Electric 2017-11-06T23:03:53+00:00

Electric

In Re:  I/M/O Electronic Application of Kentucky Power Company for (1) A General Adjustment of its Rates for Electric Service; (2) An Order Approving its 2017 Environmental Compliance Plan; (3) An Order Approving its Tariffs and Riders; (4) An Order Approving Accounting Practices to Establish Regulatory Assets and Liabilities; and (5) An Order Granting All Other Required Approvals and Relief; Case No. 2017-00179; Ongoing.  

ACG is assisting the Office of Rate Intervention for the Kentucky Attorney General in its analysis of the AEP-Kentucky Power Company rate case.  ACG will assist the Attorney general and evaluating the Company’s rate design proposals as well as the Company’s economic development surcharge proposal.  ACG will also provide an analysis on the impact of the Company’s rate design proposal on low-income customers.

 

In Re:  I/M/O the Joint Application of Great Plains Energy Incorporated, Kansas City Power & Light Company and Westar Energy, Inc. for approval of the Acquisition of Westar Energy, Inc. by Great Plains Energy Incorporated; Docket No. 18-KCPE-095-MER; Ongoing.  ACG is assisting the Kansas Electric Power Cooperative, Inc. (“KEPCo”) in the examination of proposed merger of Great Plains Energy and Westar Energy.  ACG will examine the Joint Applicants’ Application for financial analysis regarding the level of financial risk that may result for the transaction. ACG will prepare analyses that will examine a number of different contractual, regulatory and policy actions that can be taken to mitigate the risk of this transaction to KEPCo and its ratepayers. This analysis will include the development of regulatory mechanisms often referred to as “ring fencing” measures to mitigate future financial and regulatory risk.  Additionally, ACG will evaluate the necessity of competitive bidding conditions and the Combined Company’s integrated resource plan.

 

In Re: I/M/O The Formula Rate Plan Filings of Entergy Arkansas, Inc. Pursuant to APSC Docket No. 15-015-U; Docket No. 16-036-FR; Ongoing.  ACG is assisting the Division of Consumer Utility Rate Advocacy in evaluating Entergy’s formula rate plan and evaluation report.  ACG will work with counsel to ensure that the FRP filing is consistent with the FRP rules and statute.  ACG developed a historic and regional peer-group benchmarking analyses on the Company’s operation and maintenance (“O&M”) costs, administrative and general (“A&G”) costs, and proposed changes to plant in service focusing on larger production, transmission and distribution plant investment changes.

 

In Re:  I/M/O Petition of NSTAR Electric Company and Western Massachusetts Electric Company each d/b/a Eversource Energy for Approval of an Increase in Base Distribution Rates for Electric Service Pursuant to G.L. c. 164, § 94 and 220 C.M.R. § 5.00; D.P.U. 17-05; Ongoing.  ACG is assisting the Massachusetts Attorney General’s Office to provide expert testimony in the matter of NSTAR Electric Company/Western Massachusetts Electric Company d/b/a Eversource Energy rate case before the Massachusetts Department of Public Utilities.  ACG will evaluate the Company’s proposed Grid Wise Performance Plan and the associated Performance Based Ratemaking Mechanism (“PBRM”).

 

Before the Section 70, Article 13 Arbitration Panel; Northeast Nebraska Public Power District; City of South Sioux City, Nebraska; City of Wayne, Nebraska; City of Wakefield, Nebraska; City of Valentine, Nebraska; City of Beatrice, Nebraska; City of Scribner, Nebraska; Village of Walthill, Nebraska, (Plaintiff) v. Nebraska Public Power District (Defendant); Completed 2017.  ACG assisted the Plaintiff’s in this matter in evaluating if a discount provided was unfair, unreasonable, and discriminatory.

 

In Re:  I/M/O the Joint Application of Great Plains Energy Incorporated, Kansas City Power & Light Company and Westar Energy, Inc. for approval of the Acquisition of Westar Energy, Inc. by Great Plains Energy Incorporated; Docket No. 16-KCPE-593-ACQ; Completed 2017.  ACG assisted the Kansas Electric Power Cooperative, Inc. (“KEPCo”) in the examination of proposed merger of Great Plains Energy and Westar Energy.  ACG examined the Joint Applicants’ Application for financial analysis regarding the level of financial risk that may result for the transaction ACG will prepare analyses that will examine a number of different contractual, regulatory and policy actions that can be taken to mitigate the risk of this transaction to KEPCo and its ratepayers. This analysis will include the development of regulatory mechanisms often referred to as “ring fencing” measures to mitigate future financial and regulatory risk.

 

In Re: I/M/O The Application of Oklahoma Gas and Electric Company for Approval of a General Change in Rates, Charges, and Tariffs; Docket No.16-052; Ongoing.  ACG is assisting the Division of Consumer Utility Rate Advocacy in evaluating Oklahoma Gas and Electric Company’s rate case filing.  ACG will work with counsel in evaluating the Company’s proposed class cost of service study, rate design, and formula rate plan as well as other rider revisions.  ACG will developed an alternative class cost of service study and rate design.  ACG will also evaluate the Company’s proposed formula rate plan for consistency with legislation and other formula rate plans that have been approved by the Commission.  Additionally, ACG will evaluate the appropriateness of the proposed riders and revisions to existing riders.

 

In Re: I/M/O The Formula Rate Plan Filings of Entergy Arkansas, Inc. Pursuant to APSC Docket No. 15-015-U; Docket No. 16-036-FR; Completed 2016.  ACG assisted the Division of Consumer Utility Rate Advocacy in evaluating Entergy’s formula rate plan.  ACG will work with counsel to ensure that the FRP filing is consistent with the Company’s other tracker mechanisms and that there are no double recoveries of costs or lost revenues, nor any other unanticipated conflicts with these other trackers. ACG developed a historic and regional peer-group benchmarking analyses on the Company’s operation and maintenance (“O&M”) costs, administrative and general (“A&G”) costs, and proposed changes to plant in service focusing on larger production, transmission and distribution plant investment changes.  ACG also developed general forecasts of the O&M, A&G, and investments under future FRPs and developed rate impact outlook.  ACG prepared a retail rate benchmark analysis that compared the Company’s existing rates, and projected FRP rates, against historic trends and a regional peer group average over a five year period. Additionally, ACG analyzed and evaluated all possible material issues impacting ratepayers with a particular emphasis on fixed income and lower income households.

 

In Re:  In the Matter of the Application of Potomac Electric Power Company for Authority to Increase Existing Retail Rates and Charges for Electric Distribution Service; Formal Case No. 1139; Completed 2017.  ACG assisted the D.C. Office of the People’s Counsel in the examination of Pepco’s request for a rate increase.  ACG provided a general policy analysis as well as an examination of the Company’s jurisdictional and class cost of service studies, rate design, and the bill stabilization adjustment mechanism.

 

In Re:  Examination of Kemper IGCC; Docket No. 2017-AD-112; Ongoing.  ACG is assisting the Mississippi Public Utilities Staff (“MPUS”) in the analysis of the economic and rate impacts of the Kemper IGCC Project.  ACG will examine the overall net benefits of the Kemper project from the perspective of Mississippi Power’s ratepayers as well as the State of Mississippi.  This net benefits analysis will require the development and execution of two differing modeling activities: (1) a rate impact model and (2) an economic impact model.  ACG will also evaluate cost allocation and rate design issues as well as assist the estimation of a revenue requirement.  ACG will also conduct a financial analysis to examine how various cost recovery scenarios would impact Mississippi Power and its parents cash flow position and how those cash flow changes may impact various key financial statistics commonly examined for debt rating purposes such as free cash flow from operations as share of debt, cash flow from operations as share of debt, capital structure, and other metrics commonly replied upon by Moody’s, S&P and Fitch.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of a Second Extension of the Solar Generation Investment Program and Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service; BPU Docket. No. EO16050412; Ongoing.  On behalf of the New Jersey Division of Rate Counsel, ACG is reviewing the Public Service Electric & Gas Company’s proposed Solar 4 All Extension Program.  The extension of PSE&G’s existing “Solar 4 All” would expand the development of solar installations to develop an additional 100 MW of solar photovoltaic systems within the Company’s electric service territory.  Under this program, PSE&G proposed to finance, own, and operate solar systems that will be installed in target landfills and brownfields which have been identified in the 2011 Energy Master Plan (“EMP”) and the Solar Act legislation.  PSE&G would recover all program costs through the Regional Greenhouse Gas Initiative Recovery Charge (“RRC”).  ACG will examine the policy and economic implications of the program.

 

In Re:  Petition for Rate Increase by Florida Power & Light Company; Docket No. 160021-EI; Completed 2016.  ACG is assisting the Florida Office of Public Counsel in examining the Company’s petition for a rate increase.  ACG is evaluating the forecasting methodologies used the Company proposed multi-year rate plan.  ACG’s analysis will examine the Company’s customer and load growth forecasts as well as the energy sales and revenue forecasts.

 

In Re: Review of Policies Related to Customer-owned Solar Generation and Possible Modification of the Commission’s Current Net Metering Rules; Docket No. R-33929; Ongoing.  ACG is assisting the Louisiana Public Service Commission in examining the solar energy polices and rulemaking to make a number of housekeeping changes to the rules relating to reimbursement rates and utility installation caps. Additionally, ACG will provide a policy analysis regarding the solar energy policies.  ACG will provide an expert report on the findings of the solar energy policies analysis.

 

In Re: Federal Energy Regulatory Commission Confederated Salish and Kootenai Tribes, Energy Keeper, Incoporated, Project No. 5-103, Completed 2016.

ACG assisted the Duncan Weinberg law firm in developing a wholesale cost of service analysis, from a hydroelectric generation facility, for a group of irrigation customers, before the Federal Energy Regulatory Commission (“FERC”).  ACG conducted a net benefits evaluation in the determination of the cost of producing power at the project.  ACG also examined the reasonableness of the rental payments of the project.

 

In Re:  I/M/O the Merger of the Southern Company and AGL Resources, Inc.; Docket No. GM15101196; Completed 2016. ACG assisted the New Jersey Division of Rate Counsel in examining the Joint Petition for approval of the merger of the Southern Company and AGL Resources. This included the evaluation of the Joint Petitioners’ proposed commitments in relationship to the Board merger standards and policies, synergy savings, merger benefits, and future reporting and monitoring if the merger is approved.  ACG also analyzed the impact that the proposed merger will have on reliability and service quality, the local community, rates and charges, Corporate Governance, and regulatory oversight.

 

In Re: I/M/O The Empire District Electric Company Request for Authority to Implement a General Rate Increase for Electric Service; Case No. ER-2016-0023; Completed 2016. ACG is assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. Empire District Electric Company is requesting an increase of approximately $33.4 million, or an increase of 7.28%. The Company is requesting the additional revenue to recover investment costs, property taxes, and long termoperation and maintenance costs.  The Company is proposing a 15.5 percent increase to the residential customer charge. ACG examined the Company’s cost of service issues and proposed revenue distribution and rate design.  (no work actually performed)

 

In Re: I/M/O The Application of Entergy Arkansas, Inc. for Approval of Changes in Rates for Retail Electric Service; Docket No. 15-015-U; Completed 2016.  ACG assisted the Division of Consumer Utility Rate Advocacy in evaluating Entergy’s request for a rate increase in matters pertaining to the economic development rider and the Company’s cost of service study.  ACG provided expert testimony and research.

 

In Re: I/M/O Union Electric Company d/b/a Ameren Missouri’s tariff to Increase Its Revenues for Electric Service; Case No. ER-2014-0258; Completed 2015. ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. The Company’s filing requested an increase of approximately $264 million, and listed several factors including continued investment in delivery systems, escalating net energy costs, and revenue requirement increases.  ACG provided research, cost of service, revenue distribution and rate design expertise and support to the Office of Public Counsel to assist with the analysis of the Company’s rate increase request.

 

In Re: I/M/O The Empire District Electric Company for Authority to File Tariffs Increasing Rates for Electric Service Provided to Customers In the Company’s Missouri Service Area; Case No. ER-2014-0351; Completed 2015. ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. Empire District Electric Company requested an increase of approximately $24.3 million, or an increase of 5.54%. The Company requested the additional revenue to recover investment costs, RTO transmission fees, property taxes, and long term maintenance costs.  The Company was proposing a 50 percent increase to the residential customer charge. ACG provided expert testimony and analysis which included an alternative cost of service model, a two-step revenue allocation, and proposed a rate design, which did not increase the customer charges.  ACG’s customer charge recommendation was consistent with the results of the alternative CCOSS and limited the impact of the rate increase to the residential and small commercial customers.  ACG also assisted OPC with settlement negotiations with the Company and other intervenors in the case.

 

In Re: I/M/O Kansas City Power & Light Company’s Request for Authority to Implement a General Rate Increase for Electric Service; Case No. ER-2014-0370; Completed 2015. ACG assisted the Missouri Office of the Public Counsel in analyzing the Company’s application and CCOSS. The Company is requested an increase of 15.75% or $120.9 million.  The Company requested the additional revenue to recover costs associated with operation, maintenance, fuel and purchase power, transmission fees, property taxes and additional investments in plant and expenses.  The Company was proposing a 178% increase to residential customer charges.  ACG provided expert testimony and analysis which included an alternative cost of service model, a two-step revenue allocation, and proposed a rate design, which did not increase the customer charges.  ACG’s customer charge recommendations limited the impact of the rate increase to the residential and small commercial customers and balanced the relationship between customer charges and customer related costs.  ACG also provided testimony on the behalf of OPC regarding the Company’s proposed electrical vehicle charging station pilot program which would install 1,000 charging stations.  ACG recommended the Commission reject the charge station program due to the lack of information regarding capital investments and expenses relating to the program and the Company’s failure to provide detail illustrating that the program was in the public’s interest.

 

In Re: PSE&G Economic Analysis of Capital Expenditure Program (Rutgers Study); RC File No.: 15-G-93; Completed 2015. ACG assisted the New Jersey Division of Rate Counsel in examining the Rutgers’ Economic Impact Analysis based on capital expenditures made by the Public Service Electric and Gas Company (“PSE&G”). The examination of the impact analysis will focus on the reasonableness of the assumptions, along with the positive and negative economic impacts discussed within the study.

 

In Re: The United States Environmental Protection Agency’s Proposed Rule on Carbon Dioxide Emissions from Existing Fossil-Fuel Fired Electric Generating Units under Section 111(d) of the Clean Air Act. Docket No. R-33253; Ongoing. ACG is assisting the Louisiana Public Service Commission in researching and preparing comments regarding the reasonableness and impacts of the Environmental Protection Agency’s potential policy. ACG is also creating analytical models to determine company specific impacts, costs, and economic development changes as well as assisting the LPSC in developing a State Implementation Plan.

 

In Re: Methodology for Calculating Avoided Costs of Complying with the Global Warming Solutions Act. DPU 14-86; Completed 2015. ACG assisted the Massachusetts Attorney General’s Office in reviewing the Marginal Abatement Cost Curve, which is used to assess the cost-effectiveness of energy efficiency programs. ACG has been tasked with analyzing this model, with particular attention paid to the avoided costs of complying with the Global Warming Solutions Act.

 

In Re: I/M/O Examination of the Comprehensive Costs and Benefits of Net Metering in Louisiana; Docket No. X-33192; Completed 2015. ACG assisted the Louisiana Public Service Commission with a comprehensive cost-benefit analysis of net metering in Louisiana in order to develop appropriate policies for the state.  ACG also investigated the ratepayer impacts at varying levels of participation in the net metering program. ACG provided an expert report to the Commission which included three empirical models to estimate the impact of the Commission’s net metering policies on ratepayers of Louisiana regulated utilities.  ACG conducted a cost-benefit analysis that examined a wide range of current and projected costs and benefits associated with solar NEM installations.  Additionally, a cost-of-service analysis was performed that estimated the ratemaking implications of the Commission’s solar NEM policies.  ACG also conducted an income distribution analysis that examined the distribution of solar NEM benefits across various income distribution categories.

 

In Re:  In the Matter of Docket No. 8191, Petition of Green Mountain Power Corp. for Approval of an Alternative Regulation Plan; Docket No. 8190, Investigation into Green Mountain Power Corp. Tariff Filing Requesting a Rate Decrease; Completed 2014.  ACG assisted AARP of Vermont in analyzing the Company’s alternative regulation plan.  ACG is assessed the benefits and detriments of the plan and whether it is in compliance with state regulations. After analysis, ACG determined the initially proposed plan was unnecessarily complex and shifted risk from Green Mountain Power to the ratepayer. ACG presented the AARP’s recommended modifications to the plan, creating a more transparent and risk equitable alternative regulation plan.

 

In Re:  In the Matter of Delmarva Power & Light Company’s Application For Approval of a Forward Looking Rate Plan; Docket No. 13-384; Completed 2014.  ACG assisted Delaware’s Division of the Public Advocate with an analysis of the Company’s request to increase electric revenue by $56.3 million over four years.  ACG evaluated the benefits and/or detriments of this type of rate plan for residential and small commercial consumers, and whether the plan is consistent with rate design principles.  ACG also examined the Company’s Regulatory Planning Model, which is used to forecast the Company’s distribution rate base and earnings. (Case Settled – No work actually completed)

 

In Re:  New Jersey Renewable Energy; Ongoing.  ACG is assisting the New Jersey Division of Rate Counsel in its ongoing oversight of the state’s continued efforts to promote renewable energy within the state.  ACG has provided assistance in the analysis of the 2012 “Solar Act”, which provided for aggregate net metering and increased incentives for solar energy on landfills, among others provisions.  ACG has also provided an analysis of the New Jersey Solar Renewable Energy Credit (“SREC”) market and solar development trends to determine the size and scope of volatility in the market.

 

In Re: I/M/O the Merger of Exelon Corporation, Pepco Holdings, Inc., Potomac Electric Power Company, Exelon Energy Delivery Company, LLC and New Special Purpose Entity, LLC; Docket No. FC 1119; Completed 2015. ACG assisted the Office of the People’s Counsel for the District of Columbia in analyzing the policy aspects of the proposed merger of Exelon and Pepco, including the potential impacts on service quality, cost of service, and rates.  ACG provided expert testimony on various economic, public policy, and regulatory policy issues associated with the merger.  ACG provided an economic impact analysis, as well as review and analysis of the impact of the merger on employment, utility management and operation, system reliability, regulatory oversight, and potential impacts on the competitive market.

 

In Re:  Central Maine Power Company’s Rate Design Case (Phase II) in Connection with Their ARP 2014 Proceeding; Docket No. 2013-00168; Completed 2014.  ACG assisted Maine’s Office of Public Advocate in examining Central Maine Power’s Rate Design filing.  In addition to analyzing the Company’s rate design and revenue distribution, ACG also provided a critique of the Company’s Class Cost of Service and Marginal Cost of Service Studies. ACG evaluated the impact of the Company’s proposed standby service rates on residential and net metered customers.  ACG’s analysis found several weaknesses in the proposed Marginal Cost of Service Study including failure to utilize an appropriate methodology, and the use of flawed historic and forecast data to develop cost estimates. In response to these weaknesses, ACG recommended a two-step methodology for developing rates, along with the rejection of the Company’s standby rates, as the rates were inconsistent with Maine’s energy efficiency and renewable generation policies.

 

In Re:  The Petition of Fitchburg Gas and Electric Company (Electric Division) d/b/a Unitil for Approval of an Increase in Base Distribution Rates for Electric Service; D.P.U. 13-90; Completed 2014.  ACG assisted the Massachusetts Attorney General with an examination of the capital cost adjustment mechanism (“CCAM”) and the performance-based regulation (“PBR”) proposals filed by the Company.  ACG also critiqued the Company’s productivity-cost inflation analysis. ACG recommended rejection of the PBR based on several factors including lack of future ratepayer benefits, a flawed productivity-cost inflation analysis, and an alternative analysis suggesting the electric distribution productivity was higher than the Company’s analysis suggested.

 

In Re:  In the Matter of Delmarva Power & Light Company’s Application For an Increase in Electric Base Rates; Docket No. 13-115; Completed 2014.  ACG assisted Delaware’s Division of the Public Advocate with an analysis of the Company’s class cost of service study (CCOSS) and rate design. ACG also assessed the Company’s reliability and evaluated its compliance with Commission standards.  ACG recommended rejection of pro forma Adjustment 26 finding that it lacked a defined review for appropriateness and reasonableness.  For the CCOSS, ACG recommended the modifications of using a Total Distribution Plant allocator to allocate general and common plant accounts.  ACG’s rate design recommendations included a two-step methodology, whereby, the first step would limit the rate increase to any under-earning class, and the second step would distribute any remaining revenue deficiency across all other classes in proportion to their test year revenue.

 

In Re:  In the Matter of the Application of Baltimore Gas & Electric Company for Adjustments to Its Electric and Gas Base Rates; Case No. 9326; Completed 2013. ACG assisted the Maryland Office of People’s Counsel with an examination of the Company’s filing and provided expert opinions on the Electric Reliability Investment initiative (ERI), the class cost of service study (CCOSS), and the rate design.  ACG recommended rejection of the Company’s ERI finding it to be inconsistent with the Governor’s Reliability and Resiliency Task Force report.  For the Electric CCOSS, ACG recommended the modification of using an A&E allocation method using a 4CP measure of demand which recognizes the dual-use nature of sub-transmission assets, and the modification of using a total distribution plant allocation of general plant costs.  For the Gas CCOSS, ACG recommended the modification of allocating main-related distribution plant on the basis of demand and commodity, and the use of a total distribution plant allocator for general and common plant accounts.  ACG’s rate design recommendations included a two-step methodology, whereby, the under-earning classes would receive 1.25 times the system average increase and then the remaining increase would be allocated to the remaining classes in relation to their current revenues.  The distribution rates would be increased with allocations to the volumetric and demand components on an equal percentage basis.                  

 

In Re:  In the Matter of the Application of Potomac Electric Power Company for Authority to Increase Existing Retail Rates and Charges for Electric Distribution Service; Formal Case No. 1103; Completed 2013.  ACG served as the main policy witness for the D.C. Office of the People’s Counsel.  ACG provided an overview of the OPC’s position as well as an expert opinion on the regulatory policy issues associated with the Company’s proposed Rate Making Adjustment 34. ACG recommended rejection of Rate Making Adjustment 34 due to the proposed investments not being known and measureable and the omission of any prudence review.

 

In Re:  In the Matter of the Application of Delmarva Power & Light Company for Adjustments to Its Retail Rates for the Distribution of Electric Energy; Case No. 9317; Completed 2013.  ACG assisted the Maryland Office of People’s Counsel with an examination of the Company’s filing and provided expert opinions on the Grid Resiliency Charge (GRC), the class cost of service study (CCOSS), and the rate design.  ACG recommended rejection of the Company’s GRC in its entirety and identified numerous deficiencies.  For the CCOSS, ACG recommended allocator modifications to the accounts of General and Common Plant, Customer Service and Information Expense, and Sales Expense. ACG’s rate design recommendations included a two-step methodology, whereby, the under-earning classes would receive 1.05 times the system average increase and then the remaining increase would be allocated to the remaining classes in relation to their current revenues.  The distribution rates would be increased with allocations to the volumetric and demand components on an equal percentage basis.

 

In Re: I/M/O the Verified Petition of Rockland Electric Company for Approval to Implement an Extended SREC-Based Financing Program Pursuant to N.J.S.A. 48:3-98.1 (SREC II Program); BPU Docket EO12090799; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining the Company’s request to extend its current Solar Renewable Energy Certificate (SREC) financing program into the “SREC II Program.”   SREC II Purchase and Sale Agreements of approximately 4.5 MW of installed solar capacity were estimated over a three-year period in their service territory.

 

In Re:  In the Matter of the Application of Potomac Electric Power Company for an Increase in Its Retail Rates for the Distribution of Electric Energy; Case No. 9311; Completed 2013.  The Company requested a $60.8 million increase in base distribution revenue.  ACG was retained by the Maryland Office of People’s Counsel to provide an expert opinion on the issues of the Grid Resiliency Charge (GRC), the class cost of service study (CCOSS), and the rate design.  ACG recommended rejection of the Company’s GRC proposal since it was premature, was inconsistent with the recommendations included in the Governor’s Resiliency Task Force Report, included a number of inherent mechanism design flaws, and was inconsistent with prior Commission precedent on infrastructure trackers.  ACG recommended alternative CCOSS allocation factors that included the use of an Average and Excess demand allocator based on a 4 Coincident Peak measure for allocating sub-transmission Plant and Associated Expenses; the use of the Sum of Customer Max and Non-Coincident Annual Class Peak Demands, with 50 percent weight given to each factor, to allocate secondary voltage distribution plant accounts and related O&M expenses; and the allocation of PSC Assessments based on gross Maryland retail sales revenue.  ACG also recommended that the Company update its supporting cost studies for meters and customer accounts and sales expense, as well as the installation on customer premise cost study and its outdoor lighting cost allocation study.  For rate design, ACG recommended that revenue responsibilities for developing rates should be allocated using a two-step methodology. In the first step, the under-earning classes receive 1.05 times the system average increase. In the second step, the remaining increase is allocated to all classes in relation to their current revenues.

 

In Re:  I/M/O the Petition of Atlantic City Electric Company Concerning a Proposal for an Extended Solar Renewable Energy Certificate (SREC) Based Financing Program; BPU Docket No. EO12090799; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining the Atlantic City Electric Company’s request for approval of its proposed 23 MW long term Solar Renewable Energy Certificate (SREC) financing program.

 

In Re:  I/M/O the Petition of Fishermen’s Atlantic City Wind Farm, LLC for the Approval of the State Waters Project and Authorizing Offshore Wind Renewable Energy Certificates; BPU Docket No. EO11050314V; Completed 2013.  ACG was retained by the New Jersey Division of Rate Counsel to provide an expert opinion to the Board of Public Utilities on the revised offshore wind development application submitted by Fishermen’s Atlantic City Wind Farm (FACW).  ACG recommended rejection of the FACW project because it did not meet statutory requirements and it was not in the public interest since it would not produce a net economic benefit to New Jersey ratepayers.

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of Extension of a Solar Generation Investment Program and Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service; BPU Docket. No. EO12080721; Completed 2013.  On behalf of the New Jersey Division of Rate Counsel, ACG reviewed Public Service Electric & Gas Company’s proposed Solar 4 All Extension Program.  The extension of PSE&G’s existing “Solar 4 All” would expand the development of solar installations to develop an additional 136 MW of solar photovoltaic systems within the Company’s electric service territory.  Under this program, PSE&G proposed to finance, own, and operate solar systems that would be installed on landfills, brownfields, warehouse roofs and parking lots.  PSE&G would recover all program costs through a new component of the Regional Greenhouse Gas Initiative Recovery Charge (“RRC”).

 

In Re:  I/M/O the Petition of Public Service Electric and Gas Company for Approval of a Solar Loan III Program and an Associated Cost Recovery Mechanism and for Changes in the Tariff for Electric Service; BPU Docket. No. EO12080726; Completed 2013.  ACG assisted the New Jersey Division of Rate Counsel in examining Public Service Electric & Gas Company’s proposal for a third solar loan program as a continuation of its Solar Loan I and Solar Loan II programs.  PSE&G would continue its solar photovoltaic development program across all customer classes within its electric service territory.  PSE&G would provide financing for the installation of these systems on the customers’ premises, which is repaid using solar renewable energy certificates (“SRECs”) or cash. PSE&G would recover all program costs through a new component of the Regional Greenhouse Gas Initiative Recovery Charge (“RRC”).

 

I/M/O the Petition of Jersey Central Power & Light Company Concerning a Proposal for an SREC-Based Financing Program; BPU Docket No. EO12080750; Completed 2013. ACG assisted the New Jersey Division of Rate Counsel in examining the filing by Jersey Central Power & Light requesting approval of its proposed 52 MW long term Solar Renewable Energy Certificate (SREC) financing program.  The “SREC II Program” is a continuation of the Company’s “SREC I Program,” whereby, JCP&L would support SREC-based financing of solar generation projects by entering into Board-approved long-term agreements for the purchase of SRECs from solar project owners or developers at prices set through bi-annual solicitations.

 

In Re:  I/M/O the Petition of Public Service Electric & Gas Company for Approval of Changes in its Electric RGGI Recovery Charges and its Gas RGGI Recovery Charges and for Changes in the Tariff for Electric Service; BPU Docket No.: GR12070605 & ER12070606; Completed 2013. On behalf of the New Jersey Division of Rate Counsel, ACG reviewed the Company’s proposed changes to its cost recovery of six energy efficiency, demand response, and solar energy programs.

 

In Re:  Rule Making to Consider the Impact of Alternative Fuel Vehicles on Electric and Gas Utility Operations; LPSC File No. 334; Completed 2013.  ACG assisted the Louisiana Public Service Commission in the development of potential rules for alternative fuel vehicles for Louisiana’s electric and natural gas utilities.  Tasks included reviewing best practices rules and regulations, developing stakeholder questions, coordinating a technical hearing, and synthesizing the information from the technical hearing.

 

In Re:  Avista Utilities 2011 & 2012 General Rate Cases; Consolidated Docket Nos. UE-110876 & 120436; Completed 2012.  ACG assisted the Washington Attorney General with an examination of the revenue decoupling mechanism proposed by the Northwest Energy Coalition as well as revenue requirement issues.  ACG submitted testimony detailing the proposal’s lack of compliance with the UTC’s conservation policy statement and its unfair shift of revenue recovery risk onto ratepayers.

 

In Re:  Application of El Paso Electric Company to Change Rates and to Reconcile Fuel Costs; Docket No. 40094; Completed 2012.  El Paso Electric Company requested a base rate increase of $26.255 million.  ACG was retained by the City of El Paso to analyze the Company’s Jurisdictional Allocation Study, Class Cost of Service Study, and rate design proposal.  The case was settled before testimony was submitted.

 

In Re:  In the Matter of the Application of Delmarva Power & Light Company for Authority to Increase Its Rates For Electric Distribution Service; Case No. 9285; Completed 2012.  Delmarva Power & Light Company requested a $25.2 million increase in its Maryland distribution rates.  ACG was retained by the Maryland Office of People’s Counsel to provide an expert opinion on Delmarva’s proposed Reliability Investment Recovery Mechanism (“RIM”), class cost of service study (“CCOSS”), and rate design.  ACG recommended rejection of the Company’s RIM due to numerous deficiencies.  ACG found the RIM to be poorly-constructed, ambiguous, and unproven as a regulatory mechanism. It also placed an undue amount of risk on ratepayers without proving commensurate benefits.  Concerning the CCOSS, ACG presented alternative allocation factors for several accounts including General Plant, Common Plant, Customer Service and Information Expenses, and Sales Expenses.  ACG’s rate design recommendations included increasing customer charges for those classes where their current revenues were less than their customer-related costs to a level that moved towards their full cost of service.  Distribution rates would also be moved towards their full cost of service.  ACG’s revenue distribution recommendations included constraints that would prevent any one class from receiving a rate increase greater than 1.25 times the system average.

 

In Re:  In the Matter of the Application of Potomac Electric Power Company For Authority to Increase Its Rates and Charges For Electric Distribution Service; Case No. 9286; Completed 2012.  Potomac Electric Power Company requested a $68.4 million increase in its Maryland distribution rates.  ACG was retained by the Maryland Office of People’s Counsel to provide an expert opinion on Delmarva’s proposed Reliability Investment Recovery Mechanism (RIM), class cost of service study (CCOSS), and rate design. ACG recommended rejection of the Company’s RIM due to numerous deficiencies.  ACG found the RIM to be poorly-constructed, ambiguous, and unproven as a regulatory mechanism. It also placed an undue amount of risk on ratepayers without proving commensurate benefits.   ACG presented an alternative CCOSS which altered several allocation factors including the use of the Sum of Customer Max Demands and Non-Coincident Annual Class Peak Demands for secondary voltage distribution plant accounts and related operations and maintenance expenses, and allocating PSC Assessments based on gross Maryland retail sales.  ACG’s rate design recommendations included increasing customer charges for those classes where their current revenues were less than their customer-related costs to a level that moved towards their full cost of service.  Distribution rates would also be moved towards their full cost of service.  ACG’s revenue distribution recommendations included constraints that would prevent any one class from receiving a rate increase greater than 1.25 times the system average.

 

In Re:  In the Matter of the Application of Potomac Electric Power Company for Authority to Increase Existing Retail Rates and Charges for Electric Distribution Service; Case No. FC1087; Completed 2012.  ACG assisted the District of Columbia’s Office of the People’s Counsel with an analysis of Potomac’s proposed infrastructure mechanism and claims of regulatory lag.  ACG recommended that the Commission reject the Company’s Reliability Investment Recovery Mechanism, finding it to be unnecessary, suffering from technical deficiencies, and inviting inefficiencies and higher rates.

 

In Re: Petition for an Increase in Rates by Gulf Power Company; Docket No. 110138-EI; Completed 2011.  ACG assisted the Florida Office of the Public Counsel with the analysis of the rate application filed by Gulf Power Company with a specific focus on the company’s affiliate transactions.  ACG examined the operations of GPC and its affiliates to ensure that any unregulated operations and affiliates were appropriately treated and that costs were correctly allocated or charged to them so that the Company’s regulated operations were not being subsidized by the nonregulated operations.

 

In Re:  Request of Fitchburg Gas and Electric Light Company d/b/a/ Unitil (Electric Division) for an Increase in Base Distribution Rates and a Revenue Decoupling Mechanism; D.P.U. 11-01; Completed 2011.  ACG assisted the Massachusetts Office of the Attorney General with an examination of the application submitted by Fitchburg Gas and Electric Light Company.  ACG provided expert testimony on the Company’s Targeted Infrastructure Replacement Factor and provided recommendations concerning the revenue decoupling reporting.

 

In Re: Petition of Western Massachusetts Electric Company for Approval of a General Increase in Electric Distribution Rates and a Revenue Decoupling Mechanism; Docket No. D.P.U. 10-70; Completed 2011.  ACG assisted the Massachusetts Attorney General with an examination of the application submitted by Western Massachusetts Electric Company to increase its electricity distribution rates. ACG provided analyses and testimony related to the Company’s proposed Inflation Adjustment Clause, Revenue Decoupling Mechanism, Rate Design Policy, Capital Reliability Reconciliation Clause, and other related matters.

In Re: Southern Indiana Gas and Electric Company d/b/a Vectren Energy Delivery of Indiana, Inc., Electric Rate Case; Completed 2010.  ACG assisted the Indiana Office of Utility Consumer Counselor (“OUCC”) with the examination of the application submitted by Vectren South Electric to increase its electric distribution rates. ACG provided testimony on the Company’s revenue decoupling proposal; its proposed Reliability Cost and Revenue Adjustment tracker, including its Variable Production Cost recovery component; and components of its proposed Midwestern Independent System Operator (“MISO”) Cost and Revenue Adjustment (“MCRA”) tracker.

In Re: Application of El Paso Electric Company to Change Rates, to Reconcile Fuel Costs, to Establish of Texas Formula-Based Fuel Factors, and to Establish an Energy Efficiency Cost Recovery Factor; Docket No. 37690; Completed 2010.  ACG assisted the City of El Paso with the examination of the application submitted by El Paso Electric Company to increase its rates for electric service.  ACG conducted analyses related to the Company’s proposed energy efficiency programs, including examination of energy and demand savings, cost-benefit analyses, spending budgets, and ability to meet energy and demand saving goals and objectives.  ACG also examined the Company’s jurisdictional allocations which included an analysis of the appropriate production and transmission allocation factors, treatment of off-system sales, and direct assignments.  ACG prepared an alternative class cost of service study which included examining the appropriate demand, energy, and customer factors; treatment of interruptible customers; examination of MCD and NCP methodologies; and the allocation of expenses and rate base accounts.  Finally, ACG developed alternative revenue distributions and rate design recommendations for residential, small commercial, general service, industrial, and governmental customers.  Our rate design analyses included examinations of load factors, seasonal differentials, time-of-use rates, customer charges, and inverted block rates.

 

In Re: Review of Replacement Fuel Costs Associated with the February 26, 2008 Outage on Florida Power & Light’s Electrical System; Completed 2010.  ACG assisted the Florida Office of the Public Counsel in evaluating the net replacement power cost (“net RPC”) estimate proposed by Florida Power & Light Company (“FPL”).  The Company offered this estimate in order to credit rate payers for the loss of load event in Florida on February 26, 2008.  ACG provided testimony on the merits of FPL’s proposal and provided a series of alternative net RPC credit calculations including an alternative RPC recommendation.

In Re: Research Support on Louisiana Renewable Energy Development Project, Miscellaneous Energy Efficiency and Conservation Issues; Completed 2009. ACG assisted the City of Ruston, Louisiana, in evaluating the opportunities of a co-firing application at the municipal generation facility owned by the City.

In Re: Petition of Massachusetts Electric Company and Nantucket Electric Company for a General Increase in Electric Rates and Approval of a Revenue Decoupling Mechanism; Completed 2009.  ACG assisted the Massachusetts Attorney General with the examination of the application submitted by Massachusetts Electric Company and Nantucket Electric Company to increase its electric rates for electric service rendered in Massachusetts. ACG prepared discovery and provided testimony on the Company’s revenue decoupling proposal, net inflation factor proposal, capital recovery mechanism, and several issues related to the Company’s proposed inclining block rate design.

In Re: Petition for increase in rates by Florida Power & Light Company; Docket Nos. 080677-EI and 090190-EI; Completed 2009.  ACG assisted the Florida Office of the Public Counsel in analyzing Florida Power & Light Company’s application for a rate increase. ACG prepared discovery, analyzed Company Minimum Filing Requirements, and filed direct testimony on accounting issues and affiliate transactions issues. Issues examined included the ratemaking treatment of acquisition premiums, affiliate transactions, cost allocations between regulated and unregulated affiliates, load forecasting, and projected billing determinants.

In Re: Petition for increase in rates by Progress Energy Florida, Inc.; Docket No. 090079-EI; Completed 2009.  ACG assisted the Florida Office of the Public Counsel with analyzing Progress Energy Florida’s application for a rate increase.  ACG prepared discovery, analyzed Company Minimum Filing Requirements, and prepared direct testimony on accounting issues and affiliate transactions issues. Issues examined included the ratemaking treatment of affiliate transactions, cost allocations between regulated and unregulated affiliates, and the treatment of revenue recorded below-the-line for ratemaking purposes.

In Re: New Jersey, Provision of Basic Generation Service (“BGS”); Completed 2009.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, by providing an expert opinion to the New Jersey Board of Public Utilities on cost recovery proposals by electric distribution companies (“EDCs”) for increased solar energy costs.

In Re: In the Matter of the Renewable Portfolio Standard – Amendments to the Minimum filing Requirements for Energy Efficiency, Renewable Energy, and Conservation Programs and For Electric Distribution Company Submittals of Filings in connection with Solar Financing; BPU Docket No. EO06100744 and EO08100875; Completed 2009. ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with an expert opinion to the Board of Public Utilities on the policy and program design issues associated with the SREC-based financing proposal offered by Atlantic City Electric Company. This proposal was filed by the Company pursuant to a BPU Board Order supported by the Regional Greenhouse Gas Initiative legislation, N.J.S.A. 48:3-98.1, which authorizes electric and gas public utility companies in New Jersey to provide energy efficiency, conservation, and Class I renewable energy programs on a regulated basis.

In Re: In the Matter of the Verified Petition of Jersey Central Power & Light Concerning a Proposal for an SREC-Based Financing Program under N.J.S.A. 48:3-98.1; BPU Docket No. EO08090840; Completed 2009.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with an expert opinion to the Board of Public Utilities on the policy and program design issues associated with the SREC-based financing proposal offered by Jersey Central Power & Light Company. This proposal was filed by the Company pursuant to a BPU Board Order supported by the Regional Greenhouse Gas Initiative legislation, N.J.S.A. 48:3-98.1, which authorizes electric and gas public utility companies in New Jersey to provide energy efficiency, conservation, and Class I renewable energy programs on a regulated basis.

In Re: New Jersey Energy Master Plan; Completed 2009.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with an expert opinion to the New Jersey Board of Public Utilities on the pending New Jersey Energy Master Plan (“EMP”). ACG has provided assistance in the analysis of clean energy programs (energy efficiency and renewable energy) and its implications for rate payers and an examination of market and rate impacts of various clean energy program implementation scenarios. ACG has also examined issues related to lost distribution revenues and revenue decoupling.

In Re: In the Matter of Atlantic City Electric Company’s “Blueprint for the Future,” Establishing an Advanced Metering Infrastructure Program, Demand-Side Management Initiatives, Utility-Provided Demand Response Programs and Other Programs, and Requesting BPU Approval of Cost Recovery Mechanisms Related Thereto; BPU Docket No. EO07110881; Completed 2008.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with the examination of the solar energy and revenue decoupling proposal by Atlantic City Electric Company. The Company sought authorization to establish a separate Advanced Metering Infrastructure rate adjustment mechanism, recover program costs for the proposed Direct Load Control through the existing System Control Charge, and implement utility-provided energy efficiency and conservation programs. The Company sought to recover costs related to the proposed low-income conservation programs, solar programs, large customer Internet-based platform, and other demand-side management initiatives through the existing Societal Benefits Charge. Also included in the proposal was a Bill Stabilization Adjustment mechanism or revenue decoupling mechanism.

In Re: Investigation and Potential Rulemaking into the Development of a Potential Incentive-Based Mechanism for Fuel Cost Recovery by Louisiana Jurisdictional Electric Utilities; Docket No. R-30426; Completed 2008.  ACG assisted the Louisiana Public Service Commission in an investigation on the potential for an incentive-based mechanism for fuel cost recovery by Louisiana jurisdictional electric utilities.

In Re: Investigation into the Ratemaking and Generation Planning Implications of Nuclear Construction in Louisiana; Docket No. R-29172; Completed 2008.  ACG assisted the Staff of the Louisiana Public Service Commission with preparation of the rule to provide an incentive approach to promote nuclear power plant development in Louisiana.

In Re: Recommendations for Alternative Compliance Payments and Solar Alternative Compliance Payments for Energy Year 2008, A Stakeholder Process Regarding Alternative Compliance Payment and Solar Alternative Compliance Payment Levels for Energy Year 2009 and 2010 or Longer, and a Solar REC-Only Pilot; BPU Docket Number EO06100744; Completed 2008.  ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, in its participation in a stakeholder proceeding to consider a wide range of proposed solar energy market designs and policies. The formal purpose of the proceeding was to examine the appropriate levels for solar alternative compliance payment prices in upcoming years. In addition the stakeholder process includes an examination of solar energy market structure and design, including whether or not a rebate-based approach should be maintained relative to other financial support options that might rely more heavily on tradable SRECs.

In Re: Investigation into the Fuel Adjustment Clause Practices of Entergy Gulf States and Its Affiliates; Docket No. U-27103; Completed 2012.  ACG assisted the Louisiana Public Service Commission with an investigation into the fuel procurement and cost recovery practices of Entergy Gulf States, Inc., for fuel adjustment clause (“FAC”) purposes. The analysis includes the appropriateness of costs included in the FAC including transactions with affiliates, gas procurement practices, forecasting, natural gas markets, and conformance with PSC regulations. ACG’s analyses examine issues associated with affiliate pipeline companies, excessive nuclear fuel costs, compliance with Commission orders, pricing of electricity among affiliated companies, off-system sales and purchased power, plant outages, transportation storage costs, and risk management practices.

In Re: The Feasibility, Costs, and Benefits of Co-Firing Agricultural Residue and Energy Crops at Louisiana Generation Facilities; Completed 2008.  ACG assisted Cleco Power, LLC, and Entergy Services, Inc., with an examination of the availability and relative economics of utilizing agricultural residues and energy crops in a co-firing application at the Rodemacher Power Station under development by Cleco Power, L.L.C., and the Little Gypsy Power Station re-powering proposal offered by Entergy Louisiana, L.L.C. ACG performed an extensive literature review on the costs and heating values of agricultural residues and energy crops as well as current co-firing applications. Availability and economic analyses were done for corn stover, cotton gin trash, rice straw, grain sorghum, soybean residue, wheat straw, switchgrass, sugar cane bagasse, and wood mill residue.

In Re: Application for Approval of Advanced Metering Pilot Program; LPSC Docket No. S-30336; Completed 2008.  ACG assisted the Staff of the Louisiana Public Service Commission in its examination of the potential public benefits of implementing an advanced metering system (“AMS”) and demand response (“DR”) program for the South Baton Rouge area as proposed by Entergy Gulf States, Inc.

In Re: In the Matter of the Petition of Public Service Electric & Gas Company for Approval of a Solar Energy Program and an Associated Cost Recovery Mechanism;BPU Docket No. EO07040278; Completed 2007. ACG assisted the New Jersey Department of the Public Advocate, Division of Rate Counsel, with the preparation of an expert opinion to the Board of Public Utilities on the policy issues associated with Public Service Electric & Gas Company’s solar energy proposal. PSE&G proposed to implement a solar photovoltaic development program across all customer classes within its electric service territory. PSE&G would provide financing for the installation of these systems on the customers’ premises and recover the costs of the program, including an incentive, through its electric Societal Benefits Charge.

 

In Re: An Investigation Into the Ratemaking and Generation Planning Implications of the U.S. EPA Clean Air Interstate Rule; Docket No. R-29380; Completed 2012.ACG assisted the Louisiana Public Service Commission with the development of a methodology and recommendation for allocating NOx allowances to qualifying electricity generating units in the State of Louisiana.  The Clean Air Interstate Rule (CAIR) provides a Federal framework requiring states to reduce emissions of sulfur dioxide (SO2) and nitrogen oxide (NOx).

 

In Re: Investigation to Determine if it is Appropriate for LPSC Jurisdictional Electric Utilities to Provide and Install Time-Based Meters and Communication Devices for Each of Their Customers Which Enable Such Customers to Participate in Time-Based Pricing Rate Schedules and Other Demand Response Programs; Docket No. R-29213; Completed 2007.  ACG assisted the Louisiana Public Service Commission with its examination of the opportunities for Demand Response Mechanisms for Louisiana as required under 1252(a) of the Energy Policy Act of 2005.  ACG prepared a request for comments as well as held a technical conference to survey interested parties’ opinions on demand response and advanced metering.

 

In Re: Petition for Rate Increase by Florida Power & Light Company; Docket No. 050045-EI; Completed 2005.  ACG assisted the Florida Office of the Public Counsel with examining the issues associated with the proposed load forecast by Florida Power & Light Company’s in its request for a rate increase.  ACG also presented information associated with the Company test year O&M expenditures to be considered in evaluating its request for a 50-basis point incentive to its allowed return on equity.  Other issues that ACG examined included affiliate transactions, cost allocation techniques, advertising expenditures, charitable contributions, and FPL’s purchase of turbines from affiliates at prices significantly higher than available in the market.

 

In Re: Impact of Renewable Portfolio Standard Increase; Completed 2005. ACG assisted the New Jersey Division of Ratepayer Advocate with an evaluation of a proposed increase in the state’s renewable portfolio standard to 20 percent of all resources.  The analysis included a review of the current status of renewable energy development in the US, characterization of renewable power generation technologies, as well as recent trends in renewable technologies and market penetration.  ACG focused on the cost effectiveness of various renewable technologies compared to conventional fossil fuel technologies, including an estimation of economic and rate impacts, a discounted cash flow analysis, and analysis of renewable energy credits trading.

 

In Re:  Generic Proceeding to Explore a Formal Request for Proposal for Utilities that are Considering Alternatives for Adding Generating Capacity; Docket No. 2005-191-E; Completed 2005. ACG assisted NewSouth Energy, LLC, a Calpine Corporation subsidiary with preparation of direct and rebuttal testimony on the advantages of competitive bidding and the development of rules requiring utilities to submit Requests for Proposals to the market prior to obtaining or self-developing generation resources.

 

In Re: Petition of Entergy Mississippi, Inc. for a Certificate of Public Convenience; Docket No. 05-UA-323; Completed 2005.  On behalf of Calpine Corporation, ACG provided direct testimony addressing the proposal by Entergy Mississippi, Inc., to seek approval from the Mississippi Public Service Commission for a Certificate of Public Convenience and Necessity to acquire and operate the Attala Energy Facility.

 

In Re: In the Matter of the Application of PacifiCorp for Approval of its Proposed Electric Service Schedules and Electric Service Regulations; Docket No. 04-035-42; Completed 2005.  ACG assisted the Utah Committee of Consumer Services with the preparation of discovery and prefiled direct and rebuttal testimony concerning affiliate transactions issues including: relationships with coal affiliates, relationships between regulated and nonregulated affiliates, cost allocation methods for allocating costs between affiliated companies. The analysis included examinations of common officers and directors of affiliated companies, employee time records and exception time reports, direct assignment versus cost allocation methodologies, the Massachusetts Formula for cost allocations, and cost allocation manuals, policies and documentation.

 

In Re: Lafayette City-Parish Consolidated Government et al v. Entergy Gulf States, Inc. and Entergy Corporation; Docket No. 00994490J; Completed 2005.  ACG assisted Lafayette Utility Service, the City of Lafayette, and the Lafayette City Parish Consolidated Government with preparation of an expert rebuttal report.  The report, filed with the 15th Judicial District Court of Lafayette Parish, Louisiana, critiqued a valuation study conducted on behalf of Entergy Gulf States, Inc., that examined the fair market value of property proposed for expropriation by the City of Lafayette and the Lafayette Utilities System.

 

In Re: South Carolina Electric & Gas, Application for Adjustments in the Company’s Electric Rate Schedules and Tariffs; Docket No. 2004-178-E; Completed 2004.ACG assisted Columbia Energy, LLC (subsidiary of Calpine Corporation) with preparation of testimony before the South Carolina Public Service Commission. Issues included evaluating the reasonableness of SCE&G’s proposal to enter the entirety of its Jasper Generating Facility into rates. ACG reviewed previous rate filings, company benefit analyses, off-system sales, reserve margins, and demand forecasts.

 

In Re: Florida Power & Light Company, Levelized Fuel Cost Recovery and Capacity Cost Recovery Proceeding; Docket No. 040001-EI; Completed 2004.  ACG assisted Power Systems Manufacturing, Thomas K. Churbuck, and the Florida Industrial Power Users Group with evaluating the reasonableness of FPL’s proposal to recover costs associated with three purchased power agreements with Southern Company Services, including the preparation of testimony.

 

In Re: Review of Florida Power Corporation’s Earnings, Including Effects of Proposed Acquisition of Florida Power Corporation By Carolina Power & Light; Docket Number 000824-EI; Completed 2002.  ACG assisted the Florida Office of the Public Counsel with preparation of discovery and analysis of Company Minimum Filing Requirements.  This included the preparation of direct testimony on accounting issues; merger and acquisition issues, including synergy savings and merger costs; and affiliate transactions issues. Other examined issues included the ratemaking treatment of acquisition premiums, affiliate transactions, cost allocations between regulated and unregulated affiliates, load forecasting, and projected billing determinants.

 

In Re: Review of the Retail Rates of Florida Power & Light Company; Docket No. 001148-EI; Completed 2002.  ACG assisted the Florida Office of the Public Counsel with Florida Power & Light Company’s application for a rate increase. ACG contributed to the preparation of discovery, analysis of Company Minimum Filing Requirements, and preparation of direct testimony on accounting issues and affiliate transactions issues.  Examined issues included those associated with the ratemaking treatment of acquisition premiums, affiliate transactions, cost allocations between regulated and unregulated affiliates, load forecasting, and projected billing determinants.

 

In Re: Gulf Power Company Request for a Rate Increase; Docket No. 010949-EI; Completed 2001. ACG assisted the Florida Office of the Public Counsel with the Gulf Power Company’s application for a rate increase.  ACG prepared discovery, analyzed Company Minimum Filing Requirements, prepared direct testimony on accounting issues, forecasting issues, and affiliate transaction issues.

 

In Re: Request Letter of Non-Opposition for Official Action of Approval to Transfer of Controlling Interest in their Common Stock as a Result of the Merger of Applicants’ Corporate Parent Company, Entergy Corporation with FPL Group; Docket No. U-25354; Completed 2001.  ACG assisted the Staff of the Louisiana Public Service Commission with an investigation into the proposed merger between Florida Power & Light Group and Entergy Corporation.  ACG examined regulatory issues associated with largest proposed merger in the US power industry including rate impacts, impacts on transmission system reliability and governance, customer service, economic impacts, employment impacts, market power and competitive market conditions, merchant power interconnection issues, affiliate relationships, and synergy savings.

 

In Re: Economic Impacts of Merchant Power Plant Development Mississippi; Completed 2001.  ACG assisted the Office of the Governor, State of Mississippi with preparation of an economic impact study to model the potential economic benefits associated with merchant power plant development in Mississippi. The analysis included development of power market impact model that estimated changes in regional wholesale price associated with merchant development. Transmission and rate issues were also examined.

 

In Re: Gulf Power Company; Smith Wetlands Mitigation Plan; Docket No. 000808-EI; Completed 2001.  ACG assisted the Office of the Public Counsel with preparation of discovery, analysis of Company testimony, and preparation of prefiled direct testimony on the Wetlands Mitigation Plan.

 

In Re: Generic Issues Associated with Applications for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344l; Docket No. 22344; Completed 2001. Members of ACG assisted the City of Amarillo, Texas, with an analysis of Southwestern Public Service Company’s proposed unbundling plan. This included an analysis of proposed generation capacity auction, impacts of capacity actions on purchased power factor, the relationship of fuel adjustment clauses on unbundled rates, market power, transmission pricing and governance issues, federal-state jurisdictional issues, and price forecasting.

 

In Re: Application of Southwestern Public Service for Approval of Unbundled Cost of Service Rate Pursuant to PURA §39.201 and Public Utility Commission Substantive Rule §25.344; Docket No. 22351; Completed 2001.  Members of ACG assisted the City of Amarillo, Texas, with an analysis of the unbundled cost of service plan proposed by Southwestern Public Service Company before the Public Utilities Commission of Texas.  The proposed unbundled cost of service study was required under Senate Bill 7 in Texas to facilitate retail choice.  Analysis included the review of revenue requirement reasonableness; affiliate relationships, class cost of service, jurisdictional allocations, revenue distribution, and forecast billing determinants.

 

In Re: New Energy Ventures, Distributed Generation Proceedings; CPUC Rulemaking 98-12-015; Completed 2000.  ACG examined unbundled distribution rate design proposals by California’s investor-owned distribution utilities and their implications for rate design issues associated with distributed energy on behalf of New Energy Ventures and Honeywell Power Systems. ACG also assisted with the preparation of expert witness testimony in Phase II Distributed Generation Proceedings.

 

In Re: In the Matter of the Application of the Kansas Power and Light Company and KCA Corporation for Approval of the Acquisition of All Classes of the Capital Stock of Kansas Gas and Electric Company, to Merge with Kansas Gas and Electric Company, to Issue Stock and Incur Debt Obligations; Case Number EM-91-213; Completed 1995.  Members of ACG assisted the Staff of the Missouri Public Service Commission with preparation of discovery; preparation of direct testimony on accounting issues, financial issues, financial cost modeling, and merger issues; and preparation of cross-examination questions.

 

In Re: Preliminary Analysis of Proposed Merger Between Washington Water Power Company and Sierra Pacific Power Company; Completed 1995.  Members of ACG assisted the Nevada Public Service Commission with preparation of an expert report on accounting issues, financial issues, and merger issues.

 

In Re: Investigation into Currently Authorized Return on Equity of Tampa Electric Company; Docket Number 930987-EI; Completed 1993.  Members of ACG assisted the Florida Office of the Public Counsel with its investigation into the authorized return on equity of Tampa Electric Company.  This included assistance with preparation of discovery, direct testimony on accounting and financial issues, issues and positions for Prehearing Statement, and cross-examination questions.

 

In Re: Application of El Paso Electric Company for Authority to Change Rates, Docket Numbers 5640, 6350, 7460, 8363, 9945; Completed 1992.  Members of ACG assisted the City of El Paso in response to El Paso Electric Company’s application for a rate increase in certain municipalities in the State of Texas. This included assistance with the preparation of discovery, analysis of Company Minimum Filing Requirements, and preparation of cross-examination questions. Also, members prepared direct testimony on accounting issues, prudence issues, class cost of service studies, and cost allocations.

 

In Re: Application for a Rate Increase Filed by El Paso Electric Company; Docket No. 9945; Completed 1991. Members of ACG assisted the City of El Paso with the preparation of class cost of service studies concerning El Paso Electric Company.  Analyses included an examination of allocation methodologies including demand versus energy factors, customer factors, administrative and general allocations; coincident peak methodology, non-coincident peak methodology; and asset and expense functionalization and categorization.

 

In Re: Application for a Rate Increase Filed by El Paso Electric Company; Docket No. 9165; Completed 1990.  Members of ACG assisted the City of El Paso with the preparation of discovery, cross-examination, and testimony on class cost of service studies, affiliate transactions, excess capacity, off-system sales, financial integrity and rate moderation.  Class cost of service testimony examined allocation methodologies including demand versus energy factors, customer factors, administrative and general allocations, and the allocation of taxes; coincident peak and non-coincident peak methodologies; and asset and expense functionalization and categorization.

 

In Re: Washington Utilities and Transportation Commission vs. Puget Sound Power and Light Company; Case No. U-89-2688-T; Completed 1990.  Members of ACG assisted the Washington Utilities and Transportation Commission with an examination of prudence issues associated with the WNP-3 nuclear power plant.

 

In Re: Inquiry of the Public Utility Commission of Texas into the Prudence and Efficiency of the Planning and Management of the Construction of the South Texas Nuclear Project; Docket No. 6668; Completed 1989.  Members of ACG prepared discovery, testimony, and cross-examination questions in connection with the Commission’s review of the prudence of the South Texas Nuclear Project.

 

In Re: The Application of the El Paso Electric Company for a Rate Increase in Certain Municipalities in the State of Texas; Docket Number 635; Completed 1987.  Members of ACG assisted the City of El Paso with preparation of discovery; analysis of Company Minimum Filing Requirements; preparation of direct testimony on accounting issues, cost allocations, revenue requirement, and class cost of service issues; and preparation of cross-examination questions.

 

In Re: Application of Texas Utilities Electric Company for a Rate Increase; Docket No. 5640; Completed 1984.  On behalf of Texas Cities, members of ACG examined the request by Texas Utilities Electric Company for a rate increase. ACG prepared discovery, testimony, and cross-examination questions in connection with financial and accounting matters.

 

In Re: Application of the Connecticut Light and Power Company for an Increase in Rates and Revenues; Docket No. 83-07-15; Completed 1983.  On behalf of Connecticut Office of Consumer Counsel, members of ACG examined the request by Connecticut Light and Power Company for a rate increase. Members of ACG prepared discovery, testimony, and cross-examination questions in connection with financial and accounting matters.

 

 

Click here to return to our previous engagements.