Arkansas Public Service Commission Tariff ("TF") Docket Summary Cover Sheet
Transcription
Arkansas Public Service Commission Tariff ("TF") Docket Summary Cover Sheet
APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 Arkansas Public Service Commission Tariff ("TF") Docket Summary Cover Sheet Must be filed with each new TF docket filed at the Commission STYLE OF DOCKET: (Style may be changed by Secretary of Commission) IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND COST RATE RIDER DOCKET DESIGNATOR: TF LAST RATE CASE DOCKET: Docket Number: 07-085-TF 09-084-U Does this change company name: Yes No PETITIONER Entergy Arkansas, Inc. ATTORNEY(S’) NAME, ADDRESS, PHONE, FAX AND E-MAIL Mr. Matthew R. Suffern, Entergy Services, Inc., 425 W. Capitol Ave., P. O. Box 551, Little Rock, AR 72203, 501-377-5855, fax 501-3775426, msuffer@entergy.com Write a brief statement, limited to the space provided herein describing the case that you are filing. Please provide enough information to assure that the nature of your docket is clear. EAI requests APSC approval of the revisions to Rate Schedule No. 40, Energy Efficiency Cost Rate Rider (Rider EECR) Attachments A, B and C including the 2013 update to the Rider EECR Rates and Rate Calculation. EAI is also filing the supporting testimonies of Jeremy W. Champlin, Charles E. DeGeorge, and Margaret L. McCloskey. Pursuant to Rule 2.03(b), of the Commission's Rules of Practice and Procedure, please provide name, address, phone, fax, e-mail of at least one person, but not more than two, to appear on the Service List for this docket Mr. Matthew R. Suffern, Entergy Services, Inc., 425 W. Capitol Ave., P. O. Box 551, Little Rock, AR 72203, 501377-5855, fax 501-377-5426, msuffer@entergy.com; Steven K. Strickland, Entergy Arkansas, Inc., 425 W. Capitol Ave., P. O. Box 551, Little Rock, AR 72203, 501-377-4457, fax 501-377-4415, sstrick@entergy.com 1. Number of customers by class affected by this tariff change: Residential 583,968 ,Commercial 89,404 Industrial 20,609 Public Agencies, institutions or others 677 2. Company's current authorized retail revenue requirement: $38.6M current Rider EECR Revenue Requirement for 2012 3. Estimated annual retail revenue impact if proposal is approved, both in dollars and as a percentage of current retail revenue requirement: $24.5M or 63% 4. Estimated monthly impact on an average residential customer in both dollars and percentage increase: $1.44 increase for 1,000 kWh avg residential usage or 68.2% 5. Proposed effective date: June 1, 2013 or, if necessary, the first billing cycle of the month following APSC approval of EAI's Rider EECR Attachments A, B, and C. Form completed by: Matthew R. Suffern Representing: Entergy Arkansas, Inc. Date: 4-8-13 Entergy Arkansas, Inc. APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 425 West Capitol Avenue P. O. Box 551 Little Rock, AR 72203-0551 Tel 501 377 4457 Fax 501 377 4415 Steven K. Strickland Vice President Regulatory Affairs April 8, 2013 Ms. Kristi Rhude, Secretary Arkansas Public Service Commission P. O. Box 400 1000 Center Street Little Rock, AR 72203 Re: Docket No. 07-085-TF In the Matter of the Application of Entergy Arkansas, Inc. For Approval of Energy Efficiency Programs and Energy Efficiency Cost Rate Rider Dear Ms. Rhude: Please find attached for filing with the Arkansas Public Service Commission (APSC), Entergy Arkansas, Inc.’s (EAI or the Company) request for approval of the revised Rate Schedule No. 40, Energy Efficiency Cost Rate Rider (Rider EECR) Attachments A, B, and C reflecting the revised Rider EECR Rates and Rate Calculation. EAI has calculated its 2013 Rider EECR Rate using the estimated 2013 program costs as included in EAI’s Energy Efficiency Three-Year Plan approved by the Commission in Order No. 39 of the above referenced docket and adjusted as described in the Direct Testimony of Jeremy E. Champlin submitted in support of this filing. As explained by Mr. Champlin, EAI’s budget adjustments are within the APSC’s budget flexibility guidelines, with one exception. EAI has proposed to remove 17 percent of the original approved budget from the Energy Star New Homes Program and add the amount to the Multi-family Home Program. In accordance with the Order No. 39 budget flexibility directives, EAI requests Commission approval to remove more than 10 percent of the budget for the Energy Star New Homes Program. Additionally, Mr. Champlin describes the calculation of the Lost Contribution to Fixed Costs (LCFC) to be recovered through Rider EECR in accordance with the Commission’s Order No. 14 issued December 10, 2010 in Docket No. 08-137-U APSC FILED Time: Ms. Kristi Rhude April 8, 2013 Page 2 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 and the calculation of EAI’s incentive based on EAI’s 2012 program results in accordance with Order No. 15 issued December 10 in Docket No. 08-137-U. Additional details regarding the 2012 actual program costs and the calculation of LCFC and incentives is provided in the Company’s 2012 Energy Efficiency Program Portfolio Annual Report filed concurrently in this docket. Also submitted is the Direct Testimony of Charles E. DeGeorge, which describes the avoided energy and capacity costs used in the economic evaluation of EAI’s energy efficiency programs. Finally, EAI also submits the Direct Testimony of Margaret L. McCloskey, which supports the calculation of the Rider EECR rates. The revised Attachments A, B, and C are attached to Ms. McCloskey’s direct testimony as EAI Exhibit MLM-3. The monthly bill of a typical residential customer using 1,000 kWh per month would increase by $1.44 or 68.2 percent if the revised Rider EECR rates are approved. EAI respectfully requests Commission approval of the revised Rider EECR, Attachments A, B, and C and approval of the request to reduce the budget for the Energy Star New Homes Program by more than 10 percent. The terms of Rider EECR specify an effective date of the first billing cycle of June for redetermined rates. If the Rider EECR rates are not resolved in time for a June implementation, EAI requests APSC approval for an effective date of the first billing cycle of the month following approval of the Rider EECR. If you have any questions or need anything additional concerning this filing, please call me at (501) 377-4457 or Susan Davidson at (501) 377-5720. Work papers supporting the revised calculation of the tariff rates will be provided to parties in this docket via electronic mail and CDs. Sincerely, /s/ Steven K. Strickland SS/sd Attachments c: All parties of record w/ attachments APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF DIRECT TESTIMONY OF JEREMY W. CHAMPLIN PROJECT MANAGER ON BEHALF OF ENTERGY ARKANSAS, INC. APRIL 8, 2013 APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 I. INTRODUCTION AND BACKGROUND 2 Q. PLEASE STATE YOUR NAME, BUSINESS ADDRESS, EMPLOYER AND JOB TITLE. 3 4 A. My name is Jeremy W. Champlin. I am employed by Entergy Arkansas, 5 Inc. (“EAI” or the “Company”) as a Project Manager. My business address 6 is 425 West Capitol Avenue, Little Rock, Arkansas 72201. 7 8 Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 9 A. I am submitting this direct testimony to the Arkansas Public Service Commission (“APSC” or the “Commission”) on behalf of EAI. 10 11 12 Q. DESCRIBE YOUR WORK EXPERIENCES AND EDUCATIONAL BACKGROUND. 13 14 PLEASE A. I have a Bachelor of Science with an emphasis in Business Administration 15 from Arkansas State University and a Master of Business Administration 16 from Webster University. I am a certified Business Energy Professional. 17 Since 2003 I have worked in various areas within EAI and Entergy 18 Services, Inc. (“ESI”),1 including Customer Service, Work Force 19 Management, and Energy Efficiency. I have held numerous positions 20 including Customer Service Agent, Account Sales Associate, Senior 21 Customer Service Specialist and 1 Supervisor over Work Force ESI is a subsidiary of Entergy Corporation that provides technical and administrative services to the Entergy Operating Companies. The Entergy Operating Companies include EAI.; Entergy Gulf States Louisiana, L.L.C.; Entergy Louisiana, LLC (“ELL”); Entergy Mississippi, Inc.; Entergy New Orleans, Inc.; and Entergy Texas, Inc. -2- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 1 Management. 2 Integrated Resource Planning Group. 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 My current position is Project Manager within the 3 4 Q. WHAT ARE YOUR CURRENT DUTIES AS PROJECT MANAGER? 5 A. My current duties include identifying, developing, and implementing energy efficiency programs for EAI customers. 6 7 8 Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 9 A. The purpose of my direct testimony is to support EAI’s 2013 Energy 10 Efficiency Cost Rate Rider (“Rider EECR”) annual rate redetermination. In 11 my testimony, I provide a summary of the Company’s projected 2013 12 budget utilized in the rate redetermination calculation. I also provide a 13 summary of the actual costs for the program year 2012, which EAI 14 incorporated into its Rider EECR over/under recovery true-up calculation. 15 In addition, I explain the calculation of the estimated Lost 16 Contribution to Fixed Costs (“LCFC”) associated with EAI’s cumulative 17 2013 projected energy savings for its Energy Efficiency Programs and the 18 true-up of the 2012 LCFC estimate, consistent with the direction provided 19 by the Commission in Order No. 14 in Docket No. 08-137-U. 20 explain the calculation of EAI’s incentive amount associated with its 2012 21 program results in accordance with Order No. 15 in Docket No. 08-137-U. I also 22 In addition to my testimony, Margaret L. McCloskey, Manager, Fuel 23 and Special Riders for ESI, explains the calculation of the Rider EECR -3- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 rates that the Company is filing in the 2013 update. The revised Rider 2 EECR with Attachments A, B, and C is attached to Ms. McCloskey’s direct 3 testimony as EAI Exhibit MLM-3. 4 Manager, Supply Planning and Analysis for ESI’s System Planning and 5 Operations (“SPO”) organization,2 provides direct testimony describing the 6 avoided cost amounts used in the benefit-cost analyses. Additionally, Charles E. DeGeorge, 7 8 II. 2013 PROGRAM BUDGETS 9 Q. WHAT DOES THE PROJECTED 2013 PROGRAM BUDGET INCLUDE? 10 A. The Company’s 2013 budget utilized in the Rider EECR rate 11 redetermination calculation includes the estimated 2013 program costs for 12 the programs contemplated under EAI’s Three-Year Plan for the 2011- 13 2013 14 Commission in Order No. 39 issued in this docket on June 30, 2011, as 15 revised to reflect adjustments to program budgets based upon further 16 program design and third party implementer contract negotiations. The 17 2013 budget also includes EAI’s share of the Arkansas Weatherization 18 Program (“AWP”) funding amount for 2013 in accordance with EAI 19 program budget filed on March 1, 2011 and approved by the Commission 20 on June 30, 2011. 21 million plus all projections of additional allocated cost associated with EAI Program Years (the “Three-Year Plan”) approved by the This filing includes a projected AWP cost of $1.2 2 SPO provides various technical and administrative services to the Entergy Operating Companies, including procuring fuel and purchased power for the Entergy Operating Companies and operating and dispatching the generation resources of the Operating Companies. -4- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 administration; AWP database; projected evaluation, measurement, and 2 verification (“EM&V”) consultant cost; and allocation of the Independent 3 Evaluation Monitor (“IEM”) cost. 4 Arkansas (“EEA”) Program funding amount for 2013 is included in 5 accordance with the Third Amended Memorandum of Understanding filed 6 December 4, 2012 in Docket No. 07-083-TF and approved by the 7 Commission in Order No. 31 issued on December 31, 2012, including an 8 allocation of projected EAI administration and IEM cost based upon 9 allocation methodology directions provided in the Arkansas Energy Furthermore, the Energy Efficiency Efficiency Program.3 10 11 12 Q. WHAT IS THE PROJECTED SPENDING IN THE BUDGET FOR EACH 13 PROGRAM COMPARED TO THE BUDGET FOR 2013 INCLUDED IN 14 THE THREE YEAR PLAN? 15 A. Table 1 below shows the revised 2013 Annual Budget and the variance by program compared to the March 1, 2011 Three-Year Plan. 16 17 18 3 Arkansas Energy Efficiency Program Portfolio Annual Report Instructions, Section II. - EE Program Cost, subsection H. - Allocation Methodology. -5- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 Table 1 2013 Program Plan Final Budget Compared to Filed Budget 1 2 2013 Filed Budgets (ThreeYear Plan) ($000) EAI Programs 2013 Final Budget ($000) Difference ($000) Percent Difference to Overall Cost Residential Lighting and Appliances Residential & Small Commercial Cooling Solutions 4,319 4,447 128 2.96% 1,939 2,406 467 24.1% Home Energy Solutions 4,255 4,330 75 1.76% Energy Efficiency Arkansas 1,000 232 (768) (76.8%) AR Weatherization 1,200 1,279 79 6.58% Benchmarking 1,992 1,487 (505) (25.35%) 640 531 (109) (17.03%) 2,588 3,417 829 32% Mobile Homes 869 836 (33) (3.80%) Multifamily Direct Install 349 426 77 22.06% 12,694 12,956 262 2.06% 2,719 2,902 183 6.73% 12,006 11,333 (673) (5.61%) Agricultural Irrigation Load Control 4,006 4,131 125 3.12% Small Commercial Direct Install 1,401 1,677 276 19.7% 589 642 53 9% 52,566 53,032 466 0.89% ENERGY STAR Homes Direct Load Control C&I Prescriptive City Smart C&I Custom Agricultural Energy Solutions Total Portfolio 3 4 Q. PROGRAM BUDGET BY PROGRAM. 5 6 PLEASE EXPLAIN THE REASONS FOR THE VARIATION IN THE 2013 A. The 2013 budget variance is based upon final contract negotiations with 7 implementing contractors, EM&V contractors, database contractors, and 8 third-party auditors. 9 contractor support for the Technical Reference Manual (“TRM”) V3.0 In addition, the budget is increased to reflect -6- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 update that is required to be filed in 2013. The budgets also reflect 2 changes associated with revisions necessary to reflect the EEA revised 3 budgets reflected in the Third Memorandum of Understanding. 4 All program budgets were adjusted for additional EM&V cost, based 5 upon the final contract with Cadmus and ADM Associates for direct 6 program evaluation cost. 7 cost, and EAI’s share of the EM&V cost from Cadmus (EAI and 8 Southwestern Electric Power Company both contracted with Cadmus) 9 were allocated to each program based upon the ratio of each program’s The final contracted database cost, the IEM budget to the sum of the total budget. 10 11 12 Q. IS EAI REQUESTING A REVISION IN ANY PROGRAM BUDGETS? 13 A. Yes. EAI is requesting additional budget amounts in 2013 to 14 accommodate more robust EM&V for the Residential Load Control 15 Program at the request of independent evaluator, Cadmus. 16 Further, EAI is requesting to increase administration budgets by 17 $200,000 to initiate more awareness for all programs. 18 continue to grow within EAI’s service territory, the 2012 independent 19 evaluation report from Cadmus indicated that additional awareness efforts 20 of all programs, and especially the residential and small business 21 programs would be beneficial, and is needed to drive more market activity, 22 provide support for the trade allies, and help customers differentiate -7- As programs APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 between EAI energy efficiency programs and possible efforts to defraud 2 customers by scammers. 3 EAI’s final budget adjustments are within the budget variance 4 directives in Order No. 39 in Docket No. 07-085-TF4 with the exception of 5 the Energy Star New Homes Program. This is due to the anticipation of 6 poor new home construction projects that was also experienced in 2012. 7 EAI has proposed to remove 17 percent of the original approved budget 8 from that program and increase the Multi-family Home Program by 22 9 percent. In accordance with the Order No. 39 budget flexibility directives, 10 EAI requests Commission approval to remove more than 10 percent of the 11 budget for the Energy Star New Homes Program to the Multi-family Home 12 Program. 13 14 Q CAPITAL COSTS? 15 16 WHAT PORTION OF THE 2013 PROJECTED PROGRAM COSTS ARE A. The 2013 projected program costs include $2,417,415 of capital costs 17 associated with the development of software and installation of the 18 equipment and facilities for EAI’s Agricultural Irrigation Load Control 19 (“AILC”) Program. 20 4 The APSC issued Order No. 72 in this docket on November 16, 2012, approving EAI’s request to extend the budget flexibility provided by Order No. 39 to the 2013 program year. -8- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 III. 2012 ACTUAL PROGRAM COSTS 2 Q. WHAT WERE THE ACTUAL AND BUDGETED EXPENDITURES FOR THE 2012 PROGRAM YEAR? 3 4 A. The actual incremental expenditures recoverable through Rider EECR for 5 the 2012 program year totaled $28,515,019. The 2012 budget was 6 $39,609,138. EAI’s Energy Efficiency Program Portfolio Annual Report for 7 the 2012 program year filed concurrently in this docket provides a detailed 8 description of the 2012 program year results. 9 10 Q COSTS? 11 12 WHAT PORTION OF THE 2012 PROGRAM COSTS WERE CAPITAL A. The 2012 actual costs include $2,845,809 of capital expenditures 13 associated with the installation of the equipment and facilities for EAI’s 14 AILC Program. 15 16 Q. EXPENDITURES FOR ITS ENERGY EFFICIENCY PROGRAMS? 17 18 WHAT PROCESSES DID EAI UTILIZE TO TRACK THE ACTUAL A. EAI developed project codes to capture both the non-incremental and the 19 incremental5 costs associated with each program. These project codes 20 were shared with departments that are involved with a particular 21 program’s development and implementation so that program costs could 5 Section 7 of the Rules for Conservation and Energy Efficiency Programs provides that cost recovery shall be limited to the incremental costs which represent the direct program costs that are not already included in the then current rates of the utility. -9- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 be charged to the appropriate code. The project codes established for the 2 AILC Program included a separate project code to accumulate the 3 incremental capital expenditures. 4 5 IV. BENEFIT-COST TEST RESULTS 6 Q. WHAT WERE THE PROJECTED BENEFIT-COST ANALYSIS RESULTS FOR THE 2013 PROGRAM YEAR? 7 8 A. The 2013 program year with the updated budgets described above, results in a projected portfolio net benefit of $24,758,065 and a benefit- 9 cost ratio of 1.27 based upon Total Resource Cost (“TRC”) Test. 10 11 12 Q WHAT WERE THE BENEFIT-COST ANALYSIS RESULTS FOR 2012? 13 A. EAI performed a benefit-cost test on the evaluated savings for the 2012 14 program year. The TRC Test remained positive with a TRC net present 15 value of $9,975,512 and a TRC ratio of 1.23. Of the 15 programs, 9 16 programs achieved a TRC ratio above 1.0 with 6 programs falling below. 17 As discussed last year, the primary concern for these benefit-cost analysis 18 results are due to low avoided cost. Further, the TRC Test results for 19 three programs, Energy Star New Homes, Residential Benchmarking and 20 Agricultural Energy Solutions, were below due to market conditions and/or 21 a late start in the market due to the length of time required to conduct 22 thorough due diligence prior to completing contracts with third-party 23 implementers to ensure that customer information is protected. The cost - 10 - APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 effectiveness of the Energy Solutions Manufactured Homes Program was 2 greatly affected by the change in avoided cost, as well as a lower than 3 expected net-to-gross (“NTG”) ratio. 4 changes to this program so that it can achieve more cost effective results. In any case, EAI is considering 5 The AILC Program had a TRC ratio of 0.98 due to unexpected 6 customers opting out due to severe drought. Commercial & Industrial 7 (“C&I”) Custom Solutions Program received evaluation results that did not 8 capture all of the savings associated with EAI’s costs for that program, a 9 result that was not and could not have been anticipated. EAI’s 2012 Annual Report filed concurrently in this docket provides 10 more details on each program 11 12 13 V. CALCULATION OF LCFC 14 Q. HOW DID EAI CALCULATE THE LCFC FOR EACH PROGRAM YEAR? 15 A. LCFC is a cumulative amount based on the LCFC for individual program 16 years, which are accumulated until the Company implements new base 17 rates as a result of a general rate case decision. Upon the implementation 18 of new base rates the cumulative portion of the LCFC calculation is reset. 19 With EAI’s base rate filing made March 1, 2013 (Docket No. 13-028-U), 20 this effectively means that, from a cumulative perspective, EAI’s LCFC 21 calculation will reset. 22 Each year, the LCFC for the current program year is based on the 23 projected energy savings targets approved in the Company’s energy - 11 - APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 efficiency program plan (“Projected LCFC”). The target is adjusted based 2 upon the First Year Monthly Curve Ratio to reflect the timing of measures 3 installed throughout a calendar year from industry best practice 4 programs.6 The adjustment based upon the First Year Monthly Curve 5 Ratio then is used to reduce the potential for over-collection of LCFC 6 associated with all energy efficiency program measures being installed 7 throughout the first calendar year. The adjusted projected energy savings 8 are then multiplied by the average rate class annualized Lost Contribution 9 Rate (“Average LCR”). The Average LCR is the base rate revenues less 10 customer charge revenues calculated on a dollar per kWh basis, using the 11 Company’s most recently approved base rates. 12 The current program year LCFC also includes the prior years’ full 13 year LCFC amounts for each program year accumulated since base rates 14 were last set. The prior years’ LCFC amounts are calculated based on the 15 actual evaluated energy savings achieved, on a measure by measure 16 basis, multiplied by the seasonal rate schedule base rates less customer 17 charges (“Seasonal LCR”). The prior years’ measures are reviewed and 18 adjusted if the efficiency measures installed have reached the end of their 19 lives. 20 Also, each year, the prior year’s LCFC amount is trued-up. The 21 projected portion of the prior year’s LCFC is recalculated based on actual 6 The First Year Monthly Curve Ratio is a ratio developed by ICF International specifically for EAI to adjust the projected annual energy savings to reflect the number of months the measures are installed during the first year of the life of the measures. The last year of the life of the measures will be adjusted during the annual true-up process. - 12 - APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 evaluated energy savings achieved adjusted to reflect the measure 2 installed date, multiplied by the Seasonal LCR. 3 4 Q. WHAT IS THE 2013 LCFC? 5 A. As I explained above, the 2013 LCFC includes the projected 2013 LCFC 6 and the full year trued-up LCFC for 2011 and 2012. The 2013 first year 7 estimated LCFC is $2,530,087. The 2011 full year LCFC is $1,917,064. 8 The 2012 full year LCFC is $4,952,694. The cumulative total 2013 LCFC 9 is $9,399,844. 10 11 Q. WHAT IS THE 2012 TRUED-UP LCFC ? 12 A. As I explained above, the 2012 LCFC includes the true-up of the projected 13 2012 program year LCFC and the full year trued-up LCFC for 2011. The 14 2012 prorated trued-up LCFC is $1,410,888. The 2011 full year LCFC is 15 $1,917,064. The cumulative total LCFC for 2012 is $3,327,951. 16 The 2012 true-up prorated LCFC is less than the projected 2012 17 prorated amount because some programs were implemented later than 18 planned due to the length of time required to conduct thorough due 19 diligence prior to completing contracts with third-party implementers to 20 ensure that customer information is protected. Further, the timing of the 21 2012 actual measure installations were different than the installation 22 curves projected. More of the energy efficiency measures were installed - 13 - APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 later in the year than originally planned. The 2012 Annual Report contains 2 a more detailed discussion of the 2012 program results. 3 4 VI. INCENTIVE CALCULATION 5 Q. DID EAI’S 2012 PROGRAM YEAR ENERGY SAVINGS PERFORMANCE 6 TOWARD THE COMMISSION’S ENERGY SAVINGS TARGETS ALLOW 7 THE COMPANY TO EARN A UTILITY PERFORMANCE INCENTIVE 8 AWARD? 9 A. Yes. Q PLEASE DESCRIBE EAI’S CALCULATION OF THE PERFORMANCE 10 11 12 INCENTIVE INCLUDED IN ITS REQUEST FOR RECOVERY THROUGH 13 RIDER EECR. 14 A. In Order No. 15 of Docket No. 08-137-U, the APSC provided directives as 15 to both the qualification and calculation of incentives. Under that order, 16 the program year evaluated savings results must meet at least 80 percent 17 of the goal established by the Commission for a utility to qualify for an 18 incentive. The calculation includes a shared savings amount based upon 19 10 percent of the portfolio Net Present Value of the TRC Test, but not to 20 exceed 5 percent of portfolio budget if evaluated goal achievement is at 21 least 80 percent up to 100 percent and not to exceed 7 percent of portfolio 22 budget for evaluated goal achievement at 100 percent up to 110 percent. - 14 - APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Jeremy W. Champlin Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 EAI’s target for 2012 was 96,694 MWh of energy reductions.7 EAI’s 2 evaluated energy savings for 2012 is 107,627 MWh before line loss 3 adjustments.8 This result of 111 percent of target qualifies EAI to obtain 4 incentives. Because EAI achieved over 100 percent target, the Company 5 qualifies at the program cost cap of 7 percent. The 7 percent cap is 6 applied to the final 2012 program budget of $39,609,138 resulting in a 7 maximum possible incentive of $2,772,640. The program portfolio Net 8 Benefits based on Total Resource Cost analysis for 2012 was $9,975,512 9 and the shared savings of 10 percent is $997,551. Because the shared 10 saving amount is the less than the 7 percent cost cap, EAI’s incentive 11 amount is $997,551. EAI included this incentive amount in the total costs 12 to be included in the EECR recovery amount. 13 14 Q. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? 15 A. Yes, it does. 7 EAI’s energy savings target for 2012 of 105,413 MWh as reported in EAI’s Three-Year Plan is reduced to reflect the impact of the Self-Direct customer’s exempted usage as provided by the APSC’s Rules for Conservation and Energy Efficiency Programs, Section 11, subsection O. 8 EAI’s evaluated energy savings results reflect the application of NTG adjustments as directed by the Commission. See Docket No. 07-152-U, Order No. 7; Docket No. 08-137-U, Order No. 16; Docket No. 08-144-U, Order No. 18; Docket No. 10-010-U, Order No. 13; Docket No. 10-100-R, Order No. 1; Docket No. 10-101-R, Order No. 2 at 16-17 (collectively December 10, 2010). - 15 - APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 CERTIFICATE OF SERVICE I, Steven K. Strickland, do hereby certify that a copy of the foregoing has been served upon all parties of record by forwarding the same by electronic mail and/or first class mail, postage prepaid this 8th day of April 2013. /s/ Steven K. Strickland Steven K. Strickland APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF DIRECT TESTIMONY OF MARGARET L. MCCLOSKEY MANAGER, FUEL & SPECIAL RIDERS ENTERGY SERVICES, INC. ON BEHALF OF ENTERGY ARKANSAS, INC. APRIL 8, 2013 APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Margaret L. McCloskey Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 I. INTRODUCTION 2 Q. PLEASE STATE YOUR NAME. 3 A. My name is Margaret L. McCloskey. Q. ARE YOU THE SAME MARGARET L. MCCLOSKEY WHO FILED 4 5 TESTIMONY PREVIOUSLY IN THIS DOCKET? 6 A. Yes, I am 9 Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 10 A. I am submitting this direct testimony to the Arkansas Public Service 7 8 11 Commission (“APSC” or the “Commission”) on behalf of Entergy 12 Arkansas, Inc. (“EAI” or the “Company”). 13 14 Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 15 A. My direct testimony describes the calculation of the rates that the 16 Company is filing in the 2013 update to EAI’s Rate Schedule No. 40, 17 Energy Efficiency Cost Rate Rider (“Rider EECR”), including EAI’s rate 18 class recovery allocation methodology as well as the Lost Contribution to 19 Fixed Costs (“LCFC”) and incentives. Attached as EAI Exhibit MLM-3 are 20 proposed Attachments A, B, and C, which reflect the Rider EECR Rates 21 and rate calculation for the billing period June 2013 through May 2014. 22 23 -2- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Margaret L. McCloskey Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 II. RIDER EECR TARIFF REVISION 2 Q. WHAT METHOD DOES THE COMPANY PROPOSE TO USE TO 3 ALLOCATE THE COSTS OF 4 PROGRAMS AND LCFC TO THE RATE CLASSES? 5 A. ITS 2013 ENERGY EFFICIENCY EAI proposes to allocate the costs of its 2013 Energy Efficiency Programs 6 and the LCFC using the production demand allocation factor (“PDAF”) 7 approved in the Company’s most recent rate case adjusted to remove the 8 customer accounts that are exempt from the Rider EECR charge for the 9 Filing Year based on the Certificates of Exemption currently approved by the Commission pursuant to the Self-Direct Option. 10 11 12 Q. WAS THE PDAF SELECTED AS THE ALLOCATION METHODOLOGY FOR RIDER EECR? 13 14 WHY A. EAI’s Energy Efficiency Programs and the related LCFC provide 15 significant benefits, including the reduction in demand-related production 16 costs. Production costs are allocated based on either demand or energy, 17 and because these costs are demand-related, it is appropriate to use the 18 PDAF to allocate these costs. 19 methodology used to allocate costs in the prior year’s Rider EECR rate 20 calculation including the adjustment for the Self-Direct Option as 21 described above. This is consistent with the allocation 22 -3- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Margaret L. McCloskey Docket No. 07-085-TF 1 Q. DOES THE REVENUE REQUIREMENT INCLUDE RECOVERY OF CAPITAL COSTS? 2 3 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 A. Yes. In EAI Exhibit MLM-3, EAI has included a revenue requirement 4 calculation associated with incremental capital costs incurred in 5 connection with EAI’s Agricultural Irrigation Load Control (“AILC”) 6 Program1 and included that revenue requirement within the total revenue 7 requirement for EAI’s energy efficiency programs to be recovered through 8 the redetermined Rider EECR rate for 2013. 9 Consistent with the methodology used in prior years’ Rider EECR 10 updates, the AILC revenue requirement is the sum of the return on rate 11 base calculated by applying the before-tax rate-of-return on rate base as 12 approved in Docket No. 09-084-U to the average rate base and the 13 projected average amortization of the AILC rate base for 2013. 14 15 Q. RIDER EECR RATE. 16 17 PLEASE DESCRIBE THE CALCULATION OF THE REDETERMINED A. The redetermined Rider EECR rate is calculated by summing the 2013 projected Energy Efficiency Program costs, cumulative LCFC, and energy 18 1 The APSC issued Order No. 8 on December 28, 2010 in Docket No. 08-072-TF, approving EAI’s Irrigation Load Control Program budgets for capital and expenses for the program years 2011 and 2012. In Order No. 39, issued in Docket No. 07-085-TF on June 30, 2011, the APSC approved EAI’s AILC Program and budgets for program years 2011-2013 which incorporated the 2011 and 2012 AILC budgets approved in Docket No. 08-072-TF. In addition, the APSC approved the transfer of the AILC Program to Docket No. 07-085-TF and the closing of Docket No. 08-072-TF. -4- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Margaret L. McCloskey Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 efficiency program incentives, plus or minus an over/under recovery true- 2 up adjustment, and then multiplying this total by the rate class allocation 3 factor PDAF including the adjustment for the Self-Direct Option as 4 described above. These amounts by rate class are then divided by the 5 projected energy sales for each rate class adjusted to remove the 6 customer accounts that are currently exempt from the Rider EECR charge 7 in order to determine the rate adjustment by rate class. 8 9 Q. THE REDETERMINED RIDER EECR RATE? 10 11 WHAT IS THE CUSTOMER IMPACT OF THE PROPOSED CHANGE IN A. A typical monthly residential bill for a 1,000 kWh energy usage would 12 increase by $1.44. The impact on the rate for each rate class is shown in 13 Table 1 below. 14 Table 1 15 2013 Rider EECR Update Rate Class Impact 16 Rate Class 2013 2012 Change Residential $0.00355/kWh $0.00211/kWh $0.00144/kWh Small General Service $0.00355/kWh $0.00209/kWh $0.00146/kWh Large General Service $0.00287/kWh $0.00178/kWh $0.00109/kWh Lighting $0.00186/kWh $0.00110/kWh $0.00076/kWh -5- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Margaret L. McCloskey Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 Q. HOW MANY CUSTOMERS WILL BE AFFECTED BY THIS CHANGE? 2 A. The number of EAI customers affected by this rate change at the end of 3 February 2013 was 694,658. This number excludes those customers that 4 are currently exempt under the Self-Direct Option as explained above. 5 6 Q. WHAT IS THE TOTAL REVENUE IMPACT OF THIS REVISION? 7 A. The total projected amount to be collected over the period June 2012 8 through May 2013 by the previously approved Rider EECR was 9 $38,592,488. The redetermined revenue requirement amount proposed 10 to be collected during the period June 2013 through May 2014 is 11 $63,086,302. This is an increase in the requested Rider EECR recovery 12 amount of $24,493,814 or 63 percent. 13 14 Q. WILL THE REDETERMINATION RESULT IN ANY CHANGE IN RATE 15 DESIGN WHICH WILL RESULT IN ANY CHANGE IN REVENUE 16 ALLOCATION WITHIN A CLASS OR BETWEEN CLASSES? A. No. 19 Q. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? 20 A. Yes, it does. 17 18 -6- APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 CERTIFICATE OF SERVICE I, Steven K. Strickland, do hereby certify that a copy of the foregoing has been served upon all parties of record by forwarding the same by electronic mail and/or first class mail, postage prepaid this 8th day of April 2013. /s/ Steven K. Strickland Steven K. Strickland APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF EAI EXHIBIT MLM-3 REVISED ENERGY EFFICIENCY COST RATE RIDER AND ATTACHMENTS A, B, AND C APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: DocketNo.: 07-085-TF-Doc. 380 Docket 07-085-TF Order No.: Effective: 5/30/13 Attachment A to Rate Schedule No. 40 Page 1 of 2: Schedule Sheet 4 of 7 ATTACHMENT A ENERGY EFFICIENCY COST RECOVERY TARIFF (RIDER EECR) Line Recoverable Costs Program Costs Set forth in workpapers 1 Projected Energy Efficiency Program Costs (PEEC) $52,092,646 2 Projected Lost Contribution to Fixed Costs (LCFC) $9,399,844 (RT, CR) (CR) 3 EE Program Incentives (EEPI) $997,551 4 Prior Period Over/Under Amount (TUA)* $596,261 (CR) $63,086,302 (CR) 5 Recoverable Costs (PCRC)** (1+2 + 3 + 4) 6 Billing Units (PES)*** See Attachment C 7 Rider EECR Rate (5/6) See Attachment C * The prior period true-up adjustment (TUA) includes carrying costs as approved by the Commission. ** Projected Costs by Rate Class or “PCRC” includes the total of (1) the projected EECR Incremental Program Costs for the Filing Year (PEEC); (2) the projected LCFC for the Filing Year (LCFC); (3) the incentive earned during the Reporting Year (EEPI) ; and (4) the prior period true-up adjustment (TUA). This total is allocated to the rate classes using PDAF (see Note 4 below). *** Projected Energy Sales by kWh or “PES” includes the projected sales by rate class (see Note 6 below). (AT) APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: DocketNo.: 07-085-TF-Doc. 380 Docket 07-085-TF Order No.: Effective: 5/30/13 Attachment A to Rate Schedule No. 40 Page 2 of 2: Schedule Sheet 5 of 7 ENERGY EFFICIENCY COST RECOVERY TARIFF (CONT'D) NOTES: 1) The Company’s work papers shall provide the rationale for the particular billing units selected and for the assignment of the Recoverable Costs to the rate classes. 2) The Projected Energy Efficiency Cost Period is the twelve-month period commencing on January 1 of the Filing Year. 3) The Energy Efficiency Cost Period is the calendar year immediately preceding the Filing Year. 4) The Production Demand Allocation Factor (“PDAF”) represents each rate class allocation relative to the retail jurisdiction total and shall be the most recently approved for EAI by the Commission in a non-appealable final order, adjusted to remove the customer accounts that are exempt from the Rider EECR charge for the Filing Year based on Certificates of Exemption currently approved by the Commission pursuant to the Self-Direct Option. 5) The Carrying Charge Rate shall be the authorized rate of return on rate base most recently approved for EAI by the Commission in a non-appealable final order. 6) The Projected Energy Sales by kWh billed for each rate class (PESi) for the Projected Energy Efficiency Cost Period, adjusted to remove the customer accounts that are exempt from the Rider EECR charge for the Filing Year based on the Certificates of Exemption currently approved by the Commission pursuant to the Self-Direct Option. THIS SPACE FOR PSC USE ONLY (AT) APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: DocketNo.: 07-085-TF-Doc. 380 Docket 07-085-TF Order No.: Effective: 5/30/13 Attachment B to Rate Schedule No. 40 Page 1 of 1: Schedule Sheet 6 of 7 ATTACHMENT B RIDER EECR RATES Applicable through May 2014 (CT) The Net Monthly Rates set forth in EAI’s schedules identified below will be adjusted by the following Rate Adjustment amounts: Rate Class Rate Schedules Rate Adjustment Residential RS, RT, REMT $0.00355 per kWh (CR) Small General Service SGS,GFS, TSS, MP, AP, CGS CTV, SMWHR $0.00355 per kWh (CR) Large General Service LGS, LPS, GST PST, SSR $0.00287 per kWh (CR) Lighting L1, L1SH, L4 $0.00186 per kWh (CR) THIS SPACE FOR PSC USE ONLY APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: DocketNo.: 07-085-TF-Doc. 380 Docket 07-085-TF Order No.: Effective: 5/30/13 Attachment C to Rate Schedule No. 40 Page 1 of 1: Schedule Sheet 7 of 7 ATTACHMENT C Rider EECR Rate Calculation Rate Class PCRCi1 PESi2 Rate Adjustments3 Residential $28,212,510 7,954,833,502 $0.00355 per kWh (CR) Small General Service $16,196,524 4,567,809,919 $0.00355 per kWh (CR) Large General Service $18,195,730 6,346,030,839 $0.00287 per kWh (CR) $481,538 258,967,366 $0.00186 per kWh (CR) $63,086,302 19,127,641,626 Lighting Total (CR) Notes: (1) Projected Energy Efficiency Cost by Rate Class (PCRCi). (2) Projected Energy Sales by kWh billed for each rate class (PESi) for the Projected Energy Efficiency Cost Period, adjusted to remove the customer accounts that are exempt from the Rider EECR charge for the Filing Year based on the Certificates of Exemption currently approved by the Commission pursuant to the Self-Direct Option. (3) The Rider EECR Rate is PCRCi / PESi. (CT) APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF DIRECT TESTIMONY OF CHARLES E. DEGEORGE MANAGER, SUPPLY PLANNING & ANALYSIS ENTERGY SERVICES, INC ON BEHALF OF ENTERGY ARKANSAS, INC. APRIL 8, 2013 APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 I. INTRODUCTION AND BACKGROUND 2 Q. PLEASE STATE YOUR NAME, TITLE, AND BUSINESS ADDRESS. 3 A. My name is Charles E. DeGeorge. I am employed by Entergy Services, 4 Inc. (“ESI”),1 as Manager, Supply Planning and Analysis for the System 5 Planning and Operations (“SPO”) organization.2 My business address is 6 10055 Grogans Mill Road, Parkwood II Building, Suite 150, The 7 Woodlands, Texas, 77380. 8 9 Q. ON WHOSE BEHALF ARE YOU TESTIFYING? 10 A. I am testifying on behalf of Entergy Arkansas, Inc. (“EAI” or the “Company”). 11 12 13 Q. PLANNING AND ANALYSIS? 14 15 WHAT ARE YOUR RESPONSIBILITIES AS MANAGER, SUPPLY A. My current job responsibilities include long-term supply-side resource 16 planning for the Entergy Operating Companies, including EAI. 17 function I manage a staff that performs engineering and economic 18 analyses of the capacity and energy supply requirements of the Entergy 1 In this ESI is a subsidiary of Entergy Corporation that provides technical and administrative services to all the Entergy Operating Companies, which, in addition to Entergy Arkansas, Inc., include: Entergy Gulf States Louisiana, L.L.C. (“EGS”); Entergy Louisiana, LLC (“ELL”); Entergy Mississippi, Inc. (“EMI”); Entergy New Orleans, Inc. (“ENO”); and Entergy Texas, Inc. (“ETI”). 2 SPO provides various technical and administrative services to the Entergy Operating Companies, including procuring fuel and purchased power for the Entergy Operating Companies and operating and dispatching the generation resources of the Operating Companies. -2- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 Electric System3 in order to provide a reliable and economical resource 2 portfolio. 3 proposals for supply-side resources (“RFPs”) issued on behalf of the 4 Entergy Operating Companies since 2002 and have managed the 5 evaluation process for numerous RFPs since 2004. I participated in the 6 Summer 2009 Request For Proposals for Long-Term Supply-Side 7 Resources (“Summer 2009 RFP”) as a member of the Summer 2009 RFP 8 Economic Evaluation Team (“EET”), which led to the selection of the 9 KGen Hot Spring Energy Facility. I have been involved in each Integrated 10 Resource Plan developed for the Entergy Electric System and the 11 Operating Companies since 2006, as well as the 2012 EAI Integrated 12 Resource Plan. I have been involved in the evaluation of each request for 13 14 Q. DESCRIBE YOUR BUSINESS EXPERIENCE AND EDUCATION. 15 16 PLEASE A. Over the last 26 years, I have worked for ESI in various planning 17 positions, including regional planning, long-term generation planning, 18 operational generation planning, long-term transmission planning, and 19 operational transmission planning. I became Manager, Supply Planning & 20 Analysis in October 2004. I have a Master’s Degree in Business 3 The Entergy Electric System is comprised of the generation and bulk transmission facilities of the Operating Companies, which facilities are operated as a single, integrated electric system. EAI’s participation in the System Agreement will terminate effective December 18, 2013. -3- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 Administration from Texas A&M University and a Bachelor of Science 2 Degree in Electrical Engineering from the University of New Orleans. I am 3 a registered Professional Engineer in Arkansas, Louisiana, Mississippi, 4 and Texas. 5 6 Q. COMMISSION? 7 8 HAVE YOU PREVIOUSLY TESTIFIED BEFORE A REGULATORY A. Yes. I have testified before the Arkansas Public Service Commission 9 (“APSC” or the “Commission”), the Council of the City of New Orleans, the 10 Louisiana Public Service Commission, and the Public Service Commission 11 of Texas. 12 CED-1. A listing of my prior testimonies is included in EAI Exhibit 13 14 Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 15 A. My direct testimony provides estimates of avoided energy and capacity 16 costs that were requested by EAI to support the economic evaluation of 17 the Company’s energy efficiency Programs. 18 assumptions, models, and processes used to develop these avoided cost 19 estimates. 20 -4- I will describe the APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 II. AVOIDED COSTS 2 Q. WHAT ANALYSES AND ESTIMATES DID EAI REQUEST FROM ESI? 3 A. EAI requested estimates of avoided costs of energy and capacity for 2012 4 – 2035 for the express purpose of performing the economic evaluation of 5 the energy efficiency programs proposed by EAI for deployment in 2012 – 6 2013. 7 8 Q. ENERGY COSTS? 9 10 WHAT ANALYSES WERE PERFORMED TO ESTIMATE THE AVOIDED A. The analyses were divided into two time frames to estimate the avoided 11 energy cost. The first time frame, 2012 and 2013, represents the period 12 when EAI is still a participant in the Entergy System Agreement and is not 13 yet a participant in a Regional Transmission Organization (“RTO”). The 14 second time frame, 2014 and beyond, represents the period when EAI no 15 longer participates in the Entergy System Agreement and is assumed to 16 be a participant in the Midwest Independent Transmission System 17 Operator, Inc. (“MISO”) RTO. 18 19 Q. TIME FRAME, THE 2012 AND 2013 PERIOD. 20 21 PLEASE DESCRIBE THE ANALYSIS PERFORMED FOR THE FIRST A. The avoided energy cost for this time period is based on the SPO hourly 22 spot market, economy purchase price curve because it is representative of 23 the price of power available for purchase by the Entergy System during -5- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 this time period. The analysis uses the hourly Market Clearing Price 2 forecast for the SERC Delta Region from the Ventyx Spring 2012 SE 3 Region Reference Case. 4 developed SPO June 2012 Henry Hub Forecast of natural gas prices. 5 This resulting economy purchase price curve is used in production costing 6 simulations as representative of the hourly spot market available for 7 purchase by the Entergy Electric System and, in practice; economy 8 energy purchases that are made or that are rejected determine the 9 avoided cost of energy in many hours. This forecast is calibrated to the internally 10 11 Q. COST FOR 2014 AND BEYOND? 12 13 WHAT ANALYSIS WAS USED TO ESTIMATE THE AVOIDED ENERGY A. The AURORAxmp Electric Market Model (“AURORA”) model was used to 14 simulate market operations and produce a long-term forecast of the 15 Locational Marginal Price (“LMP”) for the EAI commercial pricing zone as 16 part of operating in the MISO Day 2 Market.4 AURORA estimates price 17 and dispatch using hourly demands and individual resource-operating 18 characteristics in a transmission-constrained, chronological dispatch 19 algorithm. 4 Day 2 Markets are centralized region-wide markets operated by RTOs that include day ahead unit commitments, a real time balancing market, and an integrated ancillary services market. In a Day 2 Market, generators are required to schedule or bid into the market, locational marginal prices are used to price the use of the transmission grid, congestion charges replace “first come, first served” transmission service, and financial transmission rights are used to hedge congestion. The “Day 2” label arose because these are things that RTOs began to implement after they initially began to operate, or in Day 2 of their creation. -6- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 2 Q. WHAT IS MEANT BY LOCATIONAL MARGINAL PRICE? 3 A. If EAI’s application to transfer control of its transmission assets to the 4 MISO RTO is approved, the MISO will determine the amount of energy 5 generated by each of EAI’s units. 6 commitment and dispatch for the other generating units that participate in 7 the MISO Day 2 Market. 8 generating unit in the market. 9 market commitment and dispatch, AURORA forecasts both unit-level MISO will, similarly, determine the MISO will then calculate a LMP for each Through the simulation of centralized operation and LMPs. 10 11 12 Q. ENERGY COST? 13 14 HOW ARE LMPs USED TO DEVELOP ESTIMATES OF AVOIDED A. The Aurora model estimates the hourly LMP for each commercial pricing 15 zone of the MISO South footprint. EAI is divided into two load zones 16 representing EAI North Arkansas and EAI Central. A composite LMP for 17 the EAI load zones is determined by taking the load weighted share of the 18 EAI North Arkansas hourly LMP and the EAI Central hourly LMP. The 19 resulting EAI zone LMP is representative of the avoided cost of energy 20 available to EAI each hour based on participation in the MISO Day 2 21 Market. 22 -7- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 1 Q. WHAT OTHER STEPS WERE DONE TO DETERMINE THE AVOIDED ENERGY COST ESTIMATES? 2 3 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 A. For both time periods, 2012 – 2013 and 2014 - 2035, once the hourly 4 avoided energy cost is determined, an avoided energy cost by time period 5 for each year is calculated by averaging all of the hourly prices within each 6 time period. The results of these analyses are the avoided energy cost 7 estimates, which are provided in highly sensitive EAI Exhibit CED-2. 8 9 Q. ESTIMATE? 10 11 WHAT IS THE BASIS FOR THE AVOIDED CAPACITY COST A. The avoided capacity cost is based on the installed cost of a new 12 combustion turbine (“CT”), which is assumed to be the lowest cost long- 13 term alternative for new capacity that is under the control of EAI. SPO 14 estimated the installed cost of a CT based on the Technology Assessment 15 Guide, which is licensed from the Electric Power Research Institute. To 16 adjust the CT cost for commencing commercial operations in future years, 17 SPO used the CT Capital Cost Real Escalation Rate from IHS CERA 18 Capital Cost Analysis Forum – Power, “Power Capital Cost Index 19 Projection – North America” November 2012 and SPO’s macroeconomic 20 forecast of Gross Domestic Product. Using this approach, the installed 21 cost of a CT is determined for each year of the period 2012 – 2035 and an 22 annual levelized CT revenue requirement is determined by applying a 23 levelized fixed charge rate that is calculated for a CT. -8- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 1 2 Q. WHAT OTHER ADJUSTMENTS TO THE ANNUAL LEVELIZED CT 3 COST ARE INCLUDED FOR PURPOSES OF ASSESSING ENERGY 4 EFFICIENCY PROGRAMS? 5 A. In addition to the installed cost of a CT, the reduction of demand through 6 energy efficiency programs may also potentially avoid transmission and 7 distribution line losses and capacity needed to meet reliability reserve 8 margins. 9 installed CT cost was grossed up by a line loss percentage determined for 10 residential, commercial, industrial, and total retail customer classes. 11 Similarly, to adjust for capacity needed to meet reliability reserve margins, 12 the installed CT cost was grossed up by the reserve margin assumed to 13 be needed by time period. For 2012 – 2013, the reserve margin is 16.85 14 percent based on EAI’s participation in the System Agreement, which is 15 the reserve margin target established for the Entergy Electric System. 16 Beginning with 2014, assuming participation in the MISO RTO, the 17 reserve margin is 12 percent based on historical reserve margin 18 requirements determined by MISO. The result of these adjustments is to 19 increase the installed CT cost by an amount needed to offset the cost of 20 line losses and reliability reserve margins. To adjust for transmission and distribution line losses, the 21 -9- APSC FILED Entergy Arkansas, Inc. Time: 4/8/2013 11:08:44 AM: Recvd Direct Testimony of Charles E. DeGeorge Docket No. 07-085-TF 1 Q. 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 ARE OTHER COSTS POTENTIALLY AVOIDED BY REDUCTION IN 2 DEMAND THROUGH ENERGY EFFICIENCY PROGRAMS THAT ARE 3 REFLECTED IN THE AVOIDED CAPACITY COST ESTIMATE? 4 A. Yes. In addition to the installed CT cost grossed up for line losses and 5 reserve margin requirements, transmission and distribution investment 6 may be avoided. An estimate of avoided transmission and distribution 7 investment was developed by Utility Operations based on the average 8 cost of actual expenditures over the prior five years, expressed as a 9 levelized annual revenue requirement in terms of $/kW-yr. Therefore, the 10 avoided capacity cost is estimated based on the installed CT cost grossed 11 up for line losses and reserve margin requirements plus an estimate of 12 avoided transmission and distribution investment. The results of these 13 analyses are the avoided levelized capacity cost estimates, which are 14 provided in highly sensitive EAI Exhibit CED-3. 15 16 Q. DOES THIS CONCLUDE YOUR TESTIMONY? 17 A. Yes. - 10 - APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 CERTIFICATE OF SERVICE I, Steven K. Strickland, do hereby certify that a copy of the foregoing has been served upon all parties of record by forwarding the same by electronic mail and/or first class mail, postage prepaid, this 8th day of April 2013. /s/ Steven K. Strickland Steven K. Strickland APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF EAI EXHIBIT CED-1 LIST OF PRIOR TESTIMONY APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. EAI Exhibit CED-1380 Docket No. 07-085-TF Page 1 of 2 Testimony Filed by Charles E. DeGeorge 1. Public Utility Commission of Texas, Docket 37482, Application of ETI for Approval of Power Cost Recovery Factor (EAI WBL Contract) 2. Louisiana Public Service Commission (“LPSC”), Docket U-29955, Joint Application of ELL and EGS for Authorization to Participate in Contracts for the Purchase of Electric Power for 2007 and for Timely Treatment (Frontier, Block Energy Purchases, SRW, Dow, and Cottonwood Contracts) 3. LPSC, Docket U-30422, Application of EGS for Approval to Enter into Contract for the Purchase of Electric Power from EAI Sourced from the Ouachita CCGT Facility and Request for Timely Treatment 4. LPSC, Docket U-30192, Application of ELL for Approval to Repower the Little Gypsy Unit 3 Electric Generating Facility and for Authority to Commence Construction and for Certain Cost Protection and Cost Recovery 5. LPSC, Docket U-31147, Application of EGS and ELL for Approval to Enter Into Contracts for the Purchase of Electric Power and for Timely Treatment (EAI Wholesale Baseload (“WBL”) Contract) 6. LPSC, Docket U-31284, Joint Application of ELL and EGS for Approval to Participate in Contracts for the Purchase of Electric Power for 2010 and for Cost Recovery (Exelon-Frontier Contract) 7. LPSC, Docket U-31971, Joint Application of ELL for approval to construct Unit 6 at Ninemile Point Station and of EGSL for approval to participate in a related contract for the purchase of capacity and energy and for cost recovery APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. EAI Exhibit CED-1380 Docket No. 07-085-TF Page 2 of 2 8. City of New Orleans (“CNO”), Docket UD-11-03, Application of Entergy New Orleans, Inc. (“ENO”) to enter into a contract for the purchase of capacity and energy from Unit 6 at Ninemile Point Station and for cost recovery 9. Arkansas Public Service Commission, Docket 11-069-U, Application of EAI for approval of the acquisition of the Hot Spring Plant to serve its retail customers 10. Arkansas Public Service Commission, Docket 12-038-U, Approval of certain Wholesale Base Load Capacity to serve EAI customers. APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF EAI EXHIBIT CED-2 AVOIDED ENERGY COST ESTIMATES THIS EXHIBIT CONTAINS HIGHLY SENSITIVE PROTECTED INFORMATION PROVIDED PURSUANT TO THE INTERIM PROTECTIVE ORDER NO. 43 IN APSC DOCKET 07-085-TF. APSC FILED Time: 4/8/2013 11:08:44 AM: Recvd 4/8/2013 11:02:39 AM: Docket 07-085-TF-Doc. 380 BEFORE THE ARKANSAS PUBLIC SERVICE COMMISSION IN THE MATTER OF THE APPLICATION OF ENTERGY ARKANSAS, INC. FOR APPROVAL OF ENERGY EFFICIENCY PROGRAMS AND ENERGY EFFICIENCY COST RATE RIDER ) ) ) ) ) DOCKET NO. 07-085-TF EAI EXHIBIT CED-3 AVOIDED CAPACITY COST ESTIMATES THIS EXHIBIT CONTAINS HIGHLY SENSITIVE PROTECTED INFORMATION PROVIDED PURSUANT TO THE INTERIM PROTECTIVE ORDER NO. 43 IN APSC DOCKET 07-085-TF.