Electric

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 2008.  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.  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.  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.