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HomeMy WebLinkAbout20071211Higgins direct.pdfBOEHM, KURTZ & LOWRY ATIORNS AT lAW 36 EA SEV STRET SUITE 1510 CICINNATI OHIO 45202 TELEPHONE (513) 421-2255 TELECOpmR (513) 421-2764 RECE 2U01 nEC I i MilO: 38 ¡rJAHO PUBUC UTiifflES COMMISSIO¡\ VI OVERNIGHT MAIL December 7, 2007 Jean D. Jewell, Secreta Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83720 In re: Case No. IPC-E-07-8 Dear Ms. Jewell: Enclosed please find nine the original and (8) copies of the DIRCT TESTIMONY OF KEVIN C. ilGGINS FILED ON BEHAF OF THE KROGER CO. dba FRED MEYER AND SMITH'S FOOD AN DRUG to be fied in the above referenced matter. I also attch an electronic version. Copies have been served on all paries on the attched certificate of service. Please place this document of fie. Respectfully yours,~~~/M Kur J. Boehm, Esq. BOEHM, KUTZ & LOWRY MLew Ene!. CERTIFICATE OF SERVICE Ri:r.r"..1.1: I hereby certify that tre copy of the foregoing was served by electronic mái~ûJ dtiel'KdGlòila, this 7th day of December, 2007 to the following: !í;j4HO PUBLIC UTlllTIES COMMiSSIO¡\Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Charered 201 E. Center PO Box 1391 Pocatello,ID 83204-1391 Email: elo(iracine1aw.net Baron L. Kline Lisa D. Nordstrom Idaho Power Company 1221 W. Idao S1. (83702) POBox 70 Boise, il 83707-0070 Email: bkline(iidahopower.com N ordstrom(iidahopower.com JohnR. Gale Vice President, Reguatory Affairs Idaho Power Company 1221 W. Idaho S1. (83702) PO Box 70 Boise, il 83707-0070 Email: rgale(i.idahopower.com Anthony Yanel 29814 Lake Road Bay Vilage, OH 44140 Email: tonvCivane1.net Weldon Stutzan Donovan Wa1er Deputy Attorney Generals Idaho Public Utilties Commssion 472 W. Washington (83702) PO Box 83720 Boise, il 83720-0074 Email: weldon.stutzanCipuc.idaho.gov donovan. walkerCipuc.idaho.gov Conley E. Ward Michael C. Creamer Givens Pursley LLP 601 W. Banock Street PO Box 2720 Boise, il 83701-2720 Email: cewCi.givenspurslev.com Denns E. Peseau, Ph.D. Utilty Resources, Inc. 1500 Libert Street, Suite 250 Salem, OR 97302 Email: dpeseauCiexcite.com Peter J. Richardson, Esq. Richardson & O'Lear 515 N. 27th Street PO Box 7218 Boise, il 83702 Email: peterCirichardsonandolear.com LotH. Cooke Acting Assistat General Counsel United States Deparent of Energy 1000 Independence Ave., SW Washigton, DC 20585 Telephone: 202-586-4219 Email: lot.cookeCihg.doe.gov Don Reading Ben Johnson Associates 6070 Hil Road Boise, il 83703 Email: dreadingCimindspring.com Dale Swan Exeter Associates, Inc. 5565 Sterrett Place Suite 310 Columbia, MD 21044 Email: dswanCiexeterassociates.com G:\WORKIKOGE\lAHO\IC-E-7-08\Comnsson Itt (Idao ).doc Electronic Copies Only: Denns Goins Email: dgoinspmg(icox.net Arur Perr Bruder Email: arhur. bruder(ihg .doe.gov ~~~ Kur J. Boehm, Esq. G:\WORKOGER\lAHO\IC-E-7-08\Comn"ion lt (Idao ).doc !" ~ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 E 20m DEC i I M1 10: 8 IDAHO PUBLiCBEFORE THE UTILITIES cOMMISS IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF TH APPLICATION OF IDAHO POWER CONWANY FOR AUTOIDTY TO INCREASE ITS RATES AND CHAGES FOR ELECTIDC SERVICE TO ELECTIDC CUSTOMERS IN TH STATE OF IDAHO ) ) ) ) Case No. IPC-E-07-8 ) ) ) DIRCT TESTIMONY OF KEVI C. HIGGINS On Behalf of The Kroger Co., Doing Business as Fred Meyer and Smith's Food and Drug December 10, 2007 r . 1 2 DIRECT TESTIMONY OF KEVIN C. HIGGINS 3 Introduction 4 Q. 5 A. 6 7 Q. 8 A. 9 10 11 Q. 12 A. 13 14 15 16 17 18 Q. 19 A. 20 21 22 23 Please state your name and business address. Kevin C. Higgins, 215 South State Street, Suite 200, Salt Lake City, Uta, 8411 1. By whom are you employed and in what capacity? I am a Pricipal in the firm of Energy Strategies, LLC. Energy Strategies is a private consulting fi specializing in economic and policy analysis applicable to energy production, transporttion, and consumption. On whose behalf are you testifying in this proceeding? My testimony is being sponsored by The Kroger Co., ("Kroger"), doing business as Fred Meyer and Smith's Food and Drg. Kroger is one of the largest grocers in the United States. Kroger has over 25 accounts served by Idaho Power, which together consume over 40 milion kWh per year. A large porton of Kroger's load taes servce under Schedule 9. Kroger's Schedule 9 load taes service at both seconda and priar voltage. Please describe your professional experience and qualications. My academic background is in economics, and I have completed all coursework and field examinations toward a Ph.D. in Economics at the University of Uta. In addition, I have served on the adjunct faculties of both the University of Uta and Westminster College, where I taught undergraduate and graduate courses in economics from 1981 to 1995. I joined Energy Strategies in 1995, 2 Higgns, DI Kroger Co. dba Fred Meyer & Smiths . 1 2 3 4 5 6 7 8 9 10 Q. 11 A. 12 13 Q. 14 A. 15 16 17 18 19 20 21 where I assist private and public sector clients in the areas of energy-related economic and policy analysis, including evaluation of electrc and gas utilty rate matters. Prior to joining Energy Strategies, I held policy positions in state and local governent. From 1983 to 1990, I was economist, then assistat director, for the Uta Energy Offce, where I helped develop and implement state energy policy. From 1991 to 1994, I was chief of staf to the chairman of the Salt Lake County Commission, where I was responsible for development and implementation of a broad spectr of public policy at the local governent leveL. Have you ever testied before this Commission? Yes. I testified in Idao Power's 2003 general rate case, Case No. IPC-E- 03-13. Have you testified before utilty regulatory commissions in other states? Yes. I have testified in over eighty proceedings on the subjects of utilty rates and reguatory policy before state utilty regulators in Alaska, Arkansas, Arzona, Colorado, Georgia, Ilinois, Indiana, Kansas, Kentucky, Michigan, Missour, Minnesota, Montaa, Nevada, New Mexico, New York, Ohio, Oklahoma, Oregon, Pennsylvana, South Carolina, Uta, Washington, Virginia, West Virginia, and Wyoming. A more detaled description of my qualifications is contaned in Attchment A, attched to ths testimony. 3 Higgins, DI Kroger Co. dba Fred Meyer & Smiths .. 1 Overview and conclusions 2 Q. 3 A. 4 5 6 7 Q. 8 9 A. 10 11 12 13 14 15 16 17 18 19 20 21 What is the purpose of your testimony in this proceeding? My testimony addresses the rate design for Idaho Power's Schedule 9, Large General Service. As par of ths testimony, I offer rate design recommendations to the Commission in support of a just and reasonable outcome in ths proceeding. What conclusions have you reached in your analysis of Idaho Power's rate design for Schedule 9? I recommend that Schedule 9 customers tang service at either primar or transmission voltage be allowed to migrate to Schedule 19 in order to have the opportty to tae service under tIme-of-use ("TOU") rates, 1 an opportty that is not otherwse available to Schedule 9 customers either under the curent or proposed taff. Unlike seconda voltage customers, Schedule 9-P and 9- T customers already have the meterig in place to faciltate TOU pricing; consequently, my proposal focuses on makng TOU rates available to priar and transmission voltage customers. Addressing ths issue now is timely. The question of extending TOU rates to Schedule 9 customers was raised in the 2003 general rate proceedig, and the matter was deferred to a later date. In Order No. 29505, issued May 25, 2004, the Commssion concluded its discussion of extending TOU rates to Schedule 9 customers by stating: 1 Alternatively, the energy rates for Schedule 9 customers taking servce either at priar or trmission servce could be set equal to the Schedule 19 energy rate for the corresponding voltage, an option that I discuss later in my testimony. 4 Higgns, DI Kroger Co. dba Fred Meyer & Smiths 1 . . . we anticipate that afer the Company has gaied experience with its 2 Schedule 19 rates, it will tu its attention to designg and proposing a 3 TOU rate strctue for Rate 9.2 4 5 The curent proceeding is the second general rate fiing made by Idaho 6 Power since the issuance of Order 29505, and the Company ha yet to put forward 7 any proposals to design or propose TOU rates for Schedule 9 customers. In light 8 of the absence of action by the Company on ths issue, my rate migration proposal 9 provides the most reasonable mean to extend the availabilty of TOU rates to 10 Schedule 9 customers at this time. 11 A migration of Schedule 9- P and 9- T customers to Schedule 19 is greatly 12 faciltated by the fact that the service charges, basic charges, and non-sumer 13 demand chages for Schedules 9 and 19 are identical. The sumer demand 14 charges are also identical, except that the Schedule 19 sumer demand charge is 15 divided into an on-peak and a non-peak component (the sum of which is equa to 16 the Schedule 9 sumer demand charge). These circumstaces provide for a 17 smooth transition from Schedule 9 to Schedule 19 both for customers and Idao 18 Power if Schedule 9 customers are permtted to migrate as I propose. Furer, 19 Idaho Power's cost-of-servce study demonstrates that the unt cost of energy for 20 servg Schedule 9-P and Schedule 19-P is virtly identical. Thus, the proposal I 21 am makg has a sound basis with respect to cost of service. 2 Idao Public Utilties Commission, Case No. IPC-E-03-12, Order No. 29595, pp. 59-60. 5 Higgins, DI Kroger Co. dba Fred Meyer & Smiths 1 Backgound 2 Q.Your proposal addresses Schedule 9. Please describe the type of service that 3 is available under this rate schedule. 4 A.Schedule 9, Large General Servce, is generally available to customers 5 with monthy energy usage in excess of 2,000 kilowatt-hours and biling demands 6 less than 1,000 kilowatts. The rate schedule contains pricing provisions for 7 service taen at seconda voltage (9-S), primar voltage (9-P), and transmission 8 voltage (9- T). 9 In the Idao Power taff, Schedule 9 is situted between Schedules 7 and 10 19. Non-residential customers with energy usage less than 2,000 kilowatt-hours 11 per month are generally served under Schedule 7, Small General Service, whereas 12 customers with billng demands of 1,000 kilowatts or more generally tae servce 13 under Schedule 19, Large Power Servce. 14 Q.How are Schedule 9 rates structured? 15 A.All of the Schedule 9 rate components are differentiated by voltage 16 (seconda, priar, and transmission). These rate components are comprised of: 17 (1) a service charge, which is a monthy customer charge; (2) a basic charge 18 which a biled on a demand basis; (3) a seasonally-differentiated demand charge; 19 and (4) an energy charge that also is seasonaly-differentiated.3 In addition, 20 Schedule 9 customers pay the Company's Power Cost Adjustment as computed in 21 Schedule 55. The power Cost Adjustment is not differentiated by voltage. 22 Q.How does the design of Schedule 9 compare with that of Schedule 19? 3 For secondar voltage customers, the energy charge has a two-block strctue (which has no bearg on my proposal). 6 Higgins, DI Kroger Co. dba Fred Meyer & Smiths 1 A. 2 3 4 5 6 7 8 9 10 11 12 13 Q. 14 15 A. 16 17 Q. 18 19 A. 20 21 22 With the exception of the energy charge, the two rate schedules are nearly identical. Schedules 9 and 19 have the same service charges, basic charges, and non-sumer demand charges. The sumer demand charges are also identical, except that the Schedule 19 sumer demand charge is divided into an on-peak and a non-peak component (the sum of which is equa to the Schedule 9 sumer demand charge).4 The big difference between the two rate schedules occurs in the design of the energy charge. The Schedule 9 energy charge has no TOU price differentiation. It is a flat energy charge that does not var with the hour of the day in which energy is consumed. In contrast, the Schedule 19 energy charge is differentiated into thee time periods in the sumer (on-peak, mid-peak, and off- peak) and two time periods in the non-sumer (mid-peak and off-peak). Are the design similarities between Schedules 9 and 19 in current rates proposed to continue under Idaho Power's proposed rates? Yes, although the demand charges for secondar voltage are no longer identical under the proposed rates. What action was taken with respect to TOU rates in Idaho Power's 2003 general rate case, IPC-E-03-13? As par of its general rate case filing in 2003, Idaho Power proposed the adoption of mandatory TOU rates mandatory for Schedule 19. The Company, argued that such rates would send improved price signals to customers. Ths recommendation was approved by the Commission in Order No. 29505. 4 The Schedule 9 demand charge does not apply to the fit 20 kW of biling demand, as these demand- related revenues being recovered in the fist energy block. 7 Higgins, DI Kroger Co. dba Fred Meyer & Smiths 1 2 3 4 5 6 7 8 9 10 11 12 13 Q. 14 15 16 A. 17 18 19 20 21 In that proceeding, I supported the Company's TOU proposal for Schedule 19. In addition, I recommended adoption ofa volunta TOU option for Schedule 9 that would offer energy prices that were differentiated by the same time periods proposed for Schedule 19. Idaho Power opposed my recommendation, argug that TOU rates for Schedule 19 should fist be implemented and evaluated prior to offering TOU rates to Schedule 9 customers. In Order No. 29505, the Commssion stated it was persuaed by the Company's rebuttl arguents to my proposal and therefore did not require TOU rates for Schedule 9 customers.s However, as I noted above, the Commission went on to state it anticipated that after Idaho Power gained experience with the Schedule 19 TOU rates, "the Company will tu its attention to designg and proposing a TOU rate strctue for Rate 9." 6 In the 2003 general rate case, did Idaho Power offer any guidance to the Commission if the Commissioii were to decide to extend TOU rates to Schedule 9 customers at that time? Yes. Although Idaho Power opposed my recommendation to extend TOU rate to Schedule 9 customers, the Company did go on to recommend that, if the Commission were to adopt TOU rates for Schedule 9 customers in that proceeding, the application be limited to priar and tranmission servce customers. The reason offered by the Company for ths limitation was that these customers had the metering in place to faciltate TOU pricing. 7 5 Idao Public Utilities Commission, Case No. IPC-E-03-12, Order No. 29595, pp. 59-60. 6 Idao Public Utilties Commission, Case No. IPC-E-03-12, Order No. 29595, pp. 59-60. 7 Case No. IPC-E-03-12, Rebuttl testimony of Maggie Brilz p. 20, line 13 -po 21, line 1. 8 Higgins, DI Kroger Co. dba Fred Meyer & Smiths 1 Q. 2 3 A. 4 5 6 Have you taken this information into account in your recommendation in this proceeding? Yes. As I indicated previously, my proposal to allow Rate 9 customers to migrate to Schedule 19 is limted to primar and transmission servce customers, consistent with Idao Power's recommendation in the 2003 general rate case. 7 Benefits of TOU pricing 8 Q. 9 A. 10 11 12 13 14 15 16 Q. 17 18 A. 19 20 21 22 What are the benefits ofTOU pricing? Energy costs var across the hours of the day, with the most expensive hours tyically occurg from the late mornng to early evening. Designng the energy price to end-use customers to reflect these varations in energy costs sends the proper signal to customers regarding the relative cost to operate the system durg the peak, mid-peak, and off-peak hours. Customers would then use ths pricing information to alter their discretionar patterns of usage, increasing effciency and lowering the overall cost of energy to the system. Are there other reasons besides economic effciency to make TOU rates available to Schedule 9-P and 9- T customers? Yes. In addition to providing these customers with an incentive to better respond to price signals, TOU rates will ensure that these customers pay rates that are more closely aligned with the costs they cause. Basic fairness dictates that customers whose patterns of energy consumption are less expensive to serve because of their load pattern should see that lower cost reflected in their bils. 9 Higgs, DI Kroger Co. dba Fred Meyer & Smiths 1 2 3 4 5 6 Q. 7 8 A. 9 10 11 12 13 14 15 16 17 18 19 Q. 20 21 A. 22 23 24 The curent failure to offer TOU rates to Schedule 9 customers deprives these customers of the opportty to reduce their power costs by responding to improved price signals. At the same time, it deprives the system of the benefit of a more effcient load pattern that would result from improving the price-responsive behavior of these customers. Does the Energy Policy Act of 2005 require utities to expand the availabilty ofTOU rates? Yes. Section 1252 of the Act conta a passage that states as follows: Not later than 18 months afer the date of the enactment of ths paragraph, each electrc utilty shall offer each of its customer classes, and provide individua customers upon customer request, a time-based rate schedule under which the rate charged by the electrc utilty vares durg different time periods and reflects the varance, if any, in the utilty's costs of generating and purchasing electrcity at the wholesale leveL. The time- based rate schedule shall enable the electrc consumer to manage energy use and cost though advanced metering and communcations technology.s Adoption of my recommendation would fuher ths objective in Idaho. Are time-of-use rates widely available for customers of comparable size to Schedule 9 in other western states? Yes. Time-of-use rates are widely available thoughout the West for customers of comparable size to Schedule 9. Table KCH-l below is a list of other western utilties that offer time-of-use rates to customers with biling demands of 1,000 kW ofless, comparable to Schedule 9. 8 Energy Policy Act of2005, Sec. 1252. I note that this section also requires state regulatory authonties to conduct an investigation and issue a decision as to whether it is appropnate .to implement these and other stadads in the Act. Higgins, DI Kroger Co. dba Fred Meyer & Smiths 10 1 2 Table KCH-l 3 Western Utilities with Time-of-Use Rates for Commercial Customers with 4 Biling Demands of 1,000 kW or less 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 State Utilty Type Arzona Arzona Public Service Optional Arzona Salt River Project Optional Arzona Tucson Electrc Power Optional Californa LADWP Optional ..500 kW Californa LADWP Mandatory :;500 kW Californa LADWP Pilot Real Time :;500 Californa Pacific Power Mandatory :;500 kW Californa PG&E Optiona":500 kW Californa PG&E Mandatory :;500 kW Californa SDG&E Mandatory Californa So. Cal. Edison Mandatory Californa SMU Mandatory Colorado Public Service Colorado Optional :;300 kW Idaho Rocky Mountain Power Optional Montaa Montaa Dakota Utilties Optional Nevada Nevada Power Optional ..300kW Nevada Nevada Power Mandatory :;300kW Nevada Sierra Pacific Power Mandatory :;500 kW New Mexico PNM Mandatory :;500 kW Oregon Portland General Electrc Optiona Uta Rocky Mountan Power Optional 38 39 Proposal for extending TOU rates to Schedule 9-P and 9- T customers 40 Q.Please describe your proposal for extending TOU rates to customers on 41 Schedule 9-P and 9-T. 11 Higgs, DI Kroger Co. dba Fred Meyer & Smiths 1 A.My proposal is very straightforward. I am recommending that Schedule 9 2 customers who are tag service at either primar or transmission voltage be 3 allowed to migrate to Schedule 19 in order to have the opportty to tae servce 4 under time-of-use ("TOU") rates, an opportty that is not otherwse available to 5 these customers either under the curent or proposed taff. Unlike secondar 6 voltage customers, Schedule 9-P and 9- T customers already have the metering in 7 place to faciltate TOU pricing; consequently, my proposal focuses on makng 8 TOU rates available to these two groups of customers. 9 Q.Should this migration be voluntary or mandatory? 10 A.I believe it would be desirable to permt this migration to occur on as 11 broad a basis as possible, yet there are several varations on eligibilty that are 12 withn the range of reasonableness. These reasonable alternatives include: (1) 13 mandatory migration to Schedule 19 for all Schedule 9-P and 9-T customers; (2) 14 volunta migration for any Schedule 9-P and 9-T customers; (3) mandatory 15 migration for all 9-P and 9- T customers with multiple accounts having an 16 aggregate load of 1,000 kilowatts or greater; or (4) volunta migration for any 9- 17 P and 9-T customer with multiple accounts having an aggregate load of 1,000 18 kilowatts or greater. I will discuss each of these options in tu. 19 Q.Please proceed. What are the advantages of a mandatory migration to 20 Schedule 19 for all Schedule 9-P and 9- T customers? 21 A.Mandatory migration has the advantage of providing the widest possible 22 exposure to TOU rates for these customers. For ths reason, I consider this option 12 Higgin, DI Kroger Co. dba Fred Meyer & Smiths 2 3 Q. 4 5 A. 6 7 8 9 10 11 12 13 14 15 16 Q. 17 18 A. 19 20 21 22 23 to be the most attactive of the four I identified. I note that the establishment of TOU rates for Schedule 19 was also implemented on a mandatory basis. What are the advantages of permittg a voluntary migration from Schedules 9-P and 9- T to Schedule 19? I recognze that some customers may not wish to migrate to Schedule 19. If that is the case, and if concerns over mandatory migration create an impediment to extension ofTOU rates to Schedule 9-P and 9-T customers, then I recommend that volunta migration be offered as a second-best solution. A volunta migration would at least provide a TOU option to Schedule 9-P and 9-T customers, a vast improvement over the curent sitution. I caution, though, that if a volunta program is adopted, it is essential that the TOU rate design provide an opportty for paricipating customers to reduce their power bils. My proposal will accomplish ths. Alternative TOU rate designs may not. A volunta program that does not provide paricipants the opportty to reduce their bils will be an empty exercise with no paricipating customers. Why do you propose the option of linkig migration to customers having multiple accounts with an aggregate load of 1,000 kilowatts or greater? Schedule 19 is generally available to customers with demands of 1,000 kilowatts or greater. In the event the Commission is reluctat to extend Schedule 19 pricing to the smaller Schedule 9- P and 9- T customers, then I suggest that Schedule 9-P and 9-T customers with multiple accounts be allowed to aggregate their loads to 1,000 kilowatts or greater in order to quaify for the Schedule 19 rate. In suggesting ths option, I am not proposing that there be any change in the 13 Higgin, DI Kroger Co. dba Fred Meyer & Smiths 1 2 3 4 5 Q. 6 7 8 9 A. 10 11 12 13 14 15 16 monthy service charge (or other applicable charges) for each individua account - I am merely proposing that aggregation can be a viable mechansm for quaifying for Schedule 19. Under ths option, each customer account would still be biled individualy for service. You have structured your proposal in terms of allowing Schedule 9-P and 9- T customers to migrate to Schedule 19. Can your proposal also be implemented through simply changing the . energy rates for Schedules 9-P and 9-T? Yes. Under my proposal, the TOU rates for Schedule 9-P and 9-T customers would be identical to the Schedule 19 rates of corresponding voltage. Hence, my proposal could also be implemented by modifying Schedules 9-P and 9-T to offer (or mandate) TOU rates that are identical to those of Schedule 19. The choice of whether to accomplish this objective though rate schedule migration or simply by changing the rates in Schedules 9- T and 9-P is a matter of administrative preference. 17 Cost-of-Service Basis for TOU Proposal 18 Q. 19 A. Is your proposal reasonable on a cost-of-service basis? Yes. Idaho Power's cost-of-service study demonstrtes that there is no 20 material difference in the unt energy costs to serve Schedules 9-P and 19-P. Ths 21 is shown in Idaho Power Exhbit No. 54, pp. 4-5, lines 300 and 480, the results of 22 which are sumarzed in Table KCH-2, below. The same Company analysis also 23 shows that as the unt demand costs for serving Schedule 9-P are generally lower 14 Higgins, DI Kroger Co. dba Fred Meyer & Smiths 1 than that of 19-P, even though both rate schedules have the same demand charges. 2 (See colums G, H and L in the cited exhbit.) Thus, from a cost-of-service 3 perspective, the case for allowing Schedule 9-P customers to utilze the sae 4 TOU energy rates as Schedule 19-P is compelling. 56 Table KCH-2 7 Comparison of Unit Cost of Service for Schedule 9-P and 19_p9 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Schedule 9-P Schedule 19-P Rate Component (Unit cost)(Unit cost) Sumer energy ($/kWh)$.030203 $.030130 Non-sumer energy ($/kWh)$.024822 $.024830 Sumer demand ($/kW)$3.62567 $3.98177 Non-sumer demand ($/kW)$2.87796 $3.20943 Basic ($/kW)$0.99970 $0.99515 Servce ($/customer/month)$540.33 $580.36 23 Revenue implications 24 Q.Are there revenue implications for allowing Schedule 9 customers to migrate 25 to Schedule 19? 26 A.As the service charges, basic charges, and demand charges are either 27 identical or nearly identical for Schedule 9 and Schedule 19 for primar and 28 transmission servce, there should be no revenue implications from my migration 29 proposal with respect to these biling components. With respect to the energy 30 portion of the rate, the revenue implications appear to be unown at ths time, 31 based on data responses to Kroger from Idao Power. However, as ths is a 9 Source: Idao Power Exhbit No. 54, pp. 4-5, lines 300 and 480. 15 Higgins, DI Kroger Co. dba Fred Meyer & Smiths 1 general rate case, any revenue implications can be addressed with the 2 framework of ths proceeding. For example, if as a result of ths proceeding, the 3 revenue requirement for Schedule 9 is reduced from the level proposed by Idaho 4 Power's, a portion of the reduction could be eararked for recovery of revenue 5 erosion associated with the establishment of TOU rates. Alternatively, if a 6 volunta TOU program is adopted, recovery of revenue erosion could be 7 allocated to the rates of Schedule 9 non- TOU-paricipants, as ths subset of 8 customers would generally have a higher cost of service than those who would 9 benefit from paricipation. 10 11 Q.Does this conclude your direct testimony? 12 A.Yes, it does. 16 Higgins, DI Kroger Co. dba Fred Meyer & Smiths BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR AUTHORITY ) TO INCREASE ITS RATES AND CHARGES FOR ) ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN )THE STATE OF IDAHO ) AFFIDAVIT OF KEVIN C. HIGGINSSTATE OF UTAH ) ) COUNTY OF SALT LAKE ) Case No. IPC-E-07-8 Kevin C. Higgins, being first duly sworn, deposes and states that: 1. He is a Principal with Energy Strategies, L.L.C., in Salt Lake City, Utah; 2. He is the witness who sponsors the accompanying testimony entitled "Direct Testimony of Kevin C. Higgins;" 3. Said testimony was prepared by him and under his direction and supervision; 4. If inquiries were made as to the facts and schedules in said testimony he would respond as therein set fort; and 5. The aforesaid testimony and schedules are true and correct to the best of his knowledge, information and belief. ~~~Ke"n ~Jlgg;-~ Subscribed and sworn to or affirmed before me this f! day of December, 2007, by Kevin C. Higgins. My Commission Expires:tlLWl1 i t~Q-~ Notary Public r-----li""- .....1E iitt.........-,I 81'-_...M1.. "'~lOr IDi _.I'------- Atthment A Page 1 of 16 KEVI C. mGGINS Principal, Energy Strategies, L.L.C. 215 South State St., Suite 200, Salt Lake City, UT 84111 Vitae PROFESSIONAL EXPERIENCE Principal, Energy Strategies, L.L.C., Salt Lake City, Uta, Janua 2000 to present. Responsible for energy-related economic and policy analysis, reguatory intervention, and strategic negotiation on behalf of industral, commercial, and public sector interests. Previously Senior Associate, Febru 1995 to December 1999. Adjunct Instrctor in Economics, Westminster College, Salt Lake City, Uta, September 1981 to May 1982; September 1987 to May 1995. Taught in the economics and M.B.A. programs. Awarded Adjunct Professor of the Year, Gore School of Business, 1990-91. Chief of Staf to the Chaian, Salt Lake County Board of Commssioners, Salt Lake City, Utah, Janua 1991 to Janua 1995. Senior executive responsibilty for all matters of county governent, including formulation and execution of public policy, delivery of approximately 140 governent services, budget adoption and fiscal management (over $300 millon), strategic planng, coordination with elected officials, and communcation with consultats and media. Assistat Director, Uta Energy Office, Uta Deparent of Natual Resources, Salt Lake City, Uta, August 1985 to Januar 1991. Directed the agency's resource development section, which provided energy policy analysis to the Governor, implemented state energy development policy, coordiated state energy data collection and dissemiation, and managed energy technology demonstration programs. Position responsibilties included policy formulation and implementation, design and admstration of energy technology demonstration programs, strategic management of the agency's interventions before the Uta Public Service Commission, budget preparation, and staf development. Supervised a staf of economists, engineers, and policy analysts, and served as lead economist on selected projects. Utilty Economist, Uta Energy Office, Janua 1985 to August 1985. Provided policy and economic analysis pertnig to energy conservation and resource development, with an emphasis on utilty issues. Testified before the state Public Service Commssion as an expert witness in cases related to the above. Acting Assistat Director, Uta Energy Office, June 1984 to Janua 1985. Same responsibilties as Assistat Director identified above. 1 Attchment A Page 2 of 16 Research Economist, Uta Energy Offce, October 1983 to June 1984. Provided economic analysis pertning to renewable energy resource development and utilty issues. Experience includes preparation of testimony, development of strategy, and appearance as an expert witness for the Energy Offce before the Uta PSC. Operations Research Assistat, Corporate Modeling and Operations Research Deparent, Uta Power and Light Company, Salt Lake City, Utah, May 1983 to September 1983. Priar area of responsibilty: designg and conducting energy load forecasts. Instrctor in Economics, University of Uta, Salt Lake City, Uta, Janua 1982 to April 1983. Taught intermediate microeconomics, priciples of macroeconomics, and economics as a social science. Teacher, Vernon-Verona-Sherrll School Distrct, Verona, New York, September 1976 toJune 1978. EDUCATION Ph.D. Candidate, Economics, University of Uta (coursework and field exams completed, 1981). Fields of Specialization: Public Finance, Urban and Regional Economics, Economic Development, International Economics, History of Economic Doctrnes. Bachelor of Science, Education, State University of New York at Plattsburgh, 1976 (cum laude). Dansh International Studies Program, University of Copenhagen, 1975. SCHOLARIDPS AND FELLOWSHIPS University Research Fellow, University of Uta, Salt Lake City, Uta 1982 to 1983. Research Fellow, Institute of Human Resources Management, University of Uta, 1980 to 1982. Teaching Fellow, Economics Deparment, University of Uta, 1978 to 1980. New York State Regents Scholar, 1972 to 1976. 2 Attchment A Page 3 of16 EXPERT TESTIMONY "In The Matter of the Application of Consumers Energy Company for Authority to Increase Its Rates for the Generation and Distrbution Of Electrcity and Oter Relief," Michigan Public Service Commission, Case No. U-15245. Direct testimony submitted November 6, 2007. Rebuttal testimony submitted November 20,2007. "In the Matter of Montaa-Dakota Utilties Co., Application for Authority to Establish Increased Rates for Electrc Servce," Montana Public Service Commission, Docket No. D2007. 7.79. Direct testimony submitted October 24,2007. "In the Matter of the Application of Public Service Company of New Mexico for Revision of its Retal Electrc Rates Pursuant to Advice Notice No. 334," New Mexico Public Reguation Commission, Case No. 07-0077-UT. Direct testimony submitted October 22,2007. Rebutt testimony submitted November 19,2007. "In The Matter of Georgia Power Company's 2007 Rate Case," Georgia Public Servce Commssion, Docket No. 25060-U. Direct testimony submitted October 22,2007. Cross examined November 7, 2007. "In the Matter of the Application of Rocky Mountain Power for an Accounting Order to Defer the Costs Related to the MidAerican Energy Holdings Company Transaction," Utah Public Service Commission, Docket No. 07-035-04; "In the Matter of the Application of Rocky Mounta Power, a Division ofPacifiCorp, for a Deferred Accounting Order To Defer the Costs of Loans Made to Grd West, the Regional Transmission Organzation," Docket No. 06-035-163; "In the Matter of the Application of Rocky Mounta Power for an Accounting Order for Costs related to the Flooding of the Powerdale Hydro Facilty," Docket No. 07-035-14. Direct testimony submitted September 10, 2007. Surebuttal testimony submitted October 22,2007. Cross examed October 30, 2007. "In the Matter of General Adjustment of Electrc Rates of East Kentucky Power Cooperative, Inc.," Kentucky Public Service Commission, Case No. 2006-00472. Direct testimony submitted July 5, 2007. "In the Matter ofthe Application of Sempra Energy Solutions for a Certificate of Convenience and Necessity for Competitive Retal Electrc Service," Ariona Corporation Commission, Docket No. E-03964A-06-0168. Direct testimony submitted July 3, 2007. "Application of Public Service Company of Oklahoma for a Determination that Additiona Electrc Generating Capacity Wil Be Used and Usefu," Oklahoma Corporation Commission, Cause No. PUD 200500516; "Application of Public Service Company of Oklahoma for a Determination that Additional Baseload Electrc Generating Capacity Wil Be Used and Usefu," Cause No. PUD 200600030; "In the Matter ofthe Application of Oklahoma Gas and Electrc 3 Atthment A Page 4 of 16 Company for an Order Granting Pre-Approval to Constrct Red Rock Generating Facilty and Authorizing a Recovery Ridèr," Cause No. PUD200700012. Responsive testimony submitted May 21,2007. Cross examined July 26,2007. "Application of Nevad Power Company for Authority to Increase Its Anua Revenue Requiement for General Rates Charged to All Classes of Electrc Customers and for Relief Properly Related Thereto," Public Utilties Commission of Nevada, Docket No. 06-11022. Direct testimony submitted March 14,2007 (phae III - revenue requiements) and March 19, 2007 (Phase IV - rate design). Cross examined April 10,2007 (Phase III - revenue requiements) and April 16, 2007 (Phase IV - rate design). "In the Matter of the Application of Entergy Arkansas, Inc. for Approval of Changes in Rates for Retal Electric Service," Arkansas Public Service Commssion, Docket No. 06-101-U. Direct testimony submitted Febru 5, 2007. Surebutt testimony submitted March 26,2007. "Monongahela Power Company and The Potomac Edison Company, both d//a Allegheny Power - Rule 42T Application to Increase Electrc Rates and Charges," Public Service Commission of West Virginia, Case No. 06-0960-E-42T; "Monongahela Power Company and The Potomac Edison Company, both d//a Allegheny Power - Inormation Requied for Change of Depreciation Rates Pursuant to Rule 20," Case No. 06-1426-E-D. Direct and rebutt testimony submitted Janua 22,2007. "In the Matter of the Tarffs of Aquila, Inc., d//a Aquila Networks-MPS and Aquila Networks- L&P Increasing Electrc Rates for the Services Provided to Customers in the Aquila Networks- MPS and Aquila Networks-L&P Missour Service Areas," Missouri Public Service Commission, Case No. ER-2007-0004. Direct testimony submitted Janua 18,2007 (revenue requiements) and Janua 25,2007 (revenue apportionment). Supplemental direct testimony submitted Febru 27,2007. "In the Matter of the Filing by Tucson Electrc Power Company to Amend Decision No. 62103, Ariona Corporation Commission, Docket No. E-01933A-05-0650. Direct testimony submitted Janua 8, 2007. Surebutt testimony filed Febru 8, 2007. Cross examined March 8, 2007. "In the Matter of Union Electrc Company d//a AmerenUE for Authority to File Tarffs Increasing Rates for Electrc Service Provided to Customers in the Company's Missour Service Area," Missouri Public Servce Commssion, Case No. ER-2007-0002. Direct testimony submitted December 15,2006 (revenue requiements) and December 29,2006 (fuel adjustment clause/cost-of-service/rate design). Rebutt testimony submitted Febru 5, 2007 (cost-of- service). Surebuttl testimony submitted Febru 27,2007. Cross examined March 21,2007. 4 Atthment A Page 5 of16 "In the Matter of Application of The Union Light, Heat and Power Company d//a Duke Energy Kentucky, Inc. for an Adjustment of Electrc Rates," Kentucky Public Servce Commssion, Case No. 2006-00172. Direct testimony submitted September 13,2006. "In the Matter of Appalachian Power Company's Application for Increase in Electrc Rates," Virgiia State Corporation Commission, Case No. PUE-2006-00065. Direct testimony submitted September 1,2006. Cross examned December 7,2006. "In the Matter of the Application of Arzona Public Servce Company for a Hearg to Determne the Fai Value of the Utilty Propert for Ratemakng Puroses, to Fix a Just and Reasonable Rate of Retu Thereon, To Approve Rate Schedules Designed to Develop Such Retu, and to Amend Decision No. 67744, Ariona Corporation Commssion," DocketNo. E-01345A-05- 0816. Direct testimony submitted Augut 18,2006 (revenue requirements) and September 1, 2006 (cost-of-service/rate design). Surebutt testimony submitted September 27,2006. Cross examined November 7,2006. "Re: The Tarff Sheets Filed by Public Service Company of Colorado with Advice Letter No 1454 - Electrc," Colorado Public Utilties Commssion, Docket No. 06S-234EG. Answer testimony submitted August 18, 2006. "Portland General Electrc General Rate Case Filng," Public Utilty Commission of Oregon, Docket No. UE-180. Direct testimony submitted Augut 9, 2006. Joint testimony regarding stipulation submitted August 22, 2006. "2006 Puget Sound Energy General Rate Case," Washington Utilties and Transporttion Commssion, Docket Nos. UE-060266 and UG-060267. Response testimony submitted July 19, 2006. Joint testimony regardig stipulation submitted August 23, 2006. "In the Matter ofPacifiCorp, dba Pacific Power & Light Company, Request for a General Rate Increase in the Company's Oregon Anual Revenues," Public Utilty Commssion of Oregon, Docket No. UE-179. Direct testimony submitted July 12, 2006. Joint testimony regardig stipulation submitted August 21, 2006. "Petition of Metropolita Edison Company for Approval of a Rate Transition Plan," Pennsylvania Public Utilties Commission, Docket Nos. P-00062213 and R-00061366; "Petition of Pennsylvana Electrc Company for Approval of a Rate Transition Plan," Docket Nos. P- 0062214 and R-00061367; Merger Savigs Remand Proceeding, Docket Nos. A-I10300F0095 and A-I10400F0040. Direct testimony submitted July 10,2006. Rebutt testimony submitted August 8, 2006. Surebutt testimony submitted August 18, 2006. Cross examed August 30, 2006. 5 Attchment A Page 6 of16 "In the Matter of the Application ofPacifiCorp for approval of its Proposed Electrc Rate Schedules & Electrc Servce Reguations," Utah Public Service Commission, Docket No. 06- 035-21. Direct testimony submitted June 9, 2006 (Test Period). Surebutt testimony submitted July 14, 2006. "Joint Application of Questa Gas Company, the Division of Public Utilties, and Uta Clean Energy for the Approval of the Conservation Enabling Tarff Adjustment Option and Accounting Orders," Utah Public Service Commission, Docket No. 05-057-T01. Direct testimony submitted May 15,2006. Rebutt testimony submitted August 8, 2007. Cross examed September 19, 2007. "Central Ilinois Light Company d//a AmerenCILCO, Central Ilinois Power Company d//a AmerenCIPS, Ilinois Power Company d//a AmerenIP, Proposed General Increase in Rates for Delivery Servce (Tarffs Filed December 27,2005)," Illinois Commerce Commssion, Docket Nos. 06-0070, 06-0071, 06-0072. Direct testimony submitted March 26,2006. Rebutt testimony submitted June 27, 2006. "In the Matter of Appalachian Power Company and Wheeling Power Company, both dba American Electrc Power," Public Service Commission of West Virginia, Case No. 05-1278-E- PC-PW-42T. Direct and rebuttl testimony submitted March 8, 2006. "In the Matter of Nortern States Power Company d//a Xcel Energy for Authority to Increase Rates for Electrc Service in Minnesota," Minnesota Public Utilties Commission, Docket No. G-002/GR-05-1428. Direct testimony submitted March 2, 2006. Rebuttl testimony submitted March 30, 2006. Cross examined April 25, 2006. "In the Matter of the Application of Arzona Public Service Company for an Emergency Interi Rate Increase and for an Interi Amendment to Decision No. 67744," Ariona Corporation Commission, Docket No. E-01345A-06-0009. Direct testimony submitted Febru 28,2006. Cross examined March 23,2006. "In the Matter of the Applications of We sta Energy, Inc. and Kansas Gas and Electrc Company for Approval to Make Certn Changes in Their Chages for Electrc Servce," State Corporation Commission of Kansas, Case No. 05-WSEE-981-RTS. Direct testimony submitted September 9, 2005. Cross examed October 28,2005. "In the Matter of the Application of Columbus Southern Power Company and Ohio Power Company for Authority to Recover Costs Associated with the Constrction and Ultimate Operation of an Integrated Combined Cycle Electrc Generating Facilty," Public Utilties Commssion of Ohio," Case No. 05-376-EL-UNC. Direct testimony submitted July 15,2005. Cross examned August 12, 2005. 6 Atthment A Page 70f16 "In the Matter of the Filng of General Rate Case Inormation by Tucson Electrc Power Company Pursuat to Decision No. 62103," Ariona Corporation Commssion, Docket No. E- 01933A-04-0408. Direct testimony submitted June 24,2005. "In the Matter of Application of The Detroit Edison Company to Unbundle and Realign Its Rate Schedules for Jursdictional Retal Sales of Electrcity," Michigan Public Service Commssion, Case No. U-14399. Direct testimony submitted June 9, 2005. Rebutt testimony submitted July 1,2005. "In the Matter of the Application of Consumers Energy Company for Authority to Increase Its Rates for the Generation and Distrbution of Electrcity and Other Relief," Michigan Public Service Commission, Case No. U-14347. Direct testimony submitted June 3, 2005. Rebutt testimony submitted June 17,2005. "In the Matter of Pacific Power & Light, Request for a General Rate Increase'in the Company's Oregon Anua Revenues," Public Utility Commssion of Oregon, Docket No. UE 170. Direct testimony submitted May 9,2005. Surebuttl testiony submitted June 27, 2005. Joint testimony regarding parial stipulations submitted June 2005, July 2005, and August 2005. "In the Matter of the Application of Trico Electrc Cooperative, Inc. for a Rate Increase," Ariona Corporation Commssion, Docket No. E-01461A-04-0607. Direct testimony submitted April 13,2005. Surebutt testimony submitted May 16,2005. Cross examined May 26,2005. "In the Matter of the Application ofPacifiCorp for Approval of its Proposed Electrc Service Schedules and Electrc Service Reguations," Utah Public Servce Commssion, Docket No. 04- 035-42. Direct testimony submitted Janua 7,2005. "In the Matter of the Application by Golden Valley Electrc Association, Inc., for Authority to Implement Simplified Rate Filing Procedures and Adjust Rates," Reguatory Commission of Alaska, Docket No. U-4-33. Direct testimony submitted November 5, 2004. Cross examined Febru 8, 2005. "Advice Letter No. 1411 - Public Service Company of Colorado Electrc Phase II General Rate Case," Colorado Public Utilties Commission, Docket No. 04S-164E. Direct testimony submitted October 12,2004. Cross-answer testimony submitted December 13,2004. Testimony withdrawn Janua 18,2005, followig Applicant's withdrawal oftestimony pertning to TOU rates. 7 Attchment A Page 8 of16 "In the Mattr of Georgia Power Company's 2004 Rate Case," Georgia Public Service Commssion, Docket No. 18300-U. Direct testimony submitted October 8, 2004. Cross examined October 27, 2004. "2004 Puget Sound Energy General Rate Case," Washington Utilties and Transporttion Commssion, Docket Nos. UE-040641 and UG-040640. Response testimony submitted September 23,2004. Cross-answer testimony submitted November 3,2004. Joint testimony regarding stipulation submitted December 6, 2004. "In the Matter of the Application of PacifiCorp for an Investigation of Interjursdictional Issues," Utah Public Service Commssion, Docket No. 02-035-04. Direct testimony submitted July 15, 2004. Cross examined July 19,2004. "In the Matter of an Adjustment of the Gas and Electrc Rates, Terms and Conditions of Kentucky Utilties Company," Kentucky Public Servce Commssion, Case No. 2003-00434. Direct testimony submitted March 23,2004. Testimony withdrawn pursuat to stipulation entered May 2004. "In the Matter of an Adjustment of the Gas and Electrc Rates, Terms and Conditions of Louisvile Gas and Electrc Company," Kentucky Public Service Commission, Case No. 2003- 00433. Direct testimony submitted March 23,2004. Testimony withdrawn pursuat to stipulation entered May 2004. "In the Matter of the Application of Idaho Power Company for Authority to Increase Its Interi and Base Rates and Charges for Electrc Service," Idaho Public Utilties Commssion, Case No. IPC-E-03-13. Direct testimony submitted Febru 20,2004. Rebutt testimony submitted March 19,2004. Cross examined April 1,2004. "In the Matter of the Applications of the Ohio Edison Company, the Cleveland Electrc Iluminating Company and the Toledo Edison Company for Authority to Continue and Modify Cert Reguatory Accounting Practices and Procedures, for Tarff Approvals and to Establish Rates and Other Charges, Including Regulatory Transition Charges Following the Market Development Period," Public Utilties Commssion of Ohio, Case No. 03-2144-EL-ATA. Direct testimony submitted Febru 6, 2004. Cross examed Febru 18,2004. "In the Matter of the Application of Arzona Public Servce Company for a Hearng to Determine the Fair Value of the Utilty Propert of the Company for Ratemakg Puroses, To Fix a Just and Reasonable Rate of Retu Thereon, To Approve Rate Schedules Designed to Develop Such Retu, and For Approval of Purchased Power Contract," Ariona Corporation Commission, Docket No. E-01345A-03-0437. Direct testimony submitted Febru 3,2004. Rebutt testimony submitted March 30, 2004. Direct testimony regarding stipulation submitted 8 Atthment A Page 9 of16 September 27,2004. Responsive / Clarfyg testimony regarding stipulation submitted October 25,2004. Cross examined November 8-10, 2004 and November 29-December 3, 2004. "In the Matter of Application of the Detroit Edison Company to Increase Rates, Amend Its Rate Schedules Governg the Distrbution and Supply of Electrc Energy, etc.," Michigan Public Service Commssion, Case No. U-13808. Direct testimony submitted December 12,2003 (interim request) and March 5, 2004 (general rate case). "In the Matter ofPacifiCorp's Filing of Revised Tarff Schedules," Public Utilty Commssion of Oregon, Docket No. UE-147. Joint testimony regarding stipulation submitted August 21,2003. "Petition of PSI Energy, Inc. for Authority to Increase Its Rates and Charges for Electrc Service, etc.," Indiana Utilty Reguatory Commssion, Cause No. 42359. Direct testimony submitted August 19,2003. Cross examined November 5,2003. "In the Matter of the Application of Consumers Energy Company for a Financing Order Approvig the Securtization of Certn of its Qualified Cost," Michigan Public Service Commssion, Case No. U-13715. Direct testimony submitted April 8,2003. Cross examed April 23,2003. "In the Matter of the Application of Arzona Public Service Company for Approval of Adjustment Mechansms," Ariona Corporation Commission, Docket No. E-01345A-02-0403. Direct testimony submitted Febru 13,2003. Surebuttl testimony submitted March 20,2003. Cross examined April 8, 2003. "Re: The Investigation and Suspension of Tarff Sheets Filed by Public Service Company of Colorado, Advice Letter No. 1373 - Electrc, Advice Letter No. 593 - Gas, Advice Letter No. 80 - Steam," Colorado Public Utilties Commission, Docket No. 02S-315 EG. Direct testimony submitted November 22, 2002. Cross-answer testimony submitted Janua 24, 2003. "In the Matter of the Application of The Detroit Edison Company to Implement the Commission's Stranded Cost Recovery Procedure and for Approval of Net Stranded Cost Recovery Charges," Michigan Public Service Commission, Case No. U-13350. Direct testimony submitted November 12,2002. "Application of South Carolina Electrc & Gas Company: Adjustments in the Company's Electrc Rate Schedules and Tarffs," Public Service Commssion of South Carolina, Docket No. 2002-223-E. Direct testimony submitted November 8, 2002. Surebuttl testimony submitted November 18, 2002. Cross examned November 21, 2002. 9 Atthment A Page 10 of 16 "In the Matter of the Application of Questa Gas Company for a General Increase in Rates and Charges," Utah Public Service Commission, Docket No. 02-057-02. Direct testimony submitted August 30, 2002. Rebuttl testimony submitted October 4, 2002. "The Kroger Co. v. Dynegy Power Marketing, Inc.," Federal Energy Regulatory Commission, EL02-119-000. Confdential afdavit filed August 13,2002. "In the matter of the application of Consumers Energy Company for determation of net stranded costs and for approval of net stranded cost recovery charges," Michigan Public Service Commission, Case No. U-13380. Direct testimony submitted August 9, 2002. Rebutt testimony submitted August 30, 2002. Cross examed September 10, 2002. "In the Matter of the Application of Public Service Company of Colorado for an Order to Revise Its Incentive Cost Adjustment," Colorado Public Utilities Commission, Docket 02A-158E. Direct testimony submitted April 18, 2002. "In the Matter of the Generic Proceedings Concernng Electrc Restrctug Issues," Ariona Corporation Commission, Docket No. E-00000A-02-0051, "In the Matter of Arona Public Service Company's Request for Varance of Certn Requiements of A.A.C. RI4-2-1606," Docket No. E-01345A-OI-0822, "In the Matter of the Generic Proceeding Concernng the Arzona Independent Scheduling Admnistrator," Docket No. E-00000A-OI-0630, "In the Matter of Tucson Electrc Power Company's Application for a Varance of Certn Electrc Competition Rules Compliance Dates," Docket No. E-01933A-02-0069, "In the Matter of the Application of Tucson Electrc Power Company for Approval of its Stranded Cost Recovery," Docket No. E- 01933A-98-0471. Direct testimony submitted March 29,2002 (APS varance request); May 29, 2002 (APS Track A proceeding/market power issues); and July 28,2003 (Arzona ISA). Rebutt testimony submitted August 29,2003 (Arzona ISA). Cross examined June 21, 2002 (APS Track A proceeding/market power issues) and September 12,2003 (Arzona ISA). "In the Matter of Savanah Electrc & Power Company's 2001 Rate Case," Georgia Public Service Commission, Docket No. 14618-U. Direct testimony submitted March 15,2002. Cross examined March 28, 2002. "Nevada Power Company's 2001 Deferred Energy Case," Public Utilties Commission of Nevada, PUCN 01-11029. Direct testimony submitted Febru 7, 2002. Cross examed Febru 21,2002. "2001 Puget Sound Energy Interi Rate Case," Washington Utilties and Transporttion Commission, Docket Nos. UE-011570 and UE-011571. Direct testimony submitted Janua 30, 2002. Cross examned Febru 20, 2002. 10 Attchment A Page 11 of16 "In the Matter of Georgia Power Company's 2001 Rate Case," Georga Public Service Commission, Docket No. 14000-U. Direct testimony submitted October 12,2001. Cross examed October 24,2001. "In the Matter of the Application ofPacifiCorp for Approval of Its Proposed Electrc Rate Schedules and Electrc Service Reguations," Utah Public Servce Commssion, Docket No. 01- 35-01. Direct testimony submitted June 15,2001. Rebutt testimony submitted August 31, 2001. "In the Matter of Portland General Electrc Company's Proposal to Restrctue and Reprice Its Services in Accordance with the Provisions of SB 1149," Public Utilty Commission of Oregon, Docket No. UE-115. Direct testimony submitted Febru 20, 2001. Rebuttl testimony submitted May 4,2001. Joint testimony regarding stipulation submitted July 27,2001. "In the Matter of the Application of APS Energy Servces, Inc. for Declaratory Order or Waiver of the Electrc Competition Rules," Ariona Corporation Commssion, Docket NO.E-01933A- 00-0486. Direct testimony submitted July 24,2000. "In the Matter of the Application of Questa Gas Company for an Increase in Rates and Charges," Utah Public Service Commission, Docket No. 99-057-20. Direct testimony submitted April 19,2000. Rebutt testimony submitted May 24,2000. Surebutt testimony submitted May 31, 2000. Cross examined June 6 & 8,2000. "In the Matter of the Application of Columbus Southern Power Company for Approval of Electrc Transition Plan and Application for Receipt of Transition Revenues," Public Utilty Commssion of Ohio, Case No. 99-1729-EL-ETP; "In the Matter of the Application of Ohio Power Company for Approval of Electrc Transition Plan and Application for Receipt of Transition Revenues," Public Utilty Commssion of Ohio, Case No. 99-1730-EL-ETP. Direct testimony prepared, but not submitted pursuat to settlement agreement effected May 2,2000. "In the Matter of the Application of FirstEnergy Corp. on Behalf of Ohio Edison Company, The Cleveland Electrc Ilumnating Company, and the Toledo Edison Company for Approval of Their Transition Plans and for Authorization to Collect Transition Revenues," Public Utilty Commssion of Ohio, Case No. 99-1212-EL-ETP. Direct testimony prepared, but not submitted pursuat to settlement agreement effected April 11,2000. "2000 Pricing Process," Salt River Project Board of Directors, oral comments provided March 6, 2000 and April 10, 2000. "Tucson Electrc Power Company vs. Cyprus Sierrta Corporation," Ariona Corporation Commission, Docket No. E-000001-99-0243. Direct testimony submitted October 25, 1999. Cross examined November 4, 1999. 11 ... Atthment A Page 12 of16 "Application of Hildae City and Intermountan Muncipal Gas Association for an Order Granting Access for Tranporttion of Interstate Natual Gas over the Pipelines of Questa Gas Company for Hildale, Uta," Utah Public Service Commssion, Docket No. 98-057-01. Rebutt testimony submitted August 30, 1999. "In the Matter of the Application by Arzona Electrc Power Cooperative, Inc. for Approval of Its Filng as to Regulatory Assets and Transition Revenues," Ariona Corporation Commssion, Docket No. E-01773A-98-0470. Direct testimony submitted July 30, 1999. Cross examined Febru 28, 2000. "In the Matter of the Application of Tucson Electrc Power Company for Approval of its Plan for Stranded Cost Recovery," Ariona Corporation Commssion, Docket No. E-01933A-98- 0471; "In the Matter of the Filing of Tucson Electrc Power Company ofUnbund1ed Tarffs Pursuat to A.A.C. RI4-2-1601 et seq.," Docket No. E-01933A-97-0772; "In the Matter of the Competition in the Provision of Electrc Service Throughout the State of Arzona," Docket No. RE-00000C-94-0165. Direct testimony submitted June 30, 1999. Rebutt testimony submitted August 6, 1999. Cross examined August 11-13, 1999. "In the Matter of the Application of Arzona Public Service Company for Approval of its Plan for Stranded Cost Recovery," Ariona Corporation Commssion, Docket No. E-01345A-98- 0473; "In the Matter of the Filng of Arzona Public Service Company of Unbundled Tarffs Pursuat to A.A.C. RI4-2-1601 et seq.," Docket No. E-01345A-97-0773; "In the Matter of the Competition in the Provision of Electrc Service Thoughout the State of Arzona" Docket No. RE-00000C-94-0165. Direct testimony submitted June 4, 1999. Rebuttal testimony submitted July 12, 1999. Cross examed July 14, 1999. "In the Matter of the Application of Tucson Electrc Power Company for Approval of its Plan for Stranded Cost Recovery," Ariona Corporation Commission, Docket No. E-01933A-98-0471; "In the Matter of the Filng of Tucson Electrc Power Company ofUnbund1ed Tarffs Pursuat to A.A.C. RI4-2-1601 et seq.," Docket No. E-01933A-97-0772; "In the Matter of the Application of Arzona Public Service Company for Approval of its Plan for Stranded Cost Recovery," Docket No. E-01345A-98-0473; "In the Matter of the Filing of Arzona Public Service Company of Unbundled Tarffs Pursuat to A.A.C. RI4-2-1601 et seq.," Docket No. E-01345A-97-0773; "In the Matter of the Competition in the Provision of Electrc Service Thoughout the State of Arzona," Docket No. RE-00000C-94-0165. Direct testimony submitted November 30, 1998. "Heargs on Pricing," Salt River Project Board of Directors, wrtten and oral comments provided November 9, 1998. 12 Atthment A Page 13 of16 "Hearngs on Customer Choice," Salt River Project Board of Directors, wrtten and oral comments provided June 22, 1998; June 29, 1998; July 9, 1998; August 7, 1998; and August 14, 1998. "In the Matter of the Competition in the Provision of Electrc Service Thoughout the State of Arzona," Ariona Corporation Commssion, Docket No. U-0000-94-165. Direct and rebutt testimony fied Januar 21, 1998. Second rebutt testimony fied Febru 4, 1998. Cross examed Febru 25, 1998. "In the Matter of Consolidated Edison Company of New York, Inc.'s Plans for (1) Electrc RatelRestrctung Pursuat to Opinion No. 96-12; and (2) the Formation of a Holding Company Pursuat to PSL, Sections 70, 108, and 110, and Cert Related Transactions," New York Public Service Commssion, Case 96-E-0897. Direct testimony filed April 9, 1997. Cross examned May 5, 1997. "In the Matter of the Petition of Sunyside Cogeneration Associates for Enforcement of Contract Provisions," Utah Public Service Commission, Docket No. 96-2018-01. Direct testimony submitted July 8, 1996. "In the Matter of the Application ofPacifiCorp, dba Pacific Power & Light Company, for Approval of Revised Tarff Schedules and an Alternative Form of Reguation Plan," Wyoming Public Servce Commission, Docket No. 2000-ER-95-99. Direct testimony submitted April 8, 1996. "In the Matter of the Application of Mountan Fuel Supply Company for an Increase in Rates and Charges," Utah Public Service Commssion, Case No. 95-057-02. Direct testimony submitted June 19, 1995. Rebuttal testimony submitted July 25, 1995. Surebutt testimony submitted August 7, 1995. "In the Matter of the Investigation of the Reasonableness of the Rates and Tarffs of Mountan Fuel Supply Company," Utah Public Servce Commssion, Case No. 89-057-15. Direct testimony submitted July 1990. Surebuttal testimony submitted August 1990. "In the Matter of the Review of the Rates of Uta Power and Light Company pursuat to The Order in Case No. 87-035-27," Utah Public Service Commission, Case No. 89-035-10. Rebutt testimony submitted November 15, 1989. Cross examined December 1, 1989 (rate schedule changes for state facilties). "In the Matter of the Application of Uta Power & Light Company and PCIU&L Merging Corp. (to be renamed PacifiCorp) for an Order Authorizing the Merger of Uta Power & Light Company and PacifiCorp into PC/uP&L Merging Corp. and Authorizing the Issuace of Securties, Adoption of Tarffs, and Transfer of Certificates of Public Convenience and Necessity 13 'l ,.. Attchment A Page 14 of16 and Authorities in Connection Therewith," Utah Public Servce Commission, Case No. 87-035- 27; Direct testimony submitted April 11, 1988. Cross examed May 12, 1988 (economic impact ofUP&L merger with PacifiCorp). "In the Matter of the Application of Mounta Fuel Supply Company for Approval of Interrptible Industral Transporttion Rates," Utah Public Service Commssion, Case No. 86- 057-07. Direct testimony submitted Janua 15, 1988. Cross examed March 30, 1988. "In the Matter of the Application of Uta Power and Light Company for an Order Approving a Power Purchase Agreement," Utah Public Service Commssion, Case No. 87-035-18. Oral testimony delivered July 8, 1987. "Cogeneration: Small Power Production," Federal Energy Regulatory Commission, Docket No. RM87-12-000. Statement on behalf of State of Uta delivered March 27, 1987, in San Francisco. "In the Matter of the Investigation of Rates for Backup, Maintenance, Supplementa, and Stadby Power for Uta Power and Light Company," Utah Public Service Commssion, Case No. 86-035-13. Direct testimony submitted Januar 5, 1987. Case settled by stipulation approved August 1987. "In the Matter of the Application of Sunyside Cogeneration Associates for Approval of the Cogeneration Power Purchase Agreement," Utah Public Service Commission, Case No. 86- 2018-01. Rebutt testimony submitted July 16, 1986. Cross examined July 17, 1986. "In the Matter of the Investigation of Demand-Side Alternatives to Capacity Expansion for Electrc Utilties," Utah Public Service Commission, Case No. 84-999-20. Direct testimony submitted June 17, 1985. Rebuttal testimony submitted July 29, 1985. Cross examined August 19, 1985. "In the Matter of the Implementation of Rules Governng Cogeneration and Small Power Production in Uta," Utah Public Service Commission, Case No. 80-999-06, pp. 1293-1318. Direct testimony submitted Janua 13, 1984 (avoided costs), May 9, 1986 (securty for levelized contracts) and November 17, 1986 (avoided costs). Cross-examined Febru 29, 1984 (avoided costs), April 11, 1985 (stadard form contracts), May 22-23, 1986 (securty for levelized contracts) and December 16-17, 1986 (avoided costs). OTHER RELATED ACTIVITY Paricipant, Oregon Direct Access Task Force (UM 1081), May 2003 to November 2003. 14 f , Attchment A Page 15 of 16 Paricipant, Michigan Stranded Cost Collaborative, March 2003 to March 2004. Member, Arzona Electrc Competition Advisory Group, December 2002 to present. Board of Directors, ex-offcio, Desert STAR RTO, September 1999 to Febru 2002. Member, Advisory Commttee, Desert STAR RTO, September 1999 to Febru 2002. Acting Chairman, October 2000 to Februar 2002. Board of Directors, Arzona Independent Scheduling Administrator Association, October 1998 to present. Acting Chairman, Operating Committee, Arzona Independent Scheduling Administrator Association, October 1998 to June 1999. Member, Desert Sta iSO Investigation Working Groups: Operations, Pricing, and Governance, April 1997 to December 1999. Legal & Negotiating Committee, April 1999 to December 1999. Paricipant, Independent System Operator and Spot Market Workig Group, Arzona Corporation Commission, April 1997 to September 1997. Paricipant, Unbundled Services and Stadard Offer Working Group, Arona Corporation Commssion, April 1997 to October 1997. Paricipant, Customer Selection Workig Group, Arzona Corporation Commssion, March 1997 to September 1997. Member, Stranded Cost Working Group, Arzona Corporation Commission, March 1997 to September 1997. Member, Electrc System Reliabilty & Safety Working Group, Arzona Corporation Commission, November 1996 to September 1998. Chaian, Salt Palace Renovation and Expansion Committee, Salt Lake County/State of UtaSalt Lake City, multi-governent entity responsible for implementation of planng, design, finance, and constrction of an $85 milion renovation of the Salt Palace Convention Center, Salt Lake City, Uta, May 1991 to December 1994. State of Uta Representative, Committee on Regional Electrc Power Cooperation, a joint effort of the Western Interstate Energy Board and the Western Conference of Public Service Commissioners, Janua 1987 to December 1990. 15 t \ Attchment A Page 16 of16 Member, Uta Governor's Economic Coordinating Committee, Janua 1987 to December 1990. Chairman, Stadad Contract Task Force, established by Uta Public Service Commission to address contractu problems relating to qualifying facilty sales under PUR A, March 1986 to December 1990. Chairman, Load Management and Energy Conservation Task Force, Uta Public Service Commssion, August 1985 to December 1990. Alternate Delegate for Uta, Western Interstate Energy Board, Denver, Colorado, August 1985 to December 1990. Aricles Editor, Economic Foru, September 1980 to August 1981. 16