via electronic and u.s. mail · tel (503) 241-7242 fax (503) 241-8160 [email protected]. suite 400 ....

TEL (503) 241-7242 ● FAX (503) 241-8160 ● [email protected]

Suite 400 333 SW Taylor

Portland, OR 97204

May 27, 2010 Via Electronic and U.S. Mail Public Utility Commission Attn: Filing Center 550 Capitol St. NE #215 P.O. Box 2148 Salem OR 97308-2148

Re: In the Matter of PGE Application for deferred accounting of 2010 pension expense Docket No. UM 1462

Dear Filing Center: Enclosed for filing please find an original and five copies of the Direct Testimony of Ellen Blumenthal (ICNU/100) with Exhibits (ICNU/101, ICNU/102, ICNU/103 and ICNU/104) on behalf of the Industrial Customers of Northwest Utilities in the above-referenced docket.

Thank you for your attention to this matter.

Sincerely yours, /s/Kelli R. Madden Kelli R. Madden Paralegal

Enclosures cc: Service List

CERTIFICATE OF SERVICE

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that I have this day served the foregoing Direct Testimony

of Ellen Blumenthal on behalf of the Industrial Customers of Northwest Utilities upon the

parties, on the service list, by causing the same to be deposited in the U.S. Mail, postage-prepaid,

and via electronic mail where paper service has been waived.

Dated at Portland, Oregon, this 27th day of May, 2010.

/s/Kelli R. Madden Kelli R. Madden

DEPARTMENT OF JUSTICE STEPHANIE S. ANDRUS (C) ASSISTANT ATTORNEY GENERAL REGULATED UTILITY & BUSINESS SECTION 1162 COURT ST NE SALEM OR 97301-4096 [email protected]

PUBLIC UTILITY COMMISSION OF OREGON DUSTIN BROWN PO BOX 2148 SALEM OR 97301 [email protected]

(W) CITIZENS' UTILITY BOARD OF OREGON GORDON FEIGHNER (C) ROBERT JENKS (C) G. CATRIONA MCCRACKEN (C) RAYMOND MYERS (C) 610 SW BROADWAY, SUITE 308 PORTLAND OR 97205 [email protected] [email protected] [email protected] [email protected] [email protected]

(W) PORTLAND GENERAL ELECTRIC RATES AND REGULATORY AFFAIRS DOUGLAS C TINGEY RANDALL DAHLGREN PATRICK G. HAGER CHRISTOPHER A. LIDDLE GENE LACKERSHIRE 121 SW SALMON ST - 1WTC0702 PORTLAND OR 97204 [email protected] [email protected] [email protected] [email protected]

BEFORE THE PUBLIC UTILITY COMMISSION

OF OREGON

UM 1462

In the Matter of PORTLAND GENERAL ELECTRIC COMPANY Application for Deferred Accounting of 2010 Pension Expense

) ) ) ) ) ) )

DIRECT TESTIMONY

OF ELLEN BLUMENTHAL

ON BEHALF OF

THE INDUSTRIAL CUSTOMERS OF NORTHWEST UTILITIES

May 27, 2010

ICNU/100 Blumenthal/1

Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 1

A. My name is Ellen Blumenthal. My business address is 13517 Queen Johanna Court, 2

Corpus Christi, Texas 78418. 3

Q. PLEASE OUTLINE YOUR FORMAL EDUCATION. 4

A. I received the degree of Bachelor of Arts in Journalism from the University of Texas 5

at Austin in 1974, but remained at the University to do additional course work in 6

accounting and business. I became a Certified Public Accountant in Texas in 1977. 7

Q. BY WHOM ARE YOU EMPLOYED AND IN WHAT CAPACITY? 8

A. I am a Principal with GDS Associates, Inc. (“GDS”). 9

Q. PLEASE OUTLINE YOUR PROFESSIONAL EXPERIENCE. 10

A. From 1975 to 1977, I worked in public accounting. My public accounting experience 11

included the preparation of financial statements, tax work, and auditing. In May 12

1977, I became a regulatory accountant with the Public Utility Commission of Texas 13

(“TPUC”). I left the TPUC in November 1980 to open an office in Austin for C.H. 14

Guernsey & Company, Consulting Architects and Engineers. I became an 15

independent consultant in 1982 and joined GDS in 2002. A copy of my résumé is 16

provided as Exhibit ICNU/101. 17

Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THIS COMMISSION? 18

A. Yes. Please see my résumé included at Exhibit ICNU/101 for details of my previous 19

appearances before the Oregon Public Utility Commission (“OPUC” or the 20

“Commission”) and other commissions. 21


Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY? 1

A. I have reviewed Portland General Electric Company’s (“PGE” or the “Company”) 2

request for authorization to defer its 2010 pension expense on behalf of the Industrial 3

Customers of Northwest Utilities (“ICNU”). I present my recommendations with 4

regard to the Company’s proposal. 5

Q. PLEASE SUMMARIZE YOUR RECOMMENDATIONS. 6

A. This Commission has determined the circumstances under which it will consider 7

allowing deferred accounting treatment. In my opinion, PGE’s 2010 pension expense 8

does not meet these criteria. Pension expense is a normal recurring cost of doing 9

business and, when there is an expense, it is included in base rates in a general rate 10

case. In addition, the magnitude of the estimated 2010 pension expense does not 11

warrant deferred accounting treatment. Therefore, PGE’s deferred accounting request 12

should be denied. 13

Q. BRIEFLY SUMMARIZE PGE’S PROPOSAL. 14

A. The Company estimates that its 2010 pension expense, calculated by its actuary 15

according to the requirements of Financial Accounting Standard (“FAS”) 87, will be 16

approximately $3.5 million. PGE’s current rates, which were set in UE 197, do not 17

include any pension expense because the Company did not request pension expense 18

in that case: 19

PGE requests no pension benefit cost in this proceeding because future 20 benefit obligations are less than the expected value of the assets 21 currently held in the plan. As in previous rate cases, we exclude a 22 negative net periodic pension cost from the test year revenue 23 requirement. According to the Employee Retirement Income Security 24 Act of 1974 (ERISA), PGE cannot use these plan assets for any 25 purpose other than funding retirement benefits, as long as the plan is in 26


operation. Therefore, regulatory orders commonly restrict pension 1 plan assets from offsetting operational costs. 2

Re PGE

Q. HOW WOULD THE DEFERRAL OF THE 2010 PENSION COST BE 6 RECOVERED FROM CUSTOMERS? 7

, OPUC Docket No. UE 197, Direct Testimony of Arleen Barnett and Joyce 3

Bell at 16, lines 9-15 (Feb. 27, 2008). PGE is proposing to defer its 2010 pension 4

expense, whatever amount it is, for later ratemaking treatment. 5

A. The Company’s testimony in this case merely states that the deferred pension expense 8

would receiver “later ratemaking treatment.”1

Q. HOW IS THE PENSION EXPENSE DETERMINED FOR INCLUSION IN 19 BASE RATES IN A GENERAL RATE CASE? 20

/ In its pending general rate case, 9

Docket UE 215, PGE is proposing a Pension Adjustment Mechanism (“PAM”), 10

which would be a separate tariff. The rate under this tariff would be updated annually 11

and would include the recovery of PGE’s FAS 87 estimated pension expense plus a 12

return on the regulatory asset in which PGE will record the deferred pension expense 13

and its cash contributions to the pension fund. The return would be earned at the 14

before tax rate of return approved in the Company’s most recent general rate case. 15

Whenever PGE has a general rate case, pension expense would be rolled into base 16

rates and the PAM would be set to zero. I assume the Company would use this 17

mechanism to recover the deferral. 18

A. FAS 87 was issued in December 1985. Many regulatory commissions, including this 21

one, adopted FAS 87 for ratemaking and include in rates the pension expense 22

calculated by actuaries in accordance with this accounting standard. Prior to the 23

1/ Re PGE, Docket No. UM 1462, PGE/100, Lackershire-Hager/10.


issuance of this statement, the pension expense that was included in rates was usually 1

the annual cash pension payments to retirees. 2

Q. HOW IS PENSION EXPENSE DETERMINED UNDER FAS 87? 3

A. Pension expense under FAS 87 is based on accrual accounting. The goal is to 4

recognize the compensation cost of an employee’s pension benefits during the 5

employee’s service period, while the employee is an employee rather than a retiree. 6

Because the pension benefit will be paid sometime in the future, assumptions must be 7

made about the future events that will determine both the amount and the timing of 8

the actual payments. These assumptions change from time to time. The performance 9

of the fund’s investments also changes from time to time. These factors, and others, 10

impact the actuarially determined pension expense. 11

Q. WHAT ARE THE CRITERIA THAT THE COMMISSION CONSIDERS FOR 12 DEFERRED ACCOUNTING TREATMENT? 13

A. In UM 1147, the Commission reaffirmed general principles it has followed for 14

evaluating whether deferred accounting treatment is appropriate. While the 15

Commission declined to set hard and fast rules, it stated that the first step in 16

evaluating whether deferred accounting is appropriate is to consider the nature of the 17

event, its impact on the utility, and the typical ratemaking treatment it would be 18

afforded in a general rate case. The Commission concluded that a reasonably 19

predictable and quantifiable risk is not appropriate for deferral. In other words, an 20

unpredictable and catastrophic event such as a hurricane that destroys a utility’s 21

infrastructure would most likely deserve deferred accounting treatment. 22


Q. IN WHAT SITUATIONS HAS THE COMMISSION ALLOWED 1 DEFERRALS? 2

A. The Commission has allowed deferrals for costs that are difficult to forecast or arise 3

from an event that is difficult to anticipate. The Commission also has allowed 4

deferred accounting when it needed to implement a new legislative mandate or 5

wished to encourage specific behavior by the utility or customers. 6

Q. WHY ISN’T PENSION EXPENSE A GOOD CANDIDATE FOR DEFERRED 7 ACCOUNTING TREATMENT? 8

A. Pension expense is a normal expense that is included in rates in a general rate case. 9

While the amount may fluctuate, it is reasonably predictable based on actuarial 10

calculations. When the assumptions inherent in the actuarial calculations change or 11

the financial performance of the fund changes, the FAS 87 pension expense changes. 12

Neither ratemaking nor the actuarial assumptions inherent in the FAS 87 13

calculation of estimated pension expense is perfect. The result is that there are likely 14

to be periods of time when the utility will recover pension expense through rates even 15

though it has no pension expense simply due to the timing of rate cases. For example, 16

from 1995 through 2001, PGE recovered approximately $5.7 million in rates while its 17

FAS 87 pension expense totaled a negative $57 million. And during 2007 and 2008, 18

the Company recovered $2.7 million through rates while its pension expense was 19

zero.2

2/ ICNU/102, Blumenthal/3 (PGE Response to OPUC Data Request (“DR”) 3).

/ 20


Q. WHAT FACTORS HAVE TRIGGERED THE INCREASE IN THE 1 ACTUARIALLY DETERMINED ESTIMATE OF PGE’S 2010 PENSION 2 EXPENSE? 3

A. The estimated pension expense has increased from less than $500,000 in 2009 to $3.5 4

million in 2010. The increase is mainly the result of changing some assumptions 5

used in the actuarial calculations such as the discount rate. For example, a decrease 6

of 10 basis points in the discount rate would increase pension expense by 7

approximately $525,222.3/ The Company estimates that a change of + 0.25% would 8

increase or decrease the $3.5 million estimated 2011 pension expense by $1.4 9

million.4/ For 2010, the Company’s actuary uses a 6.1% discount rate to estimate the 10

FAS 87 pension expense.5

Q. DOES THE PERFORMANCE OF THE PLAN’S INVESTMENTS IMPACT 12 THE FAS 87 EXPENSE? 13

/ 11

A. Yes, it does. The expected return on the plan’s assets is a component of the FAS 87 14

expense. The higher the return, the lower the FAS 87 pension expense. 15

Q. DOES THE COMPANY’S ACTUARY REVIEW AND REVISE THE FUTURE 16 FAS 87 ESTIMATED PENSION EXPENSE? 17

A. Yes. The Company provided estimates of its FAS 87 pension expense when it filed 18

its case in UE 215 on February 16, 2010. Those estimates have already been revised. 19

The revised estimate is approximately $2 million lower for 2011 and approximately 20

$2.3 million lower for 2012. Essentially, as the economy improves, so will the 21

earnings on the pension assets, which will drive down the pension expense. In the 22

3/ ICNU/103, Blumenthal/1 (PGE Response to OPUC DR 2). 4/ Re PGE, Docket No. UE 215, PGE/500, Barnett-Bell/5, lines 6-7; ICNU/104, Blumenthal/1 (PGE

Response to OPUC Data Request No. 100 in Docket No. UE 215). 5/ ICNU/104, Blumenthal/2-4 (PGE Response to OPUC DR 1).


past few years, pension expense has been zero because the pension fund was earning 1

good returns. 2

Q. PGE PROPOSES TO INCLUDE IN THE DEFERRAL AND IN THE PAM A 3 RETURN ON ITS CASH CONTRIBUTIONS TO THE PENSION PLAN. IS 4 THIS APPROPRIATE? 5

A. No. The Company implies that because the Pension Protection Act requires that the 6

pension trust actually be funded, it is the responsibility of ratepayers to pay the annual 7

FAS 87 pension expense as well as to contribute to the cash contributions necessary 8

to fully fund the pension trust. Ratepayers pay the estimated FAS 87 pension 9

expense, but should not contribute to the cash contributions. The FAS 87 pension 10

expense is the estimated pension cost for the employees who are currently working 11

for the Company. The Company should be placing these monies into the fund. It is 12

not meant to be used for other operations. 13

Q. HAS THE COMPANY MADE A CASH CONTRIBUTION TO THE PENSION 14 TRUST IN THE PAST FIVE YEARS? 15

A. Yes. PGE made a $10 million contribution in 2005 that it characterizes as one that 16

was not required.6

6/ Re PGE, Docket No. UM 1462, PGE/100, Lackershire-Hager/3, line 20.

/ As mentioned earlier, the Company recovered approximately $8.5 17

million through rates between 1995 and 2008. The monies collected through rates 18

should be deposited into the pension trust. Ratepayers should not be responsible for 19

the financial consequences of the Company’s decision not to deposit the pension 20

monies recovered through rates into the pension trust. 21


Q. IS THIS REQUEST FOR DEFERRED ACCOUNTING TREATMENT 1 PIECEMEAL OR SINGLE ISSUE RATEMAKING? 2

A. Yes, it is. PGE is asking this Commission to consider pension costs without 3

considering the other normal recurring costs of providing utility service. PGE incurs 4

many costs in the operation of its business besides pension costs. Between general 5

rate cases, some of these costs decrease while others increase. This does not justify 6

deferred accounting for those normal recurring costs that may increase between 7

general rate cases. PGE currently has a general rate case pending in which pension 8

expense will be considered and most likely included in base rates. 9

Q. WHAT WILL BE THE IMPACT ON PGE IF IT IS NOT ALLOWED TO 10 DEFER ITS 2010 PENSION EXPENSE FOR LATER RECOVERY 11 THROUGH RATES? 12

A. In its filing, PGE estimates that its 2010 net periodic pension cost will be 13

approximately $3.5 million. Total 2009 operating and maintenance expenses, 14

excluding net variable power costs, were $179.6 million. The $3.5 million pension 15

cost is less than 2 percent of this amount. 16

In my opinion, this pension expense does not meet the criteria the 17

Commission has provided for deferred accounting treatment. The impact on the 18

utility’s net income is not significant. Pension expense, when there is one, is 19

typically included in the utility’s revenue requirement in a general rate case. Deferred 20

accounting should only be used in exceptional circumstances, which this is not. This 21

request for deferred accounting can only be classified as a request for piecemeal 22

ratemaking. 23


Q. DOES THIS CONCLUDE YOUR TESTIMONY? 1

A. Yes, it does. 2


OF OREGON

UM 1462


) ) ) ) ) ) )

ICNU/101

QUALIFICATIONS OF ELLEN BLUMENTHAL

May 27, 2010

Ellen Blumenthal GDS Associates, Inc. Principal Page 1 of 6

GDS Associates, Inc. • 13517 Queen Johanna • Corpus Christi, TX 78418

361-949-1578 • Fax 361-949-4687 • [email protected] M a r i e t t a , G A • A u s t i n , T X • A u b u r n , A L • M a d i s o n , W I • M a n c h e s t e r , N H • w w w . g d s a s s o c i a t e s . c o m

EDUCATION: University of Texas at Austin Bachelor of Arts in Journalism, 1975 Certified Public Accountant in Texas, February 1977 PROFESSIONAL MEMBERSHIPS:

American Institute of Certified Public Accountants Texas Society of Certified Public Accountants EXPERIENCE: GDS Associates, Inc., March 2002 to present

Principal of GDS Associates, Inc., Engineers and Consultants, Corpus Christi, Texas. Provides financial analysis for natural gas and electric markets; assists consumers in acquiring power needs in the competitive markets; provides analysis in gas, electric, telephone and water utility rate increase filings and presents expert testimony in regulatory proceedings on behalf of interveners. Issues addressed in testimony include all aspects of revenue requirement determination.

Independent Consultant, June 1982 to February 2002

Financial analysis for natural gas and electric markets; Provided analysis and expert witness revenue requirements testimony in gas, electric, telephone and water utility rate increase applications on behalf of intervenors.

.

C. H. Guernsey & Co., Consulting Engineers & Architects, November 1980 - June 1982 Title: Regulatory Accountant and Financial Analyst Duties included preparation of financial and accounting aspects of rate filings for electric cooperatives for presentation before the Public Utility Commission of Texas. Testified as an expert witness on accounting matters before the Public Utility Commission of Texas. Advised electric cooperatives on accounting and regulatory matters. Participated in review of rate increase applications of investor-owned utilities and prepared and presented expert witness testimony based on such review. Participated in special projects such as cost-benefit analyses related to owner participation in power plants and alternative regulatory treatments for nuclear generating stations.

Public Utility Commission of Texas, May 1977 - November 1980

Title: Chief Accountant III Duties included providing expert witness testimony in investor-owned and cooperative telephone, electric and water utility rate cases filed with the Commission in the following areas: Fuel and purchased power, Operation and maintenance expenses, Federal income taxes, Taxes other than federal income taxes, Affiliate transactions, Oil and gas exploration and development. Reviewed the books and business records of public utilities to determine the reasonableness of rate requests. Reviewed public utilities' implementation of fuel adjustment clause and other rate schedules to determine compliance with tariffs approved by Commission.

Sample List of Testimony Filed and Other Utility Projects:

Application of Oncor Electric Delivery Company LLC for Authority to Change Rates, Texas Public Utility Commission Docket No. 35717, November 2008. Advisor to Nebraska Public Service Commission on gas utility regulatory matters. 2003 to present.





Portland General Electric Company General Rate Case, Oregon Public Utility Commission Docket UE 197, July 2008. Petition of PNM Resources, Inc. and Cap Rock Energy Corporation Regarding Merger and Acquisition of Stock, Texas Public Utility Commission Docket No. 35640, June 2008. Application of Entergy Gulf States for Authority to Change Rates, Texas Public Utility Commission Docket No. 34800, April 2008. Pacific Power & Light (dba PacifiCorp) to File Tariffs Establishing Automatic Adjustment Clause under the Terms of SB 408 on behalf of the Industrial Customers of Northwest Utilities, Public Utility Commission of Oregon Docket No. UE 177, January 22, 2008. Petition by New Mexico Utilities, Inc. for Authority to Amend Its Wastewater Rates, New Mexico Public Regulation Commission Case No. 07-00435-UT, November 2007.

United Water Connecticut, Inc. Application to Change Rates, Prepare rate filing and testimony. Connecticut Department of Public Utilities Docket No. 07-05-44, June 2007.

Application of AEP Texas Central Company for Authority to Change Rates, Texas Public Utility Commission Docket No. 33309, March 2007. Application of AEP Texas North Company for Authority to Change Rates, Texas Public Utility Commission Docket No. 33310, March 2007.

Staff’s Petition for a Reallocation of Stranded Costs Pursuant to PURA Sec. 139.253(f), Texas PUC Docket No. 32795, August 2006. Application of Bryan Texas Utilities for Interim Update of Wholesale Transmission Rates Pursuant to Substantive Rule 25.192(g)(1), Texas Public Utility Commission Docket No. 30925, March 2005; Docket No. 32958, June 2006. Application of AEP Texas Central Company for a Financing Order, Texas Public Utility Commission Docket No. 32475, April 2006. Application of Texas-New Mexico Power Company to Establish a Competition Transition Charge Pursuant to P.U.C. SUBST. R. 25.263(n), Texas Public Utility Commission Docket No. 31994, March 2006. Application of the Electric Reliability Council of Texas for Approval of the ERCOT System Administration Fee, Texas Public Utility Commission Docket No. 31824, January 2006. Application of Entergy Gulf States, Inc. for Recovery of Transition to Competition Costs, Texas Public Utility Commission Docket No. 31544, January 2006. Application of Sharyland Utilities, L.P. for Interim Update of Wholesale Transmission Rates Pursuant to Substantive Rule 25.192(g)(1), Texas Public Utility Commission Docket No. 31826, October 2005. Two management audits of the Sempra Energy utilities’ compliance with federal and state affiliate rules. October 2005





Petition to Inquire into the Reasonableness of the Rates and Services of Cap Rock Energy Corporation, Texas Public Utility Commission Docket No. 28813 on behalf of Pioneer Energy, August 2004. Application of CenterPoint Energy Houston Electric, LLC, Texas Genco, LP, and Reliant Energy Retail Services, LLC to Determine Stranded Costs and Other Balances, Texas PUC Docket No. 29526, on behalf of the City of Houston and the Coalition of Cities, June 2004. Application of AEP Texas Central Company for Authority to Change Rates, Texas PUC Docket No. 28840, on behalf of the Coalition of Commercial Ratepayers, February 2004. Application of the Electric Reliability Council of Texas to Change the ERCOT System Administrative Fee, Texas PUC Docket No. 28832, on behalf of the Office of Public Utility Counsel, January 2004. TXU Gas Company Statement of Intent to Change Rates in the Company’s Statewide Gas Utility System, Texas Railroad Commission Docket No. 9400, on behalf of Allied Coalition of Cities, December 2003. Application of Southwestern Electric Power Company for Authority to Reconcile Fuel Costs, Texas PUC Docket No. 28045, on behalf of the Cities Served, November 2003. Kansas Gas Service, a Division of Oneok, Inc. Application to Change Natural Gas Rates, Kansas Corporation Commission Docket 03-KGSG-602-RTS, on behalf of Unified School District No. 259, July 2003 Application of AEP Texas Central Company for Authority to Reconcile Fuel Costs, Texas PUC Docket No. 27035 on behalf of Affected Cities, April 2003. Application of West Texas Utilities Company for Authority to Reconcile Fuel Costs, Texas PUC Docket No. 26000 on behalf of the Office of Public Utility Counsel, October 2002. TXU Gas Distribution Application to Change Distribution Rates in its South Region on behalf of affected Texas municipalities, Fall 2002. Application of Ernest G. Johnson, Director of the Public Utility Division, Oklahoma Corporation Commission to Review the Rates, Charges, Services and Service Terms of Oklahoma Gas & Electric Company and all Affiliated Companies and any Affiliate or Non-Affiliate Transaction Relevant to Such Inquiry, Oklahoma Corporation Commission Cause No. PUD 200100455 on behalf of the Oklahoma Attorney General, June 2002. Petition of the Electric Reliability Council of Texas for Approval of the ERCOT Administrative Fee, Texas PUC Docket No. 23320 on behalf of Austin Energy, May 2002. Texas-New Mexico Power Company Application for Approval of Unbundled Cost of Service Rates, Texas PUC Docket No. 22349 on behalf of the Office of Public Utility Counsel, January 2001. TXU Lone Star Pipeline Application to Change the City Gate Rate, Texas Railroad Commission Docket No. 8976 on behalf of the Aligned Cities, January 2000. Reliant Energy HL&P Application for Approval of Unbundled Cost of Service Rates, Texas PUC Docket No. 22355 on behalf of the City of Houston and the Coalition of Cities, December 2000.





TXU Electric Company Application for Approval of Unbundled Cost of Service Rates, Texas PUC Docket No. 22350 on behalf of the Office of Public Utility Counsel, October 2000. Santa Fe Pipeline Partnership, L.P., FERC Docket No. OR92-8-000, et al on behalf of Refinery Holding Company, L.P., January 1996. Peoples Natural Gas Company, Rate Area Three on behalf of the Nebraska Municipalities Served, December 1995. Compliance review of Southern Union Gas Company's fuel cost recovery in the City of El Paso on behalf of the City of El Paso, Texas, Spring 1995. Houston Lighting and Power Company, Texas PUC Docket No. 12065 on behalf of Office of Public Utility Counsel, November 1994. El Paso Electric Company, Texas PUC Docket No. 12700 on behalf of Office of Public Utility Counsel and The City of El Paso, Texas, June 1994. Application of Central and South West Corporation and El Paso Electric Company For Approval of Acquisition, PUC Docket No. 12700 on behalf of Office of Public Utility Counsel, June 1994. El Paso Electric Company, Public Utility Regulation Board of The City of El Paso, Texas on behalf of the City of El Paso, Texas, May 1994. Kansas Pipeline Partnership and Kansas Natural Partnership, Kansas Docket No. 190,362-U on behalf of Citizens' Utility Ratepayer Board, September 1994. KN Energy, Inc., Kansas Corporation Commission Docket No. 186,363-U on behalf of Citizens' Utility Ratepayer Board, September 1993. City of Austin Water and Wastewater Utility before City Counsel on behalf of residential and small commercial ratepayers, October 1993. Texas Utilities Electric Company, Texas PUC Docket No. 11735 on behalf of Certain Cities Served by Texas Utilities Electric Company, September 1993. Complaint of General Counsel against Cherokee County Electric Cooperative, Inc. regarding application of Cherokee's switchover tariff, Texas PUC Docket No. 11351, on behalf of the Cooperative, June 1993. Texas Utilities Electric Company, Texas PUC Docket No.11735 on behalf of the Office of Public Utility Counsel, April 1993. Application of Entergy Corporation and GSU for Sale, Transfer or Merger, Texas PUC Docket No. 11292, on behalf of Office of Public Utility Counsel, January 1993. Peoples Natural Gas Company, Kansas Corporation Commission Docket No. 180,416-U, on behalf of the Citizens' Utility Ratepayer Board, August 1992.

Kansas Public Service Company, Kansas Corporation Commission Docket No. 179,484-U, on behalf of the Citizens' Utility Ratepayer Board, April 1992. Complaint of NBC Telecommunications, Inc. against Southwestern Bell Telephone Company, Texas PUC Docket No. 10762, on behalf of complainant, September 1992.




Central Texas Telephone Company, Texas PUC Docket No. 9981, on behalf of the Office of Public Utility Counsel, December 1991. Texas-New Mexico Power Company, Texas PUC Docket No. 10200, on behalf of the Office of Public Utility Counsel, December 1991. Greeley Gas Company, Kansas Corporation Commission Docket No. 177,142-U, on behalf of the Citizens' Utility Ratepayers Board, November 1991. Peoples Natural Gas Company, Rate Areas Two and Three on behalf of the Nebraska Municipalities Served, November 1991. Southern Union Gas Company El Paso Service Area, Public Utility Regulatory Board of El Paso on behalf of the City of El Paso, November 1991. City of Round Rock, Texas Water Commission Docket No. 8600-M, on behalf of Brushy Creek Municipal Utility District, October 1991. El Paso Electric Company, Texas PUC Docket No. 9945, on behalf of the Office of Public Utility Counsel, April 1991. Houston Lighting & Power Company, Texas PUC Docket No. 9850, on behalf of the Office of Public Utility Counsel, February 1991. Greeley Gas Company, Kansas Corporation Commission Docket No. 170,588-U, on behalf of the Citizens' Utility Ratepayers Board, August 1990. Rio Grande Valley Gas Company, Texas Railroad Commission Docket No. 7604, Consolidated, on behalf of the Intervener Cities, May 1990. Southern Union Gas Company El Paso Service Area, Public Utility Regulatory Board of El Paso on behalf of the City of El Paso, October 1990. Texas Utilities Electric Company, Texas PUC Docket No. 9300, on behalf of the Intervener Cities, April 1990. Gulf States Utilities Company, Texas PUC Docket No. 8702, on behalf of the Intervener Cities, July 1989. Central Power & Light Company, Texas PUC Docket No. 8646, on behalf of the Intervener Cities, June 1989. Lower Colorado River Authority, Texas PUC Docket No. 8400, on behalf of several wholesale customers, February 1989. Lower Colorado River Authority, Texas PUC Docket No. 8032, on behalf of several wholesale customers, June 1988. Tawakoni Water Utility Corporation, Texas Water Commission Docket No. 7368-R, on behalf of Tawakoni Water Consumers Association, January 1988. Hill Country Waterworks Company, Texas Water Commission Docket No. 172-W, on behalf of the City of Hill Country Village and the City of Hollywood Park, July 1987.





Detroit Edison Company, Michigan PSC, Case No. U-8683, on behalf of North Star Steel Michigan, May 1987. Gulf States Utilities Company, Texas PUC Docket No. 7195, on behalf of North Star Steel Texas, January 1987. Rio Grande Valley Gas Company, Texas Railroad Commission Docket No. 4717, 1984 and Docket No. 3858, on behalf of the Rio Grande Valley Cities, March 1982.

Lower Colorado River Authority, Texas PUC Docket No. 6027, on behalf of several wholesale customers, March 1985. Houston Lighting and Power Company, Texas PUC Docket No. 4540, August 1982, on behalf of the City of Houston. Houston Lighting & Power Company, Texas PUC Docket No. 3320, September 1980, on behalf of the Texas Public Utility Commission. Inquiry by Public Utility Commission of Texas into Certain Affiliate transactions of Texas Electric Service Company, Texas Power and Light Company and Dallas Power and light Company, Texas PUC Docket Nos. 1517, 1813 and 1903, February 1979, on behalf of the Texas Public Utility Commission.



OF OREGON

UM 1462


) ) ) ) ) ) )

ICNU/102

PGE RESPONSE TO DATA REQUEST

May 27, 2010


OF OREGON

UM 1462


) ) ) ) ) ) )

ICNU/103

PGE RESPONSE TO DATA REQUEST

May 27, 2010

January 7, 2010 TO: Vikie Bailey-Goggins Oregon Public Utility Commission FROM: Patrick G. Hager Manager, Regulatory Affairs

PORTLAND GENERAL ELECTRIC UM 1462

PGE Response to OPUC Data Request Dated December 18, 2009

Question No. 002 Request: For a 10 basis point change, in either direction, to the discount rate and rate of return, what would be the effect to the estimated net periodic pension cost? Response: PGE estimates that an increase of 10 basis points in the discount rate would result in a decrease of approximately $525,222 in the forecast 2010 net periodic pension cost. A decrease of 10 basis points in the discount rate would result in an increase of approximately $525,222 in the forecast 2010 net periodic pension cost. PGE estimates that an increase of 10 basis points in the expected rate of return would result in a decrease of approximately $460,000 in the forecast 2010 net periodic pension cost. A decrease of 10 basis points in the expected rate of return would result in an increase of approximately $460,000 in the forecast 2010 net periodic pension cost.

g:\ratecase\opuc\dockets\um-1462 (pension deferral)\dr-in\opuc_pge\finals\dr_002.doc



OF OREGON

UM 1462


) ) ) ) ) ) )

ICNU/104

PGE RESPONSES TO DATA REQUESTS

May 27, 2010

via electronic and u.s. mail · tel (503) 241-7242 fax (503) 241-8160 [email protected]. suite 400 ....

Documents