20241212Kaufman Testimony Supporting Stipulation.pdf

RECEIVED
2024 December 12
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN ) CASE NO. PAC-E-24-04
POWER'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND OF )
APPROVAL OF PROPOSED ELECTRIC )
SERVICE SCHEDULES AND )
REGULATIONS
TESTIMONY OF DR. LANCE D. KAUFMAN
SUPPORTING THE STIPULATION
ON BEHALF OF THE
IDAHO IRRIGATION PUMPERS ASSOCIATION
December 12, 2024

TABLE OF CONTENTS
ROCKY MOUNTAIN POWER'S GENERAL RATE CASE
Case No. PAC-E-24-04
Written Testimony of Lance D. Kaufman, Ph. D.
I. Introduction and Summary..................................................................................................... 1
I1. Summary of IIPA Participation in this Case.......................................................................... 1
EXHIBIT LIST
Exhibit 201 —Qualification Statement of Lance D. Kaufman
Page i

1 I. INTRODUCTION AND SUMMARY
2 Q. PLEASE STATE YOUR NAME AND OCCUPATION.
3 A. My name is Lance D. Kaufman. I am a consultant representing utility customers before state
4 public utility commissions in the Northwest and Intermountain West. My witness qualification
5 statement can be found at Exhibit 201.
6 Q. PLEASE IDENTIFY THE PARTY ON WHOSE BEHALF YOU ARE TESTIFYING.
7 A. I am testifying on behalf of the Idaho Irrigation Pumper's Association, Inc. ("IIPA"). IIPA is a
8 non-profit trade association whose members are large energy users in the Idaho, including
9 customers receiving electric services from PacifiCorp ("PAC" or"Company").
10 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY?
1 1 A. I provide testimony on the following items:
12 • The proposed settlement.
13 Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS.
14 A. I make the following recommendations:
15 • Find the proposed settlement results in fair,just, and reasonable rates.
16 II. SUMMARY OF IIPA PARTICIPATION IN THIS CASE
17 Q. PLEASE SUMMARIZE IIPA'S PARTICIPATION,ANALYSIS,AND FINDINGS IN
18 THIS CASE.
19 A. IIPA reviewed the opening testimony and workpapers of all company witnesses, issued
20 discovery on cost of capital, test year expenses, and cost of service, and developed positions on
21 potentially appropriate adjustments to the Company's filed case. Prior to participation in
22 settlement discussions IIPA identified and quantified potential adjustments related to the
23 following issues:
Case No. PAC-E-24-04 Kaufman, L Di 1
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1 1. Cost of capital,
2 2. Rate base,
3 3. Expenses,
4 4. Cost of service, and
5 5. Rate spread.
6 IIPA participated in multiple settlement discussions in October and November, 2024 regarding
7 this case. During these discussions all issues considered by IIPA were raised and discussed by
8 the parties, including PAC. PAC offered reasonable responses to many of the issues and
9 concerns raised by the parties. Between settlement discussions IIPA met with members and
10 other intervening parties to discuss issues in the case. IIPA proposed several of the
11 compromises that led to the final settlement proposal and finds the final proposal contains
12 terms and conditions that are acceptable to the IIPA, provides an appropriate balance between
13 the participating parties, and will likely result in fair,just and reasonable rates.
14 Q. PLEASE DESCRIBE YOUR ANALYSIS OF PAC'S COST OF CAPITAL.
15 A. IIPA submitted discovery and performed analysis of PAC's cost of capital, including estimates
16 of cost of equity and evaluation of capital structure and cost of debt. IIPA evaluated cost of
17 capital using discounted cash flow and capital pricing asset models. The cost of equity agreed
18 to in the stipulation was contained within the range of estimates of IIPA's cost of equity
19 analysis.
20 IIPA reviewed the company's credit position, debt coverage, debt issuances, and historical
21 changes in capital structure. IIPA identified capital structure as a potential area of contention,
22 with the Company's requested capital structure containing an equity ratio exceeding its actual
Case No. PAC-E-24-04 Kaufman, L Di 2
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I equity ratio. The settled return on rate base is consistent with a return on equity, cost of debt,
2 and capital structure within the range that IIPA's analysis indicates is reasonable.
3 Q. PLEASE DESCRIBE YOUR REVIEW OF PAC'S RATE BASE
4 A. IIPA investigated the annualization and prudence of major plant additions included as pro-
5 forma adjustments and historic plant additions related to wildfire restoration.
6 Q. PLEASE DESCRIBE YOUR REVIEW OF PAC'S EXPENSES
7 A. IIPA reviewed PAC's base year expense ledgers and test year adjustments. IIPA identified
8 potential issues with executive compensation,bonuses, injuries and damages, outside services,
9 and catastrophic fire fund.
10 Q. PLEASE DESCRIBE YOUR REVIEW OF PAC'S COST OF SERVICE MODEL.
1 1 A. IIPA identified several potential changes to PAC's cost of service model. These changes
12 generally reduced the cost of demand in summer months.
13 Q. PLEASE DESCRIBE YOUR REVIEW OF PAC's RATE SPREAD.
14 A. IIPA's revised cost of service model indicated that the Company's filed study allocated
15 excessive costs to Irrigation Schedule 10. The stipulated rate spread results in a rate increase
16 for Schedule 10 that is in between the rate increase indicated by IIPA's study and that indicated
17 by PAC's study, and is a reasonable compromise among parties.
18 Q. PLEASE DESCRIBE YOUR REVIEW OF PAC'S RATE DESIGN.
19 A. PAC proposed rate design for Irrigation Schedule 10 increased fixed charges, demand charges,
20 and energy charges by equal percentages. IIPA consulted with IIPA members to confirm that
21 this design is acceptable to Schedule 10 customers.
Case No. PAC-E-24-04 Kaufman, L Di 3
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I Q. ARE ALL OF IIPA'S CONCERNS ADDRESSED IN THE PROPOSED
2 SETTLEMENT?
3 A. Yes, all of IIPA's concerns are addressed in the proposed settlement through changes to
4 revenue requirement and rate spread, or indirectly through agreement for ongoing
5 collaboration. IIPA recommends that the commission find the proposed settlement to be fair,
6 just, and reasonable and in the public interest.
7 Q. HOW DOES THE SETTLEMENT AGREEMENT ADDRESS IIPA'S CONCERNS?
8 A. The agreed rate of return on rate base is consistent with IIPA's models. The non-specific
9 revenue requirement adjustments is sufficiently large to address IIPA's expense and rate base
10 issues. With the exception of the items explicitly called out in Paragraph 11, the stipulation is
I I worded in a manner that preserves IIPA's ability to continue to address disputed plant in future
12 rate cases. The rate spread is a fair compromise between IIPA's cost of service model and
13 PAC's cost of service model.
14 Q. WHAT IS YOUR RECOMMENDATION REGARDING THE STIPULATION?
15 A. IIPA recommends that the commission find the proposed settlement to be fair,just, and
16 reasonable and in the public interest.
17 Q. DOES THIS CONCLUDE YOUR TESTIMONY SUPPORTING THE STIPULATION?
18 A. Yes
Case No. PAC-E-24-04 Kaufman, L Di 4
12/12/2024 IIPA

CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 12t'day of December, 2024, 1 served a true, correct and
complete copy of the Testimony of Lance D. Kaufman, Ph.D., to each of the following, via the
method indicated below:
Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Hand Delivered
P.O. Box 83720 ❑ Overnight Mail
Boise, ID 83720-0074 ❑ Telecopy(Fax)
monica.barriossanchezgpuc.idaho.gov ❑ Electronic Mail (Email)
Adam Triplett ❑ U.S. Mail
Deputy Attorney General ❑ Hand Delivered
Idaho Public Utilities Commission ❑ Overnight Mail
P.O. Box 83720 ❑ Telecopy(Fax)
Boise, ID 83720-0074 ® Electronic Mail (Email)
adam.triplett&puc.Idaho.gov
Mark Alder ❑ U.S. Mail
Michael Snow ❑ Hand Delivered
Idaho Regulatory Affairs Manager ❑ Overnight Mail
PacifiCorp/Rocky Mountain Power ❑ Telecopy(Fax)
1407 W. North Temple, Suite 330 ® Electronic Mail (Email)
Salt Lake City, UT 84116
mark.alder(d pacificop2.com
michael.snow&pacificorp.com
Joseph Dallas (ISB #10330) ❑ U.S. Mail
Carla Scarsella ❑ Hand Delivered
PacificCorp/Rocky Mountain Power ❑ Overnight Mail
825 NE Multnomah, Suite 2000 ❑ Telecopy(Fax)
Portland, OR 97232 ® Electronic Mail (Email)
joseph.dallasgpacificorp.com
Carla.scarsella(d),pacificorp.com
Case No. PAC-E-24-04 Kaufman, L Di 5
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Data Request Response Center ❑ U.S. Mail
PacifiCorp ❑ Hand Delivered
825 NE Multnomah, Suite 2000 ❑ Overnight Mail
Portland, OR 97232 ❑ Telecopy(Fax)
datarequestgpacificorp.com ❑ Electronic Mail (Email)
Lance Kaufman, Ph.D. ❑ U.S. Mail
Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered
2623 NW Bluebell Place ❑ Overnight Mail
Corvallis, OR 97330 ❑ Telecopy(Fax)
lancegae_is�_h� ❑ Electronic Mail (Email)
Mike Veile ❑ U.S. Mail
Bayer Corporation ❑ Hand Delivered
P4 Production, L.L.C. ❑ Overnight Mail
P.O. Box 816 ❑ Telecopy(Fax)
Soda Springs, ID 83276 ❑ Electronic Mail (Email)
Mike.veile(kbayer.com
Thomas J. Budge ❑ U.S. Mail
Bayer Corporation ❑ Hand Delivered
Racine Olson, PLLP ❑ Overnight Mail
P.O. Box 1391 ❑ Telecopy(Fax)
Pocatello, ID 83204 ❑ Electronic Mail (Email)
tlnracineolson.com
Brian C. Collins ❑ U.S. Mail
Greg Meyer ❑ Hand Delivered
Bayer Corporation ❑ Overnight Mail
Brubaker& Associates ❑ Telecopy(Fax)
16690 Swingley Ridge Rd., #140 ❑ Electronic Mail (Email)
Chesterfield, MO 63017
bcollins gconsultbai.com
gmeyer(d),,consultbai.com
Kevin Higgins ❑ U.S. Mail
Neal Townsend ❑ Hand Delivered
Bayer Corporation ❑ Overnight Mail
Energy Strategies LLC ❑ Telecopy(Fax)
I I I East Broadway Suite 1200 ❑ Electronic Mail (Email)
Salt Lake City, UT 84111
khiggins(d),energystrat.com
ntownsend(k energ_ystrat.com
Case No. PAC-E-24-04 Kaufman, L Di 6
12/12/2024 IIPA

Matthew Nykiel ❑ U.S. Mail
Attorney for Idaho Conservation League ❑ Hand Delivered
710 N. 61h St. ❑ Overnight Mail
Boise, ID 83702 ❑ Telecopy(Fax)
matthew.n kiel&gmail.com M Electronic Mail (Email)
Ronald L. Williams ❑ U.S. Mail
Brandon Helgeson ❑ Hand Delivered
PacifiCorp Idaho Industrial Customers ❑ Overnight Mail
Hawley Troxell Ennis &Hawley LLP ❑ Telecopy(Fax)
P.O. Box 1617 ❑ Electronic Mail (Email)
Boise, ID 83701
rwilliams(ahawleytroxell.com
bhel_e�(a�hawleytroxell.com
Bradley Mullins ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
MW Analytics ❑ Overnight Mail
Teitotie 2, Suite 208 ❑ Telecopy(Fax)
Oulunsalo Finland, FI-90460 Z Electronic Mail (Email)
brmullins(&,,mwanalytics.com
Val Steiner ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
Itafos Conda, LLC ❑ Overnight Mail
val.steiner(kitafos.com ❑ Telecopy(Fax)
❑ Electronic Mail (Email)
Kyle Williams ❑ U.S. Mail
PacifiCorp Idaho Industrial Customers ❑ Hand Delivered
BYU Idaho ❑ Overnight Mail
williamsk&byui.edu ❑ Telecopy(Fax)
Z Electronic Mail (Email)
Eric L. Olsen, Echo Hawk& Olsen, PLLC
Case No. PAC-E-24-04 Kaufman, L Di 7
12/12/2024 IIPA

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN ) CASE NO. PAC-E-24-04
POWER'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND OF )
APPROVAL OF PROPOSED ELECTRIC )
SERVICE SCHEDULES AND )
REGULATIONS
INTERVENOR
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
LANCE D. KAUFMAN, Ph. D Exhibit 201

CURRICULUM VITAE
LANCE KAUFMAN
Western Economics,LLC
2623 NW Bluebell Place
Corvallis OR, 97330
[phone]
[e-mail]
EDUCATION:
University of Oregon Ph.D. Economics 2008—2013
University of Oregon M.S. Economics 2006—2008
University of Anchorage Alaska B.B.A. Economics 2001 —2004
CERTIFICATIONS:
Certified Depreciation Professional Society of Depreciation Professionals 2018
PROFESSIONAL EXPERIENCE:
Consultant Western Economics,LLC 2014—Present
Senior Economist Oregon Public Utility Commission 2015—2018
Public Utility Advocate Alaska Department of Law 2014—2015
Senior Economist Oregon Public Utility Commission 2013—2014
Instructor University of Oregon 2008—2012
Research Assistant University of Alaska Anchorage 2003—2008
PROFESSIONAL MEMBERSHIPS:
Society of Depreciation Professionals 2015—Present
American Economics Association 2017—Present
PUBLICATIONS:
Kaufman, Lance(2013)Three Essays on Governance Structure in the Hospital Industry.
University of Oregon
Laura R. Sangare,Lance Kaufman,Robert A. Bardwell,Deborah Nichols, and Mersine Bryan
(forthcoming)The risk of sleep-related death in an inclined sleep environment.BMC Public
Health.
RESEARCH, CONSULTING,AND ECONOMETRIC ANALYSIS:
• Hughes Socol Piers Resnick&Dym,Ltd.Martinez v TCC Wireless 2024
Aegis Insight 11

Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in Martinez et al. v. TCC Wireless Circuit Court of Cook County,Illinois,
County Department,Chancery Division.
• The Municipality of Cedar Falls, Iowa, Cedar Falls, IA 2023
Retained as a consultant for Cedar Falls Utilities to conduct a depreciation study of their
electric,gas,water, and telecommunications utilities.
• Davison Van Cleve,PC,Portland,OR 2023
Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread, and rate design in Portland General Electric Com�anX,
Request for a General Rate Revision,Public Utility Commission of Oregon,Docket No.
UE 416.
• Davison Van Cleve,PC,Portland,OR 2023
Retained as an expert witness for Alliance of Western Energy Consumers regarding cost
of capital,rate spread, and rate design in PacifiCom Request for a General Rate Revision,
Washington Utilities and Transportation Commission,Docket No. UE-230172.
• Alliance for Retail Energy Markets,La Jolla, CA 2023
Retained as an expert witness for Alliance for Retail Energy Markets regarding resource
adequacy of generation service providers in Arizona Public Service Company,Request
for a General Rate Revision,Arizona Public Utilities Commission,Docket No.
E-01345A-22-0144.
• North Carolina Sustainable Energy Association,Raleigh,NC 2023
Retained as an expert witness forNorth Carolina Sustainable Energy Association
regarding depreciation rates and coal plant securitization in Duke Energy Carolinas,
Request for a General Rate Revision,North Carolina Utility Commission Docket No. E-7
Sub 1276.
• Deep Blue Pacific Wind,Portland,OR 2023
Retained as an expert witness for Deep Blue Pacific Wind regarding least cost planning in
Portland General Electric Company,2023 Integrated Resource Plan,Public Utility
Commission of Oregon,Docket No. LC 80.
• Duane Morris LLP Boston,MA 2022
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in Harold Parsons v. The Commerce Insurance Company Suffolk Superior
Court Commonwealth of Massachusetts.
• Davison Van Cleve,PC,Portland,OR 2022
Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread, and rate design in Portland General Electric Company,
Request for a General Rate Revision,Public Utility Commission of Oregon,Docket No.
UE 394.
• Davison Van Cleve,PC, Portland,OR 2022
Retained as an expert witness for Alliance of Western Energy Consumers regarding
depreciation rates in Portland General Electric Company Detailed Depreciation Study of
Electric Utility Properties,Public Utility Commission of Oregon,Docket No.UM 2152.
• Davison Van Cleve,PC, Portland, OR 2022
Aegis Insight 12

Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread, and rate design in Pacific Power Request for a General
Rate Revision,Public Utility Commission of Oregon,Docket No. UE 399.
• Davison Van Cleve,PC,Portland,OR 2022
Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread, and rate design in Puget Sound Energy General Rate
Case to Update Base Rates,Washington Utility and Transportation Commission,Docket
No.UE-220066,UG-220067,UE-210918.
• Davison Van Cleve,PC,Portland,OR 2022
Retained as an expert witness for Alliance of Western Energy Consumers competitive
energy service in AWEC's Investigation into Long-Term Direct Access Programs,Public
Utility Commission of Oregon,Docket No. UM 2024.
• Davison Van Cleve,PC, Portland,OR 2021
Retained as an expert witness for Alliance of Western Energy Consumers competitive
energy service in Direct Access Rulemakin ,Public Utility Commission of Oregon,
Docket No.AR 651.
• Davison Van Cleve,PC, Portland,OR 2022
Retained as an expert witness for Smart Energy Alliance regarding revenue requirement,
rate spread,and rate design in Sierra Pacific General Rate Case to Update Base Rates,
Public Utility Commission of Nevada,Docket No. 22-06014.
• Davison Van Cleve,PC,Portland,OR 2022
Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread, and rate design in Avista Corp General Rate Case to
Update Base Rates,Washington Utility and Transportation Commission,Docket No.
UE-220053 &UG-220054.
• Georgia Public Service Commission, OR 2022
Retained as an expert witness for Georgia Public Service Commission depreciation rates
and decommissioning costs in Georgia Power Company's 2022 General Rate Case,
Georgia Public Service Commission,Docket No.44280.
• Nichols Kaster,PLLP,Minneapolis,Minnesota, 2013—
Deposed as expert witness for the plaintiffs re analysis of termination of older employees
in re Raymond, et al.v. Spirit Aerosystems, Inc., Case No. 16-1282-JTM-GEB,United
States District Court,District of Kansas.
• Jester, Gibson&Moore,Denver, CO 2022
Deposed as an expert witness for defendants and countersuit plaintiffs regarding lost
earnings in Franklin D. Azar&Associates.P.C.,v. Ivy Ngo v. Franklin D.Azar.
• Georgia Public Service Commission Public Interest Advocacy Staff,Atlanta, GA(2022)
Provided Testimony as an expert witness in Docket No. 44280 Georgia Power
Company's 2022 Rate Case Depreciation Study.
• Inland Empire Paper Co., Spokane,WA(2020)
Provided Testimony as an expert witness in WUTC Docket No. UE-200900,Avista
Corp's 2020 Rate Case regarding avoided cost pricing for a special contract.
• Davison Van Cleve,PC, Portland,OR 2021
Provided Testimony as an expert witness for Alliance of Western Energy Consumers
regarding depreciation, cost of service,rate design, and revenue requirement in Portland
Aegis Insight 13

General Electric Company 2021 General Rate Case,Public Utility Commission of
Oregon,Docket No. UE 394.
• Davison Van Cleve,PC,Portland,OR 2021
Provided comments as an expert witness for Alliance of Western Energy Consumers in
Puget Sound Energy's 2022 General Rate Case,Washington Utilities and Transportation
Commission.
• Davison Van Cleve,PC,Portland,OR 2022
Provided comments as an expert witness for Alliance of Western Energy Consumers in
Puget Sound Energy's 2022 General Rate Case,Washington Utilities and Transportation
Commission.
• Davison Van Cleve,PC,Portland,OR 2021
Provided comments as an expert witness for Alliance of Western Energy Consumers in
Avista Corp's Clean Energy Implementation Plan,Washington Utilities and
Transportation Commission.
• Davison Van Cleve,PC,Portland,OR 2021
Provided comments as an expert witness for Alliance of Western Energy Consumers in
PacifiCorp's General Rate Case,Public Utility Commission of Oregon,Docket No. UE
399.
• Davison Van Cleve,PC,Portland,OR 2021
Provided comments as an expert witness for Alliance of Western Energy Consumers in
Puget Sound Energy's Clean Energy Implementation Plan,Washington Utilities and
Transportation Commission.
• Hagens Berman Sobol Shapiro LLP,Phoenix,Arizona, 2021
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in Kronenberg. et al. vs.Allstate Insurance Com=any, et al. United States
District Court Eastern District of New York Case No.: 18-cv-06899 (NGG) (JO).
• Baumgartner Law,LLC,Denver, CO,2021
Deposed as an expert witness for plaintiffs re calculation of economic harm due to injury
in re In Re: Bernadette Romero and Leonard Martinez v. City of Westminster
• Killmer,Lane, and Newman,LLP,Denver, Colorado, 2020 .
Retained as expert witness for plaintiff re racial disparities in police use of force re Estate
of Eliiah J. McClain V. City Of Aurora, Colorado, Case No. 1:19-cv-0 1160-
RM-MEH,United States District Court,District of Colorado.
• Hagens Berman Sobol Shapiro LLP,Phoenix,Arizona, 2020
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in Fortson. et al. v. Garrison Pro pea and Casualty Insurance Co.United
States District Court Middle District of North Carolina Civil Action No. 1:19-cv-294.
• Hagens Berman Sobol Shapiro LLP,Phoenix,Arizona,2020
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in Lewis and Lewis. et al.v. Government Employees Insurance Co.United
States District Court For the District of New Jersey Civil Action No.
1:18—CV-05 I I I—RBK—AMD.
• Cable Huston,LLP,Portland, OR 2020
Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread and rate design in Cascade Natural Gas Corporation
Aegis Insight 14

Request for General Rate Revision,Public Utility Commission of Oregon,Docket No.
UG 390.
• Davison Van Cleve,PC, Portland,OR 2020
Retained as an expert witness for Alliance of Western Energy Consumers regarding net
power costs in Portland General Electric Com=any 2021 Annual Power Cost Update
Tariff,Public Utility Commission of Oregon,Docket No.UE 377.
• Davison Van Cleve,PC,Portland,OR 2020
Retained as an expert witness for Alliance of Western Energy Consumers regarding net
power costs in Portland General Electric Com=any 2021 Annual Update Tariff,Public
Utility Commission of Oregon,Docket No.UE 381.
• Davison Van Cleve,PC,Portland,OR 2020
Retained as an expert witness for Alliance of Western Energy Consumers regarding
revenue requirement,rate spread and rate design in Nevada Power Com =v 2021
General Rate Case,Public Utility Commission of Nevada,Docket No. 20-06003
• Frank& Salahuddin LLC,Denver, Colorado,2020
Retained as an expert witness for plaintiffs regarding calculation of lost earnings.
• Level Development Group,LLC,Denver, Colorado,2020
Develop real estate valuation model for establishing sale price of newly constructed
residential housing.
• Hagens Berman Sobol Shapiro LLP,Phoenix,Arizona, 2020
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in Jeff Olberg v.Allstate Insurance Company, Case No. C18-0573-JCC,
United States District Court,Western District of Washington at Seattle.
• Hagens Berman Sobol Shapiro LLP,Phoenix,Arizona, 2020
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in re Cameron Lundquist v. First National Insurance Company of America,
Case No. 18-cv-05301-RJB,United States District Court,Western District of Washington
at Tacoma.
• Killmer,Lane, and Newman,LLP,Denver, Colorado, 2020
Deposed as expert witness for plaintiff re racial disparities in police use of force re
Brandon Washington V. City Of Aurora; Colorado, Case No. 1:19-cv-01160-
RM-MEH,United States District Court,District of Colorado.
• Davison Van Cleve,PC,Portland,OR 2020
Retained as an expert witness for Alliance of Western Energy Consumers regarding coal
plant pollution control investments, coal plant decommissioning costs,rate spread and
rate design re PacifiCorp 2020 Request for a General Rate Revision,Public Utility
Commission of Oregon Docket No. UE 374.
• Davison Van Cleve,PC,Portland,OR and Washington Attorney General,2020
Retained as an expert witness for Packaging Company of America and Washington
Public Council regarding decommissioning costs and rate design re PacifiCorp 2020
Request for a General Rate Revision,Washington Utility and Transportation
Commission.
• Sanger Law,PC,Portland, OR,2019
Retained as a consultant for Renewable Energy Coalition and for Northwest&
Intermountain Power Producers Coalition to provide analysis of PacifiCorp avoided costs
Aegis Insight 15

in a Utility PURPA Compliance Filing at the Washington Utility and Transportation
Commission Docket,No. UE-190666.
• Sanger Law,PC,Portland, OR,2019
Retained as a consultant for Northwest&Intermountain Power Producers Coalition to
provide analysis of Portland General Electric avoided costs in support of testimony to the
Oregon Legislature.
• Powder River Basin Resource Council,Laramie,Wyoming,2019.
Testified as an expert witness for Powder River Basin Resource Council regarding coal
plant closures re PacifiCorp 2019 Integrated Resource Plan,Wyoming Public Service
Commission Docket No. 90000-147-XI-19.
• The Law Office of Ralph Lamar,Arvada, CO 2019
Deposed as an expert witness for plaintiffs regarding lost profits of a Farmers insurance
agency
• Jester, Gibson&Moore,Denver, CO 2019
Retained as an expert witness for plaintiffs regarding lost earnings in an ADEA wrongful
termination matter.
• Albrechta&Coble, Ltd. Fremont, OH 2O19
Retained as an expert witness for plaintiff regarding lost earnings in a race related
wrongful termination matter.
• Conrad Law,PC, Salt Lake City,UT 2019
Retained as an expert witness for Ellis-Hall Consultants,LLC. regarding economic
damages in Ellis-Hall Consultants,LLC. et. al.v. George B. Hofmann IV,United States
District Court,District of Utah,Central Division.
• Davison Van Cleve,PC,Portland,OR 2019
Retained as an expert witness for Alliance of Western Energy Consumers regarding net
variable power cost calculations in PORTLAND GENERAL ELECTRIC COMPANY,
2020 Annual Power Cost Update Tariff Public Utility Commission of Oregon Docket No.
UE 359.
• Sanger Law,PC,Portland, OR,2019
Testified as an expert witness for Renewable Energy Coalition and Rocky Mountain
Coalition for Renewable Energy regarding Qualified Facility avoided costs in
Application of Rocky Mountain Power for a Modification of Avoided Cost Methodology
and Reduced Term of PURPA Power Purchase Agreements Public Service Commission
of Wyoming Docket No. 20000-545-ET-18
• Sanger Law,PC,Portland, OR,2019
Retained as an expert witness for Cafeto Coffee Company regarding the necessity,design,
and location of transmission lines in SPRINGFIELD UTILITY BOARD Petition for
Certificate of Public Convenience and Necessity Public Utility Commission of Oregon
Docket No. PCN 3.
• Baumgartner Law,LLC,Denver, CO,2018
Retained as an expert witness for plaintiffs re calculation of economic harm due to injury
in re Eric Bowman,v. Top Tier Colorado, LLC,, Case No. 18CV31359,United States
District Court,District of Colorado.
• Cohen Milstein Sellers&Toll PLLC,Washington DC,2018
Aegis Insight 16

Retained as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in re Isaac Harris et al.v. Medical Transportation Management, Inc., Civil
Action No. 17-1371,United States District Court,District of Columbia.
• Davison Van Cleve,PC,Portland,OR 2020
Retained as an expert witness for Alliance of Western Energy Consumers regarding
depreciation rates in re PacifiCom Application for Authority, t�plement Revised
Depreciation Rates,Public Utility Commission of Oregon Docket No. UM 1968.
• Davison Van Cleve,PC, Salem, OR and Washington Attorney General, OR 2020
Retained as an expert witness for Packaging Company of America and Washington
Public Council regarding depreciation rates in re Pacific Power 2018 Depreciation Study,
Washington Utility and Transportation Commission,Docket No. UE-180778.
• Hagens Berman Sobol Shapiro LLP,Phoenix,Arizona, 2018
Deposed as an expert witness for plaintiffs re calculation of economic harm due to breach
of contract in re Vicky Maldonado and Carter v.Apple Inc.,AppleCare Services
Company; Inc.; and Apple CSC. Inc., Case No. 3:16-cv-04067-WHO,United States
District Court,District of California.
• Hagens Berman Sobol Shapiro,LLP,Phoenix,Arizona,2018
Deposed and testified as an expert witness for plaintiffs re calculation of unpaid mileage
for truck drivers in re Swift Transportation Co., Inc., Civil Action No. CV2004-001777,
Superior Court of the State of Arizona, County of Maricopa.
• Killmer,Lane, and Newman,LLP,Denver, Colorado, 2018
Retained as expert witness for plaintiffs re reasonable attorney fees in re Jeanne Stroup
and Ruben Lee;v. United Airlines, Inc., Case No. 15-cv-01389-WYD-STV,United States
District Court,District of Colorado.
• Klein and Frank,PC,Denver, Colorado,2018
Retained as expert witness for plaintiffs re potential jury bias in re Gail Goehrig and
Chris Goehrig v. Core Mountain Enterprises;LLC,Case No. 2016CV030004, San Juan
County District Court.
• Robert Belluso,Pennsylvania,2017
Retained as expert witness for plaintiff re lost profit in re Robert Belluso D.O.v Trustees
of Charleroi Community Park,PHRC Case No. 201505365,Pennsylvania Human
Relations Commission.
• Lowery Parady,LLC,Denver, Colorado,2017
Analyzed payroll data and calculated unpaid overtime and unpaid hours for plaintiff class
action in re Violeta Solis, et al. v. The Circle Group;LLC, et al., Case No.
1:16-cv-01329-RBJ,United States District Court,District of Colorado.
• Sawaya&Miller Law Firm,Denver, Colorado,2017
Provided data processing and analysis of employment records.
• Financial Scholars Group, Orinda, California,2017
Provided analysis of risk profile in bundled real estate and personal loans in re Old
Republic Insurance Company v. Countrywide Bank et al., Circuit Court of Cook County,
Illinois, Chancery Division.
• Financial Scholars Group, Orinda, California,2017
Aegis Insight 17

Provided consultation and analysis of financial market transactions in preparation of
settlement claims filings in re Laydon v. Mizuho Bank,Ltd., et al. and Sonterra Capital
Master Fund Ltd.; et al v. UBS AG et al.
• Clean Energy Action,Boulder, Colorado,2016—2017
Provided consultation on the appropriate discounting methodology used in energy
resource planning in the Public Service Company of Colorado application for approval of
the 2016 Electric Resource Plan,Proceeding No. 16A-0396E,Public Utilities
Commission of the State of Colorado.
• Confidential Client, 2016
Provided analysis and report on the probability that distinct crimes are independent
events based on geographical analysis of crime rates.
• Christine Lamb and Kevin James Burns,Denver, Colorado,2016
Provided data analysis for defendant of the impact of ethnicity on termination decisions
in re Aragon et al v. Home Depot USA, Inc., Case No. 1:15-cv- 00466-MCA-KK,United
States District Court,District of New Mexico.
• Steptoe&Johnson LLP,Washington,DC,2015—2016
Programmed analysis of internet traffic data for plaintiffs applying a proprietary
probability model developed to identify and verify accounts responsible for repeated
infringements of asserted copyrights by defendants' internet subscribers in re BMG
Rights Management(US)LLC,and Round Hill Music LP v. Cox Enterprises,Inc., et al.,
Case No. 1:14-cv-1611(LOG/JFA),United States District Court Eastern District of
Virginia,Alexandria Division.
• Padilla&Padilla,PLLC,Denver, Colorado,2014—2016
Provided research and analysis for plaintiffs re the impact on minority applicants from
use of the AccuPlacer Test by the City and County of Denver, and estimated damages in
re Marian G. Kerner et al. v. City and County of Denver, Civil Action No.
11-cv-00256-MSK-KMT,United States District Court,District of Colorado.
• U.S. Equal Employment Opportunity Commission,2013
Provided statistical analysis of EEOC filings.
OTHER REGULATORY PROCEEDINGS:
• Portland General Electric 2018 AUT UE 335
• Portland General Electric 2016 Annual Power Cost Variance Docket No. UE 329.
• PacifiCorp 2016 Power Cost Adjustment Mechanism Docket No.UE 327.
• Public Utility Commission of Oregon Staff Investigation into the Treatment of New Facility
Direct Access Charges Docket No.UM 1837
• PacifiCorp Oregon Specific Cost Allocation Investigation Docket No.UM 1824.
• PacifiCorp 2018 Transition Adjustment Mechanism Docket No. UE 323.
• Portland General Electric 2018 General Rate Case Docket No.UE 319.
• Avista Corp. 2017 General Rate Case Docket No. UG 325.
• Portland General Electric Affiliated Interest Agreement with Portland General Gas Supply
Docket No.UI 376.
• Portland General Electric 2017 Automated Update Tariff Docket No.UE 308
• PacifiCorp 2017 Transition Adjustment Mechanism Docket No. UE 307
Aegis Insight 18

• Portland General Electric 2017 Reauthorization of Decoupling Adjustment Docket No. UE
306
• Northwest Natural Gas Investigation of WARM Program Docket No.UM 1750.
• PacifiCorp Investigation into Multi-Jurisdictional Allocation Issues Docket No. UM 1050.
• Idaho Power Company 2015 Power Supply Expense True Up Docket No.UE 305
• Homer Electric Association 2015 Depreciation Study U-15-094
• Submitted prefiled testimony regarding the depreciation study.
• Chugach Electric Association 2015 Rate Case U-15-081
• Developed staff position regarding margin calculations.
• ENSTAR 2014 Rate Case U-14-111
• Submitted prefiled testimony regarding sales forecast.
• Alaska Pacific Environmental Services 2014 Rate Case U-14-114/115/116/117/118
Submitted prefiled testimony regarding cost allocations, cost of service,cost of capital,
affiliated interests,and depreciation.
• Alaska Waste 2014 Rate Case U-14-104/105/106/107
Submitted prefiled testimony regarding cost of service study, cost of capital,operating
ratio, and affiliated interest real estate contracts.
• Fairbanks Natural Gas 2014 Rate Case U-14-102
Submitted prefiled testimony regarding cost of service study and forecasting models.
• Avista 2015 Rate Case U-14-104
Submitted analysis supporting OPUC Staff settlement positions regarding Avista's sales
and load forecast, decoupling mechanisms and interstate cost allocation methodology.
Represented Staff in settlement conferences on November 21,November 26,and
December 4,2013.
• Portland General Electric 2015 Rate Case
Submitted pre-filed opening testimony addressing PGE's sales forecast,printing and
mailing budget forecast,mailing budget,marginal cost study, line extension policy and
reactive demand charge. Represented OPUC Staff in settlement conferences on May 20,
May 27, and June 12,2014.
• Portland General Electric 2014 General Rate Case
Submitted analysis supporting OPUC Staff settlement positions regarding PGE's sales
and load forecast,revenue decoupling mechanism, and cost of service study. Represented
OPUC Staff in settlement conferences on May 29,June 3,June 6,July 2, and July 9 of
2013. Submitted testimony in support of partial stipulation,pre-filed opening testimony
addressing PGE's decoupling mechanism, and testimony in support of a second partial
stipulation.
• PacifiCorp 2014 General Electric Rate Case
Submitted analysis supporting OPUC Staff settlement positions regarding PacifiCorp's
sales and load forecast and cost of service study. Represented Staff in settlement
conferences on June 12 through June 14,2013.
Aegis Insight 19