20120103Volume III.pdf

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BEFORE THE IDAHO PUBLIC UTILITIES
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES
HEARING BEFORE
ORIGINAL
TECHNICAL HEARING
COMMISSIONER PAUL KJELLANDER (Presiding)
COMMISSIONER MACK A. REDFORD
COMMISSIONER MARSHA H. SMITH.
PLACE:Commission Hearing Room
472 West Washington
Boise, Idaho
DATE:December 19, 2011
VOLUME III - Pages 181 - 383
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COURT REPORTING
POST OFFICE BOX 578
BOISE. IDAHO 83701
208-336-9208
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1 APPEARANCES
2 For the Staff:
3
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5 For PacifiCorp
dba Rocky Mountain Power
(RMP) :
NEIL PRICE, Esq.
Deputy Attorney General
472 West Washington
Boise, Idaho 83702
HICKEY & EVANS, LLP
by PAUL J. HICKEY, Esq.
Post Office Box 467
Cheyenne, Wyoming 82003-and-
DANIEL E. SOLANDER, Esq.
ROCKY MOUNTAIN POWER
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
RACINE, OLSON, NYE, BUDGE
& BAILEY
by RANDALL C. BUDGE, Esq.
Post Office Box 1391
Pocatello, Idaho 83204-1391
RACINE, OLSON, NYE, BUDGE
by ERIC L. OLSEN, Esq.
Post Office Box 1391
Pocatello, Idaho 83204-1391
WILLIAMS BRADBURY, PC
by RONALD L. WILLIAMS, Esq.
1015 West Hays Street
Boise, Idaho 83702
BRAD M. PURDY, Esq.
Attorney at Law
2019 North Seventeenth Street
Boise, Idaho 83702
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10 For Monsanto:
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13 For Idaho Irrigation
Pumpers Association (IIPA):
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For PacifiCorp Idaho
Industrial Customers (PIIC):
17
18 For Community Action
Partnership Association
of Idaho (CAPAI):19
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
APPEARANCES ,
.1 i N D E X
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WITNESS EXAMINATION BY PAGE
3 J.Ted Weston Mr.Hickey (Direct)184
4 (RMP)Prefiled Direct 187
Mr.Purdy (Cross)209
5 Commissioner Smith 217
Commissioner Kj ellander 220
6 Commissioner Redford 222
7 Rebecca "Becky"Eberle Mr.Solander (Direct)225
(RMP - Rebuttal)Prefiled Rebuttal 228
8 Mr.Purdy (Cross)236
Mr.Solander (Redirect)256
9
Teri Ottens Mr.Purdy (Direct)263
10 (CAPAI)Prefiled Direct 266
Mr.Solander (Cross)290
11 Mr.Price (Cross)300
Mr.Purdy (Redirect)303
12.Stacey Donohue Mr.Price (Direct)304
13 ( Staff - Rebuttal)Prefiled Rebuttal 306
Mr.Purdy (Cross)318
14
Randy Lobb Mr.Price (Direct)335
15 (Staff)Prefiled Direct 337
Mr.Purdy (Cross)360
16 Commissioner Smith 367
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HEDRICK COURT REPORTING
P.O. BOX 578, BOISE, ID 83701
INDEX
.1 EXHIBITS
2
NUMBER PAGE
3
For Rocky Mountain Power:
4
49 Stipulated Rate Spread for Two-Year Premarked
5 Two-Year Rate Plan,5 pgs Admitted 382
6 50 Electric Service Schedule No.1,Premarked
18 pgs Admitted 382
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51 Electric Service Schedule No.2,Marked 185
8 24 pgs Admitted 382
9 For the Staff:
10 101 Stipulation,Case No.PAC-E-11-12,Premarked
18 pgs Admitted 382
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102 Monthly Billing Comparison Premarked
12 Admitted 382.13 For the Public:
14 701-703 (Marked in Volume 2)Admitted 382
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HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
EXHIBITS
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1 BOISE, IDAHO, MONDAY, DECEMBER 19,2011, 9:30 A.M.
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4 COMMISSIONER KJELLANDER: Well, good morning.
5 This is the time and place for a technical hearing on a
6 proposed settlement in the matter of the Application of
7 PacifiCorp dba Rocky Mountain Power for approval of changes to
8 its electric schedules. It's Case No. PAC-E-11-12.
9 I'm Paul Kj ellander, and I'll be the Chairman of
10 today' s proceedings. To my right is Commissioner Mack Redford
11 and to my left is Commissioner Marsha Smith. The three of us
12 will ultimately render a Decision in a Final Order in this
13 proceeding.
14 Let's begin first with the appearances of the
15 parties, and let's start with PacifiCorp.
16 MR. HICKEY: Thank you, Mr. Chairman. Paul
17 Hickey of Hickey and Evans, representing Rocky Mountain Power.
18 COMMISSIONER KJELLANDER: Good morning.
19 MR. SOLANDER: My name is Daniel Solander. I'm
20 Senior Counsel for Rocky Mountain Power.
21 COMMISSIONER KJELLANDER: Welcome.
22 MR. BUDGE: Randy Budge, Racine, Olson, Nye,
23 Budge and Bailey, Pocatello, for Intervenor Monsanto Company.
24 And I have with me as well at the table Jim Smith, their energy
25 procurement manager.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
COLLOQUY
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1 COMMISSIONER KJELLANDER: Good morning.
2 And let's go now to the Commission Staff.
3 MR. PRICE: Neil Price, Deputy Attorney General
4 for the Commission Staff. I have with me also Mr. Randy Lobb.
5 COMMISSIONER KJELLANDER: Good morning.
6 And for the Idaho Irrigation Pumpers.
7 MR. OLSEN: Yes, Eric Olsen with Idaho Irrigation
8 Pumpers, with Racine, Olson, Nye, Budge, and Bailey.
9 COMMISSIONER KJELLANDER: Okay. The Community
10 Action Partnership Association of Idaho.
11 MR. PURDY: Brad Purdy on behalf of Community
12 Action, and with me is Teri Ottens.
13 COMMISSIONER KJELLANDER: Good morning.
14 MR. PURDY: Good morning.
15 COMMISSIONER KJELLANDER: And for PacifiCorp
16 Idaho Industrial Customers.
17 MR. WILLIAMS: Ron Williams with Williams
18 Bradbury.
19 COMMISSIONER KJELLANDER: Okay. Is there anyone
20 that we have missed in terms of recognition as an official
21 party to the case? I think as we all recall, the Idaho
22 Conservation League has withdrawn its participation in this
23 case, so I believe those are all of the parties today.
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Are there any preliminary matters that need to
come before the Commission?
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HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
COLLOQUY
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1 MR. PRICE: Commissioner Kj ellander, initially
2 there was a preliminary matter. I think we are going to defer
3 on that until we discuss with the Company perhaps later on
4 after the initial testimony is presented.
5 COMMISSIONER KJELLANDER: Okay.
6 MR. HICKEY: Mr. Chairman, on behalf of Rocky
7 Mountain Power, we will be glad to take up our discussions
8 during a break with Mr. Price and see if there is an ability to
9 resol ve those, and further report to the Commission after the
10 first break in the morning.
11 COMMISSIONER KJELLANDER: Okay, that sounds good.
12 Well, then, it sounds like we're ready to proceed, and let's
13 begin with the Applicant, Rocky Mountain Power.
14 MR. HICKEY: Thank you, Mr. Chairman. We would
15 call as our first witness Mr. Ted Weston. Mr. Weston is being
16 called to present testimony in support of the Stipulation that
17 was filed by the parties resolving the issues in this docket.
18 Ted.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
COLLOQUY
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1 J. TED WESTON,
2 produced as a witness at the instance of Rocky Mountain Power,
3 being first duly sworn, was examined and testified as follows:
4
5 DIRECT EXAMINATION
6
7 BY MR. HICKEY:
8 Q.For the record, would you please state your name
9 and your business address?
10 A.Yes. My name is J. Ted Weston, and my business
11 address is 201 South Main, Suite 2300, Salt Lake City, Utah,
12 84111.
13 Q.And are you employed by Rocky Mountain Power,
14 Mr. Weston?
15 A.Yes, I am.
16 Q.And what is your position with that company?
17 A.I'm currently employed as the manager of Idaho
18 regulatory affairs.
19 Q.And have you had the opportunity to prefile with
20 this Commission testimony in support of the Stipulation filed
21 by the parties, addressing the issues in this general rate
22 case?
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A.Yes, I have.
Q. And do you have any additions or corrections to
that testimony, Mr. Weston?
184
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
WESTON (Di)
RMP
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1 A.Yes, I do, I had one correction to my testimony.
2 As the Company was -- as I was preparing for hearings on
3 Friday, I discovered an oversight on the part of the Company.
4 My Exhibit 50, which was filed with my direct
5 testimony, contains the clean and legislative copies of the
6 tariff sheets complying with the Stipulation; however, the
7 Company unintentionally left off the street light tariffs which
8 are not included in Exhibit 50, so I have prepared and we are
9 providing a supplemental Exhibit 51 containing the street light
10 tariffs in compliance with a one-percent increase to those rate
11 schedules as specified in the Stipulation.
12 Q.Other than seeing that the street lighting
13 charges are properly reflected with what is now Exhibit 51, are
14 there any other changes to your testimony or the exhibits that
15 supported it, Mr. Weston?
16 A.No, there are not.
17 MR. HICKEY: Mr. Chairman, at this time, we would
18 ask that the prefiled testimony of Mr. Weston, together with
19 all of the attached exhibits, including the one just described,
20 be spread upon the record as if read.
21 COMMISSIONER KJELLANDER: And without obj ection,
22 we will spread the prefiled testimony, along with. Exhibi ts 49,
23 50, and 51, across the record as if read.
24 MR. HICKEY: Thank you.
25 (Rocky Mountain Power Exhibit No. 51 was
185
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
WESTON (Di)
RMP
.1 marked for identification. )
2 (The following prefiled testimony of
3 Mr.Weston is spread upon the record.)
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186
HEDRICK COURT REPORTING WESTON (Di)
P.O.BOX 578,BOISE,ID 83701 RMP
187 Weston, Stip - i
Rocky Mountain Power
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1 the Company's 2011 general rate case entered into by and among Rocky
2 Mountain Power, a division of PacifiCorp ("Roèky Mountain Power" or the
3 "Company"); Staff for the Idaho Public Utilities Commission ("Staff'); the Idaho
4 Irrgation Pumpers Association, Inc. ("liP A"); Monsanto Company
5 ("Monsanto"); and the PacifiCorp Idaho Industral Customers ("PIIC")
6 collectively referred to in my testimony as the Pares. Community Action
7 Parership Association of Idaho ("CAP AI") participated in the settlement
8 negotiations; however, they have chosen not to be a par to the Stipulation. The
9 Idaho Conservation League also intervened in the case and participated in the
10 settlement negotiations but later formally withdrew as a par in this proceeding.
i 1 More specifically, my testimony provides an overview of the Company's
12 2011 Idaho general rate case and an explanation of the terms and conditions of
13 ths Stipulation. I also demonstrte that this Stipulation represents a fair, just and
i 4 reçisonable compromise of the issues in this proceeding and that this Stipulation is
15 in the public interest. My testimony support the Parties' recommendation that the
16 Idaho Public Utilities Commission ("Commission") approve the Stipulation and
17 all.of its terms and conditions.
18 Background
19 Q.What price increase did the Company request in its Application for this
20 case?
21 A.On May 27, 2011, Rocky Mountain Power fied an Application with the
22 Commission supported by the testimony of 13 witnesses with several hundreds of
23 pages of testimony and fort-nine exhibits seekig authority to increase the
188 Weston, Stip - 2
Rocky MOUItain Power
.1 Company's base rates for electrc service by $32.7 millon annually, representing
2 an average increase of approximately 15.0 percent. In the Application Rocky
3 Mountain Power sought new rates effective date of June 27, 2011.
4 On June 8, 2011 the Commission suspended the rates that were the subject
5 of the Application for a period of thirt (30) days plus five (5) months makig the
6 rate effective date December 27, 2011. Paries to the Stipulation are respectfully
7 requesting that the Commission approve this Stipulation.with January 1,2012, as
8 the rate-effective date.
9 Q.Has the Company's Application been thoroughly audited and reviewed by
10 the intervening partes in this case?
11 A.Yes. As par of Staff s audit of this Application several meetings were held with.12 Company representatives durng the weeks of August 8 in Portland, Oregon and
13 August 15 in Salt Lake City, Utah. In addition, the intervening paries have asked
14 hundreds of discovery requests which the Company has responded to.
15 Representatives of the intervenig partes met August 23 and September
16 22, 2011 with the Company at the Commission's offce, pursuant to IDAPA
17 31.01.01.271 and 272, to engage in settlement discussions with a view toward
18 resolving the issues raised in Rocky Mountain Power's Application in this
19 proceeding. Based upon the discussions between the Pares, and as a compromise
20 of the positions in this proceeding a settlement was reached.
21 Q.What Test Period did the Company use to determine revenue requirement in
22 this case?.23 A.The Test Period for this Application was based on the historical 12-month period
189 Weston, Stip - 3
Rocky Mountain Power
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ending December 31,2010, adjusted for known and measurable changes through
December 31, 2011. The Test Period was prepared consistent with past
3 Commission practice and the Company's general rate cases filed previously in
4 Idaho.1 The Company_filed rate base on an end-of-period basis, which includes
5 the actul rate base at December 31,2010 plus major capital additions that wil go
6 into service by December 31, 2011.
7 Stipulation
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What is the foundation for the rate increase that the Parties agreed to in this
Stipulation?
The Parties agreed that the staing point of the Stipulation was to accept all
Commission ordered adjustments from Case No. PAC-E-1O-07, Order No: 32196.
Beyond that as a starting point and unless explicitly specified within the
Stipulation, the Paries agreed that this was a "black box" settlement, with no
agreement or acceptance by the Parties of any specific revenue requirement, cost
allocation or cost of service methodology. All Paries agree that this Stipulation
represents a fair, just and reasonable compromise of the issues in this proceeding
and that this Stipulation is in the public interest.
Please describe the terms of the Stipulation entered into by the Parties.
The Paries agree to support a two-year .rate plan with annual rate increases of
$17.0 millon per year, which results in overall average anual revenue increases
of approximately 7.8 percent in 2012 and 7.2 percent in 2013. The first increase to
base rates wil occur January 1, 2012, and wil be comprised of $6.0 millon of
non-net power cost components (capital, operations and maintenance, and other)
i Refer
to pages 9 and 10 of the diect testimony of Mr. Steven R. McDougal in Case No. PAC-E-11-12.
190 Weston, Stip - 4
Rocky Mountain Power
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1 and $11.0 milion of net power costs. The second increase to base rates wil occur
.2 Januar 1, 2013, and wil be comprised of $6.0 millon of non-net power cost
3 components and $ 1 1.0 milion of net power costs.
4 Q.Why did the Parties identify the revenue requirement components between
5 . net power cost and non-net power cost?
6 A.Simply identifying the annual revenue requirement increase would not provide
7 clarity to the amount of net power costs included in customers base rates. The
8 Partes recognzed that the fuction of the Energy Cost Adjustment Mechänism
9 ("ECAM") is to track the difference betWeen actual net power costs incured to
1 0 serve customers and the level of net power costs included in customers rates.
11 Therefore, it was necessary for the Stipulation to specify that $11.0 millon of
12 increase in 2012 and in 2013 were due to increases in net power costs. Because
13 the ECAM is based on monthly total Company dollars per megawatt-hour,
14 Paragraph 4 of the Stipulation clarfies that the $11.0 milion anual increase to
15 net power costs on an Idaho basis represents an increase to Commssion approved
16 total Company net power costs in base rates of $1.025 billon to $1.205 bilion in
17 2012 and from $1.205 bilion to $1.385 bilion in 2013. These amounts wil
18 become the total Company base net power costs for futue tracking in the
19 Company's ECAM.
20 Q.Does the Stipulation specify other ECAM related items?
21 A.Yes. The Stipulation specifies that the level of renewable energy certficate
22 ("REC") revenue included in rates in 2012 and 2013 wil be $78.8 millon, on a
23 total Company basis or $6,526,622 allocated to Idaho. This Idaho allocated
191 Weston, Stip - 5
Rocky Mountain Power
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amount wil become the base for puroses of trackig at 100 percent in the
Company's ECAM mechanism.
The Stipulation also specifies that the Idaho base load in the 2012 ECAM
load. change adjustment revenue ("LCAR") calculation would be the 2010 load
included in Case No. PAC-E-11-12 for the 2012 ECAM deferral calculation and
the 2011 load reported in the Anual Results of Operations Report for the 2013
ECAM deferral calculation.
The Stipulation also specifies that the LCAR unit value would be frozen
over the rate plan period at the curent rate of $5.47 per Iv (Case No. PAC-E-
10-07).
Finally, the Stipulation specifies that, due to the uncertinty of the
jursdictional treatment of the dispatchable irrgation -load control program
curently being discussed by the MSP Standing Committee, Idaho's share of the
customer load control service credit wil be tracked in the ECAM. The Stipulation
identifies that $1,045,423 is Idaho's curent base amount that would be tracked in
the ECAM for 2012 and 2013. There are two items that could change Idaho's
actual expense amount: first, if other states don't support system allocation of the
irrgation program; second, the agreement for the curent load control service
credit expires after the 2012 program season.
What was the single largest factor that the parties took into consideration
during settlement discussions?
The key issue dealt with by the Stipulation was to address customer rate impact
from both general rate case changes and the potential changes from ECAM
192 Weston, Stip - 6
Rocky Mountain Power
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surcharges. Since net power costs were the single largest cost driver in this case
and with the Company expecting the 2011 ECAM deferral to be in the range of
$15 to $18 millon, it was critical the Stipulation holistically address net power
- costs. Approximately 51 percent of the $32.7 millon increase requested by the
Company in this application, or $16.8 million, was due to increases in net power
costs. On a total-Company basis, net power costs included in the Application and
supported in the testimony of Company witness of Mr. Gregory N. Duvall were
$ 1.311 bilion durng the test year, an increase of more than $287 milion above
the $1.025 bilion approved by the Commission in Case No. PAC-E-1O-07 and
curently included in customer's rates. The Company expects actul net power
costs for 2011 wil be closer to $1.35 bilion, increasing to over $1.5 bilion
durig calendar year 2012.
One additional factor compounding the rate impact for Monsanto and
Agrum is that April 1, 2012, wil be the first time their tariff contract based load
would be subject to the ECAM? The Parties recognized that whatever decision
they reached regarding net power costs in the rate case had a direct impact on the
Company's ECAM.
How does the Stipulation address the rate impact of increasing net power
costs?
The Stipulation mitigates the rate impact in three ways. First, the rate plan spreads
the increase over two years for most of the Company's customers who are already
paying the ECAM rider. Second, for Agrum and Monsanto, because 2011 is the
first year that their tarff contract loads are subject to the ECAM, the Stipulation
2 All other retail taiff customers were subject to Schedule 94, Energy Cost Adjustment rates, April 1, 2010. _
193 Weston, Stip - 7
Rocky Mountain Power
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includes an inovative tiered approach of amortizing the deferred net power cost
in the ECAM for this usage. This tiered approach allows Monsanto and Agrum to
defer paying some of the ECAM increases to futue years to smooth out the
impact the ECAM increases would have along with the general rate increases,
while at the same time continuing to allow the Company certainty of cost
recovery for these costs. Third, the Stipulation specifies that the Company won't
file another general rate case before May 31, 2013, with new rates not effective
prior to January 1, 2014. Absent this Stipulation, the Company would probably
have filed a general rate case in 2012 with rates effective in 2013 that would have
included net power costs in excess of $1.5 billon. The Stipulation only increases
net power costs to $1.385 bilion in 2013, significantly less than what the
Company projects it would be absent the Stipulation. Ultimately, 90 percent of the
difference between actual net power costs and in-rates net power costs wil be
deferred and collected in the ECAM, customers get the benefit of the delay in
paying the higher level until the costs become "actual" and also benefit from 10
percent of the incremental difference not being included in the ECAM deferraL.
Would you e~plain how the amortization you referred to wi work?
The Stipulation specifies that the Company wil amortze and collect Agrium and
Monsanto's tarff contract share of Commission approved ECAM balances, which
includes deferred net power costs, REC revenues, LCAR, the incremental
irrgation load control credit and any other EeAM components, such as S02 sales,
over the following periods:
(1) The Commission-determined 2012 ECAM balance, based on the 2011
194 Weston, Stip - 8
Rocky Mountain Power
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deferrals, wil be amortized begining April 1, 2012 over a thee-year
period ending March 31, 2015. Any over or under collection of the 2012
ECAM balance would be added to the 2015 ECAM balance.
(2) The Commission-determined 2013 ECAM balance, based on the 2012
deferrals, wil also be amortzed over a thee-year period begining April 1,
2013 though March 31, 2016, with any over or under collection of that
balance added to the 2016 ECAM balance.
(3) The Commission-determined 2014 ECAM balance, based on the 2013
dèferrals, wil. also be amortized, but over a two-year period beginning
April 1, 2014 through March 31, 2016, with any over-collection or under-
collection of that balance added to the 2016 ECAM balance.
(4) Begining with the Commission-determined 2015 ECAM balance,
based on the 2014 deferrals, Monsanto and Agrum wil pay new ECAM
costs based on a 12-month collection period.
(5) Any over-collection or under-collection at the end of the amortization
periods above wil be tred up for each contrct customer and refuded or
collected as par of a subsequent ECAM collection period from these
contract customers and not from other retail customers.
Does the amortation apply to the small portion of Agrium's load that is
served on Schedule 6 and 9?
No. The portion of Agrum's load served on Schedule 6 and 9 have been subject
to and paying the ECAM, Schedule 94 rate, since its initial rate implementation
effective April i, 2010. The amortization schedule only applies to Agrum and
195 Weston, Stip - 9
Rocky Mountain Power
196 Weston, Stip - 10
Rocky Mountain Power
197 Weston, Stip - 11
Rocky Mountain Power
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I Terminal transmission line is now used and usefuL. The Parties respectflly
2 request that the Commission make that finding in its order approving the
3 Stipulation.
4 Although the Parties agree that the Populus to Termnal transmission line
5 is used and useful, they fuher agree that the portion of the transmission line
6 deemed PHFU in Case No. PAC-E-1O-07 shall not be included in customer's
7 rates until the rate-effective date from the Company's next general rate on or after
8 Januar I, 2014. The Partes to the Stipulation agree that the Company wil
9 continue to defer the depreciation expense associated with the Populus to
10 Termal transmission line, pursuant to Order No. 32224, until it is included in
11 rates on or after Januar 1,2014, and that this accumulated deferred balance wil
12 be amortzed over thee years from the date the costs are included in rates.
13 Finally, Staff, Monsanto, and the Company agree to file a Motion to
14 Suspend the Appeal on the Populus to Termal trnsmission line decision now
15 pending in the Idaho Supreme Cour, docketed as Case No. 38930-2011. A
16 motion to suspend the procedural schedule was fied October 28, 2011 with the
17 Idao Supreme Cour. If the Commission makes the fmdings requested in the
18 Stipulation on this issue, the Company and Paries agrees that within 10 days
19 thereof they wil fie a stipulation with the Idao Supreme Cour for Dismissal of
20 the appeaL.
21 The effect of these agreements on the Populus to Terminal transmission
22 line is a reasonable compromise of the issues pending on Appeal and avoidance of
23 the costs of fuer litigation of those issues. Although the Paries agree that the
198 Weston, Stip - 12
Rocky Mountain Power
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entie transmission line is curently used and useful and that the Commission
should make a finding to that effect, they also agree to delay recovery of the
porton of the costs disallowed for curent recovery in rates in Case No. PAC-E-
10-07 until on or after Januar 1,2014.
Hedging
Q. How does the Stipulation address future hedging costs?
A. The Stipulation specifies that the Company wil work with the Paries to establish
hedging limits consistent with workgroup processes established in Utah and
Oregon for new costs beginning January 1, 2013, and forward. These new costs
would be related to new hedging contracts entered into on or after that date.
Rate Design
How does the Stipulation address rate design?
The Stipulation specifies that the design of rates by rate schedule (rate design)
wil be consistent with the Company's proposals filed in its Application, adjusted
for the $17.0 millon annual revenue requirement with one modification. The
Company's proposal increases the residential customer service charge for
Schedule 1 and 36 was not adopted. The customer service charge for Schediile 1
and 36 wil remain at $5.00 per month and $14.00 per month, respectively, durng
the two-year rate plan. A sumary of the Stipulation rate design by rate schedule
is provided in the following table.
199 Weston, Stip - 13
Rocky Mountain Power
.Stipulation Rate Design Summary
Average Customer-Demand Energy
Schedule Increase Charge Charge Charge
collect the total
1 5.88%no change revenue
collect the total
36 7.96%no change revenue
3% higher than collect the rest of the
6,35 6.70%average average revenue
4% higher than collect the rest of the
9 7.02%average average revenue
5% higher than collect the rest of the
10 8.91%average average revenue
7,11,12 1.07%uniformly percentage increase to all biling elements
19 6.40%uniformly percentage increase to all biling elements
23 6.88%uniformy percentage increase to all billng elements
SPC 1 8.91%unformly percentage increase to all biling elements
SPC2 8.91%uniformy percentage increase to all billng elements.
1 Rate Spread
2 Q.Does the Stipulation specify how the $17.0 million revenue requirement
3 increase wi be spread between customer classes?
4 A.Yes. The Stipulation specifies how to calculate the rate spread, details of the rate
5 spread are included as Exhibit 49 of my testimony. A sumar of the rate spread
6 is presented in the following table:
.
200 Weston, Stip - 14
Rocky Mountain Power
.Rate Spread Comparison
Customer Class Proposed Settled
Residential - Schedule 1 7.92%5.88%
Residential- Schedule 36 15.9%7.96%
General Service
Schedule 23/23A 11.8%6.88%
Schedule 6/6AJ8/35 10.8%6.70%
Schedule 9 11.2%7.02%
Schedule 19 9.70%6.40%
Irgation
Schedule 10 19.9%8.91%
Public Street Lighting
Schedules 717A, 11, 12 0%1.07%
Schedule 400 18.7%8.91%
Schedule 401 19.9%8.91%
1 Q.
2 A..3
4
5 Q.
6 A.
7
8
9
How will the Stipulation impact residential customers?
Idaho's average residential customer on Schedule 1 uses 837 kWh a month. At
that usage level residential customers would experience a $4.84 increase per
month to their bils.
Has the Company updated its tarif schedules based on the Stipulation?
Yes. Exhibit 50 contains the clean and legislative copies of the Company's Idao
tariff schedules based on the terms of the Stipulation. The Parties to the
Stipulation respectfully request that the Commission approve the Stipulation and
these taffs as fied.
10 Conclusion
11 Q.Does the Company believe the Stipulation represents a fair, just and
12 reasonable compromise of the issues and is in the public interest?
13 A.Yes. All Partes to the Stipulation negotiated in good faith to reach a reasonable
.14 outcome. The Company believes that its initial request of $32.7 milion was
15 justified to meet the cost of serving its customers in Idaho. However, in an effort
201 Weston, Stip - 15
Rocky Mountain Power
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.
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I
2
3
4
5
6
7
8
9
10
11
12
13
14
15 Q.
16 A.
to reach an agreement with Paries, the Company was willing to reduce that
request and stipulate to $17.0 milion price increases on January 1, 2012, and
January 1, 2013. In. recognition of the two-year rate plan covered by this
Stipulation, Rocky Mountain Power wil not fie another general rate case before
May 31, 2013,' with new rates not effective prior to January 1, 2014. Rocky
Mountain Power wil continue to fie annual Results of Operations Reports with
the Commssion to enable the Commssion to ensure that rates durng the two-
year rate plan continue to be just and reasonable. The Company has been prudent
in securing resources for the benefit of its Idaho customers and should be granted
cost recovery of these expenditues: The Company wil continue to work to
control its costs while implementing mechansms and pricing proposals to help
customers use electrcity more efficiently. For these reasons the Company
supports the Stipulation entered into and respectfully requests that the
Commission approve it as filed.
Does this conclude your direct testimony?
Yes.
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20
1 (The following proceedings were had in open
2 hearing.)
3 COMMISSIONER KJELLANDER: And we will now make
4 your witness Mr. Weston available for cross-examination.
5 MR. HICKEY: If I may, Mr. Chairman, Mr. Weston
6 has a brief summary of his testimony that I would hope he might
7 be allowed to give in order to put some context on the issues
8 in the case. It's not lengthy, sir, and is offered in the
9 spiri t of something to assist the Commission.
10 COMMISSIONER REDFORD: What do you call it?
11 MR. HICKEY: Summary of his testimony.
12 COMMISSIONER KJELLANDER: We've all had an
13 opportuni ty to read it, but if you promise to be brief, then
14 certainly.
15 MR. HICKEY: Thank you, Mr. Chairman.
16 Q.BY MR. HICKEY: Mr. Weston, I'd ask you to
17 condense the prepared statement as much as you can.
18 A.I'LL do my best.
19 Q.Thank you.
A.Good morning, Chairman Kj ellander, Commissioner
21 Smith, and Commissioner Redford. It's my pleasure on behalf of
22 Rocky Mountain Power to present this Stipulation before the
23 Commission.
.24 The first thing I'd like to address this morning
25 is while some people have expressed frustration about the
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1 perceived lack of transparency with a stipulated settlement,
2 the Company would like to note that it has provided notice to
3 all of its customers through bill stuffers , it placed ads in
4 local newspapers, as well as provided six workshops June 7th
5 through the 9th and September 26th through the 28th in our
6 service terri tory, as well as Commission Staff providing two
7 workshops in October in the Company's service terri tory. In
8 those workshops, less than 50 people attended, and if you
9 remove the people that attended multiple workshops, probably
10 less than 40.
11 MR. PURDY: Excuse me, Mr. Chair. I'm sorry to
12 interrupt Mr. Weston, but I patiently listened here for a
13 minute or two now and it just strikes me that this is in the
14 nature of rebuttal to some of the issues that were discussed by
15 Ms. Ottens in her testimony; and characterizing public
16 testimony given one way or the other I think is very
17 inappropriate. I obj ect.
18 MR. HICKEY: Mr. Chairman, if I may.
19 COMMISSIONER KJELLANDER: Mr. Hickey.
20 MR. HICKEY: It's my understanding that at the
21 public hearings there was some discussion of the Company
22 responding, and it was determined that there was a more
23 appropriate forum, I believe, is what one of our co-counsel,
24 Yvonne Hogle, had reported the direction from the Commission
25 was. And this is about all Mr. Weston intended to say, but it
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1 was offered as this was the forum that the Company would have a
2 chance to comment in response to some of the concerns brought
3 to those public hearings.
4 COMMISSIONER KJELLANDER: Okay. So, are you
5 telling me that we're almost done?
6 MR. HICKEY: Yes.
7 COMMISSIONER KJELLANDER: Okay. Why don't we
8 just continue with that and I'll recognize the obj ection, and
9 should there be any need for additional questioning on that,
10 Mr. Purdy, you certainly will be entitled to it.
11 MR. PURDY: Than k you.
12 MR. HICKEY: Thank you.
13 COMMISSIONER KJELLANDER: Please continue.
14 THE WITNESS: Thank you.
15 I guess just in summary, I'd say by design and
16 Idaho Statute, the regulatory process is very transparent and
17 public, and as you're aware, all of the meetings have been
18 noticed publicly and the information has been made available to
19 the public, and this process is an open and public process.
20 If the Commission would allow, I'd just like to
21 quickly summarize the major points of the Stipulation at this
22 point. The Stipulation before you represents hundreds of hours
23 of effort on behalf of the parties that have intervened. All
24 of the intervening parties have reviewed the Application and
25 asked thousands of Data Requests.
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.1 On August 23rd and September 22nd, the Commission
2 noticed public meetings with the purpose of engaging in
3 settlement discussions. All of the parties participated in
4 those settlement discussions. And although they were unable to
5 reach a settlement at that time, they continued to hold
6 discussions.
7 And on October 4th an Agreement in principle was
8 reached among the parties, which led to the filing of the
9 Stipulation with the Commission on October 17th.
10 As you are aware, the parties to the Stipulation
11 was the Company, the Commission Staff, Monsanto, Idaho
12 Irrigation Pumpers Association, and PacifiCorp Idaho Industrial.13 Customers. While the Community Action Partnership Association
14 of Idaho and Idaho Conservation League participated in those
15 settlement discussions, they chose not to participate in the
16 Stipulation.
17 The Stipulation itself is a two-year
18 comprehensive rate plan where the parties support a $17 million
19 annual increase with rates effective January 1, 2012, and
20 January 1, 2013, representing a 7.8 percent and 7.2 percent
21 overall increase respectively. That $17 million was segregated
22 into $11 million associated with net power costs, and the
23 remaining six million was non-net power cost items including
24 capital investment, operation and maintenance costs, and other.25 components.
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.1 The Company also committed that it would make a
2 compliance filing by November 1, 2012, to implement the second
3 phase of the two-year rate plan.
4 Paragraph 5 of the Stipulation points out that
5 this was a black box settlement, which means that there was no
6 agreement or acceptance among the parties of any specific
7 revenue requirement, cost allocations, or cost of service
8 methodology; however, all of the parties did agree that the $17
9 million annual increase was an appropriate resolution to the
10 case.
11 Paragraph 6 through 10 of the Stipulation
12 summarizes the ECAM, the impacts to the ECAM, points out that.13 the current base level of net power costs are $1.025 billion on
14 a total Company basis, or 66 million allocated to the state of
15 Idaho. The Stipulation specifies that that base level of net
16 power cost in the ECAM will be 1.205 billion for 2012 and 1.385
17 billion for 2013.
18 Paragraph 7 of the Stipulation points out that
19 $78.8 million on a total Company basis or six and a half
20 million dollars on an Idaho basis of renewable energy credits
21 will be tracked in the ECAM for 2012 and '13.
22 Paragraph 8 describes the loads and the load
23 change adjustment rate that will be utilized over the rate
24 plan..25 And Paragraph 9 describes how the ECAM deferral
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23
1 associated with Monsanto and Agrium will be handled.
2 Paragraph 10 points out that the irrigation load
3 control service credit should also be tracked in the ECAM, and
4 that the parties will work jointly with Monsanto and Agrium
5 to -- and the Irrigation Pumpers Association to address future
6 contracts periods over the rate plan.
7 In conclusion, the parties to the Stipulation
8 have negotiated a fair and balanced resolution, and believe it
9 is in the public interest for the Commission to approve the
10 Stipulation as filed.
11 MR. HICKEY: Mr. Chairman, that concludes
12 Mr. Weston's summary. Thank you for allowing him to present
13 it, and he's available for examination by the Commission Staff
14 and parties.
15 COMMISSIONER KJELLANDER: Thank you.
16 Let's begin with Commission Staff. Mr. Price.
17 MR. PRICE: No questions from the Staff.
18 COMMISSIONER KJELLANDER: Move to Monsanto.
19 MR. BUDGE: No questions.
20 COMMISSIONER KJELLANDER: The Idaho Irrigation
21 Pumpers.
22 MR. OLSEN: No questions.
COMMISSIONER KJELLANDER: The PacifiCorp Idaho.24 Industrial Customers?
25 MR. WILLIAMS: No questions.
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1 COMMISSIONER KJELLANDER: And let's move now to
2 the Community Action Partnership Association of Idaho.
3 MR. PURDY: Thank you, Mr. Chairman.
4
5 CROSS-EXAMINATION
6
7 BY MR. PURDY:
8 Q.Good morning, Mr. Weston.
9 A.Good morning, Mr. Purdy.
10 Q.Before I get into some questions here, let me ask
11 you, are you the Company's policy witness with respect to
12 low-income weatherization questions?
13 A.No, I'm not.
14 Q.Do you have any familiarity with the low-income
15 weatherization evaluation that was conducted by Cadmus for the
16 Company?
17 A.Other than reading the results of the
18 Application, no, I don't.
19 Q.And do you have any knowledge about a proceeding
20 before this Commission in 2009 resulting in a Memorandum of
21 Understanding for demand-side management resources?
22 MR. HICKEY: Mr. Chairman, if I may, I think
23 these questions are clearly beyond the scope of the direct of
24.25
Mr. Weston's testimony. Maybe more importantly, Becky Eberle
is here on behalf of the Company to address the weatherization
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1 and related issues that Mr. Purdy's client is addressing, and I
2 would suggest that she would be the appropriate witness to
3 respond to this line of examination.
4 MR. PURDY: Mr. Chair, if I might.
5 COMMISSIONER KJELLANDER: Mr. Purdy.
6 MR. PURDY: Mr. Weston didn't even have a chance
7 to answer the question, "yes, I am aware," or, "no, I'm not,"
8 first of all.
9 Second of all, my concern is that in light of
10 Mr. Weston's position with the Company, that if I defer until
11 Ms. Eberle takes the stand and she defers questions that are
12 more along the lines of those made by more senior corporate
13 executives -- and that would be, in this case, Mr. Weston, and
14 I don't believe anyone else is here -- then I've lost an
15 opportuni ty to cross on some policy questions I have. If
16 Mr. Weston truly doesn't know any of this stuff and Ms. Eberle
17 does, then that's fine.
18 COMMISSIONER KJELLANDER: And so your concern is
19 that you won't know until you ask.
20 MR. PURDY: Exact 1 y .
21 COMMISSIONER KJELLANDER: Okay. I think what
22 we'll do is provide you a little bit of leeway to ask. And if,
23 in fact, Mr. Weston says he's not the correct witness, then
24 we'll move forward with that.
25 And then, additionally, my sense is that, my
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1 hope is that the hearing doesn't go for too long, so we'll
2 still have the witness here later this afternoon if we find
3 that there's a need to bring him back.
4 MR. HICKEY: We promise you that the witness will
5 be here, Mr. Chairman.
6 COMMISSIONER KJELLANDER: Okay, thank you.
7 So, Mr. Purdy, please continue.
8 MR. PURDY: Thank you.
9 BY MR. PURDY: Mr. Weston, do you recall myQ.
10 question?
11 Could you restate it, please?A.
12 Yes, absolutely:Q.
13 Are you aware of or familiar with the 2009
14 proceeding that resulted before this Commission that
15 resul ted in a Memorandum of Understanding for demand-side
16 management measures for Rocky Mountain?
17 Yes, I'm aware that a workshop was held whereA.
18 that was discussed.
19 Did -- with respect to low-income weatherizationQ.
20 and the recent evaluation of that program, what is your role
21 with the Company in terms of oversight, if any, oversight and
22 administrati ve review?
23 As Idaho regulatory affairs manager, my main roleA.
24 in that process is reviewing the Application to ensure it meets
25 the requirements, and filing that with the Commission.
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1 Q.And as regulatory affairs manager, is it fair to
2 say that you have some degree of input into policy
3 considerations for low-income weatherization?
4 A.No, I wouldn't specify it that way. As I said
5 earlier, my role would be to assure that the filing is in
6 compliance with Idaho Statutes.
7 Q.In that regard, did you review the Company's
8 filing in PAC-E-11-13, which I'll call the Cadmus evaluation
9 case, to ensure its compliance with Idaho Statutes?
10 A.Yes, I reviewed it before it was filed.
11 And you were confident that it did comply withQ.
12 Idaho Statutes as the Application as worded and presented to
13 this Commission?
14 A. I'm not aware of any Statutes on low-income
15 reporting. Like I said, there was a workshop held between the
16 investor-owned Utilities and Commission Staff and interested
17 parties to discuss evaluation -- program evaluations, and
18 reporting those evaluations to the Commission.
19 Q.Do you have knowledge regarding the Agreement
20 that was reached with Cadmus to evaluate the Company's
21 low-income weatherization program?
22 No, I do not. I wasn't involved in negotiationA.
23 of obtaining Cadmus to evaluate the Company's program.
24 Q. All right. And for these questions that I i ve
25 just asked you that you indicated more or less that you don't
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1 have involvement or familiarity, would Ms. Eberle be the
2 Company person, witness, who does have that knowledge?
3 A. You would have to ask her, but I don't believe
4 she is. She manages the low-income programs, but I don't
5 believe she was involved in the program evaluation itself, nor
6 do I believe the program evaluation is relevant in this
7 proceeding.
8 This proceeding is a general rate case proceeding
9 to discuss the Stipulation. The low-income evaluation is not a
10 portion of the Stipulation.
11 Q.So the Company does not have in attendance at
12 this hearing any witness who has direct involvement with the
13 low-income weatherization program's evaluation?
14 A.No, it does not.
15 MR. HICKEY: Object: Asked and answered.
16 And, Mr. Chairman, I would note for the record
17 that Mr. Solander last week visited with Mr. Purdy at least
18 through e-mail about the fact that Mr. Weston and Ms. Eberle
19 would be our two witnesses called today in support of the
20 Stipulation and the outstanding issues with Mr. Purdy's client,
21 and at that time I'm not aware that there was any request for
22 any additional witnesses to be here. So for the reason that
23 the question's been asked and answered, it's not relevant to
24 what's before you today, I'd ask that the obj ection be
25 sustained.
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1 MR. PURDY: Mr. Chairman, that question was not
2 asked and answered previously. The question was is there any
3 person in attendance, any witness on behalf of the Company,
4 able to testify about these things, and his answer was "no," if
5 I understood him correctly. But the question wasn i t asked and
6 answered.
7 Secondly, and I think more important, is the fact
8 that I think it's very important that this record be quite
9 clear as to what information was presented in support of the
10 Company's Application in this case and what information was
11 not, what witnesses were available and those that were not.
12 And if I can't ask these questions, I can't ferret that out.
13 Regarding any conversation I had or communication
14 I had with Mr. Solander last week, I think it's inappropriate
15 to obj ect and get into a narrative about discussions between
16 Counsel, but in no way, shape, or form was I given the
17 impression that Mr. Weston could not speak to policy issues
18 involving a DSM program very important to a party to this case,
19 and as regulatory affairs officer for the Company. I was not
20 given that impression at all. I thought he would be able to
21 testify as to policy.
22 So, I think it is important. I won't belabor
23 this, I promise you, but I think it's important to get several
24 questions and answers on the record.
25 COMMISSIONER KJELLANDER: What I'm going to do is
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1 just allow you a little bit of leeway here. I recognize the
2 witness can either answer "yes," "no," or "I don't know" to the
3 extent that it's warranted wi thin the questions, allow us to
4 proceed down this path and get rolling. So if you'd like to
5 continue, I'LL grant you some leeway. The obj ection is duly
6 noted.
7 MR. PURDY: Thank you, Mr. Chair.
8 Q.BY MR. PURDY: Mr. Weston, this has been asked
9 and answered, but because of the sidebar there I need to ask
10 again for clarification:
11 Is there any person in attendance in this hearing
12 room today who has direct knowledge and familiarity regarding
13 the Company's low-income weatherization program and its recent
14 evaluation by Cadmus?
15 A.I would answer that Ms. Becky Eberle has direct
16 knowledge of the low-income weatherization program. To the
17 extent of her knowledge of the evaluation, I'm not sure of
18 that, but I don't believe that she was involved in the
19 evaluation of the program.
20 I would also point out that the Company has a
21 pending Application before this Commission, PAC-E-11-13, that
22 specifically deals with the low-income evaluation, and when
23 that was filed, the Company asked that that be dealt with in
24 modified procedure. At that point, parties had the opportunity
25 to request, if they wished, a different handling of that case,
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1 and none was made. So that case is currently proceeding under
2 modified procedure, and that -- in my opinion, that's the
3 appropriate place for the low-income evaluation to be
4 addressed.
5 Mr. Weston, I'm sorry, but my question was notQ.
6 what your opinion is as to the. appropriate place for any of my
7 questions.
8 I believe I answered your question.A.
9 Q.A bit ago, yes.
10 So, my next question is is any person here who
11 has -- is there any person here on behalf of Rocky Mountain
12 Power who has familiarity of, with knowledge of, the actual
13 contractual arrangement with Cadmus regarding the evaluation of
14 the Company's low-income weatherization program?
15 A.No.
16 All right. And, finally, are you aware whetherQ.
17 Ms. Eberle or perhaps Staff witness Donohue referenced this
18 other proceeding that you referred to, the Cadmus evaluation
19 case, in testimony in this case?
20 I know Ms. Ottens did and Ms. Donohue did, andA.
21 I'm not sure if Ms. Eberle did or not. I don't remember seeing
22 that in her testimony.
23 MR. PURDY: If I could have just one second,
24 Mr. Chairman.
25 COMMISSIONER KJELLANDER: Yes.
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1 MR. PURDY: Thank you for your indulgence.
2 I will conclude my examination.
3 Thank you, Mr. Weston.
4 COMMISSIONER KJELLANDER: Thank you.
5 Are there any questions from members of the
6 Commission? Commissioner Smith.
7
8 EXAMINATION
9
10 BY COMMISSIONER SMITH:
11 Mr. Weston, I'm looking at page 15 of yourQ.
12 testimony where you have a chart showing the rate spread
13 comparisons.
14 A.Yes.
15 One of the things that I've read in many publicQ.
16 comments about this matter is the difference between the
17 proposed increase for residential Schedule 1 and residential
18 Schedule 36. So, when I get that question or people who are
19 actually on Schedule 36 wonder why are they being given a
20 higher percentage increase, what would you say is the correct
21 response? What's the policy behind that?
22 A. Well, the response that I provided when I've been
23 asked that question is I've pointed them to the two schedules.
24 If you look at the Schedule 1, the average rate currently is
25 9.6 cents. If you look at Schedule 36, that rate is 4.2 cents
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1 per kilowatt hour. So there is a significant difference
2 between the rates between Schedule 1 and 36, that those
3 customers who choose to participate on that optional time of
4 day rate, if they are able to shift their usage to the off-peak
5 hours as the rate is designed, will see a significant benefit
6 of a lower rate that's almost two and a half times lower than
7 Schedule 1. So, while Schedule 1 received a half a cent
8 increase if the Commission approved this Stipulation and that
9 equates to about a seven-percent increase -- or, a five-percent
10 increase, excuse me, and Schedule 36 received a three-tenths of
11 a cent increase, they received an overall smaller increase, but
12 on a percentage basis since their rate is two and a half times
13 less, the percent is larger.
14 So it's math?Q.
15 A.It's math.
16 It's a -- even a smaller number applied to aQ.
17 smaller base is larger?
18 On a percentage basis, but customers are stillA.
19 benefiting from the lower rates on the time of day rate if they
20 comply with the intent of the rate.
21 And in actuality, having explained it that way toQ.
22 me, it makes me wonder if the three-tenths is actually too low,
23 if it's actually being unfair to Schedule 1?
24 That, I can't say. That was --A.
25 Q.You can.
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1 A.That was part of the Stipulation. The rate
2 spread was part of the Stipulation.
3 Q.And fairness is in the eyes of the beholder?
4 A.That's correct.
5 Q.Do you know what percent of your customers
6 residential customers -- choose to participate in
7 Schedule 36?
8 A.It's approximately one third.
9 Q.So, about 34 percent?
10 A.Yeah. We have 57,000 residential customers.
11 42,000 of those participate on Schedule 1, and about 15,000 are
12 on Schedule 36.
13 Q.So how aggressive does the Company market
14 Schedule 36, or is there any marketing?
15 I wouldn't say that the Company markets theA.
16 optional rates. We make our customers aware.
17 Q.So tell me how you do that.
18 If a new customer went to sign up with theA.
19 Company and they called in to receive service, they would be
informed that there was an that Schedule 1 was residential
21 service and there was an optional time of day rate available to
22 them.
23
24.25
Q.So just new customers get this information?
A. I know that the Company provides annual mailings
to customers
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1 Q.Right.
2 A.-- and I believe that's reflected in those
3 mailings as well.
4 Q.Would you think it would be beneficial if the
5 Commission asked the Company to do something special to let
6 long-time residential customers know that they have another
7 option?
8 A.I'm sure the Company would be more than happy to
9 provide a mailing, a bill insert, to inform customers if the
10 Commission felt that that would be useful.
11 COMMISSIONER SMITH: Thank you. That's all I
12 have.
13
14 EXAMINATION
15
16 BY COMMISSIONER KJELLANDER:
17 Q.Just one follow-up: During the public hearings
18 in Eastern Idaho, along the same lines as Commissioner Smith
19 was inquiring of you, there seemed to be a general interest in
20 customers obtaining a higher energy IQ. Is there anything you
21 could offer in terms of what the Utility might be able to
22 attempt in an effort to try and actually provide some broader
23 overall energy information that might assist them in terms not
24.25
just of what Commissioner Smith identified in terms of some of
the tariff rates and schedules and options, but just overall on
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1 some general issues related to energy consumption and its
2 impact on rates?
3 Yeah, I would be happy to respond to that. IA.
4 think there are several things that the Company has done and is
5 continuing to look at doing.
6 One of those things that the Company has done I
7 believe quarterly in our bills to customers, the Company
8 includes what is called Voices, a letter to customers that
9 includes energy efficiency tips and other pertinent information
10 about their bill and how they can control their usage.
11 As I mentioned earlier in my summary, the Company
12 held public workshops to try to educate the customers and
13 provide some information.
14 Typically on an annual basis, the Company has
15 hosted a community action meeting in the service center where
16 hundreds of customers are invited to hear from president
17 Rich Walj e and other executives of issues facing the electric
18 utili ty. In fact, Mr. Walj e has scheduled another meeting
19 January 4th in the service territory in Idaho to present
20 current issues facing the Utility.
21 So I think the Utility, the Company, has
22 proacti vely sought ways to provide more information to our
23 customers to help make them aware of the current issues facing
24 the Company and why they are seeing the current rate increases
25 that they are experiencing.
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1 COMMISSIONER KJELLANDER: Thank you.
2 COMMISSIONER REDFORD: I have questions.
3
4 EXAMINATION
5
6 BY COMMISSIONER REDFORD:
7 Do you, Mr. Weston, speaking specifically ofQ.
8 Schedule 1 and Schedule 36, do you have a program, whether it's
9 automated or hand done, that monitors the differences between
10 the rates for comparable service?
11 Take, for instance, the time of day and
12 Schedule 1. Would you ever have a situation where your program
13 would look at it and say, my goodness, this person shouldn't be
14 on time of service, he should be on residential, or vice versa;
15 and do you ever find yourself in a position of contacting those
16 people and saying, "I know what you've got, but have you
17 considered this?"
18 And if you don't have that program, do you think
19 that would be a good program?
20 I think there was some confusion over in Southern
21 Idaho about the difference between residential and time of
22 service, and I don't attribute that to the Company at all, it's
23 just I think some of the folks over there were a little
24 confused about it.
25 I don't even know if that was a question or
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1 testimony, but try to do your best.
2 A.Okay, thanks, Mister -- Chairman Redford. I am
3 not aware of an automated program that monitors Schedule 1 and
4 36 to determine whether customers would bill cheaper on one
5 schedule or the other. I think they are vastly different
6 schedules, and the time of day rate is designed and provided
7 wi th the intent of shifting usage from on-peak periods to
8 off-peak periods. And I believe the Company, as I mentioned,
9 that is an optional rate, that the Company leaves that choice
10 up to the customers and their usage patterns to determine
11 whether or not they would be better off on one schedule or
12 another.
13 I can appreciate that, but on the other hand,Q.
14 there are a lot of folks that are not so sophisticated as to
15 that; and it just seems to me that once in a while, the Company
16 ought to tip somebody off and say, "You're probably on the
17 wrong schedule."
18 And that was not a question, just a statement, so
19 you don't have to answer that.
20 COMMISSIONER KJELLANDER: Thank you.
21 Any other questions from the Commission?
22 If not, let's look to Mr. Hickey for any
23 redirect.
24 MR. HICKEY: I have no redirect, Mr. Chairman.
25 And Mr. Weston will be available throughout the day should the
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1 need arise for him to be recalled as a witness.
2 COMMISSIONER KJELLANDER: Thank you.
3 So, Mr. Weston, you're excused for now, and
4 thanks again.
5 (The witness left the stand.)
6 COMMISSIONER KJELLANDER: Mr. Hickey, did you
7 want to move forward with your next witness on rebuttal? Was
8 that your intent?
9 MR. HICKEY: Well, I wanted to actually ask for
10 direction on that, Mr. Chairman. We're happy either way. It
11 seemed like there is almost an issue continuity here if
12 Mr. Lobb were to go next on the Stipulation and then we could
13 take up the one contested issue in the case, but clearly it's
14 your discretion. We're glad to call Ms. Eberle now if that's
15 your preference.
16 COMMISSIONER KJELLANDER: Let's see what we may
17 have in terms of an order of witnesses here. We'll just go
18 around and see if anybody has a preference. Thank you for your
19 comments.
20 MR. PRICE: Commission Staff's preference is that
21 Mr. Lobb go last, be our last witness.
22 COMMISSIONER KJELLANDER: Okay.
23 MR. PURDY: I guess I really don't have a
24 preference.
25 COMMISSIONER KJELLANDER: Okay. Well, you're the
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1 Applicant: You make the call.
2 MR. HICKEY: In deference to the position of
3 Staff, we'll go ahead and call Ms. Eberle next and be glad to
4 let Mr. Lobb go last.
5 COMMISSIONER KJELLANDER: Okay, thank you.
6 MR. HICKEY: Mr. Solander will be handling her
7 examination, Mr. Chairman.
8 COMMISSIONER KJELLANDER: Thank you.
9 MR. HICKEY: Becky, would you please come up?
10
11 REBECCA "BECKY" EBERLE,
12 produced as a rebuttal witness at the instance of Rocky
13 Mountain Power, being first duly sworn, was examined and
14 testified as follows:
15
16 DIRECT EXAMINATION
17
18 BY MR. SOLANDER:
19 Q.Good morning, Ms. Eberle.
20 A.Good morning.
21 Could you please state your name and businessQ.
22 address for the record?
23 Rebecca Eberle, 8~5 Northeast Multnomah,A.
24 Suite 800, Portland, Oregon, 97232.
25 Q.And are you currently employed by PacifiCorp or
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1 Rocky Mountain Power?
2 A.Yes.
3 Q.And what is your position within the Company?
4 A.Low-income program manager.
5 Q.And are you the same Rebecca Eberle who filed
6 rebuttal testimony in this proceeding?
7 A.Yes.
8 Q.Do you have any corrections or additions to that
9 testimony?
10 A.No, I don't.
11 Q.So if I were to ask you those same questions
12 today, your answers to each question would be the same?
13 A. Yes.
14 Does your testimony address issues raised in theQ.
15 PAC-E-11-13 docket?
16 A.The docket related to the evaluation?
17 Q.Correct.
18 A.No, it does not.
19 Q.Could you explain why it does not?
A.Well, my testimony is just based on the general
21 rate case, and the separate docket set up for the evaluation is
22 the place to direct those type of issues.
23
24.25
Q.Okay.
MR. SOLANDER: Chairman Kjellander, Ms. Eberle is
available for cross-examination.
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20
21
22
23
24.25
1 Excuse me. First, I'd like to ask that her
2 testimony be spread upon the record as if read.
3 COMMISSIONER KJELLANDER: And without obj ection,
4 we'll spread the prefiled testimony of the witness across the
5 record as if read.
6 MR. SOLANDER: Thank you.
7 (The following rebuttal testimony of
8 Ms. Eberle is spread upon the record.)
9
10
11
12
13
14
15
16
17
18
19
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1 Q.Pleae state your name, busines addre and preent position with
2 PaeifCorp dba Roeky Mounta Power (the "Company").
3 A.My nae is Rebeca Ebele. My business addrss is 825 NE Multnoma Suite
4 800, Portand, OR 97232. My preset position is Low Income Prgr Maner.
5 Qualeations
6 Q.
7 A.
8
9
10
11.12
13
14
Please deseribe your edueational and profesional baekgound.
I reeived a B.S. degr in Business Admston, with a mior in Soology
frm Orgon State Univerity. I joind th Compay in June 1980 and have held
positions in the Cusmer Serce, Reguation and Demd-Side Maement
Deents. I began mag residential energy effciency prgr includ
low income weaertion prgr in 1991. I curently mange a varety of
progrs avalable to PacifiCorp's cusomer with lite incomes includig low
income weaerition, bil assistace discounts and fuel fuds suh as Led-A-
Had.
15 Purpose of Testiony
16 Q.
17 A.
18
19
20
21 Q.
22
23 A..
What is the purpose of your rebutt tetiony?
I am fiing rebut testony to rend to the testony of Ms. Teri Otns
witness for the Communty Acton Parerhip Assoiaon of Idao ("CAP Afj,
spificaly, Ms. Ot' reuest for Low Income Weaertion assistce
("LIW A") and energy consrvation educaton fuding.
Is the LIW A progr funded with revenues obtained through the
Company's general rates that are the foeus of this proeeeg?
No. LIW A is fuded thug the reenue obtaed thug Schedule 191,
22 8 Ebele, Re - 1
Rocky.Mounta Power
229 Ebele, Re - 2
Rocky Mounta Power
.
.
1
2
3
4 Q.
5
6 A.
7
8
9
10
11
12
13
14
15
16
17
18
19
20 Q.
21 A.
22
23
24
25
26.
A vist curently fuds their progr at $6.69 pe residential cusmer and if
Rocky Mounta Power's fudi wa in to$377,SI7 anualy, the per
capita anua investent would also tota $6.69 pe residential cusmer.
Is it reasonable to compare the per capita funding for Avista's and Rocky
Mounta Power's Low Income Weatherition progrms in this maer?
No. Comparson of the fudig prvide by A vist and Rocky Mounta Power is
diffcult, at best beau A vist prvide electrc and natu gas sece wher
Rocky Mounta Power provides electrc serce only. Ms Ot fals to
acknowledge th A vist expetus ar for both its ga and elecc low income
weatherition progrs. As Ms. Stay Donohue of the Idaho Public Utities
Commssion Sta tesfied to:l
"If A vist contiues to spd 60% of its low income progr
budget on electc meaures, then (using Ms. Ottens' metodlogy)
the $420,00 budge divided by Avist's 105,286 elecc
residential cusmer (FERC Form No.1, 2010, pg. 304) equates
to a $3.98/cusmer expditu."
The Compay believes ths is a more apprat comparson to th Rocky
Mounta Power expeditu of $5.32 per customer provided by Ms. Ot.
What percent of Rocky Mounta Power's customers heat using gas?
Apprxiatly fort.six pecent of the Compay's residential cusmer in Idao
hea with natu gas. To my knowledge the na gas providers don't fud any
LIWA prgrams in Rocky Mounta Power's servce tertory. Obtag fu
frm na gas provide in Rocky Mounta Power's sece ar at a ra th
mahes th fudig A vist applies to na gas sece homes may be a mor
appropriate mea of incrg LIWA progr fudig. I don't believe it is
i Cas No. IPC-E-1 i -08 (pe 3. lines 20-24).
2 3 0 Eberle, Re . 3
Rocky Mounta Power
.
1
2
3 Q~
4 A.
5
6 Q.
7
8
9 A.
10
11.12
13
14
15
16
17
18
19
20
21
22
23
24.
appropriat to compa fudi frm an elecc only utity to fudig frm a gas
and elecc utity solely on a per capita bais as Ms. Oten ha propose.
Why isn't basing fundig solely on per capita investment reasonable?
As Ms. Donohue sugested in her testony, it may be more advantageous to
housholds thugout Idao to detee fudig bas on cusomer nee.
Do you agree with Ms. Otns' statement that it is liely that Rock
Mountain Power's customen wi have to wait for an average of eigt yean
and quite possibly migt never reeive benefts under the progm?
No, I don't believe th is liely. Although the Compay speifically reuest the
information usd by CAP AI to support its cacuon, CAP AI was not able to
provide ths inormtion at the tie my testony was.due. CAPAI's repons to
the Compay's data request 17 askig for the numbe of quaifyg cusmers on
the watig list as of Decmbe 31,2010 and Ocber 31, 2011 state:
"The numbe of eligible cusmer on the wating list chages
constly. It is not known wh the exact number of cusomers on
the watig list was on Deembe 31, 2010 without unnale
effort and reculation of data no longer curnt."
The agencies' list of custmer inte in weaterizaon seces is. likely a
movi taget. A numbe of housolds may reive seces withn a yea. May
applicats may not be served by Rocky Mounta Power and may reside in homes
tht ar not heated with electrcity, so fudig may be depdent on other sour.
Some may not quaify for a varety of rens, some may move out of the
agency's jmisdction and thre may be a few where their landlord does not wat
to parcipate. As Ms. Ot' state, th is diffcult to prect with prision.
2 31 Ebele, Re - 4
Rocky Mounta Power
.
1 Q.Ar there ways of improvig upon the aDoeation of Rocky Mounta Power's
2 funding?
3 A.Yes. Cutly fudig is allocate eveny beee Earn Idao Communty
4 Acton Parership ("EICAP") and South Idao Communty Acton
5 Agency ("SEICAA j. Bas on the respons frm CAP AI to Rocky Mounta
6 Power's da request 16, SEICAA ha a longer weatherzation wating list so the
7 Company would lie to work with the agencies to detee the most appropriate
8 mean of allocati the fudig between the two agencies.
9 Q.Does Rocky Mounta Power have a good workig relationship with the
10 weatherig agencies in its servce terrtory?
11 A.Yes. Rocky Mounta Power is grfu for the valuale seices prvided by.12 employee of EICAP and SEICAA to our income eligible cusmer.The
13 Company appreciates the positive relatonsp we mata with their st.
14 CAP AI Fuding Request - Conservation Education
15 Q.
16
17 A.
18
19
20
21
22
23
24.25
26
Pleae summari the backgund of the 550,00 one-tie conservatin
education funding.
As pa of the stpulation appved by the Commssion in Ca No. PAC-E-08-07
date Febru 4, 2009, whch CAPAI wa a par to, Rocky Mounta Power
commtt to a one-tie payment of $50,00 for constion educon.
Parh 8 of tht stipulaton sttes:
"... the Pares ag that a tota of $50,00 of demad-side
maement progr fuds will be ma avaiable to
South Idao Communty Acton Agency and Ea Idao
Communty Acton. Parerp to be us to support consation
education as a component of Rocky Mounta Power's low income
weathertion prgr Schedule 2 i. Pares agr tht it is the .
232 Ebede, Re - 5
Rocky Mounta Power
responsibilty of the Communty Action Parerhip Assoiaton of
Idao to prse sad eduction prgr to Rocky Mounta
Power by May 1, 2009 and th th prposa will conta fudi
proportonig the $50,000 beee the two agencies, objectives
and any savis esate to asist in progr evaluations and
rertg reuiments. The Pares age tht the low incomeweatherition progr (Schedule 21) and the consaton
education component of the progr is in the public intest and is
deteed to be cost-effectve even thugh the explicit
quaficaon of beefits may not be possible, and fuerore, the
Pares agre to support the jusficaon and rever of these cost
thugh the demand-side maement surhae fudig."
What is the statu of the conservation education funded by Rocky Mountain
Power?
The curculum wa develope by CAP AI st and provided to the Company in
fina form in Marh 2011. Ou two parerg agencies, EICAP and SEICAA
began providig the ener consation curculum an distbu energy
effciency kits in May 2011 to income eligible Rocky Mounta Power customer.
As of Augut 23~ 201 I, 36 housholds ha pacipated in the energy consrvaton
prgr; the agencies ag to provide an upe on their progrss in Decembe.
What is the cost of the conservation education per partcipant?
The kits were purhad at a cost of $ 1 5 eah and include th compa
fluoreent light bulbs, a kitchen aetor, outlet gaets, a night light and a
refrgerar/freezer temperatu cad. With a paicipant goal of 500 housholds,
the fudi per parcipant totas $ 1 00 with $15 coverg the effciency kit. and
$85 fudi the agencies cost to distbute the kits and provide the curculum
consist of one group session and one in-home session.
.
233 Eberle, Re - 6
Rocky Mounta Power
.
234 Eberle, Re -7
Rocky Mounta Power
.
1 Q.Does your testiony address the issues Ms. Otens' testiony rases related
2 to Case No. PAC.E-1l-13?
3 A.No. Thes issues were apprpratly adsse in Cas No. PAC-E-l1-13.
4 Conclusion
5 Q.Does the Company support CAP AI's per capita LIW A funding Prposal and
6 position on conservation education?
7 A.No. The Compay does not supprt ths spific prposa beus, as I have
8 demons, CAP AI's pe capita compason to A vi is inproprate. .When
9 you corrtly adjus Avist's fudig to exclude ga cusmer, Rocky Moun
10 Power's pe capita fudi level is acly be higher th Avist's.
11 The Compay ages with Ms. Donohue's suggeston (CASE No. JP.E-.12 11-08, page 4, lines 19.20) tht the issue of equitable fudi would be bet
13 resolved thugh a collaborative effort among staeholde.
14 As mentioned ealier the $50,000 consation eduction fug was
15 mae in Febru 200. As of Aug 2011 only 36 of the 500 kits ha be
16 pla in households. However, the Company ha intiated discusions and held
17 two meegs with reesentatives frm the two loc agencies, Commssion Sta
18 and CAP AI in an effort to . develop a consaton educaton progr tht will
19 have a positive im on al pares most importtly our income eligible
20 customers.
21 Q.Does this conclude your testiony?
22 A.Yes..
235 Ebele, Re - 8
Rocky Mounta Power
.(The following proceedings were had in1
2 open hearing.)
3 COMMISSIONER KJELLANDER: And why don't we begin
4 wi th cross-examination, Mr. Budge.
.
20
21
5
6
7
8
9
10
11
12
13 to Mr. Purdy.
MR. BUDGE: No questions.
COMMISSIONER KJELLANDER: Mr. Olsen.
MR. OLSEN: No questions.
COMMISSIONER KJELLANDER: Mr. Williams.
MR. WILLIAMS: No questions.
COMMISSIONER KJELLANDER: Mr. Price.
MR. PRICE: No questions.
COMMISSIONER KJELLANDER: And let's move on now
MR. PURDY: Thank you.
CROSS-EXAMINATION
Good morning, Ms. Eberle.
Good morning.
If you want to, just to start off, you're very
22 soft-spoken and I'm even harder of hearing than I was last
14
15
16
17
18 BY MR. PURDY:
19 Q.
23 week, so if you could speak up, I'd appreciate it personally.
24.25
A.
Q.
A.
Q.
All right.
I know you are here, as we just had a discussion
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EBERLE (X-Reb)
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1 regarding Mr. Weston's knowledge, about policy issues as they
2 pertain to low-income weatherization and the evaluation of that
3 program. Do you have familiarity with knowledge of low-income
4 weatherization, the evaluation, and general policy regarding
5 that program?
6 A.I am familiar with the low-income weatherization
7 program, yes; less so on the evaluation, as our demand-side
8 management department has staff that actually manages program
9 evaluations.
10 Q.And can you give me a name, say, of a lead person
11 in that division?
12 A.The individual that has the -- I guess
13 Esther Giezendanner, I believe, is the person who has the
14 direct
15 Q.Could you repeat that name?
16 A.Esther Giezendanner. But she reports to
17 Carol Hunter, who is a vice president for the Company.
18 Right. Okay. And do you have any knowledge ofQ.
19 the contractual arrangement entered into between Rocky Mountain
20 and Cadmus to evaluate low-income weatherization?
21 A.I do know that there was a type of RFP process,
22 but that was through our procurement department.
23 What about the terms and conditions of Cadmus'sQ.
24 services to be performed in that regard, do you know anything
25 about that?
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1 A.No, I'm not prepared. I don't have any type of
2 information on that.
3 Q.Did you participate in the comments filed by
4 Rocky Mountain in the Cadmus evaluation, Case PAC-E 11-13?
5 MR. SOLANDER: Chairman Kjellander, I'm going to
6 object at this point to the questions regarding the 11-13
7 docket. I believe Ms. Eberle stated that her testimony doesn't
8 address that docket, and Rocky Mountain Power believes that
9 those comments are more appropriately addressed in that docket.
10 COMMISSIONER KJELLANDER: Mr. Purdy.
11 MR. PURDY: Mr. Chair, regardless of what
12 witnesses think is relevant or not, the fact of the matter is
13 Staff has very much brought that case into this one through the
14 testimony of Ms. Donohue. Communi ty Action agrees that the two
15 have such a nexus factually and in terms of their consequences
16 that it's -- I think it would be unfortunate to try to analyze
17 one without reference to the other for context, and
18 COMMISSIONER KJELLANDER: Mr. Purdy, then
19 wouldn't Ms. Donohue be the appropriate witness to query on
20 that specific case since she brought it into the record, and I
21 don't believe that this witness did, at least in her previous
22 statement seemed to suggest that she didn't.
23 MR. PURDY: Yes, understood, but Ms. Donohue
24 unfortunately cannot answer questions I have as far as the
25 Company's perspective of the evaluation and its effect on
238
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1 low-income weatherization and funding not only in this case,
2 but in the Idaho Power proceeding as well.
3 MR. SOLANDER: Mr. Chairman, if I may. As
4 Mr. Weston mentioned, the Company asked that that be moved
5 forward under modified procedure and no party objected, and I
6 believe that Mr. Purdy is making an end run around that
7 modified proceeding and seeking to cross-examine on that
8 because he doesn't have thedocket -- or, that case, rather
9 opportunity to do so in that docket because no party, including
10 CAPAI, petitioned the Commission that it be handled under any
11 other way besides modified procedure.
12 MR. PURDY: Modified procedure, Mr. Chair, is not
13 a shield to be hidden under, and I'm not end-running anything.
14 I'm trying to get right to what is relevant.
15 COMMISSIONER KJELLANDER: Why don't I grant just
16 a little bit of latitude to Mr. Purdy.
17 And, Mr. Purdy, if you could please respect the
18 li ttle bit of latitude in light of the fact that it's not a
19 case that's in front of us today, and we'll move forward.
20 MR. PURDY: Thank you, Mr. Chair.
21 BY MR. PURDY: So, with all that, do you -- wouldQ.
22 you like me to restate the question?
23 A.Yes, please.
24 Do you have any familiarity regarding orQ.
25 knowledge regarding the terms and conditions of the Agreement
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1 between Rocky Mountain and Cadmus to evaluate low-income
2 weatherization?
3 A.No.
4 Q.And, again, who would that -- who would be the
5 person who would have that knowledge?
6 A.That would be staff in our demand-side management
7 department, as I had mentioned before, Esther Giezendanner, and
8 Carol Hunter would be her direct supervisor.
9 Q.All right. Okay, turning to page 3 of your
10 testimony, please correct me if I mischaracterize your
11 testimony. Actually -- yes, page 3. You take exception with
12 Ms. Ottens' per capita comparison of Rocky Mountain's funding
13 level to Avista. Is that fair?
14 A.Yes, that's fair.
15 Q.All right. And this is what we've come to call
16 the issue of parity, is it not?
17 A.That's what Ms. Ottens referred it, as it, yes.
18 Q.Okay. I want to ask a couple questions as to the
19 basis for your obj ection to what Ms. Ottens did.
20 With respect to Avista, you know that it has both
21 gas and electric customers. Is it fair -- is it just common
22 sense that virtually all of the gas customers are also electric
23 customers?
24.25
A. Well, actually, I have talked to Avista staff,
and about 13,000 are gas customers only.
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1 Q.Out of what?
2 Out of about I think it was 118, something likeA.
3 that.
4 Takes electricity, generally, to fire a gasQ.
5 furnace, does it not?
6 Yes, that's true, but the individuals have gasA.
7 service only through Avista; their electric service is through
8 another entity.
9 Electric service through another entity?Q.
10 A.Right.
11 Q.A cooperative or something, perhaps?
12 A.Yeah.
13 Okay. Do you agree or disagree that there areQ.
14 system-wide benefits from low-income weatherization programs in
15 general that other customers who don't receive the benefits of
16 the program nonetheless experience or receive themselves?
17 I do agree that in a program, if it's designed toA.
18 be cost effective, then it does have benefits to all customers.
19 Could you give me an idea of an example of someQ.
20 of those benefits?
21 Well, by reducing usage, then that means that weA.
22 don't have to purchase power from other sources or build plants
23 to take on additional load in the future.
24 What about benefits in the nature of reducedQ.
25 arrearages or debt collection costs?
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1 A.Yes, that's true.
2 Q.So nonlow-income customers receive those
3 benefits, though they don't receive any benefit through
4 low-income weatherization.
5 A.Right.
6 Q.Correct?
7 A.Yes.
8 And, similarly, would it be fair to say that anQ.
9 electric heater for Avista, because it's the same company that
10 serves both electric and gas, an electric heater for Avista
11 receives benefits from moneys spent to weatherize a gas
12 heater's home if that gas heater is also an electric customer?
13 You know -- you know, I understand your questionA.
14 and the fact that there are benefits to Avista customers, but
15 my issue really is that we're not able to include investments
16 from the Utility that provides natural gas service to our
17 customers. If we were able to include those costs and put them
18 together, then I think that you could compare the two.
19 Who is the primary gas provider, if you know?Q.
20 I believe it's Intermountain. Intermountain Gas,A.
21 I believe.
22 But you also collect costs for low-incomeQ.
23 weatherization from all customers, including gas heaters .
24 Isn't that right?
25 A. Yes, that's true.
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1 Q.So -- but, of course, you don't provide any
2 low-income weatherization to those individuals or customers, do
3 you?
4 A.No, we do. We don't provide weatherization which
5 would be show measures, insulation; but for our income-eligible
6 customers that are served by the agencies, if the agencies put
7 in efficiency measures that save on electricity, such as water
8 heating measures or a replacement refrigerator, then Rocky
9 Mountain Power covers those costs.
10 Q.Through the low-income weatherization program?
11 A.Yes, through Schedule 21.
12 Q. All right. Excuse me. If you'd look at page 3,
13 specifically line 21, you state there that approximately
14 46 percent of the Company's residential customers in Idaho heat
15 wi th natural gas. How did you derive that percentage?
16 A.We had a survey completed in 2006, and the
17 results showed that about 46 of our -- 46 percent of our
18 customers -- residential -- had gas heat, and about 31 percent
19 electric heat.
20 Q.Do you know how many people that survey went out
21 to?
22 A.No, I don't.
23 Q.Do you know what type of -- was it a type of
24 customer selected for the survey, a target customer?
25 A. I believe it was randomly-selected customers.
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1 Q.All right. And regarding your statement --
2 again, if you need a reference, it's page 3, line 23 -- you
3 state: Obtaining funding for natural gas providers would be a
4 more appropriate means of increasing low-income weatherization
5 funding.
6 You're not suggesting, are you, that this
7 Commission can order Intermountain Gas to implement and fund a
8 low-income weatherization program, are you?
9 A.No, I'm not, but it is an issue that I think is
10 relevant.
11 Q.That what?
12 A.That is relevant, that I believe that would, you
13 know, help income-eligible people in our service terri tory.
14 Q.Don't disagree with that. Thank you.
15 On page 4 of your testimony, with respect to your
16 criticism that it isn't appropriate to compare Avista -- Rocky
i 7 Mountain Power's funding level to Avista' s, do you offer any
18 alternative here as to -- strike that.
19 Let's assume that the Commission does, among
20 other things, take into consideration the relative funding
21 levels of the three Utilities. Is there some alternative to a
22 per-capi ta calculation that you are suggesting here, or are you
23 just saying that it's not appropriate to do at all?
24 A.Well, I believe that Ms. Donohue, in her
25 testimony, provided a calculation that if you just compare the
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1 electrici ty measures in the low-income weatherization program,
2 the funding for electricity, that you could compare that. And
3 that, I believe, showed that Rocky Mountain Power's per capita
4 was $5.32, and I think Avista' s was something like $3.98.
5 Q.But you're assuming that there's no
6 cross-benefits from gas weatherization to electric heaters,
7 aren't you?
8 A.Well, there's likely cross-benefits both ways.
9 Q.I'm sorry, what?
10 A.There's probably benefits both ways.
11 Q.Thank you. On page 4, specifically lines 4
12 through 5, you propose a low-income weatherization funding
13 level that is based on need. Would you please explain what you
14 mean by that and how that would be calculated?
15 A.Well, I don't know how we would calculate that,
16 but I think that would be a good issue to bring up in the
17 potential collaborative group that Ms. Donohue has mentioned in
18 her testimony, and look at factors such as I guess the waiting
19 lists and unemployment rates in service areas and number of
20 homes that have already been completed in service areas and
21 housing stock. There's a lot of issues that would need to be
22 included.
23 Q.Aren't those issues that this Commission has.24 articulated and set out in Orders over a number of years now as
25 being relevant considerations for LIWA funding?
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1 A.You know, I'm sorry, I'm not aware of that.
2 Q.Now, the Company did very much oppose the
3 proposal to increase its low-income weatherization funding in
4 its 2010 general rate case, didn't it?
5 A.Yes, I believe so.
6 Q.All right. What is it about workshops that's
7 going to change the Company's position with respect to
8 low-income weatherization funding?
9 A.Well, it just seems in the last few years during
10 rate cases in several of the Utili ties' rate cases that these
11 issues have come up. And, you know, maybe it would be
12 responsible to have the program be more consistent throughout
13 the state, and to get the Utili ties together and see what type
14 of program works the best and is the most beneficial to all of
15 our customers. I think we can learn from each other, and
16 especially learn from the agency staff who are out there who
17 are actually in contact with our customers and serving our
18 customers.
19 Q.Do you know if the Company participated in the
20 2008 generic low-income workshop? Are you familiar with that
21 proceeding?
22
23
A.I'm not sure.
Q.Case GNR-U-08-01, wherein were addressed a number.24 of low-income issues?
25 A.Oh. Yes, we did participate.
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1 Q.That was a workshop base as well, wasn't it?
2 A.Yes. I was unable to attend that, but other
3 staff from our department did.
4 Q.Fair enough. But wouldn't that be the type of --
5 isn't that the type of forum in which the Company could learn
6 from other Utili ties, as you put it? That's already been
7 conducted.
8 A.Well, as I mentioned, I didn't attend those exact
9 proceedings, but I really think there are issues out there that
10 would be beneficial if we did discuss them with a variety of
11 people.
12 Q.And what are those issues, because I don't know
13 that I have heard them?
14 A.Well, I think one of the issues that is in the
15 evaluation case, not in the general case, really is that the
16 Utilities -- Avista, Idaho Power, and Rocky Mountain Power --
17 are evaluating the programs in a different manner.
18 Q.Does the Company evaluate its program and
19 implement its program in the manner that it thinks is most
20 effective for its customers?
21 A.Well, yes, it has, but we're open to finding if
22 there's ways that we can improve upon our program.
Q.All right. And do you think that's likely to
lead in any change to the Company's resistance to increasing
low-income weatherization funding?
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1 A.Well, you know, I'm not saying today that we are
2 resisting increasing weatherization funding, but I just don't
3 believe that the formula used to determine the $377,000 figure
4 is accurate or appropriate.
5 Q.I understand that. But the Company did, as you
6 noted, resist or obj ect to an increase in low-income
7 weatherization funding in 2010, and it objects in this case?
8 A.Well, my understanding is the reason that we
9 obj ected in 2010 was because we were awaiting the results of an
10 evaluation.
11 Q.Do you know what Rocky Mountain's involvement was
12 in the evaluation?
13 A.Could you be a little more specific?
14 Q.Yes. You just mentioned the evaluation as an
15 intervening factor and something that was contingent during the
16 last rate case. I'm asking you what did the Company do as part
17 of the Cadmus evaluation? What was the Company's part of that
18 role, that equation?
19 A.Well, the evaluation was completed by an outside
20 firm called Cadmus. There were a couple of individuals
21 interviewed by Cadmus. I was interviewed by Cadmus; they had
22 specific questions on the program for me.
23 Q.Was data provided to Cadmus so that it could
evaluate the program?
A. Oh. Yes, that's the case, yes.
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i Q.Sampling data, for instance?
2 A.You know, all of the measure data on homes
3 completed from the period 2007 through 2009.
4 So Rocky Mountain would have been responsible forQ.
5 and in control of that data provided to Cadmus. Isn i t that
6 right?
7 A.Yes.
8 If, as you testify to, need is the appropriateQ.
9 benchmark on which to set low-income weatherization funding,
10 why hasn't the Company proposed that prior to this case?
11 Well, I think that is one positive thing thatA.
12 could come out of a collaborative group. If we had individuals
13 from the agencies there, I believe that we would get more
14 information on the need. I mean, there is information out that
15 we hear about on the length of the list of people waiting for
16 weatherization, but we don't know any specifics about that:
17 How long have people been on the list? What is their heating
18 source? What Utility serves them?
19 So I think there is the ability to get more
20 information that would be helpful.
21 Okay. But you do challenge Ms. Ottens'Q.
22 calculation of the waiting list in your testimony on page 4,
23 don't you?
24 A.Yes, I do.
25 Q.And you note that Ms. Ottens states customers
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1 wai t up to eight years, and you think that's not accurate. You
2 just testified you don't know. So if you don't know, how can
3 you state that's not accurate?
4 A.Well, you know, over the years I have had
5 conversations with agency -- people in the agencies, and I have
6 not heard them say that there was an eight-year wait. You
7 know, I think there's just so many issues related to this list.
8 I'm not sure but I'm going to guess that a Rocky
9 Mountain Power customer likely might get served quicker than a
10 customer from a Utility that doesn't provide any funds to the
11 agency.
12 Q. I'm sorry, could you repeat the last part of
13 that:Rocky Mountain might what?
14 A.I am assuming that in some cases, a Rocky
15 Mountain Power customer on a waiting list might get served
16 sooner than a customer of another Utility that does not provide
17 funding to the agencies.
18 Q.Are you saying that Idaho Power and Avista don't
19 provide low-income weatherization funding to the CAPAI agencies
20 in their territories?
21 A.No, but there are other Utili ties serving people
22 in the state of Idaho besides those three.
23 Q.Right.
24 A.Yeah.
25 Q.How do you know that a customer on the Rocky
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1 Mountain waiting list might receive weatherization services
2 sooner than for Idaho Power and Avista?
3 A.No, I'm not saying Idaho Power and Avista.
4 Q.Okay.
5 A.In fact, there's very few instances where I
6 believe the agencies are serving all three Utilities, because
7 of their location. The agencies serve a location.
8 Q.Yes, I understand. All right. You state in your
9 testimony that you agree that the waiting list is a moving
10 target -- and if you need a reference, I'm talking page 4, line
11 19 -- but you also testify that it's quite possible that
12 someone on the waiting list might receive weatherization within
13 a year. What do you base that on?
14 A.Just conversations I've had over the past few
15 years with agency staff.
16 Q.So your obj ection to the eight-year waiting list
17 calculation by Ms. Ottens is based on discussions or the
18 failure of CAPs to tell you that there's a waiting list and
19 A.You know, I think my obj ection is the fact that
20 really I don't think that there is facts to back up that
21 eight-year waiting list.
22 Q.What facts are there to challenge it or refute
23 it?
24.25
A. I guess it's just -- it's not facts that I have,
but it is just discussions I've had in the past.
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1 Q.And those are the facts that you're basing your
2 challenge of Ms. Ottens' calculation on, aren't they, these
3 discussions?
4 A.You know, I would say that some of the issues I
5 include as the moving target, I would say those are facts.
6 There are people on the list who move before they get served
7 because the low-income population, they move quite a bit. And
8 so I believe that some of my issues are facts.
9 Q.Would you agree that the Commission has based
10 past low-income weatherization funding rulings on the wait
11 list, and that it's important in that respect?
12 A. I'm sorry, I'm not aware of that being the reason
13 that they have increased funding.
14 Q.You don't know that that was mentioned by the
15 Commission in the Company's 2010 general rate?
16 A.It may have been, but I don't recall that.
17 MR. PURDY: Excuse me, Mr. Chair.
18 Mr. Chair, I would like to ask that the witness
19 read a very small portion of the Commission's Final Order in
20 the Company's 2010 rate case.
21
22
23
24.25
COMMISSIONER KJELLANDER: Without objection.
MR. SOLANDER: I'd like to hear what it is first.
COMMISSIONER KJELLANDER: Mr. Purdy, if you could
return to the microphone, I think there is a question.
Mr. Solander had asked a question.
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1 If you could turn on your microphone and ask the
2 question directly.
3 MR. SOLANDER: I'm sorry. I don't know which
4 section of the Order Mr. Purdy is referring to.
5 MR. PURDY: I can show him, if I may.
6 COMMISSIONER KJELLANDER: Sure.
7 MR. SOLANDER: I think the Order speaks for
8 itself. I don't know what benefit is gained from having
9 Ms. Ottens read it -- I mean, Ms. Eberle read it into the
10 record.
11 COMMISSIONER KJELLANDER: Mr. Purdy, is this the
12 same Order that the witness previously said that they didn't
13 have any direct knowledge of in terms of the specifics of the
14 Order?
15 MR. PURDY: I heard her state that and then state
16 something that might have given a different version of that, so
17 I heard her say both.
18 COMMISSIONER KJELLANDER: I don't recall hearing
19 that.
20 Mr. Solander.
21 MR. SOLANDER: I only have a portion of the Order
22 in front of me, beginning on page 60, but the section that
23 Mr. Purdy indicated doesn't appear to be a Commission Finding;
24.25
it appears to be a background section or some other summary. I
don't know what precedes page 60, but the Findings begin on the
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21
1 bottom of page 61.
2 COMMISSIONER KJELLANDER: Mr. Purdy.
3 MR. PURDY: That's the part I was going to ask
4 her to read into the record. I could read it if the Commission
5 wants to take official notice under Rule 263.
6 COMMISSIONER KJELLANDER: Let's take official
7 notice under Rule 263. The witness has already said that they
8 are not directly knowledgeable of the details of that, so why
9 don't we take it under that approach.
10 MR. PURDY: Grea t .
11 COMMISSIONER SMITH: Can we have the Order
12 number?
13 COMMISSIONER KJELLANDER: What is the Order
14 number?
15 MR. PURDY: Oh, sorry. That is Order No. 32196,
16 issued February 28, 2011, in Case PAC-E-10-07. That is on
17 page 61, as Mr. Solander indicated.
18 The Commission Findings state that the record
19 reflects a five-year backlog of homes.
COMMISSIONER KJELLANDER: Okay.
Q.BY MR. PURDY: Ms. Eberle, I don't want to end
22 this on an entirely negative note. You state in your testimony
23 that you feel you have a good working relationship with the CAP
24.25
agencies in terms of low-income weatherization.Is that right?
A. Yes.
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1 Q.All right. And have you ever had any reason to
2 doubt that the CAP agencies were effectively implementing the
3 program?
4 A.No.
5 Q.All right. Finally, regarding conservation
6 education, if I understand your proposal, it is that basically
7 the Company and the CAP agencies sit down and talk and discuss
8 what is a realistic target for funding and for a number of
9 customers that could be served through that program. Is that
10 your proposal?
11 A.Well, through the -- through a collaborative type
12 discussion, yes.
13 Q. All right.Isn't that something that could be
14 done with the CAP agencies, the Company, and Staff, and anyone
15 else who wanted to, outside the context of any workshop case
16 that might be structured?
17 A.It could.
18 Q.Okay.
19 MR. PURDY: That's all I have. Thank you.
20 COMMISSIONER KJELLANDER: Thank you, Mr. Purdy.
21 Are there any questions from members of the
22 Commission?
23 COMMISSIONER REDFORD: No.
24 COMMISSIONER KJELLANDER: None.
25 How about redirect, Mr. Solander.
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1 REDIRECT EXAMINATION
2
3 BY MR. SOLANDER:
4 Q.Just one question, please, Ms. Eberle:
5 Did the Company ask Ms. Ottens for the data
6 did the Company ask Ms. Ottens for the dataunderlying the
7 underlying Ms. Ottens' calculation of the eight-year waiting
8 list and the number of customers on the wait list?
9 Yes, that was included in the Data Request.A.
10 What was CAPAI' s Response to that Data Request?Q.
11 They did not provide any follow-up information.A.
12 So it's fair to say that she did not have anyQ.
13 support --
14 (Telephone ringing.)
15 BY MR. SOLANDER: Is it fair to state that youQ.
16 didn't receive any supporting calculations for that eight-year
17 wai ting list?
18 A.Yes.
19 MR. PURDY: And I object to that question in that
20 it mischaracterizes Ms. Ottens' testimony -- or, I'm sorry,
21 mischaracterizes the Discovery Response, which is simply that
22 Communi ty Action was not able under the time constraints to
23 provide the waiting list on two specific dates: August 31st
24 and December 31st of 2010, I believe, or 2011. Ms. Ottens
25 based her waiting list on June of 2010 --
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1 MS. OTTENS: Eleven.
2 MR. PURDY: -- 2011 data. There's no --
3 COMMISSIONER KJELLANDER: Mr. Purdy, I have to
4 confess that the telephones ringing here probably disrupted me,
5 and to be quite blunt and honest, I don't recall what the
6 question was that even led to the obj ection. And with that, I
7 think we need to backtrack just a moment or two to catch up.
8 And so, Mr. Solander, what was the question
9 again?
10 MR. SOLANDER: The question was actually,
11 could I have the court reporter read it back? I don't recall
12 my follow-up question.
13 COMMISSIONER KJELLANDER: So the phone caught you
14 just as well.
15 MR. SOLANDER: My original question was did the
16 Company ask Ms. Ottens for the data underlying her calculation
17 for the eight-year waiting list.
18 COMMISSIONER KJELLANDER: Okay. So that was the
19 question.
20 And, Mr. Purdy, you had obj ected again based on
21 what grounds?
22 MR. PURDY: On the basis that Community Action
23 did not fail to provide data supporting Ms. Ottens'
24 calculation. The Data Request
25 I'm sorry, I was distracted. I thought he just
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1 referred to Community Action's Response to Discovery Requests.
2 MR. SOLANDER: I'm sorry, could we just have the
3 court reporter read back the exchange, because there was a
4 follow-up question, and I believe I stated something along the
5 lines of is it fair to say that we did not receive the
6 supporting calculations.
7 COMMISSIONER KJELLANDER: Why don't we go back to
8 the official record and see what we've got there, if we could
9 have, Wendy, if you could recapture that for us.
10 (Whereupon, the requested portion of the
11 record was read by the court reporter.)
12 COMMISSIONER KJELLANDER: I think that brings us
13 to where we're at.
14 MR. PURDY: So my obj ection is, first -- I did
15 misspeak and I thought I did clarify that.
16 My obj ection is that clearly this does pertain to
17 Data Requests, and my obj ection is that Mr. So lander is
18 completely mischaracterizing Community Action's Response to
19 Data Requests two weeks ago in the Idaho Power case. That's
20 why I submitted via Affidavit the entire Discovery set that I
21 was going to ask questions on. This is not even in the record.
22 This is a reference to a document that has not been filed with
23 the Commission, it's not a Pleading, can't be taken official
24 notice of, and Mr. Solander is mischaracterizing Community
25 Action's Response to Discovery.
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1 MR. SOLANDER: I'm not mischaracterizing
2 anything.
3 COMMISSIONER KJELLANDER: Just a moment. He
4 wasn't completely finished yet and we don't want you stepping
5 on him. You'll get your chance.
6 MR. PURDY: It's entirely inappropriate to
7 mischaracterize information that's not even on the record
8 before the Commission.
9 COMMISSIONER KJELLANDER: Okay. Mr. Solander.
10 MR. SOLANDER: And my question didn't contain any
11 characterization. It just asked whether -- asked is it fair to
12 state that we received no data underlying -- or, no data
13 supporting that eight-year calculation. There's no
14 characterization in that question. Ms. Eberle can characterize
15 it however she wants in her answer, but I'm certainly not doing
16 that in the question.
17 COMMISSIONER KJELLANDER: Okay. I'm going to let
18 the question stand and see if we can't get the answer.
19 THE WITNESS: Okay, I'm a little bit confused,
20 but I'm going to read what the Response was to the Data
21 Response:
22 The number of eligible customers on the waiting
23 list changes constantly. It is not known what the exact number
24 of customers on the waiting list was on December 31, 2010,
25 wi thout unreasonable effort and recalculation of data no longer
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1 current.
2 MR PURDY: Mr. Chairman, may I ask a question in
3 aid of objection?
4 COMMISSIONER KJELLANDER: Certainly.
5 MR. PURDY: Ms. Eberle, you have the Discovery in
6 front of you, I assume, the entire set?
7 THE WITNESS: Yes.
8 MR. PURDY: Would you look at the preceding --
9 you're reading from Community Action's Response to Request
10 No. 17, are you not?
11 THE WITNESS: Uh-huh, yes.
12 MR. PURDY: Would you please read the Question
13 and Response to number 16?
14 THE WITNESS: Should I --
15 MR.PURDY:Please read the entire
THE WITNESS:Should I include the Question too?
MR.PURDY:Yes,read the Question and the
Response,please.
THE WITNESS:Please provide details and any
16
17
18
19
20 supporting data or calculations on how it was determined that
21 Rocky Mountain Power customers will have to wait for an average
22 of eight years to obtain low-income weatherization services.
23
24.25
Response: CAPAI obj ects to this Request on the
basis of vagueness. Wi thout waiving, CAPAI assumes that Rocky
Mountain Power is referring to the testimony of Ms. Teri Ottens
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1 previously filed in this case on behalf of CAPAI. The
2 testimony speaks for itself. Wi thout waiving, CAPAI responds
3 as follows:
4 CAPAI simply took the current homes on the
5 weatherization waiting list for SEICAA and EICAP and divided
6 that number by the average number of homes the agencies
7 weatherized in 2008. CAPAI used 2008 as our sample year
8 because this year represented the average prior to the American
9 Reinvestment and Recovery Act, which increased funding
10 significantly from 2009 through 2011. These funds are no
11 longer available and should not be used for the purpose of
12 calculating an average waiting time for low-income
13 weatherization services.
14 In addition, it should be noted that recent
15 notification from the Department of Energy concerning funding
16 levels for 2012 will be below that received in 2008, which will
17 have the effect of lowering the number of homes that can be
18 completed wi thin a year.
19 MR. PURDY: Thank you, Ms. Eberle. I'm going to
20 speed this up.
21 Mr. Chair, I think that clearly Ms. Ottens'
22 posi tion on the waiting list was it goes on to elaborate.
23 It was provided to the Company in a preceding Data Request; it
24 was responded to fully. And that's the basis for my obj ection
25 to his characterization of Community Action's Response.
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1 COMMISSIONER KJELLANDER: Mr. Solander, is there
2 need to pursue this further?
3 MR. SOLANDER: No, there's not.
4 COMMISSIONER KJELLANDER: Then the objection is
5 sustained, and are there any other questions, Mr. Solander?
6 MR. SOLANDER: No, sir. Thank you.
7 COMMISSIONER KJELLANDER: Thank you very much.
8 (The witness left the stand.)
9 COMMISSIONER KJELLANDER: At this point, it would
10 be my desire to take a ten-minute break, and we will resume at
11 fi ve minutes after the hour.12 (Recess.)
13 COMMISSIONER KJELLANDER: Welcome back. We'll go
14 back on the record.
15 We're ready now to take the testimony then from
16 the Community Action Partnership Association of Idaho.
17 Mr. Purdy, would you like to call your witness?
18 COMMISSIONER KJELLANDER: Thank you, Mr. Chair.
19 Community Action calls Teri Ottens.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
EBERLE ( Di - Reb)
RMP
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1 TERI OTTENS,
2 produced as a witness at the instance of the Community Action
3 Partnership Association of Idaho, being first duly sworn, was
4 examined and testified as follows:
5
6 DIRECT EXAMINATION
7
8 BY MR. PURDY:
9 Q.Would you please state your name and your
10 business address?
11 A.Teri Ottens, O-T-T-E-N-S. Business address is
12 5420 West Franklin, Suite B, Boise, Idaho.
13 Q.And are you the same Teri Ottens who has pre filed
14 direct testimony in this case?
15 A.I am.
16 Q.And are there any exhibits to your testimony?
17 A.No.
18 Q.Do you have any corrections to your testimony,
19 Ms. Ottens?
A.I do. Page 4 of my testimony, line 1, I state
21 that the property rate is 14.4 percent in 2010. That's
22 actually 15.8.
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24
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Q.Anything else?
A. Yes. On page 18, line -- let's see -- line 11
and 12, I refer to myself as the royal "we," "Ms. Ottens," and
263
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
OTTENS (Di)
CAPAI
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1 I should have said "my" testimony. That's just a situation of
2 a cutting and pasting from another document and proofing it.
3 Q.So you would replace the words "Ms. Ottens" with
4 "my"?
5 A.Yes.
6 Q.And then later in that line 12, the pronoun "her"
7 appears?
8 A.I would replace that with "the."
9 Q ."The. " Okay, thank you. Anything else?
10 A.No.
11 Q.Aside from those corrections, if I were to ask
12 you the same questions today as contained in your prefiled
13 direct testimony, would your answers be the same?
14 A.They would.
15 Q.Thank you.
16 MR. PURDY: Mr. Chair, with that, I would tender
17 Ms. Ottens for cross-examination.
18 COMMISSIONER KJELLANDER: And, Mr. Purdy, would
19 you like to see the testimony spread across the record as if
20 read?
21
22
MR. PURDY: Oh, yes, I would. Thank you.
COMMISSIONER KJELLANDER: And without obj ection,
23 we'll spread the prefiled testimony of Ms. Ottens across the.24 record as if read.
25 (The following pre filed direct testimony
264
HEDRICK COURT REPORTING
P. o. BOX 578, BOISE, ID 83701
OTTENS (Di)
CAPAI
.1 of Ms. Ottens is spread upon the record.)
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HEDRICK COURT REPORTING OTTENS (Di)
P. O.BOX 578,BOISE,ID 83701 CAPAI
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1 I. INTRODUCTION
2 Q:Please state your name and business address.
3 A:My name is Teri Ottens. I am the Policy Director ofthe Community Action Parnership
4 Association ofIdaho headquarered at 5400 W. Franlin, Suite G, Boise, Idaho, 83705.
5 Q:On whose behalf are you testifying in this proceeding?
6 A:The Community Action Partnership Association of Idaho ("CAP AI") Board of Directors
7 asked me to present the views of an expert on, and advocate for, low income customer 0
8 Rocky Mountain Power ("Rocky Mountain," "Company").
9 Q:Please describe CAP AI's organization and the functions it pedorms, relevant to its
10 involvement in this case..11 A:CAP AI is an association ofIdaho's six Community Action Parnerships, the Community
12 Council of Idaho and the Canyon County Organzation on Aging, Weatherization and
13 Human Services, all dedicated to promoting self-sufficiency through removing the causes
14 and conditions of poverty in Idaho's communities.
15 Q:What are the Community Action Parnerships?
16 A:Community Action Partnerships ("CAPs") are private, nonprofit organizations that fight
17 povert. Each CAP has a designated service area. Combining all CAPS, every county in
18 Idaho is served. CAPS design their various programs to meet the unique needs of
19 communities located within their respective service areas. Not every CAP provides all 0
20 the following services, but all work with people to promote and support increased self-
21 suffciency. Programs provided by CAPS include: employment preparation and dispatch,
22 education assistance child care, emergency food, senior independence and support,.23 clothing, home weatherization, energy assistance, affordable housing, health care access,
24 and much more.
25 Q:Have you testified before this Commission in otf&Pproceedings?
DIRECT TESTIMONY OF TERI OTTENS 2
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Yes, I have testified on behalf of CAP Al in numerous cases involving, among others,
Rocky Mountain, Idaho Power, and A VISTA, and United Water of Idaho.
II. SUMMARY
Please summarze your testimony in this case?
First, CAP AI, for the reasons mentioned herein, does not support and has declined to join
in the proposed settlement executed by other parties to this proceeding and currently
pending before the Commission by way of motion and stipulation. The settlement raises
numerous concerns for CAP AI including the magnitude and frequency of recent general
rate case filings, the combination of general rate increases with increasing cost
adjustment (revenue stability) mechanisms, the dangers inherent in the frequent use of
"black box settlements," and whether the interests of residential customers, paricularly
those who are or wil soon become low-income, have been adequately addressed through
a procedure that lacks transparency. Second, I wil present CAP AI's position on funding
for Rocky Mountain's low-income weatherization assistance program ("LIW A").
Finally, I wil respond to the Company's position on Low-Income Conservation
Education.
Are there any exhibits to your testimony in this case?
No.
III. CURRNT STATE OF POVERTY
Are the concerns and the positions you hold in this proceeding limited strctly to the
interests of Rocky Mountain's low-income customers?
In the past, the answer to that question would be an obvious and simple yes. But, as
everyone is well aware, we are currently experiencing one of the most severe economic
crises in our nation's history. One ofthe many consequences of this is that the ranks of
citizens who qualify as "low-income" are swell6g.7Poverty rates in Idaho have risen
DIRECT TESTIMONY OF TERI OTTENS 3
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from 12.6% in 2000 to 14.4% in the 2010 census figures representing an additional
62,000 Idaho citizens surviving under the Federal Poverty LeveL. Simultaneously, federa
funding of programs designed to assist low-income customers are being reduced or
entirely eliminated including the termination of ARRA 1 which provided a substantial, but
temporar, boost in federal low-income weatherization funds. The backlog of
households in Idaho eligible for low-income weatherization is far too great for AARA to
have even come close to eliminating.
iv. PROPOSED SETTLEMENT
A. Overview
Would you please identify the reasons that CAP AI declined to join the settlement
proposed in this case?
As with another recent general rate case settlement,2 the proposed settlement stipulation
in this case seems to address the issues and objectives of all paries except CAP AI and
low-income customers. CAP AI is concerned about Rocky Mountain's rapidly rising
rates, the frequency at which general rate cases are being filed, the increasing use of
"black box" settlements, combined with the effects of revenue stability mechanisms, the
pressure and significance of having multiple filings simultaneously pending before the
Commission, including general rate cases for the three largest electrc utilities and for
Idaho's largest investor owned public water utility3 and a separate filing by Rocky
Mountain contending that its LIWA program is not cost-effective.4
In addition to rapidly rising utility rates, the economy seems to be slipping into
recession, unemployment is skyrocketing, and federal assistance programs for low-
i The "American Recovery and Reinvestment Act."
2 Case No. IPC-E-11-08.
3 United Water of Idaho; Case No. UWI-W-11-02368
4 Case No. PAC-E-11-13.
DIRECT TESTIMONY OF TERI OTTENS 4
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income customers are being reduced or eliminated putting vulnerable low-income
customers directly in the path of a perfect storm. In spite of this, the settlement
agreement fails to include an increase in Rocky Mountain's low-income weatherzation
program (referred to herein as "LIW A"). CAP AI simply could not justify joining in yet
another black box settlement agreement resulting in yet another rate increase without any
offsetting provision for low-income customers.
Does this mean that CAP AI opposes every identifiable element of the proposed
settlement?
Not necessarily. CAPAI's decision to not sign the settlement in whole or in part was
certainly not a decision made lightly. There are certain aspects of the settlement that are
of obvious, positive value from CAP AI's perspective, such as the fact that the requested
non-net power supply costs agreed upon are less than requested and that the residential
schedule 1 customer charge wil remain at its current level of$5.00. In a vacuum, such
compromises are obviously of benefit to low-income customers who pay those rates and
charges but CAP AI, like every other pary, assessed the proposed settlement taking into
consideration the totality of everyhing it contains, as well as what it lacks. Furthermore,
CAP AI does not begin an analysis of any requested rate increase with the presumption
that some degree of rate increase wil ultimately be granted. Thus, perhaps a more
justifiable rate increase in this case would be considerably less than stipulated to, perhaps
none at alL. Regardless, for reasons that I wil explain in greater detail, CAP AI came to
the conclusion that agreeing to the overall settlement as proposed would not be in the bes
interests oflow-income customers or residential customers on the whole.
B. CAPAlS Evolving Role
Are there particular circumstances that you believe make a general rate case such as this
proceeding of significant concern to CAP AI? 269
DIRECT TESTIMONY OF TERI OTTENS 5
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In my opinion, the present case, along with the simultaneously pending general rate cases
of Idaho Power and A VISTA, highlight serious events occurrng on not just a state or
national scale, but globally. The Commission is obviously aware, as are all Amercans,
of the mounting economic problems faced by all sectors of society. The current
pendency of general rate cases for all three ofIdaho's largest electric utilities and Idaho's
largest regulated water utility,S as well as Rocky Mountain's LIWA evaluation case
claiming that the Company's LIWA program is not cost-effective,6 combined with the
problems I have referred to, could well be unprecedented. Many residential customers
who are slightly above the low-income threshold as defined for the purpose of receiving
federal and state benefits in Idaho such as LIHEAP, are rapidly slipping below that
threshold, qualifyng them as low-income. Furthermore, many existing low-income
customers have yet to avail themselves of governental and utility assistance programs
such as LIW A but eventually wil, especially if the economic crisis continues or spirals
further downward and the cost of electricity increases. Thus, the importance of every
low-income program, such as Rocky Mountain's LIWA, continues to increase.
What role do you see CAP AI fillng in terms of its appearance before this Commission
given what you have described?
First, unlike in many other states, it should be noted that there is no regular interening
party to Commission proceedings who represents, exclusively, the interests of non-low
income residential customers. While the Commission Staff certainly strves to seek a fair
balance taking residential interests into consideration when it takes its positions in any
given proceeding, Staffs legal mandate, as with the Commission, requires that it do so
for all paries, including the utility.
5 United Water of Idaho; Case No. UWI-W-11-0~~0
6 Case No. PAC-E-11-13.25
DIRECT TESTIMONY OF TERI OTTENS 6
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As the percentage of Rocky Mountain's residential customers who qualify as low-
income increases, CAP AI's involvement in proceedings before this Commission expands
in depth and scope. Low-income assistance resources are already sadly insufficient to
meet the needs of the poor. Rapid expansion of the ranks of the poor without
commensurate increase in assistance is of obvious concern to CAP AI. Many of today' s
non-low-income residential customers are tomorrow's poor. Thus, while CAP AI's
mandate is to serve and represent the interests oflow-income customers, we must remain
aware that this paricular population is rapidly expanding and, unfortnately, wil include
customers who do not yet qualify as low-income. Thus, CAP AI submits that it is the
closest thing that Idaho has to a consumer advocate for residential customers at this time.
C. Effects of Simultaneous Filings Problematic for Settlement
Does the timing of the three pending electrc general rate cases and the LIW A evaluation
case cause any paricular problem that CAP AI wishes the Commission to be aware of?
Yes. As discussed throughout my testimony, there is currently pending a very
problematic situation for CAPAI based on the fact that Rocky Mountain's LIW A
evaluation case was filed shortly before not only Rocky Mountain's general rate case, but
similar cases for Idaho Power and A VISTA.
How has this scenario proven to be "problematic" for CAP AI?
Rocky Mountain's LIWA evaluation case was filed in late April of this year. The
Company's application was, apparently, the culmination ofthe cost-effectiveness
evaluation of LIW A it had promised for some time but was completely unexpected in
terms of its nature and the relief sought. Rocky Mountain framed its application in a
highly unusual manner seeking authority to cease further evaluations on the basis that
LIWA is not cost-effective and will never satisfy traditional cost-benefit tests. In
271
DIRECT TESTIMONY OF TERI OTTENS 7
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seeming contradiction, Rocky Mountain asked the Commission to, nonetheless, approve
LIW A as a par of the Company's overall DSM portfolio.
In what manner was Rocky Mountain's application unexpected?
By the time Rocky Mountain filed its application, it was known to all that Rocky
Mountain, Idaho Power and A VISTA intended to soon file general rate cases. Casting
LIW A into such doubt immediately prior to filing its own rate case, as well as the others,
was certainly not something that CAP AI anticipated. Furthermore, a cursory review of
the CADMUS study filed in support of the application revealed that it was based on a
paltry amount of sampling data, reached incomprehensible conclusions, and seemed
facially invalid.
How did the filing of Rocky Mountain's LIW A evaluation case affect this rate case?
CAP AI had fully intended to intervene in the three imminent rate cases and seek
additional LIW A funding for all thee utilities including Rocky Mountain. By
characterizing its own program as not being cost-effective, Rocky Mountain did not
exactly do itself any favors. From CAP AI's standpoint, the ramifications were
immediately obvious. With all three ofIdaho's largest electric public utilities set to file
general rate cases, as well as United Water, it was obvious that the resources of the
Commission, Staff and CAP AI would be stretched to their very limits. Furthermore, the
fact that the LIW A evaluation case was not noticed until nearly July and a comment
deadline set for the end of September didn't help matters.
Would you please identify the specific procedural problems this caused CAP AI?
The LIW A case cast a shadow over the legitimacy of all low-income weatherization
programs in the state making settlement negotiations conducted during this past summer
quite awkward. Regardless of the fact that Rocky Mountain's application and supporting
study wil likely prove to be completely withoufiért, it was reasonable to assume that
DIRECT TESTIMONY OF TERI OTTENS
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Idaho Power and A VISTA might experence unease at the prospect of supplementing the
funding of a program that has been called into question as to its prudency. The fiing was
not likely to put Staff at ease either.
Are you suggesting that Rocky Mountain should not have filed its application at all?
Not at all. The Company was under an obligation to evaluate its DSM programs and the
study was long overdue. The lack of care taken to properly evaluate LIW A caused
unnecessary concern and procedural challenges.
Are there other aspects to the simultaneous pendency of the multiple cases?
Yes. Although the A VISTA case was the last of the three electric rate cases filed, it was
the first scheduled for settlement negotiations. Staff might have had legitimate reasons
for this, but CAP AI's primar focus was to bring Idaho Power's LIW A funding level,
which had not been increased since its 2003 rate case, into party with the other utilties.
This made settlement with A VISTA first difficult. In any event, it appears that even if
the proposed settlement agreements and their stay-out provisions are ultimately approved,
the same scenaro of multiple rate cases pending might occur again in a year and a half or
so. Of greater concern is the fact that the current rate cases do present an opportnity to
shore up the LIW A funding levels of all three utilities. The timing of Rocky Mountain's
LIW A case has caused a chiling effect on obtaining that effect through settlement
compelling CAP AI to take the issue of LIW A funding, as well as others, to hearng.
D. Current Trends of Rate Case Filngs and Settlements
What particular components of the rate increase proposed in the settlement does your
testimony address?
As the Commission is well aware, CAP AI typically does not have sufficient financial
means to retain expert witnesses to analyze, and provide testimony for, the gamut of
components that comprise any given rate increá§é. 3CAP AI has historically limited its
DIRECT TESTIMONY OF TERI OTTENS
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1 scope of issues to very few low-income specific issues, such as LIW A funding, rate
2 design, minimum customer charge, etc.
3 Q:Is CAP AI expanding its traditional scope of issues in this proceeding?
4 A:To a limited extent, yes. This is necessitated by several factors including the curent
5 economic crisis, the unprecedented spate of general rate cases and LIW A evaluation
6 proceedings currently pending before the Commission, the cumulative impact that
7 frequent general rate case filings by Idaho's three largest electrc public utilities has had
8 on residential and particularly low-income customers, the fact that those utilities seem
9 increasingly shielded by varous mechanisms that stabilize their earings putting them in
10 a relatively advantageous position in the economy but have shifted the burden of risk to.11 ratepayers and finally, the fact that all ofthe other parties agreed to settle yet another
12 general rate case using a "black box" settlement that does not specify a rate of return and
13 allocating the proposed rate increase in a uniform percentage spread across customer
14 classes without first testing the validity of a uniform rate spread through the hearing
15 process.
16 Q:Do you possess any expertise in analyzing either revenue requirement or allocation
17 among customer classes for utility ratemaking purposes?
18 A:No, I do not possess expertise in the areas of utility ratemaking, including revenue
19 requirement issues or rate spread issues. I do have expertise in the perceptions and
20 realities oflife for low-income customers and the burden that ever-increasing utility bils
21 poses for those customers. It is in that spirit that I offer my opinions.
22 Q:In light of your statement, is CAP AI taking any specific position on revenue requirement.23 issues?
24 A:Again, not in the technical sense.I believe that Staff always conducts a ver thorough
25 analysis of specific revenue requirement issuesf C1P AI generally supports the specific
DIRECT TESTIMONY OF TERI OTTENS 1
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issues raised and positions taken by Staffbut notes that Staffs settlement position in any
case is obviously the result of compromise. It is entirely possible that had every revenue
requirement issue identified in this case by Staff been litigated, the outcome might have
been a lesser revenue requirement and rate increase than settled upon.
Given that you do not purport to have technical expertise in the specifics of ratemaking,
what points do you wish to address regarding ratemaking issues?
I offer an opinion with respect to certain fundamental principles applied to the manner in
which rates have been set as oflate. I offered more specific opinions in my testimony in
the Idaho Power general rate case, but believe doing so is less justified for Rocky
Mountain because the Commission resolved many ratemaking issues for the Company
just this year in Order No. 32196 issued in Rocky Mountain's 2010 general rate case.?
The Table of Contents alone in Order No. 32196 is two pages long listing a vast aray of
technical, ratemaking issues that were resolved. It gives CAP AI a greater sense of ease
when issues have recently been litigated before and resolved by the Commission.
What then are the fundamental principles you've referred to then?
CAP AI is concerned about the relatively recent trend of Idaho's three electric utilities to
frequently file applications seeking significant rate increases. Rocky Mountain, for
example, filed general rate cases in 2005,2007,2008,2009,2010, and 2011. While not
all of those cases necessarily resulted in a general rate increase, Rocky Mountain, in
response to CAP AI discovery request No.4, states that its base tarff rate for the
residential class has increased 25% since 1989 and 22% since the year 2000 alone.
What increases have been made to Rocky Mountain's LIWA funding since its inception?
Rocky Mountain has increased its LIW A funding only twice in the past21 years from
$75,000 in 1989 to its current level of $300,000 ordered by the Commission this year.
25 7 Case No. PAC-E-I0-07.275
DIRECT TESTIMONY OF TERI OTTENS 11
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The most recent increase of $ i 50,000 was ordered by the Commission, over the
Company's objection, in Rocky Mountain's 20 i 0 general rate case.8 While LIW A is
obviously of tremendous importance to CAP AI, one must remember that even if LIW A
funding increases were increased by the same percentage as every Rocky Mountain rate
increase, LIW A is a program that, due to its extremely limited fuding, impacts only a
fraction of the Company's low-income customers.
Are there other concerns you have about frequent general rate cases?
There are several, including the fact that it can result in situations such as that curently
pending where there are several rate cases being processed simultaneously. Not only
does this stretch the resources of Staff, the Commission, and the parties quite thin, it
places considerable demand on CAP AI's limited resources. Furhermore, it creates a
sense of overwhelming despair on the part of low-income customers whose ability to
simply pay for life's necessities continue to plummet while their utility bils skyrocket.
Though "stay-out" provisions are often negotiated as a result of rate case settlements,
they typically last only a year or two and it goes without saying that the non-utility
settling paries give up something of value in exchange for them.
What other ratemaking principles applicable to this case concern you?
Though CAP AI acknowledges that "black box" settlements can be a useful tool under the
right circumstances, they seem to have become the rule, not exception. It simply does no
sit well with many if not most residential customers, especially low-income, when they
learn that their electrc utility has obtained yet another substantial increase through a
confidential settlement process. Those customers with the sophistication necessary to
truly analyze the terms and conditions of a rate case settlement wil likely be disturbed by
this lack of transparency.
25 8 Case No. PAC-E-10-07.276
DIRECT TESTIMONY OF TERI OTTENS 12
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Are there other aspects of black box settlements that trouble CAPAI?
Without the benefit of airing out ratemaking issues in the course of a public proceeding,
the potential for distrust and unease increase as settlements are based on increasingly
stale data. This can involve anything from rate of return to rate spread, the latter of
which is of paricular concern for CAP AI. Recent black box settlements have tyically
included a uniform percentage rate spread among customer classes, even when the utility
in question's cost of service study shows that some classes are being largely subsidized
by others. Though it varies, the residential class is often shown to be paying morethan
its cost of service. Regardless of the subjective nature of cost of service studies, this
trend toward deferrng needed rate spread corrections to the future does little to engender
confidence in this opaque process.
Are you suggesting that the Commission never approve black box settlements in this case
or the future?
No. I simply wish to offer one point of view suggesting that this form of rate case
resolution should not become an automatic default position for the sake of reaching
settlement and avoiding litigating a general rate case, in whole or in par, before the
Commission.
E. Revenue Sharing Mechanisms Exacerbate Foregoing Concerns
How does Rocky Mountain's power cost adjustment mechanism (ECAM) factor into
your testimony?
My limited knowledge is that the origin of cost adjustment mechanisms can be found
durng extended periods of extraordinar drought during the 1990s leading Idaho Power
to seek and the Commission to approve a mechanism that would avoid the need for that
utility to file frequent "drought surcharge" cases during times of high power supply costs
277
DIRECT TESTIMONY OF TERI OTTENS 13
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while sharing with ratepayers the benefits oflower power supply costs resulting from
things as basic as weather and market forces.
Are you contending that mechanisms such as Rocky Mountain's ECAM should be
eliminated?
Absolutely not. But I am pointing out why these types of mechanisms exacerbate the
effect that rapidly increasing rates have on low-income ratepayers. It is my
understanding that before Idaho's PCA was first approved, electric utilities often went
extended periods of time between general rate cases. A PCA allows utilities to forgo
filing general rate cases because of simple varations in power supply costs, even during
periods of extended drought or rising costs of non-hydro power supply such as coal costs
and off-system market prices of purchased power. This should seem to be the effect on
Rocky Mountain as well by virte of its ECAM. Though that particular cost adjustment
mechanism has not been in place for as long as Idaho Power's, Rocky Mountain appears
to be in a pattern of filing general rate cases every year. The current Rocky Mountain
proposed rate increase is based in large part on increased base power supply costs. Thus,
from the standpoint oflow-income customers, rapidly increasing base rates combined
with ECAM adjustments that increase their bils is confusing and compounding. It seems
to me that the ECAM and all other revenue stability mechanisms provide greater
assurance to utility's than to their customers which one could argue amounts to risk-
shifting. Whether this is fully factored into any given utility's authorized return is
difficult to discern.
What effect has this had on low-income customers?
Low-income customers, due to a lack of resources, have relatively limited ability to
control their consumption and their bils and constitute the most vulnerable customer bas
to increasingly higher rates. For these custome1§:ihe LIWA program is currently the
DIRECT TESTIMONY OF TERI OTTENS 14
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only viable means to reduce their electrc bils and, to a limited extent, offset some of the
frequent rate increases granted to Rocky Mountain.
V. LIWA FUNDING
A. Overview
What is CAP AI's proposal regarding Rocky Mountain' sLIWA program in this case?
CAPAI proposes that Rocky Mountain's LIWA funding level be increased to the amount
necessary to bring the Company into party with A VISTA's funding level on a per capita
basis.
Isn't it true that the Commission recently doubled Rocky Mountain's LIWA funding
level?
Yes. Rocky Mountain, however, was historically investing such a small amount of
capital into its LIW A program that the recent doubling should be put into proper context.
The facts and recommendations set forth in my Idaho Power testimony apply equally to
this case if adjusted for the specific facts pertinent to Rocky Mountain's program.
Would you please summarze how CAP AI arrved at its positions in the three general rate
cases concerning the issue of LIW A?
When CAP AI first learned that there would likely be a nearly simultaneous filing of all
three major electric utilities in Idaho, it began formulating a set of objectives for its
participation in those proceedings. During that process, it was realized that
notwithstanding the fact that Rocky Mountain was recently ordered to increase its LIW A
funding, A VISTA was stil funding approximately 25% more than Rocky Mountain and
over 200% more than Idaho Power. CAP AI had originally intended to seek additional
LIW A funding from A VISTA to stop the widening gap between need for LIW A and
available funding. CAP AI adheres to and advocates several principles in matters before
this Commission. One of those principles is thát b~ parity or, simply put, basic fairness.
DIRECT TESTIMONY OF TERI OTTENS 15
.
1
2
3
4
5 Q:
6 A:
7
8
9
10.11
12
13
14
15
16
17
18
19
20 Q:
21
22 A:.23
24
25
Because of the problematic timing of the three general rate cases, as well as the order in
which Staff noticed settlement discussions, CAP AI determined that, considering the
circumstances, the objective of bringing the LIW A funding levels ofthe three utilities
into relative parity outweighed obtaining greater funding from A VISTA.
Couldn't CAP AI have sought both objectives?
Yes, but because A VISTA was noticed for settlement first, any increase in A VISTA's
funding would necessitate even larger increases in the funding of Rocky Mountain and
Idaho Power to achieve parity. CAP AI submits that party applies to this issue in several
respects. First, there is no logical reason for the three utilities to fund at significantly
different levels. The evidence presented by CAP AI over the years, and presumably part
of the basis for Commission rulings, demonstrates that there exists such a sizeable gap
between need and resources for all three utilities, that there is certainly no risk of over-
funding LIW A in that sense. CAP AI believes that it was more important to focus on
bringing Rocky Mountain and Idaho Power into line with AVISTA's funding. This
parity is needed to treat both the utilities' shareholders with relative equality as well as
their low-income customers who need the assistance that LIW A offers. It is arguably
discriminatory to allow large disparties in LIW A funding to continue. Thus, CAP AI
agreed to join the A VISTA settlement, but has made clear from the outset that it intends
to seek party in funding.
How did A VISTA's per capita funding level reach such a higher level than the other two
utilities?
A VISTA agreed to nearly double its funding from $465,000 to $700,000 through
settlement approved by the Commission in Case No. A VU-E-1O-Ol. As stated earlier,
Rocky Mountain's funding has only been increased twice in 21 years and was at an
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1 unjustifiably low level when it was doubled from $150,000 to $300,000 by Commission
2 Order No. 32196 in Case No. IPC-E-10-07 issued February 28 of this year.
3 Q:How do the current fuding levels of the three utilities compare now?
4 A:A VISTA funding is currently the highest per capita and is more than 200% higher than
5 Idaho Power and roughly 25% higher than Rocky Mountain Power.
6 Q:Please explain how you arrved at this conclusion?
7 A:I divided the total program fuding by the number of each utility's Idaho electrc
8 residential customers. The customer numbers were obtained from each utility and is the
9 most recent data I had at my disposal when I made these calculations. To the extent that
10 there exists a more accurate customer count, CAP AI would obviously prefer that figure.11 for comparson purposes. A VISTA funds at $700,000 and has 104,609 Idaho electrc
12 customers for a per capita level of $6. 69/customer. Rocky Mountain Power funds at
13 $300,000 and has 56,430 Idaho electrc customers for a per capita level of $5.32. Idaho
14 Power funds at $1.2 milion and has 391,759 Idaho electrc customers for a per capita
15 level of$3.06.
16 Q:Would you please explain why prolonged, substantial disparty between the three electric
17 utilities' LIW A programs is not fair, just and reasonable?
18 A:If there is substantial funding disparty between the three utilities, then customers of thos
19 utilities are either being treated preferentially or discrminated against. Because the costs
20 of low-income weatherization programs are passed on to ratepayers, there exists a
21 legitimate concern about whether rates are fair, just and reasonable, at least to the extent
22 that they are affected by LIW A funding..23 Q:Are there other considerations that convinced CAP AI to join the recent A VISTA
24 settlement in Case No. AVU-E-l 1-01?
25 281
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1 A:There were severaL. The consideration most perinent to this case is the fact that
2 AVIST A agreed to increase its conservation education program by 25% increasing it
3 from $40,000 anually to $50,000. Incidentally, Rocky Mountain continues to
4 strenuously resist any attempt to even continue its conservation education program, let
5 alone increase its funding.
6 Q:Would you please summarze exactly what you are seeking from the Commission with
7 respect to Rocky Mountain's LIWA program?
8 A:CAPAI proposes, as it did for Idaho Power, that Rocky Mountain's funding level be set
9 at whatever funding amount is necessar to equal AVISTA's funding on a per capita
10 basis. CAP AI proposes using the most recent data available to calculate the precise.11 amount of increase needed to bring Rocky Mountain to party with A VISTA. Using Ms.
12 Ottens' per capita AVISTA calculation of $6. 69/customer multiplied by her most recent
13 Rocky Mountain Idaho residential customer population figue of 56,430 yields a needed
14 increase of $77,517 for a total annual funding level of $377,517.
15 Q:How do you respond to a possible argument that Rocky Mountain's funding should not
16 be increased so soon after the 2010 rate case order was issued?
17 A:Although Rocky Mountain's funding was increased earlier this year, it must be
18 remembered that the Company went an extraordinarly long time without any increase.
19 Furthermore, Rocky Mountain has filed more general rate cases since 2005 than either of
20 the other two utilities. Finally, if the Commission agrees to embrace parity in LIW A
21 funding, this wil bring the utilities on an even level and make future LIW A funding
22 evaluations simpler..23 B.Widening Gap Between Need and Resources for LIWA
24 Q:What is the status of the disparity between the need for LIW A and availability of
25 resources?282
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1 A:In spite of the injection of funds through the now-expired AARA, the disparity continues
2 to increase. Though diffcult to predict with precision, it is likely that Rocky Mountain
3 customers wil have to wait for an average of 8 years and quite possibly might never
4 receive benefits under the program.
5 C.CASE NO. PAC-E-l1-13 - Rocky Mountain's LIWA Evaluation Case
6 Q:You have discussed the pending Rocky Mountain proceeding seeking authorization to
7 discontinue cost-effectiveness evaluations of LIW A on the basis that the program is not
8 cost-effective and the chiling effect it has had on increasing LIW A fuding for all three
9 utilities. Why does CAP AI oppose deferrng LIW A funding increases pending resolution
10 of Rocky Mountain's 11-13 case?.11 A:The LIW A evaluation filing has seemed to have had an unfortnate chiling effect on not
12 only Rocky Mountain's LIWA program, but possibly Idaho Power's and AVISTA's
13 programs as well. While CAP AI is quite confident that the CADMUS study is so flawed
14 that it is meaningless, and bases this contention on the work of a prominent national
15 expert in the field of evaluating the cost-effectiveness oflow-income programs retained
16 by CAPAI to properly analyze the effectiveness of LIW A, Rocky Mountain's filing
17 seems to have needlessly cast a pall over other paries' perception ofLIWA and called
18 into question whether additional funding for the program is appropriate pending a
19 resolution of the LIW A evaluation case.
20 Q:Has the Commission recently spoken to the issue ofLIWA's cost-effectiveness?
21 A:Yes. In Order No. 32196 issued February 28,2011 in Case No. PAC-E-1O-08, the
22 Commission stated on pp. 61-62, in reference to Rocky Mountain's LIW A program that:.23 "(w)e find that RMP does not dispute the cost-effectiveness of its Schedule 21
24 weatherization program for its low-income customers."
25 Q:What is the status of the LIW A cost -effectivené§~ ~ase?
DIRECT TESTIMONY OF TERI OTTENS 1
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1 A:Both Staff and CAPAI have submitted comments in response to Rocky Mountain's
2 application. As I just mentioned, CAP AI, using the detailed analysis pedormed by its
3 expert, submitted extensive comments demonstrating precisely how the cost-
4 effectiveness evaluation conducted on behalf of Rocky Mountain was flawed and what
5 effect it had on the ultimate outcome of the study. CAP AI's exper concludes that there
6 is no doubt that, ifproperly evaluated, Rocky Mountain's LIWA program wil prove
7 cost-effective.
8 For its part, Staff also noted a number of deficiencies so serious that it proposes
9 that the paries to that case convene in a workshop setting to resolve the complicated task
10 of properly evaluating low-income weatherization programs. In its comments, Staff.11 noted its "long history of support for low-income weatherization programs" and cited
12 from a Commission Order dating back to 1989 identifyng the types of benefits provided
13 by LIW A. Staff also quoted from the Commission's final order in Rocky Mountain's
14 2010 rate case in which the Commission noted its continued support for LIWA and that it
15 was not disputed that the program is cost-effective.
16 Q:Would you summarze CAP AI's position that increased LIWA funding should not be
17 defered pending resolution of the LIW A evaluation case?
18 A:The program funding levels are substantially disproportionate, resulting in disparty and
19 unfairness for utilities and ratepayers. Allowing this disparity and the resulting
20 preferential/discriminatory effects to continue is not fair, just or reasonable. Second,
21 there are economic consequences to losing the opportnity to present the issue to the
22 Commission in this and Idaho Power's rate cases..23 Q:What economic consequences are you referrng to?
24 A:Although CAP AI could ostensibly initiate a docket by way of petition solely for the
25 purpose of increasing LIW A funding after Rocl?Mountain' s LIW A evaluation program
DIRECT TESTIMONY OF TERI OTTENS 2
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1
2
3
4 Q:
5
6 A:
7
8
9
10.11
12
13
14
15
16
17
18
19
20
21 Q:
22.23 A:
24 Q:
25
is concluded, this constitutes a lost opportnity for CAPAI. My understanding is that
general rate proceedings are considered an opportnity to present most relevant issues to
the Commission.
So it is possible for CAP AI to file an application for LIW A fuding increases outside the
context of a pending general rate case?
To my knowledge, any individual or entity may file an application or petition with the
Commission at its discretion but it is not always financially feasible for CAP AI to do so.
A pending general rate case offers advantages for an organization with limited resources
such as CAP AI. I am not an attorney and do not profess to have any legal expertise. I
am, however, familiar with the basic elements of Idaho law and the Commission's
procedural rules pertaining to intervenor funding. There are a number of critera that an
intervenor must satisfy in order to be entitled to a funding award. Absent the possibility
of obtaining such an award, it is a financial strain for CAP AI to formally intervene in
proceedings before the Commission. Furthermore, there are essentially economies of
scale that exist when a general rate case is pending for a utility that constitute an
economic opportnity for CAP AI to have its issues addressed. Because the Commission
generally allows any and all issues to be raised during the course of a general rate case, it
is procedurally less complicated and costly for CAP AI to intervene in a pending case tha
to initiate a new one.
VI. CONSERVATION EDUCATION
Have you reviewed the testimony fied by Rocky Mountain witness Barbara Coughlin
regarding the low-income conseration education program ("Con-Ed")?
Yes I have.
What is your response to Ms. Coughlin's testimony?
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1 A:
2
3
4
5
6
7
8
9 Q:
10
11 A:
12
13
14
15
16
17
18 Q:
Though I possess no legal expertise and assume that Ms. Coughlin is not an attorney, it
seems that she has essentially restated the arguments made by Rocky Mountain in post-
hearing briefing at the conclusion of Case No. PAC-E-1O-07. I point out that both
CAP AI and Rocky Mountain have already submitted extensive briefing on the issue of
whether a prior settlement agreement should be constred as an agreement by Rocky
Mountain to fund its Con-Ed program on an anual basis, or whether it was a one-time
expenditure. I see no reason to reiterate points already made by CAP AI's attorney in
briefing from last year's rate case.
Does Ms. Coughlin present any factual information or technical analysis that wasn't
already put before the Commission in the last rate case?
I see nothing in Ms. Coughlin's not already stated and put before the Commission in the
past case. I do note that Ms. Coughlin seems to suggest that the Company is wiling to
have a dialogue with the Community Action Agencies that administer the Con-Ed
program and agree that such dialogue would be waranted. Ms. Coughin suggests that it
might not be possible for the agencies to distribute 500 kits per year as was the original
agreement. This is the type of concern that could be addressed through collaboration
between the agencies and Rocky Mountain.
Do you have an update on the status of distrbuting the conservation kits under Rocky
19 Mountain's program?
20 A:
21
22.23 Q:
24
25
Yes. It was agreed by all concered that the best time to distribute the remainder of the
kits would be the commencement of the LIHEAP season which stars today. All kits are
expected to be distrbuted by year's end.
Do you have any response to Ms. Coughlin's suggestion that there be a "consistent state-
wide approach" to Con-Ed?
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DIRECT TESTIMONY OF TERI OTTENS 22
,.l ,""
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1 A:CAP AI would support such a proposition to the extent feasible. There are obvious
2 unique characteristics between the three electric utilities that might prevent a perectly
3 consistent model for Con-Ed, but to the extent possible, it would be desirable to CAP AI.
4 In this regard, I point out that both Idaho Power and AVISTA's Con-Ed programs are
5 funded annually. In fact, A VISTA agreed to increase funding for its program by 25% in
6 the recently approved settlement in Case No. AVU-E-II-Ol. If Rocky Mountain truly
7 desires a consistent state-wide approach, then it is only logical to continue funding Rocky
8 Mountain's program on an anual basis as well.
9 VII.CONCLUSION
10 Q:How would you summarize your testimony in conclusion?.11 A:I greatly appreciate the opportnity to present a low-income customer's perspective on
12 the many issues and challenges facing that customer today. I also appreciate the
13 Commission's consideration of this perspective. My testimony is obviously not that of a
14 expert in the technical aspects of a general ratemaking such as deterining revenue
15 requirement and allocation. The purpose of my testimony is to explain why the type of
16 settlement currently before the Commission is unbalanced from the point of view of a
17 low-income Rocky Mountain customer who strggles with the fact that his or her bil
18 seems to constantly increase. The frustration that accompanies this is elevated by that
19 same customer's inability to do anything to modify his or her consumption. A settlement
20 that does nothing but exacerbate the many inequities I suggest exist by failing to simply
21 increase funding of the only resource available to low-income customers is neither fair,
22 just nor reasonable..23 Q.Does this conclude your testimony?
A.Yes, it does.24
25 287
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1 (The following proceedings were had in
2 open hearing.)
3 COMMISSIONER KJELLANDER: And she is now
4 available for cross-examination. Why don't we begin with
5 Mr. Solander.
6 MR. SOLANDER: Thank you. First, Chairman
7 Kjellander, in the interest of saving the Commission's time, I
8 would ask that the Commission take judicial notice of the
9 testimony that Ms. Ottens provided to the Commission just a few
10 weeks ago at the Idaho Power general rate case hearings in Case
11 IPC-11-08, in particular, the examination of Ms. Ottens by
12 Ms. Nordstrom on behalf of Idaho Power and by Mr. Howell on
13 behalf of Staff beginning on page 820 of the transcript in
14 which Ms. Ottens acknowledges that she possesses no special
15 expertise in the areas of rate making. And I would ask that
16 the Commission, similar to how it did in the Idaho Power case,
1 7 give her testimony the weight in which the Commission's opinion
18 it is entitled.
19 MR. PURDY: Mr. Chair, I have a response, if I
20 may.
21 COMMISSIONER KJELLANDER: Sure.
22 MR. PURDY: I was -- it was pointed out to me
23 that I had misapplied Rule 263 of the Commission's procedural
24 rules in the Idaho Power case involving official notice. As I
25 read that rule, I do not see that it allows for testimony from
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1 another case to be taken official notice of. It states -- it
2 refers to Orders, Notices, Rules, certificates and permits,
3 matters of common knowledge -- and I don't think testimony
4 before the PUC is necessarily common knowledge -- technical,
5 financial, or scientific facts, and so on. There's no
6 provision in there that I can see for prefiled testimony in
7 another case, especially cross-examination testimony; I
8 particularly obj ect to that.
9 COMMISSIONER REDFORD: Can I ask a question?
10 COMMISSIONER KJELLANDER: Just one moment,
11 please.
12 Mr. Solander, an approach that may be of some
13 value to move things along would be if there was a request to
14 incorporate that section by reference.
15 MR. SOLANDER: I would be happy to make that
16 request. I have the transcript here. I can find the page.
17 MR. PURDY: I have not seen that, Mr. Chair,
18 would not be able to follow along without a copy.
19 COMMISSIONER KJELLANDER: I don't believe there's
20 going to be much following along, is there?
21 MR. SOLANDER: I was just going to start at
22 page 820, which is the beginning of the examination of
23 Ms. Ottens by Ms. Nordstrom -- I'm sorry, 818.
24 MR. PURDY: Mr. Chair, Community Action does not
25 have the resources, let alone the time, to obtain transcript
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1 testimony from a case that's from a hearing that's only two
2 weeks old.
3 COMMISSIONER KJELLANDER: How many pages do we
4 have?
5 Let's go off the record for just a moment.
6 (Discussion off the record.)
7 COMMISSIONER SMITH: All right, we'll go back on
8 the record. Mr. Solander.
9
10 CROS S - EXAMINAT ION
11
12 BY MR. SOLANDER:
13 Okay, good afternoon, Ms. Ottens, or goodQ.
14 morning.
15 A.Good morning.
16 Do you recall testifying before thisQ.
17 Commission
18 COMMISSIONER KJELLANDER: Just a moment,
19 Mr. Solander. Did you officially withdraw your Motion?
20 MR. SOLANDER: I withdraw my Motion.
21 COMMISSIONER KJELLANDER: Thank you.
22 BY MR. SOLANDER: Do you recall testifying beforeQ.
23 this Commission in the Idaho Power rate case, Case No.
24 IPC-11-08?
25 A.I do.
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1 Q.And do you recall the examination by
2 Ms. Nordstrom and Mr. Howell?
3 A.I do.
4 Q.And do you recall acknowledging that you do not
5 possess some expertise in the areas of rate making?
6 A.I believe that my testimony also said that --
7 Q.Okay.
8 -- in both this case and that case, that I am notA.
9 an expert in rate making.
10 On page 4, lines 4 through 14, of your testimony,Q.
11 you discuss what you term black box settlement?
12 A.Yes.
13 Isn't it true that a black box settlement is justQ.
14 another term for negotiated settlement?
15 A.A black box settlement, in my -- I am not an
16 expert in rate making. A black box settlement, in my term, is
17 a settlement that is made when you -- yes, in negotiated rate
18 making which is not a -- in which the details are not available
19 to the public.
20 Okay. Can you please describe your concerns withQ.
21 use of a black box settlement in this particular proceeding?
22 I think my concerns reflect the concerns ofA.
23 almost every single letter that was received in this case and
24 the Idaho Power case:
25 That the public does not have the knowledge to
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1 know why there has been three rate increases in the last year.
2 There is no opportunity to explain what went into this rate
3 increase and why it was justified. There are -- I understand
4 that the settlement addresses issues such as rate of return and
5 return on equity and all of those terms, those very complicated
6 terms that go into rate making of which I am not an expert.
7 But our obj ection is -- is that if you continue
8 to do black box settlements year after year after year, the
9 public loses not only trust, but they lose touch with what
10 exactly is going into their rates.
11 What, specifically, about this Stipulation is notQ.
12 sufficiently explained, in your opinion?
13 Well, my concerns are that -- I'm not sure whereA.
14 I'm at here, because I can i t discuss what was discussed in
15 settlement; but, specifically, I have several concerns:
16 One of the concerns is -- is that when there is a
17 rate increase that includes such things as return on equity and
18 that addresses reducing the overall risk of the Company without
19 any explanation to the public on why that rate increase is
20 justified, I think that not only do the low-income customers
21 suffer, but so do the residential customers. And, again, I
22 refer to the letters that were received from the numerous
23 customers, most of them who attended the hearing and still
24 walked away without an understanding on why the rate increase
25 is justified.
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1 You also state that black box settlementsQ.
2 typically included a uniform rate spread among customer
3 classes?
4 A.Typically.
5 Are you aware that Rocky Mountain Power'sQ.
6 residential customers in this rate case received the lowest
7 percentage increase apart from street lighting?
8 I understand that this case probably wasn'tA.
9 typical, yes.
10 On page 13 of your testimony, you have a sectionQ.
11 entitled Revenue-Sharing Mechanisms Exacerbate Foregoing
12 Concerns?
13 Did you give me a line?A.
14 Page 13, line 18.Q.
15 Eighteen, yeah.A.
16 Can you please provide a short explanation forQ.
17 the Commission of Rocky Mountain Power's ECAM mechanism
18 recently approved by the Commission?
19 I'm sorry, say that question again. I wasA.
20 reading.
21 Can you provide a short explanation of RockyQ.
22 Mountain Power's ECAM mechanism that was recently approved by
23 the Commission?
24 A. Well, all I can tell you is that the ECAM is the
25 same as the PCA. Once again, I'm not an expert in it, but I do
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1 know that the PCA is allowed pretty much automatically based on
2 your power cost supply and whether it goes up or it goes down.
3 Q.Can you describe any expenditures that are
4 tracked in the ECAM?
5 A.No, I cannot.
6 MR. SOLANDER: I'd ask that Ms. Ottens' testimony
7 beginning in the section on page 13, line 18, regarding
8 revenue-sharing mechanisms exacerbate foregoing concerns be
9 stricken from the record.
10 COMMISSIONER SMITH: What's your ending point?
11 COMMISSIONER KJELLANDER: You said the starting
12 point was on page 13.
13 MR. SOLANDER: All of Section E, so it would go
14 through page -- line 2 on page 15.
15 COMMISSIONER KJELLANDER: Line 2 on page 15.
16 MR. PURDY: Mr. Chair, may I respond?
17 COMMISSIONER KJELLANDER: Yes.
18 MR. PURDY: Well, I object to that request, that
19 Motion, on the basis that, as Ms. Ottens just testified, she's
20 not an expert on rate making. She is providing the perspective
21 of low-income customers. And, for instance, if you look at
22 page 14, line 17, ECAM adj ustments increase their bills , it's
23 confusing and compounding. This is just one example of what
24.25
she's really talking about, and I don't think that this is
subj ect or should be subj ect to a Motion to strike, because
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1 she's not an expert.
2 MR. SOLANDER: Chairman, if the Commission is
3 willing to do what it did in the Idaho Power proceeding and
4 give Ms. Ottens' supposed expert testimony the weight to which
5 it's entitled, I think I can move on and save time and wrap up.
6 I have other short areas of examination for Ms. Ottens, but I
7 don't need to go through each area in which there is supposed
8 expert testimony.
9 COMMISSIONER KJELLANDER: Okay. And I believe
10 the Commission does have the ability to give this the weight
11 that it deserves, and can do so not only in the context of
12 today' s proceedings but also in any future deliberations, so,
13 thank you. Let's move on.
14 MR. SOLANDER: Thank you.
15 Q.BY MR. SOLANDER: Ms. Ottens, have you reviewed
16 the testimony filed by Ms. Donohue on behalf of Staff and
17 Ms. Eberle on behalf of the Company?
18 A.Yes, I have.
19 Q.And is it still your position that Rocky Mountain
20 Power -- or, that Avista' s funding level for its electric
21 customers is higher than Rocky Mountain Power's on a per-capita
22 basis?
23 A.It is.
24 Q. But isn't it true, based on Ms. Donohue's
25 calculation, that Rocky Mountain Power's per-capita funding of
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1 $5.32 is significantly higher than Avista' selectric-only
2 funding at approximately $3.98?
3 A.If you agree with the premise that electric
4 funding should only be included.
5 Q.Thank you.
6 A.Which is not my premise.
7 Q.But it is Ms. Donohue's premise?
8 A.Yeah. I can't speak for Ms. Donohue, and I don't
9 necessarily agree with her either.
10 Q.Ms. Ottens, do you recall when Rocky Mountain
11 Power asked in a Data Request for CAPAI to provide supporting
12 detail behind the calculations of the eight-year backlog?
13 A. I do.
14 Q.You were asked to give substantiation of that
15 number, is that right, that waiting period?
16 A.Yes, we were asked -- the question was how did we
17 calculate it.
18 Q.And you were unable to give the list of the
19 backlog at any point in time to Rocky Mountain Power in
20 response to that Data Request. Is that right?
21 A.We gave the list to them on how we calculated it.
22 What we were unable to provide is that the Rocky Mountain Power
.23 asked for specific data for October of 31, 2011, and
24 December 31, 2010. And the waiting list, unfortunately, is a
25 moving target. It changes on most likely a monthly basis
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1 because it's based on how many customers actually applied for
2 LIHEAP, and in any particular point in time, how many customers
3 have been taken off the list because they have already been
4 weatherized, how many customers might be added to the list
5 because they don't qualify for LIHEAP in other words,
6 they're between the 165 and the 200-percent poverty level
7 and so it's our best guess.
8 And we haven't heard from either Staff or Rocky
9 Mountain Power a better way to come up with that waiting list,
10 so far just criticism on how we did it. We'd be more than
11 happy to be open to suggestions on a better way to come up with
12 that list.
13 Q.And is it fair to say that the waiting list was
14 reduced significantly after Idaho received funding from ARRA:
15 The American Reinvestment Recovery Act?
16 A.Well, our figures were based on June of 2011,
17 so -- and that's at the end of ARRA, not the beginning.
18 Q.Is it true that Idaho received over $30 million
19 in ARRA funding?
20 A.Yes, it is.
21 Q.And were the CAPAI agencies tasked with
22 distributing those funds?
23 A.Yes, they were.
24 Q. Were you personally involved in deciding how
25 these funds were distributed?
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1 A.No, I was not.
2 Q.Are you aware of how those funds were
3 distributed?
4 A.Are you asking when you say if I'm aware of how
5 the funds were distributed to individual agencies, is that what
6 you're asking?
7 Q.Individual agencies, and how those funds were
8 used to support weatherization programs.
9 Well, in my Discovery, which am I allowed toA.
10 refer to Discovery if it's not on the record? I'm sorry.
11 MR. PURDY: Yes.
12 THE WITNESS: In my Discovery, I do give a
13 breakdown on how the ARRA funds were distributed per agency. I
14 do not have personal knowledge on how those -- every single
15 dollar of those funds were used.
16 I can tell you that we actually received $38
17 million in ARRA funds. Thirty-one million were for
18 weatherization that was distributed between the six agencies.
19 The other 6.9 million was a weather innovation --
20 weatherization innovation funding; it was a special grant to
21 fund such things as solar water heaters, that type of thing.
22 Q.BY MR. SOLANDER: Of that 38 million then, can
23 you tell me what percent or how much went to help customers.24 with electric-heated homes in Rocky Mountain Power's service
25 territory?
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.I don i t believe -- can I look at the Discovery?1 A.
2 I'm trying to remember if that was part of what we provided
3 you.
4 I can tell you off the top of my head I do not
5 know, but if I can -- no, it doesn't look like it was broken
6 down between electric and gas and other heating sources.
7 Q.Is it true that funding for homes is limited to
8 approximately $6,500?
9 A.Yes, that is true.
And if you divide $6,500 by 38 million (sic), you
11 get somewhere in the neighborhood of 20,000 homes?.
10 Q.
12 A. May I ask a procedural question? I just
15 Q.
13 discovered in the Discovery, you know, I did break it down on
14 page 8 of our Discovery for the previous question.
16 A.
Please answer then.
So it looks like we -- of the -- of the DOE funds
17 out of 10,494 homes that were done, 5,247 were electric, 3,949
18 were gas.
Q.
A.
Q.
and you did
23 for the other -- how do you reconcile $ 6,500 divided by.24 38 million is 20,000 if you only did 10,000 homes?
25 A. I can't. I don't have a calculator in front of
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.
.
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20
1 me. I can't do that math.
2 Q.Okay.
3 MR. SOLANDER: I don't have any further
4 questions.
5 COMMISSIONER KJELLANDER: Thank you.
6 Let's see. Mr. Budge.
7 MR. BUDGE: No questions.
8 COMMISSIONER KJELLANDER: Mr. Olsen.
9 MR. OLSEN: No questions.
10 COMMISSIONER KJELLANDER: Who are we missing?
11 Mr. Williams is --
12 COMMISSIONER REDFORD: Gone.
13 COMMISSIONER KJELLANDER:gone, so we will
14 take that as no questions from him.
15 And let's move now to Mr. Price.
16 MR. PRICE: Thank you, Chairman Kjellander. I
17 have a couple questions.
18
19 CROSS-EXAMINATION
21 BY MR. PRICE:
22
23
24
25
Q.Good morning, Ms. Ottens.
A.Good morning.
Q. I'd like to refer you to page 10 of your
testimony, please.
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.
.
1 A.Okay.
2 Q.On page 10, lines 11 through 15, you make the
3 assertion that the settlement -- the proposed settlement signed
4 by the parties minus CAPAI includes a uniform percentage spread
5 across customer classes. Do you see that portion of your
6 testimony?
7 A.Yes, I do.
8 Q.Have you read the Settlement Stipulation?
9 A.Yes, I have.
10 Q.Are you aware that the settlement proposal in
11 this case does not, in fact, propose a uniform spread?
12 A.I think that's what Rocky Mountain Power said
13 earlier, and I think I answered that that probably should be
14 changed in my testimony.
15 Q.So is that a "yes" or a "no"?
16 A.Yes.
17 Q.And, in fact, doesn't the stipulated spread
18 incorporate the Company's proposed cost of service plan filed
19 in its Application, spreading the increase to various customer
20 classes?
21
22
A.Repeat the question, please.
Q.Doesn't the stipulated -- the revenue spread
23 included in the Stipulation incorporate the Company's proposed
24.25
cost of service study included in its Application, resulting in
a spread of the increase to various customer classes?
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.
.
1 A.When I read the settlement document, I just
2 see and perhaps I'm missing it -- the 7.8 percent in 2012,
3 7.2 percent in 2013, and, I'm sorry, I'm missing the part that
4 talks about where it was spread between the other cases, so I
5 guess I can't answer that question.
6 Q.Okay, we'll just move along.
7 You state on page 11 of your testimony in line 21
8 that residential rates have increased by 25 percent since 1989.
9 Do you see that part of your testimony?
10 A.Yes.
11 Q.And, in fact, the revenue increase for LIWA
12 funding has increased by $75,000 since -- or, from $75,000 in
13 1989 to its current amount of 300,000 today. Correct?
14 A.That's correct.
15 Q.And that results in approximately a 300-percent
16 increase in LIWA funding since 1989?
17 A.Which would have -- which is very much
18 appreciated, but I should point out that Rocky Mountain Power
19 started out at avery, very, very low funding rate compared to
20 the other two Utili ties.
21 Q.Would you, subj ect to check, agree though that's
22 an approximately 300-percent increase since 1989?
23
24
25
A.Yes.
Q.Thank you.
MR. PRICE: I have no further questions.
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.
1 COMMISSIONER KJELLANDER: Thank you.
2 Mr. Williams, did you have any questions?
3 MR. WILLIAMS: No questions.
4 COMMISSIONER KJELLANDER: Thank you.
5 Any questions from members of the Commission?
6 COMMISSIONER REDFORD: No.
7 COMMISSIONER SMITH: No, thank you.
8 COMMISSIONER KJELLANDER: Mr. Purdy, redirect?
9 MR. PURDY: Just one on redirect, Mr. Chair.
10
11 REDIRECT EXAMINATION
12
13 BY MR. PURDY:
14 Ms. Ottens, you were asked by Mr. Solander aboutQ.
15 ARRA and whether -- how much funding the State of Idaho
16 received and community action agencies allocated. Did the
17 CAPAI agencies fully spend out of ARRA funds?
18 A.Yes, they did.
19 Was Idaho one of the first states in the nationQ.
20 to spend out its ARRA funds?
21
24.25
A.Yes, we were, and that's why we qualified for the
22 addi tional 6.9 million, which will be spent out in the next
23 several months.
Q. And once ARRA is gone, do we have any certainty
as to future congressional action about LIWA -- Federal LIWA
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CAPAI
.
.
20
1 funds?
2 A.We do not, and the rumor that we are hearing now
3 is that it may be cut as much as 70 percent from the 2008
4 levels.
5 MR. PURDY: Thank you. That's all I have.
6 COMMISSIONER KJELLANDER: Thank you.
7 Ms. Ottens, we appreciate your testimony.
8 THE WITNESS: Thank you.
9 (The witness left the stand.)
10 COMMISSIONER KJELLANDER: And we'll move now to
11 Commission Staff. Mr. Price.
12 MR. PRICE: Yes, Commission Staff would call
13 Ms. Stacey Donohue to the stand.
14
15 STACEY DONOHUE,
16 produced as a rebuttal witness at the instance of the Staff,
17 being first duly sworn, was examined and testified as follows:
18
19 DIRECT EXAMINATION
21 BY MR. PRICE:
22 Q.Good morning. Can you please state your name and
23 spell it for the record?
24.25
A.Stacey Donohue. Donohue: D-O-N-O-H-U-E.
Q.And by whom and in what capacity are you
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DONOHUE (Di - Reb)Staff
.
.
20
21
22
23
24.25
1 employed?
2 A.I'm employed by the Idaho Public Utili ties
3 Commission as a utilities analyst.
4 Q.And, Ms. Donohue, did you have occasion to
5 prepare rebuttal testimony in this case, PAC-E-11-12, filed on
6 December 2nd of this year and consisting of 12 pages?
7 A.I did.
8 Q.And do you have any additions or corrections to
9 that testimony?
10 A.No, I do not.
11 MR. PRICE: With that, Chairman Kjellander, I
12 would move that Ms. Donohue i s rebuttal testimony be spread upon
13 the record as if read.
14 COMMISSIONER KJELLANDER: And without objection,
15 we'll spread the prefiled rebuttal testimony across the record
16 as if read.
17 (The following prefiled rebuttal testimony
18 of Ms. Donohue is spread upon the record.)
19
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DONOHUE ( Di - Reb)Staff
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25.
Q. Please state your name and business address for
the record.
A. My name is Stacey Donohue. My business address is
472 West Washington Street, Boise, Idaho.
Q. By whom are you employed and in what capacity?
A. I am employed by the Idaho Public Utilities
Commission as a Utilities Analyst in the Utilities Division,
focusing on demand-side management (DSM) issues and cases.
Q. What is your education, experience and background?
A. I received a B.A. in History from James Madison
University in 1999 and a Master's of Public Administration
(M.P.A.) from Boise State University in 2010. Prior to
joining the Commission Staff in 2010, I was employed as an
Energy Specialist at the Idaho Office of Energy Resources
where my main responsibility was managing the administration
of stimulus-funded grant projects. While completing my MPA,
I was hired by the Boise State University Department of
Public Policy and Administration to conduct survey research
and author a report on customer service and state-wide
interagency relationships for the Idaho Transportation
Department, which was presented to the ITO Board. I have
attended the New Mexico State University Center for Public
Utilities' course in Practical Regulatory Training, the
National Regulatory Research Institute's course on
"Electricity's Current Challenges", the International Energy
CASE NO. PAC-E-11-12
12-02-11 306 DONOHU, S. (Reb) 1
STAFF
Program Bvaluation Conference, as well as multiple web
trainings related to DSM issues. I serve on Idaho Power's
Bnergy Bfficiency Advisory Group (BBAG), Avista's Bnergy
Bfficiency Advisory and Technical Committees, and the
Regional Technical Forum's Policy Advisory Committee. In
addition, I have filed written comments or testimony
representing Staff's position in DSM related cases for all
three Idaho investor-owned utilities.
Q. What issues will you be addressing in your
testimony?
A. My testimony addresses the direct testimony of
CAPAI witness Teri Ottens' regarding her recommendation for
the Commission to increase Rocky Mountain Power's low income
program funding. I maintain that Ms. Ottens' definition of
low income funding level "parity" among Idaho electric
utilities does not justify the $77,517 funding increase she
recommends for Rocky Mountain Power. I further believe that
uncertainty regarding both program cost effectiveness and
overall need makes significant low income weatherization
funding increases premature in this case. I recommend that
workshops be immediately convened by interested parties to
develop consistent cost effectiveness criteria, identify
appropriate methods for measuring need, and establish
proportional funding levels.
CAB NO. PAC-B-11-12
12-02-11 307 DONOHUE, S. (Reb) 2
STAFF
While I agree with Ms. Ottens that funding for
Rocky Mountain Power' s Conservation Education (Con-Ed)
program for low income customers should be funded annually
at $50,000, I maintain that no further expenditures of this
allocation should occur after the end of the current program
year (March 2012) until the parties have agreed to a program
implementation plan for the Con-Ed program during the
previously described workshops.
Q. On pages 15 through 17 of her testimony, Ms.
Ottens defines Idaho electric utility "parity" as a
relatively equal low income weatherization funding level
based on a dollar per residential customer amount. Using
this definition, do you agree with Ms. Ottens' conclusion
that Rocky Mountain Power's funding level should increase by
26% (from $300,000 to $377,517 annually) to achieve "parity"
with Avista's current funding level?
A. No. Although I agree with Ms. Ottens that Rocky
Mountain Power and Idaho Power are funding their low income
programs at approximately $5. 32/customer and $3. 06/customer
respectively, I disagree with her conclusion that Avista's
per-customer funding level is at $6. 69/customer. Ms.
Ottens' testimony does not adequately consider that when the
Commission ordered Avista to spend $700,000 anually on low
income weatherization in Idaho, that amount was for both its
gas and electric low income weatherization programs. The
CAE NO. PAC-E-11-1212-02-11 308 DONOHUE, S. (Reb) 3
STAFF
.
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2
3
4
S
6
7
8
9
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12.13
14
15
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21
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25.
funding levels for Idaho Power and Rocky Mountain Power, on
the other hand, are only for those utilities' electric low
income weatherization programs. Ms. Ottens is, therefore,
over-stating Avista' s per customer funding level.
If Avista continues to spend 60% of its low income
program budget on electric measures, then (using Ms. Ottens'
methodology) the $420,000 budget divided by Avista's
105,286 electric residential customers (FERC Form No.1,
2010, pg. 304) equates to a $3.98/customer expenditure.
Accordingly, Rocky Mountain Power's low income investment of
$5.32/customer exceeds Avista's and does not justify an
increase on the premise of "pari ty", even as def ined by Ms .
Ottens.
Q. Do you agree that the Commission should seek to
attain parity among utilities as defined by Ms. Ottens?
A. No. It makes more sense to provide similar
funding based on relative need, not on the basis of total
residential utility customers as proposed by Ms. Ottens.
Requiring each utility to fund low income programs based on
the total number of residential utility customers is
arbitrary and does not account for differing levels of need
for low income weatherization in each utility's service
territory.
Q. Can you suggest a better method of comparing
funding levels among Idaho electric utilities?
CASE NO. PAC-E-11-1212-02-11 DONOHU, S. (Reb) 4
STAFF309
A. Yes. It would be better to compare proportional
funding levels among the utilities based on factors
measuring relative need for low income weatherization within
each utility's service territory. possible methods could
include the number of low income customers, number of homes
needing weatherization, and poverty rates. Ms. Ottens has
discussed these measures as an indicator of need, but does
not use them to calculate funding levels. Al though these
suggestions are a reasonable starting place for discussions,
determining equitable funding levels is a complicated issue
that would be best resolved through the previously mentioned
workshops.
Q. Does Staff have any concerns about the cost-
effectiveness of Rocky Mountain Power's low income
weatherization program?
A. Yes. In Case No. PAC-E-11-13 referenced by Ms.
Ottens, a post-implementation evaluation of Rocky Mountain
Power's low income program conducted by an independent third
party evaluator revealed problems with program delivery,
oversight, and cost effectiveness. While Staff did not
agree with all the methods or conclusions of the evaluation,
the evaluation did identify possible problems with the cost-
effectiveness of Rocky Mountain Power's program which should
be investigated and resolved before any funding increase is
granted.
CASE NO. PAC-E-11-1212-02-11 310 DONOHUE, S. (Reb) 5
STAFF
Q. Do these concerns extend to the other utility-
funded low income weatherization programs in Idaho?
A. Yes, Staff has identified problematic
inconsistencies among Idaho's utility-funded low income
programs. Avista published a process review of its low
income program in 2011 and Idaho Power plans to complete a
post implementation evaluation of its low income
weatherization program in 2012, but is it clear that all
three utilities have very different standards for measuring
energy savings, recording measure level data, providing
oversight of Community Action partnership ("CAP") agencies,
and calculating cost effectiveness.
For example, all low income programs should
capture and analyze measure level data from the CAP agencies .
so that the list of measures eligible for utility
reimbursement can be effectively analyzed for cost
effectiveness, and if necessary, modified. Currently,
utilities capture wide ranging amounts and types of data
from the CAP agencies, which negatively impacts program
implementation decisions. This and other discrepancies
should be resolved so that Staff, CAPAI, and the utilities
have a clear understanding of expectations surrounding
program management and cost-effectiveness calculations
before more funds are invested.
CASE NO. PAC-E-11-12
12-02-11 311 DONOHUE, S. (Reb) 6
STAFF
Q. What are Staff's concerns regarding cost-
effectiveness calculations?
A. Staff is concerned that the three companies
calculate the cost effectiveness of their low income
programs very differently. While there should be some
flexibility within the methodological details to account for
different circumstances, there should also be common,
general parameters for cost effectiveness calculations
between such similar programs.
In particular, all three utilities measure energy
savings differently. Rocky Mountain Power uses a billing
analysis, Avista uses deemed savings per measure, and Idaho
Power uses an energy audit analysis to measure energy
savings. None of these methods are necessarily wrong.
However, they all have substantial shortcomings, which can
include significant over or under-estimation of savings. It
is impossible to accurately assess a program's cost
effectiveness¡ and how to improve it if necessary, until the
disparate views on how to measure energy savings are
resolved.
In addition, there is wide discrepancy on whether
and to what extent non-energy benefits should be included in
the cost effectiveness analysis. Idaho Power does not
include any, but Avista and Rocky Mountain include some
limited and quantifiable non-energy benefits. Avista and
CASE NO. PAC-E-11-12
12-02-11 312 DONOHUE, S. (Reb) 7
STAFF
.
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12.13
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23
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25.
Rocky Mountain also include a 10% conservation preference
adder to their low income programs, which Idaho Power does
not include. Disparate methodologies make it difficult, if
not impossible, to draw conclusions about cost effectiveness
among similar programs when the benefits of each are
quantified so differently.
Q. Ms. Ottens justifies increasing Rocky Mountain
Power's low income funding by $77,517 per year citing
statistics in her testimony including rising poverty rates,
the termination of American Recovery and Reinvestment Act
(ARRA) funding, and the backlog of low income weatherization
eligible customers. Do you disagree that the economy has
impacted the number of low income customers and their
ability to pay electric bills?
A. No. Staff disagrees that this information alone
can identify program need or proper funding level. Without
proper program implementation and evaluation to determine
cost effectiveness, it is impossible to determine if the
existing program is a reasonable expenditure of ratepayer
funds.
Q. Has the Commission recently increased the funding
level for Rocky Mountain's low income weatherization
program?
A. Yes. The Commission issued Order No. 32196 on
February 28, 2011 in Case No. PAC-E-10-07 increasing Rocky
CASE NO. PAC-E-11-12
12-02-11 313 DONOHUE, S. (Reb) 8
STAFF
Mountain's low income weatherization funding level from
$150,000 to $300,000, an increase of 100%.
Q. On page 8 of her testimony, Ms. Ottens indicates
that Rocky Mountain Power Case No. PAC-E-11-13, in which the
Company asked to discontinue evaluations of its low income
program because of cost effectiveness problems, "cast a
shadow over the legitimacy of all low-income weatherization
programs in the state. .U Is she correct?
A. Yes, in part. In that case, Staff had serious
concerns about the implementation and evaluation of the
Rocky Mountain Power's low income program, including program
cost effectiveness. In addressing these issues, Staff had
the following comments:
Staff further believes there needs to be a common
understanding and approach with respect to how
utilities implement, evaluate, measure and verify
programs targeted to low income customers. The
Commission Staff, utilities, stakeholders, and other
interested parties would greatly benefit from such an
understanding. Similarly ,interested parties could
come to agreement with respect to how utilities
should manage programs and what degree of oversight
is necessary.
In pursuit of this, Staff recommends that the
Commission host an informal workshop as soon as
possible so that all interested parties can partici-
pate in a collaborative discussion about the issues
surrounding low income weatherization programs.
Workshop objectives include developing a deeper
understanding of the issues, explor (ingJ ways to
resolve those issues, and finally, developing an
action plan that creates greater certainty regarding
the implementation and evaluation of low income
weatherization programs. This workshop will allow
Rocky Mountain and the other utilities to consider
CASE NO. PAC-E-11-1212-02-11 314 DONOHUE, S . (Reb) 9
STAFF
ways to enhance the cost-effectiveness of existing low
income weatherization programs and/or create new
programs that target low income customers. At the
conclusion of the workshop, Staff will provide the
Commission with a report which will, at a minimum,
identify the agreements reached and recommendations
for future Commission action.
Additionally, in Case No. AVU-E/G-11-01, Staff
supported a Stipulation and Settlement that called for the
following:
The Company and interested parties will meet and
confer prior to the Company's next general rate
filing in order to assess the Low Income Weatheri-
zation and Low Income Energy Conservation Education
Programs and discuss appropriate levels of low- income
weatherization funding in the future.
In testimony supporting the stipulation in that case,
Staff witness Lobb stated:
Staff believes it is time to discuss all issues
associated with the Company's low income weatheriza-
tion program to assure the program is cost effective,
that it remains cost effective and that sufficient
funds based on need are made available.
In rebuttal testimony in Idaho Power Case No.
IPC-E-11-08, I recommended that Idaho Power be included in
the workshops approved in Avista Case No. AVU-E/G-11-01 and
proposed in Rocky Mountain Power Case No. PAC-E-11-13.
Q. On page 22, Ms. Ottens refers to an issue raised
but not resolved in Rocky Mountain Power's last general rate
case, PAC-E-10-07. CAAI maintains that the $50,000 funding
for the Con-Ed program should be provided on an annual
basis, while Rocky Mountain Power maintains that it was one-
CAE NO. PAC-E-11-1212-02-11 315 DONOHUE, S. (Reb) 10
STAFF
.
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25.
time funding. Do you agree with CAPAI that the $50,000
funding for Con-Ed should be an annual amount?
A. Yes, but with one important caveat. Rocky
Mountain Power should budget $50,000 annually for the Con-Ed
program, but the Company should not make any further
expenditures in the program after the end of the current
program year (March 2012) until the parties involved in the
workshops agree on a plan for program implementation. The
delay between funding order and expenditure is necessary
because CAPAI has been slow to implement and expend funds in
the past, which raises legitimate questions about the
appropriate funding level. Since Idaho Power and Avista
also fund Con-Ed programs, a consistent and effective
implementation strategy should be another topic resolved at
the workshop.
Q. What is your recommendation in this case?
A. I recommend that the Commission maintain the
current funding level for Rocky Mountain Power's low income
program recently approved in Case No. PAC-E-10-07 rather
than approve the additional 26% increase in this case as
proposed by CAPAI. I further recommend that the Commission
consolidate the low income workshops approved in Avista Case
No. AVU-E/G-11-01 and proposed in Rocky Mountain Power Case
Nos. PAC-E-11-12, PAC-E-11-13, and Idaho Power Case No.
IPC-E-11-08 to resolve issues relating to utility low income
CASE NO. PAC-E-11-12
12-02-11 316 DONOHUE, S. (Reb) 11
STAFF
programs. These issues include consistent implementation
methodology and cost effectiveness evaluation,
identification of non-energy benefits, proper determination
of need, appropriate levels of annual low income funding,
and Con-Ed program design. CAPAI's request for a funding
increase for Rocky Mountain Power's low income
weatherization program should be considered after the
consolidated workshop has resolved administration and cost
effectiveness issues.
I also recommend that the Commission order Rocky
Mountain Power to fund its Con-Ed program at $50,000
anually, but that funding not be expended until the
previously described workshops have reached agreement on
program design and implementation plans.
Q. Does this conclude your testimony in this
proceeding?
A. Yes, it does.
CAE NO. PAC-E-11-12
12-02-11 317 DONOHUE, S. (Reb) 12
STAFF
.
.
.
20
1 (The following proceedings were had in
2 open hearing.)
3 MR. PRICE: And I would present this witness for
4 cross-examination.
5 COMMISSIONER KJELLANDER: Thank you. Let's begin
6 wi th Rocky Mountain Power.
7 MR. HICKEY: We have no questions, thank you.
8 COMMISSIONER KJELLANDER: Mr. Budge.
9 MR. BUDGE: No questions.
10 COMMISSIONER KJELLANDER: Mr. Williams.
11 MR. WILLIAMS: No questions.
12 COMMISSIONER KJELLANDER: Mr. Olsen.
13 MR. OLSEN: No questions.
14 COMMISSIONER KJELLANDER: Mr. Purdy.
15 MR. PURDY: Than k you.
16
17 CROSS-EXAMINATION
18
19 BY MR. PURDY:
Q.Good morning, Ms. Donohue. First, I wanted to
21 ask you -- and I'll refer you to page 3 of your testimony
22 just generally regarding your criticism of Ms. Ottens' attempt
23 to compare the relative funding levels of the three Utilities
24
25
on a per-capita basis. Do you know if this is the basis that
Communi ty Action has been using for a number of years now in
318
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DONOHUE (X-Reb)Staff
.
.
20
1 interventions before this Commission to set LIWA funding?
2 A.It's been my understanding that it's been
3 Community Action's funding methodology.
4 Q.And do you know if the Commission has ever
5 rej ected this principle of parity in per-capita funding?
6 A.I don't think they have ever rej ected it or
7 explicitly approved it.
8 Q.Fair enough, thank you. You are -- and if you
9 need a reference, page 4 of your testimony, line 16. Am I
10 correct in characterizing your testimony as, in your opinion,
11 completely rej ecting the notion of parity or the desire to
12 achieve parity as a principle?
13 A. I don't think that it's the most useful funding
14 metric.
15 Q.Well, is that an entire rej ection or
16 qualification?
17 MR. PRICE: Objection: Argumentative. I think
18 she's answered that question.
19 COMMISSIONER KJELLANDER: Mr. Purdy.
MR. PURDY: She didn't actually answer the
21 question was it a rej ection or "yes" or "no."
22 COMMISSIONER KJELLANDER: Do you want to try
23 again?
24.25
MR. PURDY: Sure.
COMMISSIONER KJELLANDER: Okay.
319
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DONOHUE (X-Reb)Staff
.
.
1 Q.BY MR. PURDY: Are you stating -- is it your
2 testimony that you entirely disregard any value of the
3 principle of parity, or just that it's not your most important
4 consideration?
5 A.It's not the most important consideration, and I
6 would -- it may be helpful in some respect to include it as a
7 measure of proportionality.
8 Q.Okay. Thank you. And then on page 5, line 1, I
9 think you provide what you think might be a better benchmark to
utilize.Do you see that?
A.My testimony recommends several possible methods.
Q.Okay.I just wanted to ask you about those.
Beginning on line 1 of page 5 and about halfway down the page,
10
11
12
13
14 you refer to relative need for low-income weatherization, and
15 the way to arrive at this would be to include the number of
16 low-income customers, number of homes needing weatherization,
17 and poverty rates. Is that right?
18 A.Yes.
19 Q.My question is simply isn't that what we're
20 already doing, and isn't that what the Commission has taken
21 into consideration and Community Action has proposed in past
22 cases?
23
24.25
A.No.
Q.And how is it not?
A.Communi ty Action has used it as evidence of need.
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1 Staff is recommending that we use it as a method for
2 determining what the funding should be.
3 Q. All right, evidence of versus method of
4 determining. It seems, to me, either way we're talking about
5 the same benchmarks that we need to look to.
6 A.No. CAPAI wants to use a per-customer count to
7 determine a dollar funding level. Staff would rather use a
8 metric such as poverty rates, unemployment, a backlog list to
9 the extent it could be accurately determined, to determine
10 funding levels for each Utility.
11 Q.And is that metric spelled out in a way that it's
12 quantified in your testimony?
13 A.Which metric?
14 Q.The one you were just referring to.
15 I haven't proposed a specific metric. In fact, IA.
16 specifically did not propose a specific metric. I recommended
17 that this subj ect be taken up in the collaborative workshops.
18 Q.Okay. And, in fact, I think that on -- if you
19 look at page 5, line 4, you do concede that Ms. Ottens has
20 discussed these measures as an indicator of need -- again
21 referring to number of low-income customers' homes needing
22 weatherization and poverty -- and it's a reasonable starting
23 place.
24.25
I guess what I'm trying to get at is what special
formula or benchmark would be arrived at by a vast array of
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24.25
1 interests -- three different Utili ties at least, Staff,
2 Communi ty Action, other interested parties -- in a workshop
3 where we could come up with a one-size-fits-all formula? How
4 realistic is that if we haven't been able to do it up until
5 now?
6 A.Seems pretty realistic to me. It seems, to me,
7 that CAPAI has also proposed a one-size-fits-all with its
8 per-capi ta calculation.
9 Q.Okay. All right. But -- strike that.
10 Why hasn't Staff, prior to this point in time,
11 taken the position that you're taking in your testimony?
12 A.I don't know. I didn't work on the last Rocky
13 Mountain rate case. My -- I imagine that when cost
14 effectiveness is not an issue, that none of the parties look
15 extremely closely at these issues.
16 Q.I'm sorry, I didn't hear the last part.
17 A.When cost effectiveness is not an issue, that
18 these things probably get less examination than they do when
19 cost effectiveness is determined to be a problem.
20 Q.And has the Commission determined cost
21 effecti veness to be a problem for Rocky Mountain?
22 A.No.
Q.Okay. And on -- still on page 5, referring you
to line 13 of your testimony, you state that you do not
necessarily agree with all of the methods or conclusions used
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1 or arrived at in the Cadmus evaluation. Is that right?
2 A.Yes.
3 Q.Okay. Yet if I understood you correctly, you've
4 testified that Cadmus itself, the formula they used, wasn't
5 necessarily inherently wrong. Is that right?
6 A.Can you point me to a page and line?
7 Q.No, I can't, so I'll just ask you do you think
8 that the Cadmus evaluation protocol that is used, as the
9 industry goes, is necessarily wrong?
10 MR. PRICE: I would obj ect to that question,
11 Chairman. I think the reason why he can't cite to a page and
12 line number is because it's testimony from another case. It's
13 beyond the scope of her testimony in this case.
14 MR. PURDY: Might be from another case, that's
15 why I asked her the question: Is that her position.
16 COMMISSIONER KJELLANDER: And I think your
17 obj ection still stands --
18 MR. PRICE: Yes.
19 COMMISSIONER KJELLANDER: -- because it's not a
20 part of the direct testimony, and I'm going to sustain the
21 objection.
22 MR. PURDY: Okay.
23 Q.BY MR. PURDY: Do you agree with the evaluation
24 methodology used by Cadmus for Rocky Mountain in this case?
25 MR. PRICE: Again, I renew my obj ection. It's
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21
1 beyond the scope of her rebuttal testimony in this case.
2 COMMISSIONER KJELLANDER: Mr. Purdy, can you find
3 any reference in the rebuttal testimony?
4 MR. PURDY: Mr. Chair, it is a thread that is so
5 woven throughout her testimony in this case that it refers to
6 the Cadmus evaluation case that it's difficult not to point to
7 a spot.
8 COMMISSIONER KJELLANDER: Then, Mr. Purdy, if the
9 thread is so woven within that, then please find some reference
10 wi thin the testimony.
11 MR. PURDY: Yeah, sure. You bet.
12 Q.BY MR. PURDY: Okay, let's go back to page 2,
13 line 18, and you state there -- or, actually, beginning on
14 line 17: I further believe that uncertainty regarding program
15 cost effectiveness.
16 What uncertainty are you referring to?
17 MR. PRICE: I obj ect again that she has not taken
18 a position as to the cost effectiveness of the Cadmus study in
19 this testimony.
MR. PURDY: It's her testimony.
COMMISSIONER KJELLANDER: I believe he just
22 referenced a specific question about a direct line wi thin the
23 testimony, and I do believe it's a fair question to ask.
24.25
MR. PRICE: Okay.
THE WITNESS: Can you repeat the question?
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21
1 Q.BY MR. PURDY: Oh. On page 2, line 17 and 18,
2 when you testify "I further believe that uncertainty regarding
3 program cost effectiveness," what uncertainty are you referring
4 to?
5 A.We're uncertain that the program is cost
6 effecti ve.
7 Q.Why?
8 A.Well, first of all, there was an evaluation
9 recently conducted.
10 Q.In what case?
11 A.In PAC-E-11-13.
12 Q.Okay. Thank you. So that's what's causing you
13 uncertainty?
14 A.I wasn't quite finished.
15 That evaluation is causing uncertainty as to the
16 cost effectiveness of Rocky Mountain's low-income program
17 because the program is not cost effective unless nonenergy
18 benefi ts are included. However, Cadmus's calculation of
19 nonenergy benefits is unclear, at best.
Q.Okay.
A.In addition, the Cadmus evaluation is
22 overestimating savings by 25 percent by including LOO percent
23 of the savings associated with the program, even though Rocky.24 Mountain only paid for 75 percent of the measures.
25 Q.And so it sounds like you have criticisms both
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1 ways with respect to the Cadmus study. Is that fair?
2 A."Both ways." Can you clarify that?
3 Q.Well, such that it might support the notion that
4 low-income weatherization is not cost effective, or calling
5 into question whether that conclusion is erroneous.
6 A.No, I think you misunderstood my answer. I'm
7 saying there are two very significant ways in which the cost
8 effectiveness numbers may be overstated.
9 All right. You don't mention in this caseQ.
10 you're referring to, the 11-13 case, you don't mention
11 Communi ty Action's comments or the analysis filed by
12 Mr. Roger Col ton. Did you review that analysis and those
13 comments?
14 MR. PRICE: Obj ect again. This is getting a
15 li ttle far afield. It's one thing to comment on how that case
16 relates to this case. It's quite another to testify regarding
17 an expert report of that Cadmus study in this case.
18 MR. PURDY: Mr. Chair.
19 COMMISSIONER KJELLANDER: Mr. Purdy.
20 MR. PURDY: I do have a response to that.
21 You know, this is just, first -- the Cadmus case
22 was the finger knocking over the first domino, and that's been
23 the effect that this Cadmus evaluation has had not only on this.24 rate case but on the Idaho Power case, had an effect in the
25 Avista case. If you look at page 5 of Ms. Donohue's testimony,
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1 she cites 11-13 case and goes into detail about the evaluation
2 process. It's a linchpin for her position on decreasing LIWA
3 funding in this case. It's not a trick question.
4 MR. PRICE: I guess it just depends on how far
5 the Commission would like to go. Mr. Purdy has had an
6 opportunity in the 11-13 case.
7 COMMISSIONER KJELLANDER: But this is this case,
8 so let's allow a little bit of leeway and see what responses we
9 get. I think the witness is very capable of responding to the
10 questions that Mr. Purdy puts forward.
11 BY MR. PURDY: Do you recall my question?Q.
12 A.No.
13 My question was simply did you reviewQ.
14 Mr. Colton's analysis or Community Action's comments in the
15 11-13 case?
16 A.I did.
17 And just can you give us a general idea of whatQ.
18 you think about Mr. Col ton's analysis?
19 I thought he made some pretty good points.A.
20 Okay. That could tip the scales back toward theQ.
21 direction of Rocky Mountain's program being cost effective. Is
22 that right?
23 It could. However, he didn't do any additionalA.
24 actual number crunching to see what proposed changes to the
25 Cadmus evaluation, how those changes would result in changing
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1 the cost effectiveness ratios one way or another. He did not
2 discuss how much time, effort, or money it would require to
3 make those changes and collect the additional data if
4 necessary.
5 He also did not discuss Rocky Mountain claiming
6 100 percent of the savings associated with the program rather
7 than the 75 percent of the savings they generated by funding
8 75 percent of the measures.
9 Q.And Staff didn't run any numbers either. Isn't
10 it true that one would need to be in possession of the data --
11 excuse me used by Cadmus in its evaluation?
12 A.It is.
13 Q.And do you disagree with the notion that perhaps
14 Rocky Mountain didn't provide -- did not provide -- the right
15 quanti ty and type of data necessary to make a proper
16 evaluation?
17 A.Provide to --
18 Q.Cadmus.
19 A.I would agree that they did not provide all the
20 necessary information.
21 Q.Thank you. On page 6, beginning on line 5, you
22 talk about the Idaho Power I guess upcoming WAQC evaluation in
23 the year 2012. Right?
24 A. Yes.
25 Q.My question is simply this, Ms. Donohue : Given
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.1 your recommendation to engage in workshops sometime I would
2 assume it would have to be in 2012 given today' s date, how
3 would it work with an ongoing workshop case and an ongoing
4 Idaho Power low-income weatherization evaluation case? How
5 would that sync up?
6 A.Is there an Idaho Power low-income evaluation
7 case going on right now?
8 Q.I'm sorry, if I said "case," it's their
9 evaluation itself.
10 A.Is there an evaluation of Idaho Power's
11 low-income program going on right now?
.13
Q.
A.
Q.
A.
Q.
Idaho Power
2012?
A.
Q.
No.
Were you here during the Idaho Power hearing?
I was.
And did you hear Ms. Theresa Drake testify that
intended to conduct a WAQC evaluation sometime in
I heard her say sometime in 2012.
Okay. So assuming that's the case back to my
14
15
16
17
18
19
20
21 original question how would that process sync up with the
22 workshop process? In other words, wouldn't Idaho Power need to
23 evaluate its program after the workshops were done; because
.24 otherwise, if the workshops come to an entirely different
25 approach to evaluation, Idaho Power would have wasted its time.
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1 Isn't that right?
2 A.No, because if you have the workshops going on,
3 let's say, the first quarter of 2012, and then Idaho Power and
4 you -- what I hear is that you proposing Idaho Power pushing
5 back its evaluation to the -- to sometime in the future after
6 whatever changes come out of the workshop are applied to Idaho
7 Power's program --
8 Is that what you're suggesting, that their
9 evaluation be pushed back further than sometime in 2012?
10 Q.No, I'm not suggesting anything in terms of the
11 timing of their evaluation. I'm just suggesting to you that it
12 might make more sense to the Company to wait until an
13 evaluation protocol has been established before evaluating its
14 own program. Isn't that just logically obvious?
15 MR. PRICE: Objection: Vague. "Logically
16 obvious"? I don't know if that's properly formatted.
17 MR. PURDY: That is objectionable, I agree.
18 Q.BY MR. PURDY: But logically obvious or not, can
19 you understand what I'm saying?
20 A.No.
21 Q.Not at all. Okay. All right.
22 So if Idaho Power starts evaluating its WAQC
23 program on January 1st, you -- or, 2nd, excuse me -- and you,
24 Staff, the Commission, all interested parties conduct a
25 workshop on January 2nd and in the workshop we talk about the
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21
1 proper way to evaluate WAQC and it's something over on this
2 side, and Idaho Power meanwhile is evaluating WAQC by paying a
3 lot of money to a third-party contractor and doing it through a
4 methodology that's over on that side
5 MR. PRICE: Obj ection. I'm anticipating a
6 question sometime in the near future.
7 Q.BY MR. PURDY: -- what is the --
8 MR. PRICE: First, I registered an obj ection
9 regarding the inclusion of the 11-13 case, and now we're
10 getting into the Idaho Power evaluation. I just think it's way
11 beyond the scope of this witness's testimony.
12 COMMISSIONER KJELLANDER: Mr. Purdy.
13 MR. PURDY: You know what, I'll withdraw,
14 Mr. Chairman. Thank you.
15 Q.BY MR. PURDY: On page 6, lines 13 through 24, of
16 your testimony, specifically, down on line 20, you talk about
17 discrepancies between the three LIWA programs. Is that
18 right?
19 A.Yes.
Q.What discrepancies are you referring to?
A.The main discrepancy that I think needs some
22 consideration is how each of the Companies measure -- estimates
23 energy savings generated by their low-income programs.
24
25
Q.And then on page 7, line 1, you start discussion
about concerns over the different cost effectiveness
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1 evaluations. Is that right?
2 A.Well, I actually start discussing concerns about
3 cost effectiveness calculations, which is different than
4 evaluations.
5 Q.Fine. Okay. So given these discrepancies and
6 these differences, how realistic is it that we're going to come
7 up with some type of a reasonably similar methodology for the
8 three Utilities in a workshop forum?
9 A.Very realistic.
10 Q.Okay. You based that on what experience with
11 workshops?
12 A.I based that on my discussions with all three
13 Utili ties and CAPAI' s testimony that they would be happy to
14 engage in workshops if that's the Commission's Order.
15 Q.What discussions did you have with all three
16 Utilities?
17 A.I believe -- I had a couple of phone calls to
18 clarify what I was reading in their DSM report.
19 Q.Okay.
A.And I believe they said that they would be
21 int-
22 Q.Sorry. "Couple of phone calls." So are you
23 familiar--
24.25
MR. PRICE: Objection. I'd like her to have the
opportunity to finish her answer before he starts in another
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20
1 question, if that's --
2 MR. PURDY: I thought she was done, I'm sorry.
3 COMMISSIONER KJELLANDER: Please continue, if
4 there's any more to that response.
5 THE WITNESS: There was no more.
6 COMMISSIONER KJELLANDER: Okay.
7 Q.BY MR. PURDY: Do you know generally or are you
8 familiar with the generic low-income energy affordabili ty
9 workshop case in 2008 conducted before the Commission?
10 A.Not in detail.
11 Q.Do you know whether that case resulted in any
12 low-income weatherization funding changes or excuse me,
13 changes or low-income program implementation of any sort?
14 A.I don't know what the intent of that workshop
15 was, and I do not know what the result was.
16 Q.Do you know if Community Action was -- if
17 Communi ty Action requested intervention in that case and was
18 rejected by the Commission?
A.I do not know.
Q.All right. I should say the Petition rej ected,
21 not Community Action itself.
22 And in terms of your workshop proposal, how do
23 you propose laying that out in terms of the time line and what.24 tasks would be hopefully accomplished by what dates?
25 A.I haven't proposed any time line.
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21
22
1 Q.Huh. So what are we to do then with your
2 recommendation?
3 A.I imagine you would wait for a Commission Order
4 and find out if they want us all to engage in workshops, and I
5 imagine they would give us a starting date.
6 Q.So you have no time line or agenda in mind for
7 the workshops you propose in your testimony?
8 A.I have outlined a couple of items that I think
9 would be important to include in the agenda, and I would be
10 happy to start workshop proceedings if the Commission orders as
11 soon as early January.
12 Q.All right.
13 MR. PURDY: One second if I may? Thank you.
14 That's all I have. Thank you, Ms. Donohue.
15 COMMISSIONER KJELLANDER: Are there any questions
16 from members of the Commission?
17 COMMISSIONER REDFORD: No.
18 COMMISSIONER SMITH: No, thank you.
COMMISSIONER KJELLANDER: Redirect.
MR. PRICE: No redirect for this witness.
COMMISSIONER KJELLANDER: No redirect.
Okay, Ms. Donohue, you're excused. Don't wander
23 too far, just in case.
24.25
(The witness left the stand.)
COMMISSIONER KJELLANDER: We are now at noon. We
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1 have one witness left. So let me just ask if we anticipate
2 that this will be lengthy as far as the questions.
3 MR. PURDY: I don't think so. I do have a few
4 policy questions for Mr. Lobb, but I -- that's it. I don't
5 think it will take long.
6 COMMISSIONER KJELLANDER: So I think we're
7 getting an indication everybody would just like to plow
8 through. Very good, we'll move forward.
9 MR. PURDY: Okay.
10 MR. PRICE: Commission Staff calls Mr. Randy Lobb
11 to the stand.
12
13 RANDY LOBB,
14 produced as a witness at the instance of the Staff, being first
15 duly sworn, was examined and testified as follows:
16
17 DIRECT EXAMINATION
18
19 BY MR. PRICE:
20
21
22
Q.Please state and spell your name for the record.
A.My name is Randy Lobb, L-O-B-B.
Q.And by whom and in what capacity are you
23 employed?
24.25
A. I'm employed by the Idaho Public Utilities
Commission as the utilities division administrator.
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1 Q.And, Mr. Lobb, did you have occasion to prepare
2 direct testimony in support of the Stipulation and settlement
3 reached in Case No. PAC-E-11-12, which represents 23 pages and
4 includes an Attachment, Exhibit No. 101?
5 A.And I believe I had 102 as well.
6 Q.I'm sorry, including 102.
7 A.Yes, I did.
8 Q.And do you have any additions or corrections to
9 that testimony?
10 A.I do not.
11 Q.And if I were to ask you the same questions today
12 as were asked in your testimony, would your answers be the
13 same?
14 A.Yes, they would.
15 MR. PRICE: At this time, I would move that
16 Mr. Lobb' s testimony in support of the settlement and
17 Stipulation be spread across the record as if read.
18 COMMISSIONER KJELLANDER: Without obj ection, then
19 we would spread the prefiled testimony of Mr. Lobb across the
20 record along with Exhibits 101 and 102 as if read.
21 (The following prefiled direct testimony
22 of Mr. Lobb is spread upon the record.)
23
24
25
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~.
1
2
3
4
5
6
7
8
9
10
11
12.13
14
15
16
17
18
19
20
21
22
23
24
25.
Q. Please state your name and business address for the
record.
A. My name is Randy Lobb and my business address is
472 West Washington Street, Boise, Idaho.
Q. By who are you employed?
A. I am employed by the Idaho Public Utilities
Commission as Utilities Division Administrator.
Q. What is your educational and professional
background?
A. I received a Bachelor of Science Degree in
Agricultural Engineering from the University of Idaho in 1980
and worked for the Idaho Department of Water Resources from
June of 1980 to November of 1987. I received my Idaho
license as a registered professional Civil Engineer in 1985
and began work at the Idaho Public Utili ties Commission in
December of 1987. I have conducted analysis of utility rate
applications, rate design, tariff analysis and customer
petitions. I have testified in numerous proceedings before
the Commission including cases dealing with rate structure,
cost of service, power supply, line extensions i regulatory
policy and facility acquisitions. My duties at the
Commission currently include case management and oversight of
all technical Staff assigned to Commission filings.
Q. What is the purpose of your testimony in this case?
A. The purpose of my testimony is to describe the
CASE NO. PAC-E-11-1211/02/11
337 LOBB, R. (Stip) 1
STAFF
..
1
2
3
4
5
6
7
8
9
10
11
12.13
14
15
16
17
18
19
20
21
22
23
24
25.
comprehensive settlement reach by most of the parties to the
case and explain Staff's support.
Q. Please summarize your testimony.
A. Staff supports the Stipulated Settlement proposing
a two-year rate plan that recovers a limited level of capital
expendi tures and an increasing level of power supply costs
through a combination of base rate increases and Energy Cost
Adjustment Mechanism (ECAM) surcharges. Staff believes that
the comprehensive multi-year approach to resolving revenue
requirement represents a significantly better deal for
customers than could be achieved through either a one year
settlement, litigation of the current rate case, or
resolution of additional rate filings in 2012.
Staff further supports provisions of the
Stipulation that spread the revenue increase to customer
classes based in part on cost of service, generally increases
rate components on a uniform basis, addresses Populous to
Terminal transmission costs and provides resolution of
Monsanto interruptible credit valuation over the next two
years.
Q. How is your testimony organized?
A. My testimony is subdivided under the following
headings:
Stipulation Overview
The Settlement ~rocess
Page 3
Page 6
CASE NO. PAC-E-11-1211/02/11 338 LOBB, R. (Stip) 2
STAFF
.
1
2
3
4
5
6
7
8
9
10
11
12.13
14
15
16
17
18
19
20
21
22
23
24
25.
Staff Evaluation Page 8
Cost of Service Page 16
Rate Design Page 17
ECA Issues Page 18
Other Items Page 20
Stipulation Overview
Q. Would you please describe the terms of the
Stipulation?
A. Yes. The Stipulation specifies a two-year rate
plan increasing base rates by $17 million (7.8%) in year one
and $17 million (7.2%) in year two. The base rate increase
proposed to take effect on January 1, 2012 and January 1,
2013 consists of an $11 million increase in Net Power Supply
Expenses (NPSE) and a $6 million increase in non-NPSE each
year. This compares with the Company's original proposal of
increasing base rates by $32.7 million (15%) in one year.
While the Stipulation represents a comprehensive
settlement, it does not provide agreement or acceptance of
specific revenue requirement adjustments or cost of service
methodology. However, it does incorporate all Commission
ordered adjustments from Case PAC-E-10-07, Order No. 32196.
The Stipulation specifically identifies base NPSE
in 2012 and 2013 for use in the ECA including annual
Renewable Energy Credit (REC) revenue and establishes a load
change adjustment rate (LCAR) for the rate period. The
Stipulation also specifies how Monsanto and Agrium's share of
CASE NO. PAC-E-11-12
11/02/11
339 LOBB, R. (Stip) 3
STAFF
.
1
2
3
4
5
6
7
8
9
10
11
12.13
14
15
16
17
18
19
20
21
22
23
24
25.
ECAM deferral balances will be amortized and collected
through 2014.
The Stipulation further specifies spreading the
revenue increase to customer classes based, in part, on the
Company's proposed Cost of Service (COS) Study. The parties
agreed to a 25% move toward COS each year of the rate plan as
part of the proposed settlement in this case without
accepting the Company's COS methodology for revenue
allocation in the future. The parties also agreed that rate
component changes within individual customer classes will be
prorated based on the original proposal filed by the Company.
However, customer charges for Residential Schedules 1 and 36
would remain unchanged.
Other terms in the Stipulation include: 1)
escalation in the current Monsanto curtailment product value
by .. million each year of the two-year plan; 2) agreement
on the used and useful nature of the Populous to Terminal
Transmission line (including dismissal of the pending Idaho
Supreme Court appeal and excluding that portion of the line's
cost deemed plant held for future use (PHFU) from rate base
until January 1, 2014); 3) continued deferral of depreciation
expense associated with the Populus to Terminal transmission
line, pursuant to Order No. 32224; and 4) tracking Idaho's
share of the customer load control service credi t through the
ECA at the base amount of $1,045,423 pending cost allocation
CASE NO. PAC-E-11-1211/02/11 340 LOBB, R. (Stip) 4
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treatment of the dispatchable irrigation load control
program.
Finally, the Stipulation specifies a series of
collaborative meetings to address: 1) terms, conditions and
valuation of Monsanto's curtailment products; 2) cost of
service methodologies as applied to Monsanto and the
irrigation class and how said methodologies will be utilized
in the next general rate case; 3) terms of the irrigation
load control program for the 2013 season and beyond; 4)
hedging limits consistent with workgroup processes
established in Utah and Oregon.
The Stipulation specifies that Rocky Mountain Power
will not file another general rate case before May 31, 2013,
with new rates not effective prior to January 1, 2014. The
Stipulation does not prohibit the Company from revising rates
as part of its annual ECAM filing. The Stipulation is
attached as Staff Exhibit No. 101.
Q. How does the annual base revenue requirement
increase proposed in the Stipulation compare to the increase
originally proposed by Rocky Mountain Power?
A. As noted above, the Company proposed to increase
annual base electric revenue in 2012 by $32.7 million or 15%
overall. The Stipulation increases annual base electric
revenue by $17 million in 2012 or approximately 52% of the
Company's original request. The Company did not propose a
CASE NO. PAC-E-11-12
11/02/11
341 LOBB, R. (Stip) 5
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base rate increase in 2013 as part of its filing in this
case.
The Settlement Process
Q. Would you please describe the process leading to
the Stipulated Settlement?
A. Yes. The Company filed its rate application on May
27, 2011 and the Commission set a June 21, 2011 intervention
deadline. Parties ultimately approved for intervention
included the Monsanto Company, the Idaho Irrigation Pumpers
Association (IIPA), pacifiCorp Idaho Industrial Customers
(PIIC), the Community Action Partnership Association of Idaho
(CAPAI) and the Idaho Conservation League (ICL).
Once the parties to the case were determined, they
met to establish a schedule for production
requests/responses, pre-filed direct testimony, pre-filed
rebuttal testimony and the dates for the technical hearing.
The parties also established August 23, 2011 and September
22, 2011 as Settlement conference dates.
During the period prior to the first Settlement
conference, Staff thoroughly reviewed the Company's rate
filing and conducted onsite audit of Company expenses and
investments. In addition, Staff met informally with the
Company and other parties to discuss a variety of issues in
preparation for settlement negotiations. Issues discussed
included potential expense adjustments, increasing NPSE and
CASE NO. PAC-E-11-1211/02/11
342 LOBB, R. (Stip) 6
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associated ECAM rate impacts, cost of service, revenue spread
and the valuation of curtailment products.
The first Settlement conference held in August was
attended by all the parties in the case and focused primarily
on revenue requirement. Return on Equity, power supply
expenses, wages and benefits, risk management and wheeling
revenues were just a few of the revenue requirement issues
presented and discussed. The parties discussed revenue
requirement adjustments and stated their positions on issues
ranging from jurisdictional and class cost of service cost
allocation, to rate design and low income weatherization
programs. There was no discussion of a multi-year rate plan
and Settlement was not achieved at the first conference.
Q. Did additional informal discussions take place
among the parties prior to the second Settlement conference?
A. Yes. As a result of discussions during the initial
Settlement conference, it became apparent to the parties that
NPSE decisions in this case had multi-year impact through the
ECA. The parties began to analyze the combined base and
ECA rate impact on the various customer classes through the
year 2014. Prior to the September Settlement conference, the
parties circulated numerous multi-year revenue proposals so
all participants could evaluate and agree on how rates would
likely change over the period under difference scenarios.
On September 22, a proposed two-year rate plan
CASE NO. PAC-E-11-1211/02/11
343 LOBB, R. (Stip) 7
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consisting of a combination of NPSE and non-NPSE base revenue
increases was presented. Negotiations ensued on the level of
increase each year, the split between NPSE and non-NPSE
revenue, how revenue spread to customer classes would occur
and how ECAM impacts could be mitigated. No Settlement was
reached during the second Settlement conference.
Q. How did the parties ultimately agree on the terms
in the Stipulation?
A. Informal discussions among the conference
participants continued after the second conference which
ultimately led to agreement in principal regarding the two
year revenue requirement, revenue spread to customer classes
and ECAM rate mitigation. Significant negotiation also
occurred over language in the Stipulation regarding treatment
of the Populous to Terminal transmission line and the scope
of additional discussions that must occur between the Company
and interested parties before the next general rate case. As
a result of much discussion, negotiation and compromise, all
parties to the case except CAPAI signed the Stipulation. ICL
officially withdrew as an Intervenor in the case on October
14, 2011.
Staff Evaluation
Q. How did Commission Staff evaluate the Stipulation
to determine that it was reasonable?
A. There were several steps taken by Staff in this
CASE NO. PAC-E-11-12
11/02/11
344 LOBB, R. (Stip) 8
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case to fully evaluate the Stipulation and conclude that it
was reasonable. The focus of the evaluation was to assure
the best deal for customers. The first step was to identify
revenue requirement adj ustments based on a thorough review of
the Company's filing and an extensive audit of Company
financial records. The identified adjustments reducing the
requested increase must be supported by evidence on the
record and have a reasonable chance of being accepted by the
Commission.
The second step was to determine if the identified
adjustments removed costs from rate recovery or simply
removed costs from base rate recovery. For example, NPSE
adjustments might remove costs from base rate recovery only
to have them tracked for later recovery through the ECAM
mechanism.
Q. What adjustments did Staff identify and how were
they categorized?
A. Staff identified a broad range of adjustments
starting with adjustments previously approved by the
Commission in the Company's last rate case, Case No.
PAC-E-10-07. These adjustments included a lower ROE than
that proposed by the Company in this case, continued removal
of Populus to Terminal transmission costs until the next rate
case, removal of salary increases and reduction in coal
stockpile costs. Other identified adjustments included
CASE NO. PAC-E-11-12
11/02/11
345 LOBB, R. (Stip) 9
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Klamath Falls expenses, coal settlement costs, property
taxes, abandoned proj ect costs, a variety of power supply
expenses and a number of other miscellaneous costs. Staff's
proposed adjustments, if fully accepted by the Commission,
would have reduced the Company's revenue increase request by
approximately $14.3 million, $5 million of which were power
supply costs subject to recovery through the ECAM.
Q. Did other parties to the case propose revenue
requirement adjustments?
A. Yes. Other parties suggested adjusting power
supply costs, ROE, wheeling revenues, hedging expenses and
REC revenues. However, most of these suggestions were
already incorporated in Staff adjustments, previously decided
by the Commission, or in Staff's view, were without
sufficient support. Consequently, Staff evaluated the
revenue requirement settlement at this point primarily based
on Staff adjustments alone.
Q. Did Staff consider proceeding to hearing rather
than settling the case?
A. Yes. Staff considered proceeding to hearing with
the identified adjustments. In this case, Staff was not
confident that it could successfully defend all of the
identified adjustments on the record in the face of rebuttal
testimony provided by the Company.
While the Commission makes the final decision on
CASE NO. PAC-E-11-1211/02/11
346 LOBB, R. (Stip) 10
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Company revenue requirement based on the record at hearing,
it is the parties to the case that make revenue requirement
adjustment recommendations for the Commission to consider.
The outcome at hearing in terms of revenue requirement must
therefore be evaluated based on both the adjustments to the
Company's revenue request that are presented on the record
and how the Commission might decide each adjustment.
In Staff's opinion, the best case scenario at
hearing would have been an increase in the range of $18.5
million (8.5%) achieved in part by pushing $5 million in NPSE
to the ECAM for later recovery.
Q. Why did Staff pursue settlement on a multi-year
basis?
A. Staff determined that approximately $17 million of
the Company's requested $32.7 million increase in this case
was for increased NPSE that is already accumulating in the
ECAM deferral balance for recovery starting in April of next
year. Failure to recover legitimate NPSE in base rates as
part of this case pushes recovery of the expenses to the ECAM
in 2013. Clearly, cost recovery decisions in this case have
a multi-year impact on customer rates.
Q. What are the reasons for the NPSE increase?
A. The primary reason for the NPSE increase in this
case is the declining revenue from surplus electricity sales
used to offset system power supply expenses and to a lesser
CASE NO. PAC-E-II-1211/02/11
347 LOBB, R. (Stip) 11
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extent, expiration of low-cost power purchase agreements and
increasing coal costs. Surplus sales revenue has declined
due to reduced market value of electricity caused by
declining natural gas prices and increasing surplus wind
generation. While surplus sales volume has increased and the
cost to fuel natural gas generating plants has decreased, it
has not been enough to offset the decline in surplus sales
revenue.
NPSE has been characterized as the utility's power
bill that is passed on to customers. Historically, it has
been very difficult to remove expenses in this category from
both base rate and ECAM recovery.
Q. How has NPSE changed over the last few years and
what is the forecast for next year?
A. In Case No. PAC-E-10-07, the Company proposed an
increase in Idaho NPSE from $66.1 million to $69.2 million.
The Commission approved Idaho NPSE of approximately $66.2
million in that case. In this case, the Company requested
Idaho NPSE of approximately $82.8 million or approximately
$17.7 million more than currently in base rates. In its most
recent rate filing in the State of Utah, the Company
forecasted NPSE through year end 2012 to be approximately
$1.521 billion on a system basis or approximately $98.4
million in Idaho. This amount is approximately $15.6 million
more in NPSE than the Company requested in this case. The
CASE NO. PAC-E-11-1211/02/11
348 LOBB, R. (Stip) 12
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Company indicates that NPSE should level off somewhat after
2012. In the meantime, the difference between NPSE recovered
in base rates and NPSE actually incurred will be recovered
through the ECA.
Q. How does the multi-year settlement address the NPSE
issue?
A. The multi-year settlement spreads recovery of
increasing NPSE over three years by combining the proposed
$22 million in NPSE base rate increases with the existing $10
million of NPSE currently recovered through the ECA. By the
end of the rate plan in 2013, annual NPSE recovery in Idaho
will total approximately $98.2 million with the potential for
ECA rate reduction. This will allow customers to better
manage the impact of increasing power supply costs over time.
Q. How did Staff evaluate the non-NPSE increases
specified in the Stipulation?
A. Unlike NPSE costs, non-NPSE costs can only be
recovered through base rates. Therefore, Staff focused on
achieving a lower level of recovery for this category of
costs and a better deal for customers through settlement than
could be achieved through the hearing process.
The Company requested an increase of approximately
$16 million in non-NPSE in this case. Based on Staff's
identified adjustments for this category of costs, the best
outcome that could be expected at hearing was an increase of
CASE NO. PAC-E-11-1211/02/11 349 LOBB, R. (Stip) 13
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approximately $6.7 million. The Stipulation proposes an
increase of $6 million or less than 38% of the amount
originally requested by the Company. This stipulated amount
is equivalent to the Commission accepting every adjustment
proposed by the Staff plus an additional $700,000.
Q. How did Staff determine that the rate increase
proposed in the second year of the Stipulation was
reasonable?
A. Staff evaluated the rate increase proposed for the
second year based on the rate request made by the Company
last year, the overall rate request made this year and the
likelihood that the Company would make a similar rate
increase request next year. Last year the Company requested
an increase of $27.7 million (13.7%) of which $24.6 million
was for non-NPSE. The Commission approved an increase of
$14.35 million (7.07%) all of which was non-NPSE. In this
case, the Company requested an increase of $32.7 million
(15%) of which $16 million was non-NPSE.
using a 2012 forecasted test year, the Company
filed in the State of Utah to increase NPSE (over Company
proposed 2011 levels) by approximately $15.6 million on an
equivalent Idaho jurisdictional basis. The proposed rate
base increase in the Utah filing was approximately $153
million on an Idaho equivalent basis. The non-NPSE increase
associated with just the return on the increased rate base is
CASE NO. PAC-E-11-12
11/02/11
350 LOBB, R. (Stip) 14
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approximately $12 million in Idaho. Absent approval of the
Settlement, the Company could and likely would file for a
rate increase in 2012 exceeding $30 million, with more than
$12 million of the requested increase for non-NPSE. The
Stipulation proposes a non-NPSE increase that is less than
50% of that level.
Q. Could you please summarize Staff's support of the
Stipulation with regard to the revenue requirement increase
over the two-year period?
A. Yes. Because actual power supply expenses are
tracked for recovery through the ECAM, customers can pay them
now through base rates or pay them later through the ECA.
The $22 million NPSE base rate increase specified in the
Stipulation, when combined with expenses currently collected
through the ECAM, will reasonably spread recovery of expected
power supply costs through 2014.
Staff believes the $12 million non-NPSE increase
specified in the Stipulation represents a fraction of the
non-NPSE that the Company has requested in this case and
would request in a filing next year. Staff maintains that
the $6 million non-NPSE increase this year is only 38% of the
Company's request and a better deal for customers than could
be achieved at hearing. Staff further maintains that the $6
million increase in non-NPSE in 2013 is less than 50% of what
the Company would otherwise request in a filing next year.
CASE NO. PAC-E-11-12
11/02/11
351 LOBB, R. (Stip) 15
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The Stipulation prohibits the Company from any further base
rate increases until January 1, 2014.
Cost of Service
Q. Could you please describe the Stipulation with
respect to customer class cost of service (COS) and revenue
spread?
A. Yes. While the parties to the Stipulation agreed
to a revenue spread in this case based on the Company's
proposed class COS study, they did not agree to accept the
methodology in future rate cases. The Stipulation specifies
that the revenue spread to customer classes in each year of
the rate plan will include a 25% move toward the Company's
proposed COS in this case.
The resulting revenue spread to the various
customer classes in year one of the rate plan range from an
increase of 5.88% for Schedule 1 residential customers to
8.91% for Irrigators, Agrium and the Monsanto Company. Year
two increases range from 5.43% for residential customers to
8.25% for Irrigators, Agrium and the Monsanto Company. The
revenue spread and associated increases for each class, in
each year of the rate plan, is shown on Attachment 1 to the
Stipulation.
Staff believes that the 50% move toward COS over
two years is a reasonable compromise that balances the need
for each customer class to pay its fair share while
CASE NO. PAC-E-11-1211/02/11 352 LOBB, R. (Stip) 16
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mitigating an even greater rate impact that would otherwise
occur with a full COS move. The compromise also allows
parties to accept some cos responsibility without accepting a
COS methodology.
Rate Design
Q. How are individual rate components proposed to
change under the Stipulation?
A. The Parties agreed to accept, for the purposes of
this case, the Company's proposals to adjust rate components
within each rate schedule with the exception of customer
charges in Residential Schedules 1 and 36. Customer charges
for these schedules will remain unchanged at $5 and $14 per
month, respectively.
Demand charges for Schedules 6, 6A, 9 and 10 will
increase each year based in part on cost of service and
prorated to reflect the revenue increase assigned to each
customer class. Other rate components will increase
uniformly reflecting the overall increase in class revenue
requirement. Staff believes that the stipulated rate changes
are reasonable in allowing customer charges to remain stable,
demand charges to generally reflect cost of service and for
other charges including energy to reflect the class revenue
requirement increase.
Schedule 1 residential customers using the annual
monthly average of 837 kWh per month will see a monthly base
CASE NO. PAC-E-11-1211/02/11
353 LOBB, R. (Stip) 17
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rate increase of $5.47 and $4.20 in summer and winter,
respectively, in the first year. Customers will see an
additional increase of $5.36 and $4.10 per month in summer
and winter, respectively, in the second year. A monthly
billing comparison for Residential Schedule 1 at various
monthly consumption levels is shown in Staff Exhibit No. 102.
ECA Issues
Q. What ECAM issues are addressed in the Stipulation?
A. Besides specifying the ECAM level of system NPSE in
base rates for 2012 and 2013 at $1.205 billion and $1.385
billion, respectively, the Stipulation specifies the ECAM
level of system Renewable Energy Credits (RECs) included in
rates at $78.8 million and establishes the ECA LCA at $5.47
per Mwh through 2013. The Stipulation also establishes the
level of Idaho allocated Irrigation Load Control program
credits at $1.05 million to be tracked through the ECA
pending resolution of system allocation issues.
Q. Could you please explain Staff's support for these
ECAM terms specified in the Stipulation?
A. Yes. Staff supports the system NPSE levels
specified in the Stipulation for 2012 and 2013 because they
are consistent with stipulated NPSE revenue requirement
increases for those years. These levels must be specified in
order for the ECAM to work properly. The ECAM REC revenue
levels are as filed by the Company and within a reasonable
CASE NO. PAC-E-11-1211/02/11
354 LOBB, R. (Stip) 18
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range of expected revenue on an annual basis. Actual annual
revenue above or below this level will be tracked through the
ECAM and trued up each year.
The specified LGAR of $5.47 per Mwh was approved by
the Commission as part of Case No. PAC-E-10-7 and is
currently used in the ECAM. Staff supports continued use of
the previously approved LGAR level through 2013.
The Irrigation Load Control program credit level of
$1.05 million specified in the Stipulation is consistent with
Irrigation program costs currently allocated to Idaho. Staff
agrees that the ability to track irrigation program costs
assigned to Idaho through the ECAM during the period of the
rate plan is consistent with the Stipulation approved by the
Commission in Case No. PAC-E-11-06. The Multi-State Process
(MSP) on jurisdictional allocations will determine during the
rate plan period if Idaho Irrigation Load control costs will
be accepted by other state jurisdictions as a system
resource.
Q. Are there any other ECAM issues specified in the
Stipulation?
A. Yes. The Stipulation provides for multi-year
amortization of ECAM costs assigned to Agrium and the
Monsanto Company. Monsanto and Agrium are not currently
subj ect to ECAM rates. However, these customers will be
subject to the ECA starting in 2012. Consequently, they
CASE NO. PAC-E-11-1211/02/11
355 LOBB, R. (Stip) 19
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will experience a base rate increase on January 1, 2012 and a
significant ECA rate increase on April 1, 2012 as they
become subject to the tracking mechanism. This will occur
again in 2013. To mitigate the rate impact of both the base
rate increase and the ECA increase, the Stipulation provides
for amortization of ECAM balances subj ect to recovery from
the two customers. 2012 (2011 deferrals) ECAM balances will
be amortized through 2014, 2013 (2012 deferrals) ECAM
balances will be amortized through 2015 and 2014 (2013
deferrals) ECAM balances will be amortized over two years
through 2016.
Staff fully supports amortization of the ECAM
deferral balance for these customers to mitigate the much
larger rate impact that would otherwise occur. Staff notes
that agreement to amortize ECAM expense recovery for these
customers has no impact on other Rocky Mountain Power
customers in Idaho.
other Items
Q. Would you please describe the terms in the
Stipulation with regard to the Populous to Terminal
transmission line.
A. Yes. The parties agreed as part of the Stipulation
in this case that the Populous to Terminal transmission line
is currently, fully used and useful. However, the parties
also agree that the portion of the transmission line deemed
CASE NO. PAC-E-11-1211/02/11
356 LOBB, R. (Stip) 20
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plant held for future use in Case No. PAC-E-10-07 shall not
be included in rates until on or after January 1, 2014. The
parties further agree that the Staff and the Company will
file a motion to suspend the Appeal now pending in the Idaho
Supreme Court, docketed as Case No. 38930-2011. The parties
also agree that the Company will file a stipulation for
dismissal of the appeal with each party to bear its own costs
upon receipt of a final order from the Commission approving
this Stipulation. Consistent with the terms of the
Stipulation, the Company and Staff filed the motion to
suspend the appeal on October 25, 2011.
The Stipulation also directs the Company to
continue deferring depreciation expense associated with the
Populus to Terminal transmission line, pursuant to Order No.
32224, until it is included in rates on or after January 1,
2014 and that the accumulated deferral balance will be
amortized over three years from the date the costs are
included in rates.
Q. Why did Staff agree to these terms?
A. Staff agreed to the terms in the Stipulation as a
compromise in order to achieve a comprehensive settlement in
this case on revenue requirement. Staff believed that it
could agree to the position that the Populous to Terminal
transmission line was now fully used and useful as long as
that portion of the transmission line deemed plant held for
CASE NO. PAC-E-11-12
11/02/11
357 LOBB, R. (Stip) 21
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future use by the Commission was not included in rates until
on or after January 1, 2014. Staff supported continued
deferral of the Populous to Terminal depreciation expense in
compliance with Commission Order until after all costs are
included in rates. Staff further viewed future amortization
of those costs over three years as a reasonable period for
recovery.
Q. What other items are addressed in the Stipulation?
A. The Stipulation specifies that the value of
Monsanto curtailment products will increase from II million
in 2011 to il million in 2012 and to II million in 2013.
Staff believes the proposed escalation provides a reasonable
resolution of an otherwise contentious issue during the
period of the rate plan.
Finally, the Stipulation provides for workshops and
collaborative discussions to address cost of service
methodologies as applied to Monsanto and the irrigation class
and how methodologies could be utilized in the next general
rate case. Workshops will also be conducted to discuss terms
of the irrigation load control program for the 2013 season
and beyond and hedging limits consistent with workgroup
processes established in Utah and Oregon.
Staff supports and plans to participate in the
discussion on all of these issues. The two-year base rate
moratorium provides all parties the opportunity to work
CASE NO. PAC-E-11-1211/02/11 LOBB, R. (Stip) 22
STAFF
358
.
1 together to gain a common understanding of cost of service
2 issues.Agreement to discuss Irrigation credit valuation and
3 hedging practices of the Company will also provide a timely
4 review of resource acquisition choices and strategies.
5 Q.Does this conclude your testimony in this case?
6 A.Yes it does.
7
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CASE NO.PAC-E-11-12 359 LOBB,R.(Stip)23
11/02/11 STAFF
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20
1 (The following proceedings were had in
2 open hearing.)
3 MR. PRICE: And I would make Mr. Lobb available
4 for cross-examination by the parties.
5 COMMISSIONER KJELLANDER: Thank you. Let's move
6 to Rocky Mountain Power.
7 MR. HICKEY: No questions. Thank you.
8 COMMISSIONER KJELLANDER: Mr. Budge.
9 MR. BUDGE: No questions.
10 COMMISSIONER KJELLANDER: Mr. Olsen.
11 MR. OLSEN: No questions, Mr. Chair.
12 COMMISSIONER KJELLANDER: Mr. Williams.
13 Apparently, that's a "no."
14 And then let's go to Mr. Purdy.
15 MR. PURDY: Thank you.
16
17 CROSS-EXAMINATION
18
19 BY MR. PURDY:
Q.Good afternoon. Mr. Lobb, I just really want to
21 ask you a policy question. Is it fair to say that as the
22 director of the utili ties division, that, ultimately, the buck
23 stops with you with respect to policy issues in any given rate.24 case?
25 A.Wi th respect to Staff's approach, that's correct.
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1 Q.Yeah, thank you. And that would include Staff's
2 approach to low-income weatherization funding. Is that
3 correct?
4 A.Yes, it would.
5 Q.As well as program evaluation?
6 A.Program evaluation in what way?
7 Q.For instance, Staff's approach as to how
8 low-income weatherization programs should be evaluated for cost
9 effectiveness.
10 A.Yes.
11 Q.Okay. I guess I'm asking you, based on your
12 extensive time spent here with the Commission, whether what we
13 are proposing doing with respect to the evaluation of
14 low-income weatherization funding and cost effectiveness,
15 whether this is a change of position for Staff with new ideas
16 and formulas and techniques, or whether we're really talking
17 about the same basic kinds of issues, which is need, number of
18 homes that need weatherization, versus available funding.
19 Isn't that really still the core we i re dealing with?
A.I think we're taking a more serious look at it in
21 terms of how cost effectiveness is evaluated for low-income
22 programs, particularly when you're talking about spending the
23 type of money ratepayer money -- that you have proposed in.24 this case and in the Idaho Power case and in Avista cases, so I
25 think we're looking at it more closely.
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1 We've been concerned for some time. There has
2 been some discussion with regard to this PacifiCorp case and
3 Cadmus studies, but we have been concerned with regard to the
4 oversight of low-income weatherization programs, the funding
5 levels, for many years, particularly with PacifiCorp with
6 respect to the 75-, 85-percent caps, the realization rates, the
7 assumptions made in the cost effective analysis. It didn't
8 start with the Cadmus study and it's not going to finish with
9 the Cadmus study.
10 Q.All right, thank you. So you said "many years"
11 you've had these concerns?
12 A.Yes.
13 Q.All right. And so what is it about this
14 particular point in time that brings Staff to resisting any
15 low-income weatherization funding increases pending, you know,
16 a protracted workshop process?
17 A.Well, as I indicated, it's the concern that the
18 programs are cost effective, and - the amount of additional money
19 that's being requested. We're not looking at going back on the
20 funding levels that are already in place, but we believe it's
21 our responsibility to make sure that the programs are cost
22 effective both for the ratepayers and for the low-income
23 customers that have weatherization undertaken.
24 Q. Is it your perception that Community Action
25 agreed with that point of view in its comments in the Rocky
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1 Mountain 11-13 case?
2 A.I'm sorry, what --
3 Q.Isn't it true that Community Action agreed that
4 low-income weatherization programs should be subjected to some
5 type of reasonable evaluation in that case?
6 A.I believe they did, yes.
7 Q.Okay.
8 MR. PURDY: Excuse me, Mr. Chair, if I could just
9 look through my notes one minute. Thank you.
10 COMMISSIONER KJELLANDER: Sure.
11 Q.BY MR. PURDY: Okay, Mr. Lobb, you referred to
12 the type of money we're dealing with, we're talking about here.
13 You'll get no disagreement from Community Action that the
14 requested amount certainly in the Idaho Power case is a
15 substantial -- would be a substantial boost to low-income
16 weatherization. What is -- just referring to that case for a
17 moment, what is $1.5 million as requested in that case as a
18 percentage of the Company's residential revenues, if you
19 know?
20
21
A.I don't know.
Q.Did you see in Ms. Ottens' testimony that it is
22 one-third of one percent?
23
24.25
A.I think she put that number down, yes.
Q.All right. While no small amount, is one-third
of one percent increase in residential, if that were just paid
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1 for by residential customers, is that still of significant
2 concern to you?
3 A.I don't know. I think that's one of the things
4 that we really want to look at: How much money should be made
5 available.
6 Q.Okay. And in terms of the workshop proposal, do
7 you have in mind any kind of a time line, sort of a list of
8 tasks that would need to be accomplished?
9 A.Not really. It seems like every case that we've
10 had -- rate case -- has included a settlement term that
11 proposes discussions of and workshops for low-income
12 weatherization, and I think it would be Staff's desire to
13 proceed expeditiously on those workshops. We're not
14 necessarily disputing the need -- increased need. There's lots
15 of factors and indications that there's affordabili ty issues.
16 And so I think we'd want to proceed fairly quickly, but I don i t
17 have any outline or plan or time line at this point.
18 Q.And do you have any type of a vision as to the
19 final outcome of a workshop proceeding and how that outcome
20 would actually affect, if at all, low-income weatherization
21 funding?
22 A.Well, certainly we'd have a better understanding
23 of the approach that all of the companies take. We talk about
24 pari ty. I think there is some common approach that should be
25 used in terms of funding, and benefits that are included in the
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1 evaluation, how evaluations are undertaken. And so I think I
2 would expect that there be some commonality among the programs
3 in the way their -- the way their oversight's undertaken and
4 cost effectiveness is evaluated, and I think at that point you
5 could determine how much money
6 I think money is a big factor, how much ratepayer
7 money should go to this, this area, but I think common
8 application of the programs is what I i d be looking at.
9 Q.What's your vision then if, say, we go through
10 the workshop process and for any of the three Utilities we
11 determine that additional funding is needed: Would it be
12 incumbent upon Community Action, in your opinion, to file some
13 type of new proceeding?
14 A.Well, I think that would be part of the
15 discussion in the workshops is, "How can we do this?"
16 One of the things that's different about the
17 Utilities is the way they fund their low-income weatherization
18 programs. Some are funded through base rates, some are funded
19 through tariff riders. So the approach would have to be
20 different. We'd have to talk about those that perhaps were
21 funded by -- through base rates and determine how best to
22 increase funding outside of a rate case.
23 Q.And so can you see Community Action's concerns
24 about the fact that we've got three Utilities with three very
25 different programs and different ideas about things, and how is
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1 a workshop, bring everybody together, going to result in a
2 final outcome that has a dollar sign in front of it?
3 A.Well, we have settlement workshops and we seem to
4 come to a conclusion with respect to general rate cases, and I
5 think the issues are much broader and more difficult perhaps
6 there than they are with low-income weatherization. I think
7 this is very focused and I think we can reach some agreement on
8 how things should be done, at least how Staff believes they
9 should be done. And so I think workshops can be fruitful.
10 Q.And if any particular Utility were to resist
11 whatever conclusion is reached during the workshop process,
12 would Staff take action on that?
13 A.I don't know. That's really speculative. I
14 don't know what the nature of the obj ection might be or any
15 other issues that might arise.
16 Q.And do you have a sense -- finally, do you have a
17 sense of when this workshop process should conclude,
18 realistically, an end date to the whole process?
19 A.I don't have an end date in mind.
20 Q.Okay. All right, that's all I have. Thank you.
21 COMMISSIONER KJELLANDER: Thank you, Mr. Purdy.
22 Are there any questions from the Commission?
23 COMMISSIONER REDFORD: No.
COMMISSIONER KJELLANDER: Commissioner Smith.
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1 EXAMINATION
2
3 BY COMMISSIONER SMITH:
4 Q.So, Mr. Lobb, in your answers to Mr. Purdy's
5 questions about possible workshops, I heard you use the word
6 "focused" and "expeditiously." So I take it that would mean
7 you do not agree with Mr. Purdy's characterization of
8 "protracted"?
9 A.No, I think that would be the opposite of
10 protracted.
11 Q.Okay. Thanks. There's a lot of, seems to me,
12 customer angst with regard to Rocky Mountain Power in Idaho, at
13 least compared to what we hear from maybe other Utilities'
14 customers. So do you have any information about our experience
15 wi th Rocky Mountain customers, how often do they register
16 concerns with us or their difficulties? Do you have any
17 customer information whatsoever?
18 A.Well, I don't have any information with respect
19 to comparison to other Utilities, but I do have some
20 information on customer complaints and inquiries that we've
21 received over the past few years just to give you some idea of
22 what type of calls we deal with on a volumetric basis. In
23 2008, we had 72 complaints and inquiries, and about 20, 25
24 percent of the total is customer inquiries and the rest are
25 complaints dealing primarily with billing and rates -- about
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1 half is billing and rates and about half is credit collection
2 issues -- but most of them are along those lines.
3 So we had 72 in 2008, 51 in 2009, 57 in 2010, and
4 then we had 51 so far in 2011.
5 So that gives you an idea. And the breakdowns
6 are very similar each year with respect to the types of issues
7 and the number of complaints versus just questions and
8 inquiries. So that's the information that I've put together.
9 Q.Okay. So you were here earlier when I asked
10 Mr. Weston questions about Schedule 1 and Schedule 36 --
11 A.Yes.
12 Q.and the differences in the percentages, of
13 course, which is just math, but how about the issue of
14 fairness.
15 Is it fair to give the Schedule 1s a higher
16 actual increase than the Schedule 36s?
17 A.Well, I guess when the Staff looked at the
18 increases for Schedule 1 and 36 relative to one another, we
19 thought the fairness was with respect to cost of service.
20 Q.Okay.
21 A.And how does -- is it reasonable for Schedule 36
22 to have the peak/off-peak relationships that they have, and is
23 it fair for the peak prices to be significant below peak prices.24 or energy rates for Schedule 1. And I guess our conclusion
25 was -- and we fought this in we actually opposed the
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1 Company's approach to cost of service evaluation in the
2 recommendation for significant increases in Schedule 36 in the
3 last general rate case.
4 Q.Uh-huh, I remember that.
5 A.The Company modified their approach, and we had
6 to admit that it had validity and it was more equitable to
7 increase the Schedule 36 a little bit with respect to
8 Schedule 1.
9 The percentages are misleading. As Mr. Weston
10 indicated, anytime you increase -- have a reasonable increase
11 on a smaller number, you come up with a larger percentage, and
12 that's kind of the case here. You increase a
13 four-and-a-half-cent rate by the same amount as you increase a
14 nine-cent rate and you get half the percentage increase.
15 Q. But here we didn't increase 36 as much as we did
16 Schedule 1. If I understood Mr. Weston correctly, Schedule 1
17 got a half-a-cent increase, whereas Schedule 36 got a point
18 three?
19 A.I would have to look at the numbers specifically.
20 I don't know if that's -- is that on a specific rate or on a
21 revenue my understanding was --
22 Q. He gave me average rates.
23 A.Okay. I believe on a revenue basis, the
24 Schedule 36 got a larger percentage increase in revenue. And
25 the percentage is calculated, you're absolutely right.
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22
1 Q.Yeah.
2 A.But over time, their rate is going to -- their
3 rates are going to converge, the revenue is going to converge.
4 And one of the things that we try to do is have a measured
5 increase in
6 Q.Right.
7 A.-- in classes, rather than flash cut to what may
8 be a cost of service exact rate.
9 Q.So, for now, that's fair?
10 A.For now, we think a movement towards a higher
11 Schedule 36 rate is more reasonable than a flash cut move. We
12 think it's equitable.
13 COMMISSIONER SMITH: Thank you. That's all I
14 have.
15 COMMISSIONER KJELLANDER: Thank you. Any further
16 questions?
17 COMMISSIONER REDFORD: No.
18 COMMISSIONER KJELLANDER: Redirect.
MR. PRICE: No redirect.
COMMISSIONER KJELLANDER: Mr. Lobb, thank you.
(The witness left the stand.)
COMMISSIONER KJELLANDER: Well, that takes us to
23 the end of the witness list, and with that, then I would ask if.24 there are any other matters that need to come before the
25 Commission.
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1 MR. HICKEY: Mr. Chairman, on behalf of the
2 Applicant and I believe jointly with Monsanto, we would bring
3 to the attention of the Commission that the parties, at your
4 direction, have been negotiating a Electric Service Agreement
5 consistent with the expectations of the Commission that we
6 could get these terms and conditions and price issues resolved.
7 I believe Mr. Budge will be able to join me that we've been
8 successful in that regard, and it's my understanding that our
9 respecti ve clients have agreed to everything. There is the
10 logistical problem of getting signatures during Christmas week,
11 but we believe that will all occur. And rather than keep the
12 docket open or otherwise need to extend anything, we would
13 suggest that a compliance filing, filing the public and
14 redacted copy of the Electric Service Agreement, can and will
15 be made prior to the close of Commission business this week,
16 and would like to bring that issue to the attention of the
17 Commission.
18 Randy, was that accurate?
19 COMMISSIONER KJELLANDER: Mr. Budge.
20 MR. BUDGE: Yes, thank you, Paul.
21 And, Mr. Chairman, Commissioners, I believe that
22 is correct. I would expect that we would have a compliance
23 filing in the form of a 2012 Electric Service Agreement signed
24 and submitted by the end of the week. I think we are in
25 agreement as to terms.
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1 There is one question regarding one of the
2 attachments, some of the scaling factors that still has to be
3 reviewed, but I think that's a minor matter.
4 COMMISSIONER KJELLANDER: Thank you. Are there
5 any other matters that need to come before the Commission?
6 Mr. Budge.
7 MR. BUDGE: Mr. Chairman, I had a question
8 regarding -- I didn't bring it up at the beginning; I did
9 mention it to Staff and the Company earlier about submitting
10 some brief comments regarding the settlement, and I'd be
11 prepared to provide some brief oral comments. If the
12 Commission is not inclined in the interest of time, we can file
13 the written comments that we have prepared.
14 MR. HICKEY: If I could respond to that request?
15 COMMISSIONER KJELLANDER: Certainly.
16 MR. HICKEY: It seems, to me, that we were all
17 here as a group of parties to support a Stipulation and that
18 the Commission has now heard all of the testimony that the
19 parties chose to offer supporting or not supporting the
20 Stipulation, and I really don't believe oral comments or
21 wri tten comments later are either appropriate or necessary, and
22 would therefore encourage the Commission to close this docket
23 and that my friend Mr. Budge will have future dockets in future
24 proceedings to comment on future cases; but this case, I
25 believe, we've come to an amiable resolution with parties and
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1 we end the docket now.
2 COMMISSIONER KJELLANDER: Mr. Budge, is that okay
3 with you?
4 MR. BUDGE: Certainly. Monsanto did, in fact,
5 sign the Settlement Stipulation. We do believe it represents a
6 reasonable compromise and we'd urge the Commission to approve
7 it.
8 Having said that, Monsanto did not file written
9 testimony in support of the Stipulation for the reason that it
10 was adequately explained in the Company's testimony of
11 Mr. Weston and Staff testimony of Mr. Lobb, but we do want to
12 make a record of why we did support the Stipulation and also
13 express some of the concerns that we have. And I would propose
14 to present those orally in a few minutes if acceptable to the
15 Commission. If not acceptable, I'm prepared to file them in
16 writing today as well.
17 COMMISSIONER KJELLANDER: Well, it sounds as if
18 you feel compelled to offer them, so let's get them on the
19 record and let's do it now.
20 MR. HICKEY: May the record reflect that we
21 believe this is inappropriate, Mr. Chairman; that there are
22 future proceedings in all likelihood, and that whatever future
23 posi tions the Companies might find themselves in is just that:
24 A future date and nothing that is pertinent to the Commission's
25 review of the Stipulation today.
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1 COMMISSIONER KJELLANDER: And your objection is
2 duly noted.
3 MR. BUDGE: Thank you. Thank you, Mr. Chairman,
4 Commissioners. I want the record to be clear --
5 COMMISSIONER KJELLANDER: Mr. Budge, you can be
6 seated.
7 MR. BUDGE: Oh.
8 -- that Monsanto did, in fact, sign the
9 Stipulation and does support the Stipulation and urge it to be
10 approved. I think it's important that we note why a
11 Stipulation of this nature from Monsanto' s perspective was
12 approved.
13 The Stipulation does, in fact, provide price
14 certainty over the next two years, even though it does not
15 provide price stability. It's important to Monsanto that this
16 was, in fact, a black box settlement with no acceptance of any
17 particular cost of service or allocation methodology. We do
18 see it was a good compromise of disputed claims, it provides
19 some certainty, eliminates the risks as well as the costs of
20 going forward with further litigation.
21 A significant benefit to Monsanto is that
22 Monsanto, as well as Agrium, will become exposed to ECAM
23 adjustments going forward, and the fact that those were now
24 being amortized out over three years is a significant benefit
25 to those particular customers.
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1 It's also significant to Monsanto that its 1,050
2 hours of curtailment products are also going to go up in value
3 over these next two years at a rate approximately similar to
4 which the rate of their firm rates are going up over this time
5 period.
6 We think it's also important that the Stipulation
7 provided and the Company agreed as Monsanto agreed to work
8 cooperati vely going forward to try to address some of these
9 long-standing issues regarding the valuation of the curtailment
10 products, and also these allocation methodologies that have
11 been an issue of disputed past cases.
12 I think in commenting on these posi ti ve aspects
13 of the settlement, Monsanto management feels it's very
14 important that we similarly indicate that there are some
15 concerns going forward, and those concerns are such that we
16 should apprise the Commission as well as the Company. They are
17 not particularly concerns relative to this Settlement
18 Stipulation, but they're concerns relative to where we have
19 been and where we are going with this particular Utility.
20 MR. HICKEY: Commissioner.
21 COMMISSIONER KJELLANDER: I do hear your
22 obj ection.
23 MR. HICKEY: This is exactly why I made the
24 obj ection. There is another day and another fight, it sounds
25 like, or at least an opportunity to share differing views in
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1 the future, but today just isn't that day.
2 COMMISSIONER KJELLANDER: And, Mr. Budge, I have
3 to concur. It sounds like you're going beyond the issue that's
4 in front of us today. And I appreciate the fact that you have
5 addi tional concerns, but in terms of our ability to look at the
6 record wi thin this case, I don't see them assisting us in the
7 decision making we have in front of us in the near term. So
8 I'm going to allow the obj ection, I'm going to concur, and --
9 MR. BUDGE: With due respect, your Honor, I think
10 in order to -- we certainly accept the ruling and we'll end at
11 this point, but when one party supports a Stipulation and chose
12 to sign in on one of a significant nature, I think it would be
13 fundamentally important to express the reasons why we did, but
14 similarly to express some of the concerns on why management had
15 a very difficult time settling this thing.
16 And I can appreciate if the Commission does not
17 want to hear further comment on those. I would like the
18 opportuni ty to file comments that we have prepared that set
19 forth not only the reasons we did support but some of the
20 concerns we have going forward, and those are concerns that
21 have been expressed with the Company not only by Monsanto but
22 with the recently-formed large customer group, and there will
23 be more on that..24
25
MR. HICKEY: If I could be heard briefly,
Mr. Chairman. That's exactly why the Commission provided
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1 opportuni ties for parties to support or oppose the Stipulation.
2 Those opportunities were fairly offered to everyone, and to
3 come in unannounced, after the fact, and ask for some
4 posthearing filing is inappropriate, and I would hope that the
5 Commission's prior ruling would stand in that regard.
6 COMMISSIONER KJELLANDER: Mr. Budge, again, I
7 appreciate your concern. I don't know that it needs to be a
8 part of the record for us to move forward. The concerns
9 outside of the Stipulation are going to be issues that I think
10 Counsel for Rocky Mountain Power has accurately portrayed. To
11 the extent that they find themselves into other cases, they
12 will, and I just don't see what the value of that is going to
13 be for the purpose of this record.
14 And are you saying that you want to file a
15 posthearing brief?
16 MR. BUDGE: No, no, not at all, Mr. Chairman. I
17 guess we considered this a hearing process and the process
18 began some eight or nine months ago that gets culminated in a
19 settlement, and we simply, in effect, thought we would have an
20 opportunity to make a comment on the settlement, not only the
21 plus and minus. And so we don't intend to file a posthearing
22 brief; we simply would file today our written comments on the
23 Settlement Stipulation as part of the process.
24 COMMISSIONER KJELLANDER: Okay. If you want to
25 file them, that's fine, and we'll give it the weight that it
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.1 deserves.
2 Are there any other matters that need to come
3 before the Commission? Mr. Olsen.
4 MR. OLSEN: Just one matter for the Intervenors
5 and also CAPAI agency: Just a time line to file an Application
6 for Intervenor funding.
7 COMMISSIONER KJELLANDER: That's where I was
8 heading to next, and in fact that's where I thought we were
9 going when we started down this path, so next time I will just
10 go straight to that.
11 The deadline for intervening funding is going to.12 be December 23rd; that's this Friday. So get those in as soon
13 as you can so we can try to pull these things together.
14 That also raises another issue with regards to
15 timing, and I know that we've got the holiday season upon us.
16 And as we look at trying to get this Order out, along with the
17 other Orders that we have to get out on previous rate cases
18 that we dealt with in the last week or so, we need to raise
19 that issue realistically in terms of what the timing is going
20 to be in terms of trying to get the Order out. So if anybody
21 would like to throw down on that, now would be a perfect time
22 to do so.23 Mr. Price?.24 MR. HICKEY: I think the best suggestion that we
25 could make on behalf of Rocky Mountain Power, Mr. Chairman,
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1 would be for the Commission, given these difficult holiday
2 seasons and the pressure of your workload, is to consider an
3 Interim Order as was done a year ago and allow additional time
4 for the more detailed Order to be entered. And we would hope
5 that that Interim Order could become effective as early as
6 January.
7 COMMISSIONER KJELLANDER: Anyone else?
8 Mr. Price.
9 MR. PRICE: I think this is the purview of the
10 Commission; I wouldn't want to weigh in.
11 COMMISSIONER KJELLANDER: Okay. I think just
12 from our perspective -- and I wasn't here when the Interim
13 Order was kicked out, but I think it would be certainly
14 something we need to consider; but on the other side, you kick
15 out the Interim Order, you don't have the specifics, and I
16 think it sometimes creates more confusion especially for
17 customers and doesn't necessarily get to the issues that we
18 want to make sure we have out very clearly. And I don't know
19 how we're going to go down that path.
20 I think that realistically we want to put
21 together an Order, get it right, get it done the first time,
22 and have it out there so that then the process for any kind of
23 appeal associated with that can begin accordingly. And, you
24 know, that's just my general thought is the way we'll wade
25 through it.
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1 I think though that there's enough recognition
2 that in the holiday season, right now, coupled with the other
3 Orders we have to get out, that clearly there is a time crunch;
4 and I suppose we'll have to see what we get in front of us, but
5 I think it needs to be duly noted on the record that time is a
6 barrier.
7 And, you know, just for future reference, maybe
8 it is something for Utili ties to consider when they file rate
9 cases to see if there might be a way to avoid all of them
10 showing up at once and perhaps all of them wanting to be Orders
11 issued during this time frame. And I'm not blaming Rocky
12 Mountain Power or any of the other Utili ties, but I think as we
13 looked at the maj ori ty of those cases moving forward, they all
14 seem to have sort of the same time frame tied to them, and that
15 certainly is a difficult task for any entity to deal with in
16 trying to get those out in a timely basis based on the
17 statutory constraints and the rules governing our operations
18 wi thin the Public Utili ties Commission. Again, that's not
19 Rocky Mountain's specific problem, but I hope that that will be
20 something that, going forward, various Applicants would
21 consider, is that the timing of when those cases are filed is
22 going to impact the timing in which Orders can be issued, so I
23 just wanted to note that.
24 MR. HICKEY: Mr. Chairman, I certainly understand
25 and appreciate that comment, and I find it pertinent and I'm
380
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
COLLOQUY
.
.
.
1 sure my client representatives here are very attentive to your
2 words.
3 I do want to point out that the Stipulation among
4 the parties had an effective date of these new rates of
5 January 1, and that was obviously a material term of the
6 Stipulation to all of the parties and especially to Rocky
7 Mountain Power, believing that the rates would become effective
8 then. So whether it's through Interim Order or whether the
9 Commission could consider in light of the Stipulation that the
10 effecti ve date of those rates, regardless of when the Order was
11 entered, could be the 1st of January, it is a substantial issue
12 to the Utility and we would hope that that negotiated effective
13 date would remain a part of any Order that's entered.
14 COMMISSIONER KJELLANDER: I think that certainly
15 would be a piece of our deliberative process as we go forward.
16 MR. HICKEY: Thank you.
17 COMMISSIONER KJELLANDER: Okay. Are there any
18 other matters that need to come before the Commission today?
19 MR. HICKEY: Not on behalf of the Applicant.
20 Thank you very much for the chance to present the Stipulation.
21 COMMISSIONER KJELLANDER: As we continue with
22 this process, we will have some public hearings tonight that
23 will be telephonic, and those begin at seven 0' clock. The
24 details of those are in the record as part of a press release.
25 So, again, we will adjourn this technical hearing and we will
381
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
COLLOQUY
.
.
20
21
22
23
24.25
1 reconvene this evening for the telephonic public hearing. So
2 we are adj ourned.
3 (Rocky Mountain Power Exhibit Nos. 49-51,
4 Staff Exhibit Nos. 101-102, and Public Exhibit Nos. 701-703
5 were admitted into evidence.)
6 (The hearing adjourned at 12: 35 p.m.)
7
8
9
10
11
12
13
14
15
16
17
18
19
382
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
COLLOQUY
.1 AUTHENTICATION
2
3
4 This is to certify that the foregoing is a
5 true and correct transcript to the best of my ability of the
6 proceedings held in the matter of the Application of
7 PacifiCorp, dba Rocky Mountain Power, for approval of changes
8 to its electric service schedules, Case No. PAC-E-11-12,
9 commencing on Monday, December 19, 2011, at the Commission
10 Hearing Room, 472 West Washington, Boise, Idaho, and the
11 original thereof for the file of the Commission.
.12 Accuracy of all prefiled testimony as
13 originally submitted to this Reporter and incorporated herein
14 at the direction of the Commission is the sole responsibility
15 of the submitting parties.
20
21
22
23
24.25
16
17
18
19
; ..,.~.~
383
HEDRICK COURT REPORTING
P. O. BOX 578, BOISE, ID 83701
AUTHENTICATION
.
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Exhibit No~ 49 Page 1 of 5
Case No. PAC-E-11-12
Witness: J. Ted Weston?fco10ir..
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Rocky Mountain Power
Exhibit No. 49 Page 3 of 5
Case No. PAC-E-11-12
Witness: J. Ted Weston.. ROCKY MOUNTAIN POWER - STATE OF IDAHO
CASE NO. PAC-E-11-12
DETAILED RATE SPREAD
STIPULATION
Year 1 Year 2
Present 11112012 1/1/2013
27,500 Lumens, LISV, No Co Owned Pole $32.94 $33.28 $33.48
50,000 Lumens, LISV, Co Owned Pole $50.84 $51.7 $51.67
50,000 Lumens, LISV, No Co Owned Pole $45.00 $45.47 $45.74
16,000 Lumens, LIS Flood, Co Owned Pole $25.29 $25.55 $25.70
16,000 Lumens, LIS Flood, No Co OWned Pole $22.52 $22.75 $22.88
27,500 Lumens, LIS Flood, Co Owned Pole $36.37 $36.75 $36.97
27,500 Lumens, LIS Flood, No Co Owned Pole $32.94 $33.28 $33.48
50,000 Lumens, LIS Flood, Co Owned Pole $50.84 $51.37 $51.67
50,000 Lumens, LIS Flood, No Co Owed Pole $45.00 $45.47 $45.74
8,000 Lumens, LPSV, Energy Only $3.60 $3.64 $3.66
13,500 Lumens, LPSV, Energy Only $5.32 $5.38 $5.41
22,500 Lumens, LPSV, Energy Only $7.40 $7.48 $7.52
33,000 Lumens, LPSV, Energy Ony $9.01 $9.10 $9.15
SCHEDULE NO.9 - General Service - High Voltage.Customer Charge $324.00 $347.00 $370.00
All kW (May - Oct)$8.48 $9.35 $10.26
All kW (Nov - Apr)$6.41 $7.06 $7.74
Mium kW Summer $8.48 $9.35 $10.26
Minmum kW Winter $6.41 $7.06 $7.74
All kWh 3.5006 ~3.6970 ~3.8835 ~
SCHEDULE NO. 10 - Irrigation
Small Customer Charge (Season)$12.00 $13.00 $14.00
Large Customer Charge (Season)$35.00 $38.00 $41.00
Post-Season Customer Charge $19.00 $21.00 $23.00
Ali kW (June 1 - Sept 15)$4.69 $5.31 $5.98
First 25,000 kWh (June 1 - Sept 15)7.3477 ~7.9434 ~8.5312 ~
Next 225,000 kWh (June 1 - Sept 15)5.4349 ~5.8755 ~6.3103 ~
All Addl kWh (June 1 - Sept 15)4.0116 ~4.3368 ~4.6577 ~
Al kWh (Sept 16 - May 31)6.2144 ~6.7187 ~7.2164 ~
.
SCHEDULE NO. 11 - Company-Owned Street Lighting Servce
Charges per Lamp -
5,800 Lumens, High Intensity Dischage
9,500 Lumens, High Intensity Discharge
16,000 Lumens, High Intensity Discharge
27,500 Lumens, High Intensity Discharge
50,000 Lumens, High Intensity Discharge
9,500 Lumens, High Intensity Discharge - Series 1
16,000 Lumens, High Intensity Discharge - Series 1
9,500 Lumens, High Intensity Dischage - Series 2
16,000 Lumens, High Intensity Discharge - Series 2
12,000 Metal Halide
$14.89
$18.58
$25.33
$35.38
$51.93
$30.73
$33.73
$25.29
$28.21
$27.42
$15.05
$18.78
$25.60
$35.75
$52.48
$31.06
$34.09
$25.56
$28.51
$27.71
$15.14
$18.89
$25.75
$35.96
$52.79
$31.25
$34.29
$25.71
$28.68
$27.88
.
.
.
SCHEDULE NO. 12F- Customer-Owned Street Lightig Servce-Full Maintenance
Charges per Lamp
5,800 Lumens, HPSV
9,500 Lumens, riSV
16,000 Lumens, HP8V
27,500 Lumens, HPSV
50,000 Lumens, HPSV
SCHEDULE NO. 12P - Customer-Owned Street Lighting Servce-Partial Maintenance
Charges per Lamp
10,000 Lumens, MV
20,000 Lumens, MV
5,800 Lumens, HPSV
9,500 Lumens, HPSV
27,500 Lumens, HPSV
50,000 Lumens, HPSV
ROCKY MOUNTAIN POWER - STATE OF IDAHO
CASE NO. PAC-E-11-12
DETAILED RATE SPREAD
19,500 Metal Halide
32,000 Metal Halide
9,000 Metal Halide - Senes 1
12,000 Metal Halide - Senes 1
9,000 Metal Halide - Senes 2
12,000 Metal Halide - Senes 2
Present
$34.03
$41.28
$31.00
$35.64
$30.17
$31.85
SCHEDULE NO. 12E - Customer-Owned Street Lighting Servce-Energy Only
Chárges per Lamp
33,000 Lumens, LPSV
12,000 Metal Halide
19,500 Metal Halide
32,000 Metal Halide
107,800 Metal Halide
9,000 Meta Halide
5,800 Lumens, HPSV
9,500 Lumens, HPSV
16,000 Lumens, HPSV
27,500 Lumens, HPSV
50,000 Lumens,HPSV
Non-Listed Lumaie - Energy Only
$9.01
$6.94
$9.49
$14.92
$35.72
$3.95
$2.79
$3.91
$5.81
$9.93
$15.27
10.1259 ~
$6.45
$8.22
$9.88
$12.94
$17.27
$16.15
$21.62
$5.78
$7.44
$11.94
$16.09
SCHEDULE NO. 19 - Commercial and Industrial Space HeatingCustomer Charge Seconda $21.00All kWh (May - Oct) 8.2953 ~All kWh (Nov - Apr) 6.1465 ~
Rocky Mountain Power
Exhibit No. 49 Page 4 of 5
Case No. PAC-E-11-12
Witness: J. Ted Weston
STIPULATION
Year 1 Year 2
11112012 1/1/2013
$34.39 $34.60
$41.72 $41.97
$31.33 $31.52
$36.02 $36.24
$30.49 $30.67
$32.19 $32.38
$9.11
$7.01
$9.59
$15.08
$36.10
$3.99
$2.82
$3.95
$5.87
$10.04
$15.43
10.2330 ~
$9.16
$7.05
$9.65
$15.17
$36.32
$4.01
$2.84
$3.97
$5.91
$10.10
$15.52
10.2944 ~
$6.52
$8.31
$9.98
$13.08
$17.45
$6.56
$8.36
$10.04
$13.16
$17.55
$16.32
$21.85
$5.84
$7.52
$12.07
$16.26
$16.42
$21.98
$5.88
$7.57
$12.14
$16.36
$22.00
8.8093 ~
6.5274 ~
$23.00
9.3152 ~
6.9023 ~
Rocky Mountain Power
Exhibit No. 49 Page 5 of 5
Case No. PAC-E-11-12
Witness:J. Ted Weston.ROCKY MOUNTAIN POWER - STATE OF IDAHO
CASE NO. PAC-E-11-12
DETAILED RATE SPREAD
STIPULATION
Year 1 Year 2
Present 11112012 1/1/2013
SCHEDULE NO. 23/23A - General Servce
Customer Charge Seconda $14.00 $15.00 $16.00
Customer Charge Primar $43.00 $46.00 $49.00
Tota Customer Charges
All kWh (May - Oct)8.0585 ~8.5835 ~9.1030 ~
All kWh (Nov - Apr)7.0345 ~7.4928 ~7.9463 ~
Seasonal Service Charge (Secondar)$168.00 $180.00 $192.00
Seasonal Service Charge (priar)$516.00 $552.00 $588.00
Voltage Discount (0.3892) ~(0.4146) ~(0.4397) t
SCHEDULE NO. 35 - Gtmeral Service - Optional TOD
Customer Charge Seconda $59.00 $63.00 $67.00
Customer Charge Priar $145.00 $155.00 $165.00
All On-Peak kW $14.52 $15.49 $16.45
All kWh 4.3260 t 4.6154 t 4.9015 t.Seasonal Service Charge (Secondar)$708.00 $756.00 $804.00
Seasonal Servce Charge (Priar)$1,740.00 $1,860.00 $1,980.00
Voltage Discount ($0.74)($0.79)($0.84)
SCHEDULE 400
Fir Energy and Power
Customer Charges $1,345.00 $1,465.00 $1,586.00
kWh 2.6180 t 2.8515 t 3.0870 t
kW $13.50 $14.70 $15.91
Excess kVar $0.82 $0.89 $0.96
Interruptible Energy and Power
kWh 2.6180 ~2.8515 t 3.0870 t
kW $13.50 $14.70 $15.91
SCHEDULE 401
Customer Charges $375.00 $408.00 $442.00
HLH kWh (May-October)3.0820 t 3.3565 t 3.6332 t
HLH kWh (November-April)2.5630 ~2.7913 t 3.0214 t
LLH kWh (May-October)2.3110 ~2.5168 t 2.7243 t
LLH kWh (November-April)2.3110 t 2.5168 t 2.7243 t
All kW (May-October)$14.93 $16.26 $17.60
All kW (November-April)$12.04 $13.11 $14.19
.
.
.
.
~~~~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 1 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Sixth Revision of Sheet No. 1.1
Canceling Fifth Revision of Sheet No. 1.1
ROCKY MÒUNTAI POWER
ELECTRIC SERVICE SCHEDULE NO.1
STATE OF IDAHO
Residential Servce
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
of adequate capacity.
APPLICATION: This Schedule is for alternatig curent electric service supplied at approxiately
120 or 240 volts though one kilowatt-hour meter at a single point of delivery for all service required on the
premises for Residential puroses.
When conditions are such that service is supplied though one meter to more than one dwelling or
aparent unt, the charge for such service wil be computed by multiplying the minium charges by the
maxmum number of dwelling or aparent unts that may be served.
When a portion of a dwelling is used regularly for business, professional or other gainfu puros.es,
the premises wil be classified as nonresidential and the appropriate schedule applied. However, if the
wiring is so aranged that the service for Residential puroses can be metered separately, ths Schedule wil
be applied to such service.
MONTHLY BILL:
Customer Service Charge:
$5.00 per Customer
Energy Charge:
. (1) Biling months May
though October inclusive
1O.2013~ per kWh first 700 kWh
13.7717~ per kWh all additional kWh
(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: November 2,2011 EFFECTIV: January 1,2012
.
.
.
~~~~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 2 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Sixth Revision of Sheet No. 1.2
Canceling Fifth Revision of Sheet No. 1.2
ELECTRIC SERVICE SCHEDULE NO. 1- Continued
MONTHLY BILL: (continued)
(2) Biling months November
though April inclusive
7.8085~ per kWh first 1,000 kWh
1O.5415~ per kWh all additional kWh
MONTHLY BILLING REDUCTION: Rates in this schedule shall be reduced by the monthly
kilowatt-hour credit adjustment set fort under "Monthly Rates" in the curently effective Electrc Servce
. Schedule No. 34.
SEASONAL SERVICE: When seasonal service is supplied under this Schedule, the mium
seasonal charge wil be $60.00.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule wil be in accordace with
the terms of the Electrc Service Agreement between the Customer and the Company. The Electric Service
Reguations of the Company on fie with and approved by the Idaho Public Utilities Commssion, including
futue applicable amendments, wil be considered as formg a par of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-11-12
ISSUED: November 2,2011 EFFECTIVE: January 1, 2012
.
.
.
~~ROCKY MOUNTAIN. POWER .
A OlISION OF PAClFlCORP
Rocky Mountain Power
Exhibit No. 50 Page 3 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fourth Revision of Sheet No. 6.1
Cancèlig Third Revision of Sheet No. 6.1
ROCKY MOUNTAI POWER
ELECTRIC SERVICE SCHEDULE NO.6
STATE OF IDAHO
General Servce - Large Power
AVAILABILITY: At any point on the Company's interconnected system where there are facilties
of adequate capacity.
APPLICATION: This Schedule is for alternatig curent, single or thee-phase electrc service
supplied at Company's available voltage though one meterig installation at a single point of delivery for all
service required on the premises.
MONTHLY BILL:
. Rate:
Biling Months May
through October, Inclusive
Customer Servce
Charge:
Secondar voltage
delivery (Less than
2300 volts) $ 35.00 per Customer
Pnnary voltage
delivery (2300 volts
or higher) $ 105.00 per Customer
Power Rate:$ 13.28 per kW for all kW
Energy Rate:3.5305~ per kWh for all kWh
(Continued)
Billig Months November
though ApriL, Inclusive
$ 35.00 per Customer
$ 105.00 per Customer
$ 10.92 per kW for all kW
3.5305~ per kWh for all kWh
Submitted Under Case No. PAC-E-l 1-12
ISSUED: November 2,2011 EFFECTIV: Janua 1,2012
.
.
.
~~\~~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 4 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Third Revision of Sheet No. 6.2
Canceling Second Revision of Sheet No. 6.2
ELECTRIC SERVICE SCHEDULE NO.6 - Continued
Power Factor:
This rate is based on the Customer maintaing at all times a power factor of 85% lagging,
or higher, as determned by measurement. If the average power factor is found to be less
. than 85% lagging, the Power as recorded by the Company's meter will be increased by 3/4
of 1 % for every 1% that the power factor is less than 85%.
Voltage Discount:
Where Customer takes service from Company's available lines of 2300 volts or higher and
provides and maintains all transformers and other necessary equipment, the voltage discount
based on measured Power wil be:
$0.61 per kW for all kW of Power
Miíimum Bil:
The Customer Service Charge.
POWER: The kW as shown by or computed from the readings of Company's Power meter for the
IS-miute period of Customer's greatest use durng the month, determed to the nearest kW.
SEASONAL SERVICE: Service for anually recurg periods of seasonal use where service is
normally discontinued or curiled durng a par of the year may be contracted for under this Schedule under
either of the following conditions: .
(a) Customer may contract for servce under this Schedule on a year-round basis paying for all
service, including transformer losses where applicable, under the rates set forth under
"Monthly Bil" above including the monthly miimum bil during those months service is
curailed or is not utilized in the Customer's operation.
(b) Customer may contract for seasonal service under this Schedule with a net miimum
seasonal payment as follows:
$ 420.00 plus Power and Energy Charges for Customer tag service at less than
2300 volts and
plus Power and Energy Charges for Customer takg service at 2300 volts
or higher.
$ 1,260.00
(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: November 2,2011 EFFECTIV: January 1,2012
.
.
.
~2r~~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 5 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fourth Revision of Sheet No. 6A.l
Cancelig Third Revision of Sheet No. 6A.l
ROCKY MOUNTAI POWER
ELECTRIC SERVICE SCHEDULE NO. 6A
. STATE OF IDAHO
General Servce - Large Power (Residential and Farm)
AVAILABILITY: At any point on the Company's interconnected system where there are facilties
of adequate capacity for service to any customer who qualifies as a "Residential Load" or "Far Load"
under both (1) the Pacific Nortwest Electrc Power Planng and Conservation Act, P.L. 96-501 as the same
may be amended, and (2) a Residential Purchase and Sale Agreement, under Section 5(c) of such Act and in
effect between the Company and the Bonnevile Power Administration.
APPLICATION: This Schedule is for alternating curent, single or thee-phase electric service
supplied at Company's available voltage though one metering installation at a single point of delivery for all
service required on the premises.
MONTHLY BILL:
Biling Months May
through October. Inclusive
Customer Service
Charge:
Secondar voltage
delivery (Less than
2300 volts) $ 35.00 per Customer
Priar voltage
delivery (2300 volts
. or higher) $ 105.00 per Customer
Power Rate: $ 13.28 per kW for all kW
Energy Rate: 3.5305~ per kWh for all kWh
(Continued)
Billng Months November
through ApriL, Inclusive
$ 35.00 per C;ustomer .
$ 105.00 per Customer
$ 10.92 per kW for all kW
3.5305~ per kWh for all kWh
Submitted Under Case No. PAC-E-1l-12
ISSUED: November 2, 2011 EFFECTIV: January 1,2012
.
.
.
""2!~_~OUNTAIN
Rocky Mountain Power
Exibit No. 50 Page 6 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Second Revision of Sheet No. 6A.2
Cancelig First Revision of Sheet No. 6A.2
ELECTRIC SERVICE SCHEDULE NO. 6A - Continued
Power Factor:
This rate is. based on. the Customer maintaing at all times a power factor of 85% lagging,
or higher, as determed by measurement. If the average power factor is found to be less
than 85% lagging, the Power as recorded by the Company's meter wil be increased by 3/4
of 1 % for every 1% that the power factor is less than 85%.
Voltage Discount:
Where Customer takes service from Company's available lines of 2300 volts or higher and
provides and maintains all transformers and other necessar equipment, the voltage discount
based on measured Power wil be:
$0.61 per kW for all kW of Power
Miimum Bil:
The Customer Service Charge.
MONTHLY BILLING REDUCTION: Rates in this Schedule shall be reduced by the monthly
kilowatt-hour credit adjustment set fort under "Monthly Rates" in the curently effective Electrc'Service
Schedule No. 34.
POWER: The kW as shown by or computed from the readigs of Company's Power meter for the
15-miute .period of Customer's greatest use durg the month, determed to the nearest kW.
SEASONAL SERVICE: Service for anually recurg periods of seasonal use where servce is
normally discontinued or curiled durng a part of the year may be contracted for under this Schedule under
either of the following conditions:
(a) Customer may contract for service under this Schedule on a year-round basis paying for all
service, including transformer losses where applicable, under the rates set forth under
"Monthly Bil" above including the monthly mium bil during those months service is
curiled or is not utilized in the Customer's operation.
(Continued)
Submitted Under Case No. PAC-E-ll-12
ISSUED: November 2,2011 EFFECTIV: January 1,2012
.
.
.
~ROCKY MOUNTAIN
~~g~~ORP
Rocky Mountain Power
Exhibit No. 50 Page 7 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Third Revision of Sheet No. 6A.3
Cancelig Second Revision of Sheet No. 6A.3
ELECTRIC SERVICE SCHEDULE NO. 6A -. Contiued
SEASONAL SERVICE: (continued)
(b) Customer may contract for seasonal service under this Schedule with a net miimum
seasonal payment as follows:
. $ 420.00 plus Power and Energy Charges for Customer tag service at less than
2300 volts and
plus Power and Energy Charges for Customer takng service at 2300 volts
or higher.
$1,260.00
CONTRACT PERIOD: One year or longer.
SPECIA CONDITION: Domestic use means all usual residential, aparent, seasonal dwellng,
and mobile home cour use includig domestic water pumping. Farm use means all usual far electrcal
loads for raising. of crops, livestock or pastuage and includes priar processing necessar for safe and
effcient storage or shipment and irrgation pumping.
ContiguoUs parcels of land under single-ownership or leasehold shall be considered to be one Far
and noncontiguous parcels of land under single-ownership or leasehold shall be considered as one Far unit
when operated as a single Far, unless demonstrated otherwise by the owner or lessee of the parcels.
A number of factors shall determe whether contiguous or noncontiguous parcels constitute one or
more Far. These factors shall include, but are not limited to:
-- size
-- use
-- ownership
-- control
-- operatig practices
-- distace between parcels
-- custom in the trade
-- biling treatment by the utility
Operators of Farms may be requied to certify to the utility all irrigation accounts, includighorsepower rating. .
(Continued)
Submitted Under Case No. PAC-E-II-12
ISSUED: November 2, 2011 EFFECTIVE: Janua 1,2012
.
.
.
.~~~~OUNTAIN
Rocky Mountain Power
Exibit No. 50 Page 8 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fourth ReVision of Sheet No. 9.2
Canceling Third Revision of Sheet No. 9.2
ELECTRIC SERVICE SCHEDULE NO.9 - Contiued
MONTm. Y BILL:
Rate:
Biling Months May
though October, Inclusive
Billing Months November
through ApriL, Inclusive
Customer Service
Charge: $347.00 per Customer $347.00 per Customer
Power Rate: $ 9.35 per kW for all kW $ 7.06 per kW for all kW
Energy Rate:3.6970~ per kWh for all kWh 3.6970~ per kWh for all kWh
Power Factor:
This rate is based on the Customer maintaining at all times a power factor of 85% lagging,
or higher, as determed by measurement. If the average power factor is found to be less
than 85% lagging, the Power as. recorded by the Company's meter wil be increased by 3/4
of 1 % for every 1 % that the power factor is less than 85%.
Miimum:
The Customer Service Charge plus the mium Power Charge and appropriate Energy
Charges.
POWER: The kW as shown by or computed from the readings of Company's Power meter for the
15-miute period of Customer's greatest use durng the month, adjusted for power factor as specified,
determned to the nearest kW, but not less than 80 kW.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule wil be in accordace with
the term of the Electrc Service Agreement between the Customer and the Company. The Electric Service
Regulations of the Company on file with and approved by the Idaho Public Utilities Commssion, including
futue applicable amendments, wil be considered as formg a par of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-ll-12
ISSUED: November 2, 2011 EFFECTIVE: Januar 1, 2012
.
.
.
~~~~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 9 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fifth Revision of Sheet No. 10.1
Cancelig Fourth Revision of Sheet No. 10.1
ROCKY MOUNTAI POWER
ELECTRIC SERVICE SCHEDULE NO. 10
STATE OF IDAHO
Irrigation and Soil Drainage Pumping Power Servce
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
of adequate capacity.
APPLICATION: This Schedule is for alternating curent, single or thee-phase electrc service
supplied at the Company's available voltage through a single point of delivery for service to motors on
pumps and machiery used for irgation and soil draiage.
IRRGATION SEASON AN POST-SEASON SERVICE: The Irrigation Season is from June 1
. to September 15 each year. Service for post-season pumping may be taken by the same Customer at the
same point of delivery and though the same facilities used for supplying regular irigation pumping service
during months from September 16 to the following May 31.
MONTHLY BIL:
Irrigation Season Rate
Customer Servce Charge:
Small Pumping Operations:
15 horsepower or less total connected horsepower
served through one service connection - $13.00 per Customer
Large Pumping Operations:
16 horsepower or more total connected horsepower
served though one service connection - $38.00 per Customer
(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: November 2, 2011 EFFECTIVE: Janua 1,2012
.
.
.
~~l~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 10 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Sixth Revision of Sheet No. 10.2
Cancelig Fifth Revision of Sheet No. 10.2
ELECTRIC SERVICE SCHEDULE No. 10 - Contiued
MONTHLY BILL: (Continued)
Power Rate:$5.31 per kW for all kW
Energy Rate:7.9434fC per kWh for first 25,000 kWh
5.8755fC per kWh for the next 225,000 kWh
4.3368fC per kWh for all additional kWh
Power Factor: This rate is based on the Customer maintaining at all times a power factor
of 85% lagging, or higher, as determned by measurement. If the average power factor is
found to be less than 85% lagging, the power as recorded by the Company's meter wil be
increased by 3/4 of 1 % for every 1 % that the power factor is less than 85%.
Minimum:The Customer Service Charge.
Post-Season Rate
Customer Servce Charge:
Energy Rate:
$21.00 per Customer
6.7187fC per kWh for all kWh
Minimum:The Customer Service Charge.
ADJUSTMENTS: All monthly bils shall be adjusted in accordace with Schedules 34 and 94.
PAYMENT: All monthly service bilings wil be due and payable when rendered and wil be
considered delinquent if not paid within fifteen (15) days. An advance payment may be required of the
Customer by the Company in accordance with Electric Servce Regulation NO.9. An advance may be
required under any of the following conditions:
(1) the Customer failed to pay all amounts owed to the Company when due and
payable;
(2) the Customer paid an advance the previous season that did not adequately cover
bils for the entire season and the Customer failed to pay any balance owing by the
due date of the final.biling issued for the season.
(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: November 2, 2011.EFFECTIV: Janua 1, 2012
.
.
.
~ROCKY MOUNTAIN
~~2~~~ORP
Rocky Mountain Power
Exhibit No. 50 Page 11 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Sixth Revision of Sheet No. 19.2
Canceling Fifth Revision of Sheet No. 19.2
ELECTRIC SERVICE SCHEDULE NO. 19 - Continued
MONTHLY BILL:
Rate for space heatig:
Billing Months May
though October, Inclusive
Biling Months November
though ApriL, Inclusive
Customer
Service Charge: $22.00 $22.00 per Customerper Customer
Energy Rate: 8.8093~per kWh for all kWhper kWh for all kWh 6.5274~
Rate for all other service:
All other service requirements wil be supplied under Electrc Service Schedule No.6, or
Electrc Service Schedule No. 6A, or Electric Service Schedule No. 23, or Electrc Service
. Schedule No. 23A,. or Electrc Service Schedule No.35, or Electrc Service Schedule No. 35A.
SPACE HEATING: All space heating equipment shall be permanently installed and shall be the
sole means of heating the building space occupied by the Customer. All space heating equipment and
installation thereof and all supply wiring shall conform .with the Company's specifications.
AIR CONDITIONIG: All air conditioning equipment shall be permanently installed and shall be
the sole means of providing comfor cooling for the building space occupied by the Customer. All air
conditioning equipment and installation thereof and all supply wirg shall conform with the Company's
specifications. Electrc service for comfort coolig wil be metered and biled at the above rate only when
Customer also uses electrc service for his total space heating requirements.
WATER HEATING: Water heaters served hereunder shall be insulated storage, single or multiple-
unit tye of constrction approved by the Company, the heating units of which shall be noninductive and
controlled by separate thermostats. Electrc service of storage water heating will be metered and biled at the
above rate only when Customer also uses electric service for his total space heatig requirements.
(Continued)
Submitted Under Case No. PAC-E-l1-12
ISSUED: November 2, 2011 EFFECTIVE: Janua 1,2012
.
.
.
~~l~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 12 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.V.C. No.1
Fourth Revision of Sheet No. 23.1
Canceling Third Revision of Sheet No. 23.1
ROCKY MOUNTAI POWER
ELECTRC SERVICE SCHEDULE NO. 23
STATE OF IDAHO
General Servce
AVAIABILITY: At any point on the Company's interconnected system where there are facilties of
adequate capacity.
APPLICATION: Ths Schedule is for alternatig curent, single or thee-phase electrc service
supplied at Company's available voltage though one meterig installation at a single point of delivery for all
service requied on the prenuses.
MONTHY BILL:
Biling Months May
through October, Inclusive
Billig Months November
though ApriL. Inclusive
Customer Servce
Charge:
Secondar voltage
delivery (Less than
2300 volts) $15.00 per Customer $15.00 per Customer
Primar voltage
delivery (2300 volts
or higher) $46.00 per Customer $46.00 per Customer
Energy Rate:7.4928~ per kWh for all kWh8.5835~ per kWh for all kWh
(Contiued)
Subnutted Under Case No. PAC-E-l 1-12
ISSUED: November 2,2011 EFFECTIVE: Janua 1,2012
.
.
.
~~ie~OUNTAIN
Rock Mountain Power
Exhibit No. 50 Page 13 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Third Revision of Sheet No. 23.2
Cancelig Second Revision of Sheet No. 23.2
ELECTRC SERVICE SCHEDULE NO. 23 - Contiued
Power Factor:
Ths rate is based on the Customer maintaing at all ties a power factor of 85% lagging, or
higher, as determed by measurement. If the average power factor is found to be less than
85% lagging, Customer wil be biled for 3/4 of 1% of the Power recorded by the Company's
meter for every 1 % that the power factor is less than 85%. Ths Power wil be billed at the
Power Rate stated in Electrc Service Schedule NO.6.
Voltage Discount:
Where Customer taes servce from Company's available lies of 2,300 volts or higher and
provides and mantas all transformers and other necessar equipment, the voltage discount
based on measurd Energy.will be:
0.4146jt per kWh for all kWh.
Miiiium Bil:
The Customer Service Charge
POWER: The kW as shown by or computed from the readgs of the Company's Power meter for
the 15-miute period of Customer's greatest use durg the month, detered to the nearest kW.
SEASONAL SERVICE: Servce for anually recurg periods of seasonal use where servce is
normlly discontinued or curled durg a par of the year may be contrcted for under ths Schedule under
either of the followig conditions:
(a) Customer may contract for service under this Schedule on a yea-round basis paying for all
servce, includig transformer losses where applicable, under the rates set fort under
"Monthly Bil" above includig the monthly mium bil durg those months service is
curiled or is not utilized in the Customer's operations.
(b) Customer may contrct for seasonal servce under this Schedule with a net mium seasonal
payment as follows:
$180.00 plus Energy Charges for Customer tang service at less than 2,300 volts and
$552.00 plus Energy Charges for Customer tag servce at 2,300 volts or higher.
CONTRACT PERIOD: One year or longer.
(Contiued)
Submitted Under Case No. PAC-E-1l-12
ISSUED: November 2,2011 EFFECTIV: January 1,2012
.
.
.
~~tr:OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 14 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fourth Revision of Sheet No. 23A.l
Cancelig Third Revision of Sheet No. 23A.l
ROCKY MOUNTAI POWER
ELECTRC SERVICE SCHEDULE NO. 23A
STATE OF IDAHO
General Servce (Residential and Farm)
AVAILABILITY: At any point on the Company's interconnected system where there are facilties of
adequate capacity for service to any customer who qualifies as a "Residential Load" or "Far Load" under both
(1) the Pacific Nortwest Electrc Power Plang and Conservation Act, P.L. 96:.501 as the same may be
amended, and (2) a Residential Puchase and Sale Agreement, under Section 5( c) of such Act and in effect
between the Company and the Bonneville Power Admstration.
APPLICATION: This Schedule is for alternating curent, single or thee-phase electrc servce
supplied at Company's available voltage though one meterig installation at a single point of delivery for all
service required on the premises.
MONTHY BILL:
Biling Months May
through October, Inclusive
Biling Months November
though ApriL, Inclusive
Customer Servce
Charge:
Secondary voltage
delivery (Less than
2300 volts) $15.00 per Customer $15.00 per Customer
Pri voltage
delivery (2300 volts
or higher) $46.00 per Customer $46.00 per Customer
Energy Rate:7.4928~ per kWh for all kWh8.5835~ per kWh for all kWh
(Contiued)
Submitted Under Case No. PAC-E-11-12
ISSUED: November 2,2011 EFFECTIVE: Janua 1,2012
.
.
.
~~l~OUNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 15 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Third Revision of Sheet No. 23A.2
Canceling Second Revision of Sheet No. 23A.2
ELECTRC SERVICE SCHEDULE NO. 23A - Contiued
Power Factor:
Ths rate is based on the Customer maintaing at all ties a power factor of 85% lagging, or
higher, as determed by measurement. If the average power factor is found to be less th
85% lagging, Customer wil be biled for 3/4 of 1 % of the Power recorded by the Company's
meter for every 1 % that the power factor is less than 85%. Ths Power will be biled at the
Power Rate stated in Electrc Service Schedule NO.6.
Voltage Discount:
Where Customer takes service from Company's available lies of 2,300 volts or higher and
provides and maitains all transformers and other necessar equipment, the voltage discount
based on measured Energy will be:
0.4146t per kWh for all kWh.
Minimum Bil:
The Customër Service Charge
POWER: The kW as shown by or computed from the readigs of the Company's Power meter for
the 15-miute period of Customer's greatest use durg the month, determed to the nearest kW.
MONTHLY BILLING REDUCTION: Rates il ths Schedule shall be reduced by the monthy
kilowatt-hour credit adjustment set fort under "Monthy Rates" in the curently effective Electrc ServceSchedule No. 34. .
SEASONAL SERVICE: Servce for anually recurg periods of seasonal use where servce is
normlly discontiued or curiled durg a par of the year may be contrcted for under ths Schedule under
either of the following conditions:
(a) Customer may contract for service under ths Schedule on a year-round basis payig for all
service, includig transformer losses where applicable, under the rates set fort under
"Monthy Bil" above including the monthly mium bil durg those months service is
curiled or is not utilized in the Customer's operations.
(Continued)
Submitted Under Case No. PAC-E-11-12
. ISSUED: November 2, 2011 EFFECTIV: Janua 1,2012
.
.
.
~~t"0UNTAIN
Rocky Mountain Power
Exhibit No. 50 Page 16 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Second Revision of Sheet No.. 23A.3
Cancelig First Revision of Sheet No. 23A.3
ELECTRIC SERVICE SCHEDULE NO. 23A - Contiued
SEASONAL SERVICE: (continued)
(b) Customer may contract for seasonal servce under ths Schedule with a net miimum seasonal
payment as follows:
$180.00 plus Energy Charges for Customer tang service at less than 2,300 volts and
$552.00 plus Energy Charges for Customer tang service at 2,300 volts or higher.
CONTRACT PERIOD: One year or longer.
SPECIA CONDmON: Domestic use mean all usual residential, aparent, seasonal dwellig,
and mobile home cour use including domestic water pumping. Far use means all usua far electrcal loads
for raising of crops, livestock or pastuage and includes prima processing necessar for safe and effcient
storage or shipment and irgation pumping.
Contiguous parcels ofland under single-ownership or leasehold shall be considered to be one Far and
noncontiguous parcels of land under single-ownership or leasehold shall be considered as one Far unt when
operated as a single Far, unless demonstrted otherwise by the owner or lessee of the parcels.
A number of factors shall determe whether contiguous or noncontiguous parcels constitute one or
more Far. These factors shall include, but ar not litedto:
size
use
ownership
control
operating practices
distace between parcels
custom in the trde
biling treatment by the utilty
Operators of Fars may be requied to certfy to the utilty all irgation accounts, includig
horsepower ratig.
Customers who feel they meet the defintions of a Far wil have to mae application with the
Company for review. If Customer application is denied by the Company, the Customer may appeal the
decision to the Idao Public Utilities Commssion.
(Continued)
Submitted Under Case No. PAC-E-ll-12
ISSUED: November 2,201 i EFFECTIV: January i, 2012
.
.
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~~;~OUNTAIN
Rocky Mountain Power .
Exhibit No. 50 Page 17 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fifth Revision of Sheet No. 35.2
Cancelig Fourth Revision of Sheet No. 35.2
ELECTRIC SERVICE SCHEDULE NO. 35 - Continued
MONTHLY BILL:
Customer Service Charge:
Secondary voltage delivery
(Less than 2300 volts)
Priar voltage delivery
(2300 volts or higher)
$ 63.00 per Customer
$155.00 per Customer
Power Charge:
On-PeakkW $ 15.49 per kW
Energy Charge:
Per kWh for all kWh 4.6154jt
TIME PERIODS:
On-Peak
Off-Peak
7:00 a.m. to 10:00 p.m., Monday th Friday, except holidays.
All other times.
Due to the expansions of Daylight Saving Time (DST) as adopted under Section 110 of the
U.S. Energy Policy Act of 2005 the time periods shown above wil begin and end one hour later for the
period between the second Sunday in March and the first Sunday in April, and for the period between the
last Sunday in October and the first Sunday in November.
Holidays include only New Year's Day, President's Day, Memorial Day, Independence Day,
Labor Day, Thanksgiving Day, and Christmas Day. When a holiday falls on a Satuday or Sunday, the
Friday before the holiday (if the holiday falls on a Satuday) or the Monday following the holiday (if the
holiday falls on a Sunday) wil be considered a holiday and consequently Off-Peak.
Power Factor: This rate is based on the Customer maintaining at all times a Power factor of 85%
lagging, or higher, as determned by measurement. If the average Power factor is found to be less than 85%
lagging the Power as recorded by the Company's meter wil be increased by 3/4 of 1 % for every 1 % that the
Power factor is less than 85%.
Voltage Discount: Where Customer takes service from Company's available lines of 2,300 volts or
higher and provides and maintains all trsformers and other necessar equipment, the voltage discount
based on highest measured Power durg the biling cycle wil be:
$0.79 perkW
Miimum:Customer Service Charge plus applicable Demand and Energy charges.
(Contiued)
Submitted Under Case No. PAC-E-ll-12
ISSUED: November 2, 2011 EFFECTIVE: Janua 1,2012
.
.
.
",ROCKY MOUNTAIN
~~2Y!~~ORP
Rocky Mountain Power
Exhibit No. 50 Page 18 of 48
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Third Revision of Sheet No. 35.3
Cancelig Second Revision of Sheet No. 35.3
ELECTRIC SERVICE SCHEDULE NO. 35 - Contiued
POWER: The On-Peak kW shall be the kW as shown by or computed from the readings of
Company's Power meter for the l5-miute period of Customer's greatest use durg the On-Peak periods
durng the month as previously defined, adjusted for Power Factor as specified, determned to the nearest
kW.
SEASONAL SERVICE: Servce for anually recurg periods of seasonal use where servce
is normlly discontinued or curailed durng a part of the year may be contracted for under this schedule
. under either of the following conditions:
(a) Customer may contract for service under ths schedule on a year-round basis paying for all
service, including transformer losses where applicable, under the rates set fort under
"Monthly Bil" above includig the monthly minium bil durg those months service is
curailed or is not utilized in the Customer's operation.
(b)Customer may contract for seasonal service under this schedule with a net minimum
seasonal payment as follows:
$ 756.00 plus Power and Energy Charges for Customer tag service at less than
2300 volts, and
$1,860.00 phis Power and Energy Charges for Customer tag service at 2300 volts or
. higher.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule wil be in
accordance with the term of the Electric Service Agreement between the Customer and the Company. The
Electric Service Regulations of the Company on file with and approved by the Idao Public Utilities
Commssion, includig futue applicable amendments, wil be considered as forming a par of and
incorporated in said Agreement.
Submitted Under Case No. PAC-E-I 1-12
ISSUED: November 2, 2011 EFFECTIVE: Janua 1,2012
.
.
.
i ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 1 of 24
Case No. PAC.E.11.12
Witness: J. Ted Weston
A DMSION Of I'ACIfICORP
I.P.U.C. No.1
Second Revision of Sheet No. 7.1
Canceling First Revision of Sheet No. 7.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.7
STATE OF IDAHO
Security Area Lighting
AVAILABILITY: At any point on the Company's interconnected system. No new Mercury Vapor
Lamps wil be installed after May 3, 1985.
APPLICATION: This Schedule is for (1) electric service required for Security Area Lighting and
for Security Flood Lighting service where service is supplied from a Company-owned overhead wood pole
system (2) Low Pressure Sodium Vapor Security Area Lighting and (3) Customer-owned/Customer-
maintained Area Lighting.
MONTHLY BILL:
Rate:
(1) Security Area Lighting
Nominal Lamp Rating:
Initial Lumens Per Lamp Watts
Mercury Vapor Lamp:
7,000
20,000
175
400
$26.67 per lamp
$47.58 per lamp
(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.
I.P.U.C. No.1
ROCKY MOUNTAIN
POWER
A DIVISION Of PAClF1CORP
Rocky Mountain Power
Exhibit No. 51 Page 2 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
Second Revision of Sheet No. 7.2
Canceling First Revision of Sheet No. 7.2
.
.
ELECTRIC SERVICE SCHEDULE NO.7 - Continued
MONTHLY BILL: (continued)
Sodium Vapor Lamps:
5,600 high intensity discharge
9,500 high intensity discharge
16,000 high intensity discharge
27,500 high intensity discharge
50,000 high intensity discharge
Sodium Vapor Flood Lamps:
16,000 high intensity discharge
27,500 high intensity discharge
50,000 high intensity discharge
(Continued)
70
100
150
250
400
150
250
400
$16.94 per lamp on new pole
$13.48 per lamp ifno new
pole is required
$19.40 per lamp on new pole
$15.93 per lamp ifno new
pole is required
$25.55 per lamp on new pole
$22.75 per lamp ifno new
pole is required
$36.75 per lamp on new pole
$33.28 per lamp ifno new
pole is required
$51.37 per lamp on new pole
$45.47 per lamp ifno new
pole is required
$25.55 per lamp on new pole
$22.75 per lamp ifno new
pole is required
$36.75 per lamp on new pole
$33.28 per lamp ifno new
pole is required
$51.37 per lamp on new pole
$45.47 per lamp ifno new
pole is required
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16, 2011 EFFECTIVE: Januar 1,2012
.
.
.
ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 3 of 24
Case No. PAC"E.11.12
Witness: J. Ted Weston
A OIVSION OF PACIFICORP
I.P.U.C. No.1
Second Revision of Sheet No. 7.4
Canceling First Revision of Sheet No. 7.4
ELECTRIC SERVICE SCHEDULE NO.7 - Continued
MONTHLY BILL: (continued)
(2)Low Pressure Sodium Vapor Lamps
Energy Only:
Initial Lumens
8,000
13,500
22,500
33,000
Watts
55
90
135
180
Per Lamp
$ 3.64
$ 5.38
$ 7.48
$ 9.10
SPECIFICA TIONS FOR LOW PRESSURE SODIUM VAPOR LAMPS: Prices
include only energy and a single span of wire to customer's pole. The entire installation
including initial lamp requirements, support poles, and wiring with suitable provision for
connection to Company's system wil be furnished, installed, and maintained by the
customer. Lamps shall be controlled by the customer to bur only durng the period from
dusk to dawn.
(3)Customer-Owned/Customer-Maintained Area Lighting
Energy Only:
Initial Lumens
16,000 Sodium Vapor Flood
Per Lamp
$14.82
Watts
150
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule wil be in accordance with
the terms of the Electric Service Agreement between the Customer and the Company. The Electric Service
Regulations of the Company on fie with and approved by the Idaho Public Utilties Commission, including
future applicable amendments, wil be considered as forming a part of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 4 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
A DMStON Of PAClflCORP
I.P.U.C. No.1
Second Revision of Sheet No.7 A.I
Canceling First Revision of Sheet No. 7A.I
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 7A
STATE OF IDAHO
Security Area Lighting (Residential and Farm)
.
AVAILABILITY: At any point on the Company's interconnected system for service to any
customer who qualifies as a "Residential Load" or "Farm Load" under both (1) the Pacific Northwest
Electrc Power Planning and Conservation Act, P.L. 96-501 as the same may be amended, and (2) a
Residential Purchase and Sale Agreement, under Section 5( c) of such Act and in effect between the
Company and the Bonnevile Power Admnistration. No new Mercury Vapor Lamps wil be installed after
May 3,1985.
APPLICATION: This Schedule is for electric service required for Security Area Lighting and for
Security Flood Lighting service where service is supplied from a Company-owned overhead wood pole
system.
MONTHLY BILL:
Rate:
(1) Security Area Lighting
Nominal Lamp Rating:
Initial Lumens Watts Per Lamp
Mercury Vapor Lamp:
7,000
20,000
175
400
$26.67 per lamp
$47.58 per lamp
(Continued).
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.ROCKY MOUNTAIN
POWER
A aivStON Of PAClflCORP
Rocky Mountain Power
Exhibit No. 51 Page 5 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No. i
Second Revision of Sheet No.7 A.2
Canceling First Revision of Sheet No. 7A.2
ELECTRIC SERVICE SCHEDULE NO.7 A - Continued
MONTHLY BILL: (continued)
Rate:
Sodium Vapor Lamps:
5,600 high intensity discharge 70
9,500 high intensity discharge 100
.16,000 high intensity discharge 150
27,500 high intensity discharge 250
50,000 high intensity discharge 400
Sodium Vapor Flood Lamps:
16,000 high intensity discharge 150
27,500 high intensity discharge 250
50,000 high intensity discharge 400
(Continued).
$16.94 per lamp on new pole
$13.48 per lamp ifno new
pole is required
$19.40 per lamp on new pole
$15.93 per lamp ifno new
pole is required
$25.55 per lamp on new pole
$22.75 per lamp ifno new
pole is required
$36.75 per lamp on new pole
$33.28 per lamp ifno new
pole is required
$51.37 per lamp on new pole
$45.47 per lamp ifno new
pole is required
$25.55 per lamp on new pole
$22.75 per lamp ifno new
pole is required
$36.75 per lamp on new pole
$33.28 per lamp ifno new
pole is required
$51.37 per lamp on new pole
$45.47 per lamp ifno new
pole is required
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.~~;:OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 6 of 24
Case No. PAC-E.11.12
Witness: J. Ted Weston
I.P.U.C. No.1
Second Revision of Sheet No.7 A.4
Canceling First Revision of Sheet No.7 A.4
ELECTRIC SERVICE SCHEDULE NO. 7A - Continued
MONTHLY BILL: (continued)
(2) Low Pressure Sodium Vapor Lamps
Energy Only:
Initial Lumens
8,000
13,500
22,500
33,000
Watts
55
90
135
180
Per Lamp
$ 3.64
$5.38
$ 7.48
$ 9.10
.SPECIFICATIONS FOR LOW PRESSURE SODIUM VAPOR LAMPS: Prices
include only energy and a single span of wire to customer's pole. The entire installation
including initial lamp requirements, support poles, and wiring with suitable provision for
connection to Company's system wil be furished, installed, and maintained by the
customer. Lamps shall be controlled by the customer to bum only during the period from
dusk to dawn.
CONTRACT PERIOD: One year or longer.
SPECIAL CONDITION: Domestic use means all usual residential, apartment, seasonal dwellng,
and mobile home court use including domestic water pumping. Farm use means all usual farm electrcal
loads for raising of crops, livestock or pasturage and includes primary processing necessary for safe and
efficient storage or shipment and irrigation pumping.
Contiguous parcels of land under single-ownership or leasehold shall be considered to be one Farm
and noncontiguous parcels of land under single-ownership or leasehold shall be considered as one Farm unit
when operated as a single Farm, unless demonstrated otherwise by the owner or lessee of the parcels.
(Continued).
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 7 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
A DMSlON OF PACIFICORP
I.P.U.C. No.1
Third Revision of Sheet No. 11.1
Canceling Second Revision of Sheet No. 11.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 11
STATE OF IDAHO
Street Lighting Service
Company-Owned System
A V AILABILITY:In all territory served by the Company in the State of Idaho.
.APPLICATION: To unmetered lighting service provided to municipalities or agencies of
municipal, county, state or federal governents for dusk to dawn ilumination of public streets, highways
and thoroughfares by means of Company owned, operated and maintained street lighting systems controlled
by a photoelectric control or time switch.
MONTHLY BILL:
tables below.
The Monthly Biling shall be the rate per luminaire as specified in the rate
.Hifg taPor
!:1!~e!! R~ti!1g, _ _ _ _ _5,800*9,500 16,000 27,500 50,000
Watts 70 100 150 250 400-------------
Monthly kWh 28 39 59 96 148
Functional Lighting $15.05 $18.78 $25.60 $35.75 $52.48
Decorative - Series 1 N/A $31.06 $34.09 $N/A N/A
Decorative - Series 2 N/A $25.56 $28.51 $N/A N/A
Metal Hâliã.é
_ ~i:rr~~ _R~ti_nR _ _ _. _ _ _ . _9,000 12,000 19,500 32,000
Watts 100 175 250 400~ . ~ . . - . - - - - - - . .. - . - - - - . - - . - -
Monthly kWh 39 69 93 145
Functional Lighting N/A $27.71 $34.39 $41.72
Decorative - Series 1 $31.33 $36.02 N/A $N/A
Decorative - Series 2 $30.49 $32.19 N/A N/A
* Existing fixtures only. Service is not available under this schedule to new 5,800 lumen High
Pressure Sodium vapor Fixtures..(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.~~1~~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 8 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Fourth Revision of Sheet No. 12.1
Canceling Third Revision of Sheet No. 12.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 12
STATE OF IDAHO
Street Lighting Service
Customer-Owned System
AVAILABILITY: In all terrtory served by the Company in the State ofIdaho..APPLICATION: To lighting service provided to municipalities or agencies of municipal, county,
state or federal governments for dusk to dawn ilumination of public streets, highways and thoroughfares by
means of Customer owned street lighting systems controlled by a photoelectrc control or time switch.
MONTHLY BILL:
1. Energy Only Service - Rate per Luminaire
Energy Only Service includes energy supplied from Company's overhead or underground circuits
and does not include any maintenance to Customer's facilities.
The Monthly Biling shall be the rate per luminaire as specified in the rate tables below.
I:u!1e~ ~~tin,g_ _ _ _ _ _5,800 9,500 16,000 27,500
Watts 70 100 150 250
Monthl kWh 28 39 59 96
Ener $2.82 $3.95 $5.87 $10.04
50,000
400
148
$15.43
(Continued).
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: Januar 1,2012
.~~l~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 9 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
Third Revision of Sheet No. 12.2
Canceling Second Revision of Sheet No. 12.2
ELECTRIC SERVICE SCHEDULE NO. 12 - Continued
MONTHLY BILL: (continued)
Metal Halide.... No Main:tellanee I
Lumen !t~tin,g_9,000 12,000 19,500 32,000 107,800-----
_ 'Y~t~s_100 175 250 400 1000----------
Monthly kWh 39 69 93 145 352
Energy Only Service $3.99 $7.01 $9.59 $15.08 $36.10
.
LowPresSUreSôdiûllVapor ..No
Maintenance
Lumen !t~tin,g_33,000------
Watts 1 80- - - ------------
Monthly kWh 74
Energy Only Service $9.1 1
For non-listed luminaires, the cost wil be calculated for 3940 annual hours of operation including
applicable loss factors for ballasts and starting aids at the cost per kWh given below.
2. Maintenance Service (No New Servce)
Monthly maintenance is only applicable for existing monthly maintenance service agreements in
effect prior to June 29, 2007.
A. Street Lighting, "Partial Maintenance"
CJ'+r,'!~...ru.i
_ I:up~~ R~anß _ _ _ _10,000 20,000
Watts 250 400-------------
Monthly kWh 93 145
Partial Maintenance
Service $16.32 $21.85.(Continued)
Submitted Under Case No. PAC-E-11-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 10 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
A DIVISION OF PACIFICORP
I.P.U.C. No.1
Third Revision of Sheet No. 12.3
Canceling Second Revision of Sheet No. 12.3
ELECTRIC SERVICE SCHEDULE NO. 12 - Continued
MONTHLY BILL: (continued)
):,u,!_e!! ~!!tin,g _ _ _ _
Watts-------------
Monthl kWh
Partial Maintenance
Service
9,500
100
39
27,500
250
96
50,000
400
148
$7.52 $12.07 $16.26
B. Street Lighting, "Full Maintenance".ølgchPl'essul'ê$ødium -
Ilùll.MaintênllD:Ce
_L!lP~1l R~i!1~-----5,800 9,500 16,000 27,500 50,000
Watts 70 100 i 50 250 400----------
Monthlv kWh 28 39 59 96 148
Full Maintenance
Service $6.52 $8.3 1 $9.98 $13.08 $17.45
SPECIFICATIONS AND SERVICE FOR STREET LIGHTING WITH PARTIAL AND
FULL MAINTENANCE (NO NEW SERVICE): Installations must have met Company
construction standards in place at the time of installation in order to receive "full maintenance."
If Company is unable to obtain materials to perform maintenance, the street light facilties wil
be deemed obsolete and must be upgraded at customer expense in order to qualify for
maintenance under the Electrc Service Schedule. Street Lighting Service under "partial
maintenance" includes energy, lamp and glassware renewals and cleaning of glassware.
Street Lighting Service under "full maintenance" includes energy, lamp and glassware
replacements and cleaning of glassware, and replacement of damaged or inoperative
photocells, ballasts, starting aids, poles, mast arms and luminaires: provided, however, that any
costs for materials which are over and above costs for Company's standard materials, as
determned by the Company, are not included in this Electric Service Schedule. Such extra
costs shall be paid by Customer. Burning-hours oflamps wil be controlled by the Company.
(Continued).
Submitted Under Case No. PAC-E-II-12
ISSUED: December 16,2011 EFFECTIVE: January 1,2012
.
.
.
Rocky Mountain Power
Exhibit No. 51 Page 11 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I I.P.U.C. No.1
JLSccond Revision of Sheet No. 7.1
Canceling Original First Revision of Sheet No. 7.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.7
STATE OF IDAHO
Security Area Lighting
AVAILABILITY: At any point on the Company's interconnected system. No new Mercury Vapor
Lamps wil be installed after May 3, 1985.
APPLICATION: This Schedule is for (1) electric service required for Security Area Lighting and
for Security Flood Lighting service where service is supplied from a Company-owned overhead wood pole
system (2) Low Pressure Sodium Vapor Security Area Lighting and (3) Customer-owned/Customer-
maintained Area Lighting.
MONTHLY BILL:
Rate:
(1) Security Area Lighting
Nominal Lamp Rating:
Initial Lumens Per Lamp Watts
Mercury Vapor Lamp:
7,000
20,000
175
400
$26.4467 per lamp
$47.4958 per lamp
(Continued)
Submitted Under Order No. 30482Case No. PAC-E-l 1-12
ISSUED: December 28, 2007Dccember 16,2011 EFFE
.
.
.
I I.P.U.C. No. i
ROCKY MOUNTAIN
POWER
A DIVSION Of PAClflCORP
Rocky Mountain Power
Exhibit No. 51 Page 12 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
FiSecond Revision of Sheet No. 7.2
Canceling Origillal First Revision of Sheet No. 7.2
ELECTRIC SERVICE SCHEDULE NO.7 - Continued
MONTHLY BILL: (continued)
Sodium Vapor Lamps:
5,600 high intensity discharge
pole
9,500 high intensity discharge
pole
16,000 high intensity discharge
pole
27,500 high intensity discharge
pole
no new
50,000 high intensity discharge
on new pole
Sodium Vapor Flood Lamps:
16,000 high intensity discharge
pole
27,500 high intensity discharge
pole
no new
70
100
150
250
400
150
250
$16.1+94 per lamp on new
$ 13.M48 per lamp ifno new
pole is required
$ 19..iO per lamp on new
$15.1+93 per lamp ifno new
pole is required
$25.'255 per lamp on new
$22.£75 per lamp ifno new
pole is required
$36..J75 per lamp on new
$~33.28 per lamp if
pole is required
$~51.7 per lamp
$45.~7 per lamp ifno new
pole is required
$25.'255 per lamp on new
$22.£75 per lamp ifno new
pole is required
$36..J75 per lamp on new
$~33.28 per lamp if
pole is required
Submitted Under Case No. PAC-E-I J-IlOrder No. 30482
ISSUED: December 28, 2007Decembcr 16,201 J EFFE
.
.
.
I.P.U.C. No.1
ROCKY MOUNTAIN
POWER
A OIVSION OF PACIFICORP
Rocky Mountain Power
Exhibit No. 51 Page 13 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
FiSccond Revision of Sheet No. 7.2
Canceling Origiiiul First Revision of Sheet No. 7.2
50,000 high intensity discharge
on new pole
(Continued)
400 $~51.37 per lamp
$45.007 per lamp ifno new
pole is required
Submitted Under Case No. PAC-E-l 1.:0rder No. 304~
ISSUED: December 28, 2007December 16,2011 EFFE
.
.
.
~~loo~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 14 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I I.P.U.C. No.1
FiSecond Revision of Sheet No. 7.4
Canceling HrigitHtlFirst Revision of Sheet No. 7.4
ELECTRIC SERVICE SCHEDULE NO.7 - Continued
MONTHLY BILL: (continued)
(2)
(3)
Low Pressure Sodium Vapor Lamps
Energy Only:
Initial Lumens
8,000
13,500
22,500
33,000
Watts
55
90
135
180
Per Lamp
$ 3.6064
$ 5.~38
$ 7.4G8
$ 9.o-1Q
SPECIFICA nONS FOR LOW PRESSURE SODIUM VAPOR LAMPS: Prices
include only energy and a single span of wire to customer's pole. The entire installation
including initial lamp requirements, support poles, and wiring with suitable provision for
connection to Company's system wil be furnished, installed, and maintained by the
customer. Lamps shall be controlled by the customer to burn only during the period from
dusk to dawn.
Customer-OwnedJCustomer-Maintained Area Lighting
Energy Only:
Initial Lumens
16,000 Sodium Vapor Flood
Per Lamp
$ 14.t4,s_i
Watts
150
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULA nONS: Service under this Schedule wil be in accordance with
the terms of the Electric Service Agreement between the Customer and the Company. The Electric Service
Regulations of the Company on fie with and approved by the Idaho Public Utilties Commission, including
futue applicable amendments, wil be considered as formng a part of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-11-12Gfl:lef No. 30482
EFFEISSUED: December 28, 2007December 16, 2011
.
.
.
~~1",~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 15 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I I.P.U.C. No. I
~Second Revision of Sheet No.7 A.I
Canceling Original First Revision of Sheet No. 7A.I
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.7 A
STATE OF IDAHO
Security Area Lighting (Residential and Farm)
AVAILABILITY: At any point on the Company's interconnected system for service to any
customer who qualifies as a "Residential Load" or "Farm Load" under both (1) the Pacific Northwest
Electric Power Planning and Conservation Act, P.L. 96-501 as the same may be amended, and (2) a
Residential Purchase and Sale Agreement, under Section 5( c) of such Act and in effect between the
Company and the Bonnevile Power Admnistration. No new Mercury Vapor Lamps wil be installed after
May 3,1985.
APPLICATION: This Schedule is for electric service required for Security Area Lighting and for
Security Flood Lighting service where service is supplied from a Company-owned overhead wood pole
system.
MONTHLY BILL:
Rate:
(1) Security Area Lighting
Nominal Lamp Rating:
Initial Lumens Watts Per Lamp
Mercury Vapor Lamp:
7,000
20,000
175
400
$26.4(67 per lamp
$4 7 Jl95~ perlamp
(Continued)
Submitted Under Case No. PAC-E-11-120rder No. 30482
ISSUED: December 2g, 2007December 16. 2011 EFFE
.
.
.
~~;oo~OUNTAIN
I I.P.U.C. No.1
Rocky Mountain Power
Exhibit No. 51 Page 16 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
FlSecond Revision of Sheet No.7 A.2
Canceling (f-i-First Revision of Sheet No.7 A.2
ELECTRIC SERVICE SCHEDULE NO. 7A - Continued
MONTHLY BILL: (continued)
Rate:
Sodium Vapor Lamps:
5,600 high intensity discharge
pole
9,500 high intensity discharge
pole
16,000 high intensity discharge
pole
27,500 high intensity discharge
pole
no new
50,000 high intensity discharge
on new pole
Sodium Vapor Flood Lamps:
16,000 high intensity discharge
pole
27,500 high intensity discharge
pole
70
100
150
250
400
150
250
$16.+194 per lamp on new
$ 13.J448 per lamp ifno new
pole is required
$1 %W40 per lamp on new
$15.+193 per lamp ifno new
pole is required
$25.i955 per lamp on new
$22..§75 per lamp ifno new
pole is required
$36.3-75 per lamp on new
$~33.28 per lamp if
pole is required
$~51.37 per lamp
$45.QM7 per lamp ifno new
pole is required
$25.:&55 per lamp on new
$22..§75 per lamp ifno new
pole is required
$36.377S. per lamp on new
Submitted Under Case No. PAC-E- I I - I 20rder No. 30482
ISSUED: December 28, 2007December 16, 20 II EFFE
.~~;,"~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 17 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
FiSecond Revision of Sheet No.7 A.2
Canceling (Jrigiul\l-First Revision of Sheet No.7 A.2
no new
50,000 high intensity discharge
on new pole
400
(Continued)
.
.
$J2",94Jl-"f.8.per lamp if
pole is required
$~51.37 per lamp
$45.007 per lamp ifno new
pole is required
Submitted Under Case No. PAC-E- J 1-120rder No. 30482
ISSUED: December 28. 2007December 16.2011 EFFE
.
.
.
~~~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 18 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I I.P.U.C. No.1
FiSccond Revision of Sheet No.7 A.4
Canceling Original First Revision of Sheet No. 7A.4
ELECTRIC SERVICE SCHEDULE NO. 7A - Continued
MONTHLY BILL: (continued)
(2) Low Pressure Sodium Vapor Lamps
Energy Only:
Initial Lumens
8,000
13,500
22,500
33,000
Per Lamp
$ 3.tt64
$5.~38
$ 7.448
$ 9AHlQ
Watts
55
90
135
180
SPECIFICATIONS FOR LOW PRESSURE SODIUM VAPOR LAMPS: Prices
include only energy and a single span of wire to customer's pole. The entire installation
including initial lamp requirements, support poles, and wiring with suitable provision for
connection to Company's system wil be furnished, installed, and maintained by the
customer. Lamps shall be controlled by the customer to bum only during the period from
dusk to dawn.
CONTRACT PERIOD: One year or longer.
SPECIAL CONDITION: Domestic use means all usual residential, apartment, seasonal dwellng,
and mobile home court use including domestic water pumping. Farm use means all usual farm electrical
loads for raising of crops, livestock or pasturage and includes primary processing necessary for safe and
effcient storage or shipment and irrigation pumping.
Contiguous parcels of land under single-ownership or leasehold shall be considered to be one Farm
and noncontiguous parcels of land under single-ownership or leasehold shall be considered as one Farm unit
when operated as a single Farm, unless demonstrated otherwise by the owner or lessee of the parcels.
(Continued)
Submitted Under Case No. PAC-E-ll-120rder No. 30482
ISSUED: December 28, 2007December 16. 2011 EFFE
.
.
.
ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 19 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
A OIVISJON Of PAClflCORP
I I.P.U.C. No.1
SeeoaEl Third Revision of Sheet No. 11.1
Canceling FwS't-Second Revision of Sheet No. 11.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 11
STATE OF IDAHO
Street Lighting Service
Company-Owned System
AVAILABILITY:In all terrtory served by the Company in the State of Idaho.
APPLICATION: To unmetered lighting service provided to municipalities or agencies of
municipal, county, state or federal governents for dusk to dawn ilumination of public streets, highways
and thoroughfares by means of Company owned, operated and maintained street lighting systems controlled
by a photoelectric control or time switch.
MONTHLY BILL:
tables below.
The Monthly Biling shall be the rate per luinnaire as specified in the rate
Hfio,h'Vapor
!:~e!! Rl!ti!111 _ _ _5,800*9,500 16,000 27,500 50,000
Watts 70 100 150 250 400-----------
MonthlvkWh 28 39 59 96 148
Functional Lighting $.J15 .05 $18.~78 $25.::60 $35.l875 $~52.4&
Decorative -$~31.0 $~34.0
Series 1 N/A 6 9 $N/A N/A
Decorative -
Series 2 N/A $25.*956 $28.U51 $N/A N/A
M~t.l.âlide
_ ~i:rn~i~)t~t~ng_ _ _ _ _ _ _ _ . .9,000 12,000 19,500 32,000
Watts 100 175 250 400.......................................
Monthly kWh 39 69 93 145
$$
Functional Lighting N/A $27.4,71 34.W39 41.2&72
Decorative -Series 1 $31.0033 $~36.02 N/A $N/A
Decorative -Series 2 $30.+79 $~32.19 N/A N/A
Submitted Under Case No. PAC-E-11-120rder No. 30482
ISSUED: December 28, 2007December 16. 2011 EFFE
t.
.
.
~~;~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 20 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I.P.U.C. No.1
8eCOfld Third Revision of Sheet No.1 1.1
Canceling Fir-st-Second Revision of Sheet No.1 1.2
* Existing fixtures only. Service is not available under this schedule to new 5,800 lumen High
Pressure Sodium vapor Fixtures.
(Continued)
Submitted Under Case No. PAC-E-II-120rder No. 30482
ISSUED: December 28. 2007December 16.2011 EFFE
t.
.
.
~~;oo~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 21 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I I.P.U.C. No.1
~Fourth Revision of Sheet No. 12.1
CanceUng Second 'Iliird Revision of Sheet No. 12.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 12
STATE OF IDAHO
Street Lighting Service
Customer-Owned System
A V AILABILITY: In all terrtory served by the Company in the State of Idaho.
APPLICATION: To lighting service provided to municipalities or agencies of municipal, county,
state or federal governments for dusk to dawn ilumination of public streets, highways and thoroughfares by
means of Customer owned street lighting systems controlled by a photoelectrc control or time switch.
MONTHLY BILL:
1. Energy Only Service - Rate per Luminaire
Energy Only Service includes energy supplied from Company's overhead or underground circuits
and does not include any maintenance to Customer's facilities.
The Monthly Biling shall be the rate per luminaire as specified in the rate tables below.
~ig~press~Fe...S()dium. vapor-...No..1
Maiiitenance
Lumen ~~tini_5,800 9.500 16,000 27,500 50,000----
Watts 70 100 1 50 250 400
Monthly kWh 28 39 59 96 148
Energy Only $2.+9 $3.9-1-2 $9,..: 1 0.0
Service 82 5 $5A487 4 $1 5.:23
(Continued)
Submitted Under AdvH:e Letter No. 08 02Case No. PAC-E- i 1-12
ISSUED: January i 5, 2008Deccmber J 6, 20 i J EFFECTIVE: February 15, 2008January J. 20 J 2
I.
.
.
~~~l~OUNTAIN
Rocky Mountain Power
Exhibit No. 51 Page 22 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
I I.P.U.C. No.1
See6fld Third Revision of Sheet No. 12.2
Canceling FlSecond Revision of Sheet No. 12.2
ELECTRIC SERVICE SCHEDULE NO. 12 - Continued
MONTHLY BILL: (continued)
/"i".i :)li~J
_ ~u~e~ ~~tini _ _ _9,000 12,000 19,500 32,000 107,800
Watts 100 175 250 400 1000------------
Monthly kWh 39 69 93 145 352
Energy Only $3.9,5 $€r94L~l $-192 J5Jl
Service 99 1 $9.4959 8 $~36.10
LOW.Pressuire SodtumV.por -No
Maiîltenåß~e
Lumen ~~tini 33,000-------
Watts 180--------------
Monthly kWh 74
Energy Only Service $9.0-1 1 1
For non-listed luminaires, the cost wil be calculated for 3940 annual hours of operation including
applicable loss factors for ballasts and staring aids at the cost per kWh given below.
Non-Listed Luminaire $/kWh
$0.10125910233
Energy Only Service 0
2. Maintenance Service (No New Servce)
Monthly maintenance is only applicable for existing monthly maintenance service agreements in
effect prior to June 29, 2007.
A. Street Lighting, "Partial Maintenance"
MereurýVapor -Partial
Mamlenanee
Lumen ~~t!.~10,000 20,000-----
Watts 250 400---------
Monthly kWh 93 145
Partial Maintenance
Service $16.+s32 $2 1 .6185
Submitted Under QràerNø. 30482Case No. PAC-E-I 1-12
ISSUED: December 28, 2007December 16, 2011 EFFE
I.
.
.
~~\;~~OUNTAIN
I I.P.U.C. No. i
Rocky Mountain Power
Exhibit No. 51 Page 23 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
8ee60d Third Revision of Sheet No. 12.2
Canceling FfSccond Revision of Sheet No. 12.2
(Continued)
Submitted Under Order No. 30482Case No. PAC-E-J 1-12
ISSUED: December 28, 2007December 16, 2011 EFFE
I.
.
.
I I.P.U.C. No.1
ROCKY MOUNTAIN
POWER
Rocky Mountain Power
Exhibit No. 51 Page 24 of 24
Case No. PAC-E-11-12
Witness: J. Ted Weston
A DIVISION OF PACIFlCORP
SecoRd Third Revision of Sheet No. 12.3
Canceling llroSt-Second Revision of Sheet No. 12.3
ELECTRIC SERVICE SCHEDULE NO. 12 - Continued
MONTHLY BILL: (continued)
..1-
_ L,up_e!! ~!!tin.s_9,500 27,500 50,000
Watts 100 250 400-------_._-
Monthly kWh 39 96 148
Partial
Maintenance $7.44 $-l12.0 $ 16,(Wi
Service 52 7 6
B. Street Lighting, "Full Maintenance"
ß:i~~ Pre$sUrê~~.lnlì -
IFlJill.MalJlt~JlalJe~
_LE~~I! ~a.!iE~5,800 9,500 1 6,000 27,500 50,000----
Watts 70 100 i 50 250 400---------
Monthlv kWh 28 39 59 96 1 48
Full Maintenance $6.4S $8.~$ß.13.0
Service 52 3 1 $9.8&98 8 $i 7.fr45
SPECIFICATIONS AND SERVICE FOR STREET LIGHTING WITH PARTIAL AND
FULL MAINTENANCE (NO NEW SERVICE): Installations must have met Company
construction standards in place at the time of installation in order to receive "full maintenance."
If Company is unable to obtain materials to perform maintenance, the street light facilties wil
be deemed obsolete and must be upgraded at customer expense in order to qualify for
maintenance under the Electric Service Schedule. Street Lighting Service under "partial
maintenance" includes energy, lamp and glassware renewals and cleaning of glassware.
Street Lighting Service under "full maintenance" includes energy, lamp and glassware
replacements and cleaning of glassware, and replacement of damaged or inoperative
photocells, ballasts, starting aids, poles, mast ars and luminaires: provided, however, that any
costs for materials which are over and above costs for Company's standard materials, as
determned by the Company, are not included in this Electrc Service Schedule. Such extra
costs shall be paid by Customer. Burning-hours oflamps wil be controlled by the Company.
(Continued)
Submitted Under Order No. 30482Case No. PAC-E-ll-J2
ISSUED:Deeember 28, 2007 December 16, 20 I J EFFE
t.Mark C. Moech
Danel E. Solander
201 South Ma Str Suite 2300
Salt Lae City, Uta 841 11
Telephone: (801) 220~14
Facsbrle: [phone]
Danel.solander(ßacificorp.com
Mark.moench(ßacificorp.com
RECEIVED
ioii OCT r 8 AM 10: '8
, IOft.HO PUEU::
LTILlTiES COMF.';¡SSION
Attorneys for Rocky Mountain Power
BEFORE TH IDAHO PUBLIC UT COMMSSION
IN TH MATTR OF TH APPLICATION )OF PACIFCORP DBA ROCKY )
MOUNAI POWER FOR APPROVAL OF )
CHAGES TO ITS ELECTRIC SERVICE )
SCHEDULS AN A PRICE INCRASE )OF 532.7 MILION, OR )APPROXITELY 15.0 PERCENT )
CASE NO. PAC-E-l1-12
STIULATION
.Ths stpulon ("Stipulon") is ente ino by an among Roc Mounta Power, a
division of PacCorp ("Rocky Mounta Powe or the "Compay"); Sta for4he Ida Public
"
Utilities Commssion (''Sta'); Monsto Compay ("Monsto"); PacifiCorp Idao Indusal
Cusmer ("PLLC"); and the Idao Irgaton Pupe Asation In. ("LIP A'') collectvely
reer to as the "Pares". Commwity Acton Parerp Asiaton of Ida ("CAPAI")
pacipate in th seemen negotions howeer they hae chosen not to be a pa to the
Stipulaton.
L INODUCTON
1. The te and conditions of ths Stipulaton are se fort herin. The Pares
ag tht ths Stipultion rerese a fa, jus and reonale compromise of the iss in ths
pr and th th Stipulaton is in the public inte. Th Pares remmend tht the
Idao Public Utilities Commssion ("Commssonj, puruat to its auonty under Commssion
.
REDAC1D STIULATION - Page 1 Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 1 of 18
t.
Rules 271, 272 and 274, appve the Stipulon an al of its te an conditions. See IDAPA
31.01.01.271,272, and 274.
ß. BACKGROUN
2. On May 27, 2011, Roky Mounta Power filed an Application sekig authority
to incre the Compay's bas rates for elecc sece by $32.7 milion anualy, an over
avere incras of approxily 15.0%. The incre in ra vares by cusmer clas and
actu use. Rocky Mounta Powe sougt an in in ra effve Debe 27,2011.
3. With a view towa relvi th issue rase in Rocky MOlDta Powe's
Applicaon in ths prceg, reprntaves of the Pares met on Aug 23, 2011 and
Septembe 22, 2011, puruat to IDAPA 31.01.01.271 and 272, to engae in seement
discsions.
.Bas upon the setement discusions beee the Pares, as a compromise of the
positions in ths pro, and for other consdeon as se fort below, the Pares stpulat
an agr to the followi:
m TERMS OF TH STIULTION
.
Revenue Requirment
4. The Pares agr to surt a two-yea ra plan with anua ra incrass of
$17.0 millon pe year, whch results in overl avere anua revenue incr of
apxitely 7.8 peent in 2012 an 7.2 pe in 2013. Th fi incr to ba ras will
oc Janua 1,2012, and wi be comprise of $6.0 miion of non-net powe cost components
(caita, opeons and mate, and other) and $1 1.0 mion of net powe costs. The
send incre to ba rates will occu Janua 1, 2013, and will be comprse of $6.0 milion
of non-ne power cost components an $11.0 miion of net power cost. The Compay wil
mae a compliance filing Novembe 1, 2012 to implement the send yea incras of $17.0
milion effecve Janua 1,2013 th will include rese tas.
5. Unless explicitly speified with th Stipultio~ the Pares ag tht
det the anua incr of $17.0 milion pe year for two yea is a "black box"
REDACTED STIULTION - Page 2 Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
i 1/02/11 Page 2 of 18
t.
seemen with no agent or actace by the Pares of any speific revenue requient,
cost aloction or cost of sece methodology. However, the Pares agee th the st point
of the Stipultion wa to acept al Commssion orer adjusents frm Cas PAC.E.I0-7,
Or No. 32196. Al Pares ag th ths Stipulaton resets a fa, jus an renable
comprmi of the iss in th prg and th ths Stipulon is in the public in.
Power Costs
.
6. The Pares ag th ba on the reenue reuient split spifed in
pah 4, net power costs in ba raes will incr frm the curt level of $1.025 bilon to
$1.205 billon in 2012 and frm $1.205 bilion to $1.385 bilion in 2013. Thes amoun will
beme the tota Compay ba net power costs for trki in the Compay's ener cost
adjusent mecha ("ECAM.
7. Th Pares ag th $78.8 millon, on a tota Compay bais or $6,526,622
allocate to Idao (R Exhbit 2 pae 3.5) of rewale energy cercat (''RCj reenue is
included in rate in 2012 and 2013. Th Idao allocd amount will beme th bas for
purse of trkig at 100 pent in th Compay's ECAM mecha.
8. The Pares ag to upte the Idao loa in the 2012 ECAM load chae
adjusent revenue ("LCAR") cacultion to the 2010 ac load includ in PAC-E. 1 1-12 for
the 2012 ECAM defer caculation and us 2011 actu load rert in the Anua Rests of
Options Reprt for the 2013 ECAM defer caculon. The LCAR unt vaue would be
frozen over the ra pla peod at the cut ra of $5.47 pe MW (ca No. PAC-E-I0-7).
9. The Pares ag th the Compy shal amor and collec Agum and
Monsto's sha of Commssion apved ECAM baances, whch includes defer ne powe
cost defer REC's, LCAR adjusents and other ECAM components, includg the irgaton
loa contrl crt as speed in pah 10, over the followig peod:
a) Th 2012 ECAM baance (201 1 defers) over a peod oftb yea;
b) The 2013 ECAM baance (2012 deferrs) over a peod oftb yea;
c) The 2014 ECAM bace (2013 defers) over a peod of two yea.
.
REDACTED STIULA nON - Page 3 Exhibit No. 10 1
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 3 of 18
t.
.
d) Beginning with the 201S ECAM baance (2014 defers), Monsto and
Agum will pay new ECAM cost ba on a 12-month collecon peod.
Any over-cllecon or unde-cllecon at the en of the amorton peod identied in
paphs 9(a) thugh 9(c) above will be tn up for eah contr cumer and refude or
collecte as pa of a subseue ECAM collecon peod frm thes contrt cuomer and not
frm oth re cusmer. Al other cumer wi contiue to pay ECAM chages on the 12-
month collecon peod as they curently do durg the rate plan
10. The Pares ag th due to th unty of the jursdctona trtment of the
disptcbale irrgaon load contrl prgr curtly bein discse by th MSP Stadi
Commtt, Ida's sh of the cumer loa col sece crt wil be trked in the
ECAM. The Pares fu agr th $1,045,423 (R Exhbit 2 page 4.4.1) is Idao's bas
amount to be trked in the ECAM for 2012 and 2013.
Rate Spred and Rate Desig
1 1. The Pares age to a ra spre ba upon $17.0 milion in anua incr for
2012 and 2013 as se fort in more detail in Atthment 1 to ths Stipulaton.
12. Th Pares ag th the deign of rate by rae schedule (ra design) shall be
consistt with the Compay's propos filed in its Application an adjused for th. revenue
reuient spifed in ths Stipultion. Des of the ra deign ar includ in Atthment 2
to ths Stipulation.
13. The Pares age th the Compy's reidential cusomer serce chae for
Schedule 1 and 36 will reai at $5.00 pe month and $14.00 pe month revely, durg the
tie peod cover by ths Stipulation.
Other Items
.
14. The Pares ag th the vaue of Monsto's curlment pructs wi be
incre frm . millon in 2011, to . millon in 2012, and. milion in 2013.
Monsto and the Company wil execute a new energy sece agement for 2012 an 2013 in
order to reflec the term of the Stipulaton. Monsto and the Compy ag to work
REACTED STIULTION - Page 4 Exhibit No. 101
Case No. PAC-E-11-12 i
R. Lobb, Staff
11/02/11 Page 4 of 18
--
.
collaboravely and in goo fath dur the ra plan peod to adss the tes, condtions and
valuaon of Monsto's curent prduc in an effort to maxze value to the Compay and
Monsato an also to discus co of sece metodlogies as applied to th Mons loa and
how sad metodologes wi be utiliz in the nex gener rae cas. Monsato and the
Company will rert to the Sta and Commssion as apprate on the progrs mae.
15. The Pares ag th ths Stipulon does not chae or alte the irgation loa
contrl servce crt in 2012 or pror agents goverg the irgaton load contrl prgr
tht reui the irgaon loa contl sece crt to be regotiate for th 2013 sen and
beyond. The Compay an IIA wil work collabovely dur caen yea 2012 to
renegotiate the irgaton load contrl progr for the 2013 se and beond. The Compay
and lI A will work collabravely durg the ra plan peod to disc cost of sece
metodologies as aplied to the irgation clas and how sad metodologes will be utilid in
th next gener ra ca.
16. The Pares ag th the porton of the Populus to Teral trssion lie
dermed by the Commssion in Cas No. PAC-E-IO-07 to be plant held for fu us (PHF
is now us and us. The paes fuer age tht the Commssion should make a spifc
fidi th the entire Populus to Ter trmission line is now us and usfu. Althoug
the Pares agr tht the Populus to Ten trssion line is us and us, they fuer
ag tht the porton of th trssion lin deed PHF in Ca No. PAC-E-I0-07 shl not
be included in rate until on or af Janua i, 2014. Followig the fili of ths Stipulaton,
Sta and the Compay ag to fie a Motion to Sus the Appeal now pedig in the Idao
Supme Cour docketed as Ca No. 38930-2011. Upon reipt of a fi Or from the
Commssion approvi the Stipuaton, the Company ags tht it will with i 0 days therf
fie a stpulon for Dismisa of the ap with eah pa to be its own cost.
i 7. The Pares ag th the Compay will contiue to defer th depreon
exe asiate with the Populus to Ter trmion lie, purt to Or No. 32224,.
REDACTED STIULTION - Page 5 Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 5 of 18
t.
unti it is included in rates on Janua 1,2014 and th the acumulat defer bace wil be
amor over th year frm th da the co ar inluded in rate.
18. The Pares age tht the Compay will work with the Pares to eslish
hedgig lits consistt with workgrup pr esblishe in Uta an Orgon for cost
begig Janua 1,2013, and forw.
19. The Pares ag th in regntion of the two-year ra pla cover by th
Stipulon, Rocky Mounta Powe wil not fie another geer rae ca before May 31, 2013,
with new rates not effecve pror to Janua 1, 2014. Rocky Mounta Power wil contiue to
fie anua Rests of Opetions Reprt with the Commssion to enle the Commssion to
en tht rate durg the two-yea rate plan coue to be jus an renable. Ths
Stipulation doe not prhibit the Compay frm resin ra due to the ECAM, whch wil stl
ocur April 1 eah year..IV. GENERA PROVISIONS
.
20. The Pares agree tht this Stipulaton rerets a comprmise of the dispute
clai and positions of the Pares on all iss in ths pr. Oter th the abve
reference position and any teony fied in supprt of the apval of th Stipulaton, and
exce to the ext nesa for a Par to exlai before the Commion its own stts
and positions with resp to the Stipulaton, al negotaton relat to ths Stipuaton sh not
be adssible as evdece in ths or any other prin regag ths subjec ma.
21. The Pares submt ths Stipulaton to th Comssion and remmend approva
of the Stipuon in its enti puruat to Commsion Rule 274, IDAPA 31.01.01.274. The
Pares shal surt th Stipuaton beore th Commion, and no Par shal ap any
porton of th Stipulaton or any subsuent Or approvig th sa. If ths Stipultion is
chaenged by any pen not a pa to the Stipulation, the Pares to ths Stipulaton ree the
right to crss-exame witnesses an put on suh cae as they dee aproprate to red fuly
to the issues presete includi the right to rase isses tht ar incorprated in the settement
emboed in ths Stipulon. Notwthdi ths reaton of rights, th Pares to ths
REDACTED STIULA nON - Page 6 Exhibit No. 101
Case No. PAC-E-ll-12
R. Lobb, Staff
11/02/11 Page 6 of 18
i.
Stipulon ag th they will contiue to surt the Commssion's adption of the te of
ths Stipultion.
22. In the event the Commssion reec any par or al of th Stipulaton, or impose
any additiona maal conditions on apval of th Stipulaton, eah Par resees the right,
upon wrtten notice to the Commsion and th other Pares to th pr with 15 days of
the da of such action by the Commssion, to withdrw frm ths Stipuaton. In suh ca, no
Par sh be bound or prejudce by the te of th Stipulaton, an eah Par sha be
entitled to sek rensidertion of the Common's or, fie testiony as it chose crss
exae witnesse, or otherwse preset its ca in a ma consstnt with the Commssion's
-
Rules and Procures.
23. The Pares ag th th Stipuation is in the public interest and th all of its
tes and conditions ar fa, jus and renale.
24. No Par shal be boun beefte or prudce by any position asse in the
negotiation of ths Stipulon, exce to the ex exressly st herin nor sh ths
Stipulation be cons as a waiver of the righ of any Par uness such righ ar expresly
waived herin. Ths is a "blac box" seement and exection of ths Stipulation sha not be
deemed to constu an acknowledgment by any Par of th validity or invalidity of any
parcular metod, theory or prciple of reguon or cost rever. No Par shl be deeed
to have aged th any metod theory or prple of reguaton or cost rever emloyed in
anvi at ths Stipulon is appprat for relvi any issues in any other pr in the
fu. No fidi of fac or conclusions of law other th those st herin sh be deeed
to be implicit in ths Stipuaton.
25. The obligatons of the Pares uner ths Stipulaton ar subjec to th
Commssion's aproval of ths Stipulation in acrdace with its ters and conditions and, if
judicial review is sougt, upn such apval beg upheld on apal by a cour of copent
jursdcton..
REDACTED STIULA nON - Page 7 Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 7 of 18
.1
Res submitt th It da of Ocbe,.2011.
ll MOU PoBy~~Ma . Mo
Mo Ccpø
Idù Pu UC Co St Pa lda Wu Cu
ByD.NePr
~~-.By (ÇL
..
STULTION - Pag 9.:
By1l L. WD
Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
i 1/02/11 Page 8 of 18
.:
Resecly submtt this 11 day of OCobe, 20 i i.
Roe Moutain PowerBy~~Ma . Moe
MODo Copl
ByRada C. Bu
Idaho PubUc UtlUUes Coon St PafiCo lda IJdua1 Cu
"-By Q;~9~
D. Nel Prce
Idaho IrrlUOI Pur A1toti.
I..e.
ByErlL.O_.:
STIULATION - Paø 9.
By,Ronld L. WiI
Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 9 of 18
.
Reay subm tb ./ day of Oc, 2011.
1l MwIDPo:?~ø4 Mo Cø
ByRuda C. Bud
Id Publ UØ Cø"... St Pa JdI ID eu..
ByD. NePr
Ict 1r.. AaID
ByBrlL-O'".
STITION - Pap 9.
By KA4.,LW~Ra L. \V
Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 10 of18
.
ATTACHMNT i
.
.
Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
i 1/02/11 Page 11 of 18
.
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.
Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 13 of 18
.
AttdalDeat i - Semeat Rate
ROKY MONTAI PO . STATE OF IDAH
CASE NO. PAC-E.11.12
.
Attchment 2 - Seent Rate
ROCKY MONTAIN PO. STATE OF IDAH
CAS NO. PAC-E.11.12
Settment
Year 1 Year 2 Prt 1/112012 11112013
27,500 Lumen HPSV, No Co Ow Pole $32.94 $33.28 $33.48
50,00 Lumens, HPSV, Co Owed Pole $50.84 $51.37 $51.67
50,00 Luen HPSV, No Co Owed Pole $45.00 $45.47 $45.74
16,00 Lumen HPS Floo Co Ow Pole $25.29 $25.55 $25.70
16,00 Lumen HP Floo No Co Ow Pole $22.52 522.75 522.88
27,500 Lumen HP Floo Co Ow Pole 536.37 536.75 536.97
27,500 Lumen, HPS Floo No Co Ow Pole 532.94 533.28 533.48
50,000 Lumen HPS Floo Co Own Pole 550.84 $51.37 $51.67
50,00 Lumen HPS Floo No Co Owed Pole $45.00 $45.47 $45.74
8,00 Lumen, LPV, Ener Ony $3.60 $3.64 53.66
13,500 Lumens, LPSV, Ener Ony $5.32 55.38 55.41
22,500 Lumens LPSV, Ener Only $7.40 57.48 57.52
33,00 Lumns LPSV, Ener On $9.01 $9.10 $9.15
SCHEDULE NO.9 - General Se"ie - Hig Voltge
Custoer Ch 5324.00 5347.00 $370.00.All kW (My . Oc)$8.48 $9.35 510.26
All kW (Nov - Apr)$6.41 57.06 57.74
Mium kW Sumer 58.48 $9.35 510.26
MiumkW Winte $6.41 $7.06 57.74
All kWh 3.50 't 3.6970 t 3.8835 't
SCDULE NO. 10 - Irrtin
Small Cutomer Ch (Sen)$12.00 $13.00 $14.00La Cuer Ch (Sean)$35.00 538.00 $41.00Pos-Sen Cumer Ch $19.00 $21.00 523.00
All kW (Jwie 1 - Sep 15)$4.69 55.31 $5.98
Fir 25,00 kWh (Jwie 1 . Sep 15)7.3477 ø 7.9434 ø 8.5312 't
Nex 225,00 kWh Owie 1 - Se 15)5.4349 ø 5.8755 ~6.3103 ~
Al Add kWh (June 1 . Se 15)4.0116 t 4.3368 t 4.6577 ~
All kWh (Sep 16. May 31)6.2144 t 6.7187 ~7.2164 ~
.
SCDULE NO. ii - Compaay-Oned St Litig Se"le
Cb per La
5,800 Lumen High Innsty Discha
9,500 Lumen Hig Inteity Discha
16,00 Lumen High Inty Discha
27,500 Lumen, High Intensty Diha
50,000 Lumen. High Intenity Discha
9.500 Lumen High Intensity Diha . Senes 1
16.00 Lumens High Inteity Dischae. Series 1
9,500 Lumens, Hi Inteity Discha. Sees 2
16,00 Lumens High Innsit Discha -Series 2
12,000 Met Halide
515.05
518.78
525.60
$35.75
552.48
$31.06
534.09
525.56
528.51
527.71
514.89
518.58
525.33
535.38
551.93
530.73
533.73
$25.29
528.21
527.42
Pag 2 of4
515.14
518.89
525.75
535.96
552.79
531.25
$34.29
525.71
$28.68
$27.88
Exhibit No. 10 1
Case No. PAC-E-1 1-12
R. Lobb, Staff
11/02/11 Page 15 of 18
.
.
.
Attchment 2 - Seent Rate
ROCKY MOUNTAIN POR . STATE OF IDAH
CASE NO. PAC-E.11-2
19,500 Met Hade
32,00 Met Haide
9,000 Met Haide. Seres i
12,00 Met Hade - Seres 1
9,000 Met Hade - Seres 2
12,00 Met Hade - Sees 2
Prt
$34.03
$41.28
$31.00
$35.64
$30.17
531.85
SCHEDULE NO. lZE - Cusmer- Str Ligtiag ServEnerg Only
Ch pe Lap
33,00 Lwnen LPSV
12,00 Met Halde
19,500 Met Halide
32,00 Met Haide
107,800 Meta Hade
9,00 Meta Haide
5,800 Lwnen HPSV
9,500 Lwnen, HPSV
i 6,00 Lwnen HPV
27,500 Lumen, HPV
50,00 Lum HPV
Non-List Luminre - Energ On
59.01
$6.94
$9.49
514.92
$35.72
$3.95
$2.79
$3.91
$5.81
59.93
$15.27
10.1259 t
Year 1
1I1110n
534.39
$41.72
$31.33
$36.02
$30.49
532.19
Sement
Year 2
1111013
$34.60
$41.97
531.52
536.24
S30.67
$32.38
59.11
$7.01
59.59
515.08
$36.10
$3.99
52.82
$3.95
$5.87
510.04
515.43
10.2330 t
SCHEDUL NO. UF - Custoer-ned Strt Ligtig SeFuU MaiDtenanee
Chs pe Lap
5,800 Lumen. HPV
9,500 Lumens HPV
16.00 Lumen, HPV
27 tSoo Lumen HPV
50,00 Lumen HPV
$6.45
58.22
59.88
$12.94
517.27
$6.52
$8.31
59.98
513.08
517.45
SCHEDULE NO. UP - Custmer-ed Str Liti ServlePartl MaiDtenee
Chs per La
10,000 Lumens, MV
20,00 Lumen, MV
5,800 Lumens HPV
9,500 Lumen HPV
27,500 Lumen HPV
50,00 Luen, HPV
S16.15
$21.62
S5.78
$7.44
S11.94
SI6.09
SCDUL NO. 19 - Commercial and Industrl Spaee BeatigCusme Ch Senda $21.00All kWh (My - Oc) 8.2953 tAll kWh (Nov - Apr) 6.1465 t
Pag 3of4
516.32
$21.85
$5.84
$7.52
512.07
516.26
$22.00
8.803 t
6.5274 t
$9.16
57.05
59.65
$15.17
536.32
$4.01
52.84
$3.97
S5.91
S10.10
SlS.52
10.294 t
$6.56
58.36
510.04
513.16
517.55
516.42
521.98
$5.88
S7.57
S12.14
516.36
523.00
9.3152 t
6.903 ;
Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11 Page 16 of 18
.
AttehmeDt i - Seeat Rate
ROCKY MOUNTAIN POR ..STATE OF IDAH
CAS NO. PAC-E.11-2
Semeot
Year 1 Year 2
PrDt lI1l012 11111013
SCHEDULE NO. 23tiA - GeDeral Serv
Cumer Ch Send 514.00 $15.00 516.00
Cusomer Ch Pr $43.00 $46.00 $49.00Tota Cusmer Ch
All kWh (May - Oc)8.0585 t 8.5835 t 9.1030 t
All kWh (Nov - Apr)7.0345 t 7.4928 ~7.9463 ~
Seas Seice Char (Secdar)5168.00 5180.00 5192.00
Sena Sece Cha (Par)5516.00 5552.00 $588.00
Volt Discun (0.389) t (0.4146) t (0.4397) ~
SCHEDULE NO. 3S - Geieral Seic - OptioDal TOD
Cusmer Cha Senda 559.00 563.00 $67.00
Cusmer Cha Pr 5145.00 $155.00 $165.00
All On-Peak kW 514.52 $15.49 $16.45
All kWh 4.3260 ~4.6154 t 4.9015 t
Sena Seice Chae (Seconda)5708.00 $756.00 5804.00.Sena Servce Chae (Pma)51,740.00 51,860.00 51,980.00Volta Diun ($0.74)($0.79)(50.84)
SCHEDULE 40
Firm EDerg aDd Power
Cusomer Cha 51,345.00 51,465.00 51,586.00
kWh 2.6180 ø 2.8515 t 3.0870 ø
kW 513.50 $14.70 515.91
ExceskVar $0.82 $0.89 $0.96
IDternptible EDerg aDd Power
kWh 2.6180 ø 2.8515 ø 3.0870 t
kW 513.50 514.70 $15.91
SCHEDULE 401Cusmer Ch $375.00 $408.00 $42.00
lU kWh (My-obe)3.0820 t 3.3565 t 3.6332 ø
HLH kWh (Novembe-Apnl)2.5630 ø 2.7913 ø 3.0214 t
LLH kWh (My-o)2.3110 t 2.5168 t 2.7243 ø
LLH kWl (Notlembe-Apr)2.3110 t 2.5168 ø 2.7243 t
AllkW (My-üobe)514.93 516.26 517.60
All kW (Novembe-Apnl)512.04 $13.11 $14.19
.
Pag4of4 Exhibit No. 101
Case No. PAC-E-11-12
R. Lobb, Staff
i 1/02/11 Page 17 of18
\.
CERTICATE OF SERVICE
I heby cefy that on ths 1"' da of Oc. 201 I, I ca to be se vi ovegh deliver and E-
maL, a tre and corr cop of Roky Mouta Powe's Stiulon in PAC-E-I 1-12 to 1he followig:
Eric L. Olsen
Rae, OLSO Nye, Budge & Baey, Ch
20 I E. ce
P.O. Box 1391
Pocllo, ID 832041391
E-Mal: el~inelaw.net
Tim Buler (E-ma Ony)
Agrum Inc./Nu-West Industres
3010 Coda Roa
So Spr ID 83276
E-Mal: tbuller(ggrum.com
Bra Pu
CAPAJ
2019N.17tbSL
Bois, ID. 83702
E-ma: bmpurdy(hotaiL.com.Anony Yaol
29814 Lae Ro
Bay Vill, Ohi 44140
E-mail: tonYl!anel.net
James R. Smith (E-ma On)
Monto Compy
P.O. Box 816
So Spr Ida 83276
E-Ma: jim.r.smítb($ons.com
Rod L. Wil
Willis Bra, P.C.
1015 W.Hays St.
Bois ID, 83702
E-ma: ro(gwilliasbrabur.com
Dael E. Sola
Paif db Rocky Mou Powe
201 S. Mai St Su 2300
SaI La Cit, UT 84 I I 1
E-mail: Daniel.solandercificom.com
.
Rada C. Bue
Rain, OLSO Nye, Budge & Ba, Ch
201 E. Ce
P.O. Box 1391
PocDo, ID 83204-1391
E-Ma: rcb(inelaw.net
Neil Pr
De Att GenerIdao Pub& Uties Commsion
472 W. Was (83702)
POBox 83720
Bois ID 8372()74
E-Ma: neil.pric_ue.idao.gov
Bejam J. OtIdao Conson Le
710 N. 6th St
P.O. Bo 84
Bois, Idao 83702
E-ma: botto(idaoconserion.org
Bruer & As
16690 Swiey Ri Rd., #140
Cheseld, MO 63017
E-Ma: bcllin~conultbai.com
Don Schoebek
RCS, In.
90 Wasn St, Suite 780
VanuverWA, 986
E-Ma: dwsoos-inc.eom
Ted Wes
PaifCo db Roky Moun Powe
20 I S. Ma St Sui 2300
Sat La Cit, UT 84 I 1 I
E-ma: te. wesn($ifieor.eom
Care MeyerCo, Reato Opon
Exhibit No. 101
Case No. PAC-E-ll-12
R. Lobb, Staff
11/02/11 Page 18 of 18
t.PAC-E-11-12
Monthly Biling Comparison
Idaho Public Utilties Commission
General Rate Case
Residential Service
Schedule 1
First Year Stipulated Increase.
Energy Energ Summer Non-Summer Avg. Mth Cost -12 Mtls
kWh kWh1 Present First Yr.%A Presnt First Yr.%A Present First Yr.%A
0 $5.17 $5.17 0.00%$5.\7 $5.17 0.00%$5.\7 $5.\7 0.00%
\00 $15.69 $16.31 3.95%$13.36 $13.83 3.55%$14.52 $15.07 3.79%
200 $26.20 $27.44 4.73%$21.5 $22.9 4.40%$23.87 $24.97 4.61%
300 $36.72 $38.58 5.06%$29.73 $31.6 4.79%$33.23 $34.87 4.94%
400 $47.24 $49.72 5.25%$37.92 $39.82 5.01%$42.58 $44.77 5.14%
500 $57.75 $60.85 537%$46.11 $48.48 5.15%$51.93 $54.67 5.28%
600 $68.27 $7199 5.45%$5430 $57.14 5.24%$61.28 $64.57 537%
700 $78.79 $83.13 5.51%$62.48 $65.81 532%$70.64 $74.7 5.2%
716 Summer $81.02 $85.50 5.52%$64.22 $67.64 5.33%$72.62 $76.57 5.4%
800 $92.78 $97.95 5.58%$7333 $7729 5.40%$83.06 $87.62 5.49%
837 Annual $97.95 $103.44 5.60%$7735 $81.5 5.43%$87.65 $92.9 5.52%
900 $106.77 $\ 12.78 5.63%$84.18 $88.78 5.47%$95.47 $100.78 5.56%
958 Non-Summer $114.88 $121.8 5.66%$90.47 $95.45 5.50%$102.68 $108.41 5.58%
1,000 $120.76 $127.61 5.67%$95.03 $100.27 5.52%$107.89 $113.94 5.61%
1,200 $148.74 $\57.27 5.73%$116.72 $123.25 5.59%$132.73 $140.26 5.67%
1,400 $176.73 $186.92 5.77%$138.42 $146.22 5.64%$157.57 $166.57 5.71%
1,600 $204.71 $2\6.58 5.80%$\60.\\$169.20 5.68%$182.4\$\92.89 5.75%
1,800 $232.69 $246.24 5.82%$181.81 $192.18 5.70%$207.25 $219.21 5.77%.2,000 $260.68 $275.89 5.84%$203.50 $215.15 5.72%$232.09 $245.52 5.79%
2,500 $330.63 $350.03 5.87%$257.74 $27259 5.76%$294.19 $311.1 5.82%
3,000 $400.59 $424.18 5.89%$311.98 $330.04 5.79%$356.29 $37711 5.84%
5,000 $680.42 $720.74 5.93%$528.94 $559.80 5.84%$604.68 $640.27 5.89%
Second Year Stipulated Increase.
Energy Energy Summer Non-Summer Avg Mth Cost -12 Mths
kWh kWh1 First Yr.Second Yr.%A First Yr.Second Yr.%A First Yr.Second Yr."lA
0 $5.17 $5.17 0.00%$5.17 $5.17 0.00%$5.17 $5.17 0.00%
100 $1631 $16.91 3.72%$13.83 $14.30 335%$15.07 $15.60 3.52%
200 $27.44 $28.66 4.42%$22.49 $23.2 4.12%$24.97 $26.04 4.29"10
300 $38.58 $40.40 4.71%$31.6 $32.55 4.47%$34.87 $36.47 4.59%
400 $49.72 $52.14 4.88%$39.82 $41.67 4.66%$44.77 $46.91 4.78%
500 $60.85 $63.88 4.98%$48.48 $50.80 4.78%$54.67 $57.34 4.88%
600 $7199 $75.63 5.05%$57.14 $59.93 4.87%$64.57 $67.78 4.97%
700 $83.13 $8737 5.10%$65.81 $69.05 4.93%$74.47 $78.21 5.02%
716 Summer $85.50 $89.87 5.11%$67.64 $70.99 4.95%$76.57 $80.43 5.04%
800 $97.95 $103.01 5.17%$7729 $81. 7 5.01%$87.62 $92.09 5.10%
837 Annual $103.4 $108.80 5.18%$81.5 $85.65 5.03%$92.49 $97.23 5.12%
900 $112.78 $118.66 5.21%$88.78 $93.28 5.07%$100.78 $105.97 5.15%
958 Non-Summer $121.8 $127.74 5.23%$95.5 $10031 5.09%$108.41 $114.02 5.17%
1,000 $127.61 $134.31 5.25%$100.27 $105.0 5.11%$113.94 $119.85 5.19%
1,200 $157.27 $165.60 530%$123.25 $129.63 5.18%$140.26 $147.61 5.24%
1,400 $186.92 $196.89 533%$146.22 $153.86 5.22%$166.57 $17537 5.28%
1,600 $216.58 $228.19 5.36%$169.20 $178.08 5.25%$192.89 $203.14 5.31%
1,800 $246.24 $259.48 5.38%$192.18 $20231 5.27%$219.21 $230.90 5.33%
2,000 $275.89 $290.77 5.39%$215.15 $226.54 5.29%$245.52 $258.66 5.35%
2,500 $350.03 $369.00 5.42%$272.59 $287.12 5.33%$311.1 $328.06 5.38%
3,000 $424.18 $447.24 5.4%$330.04 $347.69 535%$37711 $397.46 5.40%
5,000 $720.74 $760.17 5.47%$559.80 $589.98 5.39%$640.27 $675.07 5.44%.i Includes current Schedule 34-BPA Credit which equals zero, ECAM and Customer Effciency Services Rate Adjustment.
2 Monthly average usage for summer, non-summer and annual.Exhibit No. 102
Case No. PAC-E-11-12
R. Lobb, Staff
11/02/11