be filed before 2019, 196 customers will not receive any benefit from savings. GPE admits for the first three years after the transaction, its customers would not see any savings. 197 GPE is not promising to reduce rates, only that they would likely request lower rate increases if the . 1s . approve d. 198 transaction
76.
Smaller rises in rate increases are premised on GPE recognizing savings. Absent
savings, customers are unlikely to see lower rate increases.
The Commission has already
concluded the Joint Applicants' preliminary savings estimates are too speculative to satisfy merger standard (a)(ii)-(a)(iv). If GPE's estimated savings from plant retirements are overstated by $70 million for 2020 and $80 million for 2021, it calls into question whether KCP&L and Westar will be able to deliver lower rate increases to its customers. Those figures alone cast doubt on the utilities' ability to pass on any savings to its customers. Plus, GPE estimates only about half of the savings will be shared with customers in the form of lower rate increases, the other half will go to shareholders. 199 Accordingly, the Commission finds the evidence of savings to be too speculative to support the Joint Applicants' claim that they will be able to pass savings on to their customers. Without a showing of lower rate increases, the Joint Applicants cannot establish an economic benefit resulting from the transaction. 77.
The Joint Applicants tout local ownership as one of the central benefits to the
proposed transaction, arguing it will ensure jobs are not lost to an out-of-state utility. 200 This argument is flawed as it ignores the fact that GPE is an out-of-state utility, headquartered in Missouri. More importantly, while the Commission supports local ownership of its utilities, there is no evidence that local ownership will keep jobs in Kansas. The geographic proximity of 196
Id., pp. 86-87 (Bassham). Id, p. 88-89 (Bassham). 198 Tr. Vol. 2, p. 358 (Proctor). 199 See Direct Testimony of Robert H. Glass, Ph.D., Jan. 27, 2017, p. 9. 200 Joint Applicants' Brief, p. 116. 197
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