San Carlos Irrigation Project, Arizona (SCIP)

Competitive Position Analysis and Unbundled Retail Rate Study

KRSA managed the development of a competitive position analysis and the development of unbundled rates for the SCIP. This study included a detailed analysis of SCIP’s revenue requirements and the developmentof a crosswalk between the Federal Financial Accounting System and the FERC form of accounts. In this study, we also completed an analysis of SCIP’s current competitive position with respect to neighboring utilities in the new competitive environment as well as an analysis of the potential impacts of rulings from the Arizona Corporation Commission, state and federal legislation, and an independent system operator. Because SCIP historically charged a single electric rate for all its commercial customers, KRSA helped to complete a detailed load profile analysis for each of SCIP’s commercial electric customers to determine appropriate customer classifications. Ultimately, classifications for small, medium, large and industrial commercial classes were developed. The cost of service study determined the unbundled cost to serve each of the project’s customer classes and provided a guideline as to the rates and amount of revenues that should be recovered from each of SCIP’s customer class. At various stages throughout our analysis we also participated in a total of 12 presentations to SCIP’s customers and stakeholders to assure that interested parties were able to participate in the development of the rates and that the SCIP complied with all appropriate statutory regulations relating to setting rates.


Imperial Irrigation District, California

Open Access Tariff Development and Unbundled Transmission Rate Study Project

KRSA managed the development of an unbundled open access transmission rate analysis, the development of rates for ancillary services and the development of an open access tariff. This study included a detailed analysis of IID’s transmission related revenue requirements and the development costs associated with the provision of transmission service and various ancillary services. The cost of service study determined the unbundled cost of providing transmission service to customers wishing to use IID’s transmission system as well as the unbundled costs to provide scheduling services, regulation, energy imbalance, reactive supply & voltage control, spinning and supplemental reserves.


City of Safford, Arizona

Unbundled Retail Rate Study

KRSA managed the development of unbundled rates for the City in anticipation of the deregulated environment in Arizona. This study included a detailed analysis of the current competitive position of the City with respect to neighboring utilities in the new competitive environment as well as an analysis of the potential impacts of rulings from the Arizona Corporation Commission, state and federal legislation, and an independent system operator. The cost of service study determined the unbundled cost to serve each of the City's customer classes and provided a guideline as to the rates and amount of revenues that should be recovered from each of the City’s customer class.


Town of Thatcher, Arizona

Unbundled Retail Rate Study

Working with the town staff, KRSA developed an unbundled cost of service and electric rate study for the Town in anticipation of the deregulated environment in Arizona. Because the Town has historically charged a single electric rate for all its customers, our firm helped to complete a detailed load profile analysis for each of the Town’s electric customers to determine appropriate customer classifications. This study also includes a detailed analysis of the current competitive position of the City with respect to neighboring utilities in the new competitive environment as well as an analysis of the potential impacts of rulings from the Arizona Corporation Commission, state and federal legislation, and an independent system operator.


Town of Wickenburg, Arizona

Unbundled Retail Rate Study & Strategic Planning Analysis

Mr. Delaney has provided ongoing consulting engineering services and management consulting to the above clients with regard to their long-term and short-term electric operations since 1986. Mr. Delaney has performed various engineering and economic analyses for these entities, including the representation of these entities in front of numerous federal and state agencies. He makes recommendations to their management and governing bodies and negotiates necessary programs and policies on their behalf.


Arizona Hoover Hydro-Power Customers

Arizona Power Authority Resource Layoff Program

KRSA, on behalf of numerous APA customers, created a program providing for the integration of monthly Hoover schedules among Arizona Hoover customers. The program, administered by the APA, provides for the customers’ ability to use their diversity to better utilize the federal resource on an economic basis. KRSA has worked extensively to develop the program to meet the needs of the APA contractors and has made presentations to the APA Commission, managements and other agencies to support the project and has successfully assisted in documenting and implementing the layoff program on behalf of the many Arizona Hoover power users. This program has provided economic benefits in excess of $2 million annually to the participants.


SLCA/IP Power Contractors

Amendments to Western Area Power Administration Salt Lake City Area Integrated Project (SLCA/IP) Contracts

KRSA participated in numerous negotiations, public meetings and discussions related to changes in federal hydro power production and economic impacts resulting from the Glen Canyon Dam EIS, SLCA/IP Power Marketing EIS, Energy Planning and Management Program EIS and Grand Canyon Protection Act. KRSA has participated in the negotiating group on the SLCA/IP Contract Amendments No. 1, No. 2, No. 3 and the new Contract Amendment No. 4 which implements technical and contractual changes to accommodate the hydrologic changes of the resource resulting from the various environmental processes.

Arizona Wholesale Utilities

Arizona Corporation Commission Retail Access Regulations

KRSA is providing ongoing technical assistance and testimony on various issues related to retail electric deregulation and open access in Arizona for numerous small municipal utilities. KRSA has actively participated in the restructuring proceedings at the Arizona Corporation Commission (ACC) by participation as committee members in several ACC work groups, including the Stranded Costs Work Group, the Independent System Operator and Spot Market Work Group, the Metering and Billing Work Group, and the Reliability and Safety Work Group.


Arizona Transmission Dependent Utility (TDU) Group

Salt River Project Public Process on Customer Choice

On behalf of the TDUs, KRSA closely monitored SRP’s management proposals for customer choice, and participated in SRP’s public forums and board meetings. In addition to oral comments, KRSA filed a written statement with SRP, pointing out that SRP’s transmission and distribution system also serves numerous entities who are not subject to HB2663 but also provide electric service within SRP’s service area. The written statement stressed that the promulgation of retail access by SRP must be compatible with SRP’s Open Access Transmission Tariff and accommodate the service provided to other entities using SRP’s system.


Arizona Wholesale Utilities

State of Arizona House Bill 2663

KRSA provided technical expertise to participants of the committee that was assigned the task of the writing House Bill 2663, which is the Arizona electric deregulation legislation. KRSA closely followed each of the changes to the legislation as it went through various revisions, and offered technical analysis of the various provisions changing state law to include retail competition.


Arizona Consumer Owned Electric Systems (ACES)

Desert Star Independent System Operator Development

KRSA provided technical advice and representation for numerous TDUs at numerous meetings regarding the development of the Desert Star Regional Transmission Organization proposed for several southwestern states.


Arizona Transmission Dependent Utility Group

Southwest Regional Transmission Association

KRSA was very active in the SWRTA including serving as SWRTA President and the Planning Committee Vice Chair, as well as representing numerous TDU members at various meetings of SWRTA. SWRTA was a Regional Transmission Group formed pursuant to FERC Order 888 regarding the pricing and planning of transmission to promulgate open access on the transmission grid. SWRTA has recently merged with the Western Electricity Coordinating Council (WECC); this merger was completed with the guidance of and assistance provided by KRSA.


Arizona Transmission Dependent Utility Group

Firm Tradable Rights Work Group Within Western Interconnection

KRSA chaired the Firm Tradable Rights Work Group within the Western Interconnection to attempt to develop standards and procedures to be adopted by the ISOs and Control Areas within the Western Interconnection associated with Firm Transmission Rights. The California ISO has adopted many, if not all, of the complex components of the Work Group’s efforts.


Arizona Public Service Company Wholesale Customers

APS Open Access Transmission Tariff Rate Filing Before FERC

Working with legal counsel from Washington, DC, KRSA participated in interventions in Arizona Public Service Company’s Wholesale Open Access Transmission Tariff filings in Docket Nos. ER96-153-000 and ER96-2401-000. These filings dealt with APS required filings under FERC Order 888 and reflected functional unbundling of wholesale transmission services by APS. KRSA provided analysis and testimony on APS’ cost of service, revenue requirements, technical provisions and OATT rate provisions and assisted in FERC staff settlement negotiations settlement with the customer intervener group.


Irrigation & Electrical Districts Association of Arizona

Western Area Power Administration Open Access Transmission Tariff

KRSA held the Chair of the Colorado River Energy Distributors Association (CREDA) Open Access Transmission Tariff Work Group and assisted in analysis and development of Western Area Power Administration’s Open Access Transmission Tariff. KRSA directed the efforts of CREDA in public processes and coordinating customer comments for Western’s OATT development and associated FERC filings for three of Western’s offices.


Arizona Public Service Company Wholesale Customer Group

APS Wholesale Rate Filing at FERC

KRSA participated in interventions in Arizona Public Service Company’s wholesale rate filing ER89-265-000. The filing dealt with wholesale transmission and power supply rates filed by APS on numerous wholesale customers. KRSA provided an analysis of APS’ cost of service and revenue requirements and assisted in settlement negotiations and economic analyses of various alternatives of settlement with the customer group. The intervention was ultimately settled between the customers and APS.


Numerous Federal Contractors in Arizona

Arizona Federal Power Contractors

Western Area Power Administration: Joint Planning Agreement, 10 Year Planning Policy and Agency Regulations

KRSA participated in a select group of customer representatives in negotiating new policies with the Western Area Power Administration to reinvent the federal practices for planning, constructing and funding transmission system improvements to the federal transmission system. A direct result of the policy changes was approximately 30% reductions by equalizing annual revenue requirements, development of annual planning processes, and revised federal rate proceedings including timely customer participation. The partnership proposal contained in these policy changes was fundamental in providing customer participation in the Agency decisions for operating and maintaining the system.


Arizona CRSP and Parker-Davis

Hydro-Power Customers Integrated Resource Scheduling Agreement

KRSA, on behalf of numerous small Western customers, created a program providing for the integration of the federal hydro-power schedules from Western to improve the economic dispatch of the participants and better utilize the diversity of the federal resource on an economic basis. KRSA negotiated the contract with Western, made presentations to managements and other agencies to support the project and has successfully implemented the integrated scheduling of federal resources on behalf of these entities. This resource management program has provided significant economic benefits to the participants.