1. PARTICIPATION IN INTERSTATE LEGAL PROCESSES-A State Perspective Ted Boyer Commissioner, Utah Public Service Commission

2. State Jurisdiction State Jurisdiction: Those areas mentioned by Dennis Additional state authority: approve mergers of utility companies; approve issuance of securities; review transactions with unregulated affiliates; arbitrate disputes among utilities or between utilities and customers

3. Possible areas of conflict between FERC and the states Electric restructuring-a grand experiment: Early results of electricity deregulation:

4. Utah reluctance to restructure Viewed it as a grand experiment Would the market system provide appropriate safeguards? Utah adopted a “wait and see” attitude Utah already had low utility rates Fear that Utah rates would increase in a deregulated environment

5. New Generation Resources- Another possible source of conflict State focus: Safe reliable, adequate and reasonably priced utility service FERC focus: Fair and non-discriminatory Additional state focus: Reduce risk (fuel costs, performance, etc)

6. Utah Approach to RFP Process Energy Resource Procurement Act (2005) Requirements: Advantages of Utah Process:

7. Utilities Serving Several States another potential area of conflict Challenges for utilities: Different regulatory schemes Different commissioners Different cultures Different resources Different environmental goals

8. Case Study Utah Power & Light The Problem The Solution The Result

9. State Regulatory Association an example of inter-state cooperation NARUC-National Association of Regulatory Utility Commissioners Members consist of commissioners and staff members Meet periodically (several times per year) Industry updates Federal participation (FERC, FCC) International members welcomed