Stephanie's FERC Testimony Summary.doc

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION

ARIZONA PUBLIC SERVICE COMPANY

v.

IDAHO POWER COMPANY

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DOCKET NO. EL9944003

SUMMARY OF THE DIRECT TESTIMONY OF
STEPHANIE MILLER
ON BEHALF OF
THE IDAHO PUBLIC UTILITIES COMMISSION

Stephanie Miller testifies that the Idaho Power Company native-load customers supported the construction of additional capacity in the Idaho Power transmission system designed to remedy certain foreseeable adverse events through payment of rates – in other words – to produce reliability for the native-load customer if those events occurred. She testifies that CBM and TRM reflect those reliability reserves. Moreover, she testifies that the Western Systems Coordinating Council, as well as the regional transmission associations, to which both Idaho Power and Arizona Public Service belong, have determined that transmission providers need to remove these reserves from their calculation of ATC in order to accommodate those reasonably foreseeable uncertainties in system conditions and to provide flexibility for secure system operations. Ms. Miller testifies that reserves retained for reliability in the system should inure to the benefit of the native-load customers because they have supported the investment necessary to construct that capacity designed to protect them when those events occur.
Ms. Miller also testifies that APS mischaracterized the FMC contract with Idaho Power as non-firm. She testifies that contract is not “non-firm” as that term is described in the FERC Order No. 888.