20130926Volume III 9-11-13.pdf

ORICINAL
o BEEORE THE IDAHO PUBLIC UTILIT]ES COMMISSION
IN THE MATTER OE THE APPLICATION
OE PACIFICORP DBA ROCKY MOUNTAIN
POWER TO INITIATE DISCUSSIONS WITH
INTERESTED PARTIES ON ALTERNAT]VE
RATE PLAN PROPOSALS
CASE NO.
PAC-E-13-04
TECHNICAL HEARING
:1i.. --."J.
.n()HEARING BEFORE
COMMISSIONER MACK A
COMMISSIONER
COMMISS]ONER
. REDEORD (Presiding)
PAUL KJELLANDER
MARSHA H. SMITH
PLACE:Commission Hearing Room
472 West Washington StreetBoise, Idaho
DATE:September lL, 2013
VOLUME III Pages 22 762
POST OFFICE BOX 578
BOISE, IDAHO 83701
208-336-9208
HEDRIGK
COURT REPORTING
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3r*,;g, A{" lna/ rn lwy sico /%6
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HEDRICK COURT REPORTING
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APPEARANCES
For the Staff:NEIL PRICE, Esg.
Deputy Attorney General
472 West Washington
Boise, Idaho 83702
DANIEL E. SOLANDER, Es.
PACIFICORP dba 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 Offlce Box 1391
Pocatello, Idaho 83204-].39]-
BRAD M. PURDY, Esq.
Attorney at Law
20L9 North Seventeenth Street
Boise, Idaho 83702
BENJAMIN J. OTTO, Esq.
Idaho Conservation League
710 North Sixth Street
Boise, Idaho 83702
KEN MILLER
Snake Ri-ver All-iance
Post Office Box L13L
Boise, Idaho 83701
For PacifiCorp dba
Rocky Mountaj-n Power:
For Monsanto Company:
For Community Action
Partnership Associ-ation
of Idaho (CAPAI) :
Eor Idaho Conservation
League:
For Snake River Al-l-iance:
83701
APPEARANCES
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INDEX
VOITNESS EXAMINATION BY PAGE
J. Ted Weston
(RMP)
Mr. Sol-ander ( Direct )Prefil-ed DirectPrefiled RebuttalMr. Purdy (Cross)
Mr. Sol-ander (Redirect)
Mr. Purdy (Cross)
Commissioner Redford
Mr. Price (Direct)
Prefiled DirectPrefiled RebuttalMr. Purdy (Cross)
Commissioner RedfordMr. Price (Redirect)
Mr. Purdy (Direct)
Prefiled DirectMr. Solander (Cross)
Mr. Purdy (Redirect)
Commissioner Smith
Commissioner RedfordMr. Purdy (Redirect)
Commissioner Smith
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1,26
1-47
148
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150
t-5 1_
t- 51
Randy Lobb
( Staff )
Christina Zamora
( Direct )
HEDRICK COURT
P. O. BOX 578,
REPORTING
BOISE, ID 83701
INDEX
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EXHIBITS
NUMBER PAGE
Eor Rocky Mountain Power:
1. Proposed Revenues, 5 pgs Premarked
Admitted 154
2.(This exhibits is confidential and Premarkedis provided under separate cover) Admitted 154
3.Electric Servj-ce Schedule No. L,
46 pgs
Premarked
Admitted 154
4. CAPAI Data Request 6, 6 pgs Premarked
Admitted 154
Eor Staff:
101. Stipulation, 21 pgs Premarked
Admitted 154
For Community Action Partnership of Idaho:
501. 6/LL/L3 E*mail, Weston to Budge, €t df, Marked 1164 pgs Admitted 122
HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD 83701
EXHIBITS
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HEDRICK COURT
P. O. BOX 578,
REPORTING
BOTSE, rD 83701
BOISE, IDAHO, WEDNESDAY, SEPTEMBER 11, 2073, 9:30 A.M.
COMMISSIONER REDEORD: Good morning, ladies and
gentlemen. This is the time and place set for a hearing in
Case No. PAC-E-11-14-04.
COMMISSIONER SMITH: You have to turn it on.
COMMISSfONER REDFORD: f'm sorry.
It is al-so further identified as In the matter of
the Applj-cation of Pacj-fiCorp doing business as Rocky Mountain
Power to lnitiate discussj-ons with j-nterested parties on
alternate rate plan proposals. To this date, all interested
partj-es have agreed to a settl-ement except the Community Action
Partnership Association, al-so known as CAPAI.
Eor those of you who haven't been here before, w€
constitute the Publ-ic Utilities Commission. On my left is
Marsha Smith,' on my right 1s President Kjellander, and
Commissi-oner; and myself , Mack Redford.
First of aI1, I guess we'l-f take the appearance
of the parties. Mr. Solander.
MR. SOLANDER: Good morning. Daniel- Solander on
behalf of the Applicant, Rocky Mountain Power. I have with me
at counsel table Mr. Ted Weston, who is the regulatory affai-rs
manager for Rocky Mountain Power i-n Idaho.
COMMISSIONER REDFORD: Mr. Budge.
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HEDRICK COURT REPORT]NG
P. O. BOX 5'18, BOTSE, rD
MR. BUDGE: Thank you, Mr. Chairman. Randy Budge
on behalf of Monsanto Company. And with me is Bob Geddes, who
is sitting in the back, and also Jim Smith here on my side.
Thank you.
MR. PRICE: Neil Price for Commission Staff. And
with me is Mr. Randy Lobb.
COMMISSIONER REDFORD: Mr. Otto.
MR. OTTO: Ben Otto with the fdaho Conservation
League.
MR. MILLER: Ken Miller with the Snake River
A11iance.
MR. PURDY: Brad Purdy, representing the
Community Action Partnership Association of ldaho,
Mr. Chairman. And to my right is Ms. Christj-na Zamora, who is
the relatively new executive director. This is her first
testimony before this Commissj-on.
COMMISSIONER REDFORD: Okay. Before we start
into the evidence, I understand there are preliminary matters
including a motion to strike by PacifiCorp. Mr. Solander, are
you ready to argue that?
MR. SOLANDER: I am.
COMMISSIONER REDFORD: Okay. Go ahead.
MR. SOLANDER: Thank you. I'm sure that you all
have read the pleadings, so I won't go through each of the
arguments that are contained therein.
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HEDRICK COURT REPORT]NG
P. O. BOX 518, BOTSE, rD
I wou1d like to cl-ari-fy one point from the
response that was fil-ed by CAPAI, and that is that Rocky
Mountain Power is not seeking to strike the motion to compel
from the record in the case. It's already been before the
Commissi-on; Rocky Mountain Power has fil-ed a response to the
motj-on to compel. What we are seeking to do is strike the
1ega1 brief and the motj-on from the testimony of Ms. Zamora
because we don't belleve that it's appropri-ate for a lega1
briefing which contains Iega1 arguments to then be incorporated
into testimony because it raises a number of questions. Is she
then is Ms. Zamora then adopting and swearing to the truth
of al-l- of the Iega1 arguments contained in the brief? ft just
doesnrt seem to make sense to the Company for 1egaI argument
and other nonopj-nion or fact matters to be j-ncl-uded or
incorporated by reference into the testimony which is being
sworn to by Ms. Zamora. So I just wanted to clarify that
point.
COMMISSIONER REDFORD: Mr. Budge, do you have any
comment on that?
MR. BUDGE: No, Commissioner.
COMMISSIONER REDEORD: Mr. Price.
MR. PRICE: Commj-ssion Staff supports the motion
to strike inasmuch as it pertains to the attachment to
Ms. Zamora's testimony.
COMMISSIONER REDFORD: Mr. Otto.
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HEDRICK COURT REPORTING
P. O. BOX 518, BOTSE, rD
MR. OTTO: The Conservation League doesn't have a
positi-on on the motj-on.
COMMISSIONER REDFORD: WeII, Brad, I guess it's
up to you.
MR. PURDY: Thank you, Mr. Chair, and I will try
to be brief and not repeat what is already stated in my
response to the Company's motion.
The Company, as you know, referenced five
specific areas supporting its motion. It seems that those
areas are somewhat redundant and a l-ittle difficult to
understand in that respect, especially with respect to how they
purportedly apply to any particular testimony contained in that
of Ms. Zamora's filing, so I'11 start with the five areas.
The first basis for the Company's motion is that
Ms. Zamora's testimony is, quote, difficul-t, end quote, to
understand, and that it offers, guote, 1ega1 opi-nions, end
quote. It doesn't but the problem is that the Company does
not even reference in its first area of objection any
particular word, sentence, paragraph, or sectj-on of
Ms. Zamora's testimony to which this argument purportedly
applies. To the extent that the Company fail-s to understand
the point of Ms. Zamora's testimony, then it is Community
Action's position that the appropriate means for addressing
that is simply cross-examj-nation; it can ask Ms. Zamora to
explain her testimony.
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HEDRICK COURT REPORTING
P. O. BOX 5'78, BOTSE, rD
The second section of the motion pertains to the
Company's objections that Ms. Zamora discussed CAPAI's
financial- l-imitations and the somewhat protracted process it
must go through to obtain board approval and other tasks it
must perform before it can determine whether to intervene j-n a
case, which makes expedited cases even harder for CAPAI to
engage in. The Company in thi-s regard strikes sections from
two pages of her testimony, pages 4 and page B.
The page 4 testimony of Ms. Zamora simply states
regarding CAPAI's fimlted financial- means t.hat, without
question, CAPAf has been stretched far beyond those means and
its ability to meaningfull-y participate in general rate cases
as a resuft of this expedited process has been stretched to its
l-imits. I simply don't see how that is objectionabl-e. ft
certainl-y seems relevant to CAPAI's overall objection to the
procedure empJ-oyed in this case. Again oh, excuse me.
Then the Company goes on to argue that,
regardless, the expedited alternative proposed by the Company
in this case is cheaper than had the parties fol-l-owed the
formal- rate case proceeding. That is a dispute of fact, and it
is CAPAIf s position that factual- disputes should not be settl-ed
through motions to strike, but rather through cross-examination
and the presentatlon of evidence before the Commissj-on.
Eina11y, the testimony on page 9 pertains to the
fact that due to CAPAI's financiaf l-imitations and the board
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HEDRICK COURT
P. O. BOX 518,
REPORTING
BOISE, ID
approval process and the expedited speed by which this case and
recent cases have been settled make it difficult, if not
j-mpossible, for CAPAI to be prepared by the time the first
settl-ement conference is scheduled. Again, the testimony in
question simply points out the fact that CAPAI has l-lmited
flnancial- means and is unabLe to make rapid settl-ement
decisions. The Company cites no IegaI or factual basis that f
can see for why this particular testimony should be stricken
from the record.
Regarding the third area or section of the
Company's motion, i-t pertains to Rocky Mountain's argument that
the fact that Avista provided the same information that was
through dj-scovery that was initial-l-y refused to be provided by
Rocky Mountain in this case but ultlmately was provided does
seern somewhat moot. As I just said, it was ultimately
provided. And it the Company states that it seems as though
Ms. Zamora wishes to describe the usefulness of these studies
in order to compel, by means of a discovery request, Rocky
Mountaj-n to perform similar studies to those provided by
Avista.
f want to be cl-ear that Ms. Zamora j-n no way is
attempting to argue the motion to compel. Her reference to it
and the reason she attached it to her brief is not for
incorporation of IegaI analyses and pri-ncipIes, but because the
brief also contains a number of safient factua] assertions that
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are rel-evant to CAPAITs position in this case, and striking the
testimony in such a wide-swath manner as the Company proposes
woul-d take out much of that rel-evant testimony. In that
regard, the Company seeks to strike chunks of Ms. Zamora's
testimony including sectj-ons contained on pages 12, 13, !4, 19,
20, and 21.
Twenty-one goes through the testimony of
Ms. Zamora and actually takes a yeIlow highlighter and takes
out the objected or disputed sections of her testimony. You
will quickly see that what happens is that Ms. Zamora's
sentences are chopped off. Either the start of the sentence is
miss is asked to be stricken or the end of it is asked to be
stricken, or perhaps the answer is asked to be stricken but the
question remains. The point j-s that it's nonsensical from a
grammatical standpoint, and from a logical and contextual-
standpoint.
Agaln, the Company does not in j-ts motion state
that, okay, here's the basis for our objecti-on in this section
of our motion, and here is how that objection applies to
page 14, lines 1 through 3, for j-nstance, of Ms. Zamora's
testimony. It doesn't go to that length.
I think that a motlon to strike is a rather
drastic procedural measure especially when it pertai-ns to the
only witness that CAPAI has in this proceeding, and any
strj-cken portions of her testimony shoul-d be done surgically
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HEDRICK COURT
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BOTSE, rD 83701
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and not with a meat cl-eaver.
The fourth basis for Rocky Mountain's motion
involves the fact that Ms. Zamora lacks experience with rate
case procedure before thj-s Commission, and that she draws Iegal
concl-usions and refers to the motion to compel. Again, this is
fairly redundant of previous arguments made in the other
sections of the Company's brief, but in this regard the Company
itself concedes on page 4 of its motion that and I quote
the most appropriate means for sorting out the confusion in
Ms. Zamora's testimony is cross-examj-nation, end of quote.
And CAPAI coul-d not agree more with that statement:
Cross-examination is the appropriate means for dealing with the
testimony objected to.
And, f inaIly, I'd l-ike to point out that the
Commj-ssion certainly it's not a jury of laypersons
unfami1iar with the subject matter. The Commission has, for
since I bel-ieve it was first established, been put in the
position of havj-ng to apply the appropriate weJ-ght and
probative val-ue of any information or evidence presented to it.
It is perfectly capable of doing that without striking what
real-Iy amounts to the entirety of Ms. Zamora's testimony. And
I think, again, the Commission can, as I said, give her
testimony the weight it deems entitled to, aII.ow Counsel for
the Company to cross-examine, and handl-e it in that manner.
Thank you.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD 83701
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HEDRICK COURT
P. O. BOX 578,
REPORTING
BOISE, ID
COMMISSIONER REDEORD: Are there any questions
from the Commission?
COMMISSIONER SMITH: NO.
COMMISSIONER REDFORD: No? Okay, we're going to
take about a three-, four-minute break for just a second.
COMMISSIONER SMITH: Are you going to allow
Mr. So1ander to reply?
COMMISSIONER REDEORD: Oh, excuse me.
Mr. Sol-ander, do you have a reply?
MR. SOLANDER: I just have one, one point to
make:
Mr. Purdy quoted a sect j-on of our brj-ef that
states the most appropriate means for sorti-ng out confusion in
Ms. Zamora's testj-mony is cross-examination, but he left out
the important part is that it's impossible to faj-rly and
adequately examine her on legal issues that are beyond the
scope of her expertj-se that he admlts in her testimony. That's
the only point I want to make.
COMMfSSIONER REDFORD: Any other comments by the
parties? Okay, we'f l- take about a three-mj-nute break.
(Recess. )
COMMISSIONER REDFORD: After delj-beration, the
Commissj-on has agreed to part of the motion and denied part of
the motion.
The brief wil-l be stricken.
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HEDR]CK COURT REPORTING
P. O. BOX 578, BOTSE, rD
And with regard to the rest of the testimony of
Ms. Zamora, she can testify and we'l-1 accept the weight that we
need to to eva1uate her testimony. And we suggest that
PacifiCorp, at the close of the session, that you identify,
based upon your cross-examinatj-on or other, what areas you
stil1 believe should be stricken.
Any questions? Hearing none, f guess it's your
motion application.
MR. SOLANDER: Thank you. Rocky Mountaj-n Power
is pleased to present this stipulation for your revj-ew and
approval today. As you're aware, the stipulati-on is entered
into by and among Rocky Mountain Power, Staff of the Idaho
Publ-ic Utilities Commission, Monsanto Company, PacifiCorp Idaho
Industrial- Customers, the Snake Rj-ver Alliance, Idaho
Irrigation Pumper Assoclation, and the Idaho Conservation
League. The Company and the other parties agree that this
sti-pulation on a new two-year rate plan represents a fai-r,
just, and reasonabfe compromise of the issues raised in this
proceeding, and that the stipulation is in the public interest.
Our Company witness, Ted Weston, prefiled direct
and rebuttal testj-mony in support of the stipulation, and he is
here today and will be happy to answer any questj-ons that you
might have regardi-ng the stipulation or the process that led to
ir.
COMM]SSIONER REDEORD:Are you going to present
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HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, fD
WESTON (Di)
RMP
him as a wi-tness?
MR. SOLANDER: Yes, sir. Would you like me to
move forward?
COMMISSIONER REDFORD: Go ahead.
MR. SOLANDER: Okay. I'd cal-I Ted Weston as our
f irst wi-tness.
COMMISSIONER REDEORD: Ms. Smith wil-l- issue the
oath.
J. TED WESTON,
produced as a witness at the instance of Rocky Mountain Power,
bej-ng fj-rst duly sworn, was examined and testified as follows:
COMMISSIONER REDFORD: And, Mr. Weston
COMMISSIONER SMITH: You'11 have to turn on the
mike.
COMMISSIONER REDFORD: -- as far as the speaker
is concerned, you'11 need to push the red button down, just
like we do over here.
THE WITNESS: Thank you.
DIRECT EXAMINATION
BY MR. SOLANDER:
O. Would you please state your name and business
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HEDRTCK COURT
P. O. BOX 578,
REPORTING
BO]SE, ID
WESTON (Di)
RMP
address for the record?
A. My name is Ted Weston, W*E-S-T-O-N. I work at
20L South Main, Salt Lake City, Utah, 84111.
O. And by whom are you employed and in what
capac j-ty?
A. Irm employed by Rocky Mountain Power as the Idaho
regulatory affairs manager.
O. And as part of your responsibiLities in that
posj-tion, dj-d you participate in the negotiation of the
stipulation that's being presented to the Commission today?
A. Yes, I did.
O. And did you prefile both direct and rebuttal
testimony in support of the stipulatj-on, along with four
exhibits thereto?
A. Yes.
MR. SOLANDER: Ird ask at this time that
Mr. Weston's testimony be spread upon the record as if read.
COMMISSIONER REDFORD: So granted, unless there's
an objection.
(The following prefiled direct and
rebutta1 testimony of Mr. Weston is spread upon the record. )
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a. Please state your name, business address, and present position with Rocky
Mountain Power (the "Company"), a division of PacifiCorp.
A. My name is J. Ted Weston and my business address is 201 South Main, Suite
2300, Salt Lake City, Utah, 84lll. I am currently employed as the Manager of
Idaho Regulatory Affairs.
QUALIFICATIONS
a. Briefly describe your education and professional background.
A. I received a Bachelor of Science Degree in Accounting from Utah State
University in 1983. I joined the Company in .lune of 1983 and I have held various
accounting and regulatory positions prior to my current position. In addition to
formal education, I have attended various educational, professional and electric
industry related seminars during my career with the Company.
What are your responsibilities as Manager of Regulatory Affairs?
My primary responsibilities include the coordination and management of Idaho
regulatory filings, communications and oversight of reporting requirements with
the Idaho Public Utilities Commission ("Commission").
PURPOSE OF TESTIMONY
a. What is the purpose of your testimony in this proceeding?
A. The purpose of my testimony is to present and support the Stipulation reached in
the Company's 2013 alternative rate plan proposal entered into by ar"rd among
Rocky Mountain Power, Staff for the Idaho Public Utilities Commission
("Staff'); the Idaho Irrigation Pumpers Association, Inc. ("IIPA"); Monsanto
Company ("Monsanto"); PacifiCorp Idaho Industrial Customers ("PIIC"); Idaho
Weston, Stip - I
Rocky Mountain Power
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Conservation League; and the Snake River Alliance; collectively referred to in my
testimony as the Parties. Community Action Partnership Association of Idaho
("CAPAI") participated in the settlement negotiations; however, they have chosen
not to be a party to the Stipulation.
My testimony provides an overview of the Company's 2013 altemative
rate plan and an explanation of the terms and conditions of this Stipulation. I also
demonstrate 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. My testimony supports the Parties' recommendation that the
Commission approve the Stipulation and all of its terrns and conditions.
BACKGROUND
a. What was the Company's alternative rate plan proposal?
A. On March 1,2013, the Company made two filings with the Commission; it filed a
Notice of Intent ("NOI") to file a general rate case, and a separate application
requesting that the Commission open and notice a case with the intent of
identiffing interested parties that would like to participate in alternative rate plan
discussions (the "Application"). The NOI was filed to comply with Commission
noticing requirements allowing the Company to file a general rate case around the
first of June in the event that the alternative rate plan discussions were
unsuccessful. The Company filed the Application early to provide time for parties
to discuss altematives to a general rate case.
On March 12,2013. the Commission noticed the Company's alternative
rate plan Application and set March 26, 2013, as the intervention deadline to
Weston, Stip - 2
Rocky Mountain Power
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0.
A.
identiff any interested parties that would like to participate in settlement
discussions regarding alternatives to the Company filing a general rate case. In
addition to Staff the six parties listed above intervened. The first settlement
discussion was held April 19, 2013, at the Commission's public hearing room.
A second settlement conference occurred May 2,2013. Between April lgth
and May 2nd the Parties analyzed the proposed rate plan, asked discovery
questions, and Staff performed an audit of the preliminary 2012 Annual Result of
Operations report at the Company's offices in Salt Lake City. The 2012 Annual
Result of Operations report was filed with the Commission on June 28,2013.
What Test Period did the Company use to determine revenue requirement
for the Annual Result of Operations?
The Test Period for the Result of Operations was based on the historical l2-month
period ended December 31, 2012, adjusted for known and measurable changes
through December 31,2013. The Result of Operations was prepared consistent
with past Commission practice and the Company's general rate cases filed
previously in Idaho. The Company utilized rate base on an end-of-period basis,
which includes the actual rate base at December 31,2012 plus major capital
additions that were expected to go into service by Decernber 31 , 2013.
What is the revenue requirement increase supported by the Result of
Operations?
The 2012 Result of Operations demonstrate that absent a rate change the
Company would earn 7 .6 percent return on equity ("ROE") on a nornalized basis
for calendar year 2013. Based on the most recent Commission authorized ROE of
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I 9.9 percentl the Company could justiff a $15.7 million price increase. However
2 most of that price increase was driven by three items:
3 (l) the difference between net power cost currently included in base rates
4 and actual net power costs approved in the Company's 2013 ECAM
5 filing2, which is approximately $7 million on an ldaho basis;
6 (2) the market for renewable energy certificates ("RECs") has drastically
7 declined from the level currently in rates. Idaho customers are currently
8 receiving a $6.5 million credit annually from REC sales, these sales are
9 expected to be reduced in 2013 by approximately $6.0 million;
l0 (3) The impact of the new depreciation study's proposed rates would
11 increase ldaho's allocated depreciation expense by $a.5 million annually.
12 STIPULATION
13 a. Please summarize the terms of the Stipulation entered into by the Parties.
14 A. The Parties recommended that the rate plan Stipulation would be submitted to the
15 Commission in lieu of a general rate case. If approved by the Commission, the
16 Parties agreed that Rocky Mountain Power would not file any request with the
17 Commission to increase its base rates in Idaho before May 31,2015, with new
18 rates not effective prior to January 1,2016, with the difference in timing taking
19 into consideration the Commission's normal notice and suspension periods for a
20 general rate case.
2l The Stipulation specifies that base revenue requirement for all schedules
22 will be increased on.lanuary 1,2014 by the uniform percentage amount of 0.77
' Order No. 32196.: Case No. PAC-E-13-03, Order No. 32771.
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14 POPULUS TO TERMINAL LINE
a. Please describe the treatment of the Populus to Terminal Transmission Line
percent. The Parties to the Stipulation further agreed that within each schedule the
increase will be recovered by increasing only the energy component of rates by a
uniform percentage amount. A summary of the impact by rate schedules is
provided as Exhibit No. I of my testimony.
Below is a summary of the five main areas covered by the Stipulation
which I will describe further in my testimony:
L Recovery of Populus to Terminal transmission line;
2. Recovery of the Lake Side II generation facility;
3. Modifications to components of the ECAM calculation;
4. Implementation of the new rates fronr the depreciation study currently
pending before the Commission (PAC-E-13-02); and
5. Accounting for and recovery of the retirement and removal costs
associated with closure of the Carbon Plant.
issue in the Stipulation.
The $2 million or 0.77 percent base rate increase effective January l, 2014, will
provide the Company recovery of ldaho's allocation of the 27 percent of the
Populus to Terminal transmission line investment that was deemed plant held for
future use in Commission Order No. 32196.
Later, the Commission ruled that this investment was now used and useful
and should be included in rates on or after January l, 2014. The Parties'
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recommendation in this Stipulation is supported by that Commission Order.s
Utilizing normal regulatory processes this Stipulation is simply an
implementation mechanism of Commission Order No. 32432. The parties to Case
No. PAC-E-ll-lz had recommended and the Commission ordered this investment
was used and useful and should be included in rates. This base rate increase is
designed to collect approximately $2.0 million annually from Idaho customers as
calculated and summarized in the table below.
Revenue Req uirement Comnonents 2013
Plant in Service
Idaho SG Allocation Factor
218,512,895
6.0525
Plant in Service $13,225,475
verage Accum Depr Reserve 68,47
Net Plant in Service
Pre-Tax Return
Revenue Requirement on Plant
Depreciation Expense
12,956,997
Amortization of Deferred Depreciatiorr 303.5s 1
Revenue Requirement $
Uniform Percentage Increase
Deferred Depreciation Expense
Three Year Amortization
2,015,144
Amortization Expense
I 1.13
1,443,113
268,477
0.7
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The $2.0 million annual revenue requirement is comprised of the pre-tax
return on investment, using the last Commission authorized capital structure
applied to Idaho's allocated share of investment previously included in plant held
for future use, plus the annual depreciation expense, plus the amortization of the
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I depreciation expense deferred while the investment was in plant held for future
a4/ use.
3 ECAM _ LAKE SIDE II
4 Q. Do any of the terms of the Stipulation utilize or impact the ECAM?
5 A. Yes. As part of the overall Stipulation the Parties desired a two-year rate plan. To
6 accomplish that goal the Parties recommended inclusion of a resource adder for
7 the Lake Side II generation facility that will be recovered through the ECAM at
8 100 percent, for the period that the investment in the facility is not included in rate
9 base as a component of base rates. The resource adder will begin January l, 2015,
l0 subject to the Lake Side II generation facility having achieved commercial
I I operation as of that date. While commercial operation is expected to be achieved
12 by June of 2014 the Company agreed that the resource adder wouldn't be
13 included in the ECAM until January 2015, more than six months after the in-
14 service date, as part of the settlement. Idaho customers will benefit from lower
15 power costs as a result of lower than market energy generated by Lake Side II
16 from June through December 2014 without paying any revenue requirement on
17 the plant. The ECAM deferral will be calculated by multiplying the actual
l8 megawatt-hours of generation from the Lake Side II facility by $1.99 per
19 megawatt-hour. The Parties to the Stipulation recognized that to enable a two-year
20 rate plan the resource adder was a necessary component and utilized a previous
2l Commission approved mechanism that would facilitate the Company and its
22 customers in avoiding a rate case in 2015. The $1.99 per megawatt-hour Resource
a Case No. PAC-E- l0-07. Order No. 32224. page l3 2nd paragraph.
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Adder is ldaho's allocated share of the return on and of the Lake Side II
generation facility, the calculation is summarized in the table below:
Rocky Mountain Power
Lake Side Il Resource Adder
In Service: June 2014
Rerrcnue ldaho SG ldaho
Amount Reorirement Factor Resource
Electric Plant In-Service ffi1"7?5.143
Depreciation F,>pense 21,373,722 21.373.722
Non-FuelO&M 3.934.000 3.934.000
Property Ta>res 6.000,000 6,000.000
Accum Depreciation (21,373.722)
DIT Balance (115,366.732)
Net Plant In-Service 524.984.689 58.471.267
lake Side ll 89.778,989 6.0525% $ 5.433.873
2015 MWh 2.729.5W 2.729.5U
Resource Adder ($/MWh) $ 32.89 6.0525% $ 1.99
Annually the recovery of the Lake Side II resource adder will be capped to
the first 2,729,500 megawatt-hours of generation or approximately $5.43 million
from ldaho customers through the ECAM.
Has the Commission approved utilization of a resource adder as part of the
ECAM before?
Yes. In Order No. 31033 the Commission approved inclusion of a renewable
resource adder as part of the ECAM. The resource adder provided for recovery of
investment in renewable resources that were benefiting customers through
reduced net power costs but were not yet included in base rates. The resource
adder enabled the Company to forgo filing a general rate case in 2010.
Are there any other terms of the Stipulation that impact the ECAM?
Yes. Pursuant to Commission Order No. 32771 the Parties reviewed and agreed to
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modiry the ECAM calculation by removing the wholesale sales line loss
adjustment from Monsanto and Agrium's actual load used to calculate all defenal
balances except for the Load Change Adjustment Revenue portion of the ECAM
deferral. This change will be effective for the ECAM deferral period starting June
I , 20 I 3 and ending on November 3 0, 20 I 3 .5
Effective December l" 2013, the ECAM deferral will be calculated on a
total Idaho basis using Idaho jurisdictional load; Monsanto and Agrium's share
will not be calculated and deferred separately. The rate design for the ECAM will
be based on energy sales data. Specifically, as in past ECAMs, the proposed rates
will be calculated by effectively dividing the total target dollar amount for Idaho
customers by the energy sales data at their appropriate delivery voltage levels.
Does the Stipulation change any other ECAM related items?
No. The Stipulation did not modifu the ECAM's curent level of base net power
costs of $1.385 billion on a total Company basis or REC revenues included in
rates of $78.8 million. also on a total Company basis or 56,526,622 allocated to
Idaho, both amounts will remain the base for purposes of tracking in the
Company's ECAM mechanism.
These two items were identified as major drivers of the revenue deficiency
that the Company is experiencing. However, the ECAM provides recovery of 90
percent of the net power cost differential and 100 percent of the REC revenue
5 Accordingly, the deferral period for the ECAM application to be filed February 1,2014, will reflect two
different calculation methodologies. The current methodology will be used for the December 1,2012,
through May 31,2013 period. The proposed calculation in the Stipulation will be used for the period of
June 1,2013, through November 30,2013.42
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difference enabling the Company to delay the upcoming rate case and enter into
this Stipulation.
The Stipulation also did not modify the Idaho base load in the ECAM that
is applied to the net power cost differential or the load change adjustment rate
("LCAR"). As specified in Commission Order No. 32432 from Case No. PAC-E-
ll-12, the 201I load reported in the Annual Result of Operations report will
continue to be used as base load for the calculation of the load change adjustment
in the ECAM deferral. The LCAR will remain at $5.47 per MWh.
DEPRECIATION STUDY
The Stipulation recommends Commission approval authorizing the Company to
create a regulatory asset to defer. on a monthly basis, any aggregate net increase
or decrease in Idaho allocated depreciation expense from the pending application
to change depreciation rates6 for the period beginning on the later of January l,
2014, or the effective date of the Commission Order approving new depreciation
rates, until the date that new depreciation rates are reflected in customer rates.
Under the terms of the Stipulation, the Company would be allowed to
recover or required to refund the deferred depreciation expense beginning on the
effective date of the next general rate case. The regulatory asset balance would be
amortized over a period not to exceed ten years from the effective date of the next
rate case. The Stipulation recommends that depreciation of the Carbon Plant
should not be included in this deferral but tracked separately.
CARBON PLANT
Order No. 32701 authorized the Company to create a regulatory
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I asset to transfer the remaining Carbon plant balances upon retirement from
2 electric plant in service into. This balance will be amortized from the date of
3 transfer to the regulatory asset through December 31, 2020. The regulatory asset
4 as of the date of transfer will include the un-depreciated book balance assuming
5 that existing depreciation rates were used prior to the plant retirement date. The
6 difference between the depreciation rate effective in 2014 and the current
7 depreciation rate based on the prior decommissioning date of 2020 will be
8 included in the Carbon plant regulatory asset until Carbon depreciation rates are
9 updated in the next general rate case.
l0 The Stipulation also recommends creation of a separate regulatory asset
I I for future recovery from customers Idaho's allocated share of the prudently
12 incurred Carbon removal costs. The projected removal costs were identified in the
l3 calculation of the new depreciation rates as part of Case No. PAC-E-I3-02, which
14 is subject to Commission review and approval.
15 The Stipulation supports that the Company should be allowed to recover
16 from customers Idaho's share of the prudently incurred Carbon removal costs
17 over a reasonable period determined by the Commission in a future proceeding.
18 The amortization of the Carbon removal costs will begin when the amortization
19 expense is included in rates in the next general rate case.
20 Other Terms of the Stipulation
21 a. Does the Stipulation address Monsanto's curtailment contract?
22 A. Yes. Paragraph 15 of the Stipulation summarizes some minor modifications to
23 Monsanto's curtailment contract. Monsanto and the Company, after engaging in
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I discussions and negotiations, have agreed to extend Monsanto's current
2 curtailment terms and valuation for two additional years to align the contract with
3 the rate plan. Monsanto and the Company have executed a new Electric Service
4 Agreement ("ESA") for 2014 and 2015 sub.iect to Commission approval of the
5 Stipulation. If the Commission approves the Stipulation the Company and
6 Monsanto respectfully request approval of the executed ESA, which is provided
7 as Confidential Exhibit No. 2.
8 Rate Spread and Rate Design
9 Q. Does the Stipulation speciff how the $2.0 million revenue requirement
l0 increase will be recovered from customers?
1l A. Yes. The Stipulation specifies that each rate schedule will see an equal percentage
12 increase of 0.77 percent. The Stipulation further specifies that this increase will be
13 recovered through energy rates. The rate calculations were performed based on
14 the 2012 normalized billing determinants, Exhibit No. I shows the increase
15 applied to each rate schedule and the proposed rates.
16 a. What is the impact of this increase on the average residential customer?
17 A. Idaho's average residential customer on Schedule I uses 810 kwh per month. At
18 this average usage level residential customers would see an increase of $0.66 per
19 month or $7 .92 ayear to their bills.
20 a. Has the Company updated its tariff schedules based on the Stipulation?
2l A. Yes. Exhibit No. 3 contains the clean and legislative copies of the Company's
22 Idaho electric service schedules which have been updated to reflect the terms of
23 the Stipulation. The Company respectfully requests that the Commission approve
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the Stipulation and the tariffs in Exhibit No. 3, with a January 1, 2014, rate
effective date as filed.
Conclusion
a. Does the Stipulation represent a fair, just, and reasonable compromise of the
issues and is in the public interest?
A. Yes. In an effort to mitigate customer rate impact the Company proposed a rate
plan that provided for recovery of the previously Commission approved Populus
to Terminal transmission line combined with utilizing the ECAM to recover the
majority of increased net power costs and the reduction to REC revenues. The
inclusion of the Lake Side II resource adder also enabled the Company to avoid
filing a general rate case in 2015 and delayed customer rate impact until April
2016. The results of the pending depreciation case and closure of Carbon plant
were addressed with deferred accounting. Creation of these regulatory assets
assures that customers won't see any rate impact from these changes before
January 1,2016.
As specified in the two-year rate plan covered by this Stipulation, Rocky
Mountain Power will not file another general rate case with new rates effective
prior to January 1,2016. Rocky Mountain Power will continue to file annual
Result of Operations reports with the Commission to enable the Commission to
ensure that rates during the two-year rate plan are 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 expenditures. This
two-year rate plan demonstrates the Company's conscious effort to control its
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costs while implementing innovative solutions and pricing proposals to help
mitigate customer impacts and use electricity more efficiently.
The Parties to this Stipulation have worked to thoroughly investigate and
analyz* this rate plan as an alternative to a general rate case through auditing,
qualitative discovery, and careful negotiations and have determined that the two-
year rate plan is in the public's best interest.
For these reasons the Company supports the Stipulation entered into by
the Parties and respectfully requests that the Commission approve it as filed.
Does this conclude your testimony?
Yes.
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a. Please state your name, business address, and present position with Rocky
Mountain Power (the "Compatry"), a division of PacifiCorp.
A. My name is J. Ted Weston and my business address is 201 South Main, Suite
2300, Salt Lake City, Utah, 84lll. I am currently employed as the Manager of
Idaho Regulatory Affairs.
a. Are you the same J. Ted Weston who submitted stipulation testimony in this
proceeding?
A. Yes.
PURPOSE OF TESTIMONY
a. What is the purpose of your rebuttal testimony in this proceeding?
A. The purpose of my testimony is to respond to the testimony filed by Community
Action Partnership of Idaho ("CAPAI") witness Ms. ChristinaZamora. Although
Ms. Zamora's testimony touches on a number of subjects that are irrelevant to this
proceeding, I will largely limit my response to the issues gernane to the
Stipulation, and also briefly address the most egregious misstatements contained
in her testimony regarding CAPAI's Motion to Compel and the Company's
response to the data request that was the basis for the motion.
Does Roclry Mountain Power agree with the concerns raised by CAPAI
regarding the procedural handling of the Company's alternative rate plan
proposal?
No. Rocky Mountain Power strongly disagrees with CAPAI's characterization of
the process that resulted in the Stipulation pending before this Commission. On
March 1,2013, the Company made two filings with the Commission. In order to
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preserve its right to file a general rate case, it filed a Notice of lntent to file a
general rate case, and a separate application requesting that the Commission open
and notice a case with the intent of identiffing interested parties that would like to
participate in alternative rate plan discussions (the "Application"). The Notice of
Intent was filed to comply with Commission noticing requirements that would
allow the Company to file a general rate case after May 31, 2013, in accordance
with the timing agreed to in the stipulation in the Company's 20ll general rate
case, Case No. PAC-E-ll-l2 (the "2011 GRC Stipulation"), in the event that the
altemative rate plan discussions were unsuccessful. The Company filed the
Application early to provide time for parties to discuss alternatives to a general
rate case. [t was this alternative Application that led to this proceeding and the
Stipulation that is before the Commission for approval.
After the Commission noticed the Company's Application, Rocky
Mountain Power worked closely over several months with the Commission staff
and the other intervening parties to craft a solution that provided adequate notice
to all parties, complied with Commission rules, and eliminated the need for the
general rate case filing that the Company had put parties on notice of through the
required Notice of Intent filing it had made. This effort was undertaken by all
parties with great care and attention to proper Idaho Public Utilities Commission
protocol for settlement discussions. The statements in Ms. Zamora's testimony
that the Company violated the timing for filing a general rate case agreed to in the
201I GRC Stipulation and that the current Stipulation arose out of an application
filed before May 31, 2013, ignore the fundamental fact that Rocky Mountain
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Power did not file a general rate case application, but instead worked with the
parties to craft an alternative that was acceptable to a broad cross-section of Idaho
customers and stakeholders.
How does the Stipulation address the very concern that Ms. Zamora raises
regarding the general trend of more frequent general rate case filings?
The Stipulation eliminated the current need for a general rate case and avoids a
change in base rates as a result of a general rate case until at least January l, 2016,
which means customers will enjoy at least a three-year period between general
rate case rate changes. The Stipulation appears to address the very issue that Ms.
Zamora is concerned about.
Please respond to Ms. T.a,mora's allegations that Rocky Mountain Power
failed to respond to CAPAI's data request?
The statements in Ms. Zamora's testimony and exhibit arguing that the Company
has refused or failed to provide a response to CAPAI's discovery requests are
completely false. The real issue is that Ms. Zamorajust didn't like the answer
that was provided. The Company had not prepared the analysis that they had
requested and, therefore, had nothing to give them. Rocky Mountain Power's
complete response was timely provided on May 29,2013. Later, following the
filing of the Company's Response to CAPAI's Motion to Compel, Rocky
Mountain Power completed an analysis responsive to the request made by CAPAI
and provided it to them on August 12, 2013. A true and correct copy of the
response is provided as Exhibit No. 4 to my testimony. The spreadsheet that was
provided is similar to the format of similar data responses that have been provided
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to CAPAI in other proceedings, including the Company's current Washington
general rate case. As noted in the response to CAPAI Data Request 6b, due to the
almost unlimited combinations for block rates and the vagueness of the question,
in order to be responsive the Company provided two rate design scenarios.
Additionally, the Company provided all data necessary so that CAPAI could
explore other rate design scenarios and bill impacts. The Company's response to
Ms. Zamora's other incorrect assertions regarding the Company's failure to
respond to CAPAI's discover request is fully contained in the Company's
Response to CAPAI's Motion to Compel, which was filed with the Commission
on August 9,2013.1
Does this conclude your rebuttal testimony?
Yes.
' The arguments in Ms. Zamora's testimony regarding the failure to respond seem particularly
inappropriate considering the Motion to Compel was withdrawn by CAPAI on August 14,2013.
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HEDRICK COURT
P. O. BOX 578,
REPORT]NG
BOISE, ID
WESTON (X)
RMP
(The foll-owing proceedings were had in
open hearing. )
COMMISSIONER REDFORD: Do you have any
cross-examlnation, Mr. Budge?
MR. BUDGE: No questJ-ons, thank you.
COMMISSIONER REDEORD: Mr. Price.
MR. PRICE: No questions.
COMMISSIONER REDEORD: Mr. Otto.
MR. OTTO: No questions.
COMMISSIONER REDEORD: Mr. Purdy.
MR. PURDY: Thank you, Mr. Chair.
CROSS-EXAM]NATION
BY MR. PURDY:
O. Good mornj-ng, Mr. Weston.
A. Good morning.
O. I just have a couple questions initially about
your direct testimony. Do you have that in front of you?
A. Yes, I do.
O. Okay. Would you please refer to page 2 of that
testimony; specifically, f'm going to ask you questions about
lines, roughly, 71 through 21. Do you have that in front of
you?
A. Yes.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD
WESTON (X)
RMP
a. Okay. You state that the notice of intent filed
by the Company in this case to comply with the Commission's
noticlng requirements for general rate cases woul-d all-ow the
Company to fil-e a rate case sometime after May 31st. Is that
right ?
A. That's correct.
O. Of this year?
A. That's correct.
0. And you further stated that the Company filed the
application early to provide time for parties to discuss
alternatives to a general rate case. Is that true as well?
A. Correct. On March 1st, the Company filed two
two separate documents: A notice of lntent and al-so filed an
application requesti-ng that the Commission open a docket so
that part j-es coul-d initiate discusslons.
0. Mr. Weston, I'm getting very hard of hearing in
my older age. If you could possibly just pu11 that mike a
l-ittl-e closer or speak l-ouder, I'd greatly apprecj-ate it.
A. Is that better?
0. A l-ittl-e bit.
A. I'11- try to speak into it.
a. Thank you.
COMMISSIONER SMITH: Maybe if it's set up here.
It will be cfoser to your mouth.
O. BY MR. PURDY: And I'm just going to ask you, in
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P. O. BOX 578,
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BOISE, ID
I/iESTON (X)
RMP
your opinion, whether you feel that the amount of ti-me -- wel1,
strike that.
The Company's application and notice of intent
were filed on March 1st of this year. True?
A. That's correct.
O. All- right. Do you know when the Commj-ssion
issued its notice of application?
A. I bel-leve it was March 1,2th.
O. That's my understandlng as wel-l-. So assuming
that a party that was j-nterested in this proceeding did not
become aware of this filing until March L2th, and because the
Company presumably wanted a "yes" or I'no, on its rate case
alternati-ve idea, that rea1Iy gave the parties from March 1-2th
to May 31st to do all the work they needed to do in order to
decide whether to join in the stipuJ-ation. Is that a fair
statement ?
A. I believe sor yes.
O. Pardon me.
A. Yes.
O. Yes. Okay. And the things that they needed to
do would be to, of course, conduct discovery; engage in what
turned out to be two settl-ement negotiatj-ons; make their
analyses; draft the settl-ement stipulati-on, revj-ew that, make
edits, finalize; and a number of other tasks in that time
period of roughly two and a hal-f months. Is that right?
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A. Yeah, I canrt speak to what the parties had to do
to determine, but those are some of the actj-ons that could be
involved, yeah.
0. If you coul-d direct your attention to excuse
fr€, I think I'm going to rebuttal-. I need to double-check.
Okay, yes, if you woul-d -- oor I'm sorry, f 'm
still back on direct. Forgive me.
Back on page 2 of your direct, you state
generally that the Commission noticed up the hearing, and you
just testified that it did so noticed up the application,
rather, in this case on March 72 to and f quote identify
any interested parties that woul-d like to participate in
settlement discussions regardj-ng alternatives to the Company
filing a general rate case, end quote.
Is that a fai-r quotatJ-on of your testimony?
A. Yes.
O. Okay. In the event that a party had desired to
participate in the general rate case which the 60-day notlce of
j-ntent referred to, but did not necessarily care to dj-scuss
al-ternatives to a general rate and did not intervene in this
case, the 13-04 case, it woul,d have l-ost its ability to shape
the outcome of a rate case settlement, wouldn't it?
A. f 'd l-ike to clarify that the Company never filed
a rate case. We proposed an al-ternati-ve to filing a rate case,
and that's what the application was, is to identify interested
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parties and a1low discussions and negotlations of alternatives
to filing a general rate case, whj-ch was the intent and purpose
of the Company was to avoid the necessity and assocj-ated costs
of a general rate case.
O. AIl right. I'l-1 state it one more time,
hopefully more simply:
Regardless of whether you charactertze this as a
rate case, a rate p1an, or anything eIse, the fact of the
matter is it did resul-t in an increase to the Company's revenue
requirement, did it not?
A. Yes.
O. A11 right. On page 5 of your direct, lines 1
through 3, you state, generally, that the increased revenue
requirement proposed in the sett.l-ement stipulatlon wj-lL be
collected exclusively through the energy component of rates.
fs that right?
A. That was that was one of the terms of the
stipulation, yes.
O. Okay. And the Company is not proposing any
increase to its customer monthly charge in this case, is it?
A. That's correct.
O. Al-l- right. Based on the discovery requests that
were submitted by CAPAI to the Company, are you able to have a
sense of whether low-income users are relatively higher or
lower than the average residential customer?
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A.Coul-d you by -- what do you mean by "higher or
Iowertt ?
O. Okay, thank you. Monthly, just in
terms of their monthly kilowatt hour consumption,
-- purely in
do they
the averageconsume more on average every month or l-ess than
residential- nonl-ow-i-ncome customer?
A. CAPAI asked the Company to look at usage of our
low-income customers. That's a difficul-t thing to do because
we don't have income information of our customers. I think an
agreement was reached between the Company and CAPAI to
assume to use customers that qualify for LIHEAP, which j-s
what the Company did. Based on that assumption, it indicated
that customers that received LIHEAP support typically used
higher than average energy uses than our average customer.
O. Okay, thank you. And if that then, in fact, is
true, that low-income customers typically, on average, use more
energy, would it -- what effect would it have if the Company in
this case were to have proposed an increase in the monthly
customer charge?
A. WeII, that's hard to say -- to answer to,
Mr. Purdy, because what we are all- aware is no customer is
average. You know, everyone is going to some may use more,
some may use fess. And to -- but an increase to the customer
charge would typically benefit customers that use more power.
Those that use a l-ow amount of power are benefiting by a 1ow
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customer charge currently and that's not just low-income
customers, that's a1l- residential customers. Rate design
creates winners and losers depending on how much energy you
use.
O. But all- other things bei-ng equal , if you were to
rather than recover all of the increased revenue requirement
that you're authorized through the customer monthly charge as
opposed to the energy component, isn't that going to benefit
high users, regardless of whether theyrre 1ow income or not?
A. I can't answer that.
O. Okay. Fair enough. Thank you.
And then, finaI1y, if you coul-d turn to page L4
of your direct, Iines 3 through 6, you state that the parties
who signed the stipulation have worked to thoroughly
investigate and analyze this rate plan as an al-ternative to a
general- rate case through auditing, qualitatj-ve discovery, and
careful negotiations, and have determined that the two-year
rate plan is in the public's best interest. Is that right?
A. Yes.
O. Wou1d you agree that the subject matter covered
by CAPAI's dj-scovery request submitted to the Company in this
case constj-tute qualitative discovery?
A.Yes.
O. Okay. And that those requests relate to the
consumption patterns of l-ow-income customers and the bill
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impacts that al-ternative rate designs would have on l-ow-income
customers ?
A. Could you restate your question?
0. Absolutely:
Woul-d you agree that the nature of CAPAI's
discovery request in this case was, first, to ascertain the
consumption patterns of low-income customers: Were they high,
1ow, average?
A. Yes, I guess.
O. Okay. And the dj-scovery request that was
significantly disputed in this case, CAPAI's Request 6,
subpart b, asked the Company to calculate the bil-I impact of
various rate design alternatives, did it not?
A. Yeah, I believe the discovery in question asked
the Company to perform analysis on behal-f of CAPAI and being
advised by Counsel that, you know, the production is to provide
data that the Company has.
When the Company didn't have that j-nf ormation
and sor you know, that's the point of this whole dispute
whether or not it was l-ate. The Company's position is that
we we filed the responses on time, informi-ng CAPAI that we
did not have the data that they'd requested. However, we did
go ahead and perform that analysis and provided the i-nformatj-on
to CAPAI so that they coul-d determine for themselves
appropriate rate design.
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A. And -- are you done, Mr. Weston?
A. Yes.
O. Okay, thank you. And without rearguing the
discovery dispute, isnrt it true that all of CAPAI's discovery
was first submitted to you informally on April 29Lh of this
year?
A. Yes, that's correct.
O. Thank you. Okay, if you coul-d turn to your
rebuttal- testimony, starting on l-ine 2 -- oLr excuse me,
page 2, l-ines 1 through 4. Do you have that?
A. Yes.
O. Okay. You characterize the Company's application
in this case dsr quote, a case with the intent of identifying
j-nterested parties that woul-d like to participate j-n
alternative rate plan discussions, end of quote. fs that
right ?
A. Yes.
O. Okay. Woul-d you explain what you mean by
"identifying interested parties"?
A. As the Company prepared for a rate case filing in
20L3, w€ looked at what the case drj-vers were, what was causing
the need for rate increase, and if there were alternatj-ve ways
to address those case drj-vers. And as we 1ooked at that, the
Company developed a plan that we believed that we coul-d employ
that would avoid a general rate case. And so we fil-ed an
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application with this Commissi-on, requesting that they notice
and open a docket so that any interested parties that woul-d
l-ike to participate in discussions to this al-ternatj-ve rate
plan approach could be identified and noticed and invited to
participate in those discussions.
O. Thank you. And, again, regardless of the labels
that we apply to the possibilitles, the two opti-ons of a
general rate case versus an alternative, either wdy, the
Company's objective was to obtain a revenue requirement
increase. Is that true?
A. Well , if you're speaklng of the $2 mi1l-ion
increase in thls rate p1an, the Company's position is that the
Commission afready approved that rate case in case PAC-E-7L-72
where they recognized that the Populus to Terminal investment
was used and useful- and would be incorporated in rates
January l, 20L4. Thatrs part of what the Company be1ieved
enabled us to develop a rate plan approach that woul-d avoid
filing a rate case and necessary costs and commitment of all- of
the parties.
And the reason that we explored this option with
interested parties was because we fel-t thatr ds I mentioned
earlier, when we looked at the case drivers and identlfied the
costs that would driving the need for a general rate case,
we were able to identify either current Commission cases for
example, the major case drivers that the Company was
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experiencing were from net power costs, the Company has an ECAM
mechanism that could deal with that,' a deprecJ-ation study that
was pending before the Commission/ so we fel-t like that coul-d
be heard before the Commissj-on; and the Populus to Terminal
j-nvestment that the Commission had already ruled on.
So it was the Company's bel-ief that there were
either pending dockets or previous Commission orders that dealt
with the major case drivers that we were experiencing, and that
we coufd use an alternative approach to address those issues
rather than filing a general rate case, whi-ch we had typically
done and which we would, for the j-nterest of al-I of the parties
and our customers, try to avoid.
O. Mr. Weston, I think that went beyond the scope
and intent of my questj-on, which is simply that if it were
not you needed to file for an extension of a rate plan to
obtain your increased revenue requirement, did you not, or you
wouldnft have filed anything?
A. We needed to address a couple of issues. Namely,
the treatment of the, as I mentioned already, the Populus to
Terminal- costs were already addressed by Commission order; we
had a Commission order for the treatment of the carbon plant
c]-osure. But one of the issues that were not addressed was the
pending depreciation study before this Commission and how that
increase would be addressed, and that was one of the issues
that we addressed in this stipulation.
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O. Mr. Weston, paragraph referring to Paragraph 4
of the Company's application in this case
First, do you have that document with you?
A. I do, Lf you give me just a mi-nute here.
O. Okay. Sure.
COMMISSfONER REDFORD: What page is that?
MR. PURDY: Pardon me?
COMMISSIONER REDFORD: What page is that?
MR. PURDY: Paragraph
THE WITNESS: ft's on page 2 of the Company --
MR. PURDY: Paragraph 4, page 2.
THE WITNESS: I have that.
O. BY MR. PURDY: Do you have that in front of you?
A. Yes.
O. Okay. You state that, quote, the Company
representatives have met j-nformally with the majority of its
customer representatives, including Commission Staff,
PacifiCorp Idaho Industrial Customers, Idaho Irrigation Pumpers
Associatj-on, and Monsanto, to discuss the concepts of a rate
plan that could possibly avoid the necessity and associated
expenses for all parties of prosecuting a general rate case.
Is that right?
A. Yes.
A. Okay. Was this meeting that you refer to in the
application, was that one or more meetings?
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A. Those were individual meetings. The Company
routinely meets wj-th these parties, and as part of those
discussions, we informed them that we were looking at
alternatives to a general rate case and asked if they'd be
interested in exploring those options.
O. Can you tell me if you recal-l- when and where,
roughJ-y, did those meetings take place?
A. I -- I don't I coul-d say I believe most of
those occurred j-n January.
O. January of 2073?
A. Correct.
O. Yes. And you mention to some extent what was
discussed during the meetings, which was whether there might be
some al-ternative process to obtain rate rel-ief . Was anything
else discussed?
A. I don't remember what al-l- was discussed in those
meetings.
O. I'm sorry, I dldn't hear that.
A. Sorry. I don't remember the ful-I extent of those
discussions of those meetings. I do know, l-ike, PIICT we
meet typically meet annually with our major customers and
present our business pIan. After we made the business plan
presentation, we then notifled them of this option that the
Company was considerj-ng and sought input.
O. Okay. Would you agree that CAPAI has been a
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regul-ar j-ntervenor in Rocky Mountain rate case filings for a
number of years now?
A. Yes.
O. Is there some reason why CAPAI was not informed
of and invi-ted to participate in these meetings?
A. No. We didn't meet with Snake River Al-l-iance or
fdaho Conservation League either, and whether that was an
oversight on the Company's part or not like I say, we met
with our major customers and just to get a feel if that was
even an option that the Company shoul-d pursue, but we did not
meet with al-l- of the intervening parties.
O. So if I understood your answer correctly, there
is no particul-ar reason why you did not involve CAPAI i-n those
meetings ?
A. No.
O. And, again, those meetings provided the parties
who were or apprised the parties who were invited of the
Company's intentions as early as .Tanuary of this year. True?
A. Those meetings notlfj-ed those parties that the
Company was interested in exploring other al-ternatives, yes.
O. Okay. If you would refer again to page 2 of your
rebuttal-, this time l-ines 9 through ll, you state
Sorry, do you have that?
A. .fust a moment. Was that page 2, did you say?
O. I said page 2, lines 9 through 11.
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A. Okay. Thank you.
A. You state that the Company filed the application
early enough to provide time for parties to discuss
al-ternatives to a general rate case. Is that right?
A. Yes.
O. And did the dj-scussj-ons that you conducted
both -- with the parties both pre- and postfillng of the
application ever resuft in any kind of a list of possible and
different al-ternatj-ves to a general rate case procedure?
A. f -- at the initial settlement discussion
ApriJ- 19th, the Company provided a list a list of case
drivers and a proposal its proposal- of how to deal- with
those issues.
O. I understand that the Company provided a list of
case drivers. My quest j-on though is was the overal-I outcome of
the first settl-ement negotiation to come up with a l-ist of
possible rate case al-ternative procedures, or was it to simply
just start talking about numbers?
A. From the Companyrs I canrt speak for the other
parties. Erom the Company's perspective, we presented our
proposal. I think it was then up to the other parties if they
had proposals of their own or al-ternatives that they woul-d l-ike
considered, they could have raised those as part of the
discussions and did raise those. Modifications were made to
the Company's proposal, and that's how we reached the final
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stipulation that was filed with the Commission.
O. Modifications pertaining to the substance and the
numbers, did it not, as opposed to procedure?
A. Again, the Company presented its proposals. The
other parti-es had their right and abil-ity to present thelr own
proposals to the rate pIan.
A. And, finally, with respect to this issue, would
you agree that the procedure ul-timately adopted by the parties
that led to the stipulati-on now pending before the Commlssion
is unique and unprecedented, or has there been a case resulting
in a revenue requirement increase simil-ar or identical- to this
one before?
A. f can't speak to that. I mean, the Commission
and members here have got years of experience. They can judge
for themsel-ves whether it was unique.
I can say on the Company's behalf we l-ooked at
each of the issues, felt the majority of those were addressed
in other cases already pendi-ng or had been rul-ed upon by the
Commission, and that's what we felt enabled us to utilize this
approach.
O. A11 right. Turning to page 3 of your rebuttal,
l-ines I through 10, do you have that?
A. Yes.
O. Regarding the fact that as you point out, the
settlement in this case, quote, means that -- means customers
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will- enjoy at l-east a three year period between general rate
case changes, end quote
Is that a fair statement of your testimony?
A. Yes.
O. Okay. My question to you: Is there any
guarantee that the next filing that increases Rocky Mountain's
revenue requirement won't al-so be something unique and not in
conformity with normal- general rate case procedure?
A. f'm not sure I understand your question. I
bel-j-eve the Company's conformed to Commission rul-es. We filed
a notice and that that application was noticed and -- by the
Commission. So I disagree with your generalization that we
were not in conformity with Commission ru1es.
O. No, I'm asking whether not in this case,
Mr. Weston, but whether in the next rate case I bel-ieve you
said three years or so down the road is it possJ-ble the
Company might ask for an al-ternative process once again?
A. f can't speak to that.
O. okay.
MR. PURDY: Bear with me, Mr. Chair: f'm trying
to cut down on my remaining cross.
O. BY MR. PURDY: Regarding the disputed discovery
request which asked Rocky Mountaj-n to cal-culate the monthly
bilI impacts on l-ow-lncome customers of al-ternative rate
designs, isn't it true that only the Company has the
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information necessary to make this cal-cul-ation?
A. That's correct.
O. Thank you.
A. But data request procedure is to provide the data
and al-l-ow the parties to do the analysis themsel-ves. The
difference here in this situation is CAPAI did not reguest the
data; they requested that the Company perform the analysis.
0. Are you saying that none of the discovery
requests submitted by CAPAI requested data that woul-d be
relevant to the analysis requested?
A. No, not at all. I'm saying the discovery in
dj-spute, Question No. 6, dld not request data; it requested the
Company to perform the anal-ys j-s. And that was the reason the
dispute. Had CAPAI simply requested the data to perform its
own analysis, the Company is more than happy and obl-igated to
provide that information.
O. But that was the point of my question when I
asked you isn't the Company the only party capable of making
the and I used the word "cafculation" as opposed to
tt ana 1ys i s tt
A. No, no.
O. of the impact on the monthJ-y bills of
Iow-j-ncome customers under their own rate designs?
A. No, the Company is not. The Company has the data
and is responsible to provide that data,'but as we do with all
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other parties, we expect the parties to perform their own
analysis, not the Company to perform the analysis for them.
O. But j-n answering CAPAI's discovery requests,
didn't you, first of all, rely upon the l-ow-income proxy group
we've discussed earlier, those people receiving some type of,
for instance, LIHEAP benefits?
A. Yes.
O. And then to determlne their consumption, didn't
you look at their physical address and the meter readings
throughout a year or perj-od of time, and calcu1ate an average
for that physical address?
A. The Data Request No. 6 requested that the Company
calculate different rate design alternatives. As I've
responded already, Mr. Purdy, the Company does have that
information, has the data that would be necessary to do those
calculations, and is obligated to provide that data. But the
question did not request the data; it asked the Company to
perform the analysis.
O. Isn't it true that the analysis or the study
whatever word you want to use requested in 6, subpart b,
was that analysis was performed by an employee of PacifiCorp
by the name of Ms. Joell-e Steward?
A. Yes.
O. A1l- right. But you're saying that CAPAI coul-d
have cal-cul-ated the bill impact of Rocky Mountain' s customers
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based on alternative rate design scenarios?
A. Yes. If CAPAI woul-d have requested the usage
information -- which the Company had we woul-d have provided
that, and CAPAI or any other party coul-d have used that
information to develop their own rate design proposals.
O. Eina11y, f believe that in your rebuttal-
testimony, you reference the fact that the studies, the
calculations requested by CAPAI, were provided by PacifiCorp's
Washington dj-vj-sion in that division's pending Washington rate
case. Is that true?
A. f don't believe so. Can you point me to that in
my testimony?
I think CAPAI pointed out that that information
was provided in Washington. I donrt bel-ieve the Company --
O. Yes, if you could just bear with me for a moment,
I I 1l- try to f ind that.
A. I guess we did. Excuse me, Mr. Purdy.
O. Pardon me?
A. Excuse me, I did -- on page 3, l-j-nes 22,
beginning on l-ines 22, points out that the spreadsheet that was
provided 1s simj-lar to the format of the data that have been
provided in Washington, you are correct.
O. Thank you. Thanks for doing that for me; I
appreciate it.
Is there a reason why that information coul-d be
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supplied in Washington but not in Idaho?
A. Yes: Washi-ngton rul-es provide the Company to
perform analyses for parties. The Company doesn't believe that
those rul-es apply in Idaho.
O. I'm sorry, I just didn't hear that. Could you
speak l-ouder?
A. Yes, sorry. Washington rule statute requires
that the Company perform analyses for parties. The Company
does not bel-ieve that applies in Idaho. Idaho rules don't
require the Company to perform other parties' analyses.
O. Can you direct me to which Washington rule you
are speaking of?
A. I cannotr oo. I've just been advlsed by our
counsel that that's the situation.
O. AII- right.
MR. PURDY: Mr. Chair, that is al-l the cross that
I have.
Thank you, Mr. Weston.
COMMISSIONER REDFORD: Thank you.
Mr. Price, did I ask you if you had questions?
MR. PRICE: You haven't, but I do not.
COMMISSIONER REDEORD: Mr. Budge.
MR. BUDGE: No questions.
COMMISSIONER REDFORD: Mr. Otto.
MR. OTTO: f have no questions.
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HEDRICK COURT REPORT]NG
P. O. BOX 578, BOTSE, rD
WESTON (X)
RMP83701
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HEDRICK COURT REPORTTNG
P. O. BOX 518, BOTSE, rD
WESTON (Di)
RMP
COMMISSIONER REDFORD: Okay. Mr. Sol-ander.
MR. SOLANDER: Just one questJ-on, thank you.
RED]RECT EXAMTNATION
BY MR. SOLANDER:
O. Fol-lowing the conclusion of this general rate
case, would the Company be wll-l-ing to work with CAPAI outside
of the rate case process to discuss rate price issues or other
areas of concern that CAPAI had?
A. Certaj-nly, and that was the offer that the
Company made initially and that offer still- stands. The
Company believes that we may have simil-ar j-nterests. The
Company, in its filing back i-n 2010, proposed increases to the
customer charge and again in 2071, and the rate design was
fu11y vetted in that 201,0 case. But we would definitely be
interested.
I think there's been issues before this
Commission recently that have questioned the current customer
charge l-evel, and the Company woul-d be open to exploring those
issues with interested parties if they would like to do so.
MR. SOLANDER: I have no further questions.
COMMISSIONER REDEORD: Thank you.
MR. PURDY: Mr. Chair, that incl-uded a questlon
that I think brought new informati-on into the mix here. May I
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HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD
WESTON (x/Com)
RMP
just ask one quick foI1ow-up?
COMMfSSIONER REDEORD: Go ahead, make it quick.
RECROSS-EXAMINAT]ON
BY MR. PURDY:
A. Mr. Weston, regardless of the Company's
willingness to sit down and work with CAPAI to discuss this
matter, the fact is that there can be no rate design changes
made until- effective January l-st of 201,6. Is that right?
A. That's correct.
O. Okay. Thank you.
COMMISSIONER REDEORD: Any questions from the
Commission?
COMMISSIONER SMITH: No.
COMMISSIONER REDEORD: Commissioner Kjellander.
COMMISSIONER K,JELLANDER: No .
COMMISSIONER REDFORD: I have a couple of
quest j-ons.
EXAMTNAT]ON
BY COMM]SSIONER REDFORD:
O. I believe you said that March 1,2 was the date
when the notice and application was filed. fs that correct?
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HEDRICK COURT
P. O. BOX 518,
REPORT]NG
BOISE, ID
WESTON (x/Com)
RMP
A. Yes, that was the Commission notice, the
Company' s application.
O. And do you know when CAPAI intervened?
A. I do not. I believe the intervention deadl-ine
was the 25Lh of March, but I don't know the specific date.
O. But at any rate, CAPAI fil-ed the intervention
shortly after March 72th?
A. Sometime between then and March 26Lh, y€s.
O. Did CAPAI at any time participate at any of the
settlement discussions?
A. They did, y€s, they were invol-ved.
O. And to what extent? I mean, was everything stil-l-
open and on the tabl-e at that time?
A. Yes.
O. Did CAPAI actively participate?
A. Yes.
O. Okay. Did CAPAI ever do anything by way of
calculati-ng what we're now talking about, the numbers?
A. I can't speak to that: I don't know what they
di_d.
O. You provided the information?
A. Regarding the data response in Question No. 6,
the Company performed the calcu1ation. I don't know if they
any additional analysis with the information that was provided,
I can't respond to that, but initiall-y the Company provided the
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HEDRICK COURT
P. O. BOX 5'7 B ,
REPORTING
BOISE, ID
WESTON (X/Com)
RMP
anal-ysis, yes .
O. Do you have any idea of you have stated in
your testimony that the alternative procedure is probably Iess
costly than a fuII rate case. Is that correct?
A. Yes.
O. Do you have any idea how much you've saved by
doing this alternative rate case?
A. That you know, that's hard. f don't,
Commissioner. That's hard to calculate. But, you know,
hopefully --
We didn't do all- of the pricing rate design. We
didn't take time to write and prepare testimony of several-
witnesses, other than my own. Typically the Company may have
15 to 20 witnesses that will- have to prepare testimony. The
other parties also avoided that same process, and so we bel-ieve
that there were signJ-ficant cost savj-ngs because of this
approach.
COMMISSIONER REDEORD: I have no further
questions. As a result of my examinati-on, did any of the
parties want to ask another question?
Thank you, Mr. Weston.
THE WITNESS: Thank you.
(The witness left the stand. )
COMMISSIONER REDFORD: Mr. Budge.
MR. BUDGE: Chairman, we have no witnesses to
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HEDRICK COURT REPORTING
P. O. BOX 5'78, BOTSE, rD
LOBB (Di)
Staff
present on the matter. We certalnl-y signed the stipulation and
do support approval. I have a few minor matters to take up
with the Commission regardj-ng the Monsanto contract and
Schedule 400, but f'11 do that at the conclusion of proceeding
on other matters.
COMMISSIONER REDFORD: Mr. Price.
MR. PRICE: Commi-ssion Staff cal-l-s Randy Lobb.
RANDY LOBB,
produced as a witness at the lnstance of the Staff, bei-ng first
duly sworn, was examined and testified as follows:
DIRECT EXAMINATION
BY MR. PRICE:
O. Pl-ease state your name.
A. My name j-s Randy Lobb.
A. And by whom are you employed and in what
capacity?
A. Irm employed by the Idaho Publ-ic Util-ities
Commission. I am the administrator of the util-ities
division.
0. And, Mr. Lobb, did you partlcipate in the
settlement negotiatj-ons in this case?
A. r did.
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HEDRICK COURT REPORT]NG
P. O. BOX 518, BOTSE, fD
LOBB (Dr)
Staff
O. And did you previously prepare written direct
testimony consisting of 1,4 pages with Exhibit 101 attached, and
rebuttal testj-mony consisting of eight pages?
A. Yes, I did.
O. Do you have any additions or corrections to that
testimony?
A. I have a correction in my direct testimony,
page 4, l-ine 13. It says on "March 37, 20L3." That should be
"March L, 20L3."
O. Do you have anything el-se to add?
A. No.
O. Okay.
MR. PRICE: With that, I would ask that
Mr. Lobb' s direct and rebuttal- test j-mony be spread upon the
record as if read.
COMMISSIONER REDFORD: If there are no
objections, it will be so done.
(The fol,l-owing prefiled direct and
rebuttal- testimony of Mr. Lobb is spread upon the record. )
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O. 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, Bolse, Idaho.
O. By whom are you employed?
A. I am employed by the Idaho Public Utilities
Commission as Utilities Division Administrator.
O. What is your educational and professional
background?
A. I received a Bachelor of Science Degree in
Agricultural Engineering from the University of Idaho in
1-980 and worked for the Idaho Department of Water Resources
from ,June of 1980 to November of L987 . I received my ldaho
license as a registered professional Civil Engineer in 1985
and began work at the Idaho Public Utilities Commission in
December of L987. My duties at the Commission current,ly
include case management and oversight of all technical st.aff
assigned to Commlssion filings. 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, regulatory policy and facillt,y acquisitions.
O. What is the purpose of your testimony in this
case?
CASE NO. PAC-E-13-04
8/1-5/1-3
LOBB, R. (STIP)
STAFF
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A. The purpose of my testimony is to describe the
process leading to the filed Stipulation (Proposed
Settlement), t,o present the terms of the Stipulation and to
explain the rationale for Staff's support.
O. will you please summarize your testimony?
A. The Settlement Stipulation filed in this case, was
negotiated outside of a traditional general rate case
filing, yet represents a reasonable alternative to what
1ike1y wouLd have occurred through the traditional
ratemaklng process. Staff recognizes the concern expressed
by various parties regarding settlement in advance of a
Company rate filing but maintains that the limited impact of
the settlement ls as close to a non-filing as possible.
Moreover, througth broad audit of Company results
of operations, review of rate cases filed in other
jurisdictions, and thorough discussion and negotiation of
limited settlement terms, Staff and other parties to the
case agree that the Settlement Stipulation is in the best
j-nterest of customers and should be approved by t,he
Commission.
O. Would you please describe the terms of t,he
proposed Stipulation?
A. Yes. The Stipulation has five basic provisions.
They are:
l-. A 0.77* base rate revenue increase effective JanuarY a,
201-4 to reflect previously approved inclusion of the
CASE NO. PAC-E-13-04
8/1,6/13
LOBB, R. (STIP) 2
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Populous to Terminal Transmission line,
2. A "Stay Out Provision" whereby the Company isprohibited from filing for a base rate increase before
May 31, 2015 and new base rates cannot become effectiveprior to January 1 , 201-6,
3. A Lake Side II ECAM adder beginning ,January L, 2015 toreflect both costs and benefits of the new combi-nedcycle generating p1ant,
Deferral, unLil the next general rate case, of changesin depreciation expense to be ultimately approved bythe Commission in Case No. PAC-E-1.3-02,
Deferral of Carbon Coal plant depreciation expenses and
removal costs based upon Commission Order No. 32701 andan amount to be ultimately decided by the Commission in
Case No. PAC-E-L3-02.
O. Are there any other terms specified in the
Stipulation?
A. Yes, there are two oLher terms that primarily
affect Monsanto. The first is modi-fication of ECAM
methodology, consisLent. with Commission order No. 3277L, to
assign cost responsibility to the various customer classes
for an interim period. The second is agreement between
Monsanto and the Company regarding annual true-up of the
interruptible credit within the Electric Service Agreement.
The Stipulat.ion is attached as Staff Exhibit No. 101.
Hist,ory
On January 1-0, 20L2, Lhe Commission issued Order
No. 32432 in Case No. PAC-E-a1-l-2 approving a Stipulated
Settlement for a two-year rate plan through .fanuary 1, 20L4.
The Stipulation prohibited Rocky Mountain Power from filing
4-
5.
CASE NO. PAC-E-]-3-04
8/L6/L3
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another rate case until May 31-, 201-3, with new rates not
ef f ective prior to .January l, 20l-4 .
In February of 2013, Rocky Mountain personnel made
an informal proposal to Commission Staff and other parties
to extend the multi-year agreement in lieu of another
general rate case filing. Staff saw merit in the Company's
proposal and suggested that, the Company file a case "to
investigate alternatives to a general rate case" so that al-l
interested parties would have an opportunity to part,icipate.
The Company maj-ntained that if a deal could not be struck,
it would file a traditional general rate case application on
May 31, 20L3.
On March 31, 2013, Rocky Mountain filed a Notice
of Intent t,o File a general rate case and an Application
requesting t.he Commj-ssion provide notice to part.ies
interested in entering into rate plan sett.lement.
discussions.
O. What was included in the Company's Application?
A. The Application consj-sted of two pages that simply
requested the Commission open and notice a docket and set an
intervention deadline that would formally notify interest,ed
parties of Rocky Mountaj-n's intent to engage in settlement
discussions. The Company stated that the intent. of the
settlement woul-d be to reach agreement on terms that would
allow the Company to avoid a general rate case filing in
CASE NO. PAC-E-13.04
8/L6/L3
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201-3 and extend the existing rate plan for an addiEional
period of time.
O. How did the case proceed?
A. The Commission opened the case and seE an
intervent,ion deadline. Six parties intervened lncluding the
Idaho Conservation League (ICL), the Snake River Alliance
(SRA), the Consumer Action Partnership Association of Idaho
(CAPAI), the Idaho Irrigation Pumpers Association (IfPA),
Monsanto and PacifiCorp's Idaho Indust,rial Customers (PIIC) .
Settlement workshops were held on April L9, 201,3
and May 2, 2013, where all parties participated. Rocky
Mountain Power (RMP) made its initial proposal and
negotiations ensued. Apart from the issues specifically
identified in the Settlement. Stipulation, other issues
discussed included the raEemaking process, the perceived
lack of information or evidence that justifled provisions of
the Settlement, rate design, cost of service and Monsanto
contract provj-sions.
After review of the general Staff audit and
lengthy discussion of alternatives, all parties except CAPAI
agreed to settlement terms and signed the Stipulation.
Rocky Mountaj-n submitted the document for Commission
approval on ,June 3, 201-3 .
Staff Evaluation
O. How did St.aff evaluate t.he Stipulation to
CASE NO. PAC-E-13-04
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det,ermine that the terms were reasonable?
A. Staff began its evaluation by reviewj-ng the terms
proposed in t.he Stipulat,ion. With few exceptions, the
expenses proposed for recovery in rates were either already
approved by the Commission for future rate recovery or were
dependent upon Commission determination in an existing case.
For example, the proposed base rate increase of
approximately $2 million (0.77?") represents the revenue
requirement for the 27* of the Populus to Terminal
transmission line approved for rate recovery by the
Commission in order No. 32432. The Stipulat,ion also
specifies that Rocky Mountain will be allowed to defer as a
regulatory asset the difference between current depreciation
expenses and new depreciation expenses approved by the
Commission in Case No. PAC-E-13-02. The deferred balance,
reflecting either an increase or decrease in expenses will
be amortized in the next general rate case.
Fina11y, the Stipulation specifies accounting and
ratemaking treatment for the Carbon coal plant removal costs
based primarily on previous or expected Commission Orders.
The Commission already approved Carbon removal cost deferral
in Order No. 3270L and will specify the appropriate
projected removal cost and associated depreciation expense
in Case No. PAC-E-L3-02.
These are all issues that have been or will be
CASE NO. PAC-E-13-04
I /t6 / 1,3
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decided by the Commission with respect to rate recovery in
the next general rate case regardless of the outcome in this
case.
O. What. issues have not and will not be addressed by
the Commission prior to the conclusion of this case?
A. Treatment of costs associated with the Lake Side
II Combined Cyc1e gas plant currently under construction has
not been addressed by the Commission. It is unlikely cost
recovery of t.he plant would be futly addressed by the
Commission bef ore its scheduled online date of .June 1-, 20]-4 .
However, the Stipulation specifies that costs and
benefits of the plant will be tracked through the ECAI"I
starting January 1, 20L5. A1t.hough the Stipulation
specifies that project costs would be included in the ECAM
outside of a general rate case, costs would not be included
for the first six months of project operation while the
benefits would automatj-ca1Iy flow through the ECAftl on the
first day of project operation.
O. What is the impact on customers of including Lake
Side II in the ECAM?
A. The actual benefits derived from Lake Side II are
difficult to quantify because they will depend upon the
price of natural gas as compared to the operating cost of
other generation resources. The more Lake Side II operates
economically, the more benefits will aut.omatically flow
CASE NO. PAC-E-13-04
8/L6/13
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STAFF
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t.hrough Ehe ECAM in the f orm of Iower operat.ing costs.
CusLomers wilI receive t.hese benefit,s without incurring any
project capit,al costs for sj-x months.
Starting January L, 20L5, annual capital revenue
requirement not to exceed $5.43 million will be added to the
ECAM for recovery from Idaho customers. This will allow an
equitable tracking of project benefits and cost.s unt.il Lake
Side II is permanently placed j-n base rates. ECAM rates
reflect.ing Lake Side II capital costs will not be effective
unt,il April L, 20L5.
O. WilI the Commission have an opportunity Eo review
actual proj ect costs for prudency?
A. Yes. A fu1l review of project cost,s and
justification for the generati.ng plant will be conducted as
part, of t,he Company's nexE general raLe case. Up to a year
of actual plant operation will also be available to assess
t.he value of the plant to Idaho customers. Any subsequent
adjustment in cost recovery can be included as an offset to
costs previously tracked through the ECAM.
O. What is t,he effect, of changes to ECAI,I cosL
allocation methodology?
A. The changes result in a slight, shift of ECAM cost
responsibiliEy from Monsant.o and Agrium to other cusEomer
classes. The modification results in an approximat,e $90,000
shift in Ehe last six months of 20L3 but becomes a non issue
cAsE NO. PAC-E-13-04
8/L6/13
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when t.he ECAM deferral is calculated on a t,otal Idaho basis
on December l, 2013. The parties agreed t,hat the temporary
cost shift was equitable given reduced line losses
experienced by these transmission service 1eve1 customers.
O. Why did the Staff support changes t.o t,he
Monsanto/Rocky Mountain Power Elect.ric Service AgreemenL?
A. This Stipulation Lerm resolves a long-standing
dispute between t.he Company and Monsanto regardj-ng the
annual true-up of t.he interruptible credit and does not
impact any other cusLomer class. Consequently, all parties
support resolution of this issue.
a. VJhat other cost recovery issues are specified by
the st.ipulat,ion?
A. The only oLher issues specified in the Stipulati-on
include t.he stay-out provisions t.hat prohibit t.he Company
from filing a general rate case prior to May 31, 20L5 or
increasj-ng base rates prior to January 1, 20L6, and how the
0.77* increase will be applied to exist.ing customer rates.
Staff maintaj-ns thaL the stay-out provision
prohibiting further base rate increases is clearly in t,he
best inEerest of customers and that a small uniform increase
in revenue requiremenE limit.s the impact on all Company
customers.
O. Has t,he Company made 2013 rate fi1-ings in other
state jurisdictions?
CASE NO. PAC-E-13-04
8/L6/L3
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A. Yes, the Company has pending rate cases in Oregon
and Washington requesting increases of 4.62 and 14.1?
respect,ively.
A. Did Staff conduct an audit of Company results of
operations to determine if settlement was a reasonable
alternative to a general rate case in Idaho?
A. Yes. Staf f spent two days at Company headquart.ers
and multiple days in Boise reviewj-ng results of operations
for the twelve months ended December 2A12. Potential
proforma adjustments were also eval-uatred. Staff audited
the results of operations and records to determine
reasonableness, identify pot.ent.ial issues and evaluate the
magnitude of potent.ial adjustment,s. The resufts of
operaLions indicat.e the Company was preparing the General
Rate Case with an Idaho revenue requirement j-ncrease that
could be greaEer than $15 Million. GeneraL rate case issues
and potential adjustments ident.ified by Staff include E,he
following: plant in service changes, depreciation and
amortizatj-on expenses, property t,axes, net power supply
costs, labor increases, pension cost,s, outside services,
injuries and damages, operation and mainLenance expenses,
income t,axes with the impact from bonus depreciatj-on,
memberships, subscriptions, donations, SO2 emission
allowance sales, allocation of renewable energy credits
(REC) and the sale of RECs.
cAsE NO. PAC-E-13-04
8/t5/L3
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Based on its audit., Staff determined that even wit.h
t,ypical rate case adjustments similar to t.he St,aff position
in the IasE few cases, the resulting Idaho revenue
requirement would be greater t,han the approximate $2 MilIion
(0.77* ) increase proposed in the sett.lement discussions to
be effective ,January 1, 201-4. Staff also verified the
revenue requj-rement associated wiLh Ehe inclusion of the
remaj-ning 272 of the Populus to Terminal transmission line
investmenL and eval-uat.ed the ECAM adder associated with Lake
Side II.
General Coneerng
A. Do you have any concerns aboutr
stipulated base rate increase without a
filing from the Company?
cAsE NO. PAC-E-13-04
8/16/L3
A. The lack of a Company filing that proposes and
justifies an increase in rates is certainLy a consideration
in deciding whether Eo accept the Stipulated Set.t.Iement. A
formal raLe case filing can be more transparent and provide
more Eime Lo address a broader range of issues. St,aff
ultimately determined that. while a more formal filing could
have provided more information upfront for parties Lo
evaluate, it likely would have included a proposal and
justification for a much }arger increase. The tradeoff in
this case is to forgo the t.raditional rate filing as a
condition for obEaining a Iimited increase wit.h rate
accepting a
general rate case
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stability over t.ime.
The fact that a traditional filing has not. been
made has not prevented the St.aff from auditing and
evaluating just.ificat.ion for the increase. As previously
indicated, t.he impact of the Sett,lement, is quite limited
with straight forward justification. Staff believes that
other seLtlement terms are similarly strai-ght forward, have
limited or no impact through the rate plan period and would
like1y be justified through the tradiLional rate filing
process anyway.
Finally, Staff sees value for both the Company and
it,s ratepayers in avoiding cost.ly rate proceedings if
reasonable alt.ernatives are avaj.lable. UItimately, Staf f
believes t.hat, Ehe process and the associated sett.lement
resufLs is a better deal for all customers in this case.
0. Do you have any concerns that important, issues
such as class cosL of service and rat,e design are not
addressed in this case?
A. I have some concern that cosL allocation among the
classes can become less accurat,e over time. Likewise,
conditions can change that, justify a fresh look at rate
structure. However, these issues were considered and
addressed in the last general rate case, Case No.
PAC-E-L1-12. In t.hat case, t.he Company-proposed class cost
of service study was used as t.he basis for making a 50? move
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toward cost of service over the two-year rate period (20L2-
2013). Rate structure was also modified to move demand
charges closer to cost of service while uniformly increasing
energy charges and maintaining customer charges aE current
l-eve1s.
St.aff does not believe t,hat conditions have
changed enough since the last rate case to require
modification in this case in Lhese areas. This is
particularly true when addressing these issues could mean
rejecting a favorable rate seLtlement or eausi-ng significant
rate impacts for a select group of cusLomers when litt1e
impact occurs as a result of the Settlement. Consequently,
Staff supports a uniform revenue requirement increase for
all customer classes and a uniform increase in only the
energy component of rates.
Sunmary
a. Could you please summarize Staff's view of the
rate case process and resulting Settlement?
A. Yes. Given the relatively sma1I size of the rate
increase and llmited nature of Set,tlement E,erms, Staff
maintains that the process used in this case is a reasonabl-e
alternative to a traditional rate case filing. The Lerms of
the Settlement have limited rate impact and primarily
address cost. recovery for iLems previously approved or wilI
be decided by the Commission in separate proceedings. The
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agreement provides rate st.ability through January of 20L6
and was signed by all parties to the case except. CAPAI.
St,aff believes t,he Sett.Iement Stipulation is j.n the public
int,erest and should be approved by the Commission.
O. Does that conclude your testimony?
A. Yes it does.
cAsE NO. PAC-E-13-04
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O. 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.
O. Are you the same Randy Lobb who previously
submitted testimony in this proceeding?
A. Yes f am.
O. What is the purpose of your rebuttal testimony in
t.his proceeding?
A. The purpose of my rebuttal testimony is to address
issues raised in the direct. testimony of Christina Zamora on
behalf of the Community Action Partnership Association of
rdaho (CAPAI) .
O. Would you please summarize your testimony?
A. Yes. Through the tesE,imony of Ms. Zamora, CAPAf
unfairly blames historic rate case processing and
specifically the processing of this case for its failure to
prevail on issues of interest or to obtain requested
information to fu1ly vet its issues. SEaff believes CAPAI
had numerous opportunities in recent general rate cases,
whether fu1Iy litigated or settled, to inform the terms of
the settlement or make its case directly to the Commissj-oners
at. hearing. In this case, Staff maintains that CAPAI had
more than enough Eime to obtain the information it, needed to
address its issues. Whj-le not support,ing a rate sL,ructure
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change in this case, SEaff is willing to work with CAPAI to
evaluate low income rate issues and recommend adjustments
that will benefit low income customers. However, St,aff
believes that the processing of this case, given Ehe
circumstances, is in the best interest of all customers and
did not disadvant.age CAPAI.
O. On page 6 of her testi-mony, Ms. Zamora states that
St,aff typically schedules settlement negotiations in every
case soon after t.he ease is filed and does so wit.hout ever
contacting CAPAI. Is this true?
A. Absolut.ely not. Staff does not unilaterally
schedule seLtlement negotiations. General rate case
schedules, including seE,tlemenL dates if any, are established
by all parties at a prehearing conference after the
intervenLion deadline has passed. CAPAI has intervened in
numerous general rate cases and participated in all
scheduling conferences .
O. On page 7 of her t.estimony, Ms. Zamora talks about,
typical rate cases since 2OLl and how the Staff engages in
meetings wit.h ut,ilities before a filing. She then explains
that there is typically a very abbreviated course of
discovery between Staff, the utility and possibly a large
industrial special contract customer and then the scheduling
of settlement conferences. Is she correct?
A. No, not at aII. Staff rarely meets with the
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Company t,o discuss the contents of a rate case before the
utiliEy makes a filing. However, Staff works with utilities
every day on a variety of issues so we are keenly aware of
what will likely be included in a rate fiting. Staff has
also processed numerous general rate case filings from all of
the ut.ilities over the last few years and has a detailed
understanding of cost drivers and issues.
Wit,h respect to abbreviated course of discovery,
Ms. Zamora is simply wrong. The Commissj.on Staff has
processed four elect,ric utility general ratse cases since
2011. During t.hat time period, Staf f processed t.wo Avista
cases and one each for Idaho Power and PacifiCorp. The
average discovery period in t.hose cases was 3.5 months and
Staff asked an average of 191 discovery requests.
Additionally, numerous other discovery requests were asked by
other parties to the ease. For the ten rate cases processed
since 2OO8, the average time allotted for discovery was
approximately four months where Staff asked an average of L47
discovery requests. CAPAI was a party in all of these cases.
O. On page 8 of her testimony, Ms. Zamora complains
that since 2OLL Staff has settled rate cases before prefile
is due and before CAPAI has a chance to prepare? How do you
respond?
A. I can't respond to CAPAI's inability to prepare in
the timeframe provided. However, Ehe maximum timeframe for
CASE NO. PAC-E-13-04
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processing rate cases is set by statute and all available
time is used by E,he parties in sett,ing the case schedule.
Staff generally believes that there is an advantage for
ratepayers if settlement occurs prior to the parties
prefiling direct testimony. Once testimony is filed, the
ut.iliEy has a better understanding of how strong or weak
party posiEions may be and may be less j-nclined to reduce it.s
revenue requirement request than it woul-d have been prior Lo
filing. In other words, the parties can often present, a
beLter case in set.tlement, negotiations than can actually be
defended in prefiled direct, testimony.
However, attempting to setEle a ease before non
utility parties file dlrect testimony does not mean the
period for discovery is significant.ly shorter or case review
is less rigorous. fn Case No. PAC-E-1L-i-2, Lhe first
settlemenE conference was held three months after the Company
filed its Application, and the Settlement Stipulation was
filed with the Commission thirteen days before original
prefile was due.
O. On page 10 of her t,estimony, Ms. Zamora claims that.
in numerous cases CAPAI is inst.ructed by Staff that CAPAI's
issues are of no relevance to them in t,he seEtlement process,
which results in CAPAI being shut out and marginalized. Do
you agree that this is the case?
A. No, I do not. CAPAI Eypically presents two main
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issues in general rate case proceedings. Those issues are
funding levels for the Low Income WeatherizaEion program and
t,he impact of rate structrure on low income customers. Staff
has worked very closely with CAPAI on both of these issues to
understand what CAPAI hopes to achieve and how its positions
might be justified. Moreover, CAPAI is always given the
opportunity to address these issues before the Commission.
fn the fully litigated PaciflCorp rate Case No.
PAC-E-1-O-7, CAPAI participated as a party and was able to
fu1ly present its positions to the Commission for decision.
CAPAf addressed low income weatherization and opposed the
Company's proposal to increase the residential customer
charge.
fn the PacifiCorp general rate Case No.
PAC-E-71--1-2, CAPAI decLined to enter into sett,lement and
instead filed testimony with the Commission regarding concern
over the settlement. process and the need to increase 1ow
income weatherization funding. These issues were presented
at hearj-ng and heard by the Commission. Although CAPAI did
not support the Stipulation, it found posiEive value in
preserving the fj-ve dolIar monthly residential customer
charge.
In other cases such as IPC-E-11-08 and AVU-E-1L-01,
CAPAI's issues were eit.her heard by the Commission at hearing
or incorporaEed in the SeEt,lement Stipulation. In all of
CASE NO. PAC-E-13-04
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Ehese cases, CAPAI had the opportunity to shape the
settlement or, alternatively, present its case directly t,o
the Commission.
O. CAPAI witness Zamora complains in testimony from
pages 15 through 20 about the processing of this case and t.he
Iack of response from Rocky Mountaj-n in answering production
requests. Could you please provide your perspective on case
processing and responses to production requesEs?
A. Yes. As I previously explained in my direct
t.estimony, settlement was achieved in this case without a
traditional Company rate filing by virtue of the straight
f orward settlement terms. All- of the set,tlement terms have
been previously approved by the Commission, are in the
process of being determined by t.he Commission or will be
subject to review by E.he Commission in the fuLure. Staff and
all other signatory parties agree t,hat the settlement is a
reasonable alt.ernative to a general rate case filing.
f have described the chronology of this case in my
direct testimony so I will not repeat it here. I do want to
point out that the time period between the Company's
Application to open the case and CAPAf's Motion to Compel
discovery was five mont,hs, from March 1, 20L3 to ,Ju1y 30,
20l.3.
On page L9 of her direct testimony, Ms. Zamora asks
if Staff took a position in the discovery dispute. No
cAsE NO. PAC-E-13-04
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discovery request, from CAPAI to Rocky Mount.ain was ever filed
with the Commission. IL cannot be found in any case file or
in any e-maiI to Commission Staff. To date, I have not seen
the discovery request. I did receive an e-mail on May 31,
201-3 from CAPAf's attorney stating that. Rocky Mountain
refused to respond t,o CAPAI's production requesE so CAPAf
would not sign the Settlement. Two months Iater, CAPAI filed
its Motion to Compel.
a. In your view, did t.he processing of t,his case
prevent CAPAI from fuI1 participatj-on?
A. f do not believe that it did. CAPAI had three
months to ask, and even compel discovery if necessary, before
the Set,tlement was fiIed. CAPAI had an additional two months
after the Settlement to obtain discovery, prepare testimony,
etc. CAPAI's traditional issue of Low fncome Weatherization
funding was not rea1ly addressed by CAPAI. The only issue
raised by CAPAf was rate design. It is likely CAPAI would
have been provided even less time to request, receive and
analyze rate informat,ion if the Company had made a
traditional rate filing.
Regardless of the rate chang'e recommendations CAPAI
might have proposed, changing rate sLrucLure in this case or
a t.raditional case can cause substantial increases for some
customers even when t,he proposed overall increase is sma1l.
O. Wou1d Staff be willing to sit down with CAPAI to
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analyze the various residential rate structures to determine
impact on low income customers?
A. Yes. St,aff worked with CAPAI recently on
collecting and analyzing relevant customer data from Avista
and is willing to do the same with data provided by Rocky
Mountain and Idaho Power. Ms. Zamora states on page 11 of
her testimony that CAPAI is the only low income residential
advocate. However, Staff advocates for Iow income customers
by limiting overall rate increases and balancing rate design
for the overall benefit of all 1ow i-ncome customers.
O. Does that conclude your rebuttal testimony in this
case?
A.Yes it does.
CASE NO. PAC-E-]-3-04
8/30/L3
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HEDRICK COURT
P. O. BOX 578,
REPORT]NG
BOISE, ID
LOBB (X)
Staff
(The following proceedings were had in
open hearing. )
MR. PRICE: I tender this witness for
cros s-examinat ion .
COMMISSIONER REDFORD: Thank you.
Mr. Solander.
MR. SOLANDER: No questions.
COMMISSIONER REDFORD: Thank you. Mr. Budge.
MR. BUDGE: No questions.
COMMISSIONER REDFORD: Mr. Purdy.
MR. PURDY: Thank you.
CROSS_EXAM]NATION
BY MR. PURDY:
O. Good morning, Mr. Lobb.
A. Good morning.
O. If you could direct your attention to page 2 of
your direct testimony, specifically, l-ines 6 through B, you
state that this requested rate j-ncrease was negrotJ-ated, quote,
outside of a traditional- general rate case filing, end quote.
Is that fair?
A. Thatrs what my testimony says, y€s.
O. Just based on your extensive tenure and
experience here, would you agree that the procedure adopted in
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HEDRICK COURT REPORT]NG
P. O. BOX 578, BOTSE, rD
LOBB (X)
Staff
this case is unprecedented?
A. I woul-dn't say it's unprecedented. We have had a
similar sort of situation in the past with Idaho Power where
settl-ement negotiations were undertaken prior to the filing of
a general rate case.
O. Can you refer me to a case number or a date when
that
A. I donrt have that off the top of my head. Itrs
captloned under the use of deferred tax credits, the use of
deferred tax credits. It was a combination of use of PCA
reduction -- power cost adjustment reduction and the use of
deferred tax credits to forgo a general rate filing, and there
were many parties that participated in that negotiation. And
it resulted in base rate increases for power supply, but there
was never a general rate case filed by Idaho Power.
O. Okay. No notice of intent was fil-ed in that
case ?
A. A notj-ce of intent was filed in that case by
Idaho Power.
O. It just never went to a rate case?
A. Yeah, there was never a traditional- rate case
filing.
O. Okay. Anything el-se?
A. No. Other than that, this is unique.
O. I'm golng to refer now to your rebuttal
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HEDRICK COURT REPORT]NG
P. O. BOX 5'78, BOTSE, rD
LOBB (x)
Staff
testimony. And, generally, in your rebuttal you challenge
Ms. Zamora's testi-mony that either recent general rate cases or
this one j-n particular result in an expedited procedure. fs
that your positlon?
A. Could you show me
O. Well
A. or cj-te it specifically?
O. We1l, just generally speaki-ng let me rephrase
that you take exception with Ms. Zamora's contentj-on that
this case necessarily resuJ-ts in an expedited process; that it
woul-d be roughly the same if we were to go to general rate
case ?
A. Yes, generally speaking, y€s.
O. Okay. And the I believe, as Mj-ster
Commissioner Redford pointed out, the notice of applicati-on was
filed on March L2th in this case. Correct?
A. Thatrs correct.
O. A11 right. And for parties who are otherwi-se
unaware of a filing, the notice of application is perhaps the
first time that that party might be aware of the fiting?
A. Thatrs true.
O. Is that a possibility?
A. Yes.
O. So that's a rel-evant date to work with as we tal-k
about the various times here?
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HEDRICK COURT REPORTING
P. O. BOX 518, BOISE, TD
LOBB (X)
Staff
A. Sure. I'11 agree with that.
0. Okay. And, agaJ-n, fol-l-owing up on questions I
asked Mr. Weston, I know that -- well-, did the Company, before
i-t fil-ed its case, contact Staff or the other way around?
A. The Company indicated to Staff that they were
pursuing an al-ternative to filing. They were going to they
planned to file a general rate case on May 31, 201,3, but they
had been looking at options or alternatives to doing that.
O. Did you inquire as to why other parties such as
CAPAI were not involved in those di-scussions?
A. We speak with the Company all the time on a
varJ-ety of issues and I think they raised this j-n the context
of another meeting on another issue, and we weren't reaIIy sure
what type of contact at that tlme originally that they had had
with other parties with regard to their the fact that they
were thinking about an al-ternative to a general- rate filing.
O. Did you hear Mr. Weston testify earlier that
these meetings or phone ca11s commenced sometime in January of
this year?
A. I heard his testimony in that regard.
O. Yes. Assuming that a party l-earns of what the
Company j-ntends to file a month or two before other parties
l-earn of that, doesn't it give those parties who had prior
knowledge additional- time to prepare their case and to prepare
for the first sett]ement conference conducted in that case?
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HEDRICK COURT REPORTING
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LOBB (X)
Staff
A. Well, the Company never made any indication of
when they wou1d make the f iling or whether they woul-d at all.
I think my impression at the time was the Company was just
bouncing thei-r idea off the Staff as to whether that's
something that the Staff woufd think would be possible at al-I.
So we didn't start analyzlng or assessing or looking at any
particular aspect of the issues the Company was looking at at
that time; we didn't start that until they actually made a
filing
O. Okay. If you need a reference, again, this i-s
your rebuttal-, page L, l-ine 25, and then it spil1s over onto
page 2, but it refers to your statement that Staff is willing
to work with CAPAI to eval-uate l-ow j-ncome rate design issues
and to recommend adjustments possibly that might benefit
l-ow-income customers. Is that true?
A. Sure. Yeah.
0.
you tell- us
A.
Could you explain what you mean by this or coul-d
how this process would take place?
Wel-l-, w€ did not have the information in this
particular case with regard to what the Company -- what CAPAI
had actually asked the Company, it wasn't part of our case
fil-e, but we did have informatlon 1n the Avista case. And we
l-ooked at that i-nformation. It was with regard to the number
of 1ow-i-ncome customers that were above the average in
e1ectrical consumption al-l--el-ectric customers, if you
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HEDRICK COURT
P. O. BOX 518,
REPORTING
BOTSE, rD
LOBB (X)
Staff
will and the number of low-income customers that were dual-
fuel and bel-ow the average, and whether or not a rate design
might be better suited for a change in rate design might be
better suited. We came to no conclusions but we looked at that
close1y, and we had a lot of Staff on the Avista case and we
worked with CAPAI in that particular case to eva1uate what we
might do. But I don't think there was any concfusions drawn as
to what type of rate design would benefit one group of
l-ow-j-ncome customers and not negatively impact the other group
of l-ow-income customers.
O. Did you draw any concl-usj-ons as to whether
low-income customers were relatively high or 1ow users or
average compared to their nonlow-income residential
counterparts ?
A. Well, Ry understanding is that there was disputes
as to how or at l-east not necessarily fuII agreement as to how
the l-ow-income customers were tal-Iied. Applications for LIHEAP
were used in some cases to determi-ne what customers are low
income because the companj-es don't generally have l-ow j-ncome
information for their customers. And the Avlsta data showed
that 60 percent of l-ow-income customers were above the average
or used were all-electric, and 40 percent of low-income
customers were be1ow the average or dual- fuel.
So what that says is you could maybe, if you
increased customer charges, you could benefit 60 percent of the
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HEDRICK COURT
P. O. BOX 578,
REPORT]NG
BOISE, ID
LOBB (X)
Staff
customers, perhaps, depending upon where they were and what
usage level-s they were at. And 40 percent of the customers
would be negatively impacted -- these are low-income
customers -- would be negatively impacted by an increase in
customer charges. And that was in the context of the Avista
case. And so it was unclear whether we wanted to do that.
Historically, CAPAI and the Commission have been
in agreement that we don't increase customer charges, w€ keep
those as l-ow as possj-bIe, we l-et customers affect their bill- by
reducing their consumption. Certainly, l-ow-income
weatherization is targeted for all--el-ectric homes, and we hope
that l-ow-income customers can take advantage of that and reduce
their consumption in that wdy, so
0. Is it possible that the mutual- agreement to keep
the monthly customer charge low mlght have been based on an
erroneous assumption, which is that l-ow-income customers are
lower usersr oD average?
A.Wel-I, there's a
the low-income customer oL,
that is to send the send a
conservation. f mean, that's
parties have l-ooked for is to
an energy charge a l-ittl-e bit
lot of reasons I thi-nk to keep
the customer charge Iow, and
prlce signal for energy
always been something that the
send that price sj-gnal by keeping
higher so that customers conserve
energy. There's an economic price sj-gnal. Customers can
affect their bill by reducing their consumptlon and if and
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HEDRICK COURT REPORTING
P. O. BOX 518, BOTSE, rD
LOBB (x)
Staff
reducing their bill by reducing their consumption.
Al-so, there's a lot of fixed-income customers
that use a sma11 amount of energy that can't afford to pay
higher customer charges.
So al-l- of these for all of these reasons, the
Staff has supported and I thought CAPAI has and has indicated
that in quite a few cases in the past that thj-s is a reasonable
goa1.
O. That, I'm sorry, what is?
A. To keep customer charges low.
O. And hasn't CAPAI articulated on numerous
occasions, including in this case, that it feel-s that it's
operating somewhat in the dark, and that it needs more
informatj-on to test its assumptions incl-uding whether it rea11y
is in the best interest of l-ow-income customers to keep the
customer monthly charge l-ow?
A. And I think that's something we shoul-d
investigate.
Now, in the 11-01 case, Avista provided data that
was almost identical to the i-nformation that was provided in
the more recent rate case, I think the 72-01- case. I don't
know what CAPAI did with that information.
Certaj-n1y, you wanted it in this particular case,
but I think in this particular case we thought it was much more
problematic to change the rate structure given the very limited
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nature of the i-ncrease overal-I.f mean, if you change rate
structure, what is a very l-imited increase for everybody
suddenly becomes a very large j-ncrease for one group of
customers while you might have a negative increase for others.
So we didn't believe that it was necessarily appropriate to
look at rate design changes in the context of this case.
But we have had opportunities over since 20ll
to look at where l-ow-income customers fal1 in the consumption
range and whether or not it was appropriate to change rate
design, but no proposal has been made by CAPAI for Avj-sta in
terms of rate design, not in the 12 the dash-12 case.
O. Do you know whether CAPAI has the same type of
i-nformation that it's obtained from Avista for Idaho Power?
A. I don't know.
O. Would you agree with me that CAPAI is stil-l-
attempting to obtain this type of information?
A. I didn't know that. f assumed that that was
perhaps the case, and certai-n1y in my testimony I j-ndicated
that the Staff wou1d help CAPAI obtain that information from
Tdaho Power as well-.
O. Do you agree it would be helpful i-n analyzing and
answering some of these questi-ons that have been raised this
morning?
A. I think it would be useful- to see where
Iow-income customers are and whether there's any benefit to
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Staff
rate structure change.
O. On page 3, lines B through 19, of your rebuttal,
you challenge some statements made by Ms. Zamora regarding the
amount of time CAPAI has to conduct discovery in these cases,
in rate cases, ds of late. You calculate an average discovery
period of 3.6 months. Could you just briefly explai-n to me how
you made that cal-culation?
A. It was made with respect to when the Companies
made their application to either when the testimony was fil-ed
or when the stipulation was filed in each of the general rate
CASES.
O. I'm sorry, what?
A. In each of the general rate cases during the
period.
O. And in making this calculation, did you take into
consideration the lag time between the date that an application
is fil-ed and the date a notice of appJ-ication is issued?
A. No, everything was the same whether it was a
fully-litigated case or a settl-ed case, the basis for
comparison was the same. So f didn't subtract that for
fulIy-li-tigated cases, and f didn't subtract that 1ag period
between application and i-ntervention deadline for any of the
cases.
O. But there generalJ-y is some degree of 1ag between
the filing and the notice of application?
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A. There can be up to two weeks. Usually an
lntervention period is about two weeks Iong.
O. And doesn't that shorten the discovery period
that you calcul-ated?
A. For aII cases, whether they're litigated or not.
O. Yes, okay. There was some discussion in your
rebuttal, I believe the page reference is page 3,lines 4, and
continui-ng on to page 4 -- excuse me.
Oh, strike that, please.
You discussed in your rebuttal testj-mony that it
isn't true that Staff always settles j-ts cases prior to the
prefiled dead.l-ine. Is that right? Or do I misunderstand you?
A. We have not always settl-ed cases prior to the
prefile.
O. What about since and including the year 20ll?
A. Let's see. We've had four cases. A11 of those
cases have been settl-ed prior to prefile.
O. There is nothing prohibiting the parties from
settling a case after they have prefiled their direct testimony
or their direct cases, is there?
A. No, and we have done that.
O. Okay. And how many of the four rate cases were
settled sj-nce 20LL? Did I hear you say all of them?
A. A11 of them.
O. Okay. And on page 4 of your rebuttal, if I
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understood you correctly, you seemed to be suggesting that
there is some advantage for ratepayers to settle a case prior
to prefile. Is that a fair statement?
A. Yeahr ds I indicated in my testimony, there can
be an advantage to negotiating prior to pref11e. Sometimes
your case can be stronger in negotiations than it actually
turns out to be when you prefile your direct testj-mony. So we
have tried to take advantage of that to make the best deal- we
can.
O. And, in factr ofl page 4, l-ines 9 through LL, you
state, and I quote, In other words, the parties can often
present a better case in settlement negotiations that can
actually be defended in prefil-ed direct testimony. End quote.
Right?
A. Absolutely.
a. Aren't you maklng an assumption, and that is that
if you go to hearing, you'11 fair worse than if you settle?
A. We always have to make that judgment in every
single case. We l-ook at the facts of every single case. We've
done a l-ot of cases. We've litigated quite a few cases as
well-; we've gone to hearing and we've litigated those.
And I don't think the Staff is afone in that
position. I think other parties that agree that settlement is
reasonabl-e and settlement is reasonable before prefile is an
appropriate consideration, and f don't think there is any
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disagreement that j-t's possible to make a better deal- in
negotiations than you can achieve through litigation.
And we have been through litigation, we know what
the issues are, it's not the fi-rst time we've addressed them.
We have a fairly good idea of what our chances are, and the
fact that the Company is going to file rebuttal to our direct
case, and it may be more difflcult to achieve an outcome that's
superior to a negotiated settlement.
O. But it might not as wel-l-?
A. Sure. You take your chance.
O. Yeah. And at some point, don't you think there
j-s val-ue in just finally litigating one of these cases?
A. Absolutely, and we have done that. In every
single case, w€ consj-der that, whether there is value in fuIIy
litigating this case, even though we bel-ieve we might be abl-e
to get a better deal through a negotiation. So itrs a
consideration i-n every single case.
O. Al-1 right. Just as a side note because it just
occurred to me, would information that gave the Commissj-on an
idea of whether l-ow-income users on average are higher or l-ower
than their residential- counterparts might al-so be pertinent to
low-j-ncome weatherization funding?
A.
o.
I'm sorry, could you repeat that question?
Sure. Okay, let me state it a different way:
If, in fact, 1ow-income customers are higher
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users, oD average, than other residential customers, might the
reason for that be that they l-ive in uninsulated or poorly
insul-ated housing stock and simply donrt have the resources to
make any changes to that housing stock, maybe they don't own,
maybe they just don't have the money to buy the weatherizatj-on?
A. I think there's al-I manner of reasons why that
they may be living in that stock. It may be rural-. They may
not be subject I mean, they may be al-1-el-ectric and fairly
efficient.
The fact is tiered rate structures and energy
charges impact more significantly the al-l--e.l-ectric customer
than a dual--fuel gas customer, 9ds space heat.
So, cIear1y, living in mobile homes or other poor
housing stock cause el-ectrical consumption to i-ncrease.
O. And those are the customers that cou1d be hardest
hit if we keep the monthly customer charge too l-ow. fsn't that
right ?
A. Any customer that's all-electric and lives in an
inefficient home is going to be impacted that way.
MR. PURDY: Mr. Chairman, if you bear with me, I
think I'm paring down my cross here.
O. BY MR. PURDY: There was quite a bit made of the
nature of CAPAI's di-scovery and the timing thereof in this
case. Woul-d you agree with me that it was generally -- wlthout
getting into confidential- settlement information that it was
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Staff
generally agreed that this case woul-d be hand1ed in an informal-
basis or manner, and that inc1uded the handling of discovery?
Do you recall- that?
A. That was never my understanding. I mean, there
might have been discussions among CAPAI and the UtiJ-ity. But
from the Staff point of vJ-ew, to the extent we had production
requests, w€ were going to file them and set response periods.
And I think the Irrigation Pumpers Association actually did
file discovery that is part of the case fil-e.
So it was never my understanding that everythlng
would be handled informalJ-y. It was a full-bIown case. That's
why we suggested to the Company that they open a case so that
it could be handled and al-l- parties coul-d have an opportunity
to ask questions and get them answered.
O. You testified on page 7, fines 3 through 4, of
your rebuttal- that, quote, to date, I have not seen the
discovery reguest, end quote, referring to CAPAI's discovery, I
assume the dj-scovery in dispute which was 6b. Is that actualJ-y
true ?
A. ft's not I have not seen it. ft's not part of
the case record, the case management file that we have.
O. Have you seen it in any other respect, sdy,
through an e-mail-?
A. I coul-d not find an e-mail- that had -- that was
sent to me or and f've tal-ked to other Staff and tried to
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HEDRICK COURT REPORTING
P. O. BOX 5'78, BOTSE, rD
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Staff
determine who might have recei-ved that with Staff, and I have
not been abl-e to identlfy that. So to the best of my
knowledge, we did not recej-ve it in e-mail form.
MR. PURDY: Mr. Chalrman, I woul-d l-ike to mark
and provide to the witness a cross exhibit if I might be
all-owed.
COMMISSIONER REDFORD: Fine.
MR. PURDY: And I frankly donrt know what our
exhibit number sequence is. We haven't otherwise filed
exhibits yet in thls case.
COMMISSfONER REDFORD: Why don't you go ahead and
j ust
COMMISSIONER SMITH: ft should be
COMMISSIONER REDFORD: -- give us the
MR. PRICE: It is 501.
COMMISSIONER SMITH: 501.
MR. PRICE: If that's the first.
MR. PURDY: 501. May I approach?
COMMISSIONER REDFORD: Yes.
MR. PURDY: Apologize: These are a littl-e rough.
My printer was running out of ink this morning.
COMMISSIONER REDEORD: We'11 take a break for
about seven or eight mi-nutes.
(Recess. )
(CAPAI Exhibit No. 501 was marked for
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HEDRICK COURT REPORT]NG
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LOBB (X)
Staff
identification. )
COMMISSIONER REDFORD: Okay, Iet's go back on the
record. Mr. Purdy, you had just issued or given to us
Exhibit 501.
MR. PURDY: Yes, I was. Thank you, Mr. Chair.
O. BY MR. PURDY: Mr. Lobb, Irve handed you what has
been marked, I believe, as CAPAI Exhibit 501, and this is
simply to see if it serves as a reminder to you whether you
ever saw the dlscovery submitted by CAPAI to Rocky Mountain,
specifically Discovery Request 6b, which is the one that was in
dispute?
A. Based on this, I received a an e-mai1 from
Ted Weston on .June 1l-th that had -- I guess it has al-l- of the
production request and responses included.
O. For 6b they are stapled to it, if you note.
A. Right. I don't know if that's al-J- the production
request responses or
O. No.
A. there's other questions that were asked.
Okay, I just didn't know.
O. Okay, that's fine. Thank you.
And, fina11y, with respect to dj-scovery, you've
indicated that you feel that CAPAI if I may paraphrase
sat on its rights and didnrt act tlmely enough with respect to
trying to obtain discovery responses from the Company through
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Staff
the summer months of this year. Is that a fair paraphrase?
A. f think so. It ultimately filed a motion to
compel, and that could have been done before the stip was even
filed.
O. Do you know anything about communications taking
place between CAPAI and Rocky Mountai-n that might have been
a that might have led CAPAI to the belief that the Company
coul-d stil-l- possibly respond?
A. No. A11 I know is that CAPAI refused to slgn
the stipulation because they didnrt get the information by
May 31st.
O. If you turn to page I of your rebuttal, lines 15
through l7 , you state that, quote, CAPAI's traditional- issue of
LIWA -- low-j-ncome weatherj-zation assistance funding was not
realJ-y addressed by CAPAI, end quote, and referring to this
case. You continue: The only issue raised by CAPAI was rate
design.
Just to be clear, isn't it true that with respect
to fow-j-ncome weatherization, there is effectively a hol-d --
whether it's temporary or not, we don't know but a hol-d for
the time being on any increases to low-income weatherization
funding?
A. Thatrs correct, generally.
O. Okay. That wou1d explai-n why CAPAI didn't raise
that issue in thls case, wouldn't it?
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HEDRICK COURT REPORTING
P. O. BOX 518, BOTSE, rD
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Staff
A. That could.
O. Yep. If you need a reference, itrs page B,
lines B through 10, but I think you'I1 know what f 'm tal-king
about. You've often stated that the best thing that Staff can
do for l-ow-income customers is to keep rates l-ow. Is that a
fair statement?
A. Yeah, 1ow-income customers and all customers.
A. And all- customers. That segues to my next
question:
That's to the benefit of all- customers, is it
not ?
A. What? Pardon me?
O. That's to the benefit of all- customers, not just
l-ow-income . Correct ?
A. Yes.
O. But might there in certain instances be things
that could be done for low-income customers that would be more
significant than keepi-ng rates Iow, such as increasing funding
for those customers who are high users because they have poor
housing, they are relatlvely priced and can't do anythlng about
ir?
A. And I think we have low-income weatherization
programs and LIHEAP programs for those sorts of customers.
Now, can you help those 1ow-income customers
whil-e negatively impacting other low-income customers? f'm not
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HEDRTCK COURT REPORTING
P. O. BOX 518, BOTSE, fD
LOBB (Com)
Staff
sure that that's a reasonable trade-off.
O. Is it your position that all low-income customers
who need weatherization have received or are receiving it?
A. No.
O. Okay. I am very close to done, if I could just
look at my notes here.
That's all I have. Thank you, Mr. Lobb.
MR. PURDY: Thank you, Mr. Chair.
COMMISSIONER REDFORD: Thank you.
Mr. Otto, have you any questions?
MR. OTTO: I have no questions.
COMMISSIONER REDEORD: Thank you. And everyone
el-se has had an opportunity to cross-examine.
Are there any questions by the Commissioners?
COMMISSIONER KJELLANDER: NO.
COMMISSIONER SMITH: NO.
COMMISSIONER REDFORD: I just have a couple
questJ-ons.
EXAM]NATION
BY COMMISSIONER REDFORD:
O. March 72 was the filing of the notice and
application, and I believe on or about the 25th CAPAI filed for
intervention. Is that your understanding?
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A. That would be the correct time frame, y€s.
O. After that, did CAPAI fu11y participate in al-l- of
the meetings and discussions?
A. I believe that they did, all of the settlement
meetings, y€s.
O. Okay. I have no further questions.
MR. PRICE: Coul-d I just have one question on
redirect?
COMMISSIONER REDFORD: Yes.
REDIRECT EXAMTNAT]ON
BY MR. PRICE:
O. I won't go over I think your testimony is
rather comprehensive, but I'd like to ask you there's been a
lot of talk about al-ternative procedures and expedited time
frames, and f'm just going to ask you to draw upon your vast
experJ-ence with the Commission. Do you believe that the
Commission Staff had an adequate amount of time and were abl-e
to devote the necessary resources towards eval-uating the
Company's aLternative rate plan in this case?
A. Absolutely. I think we didn't have any other
rate cases in-house. We put a Lot of Staff on this. And the
fact is, these are very l-imited issues, and we thought that it
was the closest thing to a nonfiling.
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HEDRICK COURT REPORT]NG
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Staff
You tal-k about alternatives to filing a general
rate case. Wellr we only l-ooked at reaIIy two al-ternatives:
One is don't fil-e at aII, that's the alternative; or this. And
we believed it was as cl-ose to a nonfil-ing as possible, and,
therefore, that the three months that we had before prefile
was orr before the settlement was filed was more than
suf f i-cient.
COMMISSIONER REDFORD: Thank you.
MR. PRICE: Thank you. I have nothing further.
COMMISSIONER REDEORD: Mr. Purdy, do you want
Exhibit No. 501- admitted?
MR. PURDY: Yes, please.
COMMISSIONER REDEORD: It will be admitted to the
record.
(CAPAI Exhibit No. 501 was admltted lnto
evidence. )
COMMISSIONER REDFORD: Okay, looks l-ike everybody
has either cross-examined or testifled except for Mr. Purdy,
and you may call your witness.
COMMISSIONER SMITH: You're excused.
(The witness l-eft the stand. )
MR. PURDY: Thank you, Mr. Chair. CAPAI calls
Ms. Christi-na Zamora.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD
ZAMORA (Di)
CAPAI
CHR]STINA ZAMORA,
produced as a witness at the instance of CAPAI, being first
duly sworn, was examined and testified as follows:
DIRECT EXAMINATION
BY MR. PURDY:
O. Ms. Zamora, would you please state and spe1I your
name for the record?
A. My name is Christina Zamora, C-H-R-I-S
COMMISSIONER REDEORD: You need to push the
button down.
THE WITNESS: My name j-s Christina Zamora,
C-H-R-T_S-T-I-N_A Z-A_M-O-R-A.
A. BY MR. PURDY: And l-ike Mr. Weston you are
somewhat soft-spoken, so if you could reaI1y just put that mike
right next to your mouth
A. Okay.
O. that would be helpfuI.
Thank you. And are you the same Christina Zamora
that has previously prefiled direct testimony in this case
consisting of 22 pages of text?
A. Yes.
A. And you attached an exhibit to that testimony,
whj-ch was the motion to compel f il-ed by CAPAI in this case.
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HEDRICK COURT REPORTING
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ZAMORA (Di)
CAPAT
Correct?
A. Yes.
O. But that's been subsequently stricken, just to be
c1ear.
Are there any corrections to your or additions to
your testimony that we need to take care of?
A. On page 2t, the question was omitted. The
question should read "Pl-ease summarize your testJ-mony."
O. Okay. So could you identify on page 27 where you
would place that question?
A. On line 2.
O. So it woul-d qo between the heading of Roman
numeraf V, Summary, and then the and then the following
sectj-on starting with "The manner in which"?
A. That's correct.
0. And so is this then missing a an rrA'r as wel-l-
as a 'rQ"? fn other words, there should be an rrA, precedi-ng
"The manner in which"?
A. Yes.
O. Okay. Aside from that, are there any other
corrections or additions to your testimony?
A. No. No.
MR. PURDY: I ask that the prefil-ed testimony of
Ms. Christina Zamora be spread upon the record as if read, and
tender her for cross.
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COMMISSIONER REDEORD: cranted.
(The fol-lowing prefiled direct testimony
of Ms. Zamora is spread upon the record. )
L25
ZAMORA (Di)
CAPAI
HEDRICK COURT REPORTING
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I.INTRODUCTION
Please state your name and business address.
My name is Christina Zamora. I am the Executive Director of the Community Action
Partnership Association of ldaho (CAPAI) headquartered at 5400 W. Franklin, Suite G,
Boise, Idaho, 83705. I am testifying on behalf of CAPAI.
Please describe CAPAI's organization and the functions it perfbrms relevant to its
involvement in this case.
CAPAI is an association of ldaho's six Community Action Agencies, the Community
Council of Idaho and the Canyon County Organization on Aging (CCOA),
Weatherization and Human Services, all dedicated to promoting self'-sufficiency through
removing the causes and conditions of poverty in Idaho's communities.
What are the Community Action Partnerships or "Agencies?"
Comrnunity Action Partnerships ("CAPs") are private, nonprotit organizations that fight
poverty. Each CAP has a designated service area. Combining all CAPS, every county in
Idaho is served. CAPs design their various programs to meet the unique needs of'
communities located within their respective service areas. Not every CAP provides all of
the fbllowing services, but all work with low-income people to promote and support
increased self-sufficiency. Progrants provided by CAPs include: employr.nerlt preparation
and dispatch, education assistance child care, emergency food, senior independence and
support, clothing, home weatherization, energy assistance, aftbrdable housing, health care
access, and much more.
II. SUMMARY
Q: Please summarize your testimony in this case?
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A:My testimony focuses on significant concerns that CAPAI has regarding the manner in
which this case has been processed, and the impact that the procedure employed has had
on the outcome embodied in the proposed settlement agreement and the ability of CAPAI
to fully and effectively participate in this case as a formal party.
Does CAPAI oppose the proposed settlernent stipulation pending before the Commission
in this case?
Ordinarily, the answer to that question would be much simpler. The fact is that, from a
purely technical and financial standpoint, it might well be that the proposed settlement is
in the best interests of all ratepayers, including low-income. This standpoint is very
limited, however, and might be more than offset by other considerations. The practical
aspect to the question and answer, however, is Iar more complex. It is CAPAI's position
that the procedure employed in this case is unlawful, detrimental to the public interest,
and might well lead to additional procedural transgressions of an equal or greater severity
as those included in this proceeding.
What is the basis of CAPAI's opposition to the procedure ernployed in this case?
There are numerous facts that form the basis for CAPAI's opposition. Because it had
reason to believe that this matter might proceed to hearing on procedural grounds, and
because those grounds are intertwined with CAPAI's Motion to Compel responses to its
discovery requests submitted to Rocky Mountain, CAPAI provicled a very detailed
discussion of its proceclural concerns, specifically related to this case, in the Brief in
Surpport of Motion to Compel, and related Affidavit of CAPAI's legal counsel, that were
submitted to the Commissiorr on Jr,rly 30, 201 3. In order to avoid repetition and avoid
engaging in an analysis in my testimony that cornes across rnore like an attorney's legal
brief, I adopt by rel'erence and incorporate in my testinlony the albrementioned Brief in
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Support of Motion to Compel brief and Affidavit, a true and correct copy of which
attached hercto as Exhibit "A."
Did you participate in the preparation of that briet'?
Yes I did. Though I obviously worked with legal counsel and do not purport to possess
the knowledge of an attorney, I was very involved in drafting, reviewing and editing the
brief and have thorough knowledge of what it contains.
III. GENERAL NATURE OF RATE CASE PROCEDURAL CHANGES
Putting aside CAPAI's concerns about the present case for the moment, does CAPAI
have overarching concerns regarding the general trend that the processing ofgeneral rate
cases has followed?
A: Yes. As this Commission is acutely aware, the frequency with which general rate cases
have been filed by Idaho's three largest electric public utilitiesl has increased remarkably
in recent years.
Please identify what concerns this recent trend causes CAPAI?
Thourgh I can only speak for CAPAI, I suspect that the one of the primary concerns of
every party involved in any rate case and the Commission itself is that increasingly
frequent general rate cases are stretching the parties resources to their limits and made a
full and thorough participation in these cases increasingly challenging. This is certainly
true for CAPAI whose resources are subject to uncertainty due to changes in f'ederal
funding levels which, in recent yeals, have decreased.
Q: What has been the eff'ect of this trend on CAPAI?
A: Without question, CAPAI has been stretchecl lar beyond its financial, technical and
practical abilities to nreaningfully participate in general rate cases. CAPAI is always
' Idaho Power, Avista, and Rocky Mountain Power.
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keenly aware and appreciative of the generosity shown by the Commission with respect
to its awards of intervenor funding over the years, but the amount of money available by
law as well as the legal requirement that expenses be funded by intervenors up-front,
have placed CAPAI's ability to continue its representation of the low-income customers
of Idaho's regulated utilities at risk. This case alone, due to the use of resources devoted
to compelling Rocky Mountain to respond to discovery in good faith and in accordance
with the law, has nearly exhausted CAPAI's resources not just fbr this case but for this
financial year and there are likely to other cases of interest to CAPAI yet this year, such
as Idaho Power's general rate case.
Aside from the financial impact of nearly annual general rate cases, have there been other
developments that concern CAPAI?
Yes. As the frequency of rate cases has increased, CAPAI has noticed a very obvious
and significant transfbrmation in the manner in which these rate cases are being handled
procedurally.
Are you suggesting that the Commission itself has adopted a dit'ferent general rate case
procedure than historically employed?
No. To my knowledge, the law regarding the manner in which general rate cases are
processed has not been changed and the Comnrission has not formally adopted any policy
to implement sLrch changes. I am referring to the manner in which the parties to general
rate cases, including the utility in question, are processing rate cases, specifically in an
abbreviated tashion and at an expedited pace.
Q: Please explain your belief that rate cases are being processed differently as
ti'equrency increases.
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A:Though my experience in PUC matters is still somewhat limited, it is my understanding
Staff typically schedules settlement negotiations in every rate case relatively soon after
the case is filed and does so without ever contacting CAPAI to ascertain whether it is
prepared to discuss settlement ancl, if so, what dates are available to CAPAI. CAPAI
only Iearns of proposed settlement afier receiving notice fiom Staff and the date and time
have been set and are generally not subject to rescheduling.
How does the foregoing procedure difl'er fiom what has historically been the case?
Though I have not been intimately involved in rate case procedure long enough to have a
historical perspective, a simple review of recent rate cases on the Commission's website
reveals several things. First, settlement discussions have not always taken place in
general rate cases and when they have, it has typically been long enough after the initial
filing of the utility's application and the issuance of the initial Notices and associated
Order by the Comntission to allow all parties the opportunity to thoroughly examine the
filing, engage in formal discovery and otherwise communicate with the Company
regarding numerous matters relevant to the filing and, in the case of Staft even conduct
fairly thorough audits of the Company's books suf ficient to formulate a position on the
many issues inherent in any rate case, particularly those involving revenue requirement,
rate spread and rate design.
Q: How does this cornpare with your understanding of the settlement of rate cases in recent
years?
A: My understanding is that not only have there been settlement negotiertions in every
electric rate case since 201I involving all three majorelectric utilities, br.rt that Staff has
settled every one ol'those cases. I do not know the last tinre that Staff chclse to litigate an
electric rate case.
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Q: ls there anything inherently wrong with Statf agreeing to most if not all rate case
settlements?
In any given case, no. But for this to become what feels like a virtual certainty seems to
have crossed an important line.
Do you know why Staff has settled all such rate cases in the past 2-3 years?
Obviously, I do not know all of Stafl's rationale for its choices other than what is stated in
testimony supporting a settlement stipulation. I find it difficult not to believe, however,
that one reason settlement has beconre a more common occurrence is that the sheer
magnitude of rate cases typically pending before this Commission have diminished
StatT's ability to apply the norrnal level of scrutiny an analysis to those cases it settles as
it historically has. [n sush a scenario, settlement, if it seems to be in the best intercsts of
ratepayers in general, becomes more appealing.
How would your describe the typical rate case procedure since 201l?
First, it seems that by the time a utility actually files its rate case, it has already engaged
in meetings and/or other communications with Staff and larger customer class
representatives. This is certainly wlrat occurred in this case. While this might enable
Staff to be better prepared tbr an expedited processing of a rate case, intervenors such as
CAPAI do not have the courtesy of having possession of such information and the time tc
analyze it prior to the filing. What typically happens next is a very abbreviated course of
discovery between Staff, the utility involved, and possibly larger industrial special
contract customers and the scheduling of the f irst of what will likely be 2-3 settlement
conferences. Although the case is still relatively yoLurg, Staff and larger, industrial
custon'ters are typically prepared at the time of the l'ir:st settlement conference to f'ully
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resolve the case. As I've already stated, based on rate cases since 2011, the final
is that Staff settles the case, often well before the direct testimony deadline.
How would you describe CAPAI's preparedness by the time of the first settlement
conference?
Cenerally, CAPAI has not even had the opportunity to engage in discovery and is still far
from identitying areas of concern and issues, let alone fbrmulated a position on those
issues.
Why is this?
There are numerous reasons including the fact that before it can even intervene in a case
before the Conlmission, CAPAI must obtain the necessary approval I'rom its Board of
Directors. Because CAPAI is governmentally funded and because there can be strict
limitations on how CAPAI utilizes its funds, the assessment of whether it is financially
feasible or e ven permissible for CAPAI to intervene in a given case can be sornewhat
protracted. Once the process of determining whethe r CAPAI is flnancially capable of
intervening in a case is complete and assuming that CAPAI decides to intervene, it then
must rely on its legal counsel and the limited time of its Staff to quickly come up to
on the issues raised by the rate case filing. Occasionally, but not always, CAPAI has an
employee who can participate in the case, bLrt that employee's other obligations generally
command the vast majority of their time. CAPAI rarcly has the financial ability to retain
an expert witness. By the time that the first settlement conf'erence is conducted in genera
rate cases, CAPAI has usually had little to no opportunity to conduct discovery, or has
submitted requests which have not yet been responded to. Thus, CAPAI is still engaged
in the process of issue identification and a risk/rewarcl analysis of pursuing any given
ob.iective. Sr"rffice it to sny, CAPAI is very far fronr being able to negotiate er settlement
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of CAPAI's issues and positions that haven't even been identified or created at the
that Staff schedules the first settlement negotiations.
Doesn't the 60 day Notice of Intent period enable CAPAI to perform the requisite tasks
you've just outlined'?
Only to an extent. A full assessment of the viability of intervention cannot be conducted
until CAPAI has seen the rate case Application to determine whether the interests of low-
income customers justify intervention in a rate case.
Without revealing anything of substance that occurs during confidential settlement
discussions, can you describe the general tone of settlement negotiations?
The general tone in all settlement negotiations is that the utility in question seems highly
motivated to settle the case in its entirety as qurickly as possible and with all parties
signatory to the settlement stipulation that results from the negotiations. The quid pro
quofor this is often that the utility will nrake certain concessions so long as the parties
wrtrp the settlement up and do so very quickly.
Q: ls there anything inherently wrong with a rapid resolution of differences between
parties to a rate case?
A: In a vacuum, no. But that assumes that all parties have had ample opportunity to fully
assess their respective issues and positions and made a decision as to whether settlement
as proposed is in their best intelests. It also assumes that all parties, including CAPAI,
have been given rcasonable responses to discovery, kept in the loop on case
developments, and had the attention of Cornmission Staff that other parties have come to
expect.
Q: If CAPAI is unprepared fbr settlement negotiations as you describe,
place during the first cliscussions?
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A: CAPAI does its best to identify the major issues it can identify and to bring those issues
to the attention of the other parties.
Q: Have there been problems in this regard?
A; Absolutely. In numerous cases, CAPAI has raised issues of interest or concern during
settlement only to be instructed by Statf and/or the utility that CAPAI's issues are of no
relevance to them and will not even be mentioned in the settlement stipulation nor
addressed during the settlement. When this occurs, CAPAI can either simply stand up
and walk out on the negotiations, or insist on stating its issues and positions on those
issues to a typically mute crowd. This is not to say that all other parties to all rate cases
do not occasionally support CAPAI and its positions. But it is fair to say that if the
utility, StafTand the utility's most heavily financed custorner groups are all in agrcement,
nottring ot value will Iikely be accomplished during settlement. This marginalization is
very effective at isolating and shutting oLrt a party such as CAPAI, but cloes not constitute
a good faith attempt to address issues of concern to all parties. Regardless of whether
this is a violation of any rule or law, it seems counter-produrctive to the concept of
settlement negotiations.
Q: Are you familiar with the three general rate cases that took place in 201I involving Idaho
Power, Avista and Rocky Mountain?
A: To a linrited extent, yes.
Q: What is your knowleclge of those cases?
A: My responsibilities in 20ll inclurded workirrg on the various low-income weatherization
programs so I was well aware that funding and program design issues were at stake
during the 201 I cases. Although the Avista case settled with CAPAI.ioining in that
settlement, CAPAI was the only party to not.join in the other two cases which ultimately
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went to hearing on the low-incclme issues. In addition, CAPAI also raised an issue of
importance whether the authorized rates of return of Idaho Power and Rocky Mountain
might be excessive given increasing cost recovery ancl other mechanisms that stabilize a
utility's earnings and make them more predictable.
What was the general outcome of those cases?
The Conrmission took no action regarding CAPAI's position on rate of return and, in
terms of low-income weatherization funding and program design, essentially segregated
that issue out and spun it off into a protracted workshop process in Case No. GNR-E-12-
0l (the "low-income workshop case"). The Commission otherwise ruled against CAPAI
ir.r the 201 I cases.
What was the result of the low-income workshop case?
On April 12,2013, the Commission issued Order No. 32788 effectively freezing low-
incomc weatherization tunding levels for several years. I'he future existence of those
prcgranls remains in doubt.
Q: In your mind, did the 201 I and workshop case rulings render CAPAI's involvement in
PUC cases pointless?
A: Obviously not, as evidenced by CAPAI's involvement in this case.
Q: What are the issues or concerns that maintain the importance to CAPAI of participation
in PUC proceedings?
A: First, it should not be overlooked that the residential class of every electric utility is its
largest in terms of customers ancl revenues generated. CAPAI is the only low-income
residential advocate and while CAPAI cloes not claim to represent the interests of the
entire rrsidential class, many of those customers are low-income or in danger o1'
becoming so. Furthermore, it isn't unusual lor low-income interests to be relevant to and
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simpatico with residential issues on the whole. Helping low-income customers be more
tirnely in paying their bills, reducing their arrearages, or keeping them connected to the
system as customers has benefits to the residential class and all ratepayers in general.
Is low-income weatherization the only issue raised by CAPAI over the past decade or
longer?
Low-income weatherization is not the only issue CAPAI has brought to the
Commission's attention over the years. One example of an area of issues still impomant
to CAPAI and relevant to all residential customers in PUC proceedings is rate design.
Beginning with Avista's2Ol2 general rate case (Case No. AVU-E-12-08), CAPAI
adopted a new strategy to its long-standing attempt to obtain low-income consumption
data and then use that data to, among other things, deterntine the impact that alternative
residential rate designs have on low-income customers. Historically, there was no actual
low-income consurnption datrt available to CAPAI to utilize fbr purposes such as rate
design. The reasons for this are varied but typically were based on the utilities' insistence
tlrat they maintain individual customer privacy. During Avista's 2012 rate case, CAPAI
proposed that Avista gather low-income consumption data based on what CAPAI calls a
"low-inconre proxy group" which is sirnply a list of those customers receiving either
LIHEAP or low-income weatherization benetits. It is essential, of course, that customers
who receive both lbrrn of benefits are counted only once tbr inclusion into the proxy
group.
Q: What was Avista's reaction to this proposal?
A: Avista was quite willing to gather low-income consumption data by sinrply identifying
those custonrers who qualily tbr the proxy group, eliminate any dcluble-counting, ancl
then collect their consurnption data using their physical adclrcsses without ever revealing
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their personal information. Upon obtaining this data, CAPAI and Avista worked together
in a collaborative and expeditious fashion to perform "model runs" which is simply a
term that CAPAI used to describe the process of establishing hypothetical rate designs
and then determine how irnplementation of those rate designs would impact the proxy
group compared to the existing residential rate design.
What, if anything, did CAPAI learn tiom this process?
CAPAI learned a great deal, including the fact that, at least with respect to Avista, low-
income customels often consume mole energy than their non-low-income residential
counterparts, in some cases substantially more. Based on this knowledge, CAPAI
challenged historical pl'esumptiorts and reconsidered the inrpact that rate design changes
would have on low-income ratepayers. For example, if low-income customers have
higher consumption rates year-around, then increasing the utility's basic nronthly
customer charge as typically requrested by utilities could actually lower the majority of
low-income custonlers' monthly bills. Similarly, altering tiered residential rates by
changing the consumption levels that demarcate the diff'erent tiers, or by changing the
commodity pricing for existing tiers, or finally, by adding a third tier, could have positive
or negative consequences fbr low-income cLlstomers that rnight not have been assumed or
expected. CAPAI believes that the acquisition of this information is of value not only to
CAPAI and low-income customers, but to the utility, other residential customers, Staff,
and the Commission.
Q: Does the fact that the outcome of Avista's 2012 general rate case was productive and
beneficial enough for CAPAI to support that settlement in any way diminish the general
procedural concerns you have already discussed?
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A:Not at all. To a certain extent, the Avista case followed the same fast-track I've already
described. In fact, CAPAI joined in the settlement weeks after it was execLlted by the
other parties bec:luse CAPAI required sufficient time to nrake a thorough analysis of the
issues it deemed important and to cletermine whether the settlement was in the best
interests of the low-income. What saved that case frorn being unfair to CAPAI and
convinced CAPAI to join in the settlement was simply the willingness of Avista to work
cooperatively, productively and in a very prompt fashion to obtain the information
CAPAI sought. Avista made its technical experts and employees available not just to
respond to questions and provide data, but to work toward the common goal of simply
better understanding the truth.
IV. PROCEDURAL CONCBRNS ABOUT THE PENDING CASE.
Would you please summarize your concerns regarding the procedure employed in the
pending case?
First, this case is a very striking example of what the consequences of deviation fiom
established rate case policy citn be, especially whcn done on an ad hoc basis. In an
attempt to avoid rc-inventing the wheel, I note that all of CAPAI's concerns regarding the
procedure followed in this proceeding are thoroughly articulated in CAPAI's Brief in
Support of Motion to Compel responses to CAPAI's discovery propounded to Rocky
Mountain. A true and correct copy of that Brief is attached hereto as Exhibit "A" and is
incorporated herein by ref'erence. Specifically, pages 2-12 of the brief outline every
procedural abnormality in this case to which CAPAI objects. I am incorporating
CAPAI's brief by reference in order to avoid re-inventing the wheel and turning what
should be testirnony into a legal brief.
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Did you have any involvement in drafting CAPAI's Brief in Support of Motion to
Compel?
I was very involved and worked with CAPAI's legal counsel to construct the brief and am
very familiar with its contents.
Without repeating everything contained in CAPAI's brief, can you generally outline the
procedural concerns you have regarding this case?
The procedural abnormalities of this case began before it was even filed. As noted in the
brief, Rocky Mountain conducted meetings, either in person or via other forms of
communication, with Staff and the Company's larger, non-residential customer groups.
CAPAI was not invited or included in these conversations and was completely unaware
that they had taken place until after the Company's tiling. While there is no transcript of
these communications, they obviously advanced the knowledge of those involved
regarding what to expect in terms of the filing and better prepare f<rr settlement
negotiations. Fur-thermore, the Company acknowledges that it was attempting to reach a
resolution on an alternative to filing a general rate case. Had these communications taken
place following the filing, they certainly wourld have been conducted as confidential
settlement negotiations. Because they occurred prior to filing, it is unclear what they are.
Please describe the procedural concerns you have regarding the tiling.
The filing itself is contusing, self-contradictory, and somewhat indecipherable. lt
consists of two documents including a 60 day Notice of Intent to file a general rate case
and an Application to "initiate discussions with interested parties on alternative rate plan
proposals.", The Notice of Intent, by itself', seems to comply with the Commission's
procedural rules and is otherwise typical. My understanding is that the typical procedure
in genererl rate cases is that the 60 day Notice of Intent is tiled tbllowed by the filing of an
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Application for a rate incrcase at the end of that 60 day period. I further understand that
this Application must contain certain information and be properly captioned fbr what it is
The only application that Rocky Mountain filed in this case seems to be more in the
nature of an investigative proceeding to explore rate case alternatives that could apply to
any utility, not just Rocky Mountain and any luture case.
What are your concerns regarding the Application filed with the Notice of Intent and
what it led to in this case'?
Though my experience in this area is still limited, it seems that, through the filing of the
Application given an unusual title and not in confbrmity with rules applicable to rate case
applications, Rocky Mountain, in reality, used this as a means of end-running existing
rules regarding rate cases and negotiating a rate case prematurely and in violation of law.
As such, the Application Rocky Mountain did file could be characterized as a rate case
application in disguise.
The term "rate plan" has been used in this case to describe Rocky Mountain's Application
and the outcome of the case it initiated. Does this have any significance to you?
No. Though I'm not yet well-versed in proper rate case procedure, it is a general truth
that labels are always trumped by substance. Regardless of how the Company worded or
labeled its Application, all that matters is the surbstance of the filing and the outcome of
the case. The proposed settlement stipulation results in a rate incrcase. Calling it a "rate
plan" or an "alternative" procedure for increasing rates does not change the fact that its
resulted in an increase to the Conrpany's rates.
How would you respond to a contention that the "rate plan" proposed in this case is not a
general rate increase subject to the otherwise applicable rules and laws'?
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A: My response is that avoiding applicable law by use of labels is a dangerous path to go
down and that will likely lead to a de fttcto changing of or disregard for the law by use of
labeling and procedural gamesmanship. Adherence to procedure that was legally
established is of great importance. Once a utility is allowed to alter that procedure
without going through the proper legal process throws the door open wide for further and
possibly more serious deviations I'rom established Iaw.
Q: Without asking you to give a legal opinion, what is your understanding as to proper rate
case procedure?
A: A thorough answer to that question is set fbrth in CAPAI's brief. I am under the beliel'
that once a procedure has been established, whether through legislation or the
administrative rulemaking process, it is the law and must be adhered to unless and until
changed according to the process just outlined. Regardless of how this case was labeled
or described in the Application, the only salient fact is that it resulted in a rate increase.
As noted in CAPAI's brief and stated in paragraph 7 of the settlement stipulation itself,
the outcome of-this case, if the settlement stipulation is approved, would be: a "base
revenue rcquirement fbr all schedurles will be incrcased."
Q: Does the Commission's Notice of Application and Order No. 32761 provide any insight
into the nzrtnre of the Application in this case?
A: Yes. Page 2 of the Commission's Notice of Application states: "the Commission finds it
reasonable to initiate a case so that parties can engage in settlement discussions in an
effbrt to avoid ornarrow issues in a general rate case." lt is significant that the
Commission's Notice speaks nrore in generic than case-specific terms referring to "a"
general rate case as opposed to the specific case at hand. Furthermore, the Comrnission's
statement of the scope ol'the case initiated by the Application is to "avoid or narrow
DIRECT TESTIMONY OF CHRISTINA ZAMORA LAI l7
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issues," not to avoid existing law by allowing the parties in a case opened for the purpose
of narrowing or avoiding issues to actLrally settle a general rate case, especially when the
60 day Notice of Intent had not even expired and a formal rate case application had not
been filed and the Company was prohibited by a previons rate case settlement from even
filing for a rate increase until May 31, 2013, as stated in CAPAI's brief.
Q: What are your specific objections Lo the fact that the settlement stipulation proposes a rat€
increase?
A: As stated in the brief and earlier in my testimony, CAPAI's objections to the requested
rate increase include: l) the fact that discussions regarding a possible settlement of Rocky
Mountain's rate proposal and the procedurc by which that settlement nright be arrived zrt
began between select parties prior to the case even being filed and ending in a stipulation
agreed to in principle in May and fbrmalized in writing in early June,20l3;2) the parties
did not wait the required 60 day period before a rate case was even considered, and; 3)
the rate increase stemming from an application filed on March 1,2013 violates the
Company's agreement in a prior case to not file for a rate increase prior to May 3lr.,20L3.
Q: Is there anything else that you find trourbling about the outcome of this proceeding?
A: Yes. It seems quite peculiar that the parties do not appear to have discussed
"alternatives" to a general rate case as the Notice of Application, Order No.32761, and
the Application itself stated was the intent ernd purpose ol'the case. The stipulation
contains no discussion of alternatives to the normal rate case process and there are
certainly no alternatives identified, let alone analyzed in the stipulation. The case was
treated f'rom the outset to the settlement stipulation exclusively as a rate case, nothing
more nor less.
DIRECT TESTIMONY OF CHRISTINA ZAMORA I42 18
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Q:
A:
Q:
A:
Regardless of CAPAI's concerns about the procedure employed in this case, and without
divulging anything of substance of a conl'idential nature, did CAPAI participate in the
settlement negotiations?
CAPAI did participate with the hope of better understanding what was and remains a
perplexing filing and procedure and to urge the parties to comply with all applicable
laws. CAPAI also desired to continue its publicly-stated goal of obtaining from Rocky
Mountain the same manner of low-income consumption data and impacts of alternative
residential rate designs that it had obtained from Avister, though the data would obviously
be different and so might the conclusions to be drawn from that data. CAPAI has, in past
years. advocated for residential rate design changes fbr Rocky Mountain and t-elt
particurlarly compelled to determine whether the assumptions built into its proposed
changes werc supported by fact.
Did CAPAI seck to obtain the data and rate design alternatives you've described from
Rocky Mountain?
Yes, though not without considerable strife and expense and with only partial success.
Unlike Avista, Rocky Mountain simply ref'used to provide CAPAI the most critical data i
sought through discovery requests unless and until CAPAI joined in the settlement
stipulation. All of this is set forth in the brief and affidavit. To this day, it seems
perplexing that Rocky Mountain ref'used to respond to CAPAI's discovery, particularly
when CAPAI had repeatedly pointed out that the data and conclusions drawn from that
data might well bring CAPAI and the Cornpany together on certain issues.
What was Staffs position or role in terms of the discovery dispute?
Staff basically tclok no position in the matter.
Did Rocky Mountain ultirnately respond in full to CAPAI's discovery requests'?
Q:
A:
Q:
DIRECT TESTIMONY OF CHRISTINA ZAMORA L43 19
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A:No. To this date, Rocky Mountain still has not provided the entirety of the infbrmation
sought by CAPAI. Unlike the data responses provided by Avista, Rocky Mountain has
simply provided an Excel spreadsheet that is largely undecipherable. CAPAI is in the
process of attempting to make any sense out of what little information the Cornpany has
provided and determine the impacts of various rate design alternatives.
To the extent Rocky Mountain provide anything in response to CAPAI discovery request
No. 6, when was that information provided?
It was not provided until August 12,2013,less than four days prior to the original
testimony prefile deadline (the Comnrission extended the deadline by one week for
CAPAI). The discovery request was submitted to Rocky Mountain, however, in April,
2013. Despite countless assurances of numerous form, the Company, after four months,
still has not fully responded to CAPAI's discovery. Furtherntore, Rocky Mourntain
refused to respond to CAPAI's cliscovery requests unless and until CAPAI withdrew its
Motion to Compel, befbre even seeing the responses, and unless and urntilCAPAI joined
in the settlement stipulation, thereby waiving its rights to oppose any aspect of the
proposed rate case settlement.
Does the fact that Rocky Mountain ultimately responded, at least in part, to CAPAI's
discovery requests diminish the concerns that CAPAI has in this case?
No. CAPAI utilized limited resources sirnply trying to convince Rocky Mountain to
respond to the discovery requests. Had the Company done so when it promised, which
was April through May, CAPAI could have utilized its lin-rited resoulces more ef'fectively
and been prepared to take a position on rate design one way or another. This loss cannot
lre recovered.
Q:
A:
Q:
A:
DIRECT TESTIMONY OF CHRISTINA ZAMORA L44
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V. ST.]MMARY
The manner in which this case was processed, if permitted to stand, will ahnost
certainly lead to even more egregious violations and de facto changes in general rate
case procedure. To the best of CAPAI's knowledge, none of the numerous states in
which PacifiCorp operates has condoned the procedure for obtaining a rate increase
employed in this case. It would set a bad precedent and send the wrong signal to Idaho
Power and Avista. CAPAI has heard that other states are considering alternatives to
general rate case procedure, but is not aware of any state that considers simply calling the
case something it isn't and violating existing law without going through the proper
channels to be a valid alternative. For all the reasons outlined in this testimony and
CAPAI's brief, the procedure employed in this case is in violation of the law and, by
virtue of that law, Rocky Mountain's Application should considered withdrawn ancl not
result in a rate increase.
When the Commission chose to break out low-income weatherization from the
201I rate cases into a separate docket, CAPAI lully and in good faith participated in that
process. It seems to be one thing to brcak out son-rething such as LIWA, but to
et-fectively eliminate existing rate case procedure, and through the use of marginalization
of CAPAI and Rocky Mountain's uncalled tbr behavior in terms of refusing to rcspond to
discovery related to rate design issues and effectively prevent CAPAI from raising rate
design issues is another matter and should not be permitted. Rate design is a legitirnate
general rate case issue regardless of whether other parties wish to address it. lf the
settling parties celn see their way fit to address issues of concern to specialcontract and
large industrial customers, then they can certainly accommodate a good faith discussion
ol'CAPAI's rate design issues.
DIRECT TESTIMONY OF CHRISTINA ZAMORA 14 5
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Q:
A:
Regardless of whether the rate increase proposed in the settlement stipulation is in
the best interests of all ratepayers, nothing is worth the cost of allowing parties to
unilaterally ignore existing law or effectively rewrite the law on an ad /roc basis. Should
the Commission deem it appropriate to allow for very limited rate cerses in which issues
such as revenlre requircment, rate spread or rate design are not fair game, then it should
accomplish this by means of obtaining the necessary legislative changes or engage in
admi nistrative rulemakin g.
CAPAI doesn't have the ability or funding necessary to determine whether the
proposed settlement is in the best interests of ratepayers and, because of Rocky
Mountain's refusal to comply in good faith with CAPAI's legitimate discovery requests
regarding rate design, CAPAI has not even had the time to t'ully analyze that issue and
determine whether the existing rate design is fair in light of the concessions that Rocky
Mountain took from the proposed settlement and all other salient facts.
Does this conclude your direct testimony?
Yes, it does.
L46DTRECT TESTIMONY OF CHRISTINA ZAMORA ))
(The following proceedings were had in
open hearing. )
COMMISSIONER REDFORD: Mr. Sol-ander.
MR. SOLANDER: Yes, thank you.
CROSS-EXAMINATION
BY MR. SOLANDER:
O. Can you explain how you reached the concfusion in
your testimony that the procedure employed in this case is
unlawful ?
MR. PURDY: Excuse me. May I have a reference to
a page, Ii-ne?
COMMTSSIONER SMITH: Page 2L.
MR. SOLANDER: Yes, page 21 , l-ine 10 .
I believe there's al-so another reference.
Page 3, beginning on line at the end of line 11.
THE WITNESS: It's my understanding that this
is this procedure is being handl-ed in a different way, and
so that's pretty much what f meant.
A. BY MR. SOLANDER: So you didn't mean that it was
being handled j-n an un1awful manner?
A. No.
MR. SOLANDER: f have no further questions.
COMMISSIONER REDFORD: Mr. Budge.
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HEDRICK COURT REPORTING
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ZAMORA (X)
CAPA]83701
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CAPAI
MR. BUDGE: No questions.
COMMISSIONER REDFORD: Mr. Price.
MR. PRICE: No questions.
COMMfSSIONER REDFORD: Mr. Otto.
MR. OTTO: No questions.
COMMISSIONER REDEORD: Do you have any further
questions, Mr. Purdy?
MR. PURDY : ,.fust one f ollow-up to Mr . So1ander ' s
question.
REDIRECT EXAMINATION
BY MR. PURDY:
a. Ms. Zamora and if you don't know because this
possibly goes into a 1ega1 area, then please say so -- but
might the procedure employed in this case be unl-awful if this
were if this were treated as a general rate case?
MR. SOLANDER: Objection: That cal-l-s for a lega1
concl-usi-on as we11.
COMMISSIONER REDFORD: Sustained.
MR. PURDY: Okay. That ' s al-I I have then . Thank
you.
COMMISSIONER REDFORD: Excuse me. Ms. Smith.
COMMISSIONER SMITH: Thank you.
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HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, fD
ZAMORA (Com)
CAPAT
EXAMINATION
BY COMMISSIONER SMITH:
O. f just had a question on page B --
A. Uh-huh.
O. of your testimony. Excuse me. At l-ines 20
through 22, you are speaking about the process of your
organization, dt least that's my understanding. Is that
correct?
A. On which lines? I'm sorry.
O. Wel-l-, your who1e answer is speaking about your
organi-zation' s structure?
A. And the process, yes.
O. And the process that you use?
A. Uh-huh.
O. So if your process l-eaves you l-ittl-e or no
opportunity to conduct discovery, that's not due to any failure
on the part of the Commissj-on's process, is it?
A. No.
O. Thank you. And on page sorry -- page L2,
l-ine 15 I think my voice j-s going you speak about
Avista's 2012 rate case and CAPAf's proposal there.
Do you have personal knowledge of that case? Did
you participate j-n it?
A. I responded to discovery requests, and al-so
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revj-ewed the data that was provided.
O. So that was something you did yourself?
A. Uh-huh.
O. A11 right. Thank you.
Letrs see. I think that's it.
COMMISSIONER SMITH: That was it. Thank you,
Mr. Chai-rman.
COMMISSIONER REDFORD: Commi-ssioner?
COMMISSIONER KJELLANDER: NO.
COMMISSIONER REDFORD: f just have a couple of
questions.
EXAMINATION
BY COMM]SS]ONER REDFORD:
O. How long have you been working for CAPAI?
A. I've been working for CAPAI since 2005.
O. Here in Boise?
A. Yes.
0. Okay. Thank you. No further questions.
COMMISSIONER REDFORD: Are there any further
questJ-ons, Mr. Purdy?
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CAPAT83701
REDIRECT EXAMINAT]ON (ContJ.nued)
BY MR. PURDY:
O. I just woul-d l-ike one quick follow-up in response
to Commissioner Smj-th's question about whether it is the
Commission's faul-t or responsj-bility that CAPAI lacks
sufficient time to prepare, and you said no. Is it do you
believe that it's the result of an expedited process adopted by
the parties not imposed by the Commission that leads to these
difficul-ti-es?
A. Yes, that's correct.
O. Okay. That's all I have, thank you.
COMMISSIONER REDFORD: Ms. Smith has one more
questJ-on , or several.
COMMfSSIONER SMITH: No, just one.
EXAMINATION
BY COMMISSIONER SMITH:
O. On page 3, line 13, you use the phrase
"additional procedural transgressions. "
A. Uh-huh.
O. What did you mean?
A. So understanding that Irm new to this process,
although I've I have experience in providing informati-on for
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zAMoRA (DilCom)
CAPA]83701
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HEDRICK COURT REPORTING
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severaf of the rate cases that CAPAI has j-ntervened in, my
intention was to explain that we have concerns about procedure
being changed as and so the ru.l-es are over here and the
procedure is just changed without guidance from the Commission.
So that's my concern.
O. So was it a sin?
A. No, I donrt think --
O. To me, a "transgression" is l-ike a sin.
A. Yeah, a very strong word, yes.
O. Okay. Well-r we already agreed, f think, that you
don't think it' s unl-awful-.
A. Uh-huh.
O. Okay. Thank you.
COMMISSIONER REDEORD: As a result of
Commlssioner Smj-th's questions, are there any questions from
the parties?
Hearing none, Mr. Kjellander, do you have any
questions ?
COMMISSIONER KTIELLANDER: No, thank you.
(The witness l-eft the stand.)
COMMISSIONER REDEORD: I believe there has only
been one exhibit. If anyone has got exhibits that they wanted
to admit apparently, Dor so
COMMISSIONER SMITH: Mr. Weston has three and
Randy has one.
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HEDRICK COURT REPORT]NG
P. O. BOX 578, BOTSE, rD 83701
MR. SOLANDER: Irm sorry, during my --
Mr. Weston's testimony and the four exhibits thereto, I moved
for the admission of when I was examining Mr. Weston.
COMMISSIONER REDFORD: Okay. Would that be
then
MR. SOLANDER: There were three exhibits to
Mr. Weston's direct testimony and one to his rebuttal-
testimony.
COMMISSIONER REDEORD: So that woul-d be Exhibit
No. 502?
MR. SOLANDER: No, I bel-ieve it woul-d be one
through four.
COMMISSfONER SMITH: I only have three.
COMMISSIONER REDFORD: And anythj-ng else?
Commissi-oner Smith.
COMMISSIONER SMITH: I'm sorry, f only have
Exhibits 1 through 3 that were attached to Mr. Westonrs direct.
If there
MR. SOLANDER: I believe I have a copy of
MR. WESTON: And then one to the
COMMISSIONER SMITH: T see it. Never mind. f
see it. ft was just out of place in my notebook. r apologize.
MR. SOLANDER: Thank you.
MR. PRICE: Chaj-rman Redford, I woul-d just
reiterate I be.l-ieve it was spread upon the record when I
153
COLLOQUY
introduced Mr. Lobb's testimony, but Commissj-on Staff has
Exhibit 101- attached to his direct testimony.
COMMISSIONER REDFORD: Thank you. Okay. The
exhibits by PacifiCorp or Rocky Mountain procedure (sic) and
the Staff are admitted.
(Rocky Mountain Power Exhibit Nos. 1
through 4 and Staff Exhibit No. 101, havj-ng been premarked for
identification, were admitted into evidence. )
COMMISSIONER REDFORD: Is there anything does
anyone want the opportunity to argue? Tf so, f'm going to put
a limit on it of ten minutes. Mr. Solander.
MR. SOLANDER: I wouLd just reiterate that the
Company is seeking approval of the stj-pulation, as wel-l as the
electric servj-ce agreement between Rocky Mountain Power and
Monsantor ds part of this application. The parties and the
testimony you have reviewed, other than with the exception of
CAPAI who did not join the stipulation, bel-ieve that it's a
just and reasonable result and in the public interest to
approve it.
COMMISSIONER REDFORD: Mr. Budge.
MR. BUDGE: Thank you, Mr. Chairman.I don't
have any argument to make, but I woul-d l-ike to point out to the
Chairman and Commi-ssion three relatively smaI1 matters, largely
procedural, that affect the Monsanto contract, if I may. The
Monsanto contract is addressed in Paragraphs 15, 16, and tl of
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BOISE, ID 83701
the stipulation in this matter
And I would l-ike to note that the Paragraph 15
provided for an amendment be made to the Monsanto el-ectric
service agreement. Paragraph L6 also provided that the parti-es
accompanying Monsanto would execute a new electric service
agreement reflecting these changes. I would simply note for
the Commission that those two items, in fact, have been
completed.
A1so, that the Company Paragraph L"7 was the
other paragraph addressing Monsanto's contract, and it did
state that Monsanto and the Company wou1d continue to work
coll-aboratively and in good faith to address the terms and
conditions to optimize the value of Monsantors curtail-ment
products prior to the next rate case. I would note, for the
Commlssion, that Monsanto has been in good faith negotiations
with the Company prior to this particular stipulation
addressing that i-ssue in accordance with the stipulation in the
20LL case, and that we do intend to continue those discussions
to try to resolve that issue prior to the next general rate
case filing in a couple of years.
I would secondly l-ike to point out that the
testimony of Mr. Weston included
Monsanto /PactftCorp new el-ectric
filed as confj-dential, Exhibit No
simply ask that this remain filed
1_55
a copy of the
service agreement. It was
. 2, under seal-. V[e wou]-d
under seal as a confidential
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exhibit. This is consistent with the agreement between the
parties of the contract. It's al-so consistent with the
procedural- means of handling the contract that we've used for
the past several- cases.
The third issue f want to address is the Idaho
Electric Service Schedul-e 400 that rel-ates to the tariff rates
for the Monsanto contract, has not been included purposely as a
part of the tariff schedules attached to Mr. Weston's
testimony, but itrs my understanding the Company wil-l-, in fact,
be filing that Schedule 400 once the stipulation is approved,
along with the other electric schedules, and we woul-d again
ask, consj-stent with past practice and agreement of the
parties, that Schedule 400 be fil-ed under confidentiality seal-
as wel-l- because it does reflect both the firm and interruptible
demand and energy charges at Monsanto, and that the Company,
when they fil-e the Schedul-e 400 refl-ecting the full charge,
that it afso be fil-ed under seal, the purpose being so that the
public record does not reflect a mechanism insofar as looking
at the firm rates and the confidential- rates to determine the
net rate that Monsanto ul-timately pays for electricity, whlch
is a matter of proprietary interests of Monsanto.
COMMISSIONER REDEORD: Thank you, Mr. Budge.
f'm asking a guestion: Whose witness was it that
introduced the stipulation?
COMMISSIONER SMITH: Randy did.
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COMMISSIONER REDEORD: Who?
COMMISSIONER SMITH: Randy did.
COMMISSIONER REDEORD: Randy did. Is that
correct?
MR. PRICE: I think it was
MR. BUDGE: Mr. Weston.
MR. PRICE: It was an exhibit for both.
MR. WESTON: I didn't file it as an exhibit. The
Company fil-ed the stipulation with the Commission. Mr. Lobb
filed it also as an exhibit to his testimony.
COMMISSIONER REDFORD: So it's been admitted.
ft's admitted. ff it j-sn't, it is. Thank you.
I think that we're right at the
MR. PRfCE: Chairman Redford, just one brief
thing.
COMMISSfONER REDFORD: Yes.
MR. PRICE: I neglected at the outset of this
proceedj-ng to communicate Mr. Ron Wil-l-iams' and his client's
support for the stipulation. He contacted me vla phone and 1et
me know that he would not be present today but asked me to
communicate their support for the stipulation, which they have
signed on to, and he represents PIIC.
COMMISSIONER REDEORD: Thank you. Wel-l-, hearing
nothing more to come before the Commission
MR. PURDY: I'm sorry, Mr. Chair, I wasnrt given
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an opportunity to make a closing.
My first request would be whether the Chair woul-d
consider entertaj-ning posthearing briefing in this matter.
COMMISSIONER REDFORD: This has been briefed and
the testimony is pretty correct. f don't think we rea11y -- I
think we have enough information to issue a decision without
further briefing.
MR. PURDY:Eine. Then if I may just make a very
brief comment
COMMISSIONER REDEORD: Go ahead.
MR. PURDY: I just wanted to emphasize that
nothing set forth in the testj-mony of Ms. Zamora, nor any of
the pleadings filed by CAPAI in this case, in any way impugns
the Commission's credibility or suggests that the Commission
has acted unlawfully. Rather, CAPAI is, as it has I think
fairly clearly articulated, significantly concerned about the
precedent that this might set for future cases and CAPAI's
desire to keep ratemaking processes as transparent as they can
be, and that this case just seems to be a step beyond what 1s
acceptable; but in no manner does CAPAI contend that that is
the Commission's faul-t.
COMMISSIONER REDFORD: f just have one question,
Mr. Purdy: There's nothing in the record that other than a
l-ot of verbiage about the stipulation. Is it your position
that you believe that the Commission should disregard the
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BOISE, ID
proceedings and the settl-ement and start over?
MR. PURDY: Ms. Zamora does take on that question
and I hate to supplant my testimony for hers, but she I think
makes it fairly clear that regardless of whether the Commission
ultimately determines that this settlement is j-n the best
interests of al-l- concerned, the concerns regarding the
procedure adopted in this case remain; and whether the
Commission could approve the settlement but state that in the
future this type of a procedure would be considered
unacceptable, or any other myriad of options, that's certainly
a possibility as well-.
COMMISSIONER REDEORD: So it is your position
that you'd l-ike to have us scrap the stipulation and go to a
different procedure, that is, a rate case.
MR. PURDY: Yes, I understand that. And, again,
Ms. Zamora states that CAPAI is not in a position to state
whether this is in the best interest of the l-ow-income
customers because of the difficulty in obtaining certain
information that it needed to make that determlnation and
whether to join in the settlement, but it does remain concerned
about the procedure.
The Commission coul-d approve the settlement on
the basis that, y€s, you know, as far as the numbers, ds far as
the lmpact on ratepayers, this is a fair, just, and reasonabl-e
resolutj-on but we do have concerns about the procedure
159
83701
COLLOQUY
1
2
3
4
5
6
1
I
9
10
11
t2
13
1,4
15
t6
!7
18
19
20
2!
22
23
24
25
HEDRICK COURT REPORTTNG
P. O. BOX 5'7I , BOTSE, rD
employed, and then provide some guidance to the party in that
respect. And that way you wouldn't have to reject the
settlement stj-pulation in its entirety, but you coul-d al-so
address the concerns that CAPAI has raised.
COMMISSIONER REDEORD: Thank you, Mr. Purdy.
Mr. Prj-ce, is there further comment?
MR. PRICE: No further comment.
COMMISSIONER REDEORD: WelI, in that case, I wil-L
consider this case ful1y submitted.
MR. OTTO: f'm sorry, Mr. Commissioner.
COMMISSIONER REDFORD: Yes. I'm sorry, Mr. Otto.
MR. OTTO: I'd just l-ike a chance to make a very
brief statement so ICL's posi-tion j-s clear on the record.
We did sign the settlement. We think the
interests of our membership are much more gIobaI than CAPAI.
We're not trying to denigrate CAPAI's position at all, and
actually we share several- of their concerns, but on the whole
we felt like that this stipulation is a positive result and
we'd encourage the Commission to approve it.
ICL does share many of the same procedural
concerns that CAPAI has raised. Likewise, we're, you know,
short-staffed and we're trying to do our best to understand
these complex cases and participate within the frameworks. To
the extent stuff is l-ess than transparent, that makes it more
difficult.
160
83701
COLLOOUY
1
2
3
4
5
6
1
B
9
10
l-1
72
13
t4
15
16
l7
1B
19
20
2!
22
23
24
25
HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD
So we'd l-ook forward to a proceeding in this
case the result was okay, but it shouldnrt be that the result
makes the process okay. The process shoul-d be good to begin
with. So we encourage the Commission to maybe weigh in on what
j-s an appropriate process for these types of situations where
settlement could be productive, but transparency and inclusion
are key.
So, with that, ICL supports the stipulation but
feel-s the procedure maybe l-eft something to be desired.
COMMISSIONER REDFORD: Thank you.
Hearing nothing further, this matter wil-1 be
closed, and we will- deliberate in due course and render a
decision. Thank you.
(The hearing adj ourned at 1-l-: 59 a. m. )
L67
83701
COLLOQUY
1
2
3
4
5
6
7
B
9
10
11
t2
13
t4
15
16
t7
18
1,9
20
27
22
23
24
25
HEDRICK COURT REPORTING
P. O. BOX 578, BOTSE, rD
AUTHENTICATION
This is to certify that the foregoing is a
true and correct transcript to the best of my ability of the
proceedings held in the matter of the application of PacifiCorp
dba Rocky Mountaln Power to initiate dj-scussions with
interested parties on alternative rate plan proposals, Case No.
PAC-E-13-04, commencj-ng on Wednesday, September 11, 201,3, dt
the Commission Hearing Room, 412 West Washington, Boise, Idaho,
and the original thereof for the file of the Commission.
Accuracy of al-l prefiled testimony as
origj-nally submitted to this Reporter and incorporated herein
at the direction of the Commissi-on is the sole responsibility
of the submitting parties.
WENDT J.Nota y- PubIi-c
in and for
residj-ng at
My CommissionIdaho CSR No.
tate
di-an,
expr-res
415
of ldaho,
Idaho.
2-B-2014
^"o.1.i'1"',rafi;*,,"
^"utffi"^-* ir*tr -"-- $*-Ei, LPusL\LJ n3
'%W"c
L62
83701
AUTHENTICATION
Rocky Mountain Power
Exhibit No. 1 Page 1 of 5
Case No. PAC-E-13-04
Witness: J. Ted Weston
l=
all
Eq
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ci \o<f,-o\oO O\+o6ltaF- @{,{,4!+o.aoa;
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O-e{m!+h\O61 61 6l C-.1 a{ e{ e.l\O r- oo O. 3 =
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Attachment D - Settlement Rates
ROCKY MOUNTAIN POWER . STATE OF IDAHO
cAsE NO. PAC-E-I3-04
Present
Price
Rocky Mountain Power
Exhibit No. 1 Page 2 of 5
Case No. PAC-E-13-04
VMtness: J. Ted Weston
Settlement
Price
Uu20t4
SCHEDULE NO. I - Residential Service
Customer Charge
All kwh (May - Oct)
<:700 kwh
> 700 kwh
All kwh (Nov - Apr)
<: 1,000 kWh
> 1,000 kwh
Seasonal Service Charge
SCHEDULE NO.36 - Residential Service Optional TOD
Customer Charge
On-Peak kWh (May - Oct)
Off-Peak kWh (May - Oct)
On-Peak kWh (Nov - Apr)
Off-Peak kWh (Nov - Apr)
Seasonal Service Charge
SCHEDULE NO.6/6A - General Service - Large Power
Customer Charge (Secondary Voltage)
Customer Charge (Primary Voltage)
All kW (May - Oct)
All kW (Nov - Apr)
Alt kwh
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE NO.7 - Customer Owned Light
Residential
Charges Per Lamp
16,000 Lumens, HPSV
SCIIEDULE NO.7/7A - Security Area Lighting
Charges Per Lamp
7000 Lumens, MV
20,000 Lumens, MV
5,600 Lumens, HPSV, Co Owned Pole
5,600 Lumens, HPSV, No Co Owned Pole
9,500 Lumens, HPSV, Co Owned Pole
9,500 Lumens, HPSV, No Co Owned Pole
16,000 Lumens, HPSV, Co Owned Pole
16,000 Lumens, HPSV, No Co Owned Pole
27,500 Lumens, HPSV, Co Owned Pole
$s.00
10.7874
14.5630
8.2571
11.1472
s60.00
$14.00
14.4027
4.9148
12.3029
4.4982
$168.00
$37.00
sl r 1.00
$14.36
$l l.8l
3.6696
$444.00
$ 1,332.00
($0.6s)
$r4.9r
$s.00
10.8759
14.6825
8.3249
r 1.2386
$60.00
fi
(
i
a
ii
fi
(
o
(
(
a
$26.83
$47.86
$ 17.04
s13.56
$ l9.s l
$ 16.02
$2s.70
$22.88
$36.97
$r4.00
t4.s26s (
4.9s71 O
12.4087 (
4.s369 (
$168.00
$37.00
$l l 1.00
$r4.36
$r 1.81
3.7293 i
s444.00
$1,332.00
(s0.6s)
$r s.03
$27.04
$48.23
$17.17
$13.67
$19.66
$ 16.1s
$2s.90
$23.06
s37.26
Attachment D - Settlement Rates
ROCKY MOUNTAIN POWER. STATE OF IDAHO
cAsE NO. PAC-E-I3-04
Present
Price
Rocky Mountain Power
Exhibit No. 1 Page 3 of 5
Case No. PAC-E-1$04
Wtness: J. Ted Weston
Settlement
Price
UU20t4
27,500 Lumens, HPSV, No Co Owned Pole
50,000 Lumens, HPSV, Co Owned Pole
50,000 Lumens,I{PSV, No Co Owned Pole
16,000 Lumens, HPS Flood, Co Owned Pole
16,000 Lumens, HPS Flood, No Co Owned Pole
27,500 Lumens, HPS Flood, Co Owned Pole
27,500 Lumens, HPS Flood, No Co Owned Pole
50,000 Lumens, HPS Flood, Co Owned Pole
50,000 Lumens, HPS Flood, No Co Owned Pole
8,000 Lumens, LPSV, Energy Only
13,500 Lumens, LPSV, Energy Only
22,500 Lumens, LPSV, Energy Only
33,000 Lumens, LPSV, Energy Only
SCHEDULE NO.9 - General Service - High Voltage
Customer Charge
All kW (May - Oct)
All kW (Nov - Apr)
Minimum kW Summer
Minimum kW Winter
All kwh
SCHEDULE NO. 10 - Irrigation
Small Customer Charge (Season)
Large Customer Charge (Season)
Post-Season Customer Charge
All kW (June I - Sept 15)
First 25,000 kWh (June 1 - Sept l5)
Next 225,000 kWh (June 1 - Sept l5)
All Add'l kWh (June I - Sept l5)
All kwh (Sept 16 - May 3l)
SCHEDULE NO. 1l - Company-Owned Street Lighting Seruice
Charges per Lamp
5,800 Lumens, High Intensity Discharge
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 I
16,000 Lumens, High tntensity Discharge - Series 1
9,500 Lumens, High Intensity Discharge - Series 2
16,000 Lumens, High Intensity Discharge - Series 2
12,000 Metal Halide
$33.48
$s 1.67
s4s.74
$25.70
$22.88
$36.97
$33.48
$s 1.67
$4s.74
$3.66
$s.41
$7.s2
$9.1 s
$370.00
$10.26
s7.74
$ r 0.26
s7.74
3.8835
$14.00
$41 .00
s23.00
$s.98
8.5312
6.3103
4.6577
7.2164
$33.74
$s2.07
$46. l 0
$2s.90
s23.06
$37.26
s33.74
$s2.07
$46.10
$3.69
s5.45
$7.s8
s9.22
$370.00
$10.26
$7.74
$10.26
87.74
3.92$ A
$14.00
$41.00
$23.00
$s.98
8.6106 p
6.3691 (,
4.7011 (
7.2$6 A
p
0
0(
$15. r4
s 18.89
$2s.7s
$3s.96
$s2.79
s31.25
$34.29
s2s.7t
$28.68
$27.88
$ 15.26
$ 19.04
$2s.95
s36.24
$s3.20
$31.49
$34.56
$2s.9r
$28.90
$28.1 0
Attachment D - Settlement Rates
ROCKY MOUNTAIN POWER. STATE OF IDAHO
CASE NO. PAC-E-i3-04
Present
Price
Rocky Mountain Power
Exhibit No. 1 Page 4 of 5
Case No. PAC-E-13-04
Witness: J. Ted Weston
Sefflement
Price
UU20t4
SCHEDULE NO. 12E - Customer-Owned Street Lighting Seruice-Energy Only
Charges per Lamp
33,000 Lumens, LPSV $9.16
12,000 Metal Halide $7.05
19,500 Metal Halide $9.65
32,000 Metal Halide $15.17
107,800 Metal Halide $36.32
9,000 Metal Halide $4.01
5,800 Lumens, HPSV $2.84
9,500 Lumens, FIPSV $3.97
16,000 Lumens, HPSV $5.91
27,500 Lumens, HPSV $10.10
50,000 Lumens, HPSV $15.52
Non-Listed Luminaire - Energy Only 10.2944 (
19,500 Metal Halide
32,000 Metal Halide
9,000 Metal Halide - Series 1
12,000 Metal Halide - Series I
9,000 Metal Halide - Series 2
12,000 Metal Halide - Series 2
SCHEDULE NO. 12F - Customer-Owned Street
Charges per Lamp
5,800 Lumens, HPSV
9,500 Lumens, HPSV
16,000 Lumens, HPSV
27,500 Lumens, HPSV
50,000 Lumens, HPSV
Lighting Service-Full Maintenance
$34.60
$4 r.97
$31.s2
s36.24
$30.67
$32.38
$6.s6
$8.36
$ 10.04
$13.16
$ r 7.ss
$34.87
$42.30
$31.t7
$36.s2
s30.91
s32.63
$16.42
$21.98
$5.88
$7.s7
$12.14
$r6.36
$23.00
9.31s2 (
6.9023 o
$9.23
$7.r 0
$9.73
$15.29
$36.60
s4.04
s2.86
s4.00
$s.96
$10. I 8
$15.64
10.3745 i
$6.61
$8.43
$10.r2
$13.26
$17.69
$l6.ss
$22.1s
$s.93
$7.63
$12.23
$16.49
$23.00
9.3916 (
6.9s89 A
SCHEDULE NO. 12P - Customer-Owned Street Lighting Service-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
SCHEDULE NO. 19 - Commercial and Industrial Space Heating
Customer Charge Secondary
All kwh (May - Oct)
All kWh (Nov - Apr)
Attachment D - Settlement Rates
ROCKY MOUNTAIN POWER -STATE OF IDAHO
cAsE NO. PAC-E-I3-04
Present
Price
Rocky Mountain Power
Exhibit No. 1 Page 5 of 5
Case No. PAC-E-13-04
Witness: J. Ted Weston
Settlement
Price
UU20t4
SCHEDULE NO.23l23A - General Service
Customer Charge Secondary
Customer Charge Primary
All kwh (May - Oct)
All kwh (Nov - Apr)
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE NO.35 - General Service - Optional TOD
Customer Charge Secondary
Customer Charge Primary
All On-Peak kW
All kwh
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE 4OO
Firm Energy and Power
Customer Charges
kwh
kw
Excess kVar
Interruptible Energy and Power
kwh
kw
SCHEDULE 401
Customer Charges
HLH kwh (May-October)
HLH kwh (November-April)
LLH kWh (May-October)
LLH kwh (November-April)
All kW (May-October)
All kW (November-April)
$16.00
$49.00
9.1 030
7.9463
$192.00
$s88.00
0
(
(0.43e7) i,
s67.00
$r6s.00
$16.45
4.9015 A
$804.00
$ 1,980.00
($o.t+1
sr6.00
$49.00
9.r82s (,
8.0157 (
$192.00
$s88.00
(0.43e7) l,
s67.00
$ 16s.00
$16.4s
4.9609 O
$804.00
$1,980.00
($0.84)
$1,586.00
3.1303 i
$ 15.91
$0.96
3.1303 (
$1s.91
$442.00
3.6855 A
3.0649 (
2.7$s A
2.7$s A
$ 17.60
$ 14.19
$ 1,586.00
3.0870 A
$ 1s.91
$0.96
3.0870 I
$ 15.91
$442.00
3.6332 I,
3.0214 A
2.72$ A
2.7243 (
s 17.60
s14. I 9
o
THIS EXHIBIT IS CONFIDENTIAL
AND IS PROVIDED UNDER
SEPARATE COVER
O
o
ROCKY MOUNTAIN
F,IOWER
AOfvlsloilOf iACIFUOnF
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 1 of 46
Case No. PAC-E-13-04
\Afitness: J. Ted Weston
Eighth Revision of Sheet No. 1.1
Canceling Seventh Revision of Sheet No. 1.1
ROCKY MOT]NTAIN POWER
ELECTRIC SERVICE SCMDULE NO. 1
STATE OF IDAHO
Residential Service
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
ofadequate capacity.
APPLICATION: This Schedule is for alternating current electric service supplied at
approximately 120 or 240 volts through one kilowatt-hour meter at a single point of delivery for all service
required on the premises for Residential purposes.
When conditions are such that service is supplied through one meter to more than one dwelling or
apartment unit, the charge for such service will be computed by multiplying the minimum charges by the
maximum number of dwelling or apartment units that may be served.
When a portion of a dwelling is used regularly for business, professional or other gainful purposes,
the premises will be classified as nonresidential and the appropriate schedule applied. However, if the
wiring is so arranged that the service for Residential purposes can be metered separately, this Schedule will
be applied to such service.
MONTHLY BILL:
Customer Service Charge:
$5.00 per Customer
Energy Charge:(l) Billing months May
through October inclusive
10.8759 I per kWh first 700 kWh
14.6825i per kWh all additional kwh
Submitted Under Case No. PAC-E-13-04
ISSUED: August 76,2013 EFFECTM: January l,2014
Y{ffiffi*HI,IOUNTAIN
Rocky Mountain Power
Exhibit No. 3 Page 2 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Eighth Revision of Sheet No. 1.2
Canceling Seventh Revision of Sheet No. 1.2I.P.U.C. No. I
ELECTRIC SERVICE SCHEDITLE NO. 1- Continued
MONTHLY BILL: (continued)
Billing months November
through April inclusive
8.3249i, per kWh first 1,000 kWh
11.23869 per kWh all additional kwh
MONTHLY BILLING REDUCTION: Rates in this schedule shall be reduced by the monthly
kilowatt-hour credit adjustment set forth under "Monthly Rates" in the currently effective Electric Service
Schedule No. 34.
SEASONAL SERVICE: When seasonal service is supplied under this Schedule, the minimum
seasonal charge will be S60.00.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule will 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 file with and approved by the Idaho Public Utilities Commission, including
future applicable amendments, will be considered as forming a part of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
(2)
EF'FECTM: January 1,2014
ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
LP.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 3 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
Sixth Revision of Sheet No. 6.1
Canceling Fifth Revision of Sheet No.6.1
ROCI(Y MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 6
STATE OF IDAIIO
General Service - Large Power
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
ofadequate capacity.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for
all service required on the premises.
MONTHLY BILL:
Rate:
Billing Months May
throueh October. Inclusive
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts) $ 37.00 per Customer
Primary voltage
delivery (2300 volts
or higher) $ 111.00 per Customer
Billing Months November
through April. Inclusive
$ 37.00 per Customer
$ I I 1.00 per Customer
$ I l.8l per kW for all kW
3.7293A per kWh for all kWh
Power Rate:
Energy Rate:
$ 14.36 per kW for all kW
3.72%A per kWh for all kWh
(Continued)
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013 EFFECTM: January l,2014
ROCKY MOUNTAIN
POWER
A OMSTOil OF PACtnCOnP
Rocky Mountain Power
Exhibit No. 3 Page 4 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Sixth Revision of Sheet No. 6A.l
Canceling Fifth Revision of Sheet No. 6A.lI.P.U.C. No. I
ROCI(Y MOT]I\TAIN POWER
ELECTRIC SERVICE SCHEDULE NO.6A
STATE OF IDAHO
General Service - Large Power (Residential and Farm)
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
of adequate capacity 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 Bonneville Power Administration.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for
all service required on the premises.
MONTHLY BILL:
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts)
Primary voltage
delivery (2300 volts
or higher)
Power Rate:
Energy Rate:
Billing Months May
through October. Inclusive
$ 37.00 per Customer
$ 1 I 1.00 per Customer
$ 14.36 per kW for all kW
3.7293(, per kWh for all kWh
(Continued)
Billing Months November
through April. Inclusive
$ 37.00 per Customer
$ 111.00
$ ll.8l
3.7293(,
per Customer
per kW for all kW
per kWh for all kWh
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013 EFFECTIVE: January l, 2014
I.P.U.C. No. I
;ROCKY MOUNTAIN
POWER
A D'VrSIOX 09 IACTFTCORP
Rocky Mountain Power
Exhibit No. 3 Page 5 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Fifth Revision of Sheet No. 7.1
Canceling Fourth Revision of Sheet No. 7.1
ROCKY MOT]NTAIN POWER
ELECTRIC SERVICE SCITEDULE NO.7
STATE OF IDAHO
Security Area Lighting
AVAILABILITY: At any point on the Company's interconnected system. No new Mercury Vapor
Lamps will be installed after May 3, 1985.
APPLICATION: This Schedule is for (l) 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 and (2) Customer-owned/Customer-maintained Area Lighting.
MONTHLY BILL:
Rate:
(1) Securitv Area Lighting
Nominal Lamp Rating:
Initial Lumens
Mercury Vapor Lamp:
7,000
20,000
Watts Per Lamp
$27.04
$48.23
175
400
per lamp
per lamp
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSIIED: August 16, 2013
ROCKY MOUNTAIN
POWER
A Orvrsroll Oi PACTFTCORP
Fourth
Canceling Third
Rocky Mountain Power
Exhibit No. 3 Page 6 of 46
Case No. PAC-E-'|3-04
Witness: J. Ted Weston
Revision of Sheet No. 7.2
Revision of Sheet No. 7.2I.P.U.C. No.l
ELECTRIC SERVICE SCHEDULE NO.7 - Continued
MONTI{LY 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 250
50,000 high intensity discharge 400
70 $17.17
$ 13.67
100 $19.66
$16.15
150 $2s.90
$23.06
per lamp on new pole
per lamp if no new
pole is required
per lamp on new pole
per lamp if no new
pole is required
per lamp on new pole
per lamp if no new
pole is required
$37.26 per lamp on new pole
$33,74 per lamp if no new
pole is required
$52.07 per lamp on new pole
$46.10 per lamp if no new
pole is required
$25.90 per lamp on new pole
$23.06 per lamp if no new
pole is required
$37.26 per lamp on new pole
533.74 per lamp if no new
pole is required
$52.07 per lamp on new pole
S46.10 per lamp if no new
pole is required
Sodium Vapor Flood Lamps:
16,000 high intensity discharge 150
27 ,500 high intensity discharge 250
50,000 high intensity discharge 400
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSIIED: August 16,2013
ROCKY MOUNTATN
POWER
A O|VTSTON Or PACiFCOSP
Fifth
Canceling Fourth
Rocky Mountain Power
Exhibit No. 3 Page 7 of 46
Case No. PAC-E-I 3-04
Wtness: J. Ted Weston
Revision of Sheet No. 7.4
Revision of Sheet No. 7.4I.P.U.C. No. I
ELECTRIC SERVICE SCHEDULE NO. 7 - Continued
MONTI{LY BILL: (continued)
(2) Customer-Owned/Customer-Maintained Area Lighting
Energy Only (No New Service):
Initiallumens Watts Per Lamp
16,000 Sodium Vapor Flood 150 $15.03
CONTRACT PERIOD: One year or longer.
PROVISIONS
1. Inoperable lights will be repaired as soon as reasonably possible, during regular business hours or as
allowed by company's operating schedule and requirements, provided the Company receives
notification of inoperable lights form Customer or a member of the public by either notifuing Rocky
Mountain Power's customer service (1-888-221-7070) or wurv.rocKvmountainpower.net/streetlights.
Rocky Mountain Power's obligation to repair lights is limited to this tariff.
2. The Company reserves the right to contract for the maintenance of lighting service provided
hereunder.
3. Temporary disconnection and subsequent reconnection of electrical service requested by the
Customer shall be at the Customer's expense. The Customer may request temporary suspension of
power for lighting by written notice. During such periods, the monthly rate will be reduced by the
Company's estimated average monthly relamping and energy costs for the luminaire. The facilities
may be considered idle and may be removed after 12 months of inactivity.
4. Pole re-painting, when requested by the Customer and not required for safety reasons, shall be done
at the Customer's expense, using the original pole color.
5. Glare or vandalism shielding, when requested by the Customer, shall be installed at the Customer's
expense. In cases of repetitive vandalism, the Company may notifu the Customer of the need to
install vandal shields at the Customer's expense, or otherwise have the lighting removed.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule will 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 file with and approved by the Idaho Public Utilities Commission, including
future applicable amendments, will be considered as forming a part of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013 EFFECTM: January 1,2014
Y(ffiouNrArN
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 8 of 46
Case No. PAC-E-13-04
\Mtness: J. Ted Weston
Fourth Revision of Sheet No. 7A.l
Canceling Third Revision of Sheet No. 7A.1
ROCKY MOUNTAIN POWER
ELECTRIC SBRVICE SCHEDULE NO. 7A
STATE OF IDAIIO
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 Bonneville Power Administration. No new Mercury Vapor Lamps will 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) Securitv Area Lighting
Nominal Lamp Rating:
Initial Lumens
Mercury Vapor Lamp:
7,000
20,000
Watts
175
400
Per Lamp
$27.04 per lamp
$48.23 per lamp
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
Y(ffiI[-H:OUNTAIN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No.3 Page 9 of 46
Case No. PAC-E-I$04
Witness: J. Ted Weston
Fourth Revision of Sheet No. 7A.2
Canceling Third Revision of Sheet No. 7A.2
ELECTRIC SERVICE SCHEDULE NO. 7A - Continued
MONTHLY BILL: (continued)
Rate:
Sodium Vapor Lamps:
5,600 high intensity discharge
9,500 high intensity discharge
16,000 high intensity discharge 150
27,500 high intensity discharge 2s0
50,000 high intensity discharge 400
70 s17.17
$13.67
100 $19.66
$ 16.1s
per lamp on new pole
per lamp if no new
pole is required
per lamp on new pole
per lamp if no new
pole is required
$25.90 per lamp on new pole
$23.06 per lamp if no new
pole is required
$37.26 per lamp on new pole
$33.74 per lamp if no new
pole is required
$52.07 per lamp on new pole
$46.10 per lamp if no new
pole is required
$25.90 per lamp on new pole
$23.06 per lamp if no new
pole is required
537.26 per lamp on new pole
533.74 per lamp if no new
pole is required
$52.07 per lamp on new pole
$46.10 per lamp if no new
pole is required
Sodium Vapor Flood Lamps:
16,000 high intensity discharge 1s0
27,500 high intensity discharge 2s0
50,000 high intensity discharge
(Continued)
400
EFFECTM: January 1,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
VROCKYMOUNTAINY(powen
\ A DrvrSrON OF PACTHCOnF
I.P.U.C. No.l
Rocky Mountain Power
Exhibit No. 3 Page 10 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Sixth Revision of Sheet No. 9.2
Canceling Fifth Revision of Sheet No. 9.2
ELECTRIC SERVICE SCHEDULE NO.9 - Continued
MONTHLY BILL:
Rate:
Billing Months May
through October. Inclusive
Customer ServiceCharge: $370.00 per Customer
Power Rate:
Energy Rate:
$10.26 per kW for all kW
3.9283(, per kWh for all kWh
Billing Months November
through April. Inclusive
$370.00 per Customer
$ 7.14 per kW for all kW
3.92830 per kWh for all kWh
Power Factor:
This rate is based on the Customer maintaining at all times a power factor of 85o/o lagging,
or higher, as determined 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 314
of lYo for every loh that the power factor is less than 85%.
Minimum:
The Customer Service Charge plus the minimum Power Charge and appropriate Energy
Charges.
POWER: The kW as shown by or computed from the readings of Company's Power meter for the
l5-minute period of Customer's greatest use during the month, adjusted for power factor as specified,
determined to the nearest kW, but not less than 80 kW.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGIILATIONS: Service under this Schedule will 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 file with and approved by the Idaho Public Utilities Commission, including
future applicable amendments, will be considered as forming a part of and incorporated in said Agreement.
Submitted Under Case No. PAC-E-I3-04
ISSIJED: August 16, 2013 EFFECTM: January l,2014
Y{ffiff*HIUIOUNTAIN
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 11 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Eighth Revision of Sheet No. 10.2
Canceling Seventh Revision of Sheet No. 10.2
ELECTRIC SERVICE SCIIEDULE No. 10 - Continued
MONTHLY BILL: (Continued)
Power Rate: $5.98 per kW for all kW
Energy Rate: 8.6106A per kWh for first 25,000 kwh
6.3691i, per kWh for the next 225,000 kwh
4.7011(, per kWh for alladditional kWh
Power Factor: This rate is based on the Customer maintaining at all times a power factor
of 85% lagging, or higher, as determined by measurement. If the average power factor is
found to be less than 85Yo lagging, the power as recorded by the Company's meter will be
increased by 3/4 of l%o for every lYothatthe power factor is less than 85%.
Minimum: The Customer Service Charge.
Post-Season Rate
Customer Service Charge: $23.00 per Customer
Energy Rate: 7.2836i, per kWh for all kWh
Minimum: The Customer Service Charge.
ADJUSTMENTS: All monthly bills shall be adjusted in accordance with Schedules 34 and94.
PAYMENT: All monthly service billings will be due and payable when rendered and will 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 Service 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
bills for the entire season and the Customer failed to pay any balance owing by the
due date of the final billing issued for the season.
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
Yffiii-H{\,IOUNTAIN
LP.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 12 of 46
Case No. PAC-E-'|3-04
Wtness: J. Ted Weston
Sixth Revision of Sheet No. 11.1
Canceling Fifth Revision of Sheet No. 11.1
ROCKY MOI]NTAIN POWER
ELECTRIC SERVICE SCHEDT]LE NO. 11
STATE OF IDAIIO
Street Lighting Service
Company-Owned System
AVAILABILITY: ln 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 governments for dusk to dawn illumination 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: The Monthly Billing shall be the rate per luminaire as specified in the rate
tables below.
Hish Pressure Sodium Vapor
Lumen Rating 5,800x 9.500 r6.000 27.500 50.000
Watts 70 100 150 250 400
Monthlv kWh 28 39 59 96 148
Functional Lishtins s15.26 $19.04 s25.9s s36.24 ss3.20
Decorative - Series I NiA $3 r.49 $34.s6 N/A N/A
Decorative - Series 2 N/A $2s.91 $28.90 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)
EFFECTM: January 1,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
OCKY
POWER
A Orvrsrortt OF PACTRCOEP
AIN
Rocky Mountain Power
Exhibit No.3 Page 13 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
Sixth Revision of Sheet No. 12.1
Canceling Fifth Revision of Sheet No. 12.1I.P.U.C. No. 1
ROCKY MOT]NTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 12
STATE OF IDAHO
Street Lighting Service
Customer-Owned System
AVAILABILITY: ln allterritory served by the Company in the State of Idaho.
APPLICATION: To lighting service provided to municipalities or agencies of municipal, count;r,
state or federal governments for dusk to dawn illumination of public streets, highways and thoroughfares by
means of Customer owned street lighting systems controlled by a photoelectric control or time switch.
MONTIILY 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 Billing shall be the rate per luminaire as specified in the rate tables below.
High Pressure Sodium Vapor- No
Maintenance
Monthlv kWh
$ 10.18
(Continued)
EFFECTM:January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
Y(HFffiHrvrouNrArN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 14 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Fifth Revision of Sheet No. 12.2
Canceling Fourth Revision of Sheet No. 12.2
Metal Halide - No Maintenance
Lgn_.! B3tl"g
Watts
laorinr, r.wt
ELECTRIC SERYICE SCHEDULE NO. 12 - Continued
MONTHLY BILL: (continued)
Low Pressure Sodium Vapor - No
Maintenance
L_u1n_eq BAtfng 33-000
Watts 180
Monthlv kWh 74
Enersv Onlv Service $9.23
For non-listed luminaires, the cost will be calculated for 3940 annual hours of operation including
applicable loss factors for ballasts and starting aids at the cost per kWh given below.
Non-Listed Luminaire $/kwh
Enersv Onlv Service $0. 1 03 74s
2. Maintenance Service (No New Service)
Monthly maintenance is only applicable for existing
effect priorto June 29,2007.
A. Street Lighting. "Partial Maintenance"
monthly maintenance service agreements in
Mercury Vapor- Partial
Maintenance
L_qntq Bqtlng 10,000 20,000
Watts 250 400
Monthly kWh 93 t45
Partial Maintenance
Service $ l6.ss $22.1s
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
Y{HFffiHIVIOUNTAIN
Rocky Mountain Power
Exhibit No. 3 Page '15 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
I.P.U.C. No. 1
Fifth Revision
Canceling Fourth Revision
of Sheet No. 12.3
of Sheet No. 12.3
Iligh Pressure Sodium -
Partial Maintenance
Partial Maintenance
Service
ELECTRIC SERVICE SCHEDULE NO. 12 - Continued
MONTHLY BILL: (continued)
B. Street Lightins. "Full Maintenance"
SPECIFICATIONS AND SERVICE FOR STREET LIGHTING WITH PARTIAL AI\iD
FIILL 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 facilities will
be deemed obsolete and must be upgraded at customer expense in order to qualifu 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 arms and luminaires: provided, however, that any costs for
materials which are over and above costs for Company's standard materials, as determined by
the Company, are not included in this Electric Service Schedule. Such extra costs shall be paid
by Customer. Buming-hours of lamps will be controlled by the Company.
High Pressure Sodium -
Full Maintenance
$1 0.1 2
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
YlHffiIVIOUNTAIN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 16 of 46
Case No. PAC-E-I3-04
Witness: J. Ted Weston
Eighth Revision of Sheet No. 19.2
Canceling Seventh Revision of Sheet No. 19.2
ELECTRIC SERVICE SCIIEDULE NO. 19 - Continued
MONTHLY BILL:
Rate for space heating:
Billing Months May
through October. Inclusive
$23.00 per Customer
Billing Months November
through April. Inclusive
Customer
Service Charge:
Energy Rate:
$23.00
6.9589(
per Customer
per kWh for all kWh9.3916(, per kWh for all kWh
Rate for all other service:
All other service requirements will be supplied under Electric Service Schedule No. 6, or
Electric Service Schedule No. 6,4,, or Electric Service Schedule No. 23, or Electric Service
Schedule No. 23A, or Electric Service Schedule No.35, or Electric Service Schedule No. 35A.
SPACE IIEATING: AII 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 CONDITIONING: All air conditioning equipment shall be permanently installed and shall be
the sole means of providing comfort cooling for the building space occupied by the Customer. All air
conditioning equipment and installation thereof and all supply wiring shall conform with the Company's
specifications. Electric service for comfort cooling will be metered and billed at the above rate only when
Customer also uses electric service for his total space heating requirements.
WATER HEATING: Water heaters served hereunder shall be insulated storage, single or
multiple-unit type of construction approved by the Company, the heating units of which shall be
noninductive and controlled by separate thermostats. Electric service of storage water heating will be
metered and billed at the above rate only when Customer also uses electric service for his total space
heating requirements.
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
I.P.U.C. No. I
ROCKY MOUNTAIN
POWER
AOIVISDil OF PACIFEOBP
Rocky Mountain Power
Exhibit No. 3 Page 17 of 46
Case No. PAC-E-13-04
\Mtness: J. Ted Weston
Sixth Revision of Sheet No. 23.1
Canceling Fifth Revision of Sheet No. 23.1
ROCKY MOTINTAIN POWER
ELECTRIC SERVICE SCIIEDULE NO.23
STATE OF IDAIIO
General Service
AVAILABILITY: At any point on the Company's interconnected system where there are facilities of
adequate capacity.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for all
service required on the premises.
MONTHLY BILL:
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts)
Primary voltage
delivery (2300 volts
or higher)
Energy Rate:
Billing Months May
through October. Inclusive
$ 16.00 per Customer
$49.00 per Customer
9.1825(, per kWh for all kWh
Billing Months November
through April. Inclusive
$16.00 per Customer
$49.00 per Customer
8.0157i, per kWh for all kWh
(Continued)
EFFECTIYE: January l, 2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
Y(ffifii*HNIOUNTAIN
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No.3 Page 18 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
Sixth Revision of Sheet No. 23A.1
Canceling Fifth Revision of Sheet No.23A.1
ROCKY MOI]NTAIN POWER
ELECTRIC SERVICE SCHEDTILE NO.23A
STATE OF'IDAHO
General Service @esidential and Farm)
AVAILABILITY: At any point on the Company's interconnected system where there are facilities of
adequate capacity 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 tle 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 Bonneville Power Administration.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for all
service required on the premises.
MONTHLY BILL:
Billing Months May
through October. Inclusive
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts)
Primary voltage
delivery (2300 volts
or higher)
$16.00 per Customer
$49.00 per Customer
Energy Rate: 9.1825(, per kWh for all kWh
(Continued)
Billing Months November
througilr April. Inclusive
$16.00 per Customer
$49.00 per Customer
8.0157i, per kWh for all kWh
Submitted Under PAC-E- I 3-04
ISSUED: August 16,2013 EFFECTM: January l,2014
U,ROCKY MOUNTAINY(powen
\ A DtvrsloN of FAcrFrcoRP
LP.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 19 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
First Revision of Sheet No. 31.2
Canceling Original Sheet No.31.2
ELECTRIC SERVICE SCHEDULE NO.31 - Continued
MONTHLY BILL:
Rate:
Billing Months May
through October. Inclusive
$370.00 per Customer
$5.70 perkW forall kW
Billing Months November
through April. Inclusive
$370.00 per Customer
$4.30 per kW for all kW
$7.74 per kW for all kW
3.9283i per kWh
Customer Service
Charge:
Back-up Facilities
Rate:
Back-up Power
Rate:
Excess Power
Rate:
Supplementary
Power Rate:
Supplementary
and Back-up
Energy Rate:
The Facilities Rate applies to the kW of Back-up Contract Power
$0.19 all kW Day $0.14 All kW Day
Back-up Power is billed on a per day basis and is based on the fifteen (15)
minute period of the Customer's greatest use of Back-up Power during the
day.
Scheduled Maintenance Power rate is one half (ll2) of the Back-up Power
Rate.
520.52 per kW for all kW
$10.26 per kW for all kW
3.9283(, per kWh
$15.48 per kW for all kW
POWER FACTOR: This rate is based on the Customer maintaining at all times a power factor of
85% lagging, or higher, as determined by measurement. If the average power factor is found to be less than85%o
lagging, the Power as recorded by the Company's meter will be increased by % of loh for every loh that the
power factor is less than 85%.
(continued)
EFFECTM: January 1,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
!,HffiOUNTAIN
Rocky Mountain Power
Exhibit No.3 Page 20 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Seventh Revision of Sheet No. 35.2
I.P.U.C. No. 1 Canceling Sixth Revision of Sheet No.35.2
ELECTRIC SERVICE SCHEDULE NO.35 - Continued
MONTHLY BILL:
Customer Service Charge:
Secondary voltage delivery
(Less than 2300 volts)
Primary voltage delivery
(2300 volts or higher)
Power Charge:
On-Peak kW
Energy Charge:
Per kWh for all kWh
TIME PERIODS:
On-Peak 7:00 a.m. to l0:00 p.m., Monday thru Friday, except holidays.
Off-Peak All other times.
Due to the expansions of Daylight Saving Time (DST) as adopted under Section I 10 of the
U.S. Energy Policy Act of 2005 the time periods shown above will 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 Saturday or Sunday, the
Friday before the holiday (if the holiday falls on a Saturday) or the Monday following the holiday (if the
holiday falls on a Sunday) will 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%o
lagging, or higher, as determined 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 314 of l%o for every l%o thatthe
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 transformers and other necessary equipment, the voltage discount
based on highest measured Power during the billing cycle will be:
$0.84 per kW
Minimum: Customer Service Charge plus applicable Demand and Energy charges.
$ 67.00 per Customer
$165.00 per Customer
$ 16.45 per kW
4.9609i,
(Continued)
EFFECTM: January 1,2014
Submitted Under Case No. PAC-E-13-04
ISSIIED: August 16, 2013
ROCKY MOUNTAIN
POWER
A 0rvrsrord oF PAcrFrcoiP
Seventh
Canceling Sixth
Rocky Mountain Power
Exhibit No. 3 Page 2'1 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
Revision of Sheet No. 35,4'.2
Revision of Sheet No. 35A.2I.P.U.C. No. I
ELECTRIC SERYICE SCHEDULE NO.35A - Continued
MONTHLY BILL:
Customer Service Charge:
Secondary voltage delivery
(Less than 2300 volts)
Primary voltage delivery
(2300 volts or higher)
Power Charge:
On-Peak kW
Energy Charge:
Per kWh for all kWh
$ 67.00 per Customer
$165.00 per Customer
$ 16.45 per kW
4.9609A
TIME PERIODS:
On-Peak
Off-Peak
7:00 a.m. to l0:00 p.m., Monday thru Friday, except holidays.
All other times.
Due to the expansions of Daylight Saving Time (DST) as adopted under Section 110 of the U.S.
Enerry Policy Act of 2005 the time periods shown above will 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 Saturday or Sunday, the
Friday before the holiday (if the holiday falls on a Saturday) or the Monday following the holiday (if the
holiday falls on a Sunday) will 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%o
lagging, or higher, as determined by measurement. If the average Power factor is found to be less than 85%o
lagging the Power as recorded by the Company's meter will be increased by 314 of 1%o for every 1o/othatthe
Power factor is less than 85%o.
Voltage Discount: Where Customer takes service from Company's available lines of 2,300 volts or
higher and provides and maintains all transformers and other necessary equipment, the voltage discount
based on highest measured Power during the billing cycle will be:
$0.84 per kW
Minimum: Customer Service Charge plus applicable Demand and Energy charges.
(Continued)
EFFECTM: January l,2014
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
J,ROCKYMOUNTAINYrcwep.\ A Dlvislotrr OF PACIFICORP
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 22 of 46
Case No. PAC-E-1 3-04
Wtness: J. Ted Weston
Ninth Revision of Sheet No. 36.2
Canceling Eiehth Revision of Sheet No. 36.2
ELECTRIC SERVICE SCHEDULE NO.36 - Continued
MONTHLY BILL:
Rate:
Billing Months May Billing Months November
throughOctober.lnclusive throughApril.Inclusive
Customer Service
Charge:
On Peak Energy Charge:
Off Peak Energy
$14.00 per Customer $14.00 per Customer
1452650 per kWh
4.95711, per kWh
12.40870 per kWh4.5369i, per kWh
Charge:
Minimum Bill: Customer Service Charge.
On Peak:
Summer months-All kWh used from 8:00 A.M. to 1 l:00 P.M., Monday through Friday,
except holidays.
Winter months--All kWh used from 7:00 A.M. to 10:00 P.M., Monday through Friday, Oexcept holidays.
Holidays include only: New Year's Day, President's Day, Memorial Day, Independence
Day, Labor Day, Thanksgiving Day, and Christmas Day.
Off Peak:
All other kWh usage.
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 will 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.
SEASONAL SERVICE: When seasonable service is supplied under this Schedule, the minimum
seasonal charge will be $168.00 plus energy charges.
CONTRACT PERIOD: One year or longer.
MONTHLY BILLING REDUCTION: Rates in this schedule shall be reduced by the monthly
kilowatt-hour credit adjustment set forth under "Monthly Rates" in the currently effective Electric Service
Schedule No. 34.
(Continued)
EFFECTM: January l,2074
Submitted Under Case No. PAC-E-13-04
ISSUED: August 16,2013
!1[ffiIVIOUNTAIN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No.3 Page 23 of 46
Case No. PAC-E-1&04
Witness: J. Ted Weston
Eishthli€+,r.rf&--Revision of Sheet No. 1.1
Canceling Sr:vexthi#xth_-Revision of Sheet No. 1.1
ROCKY MOT]NTAIN POWER
ELECTRIC SERVICE SCITEDULE NO.I
STATE OF IDAHO
Residential Service
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
ofadequate capacity.
APPLICATION: This Schedule is for alternating current electric service supplied at
approximately 120 or 240 volts through one kilowatt-hour meter at a single point of delivery for all service
required on the premises for Residential purposes.
When conditions are such that service is supplied through one meter to more than one dwelling or
apartment unit, the charge for such service will be computed by multiplying the minimum charges by the
maximum number of dwelling or apafiment units that may be served.
When a portion of a dwelling is used regularly for business, professional or other gainful purposes,
the premises will be classified as nonresidential and the appropriate schedule applied. However, if the
wiring is so arranged that the service for Residential purposes can be metered separately, this Schedule will
be applied to such service.
MONTHLY BILL:
Customer Service Charge:
$5.00 per Customer
Energy Charge:(l) Billing months May
through October inclusive
10.8't5q q%Ap per kWh first 700 kWh
14.56!+6S2:l per kWh all additional kwh
(Continued)
Submitted Under,'xd+iceXrr, I i $}dlas* lri o. t'}Ac- t-.- I 3-il4
ISSUED: -,Lugts:_l_6...?fi.l_lee+ebt*-"t-%4*-14 EFFECTM: @
}.ffiruouNrArN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 24 of 46
Case No. PAC-E-1&.04
Wtness: J. Ted Weston
li<rr*ntS[jgh* Revision of Sheet No. 1.2
Canceling $ixtFfigygn{h Revision of Sheet No. 1.2
ELECTRIC SERVICE SCHEDULE NO. 1- Continued
MONTHLY BILL: (continued)
Billing months November
through April inclusive
L*$:+Wtll per kWh first 1,000 kWh
I 1.+I4ll&l per kWh all additional kwh
MONTHLY BILLING REDUCTION: Rates in this schedule shall be reduced by the monthly
kilowatt-hour credit adjustment set forth under "Monthly Rates" in the currently effective Electric Service
Schedule No. 34.
SEASONAL SERVICE: When seasonal service is supplied under this Schedule, the minimum
seasonal charge will be $60.00.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule will be in accordance with
the terms of the Electric Service Agreement between the Customer and the Company. The Electric Service
Regulations of the Company on file with and approved by the Idaho Public Utilities Commission, including
future applicable amendments, will be considered as formingapart of and incorporated in said Agreement.
Submitted Under Atlrrie*-i{ *.fi*}{] c se },1 r:. I} A {' - f;: - I "i -{ }4
ISSUED: A.ugtjs_f I (lj9tiale****.-{a;+&L}
(2)
EFFECTI\rE: January l, 4q-4&:{}"}.4
I.P.U.C. No. 1
ROCKY MOUNTAIN
FIOWER
A B'V|SION OT PAOFCONP
Rocky Mountain Power
Exhibit No. 3 Page 25 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
-Fi{*b$!$I_Revision of Sheet No. 6.1
Canceling po*x+*fi ftLnevision of Sheet No. 6. 1
ROCKY MOI'NTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.6
STATE OF IDAHO
General Service - Large Power
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
ofadequate capacity.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for
all service required on the premises.
MONTHLY BILL:
Rate:
Billing Months May
through October. Inclusive
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts) $ 37.00 per Customer
Primary voltage
delivery (2300 volts
or higher) $ I I 1.00 per Customer
Billing Months November
throueh April. Inclusive
$ 37.00 per Customer
$ 1 I 1.00 per Customer
$ I l.8i per kW for all kW
3.6<rq6i per kWh for all kWhyx(
Power Rate:
Energy Rate:
$ 14.36
3.$6qq
2230
per kW for all kW
per kWh for all kWh
(Continued)
Submitted Under ease+**{4-{tr ase I\ o. tr1 ht:.-h.- 1 3 -l}4
ISSUED: G*{"&bs*.%+$.#Ailrust 1 {l, 20 1 3 EFFECTM: January l, 3$-l3?_$*ij{
-ROCKYMOUNTAIN-(powen
\ A Drvrsroil oF PAcrFrcoRP
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 26 of 46
Case No. PAC-E-1$04
Vvitness: J. Ted Weston
$#th-Sixth Revision of Sheet No.6A.1
Canceling ee***fif* nevision of Sheet No. 6A.1
ROCKY MOI]NTAIN POWER
ELECTRIC SERVICE SCI{EDULE NO.6A
STATE OF IDAI{O
General Service - Large Power @esidential and Farm)
AVAILABILITY: At any point on the Company's interconnected system where there are facilities
of adequate capacity for service to any customer who qualifies as a "Residential Load" or "Farm Load"
under both (l) 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 Bonneville Power Administration.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for
all service required on the premises.
MONTI{LY BILL:
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts) $ 37.00
Primary voltage
delivery (2300 volts
Billing Months May
throueh October. Inclusive
per Customer
Billing Months November
through April. Inclusive
$ 37.00 per Customer
$ I I 1.00 per Customer
$ I 1.81 per kW for all kW
3.6#161 per kWh for all kWh
293-A
or higher)
Power Rate:
Energy Rate:
$ 111.00
$ 14.36
3.66{}6i
i'l J9
per Customer
per kW for all kW
per kWh for all kWh
(Continued)
Submitted Under **{vie++,++.J*"{$Cn se N o. P A {' - E - 1 .i -{}:i
ISSUED: Ae*ber-ir)-2$"*;drerrust I ii. 20 1 ;?EFFECTM: January l, 2$#?01l-
LP.U.C. No. I
ROCKY MOUNTAIN
POWER
,\ orvrGloir oi PAclRcoEP
Rocky Mountain Power
Exhibit No. 3 Page 27 of 46
Case No. PAC-E-13-04
Vvitness: J. Ted Weston
Xs*r*fitn nevision of Sheet No. 7.1
Canceling Sh.il*l-'f'qgg[h Revision of Sheet No. 7.1
ROCKY MOI]NTAIN POWER
ELECTRIC SERYICE SCIIEDT]LE NO.7
STATE OF'IDAHO
Security Area Lighting
AVAILABILITY: At any point on the Company's interconnected system. No new Mercury Vapor
Lamps will 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 and (2) Customer-owned/Customer-maintained Area Lighting.
MONTI{LY BILL:
Rate:
(1) Securitv Area Lighting
Nominal Lamp Rating:
lnitial Lumens
Mercury Vapor Lamp:
7,000
20,000
Watts Per Lamp
$affia::-gj
$+;#6.jis.il
per lamp
per lamp
175
400
(Continued)
Submitted Under *dvi€s-lJ€:+2-S+Ccse No. PAC- h.- I 3 -01
ISSUED: {X-&*eF+ryBAusL:st 1 6- 20 I 3 EFFECTM: January l, 3+S3gl4
ryffi;l'IouNrArN
LP.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 28 of 45
Case No. PAC-E-13-04
Witness: J. Ted Weston
Shir*Egg;1lh Revision of Sheet No. 7.2
Canceling Wlt{Revision of Sheet No. 7.2
ELECTRIC SERVICE SCI{EDIILE NO. 7 - Continued
MONTHLY BILL: (continued)
Sodium Vapor Lamps:
5,600 high intensity discharge 70
pole
9,500 high intensity discharge
pole
16,000 high intensity discharge
pole
no new
27,500 high intensity discharge
pole
50,000 high intensity discharge
pole
Sodium Vapor Flood Lamps:
16,000 high intensity discharge
pole
27 ,500 high intensity discharge
pole
$17.841: per lamp on new
$13.566: per lamp if no new
pole is required
$19.f,-(r6 per lamp on new
S16.€+5 per lamp if no new
pole is required
$25.+{}99 per lamp on new
$*.*ss23Jxr-per lamp if
pole is required
$3WL26 per lamp on new
$33.4.e7_4 per lamp if no new
pole is required
$5-{-{i72.0: per lamp on new
84.>#4*l{) per lamp if no new
pole is required
$25.7$9S per lamp on new
$23.8S3.Q6 per lamp if no new
pole is required
$3$WlS per lamp on new
$33.4$74 per lamp if no new
pole is required
100
150
400
150
250
250
EFFECTM: January l, 2SJ*Sgll
Submitted Under A.<iviee+lt;=-}i*$3Ca se N o. f' AC' - f - ] :1 -( l.{
ISSUED: l-
YffiffiHtr'IOUNIAIN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No.3 Page 29 of 45
Case No. PAC-E-I3-04
Wtness: J. Ted Weston
&irefoq{.h_Revision of Sheet No. 7.2
Canceling {ieeffie|rd Revision of Sheet No. 7.2
50,000 high intensity discharge
pole
(Continued)
$5t#?:$_i per lamp on new
$4$r?46.U1 per lamp if no new
pole is required
400
Submitted Under advie*Fb-l*-$3C a s*'hi o. P A C - f, - I 3 -{}":l
ISSUED:EFFECTM: January l, 3S-}32QI4
I.P.U.C. No. 1
ROCKY MOUNTAIN
POWER
A O|VTS|ON OF PaC|FTCORP
Rocky Mountain Power
Exhibit No. 3 Page 30 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
s<llrx&-gi&h Revision of Sheet No.7.4
Canceling S&ireF:tgtkRevision of Sheet No. 7.4
ELECTRIC SERVICE SCHEDULE NO. 7 - Continued
MONTHLY BILL: (continued)
(2) Customer-Owned/Customer-Maintained Area Lightin g
Energy Only (No New Service):
Initial Lumens Watts Per Lamp
16,000 Sodium Vapor Flood 150 $-l4Jtl-1.i.,.{l-1
CONTRACT PERIOD: One year or longer.
PROVISIONS
l. Inoperable lights will be repaired as soon as reasonably possible, during regular business hours or as
allowed by company's operating schedule and requirements, provided the Company receives
notification of inoperable lights form Customer or a member of the public by either notifuing Rocky
Mountain Power's customer service (l-888-221-7070) or wwrv.rockvmountainpower.net/streetlishts,
Rocky Mountain Power's obligation to repair lights is limited to this tariff.
2. The Company reserves the right to contract for the maintenance of lighting service provided
hereunder.
3. Temporary disconnection and subsequent reconnection of electrical service requested by the
Customer shall be at the Customer's expense. The Customer may request temporary suspension of
power for lighting by written notice. During such periods, the monthly rate will be reduced by the
Company's estimated average monthly relamping and energy costs for the luminaire. The facilities
may be considered idle and may be removed after 12 months of inactivity.
4. Pole re-painting, when requested by the Customer and not required for safety reasons, shall be done
at the Customer's expense, using the original pole color.
5. Glare or vandalism shielding, when requested by the Customer, shall be installed at the Customer's
expense. In cases of repetitive vandalism, the Company may notiff the Customer of the need to
install vandal shields at the Customer's expense, or otherwise have the lighting removed.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule will 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 file with and approved by the ldaho Public Utilities Commission, including
future applicable amendments, will be considered as forming a part of and incorporated in said Agreement.
S ubm itted Un der At{+4e*-}{,+--+2-t#i {l n s c N r:. l} A{' - F. - 1 3 -tl :tr
ISSIJED : <lex#er-+if++*a!rgu$5-: 0_1j EFFECTM: January l, 3+SlQll
ROCKY MOUNTAIN
POWER
A OrvrsroN Or PAC|FTCOiP
Rocky Mountain Power
Exhibit No. 3 Page 31 of 46
Case No. PAC-E-13-M
Wtness: J. Ted Weston
Seire&urlh Revision of Sheet No. 7A.l
Canceling See$x*-&i$LRevision of Sheet No. 7A.lI.P.U.C. No. 1
ROCKY MOT]NTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 7A
STATE OF IDAHO
Security Area Lighting @esidential 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 Bonneville Power Administration. No new Mercury Vapor Lamps will 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:
(l) Securitv Area Lighting
Nominal Lamp Rating:
Initial Lumens
Mercury Vapor Lamp:
7,000
20,000
Watts
175
400
Per Lamp
$2*WLfr"4 per lamp
$4!.869.:l per lamp
(Continued)
Submitted Under C as e N o. PAC - F,- 1 3 -04,4etvie*)i+^-i?-{}}
ISSUED: @Lis!- 1fi*2"4 ),1 EFFECTIYE: January 1, *)+32p)A
I.P.U.C. No. I
ROCKY MOUNTAIN
FOWER
A OMSrS.l Or PACTFCOnP
Rocky Mountain Power
Exhibit No.3 Page 32 of 45
Case No. PAC-E-1 3-04
Vvitness: J. Ted Weston
+hirdl.tgggh Revision of Sheet No. 7A.2
Canceling Sses**I$x|nwision of Sheet No. 7A.2
ELECTRIC SERVICE SCHEDIILE NO. 7A - Continued
MONTHLY BILL: (continued)
Rate:
Sodium Vapor Lamps:
5,600 high intensity discharge 70
pole
9,500 high intensity discharge
pole
16,000 high intensity discharge
pole
27,500 high intensity discharge
pole
50,000 high intensity discharge
pole
Sodium Vapor Flood Lamps:
16,000 high intensity discharge
pole
27,500 high intensity discharge
pole
$17.84]l per lamp on new
$13.56(f per lamp if no new
pole is required
$19.$+S$ per lamp on new
$16.s3l: per lamp if no new
pole is required
$25.;S90 per lamp on new
$24.8S3.0& per lamp if no new
pole is required
$36*#:26 per lamp on new
$33.48:l per lamp if no new
pole is required
$5-W2.07 per lamp on new
$4W,*JA per lamp if no new
pole is required
$25.;Sgg per lamp on new
$2}*&3.06 per lamp if no new
pole is required
$3ffi:/i.per lamp on new
$33.48:1 per lamp if no new
100
150
250
400
150
250
EFFECTM: January l,X]-#,Zilr|
Submitted Under 44rriee*le.-ll43Clr se N o. P A C - E - 1 :1 -01
ISSUED: o*lt#e'r_{{!4$l}rtuuust I {r. 20 I 3
LP.U.C. No. 1
ROCKY MOUNTAIN
FIOWER
A OTVTSTON Of PACTFTCORp
Rocky Mountain Power
Exhibit No. 3 Page 33 of 46
Case No. PAC-E-13-04
\Mtness: J. Ted Weston
+*ir*'Fou11[h Revision of Sheet No. 7A.2
Canceling $ec&nt*^I'hir* Revision of Sheet No. 7A.2
50,000 high intensity discharge
pole
(Continued)
pole is required
$54ti}2$j per lamp on new
$45.z16l_0 per lamp if no new
pole is required
400
Submitted Under '{,M}Csse No. pAC-f.-l3-{}1
ISSIIED: $etober-+.*a$*+Ausust I {i. 20 1 -''EFFECTwE: January l, 2S-S101,1
}1ffiouNrArN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 34 of 46
Case No. PAC-E-1&04
\Mtness: J. Ted Weston
S*f+Fiiirlh Revision of Sheet No. 9.2
Canceling fo*rt*-fitn nevision of Sheet No. 9.2
ELECTRIC SERYICE SCHEDULE NO.9 - Continued
MONTIILY BILL:
Rate:
Billing Months May
through October. Inclusive
Customer Service
Charge: $370.00 per Customer
Power Rate:
Energy Rate:
$10.26 per kW for all kW
3.$.S".'5$ per kWh for all kWh
;a\ )p
Billing Months November
through April. Inclusive
$370.00 per Customer
$ 7.74 per kW for all kW
3.$$-4Sg per kWh for all kWh
2&)O
Power Factor:
This rate is based on the Customer maintaining at all times a power factor of 85% lagging,
or higher, as determined by measurement. [f 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 314
of lYo for every l%o that the power factor is less than 85Yo.
Minimum:
The Customer Service Charge plus the minimum Power Charge and appropriate Energy
Charges.
POWER: The kW as shown by or computed from the readings of Company's Power meter for the
l5-minute period of Customer's greatest use during the month, adjusted for power factor as specified,
determined to the nearest kW, but not less than 80 kW.
CONTRACT PERIOD: One year or longer.
ELECTRIC SERVICE REGULATIONS: Service under this Schedule will 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 file with and approved by the Idaho Public Utilities Commission, including
future applicable amendments, will be considered as formingapart of and incorporated in said Agreement.
Submitted Under **#es-H"J**{tiC;r se N o. P A C- E- 1 3 -{}4
ISSI]ED:EFFECTM: January l, 38*3gl_4
-,ROCKYMOUNTAIN-(powen
\ A DrvrsroN oF PAclFrcoiP
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 35 of 46
Case No. PAC-E-I 3-04
Witness: J. Ted Weston
eeren*h-&lgltjl1.Revision of Sheet No. 10.2
Cancelins {iix*FScv*nth Revision of Sheet No. 10.2
ELECTRIC SERVICE SCHF.DULE No. l0 - Continued
MONTIILY BILL: (Continued)
Power Rate:
Energy Rate:
Post-Season Rate
Customer Service Charge:
Energy Rate:
$5.98 per kW for all kW
8.5*{:-61061 per kWh for first 25,000 kwh
6.3-{-033(}.91p per kWh for the next225,000 kWh
4.6?147AlW per kWh for all additional kWh
$23.00 per Customer
7.U-#28361 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 determined 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 314 of l%o for every l%o that the power factor is less than 85Yo.
Minimum: The Customer Service Charge.
Minimum: The Customer Service Charge.
ADJUSTMENTS: All monthly bills shall be adjusted in accordance with Schedules 34 and94.
PAYMENT: All monthly service billings will be due and payable when rendered and will 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 Service Regulation No. 9. An advance may be
required under any of the following conditions:
(l) the Customer failed to pay all amounts owed to the Company when due and
(2)
payable;
the Customer paid an advance the previous season that did not adequately cover
bills for the entire season and the Customer failed to pay any balance owing by the
due date of the final billing issued for the season.
(Continued)
Submitted Under -4dvi*r*i{*=.14J,$C* ** N o. l'},4 f - E - ] -i -{ }"{
ISSIIED: @s:j6.2913 EFFECTM: January l, 3$*;rll
ROCKY MOUNTAIN
POWER
A OrvlSION OT PACIFICOHP
Rocky Mountain Power
Exhibit No.3 Page 36 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
#:th-Sixth Revision of Sheet No. 11.1
I.P.U.C. No. 1 Canceling St+rlrt&-fiflL Revision of Sheet No. 11.1
ROCKY MOTJNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.11
STATE OF IDAHO
Street Lighting Service
Company-Owned System
AVAILABILITY: In all territory served by the Company in the State of ldaho.
APPLICATION: To unmetered lighting service provided to municipalities or agencies ot'
municipal, county, state or federal governments for dusk to dawn illumination 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: The Monthly Billing shall be the rate per luminaire as specified in the rate
tables below.
Hish Pressure Sodium Vaoor
Lumen Rating 5.800*9.s00 16.000 27.500 50.000
Watts 70 100 ls0 250 400
Monthlv kWh 28 39 59 96 148
Functional Liehtine $15.{*ifu $18-ti99.{i4 $25."?595
$3$"$6$*3
1 ss;;qt.20
Decorat ve - Series 1 N/A $31.;51e $34.2956 N/A NiA
Decorat ve - Series 2 N/A $25.7+q i s28.6Sqii 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 advi*e-+.,t*"-a *4*{. as* hl>. il,A [' - b. - 1 "i -{};]
ISSUED: $e&>ber-f#B;\*uu st I * " 2{}'23 EFFECTIYE: January 1, 3S{+3AH
ROCKY MOUNTAIN
POWER
A O,v|SlOlr OF P clrrcOiP
Rocky Mountain Power
Exhibit No. 3 Page 37 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
"ffiab'filxth Revision of Sheet No.
Canceling $our+hEjllh Revision of Sheet No.I.P.U.C. No. 1
12.1
t2.t
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDI]LE NO. T2
STATE OF IDAIIO
Street Lighting Service
Customer-Owned System
AVAILABILITY: In all territory 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 illumination of public streets, highways and thoroughfares by
means of Customer owned street lighting systems controlled by a photoelectric 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 Billing shall be the rate per luminaire as specified in the rate tables below.
(Continued)
Iligh Pressure Sodium Vapor- No
Maintenance
$ 10.+-& i8
Submitted Under +dviee-5k {+&}tl*se No. PAC-L-l3-{}^:t
ISSUED:@?013 EFFECTM: January l, W.Lt{;!
!(.fiffiruouNrAIN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 38 of 46
Case No. PAC-E-'!3-04
Witness: J. Ted Weston
S{}"r{i}-E!8h Revision of Sheet No. 12.2
Canceling &*i*r$Iiourt![Revision of Sheet No. 12.2
Metal Halide - No Maintenance
L_u1n_eg Bgtirg
Watts
Monthlv kWh
$15.s2q
ELECTRIC SERVICE SCHEDULE NO. 12 - Continued
MONTIILY BILL: (continued)
Low Pressure Sodium Vapor - No
Maintenance
L_u1ne4 Bqtine 33.000
Watts 180
Monthlv kWh 74
Enersv Onlv Service $9.+623
For nonJisted luminaires, the cost will be calculated for 3940 annual hours of operation including
applicable loss factors for ballasts and starting aids at the cost per kWh given below.
Non-Listed Luminaire $/kwh
Enersv Onlv Service
$0.+4+3+4410ji&
5
2. Maintenance Service (No New Service)
Monthly maintenance is only applicable for existing monthly maintenance service agreements
effect prior to June 29,2007.
A. Street Lighting. "Partial Maintenance"
Mercury Vapor - Partial
Maintenance
L_u1n_eq Bqtfrg 10.000 20,000
Watts 250 400
Monthlv kWh 93 t4s
Partial Maintenance
Service $16.-*s:
$2#.I&]J
i
(Continued)
tn
Submitted Under +dv.iee-*s.-+3-#:( I a sc N o. P A {' - E - 1 3 -{}-1
ISSUED: Oetr+ires-L9-*{}{.7Auoust I 6. 2t} 1 i EFFECTM: January l, 3$-}320I ,.1
Y(ffi{rrrouNrArN
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 39 of 46
Case No. PAC-E-1 3-04
Wtness: J. Ted Weston
foll**+fif* nevision of Sheet No. 12.3
Canceling Third-Fouflh Revision of Sheet No. 12.3
I{igh Pressure Sodium -
Partial Maintenance
Monthlv kWh
$ 12.-r4:i $ l6.a'6.4e
ELECTRIC SERVICE SCI{EDULE NO. 12 - Continued
MONTHLY BILL: (continued)
B. Street Lighting. "Full Maintenance"
SPECIFICATIONS AND SERVICE FOR STREET LIGHTING WITH PARTIAL ANI)
FULL MAINTBNANCE (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 facilities will
be deemed obsolete and must be upgraded at customer expense in order to quali$ 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 arms and luminaires: provided, however, that any costs for
materials which are over and above costs for Company's standard materials, as determined by
the Company, are not included in this Electric Service Schedule. Such extra costs shall be paid
by Customer. Burning-hours of lamps will be controlled by the Company.
(Continued)
High Pressure Sodium -
Full Maintenance
$ 10.{,4 I :$13.+-616 $17.556q
S ubm itted Und er 4{ivi-ae-}+i}.-14-{ * {-'. * *': N *. f ',4 f - F. - 1 3 -t};l
ISSUED:Wl"=:EFFECTWE: January l, #J-14.N)"L1
YI,ffiXIVIOUNTAIN
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 40 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
Sev€"+h-EiefiLRevision of Sheet No. 19.2
Canceling {iix*.k-$*venth Revision of Sheet No. 19.2
ELECTRIC SERVICE SCHEDULE NO. 19 - Continued
MONTHLY BILL:
Rate for space heating:
Billing Months May
through October. Inclusive
Customer
Service Charge:
Energy Rate:
$23.00 per Customer
9.W121 per kWh for all kWh
6(
Billing Months November
through April. Inclusive
$23.00 per Customer
6.$$}}115-3" per kWh for all kWh
9A
Rate for all other serviee:
All other service requirements will be supplied under Electric Service Schedule No. 6, or
Electric Service Schedule No. 6,4., or Electric Service Schedule No. 23, or Electric Service
Schedule No. 23A, or Electric Service Schedule No.35, or Electric Service Schedule No. 35A.
SPACE IIEATING: 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 CONDITIONING: All air conditioning equipment shall be permanently installed and shall be
the sole means of providing comfort cooling for the building space occupied by the Customer. All air
conditioning equipment and installation thereof and all supply wiring shall conform with the Company's
specifications. Electric service for comfort cooling will be metered and billed at the above rate only when
Customer also uses electric service for his total space heating requirements.
WATER HEATING: Water heaters served hereunder shall be insulated storage, single or
multiple-unit type of construction approved by the Company, the heating units of which shall be
noninductive and controlled by separate thermostats. Electric service of storage water heating will be
metered and billed at the above rate only when Customer also uses electric service for his total space
heating requirements.
(Continued)
Subm itted Under Ativ.i€.*+,k,. 4*-tdbd'.*s* hj o. P A (' - L. - I 3 -{}"'1
ISSUED : Au*ott lffi,j{}ctr+b*r49.*$$EFF'ECTM: January 1, +SS:0IJ
Xffififfi:OUNT*N
Rocky Mountain Power
Exhibit No. 3 Page 41 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
.Fift{r-&Revision of Sheet No.23.1
Canceling f**r*trfiifiL Revision of Sheet No.23.1I.P.U.C. No. I
ROCKY MO{'NTAIN POWER
ELECTRIC SERVICE SCIIEDI]LE NO.23
STATE OF IDAHO
General Service
AVAILABILITY: At any point on the Company's interconnected system where there are facilities ot
adequate capacity.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for all
service required on the premises.
MONTHLY BILL:
Billing Months May Billing Months November
through October.Inclusive through April.Inclusive
Customer Service
Charge:
Secondary voltage
delivery (Less than
2300 volts) $16.00 per Customer $16.00 per Customer
Primary voltage
delivery (2300 volts
or higher) $49.00 per Customer $49.00 per Customer
Energy Rate: 9."+-*3411 per kWh for all kWh 484{F'fr per kWh for all kWhwo .a$ifi
(Continued)
Submitted Under *tal..ie*-Fi-:,+*-{}3 Cn se hi o. F A C' - F. - l 3 -(l;l
ISSUED: EFFECTIVE: January l, AS-S?S-"U
J,ROCKYMOUNTAIN-(powen
\ A D,vrsrori OF PACTFTCORP
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 42 of 46
Case No. PAC-E-1$04
Witness: J. Ted Weston
Sif+&-Sixth Revision of Sheet No.23A.1
Canceling eo*xbflftn nevision of Sheet No. 23A.1
ROCI(Y MOT]NTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.23A
STATE OF IDAHO
General Service @esidential and Farm)
AVAILABILITY: At any point on the Company's interconnected system where there are facilities of
adequate capacity for service to any customer who qualifies as a "Residential Load" or "Farm Load" under
both (l) the Pacific Nonhwest 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 Bonneville Power Administration.
APPLICATION: This Schedule is for alternating current, single or three-phase electric service
supplied at Company's available voltage through one metering installation at a single point of delivery for all
service required on the premises.
MONTHLY BILL:
Billing Months May Billing Months November
through October. Inclusive through April. Inclusive
Customer Serryice
Charge:
Secondary voltage
delivery (Less than
2300 volts) $16.00 per Customer $16.00 per Customer
Primary voltage
delivery (2300 volts
or higher) $49.00 per Customer $49.00 per Customer
Energy Rate: 9.+&;*l per kWh for all kWh ;$46+E per kWh for all kWh$2ifi .ttj3.0
(Continued)
Submitted Under 4 tlr,-ie;e i',J o, 1 *-0i r) h{' -f .;'"\ -O ::t
ISSTIED:EFFECTIVE: January l, 3$-}3:0_!l
V/,ROCKY MOUNTAINY(powen
\ ,' D|VISION Of PACIFICORP
I.P.U.C. No. I
Rocky Mountain Power
Exhibit No. 3 Page 43 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
First R*r'ision of Sheet lia. 31.2
{rlnqqliqq, Original Sheet No. 31.2
ELECTRIC SERVICE SCHEDULE NO.31- Continued
MONTHLY BILL:
Rate:
Billing Months May
through October. Inclusive
$370.00 per Customer
$5.70 per kW for all kW
The Facilities Rate applies to the kW
S0.19 all kW Day
Customer Service
Charge:
Back-up Facilities
Rate:
Back-up Power
Rate:
Excess Power
Rate:
Supplementary $10.26 per kW for all kW
Power Rate:
Supplementary 3.e{#$3 per kWh
and Back-up 1.8.?.i
Energy Rate:
Billing Months November
through April. Inclusive
S370.00 per Customer
$4.30 per kW for all kW
of Back-up Contract Power
S0.14 AllkW Day
$7.74 per kW for all kW
3.SSA.{! per kWh
2?,3i
Back-up Power is billed on a per day basis and is based on the fifteen (15)
minute period of the Customer's greatest use of Back-up Power during the
day.
Scheduled Maintenance Power rate is one halt(ll2) of the Back-up Power
Rate.
$20.52 per kW for all kW $15.48 per kW for all kW
POWER FACTOR: This rate is based on the Customer maintaining at all times a power factor of
85% lagging, or higher, as determined 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 % of l%o for every lo/o that the
power factor is less than 85%.
(continued)
EFFECTIYE: January 1, +$1{.2U1
Submitted Under Case No. PAC-E-t}-.}*l3-{};l
ISSUED:@6.2{}13
I.P.U.C. No. I
ROCKY MOUNTAIN
PO\fiIER
A OtVlSrOia Oi PAC:FTCORP
Rocky Mountain Power
Exhibit No. 3 Page 44 of 46
Case No. PAC-E-13-04
Witness: J. Ted Weston
$ix*n-Sgyg$'hRevision of Sheet No. 35.2
Canceling $i*h"giflllRevision of Sheet No. 35.2
ELECTRIC SERVICE SCIIEDULE NO.35 - Continued
MONTHLY BILL:
Customer Service Charge:
Secondary voltage delivery
(Less than 2300 volts)
Primary voltage delivery
(2300 volts or higher)
Power Charge:
On-Peak kW
Energy Charge:
Per kWh for all kWh
Minimum:
$ 67.00 per Customer
$165.00 per Customer
$ 16.45 per kW
4.9fr$es45(,
TIME PERIODS:
On-Peak 7:00 a.m. to 10:00 p.m., Monday thru Friday, except holidays.
Off-Peak 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 will 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 Saturday or Sunday, the
Friday before the holiday (if the holiday falls on a Saturday) or the Monday following the holiday (if the
holiday falls on a Sunday) will 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 determined by measurement. If the average Power factor is found to be less than 85o/o
lagging the Power as recorded by the Company's meter will be increased by 314 of l%o for every l%o that the
Power factor is less than 85%o.
Voltage Discount: Where Customer takes service from Company's available lines of 2,300 volts or
higher and provides and maintains all transformers and other necessary equipment, the voltage discount
based on highest measured Power during the billing cycle will be:
$0.84 per kW
Customer Service Charge plus applicable Demand and Energy charges.
(Continued)
Submitted Under 4eh'iee ;".Jt#r-{13[]ns* hl*" f A['-E-13-{}jl
ISSUED: 0*;{ie*-+{La+t+Au:rusl 1 6" 20 I 3 EFFECTM: January l, 3{}13?_Ql4
ryHFfiffi{vrouNrArN
I.P.U.C. No. 1
Rocky Mountain Power
Exhibit No. 3 Page 45 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
$ix**$eyet*l& Revision of Sheet No.35A.2
Canceling $i&b$i$&_Revision of Sheet No. 35A.2
ELECTRIC SERVICE SCHEDULE NO.35A - Continued
MONTHLY BILL:
Customer Service Charge:
Secondary voltage delivery
(Less than 2300 volts)
Primary voltage delivery
(2300 volts or higher)
Power Charge:
On-Peak kW
Energy Charge:
Per kWh for all kWh
$ 67.00 per Customer
$165.00 per Customer
$ 16.45 per kW
4.q#"r$y6gea
TIME PERIODS:
On-Peak 7:00 a.m. to 10:00 p.m., Monday thru Friday, except holidays.
Off-Peak All othertimes.
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 will 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 Saturday or Sunday, the
Friday before the holiday (if the holiday falls on a Saturday) or the Monday following the holiday (if the
holiday falls on a Sunday) will 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%o
lagging, or higher, as determined by measurement. If the average Power factor is found to be less than 85%o
lagging the Power as recorded by the Company's meter will be increased by 314 of 1%o for every l%o thatthe
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 transformers and other necessary equipment, the voltage discount
based on highest measured Power during the billing cycle will be:
$0.84 per kW
Minimum: Customer Service Charge plus applicable Demand and Energy charges.
(Continued)
Submitted Under Ad+i€+-bi{i:-1*-{}3f ' ase N c. P;\ C - }1- I i -04
ISSUED: S**rbe*-{4'+B+AAusust l{r. l0 ti EFFECTIVE: January 1, !,$-t32i)"1_{
I.P.U.C. No. 1
ROCKY MOUNTAIN
POWER
A OTVTSTON OF PACTFTCORP
Rocky Mountain Power
Exhibit No. 3 Page 46 of 46
Case No. PAC-E-13-04
Wtness: J. Ted Weston
*ighfhilisgh,"Revision of Sheet No. 36.2
Canceling Xishth$er€nttl Revision of Sheet No. 36.2
ELECTRIC SERVICE SCHEDT LE NO.36 - Continued
MONTHLY BILL:
Rate:
Billing Months May Billing Months November
throughOctober.Inclusive throughApril.Inclusive
$14.00 per Customer $14.00 per CustomerCustomer Service
Charge:
On Peak Energy Charge:
Off Peak Energy
Charge:
14.&e45")" per kWh
{t5t,
4.$+.;1"815_i_ per kWh
L(
12.&.$Al)49& per kWhi(
4.49"8a5i{;:l per kWh
i
Minimum Bill: Customer Service Charge.
On Peak:
Summer months-All kWh used from 8:00 A.M. to l1:00 P.M., Monday through Friday,
except holidays.
Winter months-All kWh used from 7:00 A.M. to 10:00 P.M., Monday through Friday,
except holidays.
Holidays include only: New Year's Day, President's Day, Memorial Day, Independence
Day, Labor Day, Thanksgiving Day, and Christmas Day.
Off Peak:
All other kWh usage.
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 will 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.
SEASONAL SERVICE: When seasonable service is supplied under this Schedule, the minimum
seasonal charge will be $168.00 plus energy charges.
CONTRACT PERIOD: One year or longer.
MONTHLY BILLING REDUCTION: Rates in this schedule shall be reduced by the monthly
kilowatt-hour credit adjustment set forth under "Monthly Rates" in the currently effective Electric Service
Schedule No. 34.
(Continued)
Submitted Under Atlviee lio, 1*-[]idlcse Nr:. IrA{'-[- ] 3-{}4
ISSUED : {-}:k}tisr+t|*"{}}*;\llg!t3"1-"]"1,-2! J.j EFFECTM: January l, ?g*2{lll
PAC-E- I 3-04lRocky Mountain Power
August 12,2013
CAPAI Data Request 6
CAPAI Data Request 6
Using the Company's low-income proxy Broup, and based on actual monthly test
year data as referred to in Request No.4, please make the following rate design
model runs:
a. Calculate the effects on the low-income customer proxy group's
monthly bills if the Companyos monthly basic charge were increased from its
curent level to $10, $15 and to $20, (assuming no changes to the existing
commodity rates for the Residential class's two-tiered rate). In responding to this
request, please make the requested calculations at existing rates during the test
year.
b. Assuming no change to the Company's existing monthly basic
charge, calculate the effects on the low-income proxy groups' monthly bills in
comparison to non-low income residential customers (using test year actual
monthly consumption) if the existing two-tiered rate design is changed such that
the consumption amount ofthe first tier is incrrased from the existing 700 kwh
summer block to 800 kWh/month, 1000 kWh and 1200 kWh. Please provide the
same data for the winter block of 1000 kWh if the block were changed to 800
kwh, 1200 kWh and 1400 kWh.
l't Supplemental Response to CAPAI Data Request 6
a. Please refer to Attachment CAPAI DR 6a (provided on May 29,2013) for the
requested monthly bill impact analysis for the low-income customer proxy
group who were under Schedule I in20l2.
b. Please refer to Attachment CAPAI DR 6b I't Supplemental for the requested
monthly bill impact analysis between the low-income proxy group and non-
low-income group under Schedule 1. Since there are almost unlimited
combinations of ltt block and2"d block rates for each block under a revenue-
neutral scenario, the analysis provided two rate design options: Option A
keeps the ratio of the requested l't block and2d block rates same as the ratio
of current I't block aid2"d block rates; Option B keeps the requested I't block
rate same as the current ls block rate. The attachment contains all necessary
billing determinants that CAPAI may use to explore any other rate design
scenarios and the bill impacts.
Record holder: James Zhang
Sponsor: Joelle Steward
Rocky Mountain Poiver
Exhibit No.4 Page 1 of 6
Case No. PAC-E-l$(X
Whess: J. Ted tAlbston
Rocky Mountain Pover
Exhibit No. 4Page2ol6
Case No. PAC-E-1&(X
Wtness: J. Ted Wbston
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Exhibit No. 4 Page 3 of 6
Case No. PAC-E-1}(X
\Mtness: J. Ted Weston
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Case No. PAC-E-l$(X
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Mark C. Moench (ISB# 8942)
Daniel E. Solander (ISB# 8931)
201 South Main Steeq Suite 2300
salt Lake city, utah 841ll
Telephone: [phone]
Facsimile: (801) 22A-3299
Daniel. solander@oacifi com.com
Mark.moeirch@pacifi co{p. com
Attorneys for RoclE Mountain Power
IN TIIE MATTER OF TEE APPLICATION )
oF PACIFTCORP DBA ROCI(Y )
MOUNTATN FOWER TO INITIATE )
DISCT'SSIONS WTTH INTERESTED )
PARTIES ON ALTERNATTVE RATE )
t'r
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cAsE NO. PAC-E-13-04
STIPULATION
: 't r1..: i)
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
PROPOSALS )
)
This Stipulation ("Stipulation') is entered into by and amoag Rocky Moturtain Pow€r, a
division of PacifiCorp ("Rocky Mountain Powed'or the n'Compan/'); Stafffor the ldaho Public
Utilities Commission ("Staff); Monsanto Company ("Monsanto'); PacifiCorp Idaho Industial
Customers ("P[C"); the Snake River Alliance ('SRA'1; Idatro lnigation Pumper Association
("IIPA'); and [daho Consei:nation League. The Community Action Partrership Association of
Idatro ('CAPAI') is an optional signatory. The parties above, including CAPAI if a signatory
are collectively the '?arties".
I. INTRODUCTION
l. The terms and conditions of this Stipulation ars set forth herein. The Parties
agree that this Stipulation r€prresents a fair, just and reasonable compromise of the issues raised
in this procecding aod that this Stipulation is in the publio interest. The Parties recommend that
ExhibitNo. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page 1 of 21
STIPULATION (PAC-E-13-04) - Page I
the Idalro Public Utilities Commission ("Commission") approve the Stipulation and all of is
terms and conditions. See IDAPA 3 I .0 I .0 I .27 l, 272, and 27 4.
II. BACKGROUND
2. The following Stipulation represents an agreement between the Parties on a new
two year rate plan.
3. On March 1,2013, Rocky Mountain Power filed a Notice of lntent to file a
general rate case, and an Application requesting the Commission provide notice to parties
interested in eirtering into rate plan settle,ment dissussions.
4. With a view toward resolving the issues raised in Rocky Mountain Power's
Application in this proceeding representatives of the Parties met on April 19, 2013, and May 2,
2013, pwsuant to IDAPA 31.01.01.271 and272, to engage in settlemsnt discussions.
5. Based upon the settlernent discussions between the Parties, as a compromise of
the positions in this proceeding, and for other consideration as set forth below, the Parties
stipulate and agree as follows, subject to the approval by the Commission of the terms and
conditions of this Stipulation as described below.
III. TERMS OT THE STIPULATION
BASE RATES
6. The Parties agree that the Stipulation is submitted to the Commission in lieu of a
general rate case and, upon approval by the Commission, the Parties agree Rocky Mountain
Power will not file any request with the Commission to increase its base rates in Idatro before
May3l,20l5,withnewratesnoteffectivepriortoJanuary l,20l6,withthedifferenceintiming
ExhibitNo. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page2 of 2l
STIPULATION (PAC-E- I 3-04) - P age 2
taking into consideration the Commission's normal notice and suspension periods for a general
rate case.
7. The Parties agree that base revexrue requiranent for all schedules will be
increased by the uniform percentage amount of 0.77o/o. The Parties further agree that within
each schedule the increase will be recovered by increasing only energy rates by a uniform
percentage amount. These calculations will use 2012 normalized billing determinants and the
rates will be effective January 1,2014. The rates are shown on Attachment I .
8. These rates allow recovery of the 27o/o of the Populus to Terminal tansmission
line investnent that was deemed plant held for future use in Order No. 32196. Commission
Order No. 32432 determined that this investnent is now used and useful and shall be included in
rates on or after January 7,2014. The base rate increase is designed to collect ap,proximately
$2.0 million annually from Idatro custom€rs and is calculated as set forth in the table below.
ho SG Allocation Factor
Plant in Service $
Average Accum Depr Reserve
Net Plant in Service
Revenue Requireme,nt on Plant
Depreciation E;pease
Amortization of Deferred Depreciatiolr
Revenue Requirement $2,015,140
910,652
3
303,551
1,443?lr3
268,477
ECAM
Exhibit No. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page 3 of 2l
STIPULATION (PAC-E-13-04) - Page 3
9. The Parties agree to the inclusion of and paylng for a resource adder for the Lake
Side II generation facility that will be recovered through the ECAM at 100%, for the period that
the investme,r:t in the facility is not reflected in rates as a component of rate base, beginning
January 1, 2015, subject to the Lake Side II generation facility having achieved commercial
operation as of that date. The ECAM deferral will be determined by multiplying the actual
megawatt-hours of generation from the Lake Side II generation facility by $1.99 per megawatt-
hour ldaho Resource Adder as more fully set forth in the table below:
The recovery of the Lake Side II resource adder will be capped after the first 2,729,5A0
megawatt-hours of generation, or recovery of approximately $5.43 million from Idaho customers
through the ECAM,
Pursuant to Commission Order No.32771the Parties have agreed to modiff the ECAM
calculation by rernoving the wholesale sales line loss adjustnent from Monsanto and Agrium's
actual load used to calculate all defenal balanc.es except for the Load Change Adjustment
Exhibit No. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page 4 of 21
STIPULATION (PAC-E-I3-04) - Page 4
Revenue (LCAR) portion of the ECAM deferral. This change will be effective for the ECAM
deferral period starting June 1, 2013 and ending on November 30, 2013.1
Effective December l, 2013, the ECAM deferral will be calculated on a total ldaho basis;
Monsanto and Agrium's share will not be calculated and defened separately. The rates will be
designed based on energy sales data. Specifically, as in past ECAMs, the proposed rates will be
calculated by effectively dividing the total target amount for Idaho customers by the energy sales
data at their appropriate delivery voltage levels.
DEPRECIATION STUDY AI\ID CARBON PLA}IT
10. The Parties request Commission approval of the proposed accounting treatnent
for the Company to establish a regulatory asset that would allow the Company to defer, on a
monthly basis, any aggregate net increffre or decrease in Idaho allocated depreciation expense for
the period beginning on the latter of January l,2Ol4, or the effective date in the Commission
Order approving new depreciation rates, until the date that new depreciation rates are reflected in
customer rates.
I l. The Parties agree that the Company will be allowed to recover or be required to
refund the deferred depreciation expense begrnning on the effective date of the next general rate
case. The balance shall be amortized over a period not to exceed l0 years from the effective date
of the next rate case. The Parties agree that depreciation of the Carbon Plant should not be
included in this deferral.
12. Commission Order No. 32701 authorized the Company to create a regulatory
asset to transfer the rernaining Carbon Plant balances upon retirement from electric plant in
I Accordingly, the deferral period forthe ECAM application to be filed February 7,z}l4,will reflect two
different allocation methodologies. The current allocation methodology will be used for the December l, 201 2,
throughMay3l,2013period. TheproposedallocationwillbcusedfortheJunel,z}l3,throughNovember30,
2013 period.
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 5 of 2l
STIPULATION (PAC-E-13-04) - Page 5
service and accumulated depreciation to be amortized from the date of nansfer to the regulatory
assets through December 31,2020. The regulatory asset as of the date of transfer will include
the un-depreciated book balance assuming that existing depreciation rates were used prior to the
piant retirement date. The difference between the depreciation rate effective in 2014 and the
current depreciation rate based on the prior decommissioning date of 2020 will be included in the
Remaining Carbon Balances regulatory asset until Carbon depreciafion rates are updated in the
next general rate case.
13. The Parties agree to the creation of a regulatory asset for future recovery from
Idatro ratepayers of Idatro's allocated share of the prudently incurred Carbon Removal
Costs. The projected removal costs were identified in the calculation of the new depreciation
expense as part of Case PAC-E-13-02, which is subject to Commission review and approval.
14. The Parties agree that the Company shall be allowed to rec,over from customers
Idatro's share of the prude,ntly incurred Carbon Removal Costs over a reasonable period
determined by the Commission in a future proceeding. The amortization of the Carbon rernoval
costs will begin when the amortization expense is included in rates in the next general rate case.
MONSANTO CONTRACT
15. The Parties agree Monsanto's existing Electric Se,ndce Agreement (the
"Contracf') which currently expires Decernber 3 1, 2013, shall be amended as follows:
l. A new Section 4.4 shall be added and read as follows:
4.4 Interruptible Credit Annual True-up: Beginning January 1,2014, in the
event Measured Dernand in any billing period in any Calendar Year is less than
162 megawatts, the fbllowing calculation shall occur and shall be reflected on the
Billing P€riod immediately following the Calendar Year in question:
4.4.1 If the average of the 12 months of Measured Denrands for the Calendar
Year in question is equal to or greater than l7l megawatts (the sum of 9
megawatts and 162 megawatts), a credit will be provided to Monsanto to
Exhibit No, 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 6 of 2l
STIPULATION (PAC-E-I 3-04) - Page 6
reflect the difference between a total Intemrptible Credit amount based on 162
megawatts of Measured Demand for each Billing Period in the Calendar Year
in question and the actual total Intemrptible Credit amount paid in the
Calendar Year in question. A $50,000 credit shall be added to the true-up in
2014 and2015.
4.4.2 If the average of the 12 months of Measured Demands for the Calendar
Year in question is less than 171 megawatts (the zum of 9 megawatts and 162
megawatts), then no adjustment shall be made, except for the credit of
$50,000 referenced in 4.4.1.
4.4.3 This section 4.4 is intended to reflect a compromise of positions by
Monsanto and Rocky Mountain Power and will not be deerned to set any
precedent or interpretation that is counter to the Commission Order Nos.
32424 and32432.
Monsanto waives any rights to claim any true-up of Intemrptible Credit for any
billing periods prior to January l, 2014, for months in which the Meastred
Demand was below 162 megawatts.
The Company and Monsanto shall enter into a new Elechic Ssrvice Agreement
effective January 1,2014, with an initial term through December 31, 2015. The
new Electric Service Agreernent shall be executed contemporaneously with
Monsanto and Rocky Mountain Power's execution of this Stipulation.
4. Section 4.1 of the contract will be amended to reflect the increase shown in
Attachment I related to Populus to Terminal Transmission line described in
Paragraph 7 above.
16. Monsanto and the Company agree to prepaxe and execute an Electric Service
Agreernent that reflects these changes to the contact and provide it to the Commission for
approval.
17. Monsanto and the Company will continue to work collaboratively and in good
faith to address the terms and conditions and to optimize the value of Monsanto's curtailment
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8l16l13 PageT of 2l
J.
STIPULATION (PAC-E-I 3-04) - P age 7
products to Monsanto and the Company including a discussion of cost of senrice methodologies
as applied to the Monsanto load and how said methodologies could be utilized in the next general
rate case. Monsanto and the Company will report to the Staffand Commission as appropriate on
the progress made.
RATE DESIGN
18. If CAPAI is a signatory to the Stipulation, the Parties agree to the following: the
Parties agree to conduct a rate design collaborative process to evaluate potential changes to rate
design for the Company's residential service, Schedule l, and general service, Schedule 6 and
23. The Parties further agree to meet within one month after the Stipulation is filed to begin the
collaborative discussions. If CAPAI is not a signatory to the Stipulation, the Parties agree that
this Paragraph 18 is ofno effect and does not apply.
IV. GENERAL PROVISTONS
19. The Parties agree that this Stipulation represents a compromise of the positions
of the Parties on all issues in this proceeding. Other than the above referenced positions and any
testimony or comments filed in support of the approval of this Stipulation, and except to the
exte,nt necessary for a Party to explain before the Commission its own statements and positions
with respect to the Stipulation, all negotiations relating to this Stipulation shall not be admissible
as evidence in this or any other proceeding regarding this subject matter.
20. The Parties submit this Stipulation to the Commission and recommend approval
in its entirety pursuant to IDAPA 31.01.01.274. The Parties request that the Commission notice
the filing of the Stipulation and establish a procedural schedule, including public and technical
hearings as necessary, for the review and consideration of the Stipulation by the Commission.
The Parties shall support this Stipulation before the Commission, and no Party shall appeal any
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116/13 Page 8 of 2l
STIPULATION (PAC-E-13-04) - Page 8
portion of this Stipulation or Order approving the same. If this Stipulation is challenged by any
person not a party to the Stipulation, the Parties to this Stipulation reserye the right to uoss-
examine witnesses and put on such case as they deem appropriate to respond fully to the issues
presented, including the right to raise issues that are incorporated in the settlement ernbodied in
this Stipulation. Notwithstanding this reservation of rights, the Parties to this Stipulation agree
that they will continue to support the Commission's adoption of the terms of this Stipulation.
21. In the event the Commission rejects or modifies any part or all of this
Stipulation, or imposes any additional material conditions on approval of this Stipulation, each
Party reserves the right, upon written notice to the Commission and the other Parties to this
proceeding, within 15 days of the date of such action by the Commission, to withdraw from this
Stipulation. In such case, no Party shall be bound or prejudiced by the terms of this Stipulation,
and each Party shall be entitled to seek reconsideration of the Commission's order, file testimony
as it chooses, cross-examine witnesses, and do all other things necessary to put on such case as it
deerns appropriate.
22. The Parties agree that this Stipulation is in the public interest and that all of its
terms and conditions are fair, just and reasonable.
23. No Party shall be bound, benefited or prejudiced by any position asserted in the
negotiation of this Stipulation, except to the extent expressly stated herein, nor shall this
Stipulation be construed as a waiver of the rights of any Party unless such rights are expressly
waived herein. Execution of this Stipulation shall not be deemed to constitute an
acknowledgment by any Party of the validity or invalidity of any particular method, theory or
principle of regulation or cost recovery. No Party shall be deemed to have agreed that any
method, theory or principle of regulation or cost recovery ernployed in arriving at this Stipulation
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 9 of 2l
STIPULATION (PAC-E- I 3-04) - P ase 9
is appropriate for resolving any issues in any other proceeding in the future. No findings of fact
or conclusions of law other than those stated herein shall be deerned to be implicit in this
Stipulation.
24. The obligations of the Parties under this Stipulation are subject to the
Commission's approval of this Stipulation in accordance with its terms and conditions and, if
judicial review is sought, upon such approval being trpheld on appeal by a court of competent
jurisdiction.
By
Respecttully submitted ttris Z{av ot 4,2013,
Rocky Mountain Power Monsanto Company
Idaho Public Utilities Commission Staff Snake River Alliance
By
Idaho Conservation League Idaho Irrigation Pumper Association
By By
Community Action Partnership
Associadon of ldaho
PacifiCorp Idaho Industrial Customers
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 10 of 21
By
STIPULATION (PAC-E-13-04) - Page l0
is appropriato for rosolving any issucs in aay othor proccoding in the futuro. No findingt of fact
or conchuions of law othcr thm thoso gtated hcrcin shall bc dcemod b bo implicit itr this
Stipulation
24, 'lbo obligatiou of thc Parties rnder thir Stipulatiou arc subjcct to tho
Coomissiotr's apprronal of this Stipulatioa in accodaocc with itr tcrms sd coaditioru srd, if
jtldicid rwiew is sougbt, upon such Epproval bcing upheld on appoal by a oourt of compacot
jurisdictiotr
Reepccttu[y submitsd thir 3I6y otfl;y- zott.
ByBy
Ideho Publlc Udlldoc Comnlrrlon Stefi Snr}e Rlvcr Alllance
Idaho Cmreryadon Lerguc Idaho lrrlgedon Pumper Arrocbdon
PdftCorp ldaho Indrudd Curtomcn
By.By.
Bv By
Communlty
Asrochflon
Acfion Prrtncrrhtp
ofldrho
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 11 of 21
STPUITq,TION (PAC-E-13-04) - Page l0
is apropriate for roeolving any issuoa in any other procceding in tho ftturo. No fudings of frot
or concluioas of lsw othcr thao thoss statod hcrch sbsll bc dccmed to bo implicit in this
Sffprlation
24. Ttc obligotions of the Parties rder ttis Stipulation aro subjcct to thc
Cmisaim'a app,roval of thir Stipuladon in amo,rdooo wilh itr kms and oorrditions a4 if
judisial rwiew ir eought, upom such approvtl bciug Whcld oo appool by a oourt of coopetcat
juirdtctim.
Respoctfrrlly submittod eis
-
day of . 2013.
RodryMountrh Dovrer MourrnbConprny
Idrho hDBc Utillflec Commfurion Strff $nake Rlver Alllrncn
,, ,4{h--* -
Idrho Conrervation Leegue Idnho Irrlgafiou Pumper Arsochfl on
By By.
By
Comnuutty Acdon Prrtneroh$
Anodadon of Idrho
PaclftCorp Idaho IndruHel Ctstonen
By.By
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8l16113 Page 12 of 2l
STIPULATION (PAGE-I 3-04) - Page 10
,O
is apnopriate for rcsolvitrg my iomcr in any othcr promoding in tho funrrc. No finilings of frot
or conclugions of law othcr ihrn thoss stdEd hersin shdl be deomod 1o 56 inFlicit itr tbi!
Stipulation.
24. ltc obligtionr of tbe Partieg under this Stiprlation rc subjcct to fre
Comnission's approral of this Sdplatioa in accordaco with iE tcrms ed oonditions m4 if
judidal rwiow ia souglrt, upon suc;h approval boiug uphcld on appoal by a court of compctent
jurisdictio& /
Rcspectfuly submitrd btufuaay ot fufizan.
RockyMountaiu Powor MonmubComprny
By.By
Idelo hrbllc Udltder Cohrnirlior Stefr Sneke Rlver Alllancc
Idrho Couenndoalergue Idrho lrrlgrtfun Pumper Arodrtlou
svf{,, # sv
Comnunlty Acdon Partncnhip
Amodadonof Idaho
By
STIPITLATION (PAC-E-I 3-04) - Pagt 10
PaclfiCorp ldatro Indufrd Curtomen
By
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 13 of 2l
is appropriate for rssolving any issues in any othor proceeding in the firturo. No findinp of fact
or conclusions of low othcr than thoso stated herein shall bo deemed to be implicit in this
Stipulation.
24, Tho obligations of tho Parties undsr this Stipulation are subjcct to the
Commission's approval of this Stipulation in accordanco with its terms and conditions and, if
judicial roview is sought, upon such appmval being upheld on appeal by a court of compotent
juriediction.,z-\)f ,orh.rorr.Respectfullyzubmitted this"-day __r.
RockyMountaln Power Monsauto Company
,, [)D@ u,
Idaho ConsetYaflon League Idrho lrrlga6on Pumpor Assoclstlon
By By.
Idaho Publlc Utllltlee Commlssion Staff Snake Rlver Allirnce
Conrmuulty Actlon Parherrhlp PaclflCorp ldaho tndustrlal Customers
Assoclatlon of Idaho
By By.
Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 14 of 2l
STIPULATION (PAGB-I3-04) -Page l0
is appropriate for resolving any issues in any otha procoeding in the future. No findings of fact
or conolusions of law other than those stated herein shall be deemed to be implicit in this
Stipuladon.
24. The obligations of ths Parties under this Stipulation are zubject to the
Commission's approval of this Stipulation in accordanco with its tenns and conditiolrs and, if
judicial review is sought, upon such appnrval being upheld on appeai by a court of competent
jurisdiction.
Respcctftllysubmittod this _day of .2013.
Rocky Mountain Powor Moneanto Comprny
Idaho Public Udlidcr Commtstion Strff Snake Rlver Alllrnce
By
Idaho Couservadou League
By
Communlty Acfiol Prrtuership
Asroctrtlon of ldaho
PacifiCorp Idrho Industrlal Customerr
By.By.
Exhibit No. 101
CaseNo. PAC-E-13-4
R. Lobb, Staff
8116113 Page 15 of 21
STIPULATION (PAC-E-I 3-04) * Page l0
Attachment 1
Settlement Rate Spread
& Rate Design
ExhibitNo. l0l
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 16 of 21
o
Ell
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Exhibit No. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Page 17 of 2l
..1Eol
==l -6lciS
Attachment I - Settlement Rates
ROCKY MOUNTAIN POWER . STATE OF IDAHO
CASE NO. PAC.E.13-04
Present
Price
Settlement
Price
uU20t4
SCHEDULE NO. t - Residential Service
Customer Charge
All kWh (May - Oct)
<= 700 kWh
> 700 kwh
All kwh (Nov - Apr)
<= 1,000 kWh
> 1,000 kwh
Seasonal Service Charge
SCHEDULE NO.36 - Residential Service Optional TOD
Customer Charge
On-Peak kWh (May - Oct)
OfT-Peak kWh (May - Oct)
On-Peak kWh (Nov - Apr)
Off-Peak kWh (Nov - Apr)
Seasonal Service Charge
SCHEDULE NO. 6/64 - General Service - Large Power
Customer Charge (Secondary Voltage)
Customer Charge (Primary Voltage)
All kW (May - Oct)
All kW (Nov - Apr)
Allkwh
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE NO. 7 - Customer Owned Light
Residential
Charges Per Lamp
16,000 Lumens, HPSV
SCHEDULE NO. 7/7A - Security Area Lighting
Charges Per Lamp
7000 Lumens, MV
20,000 Lumens, MV
5.600 Lumens, HPSV. Co Owned Pole
5,600 Lumens, HPSV, No Co Owned Pole
9,500 Lumens, HPSV, Co Owned Pole
9,500 t,umens, HPSV, No Co Owned Pole
16,000 Lumens, HPSV, Co Owned Pole
16,000 Lumens, HPSV, No Co Owned Pole
27,500 Lumens, HPSV, Co Owned Pole
s r 4.91 $ r s.03
$26.83 927.04
$47.86 $48.23
$17.04 $17.17
$13.56 $13.67
$rg.sr $19.66
$ 16.02 $ 16,15
$25.70 $25.90
$22.88 $23.06
$36.97 537.26
Exhibit No' 101
Case No. PAC-E-I3-4
R. Lobb, Staff
Rt16ll3 Paee 18 of 21
s5.00
1A.7874
14.5630
8.2571
11.1472
$60.00
$ 14.00
14.4027
4.9148
tz.jilg
4.4982
$ 168.00
$37.00
$l r 1.00
$ r4.36
$r r.8l
3.6696 I
$444.00
$1,332.00
($0.6s)
$s.00
10.8759 i,
14.6825 i
8.3249 (,
n.2386 p
s60.00
s14.00
t4.526s (
4:?:,-71 i
12.4087 i
4.5369 I
$ 168.00
s37.00
$l I1.00
$ 14.36
$l l.8l
3.7293 i
s444.00
sl,332.00
($0.6s)
(
i
fi
d
ai
f
I
Page2 of 5
Attachment I - Settlement Rates
ROCKY MOUNTAIN POWER . STATE OF IDAHO
CASE NO. PAC.E-1344
Present
Price
Settlement
Price
Ull20l4
27,500 Lumens, HPSV. No Co Owned Pole
50.000 Lumens, HPSV, Co Owned Pole
50,000 Lumens, HPSV, No Co Owned Pole
16,000 Lumens, HPS Flood, Co Owned Pole
16.000 Lumens, HPS Flood, No Co Owned Pole
27,500 Lumens, HPS Flood, Co Owned Pole
27,500 Lumens, HPS Flood, No Co Owned Pole
50,000 Lumens, HPS Flood, Co Owned Pole
50,000 Lumens, HPS Flood, No Co Owned Pole
8,000 Lumens, LPSV, Enerry Only
13,500 Lumens, LPSV, Enerry Only
22,500 Lumens, LPSV, Energy Only
33,000 Lumens, LPSV, Enerry Only
SCHEDULE NO.9 - General Service - High Voltage
Customer Charge
All kW (May - Oct)
AII kW (Nov - Apr)
Minimum kW Summer
Minimum kW Winter
All kwh
SCHEDULE NO. l0 - Irrigation
Small Customer Charge (Season)
Large Customer Charge (Season)
Post-Season Customer Charge
AllkW (June I - Sept l5)
First 25,000 kWh (June I - Sept l5)
Next 225,000 kWh (June I - Sept l5)
All Add'l kWh (June I - Sept l5)
All kWh (Sept 16 - May 3l)
SCHEDULE NO. ll - Company-Owned Street Lighting Service
Charges per Lamp
5.800 Lumens, High Intensity Discharge
9,500 Lumens, High lntensiry Discharge
16,000 Lumens, High Intensity Discharge
27,500 Lumens, High Intensity Discharge
50,000 Lumens, High lntensity Discharge
9,500 Lumens, High Intensity Discharge - Series I
16,000 Lumens, High Intensity Discharge - Series I
9,500 Lumens, High Intensity Discharge - Series 2
16,000 Lumens, High Intensity Discharge - Series 2
12,000 Metal Halide
$15.14 515.26
$18.89 $19.04$2s.7s $2s.e5
$3s.96 $36.24
$52.79 s53.20
$31.2s $31.49
$34.29 $34.56
$25.71 525.91
$28.68 528.90
$27.88 $28.10
Exhibit No. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Pase l9 of 2'l
s33.48
s5 r .67
$4s.74
$2s.70
$22.88
$36.97
s33.48
$5 r.67
$4s.74
$3.66
ss.4l
s7,52
$9.1 5
$370.00
$ r0.26
s7.74
$ r0.26
$7.74
3.883s I
s 14.00
$4 r .00
$23.00
$s.98
8.s3t2 i
6.3103 (
4.6577 A
7,2164 l,
s33.74
ss2.07
s46. I 0
s25.e0
$23.06
$37.26
s33.74
s52.07
s46. l0
$3.69
s5.45
$7,s8
s9.22
$370.00
s r0.26
s7.74
s10.26
$7.74
3.9283 i
s r4.00
s41.00
$23.00
ss.98
8.6 r06 I
6.3691 (
4.70n i
7.2836 i
Page 3 of 5
Attachment I - Settlement Rates
ROCKY MOUNTAIN POWER. STATE OF IDAHO
cAsE NO. PAC-E-13-04
Present
Price
Settlement
Price
utnol4
19,500 Metal Halide
32.000 Metal Halide
9,000 Metal Halide - Series I
12,000 Metal Halide - Series I
9,000 Metal Halide - Series 2
12,000 Metal Halide - Series 2
SCHEDULE NO. 12E - Customer-Owned Street Lighting Service'Energy Only
Charges per Lamp
33,000 Lumens, LPSV
12.000 Metal Halide
19,500 Metal Halide
32,000 Metalllalide
107,800 Metal Halide
s34.60
s4r.97
s3 r.s2
s36.24
s30.67
s32.38
$9.16
$7.05
$9.6s
s 15. r7
s36.32
$4.01
s2.84
$3.97
$s.91
$ 10.10
$ 15.52
10.2944 i
$9.23
$7.1 0
$9.73
$r 5.29
s36.60
$4.04
$2.86
$4.00
s5.96
$10.18
s 15.64
t0.3745
$6.61
$8.43
$10.12
s r 3.26
s r7.69
s34.87
s42.30
$31.77
s36.s2
$30.91
s32.63
$ r 6.55
522.15
$5.93
$7.63
$12.23
$16.49
s23.00
9.3916
6.9589
q,000 N4etat Halide
5.800 Lumens, HPSV
9,500 Lumens, HPSV
16,000 Lumens, HPSV
27,500 Lumens, HPSV
50,000 Lumens, HPSV
Non-Listed Luminaire - Energy Orrly
Customer Charge Secondary
All kWh (May - Oct)
Allkwh (Nov - Apr)
SCHEDULE NO. 12F - Customer-Owned Street Lighting Service-Full Maintenance
Charges per Lamp
5,800 Lumens, HPSV $6.56
9,500 Lumens, HPSV $8.36
16,000 Lumens, HPSV 510.04
27,500 Lumens, HPSV 513.16
50,000 Lumens, I-IPSV $17.55
SCHEDULE NO. 12P - Customer-Owned Street Lighting Service-Partial Maintenance
Charges per Lamp
lo,ooo Lumens' MV s16.42
20.000 Lumens, MV $21.98
5,800 Lumens, HPSV $5.88
9.500 Lumens, HPSV $7.57
27,500 Lumens,llPSV $12'14
50,000 Lumens, HPSV 516.36
SCHEDULE NO. 19 - Commercial and Industrial Space Heating
s23.00
9.3152 l,
69023 (
ExhibitNo. 101
Case No. PAC-E-13-4
R. Lobb, Staff
8116113 Paee20 of 2l
t,i
Page 4 of 5
Attachment I - Settlement Rates
ROCKY MOUNTAIN POWER. STATE OF IDAHO
CASE NO. PAC-E-13-04
Presenl
Price
Settlement
Price
lfit20t4
SCHEDULE NO. 23l23A - General Service
Customer Charge Secondary
Customer Charge Primary
All kwh (May - Oct)
All kWh (Nov - Apr)
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE NO.35 - General Service - Optional TOD
Customer Charge Secondary
Customer Charge Primary
All On-Peak kW
Ail kwh
Seasonal Service Charge (Secondary)
Seasonal Service Charge (Primary)
Voltage Discount
SCHEDULE 4OO
Firm Energy and Power
Customer Charges
kwh
kw
Excess kVar
Interruptible Energy and Power
kwh
kw
SCHEDULE 40I
Customer Charges
HLH kwh (May-October)
H LH kwh (November-April)
LLH kwh (May-October)
LLH kwh (November-April)
All kW (May-October)
All kW (November-April)
$r 6.00
$49.00
9.1030 p
7.94$ A
$ 192.00
s588.00
(0.43e7) f
s r6.00
s49,00
9.1825 i,
8.01s7 I
s 192.00
ss88.00
(0.43e7) i,
$67.00
$ r65.00
$ r 6.4s
4.9609 (,
$804.00
$ r,980.00
($0.84)
s67.00
$ r 6s.00
s 16.45
4.9015 g
$804.00
s 1,980.00
($0.84)
$ 1,586.00
3.0870 (,
$ 15.91
$0.96
3.0870 (
$ r5.91
$442.00
3.6332 i
3.42t4 (
2.7243 I
2.7243 g,
s r7.60
sr4.l9
s 1,586.00
3.1303 i
$ 15.91
s0.96
3.1303 $
s ls,9l
$442.00
3.6855 d
3.0649 l,
2.7635 (
2.7635 I
s 17.60
s 14.19
ExhibitNo. 101
Case No. PAC-E-I3-4
R. Lobb, Staff
8116113 Page2l of 2l
Page 5 of 5
. -, OrrtlookhintMessage Page I of2
O RB: ID PAC-E-13-01 ho.r.y Mountain Powerrs Response to
CAPAI 6 I
) This sendler is in yotii'
'Randy Budge'(net); Price, Neil (ID PUC) ([e-mail]);
ron@williamsbradbury. com [e-mail]) ; [e-mail]
([e-mail]) ;([e-mail]) ;
([e-mail]) ;
([e-mail]); [e-mail]
(elo@racinelaw. net) ; Randy ([e-mail]. gov)
Solander, Daniel
2 attachments
From: McNay, KaleV
E
EtoI
H
50t
afr?ht
SenE Wednesday, W 29, 2013 11:
To:'Randy Budge';;'gkafi [e-mail]'; Jim.r.srnith@nonsanto.@m';
'rcbert. [e-mail]'1 Nell (ID PUC); [e-mail]$'[e-mail]';
[e-mail];
[e-mail];
Weston, Ted (Ted.W
Tue 6/l l/13 9:54 AM
httns'//sntl lS.mail.live.com/maiMPrlntMessaees.asox?cpids:129r63f3-d2af-l le2-ad2040... 7/13t2013
i * 0utlookhintMessage
Thank you,
I(aley McNay
I
Coordinator, Regulatory Operations
503-8!3-6257
IGe Wattins, Betsy; Bell, Barry; C&T plsoorery; Weston, Ted; Solarder, Danid; Data Request Responsecerftr I
Subjeck ID PAC-E-13-04 Rocky t'toufrtain Pods Response to CAPAI 6
I
I
Attached above is Rocky Mountain f{wefs Response to CAPAI 6 in lD PAC-E-13{r+. Please tet me know
if you have any trouble opening the {ttached file(s).
Page2of 2
https://sntl 329ad38 42at-l I e2-ad20-AD... 7 I 13 12013
PAC-E- I 3-04lRocky Mountain Power
lvlay,2013
CAPAI DataRequest 6
CAPAI Data Requet 6
kwh, 1200 kwh and l4O0 kWh.
Response to CAPAIDete Request 6
Using the Compmy's low-income proxy group, ana {aseA on actual monthly test
year data as refened to in Request No.4, please make ltne fonowing rafe design
model runs: I
a- Calculatethe effects onthe customer proxy group's
monthly bills if the Company's monthly basic charge increased from its
to the existingcurrent level to $10, $15 and to $20, (assuming no
commodity rates forthe Residential class's rate). In responding to this
requesf please make the requested calculations at
year.
ing rates during the test
b. Assuning no change to the Company'f existing monthly basic
charge, calculate the effects on the low-income proxylgroups' monthly bills in
comparison to non-low income residential customers [*irg test year acfual
monthly consumption) if the existing two-tiered rate {esign is changed such that
the consumption amount of the firsttier is increased $om the existing 700 kWh
summer block to 800 kWh/month, 1000 kWh and 1200 kwh- Please provide the
same data for the winter block of 1000 kWh ifthe bld(ck were changed to 800
I
a. Please referto Attachment CAPAI DR 6a forthe monthlybill
impact analysis forthe low-income customer group who wsre under
Schedule I n2012.
b. The Company has not performed the dasi gnana I ysis requested
by CAPAIAs specified in paragraph 18 of the ion if CAPAI is party
to the Stipulation the Company agrees to parti in a collaborative rate
design prccess to evaluate alternatives.
Recordholden James7heng
Sponsor: Joelle Steward
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