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Home My WebLink About20121114Errata Petition for Reconsideration.pdfH%HO ECEIVE') POWER An IDACORP company 2012N0V II FM 3:t3 JULIA A. HILTON Corporate Counsel jhiltonidahopower.com UTILITIES 00MM ISSO November 14, 2012 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-12-15 Errata to Idaho Power Company's Petition for Reconsideration Dear Ms. Jewell: Enclosed for filing in the above matter are an original and seven (7) copies of the Errata to Idaho Power Company's Petition for Reconsideration. Very truly yours, Julia A. Hilton JAH :csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 JULIA A. HILTON (ISB No. 7740) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-6117 Facsimile: (208) 388-6936 ihiItonidahopower.com Inordstromidahopower.com RE CE 11 V L- 11112 NOV 14 PM 14 3 (DAHO PUtiL.. UI1LITtES COMMISG Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OFTHE ) APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-12-15 COMPANY FOR A DETERMINATION ) OF 2011 DEMAND-SIDE ) ERRATA TO IDAHO POWER MANAGEMENT EXPENDITURES AS ) COMPANY'S PETITION FOR PRUDENTLY INCURRED ) RECONSIDERATION On November 13, 2012, Idaho Power Company ("Idaho Power') filed its Petition for Reconsideration ("Petition") of Order No. 32667 in the above matter. In that Petition, Idaho Power incorrectly characterized the breakdown of the Idaho Public Utilities Commission's ("Commission") adjustments to its original request. As stated in the Petition, the difference in the amount requested as prudently incurred and the amount approved as prudently incurred is $699,237.50. This consists of a $526,781 accounting related adjustment, an $89,601 (misstated as $83,601) labor expense increase adjustment, and an $82,855.50 (misstated as $88,855.50) A/C Cool Credit Program adjustment. Idaho Power regrets that these figures were inadvertently misstated in the midst of its internal editing process. Because the figures occur throughout the Petition ERRATA TO IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -1 and in order to provide clarity, Idaho Power has attached a red-lined version of its filed Petition as Attachment 1. Idaho Power hereby files this Errata to update the amount it requests as prudently incurred to include the full $89,601 labor expense increase adjustment, thereby respectfully requesting a total determination of $42,558,505.50 ($35,540,120.50 of which are Idaho Energy Efficiency Rider funds and $7,018,385 are Custom Efficiency incentives) 2011 demand-side management expenditures as prudently incurred. DATED at Boise, Idaho, this 14th day of November 2012. L C IV~A_' HILtON Attorney for Idaho Power Company ERRATA TO IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 14th day of November 2012 I served a true and correct copy of ERRATA TO IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Karl Klein Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street Boise, Idaho 83702 Snake River Alliance Ken Miller Snake River Alliance P.O. Box 1731 Boise, Idaho 83701 X Hand Delivered U.S. Mail Overnight Mail FAX X Email karl.kIeincpuc.idaho.ciov Hand Delivered X U.S. Mail Overnight Mail FAX X Email peterrichardsonandoIeary.com qrecicrichardsonandoleary.com Hand Delivered X U.S. Mail Overnight Mail FAX X Email dreadinQmindsprinq.com Hand Delivered X U.S. Mail Overnight Mail FAX X Email botto)-idahoconservation.orQ Hand Delivered X U.S. Mail Overnight Mail FAX X Email kmilIersnakenveralliance.om Chnsta Bear ry, Legal Assistan ERRATA TO IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -3 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASE NO. IPC-E-12-15 IDAHO POWER COMPANY ATTACHMENT 1 JULIA A. HILTON (ISB No. 7740) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-6117 Facsimile: (208) 388-6936 ihiltonidahopower.com lnordstrom(äidahopower.com Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER ) CASE NO. IPC-E-12-15 COMPANY FOR A DETERMINATION ) OF 2011 DEMAND-SIDE ) IDAHO POWER COMPANY'S MANAGEMENT EXPENDITURES AS ) PETITION FOR RECONSIDERATION PRUDENTLY INCURRED ) Idaho Power Company ("Idaho Power" or "Company"), pursuant to RP 331, et seq., and Idaho Code § 61-626, respectfully submits the following Petition for Reconsideration of Order No. 32667, dated October 22, 2012 ("Order"). The Company petitions for reconsideration of (1) the final amount deemed prudent and (2) the Idaho Public Utilities Commission's ("Commission") directive to alter the standards used to assess the prudence of the 2011 Idaho Energy Efficiency Rider ("Idaho Rider") funded labor expense increase. I. BACKGROUND On March 15, 2012, Idaho Power filed an Application requesting that 2011 Company expenditures of $35,623,321 in Idaho Rider funds and $7,018,385 in a IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -1 regulatory asset account (Custom Efficiency incentives) for a total of $42,641,706 were prudently incurred Demand-Side Management ("DSM") expenses. In Orders No. 32512 and 32569, the Commission issued a Notice of Application and Notice of Modified Procedure establishing the comment periods in the case. Commission Staff ("Staff'), the Industrial Customers of Idaho Power, and the Idaho Conservation League intervened and filed comments in the case. In responding to Staff production requests, Idaho Power discovered that $345 had been inadvertently charged to the Idaho Rider rather than the Oregon Energy Efficiency Rider ("Oregon Rider"). The Company explained the error to Staff in discovery requests and, in its Reply Comments, sought a determination that expenditures of $35,622,976 in Idaho Rider funds and $7,018,385 in Custom Efficiency incentives for a total requested determination of $42,641,361 as prudently incurred. On October 22, 2012, the Commission issued Order No. 32667 finding that the Company prudently incurred a total of $41,942,123.50 in 2011 DSM expenses, which included $34,923,738.50 in net Idaho Rider expenses and $7,018,385 in Custom Efficiency Program incentive expenses. The difference in the amount requested ($42,641,361) as prudently incurred and the amount approved ($41,942,123.50) as prudently incurred is $699,237.50. It appears that this $699,237.50 consists of a $526,781 accounting related adjustment, an $89,601 labor expense increase adjustment, and an $882,855.50 NC Cool Credit Program adjustment. The Company seeks reconsideration of the accounting adjustment and the labor expense increase adjustment. Idaho Power does not seek reconsideration of the A/C Cool Credit Program adjustment. IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -2 II. ACCOUNTING ADJUSTMENT Idaho Power believes that the Commission has included an accounting error adjustment that was already reflected in last year's DSM prudence request. Idaho Power believes that this is due to a misunderstanding of some accounting transactions done in 2010 and 2011. In 2010, Idaho Power inadvertently charged $526,781 to the Idaho Rider which should have been charged to the Oregon Rider. In order to correct the error and as part of the 2010 DSM prudence request, Idaho Power reduced the requested amount to be deemed prudent by $526,781. However, the Idaho Rider accounting adjustment was not reflected on the Company's books until 2011. Because the Commission already reflected the adjustment in its determination of prudence of 2010 expenditures, it is not appropriate to also reflect the same adjustment a second time in 2011. Therefore, Idaho Power respectfully requests that the $526,781 be included in the determination of the total amount of DSM expenses that were prudently incurred in 2011 so as not to remove an amount that was already removed last year. III. LABOR EXPENSE INCREASE ADJUSTMENT Idaho Power also seeks reconsideration of the Commission's decision to defer prudence determination on $89,601 related to Staffs quantification of the 2011 Idaho Rider-funded labor expense increase. Based upon the Memorandum of Understanding between Staff and the Company as filed in Case No. IPC-E-09-09 as well as previous years' determination of prudent expenditures, the Company evaluated all Idaho Rider- funded expenditures by incorporating them into the three cost-effectiveness tests. The 2011 Idaho Rider-funded labor expenses were factored into those tests and have been IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -3 proven to be cost-effective. In its Comments, Staff took the position that the Company should not fund wage increases through the Idaho Rider until the increases can be vetted in a general rate proceeding. In response, the Commission's Order declined to decide the reasonableness of the increase in 2011 Idaho Rider-funded labor and directed the Company to work with Staff to determine types of information to provide Staff in order to "better assess the reasonableness of the Company's labor-related expense increase." Order No. 32667 at 9. Idaho Power takes issue with altering the standard for review of such labor expense increases and potentially applying that new standard in a retroactive manner. Idaho Power believes that in this proceeding it is most appropriate for the Commission to determine whether the 2011 Idaho Rider-funded labor expense increase was prudently incurred based upon the same standard of review that occurred in previous years. The Company believes that this is not the appropriate proceeding to add new requirements and retroactively change the method of the evaluation of prudence for Idaho Rider-funded expenditures. While the Company will comply with the Commission's directive to work with Staff to determine appropriate standards of review for assessing the prudence of Idaho Rider-funded labor-related increases, the Company believes that any changes to the standard of review should be applied prospectively. The focus of this proceeding should be on the prudence determination of previously incurred expenditures using historically utilized standards. The Company believes that the 2011 Idaho Rider-funded labor-related expenditures were prudently incurred based upon the methods and standards in place at the time they were incurred. The Company will work with Staff to alter the method of IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -4 evaluation for these Idaho Rider-funded labor-related expenses but asserts that the new method should only be applied going forward. The determination of whether Idaho Rider-funded expenditures were prudently incurred in this case should be based upon the current requirements in place at the time. IV. CONCLUSION Accordingly, Idaho Power respectfully requests that the Commission issue an order approving the $526,781 accounting adjustment and the $8,601 labor expense increase adjustment as prudently incurred. This would lead to a total determination of $42,5528,505.50 ($35,53440,120.50 of which are Idaho Rider funds and $7,018,385 are Custom Efficiency incentives) 2011 DSM expenditures as prudently incurred. DATED at Boise, Idaho, this 13 th day of November 2012. Is' JULIA A. HILTON Attorney for Idaho Power Company IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 13 th day of November 2012 I served a true and correct copy of IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Karl Klein Deputy Attorney General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Dr. Don Reading 6070 Hill Road Boise, Idaho 83703 Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street Boise, Idaho 83702 Snake River Alliance Ken Miller Snake River Alliance P.O. Box 1731 Boise, Idaho 83701 X Hand Delivered U.S. Mail Overnight Mail FAX X Email karLkleincpuc.idaho.qov Hand Delivered X U.S. Mail Overnight Mail FAX X Email peterrichardsonandoleary.com grecinchardsonandolearv.com Hand Delivered X U.S. Mail Overnight Mail FAX X Email dreadinq(mindspring.com Hand Delivered X U.S. Mail Overnight Mail FAX X Email bottoidahoconservation.orq Hand Delivered X U.S. Mail Overnight Mail FAX X Email kmillercsnakeriveralliance.orq Is/ Christa Bearry, Legal Assistant IDAHO POWER COMPANY'S PETITION FOR RECONSIDERATION -6