20240514Comments.pdf

RECEIVED
Tuesday, May 14, 2024 11:11:58 AM
IDAHO PUBLIC
UTILITIES COMMISSION
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
HAWLEY TROXELL ENNIS &HAWLEY LLP
877 W. Main Street, Suite 200
P.O. Box 1617
Boise, ID 83701-1617
Telephone: [phone]
Facsimile: 208.954.5253
Email: [e-mail]
[e-mail]
Attorneys For PIIC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR CASE NO. PAC-E-24-05
APPROVAL OF $62.4 MILLION ECAM
DEFERRAL COMMENTS OF PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS
The PacifiCorp Idaho Industrial Customers ("PIIC") appreciate the opportunity to
provide comments in the above-captioned case. PIIC is a trade organization that represents large
industrial customers receiving electrical services from Rocky Mountain Power, a division of
PacifiCorp, ("PacifiCorp") in Idaho and is therefore interested in the significant rate increase
under consideration in this case.
COMMENTS
In this case, PacifiCorp has proposed increase Idaho customer rates by $32,660,000, or
10.5%to recover deferred Net Power Costs ("NPC")through the Energy Cost Adjustment
Mechanism ("ECAM"). The ECAM deferral in this case pertains to the recovery of actual NPC
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incurred during the 12-months ended December 31, 2023, as compared to the Base NPC
established in Case PAC-E-21-07. While the overall rate increase PacifiCorp has proposed is
considerable, the proposal has an even more pronounced impact on high volume customers.
Ratepayers on Schedule 9, the rate schedule through which most PIIC members receive electrical
services, are proposed to receive a disproportionately higher rate increase of approximate 13.1%.
Nevertheless, due to the magnitude of the rate increase, it will, if approved, significantly burden
all customers, including businesses and families alike, regardless of rate schedule. The proposed
rate increase is particularly concerning, as it coincides with a period when businesses and
individuals are grappling with inflationary pressures affecting nearly every aspect of their
consumption and costs. Compounding the issue, PacifiCorp plans to file a rate case this month
or next,proposing further rate increases expected to be even more substantial than this case, at
least judging from filings in other jurisdictions.
As a threshold matter, PIIC has had little opportunity to review and evaluate the
reasonableness of PacifiCorp's Actual NPC included in the ECAM deferral. Although PIIC
supports the use of modified procedure for cases such as this, it is still important for parties to
have the opportunity to review filings and raise issues to encourage a fair and balanced process.
PIIC is not requesting a hearing in this case but does recommend that Commission consider
extending the review period for future ECAM filings, either by requiring PacifiCorp to make its
filing earlier or by adopting a later rate effective date. The Commission's Order 36153 noticing
this case was issued on April 23, 2024, and PIIC's petition to intervene, filed on April 26, 2024,
has still not been granted as of the date of filing of these comments. This has provided little time
for PIIC to review and file comments in what is a major increase to its members rates. This
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timing was not sufficient to perform a meaningful audit of the costs included in PacifiCorp's
filing. Even if PIIC had issued discovery on the day it filed its petition to intervene, it would not
have received responses in time for these comments, let alone be provided with the opportunity
to follow up based on PacifiCorp's responses.
Notwithstanding this concern, PIIC has reviewed PacifiCorp's filed testimony, and based
on the information PacifiCorp presented, has two recommendations for Commission
consideration. Specifically, PIIC recommends the Commission:
1. Amortize the rate increase over a three-year period to mitigate the overlapping
impacts from the rate case; and
2. Remove all costs, including both the cost of allowances and the dispatch costs,
associated with the Washington Climate Commitment Act("CCA')
These recommendations will be discussed further in subsections that follow.
1. Amortization Period
Given its magnitude, PIIC respectfully requests that the Commission amortize the rate
increase proposed in this manner over a three-year period. A longer-term amortization will
mitigate the impact of the rate increase by spreading the cost recovery over a longer period of
time, while mitigating the compounding rate impacts associated with PacifiCorp's upcoming rate
case. Given that Base NPC will be reset in the coming rate case, this proposal will result in more
stable rates over time.
In Case No. PAC-E-24-04, PacifiCorp filed a notice of intent to file a general rate case on
or around May 31, 2024. Based on experience in other jurisdictions, the rate increase that
PacifiCorp is likely to propose will be large in magnitude. For example, PacifiCorp filed to
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increase Wyoming customer rates by 23% last year and the rate increase expected in Idaho could
be even more significant given the length of time since a general rate case was last filed.
Notably, PacifiCorp's NPC has nearly doubled since the last general rate case, and
accordingly, the coming rate case is expected to include an increase to the ECAM Base NPC.
Actual NPC in 2023 was $2,533,782,470 on a total company basis.I This compares to Base NPC
approved in the 2021 general rate case ("GRC") of$1,368,000,000.2 This change can be
attributed to several factors, although changing energy market conditions are a key driver of this
change. Accordingly, much of the proposed rate increase in the coming general rate case will
likely be related to an increase in the NPC base used in the ECAM.
Notwithstanding the increase in Base NPC in the GRC, ratepayers will at the same time
still be paying for deferred NPC through the ECAM rates. This results in a pancaking effect
where ratepayers will effectively end up paying for heightened NPC twice, first through the
increase in Actual NPC in the ECAM and second through an increase in Base NPC in the rate
case. This represents an undesirable outcome of the ECAM deferral and a reason to adopt
mitigation measures to smooth the rate impacts of heightened NPC more evenly over time.
Additionally, market conditions in 2024 to date have been more favorable than they were
in 2023. As of writing these comments, for example, natural gas prices were approximately
$1.40, back to levels not seen since prior to 2020, and less than half the level that were seen in
1 Painter Di.,Exhibit No. 1 at 1:7.
2 Case No. PAC-E-21-07, Settlement Stipulation at 4(Oct. 25, 2021).
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2023.3 Natural gas prices are no longer"soaring" as represented in PacifiCorp's press release for
this matter, which is one reason to expect that the deferral will decline in next year's ECAM
filing.4 The major issues related to PacifiCorp's coal operations appear to have been largely
resolved and not expected to be more impactful in 2024 as they were in 2023. Accordingly,
there is at least a strong indication that NPC will decline or stay flat in 2024 relative to 2023
levels.
Finally, given the expected increase to Base NPC in the coming general rate case, the
2026 ECAM, with rate effective June 1, 2026 will, all things equal, result in a major reduction to
the ECAM deferral rates. As the Base NPC increases,the deferral will decline, but that
reduction will not occur until after the higher Base NPC is included in an ECAM filing.
Considering the effects of these various filing, PIIC recommends a three-year
amortization of the rate increase approved in this matter. This will spread the burden of the
increase through 2026, when Base NPC is reset through the coming general rate case, and result
in more rate stability.
Notably, PIIC is recommending that the rate increase be spread over the three-year
period, as opposed to the total ECAM balance. Using PacifiCorp's initial filing as an example,
PIIC's proposal would be for the rate increase amount of$32,660,000 be spread over 3-years as
opposed to the total $64,906,940 balance sought for recovery. This would result in ECAM
3 See EIA Today in Energy,Northwest Natural Gas Spot Price(Available at
https://www.eia.gov/todayinenergy/prices.php, accessed May 8, 2024).
4 RMP Application, Customer Notices, at 2.
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recovery of$43,133,607 beginning on June 1, 2024, an approximate 3.5%rate increase.5
Further, $10,886,666 would transferred to be recovered in next years' ECAM filing effective
June 1, 2025, and the remaining $10,886,666 would be recovered in the 2026 ECAM effective
June 1, 2026, when the Base NPC will have been reset through the coming GRC.
2. Washington Climate Protection Plan Costs
PIIC also recommend that, consistent with Order 36015 in Case No. AVU-E-23-04, the
Commission exclude all costs associated with the Washington CCA from Idaho customer rates,
including both the cost of Washington carbon dioxide allowances as well as the associated
impact of those allowances on the economic dispatch of the Chehalis power plant.
The Washington CCA was passed by the Washington State Legislature in 2021.E Among
other things, the CCA required the Washington Department of Ecology ("Ecology")to adopt
rules establishing a"cap and invest"program. Accordingly, Ecology adopted CCA rules in
September 2022 that went into effect on January 1, 2023.7 The cap and invest program requires
certain covered entities to purchase greenhouse gas allowances through a state sponsored auction
to cover carbon emissions from emitting resources, including from the Chehalis power plant.
5 This amount consists of$32,246,000 in current ECAM revenues,plus $32,660,000 amortized over
three years or$10,886,666 in amortization per year.
6 See Washington State 67th Legislature, 2021 Regular Session,Engrossed Second Substitute Senate
Bill 5126, § 8 (2021). See also Revised Code of Washington("RCW") 70A.65.060.
7 Washington Administrative Code("WAC"), Chapter 173-446.
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In its filing, PacifiCorp identified $42 million of costs associated with purchasing
allowances for the Chehalis power plant located in Washington.$ While not discussed in
PacifiCorp's testimony, the Washington CCA also impacted the way that the Chehalis power
plant was dispatched. Because the cost of allowances was factored into the dispatch price for the
Chehalis power plant, it was dispatched less efficiently than if the cost of allowances had not be
considered. This is of particular concern in the EIM,where the cost of Washington CCA
allowances would have been considered in the bid prices that PacifiCorp submitted for Chehalis,
resulting in uneconomic dispatch instructions from the market. While we know that the CCA
impacted the dispatch of Chehalis, the precise amount of the impact was not detailed in
PacifiCorp's filing.
In Case No. AVU-E-23-04, the Commission clearly stated that Washington CCA costs,
such as these, are not properly apportioned to the costs included in Idaho customer rates, stating
"the primary question raised by the Application, and the CCA in general, is whether the costs
associated with the CCA should be borne by Idaho ratepayers; the Commission finds they should
not." PIIC agrees with this finding and requests that it be applied consistently in this case.
Notwithstanding, there is also a separate question, which the Commission did not address
in Case AVU-E-23-05, of whether Washington CCA allowances are, indeed, an item of NPC and
thus, includible in the ECAM deferral. PIIC believes they are not. In its 2023 FERC Form 1,
PacifiCorp recorded the cost of allowances in FERC Account 555, Purchased Power. The
Washington CCA allowances, however, have nothing to do with purchased power; and therefore,
8 Painter,Di. at 24:21-23.
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this accounting was not proper. As Avista noted in its filing in AVU-E-23-05, the proper
accounting for the cost of environmental allowances is to record them in Account 509,
Allowances. Account 509 is not included in ECAM. Therefore, irrespective of the
reasonableness of the allowances themselves, they are not eligible for recovery through ECAM.
Unlike Avista, PacifiCorp did not make a filing to request to include Account 509 in the ECAM,
and any such changes to the ECAM could only be made prospectively. Further, PIIC believes
that PacifiCorp's accounting is improper and leads to problems with transparency over the
environmental costs included in its results of operations. Thus, regardless of the Commission's
findings on the reasonableness of the allowances themselves, PIIC requests the Commission also
enter a finding that PacifiCorp erred in including the cost of Washington CCA allowance costs in
FERC Account 555, Purchased Power, and issue an accounting order requiring PacifiCorp to
record allowance purchases to FERC Account 509, Allowances.
With respect to the reasonableness of the CCA costs, the Commission's precedent
established in AVU-E-23-04, excluding Washington CCA costs from rates, is largely consistent
with every jurisdiction that has reviewed the cost of CCA allowances to date. PIIC is not aware
of any jurisdiction that has approved the inclusion of Washington CCA allowance costs in rates.
Thus, if the Commission were to issue an order approving recovery of Washington CCA costs
from Idaho customers, it would be the first to do so.
The Oregon Public Utility Commission did not allow PacifiCorp to include the cost of
CCA allowances nor the associated dispatch costs in PacifiCorp's 2024 Transition Adjustment
Mechanism ("TAM") filing. The TAM is a docket used to forecast and establish base net power
costs for the coming year, in this case for 2025. In that docket, the Oregon Commission stated
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"[w]e disallow the Washington CCA costs as a state-specific initiative that is properly allocated
to Washington under PacifiCorp's MultiState Process."9 PacifiCorp later filed a motion for
reconsideration, which the Commission denied and is now seeking judicial review of the
Commission's order before the Court of Appeals of the State of Oregon.
In Docket No. 20000-633-ER-23, PacifiCorp's 2023 Wyoming General Rate Case, the
Wyoming Public Service Commission similarly concluded that"RMP shall not recover any costs
associated with the [CCA] in any rates charged to Wyoming customers."10 Like Oregon, it
concluded that under the MultiState Process ("MSP") "the [CCA] is a `State-Specific
Initiative."'11 PacifiCorp later requested rehearing of the Wyoming Commission decision, and
the Commission denied that request. At this time, it is unknown whether PacifiCorp will appeal
the Wyoming decision.
Finally, in Washington, ratepayers are provided free allowances in the manner discussed
below, and therefore the cost impacts associated with the CCA on Chehalis, including the costs
of dispatch, were also not considered in revenue requirement in PacifiCorp's recent 2023
Washington General Rate Case Docket UE-230172. To PIIC's knowledge, the Utah Public
Service Commission and the California Public Utilities Commission have yet to hear this issue.
9 In re PacifiCorp, dba Pacific Power, 2024 Transition Adjustment Mechanism, Or.PUC Docket No.
UE 420, Order No. 23-404 at 1 (Oct. 27, 2023).
10 In re the Application of Rocky Mountain Power for Authority to Increase Its Retail Electric Service
Rates by Approximately$140.2 Million Per Year or 21.6 Percent and to Revise the Energy Cost
Adjustment Mechanism. 20000-633-ER-23,Memorandum Opinion,Finding,and Order¶211 (Jan 2,
2024).
11 Id.
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PacifiCorp makes no reference to the Commission's precedent in AVU-E-23-04, nor the
decisions in Oregon and Wyoming. The only justification that it provides is its estimate "that
NPC would have increased by $23.6 million on a total-Company basis if the generation from
Chehalis were removed."12 This additional cost of removing Chehalis entirely form Idaho
customer rates, however, is beside the point. Suggesting that this additional cost is somehow a
benefit of the CCA conflates a harm with a benefit. With respect to NPC, the CCA is a harm to
ratepayers because it increases costs in order to advance a specific state policy of Washington.
Ratepayers are not benefitted from the CCA simply because the rule did not entirely eliminate
the benefits of the Chehalis plant. Concluding so would be illogical. It is the equivalent to the
argument that one benefits from driving a car, and therefore, after an auto collision where the car
is still drivable, there was no harm done because the user could still benefit from driving the car.
The fact that benefits exist does not negate the economic harm and diminishment of those
benefits resulting from the CCA, particularly where Washington customers themselves do not
bear any of that economic harm themselves.
To the contrary, Washington ratepayers have vastly benefited economically from the
CCA. In 2024, Washington collected total revenues from the allowance auctions revenues of
approximately $2,000,000,000, much needed revenues for a highly populated state without
income taxes. So far, five CCA allowance auctions have taken place. The average auction price
in 2023 was $54.86 per allowance. The prices fell substantially, however, in the most recent
auction. The fifth auction, which occurred on March 6, 2024, resulted in an allowance price of
12 Painter,Di-25:3-9.
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$25.76. This reduction is due to a ballot initiative scheduled for November, which would repeal
the Washington CCA in its entirety, an outcome which would potentially further complicate this
issue.
As alluded to above, as the Commission is aware, the revenues generated from selling
these allowances are not collected equally between in state and out of state energy consumers.
Electric generating facilities, such as the Chehalis power plant, must purchase and retire
allowances covering 100% of greenhouse gas emissions. However, to reduce the burden of the
costs of such allowances to Washington ratepayers, ecology allocates free allowances to
Washington retail electric service utilities to cover their compliance obligations associated with
their Washington retail load.13 In other words,utilities, including the Company, are provided
free allowances for their in-state ratepayers,while out-of-state ratepayers must pay the entirety of
the allowance costs.
Based on Ecology's forecast, PacifiCorp is expected to receive $7,699,149 in no-cost
allowances over the period 2023-2026. Based on the average auction prices in 2023, that volume
of free allowances amounts to a $422,356,066 benefit provided to only Washington customers,
which is not equally provided to Idaho customers.
The revenues from the auctions are further earmarked to benefit Washington ratepayers
and are distributed in a special account and are made available to the legislature. There are
restrictions on the use of some of the funds, although the majority can be used at the discretion of
the legislature. Approximately, 75% of the funds must be distributed into the Climate
13 RCW 70A.65.120, (4).
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Commitment Account, which must be used for programs "physically located in Washington
state," including funding programs related to the working families tax rebate, making loans to
local governments, advancing renewable resource development, financing technical education in
colleges and higher education, and other similar investments.14 Notwithstanding these
requirements, the actual use of the funds has been somewhat opaque. To date only about $76.2
million of the $2 billion in revenue has been distributed to grant funding, most of which have
gone towards public transportation. By some accounts, leaving the collected monies in the CCA
accounts, while overspending on others,provides the Washington legislature with nearly
unlimited flexibility in how the funds are disposed. And for a state with no income tax, with
many budgetary challenges, having these funded accounts is a major benefit.
Given the characteristics of the program, the costs associated with the CCA are best
addressed through the MSP 2020 Protocol that governs interjurisdictional cost allocation issues
between PacifiCorp's six states. A fundamental principle of interjurisdictional cost allocation
established in the MSP is that states' policy decisions should not impact the costs allocated to
other states. Accordingly,pursuant to the terms of the MSP 2020 Protocol, the cost of
Washington CCA allowances are not appropriately allocated to Idaho customers.
Further, Washington has historically not participated in the MSP interjurisdictional
allocation agreements and has adopted its own allocation framework that focuses on resources
located in PacifiCorp's Western balancing area. While Washington became a signatory to the
2020 Protocol, the 2020 Protocol methodology generally is not used to set rates in Washington.
14 RCW 70A.65.260.
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Rather, Washington uses a separate allocation framework referred to as the Washington Inter-
Jurisdictional Allocation Methodology ("WIJAM") identified in Appendix F to the 2020
Protocol. As a result of Washington's different allocation method, however, PacifiCorp's
proposal in this case will otherwise result in it over recovering the cost of Washington CCA
compliance. Under the WIJAM method, Washington is allocated a higher portion of Chehalis.
Washington receives approximately 20% of the cost of Chehalis, as compared to its approximate
7%total-system allocation. Under the 2020 Protocol, however, the remaining states are
allocated 93% of the cost of Chehalis. Accordingly, as a result of the different allocation
methods, RMP recovers 112% of the cost of Chehalis between its six jurisdictions. Thus, after
considering the free allowances provided for Washington's 20% share of Chehalis, PacifiCorp's
allocation assumes that it will need to acquire allowances on behalf of other states based on
approximately 93% of the output of Chehalis, resulting in allowance costs covering 112% of
Chehalis.
Considering the foregoing, PIIC recommends that that all costs associated with the
Washington CCA be removed from the ECAM deferral, including both the $42 million in costs
associated with direct allowance purchases, as well as the impacts on Chehalis' dispatch.
Estimating the impact of Washington CCA on Chehalis dispatch in 2023 would require a
counterfactual analysis of Chehalis's dispatch evaluating the dispatch benefits in the absence of
the CCA costs. Given the short comment period in this case, PIIC has not had an opportunity to
study the impacts of the Washington CCA on Chehalis' dispatch. In the Wyoming 2022 GRC,
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this dispatch cost was estimated to be approximately $9,559,205 on a total company basis,15 and
is thus material. Given the time constraints of the case, if the Commission agrees with PIIC's
recommendation, Idaho PUC Staff could potentially perform its own analysis of the dispatch
impacts. Alternatively, the Commission could continue to defer the dispatch cost of the
Washington CCA, requiring PacifiCorp to perform an analysis of the dispatch impacts in its next
ECAM filing, with an adjustment in that case for the 2023 costs. Viewed in conjunction with
PIIC's recommendation for a three-year amortization of the proposed rate increase, this approach
will provide the benefit of affording further time for parties to analyze and study the impacts of
the CCA on dispatch costs of Chehalis.
CONCLUSION
PIIC appreciates the opportunity to provide these comments and looks forward to
working with parties on further resolution of this matter.
Dated this 14th day of May, 2024.
HAWLEY TROXELL ENNIS &HAWLEY LLP
By
l V41t,
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
Attorneys For PIIC
15 See WIEC Exhibit 202,Direct Testimony of Bradley Mullins at 33:2.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I caused to be served a true copy of the foregoing
COMMENTS OF PACIFICORP IDAHO INDUSTRIAL CUSTOMERS by the method
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Dated: May 14, 2024.
Ronald L. Williams, ISB No. 3034
Brandon Helgeson, ISB No. 11615
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