. Special Remaps of millions of Capital Data
6.2.2 GRC/Non GRC Categorization:
We can take the approach below to achieve the solution to categorize millions of Capital data records into relevant
for GRC/Non-GRC as show in
“Fig.8.”
Fig.8. GRC/Non-GRC Capital Data Categorization
6.3 Report generation
In SAP Analysis for Office, report generation for General Rate Case (GRC) filing follows the structured data
enrichment process. After extracting Capital Transaction Data into SAP HANA or BW, users launch Analysis for Office
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within Excel to consume the enriched dataset. Using embedded queries or BEx queries, key fields such as Budget
Code, Workpaper Group, Witness Area, GRC/Non-GRC status, Labor/Non-Labor, Hours Worked, Vacation, and Sick
Time are selected for reporting. Through pivot tables, users can dynamically analyse Capital Data by Workpaper
Group or Witness Area. Calculated fields
—
such as FTE (using formulas like (Total Hours - Vacation - Sick) / Standard
Hours)
—
can be added directly in Excel. Filtering, grouping, and hierarchical breakdowns allow auditors and
regulatory teams to slice data as required. Final outputs include structured Excel reports with drilldowns, charts,
and exportable summaries, ensuring data transparency and alignment with CPUC reporting standards.
List of characteristics to be reported for General Rate Case Capital filing with CPUC is shown in
“Fig.9.”
Fig.9. Capital – GRC Filing Detailed Report
List of characteristics to be reported for General Rate Case Capital filing with CPUC is shown in
“Fig.10.”
Fig.10. Capital – GRC Filing Summary Report
6.4 Task automation and validation
The task automation and validation process for General
Rate Case data, as described, involves a sequence of
steps initiated by a WebI report. This report's data is
automatically distributed to a Network Attached
Storage (NAS) drive via Infoburst, utilizing the EDIX
system for this transfer. Subsequently, a job within the
Workiva platform is triggered to load the data from the
designated EDIX location on the NAS drive. Finally,
Workiva is used to generate the required reports,
specifically focusing on capital-related information
derived from the loaded data. This entire flow aims to
automate the extraction, transfer, loading, and
reporting of GRC data, with Workiva serving as the final
reporting and potentially validation environment.
6.5 Electronic filing submission to CPUC
The electronic filing submission to the CPUC for the
General Rate Case (GRC) is the final step in a
comprehensive reporting pipeline that integrates
multiple systems and tools. Source data is pulled from
SAP ECC, TM1, SAP UI5 applications, and SharePoint, and
consolidated into SAP HANA using a combination of
virtual tables and physical data loads, governed by
predefined business rules. The enriched data includes
Budget Codes, Workpaper Groups, Witness Areas,
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GRC/Non-GRC
classifications,
Labor/Non-Labor
breakdowns, and FTE calculations (adjusting for vacation
and sick time). This dataset is then accessed through
front-end tools like SAP Analysis for Office (for
structured, Excel-based reporting), Power BI (for
interactive dashboards and data visualization), and Web
Intelligence if needed for tabular outputs. For formal
CPUC submission, Workiva is used to compile, narrate,
and submit the electronic filing package, integrating
data outputs and documentation from Analysis for
Office and Power BI. This ensures traceability, audit
readiness, and compliance with CPUC regulatory
requirements.
6.6 Key stakeholders involved (IT, finance, regulatory
affairs)
The General Rate Case (GRC) reports generated through
SAP HANA and delivered via tools like SAP Analysis for
Office (A40), Workiva, and Power BI serve a diverse
group of stakeholders across the organization. IT teams
are responsible for ensuring data integration,
transformation, and platform stability, enabling
accurate and timely data availability. Finance teams rely
on these reports to validate capital expenditures, labour
costs, and FTE allocations, ensuring alignment with
budgetary and forecasting assumptions. Regulatory
Affairs teams use the insights to prepare defensible
narratives, comply with CPUC submission standards, and
respond to audit or data requests. Collectively, these
stakeholders use the GRC reporting framework to
support strategic planning, maintain regulatory
compliance, and ensure financial transparency
throughout the rate case cycle.
7. Results and Evaluation
7.1
Time saved (e.g., filing process reduced by X%)
Implementing SAP HANA for GRC filing is estimated to
potentially reduce the overall filing timeline by 20% to
50% or more, depending on the utility's existing
processes and the extent of HANA adoption. This is
attributed to faster data collection and preparation (30-
60% potential savings), quicker report generation and
analysis, streamlined review cycles (10-30% potential
savings), and reduced rework. The actual time saved
varies based on the initial inefficiencies, the
comprehensiveness of the HANA implementation, the
level of automation, and user adoption. While a precise
figure requires a specific analysis, a significant time
reduction is a realistic expectation for strategic HANA
deployments.
7.2
Reduction in manual errors
Implementing SAP HANA for GRC filing offers a
substantial reduction in manual errors by automating
data integration, calculations, and report generation,
while also enforcing data validation and providing a
centralized, governed environment that eliminates
manual transcription, spreadsheet inaccuracies, version
control issues, and inconsistencies arising from
disparate systems; this strategic use of HANA, coupled
with improved audit trails, is expected to decrease
errors significantly, potentially by 50% to 90% or more,
leading to more accurate and defensible rate case
filings.
7.3
Improved compliance and audit readiness
Automating the General Rate Case (GRC) process with
SAP HANA significantly enhances compliance and audit
readiness by establishing a transparent, traceable, and
controlled data environment. HANA's centralized data
repository ensures a single source of truth, reducing
inconsistencies that can lead to compliance issues. Built-
in data validation rules and audit trails meticulously
track data lineage and modifications, providing a clear
history for regulatory scrutiny. Furthermore, the
platform's robust security features and access controls
help meet data governance requirements, while
standardized reporting ensures consistent and accurate
submissions, facilitating easier regulatory review and
reducing the risk of non-compliance findings during
audits. This comprehensive approach within SAP HANA
creates a more defensible and compliant GRC filing
process.
7.4
KPIs tracked (e.g., report accuracy, cycle time,
system uptime)
Capital reporting KPIs in a GRC aim to justify
expenditures,
demonstrate
efficient
project
management, and ensure prudent investment for
ratepayers. These metrics cover project cost and budget
adherence (budget variance, cost per unit/customer,
capital expenditure as a percentage of revenue), project
schedule and timeliness (schedule variance, time to
commission), asset condition and performance (asset
age profile, reliability metrics, aging infrastructure
investment), prudence and justification (BCR/NPV,
alternatives analysis, regulatory compliance), customer
impact (investment per customer for enhancements,
outage reduction), and forecasting accuracy. The
specific KPIs used depend on the utility type, projects,
and regulatory requirements, necessitating historical
data and future projections for justification.
8. DISCUSSION
8.1
Analysis of benefits and trade-offs
Implementing SAP HANA for GRC filings presents a
compelling case for utilities, offering substantial benefits
like increased efficiency, accuracy, transparency,
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advanced analytics, improved collaboration, enhanced
compliance, and scalability, often outweighing the
trade-offs
of
significant
upfront
investment,
implementation complexity, the need for skilled
personnel, data migration challenges, ongoing costs,
organizational change, and security considerations, thus
necessitating a thorough cost-benefit analysis tailored
to each utility's specific context to ensure a successful
and valuable implementation.
8.2
Organizational
change
management
considerations
Successfully implementing SAP HANA for GRC filing
requires a proactive organizational change management
strategy
encompassing
clear
stakeholder
communication, thorough impact assessment and
planning,
comprehensive
training
and
skill
development, process redesign and optimization, strong
leadership alignment, empowered change agents, a
phased
rollout
with
iterative
improvements,
performance monitoring with feedback loops, effective
resistance management, and consistent communication
of successes to ensure smooth adoption, maximize ROI,
and achieve lasting enhancements in efficiency,
accuracy, and compliance.
8.3
Lessons learned
Lessons Learned from the Rate Case Process
: An
analysis of utility rate case experiences, highlighting best
practices and common challenges in implementing GRC
automation with SAP HANA emphasize the critical need
for comprehensive planning, including a clear definition
of scope and objectives, thorough data readiness
assessment and cleansing, and robust integration
strategies with existing systems [2]. Strong cross-
functional collaboration between IT, finance, regulatory,
and business teams is paramount, alongside securing
executive sponsorship and proactively managing
organizational change through effective communication
and training. A phased implementation approach with
iterative testing and feedback loops is recommended to
mitigate risks and ensure user adoption, while focusing
on data governance, security, and establishing clear
audit trails from the outset are crucial for maintaining
compliance and realizing the full benefits of the
automated GRC process.
8.4
Reusability or scalability of the solution for other
utilities or processes
The SAP HANA-based solution for GRC filing offers
significant potential for reusability and scalability, both
for other utilities and for different processes within the
GRC lifecycle. The underlying SAP HANA platform
provides a robust and scalable infrastructure capable of
handling large data volumes and complex processing
requirements common across the utility industry.
Standardized data models and pre-built functionalities
for data integration, validation, and reporting can be
adapted and reused for various utilities, albeit with
necessary customizations to accommodate specific
regulatory
requirements,
data
structures,
and
organizational workflows. Furthermore, the modular
nature of SAP solutions allows for the extension and
scaling of the GRC filing solution to incorporate
additional processes, such as regulatory data requests,
compliance reporting, and audit management, providing
a comprehensive and reusable framework for regulatory
interactions.
9. CONCLUSION AND RECOMMENDATIONS
9.1
Summary of findings
Findings from implementing SAP HANA for General Rate
Case (GRC) filing consistently point towards significant
improvements in efficiency, accuracy, and transparency.
The high-performance platform drastically reduces data
processing times, streamlines data collection from
disparate systems, and automates complex calculations,
leading to faster filing cycles and reduced manual effort.
Enhanced data validation and a centralized data
repository minimize errors and ensure data integrity,
bolstering the reliability and defensibility of rate
requests. Furthermore, the advanced analytical
capabilities of SAP HANA enable deeper insights into
cost drivers and operational performance, supporting
more robust justifications for proposed rates. The
integrated reporting and audit trails improve
transparency for all stakeholders and enhance
compliance readiness. While initial investment and
organizational change management are crucial
considerations, the overall findings suggest that SAP
HANA provides a powerful foundation for modernizing
the GRC filing process, yielding substantial benefits for
utilities in navigating the complex regulatory landscape.
Utility companies can use the below implementation
strategy or migration strategy for GRC filing purposes
[3].
Southern California Edison's (SCE) 2025 General Rate
Case Total Compensation Study, conducted by Willis
Towers Watson, evaluates the competitiveness of SCE's
compensation packages across various employee
categories, concluding that overall compensation is
within market norms as mentioned in CPUC
documentation [4].
SCE's Study of Residential Disconnections and
Arrearages, analyses the impact of proposed rate
increases on customer disconnections and arrearages,
noting that pandemic-related moratoriums have
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influenced recent trends, complicating the assessment
of rate impacts as mentioned in CPUC documentation
[5].
Below is the Public Advocates Office's report on
PacifiCorp's 2023 General Rate Case, recommending a
revenue requirement lower than PacifiCorp's proposal,
with adjustments to rate base and amortization
expenses, while not opposing the company's tax and
depreciation calculations as mentioned in CPUC
documentation [6].
The Pacific Gas and Electric Company (PG&E) General
Rate Case (GRC) proceedings, overseen by the California
Public Utilities Commission (CPUC), are comprehensive
reviews conducted every four years to assess PG&E's
revenues and expenses, ensuring that utility rates
remain just and reasonable. In its 2023-2026 GRC
application (A.21-06-021), PG&E proposed a $15.4
billion revenue requirement for 2023, marking a 26%
increase from the 2022 authorized amount, primarily
driven by inflation and substantial investments in
undergrounding electric lines to mitigate wildfire risks.
The CPUC's Decision 23-11-069 approved a $13.5 billion
base revenue requirement for 2023, reflecting an 11%
increase over 2022, and endorsed key initiatives such as
the undergrounding of 1,230 miles of electric lines,
installation of 778 miles of covered conductor, and
allocation of $1.3 billion for vegetation management.
Additionally, the decision sanctioned over $2.5 billion in
investments from 2023 to 2026 to enhance the electric
distribution system's capacity and reliability. A
settlement in Track 2 of the proceeding resulted in an
additional $221.233 million revenue requirement
increase to be recovered over 2023 and 2024[7].
"Technology Platforms Essential to Prove Need in Utility
Rate Cases," T&D World discusses the critical role of
robust digital platforms in helping electric utilities justify
rate increases to Public Utility Commissions (PUCs). As
utility projects grow in complexity and involve
geographically
dispersed
teams,
maintaining
comprehensive, real-time documentation becomes
challenging. Key decisions made during planning,
construction, and operations phases can significantly
impact rate cases years later, yet the personnel involved
may no longer be available to provide context.
Implementing advanced technology platforms enables
utilities to systematically capture and archive project
data, including change management records, issue logs,
and financial impacts. This thorough documentation is
essential for demonstrating the necessity of rate
adjustments, particularly as utilities invest in grid
modernization, electric vehicle infrastructure, and
resilience against natural disasters. By leveraging these
digital tools, utilities can ensure transparency and
accountability,
facilitating
more
effective
communication with regulators and stakeholders [8].
"Accelerating Utility Rate Case Filings with Generative
AI" from Utility Dive discusses how generative AI (GenAI)
is transforming the traditionally complex and time-
consuming process of utility rate case filings. These
filings, which justify changes to consumer rates for
essential services like electricity, water, and gas, often
require 12 to 18 months to prepare due to detailed
financial analyses and regulatory compliance. GenAI
offers a solution by rapidly analysing vast amounts of
historical rate case data, extracting relevant precedents
and insights to inform current filings. This capability
enables utilities to construct more robust, evidence-
backed proposals, streamlining documentation and
enhancing transparency. As utilities face increasing
demands
for
infrastructure
upgrades
and
modernization, integrating GenAI into rate case
preparations can lead to more efficient regulatory
processes and better alignment with stakeholder
expectations [9].
Strategic benefits of SAP-based automation in
regulatory contexts
Strategic benefits of SAP-based automation in
regulatory contexts, specifically for General Rate Case
(GRC) filings, extend beyond mere efficiency gains to
provide significant competitive and operational
advantages. By establishing a centralized and auditable
data foundation, SAP enables utilities to proactively
manage regulatory compliance, reducing the risk of
penalties and fostering stronger relationships with
regulatory bodies. The enhanced data accuracy and
analytical capabilities support more data-driven and
defensible rate requests, potentially leading to more
favourable outcomes. Furthermore, the increased
efficiency frees up valuable resources, allowing utility
staff to focus on strategic planning and customer service
initiatives. The scalability of SAP solutions ensures the
utility can adapt to evolving regulatory landscapes and
business growth, fostering long-term sustainability and
operational agility. Ultimately, SAP-based automation
transforms regulatory compliance from a reactive
burden into a strategic enabler of improved
performance, reduced risk, and enhanced stakeholder
trust.
9.2
Future improvements (e.g., AI integration,
predictive analytics)
The future of SAP HANA in General Rate Case (GRC) filing
holds exciting potential through the integration of
advanced technologies like Artificial Intelligence (AI) and
predictive analytics. AI could automate the extraction
and analysis of unstructured data within regulatory
documents and internal reports, providing deeper
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insights and identifying potential compliance risks or
areas of scrutiny. Predictive analytics could forecast key
financial and operational metrics, enabling utilities to
proactively justify rate adjustments based on
anticipated future trends and potential scenarios,
leading to more robust and forward-looking rate cases.
Furthermore, AI-powered anomaly detection could flag
unusual data patterns or inconsistencies in GRC filings,
enhancing data quality and reducing the likelihood of
errors or regulatory challenges. Machine learning
algorithms could also optimize the GRC preparation
process itself, learning from past filings to suggest best
practices, automate document generation, and
streamline workflows, ultimately leading to more
efficient and effective regulatory submissions.
The Neudesic blog, post explores how generative AI
(GenAI) can transform the preparation and submission
of General Rate Cases (GRCs) in the utility sector [10].
Traditionally a complex and time-consuming process,
GRCs involve extensive data collection, analysis, and
documentation to justify rate adjustments to regulators
and stakeholders. GenAI, powered by large language
models, can streamline this process by rapidly
aggregating and interpreting vast datasets, assisting in
forecasting costs, and generating coherent draft
documents aligned with regulatory requirements.
Additionally,
GenAI
can
enhance
stakeholder
engagement by efficiently handling information
requests and analysing feedback to inform strategic
communications. While many utilities have begun
exploring GenAI for customer service applications, its
integration into GRC workflows offers significant
potential for operational efficiency and improved
decision-making. However,
challenges
such as
integrating with legacy systems and ensuring regulatory
compliance remain, underscoring the need for strategic
planning and expert guidance in adopting GenAI
solutions.
9.3
Recommendations for utilities, IT leaders, and
regulators
For utilities, the recommendation is to strategically
invest in SAP HANA and its related tools to modernize
their GRC filing processes, focusing on comprehensive
data
integration,
end-to-end
automation,
and
leveraging advanced analytics for robust rate
justifications. IT leaders should prioritize building a
skilled team, ensuring robust data governance and
security frameworks, and establishing scalable
infrastructure to support the implementation and
ongoing maintenance of the SAP environment.
Regulators are encouraged to collaborate with utilities
to define clear data standards and embrace digital
submissions facilitated by platforms like SAP, fostering
greater transparency and efficiency in the review
process, potentially exploring AI-driven tools to analyse
filings and identify key areas for review, ultimately
streamlining the regulatory oversight process while
ensuring fair and reasonable rates for consumers.
REFERENCES
[1] Rate Case Support
https://www.consultcelerity.com/case-studies/gas-
electric-utilities/
[2] Lessons Learned from the Rate Case Process
: An
analysis of utility rate case experiences, highlighting best
practices and common challenges.
https://www.mcr-group.com/wp-
content/uploads/2024/01/Rate-Case-Paper-Part-2-
Lessons-Learned.pdf
[3] SAP HANA XSA Migration Strategy
https://help.sap.com/doc/4b2182c05561496d83e2a32
b7d22a625/2.0.04/en-
US/SAP_HANA_XS_Advanced_Migration_Guide_en.pdf
[4] 2025 General Rate Case Total Compensation Study
:
A study examining total compensation as part of
Southern California Edison's GRC filing.
https://docs.cpuc.ca.gov/PublishedDocs/SupDoc/A230
5010/6064/508571399.pdf
[5] 2025 GRC Study on Residential Disconnections
:
Assessment of how proposed rate increases may impact
residential service disconnections.
https://docs.cpuc.ca.gov/PublishedDocs/SupDoc/A230
5010/6065/508572055.pdf
[6] PacifiCorp’s GRC Operations Report
: Details on
PacifiCorp's operational results and methodologies in
their GRC filing.
https://docs.cpuc.ca.gov/PublishedDocs/SupDoc/A220
5006/5704/500158375.pdf
[7] Pacific Gas and Electric (PG&E) General Rate Case
(GRC) Proceedings Overview
https://www.cpuc.ca.gov/industries-and-
topics/electrical-energy/electric-rates/general-rate-
case/pacific-gas-and-electric-grc-proceedings
[8] Technology Platforms Essential to Prove Need in
Utility Rate Cases
The American Journal of Engineering and Technology
192
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https://www.tdworld.com/electric-utility-
operations/tools-and-
technologies/article/21164430/technology-platforms-
essential-to-prove-need-in-utility-rate-cases?
[9] Accelerating utility rate case filings with generative
AI
https://www.utilitydive.com/news/accelerating-utility-
rate-case-filings-generative-ai-artificial-intelligence-
genai/730551/
[10] Neudesic on GenAI Use Cases for GRC
: Exploration
of how Generative AI can assist in preparing and
managing GRC filings.
https://www.neudesic.com/blog/genai-use-cases-
general-rate-case/
[11] Towards Multi-way Join Aware Optimizer in SAP
HANA
http://www.vldb.org/pvldb/vol13/p3019-wi.pdf
