BEFORE THE RÉGIE DE L'ÉNERGIE
IN THE MATTER OF:
HYDRO QUÉBEC TRANSÉNERGIE
Demande relative à la modification
des tarifs et conditions des services
de transport d'Hydro-Québec à
compter du 1er janvier 2009
DOSSIER R-3669-2008
prepared on behalf of:
l'Association québécoise des consommateurs
industriels d'électricité (AQCIE)
29 October 2008
Conseil de l'industrie forestière du Québec (CIFQ)
prepared evidence of:
Robert D. Knecht
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140
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My name is Robert D. Knecht. I am a Principal and the Treasurer of Industrial
Economics, Incorporated (“IEc”), a consulting firm located at 2067 Massachusetts
Avenue, Cambridge, MA 02140. As part of my consulting practice, I prepare analyses
and expert testimony in the field of regulatory economics. In Canada, I have
submitted expert evidence in regulatory proceedings in Québec, Ontario, Alberta, New
Brunswick, Nova Scotia, Manitoba, and Prince Edward Island.
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This is my first appearance in a proceeding involving Hydro Québec TransÉnergie
(“HQT”). I participated extensively in several hearings in Alberta regarding the
evolution of rates for transmission service, from the integrated utility-owned
“Gridco,” to the independent “Transmission Administrator,” and on to the current
Alberta Electric System Operator. Also, in matters regarding Hydro Québec
Distribution (“HQD”), I have submitted evidence or reports before the Régie in
dockets R-3477-2001, R-3492-2002 (Phases 1 and 2), R-3541-2004, 3563-2005, R3579-2005, R-3610-2006, R-3644-2007, R-3648-2007 and R-3673-2008.
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I obtained a B.S. degree in Economics from the Massachusetts Institute of Technology
in 1978, and a M.S. degree in Management from the Sloan School of Management at
M.I.T. in 1982, with concentrations in applied economics and finance. My curriculum
vitae and a schedule of my expert evidence presented to regulatory tribunals during
the past five years are attached as Exhibit RDK-1.
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I was retained by l'Association québécoise des consommateurs industriels d'électricité
(“AQCIE”) and the Conseil de l'industrie forestière du Québec (“CIFQ”) to evaluate
the cost allocation methods adopted by HQT in this proceeding, focusing on those
aspects that have changed since HQT’s last rates proceeding at Docket No. R-36402007. AQCIE/CIFQ also asked me to investigate any changes in cost allocation and
rate design proposals put forward by other parties in this proceeding.
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P L E A S E S U M M A R I Z E T H E M AT E R I A L S T H AT Y O U R E V I E W E D F O R T H I S
A S S I G N M E N T.
My review included the following materials:
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Various materials filed at Docket R-3549-2004, including some of the HQT
filing, and the evidence submitted by Dr. Orans, Dr. El-Ramly, Mr. Harper,
and London Economics, Inc. (“LEI”);
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The Régie’s decision in that proceeding at D-2006-66;
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HQT’s cost allocation study filed in R-3640-2007;
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The Régie’s decision at D-2008-019 (relating to cost allocation and rate
design matters);
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Excerpts from the filing in the current case, focusing on exhibits HQT-11
and HQT-12, with parts of exhibit HQT-1 for background and exhibit HQT9 for system planning;
Evidence of Robert D. Knecht
Docket No. R-3669-2008
1
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HQT responses to IRs from AQCIE/CIFQ, Option Consommateurs (“OC”),
and the Régie.
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In addition, as noted earlier, I participated in several HQD proceedings in which the
cost allocation methodology adopted by the Régie for HQT has been ported down to
the distribution level.
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As a newcomer to the HQT proceedings, I recognize that much water has already
flowed under the bridge, and that I still could benefit from additional review of all of
the history that supports the current HQT policies. I will continue to review the
historical record as this proceeding goes forward. The conclusions and
recommendations in this evidence are based on my current understanding and
evaluation, and I will notify the Régie promptly of any additional conclusions or
changes to this evidence.
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P L E A S E S U M M A R I Z E Y O U R U N D E R S TA N D I N G O F T H E K E Y C O S T
The Régie laid out the basics for both cost allocation and rate design in its decision D2006-66. For the purposes of this proceeding, HQT’s cost allocation study allocates
costs between native load service and point-to-point service. However, the results of
the cost allocation analysis are not used in the transmission rate design process. It
appears that the primary (or perhaps only) purpose of the transmission cost allocation
analysis is to establish the methodology for allocating transmission costs at the
distribution (HQD) level.
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In summary, HQT’s costs are functionalized into the five general categories listed
below, and then classified and allocated as follows:
F U N C T I O N A L I Z AT I O N , C L A S S I F I C AT I O N A N D A L L O C AT I O N A S P E C T S O F H Q T ’ S
C O S T A L L O C AT I O N S T U D Y.
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Generation Integration Facilities (Step-up transformers and connection
lines to the network): Costs are classified into energy and demand
components by system load factor, and allocated on energy and 1 CP
demand;
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High Voltage Network around Montréal and Montréal to Québec: Costs
are classified as 100% demand-related and allocated using a 1 CP demand
allocator;
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Very High Voltage and 450 kV Systems (including the very high voltage
transmission lines from power producing regions to consuming regions):
Costs are classified into energy and demand components by load factor,
and allocated on energy and 1 CP demand;
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Interconnections (including both Churchill Falls and others): Costs are
classified into energy and demand components by load factor, and
allocated on energy and 1 CP demand;
Evidence of Robert D. Knecht
Docket No. R-3669-2008
2
Customer Connections: Direct assignment.1
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For the 2009 study, the load factor classification split is approximately 58.5 percent
energy-related, 41.5 percent demand-related. In total, of HQT’s $2,876 million
revenue requirement, some 51 percent ($1,468 million) is demand-related, 29 percent
is energy-related ($835 million) and 20 percent ($573 million) is directly assigned.
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W H AT A R E T H E M A J O R C H A N G E S I N H Q T ’ S C O S T A L L O C AT I O N S T U D Y I N T H I S
PROCEEDING?
The major changes to HQT’s methodology are both quantitative and methodological.
At this writing, I have identified four material changes:
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First, HQT has segregated out some $86 million in costs that are “customer
connections of the type Toulnustouc,” which it has included in the customer
connections cost category, and which it has directly assigned to point-topoint service. At this writing, it is not clear to me where these costs were
previously recorded. The only cost category that shows a material decline
since 2008 is “other high voltage,” and that decline is some $30 million.
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Second, peak demand for point-to-point service has increased substantially,
from 591 MW in 2008 to 1934 MW in 2009.
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Third, because HQT does not meter energy used in point-to-point service
(nor does it bill on an energy basis), it must estimate the energy used for
cost allocation purposes. In 2008, the assumed load factor for point-topoint service was about 65 percent; in 2009, it is 57 percent. It is my
understanding that the 2009 load factor is based on extrapolating from
metered information for two export interconnections (HQT-MASS and
HQT-NE).
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Fourth, HQT’s revenue requirement includes some $44 million in costs
related to a new Ontario interconnection. HQT proposes to treat these costs
for cost allocation purposes in the same manner as all other interconnection
costs. That is, HQT classifies the costs using a load factor split and
allocates them using energy and 1 CP allocators. Under this method, some
94 percent of these costs are assigned to native load service.
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33
The first of these two changes contribute substantially to the rise in costs allocated
to point-to-point service from $38 million in last year’s study to $205 million in the
current study.
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DO YOU DISAGREE WITH ANY OF HQT’S PROPOSALS IN ANY OF THESE FOUR
AREAS?
Based on my review thus far, I am addressing only the issue of the classification and
allocation of Ontario interconnection costs. In both its decision in the last proceeding
1
See HQT-11, Document 2, Tables 7, 8 and 9
Evidence of Robert D. Knecht
Docket No. R-3669-2008
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1
2
and in Decision D-2008-116 in this proceeding, the Régie identified this cost
allocation issue as a matter of concern.2
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11
HQT’s proposal for the classification and allocation of these costs is based primarily
on Régie precedent. HQT offers little in the way of any analysis demonstrating that
the costs associated with the Ontario interconnection should be classified as 58.6
percent energy and 41.4 percent demand-related.3 Moreover, HQT does not explain
why these costs should be assigned as 94 percent related to native (HQD) load and
only 6 percent to point-to-point service. HQT’s argument is the (quite logical)
argument that cost causation for the Ontario interconnection is similar to the cost
causation for the “other interconnections,” and therefore the same methodology should
apply.4
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14
Nevertheless, because the Régie has identified this as an issue, it is reasonable to
subject it separately to cost causation principles. And, to do so, the key question that
should be asked is “why was this interconnection installed.”
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Based on my review of the evidence available, HQT’s justifications for this
interconnection appear to be:
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System reliability in that geographic region; and,
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Increased ability to trade with Ontario and/or wheel power through Québec.5
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In addition, it appears that the 1,250 MW interconnection capacity has been reserved
by HQP in total for 50 years.6 This suggests that the primary motivating factor for the
interconnection is export service.
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Thus, to the extent that the Régie wishes to focus on cost causation related to these
costs, I recommend that the costs be split 50/50 between native load service (for the
reliability benefits) and point-to-point service (for the export trade ability).
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Moreover, for the cost component that is related to reliability, I recommend that it be
classified as 100 percent demand-related. System reliability requirements are most
2
I recognize that the Régie also identified HQT’s estimate of the energy use by point-to-point
customers as an issue for this proceeding. However, I have no better information than that
used by HQT in this proceeding for such an estimate, and I therefore do not address this issue.
3
The system load factor used by HQT for classifying interconnection costs is slightly different
than that used for generation integration and other high voltage costs. See HQT-13, Document
4, pages 23 to 24.
4
This reference to “other interconnections” means the existing interconnections other than
Churchill Falls. Although D-2006-66 specifies that the same cost classification and allocation
methodology should apply to both the Churchill Falls and the other interconnections, the cost
causation factors for those two types of interconnections are quite different.
5
See, in particular, HQT-13, Document 4. Pages 16 to 19.
6
Id.
Evidence of Robert D. Knecht
Docket No. R-3669-2008
4
1
2
3
4
critical during peak periods. As such, there are no energy-related aspects to cost
causation. Unlike generation interconnections, where costs may be similar to the
fixed costs of generation, the interconnections are necessary to meet extreme
conditions. Therefore a demand classification is appropriate for these costs.
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7
D O Y O U H AV E A N Y A D D I T I O N A L C O N C L U S I O N S O R R E C O M M E N D AT I O N S
R E G A R D I N G H Q T ’ S C O S T A L L O C AT I O N A N D R AT E D E S I G N P R O P O S A L S .
Not at this time.
Evidence of Robert D. Knecht
Docket No. R-3669-2008
5
EXHIBIT IEc-1
CURRICULUM VITAE AND
EXPERT TESTIMONY SCHEDULE
OF
ROBERT D. KNECHT
Evidence of Robert D. Knecht
Docket No. R-3677-2008
ROBERT
D.
KNECHT
Robert D. Knecht specializes in the practical application of economics, finance and management theory
to issues facing public and private sector clients. Mr. Knecht has more than twenty years of consulting
experience, focusing primarily on the energy, metals, and mining industries. He has consulted to
industry, law firms, and government clients, both in the U.S. and internationally. He has participated in
strategic and business planning studies, project evaluations, litigation and regulatory proceedings and
policy analyses. His practice currently focuses primarily on utility regulation, and he has provided
analysis and expert testimony in numerous U.S. and Canadian jurisdictions. In addition, as Treasurer of
IEc since 1995, Mr. Knecht is responsible for the firm's accounting, finance and tax planning, as well as
administration of the firm's retirement plans. Mr. Knecht's consulting assignments include the
following projects:
C For the Pennsylvania Office of Small Business Advocate, Mr. Knecht provides analysis and expert
testimony in industry restructuring, base rates and purchased energy cost proceedings involving
electric, steam and natural gas distribution utilities. Mr. Knecht has analyzed the economics and
financial issues of electric industry restructuring, stranded cost determination, fair rate of return,
claimed utility expenses, cost allocation methods and rate design issues.
C For independent power producers and industrial customers in Alberta, Mr. Knecht has provided
analysis and expert testimony in a variety of electric industry proceedings, including industry
restructuring, cost unbundling, stranded cost recovery, transmission rate design, cost allocation and rate
design.
C For industrial customers in Québec, Mr. Knecht has prepared economic analysis and expert testimony
in regulatory proceedings regarding cost allocation, compliance with legislative requirements for crosssubsidization, and rate design.
C As part of international teams of experts, Mr. Knecht has prepared the economic and financial analysis
for industry restructuring studies involving the steel and iron ore industries in Venezuela, Poland, and
Nigeria.
C For the U.S. Department of Justice and for several private sector clients, Mr. Knecht has prepared
analyses of economic damages in a variety of litigation matters, including ERISA discrimination,
breach of contract, fraudulent conveyance, natural resource damages and anti-trust cases.
C Mr. Knecht participates in numerous projects with colleagues at IEc preparing economic and
environmental analyses associated with energy and utility industries for the U.S. Environmental
Protection Agency.
Mr. Knecht holds a M.S. in Management from the Sloan School of Management at M.I.T., with
concentrations in applied economics and finance. He also holds a B.S. in Economics from M.I.T. Prior
to joining Industrial Economics as a principal in 1989, Mr. Knecht worked for seven years as an
economic and management consultant at Marshall Bartlett, Incorporated. He also worked for two years
as an economist in the Energy Group of Data Resources, Incorporated.
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140 USA
617.354.0074 | 617.354.0463 fax
August, 2006
www.indecon.com
ROBERT D. KNECHT
EXPERT TESTIMONY SUBMITTED IN REGULATORY PROCEEDINGS: 2004 TO 2008
DOCKET #
REGULATOR
UTILITY
DATE
CLIENT
TOPICS
P-20082044561
Pennsylvania Public
Utility Commission
Pike County Light & Power
October 2008
Pennsylvania Office of
Small Business Advocate
Electric default service procurement
R-3673-2008
Régie de l’Énergie,
Québec
Hydro Québec Distribution
August 2008
AQCIE/CIFQ
Electric supply contract modifications.
1550487
Alberta Utilities
Commission
ENMAX Power Corporation
July 2008
D410 Group
Formula-based (performance-based)
ratemaking; ratepayer-supplied equity
contributions.
R-20082039417 et al.
Pennsylvania Public
Utility Commission
UGI Utilities (Gas Division)
July 2008
Pennsylvania Office of
Small Business Advocate
Design day demand forecast.
R-20082039284
Pennsylvania Public
Utility Commission
UGI Penn Natural Gas
July 2008
Pennsylvania Office of
Small Business Advocate
Revenue sharing, gas supply costs.
R-20082039634
Pennsylvania Public
Utility Commission
PPL Gas Utilities
July 2008
Pennsylvania Office of
Small Business Advocate
Lost and unaccounted-for gas, gas
supply costs.
A-20082034045
Pennsylvania Public
Utility Commission
UGI Utilities, PPL Gas
Utilities
June 2008
Pennsylvania Office of
Small Business Advocate
Public benefits of proposed sale.
R-20082011621
Pennsylvania Public
Utility Commission
Columbia Gas of Pennsylvania
May 2008
Pennsylvania Office of
Small Business Advocate
Cost allocation, revenue allocation, rate
design.
R-20082028039
Pennsylvania Public
Utility Commission
Columbia Gas of Pennsylvania
May 2008
Pennsylvania Office of
Small Business Advocate
Gas supply cost functionalization; cost
reconciliation method, sharing
mechanisms.
R-3648-2007
Régie de l’Énergie,
Québec
Hydro Québec Distribution
April 2008
AQCIE/CIFQ
Electric supply contract modifications.
R-20082021348
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
April 2008
Pennsylvania Office of
Small Business Advocate
Sharing mechanisms, gas supply
contracts.
R-20082012502
Pennsylvania Public
Utility Commission
National Fuel Gas Distribution
Company
March 2008
Pennsylvania Office of
Small Business Advocate
Transportation and sales customer rate
design, design day forecasts.
1
ROBERT D. KNECHT
EXPERT TESTIMONY SUBMITTED IN REGULATORY PROCEEDINGS: 2004 TO 2008
DOCKET #
REGULATOR
UTILITY
R-20082013026
Pennsylvania Public
Utility Commission
T.W. Phillips Gas and Oil
Company
P-00072342
Pennsylvania Public
Utility Commission
2007-004
DATE
CLIENT
TOPICS
March 2008
Pennsylvania Office of
Small Business Advocate
Rate design treatment of capacity
release revenues.
West Penn Power d/b/a
Allegheny Power
February 2008
Pennsylvania Office of
Small Business Advocate
Default service electricity procurement,
rate design, reconciliation.
New Brunswick Board
of Commissioners of
Public Utilities
New Brunswick Power
Distribution and Customer
Service Corporation
November 2007
New Brunswick Public
Intervenor
Cost allocation, revenue allocation, rate
design.
R-3644-2007
Régie de l'Énergie,
Québec
Hydro Québec Distribution
October 2007
AQCIE/CIFQ
Cost allocation, revenue allocation, rate
design.
P-00072305
Pennsylvania Public
Utility Commission
Pennsylvania Power
Corporation
July 2007
Pennsylvania Office of
Small Business Advocate
Default electric service procurement.
R-00072334
Pennsylvania Public
Utility Commission
UGI Penn Natural Gas, Inc.
July 2007
Pennsylvania Office of
Small Business Advocate
Asset management arrangement, gas
procurement.
R-00072333
Pennsylvania Public
Utility Commission
PPL Gas Utilities Corporation
July 2007
Pennsylvania Office of
Small Business Advocate
Design day forecasting, gas
procurement.
R-00072155
Pennsylvania Public
Utility Commission
PPL Electric Utilities
Corporation
July 2007
Pennsylvania Office of
Small Business Advocate
Cost allocation, revenue allocation, rate
design, energy efficiency.
R-00049255
(Remand)
Pennsylvania Public
Utility Commission
PPL Electric Utilities
Corporation
May 2007
Pennsylvania Office of
Small Business Advocate
Revenue allocation.
R-00072175
Pennsylvania Public
Utility Commission
Columbia Gas of
Pennsylvania, Inc.
May 2007
Pennsylvania Office of
Small Business Advocate
Gas procurement.
R-00072110
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
April 2007
Pennsylvania Office of
Small Business Advocate
Gas procurement, margin sharing
mechanisms.
R-00061931
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
April 2007
Pennsylvania Office of
Small Business Advocate
Cost allocation, revenue allocation,
retail gas competition.
P-00072245
Pennsylvania Public
Utility Commission
Pike County Light & Power
Company
March 2007
Pennsylvania Office of
Small Business Advocate
Default service procurement, rate
design.
2
ROBERT D. KNECHT
EXPERT TESTIMONY SUBMITTED IN REGULATORY PROCEEDINGS: 2004 TO 2008
DOCKET #
REGULATOR
UTILITY
R-00072043
Pennsylvania Public
Utility Commission
National Fuel Gas
Distribution Company
C-20065942
Pennsylvania Public
Utility Commission
R-3610-2006
DATE
CLIENT
TOPICS
March 2007
Pennsylvania Office of
Small Business Advocate
Design day requirements.
Pike County Light & Power
Company
November 2006
Pennsylvania Office of
Small Business Advocate
Wholesale power procurement by
provider of last resort.
Régie de l'Énergie,
Québec
Hydro Québec Distribution
November 2006
AQCIE/CIFQ
Post-patrimonial generation cost
allocation; cross-subsidization; rate
design.
P-00052188
Pennsylvania Public
Utility Commission
Pennsylvania Power
Company
September 2006
Pennsylvania Office of
Small Business Advocate
Affidavit: POLR rates, wholesale to
retail.
R-00061493
Pennsylvania Public
Utility Commission
National Fuel Gas
Distribution Corporation
September 2006
Pennsylvania Office of
Small Business Advocate
Rate of return, load forecasting, cost
allocation, revenue allocation, rate
design, revenue decoupling.
R-00061398
Pennsylvania Public
Utility Commission
PPL Gas Utilities Corporation
August 2006
Pennsylvania Office of
Small Business Advocate
Cost allocation, revenue allocation,
rate design.
R-00061365
Pennsylvania Public
Utility Commission
PG Energy/Southern Union
Company
July 2006
Pennsylvania Office of
Small Business Advocate
Merger savings, cost allocation,
revenue allocation, rate design.
R-00061519
Pennsylvania Public
Utility Commission
PPL Gas Utilities Corporation
July 2006
Pennsylvania Office of
Small Business Advocate
Design day weather and throughput
forecasts; gas supply hedging.
R-00061518
Pennsylvania Public
Utility Commission
PG Energy/Southern Union
Company
July 2006
Pennsylvania Office of
Small Business Advocate
Design day weather and throughput
forecasts; gas supply hedging.
A-125146
Pennsylvania Public
Utility Commission
UGI Utilities, Inc., Southern
Union Company
June 2006
Pennsylvania Office of
Small Business Advocate
Public benefits of proposed sale of PG
Energy to UGI; asset management
agreement.
R-00061355
Pennsylvania Public
Utility Commission
Columbia Gas of
Pennsylvania
May 2006
Pennsylvania Office of
Small Business Advocate
Gas supply and hedging plan;
procedural issues
R-00061296
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
April 2006
Pennsylvania Office of
Small Business Advocate
Gas procurement and procedural
issues.
R-00061246
Pennsylvania Public
Utility Commission
National Fuel Gas
Distribution
March 2006
Pennsylvania Office of
Small Business Advocate
Gas procurement; unaccounted for gas
retention rates.
2005-002
Refiling
New Brunswick Board
of Commissioners of
Public Utilities
New Brunswick Power
Distribution and Customer
Service Company
New Brunswick Public
Intervenor
Cost allocation, rate design.
February 2006
3
ROBERT D. KNECHT
EXPERT TESTIMONY SUBMITTED IN REGULATORY PROCEEDINGS: 2004 TO 2008
DOCKET #
REGULATOR
UTILITY
P-00052188
Pennsylvania Public
Utility Commission
Pennsylvania Power
Company
R-3579-2005
Régie de l'Énergie,
Québec
2005-002
DATE
CLIENT
TOPICS
December 2005
Pennsylvania Office of
Small Business Advocate
Cost allocation and rate design for
POLR supplies.
Hydro Québec Distribution
November 2005
AQCIE/CIFQ
Generation cost allocation; crosssubsidization; revenue allocation.
New Brunswick Board
of Commissioners of
Public Utilities
New Brunswick Power
Distribution and Customer
Service Company
August 2005
New Brunswick Public
Intervenor
Cost allocation, rate design.
R-00050538
Pennsylvania Public
Utility Commission
PG Energy
July 2005
Pennsylvania Office of
Small Business Advocate
Gas procurement diversification.
R-00050540
Pennsylvania Public
Utility Commission
PPL Gas Utilities Corporation
July 2005
Pennsylvania Office of
Small Business Advocate
Gas procurement, hedging, retention
rates, sharing mechanism.
R-00050340
Pennsylvania Public
Utility Commission
Columbia Gas of
Pennsylvania
May 2005
Pennsylvania Office of
Small Business Advocate
Gas procurement, hedging and
diversification.
R-3563-2005
Régie de l'Énergie,
Québec
Hydro Québec Distribution
April 2005
AQCIE/CIFQ
Generation cost allocation; industrial
demand response.
R-00050264
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
April 2005
Pennsylvania Office of
Small Business Advocate
Gas procurement, risk hedging,
financing costs in the gas cost rate.
R-00050216
Pennsylvania Public
Utility Commission
National Fuel Gas
Distribution
March 2005
Pennsylvania Office of
Small Business Advocate
Gas supply procurement and forward
pricing policies.
EB-2004-0542
Ontario Energy Board
Union Gas Limited
March 2005
Tribute Resources Inc.
Cost allocation and rate design for
service to embedded storage pools.
R-00049884
Pennsylvania Public
Utility Commission
Pike County Light and Power
(Gas Service)
January 2005
Pennsylvania Office of
Small Business Advocate
Fair rate of return, cost allocation,
class revenue assignment.
R-00049656
Pennsylvania Public
Utility Commission
National Fuel Gas
Distribution
December 2004
Pennsylvania Office of
Small Business Advocate
Fair rate of return, uncollectibles
costs, automatic rate adjustments,
cost allocation, rate design.
R-3541-2004
Régie de l'Énergie,
Québec
Hydro Québec Distribution
November 2004
AQCIE, CIFQ
Allocation of post-patrimonial
generation costs.
C-20031302
Pennsylvania Public
Utility Commission
Columbia Gas of
Pennsylvania
July 2004
Pennsylvania Office of
Small Business Advocate
Customer assistance program funding
and cost allocation.
R-049255
Pennsylvania Public
Utility Commission
PPL Electric Utilities
Corporation
June 2004
Pennsylvania Office of
Small Business Advocate
Transmission and distribution cost
allocation, rate design, automatic
distribution increases.
4
ROBERT D. KNECHT
EXPERT TESTIMONY SUBMITTED IN REGULATORY PROCEEDINGS: 2004 TO 2008
DOCKET #
REGULATOR
UTILITY
P-042090 et
al.
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
RP-2003-0203
Ontario Energy Board
R-049157
P-042090
DATE
CLIENT
TOPICS
June 2004
Pennsylvania Office of
Small Business Advocate
Collections and universal service cost
issues.
Enbridge Gas Distribution
May 2004
Vulnerable Energy
Consumers Coalition et
al.
Cost allocation, rate design for
pipeline and storage costs.
Pennsylvania Public
Utility Commission
Philadelphia Gas Works
April 2004
Pennsylvania Office of
Small Business Advocate
Cash receipts reconciliation clause.
R-049108
Pennsylvania Public
Utility Commission
National Fuel Gas
Distribution
March 2004
Pennsylvania Office of
Small Business Advocate
Uncollectible cost responsibility for
standby charges.
Application
1306819
Alberta Energy and
Utilities Board
ENMAX Power Corporation
January 2004
Calgary Industrial Group
Calgary Building Owners
T&D cost allocation, rate design,
ratepayer equity funding.
October 2008
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, MA 02140 USA
617.354.0074 | 617.354.0463 fax
www.indecon.com
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