- PDF Free Download

Stipulating Parties/100 Peng-Andrews-Jenks 1 Docket UM 1626 Stipulating Parties Exhibit 100 Peng, Andrews and Jenks BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON JOINT TESTIMONY OF MING PENG, ELIZABETH ANDREWS, AND BOB JENKS In Support of Stipulations for Implementation of Depreciation Rates APRIL 2013 Page 0 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Q. Please state your names and positions. A. My name is Ming Peng. I am employed by the Public Utility Commission of Oregon ( PUC ) as a Senior Economist in the Energy Division and am appearing here on behalf of the Staff of the PUC ( Staff ). I have been an analyst at the PUC since 1999, working in a wide area of topics and testifying in various formal state hearings, with my current responsibility focusing on the review of energy utility depreciation rates. I have a Bachelor s degree in Statistics from People s University of China and Master s degree in Agricultural Economics from University of Idaho. Further, I passed the Certified Rate of Return Analyst (CRRA) exam, and awarded as a CRRA by Society of Utility and Regulatory Financial Analysts in June 10, 2002. My name is Elizabeth M. Andrews. I am employed by Avista Corporation as Manager of Revenue Requirements in the State and Federal Regulation Department. I am a 1990 graduate of Eastern Washington University with a Bachelor of Arts Degree in Business Administration, majoring in Accounting. That same year, I passed the November Certified Public Accountant exam, earning my CPA License in August 1991 1. I worked for Lemaster & Daniels, CPAs from 1990 to 1993, before joining the Company in August 1993. I served in various positions within the sections of the Finance Department, including General Ledger Accountant and Systems Support Analyst until 2000. In 2000, I was hired into the State and Federal Regulation Department as a Regulatory Analyst until my promotion to Manager of Revenue Requirements in early 2007. I have also attended several utility accounting, ratemaking and leadership courses. 1 Currently I keep a CPA-Inactive status with regards to my CPA license. Page 1 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 My name is Bob Jenks. I am the Executive Director of the Citizens Utility Board ( CUB ). I am a graduate of Willamette University with a Bachelor of Science Degree in Economics. I have provided testimony and comments in a variety of PUC dockets. Between 1982 and 1991, I worked for the Oregon State Public Interest Research Group, the Massachusetts Public Interest Group and the Fund for Public Interest Research on a variety of public policy issues. As Executive Director, my responsibilities include the review of all filings in Oregon and to represent the customers concerns that have arisen from this Docket. Hereafter, Staff, the Company and CUB will collectively be referred to as the Parties. Q. Are there any intervening parties in this Docket that did not sign the Stipulation? A. No, there are not. As such, the Parties to the Stipulation represent all parties in this proceeding. Q. What is the purpose of your joint testimony? A. The purpose of our joint testimony is to describe and support the two Stipulations between Commission Staff, CUB, and the Company ( Signing Parties ) in docket UM 1626 (Docket). The Stipulations are attached herewith as Exhibit 101 and Exhibit 102, resolving all issues surrounding depreciation rates on common and directly assigned plant, respectively. 20 Page 2 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 Q. Please summarize Avista s depreciation study proposal. A. Avista s depreciation study recommended revisions in depreciation lives, curves, and net salvage rates for all plant accounts, and a revision to life span from average remaining life methodology for gas generation plant assets. On September 10, 2012, the Company filed a petition requesting authority to revise its book depreciation rates consistent with the results of a study recently 7 undertaken by the Company. 2 That study, according to the Company, shows that the 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Oregon annual depreciation expense on the Company s books should be increased by approximately $1.769 million, based on the average service life rates of gas plant in service as of June 30, 2012. Accordingly, the Company requested authorization to revise its depreciation rates to reflect this $1.769 million increase in book depreciation expense. The Company requested authorization for the proposed depreciation rates, in two phases. The first phase proposed approving common plant (allocated) depreciation rates to commence with the Company s Washington and Idaho jurisdictions implementation on January 1, 2013. The second phase, proposed to implement depreciation rates on plant directly assigned to Oregon, and would be effective at the conclusion of the Company s next Oregon general rate case. On October 8, 2012, a prehearing conference was held that established the procedural schedule for this docket. The Parties in this Docket recognized the need for sufficient time for Staff and interested Parties to complete their review of the Company s depreciation study. Accordingly, the Parties entered into a Stipulation on February 7, 2 Avista hired Gannett Fleming, Inc. to undertake a depreciation study of its depreciable electric, gas and common plant that was completed in 2012. The objective of this assignment was to recommend depreciation rates to be utilized by Avista for accounting and ratemaking purposes. Page 3 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2013, that represented the first phase of the proposal to implement new depreciation rates on common plant effective January 1, 2013. The Parties agreed not to defer the additional depreciation expense resulting from the implementation of common plant depreciation rates effective January 1, 2013. A copy of that Settlement Stipulation is attached as Exhibit 101. On March 13, 2013, a second settlement conference was held representing the second phase of the Company s proposal for the remaining depreciation rates on plant directly assigned to Oregon, and the Parties reached final agreement on revisions to the Company s book depreciation rates. If ultimately approved by the Commission, such rates would constitute the Oregon direct depreciation rates, which would be effective at the conclusion of the Company s next Oregon General Rate Case. A copy of the settlement stipulation is attached as Exhibit 102. Q. Did Staff independently review the depreciation study? A. Yes, Staff s review was independent and comprehensive. Staff developed a set of proposed Iowa Curves, average service lives, and net salvage rates for each of the plant accounts. Q. Did independent staff analysis suggest adjustments to Avista s proposal? A. Yes. Staff proposed two types of adjustments. The first type of adjustment concerns Iowa curves and projected average service lives. The second type of adjustment concerns net salvage rates. Net salvage is the difference between gross salvage and cost of removal. Net salvage is positive when gross salvage exceeds the cost of removal and reduces the revenue requirement. Conversely, net salvage is negative when cost of removal exceeds gross salvage and increases the revenue requirement. Staff performed Page 4 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 an independent review of Avista s depreciation statistics and recommended depreciation parameters for numerous depreciation groups. Q. How did Avista and Staff analyze Iowa Curves and Average Service Lives? A. Both Avista and Staff utilized the actuarial plant balances methodology to analyze historical retirement data to help determine Iowa curves and average service lives for each depreciation group. Q. Were Staff and Avista able to resolve the study differences for the plant accounts? A. Yes, the differences were resolved in a settlement meeting held on March 13, 2013. We recommend that the Commission adopt the position outlined in the attached Stipulation. The Stipulation discusses the changes in the Staff Settlement Proposal agreed to at the settlement meeting and also provides a table which details the straight line, remaining life, average service life group depreciation rates derived for each depreciation group (see Exhibit 102, Attachment A). Q. What is the final impact on estimated depreciation expense due to settlement discussions? A. The net annual difference in depreciation expense when comparing the final settlement position to the depreciation study as-filed is a reduction of approximately $318,614. Q. Could you please describe the terms of the two Stipulations? A. Yes. The Parties have agreed to an overall increase of $1,450,414 in the annual depreciation expense based on the plant balances at June 30, 2012. This represents a reduction of $318,614 for Phase II in the Stipulation, in depreciation expense on directly assigned plant beyond what the Company had originally filed. There were no changes to Page 5 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the depreciation rates or expense for the Common plant accounts addressed in the first phase of this docket. The agreed-upon depreciation rates set forth in these Stipulations shall be effective in two phases. The first Stipulation representing the first phase of this docket addresses common plant and shall be effective January 1, 2013. There were no changes to the Company s proposed depreciation rates for Phase I. The Parties have also agreed not defer the associated additional depreciation expense resulting from the implementation of common plant depreciation rates effective January 1, 2013. Exhibit 101 Attachment A provides detail of the affected plant accounts and specified depreciation rates. The second stipulation attached herein as Exhibit 102, addresses the agreement of the Parties on the book depreciation rates on plant that is directly assigned to Oregon. The Parties have agreed that the Company will implement new book depreciation rates on plant that is directly assigned to Oregon effective at the conclusion of the Company s next Oregon general rate case. The Parties also agreed that the Company will file a new depreciation study within five years from the conclusion of this docket. Exhibit 102 Attachment A, provides detail of the affected plant accounts and specified depreciation rates reflecting the $318,614 for Phase II in the Stipulation, reduction to depreciation expense. Q. What other terms are included in the two Stipulations? A. The Stipulations in this docket represent negotiated compromises among the Parties. Thus, the Parties have agreed that no particular party shall be deemed to have approved the facts, principles, methods, or theories employed by any other in arriving at these Stipulations, and that the terms incorporated in these Stipulations should not be viewed as Page 6 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 precedent setting in subsequent proceedings. In addition, the Parties have the right to withdraw from these Stipulations if any material part is rejected or modified by the Commission. Q. Do these Stipulations represent a complete resolution of all issues in this docket? A. Yes, these Stipulations represent a complete resolution of all issues. Q. Why does the PUC Staff support the revisions to the depreciation rates proposed for Phase II? A. The final adjustments were not fully relying on the statistical calculations, or industry average level, or Avista s book balance, because some data was not fully available. The final adjustment decisions were made based on the combination of the considerations of Avista s plant retirement patterns and in-house engineering opinion, the industry average level, and Staff analyst s experiences. The stipulated position on plant asset survivor curves-projection life, net salvage rates in Phase II as reflected in the depreciation rates is consistent with the results of Staff s thorough review and valuation of plant asset by depreciation groups. Accordingly, it is Staff s position that the stipulated adjustment represents a fair and reasonable level of depreciation expenses to be included in the depreciation rates. Q. What do the Parties recommend regarding these Stipulations? A. The Parties recommend that the Commission adopt both Stipulations in their entirety. Q. Does that complete your joint testimony in this proceeding? A. Yes, it does. Page 7 JOINT TESTIMONY UM 1626

Stipulating Parties/100 Peng-Andrews-Jenks 1 EXHIBIT 101 Page 0 JOINT TESTIMONY UM 1626

UM 1626 Exhibit 101 BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON UM 1626 In the Matter of ) ) AVISTA CORPORATION, dba ) STIPULATED AGREEMENT AVISTA UTILITIES, ) ) Petition Requesting ) Authority to Revise Its ) Book Depreciation Rates ) This Stipulation is entered into for the purpose of implementing Avista Corporation s (Avista) book depreciation rates on common (allocated) plant effective January 1, 2013. PARTIES The Parties to this Stipulation are Avista, the Staff of the Public Utility Commission of Oregon (Staff) and the Citizens Utility Board of Oregon (CUB), representing all parties to this proceeding. BACKGROUND 1. On September 10, 2012, Avista filed a petition requesting authority to revise its book depreciation rates. The Company requested authorization to revise its book depreciation rates consistent with the results of a study recently undertaken by the Company. 1 That study shows that the annual common depreciation expense recorded to O&M and A&G expense on the Company s books should be increased by approximately $357,079 (Oregon Share) based on the average service life rates of common general and natural gas plant in service as of June 30, 1 Avista hired Gannett Fleming, Inc. to undertake a depreciation study of its depreciable electric, gas and common plant in service the study was completed in 2012. The objective of this assignment was to recommend depreciation rates to be utilized by Avista for accounting and ratemaking purposes. STIPULATION UM 1626 Page 1 of 6 Exhibit 101

UM 1626 Exhibit 101 2012, that is allocated to Oregon. The Company requested authorization for the proposed depreciation rates, in two phases. The first phase proposed approving common plant depreciation rates to commence with the Company s Washington and Idaho jurisdictions implementation, and to defer the associated additional depreciation expense until the conclusion of the next general rate case filed by the Company in Oregon. The second phase, which proposed to implement depreciation rates on plant directly assigned to Oregon, would be effective at the conclusion of the next general rate case filed by the Company. 2. Avista is a utility that also provides service to electric and natural gas customers in eastern Washington and northern Idaho, in addition to its natural gas customers in Oregon. In Docket No. UG-120437, pursuant to a settlement filed with the Washington Utilities and Transportation Commission, the Settling Parties agreed to the Company s proposed depreciation rates, as originally filed, on its natural gas and common plant with a January 1, 2013 effective date as documented in the Multiparty Settlement Stipulation, dated October 19, 2012. On October 10, 2012, the Company filed an electric and natural gas general rate case with the Idaho Public Utilities Commission (Case Nos. AVU-E-12-08 and AVU-G-12-07), which included the recommendation that new common plant depreciation rates be effective to coincide with Washington s effective date. 3. The Parties in this Docket recognized the need for sufficient time for Staff and interested Parties to complete their review of the Company s depreciation study. This Stipulation provides for implementation of new common plant depreciation rates effective January 1, 2013. 4. Approval of this Stipulation would provide for the opportunity to simultaneously implement new depreciation rates for common plant in all three jurisdictions in which Avista STIPULATION UM 1626 Page 2 of 6 Exhibit 101

UM 1626 Exhibit 101 serves: Oregon, Washington and Idaho. Allowing Oregon depreciation rate changes to be effective at the same time as the other two jurisdictions will synchronize the three States depreciation rates. Further, implementing depreciation rates in all three States on January 1, 2013 will simplify future accounting and audits of depreciation expense, since the same rates and methodology will be in effect for the entire year. AGREEMENT 5. Avista will implement new book depreciation rates on common plant effective January 1, 2013. The Parties to this Agreement have agreed to the Company s proposed depreciation rates on common plant, as shown in Attachment A, which provides detail of the affected plant accounts and specified depreciation rates. 6. The Parties agree that Avista will not defer the associated additional depreciation expense resulting from the implementation of common plant depreciation rates effective January 1, 2013. 7. The Parties agree that the remaining depreciation rates on plant that is directly assigned to Oregon, and which are also a part of the overall depreciation study, will be reviewed in this Docket; however, the implementation of new depreciation rates on directly assigned plant will not occur until the conclusion of the Company s next Oregon general rate case. 8. The Parties agree that this Stipulation is in the public interest and results in an overall fair, just and reasonable outcome. 9. The Parties agree this Stipulation represents a compromise in the positions of the Parties. As such, conduct, statements, and documents disclosed in the negotiation of this Stipulation shall not be admissible as evidence in this or any other proceeding unless STIPULATION UM 1626 Page 3 of 6 Exhibit 101

UM 1626 Exhibit 101 independently discoverable or offered for other purposes allowed under ORS 40.190. Further, this Stipulation sets forth the entire agreement between the Parties and supersedes any and all prior communications, understandings, or agreements, oral or written, between the Parties pertaining to the subject matter of this Stipulation. 10. This Stipulation will be offered into the record in this proceeding as evidence pursuant to OAR 860-001-0350(7). The Parties agree to support this Stipulation throughout this proceeding and any appeal. The Parties further agree to provide witnesses to sponsor this Stipulation in testimony, briefing and at the hearing, or, in a Party s discretion, to provide a representative at the hearing authorized to respond to the Commission s questions on the Party s position as may be appropriate. 11. If this Stipulation is challenged, the Parties to this Stipulation reserve the right to cross-examine witnesses and put on such case as they deem appropriate to respond fully to the issues presented, including the right to raise issues that are incorporated in the settlement embodied in this Stipulation. Notwithstanding this reservation of rights, the Parties agree that they will continue to support the Commission s adoption of the terms of this Stipulation. 12. The Parties have negotiated this Stipulation as an integrated document. If the Commission rejects all or any material part of this Stipulation or imposes additional material conditions in approving the Stipulation, any Party disadvantaged by such action shall have the right to withdraw from this Stipulation, pursue their rights under OAR 860-001-0350(9), and/or seek reconsideration or appeal of the Commission s order in accordance with OAR 860-001- 0720. However, prior to withdrawal, the Party shall engage in good faith negotiation with the other Parties. No Party withdrawing from this Stipulation shall be bound to any position, commitment, or condition of this Stipulation. In the event any Party withdraws from the STIPULATION UM 1626 Page 4 of 6 Exhibit 101

Exhibit 101 UM 1626 Exhibit 101

UM 1626 Settlement Depreciation Rates [1] [2] [3] [4] UM 1626 Exhibit 101 ATTACHMENT A Line Account Number Description Filed Study Rate Filed and Settled Curve - Life Net Salvage % % 1 COMMON PLANT 2 GENERAL PLANT - CD AA 3 389.3 Removing Property of Others 1.56 65-R4 0 4 390.1 Structures & Improvements 2.00 30-S1 0 5 391.0 Office Furniture & Equipment 17.63 15-SQ 0 6 391.1 Computer Equipment 23.70 5-SQ 0 7 394.0 Tools, Shop & Garage Equipment 4.93 20-SQ 0 8 395.0 Laboratory Equipment 14.29 15-SQ 0 9 397.0 Communication Equipment 3.40 15-SQ 0 10 397.2 Communication Equipment-Portable 11.95 15-SQ 0 11 397.7 Communication Equipment-Lease 1.00 5-SQ 0 12 398.0 Miscellaneous Equipment 40.48 10-SQ 0 13 GAS PLANT 14 COMMON GAS GENERAL PLANT - GD AA 15 391.0 Office Furniture & Equipment 6.49 15-SQ 0 16 391.1 Computer Equipment 21.60 5-SQ 0 17 394.0 Tools, Shop & Garage Equipment 5.06 20-SQ 0 18 395.0 Laboratory Equipment 7.16 15-SQ 0 19 397.0 Communication Equipment 3.84 15-SQ 0 20 COMMON TRANSPORTATION AND POWER OPERATED EQUIPMENT 21 392.1 Transportation Equipment - Autos 21.28 L3-6 5 22 392.2 Transportation Equipment - Light Trucks 16.17 R2-10 10 23 392.3 Transportation Equipment - Medium Trucks 19.08 L4-12 10 24 392.4 Transportation Equipment - Heavy Trucks 6.07 L3-15 15 25 392.5 Transportation Equipment - Other 5.67 L0-15 5 26 396.3 Power Operated Equipment - Medium Trucks 6.90 L4-12 10 27 396.5 Power Operated Equipment - Other 4.91 L0-15 5 Exhibit 101 1 of 1

Stipulating Parties/100 Peng-Andrews-Jenks 1 EXHIBIT 102 Page 0 JOINT TESTIMONY UM 1626

UM 1626 Exhibit 102 BEFORE THE PUBLIC UTILITY COMMISSION OF OREGON UM 1626 In the Matter of ) ) AVISTA CORPORATION, dba ) STIPULATED AGREEMENT AVISTA UTILITIES, ) ADDRESSING DEPRECIATION ) RATES ON DIRECTLY ASSIGNED Petition Requesting ) PLANT Authority to Revise Its ) Book Depreciation Rates ) This Stipulation is entered into for the purpose of implementing Avista Corporation s (Avista) book depreciation rates on plant directly assigned to Oregon effective at the conclusion of the Company s next Oregon general rate case. PARTIES The Parties to this Stipulation are Avista, the Staff of the Public Utility Commission of Oregon (Staff) and the Citizens Utility Board of Oregon (CUB), representing all parties to this proceeding. BACKGROUND 1. On September 10, 2012, Avista filed a petition requesting authority to revise its book depreciation rates consistent with the results of a study recently undertaken by the Company.1 That study shows that the annual Oregon Direct depreciation expense on the Company s books should be increased by approximately $1,418,321, based on the average service life rates of Oregon general and direct natural gas plant in service as of June 30, 2012. 1 Avista hired Gannett Fleming, Inc. to undertake a depreciation study of its depreciable electric, gas and common plant in service. The study was completed in 2012. The objective of this assignment was to recommend depreciation rates to be utilized by Avista for accounting and ratemaking purposes. STIPULATION #2 UM 1626 Exhibit 102 Page 2 of 6

UM 1626 Exhibit 102 2. The Company requested authorization for the proposed depreciation rates, in two phases. The first phase proposed approving common plant depreciation rates to commence with the Company s Washington and Idaho jurisdictions implementation, and to defer the associated additional depreciation expense until the conclusion of the Company s next Oregon general rate case. The second phase, which this Stipulation addresses, proposes to implement depreciation rates on plant directly assigned to Oregon and would be effective at the conclusion of the Company s next general rate case. 3. The Parties in this Docket recognized the need for sufficient time for Staff and interested Parties to complete their review of the Company s depreciation study. Accordingly, the Parties entered into a Stipulation on February 7, 2013, to implement the first phase where Oregon common plant depreciation rates became effective January 1, 2013. The Company also agreed not to defer the associated additional depreciation expense resulting from the implementation of common plant depreciation rates effective January 1, 2013. 4. On March 13, 2013, a second settlement conference was held for the remaining depreciation rates (second phase) on plant directly assigned to Oregon, and the Parties reached final agreement on revisions to the Company s book depreciation rates. If ultimately approved by the Commission, such rates would constitute the Oregon direct depreciation rates, which would be effective at the conclusion of the Company s next Oregon general rate case. AGREEMENT 5. The Stipulating Parties (Parties) have agreed to book depreciation rates on plant that is directly assigned to Oregon. Attachment A, in this Stipulation, Oregon Final Summary Table for UM 1626 Depreciation Study, details the affected plant accounts and specified depreciation rates for both common plant previously agreed upon by the Parties in the first STIPULATION #2 UM 1626 Exhibit 102 Page 3 of 6

UM 1626 Exhibit 102 phase of this docket in the Stipulation dated February 7, 2013, as well as the plant that is directly assigned to Oregon, as addressed in this Stipulation. The result of the agreed-upon depreciation rates for directly assigned Oregon plant is an increase of approximately $1,099,707 to depreciation expense based upon plant balances at June 30, 2012. This represents a reduction of approximately $318,614 (see Attachment A - Settlement Adjustments) from what was originally filed by the Company. 6. The Parties agree that Avista will implement new book depreciation rates on plant that is directly assigned to Oregon effective at the conclusion of the next Oregon general rate case filed by the Company. 7. The Parties agree that the Company will file a new depreciation study within five years of the date that the Commission approves this Stipulation. 8. The Parties agree that the rates resulting from the Stipulation are in the public interest and fair, just and reasonable. 9. The Parties agree this Stipulation represents a compromise in the positions of the Parties. As such, conduct, statements, and documents disclosed in the negotiation of this Stipulation shall not be admissible as evidence in this or any other proceeding unless independently discoverable or offered for other purposes allowed under ORS 40.190. Further, this Stipulation sets forth the entire agreement between the Parties and supersedes any and all prior communications, understandings, or agreements, oral or written, between the Parties pertaining to the subject matter of this Stipulation. 10. This Stipulation will be offered into the record in this proceeding as evidence pursuant to OAR 860-001-0350(7). The Parties agree to support this Stipulation throughout this proceeding and any appeal. The Parties further agree to provide witnesses to sponsor this STIPULATION #2 UM 1626 Exhibit 102 Page 4 of 6

UM 1626 Exhibit 102 Stipulation at the hearing, or, in a party s discretion, to provide a representative at the hearing authorized to respond to the Commission s questions on the party s position as may be appropriate. 11. If this Stipulation is challenged, the Parties to this Stipulation reserve the right to cross-examine witnesses and put on such case as they deem appropriate to respond fully to the issues presented, including the right to raise issues that are incorporated in the settlement embodied in this Stipulation. Notwithstanding this reservation of rights, the Parties agree that they will continue to support the Commission s adoption of the terms of this Stipulation. 12. The Parties have negotiated this Stipulation as an integrated document. If the Commission rejects all or any material part of this Stipulation or imposes additional material conditions in approving the Stipulation, any Party disadvantaged by such action shall have the right to withdraw from this Stipulation, pursue their rights under OAR 860-001-0350(9), and/or seek reconsideration or appeal of the Commission s order in accordance with OAR 860-001-0720. However, prior to withdrawal, the Party shall engage in good faith negotiation with the other Parties. No Party withdrawing from this Stipulation shall be bound to any position, commitment or condition of this Stipulation. In the event any Party withdraws from the Stipulation, then no part of the Stipulation may be offered or admitted into evidence in any proceeding. 13. By entering into this Stipulation, no Party shall be deemed to have approved, admitted, or consented to the facts, principles, methods, or theories employed by any other Party in arriving at the terms of this Stipulation other than as specifically identified in this Stipulation. No Party shall be deemed to have agreed that any provision of this Stipulation is appropriate for resolving the issues in any other proceeding. STIPULATION #2 UM 1626 Exhibit 102 Page 5 of 6

UM 1626 Settlement Depreciation Rates UM 1626 Exhibit 102 ATTACHMENT A First phase effective January 1, 2013, (Stipulation Dated February 7, 2013.) (Common Plant) Line Account Number [1] [2] [3] [4] [5] Description Filed Study Rate % Filed and Settled Curve - Life Net Salvage % Settlement Adjustments 1 COMMON PLANT 2 GENERAL PLANT - CD AA 3 389.3 Removing Property of Others 1.56 65-R4 0 $ - 4 390.1 Structures & Improvements 2.00 30-S1 0-5 391.0 Office Furniture & Equipment 17.63 15-SQ 0-6 391.1 Computer Equipment 23.70 5-SQ 0-7 394.0 Tools, Shop & Garage Equipment 4.93 20-SQ 0-8 395.0 Laboratory Equipment 14.29 15-SQ 0-9 397.0 Communication Equipment 3.40 15-SQ 0-10 397.2 Communication Equipment-Portable 11.95 15-SQ 0-11 397.7 Communication Equipment-Lease 1.00 5-SQ 0-12 398.0 Miscellaneous Equipment 40.48 10-SQ 0-13 GAS PLANT 14 COMMON GAS GENERAL PLANT - GD AA 15 391.0 Office Furniture & Equipment 6.49 15-SQ 0-16 391.1 Computer Equipment 21.60 5-SQ 0-17 394.0 Tools, Shop & Garage Equipment 5.06 20-SQ 0-18 395.0 Laboratory Equipment 7.16 15-SQ 0-19 397.0 Communication Equipment 3.84 15-SQ 0-20 COMMON TRANSPORTATION AND POWER OPERATED EQUIPMENT 21 392.1 Transportation Equipment - Autos 21.28 L3-6 5-22 392.2 Transportation Equipment - Light Trucks 16.17 R2-10 10-23 392.3 Transportation Equipment - Medium Trucks 19.08 L4-12 10-24 392.4 Transportation Equipment - Heavy Trucks 6.07 L3-15 15-25 392.5 Transportation Equipment - Other 5.67 L0-15 5-26 396.3 Power Operated Equipment - Medium Trucks 6.90 L4-12 10-27 396.5 Power Operated Equipment - Other 4.91 L0-15 5 - $ - Second phase effective at conclusion of next Oregon General Rate Case (Directly Assigned Plant) [1] [2] [3] [4] [5] [6] [7] [8] Filed Study Rate Filed Curve - Life Net Salvage % Filed Study Rate Settled Curve - Life Net Salvage % Settlement Adjustments GAS PLANT -OREGON UNDERGROUND STORAGE 28 351.2 Compressor Station 1.92 55-S2.5-5 1.92 55-S2.5-5 $ - 29 351.4 Office 1.93 55-S2.5-5 1.93 55-S2.5-5 - 30 352.0 Storage Wells 2.02 50-R3 0 1.67 60-R3 0 (3,172) 31 352.2 Reservoirs 2.21 45-R4 0 1.63 60-R3 0 (8,492) 32 352.3 Cushion Natural Gas 2.21 50-R4 0 1.49 60-R3 0 (1,397) 33 353.0 Lines 1.80 55-S2.5 0 1.80 55-S2.5 0-34 354.0 Compressor Station Equipment 2.02 50-S2.5 0 2.02 50-S2.5 0-36 357.0 Other Equipment 2.47 40-R2 0 2.47 40-R2 0 - DISTRIBUTION PLANT 37 374.4 Land - Easements 2.01 50-R3 0 2.01 50-R3 0-38 375.0 Structures & Improvements 1.85 50-R2.5 0 1.85 50-R2.5 0-39 376.0 Mains 2.08 55-R2.5-30 1.94 58-R2.5-30 (191,002) 40 378.0 Measuring/Regulating Station Equipment 2.97 35-R1.5-15 2.59 40-R2-15 (14,574) 41 379.0 Measuring/Regulating City Gate Equipment 2.76 40-S0.5-15 2.43 45-R2.5-15 (4,510) 42 380.0 Services 1.83 45-R2.5-20 1.68 48-R2.5-20 (87,028) 43 381.0 Meters 3.19 36-R1.5-2 3.19 36-R1.5-2 - 44 385.0 Measuring/Regulating Industrial Equipment 1.29 50-R2-15 1.29 50-R2-15 - 45 387.0 Other Equipment 1.00 12-S3 0 1.00 12-S3 0 - GAS GENERAL PLANT 46 390.1 Structures & Improvements 1.72 30-S1 0 1.46 35-S1 0 (8,438) 48 393.0 Stores Equipment 4.89 25-SQ 0 4.89 25-SQ 0-49 394.0 Tools, Shop & Garage Equipment 5.35 20-SQ 0 5.35 20-SQ 0-50 395.0 Laboratory Equipment 17.63 15-SQ 0 17.63 15-SQ 0-52 397.0 Communication Equipment 6.71 15-SQ 0 6.71 15-SQ 0-53 398.0 Miscellaneous Equipment 5.07 10-SQ 0 5.07 10-SQ 0 - $ (318,614) 1 of 1