HomeMy WebLinkAbout20040622Staffs Answer to Reconsideration.pdft: ;:- 'V r-.
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LISA NORDSTROM (ISB NO. 5733)
WELDON B. STUTZMAN (ISB NO. 3283)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
TELE: (208) 334-0314
(208) 334-0318
FAX: (208) 334-3762
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS INTERIM AND BASE
RATES AND CHARGES FOR ELECTRIC SERVICE.
CASE NO. IPC-O3-
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
COMES NOW the Staff of the Idaho Public Utilities Commission by and through its
attorneys of record and respectfully submits this Answer to Idaho Power Company s Petition for
Reconsideration of issues decided in Order No. 29505 dated May 25 , 2004.
31.01.01.331.05.
IDAP A
Idaho Code ~ 61-626 establishes the right of a public utility to petition for
reconsideration of a Commission final order within 21 days from the date of the order. The
purpose for granting reconsideration is to bring to the Commission s attention mistakes made in
the final order and allow the Commission an opportunity to correct any errors. Washington
Water Power Co. v. Kootenai Envtl. Alliance 99 Idaho 875, 591 P.2d 122 (1979). Idaho Power
has identified computational errors made in Order No. 29505, and those errors are appropriate
for correction in an order on reconsideration. The Company also requests clarification of the
Commission intent regarding a Demand Side Management proposal for Schedule 19
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
customers, and the Commission appropriately may provide clarification in a limited order on
reconsideration. Idaho Power mostly in its Petition, however, renews the same arguments it
made unsuccessfully in its case and post-hearing brief. The Commission should grant the
Company s Petition for Reconsideration only to correct the computational errors and clarify its
intent regarding a Schedule 19 customer DSM program.
THE COMMISSION ACTED WELL WITHIN ITS
RATEMAKING AUTHORITY IN ESTABLISHING A
REALISTIC TAX COST TO BE INCLUDED IN RATES
The first part of Idaho Power s Petition for Reconsideration is devoted to re-arguing
the Company s position on the Commission s determination of a fair and realistic tax cost to be
included in customer rates. In large part, the Company merely misstates or mischaracterizes the
Commission s approach and renews its argument made in its rebuttal testimony and post-hearing
brief. For example, the Company argues "the Commission s acceptance of Staffs use of a five-
year average to calculate test year income tax expense is premised on an intent to recognize the
one-time tax refund the Company received in the year 2002 based on a change in federal tax
methodology which was permitted by the IRS in the Company s tax return for the year 2001."
Petition p. 7. Idaho Power then argues that the Commission "used a past event that will not re-
occur to determine the income tax rate to be used in computing Idaho Power s future income tax
expense and resulting revenue requirement." This is wrong, according to the Company, because
this Commission ha( s J repeatedly refused to base future rates on past events. The Commission
cannot reduce future rates to offset a perceived financial benefit that occurred in the past." The
Company argues "such an attempt is clearly retroactive ratemaking." Petition pp. 7-
First, the Company argues too broadly that future rates cannot be based on past
events.Ratemaking is based on a historical test year which is nothing but past events.
Individual events in the test year are scrutinized for their likely impact on future company costs
and even events outside the test year are reviewed and brought into the test year if they provide a
reasonable indication of expenses going forward. If the Commission could not consider what the
Company actually paid in taxes and instead was forced to use the published tax rates, as Idaho
Power argues, ratepayers would provide millions of dollars in revenues for taxes never paid by
the Company. The Commission s adoption of a five-year average of actual tax expense was a
reasonable method of predicting future tax expenses for Idaho Power.
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
Second, Idaho Power incorrectly argues that the Commission
, "
to support its findings
and conclusions that the Company s customers did not enjoy the benefits of the tax refund.
. .
had to determine that the method change whether in 2001 or 2002, resulted in excessive
earnings for the Company.Petition p. 10. The Company characterizes this as "a retroactive
determination of the Company s current earnings based on a past event." Id. Like the previous
argument, this is nothing more than a mischaracterization of the Commission s intent and
purpose in using a five-year average to assess future tax costs. The goal is to include in customer
rates the appropriate amount, absent a perfect predictor of future events, to collect sufficient
revenue to pay actual tax expenses. In this case, adoption of a five-year historical average is a
reasonable method, and one that falls well within the Commission s authority in determining fair
and just rates , to include a tax expense component in customer rates.
Idaho Power also asserts the Company presented evidence establishing that the
customers did in fact receive a benefit from the huge tax refund in 2002. Because "the tax
deduction coming from the one-time event allowed the Company to defer the rate case for one
year " Idaho Power concludes "the Company s Idaho retail customers (ratepayers) did enjoy the
benefits and share in the refund.Petition p. 11. This is a remarkable assessment of the
Company s unique ability to time its rate case and select the test year to its advantage. From the
customers' perspective , it looks more like the Company calculated the benefit it would reap from
the tax refund was greater than a one year gain from increased rates, and concluded it was
financially beneficial to delay the rate case in an effort to prevent the refund (and lower test year
tax expense) from affecting rates. That is fair enough, if the only objective is financial benefit to
the Company. But it is disingenuous to argue ratepayers materially benefited because the
Company delayed rate increases one year in order to avoid sharing a significant financial gain
with ratepayers.
These arguments included in Idaho Power s Petition for Reconsideration are not new
and do not demonstrate the Commission made errors in Order No. 29505 that need correction on
reconsideration. The Company s request that the Commission grant reconsideration and simply
issue an order reversing its decisions based on the Company s assertions should be denied.
The Company also attempts to present new evidence with its Petition, and also offers
to present additional evidence during a hearing on reconsideration.The new evidence the
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
Company filed with its Petition is parts of an Internal Revenue Service Private Letter Ruling
8525156, set forth at pages 12-13 of the Petition, and four letters from accounting firms. Staff
objects to the new evidence the Company filed with its Petition for Reconsideration.
The Commission s Rule of Procedure 331 requires a petition for reconsideration to
include "a statement of the nature and quantity of evidence or argument the petitioner will offer
if reconsideration is granted." IDAP A 31.01.01.331.01. The rule provides for a statement
description of the proposed evidence, rather than inclusion of the evidence itself, in order to
prevent improper admission of evidence into the record. Idaho Power disregarded the rule and
attached its new evidence to its Petition, which tactic if successful would deny all other parties
an opportunity to evaluate and respond to the evidence. Absent its proper admission into the
record, Idaho Power s new evidence may not be considered by the Commission, and Staff thus
objects to the IRS Private Letter Ruling 8525156 and the four accountant letters attached to its
Petition.
Finally, the new evidence attached to the Company s Petition is duplicative of
evidence it already offered in its rebuttal case. Presumably, it could have been presented to the
Commission, and been available to the other parties, at that time. For these reasons, Staff objects
to the new evidence Idaho Power included in its Petition for Reconsideration.
Idaho Power did also provide a statement of additional new evidence it is prepared to
present at a hearing if the Commission grants reconsideration on the tax expense issue. At page
16 of its Petition, the Company states it can offer evidence on four issues relating to the
Commission s assessment of a fair tax cost component. If the Commission determines to grant
reconsideration to receive additional evidence on the treatment of the Company s actual tax
expenses, Staff agrees a hearing would be appropriate and is prepared to offer additional relevant
evidence, including on the effect normalization of the significant tax refund would have had on
customer rates.
THREE-YEAR RECOVERY PERIOD FOR ADDITIONAL
TAX ASSESSMENT, DISALLOWANCE OF LEGAL EXPENSES,
REMOVAL OF CAPITALIZED INCENTIVE PAY
Idaho Power raises an argument for reconsideration on three discrete accounting
issues, but does not ask for a hearing, nor does the Company propose new evidence on the issues.
Idaho Power merely asks the Commission to change its Order. The first issue relates to the
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
Commission s decision to amortize over a three-year period recovery of a $2.9 million tax
payment resulting from the Company s 1998-2000 tax audit cycle. The Commission cogently
explained the reasons it adopted a three-year recovery period at page 30 of Order No. 29505:
First
, "
ratepayers should pay the amount of the tax deficiencies once, not the entire three-year
deficiency every single year." Second
, "
because the Company s three-year audit cycle allows
for the possibility of tax deficiencies every third year, the Commission finds it reasonable to
average the additional tax deficiencies over a three-year period. This symmetry between tax
expense and collection in rates will allow the Company to recover its legitimate tax costs while
minimizing the potential for over-collection." Order No. 29505 p. 30.
In its Petition for Reconsideration, Idaho Power simply states that "a two-year
amortization period is a more reasonable period" than the Commission approved three-year
recovery period. This assertion alone does not justify granting reconsideration to change the
Commission decision on recovery of the $2.9 million tax payment from the 1998-2000 audit
cycle.
The second accounting issue relates to the Commission s decision to disallow
recovery of legal costs Idaho Power incurred by participating in two different refund cases filed
at the Federal Energy Regulatory Commission (FERC). The Company asserts it "is exposed to a
continuing stream of litigation in both the courts and before various regulatory agencies each
year " and that the $352 544 legal costs for the refund cases occurred in the test year and is
representative of its annual legal expenses. By disallowing recovery of the refund case expenses
the Company implied the Commission is not permitting it to recover usual legal expenses it is
anticipated will occur each year. The Company also argues, noting that the Commission
approved recovery of consultant fees over a five-year period, that the Commission should allow
recovery of the refund litigation expenses over a similar period.
The Company s argument on this issue is little more than a statement of its
disagreement with the Commission s decision, and does not justify granting reconsideration on
the issue. It is clear in Order No. 29505 that, although the Commission did not allow recovery in
rates of the refund litigation costs
, "
the majority of legal costs incurred in 2003 remain in the test
year expenses for recovery.Order No. 29505 p. 28.Thus, the Commission allowed as
recoverable costs usual and normal legal expenses the Company incurs each year. In contrast
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
the refund litigation expenses were unusual and extraordinary, partly due to their "relationship
with trading activities.Id. The FERC cases came about because of the trading practices of
wholesale energy brokers, including IDACORP Energy, a sister subsidiary of IDACORP. Idaho
Power was put in the unusual position of having to defend its interests against the interests of an
affiliated corporate entity. Because Idaho Power s involvement in the cases arose solely because
of the activities of IDACORP Energy and IDACORP, it is untenable to ask ratepayers to pay
unusual legal expenses Idaho Power incurred in the resulting litigation. There is no reason in
law or fact to grant reconsideration on the refund cases litigation expense issue.
The third accounting issue relates to the Commission s decision to eliminate from the
test year all pro forma adjustments the Company made for incentive pay. Idaho Power does not
ask for reconsideration of the decision to eliminate the operating expense portion of the incentive
pay, thus limiting its request for reconsideration to the removal of the capitalized portion. The
Company s test year rate base included $7 741 747 for incentive pay expenses incurred prior to
the test year, and Idaho Power notes the Commission s decision would require it to immediately
record a reduction in earnings in that rate base amount. The Company asks for approval to create
a regulatory asset in the amount of $7 741 747 to be amortized, without interest, over a 20-year
period. The Company also assumes this treatment, if allowed, would permit it to add $387 088
to annual expenses.
Idaho Power does not ask for reconsideration of the merits of the Commission
decision on incentive pay, but only points out that a consequence of the decision has a significant
one-time effect on its earnings. In other words, the Company is asking for additional relief from
a decision of the Commission, but does not argue the decision is legally incorrect. Because the
purpose for reconsideration is to provide an opportunity for the Commission to correct errors in
its final order, the Company s request for additional relief from the Commission s Order is not
proper for review on reconsideration. Idaho Power does not direct attention to factual or legal
errors regarding removal of the incentive pay from the test year, and the Company s request for
relief on reconsideration should be denied.
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
COMPUTATIONAL ERRORS
Idaho Power in its Petition for Reconsideration identifies several computational
errors in Order No. 29505 , which the Company previously identified in a "Notice of
Computational Errors in Establishing the Company s Revenue Requirement." Because
correcting errors in a final order is appropriate for reconsideration, Staff supports approving the
Company s Petition for that purpose. Staff is reviewing the computational errors the Company
has identified, and may ultimately agree with some or all of the changes proposed by the
Company. Staff is committed to working with Idaho Power to ensure the corrections are
accurate and complete. Idaho Power and Staff will submit a statement to the Commission
showing all computational errors that should be corrected in Order No. 29505.
SUMMARY OF STAFF'S ANSWER TO
IDAHO POWER'S PETITION FOR RECONSIDERATION
Consistent with the purpose of reconsideration, Staff believes the Commission should
grant Idaho Power s Petition for Reconsideration to correct computational errors in Order No.
29505. Staff further believes reconsideration of Order No. 29505 is appropriate to clarify the
Commission s intent regarding a DSM program for Schedule 19 customers. Neither of these
objectives for reconsideration requires further evidence, and instead are issues the Commission
can address directly in a final order on reconsideration.
The Company s request that the Commission grant reconsideration and simply issue
an order reversing its decision to establish tax costs based on a five-year average should be
denied. Staff objects to the new evidence on this issue Idaho Power filed with its Petition for
Reconsideration. If the Commission determines to grant reconsideration to receive additional
evidence on the treatment of the Company s actual tax expenses, Staff agrees a hearing would be
appropriate and is prepared to offer additional relevant evidence, including on the effect
normalization of the significant tax refund would have had on customer rates.
Finally, the Commission should deny Idaho Power s request for reconsideration of
the three-year recovery period for the additional tax assessment, disallowance of the refund
litigation expenses, and removal of the capitalized portion of incentive pay. The Company does
not point out factual or legal errors relating to these issues, but merely asks the Commission to
reverse the decisions based on the assertions of the Company.
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
Respectfully submitted this 22nd day of June 2004.
0 ~
Weldon B. Stutzman
Deputy Attorney General
Lisa Nordstrom
Deputy Attorney General
M:IPCEO313 ws Staff Answer to Recall
STAFF'S ANSWER TO IDAHO
POWER'S PETITION FOR
RECONSIDERATION
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF JUNE 2004
SERVED THE FOREGOING STAFF'S ANSWER TO IDAHO POWER'S PETITION
FOR RECONSIDERATION IN CASE NO. IPC-03-, BY MAILING A COpy
THEREOF POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINEMONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
JOHN R GALE
VICE PRESIDENT - REG AFFAIRS
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
PETER J RICHARDSON ESQ
RICHARDSON & O'LEARY
PO BOX 1849
EAGLE ID 83616
DON READING
BEN JOHNSON ASSOCIATES
6070 HILL ROAD
BOISE ID 83703
RANDALL C BUDGE
RACINE OLSON NYE BUDGE BAILEY
CHAR TERED
PO BOX 1391
POCATELLO ID 83204-1391
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
LAWRENCE A GOLLOMP
ASSISTANT GENERAL COUNSEL
S. DEPARTMENT OF ENERGY
1000 INDEPENDENCE AVE SW
WASHINGTON DC 20585
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POTOMAC MANAGEMENT GROUP
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McDEVITT & MILLER LLP
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UNITED WATER IDAHO INC
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BOISE ID 83719-0420
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ADVOCATES OF THE WEST
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NW ENERGY COALITION
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UTILITY RESOURCES INC.
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ECONOMICS DEPARTMENT
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