20221007ICL to IPC 5-23.pdf

Marie Callaway Kellner (ISB No. 8470)
710 N. 6s Street
PO Box 844
Boise,ID 83701
Telephone: [phone]
mkellner@idahoconservation. org
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Iiiililt PTIBLIC
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Attorney for the Idaho Conservation League
Intervenor
October 7,2022
YIA ELECTRONIC FILING
JanNoriyuki
Idaho Public Utilities Commission
11331 W. Chinden Blvd, Bldg. 8
suite 201-A (83714)
PO Box 83720
Boise, D 83720-0074
RE CaseNo. PC-E-22-22
In the Matter of Idaho Power Company's Application to Complete the Study
Review Phase of the Comprehensive Study of Costs and Benefits of On-Site
Generation & For Authority to Implement Qhanges to Schedules 6, 8, and 84 for
Non-Legacy Systems
Dear Secretary Noriyuki,
Attached for electronic filing is the Idaho Conservation League's Response to the Second
Production Request of Idaho Power Company in the above-referenced matter.
Please respond with any questions or concenr about the above referenced matter or the
attached response and accompanymg documents.
Regards,
s/ Marie Callaway Kellner
Marie Callaway Kellner
ISB No. 8470
Ipano PueI.rc Urrtrres CorrarratssloN, Case No. IPC-E-22-22
Idaho Conservation League, Response to Company's First Production Request
Marie Callaway Kellner (ISB No. 8470)
710 N 66 Street
PO Box 844
Boise,ID 83701
Telephone: Q08) 537 -7993
mkellner@idahoconservation. org
Attorney for the Idaho Conservation League
lntervenor
IN THE MATTER OF IDAHO )
POWER COMPAI\IY'S )
APPLICATION TO COMPLETE )
THE STTIDY REVTEW PHASE OF )
THE COMPREHENSTVE STUDY )
OF COSTS AI\ID BENEFITS OF ON. )
srTE GENERATTON & FOR )
AUTHORITY TO IMPLEMENT )
CIIAI\IGES TO SCIIEDIJLES 6,8, )
AND 84 )
BEFORE THE IDAHO PUBLIC UTILITIES COM1VIISSION
CASE NO. IPC.E-22-22
IDAHO CONSERVATION LEAGTIE
RESPONSE TO THE SECOND
PRODUCTOTN REQUEST OF
IDAIIO POWER COMPAI\IY TO
THE IDAHO CONSERVATION
LEAUGE
Submission to the Commission
The Idaho Conservation League submits to the Idaho Public Utilities Commission responses to
the Second Production Request of Idaho Power Company to The Idaho Conservation League, dated
September 22,2022. Supporting infonnation and attachments are referenced in responses. The following
responses and attachments are submitted:
ICL Response to Second IPC Data Request; Response to RFPs 5 through 23
Patrick McGuire CV
Tom Beach CV
IoeHo Puel.rc Uru,rrIss Couurssror.r, Case No. IPC-E-22-22
Idaho Conservation League, Response to Company's First Production Request
ldaho Conservation League (!CL) Responses to ldaho Power Company (lPC)
Second Production Request to ICL
October 6,2022
REQUEST FOR PRODUCTION NO. 5: Page 2 of the Crossborder Energy Review
("Review") of ldaho Power's Value of Distributed Energy Resources ('VODER') Study
states that, "avoided energy costs should reflect more timely and accurate data than the
IRP forecast or the three-year rolling averages used by lPC. For example, they could be
based on EIM prices from the prior 12 months, adjusted based on natural gas forward
market prices for the next year." Please respond to the following questions:
a) How should a historical market price be adjusted utilizing a natural gas forward
market price?
b) How would a real market price that is adjusted based on a natural gas forward
market be a better adjustment than using the actual market price?
Response
a) The discussion that IPC cites emphasizes the importance of timely and accurate
assessments of avoided energy costs. A recent historica! price could be used -
such as the most recent historical year, which is likely to be more accurate than a
stale price based on a longer period of historical data from which the underlying
gas market prices have changed significantly. Alternatively, as suggested in the
report, a forecast price could be used that adjusts recent historical electric prices
from the prior year based on a ratio of natural gas forward market prices for the
upcoming year divided by the recent historical gas market prices for the same
year as the historical electric market prices. This is similar to calculating market
heat rates for the recent historical year, then multiplying those market heat rates
by a forecast of gas market prices for the upcoming year using gas forward
market prices.
ln our Review, we observe that that the $47.3 per MWh historical price we
determined based on EIM prices in August 2021 to July 2022 is significantly
higher than the $28.24 per MWh average 2019-2021 EIM price IPC cites. We
clarify, however, that our review did not make use of any adjustments based on
gas forwards, except to suggest the idea conceptually.
As an example of how a historical price could be adjusted using a forward price,
assume we are at the end of 2021, and that the historical average EIM and
Henry Hub market prices were28.24 $/MWh and $2.84 per MMBtu, respectively;
Also, for the sake of this example, assume that the Henry Hub futures market
price at that time for the period August 2021 to July 2022 was the actual $5.60
per MMBtu that materialized during that period (i.e. let's assume the forward
market price at that time was perfectly accurate). Then, the adjustment would be
to compute a forecast electric market price equal to ($28.24 per MWh) x ($5.61
per MMBIU I $2.84 per MWh) = $55.80 per MWh, which is much closer to the
actual EIM price for this period of $47.3 per MWh.
b) A forecast market price would be better than an historica! market price, to the
extent that prices during the forecast period are what is of interest. Using a stiale
historical market price, which fails to reflect significant natural gas market price
changes that are expected to occur through a forecast period of time, is clearly
worse than an estimate based on adjusting the historical market prices for
expected changes in future gas market prices - either up or down.
Actual market prices are clearly best for analysis of the historica! period in which
they existed. However, that does not mean historical prices are best for analysis
of future periods, particularly when there are expectations for different natural
gas market conditions in the future period than in the historical period. This is
exacfly the case in the VODER study, where 2019-2021 prices do not reflect the
significant cost increases that have occurred in 2022 and that are likely to persist,
based upon recent forward market expectations.
REQUEST FOR PRODUCTION NO. 6: Page 3 of the Review states that the "low ELCC
is surprising, given that the 2021 IRP shows that the ELCC of IPC's existing solar
resources are over 60%, and the new Jackpot solar project that lPC is adding in late
2022 or 2023 has an ELCC of 34o/o. Yes, utility scale solar facilities that use tracking
arrays will have somewhat higher ELCCs than fixed rooftop arays, and the ELCC of
solar generally will decline as more solar is added to a utility's resource mix, but the
difference between a 34o/o ELCC for new utility scale solar and 7.60/o for new rooftop
solar is excessive."
a) Please explain why it is reasonable to compare the ELCCs of a utility-scale solar
facility with tracking capabilities that exports all energy generated for all production
hours to the grid to behind-the-meter customer generation that exports only the excess
energy which is typically lower during the hours of highest risk for the utility?
Resoonse
We have examined IPC's profiles for exports from behind the meter (BTM) solar, and
they do not differ materially frcm the hourly profile of the full output expected from fixed
solar arrays. This indicates that the distribution of exported energy across the day is
similar to a typical PV production profile, and we would not expect a major difference
between the ELCC based on exports alone and the ELCC for the entire output of a solar
facility, normalized to the different amounts of exports vs. full output.
Regarding trackers vs. fixed anay solar, we understand that trackers have higher
output. For example, whereas PVWATTS shows 1,710 kwh/kw for a fixed (roof mount)
system in Boise, a tracker produces about 19% more energy (i.e. 2,031 kwh/kw),
according to NREL's PMffATTS tool.
Nevertheless a 19% increase in output should not translate to a 4.5x increase in the
ELCC value (i.e. 34.0% vs. 7.6%). Such an increase in ELCC value is not comparable
to the increase in energy output or energy value for a tracker versus a fixed anay.
REQUEST FOR PRODUCTION NO. 7: Page 3 of the Review states that ldaho Powe/s
"approach makes the mistake of ignoring that only about one-half of the distributed solar
capacity is used to produce exports; the other half serves the customers' loads behind
the meter. The amount of real-time exportsin 2020-2021, as a percentiage of total
output, indicates that about 52o/o of the solar capacity is used for exports. Thus IPC's
capacity contributions need to be increased by a factor of 1 divided by 0.52."
a) Please explain why the capacity contributions should be increased by a factor of 1
over 52o/o?
Response
IPC's solar export profile indicates that 52o/o of solar is exported, as explained in our
response to Request for Production No. 8. Thus, to calculate the capacity contribution
of the full nameplate capacity of the array, we divide IPC's solar capacity contributions
by 0.52 to recognize the value of all solar production, rather than just exported energy:
7.620/o I 52o/o -- 14.7o/o. Then, to be consistent, we divide the capacity contribution for a!!
solar by the tota! production of solar in annual kWh per kW-AC, to yield the avoided
generation capacity cost in $ per MWh of solar output.
Altematively, if we had used the 7 .620/o as the capacity contribution of exports alone, we
would have divided the solar capacity contribution in dollars by just the export volumes,
which would have been 52% times 1,710 kwh/kw. Mathematically, both produce the
same result.
REQUEST FOR PRODUCTION NO. 8: Page 3 of the Review states that the "amount of
real-time exports in 2021-2021, as a percentage of total output, indicates that about
52o/o of the solar capacity is used for exports.'
a) Please provide allworkpapers used to determine the 52% used in the Review.
Resoonse
See the row 8781 of the "PV\ /ATTS" tab, in the "lPC T&D Avoided Cost and PCAFs
(CONFIDENTIAL)' worksheet. Data in Appendix 4.9 of the VODER study shows the
following rea! time export quantities, including losses. Based upon 1,710 kwh/kw
assumed PVWATTS output for Boise, the solar capacity in 2020 and 2021 imply 52o/o
exports:
2020 2021 Averaqe
RT Export MWh 40.138 62,578
Nameplate MW 53 62
Exoorts (kwh/kw)757 1.009
As % of 1,710 kWh 44o/o 59o/o 52o/o
REQUEST FOR PRODUCTION NO.9: Page 3 of the Review states that "[iJnstead of
using ELCCS, we prefer the use of the peak capacity allocation factor (PCAF) method."
a) Please provide allworkpapers associated with the PCAF method used in the Review.
Response
a) Please refer to the attachments provided in response to Request for Production No.
1. The PCAF values used in our review are indicated in the following worksheets:
o IPC T&D Avoided Cost and PCAFs.xlsbo Distribution PCAF using ICL Request No 12.xlsb
The29.4o/o transmission PCAF, and the 27.0o/o generation capacity PCAF values are
shown in the first workpaper referenced. See cell F18 and l(20 of the 'Summary' tab
The 33.4% distribution PCAF is provided in the second workpaper referenced above.
REQUEST FOR PRODUCTION NO. 10: Page 3 of the Review states that the
'ELCC of solar generally wil! decline as more solar is added to a utility's resource mix."
a) Please explain how the PCAF is able to capture the declining contribution of solar as
penetration increases.
Resoonse
The PCAF calculation captures the average PV capacity factor in hours within 1Oo/o of
the maximum hourly load for the year. As more behind the meter (BTM) solar is added
to the resource mix, the profile of peak loads will change. For example, peaks that
occur during solar production hours would decrease, as more load during those hours is
served from BTM solar. This would lead to different hours reflected in the top 10%
hours for utility-served load.
ln addition, once solar penetration becomes significant in ldaho (e.9. similar to stiates
like Arizona or Califomia), it would make sense to determine PCAFs on the basis of net
load (i.e. hourly load less hourly utility-scale, in-front-of-the-meter solar and wind
supply). As the net loads shift to later in the day with increasing amounts of utility-scale
solar, this would enable the PCAF method to capture the declining contribution of solar
as penetration increases.
At current levels of solar on the IPC system, we do not yet see a need to turn to net load
PCAF calculations.
REQUEST FOR PRODUCTION NO. 11: Page 4 of the Review states that the
"PCAF method calculates the capacity contribution of solar exports across all hours that
have loads within 10o/o of the system peak hour. This method weights the solar output in
these high-load hours by how close the system load in that hour is to the annual peak
hour load. The hour with the annual peak load is weighted the most."
a) Please explain why the hour with the annual peak load should be weighted the most.
Response
We assume the value of incremental capacity is near zero unless there is a need for
capacity. The need for capacity materializes as load approaches the leve! of existing
system capacity. System supply capacity can be viewed as a constraint on the total
amount of demand that can be served. As demand approaches its annual maximum,
there may be capacity-related costs associated with serving additional demand. Thus,
a PCAF distribution, which focuses on the timing of the top load hours, and which
assigns the greatest weight to the peak load hour, provides a statistical distribution that
identifies the hours in which capacity constraints are most likely to exist.
Mathematically, PCAFs are a set of hourly allocation factors for the hours with Ioads
that are above a certain threshold (e.9. 90% of the annual peak hourly !oad), with each
hour with a load above this threshold load weighted by the amount by which the load in
that hour exceeds the threshold. Thus, for example, the PCAFs for the loads at the
system, substation, or circuit level can be determined using the following formula:
PCAFs(h):
where:
PCAFs(h) - peak capacity allocation factor for the system, substation, or circuit s in hour
h,
Loads(h) = the load for the system, substation, or circuit s in hour h, and
Thresholds = 90% of the annual peak load for the system, substation, or circuit s.
Al! hours where the load is below the threshold of 90% of the annual peak hourly load
are assumed to have a PCAF ol zero.
REQUEST FOR PRODUCTION NO. {2: Page 4 of the Review stiates that Crossborder
"derived hourly PCAFs for IPC using system load data from 2016-2020. Using this
PCAF method, the capacity contribution of real-time solar exports is 28.6% in 2020 and
25.3o/o in 2021, for an average of 27.lYo."
a) Please explain what solar data was used for the2016-2020 PCAF analysis.
b) lf a generic solar generation shape was used, please explain how the relationship
between system load, weather and production is considered in the analysis.
c) Please provide allworkpapers associated with the calculations, including the hourly
results for the PCAF 2016-2020 analysis.
d) Please explain the rationale for using 2016-2020 data and omitting the provided 2021
datra based on peak load reduction attributable to energy efficiency and/or demand
response.
Response
a) As shown in the'lPC T&D Avoided Cost and PCAFs" worksheet, the solar data used
is from PMffatts for Boise, ldaho.
b) Use of a generic, typical meteorologica! year (TMY) profile does not capture actual
weather conelations, for example such as when PV generation may have a positive
corelation with system load, to the extent high loads occur on sunny days.
Nonetheless, our analysis based on actual 2016-2020loads and generic simulated
solar data provides a @nservative estimate of capacity contribution. To the extent
actual PV generation would increase vs. simulated PV generation on an actual peak
day, we would expect the solar capacity contribution would increase. We relied on a
generic profile to the extent actual PV profiles were not available.
c) Please refer to the worksheets identified in response to Request for Production No.
9. The results of the 2016-2020 PCAF calculations are shown on the "Summary" tab
of the "lPC T&D Avoided Cost and PCAFs (CONFIDENTIAL)" worksheet.
d) Our PCAF calculations make use of the available 2020 and 2021 solar export
profiles that were provided in Appendix 4.9 of the VODER Study, and public FERC
Form 714load datra for 2016-2020.
REQUEST FOR PRODUCTION NO. 15: Page 5 of the Review stiates that'[c]ollectively,
these resour@s can have a much larger impact to reduce IPC's need for T&D upgrades
over time - by being a much larger amount of capacity, by concentrating load
reductions in certain Iocations, and by moving the utility to a much lower long-term
demand trajectory."
a) Please explain how concentrating load reduction by location creates a lower demand
trajectory.
Resoonse
a) Capacity increases and investments may be needed when system capacity
becomes constrained in a certain location. The IPC system is unlikely to be
equally constrained in all locations, and DERs are unlikely to be developed
equally across IPC's service territory. To the extent DERs arise in particular
locations where system constraints might otherwise exist, the aggregate value of
the DERs in that location may be able to defer or avoid investments needed to
expand system capacity. Looking at a single type of DER in a single location,
however, is unlikely to revealthe value of multiple DERs concentrated in a
particular location (e.9. Boise).
When many DER projects, with different DER technologies, are aggregated, the
net Ioad to be served by IPC is reduced. Thus, more DER projects concentrated
in a given location will result in lower trajectories of demands in that location than
with only a single DER project in that location.
Finally, DERs such as BTM solar have useful lives of 25 years or more. The
aggregate development of all types of load-reducing or load-shifting DERs, with
that growth continuing into the future, will place the utility on a significantly lower
long-term trajectory of demand growth over the next 25 years than if the DERs
did not exist.
REQUEST FOR PRODUCTION NO. 16: Asset replacement projects include replacing
equipment at the end of its useful life, replacement of obsolete or unsupported
equipment, and relocating equipment such as due to alignment changes (road
widening). Page 5 of the Review states that "replacement projects are demand-related
in that they are necessary to keep the grid's capacity from declining."
a) PIease explain how asset replacement projects can be defened through customer
generation exported energy. Please be specific to ldaho Power's system and its
growing customer base, including how customer generation could defer projects such
as replacing an aged customer distribution transformer, replacing out of date
communications equipment, and replacing damaged pole plant.
Response
Replacement costs are part of the average cost of capacity. !f the demand for capacity
can be reduced, then the replacement costs associated with that decrement in demand
can be avoided. We recognize that certain 'setup'costs, such as pole replacement,
cannot be avoided if a line is to remain functional. However, in the long-run it is
possible that entire transmission lines may be avoided with increased DERs, at which
point a broader set of costs may be avoided (e.9. transformers, communications, and
poles). Finally, in performing a linear regression, our analysis of avoided T&D costs
assigns costs that do not vary with peak load growth - such as end-of-life replacement
projects that do not impact system capacity, or moving infrastructure for road widening -
as a "fixed" cost, and only associates the costs that do vary with load grov'rth or system
capacity with the margina! cost of the grid.
REQUEST FOR PRODUCTION NO. {7: !n Table 2 Crossborder Recommendation for
IPC's T&D Deferral Cosfs shows different "Solar Capacity Contribution" for
Transmission and Distribution.
a) Please explain why these values are different and provide associated supporting
data.
Response
a) Our analysis of distribution PCAFs relies upon distribution substation loads, as
provided by IPC in response to ICL Request No. 12. Our analysis of transmission
PCAFs relies upon system peak loads, as reported in FERC Form 714. As noted in
IPC's response to ICL Request for Production No. 6, 'FERC Form 714 covers all
generation assigned to the ldaho Power balancing authority area and actual
interchange with other balancing authority areas to determine the net energy for load in
the ldaho Power balancing authority area.'Thus, the reason for using different load
data sources in each analysis is to accurately capture hourly distribution system and
hourly transmission system loads. We note that the PCAF results for each analysis are
similar (e.9. 29.4o/o and 33.4o/o differ by only 4.0o/o), which one would expect given that
the IPC system load at the transmission level is the aggregate of the utility's demand
across its distribution systems.
REQUEST FOR PRODUCTION NO. 18: Page 4 of the Review states that the'PCAF
method calculates the capacity contribution of solar exports across all hours that have
loads within 10o/o of the system peak hour."
a) Please verifu if this indicates that the T&D Defenal Costs should apply to exports only
during those hours with loads within 1Oo/o ol system peak.
b) lf not, please explain the reason for applying those T&D Deferral Costs to other hours
of energy export.
Response
a) No. lt is possible that the PCAF analyses could be used to identify the top 10%
load hours in which T&D defenalvalue is concentrated and only provide T&D
deferral value in those hours. This would require a complicated hourly ECR
export compensation structure However, it is much simpler, and easier for the
customer to understand, to use the expected, or average, defenal costs in the
ECR across either all hours or across the TOU period hours when the defenal is
expected to occur. Thus, the T&D defenal compensation included in an ECR
should conespond to the ECR time periods, e.g. either a flat rate or a TOU
period rate. We also note that, for the purpose of estimating the avoided costs of
all customer solar, T&D defenal value should not be limited to exports, because
all of a customer's solar generation replaces utility supply.
b) See response to subpart a. An unavoidable feature of a flat or TOU ECR is that
the various costs it includes are all reflected as flat (or TOU) average values.
Unless an hourly ECR is used, it is not possible to send distinct hourly prices. ln
addition, too much granularity in prices risks mismatches between forecast
conditions assumed in the hourly ECR rate, and actua! conditions on the ground.
For example, an early September heat wave could produce very hlgh hourly
loads that might not be anticipated by PCAF analysis based on historical load
data that does not feature the same early September heat wave.
REQUEST FOR PRODUCTION NO. 19: Page 7 of the Review states that the "marginal
losses associated with behind-the-meter solar resources are higher than system
average losses because much of the solar output occurs in the aftemoon hours when
loads and losses are higher."
a) Please provide data to support the statement that much of the solar output occurs
when loads and losses are higher.
Response
a) As a point of clarification, see response to Request for Production 1d, which
shows that the primary reason marginal losses are higher than average Iosses, in
any hour, is that losses are based upon the square of load. Thus, an increase in
load results in an increase in losses that is proportionate to the square of the load
increment. This non-linear increase in losses is the primary reason that marginal
losses are always higher than average losses.
ln addition, the overall level of line losses will be highest when line loadings are
highest. IPC's FERC Form 714 data, e.g. for 2020, shows that IPC loads are
higher in the daytime than at night. The following figure compares hourly
average Form 714 loads in 2O2O and hourly average solar capacity factors for a
Boise, ldaho PVWATTS profile, demonstrating the conelation between solar
output and load. We note that IPC load was about 2,100 MW when solar PV
peaks during daytime hours, as opposed to nighftime hours where load is as low
as 1,700 MW.
IPC Form 7t4 Loadin 2O2O
vs. PVWatts Hourly Profile
2,3OO
2,20O
2,1(n
2,000
1,900
1,800
1,,7O0
1,500
1,500
oEoIT
iP
C'oel!L'L!olin
==Ea!oJ(Jg
0.70
0.50
0.s0
0.40
0.30
0.20
0.10
l2 3 4 5 6 7 8 910t112131415t61718192021222324
Hour
REQUEST FOR PRODUCTION NO. 20: Page 8 of the Review stiates that "[itn the
absence of an up-todate study of marginal line losses, it is reasonable to double IPC's
system average resistive line losses trom2012, to 11 .60/0."
a) Please provide any doanmentation or data that supports the idea that doubling the
losses is reasonable.
Resoonse
a) See response to Reguest for Production 1d. The referenced RAP study explains why
doubling average losses is a reasonable way to estimate maryinal losses.
REQUEST FOR PRODUCTION NO. 21: Page 8 of the Review states that the'scenario
whose resource mix most closely resembles the subsequenl2A2l !RP's preferred plan
is Case 9 - the High Solar with 200 MW Storage case." However, the base case in the
integration study already includes 131 MW of solar contracts plus 120 MW from Jackpot
solar.
a) Please explain how a scenario that includes 794 MW of new solar, for a total of 1,045
MW closely resembles the IRP where only 420 MW of solar were in the prefered
portfolio in the next 5 years.
Response
a) Case 9 of the 11 cases in the E3 VER study has the resource mix additions that
most closelv resemble the 2021 IRP preferred plan:
ft includes 200 MW of storage in 2029, similar to the 2021 IRP addition of 255 MW of
storage in 2029. The other VER cases, except for Case 10, include no new storage.
ft includes 794 MW of solar added in 2023, as do all the other VER study cases,
except Cases 1, 4, and 5, which show zero solar added. Following the addition of
120 MW from Jackpot solar in 2023, the 2021 IRP shows significant solar additions
from 2025 to 2029 (i.e. +985 MW, or about +200 MW per year).
We also note that, to the extent 794 MW of new solar is greater than 42O MW of
solar in the prefened portfolio in the next 5 years, integration costs are likely to be
larger than if the CER study had assumed only 420 MW. Thus, in our judgement
Case 9 in the E3 VER study does not underestimate integration costs.
REQUEST FOR PRODUCTION NO. 22: Please explain the fuel hedging value that
exists under each of the following avoided energy inputs for an Export Credit Rate
("ECR"):
a) lntegrated Resource Plan - ldaho Power Price
b) ICE Mid-C lndex Price
c) Energy lmbalance Market Load Aggregation Point ("ELAP') Price
Response
a-c) A fuel hedging value exists for any supply source whose cost that is not linked
directly to volatile natural gas prices. Thus, for each of the electricity market-based
export credit rates listed above, which 4 dependent on natural gas market prices,
there is little or no fuel hedge value. Electricity market prices are directly impacted by
natural gas market prices. Rather, it is the behind the meter solar generation serving
the custome/s Ioad that provides a hedge against the gas-cost sensitive utility supply
costs that otherwise would have to be incuned by lPC. To be conservative, and to
recognize that IPC proposed export credit rates willfluctuate with natural gas prices, we
removed exports from the fuel hedge value.
REQUEST FOR PRODUCTION NO. 23: For each of the co-authors of the Crossborder
Energy Review ("Review"), R. Thomas Beach and Patrick G. McGuire, please provide
the following to the extent not included with ICL's initial comments:
a) A cuniculum vitae and/or resume;
b) A list of any and all cases or matters in which he has offered testimony, live or
prepared, within the preceding four (4) years and include on whose behalf the testimony
was provided;
c) A list of all publications authored in the previous ten (10) years;
d) A statement of the compensation to be paid for the Review and any testimony
provided in this matter; and
e) A copy of all materials provided by ICL or another Party to this case in relation to the
Review.
Response
a) Please see the following attiachments:
. Tom Beach CV - 2020.pdt. Patrick McGuire CV - 2019.pdf
b) A list of cases in which we've offered testimony is included in the CV attachments
provided in response to subpart a. Additional cases through 2022ho-date include:
R. Thomas Beach
Public Utility Commission of Texas. August 26,2022 Testimony on behalf of EVgo
Services LLC in Docket No. 53601.
Calffornia Public Utilities Commission. August 8,2022 Testimony on behalf of Calpine
Corporation in A. 21-09-018.
Massachusetts Department of Public Utilities. May 27,2022 Testimony on behalf of
EVgo, lnc., in D.P.U. 21-90, D.P.U. 21-91TRACK 2
Soufh Carolina Public Serwbe Commission. May 18,2022 Testimony on behalf of the
South Carolina Coastal Conservation League and Southern Alliance for Clean Energy,
in Docket No.2022-1-E
Soufh Carolina Public Service Commission. March 15,2022 Testimony on behalf of the
South Carolina Coastal Conservation League and Southem Alliance for Clean Energy,
in Docket No.2022-2-E
California Public Utilities Commission January 14,2022 Testimony on behalf of the
Solar Energy lndustries Association in A. 21-09-001
Arkansas Public Service Commission November 22,2021 Testimony on behalf of the
City of Batesville, in Docket No. 21-099-U
California Public Utilities Commission September 27,2021 Testimony on behalf of the
Solar Energy Industries Association, in R. 14-10-003.
California Public Utilities Commission. June 18,2021 Testimony on behalf of the Solar
Energy lndustries Association, in R. 20-08-020.
Arkansas Public Service Commission. March 31,2021 Testimony on behalf of the City
of Hot Springs, in Docket No. 21-042-U
Public Seryice Commission of South Carolina. January 22,2021 Testimony on behalf
of the South Carolina Coastal Conservation League, Southem Alliance for Clean
Energy, Upstate Forever, Vote Solar, Solar Energy lndustries Association, and North
Carolina Sustainable Energy, in Docket 2020-229-E.
CaliforniaPublicUtilitiesCommission. November20,2020Testimonyon behalf of the
Solar Energy lndustries Association in A. 19-11-019
Arizona Corporation Commission. October 9,2020 Testimony on behalf of EVgo
Services LLC in Docket E-01345A-19-0236
Public Seruice Commission of South Carolina. October 8,2020 Testimony on behalf of
South Carolina Coastal Conservation League, Southem Alliance for Clean Energy, Vote
Solar, Solar Energy lndustries Association, and the North Carolina Sustrainable Energy
Association, in Docket No. 2019-182-E
New Jersey Board of Public Utilities. September 4,2020 Testimony on behalf of EVgo
Services LLC, in BPU Docket No. EO18101111
California Public Utilities Commission. July 26,2020 Testimony on behalf of the Solar
Energy lndustries Association in A. 20-10-012
Arkansas Public Service Commission. July 2,2020 Testimony on behalf of Producers
Rice Mill, lnc. in Docket No. 20-016-U.
Montana Public Service Commission May 7 ,2020 Testimony on behalf of Vote Solar
and Montana Environmental lnformation Center, in Docket D2019.09.059.
California Public Utilities Commission April 6,2020 Testimony on behalf of SEIA in
Application 1 9-03-002.
Calffornia Public Utilities Commission. March 17, 2020 Testimony on behalf of the Solar
Energy lndustries Association in A. 19-03-002
Patrick G. McGuire
Calffornia Public Utilities Commission. May 31,2019 Testimony in Application 17-12-
012, on behalf of Solar Energy lndustries Association.
c) Publications and regional studies not in testimony listed above include:
Joseph Weidman & Tom Beach, Distributed Generation Policy: Encouraging
Generation on Both Sides of the Meter, 26 ELECTRICIW J. 88, 89 (2013).
https://www.sciencedirect.com/science/article/abs/oii/S1040619013001905
R. Thomas Beach & Patrick G. McGuire. "Evaluating the Benefits and Costs
of Net Metering in California" prepared for the Vote Solar lnitiative, January
2013.
https://www.qrowsolar.orq/wp-contenUuoloadsi20l2/06/Crossborder-Enerqv-
CA- N et- M ete ri n q - Co st- B e n efi t- J a n -2 0 1 3-fi n a I . o df
a
a
R. Thomas Beach & Patrick G. McGuire. "The Benefits and Costs of Solar
Generation for Electric Ratepayers in North Carolina," OctoberlS, 2013.
https ://ene rqvn c.orq/wp-
contenUuploads/201 7/03/Benefits Costs Solar Generation-
for Electric Ratepavers NC.pdf
R. Thomas Beach & Patrick G. McGuire. "The Benefits and Costs of Net
Metering Solar Distributed Generation in V[oming," June '13,2022.
https://www.powderriverbasin.orq/wp-contenUuploads/2022l05/Benefits-and-
Costs-of-Net-Meterinq-Solar-DG-in-Wvom i no-J une-2022-web.pdf
d) ln our July 29,2022 response to the lCUSierra Club RFP, we estimated a
$32,500 cost for this work.
e) ICL or another party to this case did not provide materials in relation to the
Review. We obtained IPC's VODER study and attachments directly from IPC
a
Plrnrcr G. McGurns
Enerry PolicyAdvisor Page 1
Mr. McGuire is energy policy advisor with the consulting firrn Crossborder Energy.
Crossborder Energy provides analytical consulting services and strategic advice on market and
regulatory issues conceming the natural gas and electric industries. The firm is based in
Berkeley, California, and its practice focuses on the energy markets in California and the U.S.
Mr. McGuire has worked for Crossborder Energy since 1992, and has participated in the most of
the firm's analytic work. From 1989 through l992he was employed by Sierra Energy and Risk
Assessment, an energy consulting firm in Roseville, California with a focus on electric utility
production cost modelin g.
Anpls oF EXPERTISE
Mathematics, Economics, and Computer Programming. Applies economic ft*ry,
mathematics, and computerprogramming and modeling skills to the firm's study of
regulatory and public policy issues in the natural gas and electic industries.
Responsible for drafting much of the technical analyses used in the firm's work products.
Detailed knowledge of relevant computer applications used for consulting studies.
Electrtcity Markets. Modeling and statistical review of electricity markets, with
particular emphasis on California and other deregulated electricity markets. Has
monitored of California Independent System Operator electricity markets since
deregulation commenced inApril, 1998. Studies have included the impact of cap-and-
trade regulation of greenhouse gas emissions on the California electricity market.
Natural Gas Markets. Monitoring and modeling of natural gas markets in the U.S.
Developed a model of the NorthAmerican regional natural gas transportation grid, using
a network equilibrium methodology. Provides clients with summary and analysis of
regulatory developments in the Califomia and western U.S. natural gas market.
Rate Design and Cost Allocation. Work has included analysis and forecasts of the
impacts of changes in policies and regulations on retail rates for electricif and natural
gas. Has worked with cost allocation and rate design models used to develop natural gas
and electricity rates, including natural gas transmission and distribution rates. Has
extensive experience with PG&E, SoCal Edison, SoCalGas, and SDG&E electicity and
natural rates. Has developed and updated the cost allocation and rate design for a small
municipal electric utility in Califomia.
Renewables. Analysis of Renewable Portfolio Standard (RPS) programs, including the
impacts of such progftlrns on retail rates. Developed models of revenue requirement
impacts of the proposed RPS programs in Florida, New York, and Nevada. Has tracked
the historical and forecasted development of the RPS program in California.
Net Metering and Photovoltaic Incentives. Has modeled the Renewable Energy Credit
(REC) ince,ntive payments for solar photovoltaic installations, including analysis of state
incentive programs for Florida and New York. Has conducted cost/benefit studies,
Parmcr G. McGurnr
Energy PolicyAdvisor Pase2
including detailed computer modeling, of the net metering program for residential and
commercial solar installations in California. Co-authored stateJevel studies ofNet
Energy Metering or distributed solar generation costs and benefits, in several states
including California, Colorado, New Hampshire, North Carolina, andArizona.
Gas-fired Generation Costs. Has modeled traditional gas-fired generation costs using
the Market Price Referent (MPR) approach used in California as the cost benchmark for
the RPS program. Has worked extensively on Combined Heat and Power (CI{P) issues
in Califomia.
Contract Analysis. Performed contract analyses for independent power producers, to
address contract restrucfuring and economic evaluation issues. Served as an expert
witness in an arbitation case for a Nevada Geothermal project.
Testimony
Oregon Public Utilities Commission October 15, 2015 Testimony in Docket UM 1734
onbehalf of Sierra Club.
Yermont Public Service Board. Septernber 23,2014 Testimony in Docket No 8010 on
behalf ofAllco Renewable Energy Limited.
California Public Utilities Commission March 19,2003 Testimony in Rulemaking02-
01-01 1 regarding Direct Access.
Papers
A Self-Scoring Systern to Elicit True Cost Multi-Dimensional Bids in an Electric Power
Auction, C. B. McGuire and Patrick G. McGuire. Proceedings of the 15s Annual North
American Conference of the International Association for Energy Economics, October
1993, pp. 304-314.
Epucrrrox
Mr. McGuire holds a B.A. in mathematics from the University of California at Santa Cruz.
Exppmpxcr
Crossborder Energt
Energy Policy Advisor 1992 - Present
Responsible for general ana$ic support for a broad range of policy and rate design issues in the
natural gas and electric industries. Conducted regular reviews of avoided cost energy pricing for
cogeneration clients. Assisted in power purchase contract implementation and renegotiation.
Monthly market monitoring of the deregulated California electricity and natural gas markets.
Review of CAISO, CPUC and FERC policy developments affecting the California market.
Plrnrcx G. McGurnr
Energy PolicyAdvisor Paee 3
Application of general analytical policy analysis tools to electricity and gas market issues.
Developed computer model of the deregulated California electricity market and a linear
programming model of theNorthAmericanpipeline gnd. Developed models of various state-
level renewable programs and related solar customer incentives, including net metering.
Sierra Energ,t & RiskAssessment
Associate Mathematic ian, L989 -1992
Responsible for maintaining databases and VO related to electric production cost simulation
models. Developed numerous computer models related to the electric industry, including
electricity transmission and losses, load profile analysis, DSM program evaluation, and merger
cost/benefit analysis.
R. Tnou.ls BnAcs
Principal Consultant Page 1
Mr. Beach is principal consultant with the consulting finn Crossborder Energy. Crossborder
Energy provides economic consulting services and strategic advice on market and regulatory
issues conceming the natural gas and electric industries. The firm is based in Berkeley,
California, and its practice focuses on the energy markets in California, the U.S., and Canada.
Since 1989, IvIr. Beach has had an active consulting practice on policy, economic, and
ratemaking issues concerning renewable energy development, the restructuring of the gas and
electric industries, the addition of new natural gas pipeline and storage capacity, and a wide
range ofissues concerning independent power generation. From 1981 through 1989 he served
at the California Public Utilities Commission, including five years as an advisor to three CPUC
commissioners. While at the CPUC, he was a key advisor on the CPUC's restructuring of the
natural gas industry in California, and worked extensively on the state's implementation of the
Public Utilities Regulatory PoliciesAct of 1978.
Anr^l,s oF ExPERTTSE
Renewable Energt Issues: extensive experience assisting clients with issues concerning
Renewable Portfolio Standard programs, including program structure and rate impacts.
He has also worked for the solar industy on rate design and net energy metering issues,
on the creation of the Califonria Solar Initiative, as well as on a wide range of solar issues
in many other states.
Restructuring the Natural Gas and Electric Industries; consulting and expert testimony
on numerous issues involving the restructuring of the electric industy, including the 2000
- 2001 Western energy crisis.
Energt Markets: studies and consultation on the dynamics of natural gas and electric
markets, including the impacts of new pipeline capacity on natural gas prices and of
electric restructuring on wholesale electric prices.
Quaffiing Facility Issues.' consulting with QF clients on a broad range of issues
involving independent power facilities in the Western U.S. He is one of the leading
experts in California on the calculation of avoided cost prices. Other QF issues on
which he has worked include complex QF contact restucturings, standby rates,
greenhouse gas emission regulations, and natural gas rates for cogenerators.
Crossborder Energy's QF clients include the full range of QF technologies, both fossil-
fueled and renewable.
Pricing Policy in Regulated Industries: consulting and expert testimony on natural gas
pipeline rates and on marginal cost-based rates for natural gas and electric utilities.
Crossborder Energt
R. Tnopr,ls Bnacu
Principal Consultant Page 2
Eouclrrox
Mr. Beach holds a B.A. in English and physics from Darfrnouth College, and an M.E. in
mechanical engineering from the University of Califomia at Berkeley.
Acnoprvrrc llouons
Graduated from Darfinouth with high honors in physics and honors in English.
Chewon Fellowship, U.C. Berkeley, 197 8-79
PnorBssroNAL AccREDrrATroN
Registered professional engineer in the state of California.
Expnnr Wrrxnss Tnsrruoxy BEFoRE THE CALTToRNTA PuBLrc Urrr,rrrrs Courrrssrox
Prepared Direct Testimony on Behalf of Pacific Gas & Electric Company/Pacific Gas
Tfansmission (I. 88-12-027 - July 15, 1989)
. Competitive and environmental benefits of new natural gas pipeline capacity to
Califurnia.
1
2. a.Prepared Direct Testimony on Behalf of the Canadian Producer Group (A. 89-
08-024 -November 10, 1989)
Prepared Rebuttal Testimony on Behalf of the Canadian Producer Group (A.
89-08-024 - November 30, 1989)
Natural gas procurement policy; gas costforecasting.
Prepared Direct Testimony on Behalf of the Canadian Producer Group (R. 88-08-018
- December 7,1989)
o Brokering of interstate pipeline capacity.
Prepared DirectTestimony on Behalf of the Canadian Producer Group (A. 90-08-029
-November l, 1990)
o Natural gas procurement poliqt; gas costforecasting; brokeragefees.
Prepared DirectTestimony on Behalf of the Alberta Petroleum Marketing Commission
and the Canadian Producer Group 0. 86-06-005 - December 21,1990)
o Firm and interruptible ratesfor noncore natural gas users
b.
o
3
4.
5
Crossborder Energt
R. Tno*r.Ls Brlcu
Principal Consultant Page 3
6. a.Prepared Direct Testimony on Behalf of the Alberta Petroleum Marketing
Commission (R. 88-08-018 - January 25,1991)
Prepared Responsive Testimony on Behalf of the Alberta Petroleum Marketing
Commission (R. 88-08-018 - March 29,1991)
Brokering of interstate pipeline capacity; intrastate transportation policies.
Prepared Direct Testimony on Behalf of the Canadian Producer Group (A. 90-08-
DZ9lPhase II - April 17, l99l)
o Natural gas brokerage and transportfees.
Prepared Direct Testimony on Behalf of LUZ Partnership Management (A. 9l-01-027
-July 15, l99l)
o Natural gas parity ratesfor cogenerators and solar thermal power plants.
Prepared Joint Testimony of R. Thomas Beach and Dr. Robert B. Weisenmiller on Behalf
of the California Cogeneration Council (1. 89-07-004 - July 15, l99l)
o Avoided cost pricing; use ofpublished natural gas prtce indices to set avoided
cost prices for qualifying faiiltdes.
a. Prepared Direct Testimony on Behalf of the Indicated Expansion Shippers (A.
89-04-033 - October 28,1991)b. Prepared Rebuttal Testimony on Behalf of the Indicated Expansion Shippers (A.
89-04-0033 - November 26,1991)
o Natural gas pipeline rate design; cost/benefit analysis of rolled-in rates.
Prepared Direct Testimony on Behalf of the Independent Petroleum Association of
Canada (A. 9l-04-003 - January 17,1992)
o Natural gas procurement policy; prudence ofpast gas purchases.
a. Prepared Direct Testimony on Behalf of the California Cogeneration Council
(I.86-06-005/Phase II - June 18,1992)b. Prepared Rebuttal Testimony on Behalf of the California Cogeneration Council
(I. 86-06-005/Phase II - July 2,1992)
. Long-Run Marginal Cost (LRMC) rate designfor natural gas utilities.
Prepared Direct Testimony on Behalf of the California Cogeneration Council (A.92-
10-017 - February 19, 1993)
Performance-based ratemaking for electric utilities
b
o
7
8.
9
10.
11.
t2
13
a
Crossborder Energt
R. Tnou.Ls BnAcu
Principal Consultant Page 4
14.
o
15 a.
16.
t7.
18.
19.
20.
2t.
Prepared Direct Testimony on Behalf of the SEGS Projects (C. 93-02-014/A. 93-03-053
- May 21,1993)
Natural gas transportation s ervice for wholes ale customers.
Prepared Direct Testimony on Behalf of the Canadian Association of Petroleum
Producers (A.92-12-0431A.93-03-038 - June 28, 1993)
Prepared Rebuttal Testimony of Behalf of the Canadian Association of
Petroleum Producers (A. 92-12-0431A.93-03-038 - July 8, 1993)
Natural gas pipeline rate design issues.
b.
Prepared Direct Testimony on Behalf of the SEGS Projects (C. 93-05-023 -November 10, 1993)
Prepared Rebuttal Testimony on Behalf of the SEGS Projects (C. 93-05-023 -January 10,1994)
. Utility overcharges for natural gas service; cogeneration parity issues.
Prepared Direct Testimony on Behalf of the City of Vernon (A. 93-09-006/A. 93-08-
0221 A. 93-09-048 - June 17, 1994)
o Natural gas rate designfor wholesale customers; retail competition issues.
Prepared Direct Testimony of R. Thomas Beach on Behalf of the SEGS Projects (A.94-
0l-021 -August 5,1994)
o Natural gas rate design issues; rate parityfor solar thermal power plants.
Prepared Direct Testimony on Transition Cost Issues on Behalf of Watson Cogeneration
Company (R. 94-04-03 | ll. 94-04-032 - December 5, 1994)
. PolicT issues concerning the calculation, allocation, and recovery of transition
costs associated with electric industry restructuring.
Prepared Direct Testimony on Nuclear Cost Recovery Issues on Behalf of the California
Cogeneration Council (A. 93-12-025t1.94-02-002 - February 14, 1995)
o Recovery of above-market nuclear plant costs under electric restructuring.
Prepared Direct Testimony on Behalf of the Sacramento Municipal Utitity District (A.
94-ll-015 -June 16, 1995)
o Natural gas rate design; unbundled mainline transportation rates.
a
a.
b.
Crossborder Energt
R. Tnouas BrAcs
Principal Consultant
22.
23. a.
Page 5
Prepared Direct Testimony on Behalf of Watson Cogeneration Company (A. 95-05-049
- September ll, 1995)
c Incremental Energt Rates; air quality compliance costs.
b.
Prepared Direct Testimony on Behalf of the Canadian Association of Petroleum
Producers (A. 92-12-0431A. 93-03-038/A. 94-05-0351A. 94-06-03 4/A. 94-09-
056/A. 94-06-044 - January 30,1996)
Prepared Rebuttal Testimony on Behalf of the Canadian Association of
Petroleum Producers (4. 92 -12 -0 43 I A. 93 -03-03 8/A. 94-05 -03 5/A . 9 4 -06-
034/ A. 94-09-0561 A. 94-06-044 - February 28, 1996)
Natural gas market dynamics; gas pipeline rate design.
Prepared Direct Testimony on Behalf of the Electricity Generation Coalition
(A.97-03-002- December 18, 1997)
Prepared Rebuttal Testimony on Behalf of the Electricity Generation Coalition
(A. 97-03-002 - January 9, 1998)
Natural gas rate designfor gas-fired electric generators.
24 Prepared Direct Testimony on Behalf of the California Cogeneration Council and
Watson Cogeneration Company (A. 96-03-031 - July 12, 1996)
o Natural gas rate design: parity ratesfor cogenerators.
25 Prepared Direct Testimony on Behalf of the City of Vernon (A. 96-10-038 -August 6,
re97)
a Impacts of a major utility merger on competition in natural gas and electric
markets.
a
26. a.
a
27
a
b.
Prepared Direct Testimony on Behalf of the City of Vernon (A. 97-03-015 - January
16, 1998)
Natural gas service to Baja, Califurnia, Mexico.
Crossborder Energt
R. Tnouras Br.tcn
Principal Consultant Page 6
28. a.
b.
c.
a
29. a.
b.
c.
d.
e.
o
30. a.
b.
a
31. a.
b.
a
Prepared Direct Testimony on Behalf of the California Cogeneration Council
and Watson Cogeneration Company (A. 98-10-012lA. 98-10-031/A. 98-07-005
- March 4,1999).
Prepared Direct Testimony on Behalf of the California Cogeneration Council
(A. 98-10-0l2lA. 98-01-031/A. 98-07-005 - March 15, 1999).
Prepared Direct Testimony on Behalf of the California Cogeneration Council
(A. 98- I 0-0 l2l{. 98-01-03 I /A. 98-07-005 - June 25, 1999).
Natural gas cost allocation and rate designfor gas-fired electric generators.
Prepared Direct Testimony on Behalf of the California Cogeneration Council
and Watson Cogeneration Company (R. 99-ll-022 - February I l, 2000).
Prepared Rebuttal Testimony on Behalf of the California Cogeneration Council
and Watson Cogeneration Company (R. 99-ll-022 - March 6, 2000).
Prepared Direct Testimony on Line Loss Issues of behalf of the California
Cogeneration Council (R. 99-l l-022 - April 28, 2000).
Supplemental Direct Testimony in Response to ALJ Cooke's Request on behalf
of the California Cogeneration Council and Watson Cogeneration Company
(R. 99-l l-022 - April 28, 2000).
Prepared Rebuttal Testimony on Line Loss Issues on behalf of the California
Cogeneration Council (R. 99-l l-022 - May 8, 2000).
Market-based, avoided cost pricingfor the electric output of gas-fired
cogenerationfacilities in the Caffirnia market; electric line losses.
Direct Testimony on behalf of the Indicated Electric Generators in Support of
the Comprehensive Gas OII Settlement Agreement for Southern California Gas
Company and San Diego Gas & Electric Company (I. 99-07-003 - May 5,
2000).
Rebuttal Testimony in Support of the Comprehensive Settlement Agreement on
behalf of the Indicated Electric Generators (I. 99-07-003 - May 19, 2000).
Testimony in support of a comprehensive restructuring of natural gas rates and
services on the Southern California Gas Company system. Natural gas cost
allocation and rate designfor gas-fired electric generators.
Prepared Direct Testimony on the Cogeneration Gas Allowance on behalf of the
California Cogeneration Council (A. 00-04-002 - September l, 2000).
Prepared Direct Testimony on behalf of Southern Energy California (A. 00-04-
002 - September l, 2000).
Natural gas cost allocation and rate designfor gas-fired electric generators.
Crossborder Energt
R. Tnotvr.q.s Bnlcn
Principal Consultant Pase 7
32. a.
33.
34. a.
35.
36.
a
37. a.
b
Prepared Direct Testimony on behalf of Watson Cogeneration Company (A.
00-06-032 - September 18,2000).
Prepared Rebuttal Testimony on behalf of Watson Cogeneration Company (A.
00-06-032 - October 6, 2000).
Rate designfor a natural gas "peaking service."
Prepared Direct Testimony on behalf of PG&E National Energ;r Group &
Calpine Corporation (I. 00- I l -002-April 25, 200 1 ).
Prepared Rebuttal Testimony on behalf of PG&E National Energy Group &
Calpine Corporation (I. 00-l l-002-May 15,2001).
Terms and conditions of natural gas service to electric generators; gas
curtailment policies.
Prepared Direct Testimony on behalf of the California Cogeneration Council
(R. 99-l l-022-Nlay 7,2001).
Prepared Rebuttal Testimony on behalf of the California Cogeneration Council
(R. 99-l l-022-May 30,2001).
Avoided cost pricingfor alternative energt producers in Califurnia.
Prepared Direct Testimony of R. Thomas Beach in Support of the Application of
Wild Goose Storage Inc. (A.01-06-029-June 18,2001).
Prepared Rebuttal Testimony of R. Thomas Beach onbehalf of Wild Goose
Storage (A. 0 I -06-029-Novemb er 2, 2001)
Consumer benefitsfrom expanded natural gas storage capacity in California.
Prepared Direct Testimony on behalf of the County of San Bernardino (I. 0l-06-047-
December 14,2001)
Reasonableness review of a natural gas utility's procurement practices and
storage operations.
Pre,pared Direct Testimony on behalf of the California Cogeneration Council
(R. 0 l - I 0-024-May 31, 2002)
Prepared Supplemental Testimony on behalf of the California Cogeneration
Council (R. 0 I - I 0-024-May 31, 2002)
Electric procurement policiesfor California's electric utilities in the aftermath of
the Califurnia energt crisis.
a
a.
b.
a
b
a
a.
b.
a
b.
a
Crossborder Energt
R. Tnourns Bracn
Principal Consultant Page 8
38
39
Prepared Direct Testimony on behalf of the California Manufacturers & Technology
Association (R. 02-01 -01 l-June 6, 2002)
o "Exitfees" for direct access customers in Califtrnia.
Prepared Direct Testimony on behalf of the County of San Bernardino (A.02-02-012
- August 5,2002)
o General rate case issues for a natural gas utility; reasonableness review of a
natural gas uttlity's procurement practices.
Prepared Direct Testimony on behalf of the California Manufacturers and Technology
Association (A. 98-07-003 - February 7,2003)
Recovery of past utility procurement costsfrom direct access customers.
Prepared Direct Testimony on behalf of the California Cogeneration Council,
the California Manufacturers & Technolory Association, Calpine
Corporation, and Mirant Americas, Inc. (A 01-10-01I - February 28,2003)
Prepared Rebuttal Testimony on behalf of the California Cogeneration Council,
the California Manufacturers & Technolory Association, Calpine
Corporation, and Mirant Americas, Inc. (A 01-10-01I - March 24,2003)
40.
O
41. a.
42. a.
43
a
b.
a
b.
Rate design issues for Pacific Gas & Electric's gas transmission system (Gas
Accord II).
Prepared Direct Testimony on behalf of the California Manufacturers &
Technolory Association; Calpine Corporation; Duke Enerry North America;
Mirant Americas, Inc.; Watson Cogeneration Company; and West Coast
Powerr lnc. (R. 02-06-041-March 21,2003)
Prepared Rebuttal Testimony on behalf of the California Manufacturers &
Technologgr Association; Calpine Corporation; Duke Enerry North America;
Mirant Americas, Inc.; Watson Cogeneration Company; and West Coast
Power, Inc. (R. 02-06-041 - April 4, 2003)
o Cost allocation of above-market interstate pipeline costsfor the Califurnia
natural gas utilities.
Prepared Direct Testimony of R. Thomas Beach and Nancy Rader on behalf of the
California Wind Energy Association (R. 0l-10-024 - April l, 2003)
Design and implementation of a Renewable Porfolio Standard in Califurnia.
Crossborder Energt
R. Tnopr^ls Brlcu
Principal Consultant Page 9
44. a. Prepared Direct Testimony on behalf of the California Cogeneration Council
(R. 0l-10-024 - June 23, 2003)b. Prepared Supplemental Testimony on behalf of the California Cogeneration
Council (R. 0l-10-024 - June 29, 2003)
o Power procurement policiesfor electric utilities in Califurnia.
45. Prepared Direct Testimony on behalf of the Indicated Commercial Parties (02-05-004
- August 29,2003)
o Electric revenue allocation and rate designfor commercial anstomers in southern
Califurnia.
46. a. Prepared Direct Testimony on behalf of Calpine Corporation and the
California Cogeneration Council (A.04-03-021- July 16, 2004)b. Prepared Rebuttal Testimony on behalf of Calpine Corporation and the
California Cogeneration Council (A. 04-03-021 - July 26, 2004)
. Polic! and rate design issuesfor Pacific Gas & Electric's gas tronsmission
system (Gas Accord III).
47. Prepared Direct Testimony onbehalf of the California Cogeneration Council (A. 04-
04-003 - August 6,2004)
. Policl and contract issues concerning cogeneration QFs in California.
48. a. Prepared Direct Testimony on behalf of the California Cogeneration Council
and the California Manufacturers and Technolory Association (A.04-07-044
-January 11,2005)b. Prepared Rebuttal Testimony on behalf of the California Cogeneration Council
and the California Manufacturers and Technologr Association (A.04-07-044
-January 28,2005)
o Natural gas cost allocation and rate designfor large transportation customers in
northern Califtrnia.
49. a. Prepared Direct Testimony on behalf of the California Manufacturers and
Technology {ssociation and the Indicated Commercial Parties (A.04-06-024
- March 7,2b05)b. Prepared Rebuttal Testimony on behalf of the California Manufacturers and
Technolory Association and the Indicated Commercial Parties (A.04-06-024
-April26,2005)
o Electric marginal costs, revenue allocation, and rate designfor commercial and
industrial electric customers in northern Califurnia.
Crossborder Energt
R Tnou.Ls Br^c.cu
Principal Consultant Page 10
50.
51.
a
52. a.
53
54. a.
55
56.
Prepared Direct Testimony on behalf of the California Solar Energy Industries
Association (R. 04-03-017 - April 28,2005)
o Cost-effectiveness of the Million Solar Roofs Program.
Prepared Direct Testimony on behalf of Watson Cogeneration Company, the
Indicated Producers, and the California Manufacfuring and Technolory Association
(A. 04-12-004 - July 29,2005)
Natural gas rate design policy; integration of gas utility systems.
Prepared Direct Testimony on behalf of the California Cogeneration Council
(R. 04-04-003/R. 04-04-025 - August 31,2005)
Prepared Rebuttal Testimony on behalf of the California Cogeneration Council
(R. 04-04-003/R. 04-04-025 - October 28, 2005)
b.
o Avoided cost rates and contracting policies for QFs in Califurnia
a. Prepared Direct Testimony on behalf of the California Manufacturers and
Technology Association and the Indicated Commercial Parties (A. 05-05-023
- January 20,2006)b. Prepared Rebuttal Testimony onbehalf of the California Manufacturers and
Technology Association and the Indicated Commercial Parties (A. 05-05-023
- February 24,2006)
Electric rnarginal costs, revenue allocation, and rate designfor commercial and
industrial electric customers in southern California.
a
b.
Prepared Direct Testimony on behalf of the California Producers
018 - January 30, 2006)
Prepared Rebuttal Testimony on behalf of the California Producers
08-018 - February 21,2006)
( R.04-08-
( R. 04-
. Transportation and balancing issues concerning California gas production.
Prepared Direct Testimony on behalf of the California Manufacturers and Technology
Association and the Indicated Commercial Parties (A. 06-03-005 - October 27,
2006)
a Electric marginal costs, revenue allocation, and rate designfor commercial and
industrial electric customers in northern California.
Prepared Direct Testimony on behalf of the California Cogeneration Council (A. 05-
12-030 - March 29,2006)
o Review and approval of a new contract with a gas-fi.red cogmeration project.
Crossborder Energlt
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Principal Consultant
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59
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b.
Pase 11
a. Prepared Direct Testimony on behalf of Watson Cogeneration, Indicated
Producers, the California Cogeneration Council, and the California
Manufacturers and Technology Association (A. 04-12-004 - July 14, 2006)b. Prepared Rebuttal Testimony on behalf of Watson Cogeneration, Indicated
Producers, the California Cogeneration Council, and the California
Manufacturers and Technology Association (A.04-12-004 - July 31, 2006)
o Restntcturing of the natural gas system in southern Califurnia to includefi,rm
capacity rights; unbundling of natural gas sertices; risHreward issuesfor natural
gas utilities.
Prepared Direct Testimony on behalf of the California Cogeneration Council (R. 06-
02-013 - March 2,2007)
Utility procurement policies concerning gas-fired cogeneration facilities
Prepared Direct Testimony on behalf of the Solar Alliance (A. 07-01-047 -August 10,2007)
Prepared Rebuttal Testimony on behalf of the Solar Alliance (A. 07-01-047 -September 24,2007)
Electric rate design issues that irnpact customers installing solar photovoltaic
systems.
Prepared Direct Testimony on Behalf of Gas Transmission Northwest
Corporation (A. 07 -12-021 - May I 5, 2008)
Prepared Rebuttal Testimony on Behalf of Gas Transmission Northwest
Corporation (A. 07-12-021 -June 13, 2008)
Utility subscription to new natural gas pipeline capacity serving Califurnia.
Prepared Direct Testimony on behalf of the Solar Alliance (A. 08-03-015 -September 12,2008)
Prepared Rebuttal Testimony on behalf of the Solar Alliance (A. 08-03-015 -October 3,2008)
Issues concerning the design of a utility-sponsored program to install 500 MW of
utility- and independently-owned solar photovoltaic systems.
a
60. a.
61. a.
b.
o
b.
o
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Principal Consultant Paee 12
62.Prepared Direct Testimony on behalf of the Solar Alliance (A. 08-03-002 - October 31,
2008)
Electric rate design issues that impact customers installing solar photovoltaic
systems.
Phase II Direct Testimony on behalf of Indicated Producers, the California
Cogeneration Council, California Manufacturers and Technology
Association, and Watson Cogeneration Company (A. 08-02-001 - December
23,2008)
Ph.ase II Rebuttal Testimony on behalf of Indicated Producers, the California
Cogeneration Council, California Manufacturers and Technology
Association, and Watson Cogeneration Company (A. 08-02-001 -January27,2009)
Natural gas cost allocation and rate design issues for large anstomers.
a
63. a.
64.
65
66.
Prepared Direct T
(A. 09-0s-026 -
b.
a
a.estimony on behalf of the California Cogeneration Council
November 4,2009)
Natural gas cost allocation and rate destgn issues for large customers.
Prepared Direct Testimony on behalf of Indicated Producers and Watson
Cogeneration Company (A. 10-03-028 - October 5, 2010)
Prepared Rebuttal Testimony on behalf of Indicated Producers and Watson
Cogeneration Company (A. 10-03-028 - October 26,2010)
o Revisions to a program offirm backbone capacity rights on natural gas pipelines.
Prepared Direct Testimony on behalf of the Solar Alliance (A. 10-03-014 - October 6,
2010)
a Electrtc rate design issues that impact customers installing solar photovoltaic
systems.
Prepared Rebuttal Testimony on behalf of the Indicated Settling Parties (A. 09-09-013
- October 11,2010)
o Testirnony on proposed modifications to a broad-based settlement of rate-related
issues on the Pactfic Gas & Electrtc natural gas pipeline system.
o
a.
b.
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Principal Consultant Page 13
68. a.
b.
c.
a
69
a
70.
a
71.
a
72. a.
o
73.
a
74.
a
Supplemental Prepared Direct Testimony on behalf of Sacramento Natural Gas
Storage, LLC (A. 07-04-013 - December 6, 2010)
Supplemental Prepared Rebuttal Testimony on behalf of Sacramento Natural
Gas Storage, LLC (A. 07-04-013 - December 13, 2010)
Supplemental Prepared Reply Testimony on behalf of Sacramento Natural Gas
Storage, LLC (A. 07-04-013 -December20,2010)
Local reliability benefits of a new natural gas storagefacility.
Prepared Direct Testimony on behalf of The Vote Solar Initiative (A. l0-11-015-June
l, 201 l)
Distributed generation policies ; utility distribution planning.
Prepared Reply Testimony on behalf of the Solar Alliance (A. l0-03-014-August 5,
20Lt)
Electric rate designfor commercial & industrial solar customers.
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
I I -06-007-February 6, 2012)
Electrtc rate designfor solar customers; marginal costs
b.
Prepared Direct Testimony on behalf of the Northern California Indicated
Producers (R. I l -02-01 9-January 31, 2012)
Prepared Rebuttal Testimony on behalf of the Northern California Indicated
Producers (R. 1 l -02-019-February 28, 2012)
Natural gas pipeline safety policies and costs
Prepared Direct Testimony on behalf of the Solar Enerry Industries Association (A.
I I - 1 0-002-June 12, 2012)
Electric rate designfor solar customers; marginal costs
Prepared Direct Testimony on behalf of the Southern California Indicated Producers
and Watson Cogeneration Company (A. I l-l l-002-June 19, 2012)
Natural gas pipeline safety policies and costs
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Principal Consultant Page 14
75. a.
76. a.
77
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78.
79
a
b.
a
Testimony on behalf of the California Cogeneration Council (R. 12-03-014-
June 25, 2012)
Reply Testimony on behalf of the California Cogeneration Council (R. 12-03-
01,1-July 23,2012)
Ability of combined heat and power resources to serve local reliability needs in
southern California.
Prepared Testimony on behalf of the Southern California Indicated Producers
and Watson Cogeneration Company (A. I l-l l-002, Phase 2-November 16,
20t2)
Prepared Rebuttal Testimony on behalf of the Southern California Indicated
Producers and Watson Cogeneration Company (A. I l-l l-002, Phase 2-
December 14,2012)
c Allocation and recovery of natural gas pipeline safety costs.
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
l2-12-002-May 10, 20 I 3)
Electric rate designfor commercial & industrial solar customers; marginal costs.
b.
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
I 3-04-0 I 2-December 13, 2013)
a Electric rate designfor commercial & industrial solar customers; marginal costs.
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
I 3-l 2-01 s-June 30, 2014)
Electric rate designfor commercial & industrial solar customers; residential
time-of-use rate design issues.
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R. Tnouas Bplcu
Principal Consultant Page 15
80. a.
8l
82.
b.
Prepared Direct Testimony on behalf of Calpine Corporation and the Indicated
Shippers (A. l3-12-012-August I l,2014)
Prepared Direct Testimony on behalf of Calpine Corporation, the Canadian
Association of Petroleum Producers, Gas Transmission Northwest, and the
City of Palo Alto (A. l3-12-012-Augustll,20l4)
Prepared Rebuttal Testimony onbehalf of Calpine Corporation (A. 13-12-012-
September 15,2014)
Prepared Rebuttal Testimony on behalf of Calpine Corporation, the Canadian
Association of Petroleum Producers, Gas Transmission Northwesf and the
City of Palo AIto (A. l3-12-012-September 15, 2014)
o Rate design, cost allocation, and revenue requirement issues for the gas
transmission system of a major natural gas utility.
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (R.
I 2-06-0 I 3-September 15, 201 4)
. Comprehensive review of policiesfor rate designfor residential electric
cus tomers in Califurnia.
Prepared Direct Testimony on behalf of the Solar Enerry Industries Association (A.
l4-06-014-March 13, 201 5)
Electrtc rate designfor commercial & industrial solar custotners; marginal costs.
a. Prepared Direct Testimony on behalf of the Solar Energy Industries Association
(A. l4-l 1-01,1--May l, 201 5)b. Prepared Rebuttal Testimony on behalf of the Solar Energy Industries
Association (A. l4-l 1 -014-May 26, 2015)
o Time-of-use periods for residential TOU rates.
Prepared Rebuttal Testimony on behalf of the Joint Solar Parties (R. 14-07-002 -September 30,2015)
Electric rate design issues concerning proposalsfor the net energl metering
success or tariff in Calift rnia.
c.
d.
83
84.
85.
a
a
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
I 5-04-012-luly 5, 2016)
Selection of Time-of-Use periods, and rate design issuesfor solar customers.
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Principal Consultant Page 16
86.
87
88.
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93.
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
16-09-003 - April 28,2017)
Selection of Time-of-Use periods, and rate design issues for solar customers
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
l7-06-030 - March 23,2018)
Selection of Time-of-Use periods, and rate design issues for solar customers
a
a
a
Prepared Direct and Rebuttal Testimony on behalf of Calpine Corporation (A. 17-11-
009 - July 20 and August 20,2018)
Gas transportation rates for electric generators, gas storage and balancing issues
89 Prepared Direct Testimony on behalf of Gas Transmission Northwest LLC and the
City of Palo AIto (A. l7-l l-009 - July 20, 2018)
c Rate designfor intrastate backbone gas transportation rates
Prepared Direct Testimony on behalf of EVgo (A. l8-l l-003 - April 5, 2019)
o Electric rate designfor commercial electric vehicle charging
Prepared Direct and Rebuttal Testimony on behalf of Vote Solar and the Solar Energy
Industries Association (R. 14-10-003 - October 7 and2l,2019)
o Avoided cost issuesfor distributed energl resources
Prepared Direct and Rebuttal Testimony on behalf of EVgo (A. l9-07-006 - January l3
and February 20,2020)
o Electric rate designfor commercial electric vehicle charging
Prepared Direct Testimony on behalf of the Solar Energy Industries Association (A.
19-03-002 - March 17,2020)
c Electric rate design issues for solar and storage customers
90
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Principal Consultant Page 17
I
Expnnr Wrrxnss Tosrruoxv BBronB rnp Anrzoxl Conpourrox CourrrssroN
Prepared Direct, Rebuttal, and Supplemental Testimony on behalf of The Alliance for
Solar Choice (TASC), (Docket No. E-00000J-14-0023, February 27, Apil7, and June
22,20t6).
o Development of a benefit-cost methodologtfor distrtbuted, net metered solar
resources in Arizona.
2 Prepared Sunebuttal and Responsive Testimony on behalf of the Energy Freedom
Coalition of America (DocketNo. E-01933A-15-0239 - March 10 and September 15,
2016).
a Critique of a utility-owned solar program; comments on aftxed rate credit to
replace net energt metering.
a
3. Direct Testimony on behalf of the Solar Enerry Industries Association (Docket No. E-
01 345A-1 6-0036, February 3, 2017).
4. Direct and Surrebuttal Testimony on behalf of The Alliance for Solar Choice and the
Energy Freedom Coalition of America (DocketNos. E-01933A-15-0239 (TEP), E-
01933A-15-0322 (TEP), and E-04204A-15-0142 (UNSE) - May 17 and September 29,
2017).
Exrnnr Wrrxnss Trsrruoxv Bpronp rHE CoLoRADo PuBLrc Urrlrups Corrurssrox
1 Direct Testimony and Exhibits on behalf of the Colorado Solar Energy Industries
Association and the Solar Alliance, (DocketNo. 09AL-299E- October 2,2009).
https://www.dora.state.co.us/pls/efilDDMS_Public.Displav_Document?p_section:PUC&
p_source:EFI_PRIVATE&p_doc_id:3470190&p_doc_key:0CD8F7FCDB673Fl04392
8849D9D8CABl&p handle not found:Y
o Electric rate design policies to encourage the use of distributed solar generation.
Direct Testimony and Exhibits on behalf of the Vote Solar Initiative and the Interstate
Renewable Energy Council, (Docket No. I lA-418E - September 21,201 l).
3
o Development of a community solar programfor Xcel Energt.
Answer Testimony and Exhibits, plus Opening Testimony on Settlement, on behalf of the
Solar Energy Industries Association, (Docket No. 16AL-0048E [Phase II] - June 6 and
September 2,2016).
Rate design issues related to residential customers and solar distributed
generation in a Public Serttice of Colorado general rate case.
2
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Principal Consultant Page 18
ExprRr Wrrxpss Trsrruorw BEnoRE rnn Gnoncm Punr,rc SnRvrcu Corrrrrssrox
1. Direct Testimony on behalf of Georgia Interfaith Power & Light and Southface
Enerry Institute, Inc. (Docket No. 40161 - May 3,2016).
o Development of a cost-effectiveness methodologtfor solar resources in Georgia.
Exrpnr Wrrxrss Tnsrlrroxv BEFoRE rnB Ioano Punr,rc Urrr,mrps Courrrssrox
Direct Testimony on behalf of the Idaho Conservation League (Case No. IPC-E-l2-
27-May 10,2013)
2.
Costs and benefi* of net energl metering in ldaho.
Direct Testimony on behalf of the Idaho Conservation League and the Sierra
CIub (Case Nos. IPC-E- 1 5-0 1/AVU-4- I 5-0 I /PAC-E- I 5-03 - April 23, 201 5)
Rebuttal Testimony on behalf of the Idaho Conservation League and the Sierra
Club (Case Nos. IPC-E-15-01/AW-4-15-01/PAC-E-15-03 - May 14,2015)
Issues concerning the term of PUWA contracts in ldaho.
2.Direct Testimony on behalf of the Sierra Club (Case No. IPC-E-17-13 -December 22,2017)
Rebuttal Testimony on behalf of the Sierra Club (Case No. IPC-E-17-13 -January 26,2018)
Exrnnr Wrrxnss Tpsrrrroxv Bpronr rnn MlsslcHUsETTs DrpmrrrsNT oF Punr,rc
Utrr,runs
a
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b.
a
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b.
I Direct and Rebuttal Testimony on behalf of Northeast Clean Energy Council, Inc.
(Docket D.P.U. l5-155, March l8 and April 28, 2016)
Residential rate design and access fee proposals related to distributed generation
in a National Grid general rate case.
Exprnr WmNpss Tnsrruorw Bpronn rnp MrcrucAN PuBLrc SERvrcE Couurssrox
Prepared Direct Testimony on behalf of Vote Solar (Case No. U-18419-January 12,
2018)
Prepared Rebuttal Testimony on behalf of the Environmental Law and Policy Center,
the Ecology Center, the Solar energ:f Industries Association, Vote Solar, and the
Union of Concerned Scientists (Case No. U-18419 - February 2,2018)
I
2.
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R Tuouas Bslcs
Principal Consultant Page 19
1
Exppnr Wrrxnss Tpsrruorv Boronp rnn MrNxpsou Punr,rc Urrr,rrrns Coprprrssrox
Direct and Rebuttal Testimony on Behalf of Geronimo Energy, LLC. (In the Matter of
the Petition of Northern States Power Company to Initiate a Competitive Resource
Acquisition Process [OAH Docket No. 8-2500-30760, MPUC Docket No. 8002/CN-12-
1240, September 2T ardOctober 1 8, 20131)
Testimony in support of a competitive bidfrom a distributed solar project in an
all-source solicitation for generating capacity.
Exrpnr WrrNnss Tpsuproxv Bnronn rnp MoNr.rrN,q, PurLrc Sunvrcp Couurssrox
Pre-frled Direct and Supplemental Testimony on Behalf of Vote Solar and the Montana
Environmental Information Center (Docket No. D2016.5.39, October 14 and
November 9,2016).
Avoided cost pricing issuesfor solar QFs in Montana.
I
a
Exprnr Wrrxnss Trsrluoxv Bnronn rnp Punr,rc Ururrns CouurssroN oF NEvADA
2
3
I
4. a.
Pre-filed Direct Testimony on Behalf of the Nevada Geothermal Industry Council
(Docket No. 97-2001-May 28,1997)
Avoided cost pricingfor the electric output of geothermal generationfacilities in
Nevada.
Pre-filed Direct Testimony on Behalf of Nevada Sun-Peak Limited Partnership
(Docket No. 97-6008-September 5, 1997)
. QF pricing issues in Nevada.
Pre-filed Direct Testimony on Behalf of the Nevada Geothermal Industry Council
(Docket No. 98-2002 - June 18, 1998)
Market-based, avoided cost pricingfor the electric output of geothermal
generation facilities in Nevada.
Prepared Direct Testimony on behalf of The Alliance for Solar Choice (TASC),
(DocketNos. 15-07041 and 15-07042 -October 27,2015).
Prepared Direct Testimony on Grandfathering Issues on behalf of TASC, (Docket
Nos. 15-07041 and l5-07042-February 1,2016).
b
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Principal Consultant Page 20
c. Prepared Rebuttal Testimony on Grandfathering Issues on behalf of TASC,
(Docket Nos. I 5 -07 04 I and I 5 -070 42 -F ebruary 5, 201 6).
o Net energl metering and rate design issues in Nevada.
Exponr Wmxnss Tnsnuorw Brronn rnn Nnw ITAMpSHTRE PuBLrc Uru,Ittns Cou*rtssrox
I
I
Prepared Direct and Rebuttal Testimony on behalf of The Alliance for Solar Choice
(TASC), (Docket No. DE 16-576, October 24 and December 21,2016).
a Net energt metering and rate design issues in New Hampshire.
ExpBRrWmnBss Trsrruorw Brnonr rnr Nrw Mrxco Punr,rc RpculauoN CoMMrssroN
I
Direct Testimony on Behalf of the Interstate Renewable Energy Council (Case No. l0-
00086-UT-February 28, 20 I l)
ill ll
a Testimony on proposed standby rates for new distributed generation projects;
cost-effectiveness of DG in New Mexico.
2.Direct Testimony and Exhibits on behalf of the New Mexico Independent Power
Producers (Case No. I l-00265-UT, October 3,201,I)
o Cost capfor the Renewable Portfulio Standard program in New Mexico
ExrnRr Wrtxrss Tnsrrnrorw Bnnonr rur NoRrn Clnor,rxa Urrlrrrcs Coruuusstox
Direct, Response, and Rebuttal Testimony on Behalf of the North Carolina Sustainable
Energy Association. (In the Matter of Biennial Determination of Avoided Cost Rates for
Electric Utility Purchases from Qualifring Facilities -2014; Docket E-100 Sub 140; April
25,May 30, and June 20, 2014)
Testimony on avoided cost issues related to solar and renewable quaffiing
facilities in North Carolina.
Apil25,20l4: http://starwl.ncuc.netAJCUC/ViewFile.aspx?ld:89Rb50f-l7cb-4218-87bd-
c743el238bcl
May 30, 2014: http://starw l.ncuc.netAllCUC/ViewFile.aspx?Id:l9e0b58d-a7f6-4d0d-9f4a-
08260e561443
June 20, 2104: http://starw I .ncuc.netlNtrCUC/ViewFile.aspx?ld:bd549755-d I b8-4c9b-b4al -
fc6e0bd2f9a2
o
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Principal Consultant Page 2l
2 Direct Testimony on Behalf of the North Carolina Sustainable Energy Association. (In the
Matter of Biennial Determination of Avoided Cost Rates for Electric Utility Purchases
from Qualiffing Facilities - 2018; Docket E-100 Sub 158; June 21, 2019)
o Testimony on avoided cost issues related to solar and renewable qualifying
facilities in North Carolina.
Exrrnr Wrrxrss Tosrrvroxv Bnronn rHE PuBLrc Uru,rrrns CouuussroN or Onrcox
La.
a
Direct Testimony of Behalf of Weyerhaeuser Company (UM 1129 - August 3,
2004)
Surrebuttal Testimony of Behalf of Weyerhaeuser Company (UM I129 -October 14,2004)
2 Direct Testimony of Behalf of Weyerhaeuser Company and the Industrial
Customers of Northwest Utilities (UM I129 lPhase II - February 27,2006)
Rebuttal Testimony of Behalf of Weyerhaeuser Company and the Industrial
Customers of Northwest Utilities (UM I 129 I Phase II - April 7 ,2006)
Policies to promote the development of cogeneration and other qualifying
facilities in Oregon.
J.Direct Testimony on Behalf of the Oregon Solar Energy Industries Association (UM
l9l0,0l9l l, and l9l2 - March 16, 2018).
a Resource value of solar resources in Oregon
Exprnr Wlrurss TrsrrlroNy Brronr rnB Punnc Srnvrcn CouurssroN oF SourH
Clnor,rxl
I Direct Testimony and Exhibits on behalf of The Alliance for Solar Choice (Docket No.
2014-246-E - December ll,2014)
https://dms.psc.sc.gov/attachments/matter/B7BACF7A-155D-l4l F-2368C43774988F85
Methodologtfor evaluating the cost-effectiveness of net energl metering
b.
a.
b.
a
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Principal Consultant Page 22
ExprRr Wlrxnss Tnsrrprorv BrroRp rnn Punlrc Uulrrrcs Conrurssrox or Trxls
Direct Testimony on behalf of the Solar Energy Industries Association (SEIA) (Docket
No. 44941 - December I l, 2015)
a Rate design issues concerning net metering and renewable distributed generation
in an El Paso Electric general rate case.
Exprnr Wrrxpss TBsrruorw BproRe rHE PuBLrc Spnvrcr CouurssroN oF UrAH
1 Direct Testimony on behalf of the Sierra Club @ocket No. l5-035-53-September 15,
2015)
o Issues concerning the term of PURPA contracts in ldaho.
Exrpnr WtrNnss Tnsuuoxy Bnronn rne VpnuoNT PuBLrc SERvrcE Bo.mo
l. Pre-filed Testimony of R. Thomas Beach and Patrick McGuire on Behalf of Allco
Renewable Energy Limited (Docket No. 8010 - September 26,2014)
o Avoided cost pricing issues in Vermont
Exprnr Wnxnss TpsrtrroNv Bpronn rnn VrRcrxra CoRponruoN CoMMrssroN
Direct Testimony and Exhibits on Behalf of the Maryland - District of Columbia - Virginia
Solar Energy Industries Association, (Case No. PUE-2011-00088, October 11, 2011)
htto://www. scc.virsinia.sxYo250l !.PDF
a Cost-ffictiveness of, and standby rates for, net-metered solar customers.
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R. Tttoltls Bnlcn
Principal Consultant Paee 23
Lrrrcluox Expnnrnucp
Mr. Beach has been retained as an expert in a variety of civil litigation matters. His work
has included the preparation of reports on the following topics:
The calculation of damages in disputes over the pricing terms of natural gas sales
contracts (2 separate cases).
o The valuation of a contract for the purchase of power produced from wind generators.
o The compliance of cogeneration facilities with the policies and regulations applicable to
Qualiffing Facilities (QF$ under PLIRPA in California.
o Audit reports on the obligations of buyers and sellers under direct access electric
contracts in the Califomia market (2 separate cases).
o The valuation of interstate pipeline capacity contacts (3 separate cases).
In several of these matters, Mr. Beach was deposed by opposing counsel. Mr. Beach has also
testified at trial in the bankruptcy of a major U.S. energy company, and has been retained as a
consultant in anti-trust litigation concerning the Califonria natural gas market in the period prior
to and during the 2000-2001 California energy crisis.
a
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