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Llllllll\L\Ill\0 W 0 Nm05 I llllllll\l\ill\0 W 0 nm05"4"z:"'§"§"4"§"" 1 Melissa M. Krueger ORIGIN Thomas L. Mum aw r""~ 2 a Thomas A. Loquvam a 3 Pinnacle West Capital Corporation 400 North 5th Street, MS 8695 4 . "1 " rl:'**"l8 ¢=""Wt Phoenix, Arizona 85004 ll l 9 $4 myi »* I * _ . RU.. \".L1:L- '<' -.~s'T 1 Tel: (602)250-3630 "r*I ,. I I s - . 'JL 5 v \~ I L,-,;"\ x Fax: (602) 250-3393 i 6 E-Mail: [email protected] [email protected] 7 [email protected] 8 Attorneys for Arizona Public Service Company 9 1 0 BEFORE THE ARIZONA CORPORATION COMMISSION 11 COMMISSIONERS Arizona Cnmoratinss "Inf?;§T§%s386:! _¢*'~ ,~°~ . 1 2 §""s "Si ' i""~ ET"°'-8" :Hils T" 'i DOUG LITTLE, Chairman 1.) -L _ * *_JP 5 *= " 851 3- ",\:i BOB STUMP 4 13 2. 1) ,a *mF ,Q*oiii BOB BURNS s I l 1, TOM FORESE "w 14 3 ,,,,»..».1.\-.;~.2.-pUri" .. ANDY TOBIN : 15 5 1 -4uni 16 IN THE MATTER OF TI-IE APPLICATION DOCKET no. E.04204A-15_0142 OF UNS ELECTRIC, INC. FOR THE 17 ESTABLISHMENT OF JUST AND ARIZONA PUBLIC SERWCE REASONABLE RATES AND CHARGES CO1\1PANY'S NOTICE OF FILING 18 DESIGNED To REALIZE A SURREBUTTAL TESTIMONY REASONABLE RATE OF RETURN ON 19 THE FAIR VALUE OF THE PROPERTIES OF UNS ELECTRIC, INC. DEVOTED TO 2 0 ITS OPERATIONS THROUGHOUT THE STATE OF ARIZONA, AND FOR 21 RELATED APPROVALS.._ 22 23 Arizona Public Service Company provides notice of filing the Surrebuttal 24 Testimony of Ashley C. Brown, Ahmad Faruqui, Charles A. Miessner, and Cory Welch 25 in the above-referenced matter. 26 27 28 I'll I 1 RESPECTFULLY SUBMITTED this 23rd day of February 2016. 2 p 3 By: I77"£»=.wn¢4Ar* Melissa M. Er/ 4 Thomas L. Mum aw Thomas A. Loquvam 5 Attorneys for Arizona Public Service Company 6 7 ORIGINAL and diirteen (13) copies of the foregoing filed this 23rd day of 8 February 2016, with: 9 Docket Control 10 ARIZONA CORPORATION COMMISSION 11 1200 West Washington Street Phoenix, Arizona 85007 12 COPY of the foregoing mailed/delivered 13 this 23rd day of February 2016 to: 14 15 Jane L. Rodder Janice Alward Administrative Law Judge Legal Division 16 Arizona Corporation Commission Arlzona Corporation Commission 1200 W. Washier ton 1200 W. Washing ton 17 Phoenix, AZ 85807 Phoenix, AZ 85807 18 Brian Smith Thomas Broderick 19 Bridget Humphrey Utilities Division - Legal Division Arizona Corporation Commission 20 Arizona Corporation Commission 1200 W. Washier ton 1200 W. Washing ton Phoenix, Az 85807 21 Phoenix, Az 850807 22 Bradley S. Carroll Kirbg Chapman 23 UNS Electric, Inc. Sulp ur Springs Valley Electric 88 East Broadway Blvd. Cooperatlve, Inc. 24 Mail Stop HQE910 311 E. Wilcox P.O. Box 71 l Sierra Vista, AZ 85650 25 Tucson, AZ 85702 26 27 28 2 ll\l 1 Steve W. Chriss C. Webb Crockett Wal-Mart Stores, Inc. Patrick J. Black 2 2011 S.E. 10th Street Fennemore Crai , P.C. Bentonville, AR 72716-0550 2394 East Care back Road, Suite 600 3 Phoenix, AZ 85016 Attorneys for Freeport-McMoRan and 4 AECC 5 Jeffrey W. Crockett Kenneth R. Saline 6 Crockett Law Group PLLC K.R. Saline & Associates, PLC 2198 E. Camelback Road, Suite 305 160 N. Pasadena, Suite 101 7 Phoenix, Az 85016-4747 Mesa, AZ 85201 Attorney for SSVEC 8 Michael W. Patten Rick Gilliam 9 Jason D. Gellman Vote Solar Snell & Wilmer L.L.P. 1120 Pearl Street, Suite 200 10 One Arizona Center Boulder, CO 80302 400 E. Van Buren Street, Suite 1900 11 Phoenix, As 85004-2202 Attorneys for UNS Electric 12 13 Meghan Grabel Garry D. Has Osborn Maledon, P.A. 14 The Law Of ices of Garry D.Hays, PC 2929 North Central Avenue 2198 E. Camelback Rd., Suite 305 Phoenix, As 85012 15 Phoenix, AZ 85016 Attorney for AIC Attorney for ADSA 16 Katie A. Dittelberger Kevin C. Higgins 17 Earthjustice Ener y Strategies, LLC 633 17th Street, Suite 1600 215 South State Street, Suite 200 18 Denver, CO 80202 Salt Lake City, UT 84111 Attorneys for Vote Solar 19 20 Timothy M. Ho an Mark Holohan, Chairman 21 Arizona Center lm Law in the Public Ar*iSEIA Interest 2122 W. Lone Cactus Drive, Suite 2 22 514 W. Roosevelt Street Phoenix, AZ 85027 Phoenix, AZ 85003 23 Attorney for ACAA, Vote Solar, SWEEP & WRA 24 Briana Kobor Eric J. Lacey 25 Vote Solar Stone Mattheis Xenopoulos & Brew, PC 360 22nd Street, Suite 730 1025 Thomas Jefferson St., NW, 8th Fl. 26 Oakland, CA 94612 West Tower Washington, DC 20007-5201 27 Attorney for Nucor 28 3 H H H 1 Craig A. Marks Robert J. Metli Craig A. Marks, PLC Munger Chadwick, P.L.C. 2 10645 n. Tatum Blvd., Ste. 200-676 2398 East Camelback Road, Suite 240 Phoenix, AZ 85028 Phoenix, AZ 85016 ` 3 Attorney for AURA Attorney for Nucor 4 Jay I. Moyes Cynthia Zwick 5 Jason Y. Moyes Arizona Community Action Association Modes Sellers & Hendricks Ltd. 2700 n. 3rd Street, Suite 3040 6 1850 N. Central Ave., Suite 1100 Phoenix, AZ 85004 Phoenix, AZ 85004 7 Attorneys for FPAA 8 Vincent Nitido Jill Tauber 9 Trico Electric Cooperative, Inc. Chinyere A. Osuala 8600 W. Tangerine Road Earthjustice Washington DC Office 10 Mara fa, AZ 85653 1625 Massachusetts Avenue, NW, Suite 702 11 Washington, DC 20036-2212 12 Daniel W. Pozefsky Pat Quinn 13 Chief Counsel AURA RUCO 5521 E. Cholla St. 14 1110 W. WashierEton, Suite 220 Scottsdale, AZ 85254 Phoenix, Az 85 07 15 16 Col1IIt Rich Lawrence V. Robertson, Jr. Rose Law Group pp Attorney At Law 17 7144 E. Stetson Drive, Suite 300 2247 E. Frontage Road, Suite 1 Scottsdale, AZ 85251 P.O. Box 1448 18 Attorney for TASC Tubac, AZ 85646 Attorney for Noble Americas 19 20 Gary Yaquinto Ken Wilson Arizona Investment Council Western Resource Advocates 21 2100 N. Central Avenue, Suite 210 2260 Baseline Road, Suite 200 Phoenix, AZ 85004 Boulder, CO 80302 22 23 Ellen Zuckerman Jeff Schlegel 24 SWEEP Senior Associate 4231 E. Catalina Drive SWEEP Arizona Representative 25 Phoenix, As 85018 1167 W. Samalayuca Dr. Tucson, AZ 85704-3224 26 27 28 _4- 1 Scott Wakefield Timothy J. Saba Hienton & guns, P.L.L.C. Snell & Wilmer L.L.P. 2 5045 n. 12 Street, Suite 110 One Arizona Center Phoenix, As 85014-3302 400 E. Van Buren Street 3 Attorney for Wal-Malt Phoenix, AZ 85004 Attorney for Trico 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 1 2 3 4 5 6 7 8 9 10 11 12 13 SURREBUTTAL TESTIMONY OF ASHLEY c. BROWN 14 On Behalf of Arizona Public Service Company 15 Docket No. E-04204A-15-0142 16 17 18 19 20 21 22 23 24 25 26 27 February 23, 2016 28 Table of Contents 1 1. INTRODUCTION 1 2 11. THE EFFECT UNSE'S PROPOSAL WILL HAVE ON LOW INCOME 3 5 4 111. THE FUTURE OF SOLAR AFTER UNSE s PROPOSAL 9 5 IV. ARGUMENTS FOR DELAY AND INACTION SHOULD BE REJECTED no . 26 6 v. UNSE'S PROPOSAL FOR A RENEWABLE CREDIT RATE is AN APPROPRIATE WAY To COMPENSATE CUSTOMERS FOR ENERGY 7 ...35 8 VI. CONCLUSION 44 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 i SURREBUTTAL TESTIMONY OF ASHLEY c. BROWN 1 ON BEHALF OF ARIZONA PUBLIC SERVICE COMPANY (Docket No. E-04204A-15-0142) 2 1. INTRODUCTION 3 Q- PLEASE STATE YOUR NAME, OCCUPATION, AND ADDRESS. 4 5 A. My name is Ashley C. Brown. I am Executive Director of the Harvard Electricity Policy 6 Group (HEPG) at the Harvard Kennedy School, at Harvard University. HEPG is a 7 "think tank" on electricity policy, including pricing, market rules, regulation, 8 environmental and social considerations. HEPG, as an institution, never takes a position 9 on policy matters, so my testimony today represents solely my opinion, and not that of 10 the HEPG or any other organization with which I may be affiliated. 11 Q- PLEASE DESCRIBE YOUR PROFESSIONAL QUALIFICATIONS. 12 A. I am an attorney with extensive experience in infrastructure, especially energy and 13 regulatory matters. I served 10 years as a Commissioner of the Public Utilities 14 Commission of Ohio (1983-1993), where I was appointed and re-appointed by 15 Democratic Governor Richard Celeste. I also served as a member of the NARUC 16 Executive Committee and as Chair of the NARUC Committee on Electricity. I was a 17 member of the Advisory Board of the Electric Power Research Institute. I was also 18 appointed by the U.S. Environmental Protection Agency as a member of the Advisory 19 Committee on Implementation of the. Clean Air Act Amendments of 1990, where I 20 served on the subcommittee charged with implementing emissions trading. I am also a 21 past member of the Boards of Directors of the National Regulatory Research Institute 22 and the Center for Clean Air Policy. I have served on the Boards of Oglethorpe Power 23 Corporation, Entegra Power Group, and e-Curve, and as Chair of the Municipal Light 24 Advisory Board in Belmont, MA. I serve on the Editorial Advisory Board of the 25 Electricity Journal. 26 27 28 1 I have been at Harvard continuously since 1993. During that time I have also been 2 Senior Consultant at the firm of RCG/Hagler, Bailly, Inc.
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