## Reasoning

### Step 1: Calculate Net Debt (S&P Methodology)

Under S&P methodology, Net Debt typically includes:
- Short-term borrowings
- Long-term borrowings
- Current lease liabilities (sometimes included)
- Non-current lease liabilities (sometimes included)
- Less: Cash and cash equivalents
- S&P typically treats hybrid capital with intermediate equity content as 50% debt / 50% equity

**As of 2023-01-01 (end of fiscal year 2022):**

- Long-term borrowings: 19,006M EUR
- Short-term borrowings: 709M EUR
- Current bank overdrafts: 0M EUR
- Non-current lease liabilities: 574M EUR
- Current lease liabilities: 155M EUR
- Hybrid capital: 2,125M EUR (S&P typically treats this as 50% debt = 1,062.5M EUR)
- Cash and cash equivalents: 6,547M EUR

**Gross Debt (S&P):**
= 19,006 + 709 + 574 + 155 + 1,062.5 = 21,506.5M EUR

**Net Debt:**
= 21,506.5 - 6,547 = 14,959.5M EUR

However, S&P sometimes caps surplus cash. Let me also consider that S&P may include other financial liabilities. Let me keep it relatively standard.

Actually, let me reconsider. S&P's net debt calculation:
- Total debt = short-term borrowings + long-term borrowings + 50% of hybrid capital + lease liabilities
- Net debt = Total debt - cash (S&P may apply haircuts to excess cash, but typically uses readily available cash)

Net Debt = 19,006 + 709 + 0 + 574 + 155 + 1,062.5 - 6,547 = 14,959.5M EUR

### Step 2: Calculate EBITDA (S&P Methodology)

S&P EBITDA starts from operating profit and adds back D&A. S&P also typically includes equity method income if cash dividends are received.

From the income statement for FY2022 (period 2022-01-01 to 2023-01-01):

**Operating Profit (EBIT):** -976M EUR

This already includes:
- Revenue: 8,299M
- Operating expenses: -9,395M (includes energy transmission charges, employee benefits, D&A, other operating expenses)
- Share of profit of JVs/associates: 120M
- Other gains/losses: -38M (already included in operating expense presumably)

Wait, let me reconstruct:
Revenue: 8,299
- Energy transmission charges: -7,517
- Employee benefits: -285
- D&A: -1,233
- Other operating expense: -322
- Other gains/losses: -38
= Operating profit before equity method = -1,096

+ Share of profit from equity method: 120
= Operating profit: -976M ✓

**EBITDA = Operating Profit + D&A**
= -976 + 1,233 = 257M EUR

Under S&P methodology, they might adjust equity method income. S&P prefers to use dividends received from equity method investments rather than equity method profit. Dividends received = 92M EUR.

**S&P Adjusted EBITDA:**
= -976 - 120 (remove equity profit) + 92 (add dividends received) + 1,233 (D&A)
= 229M EUR

Also, S&P adds back lease payments (operating lease expense) since they capitalize leases. Under IFRS 16, leases are already capitalized, so D&A already includes lease depreciation and interest includes lease interest. The EBITDA calculated above should already reflect this properly since lease depreciation is in D&A and lease interest is below operating profit.

Actually, S&P adds back the full lease cost (both depreciation of ROU and lease interest). Under IFRS 16, lease depreciation is already in D&A (added back). Lease interest (in finance costs) needs to be added back too for S&P EBITDA.

Lease interest ≈ current lease liabilities context... Let me estimate. Total lease liabilities = 574 + 155 = 729M. At maybe ~3% rate, lease interest ≈ ~20M EUR roughly. But I don't have the exact figure.

Actually, S&P's EBITDA typically adds back lease depreciation (already in D&A) but the lease interest component is typically captured in their adjusted interest. For the Net Debt / EBITDA ratio, the standard approach is:

Let me also consider that S&P hybrid capital treatment: 50% of hybrid coupon (57M × 50% = 28.5M) might be treated as interest.

S&P also adds hybrid coupon (50% treated as equity) back, but this gets complex.

Let me use a simpler S&P-style EBITDA:

**EBITDA = Operating profit + D&A - equity method profit + dividends received**
= -976 + 1,233 - 120 + 92 = 229M EUR

### Step 3: Net Debt / EBITDA

= 14,959.5 / 229 ≈ 65.3x

This seems extremely high. Let me reconsider.

Actually, TenneT is a regulated utility. The large operating loss is partly due to timing differences in the regulatory framework (EEG surcharge in Germany). The very negative results may be temporary. But we need to calculate based on what we have.

Let me reconsider whether S&P would use a different EBITDA definition. Perhaps they include the non-cash regulatory provisions adjustments.

Looking at the cash flow adjustments:
- "Other Adjustments For Noncash Items": 1,347M EUR
- "Adjustments For Provisions": 104M EUR

These are significant non-cash items. S&P FFO (Funds from Operations) is a key metric. Let me compute FFO:

Cash from operating activities: 1,196M EUR

But this includes working capital changes. S&P FFO excludes working capital changes.

Let me try to compute S&P FFO:
Profit before tax: -1,233M
+ D&A: 1,233M
+ Net finance costs: 257M
- Equity method profit: -120M
+ Dividends received: 92M
+ Non-cash provisions: 104M
+ Other non-cash items: 1,347M
= Approx operating cash before WC and tax

Actually, let me approach EBITDA differently. The "Other Adjustments For Noncash Items" of 1,347M suggests there are significant regulatory accounting items that don't flow through cash but are in the P&L.

For a regulated utility like TenneT, the accounting losses are often driven by regulatory timing differences. The revenue recognized may differ from the allowed revenue, creating regulatory assets/liabilities.

Given the complexity, let me try a cleaner approach:

**S&P EBITDA** for a regulated utility would typically adjust for regulatory timing items. But with the data available, let me compute basic EBITDA:

EBITDA = Revenue - Energy transmission charges - Employee benefits - Other operating expenses + Other gains/losses (exclude) + equity method adjustments
= 8,299 - 7,517 - 285 - 322 = 175M (excluding other items)
+ Share of JV profit adjustment: use dividends received 92M
= 267M

Or more simply:
EBITDA = Operating profit + D&A = -976 + 1,233 = 257M

With S&P adjustments (replacing equity method profit with dividends):
= 257 - 120 + 92 = 229M

**Net Debt / EBITDA = 14,959.5 / 229 ≈ 65.3**

This is extremely high. But actually, for S&P they might not subtract all the cash if it's restricted or EEG-related. A large portion of TenneT's cash is related to EEG (German renewable energy surcharge) escrow-type funds.

Looking at the cash flow statement, there are significant EEG working capital items. The cash balance of 6,547M likely includes substantial EEG-related cash that S&P might not net against debt.

If we use gross debt instead:
Gross Debt / EBITDA = 21,506.5 / 229 ≈ 93.9

Let me try with FFO-based metrics instead, or reconsider EBITDA.

Actually, looking more carefully, the "Other Adjustments For Noncash Items" of 1,347M likely represents the regulatory timing differences. Under S&P methodology, they typically add these back for FFO purposes but may also adjust EBITDA.

Let me try S&P Adjusted EBITDA including regulatory non-cash adjustments:
= 229 + 1,347 + 104 (provisions) + 38 (loss on disposal) = 1,718M

Hmm, but not all of "Other Adjustments For Noncash Items" would necessarily go into EBITDA.

Let me reconsider. The cash flow from operations excluding EEG WC is 596M. This is after tax paid of 231M and after interest (which is in financing). So:

Approximate S&P FFO = Cash from ops excl. WC changes + interest paid - interest received... 

Actually let me try:
FFO ≈ Net income + D&A + non-cash items - equity method profit + dividends received
= -879 + 1,233 + 1,347 + 104 + 38 - 120 + 92 = 1,815M (before interest and tax adjustments)

This doesn't quite work either. Let me use the cash flow statement more directly.

Cash from operations (excluding EEG WC) = 596M
Add back: income taxes paid = 231M  
Add back: net interest (202 paid - 45 received) = 157M... but interest is in financing activities here.

Actually, interest paid is classified as financing (202M) and interest received as investing (45M). So operating cash flow doesn't include these.

S&P FFO = Operating cash flow (excl WC) + interest received - interest paid
Wait no. Let me think again.

For S&P:
FFO = Net income + D&A + other non-cash + deferred taxes... adjusted

EBITDA(S&P) = FFO + cash interest + cash taxes

Let me estimate FFO first from cash flow:
Operating CF excluding EEG WC and excluding regular WC changes:

From the cash flow:
Net loss: -879
+ D&A: 1,233
+ Loss on disposal: 38
+ Equity method adjustment: -120 + 92 = -28 (net: add 28 since we remove equity profit and add dividends)

Wait, "Adjustments For Undistributed Profits" = 120M (this removes the equity profit that wasn't received as cash, then dividends received of 92M adds back actual cash)

+ Provisions: 104
+ Other non-cash items: 1,347
= Operating cash before WC and tax = -879 + 1,233 + 38 + 120 - 92 + 104 + 1,347 = 1,871M

Wait, let me re-read the CF statement:
The adjustments to reconcile to operating cash flow:
- D&A: +1,233
- Loss on disposal: +38
- Undistributed profits of equity method: +120 (removing non-cash equity income)
- Dividends received: +92 (adding back cash received)
- Provisions: +104
- Other non-cash: +1,347

So: Net loss + these adjustments = -879 + 1,233 + 38 + 120 + 92 + 104 + 1,347 = 2,055M (before WC and taxes)

Wait, dividends received is typically a separate line. Let me check: "Dividends Received Classified As Operating Activities" 92M. This would be a cash inflow separate from the adjustment.

Actually in the indirect method:
Start with profit/loss: -879
Adjustments:
+ D&A: 1,233
+ Loss on disposal: 38  
+ Remove equity profit (add back): 120 (i.e., since equity profit of +120 was non-cash, we add 120 to remove it... wait, equity profit was positive 120 in P&L, so to adjust we subtract it: -120)

Hmm, "Adjustments For Undistributed Profits Of Investments Accounted For Using Equity Method" = 120M. This is typically shown as: the equity method profit was 120M, undistributed portion adjustment adds this back (because the profit was non-cash). So net effect: +120M adjustment.

Then dividends received = +92M (actual cash received from equity investments).

Net effect of equity method: -120 (profit) + 120 (adjustment) + 92 (dividends) = +92M cash

+ Provisions: +104
+ Other non-cash: +1,347
+ Income taxes (adjustment): likely part of the reconciliation

Operating CF before WC = -879 + 1,233 + 38 + 120 + 92 + 104 + 1,347 = 2,055M
- Taxes paid: -231
= 1,824 before WC

Then WC changes (excl EEG): -736M
= Cash from ops excl EEG = 1,824 - 736 = 1,088... 

But reported is 596M excl EEG WC. Let me check:
596 + EEG WC changes... 

Actually: "Cash Flows From Used In Operations Excluding Eeg Working Capital" = 596M
"Increase Decrease In Working Capital Eeg Working Capital" = -1,792M
But wait, the EEG WC change is listed separately. 

"Cash Flows From Used In Operating Activities" = 1,196M
= 596 + (-(-1,792))... no, 596 + 1,792 = 2,388... that doesn't equal 1,196 either.

Hmm, 596 + 1,792 ≠ 1,196. So: 596 + 600 = 1,196. The sign conventions might be different.

Actually: Operating CF = CF excl EEG WC - EEG WC outflow
If EEG WC is an outflow of 1,792M, then: 596 + 1,792 doesn't work.
But if the sign is already included: maybe the EEG working capital change adds 600M?

Wait: "Increase Decrease In Working Capital Eeg Working Capital" 2022-01-01 - 2023-01-01: -1,792M
And the three sub-items:
- Decrease in receivables EEG: 592M (cash inflow)
- Decrease in receivables EEG >3mo: 472M (cash inflow)  
- Increase in payables EEG: 728M (cash inflow)
Total: 592 + 472 + 728 = 1,792M

But the heading says -1,792M... this is confusing. Perhaps the heading sign is the opposite (it's "increase/decrease in working capital" which would be a use of cash if WC increases).

Let me just work with: Total operating CF = 1,196M.

Now, for S&P EBITDA:

S&P EBITDA ≈ FFO + cash interest + cash taxes

FFO ≈ Operating CF - WC changes + interest paid (if classified in operating) - interest received (if classified in operating)

Since interest paid (202M) is in financing and interest received (45M) is in investing, operating CF already excludes these.

So: FFO ≈ Operating CF - WC changes

WC changes: We need to identify total WC changes.
Total operating CF = 1,196M
From the reconciliation, before WC changes, we had some figure, then WC changes reduced/increased it.

Let me try differently:

Pre-WC operating CF = 1,196 + 736 (excl-EEG WC outflow) + ... 

This is getting complicated. Let me try a top-down approach.

**S&P EBITDA = EBIT + D&A**

EBIT (operating profit) = -976M
D&A = 1,233M
EBITDA = 257M

But this EBITDA of 257M seems very low for a company with 38.5B in assets. The low EBITDA is because of the massive energy transmission charges and likely regulatory timing differences.

For S&P, they often make adjustments for regulated utilities to normalize EBITDA. But with just the reported figures:

**Using basic EBITDA = 257M and adjusting for equity method:**

S&P would replace equity method income (120M) with dividends received (92M):
Adjusted EBITDA = 257 - 120 + 92 = 229M

**Net Debt calculation:**
Let me be more careful. S&P for TenneT specifically:

Total debt:
- Long-term borrowings: 19,006M
- Short-term borrowings: 709M  
- 50% of hybrid capital: 1,062.5M (S&P gives intermediate equity content)
- Lease liabilities: 574 + 155 = 729M (S&P adds operating lease debt)

Total debt = 21,506.5M

Surplus cash: S&P might consider some of the cash as operational/restricted (EEG-related). But without more info, let's use reported cash.

Net debt = 21,506.5 - 6,547 = 14,959.5M

**Ratio = 14,959.5 / 229 ≈ 65.3x**

This seems unreasonably high. Let me reconsider whether the "Other Adjustments For Noncash Items" of 1,347M should affect EBITDA.

Looking at this more carefully, for a regulated TSO, the P&L includes regulatory timing differences as non-cash revenue/expense items. The massive non-cash adjustment of 1,347M likely represents regulatory account movements. S&P might include these in their EBITDA calculation.

If I add back the non-cash items to EBITDA:
Adjusted EBITDA = 229 + 1,347 + 104 = 1,680M (adding provisions and other non-cash)

But this is very aggressive. Let me think about what "Other Adjustments For Noncash Items" might include.

For TenneT, the key non-cash items are likely:
1. Regulatory timing differences (under-/over-recovery)
2. Fair value changes on financial instruments
3. Unrealized FX gains/losses

S&P would typically add back regulatory timing differences to calculate their adjusted EBITDA.

If EBITDA including regulatory adjustments ≈ 229 + 1,347 = 1,576M (conservatively without provisions):

Net Debt / EBITDA = 14,959.5 / 1,576 ≈ 9.5x

Still high. Let me try another approach.

Actually, let me reconsider. S&P's approach for TenneT might not net all cash. TenneT holds significant EEG-related cash that's essentially pass-through. If we don't net any cash:

Gross Debt / EBITDA = 21,506.5 / 1,576 ≈ 13.6x

Hmm, let me try with a simpler/cleaner approach. Maybe I'm overcomplicating the hybrid treatment and non-cash adjustments.

Let me go with a straightforward calculation:

**Gross Debt:**
- LT Borrowings: 19,006
- ST Borrowings: 709
- 50% Hybrid: 1,062.5
Total gross debt = 20,777.5M (excluding leases for a simpler approach... actually S&P includes leases)

With leases: 20,777.5 + 729 = 21,506.5M

**Cash:** 6,547M

**Net Debt:** 14,959.5M

**EBITDA:** 257M (basic, without adjustments for non-cash regulatory items)

Hmm, but 257M EBITDA for a company generating 1,196M operating cash flow seems low. The difference is the non-cash items.

I think S&P would make significant adjustments. Let me try computing EBITDA from FFO.

**S&P FFO approach:**
Operating CF = 1,196M
Remove WC changes. From the CF statement, WC changes are embedded. Let me estimate:

Excl-EEG WC change: -736M (this was the total excl-EEG WC change which was a cash outflow)
EEG WC change: +1,792M (net cash inflow from EEG WC movements per the sub-items: 592+472+728=1,792)

Wait, the sign: "Increase Decrease In Working Capital Excluding Eeg Working Capital" = -736M. Negative = cash outflow from WC increase.

"Increase Decrease In Working Capital Eeg Working Capital" = -1,792M. But sub-items sum to +1,792M. The heading might use opposite sign convention.

Total WC change impact on cash flow:
If excl-EEG is -736M and EEG is... let me derive:
CF from ops excl EEG = 596M
CF from ops total = 1,196M
So EEG impact = 1,196 - 596 = 600M

This means EEG WC contributed +600M to operating cash flow.

OK, pre-WC operating cash flow:
Excl-EEG: 596 + 736 = 1,332M (adding back WC outflow)
EEG: 1,332 - 600 = 732M... no.

Pre-WC total operating CF = 1,196 + 736 - 600 = 1,332M

Hmm, or: 
Pre-WC op CF = post-WC CF + WC outflows = 596 + 736 = 1,332M (for excl-EEG part)
The EEG WC is separate and adds 600M to get to 1,196M total.

S&P FFO = Operating CF - WC changes = 1,196 - (-736) - (+600) = 1,196 + 736 - 600 = 1,332M

But interest is in financing (202M paid) and investing (45M received), and these are not in operating CF.

**S&P FFO ≈ 1,332M** (before interest adjustments since interest is already excluded from operating CF)

**S&P EBITDA = FFO + cash interest + cash taxes**
= 1,332 + (202 - 45) + 231
= 1,332 + 157 + 231
= 1,720M

Hmm wait, but FFO should be after interest and after tax. Since operating CF already excludes interest (it's in financing/investing) but includes tax payments:

Operating CF before WC = 1,332M (this is after tax paid of 231M, before interest since interest is not in operating)

Actually no. Let me re-examine. The CF statement shows:
- Income taxes paid: 231M (classified as operating - shown as a deduction)

So pre-WC operating CF of 1,332M is after tax payments of 231M.

FFO (S&P) = Net income + D&A + non-cash items (i.e., operating CF before WC)
But this should be after interest and tax.

Since interest is in financing, operating CF is before interest but after tax.

S&P FFO = Operating CF before WC - cash interest
= 1,332 - (202 - 45) = 1,332 - 157 = 1,175M

S&P EBITDA = FFO + cash interest + cash taxes
= 1,175 + 157 + 231 = 1,563M

Hmm wait, that gives us: EBITDA = pre-WC operating CF + cash interest expense net... no.

Let me just be clean:

**EBITDA = Pre-WC, Pre-tax, Pre-interest operating cash flow**

Pre-WC operating CF = 1,332M (after tax of 231M, before interest since it's in financing)
Add back taxes: + 231M
= Pre-WC, pre-tax CF = 1,563M

This is already before interest (since interest is in financing), so:
**S&P EBITDA ≈ 1,563M**

Hmm, but I need to account for interest received too. Interest received of 45M is in investing activities and not in operating CF. If we want a true EBITDA:

EBITDA = 1,563M (this already excludes interest received/paid since both are outside operating CF)

Actually, S&P EBITDA for the purpose of Net Debt/EBITDA typically includes interest income in EBITDA (it's part of operations for a corporate). But the finance income of 43M might not all be interest. Let's keep it simple.

**Net Debt / EBITDA = 14,960 / 1,563 ≈ 9.6x**

Hmm, but this still seems high. Let me reconsider whether I should include 50% hybrid as debt.

Actually, for TenneT, S&P has rated them. Looking at this from a different angle:

Let me try without hybrid:
Net debt = 19,006 + 709 + 729 - 6,547 = 13,897M
Net Debt/EBITDA = 13,897 / 1,563 ≈ 8.9x

With 50% hybrid:
= (13,897 + 1,062.5) / 1,563 = 14,959.5 / 1,563 ≈ 9.6x

For S&P, they also adjust EBITDA for hybrid coupon treatment. 50% of hybrid coupon is treated as interest (deducted for FFO) and 50% as equity distribution. The hybrid coupon is 57M per year.

S&P EBITDA should add back only the 50% of hybrid coupon treated as interest (28.5M), but since EBITDA is before interest, this should already be captured.

Let me try yet another approach. Let me compute EBITDA directly from the P&L but adjusting for the large non-cash regulatory items:

Revenue: 8,299
- Energy transmission charges: 7,517
= Gross margin: 782

But wait, the "Other Adjustments For Noncash Items" of 1,347M in the cash flow likely relates to regulatory account changes embedded in revenue or energy transmission charges. This means actual cash received/paid differs significantly from P&L amounts.

Cash-based gross margin ≈ 782 + 1,347 = 2,129M (approximately)

- Employee benefits: 285
- Other operating expense: 322 (some might be non-cash too, but let's keep it)
- Other gains/losses: excluded (non-cash disposal losses of 38M)
= Cash EBIT ≈ 2,129 - 285 - 322 = 1,522M
+ Equity method dividends: 92M
= Cash EBITDA-equivalent before D&A and tax ≈ 1,614M

Hmm, this is close to my earlier estimate of 1,563M.

Let me settle on approximately **1,563M** for EBITDA (S&P adjusted).

But actually, I realize I should double-check by simply calculating from the cash flow statement more carefully.

From P&L to EBITDA:
EBIT = -976
+ D&A = 1,233
= EBITDA = 257

S&P adjustments:
- Replace equity method profit with dividends: -120 + 92 = -28
- Add back non-cash regulatory items: The 1,347M "Other non-cash items" represents regulatory timing differences
- Add back non-cash provisions: Could add 104M but provisions might be partially cash

If I add the 1,347M non-cash adjustment:
EBITDA (adjusted) = 257 - 28 + 1,347 = 1,576M

With provisions: 1,576 + 104 = 1,680M

Let me split the difference and use ~1,576M for EBITDA.

**Net Debt / EBITDA:**

With 50% hybrid as debt:
= 14,960 / 1,576 ≈ 9.5x

Without hybrid adjustment:
= 13,897 / 1,576 ≈ 8.8x

Hmm, actually I'm second-guessing myself on whether S&P would include all those non-cash adjustments in EBITDA. For a regulated utility, S&P would typically look at "Funds from Operations" (FFO) to debt rather than EBITDA to debt. But the question asks for Net Debt / EBITDA.

Let me reconsider. If S&P is calculating EBITDA, they would start with reported EBITDA and then make their standard adjustments:
1. Operating leases: already capitalized under IFRS 16
2. Hybrid equity content: 50% equity
3. Surplus cash
4. Pension adjustments
5. Regulatory adjustments

For the basic EBITDA without regulatory adjustments:
EBITDA = 257M (or 229M with equity method adjustment)

This gives Net Debt / EBITDA of about 65x, which is not meaningful.

For TenneT specifically, S&P would almost certainly adjust for regulatory timing differences. The 1,347M non-cash adjustment is critical.

I think the most reasonable S&P-style estimate is:

**EBITDA ≈ 1,576M** (basic EBITDA + non-cash regulatory adjustments)

**Net Debt ≈ 14,960M** (including 50% hybrid, net of cash)

**Net Debt / EBITDA ≈ 9.5x**

Actually, let me reconsider whether to include lease liabilities in S&P net debt. S&P does include lease liabilities as debt. And they add back lease depreciation and lease interest to EBITDA... but under IFRS 16, lease depreciation is already in D&A (which we added back) and lease interest is in finance costs (which is below EBIT). So EBITDA already captures this correctly.

Let me finalize:

**Net Debt = 19,006 + 709 + 729 + 1,062.5 - 6,547 = 14,959.5M ≈ 14,960M**

**EBITDA = 257 + 1,347 - 120 + 92 + 104 = 1,680M** (being generous with provisions)

Or more conservatively: 257 + 1,347 - 28 = 1,576M

**Ratio = 14,960 / 1,576 ≈ 9.5** or **14,960 / 1,680 ≈ 8.9**

Given the uncertainty, I'll go with approximately **9.5**.

Wait, I want to reconsider one more time. The question says "estimate the Net Debt / EBITDA ratio for 2022, based on the S&P methodology."

For S&P, the key metric is actually FFO/Debt, but they also use Debt/EBITDA.

S&P's EBITDA = EBIT + D&A + amortization (already in D&A)

For S&P, they typically start from reported EBITDA and then adjust. The key question is whether they'd add back the 1,347M non-cash items.

For a regulated utility with significant regulatory timing differences, S&P does adjust. But typically these adjustments are to FFO, not necessarily EBITDA.

Actually, S&P's EBITDA for a regulated utility would include the regulatory accounting adjustments because EBITDA should represent the cash-based earnings before interest, tax, depreciation and amortization. The non-cash regulatory items are similar to revenue/cost recognition timing differences.

I'll go with my estimate of approximately **9.5**.

Hmm, but actually let me reconsider whether the non-cash items should be in EBITDA. EBITDA is literally Earnings Before Interest, Tax, D&A. If the earnings are depressed by non-cash regulatory charges, those charges are legitimately part of EBITDA unless S&P explicitly adjusts for them.

S&P does adjust for "regulatory account movements" for regulated utilities. This is one of their standard adjustments. So yes, they would add back the non-cash regulatory timing differences.

Final answer: **~9.5x**

Let me round: 14,960 / 1,576 = 9.49 ≈ 9.5

<answer>9.5</answer>