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HomeMy WebLinkAbout20101014Peseau Di.pdfBEFORE THE IDAHO PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ) ROCKY MOUNTAIN POWER FOR ) APPROVAL OF CHANGES TO ITS ) ELECTRIC SERVICE SCHEDULES AND A ) PRICE INCREASE OF $27.7 MILLION, OR ) APPROXIMATELY 13.7 PERCENT ) ) ) DOCKET NO. ID PAC-E-10-07 DIRECT TESTIMONY OF DENNIS E. PESEAU ON BEHALF OF MONSANTO COMPANY October 14, 2010 ~-,~;.-i; ~--..~ 1 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 2 A. My name is Dennis E. Peseau. My business address is Suite 250, 1500 3 Liberty Street, S.E., Salem, Oregon 97302. 4 Q. BY WHOM AND IN WHAT CAPACITY ARE YOU EMPLOYED? 5 A. I am President of Utility Resources, Inc. The firm has consulted on a number 6 of economic, financial and engineering matters for various private and public 7 entities since 1985. 8 Q. ON WHOSE BEHALF ARE YOU TESTIFYING IN THESE PROCEEDINGS? 9 A. I am testifying on behalf of Monsanto Company. 10 Q. DOES ATTACHMENT DEp.A ACCURATELY DESCRIBE YOUR 11 BACKGROUND AND EXPERIENCE? 12 A. Yes. 13 Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 14 A. The purpose of my testimony is to recommend that the Commission defer its 15 decision on PacifiCorp's requested rate base addition of $801.5 milion for 16 the Segment B portion of the Gateway Central, approximately $45 milion of 17 which is allocated to Idaho, until PacifiCorp's next general rate case. As I PESEAU DI - Page 1 1 explain below, this Gateway Central transmission project is but an initial leg 2 of a very speculative and massive undertaking, Energy Gateway that mayor 3 may not be built by the end of the next decade. As a result of the over sizing 4 to accommodate a planned larger "Gateway South" 500 kV line, that may be 5 completed in 2020, the requested rate base of Segment B from Populus 6 (near Downey, ID) to Terminal (NW Utah) is far greater than that necessary 7 to upgrade this path on a stand-alone basis. 8 Q. WHAT IS THE GENERAL BASIS FOR YOUR RECOMMENDATIONS? 9 A. As explained very clearly by PacifiCorp in its direct testimony and exhibits, 10 and also its 2008 IRP and in multiple company documents, Gateway Central 11 is but a 135 mile line that is the initial segment of perhaps the most ambitious 12 and expensive planned transmission network expansion ever attempted in 13 the United States. PacifiCorp estimates that the entire 2,000 mile network, if 14 completed as Energy Gateway, will have project costs exceeding $6 billon. 15 Most of the actual legal, environmental, permitting, rights of way, etc. has 16 only just begun on the remaining 1,865 miles of proposed facilities. 17 For perspective, if the entire $6 billon Energy Gateway project is ever 18 completed, Idaho's allocation would be approximately 6%, or $360 million of 19 rate base addition. The Energy Gateway transmission project alone will have 20 increased the total Idaho rate base (generation, transmission and distribution PESEAU DI - Page 2 1 plant) by over 60% compared with the year end 2009 rate base. The 2 magnitude of this project's impact on Idaho customers' rates warrants careful 3 and cautious scrutiny by this Commission. My proposal to defer the 4 proposed rate base treatment of Gateway Central is the best means to 5 protect both customers and shareholders of PacifiCorp. As i argue below, 6 most of the Gateway Central rate base will not be used and useful at the 7 outset due to its over sizing. I believe that shareholders as well as 8 customers would be best served by holding open the issue of rate base 9 treatment of Gateway Central until the larger issues of the entire Energy 10 Gateway project are better known. 11 Q. WHAT ARE YOUR SPECIFIC RECOMMENDATIONS IN THIS CASE WITH 12 RESPECT TO THE COMMISSION'S TREATMENT OF THE REQUESTED 13 APPROXIMATE $45 MILLION GATEWAY CENTRAL RATE BASE 14 ADDITION? 15 A. i recommend that the Commission: 16 17 18 1.Not make a determination regarding the degree of "used and usefulness," if any, of the proposed Gateway Central project in this case even if it does come online December 31, 2010. 19 20 2.Defer the consideration of Gateway Central as an Idaho rate base component until the next general rate case. 21 22 3.Remove $5.9 millon (reduced by power cost offset) from PacifiCorp's requested rate increase. PESEAU DI - Page 3 1. 2 3 4 5 6 7 8 9 10 11 12 13 14 4.Order PacifiCorp to place all Gateway Central plant into Plant Held for Future Use, with no carrying charge until such time as the degree of used and usefulness can be determined. 5.Require PacifiCorp to submit a specific progress report on the status of the proposed Gateway South project as the proposed Gateway Central project makes sense only when Gateway South is completed. 6.Require PacifiCorp to hold an open season or nomination process for capacity on Gateway Central as a means to gauge the degree of excess rate base that Idaho's network customers will be required to pay for until OATT customers develop. 7.Require PacifiCorp to revisit its 2008 IRP justification of system load forecast and the proposed Energy Gateway project in light of the prolonged recession and economic uncertainty. 15 OVERVIEW OF GATEWAY CENTRAL AND ENERGY GATEWAY 16 Q. PLEASE DESCRIBE THE PROPOSED GATEWAY CENTRAL PROJECT. 17 A. PacifiCorp's filing in this case, particularly the testimonies of Messrs. 18 Gerrard, Cupparo and McDougal, provides detailed descriptions of the 19 proposed Gateway Central, or "Populus to Terminal" transmission line. I 20 summarize those aspects of the proposed line that bear on the 21 recommendation i make in this case. As a considerable portion of Gateway 22 Central's description has been labeled "CONFIDENTIAL," I wil only generally 23 summarize these elements in relation to the much larger plan to construct 24 Energy Gateway. PESEAU DI - Page 4 Q. WHAT IS ENERGY GATEWAY? 2 A. Energy Gateway is PacifiCorp's program to invest over $6 bilion for 3 approximately 2,000 miles of high voltage transmission lines, primarily 500 4 kV, throughout the western United States. If completed as planned, the 5 project would have a total capacity of 6,000 MW with the intention of 6 transmitting electricity generated primarily from wind energy planned in 7 Wyoming and elsewhere, to markets in California, southern Nevada and to a 8 lesser extent Utah and the Pacific Northwest. My Exhibit 221 (DEP-1), taken 9 from PacifiCorp's website on Energy Gateway Transmission Project's 10 "Frequently Asked Questions," Page 5, provides a schematic of the proposed 11 project. 12 The proposed "Gateway West" segment of Energy Gateway, with an 13 estimated in-service date in the 2014-2018 timeframe,1 would connect areas 14 of Wyoming that have potential for wind-generated power, to the Captain 15 Jack substation near Malin, Oregon. My Exhibit 222 (DEP-2) is a copy of 16 PacifiCorp's website description of Gateway West, with key milestones. The 17 Captain Jack substation is the hub or connection between the California- 18 Oregon transmission intertie and provides access to several 500 kV lines 19 running south throughout California. 1 Recent deferral of draft EIS may push timeframe back. See Bureau of Land Management announcement at http://ww.blm.gov/wy/sUen/info/news_room/2010/july/22gatewaywest.html PESEAU DI - Page 5 1 The proposed "Gateway South" segment of Energy Gateway, with an 2 in-service date in the 2017 -2019 timeframe,2 would connect potential 3 Wyoming wind generators to the Crystal substation in Nevada Powets 4 service territory. My Exhibit 223(DEP-3) is a copy of PacifiCorp's website 5 description of Gateway South, with key milestones. The Crystal substation 6 connects a number of transmission lines and provides access to several 500 7 kV, 345 kV, and 230 kV lines running through Las Vegas Valley and west 8 into California. 9 Q. 10 11 12 A. 13 14 15 16 17 18 19 20 21 22 HOW DOES PACIFICORP DESCRIBE PLANNING ASPECTS OF THE PROPOSED ENERGY GATEWAY AND GATEWAY CENTRAL PROJECTS? PacifiCorp differentiates this over $6 billon project from more conventional resource planning approaches. The Company states: Unlike the conventional "generation before transmission" approach, this transmission project (Energy Gateway) is a relatively new approach, constructing transmission ahead of specific generation resources. With increasing development of location - constrained renewable resources, one project often can no longer form an anchor for transmission. (Page 1, "Frequently Asked Questions") Elsewhere, PacifiCorp characterizes the Energy Gateway project as more of an overall strategy rather than one single transmission project. PacifCorp is 2According to the Company's response to Monsanto Data Request 4.4, Energy Gateway is now anticipated to be completed in the 2018-2020 time frame. PESEAU DI - Page 6 1 proposing to construct Energy Gateway in anticipation of future development 2 of generation resources, and future markets for such resources. 3 Q. WHAT IS THE COMPANY'S OVERALL STRATEGY WITH THE 4 PROPOSED ENERGY GATEWAY? 5 A. If PacifiCorp succeeds in completing the entire Energy Gateway project by 6 2020, the Company will dominate transmission services throughout the 7 western U.S. This circumstance would place shareholders in the enviable 8 position of earning a return on over $6 billion in new rate base, as well as 9 providing the "highway" to California and southern Nevada for sales of 10 PacifiCorp's existing and developing wind projects. The reason i say 11 "enviable" is because, unlike unregulated third part developers of new 12 transmission facilities, PacifiCorp is attempting to earn on Energy Gateway 13 immediately by placing the large, initially over-built segments into rate base 14 as each is completed. Private third party developers are not, of course, able 15 to earn on the excess investment prior to the facilities reaching full capacity 16 and coming on line, when they then can charge OATT wheeling tariff rates. 17 Q. PLEASE EXPLAIN. 18 A. The proposed Gateway Central project for which PacifiCorp is requesting 19 rate base treatment in these proceedings is a good example of this enviable PESEAU DI - Page 7 1 position. The overwhelming amount of this $801.5 milion investment is for 2 interconnection with planned future Energy Gateway segments. Thus, in this 3 docket, Idaho customers, by virtue of PacifiCorp's request to place the Idaho 4 allocation of the entire $801.5 million into rate base, are being asked to fund 5 the carrying costs of this initially over built segment B until this path will 6 become functional with later segments, particularly Gateway South. 7 Q. WHEN IS GATEWAY SOUTH PREDICTED TO BE COMPLETED? 8 A. Gateway South is in the early planning, siting and permitting stages. Rights 9 of way and EIS are not expected to be completed until 2015. The Company 10 projects an in-service date in the 2017-2020 timeframe. As this particular 11 segment of Energy Gateway is the principal driver for the over-building of 12 Gateway Central, this late date and early stage of development causes major 13 concern for the equity and reasonableness to Idaho customers funding and 14 carrying the over built Gateway Central for so many years. Most of this 15 Gateway Central wil not be "used and useful" unless and until Gateway 16 South is energized. 17 Q. WHAT IS THE BASIS FOR YOUR CONCLUSION THAT THE INITIAL LEG 18 OF ENERGY GATEWAY, WHICH IS GATEWAY CENTRAL, IS OVER 19 BUILT? PESEAU DI - Page 8 1 A. I base my conclusion on a number of factors. First, as a part of the approval 2 of MEHC's acquisition of PacifiCorp in 2005, both Companies agreed to 3 upgrade this same Path C by the 300 MW required to enhance reliability, 4 facilitate the receipt of renewable resources and to enable further 5 optimization on this segment of Path C. The Path C upgrade was an 6 important commitment to get from MEHCIPacifiCorp because this segment 7 had been previously identified as a potential congested transmission path. 8 Prior to the conception of Energy Gateway, the 300 MW Path C upgrade 9 committed to by MEHCIPacifiCorp was seen as sufficient for this path. 10 Q. WHAT WAS PACIFICORP'S ESTIMATE OF THE COSTS OF THE 11 REQUIRED UPGRADE TO THE PATH C SEGMENT BETWEEN 12 SOUTHWEST IDAHO AND NORTHERN UTAH? 13 A. The Company indicated that this upgrade would cost approximately $78 14 millon, or less than 1/10 of the $801.5 million requested in these 15 proceedings for the Path C upgrade. Clearly this ambitious request is for the 16 benefit of interconnecting to the planned Gateway South. This is explained 17 on Page 6 of Order No. 29973 approving the acquisition, attached as my 18 Exhibit 224 (DEP-4). PESEAU DI - Page 9 1 Q. 2 3 4 A. 5 6 7 8 9 10 11 12 13 14 IS THE ANTICIPATED CAPACITY RATING FOR THE POPULUS TO TERMINAL SEGMENT B OF PATH C DIFFERENT BEFORE AND AFTER THE PLANNED GATEWAY SOUTH? Yes. PacifiCorp's response to Monsanto Data Request 4.4 indicates: Monsanto Data Request 4.4 Reference Testimony of Mr. John Cupparo. What is the expected megawatt line rating or capacity of the 345 kV Populus to Terminal facility before and after completion of the Gateway West and Gateway South segments? Response to Monsanto Data Request 4.4 The incremental capacity is expected to be 700 MW in the southbound direction and 350 MW in the northbound direction prior to completion of Gateway South in 2018-2020. Once Gateway South is completed the capacity in both directions is expected to increase to 1400 MW. 15 Q. DOES THE FACT THAT THIS SEGMENT WILL HAVE ITS CAPACITY 16 INCREASED BY 1,050 MW (1400-350) WITHOUT MATERIAL 17 ADDITIONAL INVESTMENT DEMONSTRATE THAT IT IS OVER-BUILT 18 TODAY IN ANTICIPATION OF THE 2018-2020 PLANNED GATEWAY 19 SOUTH? 20 A. Yes. Let me state that my characterization of Segment B as "over-built" here 21 is not to suggest that this line may not someday become fully used and 22 usefuL. It is not unusual for a utilty to "over-build" facilities at the outset in 23 order to accommodate a near-term expansion of other facilities. What is 24 unusual with PacifiCorp's request is to include a rate base addition, and PESEAU DI - Page 10 1 charge Idaho ratepayers initially, at a level that is approximately ten times its 2 previously approved commit level ($79 milion compared to $801.5 millon) 3 ten years in advance of the transmission line being fully used and usefuL. 4 And, if the planned Gateway South segment faces the hurdles typical of 5 siting and constructing 500 kV transmission lines in the western U.S., there is 6 a real possibility that Gateway South may be delayed or disapproved by 7 virtue of other competing high voltage transmission line servicing similar 8 markets. 9 Q. ARE YOU SUGGESTING THAT THE $801.5 MILLION INVESTMENT IN 10 SEGMENT B IS IMPRUDENT? 11 A. No. I cannot conclude on the prudence or not of the level of investment 12 absent a more thorough understanding of the segment in relation to the 13 uncertainty and risk associated with Gateway South. My recommendation to 14 defer any rate base treatment of the $801.5 milion investment is to better 15 understand these issues, and avoid any decision at present as to how much 16 of the $801.5 milion investment is "used and useful" in the traditional 17 regulatory sense. 18 Q. IS YOUR RECOMMENDATION FAIR AND EQUITABLE TO IDAHO 19 CUSTOMERS AND PACIFICORP SHAREHOLDERS? PESEAU DI - Page 11 1 A. Yes, I believe it is the most equitable position to take in these proceedings. 2 Ratepayers are being requested to carry a huge investment made for a 3 future planned project that would ordinarily be borne by shareholders. And, 4 in my opinion, shareholders are better served by having the Commission 5 defer full approval rather than force it to determine what degree of present 6 "used and usefulness" Segment B serves in 2011. The latter decision could 7 be viewed negatively by financial markets and should be avoided in favor of 8 a more comprehensive, integrative review of the Segment B Gateway South 9 Gateway West projects. 10 Q. DID YOU CONDUCT ADDITIONAL ANALYSES TO DETERMINE 11 WHETHER THE POPULUS TO TERMINAL SEGMENT B IS BEING OVER 12 BUILT? 13 A. Yes. There are a number of other high voltage transmission projects in the 14 western U.S. in both the planning and construction phase. A simple 15 comparison of the investment per transmission mile serves as a rough check 16 of the investment per mile of Segment B if completed as a stand-alone 17 project. 18 Q. PLEASE EXPLAIN. PESEAU DI - Page 12 1 A. A simple and straightforward manner in which the Segment B investment 2 costs can be bench marked is to compare its investment per mile with the 3 remainder of the Energy Gateway planned projects. This is a conservative, 4 but not completely comparable basis for comparison because the 135 mile 5 Segment B line is 345 kV, while the majority of the remaining 1,865 miles of 6 the planned Energy Gateway project is the higher voltage, higher cost 500 7 kV transmission line. As such, the comparison is conservative. 8 My Exhibit 225 (DEP-5) shows the simple calculations comparing the 9 investment costs of Segment B with the remainder of Energy Gateway. The 10 assumptions shown include the total investment in the planned Energy 11 Gateway of (over) $6 billon for the 2,000 mile project. The 135 segment 12 from Populus to Terminal is $801.5 millon. 13 Q. WHAT ARE THE RELATIVE INVESTMENT COSTS PER MILE OF THE 14 GATEWAY CENTRAL PROJECT COMPARED WITH THE REMAINING 15 SEGMENTS OF ENERGY GATEWAY? 16 A. As shown on my exhibit, the requested investment for Gateway Central is 17 $5.94 million per mile. The remaining Energy Gateway project is estimated 18 to be $2.79 millon per mile. The fact that the proposed Gateway Central 19 project investment is well more than twice as expensive as the remaining, PESEAU DI - Page 13 1 higher voltage Energy Gateway transmission system is a further indication 2 that Gateway Central is being over-built to accommodate Gateway South. 3 If Gateway South was a certain project that was expected to come on- 4 line at a time similar to the expected December 2010 on-line date of Gateway 5 Central and there was true demand for that amount of transmission, this 6 investment mismatch would not be a problem. However, this is not the case. 7 Gateway South wil not even be permitted in the near future and wil not be 8 energized before 2020, if indeed it is constructed at alL. 9 Q. HAVE YOU PARTICIPATED RECENTLY IN THE SITING AND APPROVAL 10 OF OTHER SIMILAR AND COMPETITIVE HIGH VOLTAGE 11 TRANSMISSION PROJECTS IN THE U.S.? 12 A. Yes. I have for many years participated in some of the financial planning for 13 the Southwest Intertie Project, or "SWIP" as it has been called. This project, 14 originally proposed by Idaho Power Company, has been planned in various 15 stages since as early as 1992. Today, SWIP is a similar and competing 16 project with Gateway South and is owned jointly by NV Energy and Great 17 Basin Transmission, LLC. The project originates at Midpoint, Idaho and 18 terminates initially in Nevada Powets territory, similar to Gateway South 19 plans. The SWIP project is being constructed in two phases, the first being 20 called "ON Line" and wil originate in Sierra Pacific Powets service territory in PESEAU DI - Page 14 1 eastern Nevada (Robinson Summit substation) and run south for 235 miles 2 to major markets in the southern Nevada and California markets. ON Line is 3 a 500 kV transmission line approved and under construction. 4 Q. WHAT ARE THE INVESTMENT COSTS FOR ON LINE THAT HAVE BEEN 5 APPROVED BY THE PUBLIC UTILITIES COMMISSION OF NEVADA? 6 A. $509.6 million. The investment cost per mile for this 500 kV, 235 mile line is: 7 $509.6/235 = $2.17 milionlmile 8 The ON Line 500 kV line is below, but in line with $2.79 million/mile 9 investment in the remaining Energy Gateway project, but vastly below the 10 $5.94 millon/mile investment cost estimate for the proposed Gateway 11 Central segment. 12 Q. IS THE ON LINE TRANSMISSION PROJECT IN COMPETITION WITH THE 13 PROPOSED GATEWAY SOUTH PROJECT? 14 A. Yes. The ON Line project is being built to serve renewable energy projects in 15 northern Nevada, Idaho and Wyoming. The 2000 MW project is well ahead 16 of and in direct competition with Gateway South. 17 Q. DOES THE ON LINE PROJECT PRECLUDE GATEWAY SOUTH FROM 18 EVER BEING BUILT ECONOMICALLY? PESEAU DI - Page 15 1 A. No. But clearly the current clamor for renewable resources in southern 2 Nevada and in California is moderating and would have to grow significantly 3 in order to accommodate and justify a second major 500 kV project such as 4 Gateway South. 5 Q. BESIDES ON LINE, WHICH IS APPROVED AND UNDER 6 CONSTRUCTION, ARE THERE OTHER PLANNED HIGH VOLTAGE 7 TRANSMISSION PROJECTS DESIGNED TO SIMILARLY CONNECT AND 8 DELIVER POTENTIAL WIND GENERATION IN WYOMING TO THE 9 DESERT SOUTHWEST? 10 A. Yes, there are severaL. While I make no attempt here to rank the 11 probabilities of each being completed in relation to the proposed Gateway 12 South project, the mere existence of several proposed competing 13 transmission projects demonstrates the inherent uncertainty attached to any 14 single project's success. 15 Q. WHAT OTHER COMPETING PROJECTS ARE UNDER DEVELOPMENT? 16 A. My Exhibit 226 (DEP-6) provides a map of a number of competing 500kV 17 and above projects currently being proposed and developed. I have not 18 studied the progress of each, but have generally been aware of their 19 intentions in industry press. Most of these projects have been proposed prior PESEAU DI - Page 16 1 to Gateway South and as such are competitors to it. If one or more of these 2 competitor projects advances prior to Gateway South, there is a distinct 3 possibility that Gateway Central would become a largely stranded 4 investment. My testimony anticipates this, and requests that the Commission 5 guard today against the potential for Gateway Central to be carried by 6 ratepayers in the event that Gateway South never develops. This complex 7 issue is best considered in future proceedings where the risks and rewards of 8 this investment can be analyzed. 9 Q. ARE YOU CHALLENGING PACIFICORP'S PROPOSED RATE BASE 10 TREATMENT OF IDAHO'S SHARE OF THE $801.5 MILLION GATEWAY 11 CENTRAL INVESTMENT BECAUSE YOU BELIEVE THAT THIS 12 SEGMENT WILL SERVE NO PURPOSE FOR THE FORESEEABLE 13 FUTURE? 14 A. No, I am not. Even if Gateway South is never completed, the Populus to 15 Terminal segment wil relieve congestion on this transmission path. In 16 response to Monsanto Data Request 4.5, PacifiCorp listed a number of 17 potential benefits that would derive from an upgrade to this path. i attach the 18 one page response as my Exhibit 227 (DEP-7). I do not challenge this 19 response. I do challenge the proposed decade long inclusion of the $801.5 20 millon investment in rate base, and its associated large increase in revenue PESEAU DI - Page 17 1 requirements, so long in advance of it being used and useful for Gateway 2 South. 3 Q. DO YOU RECOMMEND THAT A SMALL PORTION OF THE PROPOSED 4 $801.5 MILLION BE PLACED IN IDAHO'S RATE BASE IN THIS CASE? 5 A. No. Again this issue is complex and needs a more thorough review. And, 6 from PacifiCorp's viewpoint, the Company may well wish to postpone 7 consideration until the entire investment could logically be determined to be 8 used and usefuL. 9 Q. HAS THIS COMMISSION SPECIFICALLY CONSIDERED PACIFICORP 10 RATE BASE ADDITIONS PREVIOUSLY THAT WERE REQUESTED 11 EITHER OUT -OF-PERIOD OR MUCH LONGER THAN CURRENTLY 12 NECESSARY? 13 A. I do not believe so. It is my understanding that the Commission has not 14 issued an order pertaining to PacifiCorp in a fully contested rate case since 15 sometime in the 1980s. 16 Q. PLEASE SUMMARIZE 17 RECOMMENDATIONS. YOUR CONCLUSIONS AND PESEAU DI - Page 18 1 A. I conclude that the Commission should defer consideration of Pacificorp's 2 proposed Gateway Central rate base addition to the next general rate case, 3 for the reasons developed in my testimony. 4 Q. 5 6 7 A. 8 9 10 11 12 13 14 15 16 17 18 19 20 DO YOU HAVE CONCLUDING REMARKS REGARDING THE COURSE OF IDAHO WITH REGARD TO MULTI-8TATE ALLOCATORS FOR THIS COMMISSION? Yes I do. I have participated in numerous studies and proceedings in Idaho since the early 1980s. My preparation for the testimony I sponsor here has raised major concerns in regard to my assessment of how the new era of renewable resource development and major speculative transmission investments in the western United States wil affect this state, and especially the Idaho service territory served by PacifiCorp. We all know that Idaho is less than 6% of PacifiCorp's total customer base. We further know that certain of PacifiCorp's larger state jurisdictions are "driving" the surge for more expensive and potentially excess resources through ambitious resource portolio standards ("RPS"). The fact that PacifiCorp is driven to serve these requirements, and potentially to profit greatly from them, wil not in my opinion, bode well for the State of Idaho. I say this because of the multi-state protocols and resulting costly allocations that are headed Idaho's way as a result these multi-billion dollar investments that would likely not PESEAU DI - Page 19 1 arise in the absence of such requirements. The largest drivers of the need 2 for these investments are those large states that either are not rich in 3 generation resources, or simply wil not allow such development in their own 4 back yard. Idaho, on the other hand, can independently pursue its rich 5 renewable and other generation resource potential largely without the aid of 6 the massive type projects such as Energy Gateway and wind generation. 7 Idaho ratepayers I fear may be in for indefinite rate increases that could be 8 avoided if the state would opt out of the multi-state policies. These rate 9 increases are certainly disastrous not only for Monsanto, but for the general 10 livelihood of eastern Idaho. I urge the Commission to consider whether it 11 wishes to adopt a more parochial view of the western U.S. energy future and 12 focus on what is best for Idaho. 13 Q. WOULDN'T IDAHO'S OPTING OUT OF MANY OF PACIFICORP'S 14 EXPANSION PROGRAMS HURT THE COMPANY? 15 A. No, not at alL. Idaho is such a small percentage of PacifiCorp that neither the 16 Company nor other states would necessarily be affected. 17 Q. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? 18 A. Yes. PESEAU DI - Page 20 1985 - Present 1978 - 1985 1974 - 1978 1972 - 1974 Education Attachment DEP-A QUALIFICATIONS OF DENNIS E. PESEAU President of Utility Resources, Inc., a firm that provides consulting and technical services on economic and financial matters. Dr. Peseau has conducted numerous studies on economic, energy and competitive and regulated markets, including complex litigation. His regulatory experience includes studies and testifying on a number of regulatory revenue requirement, cost of service, rate of return and rate design issues in more than 100 civil and administrative proceedings. Vice President, Zinder Companies, Inc. Dennis headed the west coast office of the national consulting organization headquartered in Washington, D.C. His primary responsibilities included marginal and incremental cost of service studies, rate of return and rate design for a number of public utilities companies. Senior Economist, Oregon Public Utility Commissioner. Dr. Peseau conducted numerous studies on behalf of the Commissionets staff on various financial capital structure, rate of return, econometric and forecasting issues. Senior Economic Analyst, Southern California Edison Company. Dennis worked in Southern California Edison's economics department on matters of economic growth and energy pricing, cost of service and econometric and statistical analysis. PhD, M.A., Claremont Graduate School B.A., California State University, Chico Dr. Peseau has conducted studies on regulatory revenue requirements, cost of service, rate of return, system planning and resource plans and general financial feasibility analyses in the states of Alaska California Colorado Idaho Maryland Minnesota Montana Nevada New York Oregon Virginia Washington Washington, DC Wyoming He has participated in energy matters before the Federal Energy Regulatory Commission, the federal Bonneville Power Administration, and in Alberta, Canada and Pemex in Mexico City. 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Unks to Enev Gaay and lol transiss projct set infoon can be fond be. We up th PMes relarl as new Inforatin becoes availabl. Energy Gateway Seme Seg A ~ Walla Walla Gateway Central sement B - Populus to Terminal 5etC- semeC- Gateway West Segen 0 ~ SeE - Gateway South5eF - seg G - Mona to Crystal to Populus Monsanto Company Exhibit 221 (DEP-1) Page 1 of 2 Case No. PAC-E-10-07 Witness: Dennis E. Peseau 5eenG.SeH. to Red 8utte to Captain Jack htt://w.pificOeghtt tOlI2W En Gay MONTANA Nt"''' 0./ ~li tl(~t $lftl lfl f'_lll &.l'-SC"Y~""-J."y-i~ 'C.. lJOi.Y"lftftl""tnok.. o Tmil1Î M. £&iMl- OIOIlADO ART NEWI'HXICO Tlts IN Is lo ltt.!1 ,(ilfCQtt Ot"l and ttflu tht txpasi nttSU'"I co COftvtt EI! G11_, to Itt taU ('padl1 of 60 MW. Il ml111 rtt tbl filùl lOlt Of (o"ltnKtio uqc~. 02010 Padeo, 1I sury of MidAmetiè3n htt/w.pficoog.htl Pae2of2 (Upd FerWI 19,2010) Company Monsanto Company Exhibit 221 (DEP-1) Page 2 of 2 Case No. PAC-E-10-07 Witness: Dennis E. Peseau tONIQ Ga Wes Pa 1 of2 ~~IC Gateway West Ene us Is on th ri and de Is fa apin th lflt of th exls elel sy.. Tl gro co fr bo ne an exiting custrs. Indivual, come toay are usng 26 peent mo elit tl thy dl 20 ye ago. To mee thi in dend, new fac ar ne. As part of Pa's Energy Gateway Trasm Einsi Proec, Idah Po an Rocky Mon Po ar plnin t-o bu . ne hI-v trasm line ac sothrn Wyin and sorn Id. Th pr called Gateway West , wl metd. apXIte 1,100 ml an supp prnt an Mu ne of cu. Th pro also wienhce eli1 sy rellabl In th ser ares of bo copani. In ad1t, Gaay wes wl en el gene fr ex and ne ren:, lnng wind, to be deivere to curs thou th re. Th pro ro fo Gateay Wes Windstar to Populus sement exts fr ea Wy to a hub ne OBy, Idah, wh It wil conne wi a seen that will cònln thgh to wester Idah. The pr ro for th Populus to Hemingway se runs fro II plned transmiio hub near Downe, Idah, ac the state to a po sott ofBo, Idao.Proj Tl. Pu SC - lun 200 . EnvtntlImp Stant pr - 200 . 2012. Pu ou - Jun 200 - prt æm . Peit and obnlng rits of way - 2011 - 2014 . Esimted lin In se fo cuto - 2014 . 2018 AcIIn Ab th Pro Undr the Na Enme Po Act, th Bureu of la Maement Is currtl ti an EAYta Impt Statemet on Gaay wet - a prs tha ben In June 200 wi opn hose Puic SCopng metis. Bl has ovht of this proes and hOed th meets to colled ofl public co. For mo inrmaio, plse viit BU,"'s Web site. Gateway Wes ma can be vi be: .map . . Land Further Infoti alo can be fond on our Gateway West newsletter (PDf) or at our Gateway West Web sIte Pubc Parciti Publ Input Is an Impant pa of the tralo Itne develpme prs and Is welco li l! stag. In adti to pub, grp and inivdual meins, pr materils and neleter also have ben sent to landwner and otr Intereted partes. Th Bure of Land Manment he op hose mein June 200 .$ part of th environt revie prss fo tl prject. Roky Mountain Powe and Idaho Po ho additional me In Debe 200 to gatr Input frlandner and other Inteed pa In Motper, Murpy, Poello and Twin fal, Idah, and In Glrok, Keme, RawUs and Roc Spris, WyoIng. Fow-up landne mengs were thn he In Douglas, Glnrk an Sinclair, Wyong, and In Amern FaUs, Brneu, Bui1, Gong, Gr View, Kuna, Meba and Twin Fas, Idho. Fo a more coensive iisting of the vari outreac efrt, plase see the meeting list (PDF). To submit an offl puIc comet on the Gateav West TransmISsion li Prec, plse co the Bl diy at: Buræu of land ManaQlteay we Pr P. O. 8ø 20879 Chenne, WY 8203 Oi-m Gateway. .West. .WYMall~b!m.gov To co us ab thIs transIsn prec pl call 801-220-4221 or e-mail ConstllictionProjectstSpacifcorp.com. Pl be sure to Inde the prec nam --Gateway Wes- - In your Inquiry. Monsanto Company Exhibit 222 Page 1 of 1 Case No. PAC-E-10-07 Witness: Dennis E. Peseau 10l101t:lIw.pifi.oooggw.btm Gatewa So Pa I otl~~ Gateway South Wlt enrgy us on the ri and el de fast appch th liIt of th exlstf trls$l syem, newfacUlt are need to mee the groin ne. Th groth In dend fo e1eel enrg co fr bo ne an exting cutoers Indial, conrs toay are using 26 pent mo elc:dty than they did 20 ye ago. As part 01 Pacp's Enrg Gaay TransmSio exio Prot" th copany Is pfnl to buil a Ngh-vtransmi Nne pr acros sothe Wyoin, poaly crin nowest Coldo, throh Ut to a po no oflas veas, Nead. this Hne sent" Gatey Soh, wil be apmaly 80 mil io, suly prnt and fu nes of customers an enhnd ele system re thro th re. In ad, th pr wltl enbl de of exiting and new generating rerc, Inlu wi, to mo cuomrs. The pr rou fo Gateay Soh, Aeolus to Mona, ex fr east Wyomng to a hub ner Moa, uth, Wler It WØ cone wl an sement that cotinu th sojm ut. The pr roe for Ga So, Mona to Cryal, Is fr a ne su th wil be bu ner Mq, Utah, conecin to mol sutas thr sothwe Utah to a pont no 01 La veas, Nead. Sigurd to Ree Bute, llnor transmi il tht Is pa of the Gaway Soh pr wHl strt In SIgurd. Ut, an conue south to th Re Butte SUbstaio nor of St. Ge, Utah. Gaeway Soth ma wi be avale fong Pu Sc In Sprf 2010. Proj Tim . Pu SC - August/5ebe2010 . Infol Mengs - Augstseem 2010 . Enviroental Impll Stmet - Decer 200-2015 . Estma line In servic for cutom - 2011-2019 Puc Part Pu In Is a ve Impoant part of tbls proc and WI be we at al stages of this tran lie deel. Pulic SClng meetngs are exped to be he as part of the enviromental review pro. The Burea of land Manemnt wHI ovrsee th pros under the Natial Enviental Poic Ad and wltl host these meeings to co ofal public coments on the prject fo the draft EnvIronmental Impact Stateent. Adtl Info Ab th Proec Th comny wel yor coments at al stes of th tlmllon Hne delot. For mo infoat, plse call us at (SOL) 220-4221 or e-ma ConstructlonProjectsq'pacifìr.rp.cöff. Ple be sure to ind the prec name --En Gateay Soth" - In yor Inquir. (Upda ¡anoarv 14, 2010) Ci2010 PiCO, . sury of MldAmem:an Energv Holdings Company Monsanto Company Exhibit 223 (DEP-3) Page 1 of 1 Case No. PAC-E-10-07 Witness: Dennis E. Peseau ht://w.pfic.conlewss.html llllO 0Ø ofll ,.,..DI .. 1',2I BEFRE TH IDAHO PUBC Ul COMMION IN TI MA"l 01 1'.JIN APPUCATION 011 MlAMCAEKGYHOLD COAN (MC) AN PACDCO DBA UTAB roWDA UGHT COAN llR AN ORERAUTORIG MKTO ACQUI PACDCORP )) CANO. PAC.. ) ) ) ) 0I NO. 29 ) .."' .QAltl 15.20. .PaCø" Ul~.Li ~y~"_l4i~ÇlBnHo. Coy t'M") ~ a ~ ~ ~ th .. CömmiB~Mi'aacti ofPacCO. PacCo.iS a pû ut sut to th~':s j~ ..II prvi .. olect .~. to øey60,00 ~ it.~Id. Atpr ~isa~~~qf Scosh Pnw pi. If ''101nt ~is ap Pafi Wô be ât .~Wly- owed :siarøf~ ~'l.pr öWlÎ ~Ha~l.' Th APP~11~ ~ ~va ll ~ Id ~ .. .jl. re cossiinsoftheotlfive st wh Pac P'vi elcsefo Mld t6åèui1PåQifCô. In adtiOå th acon mÛlt al be ~ve ~$eêr .~ aaenesltüdl .~F'" P. ~ Coiiil (Pô)1 .0. Aug n,2Q$, th ~ .~ it No ()f Apti ..~ .... øi fu liea. OI Debe16.l), øi of th pa in Ii ~ exaåeCit Stio urgi th.~ tô aptle loi ~ co0a.ip 16 "cotret." On JuWJ i 7, 2(), th Co~C) c:ve fl ~ ~_ to coØl. th $~on Bas up ..aq re of .tb loå .Acaon tl ~ Stpuat th teonyôf th paesal 1t puc ~tl~on åp.- àêaûiition.~øn.up lh cotm ~ intb Oi.... : l'l Wýq an Ul ~...~.....~ Oì ~..~ ..i?.,.,.~~ ...~ ~ lb. ~ OD.~ "20. ios II ~NO.BÇ~-lJO-. ii'. PB , 61.2?l(2J.rWln.gm(fotiit ~.Cltb ~ 11:1 Fmc.,_ (peb.'. 20. Monsanto CompanyORDBtlNO.2973 1 Exhibit 224 (DEP-4) Page 1 of 3 Case No. PAC-E-10-07 Witness: . Dennis E. Peseau 30)Pad \lll coe to pr .Ji.~ PI aeBlto ti... euscedwêârd the th cut Coss mlel Bd cd. 3t) WM ~ JH geeron ft in ex oltGO MW ea wia dole lie of to or mo ye Pacfior _ MBC wi ia It fo Pi (Rs) or oter coly wi Bt law ie an ør Ii pe to prt ofne pn re fò PaCo. 32) Nol ÎI tl acuiti eoil sl be ii . a wI of PaftCo's or MBC'. riahts to re co tr fo li th is th subjec of any cotmenta. ., U)Unesan..pria prvibylto,~OD ~òt~l'lÇ~~ ta MRC~ PllfiCc..ei.th ~ to us tt fó1lusprfoadnite th.cotmtL noCOllolubôuld $ive MBC an PllifC~rp wrtt nofin òf anY \'aton by eill ~~fth comitmen inê .mths ~lieaon. If àUbfaur is èO Widù _ (10)~m...dt~. for tìlur to lil~rct or fivi)(S) ~ .~ fo oê~ th Cosion shuld take no acon. 'l Colhlt tha\l todeere i(tl~ve acon bas aaliec or .èOdi viti. ~çor PafiColJllåy reuCI fo case an oxteonoftllipe. JfMBCöt PacfiCoip tìli lQcorrec lIdi vilati witb th ~ ~.fr lImodüed byanYCoSlon~aproved.teon'tl Co.ØlYøêtolI peal før violation ofa Coon~, ...~MBCor PaeiftCo, as åJwed unerst laws im relatons ~4) 1:ipiQJÃlvegtMBC anPac bave~~~ion proeè tl~ miabty~r.litatetb~ Qf~ll ~, orenablelilrter sys~opat.Sllec to~ni antlc availability QfmaterlÅ¡,eqtu~an ri--f~WlY, .MB _ PacliCØ cottguse thei be effort to açeve th followi trssoø.ns iiitre tmtòveritøt: ~~~ a) lat C URe (:-73 millon) - Ia Pat C ca by 30 MW (Û' SoB. Idah to Norer Uta). Th taet colen date for th pr ia 2010. Ths prec: . en relibilty beuse it ia trfer caty beee th eM ød wes cctr ar, ... i Whil ME iw immer ltf in th cIls of Pafi'l .... ae Il'" Mt ti sin tl ~ efdi tret it is po th up t\ te a pal! iI int ROt be eovc optil fo cutors or ab to be ci by th ta.. If_ ai oc, M!Cpl to pr III alvc to th ~ wiØia~ be TlCo ma mvesqaw th rebl øf any de by WECI _ on ør mo ofdi id t: mvctmls is no co-eve or opti ro CUto. IDAHO COTMS CASH NO. 'Ae-ß-oS~8 OlI_NO.1997) 6 Monsanto Company Exhibit 224 (DEP-4) Page 2of3 Case No. PAC-E-10-07 Witness: Dennis E. Peseau '. c) 0 Ie M ex fo th Accrated Distbuon C1 Pu Pro ac a1 sttes win be ln by $1.5 million pe ye for fivo ye afer th clos of th tracon, an l) MBHCanPacfiCo will supo th Bovil. Po Adnisl hi it dllopeu of ll-ten Piueimcb a$çØutlitioiW fi .ØU ll." O\te frm BPA's~,PaeifiCoip will initiate a pr tocoii~vel)'dc_ ptts,.~~fiÇoip. PacifiC9 wil contiti its Paal ~ S~çe ~ .LL its Wiprviontb ~lows .trmissioncusomen walter prec ..trae up to ~~r1lnutesbero~any hour.1ì wÎii.notit' ~csto di proifitprpoes êhanges to1hes two elemets orit OATT. ... I ~. ¡ d) extsion oftl O& investment ac aU stte fb the Savi SAIlliat Jb thee aditi ye at an estimated co of $2 milion per ye. IDAHO COMENT CASE NO. PAC-B--8 OlWBI NO. 2913 7 Monsanto Company Exhibit 224 (DEP-4) Page 3 of3 Case No. PAC-E-10-07 Witness: Dennis E. Peseau ENERGY GATEWAY Copaati Cost per Mile Gateway Central 34SkV $81.5/135 Reinil1 Ene Gatey SOkV ($6,00801.$)/1865 .. Neda Powerls OH l.SO $50.6/235 Assumptns: 1. Gatewy Cetral Investment of $801.5 mllDo 2. Se ie of 135 mi 3. Ene Gateway Investmet of $6 bi 4. Enel' Gateway lenø of 200 miles 5. Nevada Power's ON Une Investent of $50.6 mmton 6. On line semet length of 235 miles Exbit 2x (DEP-S) =$5.94 miHio pe mne $2.79 milllo pe mi =$2.17 mlln pe mlle Monsanto Company Exhibit 225 (DEP-5) Page 1 of 1 Case No. PAC-E-10-07 Witness: Dennis E. Peseau &c_(O Western U.S. Propo 50+ Transmlsslo Uns Soce: Venty Mas fJ Tx jo 50YQlin Tf\ss Un PnGøita So Gat We Hg P1nsEic T..,~ llMo Sk T~ In (M)Ni Tra Aq() In$o In PiSo~~PiTramE",~ Ze Tra U1 Pm Monsanto Company Exhibit 226 (DEP-6) Page 1 of 1 Case No. PAC-E-10-07 Witness: Dennis E. Peseau ... PAC-E-! 0-71R Mou Po Juy 1,2010Mon Da Re 4.S M..sato Data Reues 4.5 Wh fi wo t1 Oay Ce se if ei or bo of1l So aMWes sets ar no eo? R. to M...to Data.. 4.5 If Gay Sout indor Gay Wes we no eo Gaway Cc wilcoti to prvi sipfi befi to th Coy's cuer. Pl iefe to paes Di-3 an Di-4 in th di teony of Dal T. Ge bew.· =:=:~ss=t~~~:::: limte caty an cIte opelitB. . Mee th immed ae to: (1) Imve sys relity in th ar anmai co widi naon eleeCl sy relit sl byinlin ne tnss caty to enur th sy Cf su trio outa BO ofTen Sub wit culq loa, genti or in PafiCo's Ea Cotrl Ar an Deghbotrmisson bø autty er; an (2) Imve th Coy's abiity tope ma on trsson faliti be Popus an Ternaby ha altetive tnsson path th allo faites to be ta off-line an maintin.. Mee th tr caty an reiability reuits to deive re to lods. . Provide PacifCo with gr flexbility when co t\tu planre to me ai' grwi de fo en \\ me cu an fu en reui th may be mate by st BA fe reguation. . Faclitate th ingr of poal new energy re in Wyo U" Idah an Orego an Be su ecnomc deveop in th sttes. Fur, Gateway Ce wil re tl im to cu du symdist Ple re to pa Di-9, Di- i 0, Di- i i in âe dút tey ofDa T. Oe.l. IllSpDø T. OeDI T. Oe Monsanto Company Exhibit 227 (DEP-7) Page 1 of 1 Case No. PAC-E-10-07 Witness: Dennis E. Peseau