20080416Exhibit Supporting Application.pdf

""
FISHER' PUSCH & ALDERMAN: LLP
ATTQRNEYS AND COUNSELORS AT LAW
, ,
April 15,2008
c.-maildrhèiìWaw.corq-1' §- =r_.
in~~: ~
r;, ':..~; , (.1
i~:. -.
3:.~ ::~1enG ca,
fBi ui0, CO
;0rnt' 'tn,
. John R. HammondJr. .
. -
idaho Public 'Utilities Commission'
472 W. .Washington Street
P. O. Box 83720
Böise, Idaho 83720-0074
, -
, '-
l -
Re:, In the Matter oftheApplicatton of Rocky Mountain Powerforan Accounling'
Order to Establish a RegulatoryAsset, Case No. PAC-E-08-02, ~, I
,
Dear Commission:
.,
Enclosed are' exhibits in support of ìts AppÚcation in Cas~ No, P AC- E-08-02 ,which are
being claimed by Rocky :Möúntain Power, pursuant to Conuission Rulèof Procedu 67 , as
'confidential and constitute, trade secrets, as defined by Idaho ,Code §§ 9-340 and 48-801. ;These ;
exhibits have been filed with theCommission- ön coloreçl paper with each page of ea.ch exhibit
marked "CONFIDENTIAL". A Certificate of Attorney is also enclosed (ar origi:nal and 7.
copies) to verify the 'C.oIhpàny's claim that these exhibits are confidential and constitute trade
secrets and are exempt' from public disclosùre according to Idaho Code §§ 9-340 and 48-801.. . I ., . ~~ ,J;
In addition, enclosed is Exhibit 3 (an -original, and' 8 c9pies) also for. filing in s~pport of .. the Company',s Application. '
If YÖll have any questions, ple'ase do not hesitate to contact me. '.. ~ ....
Sincerely,. .
FISHER PUSClI &ALDERMAN LLP
.¡!
JRH/hdp
Enclosures "
T 208.331. 000. F 208.331.400 . P.oBox 1308 Boise, Id 83701 . Suite 500, US 'Bank PlazalÒi S. CapitolBlvd. Boi~e, Id 8FO,i, i .
John R. Hanond, Jr. ISB # 5470
FISHER PUSCH & ALDERMAN LLP
101 So. Capitol Blvd., 5th Floor
PO Box 1308
Boise il 83701
Telephone: [phone]
FAX: [phone]
Email: jrhcgfpa-law.com
i 5 PH 3= 58
Mark C. Moench
Sr. VP and General Counsel
201 South Main, Suite 2400
Salt Lake City UT 84111
Telephone: [phone]
FAX: [phone]
Email: mark.moench(ipacificorp.com
Daniel E. Solander
Senior Counsel
201 South Main, Suite 2400
Salt Lake City UT 84111
Telephone: (80l) 220-4014
FAX: [phone]
Email: daniel.solander(ipacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION'
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR AN )
ACCOUNTING ORDER TO ESTABLISH A )REGULATORY ASSET )
)
CASE NO. PAC-E-08-02
EXHIBIT IN SUPPORT OF
APPLICATION
COMES NOW, Rocky Mountain Power, a division of PacifiCorp (the
"Company"), and submits as Exhibit 3 in support of its Application for an Accounting
Order to Establish a Regulatory Asset, the direct testimony of Bruce N. Wiliams, Vice
EXHmIT IN SUPPORT OF APPLICATION - 1 ORIGINAL
BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH
In the Matter of the Request of ROCKY
MOUNTAIN POWER for Waiver of
Solicitation Process and for Approval of
Significant Energy Resource Decision
Docket No. 08-035-
TESTIMONY OF
BRUCE N.WILLIAMS
FOR
ROCKY MOUNTAIN POWER
EXHIBIT RMP 3
APRIL 1, 2008
1 Q.
2 A.
3
4
5 Q.
6 A.
7
8 Q.
9 A.
10
11
12
13
14
15 Q.
16 A.
17
18
19
20
21
22
Please state your name, bnsiness address and job title.
My name is Bruce N.Wiliams. My business address is 825 NE Multnomah,
Suite 1900, Portland, Oregon 97232. I am Vice President and Treasurer of
PacifiCorp. Rocky Mountain Power is a division ofPacifiCorp ("Company").
What are your responsibilties in your cnrrent position?
I am responsible for the Company's treasury, credit risk management, pension
and other investment management activities.
Please describe your business and educational background.
I have been employed by the Company for 22 years. My business experience has
included financing of the Company's electrc operations and non-utility activities,
investment management, and investor relations. lreceived a Bachelor of Science
degree in Business Administration with a concentration in Finance from Oregon
State University in June 1980. I also received the Chartered Financial Analyst
designation upon passing the examination in September 1986.
What is the purpose of your testimony?
My testimony supports Rocky Mountain Power's Verified Request for Waiver of
Solicitation Process and for Approval of Significant Energy Resource Decision
("Request") with respect to the Company's proposal to acquire the generating
plant ("Plant") identified in the Confidential Testimony of Stefan A. Bird. The
Request is fied under the Utah Energy Resource Procurement Act ("Act"),
specifically Utah Code An. §§ 54-17-201(3), 54-17-302 and 54-17-501. It is
also fied in accordance with Commission rules adopted under the Act, Utah
Page 1 - Confidential Testimony of Bruce N. Wiliams
23
24
25 Q.
26 A.
27
28
29
30
31
32 Q.
33 A.
34
35
36
37
38
39
40
41
42
43
Admin. Code R746-430-2, R746-430-4 and R746-440-1. My testimony describes
generally how the Company wil finance the acquisition the Plant.
What do you expect the source of funds to be for the acquisition of the Plant?
The Company expects to use a reasonable mix of capital designed to provide a
competitive cost of capital, predictable capital market access and to allow the
Company to remain financially stable. The Company anticipates utilizing funds
from sources similar to those used in the past, including operating cash flows and
the issuance of new long-term and short debt and, if necessary, new equity capital
to fud the acquisition of the Plant.
Is the Company capable of financing the acquisition of the Plant?
Yes. In addition to the internally generated fuds, the Company curently has
access to the capital markets and expects to be able to borrow funds necessar to
help finance the acquisition of the Plant. This access was evidenced most recently
by the Company's October 2007 issuance of $600 milion of first mortgage
bonds. PacifiCorp senior secured debt is currently rated "A3" and "A-" by
Moody's Investors Service and Standard and Poor's, respectively, both of which
are investment grade ratings. In addition, the Company has received cash equity
contributions from its parent company in the past and, if necessar, may again in
the future. The Company's access to the capital markets in the future wil be
influenced by outcomes of regulatory matters, industr developments and
regulatory authority to issue securities.
Page 2 - Confidential Testimony of Bruce N. Willams
44 Q.Does the Company have regulatory authority sufficient to allow it to
45 finance the acquisition of the Plant?
46 A.Yes. The Company has authority to issue sufficient amounts of short-tenTI and
47 long-term debt and common equity for acquisition ofthe Plant. Our regulatory
48 authority allows securties to be issued for certain purposes including (1) the
49 acquisition of property, (2) the construction, completion, extension or
50 improvement of utility facilties, (3) the improvement of service, (4) the discharge
51 or lawful refunding of obligations which were incurred for utility purposes or
52 (5) the reimbursement of the Company's treasur for fuds used for the foregoing
53 purposes.
54 Q.Does the Company have a debt-to-equity ratio which provides the
55 Company with financial stabilty'!
56 A.Yes, the Company's capital structure is appropriate for providing financial
57 stability in this matter. The Company expects its capital structure may change
58 over time, due in par to capital spending, nonetheless it expects to remain
59 financially stable.
60 Q.What is your conclusion?
61 A.The Company has the financial capability to acquire the Plant.
62 Q.Does this conclude your testimony?
63 A.Yes.
Page 3 - Confidential Testimony of Bruce N. Wiliams
- '
CERTIFICATE OF SERVICE
I hereby certify that I caused a tre and correct copy ofthe foregoing TESTIMONY OF
BRUCE N. WILLIAMS FOR ROCKY MOUNTAIN POWER to be sered upon the
following by electronic mail and hand delivery to the addresses shown below on April 1,2008:
Michael Ginsberg
Patricia E. Schmid
Assistant Attorney Generals
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 84111
mginsberg(futah.gov
pschn1Íd(ßutah. gov
Paul H. Proctor
Assistant Attorney General
500 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 84111
pproctor(ßutah. gov
Wiliam A. Powell
Division of Public Utilities
400 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 84111
wpowellcgutah. gOY
Michele Beck
Cheryl Muray
Committee of Consumer Services
200 Heber M. Wells Building
160 East 300 South
Salt Lake City, UT 84111
mbeckcgutah.gov
cmurrayßutah.gov
Gary A. Dodge
Hatch, James & Dodge
10 West Broadway, Suite 400
Salt Lake City, UT 84101
gdodge(ßhj dlaw .com
F. Robert Reeder
Wiliam J. Evans
Michael J. Malmquist
Vicki M. Baldwin
Parsons Behle & Latimer
201 South Main Street, Suite 1800
Salt Lake City, UT 84145-0898
frccdercgarsonsbchlc.com
bevans(f,parsonsbehle.com
mmalmquistcgparsonsbehle.com
vbaldwincgarsonsbehle.com
SaltLake-37 I 469.4 008500-01002