Attch20_WWPE9812_StaffComments.doc

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]

Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF THE WASHINGTON WATER POWER COMPANY FOR AUTHORITY TO REVISE ELECTRIC TARIFF SCHEDULE 66 TEMPORARY POWER COST ADJUSTMENT IDAHO AND TO IMPLEMENT A RELATED REBATE.
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CASE NO. WWPE-98-12

COMMENTS OF THE COMMISSION STAFF

COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of Application, Notice of Modified Procedure and Notice of Comment/Protest Deadline issued on December 22, 1998, submits the following comments.
On December 15, 1998, The Washington Water Power Company filed an Application with the Idaho Public Utilities Commission requesting to revise rates on Schedule 66 - Temporary Power Cost Adjustment - Idaho. The Company proposes to reduce Idaho rates for a one year period by $3,093,000 or approximately 2.66%. The proposed reduction is the result of the balance in the PCA balancing account exceeding the $2.2 million trigger.

On January 12, 1999, the Company filed a substitute Schedule 66. Substitute Schedule 66 changes only the tariff schedule references to which Schedule 66 rates apply. The actual rates did not change. References to schedules associated with the DADS experiment, the original MOPS experiment and the Sandpoint service area, all of which have been canceled or will be canceled prior to the requested February 1 effective date, have been eliminated and the schedules associated with the on-going MOPS II experiment have been added.

STAFF ANALYSIS
As directed by the Commission in the case that established Water Powers PCA, Case No. WWP-E-88-3, Order No. 22816, the Company proposes to spread the decrease uniformly to all customer classes and to refund the decrease based on energy use, except for lighting customers. Lighting customers are to receive the same decrease as all other customer classes with the uniform percentage decrease applied to their flat rate charges. The order also specifies that any decrease is to be refunded over a one year period. Company witness McKenzies Exhibit No. 1, Page 2 of 4, shows the calculation of the decrease which has been verified by Commission Staff.
The amounts calculated on Exhibit No. 1, Page 2 of 4, are combined with rates from a Power Cost Adjustment rebate currently in effect to produce the proposed rates shown on substitute Schedule 66. The Companys Exhibit No. 1, Page 4 of 4, shows the calculation of the combined rate which has also been verified by Staff. The existing rebate will expire May 31, 1999.
Staff has not completed a thorough audit of the PCA balancing account. Staff proposes to do that in conjunction with its general rate case audit in Case No. WWP-E-98-11. Final resolution of any balancing account differences would then be booked to the deferral account.
Washington Water Powers Power Cost Adjustment mechanism tracks rebates and surcharges on a dollar-for-dollar basis during the recovery period and, at the end of the recovery period, trues-up the difference by crediting it back to the balancing account.

STAFF RECOMMENDATION
Staff recommends approval of the Companys Application as filed and subsequently revised to include substitute Schedule 66. Staff agrees that the proposed effective date of February 1, 1999 is appropriate.

Respectfully submitted this day of January 1999.

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Scott Woodbury
Deputy Attorney General

Technical Staff: Keith Hessing

SW:KH:jo/misc\comments\wwpe9812.sw

STAFF COMMENTS 3 January 12, 1999