The regulator wanted the reasoning, not the result
A network operator set a tariff on evidence that was still moving, and the regulator reopened the file nineteen months later.
Engagement
Decision framing, 2 weeks, then evidence review, 4 to 8 weeks, then board handover, 2 weeks.
The decision in front of the board
The company had to set a tariff for a regulated network. The cost forecast behind it would not firm up for another year. The board could wait for the forecast, or decide and carry the uncertainty. Waiting had a price the board could name. Deciding had a risk it could not.
Nineteen months later the regulator reopened the decision. The letter did not ask whether the tariff was right. It asked what the board knew on the day of the vote. It asked which alternatives sat in front of the board, and why the board set them aside. A deck cannot answer that. A deck carries the chosen path and nothing else.
What Plenary did
Two of us carried the file, and one of the two was a partner. No juniors worked on the analysis. We began by narrowing the question the board had in front of it. The agenda said set the tariff. The real decision was whether to set it before the forecast firmed, and on what basis. We wrote that question down and tested it with the chair before gathering any evidence.
The record came next. Every alternative went in, including the ones management had dropped early, with the evidence for and against each as it stood that month. The limits of confidence sat in the same sentences as the recommendation. A section named what would make the recommendation wrong, and what the board should watch for. The file stayed with the company in editable form.
What happened next
File status
Reopened by the regulator.
When the regulator wrote
The company did not have to investigate its own decision. It sent the record. The alternatives were in it. So was the state of the evidence on the day of the vote. So was the section on what would make the decision wrong, dated before the vote. The exchange closed. Nobody had to reconstruct the decision.
“The regulator asked for our reasoning. We had it in writing, and it was dated.”
Ask which of these is closest to your file.
The gap is in what we can say, not in what we have done.