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SCEG OATT Formula Transmission Rate Filing.pdf - SCANA ...

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

Direct Testimony of Jimmy Addison<br />

Docket ER 10- -000<br />

Page 12 of 19<br />

Exhibit No. SeE-1<br />

The projected annual capital expenditure related to these projects will be more than<br />

2<br />

3<br />

4<br />

5<br />

6<br />

7<br />

8<br />

9<br />

double SCE&G's normal annual capital expenditure. According to S&P's April 2009<br />

ratings report for <strong>SCANA</strong>, SCE&G's proposed construction project "introduces<br />

significant construction and financing risk which places considerable pressure on the<br />

consolidated credit profile of SCAN A and necessitates that all remaining aspects of the<br />

business perform satisfactorily in order to provide support and preserve the current<br />

ratings." See Exhibit SCE-5. Moody's July 14, 2009 downgrade also reflected the<br />

concern that analysts have "with the material execution risks associated with a project of<br />

this magnitude for a company of this size." See Exhibit SCE-3.<br />

10 Q.<br />

ARE THERE ANY OTHER BUSINESS RISKS?<br />

II A.<br />

12<br />

Yes, those business risks involve the Commission's new transmission grid reliability<br />

rules.<br />

13<br />

14<br />

Q. HOW DO THE NEW RELIABILITY RULES IMPACT SCE&G'S BUSINESS<br />

RISK?<br />

IS<br />

16<br />

17<br />

18<br />

19<br />

20<br />

21<br />

A. Pursuant to the Energy Policy Act of 2005, the Commission has adopted transmission<br />

grid maintenance and operation reliability standards, which are enforced, under the<br />

Commission's auspices, by NERC. These reliability standards increase SCE&G's<br />

business risk in several ways. First, the new reliability regime requires performance of<br />

transmission operation and maintenance in accordance with a mandated set of standards<br />

and subject to penalties. This reliability regime is relatively new and untested; therefore,<br />

there is a measure of uncertainty as to both the requisites for meeting the standards and

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