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DIRECT TESTIMONY of ANN E. BULKLEY on Behalf of Arizona Public Service Company Docket No. E-01345A-19-0236 October 31, 2019

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DIRECT TESTIMONY of ANN E. BULKLEY on Behalf of Arizona Public Service Company Docket No. E-01345A-19-0236 October 31, 2019 1 2 3 4 5 6 7 8 9 DIRECT TESTIMONY OF ANN E. BULKLEY 10 On Behalf of Arizona Public Service Company 11 Docket No. E-01345A-19-0236 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 October 31, 2019 28 1 Table of Contents 2 I. INTRODUCTION ............................................................................................................... 1 3 II. PURPOSE AND OVERVIEW OF DIRECT TESTIMONY .............................................. 2 4 III. SUMMARY OF ANALYSIS AND CONCLUSIONS ....................................................... 4 5 IV. REGULATORY GUIDELINES ......................................................................................... 9 6 V. CAPITAL MARKET CONDITIONS ............................................................................... 11 7 A. Effect of Market Conditions on Valuations and Dividend Yields ........................... 12 8 B. The Current and Expected Interest Rate Environment ............................................. 18 9 C. Effect of Tax Reform on the ROE ........................................................................... 24 10 VI. PROXY GROUP SELECTION ........................................................................................ 30 11 VII. COST OF EQUITY ESTIMATION ................................................................................. 32 12 A. DCF Model ............................................................................................................... 39 13 B. CAPM Analysis ........................................................................................................ 43 14 C. Bond Yield Plus Risk Premium Analysis ................................................................ 49 15 D. Expected Earnings Analysis ..................................................................................... 52 16 VIII. REGULATORY AND BUSINESS RISKS ...................................................................... 54 17 A. Regulatory Risk Assessment .................................................................................... 55 18 B. APS’s Capital Expenditure Plan .............................................................................. 57 19 C. Generation Risk ........................................................................................................ 59 20 IX. CAPITAL STRUCTURE .................................................................................................. 60 21 X. CONCLUSIONS AND RECOMMENDATION .............................................................. 61 22 XI. FAIR VALUE RATE BASE ............................................................................................. 62 23 XII. FAIR VALUE RATE OF RETURN ................................................................................. 68 24 25 ATTACHMENT LIST 26 Ms. Bulkley’s Resume and Testimony Listing .............................. Attachment AEB-1DR 27 Constant Growth DCF for Proxy Group ......................................... Attachment AEB-2DR 28 -i- 1 Projected DCF for Proxy Group ..................................................... Attachment AEB-3DR 2 Beta Estimates for Proxy Group ..................................................... Attachment AEB-4DR 3 Long-Term Growth Estimates for S&P 500 Index ........................ Attachment AEB-5DR 4 Capital Asset Pricing Model Analysis ............................................ Attachment AEB-6DR 5 Risk Premium Analysis .................................................................. Attachment AEB-7DR 6 Expected Earnings Analysis for Proxy Group ................................ Attachment AEB-8DR 7 8 Regulatory Risk Assessment for Proxy Group ............................... Attachment AEB-9DR 9 Comparison of Nuclear Generation for Proxy Group .................. Attachment AEB-10DR 10 Capital Structure Analysis ............................................................ Attachment AEB-11DR 11 Fair Value Rate of Return ............................................................. Attachment AEB-12DR 12 Comparable Transactions Analysis .............................................. Attachment AEB-13DR 13 Estimates of Inflation .................................................................... Attachment AEB-14DR 14 Yardeni Research Publication ...................................................... Attachment AEB-15DR 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -ii- 1 DIRECT TESTIMONY OF ANN E. BULKLEY ON BEHALF OF ARIZONA PUBLIC SERVICE COMPANY 2 (Docket No. E-01345A-19-0236) 3 I. INTRODUCTION 4 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 5 A. My name is Ann E. Bulkley. My business address is 293 Boston Post Road West, 6 Suite 500, Marlborough, Massachusetts 01752. 7 Q. WHAT IS YOUR POSITION WITH CONCENTRIC ENERGY ADVISORS, 8 INC. (CONCENTRIC)? 9 A. I am employed by Concentric as a Senior Vice President. 10 Q. ON WHOSE BEHALF ARE YOU SUBMITTING THIS DIRECT 11 TESTIMONY? 12 A. I am submitting this Direct Testimony on behalf of Arizona Public Service 13 Company (APS or the Company). APS is a wholly-owned subsidiary of Pinnacle 14 West Capital Corporation (Pinnacle West). 15 Q. PLEASE DESCRIBE YOUR EDUCATION AND EXPERIENCE. 16 A. I hold a Bachelor’s degree in Economics and Finance from Simmons College and 17 a Master’s degree in Economics from Boston University, with over 20 years of 18 experience consulting to the energy industry. I have advised numerous energy and 19 utility clients on a wide range of financial and economic issues with primary 20 concentrations in valuation and utility rate matters. Many of these assignments 21 have included the determination of the cost of capital for valuation and ratemaking 22 purposes. My resume and a summary of testimony that I have filed in other 23 proceedings are provided as Attachment AEB-1DR. 24 Q. PLEASE DESCRIBE CONCENTRIC’S ACTIVITIES IN ENERGY AND 25 UTILITY ENGAGEMENTS. 26 A. Concentric provides financial and economic advisory services to many and various 27 energy and utility clients across North America. Our regulatory, economic, and 28 1 market analysis services include utility ratemaking and regulatory advisory 2 services; energy market assessments; market entry and exit analysis; corporate and 3 business unit strategy development; demand forecasting; resource planning; and 4 energy contract negotiations. Our financial advisory activities include buy and 5 sell-side merger, acquisition and divestiture assignments; due diligence and 6 valuation assignments; project and corporate finance services; and transaction 7 support services. In addition, we provide litigation support services on a wide 8 range of financial and economic issues on behalf of clients throughout North 9 America. 10 II. PURPOSE AND OVERVIEW OF DIRECT TESTIMONY 11 Q. WHAT IS THE PURPOSE OF YOUR DIRECT TESTIMONY? 12 A. The purpose of my Direct Testimony is to present evidence and provide a 13 recommendation regarding the Company’s Return on Equity (ROE)1 and to 14 provide an assessment of the capital structure to be used for ratemaking purposes 15 as proposed in the Direct Testimony of APS witness Elizabeth A. Blankenship. 16 My Direct Testimony also provides evidence and a recommendation as to the 17 appropriate Fair Value Rate of Return (FVROR) and to the reasonableness of the 18 Company’s proposed Fair Value Rate Base (FVRB). My analyses and 19 recommendations are supported by the data presented in Attachment AEB-2DR 20 through Attachment AEB-15DR, which were prepared by me or under my 21 direction. 22 Q. PLEASE PROVIDE A BRIEF OVERVIEW OF THE ANALYSES THAT 23 LED TO YOUR ROE RECOMMENDATION. 24 A. As discussed in more detail in Section VI, in developing my ROE recommendation, 25 I applied the Discounted Cash Flow (DCF) model, the Capital Asset Pricing Model 26 27 1 Throughout my Direct Testimony, I interchangeably use the terms “ROE” and “Cost of 28 Equity.” -2- 1 (CAPM), a Risk Premium approach, and an Expected Earnings analysis. I also 2 considered several additional risk factors that affect the Company’s required ROE, 3 including: (1) the Company’s capital expenditure requirements relative to the 4 proxy group; (2) the Company’s regulatory risk relative to the proxy group, 5 including current and proposed adjustor mechanisms; and (3) the Company’s 6 dependence on nuclear generation. Finally, I considered the Company’s proposed 7 capital structure as compared to the capital structures of the proxy companies. 8 While I did not make any specific adjustments to my ROE estimates for any of 9 these factors, I did take them into consideration in aggregate when determining 10 where the Company’s Cost of Equity falls within the range of analytical results. 11 Q. WHAT ARE YOUR CONCLUSIONS REGARDING THE APPROPRIATE 12 COST OF EQUITY AND FVROR FOR APS? 13 A. My analyses indicate that APS’s Cost of Equity should be within a range from 14 10.00 percent to 10.50 percent. Considering the results of the analyses summarized 15 in Figure 1 and discussed in greater detail in the remainder of my testimony, I 16 believe that the Company’s requested ROE of 10.15 percent is reasonable and may 17 be a conservative estimate of the cost of equity. I also believe that the Company’s 18 proposed return on the Fair Value Increment of 1.00 percent is significantly lower 19 than reasonable estimates of the minimum rate of return that should be applied to 20 the fair value increment and results in an FVROR is 5.62 percent. 21 Q. WHAT ARE YOUR CONCLUSIONS REGARDING THE COMPANY’S 22 FVRB? 23 A. In order to determine the reasonableness of the Company’s FVRB, I conducted
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