Virginia Electric and Power Company Subsection A 4 Rate Adjustment Clause. Direct Testimony and Exhibits

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2 Virginia Electric and Power Company Subsection A 4 Rate Adjustment Clause Table of Contents Direct Testimony and Exhibits David M. Wilkinson James D. Jackson, Jr. Paul B. Haynes Filing Schedule 46 Filing Schedule 46A Filing Schedule 46B Filing Schedule 46C

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4 COMMONWEALTH OF VIRGINIA STATE CORPORATION COMMISSION APPLICATION OF VIRGINIA ELECTRIC AND POWER COMPANY For approval of a rate adjustment clause pursuant to A 4 of the Code of Virginia Case No. PUE APPLICATION Virginia Electric and Power Company, d/b/a Dominion Virginia Power ("Dominion Virginia Power" or the "Company"), by counsel, pursuant to A 4 ("Subsection A 4") of the Code of Virginia ("Va. Code") and 20 VAC ,20 VAC , and 20 VAC of the Commission's Rules Governing Utility Rate Applications and Annual Informational Filings, 20 VAC , et seq. (the "Rate Case Rules"), respectfully files its Application 1 with the State Corporation Commission of Virginia (the "Commission") for approval of a revised increment/decrement RAC, designated as Rider T1, for an adjustment to the Company's recovery of costs recoverable under Subsection A 4, described in detail below and currently being recovered through a combination of the Subsection A 4 component of base rates and current Rider Tl. Approval of this revised Rider T1 will assure the timely and current recovery of the Company's Subsection A 4 revenue requirement for the rate year September 1, August 31,2015 ("Rate Year"), including (i) costs charged to the Company by PJM 1 In its initial Subsection A 4 rate adjustment clause ("RAC") filing in Case No. PUE , the Company styled its initial pleading as a petition, consistent with the language of Subsection A 4 stating that "[u]pon petition of a utility... the Commission shall approve a rate adjustment clause" under that subsection. In its April21, 2009 Order for Notice and Hearing, and throughout that proceeding, the Commission described that filing as an application, consistent with Rule 80 of its Rules of Practice and Procedure, 5 V AC , and Rules and 60 of its Rate Case Rules, 20 VAC and -60, respectively. To avoid potential confusion, this filing is styled as an application consistent with the Commission's approach in Case No. PUE

5 Interconnection, L.L.C. ("PJM") for transmission services provided to the Company by PJM, as determined under applicable rates, terms, and conditions approved by the Federal Energy Regulatory Commission ("FERC"); and (ii) costs charged to the Company by PJM associated with demand response programs approved by FERC and administered by PJM. In support of its Application, the Company respectfully shows the following: I. GENERAL INFORMATION 1. Dominion Virginia Power is a public service corporation organized under the laws of the Commonwealth of Virginia furnishing electric service to the public within its certificated service territory. The Company also supplies electric service to nonjurisdictional customers in Virginia and to the public in portions of North Carolina. The Company is engaged in the business of generating, transmitting, distributing, and selling electric power and energy to the public for compensation. The Company is also a public utility under the Federal Power Act, and certain of its operations are subject to the jurisdiction of the FER C. The Company is an operating subsidiary of Dominion Resources, Inc. The Company's name and post office address are: Virginia Electric and Power Company 120 Tredegar Street Richmond, Virginia The addresses and telephone numbers of the attorneys for the Company are: Lisa S. Booth William H. Baxter ll Dominion Resources Services, Inc. 120 Tredegar Street, RS-2 Richmond, Virginia (804) (804) lisa.s.booth@dom.com william.h.baxter@dom.com 2

6 Stephen H. Watts, II Joseph K. Reid, III Lisa R. Crabtree McGuire Woods LLP One James Center 901 East Cary Street Richmond, Virginia (804) (804) (804) mcguirewoods. com mcguirewoods. mcguirewoods. com II. BACKGROUND, SUMMARY AND BASIS FOR SUBSECTION A 4 RAC 3. Subsection A 4, adopted during the 2007 Session of the Virginia General Assembly as part of what is now known as the Virginia Electric Utility Regulation Act (the "Act"), provides that the following costs incurred by an investor-owned incumbent electric utility, 2 such as the Company, "shall be deemed reasonable and prudent": "(i) costs for transmission services provided to the utility by the regional transmission entity of which the utility is a member, as determined under applicable rates, terms and conditions approved by the Federal Energy Regulatory Commission" ("A 4(i) Costs"); and "(ii) costs charged to the utility that are associated with demand response programs approved by the Federal Energy Regulatory Commission and administered by the regional transmission entity of which the utility is a member" ("A 4(ii) Costs"). Subsection A 4 provides further that "[u]pon petition of a utility at any time after the expiration or termination of capped rates, but not more than once in any 12-month period, the Commission shall approve a rate adjustment clause under which such costs, including, without limitation, costs for transmission service, charges for new and existing transmission facilities, administrative charges, and ancillary service charges designed to recover 2 The term "incumbent electric utility" is defined for purposes of to mean "each electric utility in the Commonwealth that, prior to July 1, 1999, supplied electric energy to retail customers located in an exclusive service territory established by the Commission." Va. Code

7 transmission costs, shall be recovered on a timely and current basis from customers." Finally, Subsection A 4 states that "[r]etail rates to recover these costs shall be designed using the appropriate billing determinants in the retail rate schedules." 4. Effective May 1, 2005, the Company became a member of PJM, a regional transmission entity that has been approved as a regional transmission organization ("RTO") by FERC, at which time PJM assumed operational control of the Company's electric transmission facilities, and the Company gained direct access to the PJM capacity and energy markets. Accordingly, PJM is "the regional transmission entity of which the [Company] is a member" for the purposes of Subsection A 4. As an integrated electric utility member of PJM, the Company obtains transmission service from PJM and pays PJM charges for such service at the rates contained in PJM's Open Access Transmission Tariff ("PJM OATT") approved by FERC. These charges constitute A 4(i) Costs and include: A. Network Integrated Transmission Service ("NITS") charges in accordance with the PJM OATT, Attachment H-16, Annual Transmission Charges- Virginia Electric and Power Company, based on PJM rates for calendar years 2013 and 2014; B. Annual PJM charges under the PJM OATT, Schedule 12, Transmission Enhancement Charges, (which are based upon the latest data available through PJM) for net transmission service enhancement costs/credits; C. PJM administrative charges calculated under the PJM OATT, Schedule 9, Administrative Services; and D. PJM charges under the PJM OATT, Schedule la for Scheduling, System Control, and Dispatch Service ancillary services. 3 3 The Company currently recovers these costs through its NITS rate and, therefore, does not have a separately stated rate in the PJM tariff for these ancillary services. 4

8 5. The Company also pays PJM charges for the costs of PJM demand response programs- i.e., the Economic Load Response Program and the Emergency Load Response Program- determined in accordance with Section 3.3A of Attachment K of the PJM OATT, the last section of Attachment K (labeled Emergency Load Response Program), and Attachments D and DD-1 of the PJM OATT. Both are demand response programs approved by PERC and administered by PJM and, as such, constitute A 4(ii) Costs. Accordingly, the Company has incurred, and will continue to incur, these A 4(i) and A 4(ii) Costs (collectively, the "Subsection A 4 Costs"), which are deemed by Subsection A 4 to be reasonable and prudent. 6. The Company made its initial filing for Commission approval of a Subsection A 4 RAC, designated Rider T, on March 31,2009 in Case No. PUE ("2009 Rider T Case"), seeking recovery of a total revenue requirement of $227.3 million for the rate year of September 1, 2009 through August 31, 20, partially offset by a $149.4 million reduction in base rates due to the removal of transmission rates then included in base rates, for an annual net increase in Rider T of $77.9 million. On June 29, 2009, the Commission issued its Final Order in that proceeding ("2009 Rider T Order") approving the proposed initial Rider T, with certain modifications. The Commission approved: the Company's proposed formula methodology for determining the revenue requirement for the next Rider T application; the Company's proposed deferral and true-up methodologies and proposed rate design; and the Company's recovery of Interruptible Load for Reliability ("ILR") costs. 4 The Commission excluded from Rider T recovery of five PJM administrative charges and the Company's proposed carrying costs on the deferred balance of Rider T. The Commission also directed certain modifications to the 4 The Commission also approved the recovery of deferred RTO costs approved by FERC in Docket No. ER and billed to the Company under PJM's Rate Schedule DRC ("DRC Costs"). However, as discussed in Paragraph 7, infra, consistent with the Commission's March 11, 20 Order Approving Stipulation and Addendum in Case Nos. PUE , et al. (including the 2009 Rider T Case), the Company agreed, and was directed, to waive recovery of the DRC Costs after December 31, 20 I 0. 5

9 Company's proposed rates applicable to Section customers ("Special Contract Rates"). 5 On July 24, 2009, the Company timely made its compliance filing with the Commission's Division of Energy Regulation (the "Division"), including the final initial Rider T designed to recover a revenue requirement of $217.4 million over the September 1, 2009 August 31, 20 rate year, which the Division accepted by letter dated August 14, On March 11, 20, the Commission entered its Order Approving Stipulation and Addendum in Case Nos. PUE , et al. (including the 2009 Rider T Case), under which, among other things, the Company was directed, as it had agreed, to waive recovery of DRC Costs after December 31, On March 31, 20, the Company made its first revised Subsection A 4 RAC filing in Case No. PUE ("20 Rider T Case"), seeking recovery of a total revenue requirement of $339 million, representing an annual revenue increase of $119 million for the rate year beginning September 1, 20. In addition to the formula methodology and deferral and true-up mechanisms approved in the 2009 Rider T Order, the Company proposed the updating of certain Subsection A 4 Costs that would be incurred by the Company for the period January 1 through August 31, 20 based upon known changes from corresponding components of the cost of service used to develop the Rider T rates then currently in effect. The Company and the Commission Staff agreed that the revenue requirement should be reduced to $337.9 million. In its Final Order issued June 29, 20 ("20 Rider T Order"), the Commission approved the agreed revised revenue requirement of $337.9 million and the methodologies and mechanisms proposed by the Company to develop it, including the update of certain Subsection A 4 Costs for known changes, as well as the Company's proposed cost allocation and rate design. On July 29, 5 The Commission found it reasonable to require the Company to (i) assess the energy-allocated cost of transmission as a per kilowatt-hour ("kwh") rate, and (ii) design the unit rate by dividing the energy-allocated transmission cost by the kwh consumption figure used in allocating that cost to the Special Contract Rates. 6

10 20, the Company timely made its compliance filing with the Division, including the final initial Rider T (including DRC Costs effective September 1, 20) and final revised Rider T (excluding DRC Costs effective January 1, 2011) designed to recover a revenue requirement of $337.9 million for the September 1, 20- August 31, 2011 rate year. The Division accepted the initial Rider Ton August 16, 20 and stated that the revised Rider T would be accepted for filing closer to its effective date. On December, 20, the Company resubmitted the revised Rider T, which the Division accepted on December 27, On May 2, 2011, the Company made its second revised Subsection A 4 RAC filing in Case No. PUB ("2011 Rider T Case"), seeking recovery of a total revenue requirement of $480.7 million, representing an annual revenue increase of $143.7 million for the rate year September 1, August 31, The Company's proposed revenue requirement used the same methodology as approved in the 20 Rider T Order with three exceptions. First, the DRC cost calculation (previously Formula Schedule 7) was removed from the revenue requirement formula, consistent with the discussion in footnote 4 and paragraph 7 above. Second, the 2009 true-up was adjusted to reflect a recalculation of the 2008 and 2009 demand allocation factors, which reduced the revenue requirement. Finally, the Company requested canying costs with respect to the cumulative monthly under- or over-recovery deferral balance under the true-up mechanism for Rider T. In its Final Order issued July 19, 2011 ("2011 Rider T Order"), the Commission approved a revenue requirement of $466.4 million, the removal of the DRC cost calculation, and the correction to the jurisdictional allocation factors, but denied the request for carrying costs. The Commission further approved the Company's proposed rate design and allocation of costs. On August 4, 2011, the Company timely made its compliance filing with the Division, including a revised Rider T designed to recover a revenue requirement 7

11 of $466.4 million over the September 1, August 31, 2012 rate year. The Division accepted the revised Rider T on August 18, On July 29, 2011, in Case No. PUE ("Standby Charge Proceeding"), the Company sought approval, pursuant to Va. Code F, 6 of a standby charge and methodology to be applicable to residential eligible customer-generators who engage in net energy metering under Va. Code and have a capacity that exceeds kilowatts ("kw"), but is not greater than 20 kw. As pertinent to this Application, with respect to the recovery of transmission-related costs, the Company proposed that the applicable eligible customergenerators pay the greater of the usage-based (per kwh) Rider T charge or an alternative Rider T demand-based (per kw) charge, resulting in a standby charge comprising the difference between the demand-based charge and the usage charge, but not less than zero. On November 23, 2011, Commission issued a Final Order which, among other things, approved the transmission-related standby charge as a component of Rider T to be effective on and after April1, On December 13, 2011, the Company submitted the approved revisions to the Rider T tariff, which were filed with the Clerk of the Commission and sent to the Division on December 14, On December 14, 2011, the Division accepted the revised tariffs. 6 Va. Code F currently provides: Any residential eligible customer-generator or eligible agricultural customergenerator who owns and operates, or contracts with other persons to own, operate, or both, an electrical generating facility with a capacity that exceeds kilowatts shall pay to its supplier, in addition to any other charges authorized by law, a monthly standby charge. The amount ofthe standby charge and the terms and conditions under which it is assessed shall be in accordance with a methodology developed by the supplier and approved by the Commission. The Commission shall approve a supplier's proposed standby charge methodology if it finds that the standby charges collected from all such eligible customergenerators and eligible agricultural customer-generators allow the supplier to recover only the portion ofthe supplier's infrastructure costs that are properly associated with serving such eligible customer-generators or eligible agricultural customer-generators. Such an eligible customer-generator or eligible agricultural customer-generator shall not be liable for a standby charge until the date specified in an order of the Commission approving its supplier's methodology. 8

12 11. On May 2, 2012, the Company made its third revised Subsection A 4 RAC filing in Case No. PUE ("2012 Rider T1 Case") seeking recovery of a total revenue requirement under Subsection A 4 of $372,900,596, representing an annual revenue decrease of $99,556,568 for the rate year September 1, August 31, In its application, the Company also requested an ongoing limited waiver of filing Schedule 46 as to FERC rulings and Schedule 46B materials that had been previously filed as part of Company applications in previous Subsection A 4 RAC proceedings, which was granted by the Commission in its May 9, 2012 Order for Notice and Hearing in the 2012 Rider T1 Case. The Company requested the implementation of Rider T1 to be an increment/decrement rider adjusting the recovery of Subsection A 4 costs that were combined into base rates as a result of the Company's 2011 Biennial Review. In its Final Order issued August 2, 2012 ("2012 Rider T1 Order"), the Commission approved implementation of Rider T1 as an increment/decrement rider. Subsection A 4 revenues and costs were also approved to be tracked separately in base rates, and the continued use of deferral accounting and true-ups of all Subsection A 4 revenues and costs was affirmed. The 2012 Rider T1 order approved Rider T1 in the decrement revenue requirement amount of ($99,556,568) to be effective for service rendered on and after September 1, On August 9, 2012, the Company timely made its compliance filing with the Division including Rider T1 designed to recover a decrement revenue requirement of ($99,556,568) over the September 1, August 31,2013 rate year. On August 17,2012, the Division accepted the revised tariffs. 12. On May 2, 2013, the Company made its fourth revised Subsection A 4 RAC filing in Case No. PUE ("2013 Rider T1 Case"), seeking recovery of a total revenue requirement under Subsection A 4 of $404,390,704, representing a $21,708,898 increase from the projected revenues associated with then-effective Subsection A 4 base rates determined for 9

13 the rate year and then-effective Rider Tl. Consistent with the approach approved by the Commission in the 2012 Rider T1 Case, the Company sought approval of a revised increment/decrement Rider T1 in the amount of ($80,967,667). The Staff recommended approval of the application, and on July 22, 2013, the Commission issued its Final Order ("2013 Rider T1 Order") approving the revised Rider T1 in the amount proposed by the Company. On August 13, 2013, the Company timely made its compliance filing with the Commission, including Rider T1 designed to recover a decrement revenue requirement of ($80,967,667). On August 22, 2013, the Division accepted the revised tariffs. 13. Consistent with the methodology approved in the 2012 and 2013 Rider T1 Cases, in order to recover its Subsection A 4 Costs on a timely and current basis from customers, as required by Subsection A 4, the Company seeks Commission approval in this Application of a Subsection A 4 revenue requirement for the Rate Year to be recovered through a combination of base rates and a revised increment/decrement Rider Tl. Rider T1 is designed to recover the increment/decrement between the revenues produced from the Subsection A 4 component of base rates and the new revenue requirement developed from the Company's Subsection A 4 costs for the Rate Year. 14. For the purposes of developing the revenue requirement for consideration in this proceeding, the Company has assumed an effective date of September 1, The Company proposes Rider T1 be effective for usage during the Rate Year, consistent with the rate year approved in the previous Rider T/T1 cases. The total Subsection A 4 revenue requirement to be recovered over the Rate Year is $538,019,256. This represents a $131,695,526 increase over the projected revenues associated with current Subsection A 4 base rates determined for the rate year and current Rider Tl. Consistent with the approach approved by the Commission in the 2012 and 2013 Rider T1 Cases, this Application seeks approval in this proceeding of a

14 revised increment/decrement Rider T1, in the increment amount of $49,752,283 for the Rate Year. 15. The Company does not propose for revised Rider T1 any changes from the cost allocation and rate design methodologies previously approved for Subsection A 4 RACs. III. DIRECT TESTIMONY AND SUPPORTING EVIDENCE 16. In support of its Application, the Company hereby files the direct testimony of three witnesses. A. David M. Wilkinson, Manager - Regulation in the Regulatory Accounting Department for the Company, will present the Company's revenue requirement for recovery of Subsection A 4 Costs for the Rate Year, including the increment/decrement to be recovered through Rider T 1; the formula mechanism and protocol for developing this revenue requirement for appropriate recovery of Subsection A 4 Costs; the update of certain Subsection A 4 Costs for known changes during the Update Period of January 1, 2014 through August 31, 2014; and the annual deferral and true-up mechanisms - all to assure timely and current recovery of Subsection A 4 Costs reflected in this revenue requirement, and to insure that customers will be charged only actual costs incurred, all consistent with the Commission's previous 2009, 20, and 2011 Rider T Orders and 2012 and 2013 Rider T1 Orders. B. James D. Jackson, Jr., Regulatory Consultant in the Company's Electric Transmission Policy Group, will provide an overview and description of PJM and the specific FERC-approved Subsection A 4 Costs reflected in the revenue requirement presented by Mr. Wilkinson. C. Paul B. Haynes, Director- Regulation for the Company, will present the Company's proposed methodology for design and calculation of retail rates for recovery of such Subsection A 4 Costs, including the Rider T 1 rates to be approved in this proceeding, using the 11

15 appropriate billing determinants as directed by Subsection A 4. IV. SUPPORTING SCHEDULE 46 AND REQUESTS FOR WAIVER OF SCHEDULE Rule 60 of the Rate Case Rules, 20 VAC , provides that an application filed pursuant to Subsection A 4 "shall include Schedules 45 and 46 as identified and described in 20 VAC , and which shall be submitted with the utility's direct testimony." 18. Filing Schedule 46 is divided into three sections: A. Filing Schedule 46A, sponsored by Company Witness Wilkinson, provides: a schedule of all projected costs by type of cost and year associated with Subsection A 4 costs for the Rate Year, including the increment for this proceeding, for which the Company is seeking Commission approval in this proceeding; all documents, contracts, studies, investigations, or correspondence that support such Subsection A 4 costs; the annual revenue requirement over the duration of the proposed Rate Year; 7 and a detailed description of all significant accounting procedures and internal controls that the Company will institute to identify all such Subsection A 4 costs. B. Consistent with the grant of an ongoing and limited waiver in the 2012 Rider T1 Case, Filing Schedule 46B, sponsored by Company Witness Jackson, provides an index offerc rulings, issued since the Company filed its application in the 2013 Rider T1 Case, approving the wholesale rates and costs for which the Company is now seeking recovery approval under Subsection A 4, including the docket/case number(s) of each such ruling. C. Filing Schedule 46C, sponsored by Company Witness Haynes, provides both the annual revenue requirement over the duration of the proposed RAC allocated by class, 7 Consistent with past practice, the Company has provided only one annual revenue requirement because it expects to update its Subsection A 4 RAC on an annual basis. 12

16 and detailed information relative to the Company's methodology for allocating the Rider T1 increment among rate classes, as well as the design of the class rates. D. The Company, for good cause shown, and pursuant to 20 VAC E, respectfully requests that the Commission waive, in part, the requirements of Rules 60 and 90 of the Rate Case Rules with respect to Filing Schedule 45 (Return on Equity Peer Group). Specifically, the Company does not herein request treatment of any costs that would require the Commission to determine an applicable return on equity and accordingly, the Company respectfully requests that the Commission waive, for good cause shown, the requirements of 20 VAC and 20 VAC with respect to submission of Filing Schedule 45 with this Application. Similar waiver requests from the requirements of Filing Schedule 45 were granted in the Company's 2009, 20, and 2011 Rider T cases and the 2012 and 2013 Rider T1 cases. 19. In the event that the Commission denies these waiver requests as they relate to Filing Schedule 45, the Company respectfully requests that the Commission (1) refrain from making a determination, as is its right under Rule D of the Rate Case Rules, 20 V AC D, that this filing is not in full compliance with the requirements of the Rate Case Rules; (2) allow the case to proceed according to the timetable established by this May 2, 2014 filing; (3) permit the Company to submit the required information within 15 business days, and (4) grant the Company such further relief as may be necessary or appropriate. V. COMPLIANCE WITH COMMISSION RULE 20. The Company's Rider T1 Application complies with the requirements contained in Rule of the Rate Case Rules, 20 VAC ("Rule "). In accordance with Rule A, the Company filed with the Commission on March 3, 2014 a notice of intent to file this Application under Subsection A 4. Copies of this Application, to the extent required by Rule J, along with the additional information required by Rule J, have been served upon the 13

17 persons addressed in that Rule. A complete copy of this Application has been served upon the Division of Consumer Counsel of the Office of the Attorney General, in conformity with Rule J. Also included with and following this Application, pursuant to Rule, is a table of contents of this filing, including exhibits and schedules. WHEREFORE, the Company requests the Commission to: (1) schedule this matter for hearing; (2) approve proposed revised Rider T1, for an adjustment to the recovery of Subsection A 4 Costs under base rates to allow for the Company's timely and current recovery of costs recoverable under Subsection A 4; (3) grant the Company's requests for waiver regarding Filing Schedule 45; and ( 4) grant the Company such further relief as may be necessary or appropriate. 14

18 Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY Lisa S. Booth William H. Baxter II Dominion Resources Services, Inc. 120 Tredegar Street, RS-2 Richmond, Virginia (804) (804) com Stephen H. Watts, II Joseph K. Reid, III Lisa R. Crabtree McGuire Woods LLP One James Center 901 East Cary Street Richmond, Virginia (804) (804) (804) mcguirewoods. com mcguirewoods. com mcguirewoods. com Counsel for Virginia Electric and Power Company May 2,

19 ... ~ ~... =

20 DIRECT TESTIMONY OF DAVID M. WILKINSON ON BEHALF OF VIRGINIA ELECTRIC AND POWER COMPANY BEFORE THE STATE CORPORATION COMMISSION OF VIRGINIA CASE NO. PUE I. INTRODUCTION 2 Q. 3 4 A Please state your name, business address, and position with Virginia Electric and Power Company ("Dominion Virginia Power" or the "Company"). My name is David M. Wilkinson. I am a Manager- Regulation in the Regulatory Accounting Department for the Company. My business address is 701 East Cary Street, Richmond, Virginia A statement of my background and qualifications is attached as Appendix A. 8 Q. 9 A. 11 Please describe your areas of responsibility with the Company. I am responsible for the development of revenue requirement analyses and calculations used for rate setting purposes in rate proceedings before the State Corporation Commission of Virginia (the "Commission") and in other jurisdictions. 12 Q. Will you be introducing any exhibits with your testimony? 13 A. Yes. Company Exhibit No._, DMW, consisting of Schedule 1 Formula Schedules through and Schedule 2 - Formula Schedule 11, was prepared under my supervision and direction, and is accurate and complete to the best of my knowledge and belief. I am also sponsoring Filing Schedule 46A, Statements 1 through 13, included with the Company's Application pursuant to the Commission's Rules

21 1 2 Governing Utility Rate Applications and Annual Informational Filings, 20 V AC , et seq. 3 Q. 4 A Will Dominion Virginia Power present any other witnesses in this proceeding? Yes. Company Witness James D. Jackson, Jr. will discuss PJM Interconnection, L.L.C. ("PJM") and the Company's activities as a member of PJM. Additionally, Mr. Jackson will describe the nature of the charges and credits billed to the Company by PJM, as well as the rates and tariffs approved by the Federal Energy Regulatory Commission ("FERC") used to develop the costs under the Virginia Electric Utility Regulation Act (the "Act"), A 4 ("A 4" or "Subsection A 4") of the Code of Virginia ("Va. Code"), included for recovery under Subsection A 4. Company Witness Paul B. Haynes will testify regarding the allocation of the rate adjustment clause ("RAC"), Rider T1, the revenue requirement among the customer classes, and the rate design for recovering the revenue requirement through retail rates. 14 Q. 15 A Please describe the purpose of your testimony in this proceeding. My testimony will present the total revenue requirement of $538,019,256 that the Company is seeking to recover through a combination of base rates and Rider T 1 from Virginia jurisdictional retail customers under Subsection A 4, for the twelvemonth rate year beginning September 1, 2014 and ending August 31, 2015 (the "Rate Year"). This total revenue requirement includes an increment Rider T1 of $49,752,283, which will be discussed later in my testimony. The requested total revenue requirement of $538,019,256 represents an increase of $131,695,526 over the revenues projected to be produced during the Rate Year by the combination of the 2

22 1 2 base rate component of Subsection A 4 (the Company's former Rider T) and the Rider T1 rates currently in effect Q. A. Does your testimony include a discussion of the primary drivers of the increase of $133.6 million in the total revenue requirement requested in this Application over that approved in the previous Rider Tl Case? Yes, a detailed discussion is provided in my conclusion, beginning on page 41 below. The requested total revenue requirement in this Application of $538,019,256 also represents an increase of $133,628,552 over the total revenue requirement approved in Case No. PUE (the "2013 Rider T1 Case"). In summary, the increase in the total revenue requirement requested in this Application is primarily due to a significant increase in the cost of net investment in plant included in the Network Integrated Transmission Service ("NITS") charges billed by PJM, the Company's regional transmission entity, and based on PERC-approved tariffs. The increased charges associated with plant investment included in the NITS rate are partially offset by net transmission enhancement credits ("Transmission Enhancement Credits") from PJM, which represent amounts recovered for transmission projects from other members of PJM through shared cost responsibility. The increased charges for net investment in plant are found in the projected Subsection A 4 cost of service (the net of the NITS charges on Schedule 1, Formula Schedule 2, Page 1, Line 1 and net Transmission Enhancement Credits on Schedule 1, Formula Schedule 2, Page 1, Lines 16 and 18) and a component of the Update Period adjustment (discussed later in this testimony) on Schedule 1, Formula Schedule, Page 1, Line 15. 3

23 1 Q A. What is the primary reason for the increase in net investment in the transmission plant referenced in the response to the previous question? As discussed in the direct testimony of Company Witness Jackson, the Company has projected an increase in investment in transmission plant from December 31, 2013 to December 31, 2014 of over $800 million. More than $724 million of the projects are deemed to be either PJM Regional Transmission Expansion Plan ("RTEP") baseline reliability projects or other reliability projects. The Company is contractually obligated though the PJM Consolidated Transmission Owners Agreement to construct any reliability upgrade assigned to Dominion Virginia Power through the RTEP process by PJM. Also, PERC-approved and North American Electric Reliability Corporation ("NERC")-enforced reliability standards require that transmission owners ("TOs") remedy any potential reliability violation or face penalties up to one million dollars per day per violation. The Company is required to maintain the reliability of the transmission system. 15 Q A Would you provide an overview of the recovery mechanism that the Company is requesting in this proceeding? Consistent with the methodology approved in Case No. PUE (the "2012 Rider T1 Case") and the 2013 Rider T1 Case, the Company is requesting approval of a revised increment/decrement RAC, Rider T1, under Subsection A 4 to adjust the combination of the existing Subsection A 4 component of base rates and the current! y existing Rider Tl. The Rider T1 presented in this case is designed to recover the increment/decrement between the revenues produced from the current Subsection A 4 component of base rates and the new revenue requirement developed from the 4

24 Company's Subsection A 4 costs for the Rate Year presented in this Application. The Company will continue to identify and track separately Subsection A 4 costs and the revenues derived from both the Subsection A 4 component of base rates and Rider T 1, thus maintaining the dollar-for-dollar recovery of these costs and the associated deferral accounting consistent with Commission approval in prior Subsection A 4 cases. The Company proposes the approval of this revised Rider T 1 to recover the increment/decrement of total Subsection A 4 costs relative to the Subsection A 4 component of base rates. 9 Q. 11 A Please describe the Company's proposed mechanism for determining the revenue requirement associated with the revised Rider Tl RAC. As presented in my Schedule 2, Formula Schedule 11, the revenue requirement proposed to be recovered through the revised Rider T1 RAC in this proceeding is $49,752,283. This amount is determined by comparing: (1) the Company's total proposed revenue requirement of $538,019,256 for recovery of Subsection A 4 costs during the Rate Year; and (2) the $488,266,973 of revenues projected to be produced by the current Subsection A 4 component of base rates during the Rate Year. I will discuss the revenue requirement calculations in detail in Section III of my testimony Q. Are the Subsection A 4 costs that the Company proposes to recover in this case consistent with those approved by the Commission in the Company's previous Rider T and Rider Tl cases? 21 A Yes, consistent with Subsection A 4 and the Commission's Final Orders dated June 29, 2009 in Case No. PUE (the "2009 Rider T Case"); June 29, 20 in Case No. PUE (the "20 Rider T Case"); July 19, 2011 in Case No. 5

25 PUE (the "2011 Rider T Case"); August 2, 2012 in the 2012 Rider T1 Case; and July 22, 2013 in the 2013 Rider T1 Case, Dominion Virginia Power's Subsection A 4 revenue requirement in this proceeding is based upon: ( 1) costs for transmission services provided to the Company by PJM, the regional transmission entity of which the Company is a member, according to applicable rates, terms, and conditions approved by the PERC; and (2) costs charged to the Company associated with demand response programs approved by the PERC and administered by PJM. I will refer to all of these costs collectively as "Subsection A 4 costs" in my testimony. 9 In particular, I will define and discuss how the following categories of costs were utilized to determine the revenue requirement in this proceeding: 11 Current Subsection A 4 Costs These are the forecasted Subsection A 4 costs for the Rate Year sought to be recovered from Virginia retail customers. 14 True-up of Subsection A 4 Costs This is the difference between the actual revenues received from Virginia retail customers for the recovery of Subsection A 4 costs and the actual Subsection A 4 costs incurred during calendar year Update of Subsection A 4 Costs This is an update of certain Subsection A 4 costs that will be incurred by the Company during the period January 1, August 31, 2014 (the "Update Period") 6

26 1 2 based upon known changes to components of the cost of service used to develop the Subsection A 4 rates currently in effect. 3 Q. 4 5 A. Is Schedule 1, consisting of Formula Schedules 1 through, consistently numbered with that presented in the 2013 Rider T1 Case? Yes, it is. 6 Q A Please briefly describe key issues resolved by the Commission in its Final Orders in the 2009, 20, and 2012 Rider T/T1 cases, and reflected in the Company's current Application. In its Final Order in the 2009 Rider T Case, the Commission authorized three key components of Subsection A 4 recovery on a prospective basis. The first such component relates to the scope and types of costs recoverable at the retail level through Subsection A 4 tariff rates as provided by Subsection A 4. These costs, based on PERC-approved rates and billed by PJM, include: costs for transmission services; charges for new and existing transmission facilities; administrative charges; ancillary service charges designed to recover transmission costs; and costs associated with demand response programs. Second, the Commission authorized the deferral and true-up of Subsection A 4 costs incurred after the expiration of capped rates pursuant to Va. Code A 7 ("Subsection A 7"). Third, the Commission approved the use of a formula mechanism to develop the revenue requirement proposed to recover Subsection A 4 costs in future Subsection A 4 filings, including this current proceeding. 7

27 In addition to the three components noted above, this Application includes an update to certain Subsection A 4 costs for the Update Period based on known changes in certain components of the cost of service used to develop the Subsection A 4 rates currently in effect. The Commission first approved a revenue requirement change for an Update Period in its Final Order in the 20 Rider T Case. The change in the revenue requirement associated with the Update Period allows for recovery in rates of current cost levels arising from changes in FERC-approved rates and billing determinants that are known to occur during the Update Period. The resulting change in the revenue requirement associated with the Update Period allows for a more timely recovery of these known costs during the Rate Year consistent with the "timely and current" cost recovery provision of Subsection A Finally, in its Final Order in the 2012 Rider T1 Case, the Commission approved the implementation of Rider T1 to be an increment/decrement rider adjusting the recovery of Subsection A 4 costs in coordination with the Subsection A 4 component of base rates. Additionally, the Commission approved the separate tracking of Subsection A 4 revenues and costs in base rates and the continued use of deferral accounting and true-ups of all Subsection A 4 revenues and costs. 18 Q A. Is the Company requesting the same recovery mechanism in this proceeding as that approved in the 2012 and 2013 Rider T1 Cases? Yes, it is. 8

28 1 II. SUBSECTION A 4 COSTS 2 Q A Before discussing the development of the Company's proposed revenue requirement, please describe the nature of the Subsection A 4 costs sought to be recovered from Virginia jurisdictional retail customers in this proceeding. Subsection A 4 provides that certain costs incurred by the Company are deemed to be reasonable and prudent. This statutory provision also establishes broad guidelines for the recovery of these costs through retail rates. It reads in part as follows: The following costs incurred by the utility shall be deemed reasonable and prudent: (i) costs for transmission services provided to the utility by the regional transmission entity of which the utility is a member, as determined under applicable rates, terms and conditions approved by the Federal Energy Regulatory Commission, and (ii) costs charged to the utility that are associated with demand response programs approved by the Federal Energy Regulatory Commission and administered by the regional transmission entity of which the utility is a member. Subsection A 4 also provides additional detail regarding specific costs that are recoverable through a RAC by directing that, upon petition by a public utility, "the Commission shall approve a rate adjustment clause under which such costs, including, without limitation, costs for transmission service, charges for new and existing transmission facilities, administrative charges, and ancillary service charges designed to recover transmission costs, shall be recovered on a timely and current basis from customers." The types of costs included in this filing are consistent with those previously approved for recovery in the Commission's Final Orders in the Company's 2009, 20, 2011, 2012, and 2013 Rider T/T1 cases The costs for services described in Subsection A 4 are derived from the FERCapproved tariff rates contained in the PJM Open Access Transmission Tariff ("PJM 9

29 OATT"). PJM applies these rates to billing determinants as detailed on Formula Schedule 2. PJM billing determinants are defined as the units of measure used as PJM' s bases for charging customers, including Dominion Virginia Power, for services. Examples of billing determinants include megawatts ("MW"), megawatthours ("MWh"), etc. The resulting costs incurred by the Company are then allocated to the Virginia jurisdiction based on a one coincident peak ("1CP") allocation factor, or the energy allocation factor, consistent with PJM's respective bases for charging the Company. The results of the foregoing calculations are the estimated current Subsection A 4 costs set forth in Formula Schedule 2. These resulting costs are the bases for the revenue requirement to be recovered through retail rates pursuant to Subsection A 4. Company Witness Jackson provides a more detailed explanation of how these Subsection A 4 costs are developed at PJM Listed below are the five components of costs approved by the Commission for recovery in the Company's previous Rider T and T1 cases, and the related PERCapproved PJM services associated with those costs. Formula Schedule 2 elaborates on these components and demonstrates how they are used to derive the cost of service and, ultimately, the revenue requirement for recovery of Subsection A 4 costs to be incurred during the Rate Year. Formula Schedules 3 through 8 provide support for the data utilized in Formula Schedule 2. Formula Schedule 9 calculates the cost of service and the revenue requirement for the true-up component of all Subsection A 4 costs incurred during calendar year 2013, and reports the revenues intended to recover those costs. Finally, Formula Schedule determines the cost of service and, ultimately, the revenue requirement for updating to certain known Subsection A 4

30 costs or rate changes incurred by the Company during the Update Period. The changes in the Update Period costs are included in this filing because the difference between the level of costs currently being billed by PJM, and the level of costs used to determine rates currently in effect, is now known for the Update Period. 5 The costs being recovered through this Subsection A 4 RAC include: ( 1) Costs for Transmission Service - The FERC-approved Annual Transmission Revenue Requirement ("ATRR") uses the NITS tariff rate that PJM charges Dominion Virginia Power as a transmission customer to determine its share of the costs associated with operation of, and investment in, the transmission system owned by Dominion Virginia Power and operated by PJM, less offsetting revenue credits for Firm and Non-Firm Point-to-Point Transmission Service, plus a Dominion Settlement Charge associated with FERC Docket No. EL (2) Charges for New and Existing Transmission Facilities - Transmission enhancement charges ("Transmission Enhancement Charges") from PJM to Dominion Virginia Power are for transmission projects approved in the PJM RTEP, whereby PJM identifies and directs the construction of enhancement or expansion projects, as required, to meet the demands for firm transmission service in the PJM region. Such projects often benefit customers of more than one utility. Therefore, the revenue requirements resulting from these designated projects are shared with other utilities based upon the benefits respectively provided. Net Transmission Enhancement Charges included on PJM's invoices include the allocated portion of other utilities' RTEP construction project revenue requirements for which Dominion Virginia Power is responsible, and provide credits for Dominion's own RTEP construction project revenue requirements for 11

31 which other TOs are responsible. Other Charges, which are presented in the Transmission Enhancement section of Formula Schedule 2, Page 1 of 2, Lines 20 and 21, include the Generation Deactivation charge and the Michigan - Ontario Interface PARs charge described in more detail by Company Witness Jackson. (3) Administrative Charges- These charges are billed to Dominion Virginia Power by PJM to recover the costs associated with operating PJM, and for funding various organizations through schedules included in the PJM OATT ( 4) Ancillary Service Charges Designed to Recover Transmission Costs- These charges are billed by PJM to recover Dominion Virginia Power's costs of Scheduling, System Control, and Dispatch Services. Dominion Virginia Power currently recovers these costs through its NITS rate and, therefore, does not have a separately stated rate in the PJM tariff for these ancillary services (5) Costs Associated with Demand Response Programs Approved by the FERC -The PJM Emergency Load Response Program is designed to provide a method by which curtailment service providers ("CSPs") may be compensated by PJM for customers' load reduction during an emergency event, while the PJM Economic Load Response Program is designed to provide an incentive for customers of CSPs to reduce consumption when PJM energy market prices are high. The PJM Economic Load Response Program offers customers of CSPs the opportunity to participate in the PJM Energy Interchange Market, and to receive energy payments by curtailing load or self-generating, based on the locational marginal price ("LMP"), at their discretion. 12

32 1 Q. 2 Does the Company expect changes during the Rate Year to any of the types of cost components and/or services previously approved for recovery through the 3 Subsection A 4 component of base rates or the Rider Tl RAC? 4 A. No, it does not. 5 III. DETERMINATION OF THE REVENUE REQUIREMENT 6 Q. How did the Company develop the revenue requirement to recover the 7 8 A Subsection A 4 costs presented in this proceeding? As stated previously and consistent with previous Rider T and T1 cases, the three main components of the revenue requirement proposed by the Company in this proceeding are: ( 1) current Subsection A 4 costs for the Rate Year of September 1, 2014 through August 31, 2015 in the amount of $448.2 million; (2) the true-up of the difference between the actual revenues received and the actual Subsection A 4 costs incurred during calendar year 2013 in the amount of $39.7 million; and (3) an update of Subsection A 4 costs for the Update Period based upon known rates, terms, and conditions applied to known billing determinants in effect during the Update Period in the amount of $50.0 million. More specifically: (1) The Subsection A 4 costs estimated to be incurred during the Rate Year are determined by populating the portion of the Commission-approved revenue requirement formula in Formula Schedule 2 with the applicable PERCapproved rates from tariffs in effect on the date of this Application. In addition, the Company has populated the Subsection A 4 formula with projected billing determinants for the Rate Year, as well as the most current 13