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Corrected Revised Rebuttal Testimony and Attachments of Alice K. Jackson
Proceeding No. 16A-0396E
Hearing Exhibit
Page 39 of 102
@ ARE YOU AWARE OF ANY OTHER JURISDICTIONS THAT PROCURE
RESOURCES TO POTENTIALLY REPLACE GENERATION DEEMED “AT
RISK”?
A. No. In my view, in calculating our resource need and procuring resources to fil
the need, we should consider our energy and demand forecasts and factor in any
retirements that are actually scheduled and have been decided upon and will
occur during the RAP.%° Requiring the Company to speculate on potential
retirements and acquire resources to potentially replace these resources has too
many “potentials” and is not contemplated as part of Rule 3607, which sets forth
the parameters of the evaluation of existing resources required in an ERP filing.”°