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HomeMy WebLinkAbout20020904Volume 2, pg 141-181.pdf 1 (The following proceedings were 2 had in open hearing.) 3 MR. FELL: And move for the admission 4 of Exhibit Nos. 12 through 16. 5 COMMISSIONER SMITH: Without 6 objection, Exhibits 12 through 16 will be admitted. 7 (PacifiCorp Exhibit Nos. 12 8 through 16 were admitted into evidence.) 9 MR. FELL: Mr. Watters is available 10 for cross-examination. 11 COMMISSIONER SMITH: Thank you. 12 Mr. Olsen, do you have examination for 13 Mr. Watters? 14 MR. OLSEN: Just a few questions. 15 16 CROSS-EXAMINATION 17 18 BY MR. OLSEN: 19 Q. Mr. Watters, I direct you to page 2, 20 lines 1 through 15, of your rebuttal testimony. In 21 there you summarize the range of interruptible or 22 curtailment products which PacifiCorp has purchased 23 or proposed to purchase from its retail customers. 24 Are you familiar with the rate 25 proceedings that PacifiCorp filed earlier this year 150 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 where it adjusted or sought to recover various 2 extraordinary power purchase costs and also changed 3 rates of various customer classes here in Idaho? 4 A. I am fairly familiar, yes. 5 Q. Were you familiar with the rate 6 structure that the irrigation class had prior to the 7 settlement or the agreement that was reached between 8 the Company and various Intervenors? 9 A. Mr. Taylor would probably be the best 10 to answer that, but I am somewhat familiar with the 11 prior rate structure. 12 Q. Okay. Maybe just to refresh your 13 recollection, the prior Schedule 10 had what's known 14 as the ABC rate structure. I think the A schedule 15 had a firm rate, the C rate was an interruptible 16 rate? 17 A. Uh-huh. 18 Q. This is a general question: 19 Where would that interruptible rate as 20 a demand-side resource fall into your Exhibit 12, 21 which is discussed on page 2, lines 1 through 15? 22 A. Now, on Exhibit 12, it would fall 23 probably into the category of economic curtailment. 24 Q. Okay. Economic curtailment. And 25 there is two categories for that? 151 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 A. Yes. And, again, just to clarify, 2 each -- maybe Mr. Griswold referred to it, but each 3 customer is different, and those products are 4 tailored specifically to different customers and 5 what they can do. For instance, the Irrigators, if 6 I remember correctly have a real problem going too 7 many hours. They have to get enough water on their 8 fields, and so we -- I think previously the tariff 9 was structured somewhat to meet their requirements. 10 Q. Okay. 11 A. So these terms, all I'm saying is 12 across the sheet here they may not be exactly the 13 same, but they would fall under the general economic 14 curtailment category. 15 Q. Okay. That's all I was trying to find 16 out there, the general. 17 From your testimony here in your 18 rebuttal, is it fair to say that demand-side 19 resources like curtailment or interruptibility is a 20 important part of PacifiCorp's planning? 21 A. Yes. 22 Q. Okay. 23 MR. OLSEN: I'll reserve the other 24 questions for Mr. Taylor. 25 COMMISSIONER SMITH: Okay. Thank you, 152 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 Mr. Olsen. 2 Mr. Woodbury, do you have questions? 3 MR. WOODBURY: Yes, I do. Thank you. 4 5 CROSS-EXAMINATION 6 7 BY MR. WOODBURY: 8 Q. Mr. Watters, looking at your 9 Exhibit 12 -- 10 A. Uh-huh. 11 Q. -- and I guess comparing that to 12 Mr. Griswold's Exhibit 4, does Exhibit 4 contain any 13 more complete list of interruptible curtailment 14 products? 15 A. I don't have Mr. Griswold's Exhibit 4. 16 Q. Okay. They are quite -- 17 Maybe your Counsel can provide it. 18 COMMISSIONER SMITH: Mr. Woodbury, why 19 don't we wait until -- 20 MR. WOODBURY: Pardon? 21 COMMISSIONER SMITH: Why don't we wait 22 until Mr. Watters' counsel has provided him with a 23 copy of that exhibit. 24 MR. WOODBURY: That's what I asked. 25 MR. FELL: (Indicating.) 153 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 THE WITNESS: Thank you, Jim. 2 This would be -- 3 Maybe I could ask you to repeat your 4 question so that I'm clear. 5 Q. BY MR. WOODBURY: Have you seen 6 Mr. Griswold's Exhibit 4 before? 7 A. I have it in front of me now. 8 Q. Have you seen it before? 9 A. It looks somewhat familiar to other 10 things I've seen in the past. 11 Q. Would you accept, subject to check, 12 that the -- that the interruptible curtailment 13 products that you set forth in your Exhibit 12 are 14 also contained in Mr. Griswold's Exhibit No. 4, with 15 the exception maybe of system integrity? 16 A. They fall into the same general 17 category. It looks like here these are -- specific 18 terms have been laid out here because one is 19 referring to Monsanto specific demand-side options, 20 where my exhibit is more general in content, but 21 these would fall into these categories. 22 Q. All right. You indicate that your 23 Exhibit 12 represents those interruptible 24 curtailment products of most value to PacifiCorp. 25 Is that correct? Page 1, line 21. 154 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 A. Uh-huh. Yeah, I believe they do. 2 Q. And the way that you set them forth in 3 your Exhibit 12, is that a ranking in order of 4 value? 5 A. Not necessarily, no. 6 Q. And can you -- is there a ranking of 7 those? 8 A. Not really, and let me explain why, 9 because the economic curtailment options have -- I 10 think in my testimony I talked about what are the 11 parameters that make up the value associated with 12 those, and depending what those parameters are -- 13 and we've already talked about it: What is the term 14 of the economic interruption, is it a summer only 15 product, is it an annual product, how many hours is 16 it, over what period of time is it -- because as we 17 evaluate that option, we have to take into 18 consideration what is the underlying values in the 19 marketplace associated with commodities that drive 20 markets. 21 For instance, natural gas. Natural 22 gas in the wintertime is typically higher as opposed 23 to maybe in the summer. Same thing with 24 electricity. Commodities move by season, their 25 prices move by season. 155 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 So depending on what the specific 2 product is, the economic curtailment could provide 3 greater value or it could provide less value than 4 the operating reserves, but it depends on how we 5 define it, how many hours a day is it. All of those 6 parameters come into values in those products. 7 Q. There was a discussion with 8 Mr. Griswold as to perhaps whether economic 9 curtailment offered by Monsanto would be of greater 10 value than the nonspinning operating reserve? 11 A. Uh-huh, I remember that. 12 Q. Would you agree with that? 13 A. I thought maybe if you could ask -- 14 you asked it as do you remember the conversation 15 and, yes, I do. 16 Q. Do you remember that conversation? 17 A. Yes, I do remember the conversation, 18 but I'm wondering what your question is. 19 Q. Would you agree that with respect to 20 the products offered by Monsanto through this case, 21 that the economic curtailment would be of greater 22 value to PacifiCorp? 23 A. I think that's what we're going to 24 determine after we look at their rebuttal testimony 25 that came in, because it's not clear to me what the 156 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 offer is. And I think in our discussions with 2 Monsanto and now with the latest somewhat proposal 3 that they have put out in their rebuttal, we need to 4 evaluate that because the values move around, and I 5 think that we will be prepared to answer 6 specifically based on that. 7 Now, I will say this: In general, 8 with what was in my rebuttal testimony, or 9 specifically referring to the 500 hours of 10 interruption and what we've evaluated there, that 11 product, because it was 500 hours in length, we 12 could put it into the highest period of the market 13 which is what we would typically economically 14 curtail, which would be the summertime. So that 500 15 hours fits right into that peak amount. That, in 16 and of itself, provides a significant value, a 17 higher value than the operating reserves on a 18 per-kW-month basis. 19 Now, if you spread those hours out and 20 that's what we're going to be determining as we 21 evaluate the latest proposal going to 1,000 hours, 22 we're going to determine what is that value, and 23 what that will tend to do. I don't know the amount, 24 but I know the direction. It will drive the value 25 of those reserves on a per-kW-month basis down. 157 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 However, it may be more valuable to Monsanto because 2 they have increased the overall amount. So we have 3 to weigh both of those factors. 4 And so once we get to that, I'll be 5 able to answer that question more specifically, but 6 in the instance of the exhibits or the products that 7 are in my rebuttal testimony, right now on a 8 per-kW-month basis, that has a higher value. 9 Q. On page 7 of your testimony, you 10 speak -- you state that PacifiCorp is unwilling to 11 accept the risk, that the value of their reserves 12 will continue unchanged, and that there's a need to 13 incorporate some changes in the contract, and one of 14 those is the ability to change the agreement through 15 reopeners. Correct? You say based on the value of 16 the product -- the ability to change the agreement 17 based on the value of the product? 18 A. And, again, we're specifically 19 referring to the operating reserves in this case. 20 Is that what you're referencing? Page 7, lines -- 21 Q. Starting at line 11. 22 A. Yes, that's what I thought. It's 23 directly referring to the operating reserves, and as 24 Mr. Griswold stated, the WECC has been having 25 numerous meetings discussing what will be the new 158 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 operating reserve criteria in the WECC, and 2 historically we've held seven percent on firm 3 service, half of which has to be spinning, half of 4 which is nonspinning. That's the product that we 5 have contracted in the past with Monsanto for is the 6 nonspin portion. 7 As we move forward, they're talking 8 about frequency response reserves, and they believe 9 that having more of those is more important to 10 reliability of the grid. Although we've been 11 operating for a number of years with the current 12 criteria, the WECC can change the criteria, making 13 PacifiCorp carry more frequency response reserves. 14 At the same time they're looking at if they do that, 15 maybe we don't have to carry as much of the other 16 contingency reserves. But it has not been settled 17 and it is the subject in a fairly good debate -- 18 good, healthy debate -- and it has not been agreed 19 to, and I'm not a great prognosticator, but these 20 discussions have been going on for some time and all 21 I hear of is that they expect to have some decision 22 in 2003. 23 And I will say this as well: There is 24 good support for it and there is also some people 25 that are not having support for it. So we really 159 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 don't know. It's an unknown to us. And typically 2 when you have an unknown like that, managing the 3 risk of our system, we don't want to take on the 4 risk of buying a product that does not have value 5 for our customers and to fix that amount. 6 Q. Are you participating in those 7 discussions? 8 A. Personally, I am not. There are 9 people in our company that are. 10 Q. Is anybody from the Company 11 participating? 12 A. Yes, I just said that, that there are 13 people in the Company that are. 14 Q. Who? 15 A. Robert Williams, in our grid ops. 16 Mainly coming through the transmission side of the 17 business, because they're responsible for 18 reliability. 19 Q. Starting on page 7 of your testimony, 20 you enter into discussion regarding the valuation of 21 Monsanto's proposal for interruptibility? 22 A. Uh-huh. 23 Q. And the interruptible products that 24 you entertain to value are the economic curtailment 25 with a buy-through option, nonspinning operating 160 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 reserves, and the system integrity product. Now, 2 products that you're pricing have the 3 characteristics set forth in Mr. Griswold's 4 Exhibit 10? 5 A. Yes, Mr. Griswold's Exhibit 10 is 6 reflective of our valuation on Exhibits 13, 14, and 7 15 in my testimony. He's incorporated those values. 8 Q. I can't hear you. 9 A. He has incorporated those values into 10 his exhibit. 11 Q. And it was those particular 12 characteristics that you considered in developing a 13 pricing method? 14 A. Correct. 15 Q. And if those values were or 16 characteristics were to change, then your pricing 17 methodology would change also? 18 A. Not necessarily the methodology. I 19 think the methodology stays somewhat consistent, 20 but -- 21 Q. Just the input data? 22 A. It really gets down to what I said 23 earlier, that as you increase certain elements of 24 this, such as the number of hours of interruption, 25 we are now spreading in that case again, like I 161 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 said -- I know what the direction is, but I don't 2 know the amount. When you spread 1,000 hours over 3 five days a week, eight hours a day, it's 40 hours a 4 week, 1,000 hours, that's roughly about seven, six 5 and a half, seven months that we're spreading that 6 over. In this case when we had earlier we were 7 spreading it mainly over the three key months of 8 summer, so there's a significant value difference. 9 But again, we need to evaluate it because Monsanto 10 has offered more hours, which has to be reflected in 11 the value to Monsanto. They've also added 12 additional amount in their rebuttal, and that's what 13 we're evaluating. But what will change -- the 14 methodology won't change. It's just that the 15 forward price curves and the value of gas in the 16 market is different over a longer period of time 17 than it is over a shorter period of time. 18 Q. In valuing those products, do you 19 consider also the presence of the reopeners that you 20 identify in page 5 of Exhibit 10; and if those 21 reopeners were not present, would it be priced 22 differently? 23 A. Exhibit -- Bruce Griswold's 24 Exhibit 10? 25 Q. Yes. 162 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 A. As far as the operating reserve 2 calculation, it is calculated based as if it would 3 stay with the current -- the current criteria in the 4 WECC. So we were making that assumption and that's 5 why we asked for a reopener on it, because if it 6 does change, then we would need to make the change. 7 Q. What about the agreement reopener with 8 respect to interruptibility? Does that affect your 9 pricing? 10 A. We have based our prices on current 11 market gas and electricity out through -- on a 12 forward price curve '02 through '06, the four years 13 that we've been talking about, 4.4 years -- or, four 14 years, four months. 15 Q. Looking at your Exhibits 13, 14, and 16 15, those are your calculation methods? 17 A. Uh-huh. 18 Q. And you have a bottom line on each of 19 those that shows a net benefit of zero on 14 and 15 20 also? 21 A. Correct. 22 Q. What is the Company intending to 23 convey by assigning zero as a net benefit, that the 24 options have no -- presented by Monsanto -- have no 25 net benefit to the Company? 163 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 A. What we're showing is that based on 2 our evaluation on each one of these products, that 3 we are providing Monsanto the full value of the 4 product in the marketplace. 5 Q. Looking at your Exhibit 13, you have a 6 line there on operating reserves calculation "lost 7 retail revenue," and you assign a value of 859,000. 8 Does that factor into the Company's choice of 9 alternatives, say, if you're choosing to meet your 10 requirements with a peaker resource and your other 11 choice was this, would you build a peaker to avoid 12 the risk of operating for lost revenue? 13 A. Would we build a peaker? 14 Q. Does this bias the Company in a way 15 that this is a factor in its particular choice? 16 A. What we have here is what is currently 17 on our system to carry reserves, how we carry 18 reserves, so the value here is based to us backing 19 off current generation that we have in our portfolio 20 that we use to carry operating reserves. That's 21 based on Cholla coal plant in Arizona and Gadsby. 22 These are our highest-cost incremental resources, so 23 that's where we carry 90 -- we carry more than just 24 there, but the 95 megawatts typically what we have 25 done here is we have weighted it what we can carry 164 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 on Cholla and what we can carry on Gadsby. Those 2 numbers are 40 megawatts on Cholla and 55 megawatts 3 on Gadsby. We then look at that and basically we do 4 not need Monsanto, so to speak, for operating 5 reserves, usually, during the evening hours. We 6 have adequate reserves currently in the system. So 7 this is evaluated over 430 hours a month, which 8 represents the heavy load hours, comparing us 9 backing off on our units against the market; because 10 otherwise if Monsanto provides us the product, we 11 would not back these units off, we would sell them 12 to market. So we looked at that on a annual basis 13 and provided here again the full value of that, less 14 the lost retail revenues. 15 Q. I understand -- do I understand that 16 the difference between the economic curtailment 17 option and the nonspinning operating reserve option 18 is one is interruption at -- economic curtailment is 19 interruption at PacifiCorp's discretion at any time 20 and the other is pursuant to WECC criteria? 21 A. This is what I would call a contingent 22 option, so to speak. We have to lose a unit that is 23 over 200 megawatts in size. Then we need to have 24 the operating reserves to cover that and we would go 25 to Monsanto to recover on an outage greater than 165 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 200 megawatts. If it's an outage on a unit that's 2 smaller than that, we don't have to respond by the 3 operating criteria, minimum operating criteria. 4 Q. Do you have any familiarity with the 5 multistate process? 6 A. Not an expert, but I have some 7 familiarity. 8 Q. Do you know whether the Utah task 9 force proceedings are open to Monsanto or whether 10 Monsanto has been invited to participate? 11 A. I believe Monsanto has been involved 12 in the multistate process. I believe that's true. 13 I don't know specifically about a Utah task force 14 though. 15 Q. Thank you, Mr. Watters. Mr. Watters, 16 who would be -- who would be the witness to ask 17 questions regarding the Magcorp contract and perhaps 18 the Empire contract, and the presence within those 19 contracts of reopener provisions? 20 A. I believe Mr. Griswold would be the 21 best person to answer those. 22 Q. Okay, I'll get him when he comes 23 back. 24 MR. WOODBURY: Thank you, 25 Madam Chairman. No further questions. 166 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 COMMISSIONER SMITH: Thank you, 2 Mr. Woodbury. 3 Mr. Budge. 4 MR. BUDGE: Thank you, Madam Chairman. 5 COMMISSIONER SMITH: You can still go 6 for another ten minutes. 7 MR. BUDGE: Do you want me to get 8 started until we need a break? 9 COMMISSIONER SMITH: Yes. Yes. 10 MR. BUDGE: Thank you. 11 12 CROSS-EXAMINATION 13 14 BY MR. BUDGE: 15 Q. Mr. Watters, looking at this matrix, 16 Exhibit 12, that provides various criteria for 17 interruptibility that the Company evaluates. That's 18 basically my understanding of what that exhibit 19 portrays, the things you look at in valuing an 20 interruptible customer? 21 A. Uh-huh, right. 22 Q. Would you agree that if you compared 23 Monsanto with virtually any other interruptible 24 customer you have available on the system, what 25 Monsanto's offered in this case, that Monsanto is 167 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 really at the top of the heap as far as providing 2 benefit and value to PacifiCorp? 3 A. I believe that Monsanto is one of the 4 people that are at the top of the heap. I believe 5 that Monsanto here has worked with us over a period 6 of time to look at the different options that are 7 available. I think we've both tried to respond to 8 each other the best we could, trying to find our way 9 through the forest here. But Monsanto trips its 10 furnaces. 11 I also have an agreement with Nucor 12 and they do a very fine job on interrupting their 13 furnaces as well for the Company. 14 We do not currently have economic 15 curtailment with Monsanto or with Nucor, and so from 16 that standpoint of the agreements we've had that 17 have been interruptible over the last few years, 18 both Monsanto and Nucor have provided benefits to 19 our eastern control area. 20 Q. As far as we look at what might be 21 considered unique characteristics of the Monsanto 22 interruptibility -- and I'm talking about the 23 proposal that's been laid out now and not prior 24 agreements -- would you agree that the sheer size of 25 the Monsanto load -- 162 megawatts -- makes it 168 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 unique from any other curtailment customer? 2 A. It is unique in the sense that it is 3 such a large load. And typically from an operating 4 standpoint when we're making phone calls to have to 5 trip loads, you have to -- well, some of these 6 products I won't offer to customers that are small, 7 because we can't cover it all. We can't offer it to 8 a two-megawatt customer. Even ten megawatts 9 sometimes might be pushing it. But for these very 10 large customers such as Monsanto, who is our 11 largest, I believe, making one phone call to cut 12 load is a nice thing from an operator's standpoint, 13 and that's what's nice about Nucor and -- is that we 14 can get big pieces; because most of the time our 15 system is going to respond to the small stuff just 16 fine, I'm not too concerned, but having the big 17 chunks that you can have to manage the system, it's 18 a nice feature. 19 Q. And when you make that one phone call, 20 the fact that Monsanto is able to come down 21 everytime and in a matter of seconds differentiates 22 it from even a Nucor, wouldn't it? 23 A. No, I have pretty much the same 24 parameters with Nucor. They will trip immediately. 25 They have to in order to -- they have to meet the 169 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 same criteria that we have with Monsanto. 2 Q. And what about the flexibility of 3 being able to take one, two, or three loads at a 4 time, does that make Monsanto more valuable or 5 unique to the Company? 6 A. Right today we can only take two at a 7 time. We can't take three unless I think it's under 8 an emergency. 9 Q. Well, if the ultimate proposal by 10 Monsanto was that you could take one, two, or all 11 three -- 12 A. The latest one? 13 Q. Yes. 14 -- would that be more valuable to 15 you -- that flexibility provide more value than 16 other customers that do not allow those types of 17 increments? 18 A. That's -- that's a hard question. Let 19 me tell you why: 20 Under the current as of what I've read 21 as of yesterday Monsanto has offered economic 22 curtailment with buy-through on all three furnaces, 23 so when it comes time for planning to meet their 24 load, I can call Monsanto and say we're going to 25 economic curtailment. I do that two hours in 170 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 advance, and then they say back within one hour 2 whether they want to buy through or whether they 3 will take a physical interruption. So in this case, 4 I no longer have a physical interruption such as I 5 would have in the operating reserves; I have a 6 financial interruption. And it looks more like a 7 financial instrument to me, which means I still have 8 an obligation to serve Monsanto, I just get to 9 charge them a different price during those hours. 10 That is different than the arrangement, for 11 instance, that I have with Nucor, which is a 12 physical interruption on the system. So I'm just 13 trying to differentiate between the two, and so 14 that's why it's hard to answer your question. They 15 each provide different things. 16 Q. I understand. The types of 17 interruptions that Monsanto offered was intended to 18 provide the Company with the greatest flexibility to 19 provide value? 20 A. Uh-huh. 21 Q. And Monsanto has essentially said what 22 you would like, whatever you would like. We will 23 offer emergency or system integrity interruptions, 24 we'll offer economic interruptions, we'll also offer 25 operating reserve interruptions? 171 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 A. Uh-huh. 2 Q. Are there any other customers that 3 provide the Company with all three possibilities? 4 A. Currently, I am not aware of a 5 customer that has all three within -- that they have 6 offered, but I currently don't have a contract with 7 anyone that has all those either. 8 Q. And insofar as the hours that are 9 offered where you could take a one-hour block, a 10 three-hour block, a four-hour block, or eight-hour 11 block, does that not provide flexibility and value 12 to the Company in making its decisions? 13 A. What the economic -- if what we're 14 referring to, the latest proposal by Monsanto, then 15 what that does for the Company is it gives us a 16 hedge against market price in serving the load eight 17 hours a day for 1,000 hours a year. It's a 18 buy-through; it's still an obligation. So what it 19 does is it shifts that risk from PacifiCorp to 20 Monsanto and we're willing to pay Monsanto for that, 21 for them wanting to accept the market risk for 1,000 22 hours a year. 23 MR. BUDGE: I may have been confused. 24 Did you want to break at quarter to one? 25 COMMISSIONER SMITH: No. 172 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 MR. BUDGE: I misunderstood. 2 Q. BY MR. BUDGE: Mr. Watters, I wanted 3 to ask you about PacifiCorp's perspective whether 4 certain things that have been identified by others 5 are valued to your system -- valuable to your system 6 in the form of demand-side management response-type 7 programs. And there was a paper that was presented 8 to the National Association of Regulatory Utility 9 Commissioners recently at a meeting in Portland in 10 July. Did you attend that? 11 A. I did not attend that. 12 Q. But that report that NARUC presented 13 identified what they felt were some very specific 14 benefits of demand response programs, such as 15 curtailment of the Monsanto load, and I just wanted 16 to go through this list of a few points that they 17 had identified and have you tell me whether or not 18 you also feel those benefits would apply to the 19 PacifiCorp system in utilizing Monsanto's 20 curtailment as a resource. 21 A. Okay. 22 Q. The first benefit identified was 23 system reliability. 24 A. Yes. 25 Q. And the second one was cost reduction, 173 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 and cost reduction -- 2 A. And this is specifically in 3 relationship -- get closer -- specifically -- 4 Q. Specifically cost reduction was 5 referred to benefits that are provided through, A, 6 direct cost savings from avoided generation, as well 7 as avoided transmission and distribution costs; and, 8 B, direct and indirect reduction in the wholesale 9 market prices? 10 A. I just needed to ask you a clarifying 11 question on your question. 12 Q. Okay. 13 A. This is all in reference to 14 interruptibility of retail customers? 15 Q. Correct, interruptibility of the 16 Monsanto load as a valuable benefit in resource to 17 PacifiCorp. 18 A. It provides us a benefit against the 19 market prices. I think you mentioned that one. 20 Typically, we would tend to hedge out 21 our risk of our contracts based on the terms of 22 those agreements. So in the case of Monsanto, I'm 23 not sure that we would go build CT necessarily, but 24 we would definitely go to the market and secure a 25 product, and that's how I evaluated in my exhibits 174 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 what we would do and that again provides value for 2 us to mitigate risk. 3 In agreement -- there was a third 4 one. I can't recall what you said. You said 5 generation, market price. 6 Q. I think there was market price, 7 avoided transmission, and distribution costs was the 8 third item? 9 A. It's possible. I don't know in the 10 case of Monsanto, but it may be possible to avoid 11 some transmission if we had the ability to 12 automatically relay and trip Monsanto if there was 13 an issue on the transmission system, that otherwise 14 if we didn't have that remedy if it made us incur 15 capital costs to improve the transmission system. 16 So, it can. I'm just not sure about Monsanto, 17 whether it does that or not. 18 Q. Certainly there are savings in avoided 19 generation plan and there are savings regarding 20 possible market purchases, and you have a question 21 mark on transmission there? 22 A. Well, no, I said on generation. 23 Typically I would not go invest in a 30-year, 24 20-year generation asset for a five-year contract. 25 That's -- that would be my position there. But if 175 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 Monsanto was a long-term, then indeed having the 2 ability to trip could avoid building new generation. 3 Q. The third item was market efficiency 4 which was described in the paper to the extent 5 customers will alter behavior to reduce or shift 6 on-peak usage and costs to off-peak periods that 7 result in more efficient use of the remaining 8 electric system. Would that be a yes? 9 A. In general, that is very true. In the 10 case of a utility like PacifiCorp that has a unique 11 system of hydro assets and thermal assets, we 12 typically keep our thermals pretty well loaded as it 13 is by how we operate on-peak the hydro and then fill 14 the pond, so to speak, off-peak by running our 15 thermals and putting our energy back in our hydros. 16 So the way we operate the system, that automatically 17 makes ours more efficient. That's not to say that 18 there wouldn't be some benefit of shifting in the 19 system, but in general we would probably not see as 20 much benefit as some other thermal-based systems. 21 Q. And Monsanto's consumption of those 22 shoulder or off-peak hours also adds to that same 23 efficiency of operation of the thermal units, does 24 it not? 25 A. It would be a load on the system that 176 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 would be served during that time period, so 2 obviously that's coming from our resources. 3 Q. Okay, the fourth point is risk 4 management. Demand response allows utilities to 5 hedge their risk exposure to system emergencies and 6 price volatility? 7 A. Yes, that's very true, and that's 8 exactly how we did our evaluation in the case of 9 Monsanto is looking at market price volatility. 10 Q. And environmental issues. I believe 11 that refers to the fact that peaking plants are some 12 of the more inefficient which you have and their 13 operation creates certain environmental concerns in 14 the way of emissions. All of those things would be 15 avoided through curtailment of the existing 16 customer? 17 A. I'm not a -- I'm not an expert on our 18 emissions, but I'm assuming that -- I do know that 19 they -- our new peakers -- West Valley, Gadsby -- 20 are better for the environment than the Gadsby steam 21 units that ran on gas, and it is also, I believe, 22 they are better environmentally. 23 Q. And I think the point is we would 24 certainly add more environmental problems if we were 25 not having them at all? 177 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 A. I guess there would be some detriment 2 to the environment. 3 Q. The fifth point was market power 4 mitigation, the use of reliability-based or 5 market-based demand response during peak periods 6 provides a important safety valve for the market. 7 Use of coal plants could eliminate the need to make 8 high, above-market bids? 9 A. I think that's generally true, 10 although the West-wide market is a very charming 11 market, so that would need to be -- I think a 12 comment there is referring to if we had a lot of 13 that around the West, you could really mitigate; but 14 if you only have 1,000 megawatts of it or something 15 less than that, it may not be mitigated that much 16 depending on where we are and what time of the year 17 it is. But obviously specifically for PacifiCorp, 18 that's why we're pricing these options out to 19 Monsanto, because they do provide value to us, and I 20 don't think that's in question. 21 Q. And then the final point: I asked you 22 about market efficiency. What about system 23 efficiency from an operational standpoint, demand 24 response curtailment such that Monsanto provides an 25 option to use -- to address any transmission or 178 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 distribution bottlenecks that may exist? 2 A. Again, one thing as I've been 3 listening here today that we really need to keep in 4 mind as we talks about this is we need to look at 5 interruptions and I think referring to them as what 6 they are. System integrity definitely helps if 7 we're in an emergency situation on a -- the entire 8 system. 9 Economic curtailment, I don't know 10 what Monsanto is going to do, I don't know. They 11 may not help me at all. They may buy through. That 12 would provide me no benefit. 13 Operating reserves is obviously a 14 relationship we've had together for some time and 15 that is a benefit to our system operations and that 16 can tend to help make our system more efficient. So 17 as we go forward, there's really three things there, 18 and we need to keep that in mind. 19 Q. If you look to a demand response 20 offering like Monsanto, does that not, in effect, 21 eliminate the capital costs the Company otherwise 22 has to spend to build peaker plants? Is capital 23 costs a consideration? 24 A. It all depends on location and 25 everything. Peaker plants could have been needed 179 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 in -- I mean, there was reasons why the peakers are 2 located down in Salt Lake: It's a large load area 3 that we put those peakers in place. There is 4 voltage support issues in the Wasatch Front and 5 themselves, they tended to help that. 6 So peakers are -- when one looks at a 7 peaker and I think there's some testimony by 8 Mr. Rosenberg and a few others on peakers, with 9 peakers, peakers could give you a lot of 10 flexibility. Peakers and Monsanto do as well. 11 But the other thing peakers do is I 12 have them available to me all the time. They're 13 available 8,760 a year, which makes them a little 14 bit different. 15 Right now we're operating our peakers 16 well over 30 percent. So one needs to consider how 17 often we're operating them and because the peaker 18 technology, these peakers are pretty much in the 19 money quite a bit of the time, so they provide value 20 beyond typically hitting a peak resource. I'm able 21 to market those and make them more efficient during 22 the day. And they also carry operating reserves. 23 So depending on what ultimate 24 arrangement comes out of this process with Monsanto, 25 if it's 162 megawatts of economic curtailment, that 180 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp 1 provides me a hedge against market operation risk 2 but it doesn't provide me operating reserves like a 3 peaker that adds value to my system. So it's really 4 hard to say how you would compare the two, because 5 really there's a little bit of apples and oranges 6 there. It's not straightforward. 7 COMMISSIONER SMITH: Mr. Budge, would 8 this be a good time to break? 9 MR. BUDGE: Very good. Thank you. 10 COMMISSIONER SMITH: Thank you. 11 We will come back at 2:15 and continue 12 Mr. Budge's cross. 13 (Noon recess.) 14 15 16 17 18 19 20 21 22 23 24 25 181 HEDRICK COURT REPORTING WATTERS (X-Reb) P.O. BOX 578, BOISE, ID 83701 PacifiCorp