20030512Reply Comments.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
Attorneys for Idaho Power Company
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Boise, Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER COST)
ADJUSTMENT RATES FOR ELECTRIC
SERVICE TO CUSTOMERS IN THE STATE
OF IDAHO FOR THE PERIOD MAY 16, 2003 )
THROUGH MAY 15, 2004
CASE NO. IPC-03-
IDAHO POWER COMPANY'
REPLY COMMENTS
COMES NOW Idaho Power Company ("Idaho Power" or "Company ), by
and through its Attorneys of record, and hereby replies to the comments of the
Commission Staff ("Staff") amdthe Idaho Irrigation Pumpers Association, Inc.
Irrigators
BACKGROUND
On May 8 2003, the Staff and the Irrigators submitted comments
responding to the Company s application for authority to implement this year s Power
Cost Adjustment (PCA). The comments can be divided into four distinct categories.
IDAHO POWER COMPANY'S REPLY COMMENTS , Page
(1 )The first category of comments are those based upon the
traditional PCA audit function of the Staff. These comments by Staff relate to the
examination of PCA accounting entries to verify that Idaho Power s entries were
accurate and appropriately reflect the amounts contained in the FERC accounts that
are tracked within the PCA.
(2)The second category of comments relate to potential adjustments
to PCA computations based upon differences of opinion between Staff and Idaho
Power with regard to how aspects of certain settlements and stipulations should be
reflected within PCA computations.
(3)The third category consists of Staff's recommendations for process
changes that could potentially reduce future PCA expenses and facilitate future PCA
audits. These recommendations have no current PCA computational impact.
(4)The fourth category of comments relates to proposals by Staff and
Irrigators proposal to change the currently approved PCA methodology.
CATEGORY ONE -- AUDIT ITEMS
With only one exception , the Staff's audit verifies that the accounting
entries performed by Idaho Power were accurate and appropriately reflect the amounts
to be tracked in the PCA.
The one exception is noted on Page 4 of Staff's comments. Staff
identifies a missing payment from I E to Idaho Power relating to termination of an
ancillary services contract with Montana Power. The Company agrees with Staff that
this oversight did occur during the 2002/2003 PCA year and an adjustment is
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 2
appropriate. After jurisdictional and Company sharing, the impact of this adjustment
would be $38 370.32. Idaho Power is prepared to make this change.
CATEGORY TWO -- SETTLEMENT ITEMS
(1 )Pricing of Real-Time Transactions Between IPC and IE.
On Page 3 of its comments, Staff correctly notes that Idaho Power
voluntarily offered to finally resolve the remaining real-time pricing question at the
FERC by presenting to FERC two alternative real-time pricing methodologies and
agreeing to use the alternative that provided the more favorable real-time prices to its
customers over the life of the now-terminated IE-IPC Agreement. The Company
expects that the FERC will accept the Company s offer. The weighted-average method
produced the more favorable results for our customers over the life of the IPC-
agreement including the four months relevant to this year s PCA filing, April through
July of 2002. That is why the Company originally proposed this methodology to both
this Commission and the FERC. The Company used the weighted-average method to
price real-time transactions in its voluntary pricing adjustment in last year s PCA filing
and has continued to use that same method in this year s PCA.
In this PCA case , Staff recommends that the Commission accept three
months of real-time pricing using the weighted-average method as proposed by the
Company and recalculate the fourth month, July 2002 , because in that one isolated
month the Staff believes that the alternative high-low pricing method would show a
customer advantage of $50 242.47.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 3
The Company has been consistent in its position before the FERC and
this Commission that it is reasonable to use the most favorable methodology when
assessed over the entire time period. It is not reasonable to use one method one
month and a different method the next. In effect , Staff is requesting that for one month
during the entire time that the real-time transfer price was in effect, a different pricing
method should be used. The cherry picking approach advocated by the Staff is
arbitrary and should be rejected by the Commission.
(2)Double Transmission Payment.
On Page 6 of Staff's comments, Staff discusses $428,625 of additional
revenue it believes should be added to the PCA. The $428 625 additional revenue is
related to third-party transmission expenses associated with a contract where I E sold
spinning reserves to Tri State Electric Cooperative ("Tri State ). IE has paid this
$428 625 amount to third party transmission providers in order to provide the spinning
reserves to Tri State. Obviously, this third-party transmission cost was included in the
price IE charged to Tri State and became part of the corresponding total revenues IE
received. IE and IPC have proposed to the FERC that they flow through all of IE's profit
from the IE-Tri State contract to Idaho Power and its customers. In order to properly
determine the total actual profits received by IE, these out-of-pocket third-party
transmission costs must be deducted from the total Tri State revenues. If this
Commission adjusts the FERC settlement amount by the $428 625 proposed by Staff
then the Company s shareholders will pay these third-party transmission costs twice.
This is not a reasonable result and would constitute an additionallPUC penalty levied
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 4
prior to a full discussion of (1) the facts leading up to the FERC settlement, and (2) this
Commission s authority to levy such an additional penalty.
(3)Departure From Approved 90/10 Split.
Also on Page 6 of its comments , Staff recommends the PCA sharing
mechanism be altered as it is applied to the additional amount of compensation paid to
Idaho Power by IE as a result of the anticipated FERC Settlement. Specifically, Staff
proposes to return to the customers the 10 percent of benefits normally retained by the
Company in such a PCA transaction. The reason given is that Idaho Power should not
receive a financial benefit for its failure in its regulatory responsibilities. The fact is that
the Company has not yet had its opportunity to discuss with this Commission the
reason for the FERC determinations and the lack of impact on Idaho customers
resulting from the Company s failure to file three contracts with FERC. It is premature
to decide now if the Commission should (or legally can) impose an additional penalty for
failure to file contracts with the FERC. Once the FERC determination is final , the
Commission will have the ability to address the three contracts that were the basis for
the settlement and determine if additional compensation is warranted in the context of
Case No. IPC-01-16.
(4)Continuing Credit For IE Contract Benefits.
The Staff also took issue with the Company s proposal to end the $2
million revenue credit being flowed through to Idaho retail customers as a realized
customer benefit from the Agreement for Electricity Supply Management Services with
IDACORP Energy ("IE Agreement"). The record in support of the Commission
approved Stipulation that established the $2 million revenue credit shows that the $2
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 5
million amount was computed on the basis of estimates of cost savings that would.
accrue to Idaho Power as a result of the IE Agreement. Idaho Power agreed to
recognize those cost savings immediately rather than waiting for a general rate case.
Staff cites language from the stipulation that the credit would continue until new Idaho
Power tariff rates were implemented as a result of the next general rate case.
course , the stipulation was predicated on the presumption that the IE Agreement would
still be operational at the time of the next general rate case. As we now know, that is
not the case. A number of factors, including the complete collapse of the electric
energy trading markets, created an impossible situation for IE and Idaho Power to
continue under the Agreement. The IE Agreement has not been functionally
operational since August 1 2002 and the Company filed with the FERC to approve
termination of the IE Agreement on March 17 2003. Despite ending the IE relationship,
Idaho Power continued to flow through the credit throughout the balance of the PCA
year, August 1 2002 to March 31 2003. Idaho Power believes that now is the
appropriate time to recognize the end of the relationship and its legacy ratemaking
impacts.
CATEGORY THREE -- RECOMMENDATIONS NOT
AFFECTING PCA COMPUTATION
In their comments, Staff identifies several recommended changes to
Company processes that have the potential to reduce future PCA expenses or improve
the PCA audit process. These recommendations do not affect the computation of the
current PCA. The first is the Staff's recommendation that the Company issue a Request
For Proposals ("RFP") to solicit proposals for management of the Company s natural gas
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 6
transportation nomination and other natural gas fuel services associated with the
Company s Danskin facility at Mountain Home. While the Company has not undertaken a
formal RFP process in the past, it did compare types and levels of service available from
potential service providers before finally choosing IGI Resources. While completing an
RFP process involves expenditures of both time and money, the Company is willing to
pursue Staff's recommendation to issue an RFP. Idaho Power will keep Staff advised as
to the status of the RFP process as it runs its course.
The second Staff recommendation relates to providing additional
documentation in the Risk Management Committee ("RMC") minutes to explain why
certain hedge transactions are not completed in the same times and amounts as
originally authorized. The Company concurs that it would be a relatively simple matter to
make this documentation explicit in the RMC minutes.
Finally, the Commission Staff Consumer Division recommends that during
this period of difficult economic times the Company encourage its customer service
representatives to continue to work with customers to establish payment arrangements
when customers call the utility stating that they are unable to pay bills in full. Staff also
recommends Idaho Power provide customers with energy conservation information. Both
of these recommendations are consistent with ongoing Company policy and practice and
will continue to be a part of the Company s customer relations activities.
CATEGORY FOUR -- PROPOSED CHANGE TO PCA METHODOLOGY
Both the Staff and Irrigators propose that the Commission modify the
methodology for establishing normalized energy loads used to compute the PCA true-up
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 7
rate. While the Company believes that the approved methodology it used in this filing has
worked well over the life of the PCA, the Company agrees with the Irrigators' position that
if the Commission determines that the methodology for computing the true-up rate should
be re-evaluated for potential change, then a hearing is appropriate. The Company also
believes that due process requires that any change in the approved methodology
resulting from that hearing and related investigation should only be applied
prospectively and not applied to compute the PCA in this proceeding.
The Approved Methodology
As the Irrigators have noted in their comments
, "
each party has its own
version" of the creation and history of the PCA. (Irrigators Comments, p. 2.) While
there may be differences of opinion as to history, there is no dispute among the parties
that the Company s current filing is consistent with the 1993 normalized Idaho
jurisdictional sales methodology previously approved by the Commission. Commission
Staff acknowledges this on Page 11 of its comments , in referring to the Company
filings in 2001 and 2002 as "departing from the approved methodology," i.e. departing
from the methodology used in the current filing.
The Company does not believe that Staff's characterizations of the
historical use of normalized energy consumption utilized by the Commission for
determination of the PCA true-up rate are entirely accurate.
In setting a historical context for the current PCA methodology, Staff's
comments are incomplete in their characterization of the first eight years of PCA true-up
computations. Specifically, in 1994 and 1995, the first two years with PCA true-up
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 8
determinations , the values used to determine the PCA true-up were based upon
normalized system loads that were later determined to be inappropriate in PCA
computations. Idaho-specific loads rather than system loads should have been used
and sales level loads rather than load level loads should have been used. The impact
of this error was that the Company undercollected the authorized true-up amount in
both 1994 and 1995.
For the years 1996 , 1997 and 1998, the Commission determined the PCA
true-up component utilizing 1993 normalized Idaho jurisdictional sales of 10,750,796
MWh. All PCA computations and methodologies relate to 1993 because that was the
test year" on which the PCA was established. In 1999, as a result of a hearing to
address modifications to the FMC contract, the Commission also modified the Idaho
jurisdictional sales value to 10 802 636 for PCA true-up computations. This value was
representative of a modified 1993 normalized level. This value was again utilized and
accepted in 2000. It is clear that throughout this period of time, the Commission
approved methodology for purposes of the true-up computation , was the 1993
normalized Idaho jurisdictional sales.
The Staff comments state that in 2001 and 2002
, "
the Company departed
from approved methodology" when computing the true-up rate. (Staff comments
p. 11.) This statement does not accurately characterize the Company s proposals in
those two years. Rather, as Mr. Said has testified in this case, in both 2001 and 2002
the Company voluntarily offered to deviate from the Commission approved
methodology in an effort to mitigate the impact of high true-up levels on the Company
customers. (Said Direct Testimony, p. 13.) In 2001 and 2002 Staff recognized that the
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 9
Company s offer to deviate from Commission approved methodology harmed no party
other than the Company and recommended Commission acceptance of the Company
offer.
Overcollection - Undercollection
Staff's comments on Page 12 state that if the Commission had not
accepted the Company s offer to deviate from approved methodology, the Company
would have overcollected the approved true-up amounts by approximately $70 million.
No evidence as to how the $70 million figure was derived has been provided. The
Irrigators' comments include an attachment that also shows an estimate of
overcollection of true-up amounts in 2001 and 2002 if the approved methodology had
been used. In its comments , the Irrigators suggest an estimate of overcollection for
2001 and 2002 at $40 million ($15 million in 2001 and $25 million in 2002) if the
Company had not offered a deviation from approved methodology.
In order to evaluate the overcollection estimations presented by the Staff
and the Irrigators in their comments, the Company has also attempted to estimate the
overcollection that might have occurred if the Company had not offered to deviate from
the approved true-up computation methodology in 2001 and 2002. The Company
estimate is that the overcollection could have amounted to $33 million. (If this
hypothetical overcollection is an issue that the Commission intends to pursue further, it
certainly appears that a separate proceeding to reconcile these three differing amounts
would be necessary.
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 10
However, the Company also estimated the undercollection that actually
occurred in 2001 and 2002 as a result of deviating from the Commission approved
methodology. Because actual sales levels during these years were below the levels
offered by the Company for use in true-up rate computations , the Company estimates
that it undercollected the authorized true-up amounts over the last two years by $13
million. The Company has not requested that there should be a retroactive change to
collect that amount , i.e., a true-up of the true-up, but the Company does believe it is
appropriate for the Commission to recognize that the Company s offer to deviate from
the approved methodology has harmed the Company and benefited its customers in
each of the last two years.
The Irrigators' Contention That Idaho Power Has Overcollected Over the Life of
the PCA Is Wrong
In an attachment to their comments , Irrigators argue that, over the life of
the PCA, Idaho Power has overcollected nearly $40 million. This is simply wrong. The
Irrigators' support for this assertion is contained in an attachment to their comments.
The spreadsheet attached to these comments as Attachment 1 is the Company
attempt to show the deficiencies of the Irrigators' analysis. The top half of Attachment
replicates the Irrigators' attachment. The bottom half shows the Company s attempt to
correct for deficiencies in the analysis. Hopefully, having both analyses presented
together will assist the Commission in evaluating the differences.
The first difference between the two analyses, as seen in the rows of the
Attachment 1 analyses, is that the Irrigators did not include 1994. In Attachment 1 the
Company has included 1994. The second difference, also seen in the rows , is that
IDAHO POWER COMPANY'S REPLY COMMENTS, Page
Attachment 1 reflects two PCA rate adjustments in 2001 , the first in May, the second in
October. PCA rates in 2001 and 2002 differed within blocks for Residential customers
in 2001 and PCA rates differed by class in 2002. The Company has attempted to
capture these differences whereas the Irrigators did not.
Within the columns of the Company s Attachment 1 analyses, there are
also some differences. The Irrigators show a constant Historic Normalized kWh that is
not reflective of how PCA true-up rates were historically determined. The Company has
replaced this column with kWh actually utilized by the Commission in the determination
of PCA rates. As a result of the Irrigators using a constant "Historic Normalized kWh"
they next show what the Company can only assume is a hypothetical "Target
Normalized Revenue." The Company has replaced this column with the Commission
approved true-up amounts.
For the column that Irrigators entitle "Actual kWh " it would appear that
Irrigators utilized a January through December look at the Company s actual sales in
kWh. In Attachment 1 the Company replaced these calendar year actuals with PCA
rate period actuals typically from May 16th to May 15th of the following year. The
Company s computation of Actual revenue differs from Irrigators primarily due to the
more specific look at sales levels at the time the various PCA rates were actually in
place.
As a result of the Company s correction of deficiencies in the Irrigators
analysis, it can be seen on Attachment 1 that, rather than the Irrigators' contention that
the Company has overcollected nearly $40 million above Commission approved PCA
true-up amounts over the life of the PCA, the Company has actually undercollected
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 12
nearly $15 million below Commission approved PCA true-up amounts over the life of
the PCA. Thirteen million of that $15 million undercollection has occurred in the last two
years.
Changes To Methodology Should Be Applied Prospectively
As previously noted , in 1994 and 1995, the Company, in its 1996 PCA
filing, notified the Commission that the wrong value had been erroneously utilized for
PCA true-up purposes in each of the previous two years. The Company proposed a
correction to the computations prospectively and also sought to have the ability to
collect amounts that would have been collected had the correct sales level been utilized
in computations. As stated in Order No. 26455 in Case No. IPC-96-05:
The Company not only proposes to correct the
calculation for the 1995/1996 true-up, but to recapture the
difference between the correct and incorrect calculation of the
1994/1995 true up. (Order No. 26455, p. 2.
Staff and the Industrial Customers both agreed with a prospective
correction of the error, but both opposed correction of past errors stating that such
correction was retroactive ratemaking. A middle ground settlement solution was
contemplated. Ultimately, the Commission found:
The Commission agrees that it is more appropriate and
reasonable to calculate the true-up component of the PCA by
dividing the deferred expense balance by the Idaho
jurisdictional sales volume rather than the normalized system
firm load. We find that the use of normalized system firm load
in prior calculations has resulted in the Company under
recovering approximately $333,274 in the 1993-94 true-up and
171 661 in the 1994-95 true up. We agree with the
Company that both the utility and its customers should be
treated with fairness by this Commission. We find that the
alternative proposal , offered by way of settlement , to defer
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 13
implementation of the change in true-up methodology until next
year s true-up presents a fair, just and equitable result. (Order
No. 26455, p. 3.
The Irrigators state that they accept the normalized sales values offered
by the Company in each of the last two years. The Irrigators recognize that they have
received benefits as a result of the Company s offer in each of the last two years. They
would like a similar benefit this year, but would argue that if given the benefit , it should
be even larger. They propose using 2002 normalized sales in the computations this
year, but question whether the 2002 normalization as provided by the Company to the
Staff and Irrigators is appropriate. Irrigators find the values "puzzling" because the
values are 2% less than in 2000. The fact that the Irrigators desire to raise the question
of the proper computation of normalized values highlights the very reason that the
Commission , in approving the current methodology, established a fixed annual energy
amount to utilize when computing the PCA true-up. The Commission intended the PCA
filing evaluation to be primarily an audit function rather than a process that included re-
establishment of facts. Moving to an annual revisiting of the annual energy amount will
likely result in a much more complex and contentious PCA process.
The Company requests that the Commission reject the proposals of the
Staff and Irrigators to change PCA true-up rate computations from the Commission
approved methodology. The Company believes that only the Company has the right to
propose a deviation from Commission approved methodology at those times when it is
clear that only the Company is adversely impacted. Of course, the PCA true-up
denominator is not the only PCA methodologic issue that may require attention. The
Company has pointed out in its most recent filings that during the recent periods of
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 14
extreme market prices and resulting high true-up levels the Company is also adversely
impacted by the fact that carrying charges are no longer computed once the true-up
balance is reflected in rates. Such an interest free loan has been a significant benefit to
customers at the expense of the Company.
In the end , picking and choosing methodologic changes during a PCA
review period will almost always lead to an unfair, unjust, and inequitable result for
some party. The Company demonstrated in each of the last two years a willingness to
be fair with its customers. The reality is that the Company was damaged by its offer
due to undercollection of approved true-up amounts. It is appropriate to now return to
the Commission approved methodology to insure that the Company is not further
damaged.
CONCLUSION
The Company has shown that, except for 2001 and 2002 , over its ten-
year life the PCA has been remarkably evenhanded in its treatment of customers and
the Company. If the Commission desires to consider changes to the currently approved
methodology, sound regulatory policy and legal due process would require that
proposed changes in PCA methodology be addressed in a separate hearing
established to evaluate various aspects of the PCA methodology and any changes
should only be applied prospectively.
IDAHO POWER COMPANY'S REPLY COMMENTS , Page 15
DATED this 12th day of May, 2003 , in Boise , Idaho.
OM~BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S REPLY COMMENTS, Page 16
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of May, 2003, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S REPLY
COMMENTS upon the following named parties by the method indicated below, and
addressed to the following:
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
---X-Hand Delivered
S. Mail
Overnight Mail
FAX
Randall C. Budge
Racine , Olson , Nye, Budge & Bailey
O. Box 1391
Pocatello, Idaho 83204-1391
Hand Delivered
S. Mail
Overnight Mail--X- FAX
GJ.BARTON L. KLINE
-----.J
---X-
CERTIFICATE OF SERVICE
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