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HomeMy WebLinkAbout19911018Spann Direct.pdfO o ,c,:lE1'j['J E riLED N ' jt- [uI 18 Pn 1 53 Iiliil0 ir'uBLlc . t, :-iills cot'l lilsslot{ BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR APPROVAL OF AN INTERCONNECTION TARIFF FOR NON UTILITY GENERATION - SCHEDULE 72 CASE NO. IPC-E-90-20 ) ) ) ) ) ) IDAHO POWER COMPANY DIRECT TESTIMONY ON RECONSIDERATION OF ROBERT M. SPANN oo I 2 3 4 5 6 7 8 9 l0 rl t2 l3 14 t5 16 t7 l8 l9 20 2t 22 23 24 25 a A a A Please state your name and business address. My name is Robert M. Spann. My bus'iness address is Charles R'iver Associates, 555 13th Street, N.W., }Jashington, D.C. By whom are you empl oyed? I am an i ndependent economi c consul tant affj I i ated wi th Charles Rjver Associates, an economic consulting firm wjth offices in l.lashjngton and Boston. Please describe your educatjonal background and prior work experi ence. I recejved both my Bachelors and Masters Degrees 'in Economics from North Carolina State University in 1970. I recejved my Ph. D. 'in Economi cs, w j th a co-major i n Stati sti cs, from the same Universjty in 1973. hlhile doing graduate work at North Caroljna State, I taught courses in principles of econom'ics. I was al so the reci pi ent of a Nat'ional Sc'ience Foundat j on Fel I owshi p and a Resources for the Future Dj ssertati on Fellowship. I have served on the facult'ies of Virg'inia Polytechnic Institute and State University, Montana State University, the Univers'ity of Chicago, and George Wash'ington Un'iversity. I have taught courses in econometrics, economic theory, appl ied microeconomics, and regulatory econom'ics. During the period 1975-1989, I was a Prjncipal of ICF Incorporated, a t^lash'ington D.C. consulting firm. I have been actively involved as a consultant'in the areas of energy, utility, and antjtrust economics sjnce 1972. Durjng the last Spann, Di -Recon Idaho Power Company a A I o 18 years I have performed consulting assignments for state regulatory bodies, federal government agencies, regulated utiljties, energy companies, and utility consumers. I have testjfjed before state and federal regulatory bodies and courts on numerous occasions. I am a member of the American Economic Association, the International Association of Energy Economjsts, and am an associate member of the American Bar Assoc'iation Section on Antitrust. I have publ i shed numerous artj cl es on regul atory economics in professional journals. Exhjbit 2 (RMS-1) is my resume. Are you familiar with PURPA and cogeneration and small power production (CSPP) jssues? Yes. I was a consultant to the Department of Energy during the drafting and implementatjon of the FERC rules cjted by Dr. Reading. One of my assignments was advi sing the Department of Energy's Policy Office on issues regarding the implementation of PURPA Section 210 (Cogeneration and Small Power Production). During the last twelve years I have served as a consultant to varjous cogenerators and small power producers jn a number of states, served as a consultant to a number of State PUCs on PURPA implementatjon jssues and worked wi th numerous el ectri c uti l i t'ies on CSPP 'i ssues . I have testified for Idaho Power on several occasions before th'is Spann, D'i-Recon Idaho Power Company o I ? 3 4 5 6 7 8 9 l0 1l t2 13 t4 15 16 t7 18 19 20 2t 22 23 24 25 a A 2 o Commission. I have also testified on behalf of CSPPs before the New York Public Serv'ice Commissjon, the Florida Public Servjce Commjssion, the Pennsylvanja Public Ut'ilit'ies Commi ss'ion and the Federal Energy Regul atory Commi ss'ion . The jssues I have addressed on behalf of CSPPs in prior testimony has jncluded avo'ided costs, standby rates, and the economic impact of m'inimum flows at a small hydro site. I have also done a substantial amount of work for CSPPs that did not involve test'imony. For the past nine years, I have worked wjth a major Virginia cogenerator, assisting in contract negotiatjons and jn analyzing fil ings made by Virginia Power. I have worked with other cogenerators perform'ing economjc evaluations of potential cogeneration projects, analyzing transmissjon issues, and various other matters. Fjnally, I assisted the New Jersey Board of Public Ut'ilities and the South Carol'ina Publ'ic Service Comm'ission in the design and implementatjon of avojded cost rates for CSPPs in those states. What js the purpose of your testimony in this proceeding? Idaho Power Company asked me to rev'iew the testimony of Dr. Reading, prepared on behalf of the Independent Energy Producers of Idaho. In addition, I will be discussing the mannerin wh'ich CSPPs i n other states are charged for interconnection costs. Spann, Di -Recon Idaho Power Company a 1 2 3 4 5 6 7 8 9 10 1l t2 13 14 15 16 t7 18 19 20 2l 22 23 24 25 a A 3 a Please summarjze your comments on Dr. Read'ing's testimony. My conclusions can be summarized as: o Much of Dr. Reading's test'imony regarding PURPA and average costs versus 'incremental costs is simply an i rrel evant smoke screen. That d'i scuss i on has noth i ng to do wi th the actual issues jn dispute in thjs proceeding. o At the concl us'i on of Dr. Read i ng' s test i mony he performs exactly the same type of calculatjon as does Idaho Power--djvid'ing current expenses for di strj but'i on and transmi ssi on operati on and ma'intenance (0&M) by existing plant investment to obtajn a percentage charge for 0&M expenses. The only substantive djfference between Dr. Readi ng's cal cul at'ions and Idaho Power's j s that Dr. Readjng omits Administrative and General (A & G) expenses from h'i s cal cul at j ons. o In Case No. IPC-E-89-ll, Idaho Power's last avojded cost case, Dr. Dennis Peseau testjfjed for the Independent Energy Producers of Idaho. In that case, Dr. Peseau testified that Idaho Power's A & G costs must be jncluded in setting Idaho Power's avoided costs. Al I of the arguments that Dr. Peseau made for including A & G expenses in the avoided costs that Idaho Spann, Di -Recon Idaho Power Company o t 2 3 4 5 6 7 8 9 10 ll t2 13 14 15 16 l7 I8 19 20 2l 22 23 24 25 a A 4 o Power pays to CSPPs apply equal 1y wel I to jnclud'ing A & G expenses in the 'interconnection costs that CSPPs pay to Idaho Power. Thus if A & G costs are i nc'l uded i n the avoi ded cost rates Idaho Power Company pays to CSPPs, they should be jncluded in the interconnect'ion charges CSPPs pay to Idaho Power Company. o If A & G costs are not included in the jnterconnect'ion charges CSPPs pay to Idaho Power Company, they should not be incl uded in the avoided cost rates Idaho Power Company pays to CSPPS. Please summarize your testimony regarding the practices of other utilities regarding interconnectjon costs. My general experience is that it js common pract'ice for utilities to charge CSPPs for both the capital and 0 & M costs of i nterconnectj ons. In addi ti on, Idaho Power Company personnel, at my request, have conducted a survey of the practices of the eleven other major electric util'itjes in the Pacifjc Northwest and the West. The results of the survey can be summarized as: o All of these utjlitjes charge the CSPP for the capita1 costs of interconnections. o With the sole exception of the Washington Water Power Company, all eleven utjlit'ies charge the Spann, Di -Recon Idaho Power Company t I 2 3 4 5 6 7 8 9 l0 lt t2 l3 l4 l5 l6 17 l8 l9 20 2l 22 23 24 25 a A 5 o CSPPfor0&Mcosts. o F'ive of the utilitjes charge the CSPP a monthly percentage 0 & M rate. In four of these cases, the rate js virtually identical to the rate Idaho Power Company has proposed in thjs proceeding. o Five of the util'ities charge the CSPP actual 0 & M costs. These utilities have a much smaller number of CSPP contracts than the ut'ilities which charge a percentage rate sjmjlar to that proposed by Idaho Power Company in thjs proceeding. lllhy do you state that much of Dr. Reading's testimony regarding PURPA and average versus incremental costs is simply an imelevant smoke screen? Because Dr. Reading is attempting to djvert attention from the real jssue by portraying the dispute in theoretical terms, 'i.e., average cost versus jncremental cost. The issue in thjs proceeding is not average costs versus incremental costs. The sole issue raised in Dr. Reading's test'imony'is whether or not A & G costs should be included in the charges to CSPPs for interconnection equipment. Idaho Power Company jncludes these costs. Dr. Readjng makes them disappear. How does Dr. Readjng's calculatjon of a monthly 0 & M charge of 0.5 percent of interconnectjon capital investment differ from Idaho Power Company's proposed 0.7 percent monthly charge? ann, Di -Recon aho Power Company t I 2 3 4 5 6 7 8 9 l0 11 t2 l3 l4 15 16 t7 18 19 20 2t 22 23 24 25 a A a Sp Id 6 o The sole difference js the treatment of A & G expenses. Idaho Power Company djvides 0 & M expenses'including A & G expenses by distribution plant to obtain the proposed .7 percent per month charge. Dr. Reading ef iminates A & G expenses from the cal cul at i on . Both Idaho Power and Dr. Reading are trying to estimate the jncremental annual 0 & M expenses which are incurred by Idaho Power Company when Idaho Power Company i s 'i nterconnected to a CSPP. Both Idaho Power and Dr. Reading est'imate these jncremental costs by establishing the ratjo of expenses jn certain FERC accounts to existing investment. Is it standard practice jn the utility industry to jnclude A & G costs in the calculation of incremental costs? Yes. In calculating avo'ided or incremental costs, util'ity analysts would not ask the question 'what specific costs are avo'ided when a spec'ific one or two lllw CSPP connects to the utility system?' Rather, they use a general relationship between costs and load to calculate the costs that would be avoided by the typical QF. Thjs would generally include A & G costs . The exact same reasoning applies to 'interconnection costs. A utility wjth more interconnections, and greater investment 'in jnterconnectjons would generally have higher A & G costs than a ut'i 'l i ty wi th fewerinterconnect j ons and I ess i nvestment 'in i nterconnecti ons. Spann, Di -Recon Idaho Power Company a I 2 3 4 5 6 7 8 9 l0 l1 t2 13 l4 l5 16 t7 l8 19 20 ?l 22 23 24 25 A a A 7 Oa I z 3 4 5 6 7 8 9 l0 ll t2 l3 l4 l5 l6 t7 l8 l9 20 2t 22 23 24 25 a Are A & G expenses included in the jncremental cost calculations used to set the avo'ided cost rates that Idaho Power Company pays to CSPPs for the purchase of power from CSPPs? Yes, they are. IfA & G expenses are included jn the avoided costs rates that Idaho Power Company pays to CSPPs, should they also be jncluded in the jnterconnection costs Idaho Power Company charges CSPPs? Yes. The same logic applies in both sjtuat'ions. If Idaho Power avojds A & G expenses when it avojds investing in a power p1 ant due to the purchase of power from a CSPP, obviously Idaho Power's A & G expenses increase when Idaho Power increases its investment in djstribut'ion plant in order to interconnect a CSPP. As such, if A & G costs are included 'in the avoided costs rates CSPPs are paid, they should be jncluded jn the interconnect'ion costs that CSPPs pay Idaho Power. If A & G costs are not'included in the interconnection costs that CSPPS pay to Idaho Power, should they be included jn the avoided cost rates that Idaho Power pays to CSPPs? Clearly not. Dr. Reading's 1og'ic 'is that A & G costs are fixed. If they are fixed and don't vary with output, they are not avoided when CSPPs supply power to Idaho Power Company. Thus under Dr. Reading's approach, A & G costs would be Spann, Di -Recon Idaho Power Company A a A a A 8 I 2 3 4 5 6 7 8 9 l0 ll t2 13 l4 l5 16 t7 18 19 20 2l 22 23 24 25 a A a A a A O O excluded from the calculation of avo'ided costs and excluded from the rates paid CSPPS. Does Dr. Readjng present any data or analysis to support his claim that Idaho Power's A & G costs are unaffected by jnterconnecting with CSPPs? No. He simply makes thjs statement in order to reduce the rates CSPPs must pay Idaho Power. His testimony does not conta'in any data or analysis which even remotely supports thjs assumpti on. Have you revjewed Exhjbit 705 attached to the prefiled direct testimony of Independent Energy Producers' witness Peseau in Case No. IPC-E-89-ll? Yes, I have. The analys'i s conta'ined i n that exhi bi t i ndi cates that A & G expenses should be included in the rates CSPPs pay Idaho Power Company for interconnection costs. As such, the analysis that Dr. Peseau presented in that Docket directly contradicts Dr. Reading's testimony in thjs case. For the convenjence of the parties, I have attached a copy of Dr. Peseau's Exh'ibit 705. Please explain why Independent Energy Producers' witness Peseau's analysis jn Case No. IPC-E-89-11 d'irectly contrad'icts Dr. Readjng's testimony in this proceeding. Dr. Readjng has testjfjed that when a utility increases 'its distrjbution plant due to jnterconnecting a CSPP, there is no increase in the utility's A & G expenses. Dr. Peseau's Spann, Di -Recon Idaho Power Company 9 O analys'is shows that this assert'ion by Dr. Read'ing simply isn't true. In Case No. IPC-E-89-ll, Dr. Peseau test'ifjed that: "I have examjned the relatjonsh'ip between A & G expenses and general p1 ant wi th generated and purchased power and wi th oroduct'ion. transmiss'ion and distributionplant using regression analysis. ...The purpose of the anal ys'i s v{as to determ'i nethe extent to which additional 'investment i n producti on. transmi ssj on and di stri buti on pl ant and addj ti onal power purchases were assocj ated wi th greater levels of A & G expenses and general plant j nvestment" I Peseau Di rect, p. 34, I 'ine 20 through p. 35, I jne 12, emphasis addedl. Dr. Peseau's Exh'ib j t 705 shows that an j ncrease 'in pl ant i nvestment, regardl ess of whether j t i s production, distrjbutjon or transm'ission plant increases A & G expenses. a. Do other utiljties charge CSPPs for interconnection 0 & M costs ? A. Yes. As I previously testjfied, except for Washington Water Power, all eleven utilitjes we contacted charge CSPPs for 'interconnection 0 & M costs. a. Are the rates charged CSPPs for jnterconnection 0 & M costs similar to those proposed by Idaho Power? A. Yes. Five of the utilities we surveyed follow the same general procedure for charging interconnectjon 0 & M costs as does Idaho Power. All but one of the fjve util'itjes charge for distributjon 0 & M at a rate that is roughly .7 percent of interconnection capital investment per month. Thjs is Spann, Di -Recon Idaho Power Company l0 o I 2 3 4 5 6 7 8 9 l0ll t2 t3 l4 l5 l6 t7 l8 19 20 2l 22 23 24 25 26 27 ?8 29 30 3l 32 I 2 3 4 5 6 7 B 9 l0 ll t2 l3 14 l5 l6 a o o vjrtually identical to the rate proposed by Idaho Power. All but one of these utiljtjes charge an 0 & M rate for transmission level interconnections that 'is between .34 and .5 percent of interconnectjon capital investment per month. This 'is virtually identical to the rate proposed by Idaho Power. The other five utilities charge CSPPs actual 0 & l'| costs. As a general ru1e, these utjljtjes have only a small number of CSPP contracts--many fewer CSPP contracts than do ejther Idaho Power or the other utiljtjes which charge 0 & M on a percentage basis. Have you prepared an exhibit that summarizes the results of your survey? Yes, that exhibit js attached to my testjmony as Exhibit 3. Does th j s concl ude your rebuttal test'imony? Yes, jt does. Spann, Di -Recon Idaho Power Company A a A 1t O ROBERT M. SPANN Economics and Statistics, North Carolina State Llniversity Economics, North Carolina State University o Chorles River Associotes EXHiBTT 2 (RMS-r) CASE NO. IPC-E-90-20 SPANN, IPCO Page I of 6 Ph.D. B.S. Dr. Spann is a senior consultant to CRA. He works with CRA on projects in the areas of regulatory economics, energy, insurance, strategic planning and anti-trust. He has over seventeen years of consulting experience involving regulated industries, energy, communications, insurance, and anti-trust. This experience has included testifying before state and federal administrative agencies, boards of arbitration, and the courts. Prior to affiliating with CRA in May of 1989, Dr. Spann was a Senior Vice President and Member of the Board of Directors of ICF Incorporated. He has also held academic positions on the faculties of George Washington University, Virginia Polytechnic Institute, the University of Chicago, North Carolina State University and Montana State University. PIIBLICATIONS A. Electric Utility Economics "Rate of Return Regulation and Efficiency in Production: An Empirical test of the Averch-Johnson Thesis," Bell Journal of Economics and Management Science, Vol. 5, No. 1, 1974. "Strategic Planning for Power System Reliability and Vulnerability: An Optimization Model for Resource Planning Under lJncertainty" (with I.H.Shavel and A.P. Sanghvi), IEEE Transactions on Power Apparatus and Systems, Volume 9, No.2,7982. cgu o O "The Effect of Electric Rate Design on Solar Heating" (with K.P.I-inder and E. Wessler), in Ener$r and Communications in Transtlioq, MSU Public Utility Papers, L981.. "Econometric Estimation of Peak Electric Utility Demands" (with E.G.Beauvais), Journal of Economics, Volume 9,1979. "The Demand for Electricity in Virginia" (with M.P. Murray,L. Puney, and E.G. Beauvais), The Review of Economics and Statistics, Volume 60, No. 4, November 1978. "The Regulatory Cobweb: An Analysis of Inflation, Deflation, and Alternative Administrative Rules in Public Utilities," Southern Economic Journal, July 1976. ,'ANoteontheRegu1atedFirm'sCostFunction,'', Vol. 3, No. 3, 1975. "Restructuring the Electric Utility Industry: A Framework for Evaluating Public Policy Options in Electric Utilities," in W.H. Shaker and W. Steffy (editors), Electric Power Reform: The Alternative for Michigan. Ann Arbor: University of Michigan Institute of Science and Technology, 1976. "Industrial and Commercial Rate Structures and Econometric Estimation of the Demand for Electricity," in James Boyd (ed.), Proceedings of the Electric Power Research Institute Conference on Time of Day and Seasonal Load Forecasting. Palo Alto: EPRI, 1976. B. Petroleum Economics The Supply of Natural Resources: The Case of Oil and Natural Gas, New York: The Arno Press, 1979. "supply Response in a Regulated Industry: The Case of Natural Gas" (with E.W. Erickson), Bell Journal of Economics and Management Science, Vol. 2, No. l,1970. Chorles RiverAssociotes EXHTBTT 2 (RMS-l) CASE NO. IPC-E-90-20 SPANN, IPCO Page 2 of 6c$u o o 'The Political Economy of Crude Oil Price Controls" (with E.W. Erickson, W.L. Peters, P.J. Tese), Natural Resources Jounlal, Vol. 18, No. 4, October 1978. "Alternative Strategies for Dealing with the Natural Gas Shortage" (with P. Staratt), irr E.W. Erickson and L. Waverman (eds.), The Enerry Ouestion. Toronto: The University of Toronto Press, 1974. "Oil Imports, the Wellhead Price of Natural Gas, National Energy Poliry and Joint Costs in Oil and Gas Exploration" (with E.W. Erickson), in D. Limaye (ed.) Energ.v Policy Evaluation. Lexington: Irxington Books, 7974. "An Economic Analysis of Substitution and Usage Effects in Industrial Energy Demand" (with E.W. Erickson and R. Ciliano), in D. Limaye (ed.) Enerry Policy Evaluation. Lexington: Lexington Books, 1974. "Substitution and Usage in Energy Demand: An Econometric Estimation of l,ong-Run and Short-Run Effect" (with E.W. Erickson and R. Ciliano), in Milton F. Searl (ed.), Energ.v Modeling: Art. Science. Practice. Washington: Resources for the Future, 1973. "Joint Costs and Separability in Oil and Gas Exploration" (with E.W. Erickson),in Milton F. Searl (ed.), Energv Modeling: Art. Science. Practice. Washington: Resources for the Future, 7973. "Balancing the Supply and Demand for Naturai Gas" (with E.W. Erickson), in Balancing the Supply and Demand for Energy in the United States. Denver: University of Denver, 7972. "Price, Regulation and the Supply of Natural Gas in the United States" (with E.W. Erickson), in Keith Brown (ed.), Regulation of the Natural Gas Producing Industry. Washington: Resources for the Future, \972. "Natural Gas Prices, Crude Oil Prices and the Supply of Natural Gas" (with E.W. Erickson). Written testimony for the U.S. Senate, Committee on Interior and Insular Affairs, 91st Congress. Washington, D.C.: U.S. Government Printing Office, 1972. Chorles River Associotes EXHIBIT 2 (RMS-l) CASE NO. IPC-E-90-20 SPANN, IPCO Page 3 of 6(-& o C. Taxation "Oil Supply and Ta:< Incentives" (with E.W. Erickson and S.W. Millsaps), Brookings Papers on Economic Activity. No.2, 1974. "Ta;r Revenue and Economic Effects of Tax Exempt State and L,ocal Bonds: A General Equilibrium Approach of Tax Policy Analysis," Conference on Tax Research. Washington: U.S. Treasury, Office of Ta,r Analysis, 1977. "Percentage Depletion and the Price and Output of Domestic Crude Oil" (with E.W. Erickson and S.W. Miilsaps). U.S. Congress, House Ways and Means Committee, Ta"r Reform Hearings, Nafural Resources, February 8, 1973. "Taxation and the Petroleum Industry" (with E.W. Erickson, D.N. Hyman and S.W. Millsaps), in The Petroleum Industry's Tax Burden. Compendium prepared for the U.S. House Ways and Means Committee and U.S. Senate Committee on Finance. Washington, D.C.: Taxation with Representation, 1973. "Ta^:ration, Regulation, Electric Utility Pricing and the Efficient Allocation of Energy Resources," in C. Cicchetti and J. Jurewitz (eds.), Studies in Electric Utility Regulation. Cambridge: Ballinger Books, 1975. "Ta,.r Incentives in the Petroleum Industry" (with E.W. Erickson and S.W. Millsaps), in E.W. Erickson and L. Waverman (eds.), The Energ.v Ouestion. Toronto: The University of Toronto Press, 1974. D. Industrial Organization and Antitrust Economics "The Economics of Railroading: The Beginning of Cartelization and Regulation" (with E.W. Erickson), Bell Joutualof Economics and Management Science, Vol. 1., No.2, 1970. "Mergers Involving Firms in Financial Decline: a Conceptual Model" (with C.H. Ufen), Southern Journal of Business, July 1970. EXHTBTT 2 (RMS- CASE NO. IPC-E- SPANN, IPCO Page 4 of 6 o Chorles River Associotes l) 90-20(r& o o Chorles River Associotes EXHTBTT 2 (RMS-t) CASE NO. IPC-E-90-20 SPANN, IPCO Page 5 of 6 "Competition, Prices and Tax Policy {or the Petroleum Industry" (with E.W. Erickson and S.W. Millsaps). Statement submitted to the United States Senate Committee on Finance, November 28, t973. "Competition in the Field Markets for New Natural Gas Supplies" (with E.W. Erickson and S.W. Millsaps). Statement submitted to the United States Senate Committee on Finance, November 28, 1973. "An Analysis of the Competitive Effects of Joint Ventures in the Bidding for Tracts in OCS Offshore L.ease Sales," in Hearings Before the Special Subcommittee on Integrated Oil Operations of the Senate Committee on Interior and Insular Affairs, Market Performance and Competition in the Petroleum Industry (with E.W. Erickson). Washington, D.C: Government Printing Office, 1974. E. Public Sector Economics "Macroeconomics of Unbalanced Growth and the Expanding Public Sector: Some Simple Tests of a Model of Government Growth," Journal of Public Economics, Volume 8, No. 3, December L977. "The Effects of Public Spending on the Divisibiiity of Public Outputs in Consumption, Bureaucratic Power and the Size of the Tax Sharing Group" (with T.E. Borcherding and W. Busch) in T.E. Borcherding (ed.), Budgets and Bureaucrats: The Sources of Government Growth. Durham: Duke University Press, 1977. "Public vs. Private Production of Governmental Services," in T.E. Borcherding (ed.), Budgets and Bureaucrats: The Sources of Government Growth. Durham: Duke University Press, 1977. "Rates of Productivity Change and the Growth of State and Local Government Expenditures" in T.E. Borcherding (ed.) Budgets and Bureaucrats: The Sources of Government Growth. Durham: Duke University Press, 1977. "Collective Consumption of Private Goods," Public Choice, Vol. 2l,Winter 1974. cgu oa Chorles RiverAssociotes EXHiBTT 2 (RMS-l) CASE NO. IPC-E-90-20 SPANN, IPCO Page 6 of 6 F. Telecommunications "Pricing within Urban Telephone Networks: Welfare, Allocative and Distributional Effects of Alternative Pricing Policies" in C.F. Phillips, Jr. (editor), Expanding Economic Concepts of-Regulation in H_ealth. Postal and Telecomnlunications Services. Lexington, Va.: Washington & ke University, 1,977. Prior Testimony Before: Arizona Corporation Commission Connecticut Department of Public Utilities Georgia Public Service Commission Federal Energy Regulatory Commission Postal Rate Commission International Chamber of Commerce Arbitration Panel North Carolina Utilities Commission Idaho Public Utilities Commission South Carolina Public Service Commission Georgia Public Service Commission Florida Public Service Commission New York Public Service Commission Montana Public Service Commission Pennsylvania Public Utilities Commission Virginia State Corporation Commission Illinois Department of Insurance Federal Bankruptcy Court, Manchester, NH Delaware Public Service Commission District of Columbia Public Service Commission Maryland Public Service Commission Kansas Corporation Commission New Jersey Board of Public Utilities Travis County District Court, Austin Texas Ohio Public Utilities Commission Arkansas Public Service Commission UX, o a E, t.EFOfo-z t o EanoN s) q)lt o Ea * (o (f) rJ)(o+ rx c{ @ * + tl. o +to+ 'TN o o€=c€o(LELJoi-5= rf ;-o6 .srtro-.sd EH bo*(E E'o;trDEE> C)= U,-t ==€:OU u--eg =E oo J o a CDc op CL:, oE(,oc Eo 0) a -cPco o(L s @g? o oo).Po eOOo'F -ofc =o{-, l-(aoOF oo oo ss@@(o (r)dd crOOo'F -9, =CZo +, l-ooOF oo oo>=ast\ tJ)(o$qaloo EfPo E Po CrOoo'F .9, =C-- cn +, t-(/)oOF oo oo ssloo(o rr)dci E) o 3 Eo)J c-9d.9e g€ E8E E.90F'noo oLOOoEE<>>gl*B-tr(o$,xea?;'o o =->Co oPooo E.:o-oo ee P!s6- iaDOCu,ts.: OgE*- e P i+.! F:=II: s= g > trf ).*> o-o o o-Lao z o- oo o(J o(n -ofL ocoN L oo o 3oo- oco Co oo o 3oL oEo oz oo UJ d oo(9 .9 =ooo. P CD ={ q) 3oL o '6 o0- oou, (E oco(, E'Csts oo- o 3oo- q) ct)fo- oo lrJ & 6o(9 oc').9o oa o 3oL o 'o oL o .9a PE CD =d o 3oL s.o :) 0) 3oL q)Po =oo3 E oTLoE, UJII o)@o) Eo iF :t cASE rPC-E-90-20 SPANN, Di IDAHO POWER COMPANY EXHIBIT 3, Page 1 of 1 o o IDAHO POWER COMPANY ' REGRESSION OUTPUT TOR ADMINISTRATIVE AND GENERAL EXPENSE AND GENERAL PI,ANT STATISTICAL ANALYSIS DEPENDENT VARIABLE 1 TOTAL OBSERVATIONS ].6 USABLE OBSERVATIONS ].6 R**2 .96744156ssR .38375L528+L5 DURBTN-WATSON 1,. 9L389965 a( 8)= 4.7725sNO. I,ABEL VAR I,AG AANDGSKTPPED/I{rSSING o DEGREES OF FREEDOM 13RBNI**2 .96243257sEE 1718L1 95. STGNIFICANCE LEVEL .78L587COEFFICIENT STAND. ERROR************ ************ -5040132. 6080289..24257968-01 .1970L508-022.396557 t.252742 ***T-STATISTIC * *** * ********** l_ 2 3 ******* CONSTANT PTDPLT PURCH 0 7 4 *** 0 0 0 -.8289297L2.3L268 1.913049 *** 0 0 0 NO.*** 1 2 3 DEPENDENT VARIABLE 2 TOTAL OBSERVATIONS 15 USABLE OBSERVATIONS ].5 R**2 .78394835 ssR .100486668+l-8 DURBIN-WATSON I.3552O6L7 a( 8)= L4-9283I,ABEL VAR I,AG******* *** CONSTANT OPTDPLT 7 PURCH 4 GENPI,ANTSKTPPED/ITISSING 0 DEGREES OF FREEDOM 13RBAR**2 .7507 0963sEE 879L8955. SIGNIFICANCE LEVEL .6055458-01 COEFFICIENT STAND. ERROR* ** ********* .2028605E+08 .31113828+08.50342048-01 .10081638-01 -1.738940 6.410483 T-STATISTIC** *** ******* .65L9946 4.993443 -.27L2650 Exhibit 705 Case No. IPC-E-89-L1 Peseau, IEP Page 1 of 1