20180126Faruqui Rebuttal.pdf

IiECE IVED
?il10 JI\t{ 26 PH lr: 30
u T r Jfi ilLcciH3iil8 t' o *
BEFORE THE IDAHO PUBL]C UTILIT]ES COMMISSION
]N THE MATTER OE THE APPLICAT]ON
OF IDAHO POWER COMPANY FOR
AUTHORITY TO ESTABLISH NEW
SCHEDULES FOR RESIDENTIAL AND
SMALL GENERAL SERVICE CUSTOMERS
WITH ON_SITE GENERATION.
CASE NO. IPC-E-11_1.3
IDAHO POWER COMPANY
REBUTTAL TEST]MONY
OF
DR. AHMAD FARUQUI
)
)
)
)
)
)
)
1
Z
3
4
5
6
1
9
a What is
A.My name
with the Brattle Group,
address is 201 Mission
I. INTRODUCTION
your name
is Ahmad
and address?
Earuqui. I am a
an economics consulting
Street, Suite 2800, San
Principal
f 1rm. My
Erancisco,
California 94105.
O. On whose behal-f
A. I am testifying
Company ("Idaho Power") .
18 III is a
t9 empirical
generation
customers.
are you submitting
on behalf of Idaho
testimony?
Power
10 O. What is the purpose of your testimony?
A. The purpose of my testimony is to address
several issues raised by various parties in response to
direct testimony filed by Idaho Power witnesses Davld M
Ange11, Connie G. Aschenbrenner, and Timothy E. Tatum.
11
72
13
t4
15
L6
L1
ZU
27
a)
A
How is your testimony organized?
My test.imony is organized into several-
Section II presents my qualifications. Section
summary of my testimony. Section IV presents an
assessment of the differences between distributed
("DG") customer load shapes
discussion the cost shift
implications.
by intervenors.
sections.
and those of non-DG
Section V is a of
22 between DG and non-DG customers, and its
23 Section VI addresses other issues raised
24 Section VII presents a summary of decisions to address the
25
FARUQUI, REB 1
Idaho Power Company
1 cost shlft issue in other jurisdictions. Section VIII
2 concludes my testimony.
3 rr. QuArrFrcATroNs
4 Q. What are your qualifications as they pertain
5 to this testimony?
6 A. I am an energy economist. My consulting
7 practlce is focused on customer-rel-ated j-ssues. My areas
8 of expertise include rate design, demand response, energy
9 efficiency ("EE"), distributed energy resources, advanced
10 metering infrastructure, plug-in electric vehicles, energy
11 storage, inter-fuel- substitution, combined heat and power,
72 microgrids, and demand forecasting.
13 I have worked for nearly 150 cl-ients on five
74 continents. These include electric and gas utilities,
15 state and federal commissions, independent system
16 operators, government agencies, trade associations,
L1 research j-nstitutes, and manufacturing companies. I have
1B testified or appeared before commissions in Alberta
79 (Canada), Arizona, Arkansas, California, Colorado,
20 Connecticut, Delaware, the District of Columbia, EERC,
27 Il-Iinois, Indiana, Kansas, Maryland, Mi-nnesota, Nevada,
22 Ohio, Oklahoma, Ontario (Canada), Pennsylvania, ECRA (Saudi
23 Arabia), and Texas. A1so, I have presented to governments
24 in Australia, Canada, Egypt, Ireland, the Philippines,
25
FARUQUI, REB 2
Idaho Power Company
1 Thailand, and the United Kingdom and given semj-nars on al-f
2 six conti-nents.
3 My research has been cited in Business Week, The
4 Economist, Forbes, National Geographic, The New York Times,
5 San Francisco Chronicle, San Jose Mercury News, WaI1 Street
6 Journal, and USA Today. I have appeared on Fox Business
7 News, National Public Radio, and Voice of America and I
8 have authored, co-authored, or co-editor four books and
9 more than 150 articl-es, papers, and reports on energy
10 matters. I have published in peer-reviewed journals such
11 as Energy Economics, Energy Journal, Energy Efficiency,
\2 Energy Policy, Journal of Regulatory Economics and
13 Utilities Policy, and trade journals such as The
74 Electricity Journal and the Public Util-ities Fortniqhtly.
15 I hol-d B.A. and M.A. degrees from the University of
1,6 Karachi, Pakistan, an M.A. in agricultural economics, and a
71 Ph.D. in economics from the University of California at
18 Davis.
1,9 More details regarding my professional- background
20 and experience are set forth in my Statement of
2L Qualifications, included in Exhibit No. 16.
22 III. SI'MMARY
23 O. Please summarize your testimony.
24 A. Intervenors have opposed various aspects of
25 Idaho Power's proposal to create a separate rate class for
FARUQUI, REB 3
Idaho Power Company
1 residential DG customers. However, having reviewed Idaho
2 Power's proposal, I find that the proposa1 is reasonabl-e
3 and justified.
4 DG customers rely heavily on the power grid. When
5 the sun is not shining or the wind is not blowlng, they are
6 drawing power from the grid, like other consumers. And
7 when the sun is shining or the wind is blowing, and their
8 power generation exceeds their power consumption, they will
9 be exporting power to the grid, unl-ike non-DG customers.
10 In other words, they have a bi-directional relationship
11 with the grid.
72 However, the rate that Idaho Power currently offers
13 to DG customers is ldentical to the rate for non-DG
t4 residential customers. It over-compensates DG customers
15 for the power they
occurs because the
se11 to the grid. The over-compensation
t6 residential- rate at which they are
Ll compensated includes not only the variable costs of
18 electricj-ty, which the DG customers are selling to Idaho
19 Power, but also costs associated with the transmission and
20 dlstribution grid, as well as generation capacity costs and
which DG customers
it does not
27 fixed costs of customer service, none of
22 are selling to Idaho Power. Furthermore,
23 reflect additional costs that DG customers may impose on
with the24the system because of
grid.
their two-way interaction
EARUQUI, REB 4
Idaho Power Company
Z5
1 This over-compensation to DG customers has to be
2 recovered from non-DG customers to ensure that the utility
3 recovers its revenue requirement. Thus, non-DG customers
4 end up paying a higher rate than they would otherwise be
5 paying. This resul-ts in an unintended cross-subsidy from
6 non-DG customers (including a disproportionately large
7 share of l-ower income customers) to DG customers. That
B cross-subsidy largely remains invisible to the non-DG
9 customers.
10 This cost shift can be ameliorated through the
11 creation of a separate class of DG customers. These
12 customers would be offered rates based on their cost of
13 service. Doing
their fair share
so would ensure that DG customers will pay
74 of electricity costs while still being
15 compensated an appropriate amount for the
Since
electrj-city they
residential DG76
T1
1B
79
20
2t
22
Z3
24
generate from their solar panels.
customers have very di-fferent load characteristics than
non-DG customers, i-t is appropriate to consj-der them a
separate cfass of customers with their own unique rate.
The problem with Idaho Power's current rate
offerlng, and a description of how thls problem can be
addressed through the introduction of a separate, cost-
based rate for DG customers, is provided in Flgure 1.
FARUQUI, REB 5
Idaho Power Company
25
Problem with Current Rate
1 Figrrre 1: How a Separate DG Rate Corrects the Problem in
2 Idaho Power's Existing Rate Offering
o rPc o 06 tusto,Bpry fortEi
u5eotihepoE8rid
throughaseF de.aeaadarcrom.6ad
tatrly torPVoutBrt
undar-r<m6(6f,ofr
OG curtoros dseto nd
mdcrirt wdh 2-rt rata<-
Bill < Cost
-sss
4
Bill = Cost
r\@,*.o,,*u*-@ ratesrcaoroe
fhactdb$ \
Bill > Cost
+sss
r*oErd(o*tro6all(60lB
Bill = Cost (ontintto ,effet
Se aE le(d otoOneun;ntm
rub5dYtrcm nm-(K
cufrm6toOG(u5tofi6 B rercled
54rC€SdEl
invi5iblEUninffi \
rubidyftom.m-oc \
au$omdatooG
3
4
tr
6
1
R
9
In this testimony, I elaborate on a number of points
rateabout Idaho Power's proposal- to create a separate
class for residenti-al DG customers. These i-nclude:
a There is empirical evldence that DG customer load
shapes differ signlficantly from that of the typical
shapes also differresidentiaf customer in Idaho. DG load
10 significantly from those of customers who participate in EE
11 programs.
12 . These differences in load shape lead to a
13 significant and disproportionate
infrastructure costs
shlft in t.he recovery of
14 power system from DG customers to non-
15 DG customers.
16 a Low-income customers are disproportionately and
shift.t1 negatively impacted by the
. While DG adoption
COSt
1B Ievels in Idaho are modest,
19 they are growing fast, ds they are in the rest of the
EARUQU], REB 6
Idaho Power Company
Correstion with Separate DG Rate
DG
Customers
ldaho
Power DG
Customers
ldaho
Power
Non-DG
Customers Non-DG
Customers
1
2
3
4
5
6
'7
B
9
country. Thus, 1t is important to create a new rate cfass
for DG customers now.
A "value of solar" (*VOS") study is not a
10
cost-effectiveness analyses and i-n
resource planning decislons. But ratemaking decisions
should be based on cost of service and the generally
accepted principles of rate design.
. There is precedent for creating a separate rate
cl-ass for DG customers. This has been implemented in both
Arizona and Kansas. Many states continue to grapple with
the challenges presented by net metering with volumetric
rates.
DG CUSTOMER LOAD STIAPES ARE SIGTiIIFICATiITLY DIFFERENT
TEA}I THOSE OF NON-DG CUSTOMERS
a Does the hourly load shape of DG customers
non-DG customers?differ significantly from that of
A. Yes. While Witness Morrison (IPUC Staff)t
suggests that the differences in load shape are j-mmaterial,
I have conducted empirical analysis with Idaho Power data
which flnds that the differences are quite significant.
0. What data di-d you use to analyze the l-oad
shapes of DG and non-DG customers?
necessary prerequisite
play a valuable rol-e in
a
1 Morrison DI, pp. 3, 11.
for DG rate reform. VOS studies can
FARUQUI, REB 1
Idaho Power Company
11
72
13
t4
15
1,6
L1
1B
19
20
2t
22
23
24
25
IV
1 A. Idaho Power provided me with hourly load data
2 for its residential DG and non-DG customers. The data
3 begins in January 2074 and runs through October 2017. The
4 non-DG customer dataset is Idaho Power's l-oad research
5 sample, which consists of 52L customers who have not
6 install-ed rooftop photovoltaic (*PV"). The DG customer
7 dataset includes L,545 net metering customers who installed
B rooftop PV at some point since 2002. The data includes the
9 date of installation of rooftop PV and reflects the net
10 l-oad of the DG customers, including exports to the grid.
11 O. What was your methodologlcal approach to
12 analyzing the DG customer load shapes?
13 A. I calculated the hourly average consumption of
14 DG customers before and after the installation of DG. This
15 gives a sense of how the DG customer load profiles differ
t6 before and after the install-ation of rooftop PV.
71
1B
I9
20
27
22
23
24
I
those of
sample.
profiles
o
customer
A
changes
solar PV
also compared these average DG load profiles to
non-DG customers in Idaho Power's load research
This provides perspective on how DG customer l-oad
differ from the typical residential- customer.
. What did you find in your analysis of DG
Ioad shapes?
. The net load shape of residential- customers
those customers install rooftopsignificantly when
Figure 2 summarizes the comparison of average
EARUQUI, REB 8
Idaho Power Company
1
2
3
4
5
6
1
B
9
load profiles for non-DG customers relative to DG customers
both before and after the installation of rooftop PV. The
those of non-DGload shapes of DG
customers prj-or to
customers resembl-ed
the installation of sol-ar PV, though the
somewhat higher than
summer and non-summer
hourly
those
loads for DG customers were
for non-DG customers in both
months (we define the summer period to
September, and the non-sunrmer period to
include June through
include October
non-summer perlod asthrough May;
t'winter" ) .
hereafter we refer to the
10 This is no longer the case following
foad shapes are dramatically different
wi-nter.
Hourly DG and Non-DG Customer Load
11 installation, when
in both summer andt2
13
74
Figure 2: Average
Profiles
Summer Winter
25
^ 20
i 15
!,0
E --
2 to
.ll
:.o
Non-DG
2a
( ro
3
!
i lo
r
a
o5
ilon-OG
I I 3 a 3 a' I 9 tO il 12 r' la g 16l, la ltsrl l2trra
Hdr Endtna Hour€ndln,
consumption
lnstal-latlon
15 Quantitatively,
of DG customers
the average annual net energy
76 was 36 percent lower following
t1
1B
FARUQU], REB 9
Idaho Power Company
79
?or!DG l.strllataon
PostDG Init.ll.rion
1
2
3
4
5
6
of DG average.2 fn contrast, those
demand was modestly
customers' average
higher bymonthly
In other
max].mum 4 percent.
their totalwords, while the DG customers reduce
energy needs, their
persists. Table 1
heavy reliance on grid infrastructure
summarizes results of the analysis.
Tab1e 1: Load Characteristics of DG and Non-DG Customers
Avg Monthly Net Avg Monthly
Energy Consumption Max Demand Load
(kwh) (kW) Factor
Pre-PV Summer Months
Post-PV Summer Months
% Change
Pre-PV Winter Months
Post-PV Winter Months
% Change
Pre-PV All Months
Post-PV All Months
% Change
L,207
523
-57%
L,179
918
-22%
7.O
6.8
-3%
6.9
7.5
8%
7.0
7.2
4%
24%
77%
-55%
23%
t7%
28%
23o/o
1.4%
38%
1,188
766
-36%
1
B
9
Source: Brattle analysis of IPC load data.
O Are the load characteristics of DG customers
similar to those of EE customers?
A No, there are slgnificant differences between
11 DG customers and other residential customers
10
72 various EE measures. Witness Donohue (IPUC
who pursue
Staff): has
2 I additionally used a fixed-effects regression model to analyze
the change in energy consumption attributable to the installatlon of
DG. A regression-based approach allowed me to control for externalfactors that may drive differences in pre- and post-DG energy
consumption (e.9., differences in weather). Under this alternatlve
approach, I found that the decrease in energy consumption was evenlarger, amounting to a 67 percent reduction in pre-DG energy
consumption.
3 Donohue DI, pp. 2, 18.
FARUQU], REB 1O
Idaho Power Company
1 claimed that these two customer types are "almost
2 idenLrcal," and has used this assertion in arguing that a
3 separate DG rate class j-s not warranted.
4 To address this issue empirically, I have conducted
5 a similar analysis to the one described above, but have
5 compared the load shapes of customers in Idaho Power's EE
7 proqrams to those of other non-DG customers. The purpose
B of the analysis is to see if the significant differences
9 between DG and non-DG customers are also observed when
10 comparing EE customers to the non-DG customers.
11 a. What data did you use in your comparison of
12 non-DG customer and EE customer load profiles?
13 A. Eor non-DG customers, f used the same load
74 research data described above. For EE customers, Idaho
15 Power provided me with hourly load data for a sample of 516
76 customers. The sample of EE customers was created by
L1 randomly selecting 20 percent of all customers who
1B participated in an Idaho Power-sponsored EE program between
L9 2075 and 2015. The EE programs included in the sample are
20 the Energy House Calls program, the Heating and Cooling
2L Efficiency program, the Home Improvement program, and
22 income qualified weatherization programs. The dataset
23 indicated the program in which the customer was enrol-Ied
24 and the date the customer participated in the program.
FARUQUI, REB 11
Idaho Power Company
Z5
1
2
3
4
5
6
1
B
9
o What did you find in your comparison of non-DG
customer load shapes to those of EE program participants?
A.EE customers have load shapes that are simil-ar
to those of customers who have not enrol-l-ed in EE programs,
though the hourly loads of EE customers were somewhat
higher 1n summer months and significantly higher in winter
months. It is reasonable that the EE customers have
significantly higher hourly l-oads in the winter because
e1ectric heating is a requJ-rement to qualify for Idaho
Power's EE programs. Across all- EE customers in the
sample, energy consumption decreased by one percent and
maximum demand decreased by three percent following
participation in the EE program. Figure 3 il-l-ustrates the
difference between non-DG customers who have parti-cipated
in EE and those who have not.
Figrrre 3: Average llourJ.y Customer Load Profiles with and
without Energy Efficiency
Summer Winter
Portca lnlt.ll.ton
Non-lE
ilon-€E
10
11
72
13
t4
15
16
71
1B
2.5
,.0
>ls3
i roz
0.5
0.0
3.5
3.0
2.9
i ro
!
3 1.5
2
1.0
0.0
I 2 I 4 5 5 7 8 9 1O1112131415151718192021222324
Hour Cndlnt
I 2 ! 4 S 6 7 8 9 10111213141S16171819202122212t
H@r €ndlna
19 EE customers are different than DG customers. Unl-ike DG
20 customers, EE customers do not export energy to the power
FARUQUI, REB 72
Idaho Power Company
Poit-Et lnrbll.tio.
1
2
3
4
5
6
1
6
9
grid. Further, while EE i-nvestments commonly result in a
reduction in both max demand and energy consumption, the
instal-lation of PV largely only provj-des the latter.
O. Did you also analyze the diversity of load
profiles among DG and non-DG customers?
A. Yes, I did. Witness Kobor (Vote So1ar)
suggests that the load profiles of DG customers are not
sufficiently different than those of non-DG customers when
accounting for diversity in load shapes across the entire
resldential customer segment.4 My analysis shows that in
fact the DG load shape is significantly dlfferent even when
accounting for this diversity.
O. How did you analyze the diversity of
residential load shapes?
A. Using the same hourly residential load data
descri-bed earlier in this section of my testimony, I
established the 1Oth and 9Oth percentiles of non-DG
resldential- load across each hour of the day in the summer
and winter. The wide spread between the 10th and 90th
percentile in each hour indicates that there
significant diversity across non-DG customer
is indeed
load shapes.
of this22 But the average DG load shape stilf falls outside
23 range during several hours of the day. This is
specifically the case when DG customers are exporti-ng power
10
11
I2
13
74
15
l6
71
1B
t9
20
27
a Kobor DI, pp. 42-41
FARUQU], REB 13
Idaho Power Company
24
1
2
3
4
to the grid a characteristic
other residenti-a1 customer. The
that is not shared by any
results of my analysj-s are
summarj-zed in Figure 4.
Figrrre 4: Diversity in Residential Load Profiles
Summer Winter
t'
E
2
ilon-O6 (9OXl
3
E
z
ilon-Oc (9(H)
flon-OG
Non-OG ll0X)Xon-OG (lOX)
,ort.PV Curtomers
'2
Poal.PV Curtomer
6 r a 9 l0lrrlttl,l5 l5 lo ,r It
Houi Endina Hour C.dint
5
6
1
I
9
O What do you conclude from your analysis of DG
10
customer load shapes?
A. The DG customer load profile is significantly
different than that of the typical residential- customer.
There is a coflrmon misperception that, by virtue of
generating their own el-ectricity, DG customers rely on the
power grid significantly less than non-DG customers. In
fact, while a customer reduces his/her total energy needs
by install-ing a rooftop PV system, the customer stil-l
requires nearly the same amount of power grid
infrastructure.
DG customers still consume a significant amount of
el-ectricity during hours when the sun is not shining. And
when the sun is shining, DG customers may be exporting
power to the grid. As a result, DG customers sti1l have
11
t2
13
74
15
76
71
1B
FARUQUI, REB 74
Idaho Power Company
79
I
o
Non-OG
1
2
3
4
5
6
7
o
9
significant demand
drive the need for
during those system peak hours that
investments in infrastructure that are
neces sary
DG
to maintain a sufficient leve1 of reliability.
customers afso introduce new challenges to
Is there a cost shift between DG and non-DG
Yes. Witnesses Burgos (City of Boise)6 and
Conservatlon League) I have suggested that the
is unimportant or otherwlse has not been
operators of the power grid, as described extensively in
Mr. AngelI's Dlrect. Testimony.s
V. THE DG COST SHIFT IS REJAL A}iID SHOI'LD BE ADDRESSED
10
O.
customers ?
A.
Otto (Idaho
cost shift
11
t2
13 correctly quantified by fdaho Power, and therefore shoufd
1-4 not warrant the creation of a separate rate cl-ass for DG
15 customers. However, ds I discussed previously, the unique
16 load characteristics of DG customers combined with net
L1 metering under a fl-at volumetric rate disproportionately
18 shifts the recovery of Idaho Power's costs from DG
19 customers to non-DG customers.
ZU The magnitude
depend on a number of
of this unintended cross-subsidy will
factors, such as the number of2t
s Ange11 DI.
6 Burgos DI, pp.
7 otto DI, pp. 4
6, 8
FARUQUT, REB 15
Idaho Power Company
1
2
3
4
q,
6
7
8
9
customers adopting PV, the average size of PV installation,
and the rate structure and l-evel-. A survey of studies in
other jurisdictions designed to quantify the magnitude of
this cost shift found that it could amount to between
approximately $400 and $1,800 per DG customer per year.e
This is summarized in Eigure 4, with supporting details in
Exhibit No. 77. Whil-e Idaho Power's estimate fal-ls at the
l-ower end of this range, there is l-ittl-e doubt that such a
subsidy exists under the current rate structure.
10
11
Figrre 5: Rooftop P\I Cost Shift Estimates ($
customer per year)
s2,000
s1,8oo
s1,5oo
s1,4oo
s86s
(201s)
sess
(2020)
s661
(20201
per P\I
st,7s2
{2020)
s740(201s)
s620(2015)
s1,2oo
s1,ooo
ssoo
s6oo
S4oo
s2oo
Go
oEL
s
oo
5444 5471
(201s)(201s)
ss11
(201s)
ss33
(201s)
S1,o51(2020)
Arizona Hawaiian PG&E -
Public Electric Lower
SeNice Range
s1,6oo
(2015)
SDG&E PG&E.
Upper
Range
so I
NVPUC NVEnergy E3-NV NVPUC NVEnergy E3-CA
(SPPC) (SPPC) Estimate (NPC) (NPC) Estimate
ldaho
Power
t2
13
74
15
!6
Notes: Year indicates date of cost shift estimate, which is
so.neti*.s a forecast. In some cases, reported estimates were
converted to annuaf dollars per net metering customer for
comparison purposes. The PG&E ranges are cal-culated using
I For further discussion of the cost shift studles, see Barbara
Alexander, AshJ-ey Brown, and Ahmad Faruqui, "Rethinklng Rational-e for
Net Metering," Publ-ic Utilities Fortnightly, October 2016.
FARUQUI, REB 76
Idaho Power Company
1
2
3
4
5
6
1
I
9
assumptions from the Cal-ifornia PubIic Utilities
Public Modeling Tool-. PPC and NPC refer to Sierra
Company and Nevada Power Company service territories
Commi-ssion's
Pacific Power
respectively.
10
O. Do low income customers bear a
disproportionate share of the cost-shift burden?
A. Yes. Witness Donohue (IPUC Staff)s suggests
that low income customers are not hurt by the DG cost
shift. However, research supports the observation that fow
income customers bear a disproportionate share of the cost-
shift burden. Publ-icly avaiIable studies by E3,o (for the
California Publ-lc Utilities Commission), Dr. Severin
Borensteinll (a professor at UC Berkefey), and Solar Pulselz
(a solar market research firm which pairs customers with
rooftop PV lnstallers) have all shown empirically that
lower income customers have been less likely to install
rooftop PV than higher income customers. Tab1e 1
summarizes the conclusions of each study.
e Donohue DI, p. 22
ro E3, "fntroduction to the Cal-j-fornia Net Energy Metering
Ratepayer Tmpacts Evaluatj-on, " Report prepared for the CafiforniaPublic Utifities Commission, October 20L3.
11 Severin Borenstein, "Prj-vate Net Benefits of Resj-dential- Sofar
PV: The Rol-e of Electricity Tariffs, Tax Incentives and Rebates, " Haas
Energy Institute Working Paper, July 2015.
12 Sol-ar PuIse Staff, "Is Going Sol-ar Just for Wealthy People?"
July 2016, accessed online October 2076.
FARUQUI, REB 7'I
Idaho Power Company
11
72
13
74
15
76
71
1B
19
20
2t
1 Table 22 Rooftop
The Relationship Between Household Income and
P\I Adoption
3
4
5
6
7
8
9
O. Shoul-d the cost shift be ignored due to the
modest number of residential customers who currentl-y have
DG in ldaho?
A. Witness Levin (Snake River Alliance and NW
Energy Coalition) tr huu suggested that current low levels of
rooftop solar adoption in Idaho Power's service territory
are reason to delay the creation of a separate DG rate
c1ass. In fact, the opposite is true.
There are significant benefits to correcting the DG
rate design before rooftop PV is adopted in larger numbers.
At limited l-evels of adoption it is easier to address
issues such as grandfathering of existing DG customers into
13 Levin DI, p. 23.
EARUQUI, REB 18
Idaho Power Company
10
11
72
13
L4
E}/CPUC
(2o13)
Using data for 115,000 DG customers in California, the study
found that the median income of DG customers was 3496
($23tlyear; higher then thet of all utility cuntomerc. The study
relied on U.S. Census income data at the Census tract level and
utiliry customer data.
Using Census tract-level income data and utility data to estimate
individual household incomes, the study exarnines the income
distribution of solar adopters and how that has changed over time.
The study finds that "the skew to weahhy households ado,pting
solar is stifl significaat, but has lessened since 2011."
Boreostein / UC Berleley
(2ols)
Using household-level data for I 1,000 households, the study found
that "expensive homes and wealthy homeowners are much more
likely to have solar panels." While the study suggests that the
income gap is narrowing, it finds that the everirge household
income of a DG cnstorrcr was $117t, comlnred to ar avef,ate
annual income of i87k for the average household in the sample.
SolerPulse
(2o16)
Key FinilingsStudy
1
2
3
4
5
6
1
9
the current DG rates policy. The impacts of grandfathering
on customers - and the contentiousness of the issue grow
as more customers adopt rooftop PV. The same al-so applies
to customer educati-on. It is easier to educate customers
about their rate options when the vast majorlty 1s in a
simil-ar situation rather than when they have become
bi furcated.
The current fevel of PV adoption should not
influence the fPUC's decision in reforming DG rates. While
the market penetration of rooftop solar may currently be
modest in Idaho Power's service territory, the rooftop
solar industry is a newly emerging industry. In fact,
SolarCity (a well--known, established national- rooftop sol-ar
developer) was acquired in 2016 by Tesla at a price tag of
$2.6 bill-ion.ts Rooftop PV costs have come down
significantly over the last severa1 years, and the sofar
industry has grown at the same time. The number of DG
installations in Idaho Power's service area has lncreased
by more than 400 percent over the past five years.
VI. OTHER ISSUES
a. Is a "Value of Sol-ar" study a necessary
prerequisite for proceeding with the establishment of a
separate DG rate class?
1a Robert Earris, "Tes1a and Sol-arCity merger gets approval from
shareholders," CNBC (November 2076), accessed January 10, 20L8.
FARUQUI, REB 79
Idaho Power Company
10
11
L2
13
74
15
76
l1
1B
t9
20
27
22
ZJ
1
2
3
4
5
6
1
B
9
A. No. Witnesses Beach (Sierra Cl-ub),rs Kobor
(Vote Solar) ,t0 and Levin (Snake River All-iance and NW
Energy Coalition) 1' have suggested that a study of the costs
and benefits of rooftop solar PV be conducted before
creating a separate DG rate class. Whil-e research can be
helpful in understanding the costs and benefits of solar
generation in Idaho, and helpful in integrated resource
planning studies, a VOS study should not be viewed as being
a prerequisite to establ-ishing separate customer cl-asses.
VOS studies produce an extremefy wide range of
resul-ts, even within a single jurisdiction. EarIi-er in
this testimony, for instance, I cited 72 studies which
found that the DG subsidy embedded in current rate designs
around the U.S. ranges from $444 to $1,752 per DG customer
per year. A study by The Rocky Mountain Institute, which
surveyed 15 VOS studies, found that the benefits of rooftop
solar range from significantly bel-ow to significantly above
the average reta11 rate.18
This range of results from VOS studies can largely
be explained by the fact that the studies are, for
1s Beach
16 Kobor
1r Levi-n
6
10
11
72
13
14
15
76
71
1B
L9
20
Df,
DI,
DI,
P.
p.
pp
14.
ZI_ZZ.
18 Lena Hansen, Vlrginia Lacy, Devi Glick, "A Review of Sofar PV
Benefit & Cost Studies, " prepared by Rocky Mountain Institute,
September 20L3.
FARUQUI, REB 20
Idaho Power Company
1 practical reasons, heavily dependent on many assumptions.
2 Potential- benefits such as avoided distribution costs due
3 to possible peak demand reductions from sol-ar PV, for
4 instance, are often based on anecdotal information rather
5 than on detailed engineering studies, which would be
6 expensive and time-consuming. Other assumptions in the VOS
7 studies are subject to simil-ar uncertainty.
B Further, the "va1ue" of sol-ar is not rel-evant when
9 determining if one segment of customers is distinctly
10 different from another. That difference is better
11 addressed through an assessment of customer l-oad shapes and
72 the associated system costs.
13 O. Wil-l the creatj-on of a separate rate class
L4 increase or reduce the uncertainty faced by customers who
15 are considering investing in DG?
76 A. Contrary to the comments of Witnesses Burgos
l7 (City of Boise),rs King (ICEA) ,20 Leonard (ICEA) ,21 and White
18 (ICEA),r, correcting the DG rate design now will provide
19 more certainty to customers who may be considering
20 investing in rooftop PV.
1e Burgos DI, p. 1.
20 King DI, p. 72.
21 Leonard DI, p. 4-5.
2z White DIr p. 4-6.
EARUQUT, REB 27
Idaho Power Company
1 For the various reasons discussed earl-ier in this
2 testimony, net metering with flat volumetric rates 1s not
3 sustainabl-e and will require a change to the DG
4 compensation mechanism. This inevitabl-e change j-s
5 occurring in other jurisdictions throughout the U.S., where
6 net metering policies are being ended (e.9., Arizona,
7 Hawaii) and/or the underlying DG rate structure is being
B modified (e.9., Nevada) . Reforming the DG rate now will-
9 take some of the uncertainty out of the decision-making
10 process for customers who are considering whether or not to
11 invest in rooftop solar.
L2 0. Should state and local economic and policy
13 goals prevent a separate rate for DG customers from being
14 established?
15 A. No. Witnesses Bishop (Auric Solar),2: Burgos
76 (City of Boise),zn and King (ICEA)zs have suggested that the
77 establishment of a separate DG rate class wil-l impede
18 economic development in the state, Iead to a l-oss of jobs,
19 and interfere with the state's environmental policy goals.
20 Even if that were the case, rates should not be tools for
27 promoting
rather be
economic and environmental policies, but should
based on the cost of service. PoIicy ob;ectlves
23 Bishop DI, pp. 2-3.
2a Burgos DI, pp. 2, 5 .
2s King DI, pp. 3-4, 14
FARUQUI, REB 22
Idaho Power Company
22
1
2
3
4
5
6
1
I
9
are best promoted through other means outside of the
ratemaking process such as tax credits and income
subsidies.
Distributed PV is a clean source
provides a societal benefit in the form
of electricity that
of reduced
a pollcy standpoi-nt, it may
environmental beneflts of
emissions. From
10
greenhouse gas
be desirable to recognize these
PV and promote its adoption.
sense to selectively promote
subsidies that are embedded
externality, essentially
that price is part of the
is economically efficient
externality in rates for
However, it does not make
PV adoption through hidden
in el-ectric rates.
i-nternalrzinq the externality, and
utility's cost structure, then it
to reflect the price of that
all customers.However, it would
if only certain
compensated for
11
L2
13
t4
15
76
71
1B
79
20
27
22
23
24
25
If a price has been assigned to a certain
violate the core principles of ratemaking
customers or technologies were charged or
their impact on those externalities.
For instance, investments in rooftop solar PV that
are artificially subsidized through the current rate
structure could potentially instead be made in l-ower cost
utility-scale sol-ar or EE, while achieving many of the same
benefits. A11 technologies and customers should be on a
l-evel playing field when developing residential rate
design.
FARUQUI, REB 23
Idaho Power Company
1
2
3
4
5
6
1
B
9
VII. EXPERIENCE I}I OTHER iII'RISDICTIONS
O. Have utilj-ties and regulatory commissions in
other jurisdictions establj-shed a separate rate class for
DG customers in order to address the various cost shift
issues described in your testi-mony?
A. Yes. I am aware of two notabl-e cases: Sal-t
River Project ("SRP") in Arizona, and the Kansas
Corporation Commissj-on (*KCC") .
O. Pl-ease describe the activity by SRP.
A. In 2074, SRP developed a proposal to create
separate rate class for DG customers.26 SRP's governing
Board of Directors unanimously approved the proposal in
10 a
11
I2
13 2075.21 In doing so,
74 became the standard
a three-part rate with a demand charge
rate for all of SRP's future
customers. Existing DG customers were
under the pre-existing rate structure.
Please describe how the DG cost shift issues
15 residential DG
16 grandfathered
o.
1,9
l1
18 were addressed in Kansas.
26 Salt River Prolect Agricultura.J- Improvement and Power District,
"Proposed Adjustments to SRP's Standard El-ectric Price Pl-ans Effectivewith the Apri-l 2015 Bil-l-j-ng Cyc1e," December 72, 20L4, accessed on
January 10, 20\8,
http : / / www. srpnet . com/prices /priceproces s /pdf x/Bf ueBook. pdf .
27 'SRP Board Approves Reduced Price Increase, " SRP (Salt River
Project) press release, February 26, 20L5, accessed on January 10,
201-8 , http: / /www. srpnet . com/newsroom/rele ases / 022 615 . aspx.
FARUQUI, REB 24
Idaho Power Company
1
2
3
4
5
6
1
B
9
explore
for DG
Energy
Order
treated as a
requirement.2e
load and cost
customers as
o.
decisions to
separate
The KCC
A. In 2016, the KCC opened a regulatory docket to
the possibllity of creatj-ng a separate rate cfass
customers.2s After revlewi-ng f ilings by Westar
and various intervenor groups, the KCC issued an
in 2011 confirming that DG customers should be
rate class wlth its own revenue
cited
characteristics
reasons for its
the significantly different
between DG and non-DG
decision.
10 Have other jurisdictions made similar
11 address
72 rate treatment for DG
cost shift issues through specific
customers?
13 A Yes. In California, the California Publ-ic
L4 Utilities Commission elected to make time-of-use rates the
15 mandatory rate offering
Unlike other residential
11 have the option to enroll
customers, DG customers will not
in a flat rate.
28 Kansas Corporatlon Commission, Staff Motion to Open Docket,
Docket No. 16-GIME-403-GIE, March 11, 2016,
http: //esLar.kcc.ks.govlestar/ViewFiIe.aspx/S20160311132834.pdf?Id:e4c1
8 f0 c- I 42 4 - 4df2- 9d6e- 8 1 6 f 7 8 61 b3 41
2e Kansas Corporation Commission, Final- Order, Docket No. 16-GIME-
403-GIE, March 11, 2076, p. 8,
http : / /estaq, kcc. ks . govlest4r/ViewEile . aspx/S!0 1 6031 1 132 834 . pdf ?Id
8 f0 c- L 42 4 - 4dt2- 9d6e- 8 1 6f 7 8 67b3 4'7
30 Cafifornia Pubfic Utj-llties Commission, Decision Adopting
Successor to Net Energy Metering Tariff, Rul-emaking 14-07-002, January28, 2016,
http :,/,/docs . cpuc . ca . gov,/ pubf ishedDocs / Publi shed/G0 0 0 /M1 5 8 /K1 8 1 / 1 5 8 1 8 1 67
8.pdf
EARUQUI, REB 25
Idaho Power Company
f or residential- DG customers.30
t6
1
2
3
4
5
6
1
I
9
In Arizona, Arizona Public Service and j-ntervenors
reached a settlement agreement which established that
residential DG customers coul-d choose either (1) a three-
part rate
volumetric
customers
is offered
o.
commissions
Are there
addressing
Yes. In
other
the DG
or (2) a two-part rate wj-th a time-of-use
charge and a "grid access charge".:r DG
do not have access to the flat rate option that
to other residential customers.
10
notable cases of regulatory
cost shift challenges?
the Hawaii Public Utilities
11
t2
13
74
15
16
71
18
79
Hawaii,
Commission has ended the state's net energy metering policy
and replaced it with two other options. rz The first is the
"self-supply option" in which DG customers can net their DG
output against their electricity consumpti-on, but are not
compensated for net exports to the grid. The second is the
"grid-suppfy" option, in which all output from the PV
system j-s compensated at a l-evel below the retail
el-ectricity price.
31 The grid access charge is a monthly charge based on the
capaclty of the rooftop PV system; Ari-zona Corporate Commission,
Staff's Notice of Filing Settlement Agreement, Docket No. E-01345A-16-
0036 and Docket No. E-01345A-I 6-0123, March 2'7, 20L'7,
http: / / images. edocket . azcc./docketpdf /00001784 13. pdf .
32 Hawaii Public Util-ities Commission, Decision and Order
Resolving Phase 1, Docket No. 2014-0192; Order No. 33258, October 12,
2015, http: / /pr:'c.hawaii .qov /wp-content/uploads /2 01,5 / L0 / 2014-0192-Order-
Resolving-Phase-1-Issues- f inal . pdf .
FARUQUI, REB 26
Idaho Power Company
1 Additionally, many utillties have pursued rate
2 changes for all customers, such as increasing the monthJ-y
3 customer charge.::
4 Q. What do you conclude from your review of the
5 experj-ence in other jurisdictions?
6 A. Util-ities and regulatory commissions
7 increasingly understand the importance of addressing the
8 challenges associated with the DG cost shift. A variety of
9 approaches have been taken, and the creation of a separate
10 rate class for DG customers is one such approach with
11 precedent in other jurisdictions. In this regard, Idaho
L2 Power's proposal is consistent with experience elsewhere.
13 VIII. CONCLUSION
74 O. Do you support Idaho Power's proposal to
15 create a separate rate cl-ass for DG customers?
L6 A. Yes, I support Idaho Power's proposal. DG
71 customers have unique l-oad characteristics that make them
18 distinctly different from the rest of the residential
79 class. These l-oad characteristics l-ead to a significant
20 cost shift when DG customers are bil-l-ed under the current
27 residential rates with net met.ering. That cost shift will
22 only grow if l-eft unaddressed. Given the trajectory of PV
33 See, for instance, Minnesota PubIic Utility Commission, In the
Nlatter of the Application of Northern States Power Conpany forAuthority to Increase Rates for Efectric Service in Minnesota, Docket
No. 8002/GR-15-826.
FARUQUI, REB 27
Idaho Power Company
1
2
3
4
5
6
1
o
9
adoption in Idaho,
DG rate offering,
O. Does
A. Yes,
it makes sense to proactively reform the
until- it is too late.
testimony?
rather than waiting
this conclude your
it does.
10
11
I2
13
74
15
t6
t1
1B
L9
20
27
22
23
24
25
FARUQUI, REB 28
Idaho Power Company
26
1
2
3
4
5
6
1
B
9
ATTESTATION OE TESTIMONY
STATE OF
SS.
County of ..
I, Dr. Ahmad Faruqui, having been duly sworn to
testify truthfully, and based upon my personal knowledge,
state the following:
I am an energy economist and am competent to be a
witness in this proceeding.
f declare under penalty of perjury of the Iaws of10
11 the state of Idaho that the foregoing rebuttal
1,2 true and correct to_ the best of my information
13 DATED this 26th day of January, 2018.
74
15
76 Dr. Ahmad Faruqui
SUBSCRIBED AND SWORN to before me this
January, 2018.
7-t
1B
testimony is
and belief.
26th day of
L9
20
2L
22
23
24
25
Zf)
Notary Public
Residing at:
My commission expires
for
FARUQUI, REB
Idaho Power Company
r.,,ffi
AI{TOII{ETIE F. ilIVEt{
ilolary Publlc - tht! ol Florftle
My Comm. Erplrar Ocl l6,20tE
Commlselon # FF l{f743
Eon@d Ilrogh t&tlmd t{ffiy f$0.
21
)
)
)
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC.E.17.13
IDAHO POWER COMPANY
FARUQUI, REB
TESTIMONY
EXHIBIT NO. 16
Statement of QSralifications
Dr. Ahmad Faruqui is an energy economist whose work is focused on the efficient use of energy.
His areas of expertise include rate design, demand response, energy efficiency, distributed energy
resources, advanced metering infrastructure, plug-in electric vehicles, energy storage, inter-fuel
substitution, combined heat and power, microgrids, and demand forecasting. He has worked for
nearly 150 clients on 5 continents. These include electric and gas utilities, state and federal
commissions, independent system operators, government agencies, trade associations, research
institutes, and manufacturing companies. Ahmad has testified or appeared before commissions
in Alberta (Canada), Arizona, Arkansas, California, Colorado, Connecticut, Delaware, the
District of Columbia, FERC, Illinois, Indiana, Kansas, Maryland, Minnesota, Nevada, Ohio,
Oklahoma, Ontario (Canada), Pennsylvania, ECRA (Saudi Arabia), and Texas. He has presented
to governments in Australia, Egypt, Ireland, the Philippines, Thailand and the United Kingdom
and given seminars on all 6 continents. His research been cited in Business Week, The
Economist, Forbes, National Geographic, The New York Times, San Francisco Chronicle, San
/ose Mercury News, Wall Street /ournal and USA Today. He has appeared on Fox Business News,
National Public Radio and Voice of America. He is the author, co-author or editor of 4 books and
more than 150 articles, papers and reports on energy matters. He has published in peer-reviewed
journals such as Energy Economics, Energy /ournal, Energy Efficiency, Energy Policy, /ournal of
Regulatory Economics and Utilities Policy and trade journals such as The Electicity /ournal and
the Public Utilities Fortnightly He holds BA and MA degrees from the University of Karachi,
where he was awarded the Gold Medal in Economics, an MA in agricultural economics and a
Ph.D. in economics from The University of California at Davis, where he was a Regents Fellow
and the recipient of a dissertation grant from the Kellogg Foundation.
AREAS OF DGERTISE
Expert witness. He has testified or appeared before state commissions in Arkansas,
California, Colorado, Connecticut, Delaware, the District of Columbia, Illinois,
Indiana, Iowa, Kansas, Michigan, Maryland, Ontario (Canada) and Pennsylvania.
He has assisted clients in submitting testimony in Georgia and Minnesota. He has
made presentations to the California Energy Commission, the California Senate,
the Congressional Office of Technology Assessment, the Kentucky Commission,
the Minnesota Department of Commerce, the Minnesota Senate, the Missouri
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 1 of33
a
a
a
a
Public Service Commission, and the Electricity Pricing Collaborative in the state
of Washington.
Innovative pricing. He has identified, designed and analyzed the efficiency and
equity benefits of introducing innovative pricing designs such as three-part rates,
including fixed monthly charges, demand charges and time-varying energy
charges; dynamic pricing rates, including critical peak pricing, variable peak
pricing and real-time pricing;time-of-use pricing; and inclining block rates.
Regulatory strategy. He has helped design forward-looking programs and services
that exploit recent advances in rate design and digital technologies in order to
lower customer bills and improve utility earnings while lowering the carbon
footprint and preserving system reliability.
Cost-benefit analysis of advanced metering infrastructure. He has assessed the
feasibility of introducing smart meters and other devices, such as programmable
communicating thermostats that promote demand response, into the energy
marketplace, in addition to new appliances, buildings, and industrial processes
that improve energy efficiency.
Demand forecasting and weather normalization He has pioneered the use of a
wide variety of models for forecasting product demand in the near-, medium-,
and long-term, using econometric, time series, and engineering methods. These
models have been used to bid into energy procurement auctions, plan capacity
additions, design customer-side programs, and weather normalize sales.
Customer choice. He has developed methods for surveying customers in order to
elicit their preferences for alternative energy products and alternative energy
suppliers. These methods have been used to predict the market size of these
products and to estimate the market share of specific suppliers.
Hedging, risk management, and market design. He has helped design a wide range
of financial products that help customers and utilities cope with the unique
opportunities and challenges posed by a competitive market for electricity. He
conducted a widely-cited market simulation to show that real-time pricing of
electricity could have saved Californians millions of dollars during the Energy
Crisis by lowering peak demands and prices in the wholesale market.
2
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 2 of 33
a
a
a
Competitive strategy. He has helped clients develop and implement competitive
marketing strategies by drawing on his knowledge of the energy needs of end-use
customers, their values and decision-making practices, and their competitive
options. He has helped companies reshape and transform their marketing
organization and reposition themselves for a competitive marketplace. He has also
helped government-owned entities in the developing world prepare for
privatization by benchmarking their planning, retailing, and distribution
processes against industry best practices, and suggesting improvements by
specifying quantitative metrics and follow-up procedures.
Design and evaluation of marketing programs. He has helped generate ideas for
new products and services, identified successful design characteristics through
customer surveys and focus groups, and test marketed new concepts through
pilots and experiments.
Academic expeience. He has given lectures at the University of California,
Berkeley, University of California, Davis, Harvard University, University of Idaho,
University of Karachi, Massachusetts Institute of Technology, Michigan State
University, Northwestern University, University of San Francisco, San |ose State
University, Stanford University, University of Virginia, and University of
Wisconsin-Madison. Additionally, he has led a variety of professional seminars
and workshops on public utility economics around the world. Finally, he has
taught economics at the university level at San |ose State University, University of
California, Davis, and the University of Karachi.
EXPERIENCE
Innovative Pricing
a Impact Analpis for TOU Rates in Ontario. Measured the impacts of a system-
wide Time of Use (TOU) deployment in the province of Ontario, Canada, on
behalf of the Ontario Power Authority. To account for the lack of a designated
control group, Brattle created a quasi-experimental design that took advantage of
differences in the timing of the TOU rollout.
3
Exhibit No. 't6
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 3 of 33
a
a
Meazurement and evaluation for in-home displays, home energy controllers, smart
appliances, and alternative rates for Florida Power & Light (FPL). Carried out a 2-year
impact evaluation of a dynamic and enabling technology pilot program. Used
econometric methods to estimate the changes in load shapes, changes in peak
demand, and changes in energy consumption for three different treatments. The
results of this study were shared with Department of Energy as to fulfill the data
reporting requirements of FPL's Smart Grid Investment Grant.
Report the costs and benefits of dpamic pricrng in the Australian
energy market. For the Australian Energy Market Commission (AEMC),
developed a report that reviews the various forms of dynamic pricing, such as
time-of-use pricing, critical peak pricing, peak time rebates, and real time pricing,
for a variety of performance metrics including economic efficiency, equity, bill
risk, revenue risk, and risk to vulnerable customers. It also discusses ways in
which dynamic pricing can be rolled out in Australia to raise load factors and
lower average energy costs for all consumers without harming vulnerable
consumers, such as those with low incomes or medical conditions requiring the
use of electricity.
Whitepaper on emerging issues in innovative pricing. For the Regulatory
Assistance Project (RAP), developed a whitepaper on emerging issues and best
practices in innovative rate design and deployment. The paper includes an
overview of AMl-enabled electricity pricing options, recommendations for
designing the rates and conducting experimentd pilots, an overview of recent
pilots, full-deployment case studies, and a blueprint for rolling out innovative
rate designs. The paper's audience is international regulators in regions that
are exploring the potential benefits of smart metering and innovative pricing.
Assessing the full benefits of real-time pricing. For two large Midwestern
utilities, assessed and, where possible, quantified the potential benefits of the
existing residential real-time pricing (RTP) rate offering. The analysis
included not only "conventional" benefits such as avoided resource costs, but
under the direction of the state regulator was expanded to include harder-to-
quantify benefits such as improvements to national security and customer
service.
4
Exhibit No. '16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 4 of 33
a
a
a
a
Pricing and Technology Pilot Design and Impact Evaluation for Connecticut Light
& Power (CL&P). Designed the Plan-It Wise Energy pilot for all classes of
customers and subsequently evaluated the Plan-It Wise Energy program (PWEP)
in the summer of 2009. PWEP tested the impacts of CPP, PTR, and time of use
(TOU) rates on the consumption behaviors of residential and small commercial
and industrial customers.
D5mamic Pricrng Pilot Design and Impact Evaluation: Baltimore Gas & Electric.
Designed and evaluated the Smart Energy Pricing (SEP) pilot, which ran for four
years from 2008 to 2011. The pilot tested a variety of rate designs including
critical peak pricing and peak time rebates on residential customer consumption
patterns. In addition, the pilot tested the impacts of smart thermostats and the
Energy Orb.
Impact Evaluation of a Residential qmarnic Pricing Experiment: C,onsumers
Energy (Midrigan). Designed the pilot and carried out an impact evaluation with
the purpose of measuring the impact of critical peak pricing (CPP) and peak time
rebates (PTR) on residential customer consumption patterns. The pilot also tested
the influence of switches that remotely adjust the duty cycle of central air
conditioners.
Impact Simulation of Ameren Illinois Utilities' Power Smart Pricing Program.
Simulated the potential demand response of residential customers enrolled to real-
time prices. Results of this simulation were presented to the Midwest ISO's
Supply Adequacy Working Group (SAWG) to explore alternative ways of
introducing price responsive demand in the region.
Tlre Case for Dmamic picing: Demand Response Research Center. Led a project
involving the California Public Utilities Commission, the California Energy
Commission, the state's three investor-owned utilities, and other stakeholders in
the rate design process. Identified key issues and barriers associated with the
development of time-based rates. Revisited the fundamental objectives of rate
design, including efficiency and equity, with a special emphasis on meeting the
state's strongly-articulated needs for demand response and energy efficiency.
Developed a score-card for evaluating competing rate designs and applied it to a
set of illustrative rates that were created for four customer classes using actual
utility data. The work was reviewed by a national peer-review panel.
5
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 5 of 33
a
a
Analyzed the Economics of Self-Generation of Steam. Specified, estimated,
tested, and validated a large-scale model that analyzes the response of some 2,000
large commercial customers to rising steam prices. The model includes a module
for analyzing conservation behavior, another module for the probability of self-
generation switching behavior, and a module for forecasting sales and peak
demand.
Design and Impact Evaluation of the Statewide Pricing Pilou Three California
Utilities. Working with a consortium of California's three investor-owned
utilities to design a statewide pricing pilot to test the efficacy of dynamic pricing
options for mass-market customers. The pilot was designed using scientific
principles of experimental design and measured changes in usage induced by
dynamic pricing for over 2,500 residential and small commercial and industrial
customers. The impact evaluation was carried out using state-of-the-art
econometric models. Information from the pilot was used by all three utilities in
their business cases for advanced metering infrastructure (AMI). The project was
conducted through a public process involving the state's two regulatory
commissions, the power agency, and several other parties.
Economics of Dynamic Pricing: Two C,alifornia Utilities. Reviewed a wide range
of dynamic pricing options for mass-market customers. Conducted an initial cost-
effectiveness analysis and updated the analysis with new estimates of avoided
costs and results from a survey of customers that yielded estimates of likely
participation rates.
Economics of Time-of-Use Pricing: A Pacific Northwest Utility. This utility ran
the nation's largest time-of-use pricing pilot program. Assessed the cost-
effectiveness of alternative pricing options from a variety of different perspectives.
Options included a standard three-part time-of-use rate and a quasi-real time
variant where the prices vary by day. Worked with the client in developing a
regulatory strategy. Worked later with a collaborative to analyze the program's
economics under a variety of scenarios of the market environment.
Economics of Dynamic Pricing Options for Mass Market Customers - Client A
Multi-State Utility. Identified a variety of pricing options suited to meet the
needs of mass-market customers, and assessed their cost-effectiveness. Options
6
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 6 of 33
a
a
a
a
a
included standard three-part time-of-use rates, critical peak pricing, and extreme-
day pricing. Developed plans for implementing a pilot program to obtain primary
data on customer acceptance and load shifting potential. Worked with the client
in developing a regulatory strategy.
Real-Time Pricing in Cdifornia - Client: California Energy Commission.
Surveyed the national experience with real-time pricing of electricity, directed at
large power customers. Identified lessons learned and reviewed the reasons why
California was unable to implement real-time pricing. Catalogued the barriers to
implementing real-time pricing in California, and developed a program of
research for mitigating the impacts of these barriers.
Market-Based Pricing of Electricity - Client A Large Southern Utility. Reviewed
pricing methodologies in a variety of competitive industries including airlines,
beverages, and automobiles. Recommended a path that could be used to transition
from a regulated utility environment to an open market environment featuring
customer choice in both wholesale and retail markets. Held a series of seminars
for senior management and their staffs on the new methodologies.
Tools for Electricity Priciog - Clienc Consortium of Several U.S. and Forergn
Utilities. Developed Product Mix, a software package that uses modern finance
theory and econometrics to establish a profit-maximizing menu of pricing
products. The products range from the traditional fixed-price product to time-of-
use prices to hourly real-time prices, and also include products that can hedge
customers' risks based on financial derivatives. Outputs include market share,
gross revenues, and profits by product and provider. The calculations are
performed using probabilistic simulation, and results are provided as means and
standard deviations. Additional results include delta and gamma parameters that
can be used for corporate risk management. The software relies on a database of
customer load response to various pricing options called StatsBank. This database
was created by metering the hourly loads of about one thousand commercial and
industrial customers in the United States and the United Kingdom.
Risk-Based Pricing - Client Midwestern Utility. Developed and tested new
pricing products for this utility that allowed it to offer risk management services
to its customers. One of the products dealt with weather risk; another one dealt
7
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 7 of 33
with risk that real-time prices might peak on a day when the customer does not
find it economically viable to cut back operations.
Demand Response
. Combined Heat and Power Generation Sttrdy. Investigated the economic
potential for combined heat and power and regulatory policies to unlock that
potential in a Middle Eastern country.
National Action Plan for Demand Response: Federal Energy Regulatory
Commission. Led a consulting team developing a national action plan for
demand response (DR). The national action plan outlined the steps that need
to be taken in order to maximize the amount of cost-effective DR that can be
implemented. The final document was filed with U.S. Congress in |une 2010.
a
a
a
National Assessment of Demand Response Potentiat Federal Energy
Regulatory Commission, Led a team of consultants to assess the economic and
achievable potential for demand response programs on a state-by-state basis.
The assessment was filed with the U.S. Congress in 2009, as required by the
Energy Independence and Security Actof2007.
Demand response program reniew for Integrated Resource Plan
development. In response to legislation requiring the Connecticut
utilities to jointly prepare a lO-year integrated resource plan, we
conducted the analysis and helped prepare the plan. In coordination
with the two leading utilities in the state, we conducted a detailed
analysis of alternative resource solutions (both supply- and demand-
side), drafted the report, and presented it to the Connecticut Energy
Advisory Board. The analysis involved a detailed review and critique
of the companies' proposed DR programs.
Integration of DR into wholesale energy markets. Developed a
whitepaper, "Fostering Economic Demand Response in the Midwest
ISO," evaluating alternative approaches to efficiently integrating DR
into its energy markets while encouraging increased participation. This
work involved interviewing market participants and analyzing several
approaches to economic DR regarding economic efficiency,
8
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page I of 33
a
a
participation rates, operational fit with other ISO rules, and
susceptibility to state-level and lSO-level implementation barriers.
This work also involved an extensive survey of DR programs
(qualification criteria, bidding rules, incorporation into market clearing
software, measurement and verification, and settlement) in ISO/
Regional Transmission Organization (RTO) markets around the
country. The project also required a detailed review of existing DR
program tariffs for utilities in the RTO's service territory and
development of a matrix for summarizing the various characteristics of
these programs.
Integration of DR into resource adequacy constnrcts. For the Midwest
ISO, assisted in developing qualification criteria for DR as a capacity
resource (we also developed estimates of likely future contributions of
DR to resource adequacy, for use by their transmission planning
group). For PlM, as part of our review of its capacity market, we
developed recommendations on how to treat DR comparably to
generation resources while accounting for the special attributes of DR.
Our recommendations addressed product definition, auction rules, and
penalty provisions. For the Connecticut utilities in their integrated
resource planning, we evaluated future resource needs given various
levels of demand response progrirms.
Evaluation of the Demand Response Benefits of Advanced Metering
Infrastructure: Mid-Atlantic Utifity. Conducted a comprehensive assessment
of the benefits of advanced metering infrastructure (AMI) by developing
dynamic pricing rates that are enabled by AMI. The analysis focused on
customers in the residential class and commercial and industrial customers
under 600 kW load.
Estimation of Demand Response Impacts: Major C,alifornia Utility. Worked
with the staff of this electric utility in designing dynamic pricing options for
residential and small commercial and industrial customers. These options were
designed to promote demand response during critical peak days. The analysis
supported the utility's advanced metering infrastructure (AMI) filing with the
9
Exhibit No. 16
Case No IPC-E-17-13
A. Faruqui, IPC
Page 9 of 33
California Public Utilities Commission. Subsequently, the commission
unanimously approved a $1.7 billion plan for rolling out nine million electric
and gas meters based in part on this project work.
Smart Grid Strategy
a Development of a smart grid investment roadmap for Vietnamese
utilities. For the five Vietnamese power corporations, developed a roadmap to
guide future smart grid investment decisions. The report identified and
described the various smart grid investment options, established objectives for
smart grid deployment, presented a multi-phase approach to deploying the
smart grid, and provided preliminary recommendations regarding the best
investment opportunities. Also presented relevant case studies and an
assessment of the current state of the Vietnamese power grid. The project
involved in-country meetings as well as a stakeholder workshop that was
conducted by Brattle staff.
Cost-Benefit Analysis of the Smart Grid: Rocky Mountain Utility. Reviewed
the leading studies on the economics of the smart grid and used the findings to
assess the likely cost-effectiveness of deploying the smart grid in one
geographical location.
Modeling benefits of smart grid deployment strategies. Developed a model for
assessing benefits of smart grid deployment strategies over a long-term (e.g.,
20-year) forecast horizon. The model, called iGrid, is used to evaluate seven
distinct smart grid programs and technologies (e.g., dynamic pricing, energy
storage, PHEVs) against seven key metrics of value (e.g., avoided resource
costs, improved reliability).
Smart grid strategy in Canada. The Alberta Utilities Commission (AUC) was
charged with responding to a Smart Grid Inquiry issued by the provincial
government. Advised the AUC on the smart grid, and what impacts it might
have in Alberta.
Smart grid deployment anal)rsis for collaborative of utilities. Adapted the iGrid
modeling tool to meet the needs of a collaborative of utilities in the southern
U.S. In addition to quantiry/ing the benefits of smart grid programs and
a
a
10
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page '10 of 33
a
a
a
technologies (e.9., advanced metering infrastructure deployment and direct
load control), the model was used to estimate the costs of installing and
implementing each of the smart grid programs and technologies.
Development of a smart grid cost-benefit analysis fiamework. For the Electric
Power Research Institute (EPRI) and the U.S. DOE, contributed to the
development of an approach for assessing the costs and benefits of the DOE's
smart grid demonstration programs.
Analysis of the benefits of increased access to energy consumption
information. For a large technology firm, assessed market opportunities for
providing customers with increased access to real time information regarding
their energy consumption patterns. The analysis includes an assessment of
deployments of information display technologies and analysis of the potential
benefits that are created by deploying these technologies.
Developing a plan for integrated smart grid systems. For a large California
utility, helped to develop applications for funding for a project to demonstrate
how an integrated smart grid system (including customer-facing technologies)
would operate and provide benefits.
Demand Forecasting
Ioad Forecast Bottom-Up Modelling Sudy. Reviewed the load forecasting
methodology for a major Malaysian utility company and developed a load
forecast model using a bottom-up approach.
Analyzed electricity consrmption and maximum demand for a major electric
company in Hong Kong.
Forecasting Review. Evaluated and critiqued the process conducted by an
Australian utility company's electricity market forecasting, including the
forecasting of electricity demand, supply, and price.
Comprehensive Review of Load Forecasting Methodology. PIM
Interconnection. Conducted a comprehensive review of models for
forecasting peak demand and re-estimated new models to validate
recommendations. Individual models were developed for 18 transmission
zones as well as a model for the RTO system.
a
l1
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 11 of33
a
a
Analyzed Downward Trend: Western Utility. We conducted a strategic
review of why sales had been lower than forecast in a year when economic
activity had been brisk. We developed a forecasting model for identifying
what had caused the drop in sales and its results were used in an executive
presentation to the utility's board of directors. We also developed a time series
model for more accurately forecasting sales in the near term and this model is
now being used for revenue forecasting and budgetary planning.
Analyzed Why Models are Under-Foreca*iag: Southwester:r Utility.
Reviewed the entire suite of load forecasting models, including models for
forecasting aggregate system peak demand, electricity consumption per
customer by sector and the number of customers by sector. We ran a variety
of forecasting experiments to assess both the ex-ante and ex-post accuracy of
the models and made several recommendations to senior management.
U.S. Demand Forecase Edison Electric Instinrte. For the U.S. as a whole, we
developed a base case forecast and several alternative case forecasts of electric
energy consumption by end use and sector. We subsequently developed
forecasts that were based on EPRI's system of end-use forecasting
models. The project was done in close coordination with several utilities and
some of the results were published in book form.
Developed Models for Foreca.sting Hourly Loads: Merchant Generation and
Trading Company. Using primary data on customer loads, weather conditions,
and economic activity, developed models for forecasting hourly loads for
residential, commercial, and industrial customers for three utilities in a
Midwestern state. The information was used to develop bids into an auction
for supplying basic generation services.
Gas Demand Forecasting Syst"- - Client A Leading Gas Marketing and
Trading Company, Toras. Developed a system for gas nominations for a
leading gas marketing company that operated in 23 local distribution company
service areas. The system made week-ahead and month-ahead forecasts using
advanced forecasting methods. Its objective was to improve the marketing
company's profitability by minimizing penalties associated with forecasting
errors.
t2
Exhibit No. 16
Case No. IPC-E-17-'13
A. Faruqui, IPC
Page 12 of 33
a
a
Demand Side Management
a
a
the Economics of Biofuels. For a western utility that is facing stringent
renewable portfolio standards and that is heavily dependent on imported fossil
fuels, carried out a systematic assessment of the technical and economic ability
of biofuels to replace fossil fuels.
Assessment of Demand-Side Management and Rate Design Options: Large
Middle Eastern Electric Utihty. Prepared an assessment of demand-side
management and rate design options for the four operating areas and six
market segments. Quantified the potential gains in economic efficiency that
would result from such options and identified high priority programs for pilot
testing and implementation. Held workshops and seminars for senior
management, managers, and staff to explain the methodology, data, results,
and policy implications.
Likely Future Impact of Demand-Side Programs on Carbon Emissions - Client:
The Kqrstone Center. As part of the Keystone Dialogue on Climate Change,
developed scenarios of future demand-side program impacts, and assessed the
impact of these programs on carbon emissions. The analysis was carried out at
the national level for the U.S. economy, and involved a bottom-up approach
involving many different types of programs including dynamic pricing, energy
efficiency, and traditional load management.
Sustaining Energy EfEciency Services in a RestmcnEed Market - Client:
Southern California Edison. Helped in the development of a regulatory
strategy for implementing energy efficiency strategies in a restructured
marketplace. Identified the various players that are likely to operate in a
competitive market, such as third-party energy service companies (ESCOS)
and utility affiliates. Assessed their objectives, strengths, and weaknesses and
recommended a strategy for the client's adoption. This strategy allowed the
client to participate in the new market place, contribute to public policy
objectives, and not lose market share to new entrants. This strategy has been
embraced by a coalition of several organizations involved in the California
PUC's working group on public purpose programs.
13
Exhibit No. 16
Case No IPC-E-1 7-13
A. Faruqui, IPC
Page '13 of 33
Organizational Assessments of Capability for Energy Efficiency - Client U.S.
Agency for International Development, Cairo, Egypt. Conducted in-depth
interviews with senior executives of several energy organizations, including
utilities, government agencies, and ministries to determine their goals and
capabilities for implementing programs to improve energy end-use efficiency
in Egypt. The interviews probed the likely future role of these organizations
in a privatized energy market, and were designed to help develop U.S. AID's
future funding agenda.
Enhancing Profitability Through Energy Efficiency Services - Client |amaica
Public Service Company. Developed a plan for enhancing utility profitability
by providing financial incentives to the client utility, and presented it for
review and discussion to the utility's senior management and |amaica's new
Office of Utility Regulation. Developed regulatory procedures and legislative
language to support the implementation of the plan. Conducted training
sessions for the staff of the utility and the regulatory body.
Advanced Technology Assessment
Competitive Energy and Environmentd Technologies - Clients: Consortium
of clients, Ied by Southern California Edison, Included the Los Angeles
Department of Water and Power and the C,alifornia Energy Commission.
Developed a new approach to segmenting the market for electrotechnologies,
relying on factors such as type of industry, type of process and end use
application, and size of product. Developed a user-friendly system for
assessing the competitiveness of a wide range of electric and gas-fired
technologies in more than 100 four-digit SIC code manufacturing industries
and 20 commercial businesses. The system includes a database on more than
200 end-use technologies, and a model of customer decision making.
Market Infrastnrcnrre of Energy Efficient Technologies - Client: EPRI.
Reviewed the market infrastructure of five key end-use technologies, and
identified ways in which the infrastructure could be improved to increase the
penetration of these technologies. Data was obtained through telephone
interviews with equipment manufacturers, engineering firms, contractors, and
end-use customers.
a
a
a
l4
Exhibit No. '16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 14 of 33
TESTIMOI{Y
fukansas
Direct Testimony before the Arkansas Public Service Commission on behalf of Entergy Arkansas,
Inc., in the matter of Entergy Arkansas, Inc.'s Application for an Order Finding the Deployment
of Advanced Metering Infrastructure to be in the Public Interest and Exemption from Certain
Applicable Rules, Docket No. 16-060-U, September 19,2016.
Arizona
Direct Testimony before the Arizona Corporation Commission on behalf of Arizona Public
Service Company, in the matter of the Application of Arizona Public Service Company for a
Hearing to Determine the Fair Value of the Utility Property of the Company for Ratemaking
Purposes, to Fix a |ust and Reasonable Rate of Return Thereon, to Approve Rate Schedules
Designed To Develop Such Return, Docket No. E-01345A.-16-0036, |une 1, 2016.
Direct Testimony before the Arizona Corporation Commission on behalf of Arizona Public
Service Company, in the matter of the Application for UNS Electric, Inc. for the Establishment of
Just and Reasonable Rates and Charges Designed to Realize a Reasonable Rate of Return on the
Fair Value of the Properties of UNS Electric, Inc. Devoted to the its Operations Throughout the
State of Arizona, and for Related Approvals, Docket No. E-04204A-15-0142, December 9, 2015.
California
Rebuttal Testimony before the Public Utilities Commission of the State of California, Pacific Gas
and Electric Company Joint Utility on Demand Elasticity and Conservation Impacts of Investor-
Owned Utility Proposals, in the Matter of Rulemaking 12-06-013, October 17 ,2014.
Prepared testimony before the Public Utilities Commission of the State of California on behalf of
Pacific Gas and Electric Company on rate relief, Docket No. A.10-03-014, summer 2010.
Qualifications and prepared testimony before the Public Utilities Commission of the State of
California, on behalf of Southern California Edison, Edison SmartConnectrM Deployment
Funding and Cost Recovery, exhibit SCE-4, fuly 31, 2007.
Testimony on behalf of the Pacific Gas & Electric Company, in its application for Automated
Metering Infrastructure with the California Public Utilities Commission. Docket No. 05-06-028,
2006.
15
Exhibit No. 16
Case No IPC-E-17-13
A. Faruqui, IPC
Page '1 5 of 33
Colorado
Rebuttal testimony before the Public Utilities Commission of the State of Colorado in the Matter
of Advice Letter No. 1535 by Public Service Company of Colorado to Revise its Colorado PUC
No.7 Electric Tariff to Reflect Revised Rates and Rate Schedules to be Effective on June 5, 2009.
Docket No. 09al-299e, November 25, 2009.
Direct testimony before the Public Utilities Commission of the State of Colorado, on behalf of
Public Service Company of Colorado, on the tariff sheets filed by Public Service Company of
Colorado with advice letter No. 1535 - Electric. Docket No. 09S-_E, May 1, 2009.
Connecticut
Testimony before the Department of Public Utility Control, on behalf of the Connecticut Light
and Power Company, in its application to implement Time-of-Use , Intemrptible Load Response,
and Seasonal Rates- Submittal of Metering and Rate Pilot Results- Compliance Order No. 4,
Docket no. 05-10-03RE01, 2007.
District of Columbia
Direct testimony before the Public Service Commission of the District of Columbia on behalf of
Potomac Electric Power Company in the matter of the Application of Potomac Electric Power
Company for Authorization to Establish a Demand Side Management Surcharge and an Advance
Metering Infrastructure Surcharge and to Establish a DSM Collaborative and an AMI Advisory
Group, case no. 1056, May 2009.
Illinois
Direct testimony on rehearing before the Illinois Commerce Commission on behalf of Ameren
Illinois Company, on the Smart Grid Advanced Metering Infrastructure Deployment Plan,
Docket No. 12-0244, |une 28,2012.
Testimony before the Illinois Commerce Commission on behalf of Commonwealth Edison
Company regarding the evaluation of experimental residential real-time pricing program, 11-
0546, April2012.
Rebuttal Testimony before the Illinois Commerce Commission on behalf of Commonwealth
Edison Company in the matter of the Petition to Approve an Advanced Metering
Infrastructure Pilot Program and Associated Tariffs, No. 09-0263, August 14,2009.
Prepared rebuttal testimony before the Illinois Commerce Commission on behalf of
Commonwealth Edison, on the Advanced Metering Infrastructure Pilot Program, ICC Docket
No. 06-0617, October 30,2006.
16
Exhibit No. 16
Case No. IPC-E-'|7-13
A. Faruqui, IPC
Page 16 of 33
Indiana
Direct testimony before the State of Indiana, Indiana Utility Regulatory Commission, on behalf
of Vectren South, on the smart grid. Cause no. 43810, 2009.
Kansas
Direct testimony before the State Corporation Commission of the State of Kansas, on behalf of
Westar Energy, in the matter of the Application of Westar Energy, Inc. and Kansas Gas and
Electric Company to Make Certain Changes in Their Charges for Electric Service, Docket No. 15-
WSEE-l 15-RTS, March 2, 2015.
Louisiana
Direct testimony before the Louisiana Public Service Commission on behalf of Entergy Louisiana,
LLC, in the matter of Approval to Implement a Permanent Advanced Metering System and
Request for Cost Recovery and Related Relief in accordance with Louisiana Public Service
Commission General Order dated September 22, 2009,R-29213, November 2016.
Direct testimony before the Council of the City of New Orleans, on behalf of Entergy New
Orleans, Inc., in the matter of the Application of Energy New Orleans, Inc. for Approval to
Deploy Advanced Metering Infrastructure, and Request for Cost Recovery and Related Relief,
October 2016.
Maryland
Direct Testimony before the Maryland Public Service Commission, on behalf of Potomac
Electric Power Company in the matter of the Application of Potomac Electric Power
Company for Adjustments to its Retail Rates for the Distribution of Electric Energy, April 19,
2016.
Rebuttal Testimony before the Maryland Public Service Commission on behalf of Baltimore
Gas and Electric Company in the matter of the Application of Baltimore Gas and Electric
Company for Adjustments to its Electric and Gas Base Rates, Case No. 9406, March 4,2016.
Direct testimony before the Public Service Commission of Maryland, on behalf of Potomac
Electric Power Company and Delmarva Power and Light Company, on the deployment of
Advanced Meter Infrastructure. Case no.9207, September 2009.
Prepared direct testimony before the Maryland Public Service Commission, on behalf of
Baltimore Gas and Electric Company, on the findings of BGE's Smart Energy Pricing ("SEP")
Pilot program. Case No. 9208, |uly 10, 2009.
17
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page '17 of 33
Minnesota
Rebuttal testimony before the Minnesota Public Utilities Commission State of Minnesota on
behalf of Northern States Power Company, doing business as Xcel Energy, in the matter of the
Application of Northern States Power Company for Authority to Increase Rates for Electric
Service in Minnesota, Docket No. E002/GR-12-961, March 25,2013.
Direct testimony before the Minnesota Public Utilities Commission State of Minnesota on behalf
of Northern States Power Company, doing business as Xcel Energy, in the matter of the
Application of Northern States Power Company for Authority to Increase Rates for Electric
Service in Minnesota, Docket No. E002/GR-12-961, November 2,2012.
Mississippi
Direct testimony before the Mississippi Public Service Commission, on behalf of Entergy
Mississippi, Inc., in the matter of Application for Approval of Advanced Metering Infrastructure
and Related Modernization Improvements, EC- 123-0082-00, November 2016.
Nevada
Prepared rebuttal testimony before the Public Utilities Commission of Nevada on behalf of
Nevada Power Company and Sierra Pacific Power Company d/b/a NV Energy, in the matter of
net metering and distributed generation cost of service and tariff design, Docket Nos. 15-07041
and 15-07042, November 3, 2015.
Prepared direct testimony before the Public Utilities Commission of Nevada on behalf of Nevada
Power Company d/b/a NV Energy, in the matter of the application for approval of a cost of
service study and net metering tariffs, Docket No. 15-07, fuly 31, 2015.
New Me:rico
Direct testimony before the New Mexico Regulation Commission on behalf of Public Service
Company of New Mexico in the matter of the Application of Public Service Company of New
Mexico for Revision of its Retail Electric Rates Pursuant to Advice Notice No. 507, Case No. 14-
00332-UT, December ll, 2014.
Oklahoma
Rebuttal Testimony before the Corporation Commission of Oklahoma on behalf of Oklahoma
Gas and Electric Company in the matter of the Application of Oklahoma Gas and Electric
Company for an Order of the Commission Authorizing Applicant to modify its Rates, Charges
and Tariffs for Retail Electric Service in Oklahoma, Cause No. PUD 201500273, April 11, 2016.
18
Exhibit No. 16
Case No. IPC-E-I7-13
A. Faruqui, IPC
Page 18 of 33
Direct Testimony before the Corporation Commission of Oklahoma on behalf of Oklahoma Gas
and Electric Company in the matter of the Oklahoma Gas and Electric Company for an Order of
the Commission Authorizing Applicant to modify its Rates, Charges and Tariffs for Retail
Electric Service in Oklahoma, Cause No. PUD 201500273, December 18,2015.
Responsive Testimony before the Corporation Commission of Oklahoma on behalf of Oklahoma
Gas and Electric Company in the matter of the Application of Brandy L. Wreath, Director of the
Public Utility Division, for Determination of the Calculation of Lost Net Revenues and Shared
Savings Pursuant to the Demand Program Rider of Oklahoma Gas and Electric Company, Cause
No. PUD 201500153, May 13,2015.
Pennsylvania
Direct testimony before the Pennsylvania Public Utility Commission, on behalf of PECO on the
Methodology Used to Derive Dynamic Pricing Rate Designs, Case no. M-2009-2123944, October
28,2010.
Washington
Prefiled Direct Testimony before the Washington Utilities and Transportation Commission on
Behalf of Puget Sound Energy, Dockets UE-151871 and UG-151872, February 25,2076.
REGULATORY APPEARANCES
fukansas
Presented before the Arkansas Public Service Commission, "The Emergence of Dynamic Pricing"
at the workshop on the Smart Grid, Demand Response, and Automated Metering Infrastructure,
Little Rock, Arkansas, September 30,2009.
Delaware
Presented before the Delaware Public Service Commission, "The Demand Response Impacts of
PHI's Dynamic Pricing Program" Delaware, September 5,2007.
Kansas
Presented before the State Corporation Commission of the State of Kansas, "The Impact of
Dynamic Pricing on Westar Energy" at the Smart Grid and Energy Storage Roundtable, Topeka,
Kansas, September 18, 2009.
Ohio
Presented before the Ohio Public Utilities Commission, "Dynamic Pricing for Residential and
Small C&I Customers" at the Technical Workshop, Columbus, Ohio, March28,20l2.
19
Exhibit No. 16
Case No.lPC-E-'|7-13
A. Faruqui, IPC
Page 19 of 33
Texas
Presented before the Public Utility Commission of Texas, "Direct Load Control of Residential Air
Conditioners in Texas," at the PUCT Open Meeting, Austin, Texas, October 25,2012.
PI'BLICATIONS
Books
Electricity Pricing in Transition Co-editor with Kelly Eakin. Kluwer Academic Publishing,
2002.
Pricing in Competitive Electicity Markets. Co-editor with Kelly Eakin. Kluwer Academic
Publishing, 2000.
Customer Choice: Finding Value in Retail Electicity Markets. Co-editor with f. Robert Malko.
Public Utilities Inc. Vienna. Virginia: 1999.
The Changing Structure of American Industry and Energy Use Pattems. Co-editor with
|ohn Broehl. Battelle Press, 1987.
"Making the Most of the No Load Growth Business Environment," with Dian Grueneich.
Distributed Generation and lts Implications for the Utility Industry. Ed. Fereidoon P. Sioshansi.
Academic Press, 2014. 303-320.
"Arcturus. An International Repository of Evidence on Dynamic Pricing," with Sanem Sergici.
Smart Grid Applications and Developments, Green Energy and Technology. Ed. Daphne Mah,
Ed. Peter Hills, Ed. Victor O. K. Li, Ed. Richard Balme. Springer, 2014.59-74.
"Will Energy Efficiency make a Difference," with Fereidoon P. Sioshansi and Gregory Wikler.
Energy Efficiency: Towards the end of demand growth. Ed. Fereidoon P. Sioshansi. Academic
Press, 2013. 3-50.
"The Ethics of Dynamic Pricing." Smart Grid: Integrating Renewable, Distributed & Efficient
Energy. Ed. Fereidoon P. Sioshansi. Academic Press, 2012. 61-83.
"The Dynamics of New Construction Programs in the 90s: A Review of the North American
Experience," with G.A. Wikler. Proceedings of the 1992 Conference on New Construction
Program s for Demand -Sid e Managemen t, May 1992.
20
Exhibit No. 16
Case No. IPC-E-1 7-13
A. Faruqui, IPC
Page 20 of 33
Customer Response to Time of Use Rates: Topic Paper 1, with Dennis Aigner and Robert T.
Howard, Electric Utility Rate Design Study, EPRI, 1981.
Chapten in Books
"Forecasting Commercial End-Use Consumption" (Chapter 7), "Industrial End-Use Forecasting"
(Chapter 8), and "Review of Forecasting Software" (Appendix 2) in Demand Forecasting in the
Electic Utility Industry. C.W. Gellings and P.E. Lilbum (eds.): The Fairmont Press, 1992.
"Innovative Methods for Conducting End-Use Marketing and Load Research for Commercial
Customers: Reconciling the Reconciled," with G.A. Wikler, T. Alereza, and S. Kidwell.
Proceedings of the Fifth National DSM Conference. Boston, MA, September 1991.
"Time-of-Use Rates and the Modification of Electric Utility Load Shapes," with f. Robert Malko,
Challenges for Public Utility Regulation in the 1980s, edited by H.M. Trebing, Michigan State
University Public Utilities Papers, 1981.
"Implementing Time-Of-Day Pricing of Electricity: Some Current Challenges and Activities,"
with f. Robert Malko, Issues in Public Utility Picing and Regularrbz, edited by M. A. Crew,
Lexington Books, 1980.
Technical Reports
Quantifying the Amount and Economic Impacts of Missing Energy Efficiency in P/M's Load
Forecast, with Sanem Sergici and Kathleen Spees, prepared for The Sustainable FERC
Project, September 201 4.
Structure of Electicity Distribution Network Tariffs: Recovery of Residual Costs, with Toby
Brown, prepared for the Australian Energy Market Commission, August 2014.
Time-Varying and Dynamic Rate Design, with Ryan Hledik and fennifer Palmer, prepared
for RAP, lu,ly 2012. hLtp:,rr w\vw.raponline.orp-decument,'download,/id,:513 i
The Costs and Benefits of Smart Meters for Residential Customerg with Adam Cooper, Doug
Mitarotonda, |udith Schwartz, and Lisa Wood, prepared for Institute for Electric Efficiency,
July 2011.
http:,"www.smartgridnelvs.coinrartman, uploads,'I lFlFl Benefits of Smart \'leters F'inal.pdf
Measurement and Verification Principles for Behauior-Based Efficiency Programs, with
Sanem Sergici, prepared for Opower, M"y 2011.
http:,','opower.com,uploads,'librarv'fi1e,'-l0,/brattle mv'principles.pdf
Methodological Approach for Estimating the Benefits and Costs of Smart Gnd
Demonstration Projects. With R. Lee, S. Bossart, R. Hledik, C. Lamontagne, B. Renz, F.
Small, D. Violette, and D. Walls. Pre-publication draft, prepared for the U. S. Department of
Energy, Office of Electricity Delivery and Energy Reliability, the National Energy
Technology Laboratory, and the Electric Power Research Institute. Oak Ridge, TN: Oak
Ridge National Laboratory, November 28, 2009.
2t
Exhibit No. 't6
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 21 of 33
Mouing Toward Utility-Scale Deployment of Dynamic Pricing in Mass Markers. With Sanem
Sergici and Lisa Wood. Institute for Electric Efficiency, |une 2009.
Demand-Side Bidding in Wholesale Electricity Markets. With Robert Earle. Australian Energy
Market Commission, 2008. http://www.aemc.gov.au/electricity.php?r=20071025.174223
Assessment of Achievable Potential for Energy Efficiency and Demand Response in the U.S.
(2010-2030). With Ingrid Rohmund, Greg Wikler, Omar Siddiqui, and Rick Tempchin.
American Council for an Energy-Efficient Economy, 2008.
Quantifying the Benefits of Dynamic Pricing in the Mass Marker. With Lisa Wood. Edison
Electric Institute, |anuary 2008.
California Energy Commission. 200T Integrated Energy Policy Report, CEC-100-2007-008-CMF.
Applications of Dynamic Pricing in Developing and Emerging Economies. Prepared for The
World Bank, Washington, DC. May 2005.
Preventing Electrical Shocks: What Ontaio-And Other Provinces-Should Learn About Smart
Meteing. With Stephen S. George. C. D. Howe Institute Commentary, No. 210, April2005.
Primer on Demand-Side Managemenr. Prepared for The World Bank, Washington, DC. March
21,2005.
Electicity Picing: Lessons from the Front. With Dan Violette. White Paper based on the May
2003 AESP/EPRI Pricing Conference, Chicago, Illinois, EPRI Technical Update 1002223,
December 2003.
Electric Technologies for Gas Compression Electric Power Research Institute, 1997.
Electrotechnologies for Multifamily Housing. With Omar Siddiqui. EPRI TR-106442, Volumes I
and 2. Electric Power Research Institute, September 1996.
Opportunities for Energy Efficiency in the Texas Industial Sector. Texas Sustainable Energy
Development Council. With f. W. Zarnikau et al. fune 1995.
Principles and Practice of Demand-Side Managemerr. With |ohn H. Chamberlin. EPRI TR-
102556. Palo Alto: Electric Power Research Institute, August 1993.
EPRI Urban Initiative, 1992 Workshop Proceedings (Part I). The EPRI Community Initiative.
With G.A. Wikler and R.H. Manson. TR-102394. Palo Alto: Electric Power Research Institute,
May 1993.
Practical Applications of Forecasting Under Uncertainry. With K.P. Seiden and C.A. Sabo.TR-
102394. Palo Alto: Electric Power Research Instirute, December 1992.
22
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 22 of 33
Improving the Marketing fn{rastructure of Efricient Technologies A Case Study Approach. With
S.S. Shaffer. EPRI TR- I 0 I 454. Palo Alto: Electric Power Research Institute, December 1992.
Customer Response to Rate Options. With |. H. Chamberlin, S.S. Shaffer, K.P. Seiden, and S.A.
Blanc. CU-7131. Palo Alto: Electric Power Research Institute (EPRI), |anuary 1991.
Articles and Papers
"Arcturus 2.0: A meta-analysis of time-varying rates for electricity," with Sanem Sergici and
Cody Warner, The Electricity /ournal,30:10, December 2017,pp. 64-72.
https:,,'$ \ '\!'.sciencedirect.com,'science article, piiiS l0'1t1619017'-1027iA
"Moving Forward with Tariff Reform," with Mariko Geronimo Aydin, Energy Regulation
Quarterly, Volume 5, Issue 4, December 2017.
htlp;irlwwlv.en-ejgytegulalio_rrquarteliy,,galartlqle-/movinB_forrvard-wilh_tariff
1qfq1m#ethas[.!AD{m Z2h,DZLI y z) z,Qpbs
"Innovations in Pricing: Giving Customers What They 'Want," Electic Perspectives,
September/October 201 7.
http://mvdigimag.rrd.com;-publicatiqnl?i=435343#["issue id":435343,'lpage ':42]
"Moving Forward with Electricity Tariff Reform," with Mariko Geronimo Aydin,
Regulation,FaII20lT.
https:/i object.cato.org/sites/cato.org/filesi serialq/fileq/regulatio-ni 2017 l9lregulatio-n -v40n3-
5.pdf
"Enhancing Customer-Centricity," with Henna Trewn, Public Utilities Fortnightly, August
20t7.
https:.,','w-w,w. fortnightly.comi fortniehtl-v12017,'08,'en hancing-customer-cen tricitr.'
"The Public Benefits of Leasing Energy Efficient Equipment," with Neil Lessem and Henna
Trewn, The Electricity /ournal,30:6, fuly 2017, pp. 8-16.
http:,",,r,vr,vw.sciencedirect.comi scie'ncei articlei pii,'S 10,106190173015 l3
"Rethinking Customer Research in the Utiliry Industry," with Henna Trewn, Public Utilities
Fortnightly,fly 2017.
htqp-9;;17.www.fo;tn!ghtly,co-ny/fortnightlyi2OlT lUT lrethink|qg-custome-r-research
"Do Manufacturing Firms Relocate in Response to Rising Electric Rates?" with Sanem
Sergici, Energy Regulation Quarterly, 5:2, lrne 2017 .
hqp-;,r/www,eog-.rgyrggulqi,q-r-rquartgr-ly.cai artislesldo-man-u-fqcturlng-firms-relo.c,E1-e-in
response-to-nsing-electric -rates#sthash.u [.n rP NIwh.dpbs
23
Exhibit No. '16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 23 of 33
"Dynamic Pricing Works in a Hot, Humid Climate," with Neil Lessem and Sanem Sergici,
Pu blic Utili ties Fortnightly, May 2017 .
https:,iiw-r.vrv.fortniqhtl-v.comi fortnighth'i2017,'05, dvnamic-pricing-lvorks-irot-humid
climate
"The impact of advanced metering infrastructure on energy conservation: A case study of
two utilities," with Kevin Arritt and Sanem Sergici, The Electricity /ournal,30:3, April 2017,
pp. 56-63.
ht ap:,'r'r.v'lvw'. sciencedirect.com,lsc iencei'arlic [e,,'piir S 10406 19017300726
"The impact of AMl-enabled conservation voltage reduction on energy consumption and
peak demand," with Kevin Arritt and Sanem Sergici, The Electricity Journal,30:2, March
2017,pp.60-65.
htqp;//www.-s-c-i-e199direc!,cerr,n1sclence-1arti-ele/pii/S1040619816302536
"Overcoming the Over-Forecasting Bias of Pure Econometric Models: A utility case study,"
with fosephine Duh and Ingrid Rohmund, Electricity Policy, February 2017.
https:,.i ww'w.electricitypqiicy.com/imagesi2017,,February/271'eb2017lYaruquii F aruquib2TFeb
)017.pd|
"The Impact of Time-of-Use Rates in Ontario," with Neil Lessem, Sanem Sergici, and Dean
Mountain, Pu blic Utili ties Fortnightly, F ebruary 2017 .
https:/,1ww'w.fortnlghtiy.con/[ortnightly,/201 7 l{}2limpact -time -use-ra.t_es-ontario
"Competing Perspectives on Demand Charges," with Ryan Hledik, Public Utilities
Fortnigh tly, September 20 1 6.
htlp_91iilvww.fortnightly.comr'fbrtnightly,'2016i09icompeting-perspectir-es-demand charges
"An Economist's Dilemma: To PV or Not to PV, That Is the Question," Electricity Policy,
March 2016.
http:rtwww.electricitypolic-v.com,'Articiesr an-economists-dilemma-to-pv-or-not-to-pv-that-
is the-question
"Response to King-Datta Re: Time-Varying Rates," Public Utilities Fortnightly, March 2016.
htlps;,/i'www'.fortnightly'.qom'fortnighth',20i6,03;response'krng-datta-re-time r,'arying rates
"Impact Measurement of Tariff Changes when Experimentation is not an Option - A case
study of Ontario, Canada," with Sanem Sergici, Neil Lessem, and Dean Mountain, Energy
Economics,52, December 2015, pp. 39-48.
"Efficient Tariff Structures for Distribution Network Services," with Toby Brown and Lea
24
Exhibit No. 16
Case No. IPC-E-17-'13
A. Faruqui, IPC
Page 24 of 33
Grausz, Economic Analysis and Policy,48, December 2015, pp. 139-149.
"The Emergence of Organic Conservation," with Ryan Hledik and Wade Davis, The
Electricity /ournal, Volume 28, Issue 5, |une 2015, pp. 48-58.
http:lwww.sciencecli rect.comi/scienceiarticler'pii/S 104061901500 1074
"The Paradox of Inclining Block Rates," with Ryan Hledik and Wade Davis, Public Utilities
Fortnigh tly, April 20 I 5.
hltp://www-fortnightly.com/fortni ghtlyl2015l04lpatadpx inqlining-biqck-rates
"Smart By Default," w"ith Ryan Hledik and Neil Lessem, Public Utilities Fortnightly, August
2014.
http;llwwwJe-r1a!g[t]y,c-sm,/-f prtuigbtlylZf; ]-4/081vtar-t.
default?page__Ool02C0&qu1h-kqy e5b59c3e26805e2c6b9e4.69e b9.c 1855e9b,0f18c67bbe7d8d,{ca0
8a8abd39c54d
"Quantile Regression for Peak Demand Forecasting," with Charlie Gibbons, SSRN, fuly 31,
2014.
http:r',rpapers.ss rn. c om,'so l3i papers. c fm?abstract i cl - 2485557
"Study Ontario for TOU Lessons," Intelligent Utility, April 1, 2014.
htqp://w-ww.l;rre|igenqqliilly_,_c9m larticlelT4l04litudy -p,u!,arie-tou-
lessons?quicklabg 1 1=1&quicktabs 6==2
"Impact Measurement of Tariff Changes When Experimentation is Not an Option - a Case
Study of Ontario, Canada," with Sanem Sergici, Neil Lessem, and Dean Mountain, SSRN,
March 2074.
hltir:,' ssrn.con.i'abstract..2.4 I 1 8,i2
"Dynamic Pricing in a Moderate Climate: The Evidence from Connecticut," with Sanem
Sergici and Lamine Akaba, Energy /ournal,35l.1, pp. 137-160, |anuary 2014.
"Charting the DSM Sales Slump," with Eric Schultz, Spark, September 2013.
http:,,',i spark.fortnightiv.comrfortnightly,'charting-dsm-sales -slump
"Arcturus: International Evidence on Dynamic Pricing," with Sanem Sergici, The Electricity
/ournal, 26:7, AugttsVSeptember 20 I 3, pp. 55-65.
http:,/,'mr,'w-.sc iencedirect.comi sciencei/article,/pii,'S 10.1061901300 i 656
25
Exhibit No. 16
Case No.|PC-E-17-'13
A. Faruqui, IPC
Page 25 of 33
"Dynamic Pricing of Electricity for Residential Customers: The Evidence from Michigan," with
Sanem Sergici and Lamine Akaba, Energy Efficiency,6:3, August 2013, pp. 571-584.
"Benchmarking your Rate Case," with Ryan Hledik, Public Utility Fortnightly,luly 2013.
http:/iwww.fortnightly.comifortniehtlv/20 1 3i07lbenchmarking-your -rate -case
"Surviving Sub-One-Percent Growth," Electricity Policy, |une 2013.
http://ww-w.e_lectricitypolicy.com/a rt"iclesl5677 -surviving __s_u,b-one-percent-growth
"Demand Growth and the New Normal," with Eric Shultz, Public Utility Fortnightly,
December 2012.
http:i/ww-w.fo4nightly.com-.,{ortnighLlyt2012112idemq4d growth-an_d-lrew-
normal /pag e=0o1o2C I &authkey . 4a6cfOa67 41 1ee5e7c2aee5da4616b72fde10e3fbe2 1 5 164cd4e
5-dbd8e9d0c98
"Energy Efficiency and Demand Response in 2020 - A Survey of Expert Opinion," with Doug
Mitarotonda, March 2012.
Available at SSRN:
"Dynamic Pricing for Residential and Small C&I Customers," presented at the Ohio Public
Utilities Commission Technical Workshop, March 28,2012.
h ttp :r i www'. lrattle. com, d qc umen g5, [- plo_ad l., Ornrur'L pload 1 026.pd f
"The Discovery of Price Responsiveness - A Survey of Experiments Involving Dynamic
Pricing of Electricity," with fennifer Palmer, Energy Delta fnstitute, Vol.4, No. l, April 2012.
http:,'i w-ww.energydelta.olg,'mainmenu'edi-intelIigence-2.,/our-serv iceq,,qluayterll,'-2,tedi-
quarterlv _r-_ol--4-issue- 1
"Green Ovations: Innovations in Green Technologies," with Pritesh Gandhi, Electric Energy
T&D Magazine, fanuary-February 2012.
ht[p:r','ww_w.electricenergyonline.com,'?page-show articLg.&mag=76&article-618
"Dlmamic Pricing of Electricity and its Discontents" with |ennifer Palmer, Regulation,
Volume 34, Number 3, FaIl2011, pp. 16-22.
http: ,'r,vlv.rv.catLr.org oubs,'regulation, regv3zln3, reqr.'llr{n3-5.pdl
"Smart Pricing, Smart Charging," with Ryan Hledik, Armando Levy, and AIan Madian,
Public Utility Fortntghtly, Volume 149, Number 10, October 2011.
26
Exhibit No. 16
Case No. IPC-E-17-'t3
A. Faruqui, IPC
Page 26 of 33
"The Energy Efficiency Imperative" with Ryan Hledlk, Middle East Economic Survey, Yol
IV: No. 38, September 19, 2011.
"Are LDCs and customers ready for dynamic prices?" with fiirgen'Weiss, Fortnightly's Spark,
August 25,2011.
lutp;L1-ryark.fs-rt!ightly.Ea,ryl,s,LteBageslpid5B.php-?Jte.mpl,ar-q, lnt-rq q1qhir,,e&-page-ld:58&l-co-m
!-i-!yp-erd,=6&rtem-rd.=.3,3-
"Dynamic pricing of electricity in the mid-Atlantic region: econometric results from the
Baltimore gas and electric company experiment," with Sanem Sergici, /ournal of Regulatory
Economics,40:1, August 2011, pp. 82-109.
"Better Data, New Conclusions," with Lisa Wood, Public Utilities Fortnightly, March 2011,
pp.47-48.
"Residential Dynamic Pricing and 'Energy Stamps,"' Regulation, Volume 33, No. 4, Winter
2010-2011, pp.4-5.
h-t1p;/ly1zww.eate.-o_rg1p!b51,1egql31i-gnkeeyll3t:#y33n4,.htm_]
"Dlmamic Pricing and Low-Income Customers: Correcting misconceptions about load-
management programs," with Lisa Wood, Public tltilities Fortnightly, November 2010, pp.
60-64.
"The Untold Story: A Survey of C&I Dynamic Pricing Pilot Studies" with Jennifer Palmer and
Sanem Sergici, Metering International,ISSN: 1025-8248, Issue: 3, 2010, p.104.
"Household response to dynamic pricing of electricity-a survey of 15 experiments," with Sanem
Sergici, /ournal of Regulatory Economics (2010), 38:193-225
"Unlocking the €53 billion savings from smart meters in the EU: How increasing the
adoption of dynamic tariffs could make or break the EU's smaft grid investment," with Dan
Harris and Ryan Hledik, Energy Policy, Volume 38, Issue 10, October 2010, pp. 6222-6231.
hltp:,/i www"sciencedi;:eca.coxr,lscience,"art icle.;'pi i,'5030 i 421 51C0047:18
"Fostering economic demand response in the Midwest ISO," with Attila Hajos, Ryan Hledik,
and Sam Newell, Energy, Volume 35, Issue 4, Special Demand Response Issue, April 2010,
pp.1544-1552.
http:i/www.sciencedirect.com/sciencerarticle/piiiS03605,1,12C90t14009
27
Exhibit No. 16
Case No. IPC-E-'!7-'13
A. Faruqui, IPC
Page 27 of 33
"The impact of informational feedback on energy consumption - A survey of the
experimental evidence," with Sanem Sergici and Ahmed Sharif, Energy, Volume 35, Issue 4,
Special Demand Response Issue, April 2010, pp. 1598-1608.
h tt1-r:,','w'wlv,pcienqqd!rect.con/sciencer'articleipiii 50350_5,14209003387
"Dlmamic tariffs are vital for smart meter success," with Dan Harris, Utility Week, March 10,
2010.
http:r'l'"vww.qtilityyeek.co.uk/newsr'news story.asp?id-123888&title-Dynamic+tariffs-are+v
ital- for *smart+meter-success
"Rethinking Prices," with Ryan Hledik and Sanem Sergici, Public Utilities Fortnightly,
fanuary 2010, pp. 31-39.
h ttp:i i w.r.vw. fqrqnlgh1l y.comi uploadv'0 1 0 1 20 1 0 RethinkingPrices. pd I
"Piloting the Smart Grid," with Ryan Hledik and Sanem Sergici, The Electricity /ournal
Volume 22, Issue 7, August/September 2009, pp. 55-69.
h ttp:,'i r,u'ww "scie_ncedirect.com,'science/a rtictrei pii,,S 1 0405 1 900900 1 663
"Smart Grid Strategy: Quantifying Benefits," with Peter Fox-Penner and Ryan Hledik, Public
Utilities Fortnightly,lu.ly 2009, pp. 32-37.
http://'\\'ww'.fortnightlv.corn, pubs,:07012009 Q,uantif ingBenefits.pdf
"The Power of Dynamic Pricing," with Ryan Hledik and fohn Tsoukalis, The Electricity
/ournal, April 2009, pp. 42-56.
http:/l wr,v-w'.sqienqedirect.com,/science,,articiei pii,S 104061900900041.+
"Transition to Dynamic Pricing," with Ryan Hledik, Public Utilities Fortnightly, March 2009, pp.
26-33.
http:i/www.fortnightly.com/display pdf.cfm?id=03012009 DynamicPricing.pdf
"Ethanol2.0," with Robert Earle, Regulation, Winter 2009.
http:,ir'rvww. cato.or&,'pubsr'regu lat io n/regv 3 1 n4r'v3 1 n4 - noted. pdf
"Inclining Toward Effi.ciency," Public Utilities Fortnighrly, August 2008, pp. 22-27.
http :,,/ ww.u,. fortnightly. co m/ exc 1us i ve. c fm?o id=94
"California: Mandating Demand Response," with fackalyne Pfannenstiel, Public Utilities
Fortnightly, |anuary 2008, pp. 48-53.
http://www.fortnightli4.com/display pdf.cfm?id=01012008 N{andatingDemandRespon;e,pdf
"Avoiding Load Shedding by Smart Metering and Pricing," with Robert Earle, Metering
International, Issue 1 2008, pp. 7 6-77 .
28
Exhibit No. 16
Case No. IPC-E-'!7-13
A. Faruqui, IPC
Page 28 of 33
"The Power of 5 Percent," with Ryan Hledik, Sam Newell, and Hannes Pfeifenberger, The
Electricity /ournal, October 2007 , pp. 68-77 .
http://www.sciencedirect. com/sc ienceiarticlerpii/S 1 0406 1 900700099 1
"Pricing Programs: Time-of-Use and Real Time," Encyclopedia of Energy Engineering and
Technologlr,September 2007, pp. I I 75- I 183.
http:i/wr.,u-w..drsgcoalition.org,'resollrcesr'otheriPricing Programs TOU and RTP.pdf
"Breaking Out of the Bubble: Using demand response to mitigate rate shocks," Public Utilities
Fortnightly, March 2007,pp. 46-48 and pp. 50-51.
htt p:,,,'brartlegroup.com," docume nts, uploadlibraryr a rticlereport2.l.l8. pdf
"From Smart Metering to Smart Pricing," Meteing International,Issue l, 2007
http://www.brattle.com/ documents/LjploadLibrar,v,i A rticleReport2439.pdf
"Demand Response and the Role of Regional Transmission Operators," with Robert Earle, 2006
Demand Response Application Service, Electric Power Research Institute, 2006.
"2050: A Pricing Odyssey," The Electicity/ournal, October, 2006.
http:/)/wwr.v.puc.nh.gov/Electric/O6061i epacto/o20artic1es/EJo/o202050o/o20alo20Ao/o20Pricingo,/o20O
dr,'ssey.pdf
"Demand Response and Advanced Metering," Regulation, Spring 2006. 29:l24-27.
h ll-ir :,, i w ww. calc" u rgr pu bsi'regu i ;tt ilr n,' req,,'29 n 1 :'v 29n l li. pril
"Reforming electricity pricing in the Middle East," with Robert Earle and Anees Azzouni, Middle
East Economic Survey (MEES), December 5, 2005.
"Controlling the thirst for demand," with Robert Earle and Anees Azzouni, Middle East
Economic Digest (MEED), December 2,2005.
http;/www.crai.com/uploadedl iles/RELATING MATERIALS/Publicationslfiles/Conqlollingo/o20
th eolo 2 0T h i r sto/o2} f o ro/o20 De m a nd. pd f
"California pricing experiment yields new insights on customer behavior," with Stephen S.
George, Electric Light & Powea May{une 2005.
http:i/www.elp.comtinder/displayi article-disp1avl229l3l iarticles/electric- light-pow'er/volume-
B3/issue-3i departments,/news;'california-pricing-expe r iment-y-ields- new.- insights-on-customer-
behavior.html
"Quantifying Customer Response to Dynamic Pricing," with Stephen S. George, Electricity
/ournal, May 2005.
"Dynamic pricing for the mass market: California experiment," with Stephen S. George, Public
Utilities Fortnightly, |uly 1,2003, pp. 33-35.
29
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 29 of 33
"Toward post-modern pricing," Guest Editorial, The Electricity /ournal, fuly 2003.
"Demise of PSE's TOU program imparts lessons," with Stephen S. George. Electic Light &
Power, |anuary 2003, pp.1 and15.
"2003 Manifesto on the California Electricity Crisis," with William D. Bandt, Tom Campbell,
Carl Danner, Harold Demsetz, Paul R. Kleindorfer, Robert Z. Lawrence, David Levine, Phil
Mcleod, Robert Michaels, Shmuel S. Oren, Jim Ratliff, |ohn G. Riley, Richard Rumelt, Vernon L.
Smith, Pablo Spiller, ]ames Sweeney, David Teece, Philip Verleger, Mitch Wilk, and Oliver
Williamson. May 2003. Posted on the AEl-Brookings |oint Center web site, at
hLtp:. w u w.aei -brooki n gs.org pr: Di ii at ion-. a bs..ra,- l. p ir plpii. .la l
"Reforming pricing in retail markets," with Stephen S. George. Electric Perspectives,
September/October 2002, pp. 20 -21.
"Pricing reform in developing countries, " Power Economics, September 2002,pp.13-15.
"The barriers to real-time pricing: separating fact from fiction," with Melanie Mauldin, Public
Uti li ti es Fortnigh tl y, luly 15, 2002, pp. 30 -40.
"The value of dynamic pricing," with Stephen S. George, The Electricity /ournal, |uly 2002, pp.
4s-55.
"The long view of demand-side management programs," with Gregory A. Wikler and Ingrid
Bran, in Markets, Pricing and Deregulation of Utilities, Michael A. Crew and ]oseph C. Schuh,
editors, Kluwer Academic Publishers, 2002, pp. 53-68.
"Time to get serious about time-of-use rates," with Stephen S. George, Electic Light & Power,
February 2002, Volume 80, Number 2, pp. l-8.
"Getting out of the dark: Market based pricing can prevent future crises," with Hung-po Chao,
Vic Niemeyer, ]eremy Platt and Karl Stahlkopf , Regulation, Fall 2001, pp. 58-62.
http :' rvu'w,. cato. o rF,, pubs,'regulatio n regv 24n3, spec ralreport2. pdf
"Analyzing California's power crisis," with Hung-po Chao, Vic Niemeyer, |eremy Platt and Karl
Stahlkopf, The Energy /ournal,Yol.22, No. 4, pp.29-52.
"Hedging Exposure to Volatile Retail Electricity Prices," with Bruce Chapman, Dan Hansen and
Chris Holmes, The Electricity/ournal, fune 2001, pp. 33-38.
"California Syndrome," with Hung-po Chao, Vic Niemeyer, |eremy Platt and Karl Stahlkopf,
Power Economics, May 2001, Volume 5, Issue 5, pp.24-27 .
30
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 30 of 33
"The choice not to buy: energy savings and policy alternatives for demand response," with Steve
Braithwait, Pu blic Utili ties Fortnigh tly, March I 5, 200 l.
"Tomorrow's Electric Distribution Companies," with K. P. Seiden, Business Economics, YoL
XXXVI, No. 1, |anuary 2001, pp. 54-62.
"Bundling Value-Added and Commodity Services in Retail Electricity Markets," with Kelly
Eakin, Electicity /ournal, December 2000.
"Summer in San Diego," with Kelly Eakin, Public Utilities Fortnightly, September 15, 2000
"Fighting Price Wars," Haruard Business Reuiew, May-|une 2000.
"When Will I See Profits?" Public Utilities Fortnighrly, |une 1, 2000.
"Mitigating Price Volatility by Connecting Retail and Wholesale Markets," with Doug Caves and
Kelly Eakin, Electricity lournal April 2000.
"The Brave New World of Customer Choice," with f. Robert Malko, appears in Customer Choice:
Finding Value in Retail Electricity Markets, Public Utilities Report, 1999.
"'What's in Our Future?" with f. Robert Malko, appears in Customer Choice: Finding Value in
Retail Electicity Markets, Public Utilities Report, 1999.
"Creating Competitive Advantage by Strategic Listening," Electricity /ournal,I|llay 7997
"Competitor Analysis," Competi ti ve Utili ty, November 1996.
"Forecasting in a Competitive Environment: The Need for a New Paradigm," Demand
Forecasting for Electric Utilities, Clark W. Gellings (ed.), 2nd edition, Fairmont Press, 1996.
"Defining Customer Solutions through Electrotechnologies: A Case Study of Texas Utilities
Electric," with Dallas Frandsen et al. ACEEE 1995 Summer Srudy on Energy Efficiency in
Industry. ACEEE: Washington, D.C., 1995.
"Opportunities for Energy Efficiency in the Texas Industrial Sector," ACEEE 1995 Summer
Proceedings.
"Srudy on Energy Efficiency in Industry," with I"y W. Zarnikau et al. ACEEE Washington, D.C.,
199s.
"Promotion of Energy Efficiency through Environmental Compliance: Lessons Learned from a
Southern California Case Study," with Peter F. Kyricopoulos and Ishtiaq Chisti. ACEEE 1995
Summer Srudy on Energy Efficiency in Industry. ACEEE: Washington, D.C., 1995.
31
Exhibit No. 16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 31 of 33
"ATLAS: A New Strategic Forecasting Tool," with |ohn C. Parker et al. Proceedings: Delivering
Customer Value, Vh National Demand-Side Management Conference. EPRI: Palo Alto, CA, |une
199s.
"Emerging Technologies for the Industrial Sector," with Peter F. Kyricopoulos et al. Proceedings:
Delivering Customer Value, 7th National Demand-Side Management Conference. EPRI: Palo
Alto, CA, June 1995.
"Estimating the Revenue Enhancement Potential of Electrotechnologies: A Case Study of Texas
Utilities Electric," with Clyde S. King et al. Proceedings: Delivering Customer Value, 7th
National Demand-Side Management Conference. EPRI Palo Alto, CA, fune 1995.
"Modeling Customer Technology Competition in the Industrial Sector," Proceedings of the 1995
Energy Effrciency and the Global Environment Conference, Newport Beach, CA, February 1995.
"DSM opportunities for India: A case study," with Ellen Rubinstein, Greg Wikler, and Susan
Shaffer, Utilities Policy, Vol. 4, No. 4, October 1994, pp.285-301.
"Clouds in the Future of DSM," with G.A. Wikler and |.H. Chamberlin. Eleoricity /ournal,luly
t994.
"The Changing Role of Forecasting in Electric Utilities," with C. Melendy and |. Bloom. Tie
/ournal of Business Forecasting, pp. 3-7 , Winter 1993-94. Also appears as "IRP and Your Future
Role as Forecaster." Proceedings of the 9th Annual Electric Utility Forecasting Symposium.
Electric Power Research Institute (EPRQ. San Diego, CA, September 1993.
"Stalking the Industrial Sector: A Comparison of Cutting Edge Industrial Programs," with P.F.
Kyricopoulos. Proceedings of the 4CEEE 1994 Summer Srudy on Energy Efficiency in Buildings.
ACEEE: Washington, D.C., August 1994.
"Econometric and End-Use Models: Is it Either/Or or Both?" with K. Seiden and C. Melendy.
Proceedings of the 9th Annual Electric Utility Forecasting Symposium. Electric Power Research
Instirute (EPRI). San Diego, CA, September 1993.
"Savings from Efficient Electricity Use: A United States Case Study," with C.W. Gellings and S.S.
Shaffer. OPEC Review, |une 1993.
"The Trade-Off Between All-Ratepayer Benefits and Rate Impacts: An Exploratory Study, "
Proceedings of the 6th National DSM Conference. With f.H. Chamberlin. Miami Beach, FL.
March 1993.
"The Potential for Energy Efficiency in Electric End-Use Technologies," with G.A. Wikler, K.P.
Seiden, and C.W. Gellings. IEEE Transactions on Power Systems. Seattle, WA, fuly 1992.
32
Exhibit No. '16
Case No. IPC-E-17-13
A. Faruqui, IPC
Page 32 of 33
"Potential Energy Savings from Efficient Electric Technologies," with C.W. Gellings and K.P
Seiden. Energy Policy, pp. 217-230, April 1991.
"Demand Forecasting Methodologies: An overview for electric utilities," with Thomas
Kuczmowski and Peter Lilienthal, Energy: The International /ournal, Volume 15, Issues 3-4,
March-April 1990, pp. 285-296.
"The role of demand-side management in Pakistan's electric planning," Energy Policy, August
1989, pp. 382-395.
"Pakistan's Economic Development in a Global Perspective: A profile of the first four decades,
1947-87," with |. Robert Malko, Asian Profrle, Volume 16, No. 6, December 1988.
"The Residential Demand for Electricity by Time-of-Use: A survey of twelve experiments with
peak load pricing," with |. Robert Malko, Energy: The International /ournal, Volume 8, Issue 10,
October 1983, pp. 781-795.
"Incorporating the Social Imperatives in Economic Stmcture: Pakistan in the years ahead," The
/ournal of Economic Studies, Volume 1, No. 1, Autumn 1974.
33
Exhibit No. 16
Case No.IPC-E-'|7-13
A. Faruqui, IPC
Page 33 of 33
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-17-13
IDAHO POWER COMPANY
FARUQUI, REB
TESTIMONY
EXHIBIT NO. 17
Cited Rooftop PV Cost Shift Snrdies
l. Idaho Power: Idaho Power (2016). Annual Net Metering Status Reporr. Idaho Public
Utilities Commission. 29 April. P. 10.
2. Nevada hrblic Utilities Commission (SPPC): Order re Application of Nevada Power
Company d/b/a NV Energy for approval of a cost-of-service study and net metering
tariffs. 22 December 2015. Docket No. 15-07041/2.P.43.
3. NV Energy (SPPC): Order re Application of Nevada Power Company d/b/a NV Energy for
approval of a cost-of-service study and net metering tariffs. 22 December 2015. Docket
No. 15-07041/2.P.39.
4. Energy and Environmental Economics @3) - NV estimate: Energy and Environmental
Economics (2016). Nevada Net Energy Metering Impacts Evaluation 2016 Update. 17
August 2016.P.2/7.
5. Nevada Public Utilities Commission (NPC): Order re Application of Nevada Power
Company d/b/a NV Energy for approval of a cost-of-service study and net metering
tariffs. 22 December 2015. Docket No. 15-07041/2. P. 43.
6. IrIV Energy (NPC): Order re Application of Nevada Power Company d/b/a NV Energy for
approval of a cost-of-service study and net metering tariffs. 22 December 2015. Docket
No. 15-07041/2.P.39.
7. Energy and Environmental Economics @3) - CA estimate Energy and Environmental
Economics and CPUC Energy Division (2013). California Net Energy Metering Ratepayer
Impacts Evaluation. 28 October . P.7 ,22.
8. Arizona Public Service Company: Direct Testimony of Leland R. Snook on Behalf of
Arizona Public Service Company. Arizona Corporation Commission. I fune 2016. E-
013454-16-0036. P. 30.
9. Hawaiian Electric C.ompany, Hawai'i Electric Light Company, and Maui Electric
C.ompany:2015 Net Energy Metering Status Report. Hawaiian Electric Company, Inc.,
Hawai'i Electric Light Company, Inc., and Maui Electric Company, Ltd. Hawaii Public
Utilities Commission. 29 |anuary 2016. Pdf p.6/8/10/12/14.
10. Pacific Gas & Electric Pacific Gas & Electric Company's (U 39 E) Opening Comments on
the Proposed Decision Adopting a Successor to the Net Energy Metering Tariff. 7 lanlary
2016. Rl4-07-002. P.8.
",." *ilJSlLI? ll
A. Faruqui, IPC
Page 1 ol 2
11. San Diego Gas & Electrie San Diego Gas & Electric Company (U 902 E) Comments on
Proposed Decision. 7 Jamary 2016. Rl4-07-002.P.7.
12. California Public Utilities Commission: Pacific Gas & Electric Company's (U 39 E)
Comments on Party Proposals and Staff Papers. 1 September 2015. Rl4-07-002. P. 10.
Exhibit No. 17
Case No. IPC-E-'l7-13
A. Faruqui, IPC
Page 2 ot 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 26th day of January 2018 I served a true and
correct copy of REBUTTAL TESTIMONY OF DR. AHMAD FARUQU! upon the following
named parties by the method indicated below, and addressed to the following:
Gommission Staff
Sean Costello
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldahydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite 900
P.O. Box 2900
Boise, ldaho 83701
ldaho Conseryation League
Matthew A. Nykiel
ldaho Conservation League
102 South Euclid #207
P.O. Box 2308
Sandpoint, ldaho 83864
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email tom.arkoosh@arkoosLcom
erin.cecil@arkoosh. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail_FAXX Email [e-mail]
Anthony Yankel
12700 Lake Avenue, Unit 25Os
Lakewood, Ohio 44107
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]-t
Auric Solar, LLC
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, Idaho 83702
Elias Bishop
Auric Solar, LLC
2310 South 1300 West
West Valley City, Utah 84119
Vote Solar
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Briana Kobor
Vote Solar
986 Princeton Avenue S
Salt Lake City, Utah 84105
City of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701 -0500
ldaho Clean Energy Association
Preston N. Carter
Deborah E. Nelson
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Sierra Club
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
den@q ivensp u rsley. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email elias.bisl ricsolar
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email aqermain
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
den@q ivenspursley. com
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
Tom Beach
Crossborder Energy
2560 9th Street, Suite 213A
Berkeley,CA 94710
Zack Waterman
Director, Idaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Michael Heckler
3606 North Prospect Way
Garden City, ldaho 83714
Snake River Alliance
NW Energy Coalition
John R. Hammond, Jr.
FISHER PUSCH LLP
101 South Capitol Boulevard, Suite 701
P.O. Box 1308
Boise, ldaho 83701
lntermountain Wind and Solar, LLC
Ryan B. Frazier
Brian W. Burnett
KIRTON McCONKIE
50 East South Temple, Suite 400
P.O. Box 45120
Salt Lake City, Utah 84111
Doug Shipley
lntermountain Wind and Solar, LLC
1953 West2425 South
Woods Cross, Utah 84087
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
wwi lso n @ s nakerive ra I I ia n ce. o rq
[e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
[e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
14^*-)T,,w
Kiinder[ Iow{ Executive Assistant