HomeMy WebLinkAboutC_Public_Comment_47.a_180614.email_attch2of2Supporting Attachment No. 1
To Comments made by Richard Lauckhart dated December 11, 2017
Lauckhart_Schiffman Load Flow study showing EE is not needed
LAUCKHART-SCHIFFMAN DEMAND FORECAST
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2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
Load Flow modeling
(•or cnergize tastsioe
Richard Lauckhart
Roger Schiffman
February 18, 2016
Executive Summary
In November 2015, the citizen group CENSE asked Richard Lauckhart and Roger Schiffman
to study the scenario that motivates Puget Sound Energy's transmission project known
as "Energize Eastside." We (Lauckhart and Schiffman) are nationally recognized power
and transmission planners with specific knowledge of the Northwest power grid.
It is standard industry practice to use a "load flow model" to determine the need for a
transmission project like Energize Eastside. In order to assess the reliability of the grid,
analysts use specialized computer software to simulate failure of one or two major
components while serving peak load conditions. For Energize Eastside, PSE simulates
the failure of two major transformers during a peak winter usage scenario (temperature
below 23' F and peak hours between 7-10 AM and 5-8 PM).
We ran our own load flow simulations based on data that PSE provided to the Western
Electricity Coordinating Council (WECC). We used a "Base Case' for winter peak load
projected for 2017-2018. PSE confirms this is the same data used as the basis for the
company's "Eastside Needs Assessment."
Our findings differ from PSE's as follows
1. PSE modified the Base Case to increase transmission of electricity to Canada from
500 MW to 1,500 MW. This level of energy transfer occurring simultaneously with winter
peak loads creates instability in the regional grid. Transmission lines connecting the
Puget Sound area to sources in central Washington do not have enough capacity to
maintain this level of demand.
2. PSE assumed that six local generation plants were out of service, adding 1,400 MW of
demand for transmission. This assumption also causes problems for the regional grid.
3. Even if the regional grid could sustain this level of demand, it is unlikely that regional
grid coordinators would continue to deliver 1,500 MW to Canada while emergency
conditions were occurring on the Eastside.
4. We found that the WECC Base Case contains a default assumption that PSE may not
have corrected. The ratings for critical transformers are based on "summer normal"
conditions, but the simulation should use significantly higher "winter emergency"
ratings. The default value could cause PSE to underestimate System Capacity and
overstate urgency to build the project.
S.The Base Case shows a demand growth rate of 0.5% per year for the Eastside. This is
much lower than the 2.4%growth rate that PSE cites as motivation for Energize Eastside.
Our study finds critical transformers operating at only 85%of their winter emergency
rating, providing enough capacity margin to serve growth on the Eastside for 20
to 40 years.
a
Qualifications
Richard Lauckhart served as a high level decision maker at Puget
Sound Power & Light (the predecessor of Puget Sound Energy). His
employment with the company spanned 22 years as a financial and
transmission planner as well as power planning. He served as the
company's Vice President of Power Planning for four years.
Richard took a voluntary leave package when Puget Power merged
with Washington Energy Company in 1997. He provided additional
contract services to PSE for more than a year following the merger.
After leaving PSE, Richard worked as an energy consultant, providing
extensive testimony on transmission system load flow modeling
before the California Public Utility Commission.
Roger SchifPman has 23 years of energy industry experience covering
utility resource planning, electricity market evaluation, market
assessment and simulation modeling, regulatory policy development,
economic and financial analysis, and contract evaluation. Roger has
led a large number of consulting engagements for many clients. He
has extensive knowledge of industry standard modeling software
used for power market analysis and transmission planning.
We are well acquainted with the physical layout and function of the
Northwest power grid and the tools used to analyze its performance.
Our resumes can be found in Appendix H.
Richard has provided pro bono consultation to CENSE since April
2015. He has received no financial compensation other than
reimbursement of travel expenses. Roger had no relationship with
CENSE prior to this report.
5
Methodology
The power grid is a complex interconnected system with behaviors
that cannot be easily understood without computer modeling software.
We acquired a license to run the industry standard simulation software
known as "GE PSLF" to perform our studies.
The PSLF software uses a database that is supplied by the operator.
We had hoped to use the same database that PSE used in its studies,
but PSE refused to share it after months of negotiations. Instead, we
received clearance from the Federal Energy Regulatory Commission
(FERC) to access the database PSE submitted to the Western Electricity
Coordinating Council (WECC). FERC determined that we presented no
security threat and had a legitimate need to access the database (see
FERC's letter in Appendix A).
We used the WECC Base Case for the winter of 2017-18, which PSE
confirms is the database the company used for that time period. We
and PSE have made subsequent changes to the Base Case model in
order to incorporate various assumptions. We don't know exactly
what changes PSE made to the database, but we will be explicit about
the changes we made.
N-0 base scenario
To ensure that everything was set up correctly, we ran a simulation
using the unmodified Base Case and checked to see if the results
aligned with those reported by WECC. This is referred to as an "N-0"
scenario, meaning that zero major components of the grid are offline
and the system is operating normally. The outputs of this simulation
matched reported results.
The WECC Base Case assumes that the Energize Eastside project has
been built. In order to determine the need for the project, we needed
to study the performance of the grid without it. We reset the transmission
configuration using parameters from an earlier WECC case that did
not include the project.
N-0-1 contingency scenario
An "N-1-1" scenario models what would happen if two major grid
components fail in quick succession. Utilities are generally required
3 hup://www.geenergyconsultingxonVpslf-re-envisioned
to serve electricity without overloads or outages in this scenario to
meet federal reliability standards.
PSE determined that the two most critical parts of the Eastside grid
are two large transformers that convert electricity at 230,000 volts
to 115,000 volts, the voltage used by all existing transmission lines
within the Eastside. To simulate the N-1-1 scenario, the Base Case is
modified to remove these two transformers from service.
PSE apparently made two additional modifications to the WECC Base
Case. First, the amount of electricity flowing to Canada was increased
from 500 MW to 1,500 MW. Next, the company reduced the amount
of power being produced by local generation plants from 1,654 MW
to 259 MW. The rationale behind these modifications isn't obvious,
and we were concerned how the regional grid (not just the Eastside)
would perform with these assumptions in place.
To our surprise, simply increasing the flow to Canada to 1,500 MW
while also serving peak winter power demand in the Puget Sound
region was enough to create problems for the regional grid. The
simulation software could not resolve these problems (Appendix E
describes the problems in greater detail). While it's possible that PSE
and Utility System Efficiencies found ways to work around these
challenges by making additional changes to the Base Case, we do not
know what these changes were. We are confident that prudent grid
operators would reduce flows to Canada if an N-1-1 contingency
occurs on the Eastside during heavy winter consumption. PSE would
turn on every local generation plant. These responses resolve the
problems. This is the more realistic scenario we modeled in our
N-1-1 simulation.
The WECC Base Case uses default values for transformer capacity ratings
that correspond to a "summer normal" scenario. The summer rating is
reduced in order to protect transformers from overheating during hot
summer weather. The "winter emergency" rating would be consistent
with best engineering practice for equipment outages during very cold
conditions (less than 23' F) that produce peak winter demand. We used
this higher rating in our simulation.
Results
*0 results
To compare the N-1-1 results with normal operation of the grid serving
peak winter demand, we ran an N-0 study using the WECC Base Case
for winter 2017-18 with the following modifications:
1 Energize Eastside transmission lines are reverted to present
capacity.
2. Flow to Canada is reduced from 500 MW to 0 MW.
3.Transformers run at "winter normal' capacity.
Figure 1 shows load as a perentage of "winter normal' capacity on
each of the four transformers.
N-0 Case Load
(%of Winter Normal Rating)
Talbot S 74%
Talbot N 78%
Sammamish W 62%
Sammamish E 58%
o% 20% 40% 60% 80% io0
Figure ]: With all transformers in service, winter peak load causes no overloads.
N-1-1 results
The N-1-1 results are based on the WECC Base Case for winter 2017-18
with the following modifications:
1 Two transformers are out of service.
2. Energize Eastside transmission lines are reverted to present
capacity.
3. Flow to Canada is reduced from 500 MW to 0 MW.
4.Transformers run at "winter emergency" capacity.
Figure 2 shows that the remaining two transformers, Talbot N and
Sammamish W, remain within "winter emergency" capacity ratings.
N-1-1 Case Load
(% of Winter Emergency Rating)
�;Falb atS )out of service)
Talbot N 85%
Sammamish W 79%
91 E- )out of service)
0% IM 10% 30% 40% 5tl% 60% 7034 80% 90%
Figure 2: Loads on two remaining transformers are in a safe range.
E
Analysis
We carefully analyzed the results of the N-1-1 simulation to get a
broader view of how the grid is behaving in this scenario. Electricity
is served by a combination of high -voltage transformers (transforming
230,000 volts to 115,000 volts) and low -voltage transformers
(115,000 volts to 12,500 volts).
When we simulated failure of two high -voltage transformers located
at Sammamish and Talbot Hill, as PSE did, we discovered that some
of the load is redistributed to other high -voltage transformers in
the Puget Sound area (see Figure 3). This is a natural adaptation of
the networked grid that occurs without active management by PSE
or other utilities. The regional grid has enough redundant capacity
to balance the load without causing overloads on any transformer or
transmission line in the region.
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Figure 3: Load is distributed among other
transformers after two transformers fail.
10
We conclude that the grid is capable of meeting demand in emergency
circumstances in the winter of 2017-18. How soon after that will system
capacity become strained?
Concerns about future capacity are illustrated in Figure 5, PSE's
demand forecast graph?This graph raises several questions. For
example, it's not clear how PSE determined the "System capacity
range' of approximately 700 MW. If this value is derived from the
transformer capacities listed in the WECC Base Case, these capacities
are set to default values corresponding to "summer normal" conditions.
PSE's graph shows Customer Demand growing at an average rate
of 2.7% per year. However, data submitted by PSE to WECC shows a
growth rate of only 0.5% per year. An explanation of this discrepancy
is necessary to understand this graph.
I EASTSIDE CUSTOMER DEMAND FORECAST
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Figure 4: PSE's graph shows customer demand exceeding system capacity in 2018.2
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Although we don't have enough information to create a graph
suitable for long-term planning, we we feel Figure 5 is a better
approximation of system capacity and demand growth on the Eastside.
The "System capacity" is based on "winter emergency" transformer
ratings, which are more appropriate than summer ratings for this
scenario. The higher ratings raise the overall capacity to approximately
930 MW.
The "Customer demand" line shown in Figure 5 is based on loads
reported in the load flow simulation for the two remaining Eastside
transformers. The 2014 value is higher than in PSE's graph, because
these transformers serve loads outside the Eastside area. The growth
rate matches the 0.5% rate observed in WECC Base Cases.
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Figure 5: Alternative Demand Forecast shows slower demand growth and higher system
capacity (based on "winter emergency" transformer ratings).
12
Comparison with other studies
The conclusions of the t.auckhart-Schiffman study differ from previous
studies. We stand by our conclusions and will share our models and
results with anyone who has clearance from FERC.
Here we review the other studies and explain why their conclusions
might differ from ours.
PSE/Quanta
Two different load flow simulations were performed by PSE and
Quanta, a consultant employed by PSE. We have the following concerns
with both studies:
1. An unrealistic level of electricity is transmitted to Canada.
2. Nearly all of the local generation plants are turned off.
3. The appropriate seasonal ratings for the critical transformers
were not used.
4. It's not clear how the customer demand forecast was developed,
but there is an unexplained discrepancy between the forecast
used for Energize Eastside (2.4%annual growth) and the forecast
reported to WECC (0.5% annual growth).
The first two assumptions cause regional reliability problems for the
WECC Base Case that must have required additional adjustments by
PSE/Quanta. We don't know what those adjustments were.
Utility System EfflClenCleS
The City of Bellevue hired an independent analyst, Utility System
Efficiencies (USE), to validate the need for Energize Eastside. USE
ran one load flow simulation that stopped electricity flow to Canada.
According to USE, 4 of the 5 overloads described in the PSE/Quanta
studies were eliminated, and the remaining overload was minor.
Our load flow simulation studied the same scenario (N-1-1 contingency
with no flow to Canada and local generators running), but we did not
find any overloads. We believe three assumptions explain the different
outcomes:
1. USE does not specify what level of generation was assumed for
local generation plants. In verbal testimony before the Bellevue
13
City Council, USE consultants said that they did not assume all
of the capability of local generation was operating. Our study
assumes these plants will run at their normal capacity.
2. USE says emergency ratings were used for the critical transformers,
but it isn't clear if USE used "winter emergency" ratings. Our
study assumes winter emergency ratings.
3. USE does not independently evaluate the customer demand
forecast (2.4% annual growth is assumed). Our study assumes
the load growth forecast that PSE provided to WECC.
We believe our assumptions more accurately reflect the actual conditions
that would occur in this scenario.
Stantec Consulting Services
In July 2015, the independent consulting firm Stantec was asked to
review the studies done by PSE and USE. Stantec issued its professional
opinion without performing any independent analysis or load flow
simulations. Stantec says PSE's methodology was "thorough" and
"industry standard:" However, Stantec does not address the shortcomings
we have identified with previous studies.
14
Clearance from FERC
Federal Energy Regulatory Commission
Washington. DC 20426
SEP 01 2% Letter of Release,
Re: CEII No. CE15-130
VIA CERTIFIED MAIL
Richard Lauckhart
Dear Mr. Lauckhart
This is in response to the July 15, 2015 request you submitted under the Federal
Energy Regulatory Commission's (Commission or FERC) Critical Energy Infrastructure
Information (CEII) regulations at 18 C.F.R. § 388.113(d)(4) (2015). Specifically, you
requested a copy of the Puget Sound Energy, Inc. FERC Form No. 715. Annaal Transmission
Planning and Evalaorian Report.
By letter dated August 21, 2015, the Commission issued a finding that you are a
legitimate requester with a need for the information. In accordance with IS C.P.R.
§ 388.112(e), the enclosed DVD contains the information requested and is being released to
you subject to the non -disclosure agreement executed by you concerning this matter.
As provided by 18 C.F.R. § 388.113(d)(4)(iv) of the Commission's regulations, you
may appeal this determination pursuant to 18 C.F.R. § 388.110. Any appeal from this
determination must be filed within 45 days of the date of this letter. The appeal must be in
writing, addressed to David L. Mormof, , General Counsel, Federal Energy Regulatory
Commission, 888 First Street, NE, Washington, DC 20426. Please include a copy to Charles
A. Beaman, Associate General Counsel, General and Administrative Law, at the same
address.
Sincerely,
Leonard M. Tao
Director
Office of External At3airs
Enclosure
15
Choice of Base Case
To perform a load flow study, one needs a database reflecting the
physical characteristics of the power grid. FERC has recognized that
stakeholders need to have access to a Base Case that reflects the
system. Each utility or a designated agent is required to file power
flow base cases with FERC on an annual basis.3 WECC acts as a
designated agent for most of the utilities operating in the western
U.S. In an email dated November 19, 2015 Jens Nedrud, the Senior
Program Manager for Energize Eastside, confirmed that PSE uses
Base Cases filed by WECC as its Base Cases.
For the purposes of this study, Lauckhart and Schiffman obtained
the 2014 WECC Base Cases from FERC.4 These included 13 Base Case
runs, four of which are Heavy Winter scenarios. In order to evaluate
the need for the EE project, the heavy winter 2017-18 Base Case was
modified so that the Energize Eastside project was not included.'
We do not know if this modified 2017-18 Base Case is identical to
the one used by PSE to justify the project, because PSE has refused to
share their 2017-18 Base Cases for independent review. The WECC
Base Case assumes 500 MW is transmitted to Canada. PSE apparently
increased that amount to 1,500 MW. The WECC Base Case assumes
local generation in the Puget Sound Area is running at normal capacity.
PSE appears to have reduced those contributions by 1,395 MW. Our
PSLF modeling suggests that PSE's modifications are not feasible and
grid operators would not allow these conditions to occur on a heavy
winter load days
Load data from the WECC Heavy Winter Load 2017-18 Base Case is
chosen as the basis for this study. This is the latest data provided by
FERC/WECC for the winter of 2018. PSE was involved in the development
of this Base Case along with other utilities including BPA and Seattle
City Light (SCL). All utilities use these Base Cases to determine if the
grid is capable of moving power from sources to loads. Further, it is
the only data available in which there are identified loads on specific
substations.
16
The loads on the main Eastside substations in the WECC Heavy Winter
2013-14 and 2017-18 Base Cases have been examined and analyzed.
All of the Eastside substations were included:
Medina
Overlake
South Bellevue
Clyde Hill
Lochleven
Factoria
Bridle Trails
North Bellevue
College
Evergreen
Center
Phantom Lake
Ardmore
Midlakes
Eastgate
Kenilworth
Lake Hills
Somerset
The total load on these substations in the 2013-14 Base Case was
394.6 MW. The total load on these substations in the 2017-18 Base
Case was 402.4 MW. This is a peak load growth of 2.0% over the 4
year period (an average increase of 0.5% per year). This is in line with
predicted growth of energy and peak in King County.
PSE and USE appear to be extrapolating the higher growth rate of a few
substations due to "block loads" and applying it uniformly to 600 MW
of existing substation load. This simplification overestimates the overall
growth rate. Furthermore, the total load on the substations listed
above is only 400 MW. It is not clear how PSE arrived at a 600 MW load.
3 htip:ll"w.ftm.gov/dots-filing/fiorm/f`orm-715/insfra tions.asp#Geneml%201nstructiom
< On July 9, 2015 FERC provided Lauckhart the most recent WECC Base Cases that it had
available to send to requesters. Those Base Cases were ones filed in 2014 by WECC.
'On Dec. 4, 2015 Lauckhart also received from FERC a copy of the 2015 WECC FERC
Farm 715 filing. In that filing there was no Base Case, filedfor the winter of 2018. However,
there was a Base Case filed for the winter of 2020. A review of that 2020 Base Case showed
very little growth on the Eastside from the 2018 Base Case. It also showed that the rest of the
Northwest actually reduced their load forecast for the year 2020 over their forecast for 2018.
In total, the loading on the eastside 2301115 KV transformers in the 2020 case were lower
than the loading on the Eastside 2301115 KV transformers in the 2018 case. The trend is
that the situation is not getting worse since the load forecasts far the northwest are dropping
overall which also reduces loading on the Eastside 2301115 KV transformers.
°With no other changes to the WECC Base Case for the winter of2018, increasing PNW to
BC transfers to 1,500 causes the system to need to import more power across the Cascades
from Central Washington. This causes the PSLF model ran to fail to find a solution. When
we say no solution, we mean the voltage in the Puget Sound region gets too low and the
model cannot find a way to correct that.
17
Generation pattern used
PSE's gas -fired generation plants located in the Puget Sound area
have a total rated capacity of 1,654 MW. How much of this capacity
should be used to serve peak demand during a heavy winter load
event? There are three choices:
1. The Eastside Needs Assessment prepared for PSE by Quanta
assumed generation of only 259 MW, without explaining why
such a low level was used.
2. The load Flow study performed by USE also ran the plants at a
reduced rate, but the study did not specify the exact amount.
3. Three of the four WECC heavy winter Base Cases assume the
plants are running at their rated capacity of 1,654 MW. One
of the Base Cases turns off one plant for reasons that are not
clear, resulting in a lower level of generation at 1,414 MW.
The 1,654 MW capacity used by WECC in 3 of its 4 heavy winter Base
Cases is a prudent choice for several reasons. First, PSE built and/or
acquired these plants for the explicit purpose of meeting its load
obligations during cold winter events. Second, PSE has a well -documented
shortfall of generation capacity to serve peak demand, and it will be
less risky and less expensive to run these plants than to buy power
on the spot market. Third, because these plants generate electricity
at 115 kV, the strain on PSE's overloaded 230/115 kV transformers
would be reduced by Increasing the supply of 115 kV electricity.
18
Exports to Canada
PSE and USE assume that 1,500 MW of power must be delivered to
Canada, even if PSE is experiencing failure of two critical system
components (an N-1-1 contingency) during heavy winter load conditions
(temperatures less than 23° F in the Puget Sound region).
The WECC Base Cases assume otherwise. In the WECC Base Case for
heavy winter 2013-14, 500 MW of power is flowing south from Canada
to the U.S. In the WECC Base Case for heavy winter 2017-18, with the
Energize Eastside project in place, 500 MW of power is flowing north
to Canada, not 1,500 MW.
PSE and USE imply that it is the Columbia River Treaty that provides a
Firm Commitment to deliver 1,500 MW of power to Canada. It is clear
from reading numerous Treaty documents (e.g. the original treaty,
the amendment to the treaty in 1999, and related documents) that
the Treaty itself imposes no obligation on the United States to deliver
Treaty Power to Canada. To the contrary, Canada has stated they do
not want the Treaty Power delivered to Canada. Instead, PowerEx takes
delivery of Canada's share of Treaty Power at the point of generation
in the U.S. and delivers it for sale to U.S. entities. Canada finds it
preferable to receive money for their share of Treaty Power rather
than having the power delivered to Canada.
The reasonable assumption for this study is that no power will flow
from the U.S. to Canada during a major winter weather event and
simultaneous facility outages in the Eastside.
19
Regional grid capacity
limitations
Most of the electrical generation facilities that serve the Puget Sound
region are located east of the Cascade Mountains. The electricity they
produce is transmitted to customers in the Puget Sound area through
eleven major transmission lines known collectively as the "West of
Cascades - North" (WOCN) transmission path.
WEST OF CASCADES NORTH FLOWGATE
Actual Loadings and OTCs: 2&Apr10. 27111layT0 (30 Days)
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Figure 6: Chart from BPA An. load (in yellow) and maximum capacity (in red) for the WOCN path.
The exact transmission capacity of the WOCN path is confidential
information which cannot be discussed in detail here. However, there
is a report available on the web from the Bonneville Power Administration
that discusses a problem that occurred on the WOCN path in May 2010.7
On page 31, the report includes a chart showing loads and capacities
20
of the WOCN path over a 30-day period. The load (shown in yellow)
varies from 5000-7000 MW and the path capacity (in red) varies from
7000-9000 MW.
During a heavy winter usage scenario, the loads are likely to be
higher than during relatively mild weather conditions in May. PSE's
assumptions for Energize Eastside would further increase the load.
To deliver 1,500 MW to Canada, loads on the WOCN path would need
to increase by approximately 1,000 MW. To make up for the loss of
electricity that could have been generated by six local generation
plants, an additional 1,400 MW must be transmitted on the WOCN
path. In total, loads would increase by approximately 2,400 MW.
If the increased load exceeds the capacity of the WOCN path, grid
operators and utilities would have to make adjustments like they did
in May 2010. Some of these steps and consequences are described
on page 40 of the BPA report:
"Many customers (e.g., TransAlta, Calpine, PSE, PGE)
were not able to use low cost power purchases, and
instead had to operate higher cost thermal projects
that otherwise were idled or were out or planned for
maintenance. Although there were multiple complaints
regarding the ability to serve load, the basis for the
complaints appeared to be economic or financial impacts:"
We feel that WOCN path capacity limits explain why the simulation
software could not find a way to maintain voltage levels in the Eastside
given PSE's assumptions. We conclude that it is not reasonable to
build local infrastructure to support these conditions if regional
infrastructure cannot reliably serve the implied loads.
' http: //Pnucc.org/sites/defaul tlfdes/BPAWOCNLessowLearned.pdf
21
Apper
Equipment ratings
Ambient temperature affects the capacity of electrical transmission
facilities. Colder temperatures help avoid overheating. For this reason,
it is industry standard practice to provide different ratings for summer
and winter seasons.
It is also industry standard practice to allow higher loading of equipment,
including transformers, during emergency events due to the fact that
emergencies do not last long. Utilities can take advantage of the fact
that transformers can safely handle brief over -peak conditions to
reduce installation costs and maintain system reliability.
The WECC Data Preparation Manual requires transmission owners to
provide the following ratings for its transformers:
• Summer Normal Rating
• Summer Emergency Rating
• Winter Normal Rating
• Winter Emergency Rating
Relative transformer capacities
Summer Summer Winter Winter
Normal Emergenry Normal Emergenry
Figure 7: Ratings for different scenarios, normalized to Sumner Normal rating.
PSE has indicated that the rating on the Sammamish and Talbot Hill
transformers are approximately 352 MVA (Mega -volt amperes).
According to the data that PSE provided to WECC, this is the Summer
Normal Rating of these transformers. PSE has advised WECC that (a)
its Winter Normal ratings are about 9% higher than Summer Normal,
and (b) Winter Emergency Ratings are about 21%higher than Winter
Normal Ratings.
22
When running the PSLF model, the run parameters must be set to
point to the correct rating that has been provided in the data base. e
In the N-0 analysis, our load flow studies used the winter normal
rating which is 9% higher than the 352 MVA summer normal rating.
In the N-1-1 analysis, our load flow studies used the winter emergency
rating that is 21% higher than the winter normal rating.
23
Summer load scenario
Most of the load flow modeling done by PSE and USE to justify
Energize Eastside has been focused on a winter peak load scenario.
Recently, PSE has mentioned reliability concerns in the summer to
provide additional motivation to build Energize Eastside. So far, PSE
has refused to provide input data and results for both winter and
summer scenarios.
We briefly reviewed the WECC Base Case for heavy summer demand
in 2019. The peak load on Eastside substations is 281 MW in this
scenario. This is 30% lower than the total load for heavy winter
demand in 2017-18 (402 MW). The drop in transformer ratings due
to summer heat is only 9%, so this scenario should be significantly
less stressful on PSE's infrastructure than the winter scenario. Rapid
growth in air conditioning is a concern, but if there is a summer
need, then rooftop solar in Bellevue and other cities will be helpful
and should be encouraged. Further study is warranted.
24
Resumes
RICHARD LAUCKHART
J. Richard Lauckhart
Energy Consulting
J. Richard Lauckhart has 40 years of experience in power supply planning, electricity price forecasting
and asset valuation. He began his career as a distribution engineer with Pacific Gas & Electric Co., and
held various positions at Puget Sound Power & Light Co. (now Puget Sound Energy) in power supply
planning, culminating as vice president of power planning.
For the last 12 years Mr. Lauckhart has performed consulting assignments related m power market
analyses, price forecasting services, asset market valuation, integrated resource planning, transmission
line congestion analysis, and management of strategic consulting engagements for clients in North
America, including investor -owned and municipal utilities, independent power producers, and lenders.
Mr. Lauckhart received a bachelor of science degree in electrical engineering from Washington State
University in 1971 and a masters degree in business administration from the University of Washington
in 1975
Representative Project Experience
Black & Veatch
September 2008 to October 2011
Managing Director
Mr. Lauckhart oversees wholesale electricity price forecasting, project revenue analysis,
consults regarding wind integration matters electric interconnection and transmission
arrangements for new power projects, and other related matters in the electric power
industry. In addition, he heads Black & Veatch's WECC regional power markets
analysis team.
WECC Power Market Analysis and Transmission Analysis, Henwoa&Global Energy
Decisions/Ventyx
2000.2008
Senior Executive
Mr. Lauckhart oversaw wholesale electricity price forecasting, project revenue analysis,
consulted regarding electric interconnection and transmission arangements for new
power projects, and other related matters in the electric power industry. In addition, he
headed Global Energy's WECC regional power markets analysis team.
Lauckhart Consulting, Inc.
1996-2000
President
Primary client - Puget Sound Energy (formerly Puget Sound Power & Light Company):
Involved in power contract restructuring, market power analysis, FERC 888 transmission
tariffs, and other matters. Testified at FERC regarding Puget's 888 tariff. Testified for
Puget in June, 1999 arbitration with BPA regarding transmission capability on the
Northern Intertie.
NorthwestlPP
Under retainer with IPP from July 1996 through December 31, 1999. Involved primarily
in merchant power plant development activities including permitting activity, owner's
engineer identification, environmental consultant identification, water supply
26
RICHARD LAUCKHART
arrangement, transmission interconnection and wheeling arrangements, gas pipeline
arrangements, economic analysis, forward price forecasting, marketing, and related
issues.
Levitan & Associates (Boston)
Participated in teams involved in electric system acquisition activities. Performed
preliminary analysis for a major retail corporation regarding possible participation as an
aggregator in the California deregulated electric market. Involved in the evolving
discussions about deregulation in the state of Washington including participant in 1113
2831 report and ESSB 6560 report.
Member of advisory task force for Northwest Power Planning Council study of
generation reliability in the Pacific Northwest. Participating writer in a newsletter
advocating electric deregulation in the state of Washington.
Puget Sound Power & Light Company
1991-1996
Vice President, Power Planning
Involved in all aspects of a $700 million per yew power supply for a hydro/thermal utility
with a 4,600 MW peak and 2,200 aMW energy retail electric load. Included
responsibility for a 22 person department involved in power scheduling (for both retail
and wholesale power activity), power and transmission contract negotiation and
administration, regulatory and NERC compliance, forward price forecasting, power cost
accounting, and retail rate activity related to power costs. Activity included matters
related to 650 MW of existing gas -fired, simple cycle combustion turbines. In addition,
660 MW of combined cycle cogeneration "qualifying facilities" were developed by
others for Puget during this time frame. Detailed understandings of the projects were
developed both for initial contractual needs and later for economic restructuring
negotiations. Mr. Lauckhart was the primary person involved in developing Puget's
Open Access transmission tariff in accordance with FERC Order 888.
Puget Sound Power & Light Company
1986-1991
Manager, Power Planning
The company's key person in developing (1) a WUTC approved competitive bidding
process for administering PURPA obligations, and (2) a WUTC approved regulatory
mechanism for recovery of power costs called the Periodic Rate Adjustment Mechanism
(PRAM).
Puget Sound Power & Light Company
1981-1986
Director, Power Planning
The company's key person in developing a power cost forecasting model that was
customized to take into account the unique nature of the hydro generation system that
exists in the Pacific Northwest.
Puget Sound Power & Light Company
1979 —1981
Manager, Corporate Planning
Responsible for administering the corporate goals and objectives program.
Puget Sound Power & Light Company
27
RICHARD LAUCKHART
1976 —1979
Financial Planning
Improved and ran a computerized corporate financial forecasting model for the company
that was used by the CFO.
Puget Sound Power & Light Company
1974 —1976
Transmission Planner
Performed transmission engineering to assure a reliable transmission system.
Pacific Gas & Electric Company
1971-1974
Distribution Engineer
Performed distribution engineering to assure a reliable distribution system.
Other Relevant Experience
• Expert testimony for Montana Independent Renewable Generators
related to avoided cost regulations and pricing filed February 2009 at the Montana PSC
• Expert Testimony for LS Power in the SDG&E Sunrise Proceeding
regarding economics of in -area generation vs. the cost of transmission and imported
power Spring 2007
• Expert Testimony for BC Hydro in the Long Term Resource Plan,
February 2009 dealing with natural gas price forecasts and REC price forecasting
• Expert Testimony for John Deere Wind in a proceeding in Texas in
November 2008 related to avoided costs and wind effective load carrying capability
• Expert Testimony for Two Dot Wind before the Montana commission
regarding wind integration costs Spring 2008
• Expert Testimony in the BC Hydro Integrated Electricity Plan
proceeding regarding WECC Power Markets. November 2006.
• Expert Testimony for Colstrip Energy Limited Partnership before
Montana PUC regarding administration of QF contract prices. July 2006.
• Expert Testimony for Pacific Gas & Electric regarding current PURPA
implementation in each of the 50 states. January 2006.
• Expert Testimony in CPUC proceeding regarding modeling procedures
and methodologies to justify new transmission based on reduction of congestion costs
(Transmission Economic Analysis Methodology —TEAM). Summer 2006.
• Expert Testimony for BC Hydro regarding the expected operation of the
proposed Duke Point Power Project on Vancouver Island, January 2005
• Expert Testimony for PG&E regarding the cost alternative generation to
the proposed replacement of steam generators for Diablo Canyon, Summer of 2004.
• Expert Testimony in an arbitration over a dispute about failure to deliver
power under a Power Purchase Agreement, Fall 2004.
• Integrated Resource Plan Development. For a large investor -owned
utility in the Pacific Northwest, Global Energy provided advanced analytics support for
the development of a risk -adjusted integrated resource plan using RISKSYM to provide a
stochastic analysis of the real cost of alternative portfolios.
• Expert Testimony for SDG&E, Southern California Edison, and PG&E
28 regarding IRPs, WECC markets and LOLP matters before the California PUC, 2003.
RICHARD LAUCKHART
• Miguel -Mission Transmission Market Analysis -San Diego Gas &
Electric. San Diego Gas & Electric retained Global Energy to oversee an analysis of the
economic benefits associated with building the Mission -Miguel transmission line and the
Imperial Valley transformer. Global Energy performed an analysis of the economic
benefits of the Mission -Miguel line, prepared a report, sponsored testimony at the CPUC,
and testified at the CPUC regarding the report.
• Valley -Rainbow Transmission Market Analysis -San Diego Gas &
Electric. San Diego Gas & Electric also engaged Global Energy to analyze the economic
benefits associated with building the Valley -Rainbow transmission line and to respond to
the CPUC scoping memo that "SDG&E should describe its assessment of how a 500 kV
interconnect, like Valley -Rainbow, will impact electricity markets locally, regionally, and
statewide." Global Energy analyzed the economic benefits of the Valley -Rainbow, line,
prepared a report, sponsored testimony at the CPUC, and testified at the CPUC regarding
the report.
• Damages Assessment Litigation Support. Global Energy was engaged
by Steel Rives to provide damages analysis, expert testimony and litigation support in for
its client in a power contract damages lawsuit. Global Energy quantified the range of
potential damages, assessed power market conditions at the time, and provided expert
testimony to enable Steel Rives' client to prevail in a jury trial.
• Expert Testimony, Concerning the Economic Benefits Associated with
Transmission Line Expansion. Testimony prepared on behalf of San Diego Gas &
Electric Company, September 2001.
• Expert Testimony, Concerning market price forecast in support of Pacific
Gas and Electric hydro divesture case, December 2000.
• Expert Testimony, Prepared on behalf of AES Pacific regarding value of
sale for Mohave Coal project to AES Pacific for Southern California Edison, December
2000.
• Expert Testimony, Prepared on behalf of a coalition of 12 entities
regarding the impact of Direct Access of utility costs in California. June 2002.
Mr. Lauckhart was Puget's primary witness on power supply matters in eight different
proceedings before the Washington Utilities and Transportation Commission.
Mr. Lauckhart was Puget's chief witness at FERC in hearings involving Puget's Open
Access Transmission Tariff and testified for Puget in BPA rate case and court
proceedings.
29
ROGER SCHIFFMAN
SUMMARY OF QUALIFICATIONS
Mt. Schiffman has 23 years of energy industry experience covering utility resource planning,
electricity market evaluation, market assessment and simulation modeling; regulatory policy
development; economic and financial analysis, and contract evaluation. Mr. Schiffman has worked
with public and private utility companies on resource planning decisions, power plant retirement
decisions, avoided cost determinations, and on power supply procurement activity. Mr. Schiffman
has worked extensively with electric utility staff, power plant developers, regulatory personnel,
investment bankers and other industry participants in both consulting and regulatory environments.
Mr. Schiffman possesses extensive financial analysis skills, supported by thorough knowledge of
financial, economic and accounting principles. He has a strong technical understanding of the
electric utility industry and excellent analytical problem -solving skills, including quantitative analysis
and computer modeling techniques.
Principal, Black and Veatch Corporation, Inc., Sacramento, CA, March 2009 to
October, 2015
• Initiated Integrated Resource Plan for the Virgin Islands Water & Power Authority. This
project is a multi -faceted IRP, where detailed planning and potential siting impacts must be
considered in the overall planning, due to geographic and topology limitations on the islands.
Mr. Schiffman directed the analysis and playing the lead analytic role in assessing resource
needs. This included directing the data gathering efforts, taking technical lead in completing
production cost and financial modeling, and managing Black & Veatch's team of technical
experts. Mr. Scluffman also developed a stakeholder process and gave multiple presentations
before stakeholder and customer groups.
• Completed nodal market simulation and congestion study for a concentrating solar plant in
Northern Nevada. This engagement includes a review of transmission system impact studies,
power flow data and development of a PROMOD nodal simulation database to assess
congestion likelihood for the project
• Completed economic assessment of a large pumped storage project in Southern California,
including development of energy market arbitrage, capacity market and ancillary services
market revenue forecasts. Developed pro forma financial statements examining economics
of project under different ownership and off -take agreement structures.
• Completed Integrated Resource Plan for Azusa Light & Water, a municipal utility in southern
California. This project involved using Black & Veatch's EMP database and price forecast,
specifying thermal and renewable resource options, and completing detailed market
simulation and financial modeling to determine a preferred power supply plan for Azusa. A
key focus of the study is to identify resource options to replace output from the San Juan 3
coal plant, which is scheduled to retire.
• Completed Integrated Resource Plan for Pasadena Water & Power, a municipal utility in
southern California. This project involved using Black & Veatch's EMP database and price
forecast, specifying thermal and renewable resource options, and completing detailed market
simulation and financial modeling to determine a preferred power supply plan for Pasadena.
The project also included reflection of key stakeholder input, and testing stakeholder driven
1701 ARENA DRIVE
DAVIS, CA 95618
CELL ((530) 219-7349 HOME OFFICE (530) 405-3304
30 EMAIL: ROGER_SCHIFFMAN®YAHOO.COM
ROGER SCHIPFMAN PAGE
policy proposals for advancing renewable resource procurement beyond state -mandated RPS
levels. A key focus of the study is to identify resource options to replace output from the
Intermountain coal plant, which is scheduled to retire.
• Completed generation reliability study for the Brownsville Public Utility Board. This study
included directing the completion of detailed reliability modeling using GE -MARS, and
evaluating loss -of load probabilities for BPUB based on its existing system and based on the
addition of a 200 MW ownership share in the combined cycle power plant being developed in
Brownsville by Tenaska. The study also included detailed pro forma modeling of partial
ownership of the combined cycle plant, and a financial and risk assessment presented to
BPUB's Board of Directors, and also used to address rating agency questions about credit
impacts of the new power plant On behalf of Southern California Edison, completed nodal
power price forecast and assessment of high voltage transmission upgrades and additions in
Southern California. This project included an assessment of congestion, locations] marginal
pricing, transmission system losses, and economic impacts of adding new transmission
facilities in WECC, with particular focus on Southem California. PROMOD 1V was used to
complete the nodal market analysis, and PROMOD simulation results were translated into
GE-PSLF for more detailed transmission system modeling of power flow cases under a
variety of supply and demand conditions throughout the year.
• Completed four projects focused on nodal market modeling in California, Arizona and
Southern Nevada. These studies were used to assess congestion risk faced by solar and wind
generation projects at the sites where each is being developed. Completed PROMOD IV
dispatch and nodal analyses for each project, and developed risk assessments for generation
curtailment risk Also developed analyses of transmission system congestion along delivery
paths for each project, and on key economic transmission paths in Northern and Southern
California, transmission import paths into Southern California, and transmission paths in
Southern Nevada
• Completed resource and power supply planning/procurement project for confidential SPP
energy supplier. Completed a competitiveness assessment of major electricity supplier in
Nebraska, examining war structure, net resource position, generation asset characteristics,
transmission access and delivery options, and overall competitive positioning of SPP, MISO
and MRO entities that have potential to provide wholesale electricity service in Nebraska.
Worked collaboratively with client and a wholesale customer task force
• Completed due diligence analysis of portfolio of power supply assets to support bid
development. The generators being sold were located in SPP, WECC, and the Northeast. The
WECC asset is a qualifying facility, which required detailed repmsentation and modeling of
the California PUC Short -Rum Avoided Cost tariff and pricing formula. One of the SPP
assets is also a qualifying facility, which required detailed analysis of the steam load and
interaction between joint power and steam production. Completed modeling analysis and risk
assessment of power supply agreements, developed revenue forecasts for each power plant,
and completed merchant plant analysis of plant operations after PPA expiration.
• On behalf of a municipal utility client, developed database of renewable energy resource bids
solicited through an REP process, developed assessment of delivery terns and transmission
tariffs associated with power delivery from distant resources, and completed bid screening
analysis of 240 separate bids/pricing options.
• Completed PROMOD IV dispatch analysis and economic assessment of 6,000 MW portfolio
of coal and natural gas -fueled resources operating in the Midwest ISO market region.
Developed expected operations, cost, market sales and revenue forecasts for portfolio assets,
31
ROGER SCHIFFMAN PAGE
under several market scenarios. Prepared Independent Market Report for potential use in
Offering Memorandum
• Completed detailed review of California ISO ancillary services markets, and opportunity for
renewable energy and energy storage markets to participate in those markets. Analysis
included assessment of day-abead, hour -ahead, and real-time market operation.
• Completed dispatch modeling and power supply planning study examining onstmction of a
pumped storage hydro project in Hawaii. The evaluation included assessments of project
revenue in energy, ancillary services, and capacity markets in Hawaii, expected dispatch and
operation of the pumped storage project, and comparison of long-term power supply plans
with and without addition of the pumped storage project
• Completed deliverabihty and congestion analysis of wind energy resources being located in
California. Developed nodal market simulations, and examined locational marginal price
differences, congestion components, and transmission line loadings of facilities impacted by
the wind assets being studied.
• Completed detailed financial and dispatch modeling (deteconmistic and stochastic) of energy
storage project being developed in Southern California, to create dispatch profile and
estimated long-term project value of the facility. The evaluation included assessments of
project revenue in energy, ancillary services, and capacity markets in Southern California.
• Completed dispatch analysis and financial modeling of pumped storage hydro project in
Colorado, for use in regulatory proceedings. The evaluation included assessments of project
revenue in energy, ancillary services, and capacity markets in Colorado.
• Completed nodal power price forecast and assessment of high voltage transmission upgrades
and additions in Southern California. This project included an assessment of congestion,
locational marginal pricing, transmission system losses, and economic impacts of adding new
transmission facilities in WECC, with particular focus on Southern California. PROMOD IV
was used to complete the nodal market analysis, and PROMOD simulation results were
translated into GE-PSLF for more detailed transmission system modeling of power flow
cases under a variety of supply and demand conditions throughout the year.
• Completed PROMOD IV dispatch and commode analysis of Lodi Energy Center, with focus
upon expected dispatch of the project, and its fit into the overall power supply portfolio of a
Southern California Municipal Utility.
• Completed PROMOD IV dispatch analysis of a 100 MW biomass project in Florida, with
focus upon expected dispatch and market revenue for the project in Florida wholesale power
markets. Prepared Independent Market Report for use in financing omsmution of this
project.
• Completed PROMOD IV market price forecasts and detailed analyses of power markets in all
North American regions, including hourly energy price forecasts, annual capacity price
forecasts, and detailed assessment of supply/demand conditions and generator dispatch. The
assessments included forecasts of renewable energy development to each region/submarket,
forecast greenhouse gas regulation, and economic assessment of fossil and renewable energy
technologies.
32
ROGER SCHIFFMAN PAGE
Vice President, Venryx, Inc., Sacramento, CA, June 2007 to March 2009
• Managed project and led analysis for consortium of upper Midwest utilities focused on
developing plans for long-term transtwssion expansion to ensure reliability in the region and
to accommodate economic transfer of large-scale wind -based electricity generation. This
project examined congestion, reliability and economic benefits associated with large-scale
wind generation expansion in the upper Midwest, and accompanying needs for transmission
system expansion. Evaluation was completed on both nodal and zonal basis.
• Assisted investor -owned utility in the upper Midwest in completing an economic transmission
planning study consistent with FERC requirements. Provided guidance to client in
establishing study framework, and in completing detailed technical evaluation of transmission
upgrade projects. Provided assistance with stakeholder group interactions and debriefing.
• Conducted study for Western Area Power Administration examining economic impacts of
wind project integration from new wind projects located on Native American lands. Worked
with multi -party stakeholder group in completing study. Specific focus was upon power
system modeling and economic evaluation of long-term costs and benefits of wind energy
integration into the WAPA system
• Developed projections of expected dispatch, revenue, and operating costs for new combined -
cycle power plant under development in Southem California. Prepared financial projections
undu merchant plant and other likely economic scenarios. Completed evaluation of tolling
agreement terms and conditions.
• Assisted Southern California energy supplier in completing due diligence analysis for
investment and development of 300-500 MW wind generation project located in
Central/Southem California. Reviewed due diligence documents and completed economic
evaluation of expected revenue, operating costs and investment cash flows for the project at a
range of capacities varying from 100 MW to 500 MW.
Director, Navigant Consulting, Inc., Sacramento, CA, April, 2000 to June, 2007
• Responsible for managing the price forecasting subpractice within Navigant Consulting's
Energy Market Assessment group. Responsibilities included a wide variety of engagements
focused on evaluating wholesale power market conditions. Completed market assessment and
simulation studies of all North American regional power markets, including Canada and
Mexico.
• Created and Developed NCI's PROSYM market simulation practice and capabilities in
modeling WECC and Eastern Interconnected markets. Completed numerous market
simulation and assessment engagements throughout the U.S. covering all North American
market regions.
• With a team of consultants, assisting the California Energy Commission in defining and
evaluating scenarios for its 2007 Integrated Energy Plan. Reviewing market simulation results
from each of the scenarios and completing analysis of industry and consumer risks likely to be
faced in California over the next decade (ongoing).
• Directed NCI's market simulation efforts as independent consultant to the State of California
Department of Water Resources, leading m the successful underwriting of $11 billion in bond
financing and supporting the execution of power supply agreements aggregating to over
13,000 MW.
33
PAGE 5
• Developed projections of lost revenue and operating profits due to construction delays at a
large combined -cycle project in the Desert Southwest Prepared evaluation of WECC power
market conditions during the construction period for this project, and completed power
market simulations used to measure likely dispatch, revenue and operating profits of the
project during the construction delay period. Successfully presented and defended those
estimates before an Arbitration Panel, resulting in a significant financial award for our client.
• Completed PJM Market simulations and led analytical support for recent financing of a large
coal plant in PJM-West. Worked closely with investment banks and rating agencies in
identifying and assessing cash flow risks to the project.
• Prepared carbon regulation risk assessment of a new coal plant being developed in Nevada, to
evaluate long -teem potential impacts on project costs. Evaluated ratepayer risks associated
with this new project.
• Developed and maintained power market simulations to evaluate likely dispatch, costs, and
spot market purchases and sales associated with the California Department of Water
Resources purchased power contract portfolio. Results from these simulations have been
used in each of the last five years to support CDWR's sound revenue requirement filing
before the California Public Utilities Commission. Provide ongoing regulatory support to
CDWR, including consultation and banned training of CPUC staff in power market modeling.
• Directed a number of nationwide market simulation and valuation engagements examining
current market value of power plant portfolios owned by Calpme, Mirant, NRG and other
independent power producers. Worked with bond investors to develop refined valuation
estimates for subsets of each portfolio.
• Served on WECC's Power Simulation Task Force which was formed to assess available
options for the WECC to procure, maintain and use a power market simulation database and
model m its generation and transmission planning efforts. Participated in task force meetings
where criteria were developed for selecting a simulation database and model, and assisted in
evaluating proposals subnutted to the WECC task force
• Performed power market simulations of Mexico, using NmEnergy Associates' MarketPower
simulation model. Developed market price forecast and dispatch analysis of the Altamica II
project under a variety of projected fuel market conditions. Results from these analyses were
used by Senior Lenders to evaluate ongoing feasibility of the project under its financing terms.
Annual updates were provided to the lenders.
• Assisted a California investor -owned utility in conducting RFP and in evaluating bids received
for short-term and medium -term power supply contracts. Developed cost rankings,
economic screening, risk assessment and preferred bid evaluations, and assisted the utility's
planning and bid evaluation staff m presenting results to the company's senior management
• Developed WECC market simulations and assessment of investment conditions for
numerous clients used in feasibility analysis and financing support of new generation projects
being developed in WECC markets. These analyses included separate evaluation of power
market conditions in California, Mexico (Baja), Arizona, Colorado, Nevada, Oregon,
Washington, British Columbia, and Alberta.
• Reviewed and verified long-term resource plans of a major investor -owned utility located in
the Desert Southwest region. Conducted power market simulations of preferred and
competing resource plans and developed relative ranking of results.
34
ROGER SCHIFFMAN PAGE
Senior Consultant, Henwood Energy Services, Inc., Sacramento, CA, 1998 to 2000
• Prepared numerous forecasts of wholesale market electricity prices using Henwood's
proprietary market simulation tools. Drafted reports presenting price forecasts to consulting
clients. Worked closely with clients and sponsors of new merchant power plants to provide
customized market price forecasts and to seine individual client needs. Presented study
results to clients and their constituents.
• Directed project evaluation and revenue forecast for major merchant power plant in Texas.
Presented revenue forecast to investment bankers, and to several potential equity investors.
Advised and worked with project developer to successfully obtain debt and equity financing
for the project, which is currently under construction.
• Conducted economic study of market rules and entry barriers faced by developers of new
merchant power plants in domestic electricity markets. Applied study results to specific
conditions in Texas. Met with a variety of industry representatives in Texas including project
developers, transmission service providers, power marketers, utility regulators and
environmental regulators to gather market intelligence and develop study conclusions.
• Advised and worked with PricewaterhouseCoopers to perform economic evaluation and
market simulations of proposed Purchase Power Arrangements under development in
Alberta, Canada. The Power Purchase Arrangements are to be sold at auction in coming
months. Prepared economic study of market power held by incumbent electricity suppliers in
Alberta.
• Developed software and modeling mots to estimate investment cash flows and pro forma
financial results for new merchant power plants. Developed Henwood approach for
evaluating profitability of new market entrants and incorporating equilibrium amounts of new
entry in its market studies.
Senior Financial Analyst, Public Service Commission of Wisconsin, Madison, WI,
1990 to 1998
• Developed policy proposals for restructuring wholesale and retail electricity markets.
Evaluated competing policy proposals for impacts upon consumers and upon electrical
system operation. Drafted formal electricity industry restructuring policy adopted by the
Wisconsin Commission.
• Developed policies for addressing wholesale and retail market power in Primergy and
Interstate Energy Corporation merger cases. Evaluated feasibility and corporate finance
implications of asset divestimre and spin-off options for mitigating market power.
• Presented evaluation of proposed electric utility merger legislation to subcomunmee of
Wisconsin legislature. Advised individual legislators on merger policy.
• Developed policy proposal and draft legislation for reforming power plant siting law and for
allowing development of new merchant power plants in Wisconsin.
• Directed industrywideefforts to revise the PSCW generation competitive bidding
procedures. Conducted workshops on proposed revisions for utility, and other industry
participants. Drafted policy reforms adopted by the Wisconsin Commission.
• Conducted primary economic and engineering analysis of power plant proposals submitted in
generation competitive bidding cases. Prepared financial analyses of key contract terms and
risks. Evaluated economic and engineering characteristics of bid proposals using production
35
ROGER SCHIFFMAN PAGE
cost and system expansion computer modeling. Recommended preferred projects to
Wisconsin Commission.
Completed numerous financial analyses of new stock and bond issuances by Wisconsin
investor -owned utilities to evaluate investment risks and impacts upon the corporation.
Drafted formal administrative orders authorizing each issuance.
AesearchAssistant, University of Wisconsin, Madison, WI, 1989-1990
• Co-authored and provided research support for study of consolidation and mergers in the
electric utility industry.
EDUCATION
University ofWitconsin-Ma&'ram
• Graduate Studies toward MS -Finance, September 1988 - May 1990.
• Bachelor of Business Administration, Finance, Investment and Banking, May 1988.
• Curriculum concentrated heavily upon financial economics, with additional emphasis upon
economics, mathematics, and accounting.
PUBLICATIONS
Electric Uti&ty Mergers and Regulatory Po#y, Ray, Stevenson, Sduffman,
Thompson. National Regulatory Research Institute, 1992.
The Future of Wisconsin i Electric Porver Industry: Emvin mmemal Impact Statement, co-
author, Public Service Commission of Wisconsin, October 1995, Docket 05-
EI-114.
Report to the Governor on Electtc Reliability, co-author, Public Service Commission
of Wisconsin, Summer 1997.
36
TESTIMONY
ROGER SCHIFFMAN PAGER
Public Service Commission of Wisconsin, Docket 6630-UR-104, Wisconsin
Electric Power Company Rate Case, 1990, "Rate of Return on Equity, Cost of
Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 6690-UR-106, Wisconsin
Public Service Corporation Rate Case, 1991, "Rate of Return on Equity, Cost
of Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 4220-UR-105, Northern
States Power Company (Wisconsin) Rate Case, 1991, "Rate of Return on
Equity, Cost of Capital and Financial Condition"
Public Service Commission of Wisconsin, Rate of Return on Equity, Cost of
Capital and Financial Condition, Wisconsin Electric Power Company, Docket
6630-UR-105, Public Service Commission of Wisconsin, 1991
Public Service Commission of Wisconsin, Docket 05-EP-6, Advance Plan 6,
1992, "Alignment of Managerial Interests and Incentives with Integrated
Resource Planning Goals" (with Paul Newman).
Public Service Commission of Wisconsin, Docket 6680-UR-107, Wisconsin
Power & Light Company Rate Case, 1992, "Rate of Return on Equity, Cost of
Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 4220-UR-106, Northern
States Power Company (Wisconsin) Rate Case, 1992, "Rate of Rearm on
Equity, Cost of Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 6630-UR-106, Wisconsin
Electric Power Company Rate Case, 1992, "Rate of Remm on Equity, Cost of
Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 05-EI-112, Investigation on
the Commission's Own Motion Into Barriers to Contracts Between Electric
Utilities and Non -Utility Cogeneration; and Certain Related Policy Issues, 1992,
"Contract Risk in Long -Term Purchase Power Arrangements."
Public Service Commission of Wisconsin, Docket 3270-UR-106, Madison Gas
and Electric Company Rate Case, 1993, "Rate of Return on Equity, Cost of
Capital and Financial Condition."
37
ROGER SCHIFFMAN PAGE
TESTIMONY (CONTINUED)
Public Service Commission of Wisconsin, Docket 6630-CE-187, Wisconsin
Electric Power Company, 1993, "Memorandum to Commission Presenting
Economic Analysis of Competitively Bid Proposals for New Power Plants"
(co-authored).
Public Service Corarmssion of Wisconsin, Docket 6680-UR-108, Wisconsin
Power & Light Company Rate Case, 1993, "Rate of Return on Equity, Cost of
Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 4220-UR-107, Northern
States Power Company (Wisconsin) Rate Case, 1993, "Rate of Return can
Equity, Cost of Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 6630-CE-202, Wisconsin
Electric Power Company Auburn to Butternut Transmission
Line Case, 1994, `Bconotnic Cost Comparison of Transmission Upgrade and
Distributed Generation Wind Turbine Project"
Public Service Commission of Wisconsin, Docket 3270-UR-107, Madison Gas
and Electric Company, 1994 "Rate of Return on Equity, Cost of Capital and
Financial Condition."
Public Service Commission of Wisconsin. Docket 6690-CE-156, Application
of Wisconsin Public Service Corporation for Authority to Increase Electric
Generating Capacity (Stage One Competition Among Alternative Suppliers),
1994 & 1995, "Economic Analysis of Competitively Bid Power Plant
Proposals" (with Paul Newman), "Contract Risk in Purchased Power
Arrangements," "Accounting Treatment for Long -Tear Purchased Power
Contracts," "Contract Risk and Analysis of True -Up Mechanisms and
Balancing Accounts."
Public Service Commission of Wisconsin, Docket 6630-UM-100/4220-UM-
101, Wisconsin Electric Power Company/Northern States Power Company
Merger Case, 1996, "Market Power Remedies; State/Federal Jurisdictional
Issues."
Public Service Commission of Wisconsin, Docket 05-EP-7, Advance Plan 7,
1996, "Risk -Adjusted Discount Rates."
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ROGER SCHIFFMAN PAGE 10
TESTIMONY (CONTINUED)
Public Service Commission of Wisconsin, Docket 6680-UM-100, WPL
Holdings/IES Industries/Interstate Power Merger Case, 1997, "Market Power
Remedies; State/Federal Jurisdictional Issues."
Public Service Commission of Wisconsin, Docket 6630-UR-110, Wisconsin
Electric Power Company Rate Case, 1997, "Rate of Return on Equity, Cost of
Capital and Financial Condition."
Public Service Commission of Wisconsin, Docket 05-EP-8, Advance Plan 8,
1997, "Purchased Power Costs, Supply Planning Risks and Supply Planning
Parameters."
North Dakota Public Service Commission, Docket No. PU-399-01-186,
Montana -Dakota Utilities Co., 2000 Electric Operations Annual Report
(Commission Investigation of Excess Earnings), February, 2002, "Wholesale
power market conditions in the upper midwest, and the impact on the level and
profitability of off -system sales for MontanaDakotaUtilities Co."
California Public Utilities Commission, Rulemaking 02-01-011 Implementation
of the Suspension of Direct Access Pursuant to Assembly Bill 1X and Decision
O1-09-0. June, 2002. "Rebuttal Testimony of Roger Schiffman on behalf of
the California Department of Water Resources: Market modeling issues."
Washington DC Arbitration Panel, "Estimate of lost energy sales and lost
revenue due to construction delay" for two new combined cycle projects that
were built in Michigan and Arizona markets, January -February, 2006.
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