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20091231-0037 FERC PDF (Unofficia1) 12/29/2009<br />

Direct Testimony of Michael 1. Vilbert<br />

Docket ER 10- -000<br />

Page 33 of35<br />

EXHIBIT<br />

NO_ SCE-13<br />

I Q53_ Are you saying that higher growth rates could be sustainable forever?<br />

2 A53. No. Growth rates for all companies vary over time, and no company can maintain a high<br />

3 growth rate forever. Nor is it likely that some of the very low current estimated growth<br />

4 rates would stay low forever. For purposes of the DCF analysis, the growth rate<br />

5 estimates are the best available estimates for the next five years. There is a danger of bias<br />

6 if some growth rate estimates are arbitrari ly judged not to be sustainable because it<br />

7 encourages efforts to delete the companies with the highest cost of equity estimates while<br />

8 leaving the lower estimates in the sample. For a small sample this becomes a serious<br />

9 problem because the removal of one or two companies has a larger effect.<br />

10 Q54. What about the growth rates for year six and later?<br />

II A54. To my knowledge, there is no infonnation available on the likely growth rate of earnings<br />

12 and dividends available for time periods more than five years in the future. Use of the<br />

13 DCF model is necessarily subject to this limitation. Analysts sometimes attempt to<br />

14<br />

15<br />

16<br />

address this problem by making various assumptions about the likely growth path of<br />

dividends for the period beginning in year six. However, there is no recognized source of<br />

individual company data upon which to rely in order to make these assumptions.<br />

17 Q55. What is your conclusion about the growth rates used in your application of the<br />

18 FERC DCF model?<br />

19 A55. In my judgment, the question of whether the individual growth rates are sustainable is not<br />

20 a matter of concern in the current proceeding for two reasons. First, I believe that the<br />

21 five-year growth rate estimates used in the model come from widely recognized sources<br />

22 and are the best estimates currently available. Second, the FERC DCF methodology<br />

23<br />

24<br />

25<br />

attempts to address the lack of data on long-tenn dividend growth rates by estimating the<br />

five-year growth rate in the two ways discussed above. The method then creates a range<br />

of reasonableness by looking to the highest and lowest estimates from the two growth<br />

26 rates and two dividend yield estimates. The likely motivation for this approach is the<br />

27 belief that the companies with high estimates are balanced by the companies with low<br />

28 estimates so that the estimation errors cancel out. If the sample is large enough, the

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