20170705Crane Direct.pdf

O
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.PAC-E-17-07OFROCKYMOUNTAINPOWERFORA)CERTIFICATE OF PUBLIC )DIRECT TESTIMONY OFCONVENIENCEANDNECESSITYAND)CINDY A.CRANEBINDINGRATEMAKINGTREATMENT)FOR NEW WIND AND TRANSMISSION )FACILITIES )
O
ROCKY MOUNTAIN POWER
CASE NO.PAC-E-17-07
June 2017
O
l Q.Please state your name,business address,and present position.
2 A.My name is Cindy A.Crane.My business address is 1407 West North Temple,
3 Suite 310,Salt Lake City,Utah 84116.I am the President and Chief Executive Officer
4 of Rocky Mountain Power ("Company"),a division of PacifiCorp.
5 Q.Briefly describe your professional experience.
6 A.I joined the Company in 1990 and have served as Director of Business Systems
7 Integration,Managing Director of Business Planning and Strategic Analysis,Vice
8 President of Strategy and Division Services,and Vice President of Interwest Mining
9 Company and Fuel Resources.My responsibilities in these positions included the
10 management and development of PacifiCorp's 10-year business plan,directing
11 operations of the Energy West Mining and Bridger Coal companies,and coal supply
12 acquisition and fuel management for PacifiCorp's coal-fired generating plants.InO13October2014,I was appointedto my present position as President and Chief Executive
14 Officer of Rocky Mountain Power.
15 Q.Have you testified in previous regulatory proceedings?
16 A.Yes.I have filed testimony with the public service commissions in all of the states
17 where the Company serves customers,includingthe Idaho Public Utilities Commission
18 ("Commission").
19 PURPOSE AND SUMMARY OF TESTIMONY
20 Q.What is the purpose of your testimony?
21 A.My testimony details the Company's proposal to invest $2 billion in new wind and
22 transmission facilities,all of which would be operational by December 31,2020,as
23 required to leverage the full benefit of the federal wind production tax credit ("PTC"),
Crane,Di -1
Rocky Mountain Power
l the value of which is essential to the combinedprojects'overall economic viability.The
2 Wind Projects and Transmission Projects,as defined and described below,are the
3 cornerstones of PacifiCorp's Energy Vision 2020 strategy.These projects represent an
4 exciting opportunity for PacifiCorp's customers,who we expect to realize
5 approximately $137 million in benefits over time,with initial rate impacts of less than
6 1.9 percent.
7 My testimony provides an overview of the Company's Application,which
8 includes a request for certificates of public convenience and necessity ("CPCNs")for
9 new wind and transmission facilities,and a request for binding ratemaking treatment
10 for the investment in the wind and transmission projects,in accordance with Idaho
11 Code §61-541.The Company proposes to construct or procure four new Wyoming
12 wind resources with a total capacity of 860 megawatts ("MW")(collectively,the "WindO13Projects")and to construct the Aeolus-to-Bridger/AnticlineLine and 230 kV Network
14 Upgrades,as defined and discussed in more detail later (collectively,the "Transmission
15 Projects").I explain why these resource decisions are prudent and in the public interest,
16 discuss the Company's financial ability to invest in the proposed facilities,and describe
17 how the Company has pursued them in good faith.
18 Q.Please summarize your testimony.
19 A.The Wind Projects and Transmission Projects (collectively,the "Combined Projects")
20 are central to the Company's current long-term energy strategy,Energy Vision 2020,
21 under which the Company plans to use the opportunities presented by the extension of
22 the federal PTC to make major resource investments that provide significant savings to
23 customers over the lives of the resources.The Company identified and presented this
Crane,Di -2
Rocky Mountain Power
1 opportunityin its 2017 IntegratedResource Plan ("2017 IRP").
2 The Transmission Projects and Wind Projects are mutually dependent on one
3 another.The Wind Projects rely on the Transmission Projects for interconnection into
4 the Company's transmission system.In turn,the Transmission Projects are supported
5 by the key economic attributes of the Wind Projects:zero-fuel-cost generation that
6 lowers net power costs and providesten years of PTCs.The Wind Projects also generate
7 renewable energy certificates ("RECs"),which can be sold in the market and lower net
8 customer costs.The Wind Projects help decarbonize the Company's resource portfolio,
9 mitigating long-term risk associated with potential future state and federal policies
10 targeting carbon dioxide ("CO2")emissions reductions from the electric sector.
l 1 The Transmission Projects also provide significant benefits to customers.The
12 Aeolus-to-Bridger/AnticlineLine is a sub-segment of the Company's Energy Gateway
13 West transmission project,and is an integral component of the long-term transmission
14 plan for the region.The Company,with stakeholder involvement,has pursued
15 permitting of the Energy Gateway West transmission project since 2008.The
16 Transmission Projects relieve congestion on the current transmission system in eastern
17 Wyoming,provide critical voltage support to the Wyoming transmission network,
18 improve overall reliability of the transmission system,enhance the Company's ability
19 to comply with mandated reliability and performance standards,reduce line losses,and
20 create the potential for further increases to the transfer capability across the Aeolus-to-
21 Bridger/Anticline Line with the construction of additional segments of the Energy
22 Gateway project.
23 Timing is critical for both of these projects.The Combined Projects must
Crane,Di -3
Rocky Mountain Power
1 achieve commercial operation by the end of 2020 to qualify for the full benefits of the
2 PTCs and maintain favorable economics.Thus,the Company must move quickly,
3 particularlyon the Transmission Projects,which will take several years to fully permit,
4 obtain the necessary rights-of-way,and construct.To complete construction of the
5 Combined Projects by December 31,2020,the Company requests that the Commission
6 adopt the proposed schedule for review set forth in the Application.
7 Because of the time-sensitivity of the Combined Projects,the Company is
8 conducting its 2017R Request for Proposals ("2017R RFP")process simultaneously
9 with its request for CPCNs for the Wind Projects.Althoughunusual,this approach is
10 necessary in this case.If the Company waited until the conclusion of the 2017R RFP
11 to seek CPCNs,the Combined Projects could not be completed by the end of 2020,and
12 customers would lose significant PTC benefits.To allow the Combined Projects toO13moveforward,the Company has pursued the Wind Projects,which will be benchmark
14 resources in the 2017R RFP and proxy resources for purposes of the Application until
15 the 2017R RFP is completed.
16 The Company also requests approval of binding ratemaking treatment for the
17 Combined Projects in accordance with Idaho Code §61-541.The proposed ratemaking
18 treatment,known as the Resource Tracking Mechanism ("RTM"),is designed to
19 capture customer benefits and match those benefits with the costs of the Combined
20 Projects.The RTM would operate until the costs and benefits of the Combined Projects
21 are fully included in base rates through a general rate case.The RTM would be included
22 as a component of the ECAM.Once the full costs and benefits are included in base
23 rates,only the incremental fluctuations associated with production levels of energy and
Crane,Di -4
Rocky Mountain Power
1 PTCs would continue to be tracked in the ECAM,as they are today,since these are
2 entirely dependent on the variable output of the Wind Projects.The Company would
3 begin deferring the costs and benefits associated with each new facility in the month it
4 goes into service.
5 Using medium price and CO2 RSSumptions,the Company's economic analysis
6 demonstrates a present-value reduction in revenue requirement due to the Combined
7 Projects of $137 million over the life of the projects,with a year-one rate impact of less
8 than 1.9 percent.
9 Q.What other witnesses will be testifying on behalf of the Company?
10 A.In addition to my testimony,the Company's Application is supported by the testimony
11 of the followingwitnesses:
12 Mr.Chad A.Teply,Vice President of Strategy and Development,provides aO13detaileddescriptionoftheCompany's proposed acquisition of the Wind Projects.
14 Mr.Teply describes the Wind Projects,addresses the impact and timing of PTCs on
15 their acquisition,and provides information to respond to the requirements of Rule 112
16 of the Commission Rules of Procedure ("RP").
17 Mr.Rick A.Vail,Vice President of Transmission,outlines the need for the
18 Transmission Projects,and provides a detaileddescription of the transmission facilities.
19 Mr.Vail also addresses the requirements of RP 112.
20 Mr.Rick T.Link,Vice President of Resource and Commercial Strategy,
21 testifies regarding the economic analysis that supports the prudence of the Combined
22 Projects,and describes the customer benefits resulting from the timely acquisition and
23 construction of the wind and transmission facilities.Mr.Link explains the planning and
Crane,Di -5
Rocky Mountain Power
l analysis of the Combined Projects in the Company's 2017 IRP.He also provides
2 background on the pending 2017R RFP for the wind resources.
3 Mr.Jeffrey K.Larsen,Vice President of Regulation,explains the Company's
4 proposal for ratemaking treatment of the costs and benefits of the Combined Projects,
5 and the inter-jurisdictional allocation of costs.
6 Q.Has the Company developed a schedule that allows the Commission to process
7 this case in an orderly and expeditious manner?
8 A.Yes.The Company's proposed schedule is included in the Application.
9 Q.Is the Companyrequesting approvalof the Combined Projects in any other states?
10 A.Yes.Concurrent with this Application,the Company is requesting approval of the
11 Combined Projects from the Wyoming Public Service Commission and the Public
12 Service Commission of Utah.There are rate-recovery mechanisms in Oregon andO13Washingtonforinvestmentsinrenewableresourcesthatprovideapathtoseekrecovery
14 of the costs and benefits of the Combined Projects closer in time to project completion.
15 In California,the Company is required to file a general rate case in 2019,which may
16 include the costs and benefits of the Combined Projects;alternatively,California's
17 Post-Test Year Adjustment Mechanism may be used to recover costs incurred after the
18 2019 general rate case.
19 OVERVIEW OF COMBINED PROJECTS
20 Q.Please describe the Transmission Projects.
21 A.The Transmission Projects include six major elements:
22 (1)The 140-mile,Aeolus-to-Anticline 500 kV line,which includes construction of
23 the new Aeolus and Anticline substations;
Crane,Di -6
Rocky Mountain Power
1 (2)The five-mile Anticline to Jim Bridger 345 kV line,which includes
2 modifications at the existing Jim Bridger substation to allow termination of the
3 new 345 kV line;
4 (3)Installation of a voltage control device at the Latham substation;
5 (4)A new 16-mile 230 kV transmission line parallel to an existing 230 kV line from
6 Shirley Basin substation to the proposed Aeolus substation,including
7 modifications to the existing Shirley Basin substation;
8 (5)The reconstruction of four miles of an existing 230 kV transmission line
9 between the proposed Aeolus substation and the Freezeout substation,including
10 modifications as required at the Freezeout substation;
11 (6)The reconstruction of 14 miles of an existing 230 kV transmission line between
12 the Freezeout substation and the Standpipe substation includingmodifications
13 as required at the Freezeout and Standpipe substations.
14 Throughout the Company's testimony,items 1-3 above are collectivelyreferred to the
15 Aeolus-to-Bridger/Anticline Line,and items 4-6 are collectivelyreferred to as the 230
16 k"Network Upgrades.
17 Q.Wh t are the system benefits of the Transmission Projects?
18 A.The bendits of the Transmission Projects fall into three broad categories.First,the
19 Transmission Projects will relieve congestion in eastern Wyoming,which will allow
20 greater resource interconnection in that part of the state.The Company's current
21 transmission system in eastern Wyoming is operating at capacity,which limits transfer
22 of existing resources from eastern Wyoming and precludes the ability to interconnect
23 additional resources east of the proposed Aeolus-to-Bridger/AnticlineLine.The
Crane,Di -7
Rocky Mountain Power
l Transmission Projects will increase the transfer capability from east to west by 750
2 MW.When the Transmission Projects are complete,they will allow interconnection of
3 up to 1,270 MW of incremental wind resources,includingthe Wind Projects that are
4 the subject of this Application.
5 Second,the Transmission Projects will provide critical voltage support to the
6 transmission system in southeastern Wyoming.Under certain operating conditions,
7 voltage control issues have limited the ability to add additional resources,particularly
8 wind resources.
9 Third,the Transmission Projects will also increase reliability,reduce capacity
10 and energy losses on the transmission system,and provide greater flexibilityto manage
11 existing generation resources.Currently,outages on the existing 230 kV system in
12 eastern Wyoming result in deration of the transfer capacity in the area and some outageO13scenariosrequiresignificantgenerationcurtailment.The new 500 kV transmission
14 segment will significantlyreduce,if not eliminate,many of the impacts caused by the
15 230 kV outages.
16 Q.Please describe the proposed Wind Projects.
17 A.The Company requests CPCNs for the construction or acquisition of 860 MW of new
18 wind resources,which are three 250 MW facilities (referred to as Ekola Flats,TB
19 Flats I,and TB Flats II)and a fourth 110 MW facility (McFadden Ridge II),all located
20 in Wyoming.Mr.Teply's testimony provides additional details on the Wind Projects.
21 Q.Will the Companysubmit the Wind Projects into the 2017R RFP?
22 A.Yes.Each of the resources will be included in the 2017R RFP as a benchmark resource.
23 Therefore,if other resources are ultimatelyselected,they will be equal to or better than
Crane,Di -8
Rocky Mountain Power
l the Wind Projects in the Application.The Company submits this Application to
2 facilitate review of this time-limited opportunityto secure CPCNs under the schedule
3 proposed by the Company.
4 Q.What additional information will be provided once the 2017R RFP shortlist is
5 selected?
6 A.After the 2017R RFP shortlist is selected,the Company will supplement this
7 Application to provide the Commission and intervening parties with detailed
8 information about the winning bid(s).
9 Q.What is the status of the 2017R RFP?
10 A.The Company filed for acknowledgment or approval of the proposed 2017R RFP in
11 Utah and Oregon as required in those states.Following those proceedings,the
12 Company anticipates issuing the 2017R RFP to the market in August 2017.TheO13Companyplanstocompleteitsfinalshortlistbidevaluationandfinalizetheshortlistin
14 early January 2018.Mr.Link's testimony provides additional details on the RFP
15 process.
16 Q.Why is the Company requesting CPCNs for both the Transmission Projects and
17 Wind Projects?
18 A.The Combined Projects are mutually dependent on one another.The Transmission
19 Projects are necessary to relieve existing congestion and will enable interconnection of
20 the proposed Wind Projects into the Company's transmission system.The Transmission
21 Projects are not economic without incremental,cost-effective Wind Projects generating
22 zero-fuel-cost energy and PTCs.This interdependence requires the Combined Projects'
23 concurrent development.
Crane,Di -9
Rocky Mountain Power
l The renewal of the PTCs has created a unique,time-limited opportunityfor the
2 Company to construct critical transmission facilities in eastern Wyoming,while
3 providing substantial customer savings.The economics for the Combined Projects,
4 however,require that they be constructed to meet commercial operation by the end of
5 2020.
6 Q.Why must the Combined Projects be in commercial operation by the end of 2020?
7 A.The substantial customer benefits resulting from the Combined Projects assumes the
8 Wind Projects will qualify for 100 percent of the PTCs.Each of the Wind Projects are
9 eligible for 100 percent of the PTC benefits if the Wind Projects and the Transmission
10 Projects are commercially operationalby December 31,2020.Failing to meet the 2020
11 deadline puts the Company at risk to lose PTC benefits,and jeopardizes the overall
12 economics of the Combined Projects.O 13 Q.How will the Company achieve commercial operation by the end of 2020?
14 A.The Company must obtain CPCNs for the Combined Projects under the timelines
15 proposed,so that equipment and engineering,procurement,and construction contracts
16 can be executed shortly thereafter.Because the lead time for constructing the
17 Transmission Projects is longer than the lead time to construct the Wind Projects,the
18 schedules for the Transmission Projects dictate this timeline.The testimonies of
19 Mr.Teply and Mr.Vail provide additional detail on the construction timelines necessary
20 to complete the Combined Projects by the end of 2020.
O
Crane,Di -10
Rocky Mountain Power
l PUBLIC INTEREST
2 Q.In its 2017 IRP,did the Company select the Combined Projects as part of the
3 preferred resource portfolio?
4 A.Yes.Both resources are least-cost,least-risk resources,as reflected in the Company's
5 2017 IRP,filed with the Commission April 4,2017.The 2017 IRP includes the Wind
6 Projects and Transmission Projects as integral components of the Company's preferred
7 portfolio.
8 Q.Do the Combined Projects providesignificant benefits to customers?
9 A.Yes.As outlined in Mr.Link's testimony,the Combined Projects will produce customer
10 benefits that significantlyoutweigh costs.The Company's economic analysis included
11 multipleelectricity price and carbon-risk scenarios,measured over several different
12 time periods.In virtually all cases,the Combined Projects result in significant netO13customerbenefits.For example,with medium natural gas and medium CO2 price
14 assumptions over the life of the facilities,the present-valuereduction to the change in
15 revenue requirement due to the Combined Projects is $137 million.Because the
16 Company did not quantify the added benefits associated with RECs,the economic
17 analysis is conservative.
18 Q.What is the projected rate impact to customers of the Combined Projects?
19 A.The rate impact to customers is less than 1.9 percent with the first full year of operation
20 in 2021.While this percentage change reflects the year-one impact to customers,it does
21 not fully reflect the value of the Combined Projects due to costs avoided over time.
22 Mr.Link's analysis showing the present-value savings of $137 million through 2050
23 referenced above demonstrates that although there is an initial increase in cost,the
Crane,Di -11
Rocky Mountain Power
1 lifetime savings of the Combined Projects are significant.
2 Q.After the Companyfiled its IRP in April,did Companyrepresentatives meet with
3 Idaho stakeholders to provide an overview of the Combined Projects?
4 A.Yes.On May 9,2017,the Company held an informal workshop with Idaho stakeholders
5 to review the details of the Combined Projects,explain the RFP for the wind resources,
6 and discuss the scope and timing of this Application.
7 Q.In addition to the customer benefits you have already mentioned,do the
8 Combined Projects benefit the public interest in other ways?
9 A.Yes.The Transmission Projects will relieve transmission constraints that have limited
10 energy resource interconnection in eastern Wyoming.Once constructed,the
11 Transmission Projects will allow the Companyto more efficientlydeliver cost-effective
12 energy from Wyoming generationresources.
13 REQUIREMENTSFOR A CPCN AND
14 BINDING RATEMAKING TREATMENT
15 Q.What are the requirementsfor the Commission to issue a CPCN?
16 A.It is my understanding that the Commission will issue a CPCN if it is in the public
17 interest.To determine the public interest,the Commission must determine whether the
18 present or future public convenience and necessity require additional resources and
19 whether the proposal is a reasonable means of meeting this need.
20 Q.Does the present or future public convenience and necessity require additional
21 resources?
22 A.Yes.As described above and in more detail in Mr.Link's testimony,the Company's
23 2017 IRP preferred portfolio includes the Combined Projects as least-cost,least-risk
24 resources to serve long-term customer needs and provide substantial customer benefits.
Crane,Di -12
Rocky Mountain Power
l The time-sensitive opportunitypresented by the PTCs allows the Company to provide
2 cost-effective,emission-free generation to serve Idaho customers,while providing the
3 cost savings necessary to construct the required Transmission Projects and provide
4 economic benefits for customers.
5 Q.Are the Combined Projects a reasonable means of meeting the resource need
6 identified in the 2017 IRP?
7 A.Yes.The Wind Projects that will ultimately be constructed or acquired will be the
8 winning bids resulting from the 2017R RFP.The Company intends to supplement the
9 record in this case with the winning bids once they are identified.Importantly,if the
10 RFP results differ from the Wind Projects included here,the selected resources will
11 have been determined to be economically superior.In either case,the Wind Projects
12 represent the most cost-effective resources,based on what is known today.O 13 The Transmission Projects are an integral part of the Company's plans to
14 acquire additional resources,relieve existing congestion,and allow additional
15 renewable resources to interconnect into the Company's transmission system.
16 Q.What are the requirementsfor approvalof a binding ratemakingtreatment under
17 Idaho Code §61-541?
18 A.It is my understanding that Idaho Code §61-541 allows a utility that is proposing to
19 construct or purchase a generation or transmission facility to request that the
20 Commission determine in advance the ratemaking treatment that will apply to the
21 proposed facility.When reviewing an application for binding ratemaking treatment,
22 I understand that the Commission must maintain a "fair,justand reasonable balance of
23 interests between the requesting utility and the utility's ratepayers,"considering
Crane,Di-13
Rocky Mountain Power
1 specific factors.
2 Q.Does the Company's request for binding ratemaking treatment of the Combined
3 Projects fairly,justly,and reasonably balance the interests between the Company
4 and its customers?
5 A.Yes.The Company's request also satisfies each of the requirements set forth in Idaho
6 Code §61-541(4).As described in more detail in Mr.Link's testimony,the Company
7 has a Commission-accepted IRP and its 2017 IRP is currentlypending.The 2017 IRP
8 demonstrates that the proposed Wind Projects,together with the Transmission Projects,
9 are the least-cost,least-risk approach when compared to other sources for long-term
10 electric supply,including energy efficiency,demand-side management,and other
11 feasible supply alternatives.
12 In addition,as described above and in Mr.Link's testimony,the Projects willO13servethepublicinterestandprovidesubstantialbenefitstoIdahocustomers.
14 The Company also participates in regional transmission planning processes.
15 The Company is a member of the Northern Tier Transmission Group ("NTTG"),which
16 is a regional transmission planning group consisting of seven electric utility members
17 and covering a region that includes portions of seven western states.NTTG develops a
18 regional transmission plan that addresses new proposed projects and the reliabilityof
19 the regional transmission system,as required by the Federal Energy Regulatory
20 Commission's Orders Nos.890 and 1000.
21 Q.Does the Companyhave the ability to finance the Combined Projects?
22 A.Yes.The Company intends to finance the proposed Wind Projects and Transmission
23 Projects through its normal sources of capital,both internal and external,includingnet
Crane,Di -14
Rocky Mountain Power
1 cash flow from operating activities,public and private debt offerings,the issuance of
2 commercial paper,the use of unsecured revolvingcredit facilities,capital contributions
3 and other sources.Although the proposed Combined Projects are a significant
4 investment on the part of the Company,the financial impact will not impair the
5 Company's ability to continue to provide safe and reliable electricity service at
6 reasonable rates.
7 Q.How will approval support the Company's current credit rating,thereby
8 providingcustomer benefits?
9 A.Ratings agencies consider the Company's regulatory treatment when establishing its
10 credit rating,and particularlyfocus on the treatment of capital investments.Supportive
11 treatment through approval of an investment of this magnitude provides assurance to
12 ratings agencies and helps maintain the Company's credit rating.A solid credit ratingO13directlybenefitscustomersbyensuringaccesstocapitalmarketsandreducing
14 immediate and future borrowing costs related to the financing needed to support
15 regulatory operations,and strong ratings will often allow the Company to avoid having
16 to meet costly collateral requirements that are typically imposed on lower-rated
17 companies when securing power in the market.If the Company does not have
18 consistent access to the capital markets at reasonable costs,its debt issuances and the
19 resulting costs of constructing the new facilities become more expensive than they
20 otherwise would be.
21 Q.Why should the Commission approve the Company's request for binding
22 ratemakingtreatment?
23 A.In this case,approval of binding ratemaking treatment is warranted because of the
Crane,Di -15
Rocky Mountain Power
1 magnitude of the proposed investment and the significant customer benefits resulting
2 from the Combined Projects.Providing binding ratemaking treatment here comports
3 with the purpose of Idaho Code §61-541 to facilitate the acquisition and construction
4 of major generationor transmission facilities while balancing the interests of the utility
5 and customers.
6 PROPOSED RATEMAKING TREATMENT
7 Q.Please describe the Company'sproposed ratemaking treatment for the Combined
8 Projects.
9 A.The Company proposes a Resource Tracking Mechanism ("RTM")to address the
10 proper ratemaking treatment to match the costs and benefits of the Combined Projects
11 until the costs and benefits are fully reflected in base rates.This primarily includes new
12 capital and operating costs,net power costs savings,and PTC benefits.This mechanismO13willalignthecostsandbenefitssothatcustomersreceivethebenefitsfromthe
14 Combined Projects while shareholders receive appropriatecost recovery of the prudent
15 investments.The RTM would be included as a component of the ECAM.Mr.Larsen's
16 testimony provides additional detail on the proposal and further demonstrates how it is
17 consistent with the public interest.
18 Q.Is the RTM a proposal for nontraditional ratemaking as allowed under the
19 bindingratemakingauthority?
20 A.Yes.The binding ratemaking authority states that the "requested ratemaking treatments
21 may include nontraditional ratemaking treatments or nontraditional cost recovery
22 mechanisms."Mr.Larsen's testimony provides additional detail on the proposal and
23 further demonstrates how it is consistent with the public interest.
Crane,Di -16
Rocky Mountain Power
1 CONCLUSION
2 Q.What is your recommendation to the Commission?
3 A.The Company recommends that the Commission grant CPCNs for the Combined
4 Projects on the timeline requested by the Company.The Combined Projects will
5 provide substantial customer benefits and advance the public interest in Idaho.The
6 Company also requests that the Commission approve the Company's request for
7 binding ratemaking treatment for the investment in the Combined Projects.
8 Q.Does this conclude your direct testimony?
9 A.Yes.
O
O
Crane,Di -17
Rocky Mountain Power