20240924Decision Memo.pdf

DECISION MEMORANDUM
TO: COMMISSIONER ANDERSON
COMMISSIONER HAMMOND
COMMISSIONER LODGE
COMMISSION SECRETARY
COMMISSION STAFF
LEGAL
FROM: ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
DATE: SEPTEMBER 24, 2024
SUBJECT: IN THE MATTER OF ROCKY MOUNTAIN POWER'S APPLICATION
FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES IN
IDAHO; CASE NO. PAC-E-24-04.
On September 13, 2024, Staff filed a motion seeking to suspend the Company's
January 1, 2025, proposed effective date for new rates for 60 days. Staff argues 1) the slow pace
of the discovery process, resulting from the Company's simultaneous pursuit of multiple rate
cases in states across its service territory stretching its resources; and 2) accommodating the
Company's rate cases in other jurisdictions combined with the Commission's busy calendar has
complicated the scheduling of a workable technical hearing date to the point that it appears
unlikely the Commission will be able to issue a final order in this case prior to the current
January 1, 2025, effective date for new rates. Staff notified the parties of the substance of its
motion on September 12, 2024, and requested that the Commission consider this motion on less
than 14 days' notice.'
On September 20, 2024, the Company filed an answer to Staffs motion, challenging
Staffs assertion that there was good cause for suspension. Specifically, despite acknowledging
delays in some of its discovery responses, the Company notes that, between June 14, 2024, and
August 30, 2024, Staff propounded almost 2,000 discovery requests, including subparts.
According to the Company, the extensions it sought ensured accurate answers were provided that
complied with confidentiality controls.
1 Staff s motion erroneously indicated that the Company consented to the 60-day suspension. As evinced by the
Company's opposition to Staff s motion,filed September 20,2024,this representation was made in error.
DECISION MEMORANDUM 1

Additionally, although the Company sympathizes with the difficulty of coordinating
the calendars of multiple parties, it asserts that it should not be financially penalized for this
difficulty. In this vein, the Company estimates that each month of delay beyond January 1, 2025,
will cost the Company about $2 million, which would negatively affect its liquidity and credit
rating. Consequently, the Company requests that the Commission deny Staff s motion.
Alternatively, if the Commission decides to grant Staffs motion, the Company
requests authority to record a regulatory asset for the revenue requirement increase the
Commission ultimately grants in this case. This asset could accrue from January 1, 2025 until
new rates go into effect. The exact size of this asset would be unknown until the Company's new
rates are set. The Company proposes calculating the regulatory asset balance by first determining
the annual price increase for all net power cost ("NPC") and non-NPC items. However, only the
ten percent of the NPC items subject to the 90/10 sharing band in the ECAM will be deferred.
The combined annual impact of both the deferred NPC and non-NPC items divided over the
suspension period would be the regulatory asset balance. The Company further proposes seeking
recovery of this balance via a compliance filing in this case.
COMMISSION DECISION
Does the Commission wish to issue an order:
1. Suspending the Company's proposed January 1, 2025 proposed effective date for
new rates for a period of 60 days for good cause showing?
2. Authorize the Company to record a regulatory asset for the revenue requirement
increase ultimately grants in this case as described by the Company?
Adam Triplett
Deputy Attorney General
IALegaITLECTRIOPAC-E-24-04_rates\rnemos\PACE2404_dec4_at.doc
DECISION MEMORANDUM 2