HomeMy WebLinkAbout20100915McDougal Direct.pdfREeE
'lOi6 SEP l 5 M~ 9: 35
. \.Qt:ltC
UTiLi\\cv
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of )
PacifiCorp dba Rocky Mountain Power ) CASE NO. PAC-E-I0-09
for Approval of Amendments to )
Revised Protocol Allocation ) Direct Testimony of Steven R. McDougalMethodology )
ROCKY MOUNTAIN POWER
CASE NO. PAC-E-I0-09
September 2010
1 Q.
2
3 A.
Please state your name, business address and present position with
PacifCorp (the Company).
My name is Steven R. McDougal, and my business address is 201 South Main,
4 Suite 2300, Salt Lake City, Utah, 84111. I am curently employed as the director
5 of revenue requirement.
6 Qualifications
7 Q.
8 A.
9
10
11
12
13
14
15 Q.
16 A.
17
18
19
20
21 Q.
22 A.
23
Briefly describe your educational and professional background.
I received a Master of Accountancy degree from Brigham Young University with
an emphasis in Management Advisory Services in 1983 and a Bachelor of Science
degree in Accounting from Brigham Young University in 1982. In addition to my
formal education, I have also attended various educational, professional, and
electrc industr-related seminars. I have been employed by PacifiCorp or its
predecessor companies since 1983. My experience at PacifiCorp includes various
positions within regulation, finance, resource planning, and internal audit.
What are your responsibilties as director of revenue requirements?
My primary responsibilities include overseeing the calculation and reporting of
the Company's regulated earings or revenue requirement, assurng that the inter-
jursdictional cost allocation methodology is correctly applied, and explaining
those calculations to regulators in the jurisdictions in which the Company
operates.
Have you testified in previous regulatory proceedings?
Yes. I have provided testimony before the Public Service Commission of Utah,
the Washington Utilties and Transportation Commission, the California Public
McDougal, Di - 1
Rocky Mountain Power
1 Utilities Commission, the Idaho Public Utilities Commission, the Public Service
2 Commission of Wyoming, and the Utah State Tax Commission.
3 Purpose of Direct Testimony
4 Q.
5 A.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
What is the purpose of your direct testimony in this proceeding?
My direct testimony addresses the calculation and implementation of the 2010
Protocol allocation methodology. Specifically, I provide direct testimony on the
following:
. calculation of the Company's projected revenue requirement for calendar
years 20 1 0 through 2019 and the corresponding inter-jursdictional allocation
(Baseline Study);
. a review of historical results using the Revised Protocol;
. changes between the Revised Protocol and 2010 Protocol, including changes
in allocation factors, the calculation of the Embedded Cost Differential
(ECD), the fixed allocation adjustments for each state, and treatment of costs
related to the Klamath Hydroelectrc Settlement Agreement (KHSA);
. information to be included the Company's future results of operations reports
and rate cases related to the 2010 Protocol and the calculation of the ECD;
. changes to the following appendices included with the direct testimony of Ms.
Andrea L. Kelly: 1) Appendix B - Allocation Factor Applied to each
Component for Revenue Requirement; 2) Appendix C - Allocation factor-
Algebraic Definitions; 3) Appendix D - Special Contracts; 4) Appendix E - 6-
Year Levelized Fixed Dollar Embedded Cost Differential Hydro Endowment;
and 5) Appendix F - Methodology for Determining Mid-C (MC) Factor; and
McDougal, Di - 2
Rocky Mountain Power
1 . allocation of State resources associated with: 1) Demand-Side Management
2 Programs; 2) Portfolio Standards; 3) State-specific Initiatives; and 4) New QF
3 Contracts.
4 Baseline Study
5 Q.
6 A.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Why did the Company prepare the Baseline Study?
As described by Ms. Kelly, the Company prepared the Baseline Study at the
request of the Multi-State Process (MSP) Standing Committee. The purose of
the study was to compute a curent projection of revenue requirement for calendar
years 2010 through 2019 and produce the inter-jurisdictional allocation according
to the Revised Protocol, Rolled-In, and Modified Accord allocation
methodologies. The study was designed to facilitate MSP participants'
assessment of the ongoing reasonableness of Revised Protocol to determine if
modifications were needed. The focus of the Baseline Study was to create a tool
that could be used to compare curent expectations of the future on varying
allocation methodologies. The Baseline Study is not intended to precisely predict
annual revenue requirement through calendar year 2019 and does not serve to
predict futue rate setting proceedings or price changes in any state. Rather, it
serves to model differing allocation assumptions and is used as an analytical tool
to assess the impact of those assumptions on the states served by the Company.
The purpose of the Company's baseline study was described using the
following language circulated to MSP participants:
"These attachments represent the Company's best efforts to
provide reasonable draft projections of the differences in allocation
methodologies over the 10-year study horizon. Emphasis was put on
forecasting items that are treated differently and would create differences
McDougal, Di - 3
Rocky Mountain Power
1
2
3
4
5
6
7 Q.
8 A.
9
10
11
12
13
14
15
16
17
18
19
20 Q.
21 A.
22
23
24
25
26
between the allocation methodologies used. Less time was spent on items
that are treated the same in the various allocation methodologies, since this
would not impact the comparisons between allocation methodologies. As
such, the focus of the analysis was on the relative differences between
allocation methodologies, as opposed to the absolute level of total
company revenue requirement."
Please describe how the Company produced the Baseline Study.
Study preparation began in mid-2009. Projected revenue requirement was based
on actual 2008 costs which were escalated through the study time horizon to
reflect inflation and expected changes in the Company's resource base consistent
with the 2008 Integrated Resource Plan (IRP). System net power costs (NPC)
were computed consistent with these assumptions as described in the direct
testimony ofMr. Gregory N. Duvall. Jurisdictional allocation factors were
calculated for each year of the study using the forecast load from the Company's
February 2009 load forecast. Jurisdictional revenue requirement was then
calculated according to Revised Protocol and compared to the allocation
methodology preferred by each state prior to adoption of Revised Protocol, either
Rolled-In or Modified Accord. Preliminary results of the study were provided to
MSP paricipants on August 17, 2009.
Why were the August 2009 results considered preliminary?
The August 17, 2009 study was considered a draft by the Company and was
provided to MSP participants in order to vet the modeling of assumptions and the
resulting revenue requirement. The results were also considered preliminary
because of the treatment of the Klamath hydro project. At this stage in the
process the KHSA had not yet been finalized; consequently, the preliminary study
assumed that Klamath would be relicensed and included cost assumptions based
McDougal, Di - 4
Rocky Mountain Power
1
2
3
4
5
6
7
8 Q.
9 A.
10
11
12 Q.
13 A.
14
15
16
17 Q.
18
19 A.
20
21
22
on the best information available at that time. After circulating the preliminary
results in August 2009, the Company solicited feedback from the MSP
participants in workgroup meetings. As described by Ms. Kelly, several Utah
paries subsequently issued a notification to MSP participants questioning the
continued used of Revised Protocol. The Company gathered input from MSP
participants, continued to refine the revenue requirement modeling, and awaited
finalization of the KHSA in order to produce the final Baseline Study.
When was the Baseline Study finalized?
Once the KHSA was finalized, the Company incorporated it and other feedback
from MSP participants into the revenue requirement modeling, and the Baseline
Study was finalized and shared with MSP participants in March 2010.
What were the results of the Baseline Study?
Exhibit NO.2 provides the results of the Baseline Study. Revenue requirement
using Revised Protocol for each state is compared to the allocation methodology
used by that state prior to adoption of Revised Protocol, either Rolled-In or
Modified Accord.
Was the Baseline Study compared to the study performed in 2004 supporting
Revised Protocol (the 2004 Study)?
Yes. The relative differences by state between Revised Protocol and Rolled-In or
Modified Accord in the Baseline Study were compared to the relative differences
between the same allocation methodologies used in the Company's 2004 Study.
The results are shown in Exhibit NO.2. This comparison spured continued
McDougal, Di - 5
Rocky Mountain Power
1
2
3 Q.
4
5 A.
6
7
8 Q.
9 A.
10
11
12
13
14
15 Q.
16
17 A.
18
19
20
21
22
discussion among the MSP paricipants regarding whether Revised Protocol wil
perform as originally expected based on updated expectations of the futue.
Were there any additional analyses performed based on the Baseline Study
results?
Yes. At the request of the Standing Committee, the Company performed
alternative studies related to varying wholesale market prices, the value of
operating as a single integrated system, and the impact of load growth.
Please describe the study related to wholesale market prices.
The Standing Committee requested a study to test the potential impact on each
jursdiction under Revised Protocol with a given change in wholesale market
prices, one using high market prices and one using low market prices. The direct
testimony of Mr. Duvall describes the corresponding calculation ofNPC and I
incorporated his revised NPC results into the revenue requirement modeL. A
summary of the results is provided in Exhibit NO.3.
Please describe the studies performed on the value of the single integrated
system.
Two studies, a strctual separation study and go-it-alone analysis, were
completed to estimate the benefits of the Company continuing to plan and operate
as a single integrated system. The direct testimony of Mr. Duvall describes each
of these studies in greater detail along with the calculation of the impact on NPC
in each scenario. The results of these studies are provided in the direct testimony
of Mr. Duvall.
McDougal, Di - 6
Rocky Mountain Power
1 Q.
2 A.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Please describe the load. growth study.
An additional study was conducted to estimate the impact of load growt on the
various jurisdictions. The study began with the baseline study. Load growth was
then adjusted in Utah and Wyoming, the two fastest growing jursdictions, to a
level consistent with other states. Using the revised load data, the following three
changes were made to the revenue requirement calculation: 1) NPC were updated,
as described in the direct testimony of Mr. Duvall; 2) jurisdictional demand and
energy used to compute inter-jursdictional allocation factors were updated; and
3) rate base and operation and maintenance costs were updated to be consistent
with the change in loads and resources. The results of the study for both Revised
Protocol and Rolled-In are included in Exhibit NO.4. The net impact of the
change to the dynamic allocation factors and net power costs was an allocation of
103 percent of the incremental cost of load growth to Utah and Wyoming, the
fastest growing states. The slower growing states all receive a slight benefit from
the load growth because of the reallocation of fixed costs.
The load growth study showed that the dynamic allocation factors utilized
under a Rolled-In allocation methodology protect individual states from bearing
the cost of load growth in other states. This study showed that curently load
growth is not an issue and is not expected to be an issue in the futue. On the
contrary, Revised Protocol was shown to have a great deal of volatility related to
the calculation of the ECD and is therefore not a singularly effective protection
mechanism against load growth.
McDougal, Di - 7
Rocky Mountain Power
1 Historical Results
2 Q.Did the Company compare historical results utiliing Revised Protocol to the
3 2004 Study?
4 A.Yes. An analysis was prepared to help the MSP participants better understand
5 how the Revised Protocol has performed historically. The results of this analysis
6 are shown in Exhibit No.5. This analysis shows there is a great deal of volatility
7 in the Revised Protocol results, driven mainly by the ECD calculation. As a
8 result, considerable analysis was done on various options to the ECD resulting in
9 the changes described later in my testimony.
10 2010 Protocol
11 Q.Please describe the major differences between the 2010 Protocol and the
12 Revised Protocol.
13 A.The 2010 Protocol is a simplified version of the Revised Protocol that is intended
14 to reduce unintended variation in the allocation of actual revenue requirement as
15 compared to the forecasts used in the 2004 Study and the Baseline Study. The
16 specific changes to Revised Protocol incorporated into the 2010 Protocol are
17 identified below.
18 . Factor Changes: Similar to Revised Protocol, the 2010 Protocol is based on
19 an initial Rolled-In allocation of system costs. Resources classified as
20 seasonal for Revised Protocol (including simple cycle combustion turbines
21 and the Cholla Unit 4/ APS exchange) wil no longer be uniquely allocated,
22 but wil follow a Rolled-In allocation. Consequently, the allocation of system
23 costs, prior to the application of the ECD and KHSA deviations, is the same as
McDougal, Di -.8
Rocky Mountain Power
1
2 .
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
the Rolled-In allocation methodology.
ECD Changes: The scope of the ECD has been modified in the 2010
Protocol, specifically related to Qualifying Facility (QF) contracts and the
"All Other" generation resources category. All QF contracts entered into prior
to September 15, 2010, are considered system resources in the 2010 Protocol
and wil not be considered as part of the ECD calculation. New QF contracts
wil also be considered system resources unless deemed to be priced greater
than comparable resources. The embedded cost of "All Other" generation
resources includes only resources that were part of the Company's integrated
system prior to 2005.
The ECD calculation, prior to levelization, was done using forecasted
information from the Baseline study, using the following three sections from
the Revised Protocol ECD calculation:
Company Owned Hydro - West: This section was calculated the same as
under Revised Protocol.
Mid-C Contracts: This section was calculated the same as curently used
in all Company filings. The Grant Reasonable contract is included as an
offset to the Mid-C contract costs.
Generation Costs - Pre-2005 Resources ("All Other" Generation): This
section was calculated the same as in Revised Protocol with the exception
that the calculation of the embedded cost of "All Other" resources only
included costs and MWh associated with pre-2005 resources.
McDougal, Di - 9
Rocky Mountain Power
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18 Q.
19
20 A.
21
22
23
· ECD Levelization: The value of the modified 2010 Protocol ECD is
calculated for each state in the Baseline Study, levelized, and fixed for all rate
cases fied through December 31, 2016, rather than allowed to float with each
rate case or other regulatory filing.
. Klamath Costs: All costs related to the KHSA are initially allocated to all
states in unadjusted results. The depreciation expense associated with
Klamath assets wil be adjusted on January 1,2011, in order to fully
depreciate these assets by December 31, 2019. The system allocation of
Klamath costs is consistent with the benefits of the hydro output under the
Rolled-In allocation methodology. As part of the 2010 Protocol agreement, an
adjustment is made to reverse the initial system allocation of the KHSA
surcharge expected to be paid for by Oregon and California customers and
situs assigns it to those states based on the amounts stipulated in the KHSA.
This re-allocation of costs is consistent with the reallocation of hydro benefits
accomplished through the ECD component of the 2010 Protocol. The
surcharge included in the Baseline Study is levelized and fixed for the period
2011 through 2016 and included in the 2010 Protocol at the levelized amount.
Why is the scope of the ECD limited to only pre-2005 resources in the "All
Other" generation resource category?
During the MSP meetings, the costs of "All Other" generation were identified as
one of the components causing varability in the Revised Protocol ECD
calculation. Several options were studied for the "All Other" generation cost
component, including using pre-1989 resources to correspond with the date of the
McDougal, Di - 10
Rocky Mountain Power
1
2
3
4
5
6
7 Q.
8
9 A.
10
11
12
13
14
15
16
17
18
19 Q.
20
21 A.
22
23
original merger, using pre-2005 resources to align with the adoption of Revised
Protocol, or continuing to base the "All Other" resources on curent assets. The
MSP participants agreed that since the ECD compares legacy hydro resources to
"All Other" generation, using pre-2005 would provide a consistent calculation,
and would exclude new resources acquired which may cause significant impacts
on the calculation. The list ofpre-2005 resources is provided as Exhibit NO.6.
What are the costs related to the KHSA and why is an adjustment necessary
to re-allocate the KHSA surcharge?
Since the 2010 Protocol uses Rolled-In allocation as the baseline, it was decided
that the KHSA costs wil initially be system allocated. This is consistent with the
treatment of costs for other system resources under Rolled-In, and is consistent
with the benefit of the Klamath resources which are allocated to all jursdictions
under Rolled In. However, consistent with the ECD calculation which re-
allocates the hydro costs and benefits to Pacific Power states, an adjustment wil
be made to the KHSA surcharge to undo the system allocation and directly assign
the amount of the surcharge borne by California and Oregon though respective
tariff riders in those states. This re-allocation does not revoke the right of parties
in any jursdiction to review the KHSA costs for prudency.
Please explain how the ECD and KHSA surcharge will be levelied and fixed
for the period 2011 through 2016.
The starting point for the levelized ECD and KHSA calculation is the annual
amounts included in Exhibit No.7. The anual amounts were levelized using the
2008 IRP discount rate to come up with the six year net present value shown on
McDougal, Di - 11
Rocky Mountain Power
1 the bottom of Exhibit NO.8. Anuallevelized amounts were then developed that
2 result in the same net present value by jurisdiction over the six year period from
3 2011 to 2016.
4 Q.Please ilustrate the revenue requirement difference between the 2010
5 Protocol and Revised Protocol.
6 A.The difference between results using the 2010 Protocol and Revised Protocol are
7 shown on Exhibit NO.9. This exhibit shows, for each jursdiction, the revenue
8 requirement difference from changing to 2010 Protocol.
9 Future Reporting
10 Q.What information wil the Company provide in its results of operations
11 reports and rate cases related to allocation methodologies?
12 A.Subject to the approval of the Company's application, jursdictional revenue
13 requirement in future results of operations reports and rate cases wil be calculated
14 using the 2010 Protocol allocation methodology. In addition, all historical results
15 of operations fied by the Company wil include a calculation of the 2010 Protocol
16 ECD using historical data. This wil be provided for informational puroses for
17 states to track the information over time. The Company proposes to no longer
18 provide reports or comparisons using any other allocation methodologies.
19 MSP Appendix Modifcations
20 Q.Please describe the changes to Appendix B - Allocation Factor Applied to
21 each Component for Revenue Requirement.
22 A.Appendix B has been updated to remove allocation factors related to seasonal
23 resources and the Cholla resource which are no longer used in 2010 Protocol.
McDougal, Di - 12
Rocky Mountain Power
1
2
3
4 Q.
5
6 A.
7
8
9
10
11
12
13 Q.
14 A.
15
16
17
18
19
20
21
22
23
The changes to Appendix B also include general cleanup and housekeeping, such
as removing factor combinations no longer used and adding new factor
combinations since Revised Protocol was originally developed.
Please describe the changes to Appendix C - Allocation factor - Algebraic
Derivations.
Derivations of factors related to seasonal resources and the Cholla Unit 4/ APS
exchange which are no longer used in 2010 Protocol have been removed. The
income before tax factor has been removed, and state income taxes wil be
calculated using the statutory state effective tax rate, consistent with the
methodology used to calculate state income taxes associated with rate changes in
rate cases in all states. This change is necessary because of the volatility of
calculating results for a single jursdiction.
Please describe the changes to Appendix D - Special Contracts.
This document remains unchanged, other than now labeling the document as
"2010 Protocol". The appendix has two options for special contracts designed to
provide consistency between the allocation of revenues, costs and benefits derived
from adjusting allocation factors. Under option 1, the costs of a program are
embedded in the tariff price, resulting in the jurisdiction approving the contract
absorbing the full cost of the program, similar to demand-side management
(DSM) costs. Since the costs are absorbed by the jurisdiction approving the
contract, it also receives the benefits associated with the program through reduced
allocation factors. Under option 2, the contract costs are separately identified and
allocated to all states. Since the costs are allocated to all states and not to a
McDougal, Di - 13
Rocky Mountain Power
I
2
3 Q.
4
5 A.
6
7
8
9
10 Q.
11
12 A.
13
14
15
specific jurisdiction, the monthly load used to calculate allocation factors is
calculated assuming no curailment occurs.
Please describe the changes to Appendix E - 6- Year Levelized Fixed Dollar
Embedded Cost Differential Hydro Endowment.
This document has been re-crafted to reflect the ECD from the 2010 Protocol and
therefore replaces in its entirety, rather than changig Appendix E from the
Revised Protocol. Under the 2010 Protocol, the ECD amount has been levelized
and is set at a fixed amount. The ECD page has been updated to show the
amounts that wil be included in fiings made through December 31, 2016.
Please describe the changes to Appendix F - Methodology for Determining
Mid-C (MC) Factor.
This document remains unchanged, other than now labeling the document as
"2010 Protocol". The MC factor is utilized in the Baseline Study to compute the
allocation ofthe projected ECD. However, because the ECD is fixed by year and
by state in the 2010 Protocol, this factor wil not be directly utilized in fiings
16 made prior to December 31,2016.
17 State Resources
18 Q.
19 A.
How wil State Resources be allocated in 2010 Protocol?
As.mentioned above, state resources included: 1) Demand-Side Management
20 Programs; 2) Portfolio Stadards; 3) State-specific Initiatives; and 4) New QF
21 Contracts. There is no change in the allocation of State resources, which continue
22 to be situs allocated per the 2010 Protocol.
McDougal, Di - 14
Rocky Mountain Power
1 Q.
2 A.
Does this conclude your direct testimony?
Yes.
McDougal, Di - 15
Rocky Mountain Power
Case No. PAC-E-1O-09
Exhibit NO.2
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAI POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
Baseline Study and 2004 Study Comparison
September 2010
,-=i: :i~ '"6~'" II'" i:GO .-Ol ""e ..
i: "C
.a .es ~~ i:i ~¡e ~:i ~:: -~N
~ ~
"eo ~
~
s: ~
~ ~o
l""
i
t
\
g
~g
~
i.
~
¡¡
~ l ~ ! !~..
~g
101I
~
~
~
Ii
~
Ii
i
~, ,,~~ l..
~0;
~
o..
~ ~-
,..
..
L9 :t:: i;
..i;
Rock Mountain Power
Exhibit NO.2 Page 1 of 1
Case No. PAe-E-1Q-e
\Iess: Steven R. McDougal
~
G
¡e
~
G2
2
2
2
¡
~
..
SN
"~,,.., ~,~~~,..
~1
i
r
¡¡
~¡- i
i
¡ ¡r
~I
i i
j 1i.
t i i
~ ~ ~.. in C)
~ ~ ~
¡
~
~
2
~
! t t t
~
~
~
~~,~~o ,~~
0;
Case No. PAC-E-1O-09
Exhibit NO.3
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
High and Low Market Price Studies
September 2010
r-,.QN
Rocky Mountain Power
Exhibit No. 3 Page. 1 of 1
Case No. PAC-E-10-09
Witness: Steven R. McDougal
r-,.QN
Case No. PAC-E-1O-09
Exhibit NO.4
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
Load Growth Study
September 2010
Mu
l
t
i
-
S
t
a
t
e
P
r
o
c
e
s
s
(
M
S
P
)
Pe
r
c
e
n
t
a
g
e
o
f
L
o
a
d
G
r
o
w
t
h
A
l
l
o
c
a
t
e
d
b
y
S
t
a
t
e
-
2
0
1
1
t
h
r
o
u
g
h
2
0
1
9
20
1
1
-
2
0
1
9
(
9
-
Y
e
a
r
)
2
0
1
0
NP
V
~
7
.
3
6
%
20
1
1
20
1
2
20
1
3
20
1
4
20
1
5
20
1
6
20
1
7
20
1
8
20
1
9
Re
v
i
s
e
d
P
r
o
t
o
c
o
l
%
o
f
L
o
a
d
G
r
o
w
t
h
Ca
l
i
f
o
r
n
i
a
-0
.
1
0
%
-0
.
1
7
%
-0
.
2
8
%
0.
1
1
%
-0
.
1
4
%
-0
.
0
2
%
0.
0
1
%
-0
.
0
6
%
-0
.
2
2
%
-0
.
2
1
%
Or
e
g
o
n
-1
.
6
3
%
-2
.
9
0
%
-4
.
4
6
%
1.
2
3
%
-2
.
1
7
%
-0
.
6
1
%
-0
.
1
7
%
-1
.
1
1
%
-3
.
1
2
%
-2
.
9
5
%
Wa
s
h
i
n
g
t
o
n
-0
.
4
8
%
-0
.
8
9
%
-1
.
3
3
%
0.
3
6
%
-0
.
6
4
%
-0
.
1
7
%
-0
.
0
3
%
-0
.
3
1
%
-0
.
9
2
%
-0
.
8
7
%
Ut
a
h
70
.
5
6
%
73
.
0
6
%
74
.
0
7
%
67
.
6
8
%
71
.
3
7
%
69
.
7
8
%
69
.
0
8
%
69
.
7
6
%
71
.
7
1
%
71
.
7
1
%
Id
a
h
o
-0
.
4
6
%
-0
.
8
8
%
-1
.
2
1
%
0.
2
2
%
-0
.
6
6
%
-0
.
3
2
%
-0
.
0
6
%
-0
.
2
6
%
-0
.
7
7
%
-0
.
7
6
%
Wy
o
m
i
n
g
32
.
1
3
%
31
.
8
3
%
33
.
3
1
%
30
.
3
8
%
32
.
3
0
%
31
.
3
6
%
31
.
1
7
%
31
.
9
9
%
33
.
3
8
%
33
.
1
3
%
Su
m
o
f
U
T
a
n
d
W
Y
L
o
a
d
G
r
o
w
t
h
S
t
a
t
e
s
10
2
.
6
9
%
10
4
.
8
9
%
10
7
.
3
8
%
98
.
0
6
%
10
3
.
6
6
%
10
1
.
1
4
%
10
0
.
2
5
%
10
1
.
7
5
%
10
5
.
0
9
%
10
4
.
8
5
%
20
1
1
.
2
0
1
9
(
9
-
Y
e
a
r
)
2
0
1
0
NP
V
~
7
.
3
6
%
20
1
1
20
1
2
20
1
3
20
1
4
20
1
5
20
1
6
20
1
7
20
1
8
20
1
9
Ro
l
l
e
d
.
l
n
%
o
f
L
o
a
d
G
r
o
w
t
h
Ca
l
i
f
o
r
n
i
a
-0
.
0
9
%
-0
.
1
9
%
-0
.
3
0
%
0.
1
2
%
-0
.
1
3
%
-0
.
0
1
%
0.
0
3
%
-0
.
0
4
%
-0
.
2
0
%
-0
.
1
9
%
Or
e
g
o
n
-1
.
4
8
%
-3
.
2
5
%
-4
.
6
6
%
1.
3
1
%
-2
.
1
7
%
-0
.
5
5
%
0.
1
2
%
-0
.
8
3
%
-2
.
8
7
%
-2
.
7
3
%
Wa
s
h
i
n
g
t
o
n
-0
.
4
5
%
-0
.
9
8
%
-1
.
4
0
%
0.
3
7
%
-0
.
6
5
%
-0
.
1
7
%
0.
0
3
%
-0
.
2
5
%
-0
.
8
7
%
-0
.
8
3
%
Ut
a
h
70
.
0
3
%
73
.
1
3
%
73
.
9
7
%
67
.
3
8
%
71
.
0
6
%
69
.
4
2
%
68
.
3
6
%
69
.
0
5
%
71
.
0
0
%
71
.
0
3
%
Id
a
h
o
-0
.
4
9
%
-0
.
9
0
%
-1
.
2
1
%
0.
1
7
%
-0
.
6
8
%
-0
.
3
4
%
-0
.
1
2
%
-0
.
3
2
%
-0
.
8
0
%
-0
.
7
8
%
Wy
o
m
i
n
g
32
.
5
2
%
32
.
2
6
%
33
.
6
8
%
30
.
6
4
%
32
.
6
2
%
31
.
6
7
%
31
.
5
9
%
32
.
4
2
%
33
.
7
9
%
33
.
5
6
%
Su
m
o
f
U
T
a
n
d
W
Y
L
o
a
d
G
r
o
w
t
h
S
t
a
t
e
s
10
2
.
5
4
%
10
5
.
3
9
%
10
7
.
6
6
%
98
.
0
2
%
10
3
.
6
8
%
10
1
.
0
9
%
99
.
9
5
%
10
1
.
4
7
%
10
4
.
8
0
%
10
4
.
5
9
%
::
(
"
m
;
;
;:
0
)
x
0
il
¡
¡
~
~
(J
z
;
:
-
"
t/
0
Z
š
:
~
~
9
g
!g
~
.
¡
:
:
::
C
D
n
"
'
i
.
m
Q
)
:
:
;:
~
e
i
"
'
š:
'
?
.
.
~
o
0
0
C
D
0(
0
-
"
'
"
o
.
.
cî
Case No. PAC-E-1O-09
Exhibit NO.5
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
Revised Protocol Historical Analysis
September 2010
Rocky Mountain Power
Exhibit No.5 Page 1 of 4
Case No. PAC-E-10-09
Witness: Steven R. McDougal
Multi-State Process (MSP)
2004 MSP Study Comparison to Actual Results - By State
4.00%
2004 MSP Study Comparison to Actual Results
Utah ø Revised Protocol Difference from Rolled In
2.16%
1.50%
Q'Q
:Lt'.::
............I.r-r-,.r-r-co co 009Q999999999'9 9 9 9'".:..~~Q.'"==..;:ci '"~..;00.!..a.0;~....a.Q ....z ::~:"'Z :E ::~z :::i
Q'9c:~
mff~~~Results of Operations Differential ~ Rate Mitigation Cap
Rocky Mountain Power
Exhibit NO.5 Page 2 of 4
Case No. PAC-E-10-09
Witness: Steven R. McDougal
Multi-State Process (MSP)
2004 MSP Study Comparison to Actual Results - By State
2004 MSP Study Comparison to Actual Results
Oregon - Revised Protocol Difference from Modified Accord
-2..00%
1. ..~ î.
.i ~
'.....r..--¡-.....T". ;... --....-...--¡:----r--..-.--r-- ......r......---~....-.-~..1.1.1.~~~~~999999999~a ~. ¡; ~ ~ .~. ~ ~~ ~z~~~ ~
"T'-""""T"-.~ci ci 00 00 00 00 c¡c¡9 '9 -9 9 9 9 9 '9 9;,I:..;i ~go ;,I:i;0 ~""'"0 .s.tT.z ~~-V)z ~----
-1.00%
,. 2004 Study Differential -~Resiilts of Operations Differential
Rocky Mountain Power
Exhibit NO.5 Page 3 of 4
Case No. PAC-E-10-09
Witness: Steven R. McDougal
Multi-State Process (MSP)
2004 MSP Study Comparison to Actual Results - By State
4.00%
3.50%
2004 MSP Study Comparison to Actual Results
Idaho - Revised Protocol Difference from Rolled In
3.84%
1.10%
0.50%
0.00%....i...i.u:'-u:'-u:;c r-r-r-9 9 er e 9 9 ~9 9 0 '9 '9 9 '9..:;~Q.'"=:;:ä ~~c:..:;..o:a.Q ~..o:QI Q ~'"~
:E :E (;.Z :E :E j;z :::E
00i::
""'9
~
""o
iLo:::
00
9'
~
00
'9....
:E
. lI 2004 Study Differential '~.aResults of Operations Differential ..Rate Mitigation Cap
Rocky Mountain Power
Exhibit No.5 Page 4 of 4
Case No. PAC-E-10-09
Witness: Steven R. McDougal
Multi-State Process (MSP)
2004 MSP Study Comparison to Actual Results - By State
2004 MSP Study Comparison to Actual Results
Wyoming - Revised Protocol Difference from Modified Accord
-0.06%
0.00%-...,:r----.....:''!':..............r.-:..............r -'~..r-..--....-:..- ......T..,.-..
-0.20%
~~~~~~~~~9 9 9--:-9 9 .9 '9 9 ex~ "S._~~":~,u:.~.........~~æ M ~ QJ:: ~ VI Z - :::: '"
~ r-
g c¡z !:
i- i-
~ iCO ~
:: ::
i-r-i-cooooctQoooo~oooooI.:.:. "1- ,'-, ....1.. ,.-1'-:" -1..-,- . 1.,- -'-I:; ~-:; æ -1l-:;- q,"" -f. z -. :¡ .:E' ~" '.~
-0.40%
-1.80%-
-. 2004 Study Differential W~~~~~ Results of Operations Differential
Case No. PAC-E-1O-09
Exhibit No.6
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
List ofPre-2005 Resources
September 2010
Rocky Mountain Power
Exhibit NO.6 Page 1 of 1
Case No. PAC-E-10-09
Witness: Steven R. McDougal
Multi-State Process (MSP)
2010 Protocol - Pre-2005 Resources
Resources Included in Embedded Cost Differential (ECD)
All Other $/MWh Calculation
Pre-2005 Resources
BPA and Hermiston Purchase Power Contrcts
Blundell (23 MW)
Carbon
Dave Johnston
Foote Creek I
Gadsby 1,2,3
Gadsby 4,5,6
Hunter
Huntington
Jim Bridger
Naughton
Wyodak
Camas
Colstrp
Craig
Hayden
Cholla
East Hydro
Little Mountain
Hermiston
Case No. PAC-E-1O-09
Exhibit No.7
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
2010 Protocol Embedded Cost Differential by Year
September 2010
6 Year NPV 2011-2016 ~ 7.36%
Klamath Surcharge Situs
ECO Hydro
Total
Total California Oregon
Case No. PAC-E-10-09
Exhibit NO.8
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
2010 Protocol Embedded Cost Differential (Levelized)
September 2010
2011
Klamath Surcharge Situs
EGO Hydro
Total
2012
Klamath Surcharge Situs
EGO Hydro
Total
2013
Klamath Surcharge Situs
EGO Hydro
Total
2014
Klamath Surcharge Situs
EGO Hydro
Total
2015
Klamath Surcharge Situs
EGO Hydro
Total
2016
Klamath Surcharge Situs
EGO Hydro
Total
6 Year NPV
2011-2016 ~ 7.36%
Klamath Surcharge Situs
EGO Hydro
Total
Rocky Mountain Power
Exhibit No. 8 Page 1 of 1
Case No. PAC-E-10-09
Witness: Steven R. McDougal
Multi-State Process (MSP)
2010 MSP Study
6 Year Levelized Average Hydro Endowment Fixed Dollar Proposal
Revenue Requirement ($000)
Total California Oregon
(1) 1,062 11,496(0) .¡~~2Ji?l6i¡rfl
(1 )
Washington Utah Idaho Wyoming FERC
(1,286) (7,272) (976) (2,955) (70)(745) 6,240 836 484 60
.¡fftra~..II...w.if:J.(1 032J¡fff4"~f(im...4""'2' 4T01"ø;à%-7rt;5iIi¿lilll\'i:,t\""~"';;/ÛÆØ"?'" ~%&M~;;;. .:;:;;7//#.':./,,/;,:" ..;;;;;;;,;_;;;;";;;;;;;;;~z;x~lLwÆé'!:l..#itK¡¿..,,/;,,,;¡,.M,,~~ild..m,,,//-;;J0¥-i,~
Total California Oregon Washington Utah
(1) 1,062 11,496 (1,286) (7,272)
(0) WI ;gý.;i.%.%...~~3ui:ffil.(~~~;r~_ _l;....:~ ! .. ... _V,Oi'I! (745) 6,240(1) .~;2' (2,03nif¡dW~93~)i
Idaho Wyoming FERC
(976) (2,955) (70)836 484 60
~J(140YdW;(g~t~;'9lj
Total California Oregon
(1) 1,062 11,496
(0)"Ú(23:~iy~;~¡ (6,8511
(1 )
Utah Idaho Wyoming FERC
(7,272) (976) (2,955) (70)6,240 836 484 60
.. (1~~.3~fj_Ji~i~I1);¡L1;;i;EiiÝ!O;9i
Washington
(1,286)
(745)
.; .;....¡¡..~i*1I3Pjjk~.. /;~;:; A8¡a~/;~~;.A)¿IØß1Wb;
California
1
Idaho Wyoming FERC
(976)(2,955)(70)
836 484 60
Idaho Wyoming FERC
(976)(2,955)(70)
836 484
Wyoming FERC
(2,955)(70)
484
California
1
Total California
(1 1
Total Wyoming
(13,932)
2,281
FERC
(330)
281
California Utah
(34,278)
29,414
Oregon Idaho
(4,601)
3,939
Case No. PAC-E-1O-09
Exhibit No.9
Witness: Steven R. McDougal
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Exhibit Accompanying Direct Testimony of Steven R. McDougal
Compare 2010 Protocol to MSP Study Final (Revised Protocol)
September 2010
Rocky Mountain Power
Exhibit No.9 Page 1 of 1
Case No. PAC-E-10-09
Witness: Steven R. McDougal
\0.-oN
-0 !.U .-0 0..N
0""-0.0=CJ "'.:=ia-aJ :E=
li.Vi~.Wi
"0 ::"l,.~aJ .-~~ix 0 .:..N00~ia..:i ~E =i--~¡~e 0 l~~=..~CJ J:..=lii.~aJ c~CJ U .;:
~=c:-~C Q~i.aJ l'~-~.-00 'i ..0I..
+
..~JB
N--=-..:i =CJ .-
=0-=-i.0~0 U..00..("0 N.-..00.N
0r-0N
.-.-0N
.~*-*-*-ì:ì:*-ì:ì:0 0 0 0 0 0 0 0 0N0\0 "l N 0 "l \0 00.-..0 0 ô 0 0 0 0IIJ