HomeMy WebLinkAbout20101116Rebuttal Testimony Cover Letter, Summary.pdf~~~OUNTAIN
RECE
November is, 2010 29tn NOV , 6 ril' to: '4
201 South Main, Suite 230
Salt Lake City, Utah 84111
VI OVERNIGHT DELIVERY
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Jean D. Jewell
Commission Secretar
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
Re: Case No. PAC-E-1O-07
In the Matter of the Application of Rocky Momitain Power for Approval of Chages to
its Electrc Service Schedules and a Price Increase of $27.7 Milion, or Approximately
13.7 Percent
Dear Ms. Jewell:
Please find enclosed for filing an original and nie copies of Rocky Momitain Power' s Re~
Testimony in the above-referenced matter. Also enclosed is a CD contang the summj of.
testimony, testimony and exhbits, and a confdential CD contang confdential testiony and
exhbits. To the attention of the Cour Reporter is a paper copy of all documents along with a CD
containg all testimony and exhbits in their original formats.
Rocky Momitan Power would note that, in accordance with Order No. 32098, Rocky Momita
Power has not addressed in rebutt testimony the statements made by Monsanto witnesses
related to the curlment valuation.
Very try yours,
q~k.~(-rw)
Jeffey K. Larsen
Vice President, Reguation
cc: Service List
Enclosures
CERTIFICATE OF SERVICE
.'fi )1n!J \ 6 M'HO: \ 4
i hereby certify that on ths 16th day of November, 2010, I caused to be serviil'l":-mail~~.,~,e
and correct copy of Rocky Momitain Power's Rebutt Testimony and Exhbits ~R~~.:W~\.q\lSiOt.lth .c II '\I\'T.r~" .'d......to e 10 owig: U1 ..' i I,;:;'"' '-
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Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey,
Charered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: elo(iracinelaw.net
Randal C. Budge
Racine, Olson, Nye, Budge & Bailey,
Charered
201 E. Center
P.O. Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb(iracinelaw.net
Tim Buller
Jason Hars
Agrium, Inc.
3010 Conda Road
Soda Sprigs, il 83276
E-Mail: tbuller(iagrium.com
JAHars(iagrum.com
Scott Woodbur
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washigton (83702)
PO Box 83720
Boise, ID 83720-0074
E-Mail: scott.woodburØ)uc.idaho.gov
Brad Purdy
CAPAI
2019N.17thSt.
Boise, ID. 83702
E-mail: bmpurdy(ihotmail.com
Anthony Yanel
29814 Lake Road
Bay Vilage, Ohio 44140
E-mail: tony(iyanel.net
Paul J. Hickey
Hickey & Evan, LLP
1800 Carey Ave. , Suite 700
PO Box 467
Cheyenne, WY 82003
E-Mail: phickey(ihickeyevans.com
Katie Iverson (E-mail only)
Brubaker & Associates
17244 W. Cordova Cour
Sunse, Arzona 8S387
E-Mail: kiverson(iconsultbai.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
P.O. Box 844
Boise, Idaho 83702
E-mail: bottoimidahoconservation.org
Melinda J. Davison
Davison Van Cleve, P.C.
333 S.W. Taylor, Suite 400
Portland, OR 97204
E-mail: mjdimdvclaw.com
Ronald L. Wiliams
Wiliams Bradbur, P.C.
101S W. Hays St.
Boise ID, 83702
E-mail: ron(iwiliamsbradbur.com
James R. Smith (E-mail only)
Monsanto Company
P.O. Box 816
Soda Sprigs, Idaho 83276
E-Mail: jim.r.smith(imonsanto.com
Dr. Don Reading (E-mail Only)
Idaho Conservation League
6070 Hil Road
Boise, ID 83703
E-mail: dreadingimmindspring.com
An~~~
Coordinator, Admnistrative Services
ROCKY MOUNAIN POWER
SUMMY OF REBUTTAL TESTIMONY
PAC-E-IO-07 ¿mnHOVI 6 AM 10: l 4
Rocky Momitain Power, a division ofPacifiCorp, provides ths sumar of¡'!t
filed in support of its general rate case application. Copies of the Company'šfl ing are
available online at ww.pacificorp.com; click on "News and Ino" and then select
"Regulatory Inormation" and "Idaho." Copies of the filing may also be reviewed durng
regular business hours at the offces of the Idaho Public Utilties Commssion in Boise
and in these Rocky Momita Power offces:
. 2S Eat Main, Rexburg
. S09 South 200 East, Preston
. 8S2 East 1400 Nort, Shelley
. 248S2 U.S. Highway 89, Montpelier
A. RICHA W AL
President, Rocky Mountain Power
Company witness Walje provides a sumar of the Company's rebutt position for the
2010 Idaho general rate case, and addresses certain policy issues raised by intervenig
paries and the implications those issues would have to the Company if implemented. Mr.
Walje testifies that the Company requis a revenue $24.9 millon or a 12.3 percent
average increase over Rocky Momitain Power's curent rates, which is a reduction of
$2.8 millon from the Company's original requested increase $27.7 milion, or 13.7
percent overalL. Commssion approval of this increase will enable the Company to
maintan the fiancial stengt necessar to attct the reuisite capital to meet the
electrcal servce needs of its Idaho customers.
Mr. Walje's testimony also discusses the Company's efforts to control costs while
maintainng reliable service and customer satisfaction, and responds to the testiony
filed by Monsanto regarding the effect of rising electrcity prices on its business.
BRUCE N. WILLIAS
Vice President and Treasurer
Company witness Wiliams' rebutt testimony responds to the capital strctu
recommendations offered by Monsanto witness Michael P. Gorman and Idaho Public
Utilties Commission Sta witness Ms. Terr Carlock. Mr. Wiliams' also rebuts the
adjustment to pension expense proposed by Idaho Public Utilties Commssion Sta
witness Mr. Donn English.
SAMLC.HAAWAY
FINANCO, Inc.
Dr. Hadaway's rebutt testimony responds to the rate of retu on equity ("ROE")
recommendations offered by Idaho Public Utilties Commission Staff witness Ms. Terr
Carlock and Monsanto witness Mr. Michael P. Gorman. His analysis demonstrtes that
their rate of retu recommendations are not consistent with the ongoing equity market
volatilty or the contiuig financial distress that the U.S. economy is midergoing. Dr.
Hadaway also responds to the other witnesses' comments on the methodology used in his
direct testimony to estimate Rocky Momita Power's cost of equity. Dr. Hadway's
updated ROE analysis for curent market costs and conditions continues to show that the
Company's requested ROE of 10.6 is reasonable.
MAR. TALLMA
Vice President of Renewable Resource Development
Company witness Tallman rebuts the testimony of Mr. Joe Leckie of the Idaho Public
Utilties Commssion Staff as it relates to rate base associated with the Dunap wid
project and operations and maintenance costs associated with wid adminstration and the
High Plains, McFadden Ridge I, and Dunap wind projects.
CHA A. TEPLY
Vice President of Resource Development and Constrction for PacifiCorp Energy
Company witness Teply's rebuttal testimony responds to the direct testimony of Randall
J. Falkenberg on behalf of the PacifiCorp Idaho Industrial Customers regarding the
Company's management and fiancial modeling of miplaned thermal unt outages and
also responds to the direct testimony of Don Reading on behalf of the Idao Conservation
League regarding prudence of the Company's pollution control expenditues for coal-
fired power generation plants.
CAROL L HUNTER
Vice President of Services
Ms. Hmiter responds to or rebuts certin issues raised in the testimonies of Mr. Rady
Lobb and Mr. Gar Grayson of the Idao Public Utilties Commssion Sta as it relates
to the investment in the company's energy efficiency and load control programs.
CINDY A. CRAE
Vice President, Interwest Mining Company and Fuel Resources
Company witness Crae rebuts the testimony of Idaho Public Utilities Commssion Sta
witness Mr. Leckie regarding IPUC's proposed disallowance of the Company's Fuel
Stock and the testimony of PacifiCorp Idao Industral Consumers witness Mr.
Falenberg regardig fuel quaity problems at the Jim Bridger plant.
DARLL T. GERRRD
Vice President of Transmission Planning
Company witness Gerrard provides rebutt testiony to the direct testimony filed by Mr.
Denns E. Peseau on behalf of Monsanto Company and to the direct testimony of Mr.
Rady Lobb, on behalf of the Idaho Public Utilties Commssion sta, regarding the
Company's Populus to Termna tramission project. In parcular, Mr. Gerrd
responds to assertions tht the Populus to Termin tranmission project is not ''used and
usefu" and is oversized.
ERICH D. WILSON
Director, Human Resources
Company witness Wilson rebuts employee salar and anua incentive adjustments
proposed by PacifiCorp Idao Industral Consumers witness Greg Meyer and Idaho
Public Utilties Commssion Sta witness Donn English.
DR. HU SHU
Manager, Net Power Costs
Company witness Shu testifies in support of the Company's revised net power costs of
$ 1.063 bilion system-wide, which is approximately $69 millon on an Idao allocated
basis as calculated using the Generation and Reguation Initiatives Decision Tools
(GRID) modeL. Dr. Shu also responds to the adjustments to the Company's filed net
power costs proposed by Mr. Bryan Lanspery of the Idao Public Utilities Commssion
Staff, Mr. Radall J. Falenberg on behaf of the PacifiCorp Idaho Industral Customers,
and Mr. Mark T. Widmer on behalf of Monsato.
GREGORY N. DUVALL
Director, Long Range Planning and Net Power Costs.
Company witness Duvall will respond to Mr. Brian Collns and Ms. Kath Iverson's
testimony that was filed on behalf of Monsanto. Mr. Duvall will rebut Mr. Collins'
comments regardig the treatment of Monsanto's load and interrptible products in the
Company's Integrated Resource Plan (IRP), and Ms. Iverson's comments regarding the
interrptible natue of Monsanto's load and the appropriate reguatory treatment of
Monsanto.
BARAR A. COUGHLIN
Director, Customer and Regulatory Liaison
Ms. Coughin will respond to testimony of Ms. Marlyn Parker and Mr. Curis Thaden of
Idaho Public Utilties Commssion Staff (Sta and Ms. Teri Otens representing
Communty Action Parership Association of Idaho (CAPAI). Ms. Coughin will
address several customer service related issues raised by these witnesses regardig
landlord interim biling and Link Programs, Red Flag Rules, rebiling, customer
notification for rebiling, mibiled usage, meter upgrade, moratorium and winter payment
plan communcations, Lend-A-Hand contrbutions, energy conversation education, low
income weatherization fuding; and low income weatherization matching fuds.
DR. PETER C. EELKEMA
Lead/Senior Consultant, Load and Revenue Forecastig
Company witness Eelkema's testiony rebuts the increase in test year irrgation sales
proposed by Mr. Anthony Yanel on behaf of Idaho Irrgation Pumpers Association and
the increase in residential revenues proposed by Mr. Greg Meyers on behalf of the
PacifiCorp Idao Industral Customers.
STEVEN R. MCDOUGAL
Director, Revenue Requirement
Company witness McDougal testifies in support of the calculation of $24.9 millon
revenue increase and the sources of the data used in determining the normalizing
adjustments related to revenue, operations and maintenance expense, net power costs,
depreciation and amortization, taes, and rate base in developing the Idaho revenue
requirement. Mr. McDougal's rebutt testimony responds to adjustments proposed in the
pre-fied direct testimony filed by the intervening pares regarding the Company's
revenue requiement.
C. CRAG PAICE
Regulatory Consultant in the Pricing and Cost of Service Department
Company witness Paice's rebutt testimony includes revised exhbits to reflect changes
in the Idaho Results of Operations contaned in the rebutt testimony of Company
witness Mr. Steven R. McDougal. Additionally, Mr. Paice responds to the testimony of
Idaho Public Utilties Commission Sta witness Mr. Bryan Lanspery, Idao Industral
Customers witness Mr. Donald Schoenbeck, and Communty Action Parership
Association of Idaho witness Ms. Teri Ottens.
WILLIA R. GRIFFITH
Director, Pricing, Cost of Service & Regulatory Operations
Company witness Griffth's rebutt testiony provides updated proposed rate spread and
rate design exhbits tht reflect adjustents to the cost of service study to which the
Company has agreed. Mr. Grffith also addresses the direct testimony of Mr. Bryan
Lanspery of the Idaho Public Utilties Commssion sta, Dr. Don C. Readig of the
Idaho Conservation League, and Ms. Ter Ottens of the Communty Action Parership
Association of Idaho (CAPAI) concernng residential rate design issues.
Accordingly, Rocky Momitan Power proposes the following allocation of the net price
increase for major customer classes:
Customer Class
Residential - Schedule 1
Residential- Schedule 36
General Servce
Schedule 23/23A
Schedule 6/6AJ3S/3SA
Schedule 9
Schedule 19
Irrgation
Schedule 10
Special Contrcts
Schedule 400
Schedule 401
Public Street Lighting
Schedules 7/7 A, 1 1, 12
Proposed Price Chage
7.2%
14.6%
9.7%
13.3%
12.8%
10.8%
7.6%
18.2%
14.7%
0%