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¡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
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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
)
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) Case No. IPC-E-07-8
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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
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DIRECT TESTIMONY OF KEVIN C. HIGGINS
3 Introduction
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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,
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Higgns, DI
Kroger Co. dba Fred Meyer & Smiths
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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.
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Higgins, DI
Kroger Co. dba Fred Meyer & Smiths
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1 Overview and conclusions
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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
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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
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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.
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Higgins, DI
Kroger Co. dba Fred Meyer & Smiths
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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.
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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.
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Higgins, DI
Kroger Co. dba Fred Meyer & Smiths
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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
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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.
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Higgs, DI
Kroger Co. dba Fred Meyer & Smiths
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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
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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
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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
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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
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Higgin, DI
Kroger Co. dba Fred Meyer & Smiths
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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
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Kroger Co. dba Fred Meyer & Smiths
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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
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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
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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.
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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
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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
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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
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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