16. Justification of Back-up Generators

Apple Valley was required by D.03-08-069 to justify its need for and investment in backup generators used to provide additional power to supplement its pumping capacity at various locations. The issue was carried forward with an expectation that ORA would have the time in this proceeding to examine the data and decide whether there were issues of note to bring before the Commission.

ORA expressed concern that Apple Valley had acquired several back-up generators because of power interruptions or the avoidance of supply disruptions because of power interruptions. Apple Valley demonstrated that it has the generators to augment pumping, and they are only incidentally available in the event of infrequent disruptions.⁷⁰

We have the generators for two primary reasons. One is to save the costs that we would have associated with adding storage for emergency supply. What I mean by that is without our generators, we would have to have much more elevated storage to supply our water system for various reasons, such as power outages. [Secondly] We also are able to keep our system supplied with water when we have localized problems due to power.

We are satisfied that Apple Valley has a reasonable need for the backup generators, and thus that they are used and useful in providing utility service. Nevertheless, Apple Valley should continue the reports to track the use of the back-up generators and should include them in the work papers of the next rate case.

⁷⁰ Transcript, p. 222.