20140521Reply Comments.pdf

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An IDACORP CompanY
LISA D. NORDSTROM
Lead Gounsel
[e-mail]
May 21,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-14-05
2014-2015 Power Cost Adjustment - ldaho Power Company's Reply
Comments
Dear Ms. Jewell:
Enclosed for filing in the above matter please find an original and seven (7) copies
of ldaho Power Company's Reply Comments.
Very truly yours,
X,*9.7(,.tt",*-
Lisa D. Nordstro-m
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
I nordstrom@idahopower. com
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
cosr ADJUSTMENT (PCA) RATES FOR
ELECTRIC SERVICE FROM JUNE 1,2014
THROUGH MAY 31,2015, AND TO
UPDATE BASE MTES IN COMPLIANCE
WITH ORDER NO. 33OOO
RHCEll,rEgl
?0,q flAY 2 t Pl,t t: ll9
u T r1?moCi,Y,ii*r i su, o *
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. tPC-E-14-05
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Powe/' or "Company") respectfully submits the
following Reply Comments in response to the comments filed by the ldaho Public
Utilities Commission ("Commission") Staff ("Staff'), the ldaho Conservation League
("lCL"), and the lndustrial Customers of ldaho Power ("lClP") on May 15-16, 2014.
I. BACKGROUND
On Apri! 15,2014, ldaho Power requested that the Commission issue an order
that (1) approves the Company's calculation of new base rates resulting in
approximately $99.3 million of additional base rate recovery of net power supply
expense annually in compliance with Order No. 33000; (2) approves the 2014-2015
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
Power Cost Adjustment ("PCA') recovery amount of approximately $87.5 million, as the
measured deviation from newly established base rates, resulting in a net increase in
annual billed revenue of approximately $27.1 million; and (3) approves a one-time PCA
mitigation measure intended to lessen the impact of this yea/s PCA on customers by
utilizing an additional $16 million of surplus Energy Efficiency Rider funds to offset this
yea/s PCA collection, resulting in an adjusted net increase of approximately $11.1
million to become effective June 1,2014.
II. PCA RATE COMPUTATIONS
The Staff conducted an extensive review and audit of the Company's filing
through multiple rounds of discovery requests and numerous on-site visits. Based on its
review of the Company's case, the Staff verified that the Company correctly calculated
the proposed base rates in a manner that complies with Order No. 33000 and
concluded that the Company correctly calculated the proposed PCA rates according to
the Commission-approved PCA methodology.l Through its audit, the Staff atso verified
that the Company's power purchase and sales transactions and gas transactions during
the 201312014 PCA year "were reasonable and followed Risk Management Committee
recommendations."2 Based on its review, the Staff recommends that the Commission
approve the Company-proposed base rates and PCA rates effective June 1,2014.
Staff suggests that its ability to achieve a thorough review of the Company's
annual PCA filings would be aided by the provision of ldaho Powe/s workpapers in
functionalformat with the initialApplication.3 The Company has an interest in facilitating
a timely and thorough review of its annual PCA filings and is committed to working with
' Staff Comments, pp. 5-15.
'Staff Comments, p. 9.
'Staff Comments, p. 19.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
Staff to identify the desired supporting information and documentation to be filed
concurrently with future PCA requests.
III. PCA METHODOLOGY
While no party to this case found that the Company's proposed rate calculations
included any computational errors, ICIP and Staff both raise concerns with the
Company's application of the Commission-approved PCA methodology. While the
concerns raised by ICIP and the Staff both relate to the true-up component of the PCA,
each issue is quite different. With these differences in mind, the Company responds to
each concern separately.
A. ldaho Power Correctlv lmplemented the Commission's Directive to Include
Actua! ldaho Jurisdictional Sales in the Calculation of the True-up
Gomponent of the PCA Effective June 1. 2013.
ln Case No. IPC-E-13-10, the Commission issued Order No.32821, which
directed the Company to begin using actual ldaho jurisdictional sales in the calculation
of the true-up component of the PCA, effective June 1,2013. lClP acknowledges in its
Comments that the Company complied with the "literal reading of the Commission
Order."4 However, ICIP suggests that "such a reading however creates a possibly
unintended mix of normalized and actual data in the true-up calculation."s The
Company disagrees with lClP's interpretation of the Commission's intent on this issue.
ICIP's concern regarding the "possibly unintended mix of normalized and actual data in
the true-up calculation" is not supported by analysis or a demonstrated understanding of
how the PCA true-up is intended to function. ln fact, implementation of the change from
a normalized sales basis to an actual sales basis in the calculation of the PCA true-up
o lClP Comments, p. 3.
u td.
IDAHO POWER COMPANY'S REPLY COMMENTS.3
component on any day other than June 1 would result in the very "unintended mix of
normalized and actual data" that lClP is concerned about.
The Company believes that the Commission Iiterally and purposefully directed
the Company to implement the change in methodology on June 1 , 2013, to coincide
with the beginning of the 201312014 PCA collection period. The June 1, 2013,
implementation date properly aligned the new method of revenue recognition in the
PCA true-up calculation with the entire 12-month effective period of the 201312014 PCA
rates. lt should also be noted that the Commission Staff verified through its audit that
the "monthly calculated and actual amounts for revenue" used in the true-up
computation were correct.o
B. ldaho Power Correctlv Applied the Commission-Approved Load Chanqe
Adiustment Rate in the Calculation of the True-up Component of the PCA.
Since the implementation of the PCA in 1992, the Company has applied a load
change adjustment (formerly load growth adjustment) to remove the impacts that
changes in load have on net power supply expense ('NPSE"). ln other words, the load
change adjustment "adjusts" actual power supply expenses to reflect normal load
conditions before determining the level of NPSE eligible for recovery or credit through
the PCA. Because the loads directly affect the level of NPSE incurred by the Company,
the load change adjustment has always been based upon changes in load, sometimes
referred to as "loads at generation level."
ln this PCA case, Staff has concluded that because actual line losses in the
201312014 PCA year were less than the line losses assumed in the last rate case, the
Commission should consider modifying the load change adjustment to be based upon
sales rather than loads. According to Staff, its proposed modification would result in a
u Staff Comments, p. 7.
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
$14.2 million reduction to this year's PCA true-up. Staff suggests that the Commission
"hold its decision on the $14.2 million adjustment so the parties can hold a workshop to
evaluate the adjustment and its justification."T
ldaho Power has reviewed Staffs analysis and conclusions related to the load
change adjustment as described in Staffs Comments, and detailed in Attachments D,
E, and F thereto. Based on this review, the Company has a number of technical and
policy concerns. First, the Company believes that the Staff incorrectly calculated its
intended adjustment. Second, while the Company recognizes and appreciates Staff's
desire to further investigate the merits of its proposed adjustment before the
Commission makes a final decision, Idaho Power is concerned that Staff is suggesting
that the adjustment could be applied retroactively, thus undermining the mechanistic
certainty the PCA is intended to provide. As described in greater detail below, the
Company also believes the methodology change Staff suggests could have unintended
retroactive ratemaking impacts.
The Company welcomes the opportunity to explore perceived improvements to
the PCA mechanism that could be applied prospectively. However, it would be
inappropriate and inconsistent with past Commission practices to retroactively apply
such a major modification to a longstanding component of the PCA methodology.
1. The Companv Believes That the Staff lncorrectlv Calculated lts
lntended Adiustment.
A review of Attachment D to Staff's Comments suggests Staff incorrectly
assumes that the difference between June 2012 through May 2013 sales and January
'Staff Comments, p. 14.
8 The Commission has previously reviewed proposed adjustments
separate proceedings and applied changes prospectively. See Case Nos.
28402), AVU-E-00-06 (Order No. 28616), IPC-E-08-07 (Order No. 30563),
30715), and IPC-E-1 2-17 (Order No. 32552).
IDAHO POWER COMPANY'S REPLY COMMENTS - 5
to PCA methodology in
AVU-E-00-02 (Order No.
IPC-E-08-19 (Order No.
2011 through December 2011 loads represents "Line Loss Embedded in Base Rates."
It is inappropriate to compare sales and loads from two different time periods with
differing forecast assumptions and conclude that the difference reflects line losses. lt
would be more appropriate to compare January 2011 through December 2011 loads to
January 2011 through December 2011 sales, the test period used to determine base
rates in the Company's last general rate case. Upon reviewing Attachment E to Staff's
Comments, the Company also found that the Staff incorrectly included demand-
classified Public Utility Regulatory Policies Act of 1978 and demand response costs in
its proposed modification to the load change adjustment included in the PCA true-up.
After correcting for these two errors, the Company recalculated what it believes
represents the Staff's intended adjustment. These corrections result in a reduction to
Staffs proposed adjustment from $14.2 million to approximately $5.9 million.
lncluded as Attachment 1 to these Reply Comments is a revised version of
Staffs Attachment E, which details the Company's corrections to Staff's proposed
adjustment. ldaho Power's revisions to the Staffs adjustment should not be viewed as
an endorsement of the proposed method change; rather, they are provided for
informational purposes only to facilitate discussion of any prospective methodology
changes.
2. lt Would Be lnappropriate and lnconsistent With Past Commission
Practice to Retroactivelv Applv the Staff's Proposed Modification to
the PCA Methodoloqv.
The Staff states that it does not believe that its recommended modification to the
application of the load change adjustment represents a change to the PCA
methodology.e The Company disagrees. ldaho Power believes that Staffs proposal
represents a significant change in methodology to a longstanding component of the
n Staff Comments, p. 16.
IDAHO POWER COMPANY'S REPLY COMMENTS - 6
PCA that has been consistently applied by the Company and approved by the
Commission since the PCA was originally established. Not only does the Staffs
proposed adjustment represent a change in PCA methodology, it would require that the
current, Commission-approved Load Change Adjustment Rate ("LCAR') be recalculated
using a sales denominator instead of a load denominator. The Company correctly
computed 201312014 PCA true-up using the Commission-approved LCAR of $17.64 per
megawatt-hour ('MWh').10 lf the Commission were to accept the Staff's recommended
adjustment to the 201312014 PCA true-up of $14.2 million (or $5.9 million as
recalculated by Idaho Power), it would require retroactively replacing the Commission-
approved LCAR with a rate developed under a new methodology. Recognizing that
actual line losses on ldaho Power's system vary from year to year, it is neither
appropriate nor fair to retroactively implement a change to a longstanding component of
the PCA methodology based on the results in a single year. The merits of the proposed
methodology change should be thoroughly reviewed and, if found to be appropriate,
applied only on a prospective basis.
The Company further believes that the retroactive application of a revised LCAR
would be inconsistent with past Commission practice. The last time the Commission
revised the methodology used to develop the LCAR was in Case No. GNR-E-10-03
("2010 LCAR Case"). ln the 2010 LCAR Case, the Commission adopted a new
methodology for computing the LCAR that continued to utilize loads in the denominator
of the calculation, but revised the cost components included in the numerator. In Order
No. 32206 in that case, the Commission directed ldaho Power to implement the newly
calculated LCAR effective April 1 ,2011, to coincide with the subsequent PCA year. ln
'0 The current LCAR of $17.64/MWh was approved in Case No. IPC-E-1 2-14, Order No. 32585.
IDAHO POWER COMPANY'S REPLY COMMENTS - 7
other words, the Commission directed the Company to apply the new LCAR rate on a
prospective basis.
Retroactive application of the Staff's proposed PCA methodology change would
also invalidate the Company's 2013 revenue sharing computation presented in this
case. Approximately 75 percent of the Staffs PCA true-up adjustment would be
associated with the 2013 calendar year. lf adopted, the Staffs adjustment would
increase NPSE associated with 2013, and thereby reduce 2013 earnings. A reduction
in 2013 earnings would require recalculation of 2013 revenue sharing, which would
result in a reduction to the revenue sharing amount presented for Commission approval
in this case.
For these reasons, if the Commission ultimately finds merit in the Staff's
recommended modification to the PCA methodology, it should only consider applying
such a modification prospectively.
IV. ENERGY EFFICIENCY RIDER
All parties addressed their respective views on the Company's proposal to
transfer surplus Energy Efficiency Rider funds to offset this yea/s PCA. ICL and lClP
are both critical of the Company's pursuit of cost-effective energy efficiency in their
Comments. The Company believes that the criticisms addressed by ICL and lClP are
not supported by the facts. The Staff suggests that the Commission approve the use of
energy efficiency funds as an offset to this year's PCA. However, the Staff proposes
that the crediting of energy efficiency funds be reflected in the "Energy Efficiency
Services" line item on customers' bills.l' The Commission should reject the Staffs
recommendation because it adds unnecessary complexity from an administrative
t' Staff Comments, pp. 17-18.
IDAHO POWER COMPANY'S REPLY COMMENTS - 8
is inconsistent with past Commission practice and could cause customer
A. IGL lnappropriatelv Characterizes Idaho Power's Demand-Side
.,,
ICL incorrectly concludes that the surplus balance in the Energy Efficiency Rider
is due to what ICL perceives as "lackluster energy savings acquisition in 2013 and
subpar forecasts for future savings."12 ICL's conclusion is based upon incomplete and
inaccurate information. ldaho Power agrees that the incrementa! energy savings from
its energy efficiency programs decreased in 2013 as compared to the prior year.
However, ldaho Power's reduced growth in incrementa! energy savings is consistent
with declining energy savings in the Northwest region.13
The decline in growth of incremental energy savings for ldaho Power is due in
part to increased evaluation, measurement, and verification activities, including new
lower deemed-savings amounts approved by the Regional Technical Forum ("RTF').
This decline in energy savings grovtrth may give the perception that the Company has
diminished its efforts toward pursuing DSM activities. This is not the case. ldaho
Powe/s Demand-Side Management 2013 Annual Report ("DSM Report"), filed with the
Commission on March 15,2014, demonstrated that ldaho Power has developed a DSM
portfolio that offers cost-effective energy efficiency programs available to all customer
classes. The Company's continued support and pursuit of cost-effective energy
efficiency activities is evidenced by the customer participation in its DSM programs
offered to the residential class. Of the twelve energy efficiency programs available to
t' lcl Comments, p. 1.
'" Tom Eckman and Gillian Charles, Northwest Power and Conseruation Council, 2012 Regionat
Conservation Achievements and Projects for 2013-2015 - Projects for 2013-2015 Savings by RCP
Reporting Utilities, Memorandum, January 7, 2014. The Memorandum can be viewed via the following
I ink: htto ://www. nwcou nci l. orq/m ed ial69 1 4345/8. pdf .
IDAHO POWER COMPANY'S REPLY COMMENTS.9
the Residential customer class, 8 programs had an increase in customer participation
when comparing 2013 and 2012. "Energy Efficient Lighting" and "See ya later,
refrigerator," the two programs with the largest energy savings for residential customers,
experienced increases in customer participation, while also experiencing a decline in
incremental annual energy savings. Although energy savings and participation have
decreased in the Commercial/!ndustrial programs, both participation and energy savings
increased in the lrrigation Rewards program.
In its Comments, ICL makes several comparisons to the cost-effective energy
savings identified as cost-effective in the Company's most recent Energy Efficiency
Potential Study. ln these comparisons, lCL is inappropriately comparing ldaho Power's
program energy savings to the "economic" potential savings and not to the level of
energy savings ldaho Poweds third-party consultant identified as "achievable."
EnerNOC Utility Solutions Consulting ("EnerNOC"), the third-party company that
developed the tdaho Power Energy Efficiency Potential Study (or "EnerNOC Study")la
dated February 15,2013, defines economic and achievable potential as:
Economic potential represents the adoption of all cost-
effective energy efficiency measures Economic
potential assumes that customers purchase the most
cost-effective option at the time of equipment failure
and also adopt every other cost-effective and
applicable measure.
Achievable potential takes into account market
maturity, customer preferences for energy-efficient
technologies, and expected program participation.
Achievable potential establishes a realistic target for
the energy efficiency savings that a utility can hope to
achieve through its programs.
'a The ldaho Power Energy Efficiency Potentiat Study can be found in ldaho Power's Demand-
Side Management 2012 Annual Report, Supplement 2: Evaluation filed in Case No. IPC-E-13-08 or on-
line at https://www.idahooower.com/pdfs/AboutUs/RatesRequlatorv/Reoorts/60.pdf.
IDAHO POWER COMPANY'S REPLY COMMENTS. 1O
It should be noted that the achievable energy efficiency potential identified in the
EnerNOC Study for 2012 and 2013 was 128,000 MWh and 86,000 MWh, respectively,
(excluding special contract customers and Northwest Energy Efficiency Alliance or
"NEEA" savings). ldaho Power's reported energy savings were 169,107 MWh and
98,632 MWh (excluding NEEA savings and at generation level), respectively, for those
same years. Based on this data, ldaho Power is exceeding what its third-party
consultant defined as "a realistic target for the energy efficiency savings that a utility can
hope to achieve" through its programs. The Company does not view the achievable
savings as identified in the EnerNOC Study as a ceiling for energy efficiency savings
and plans to continue to pursue cost-effective savings beyond what is identified as
"achievable."15
The Company is continually investigating potential new measures and initiatives.
ldaho Power meets regularly with the Energy Efficiency Advisory Group ("EEAG") to
report on its DSM activities and solicit input on its programs. As recently as May 19,
2014, the Company held a workshop with EEAG members and other interested parties
to obtain input and ideas the Company may use to close the gap between the economic
and achievable energy efficiency potentials as identified in the EnerNOC Study with the
express goal of obtaining greater energy efficiency savings.
B. lClP tncorrectlv Represents the Commission's Statement in Order No.
33016 Regarding The Suspension of ldaho Power's Demand Response
Proqrams.
ln its Comments, lClP incorrectly represents Commission Order No. 33016
issued in Case No. IPC-E-13-21 to support its recommendation to reduce the Energy
Efficiency Rider percentage from 4 percent of base revenues to 3 percent. While the
" The ldaho Power Energy Efficiency Potentiat Study, Executive Summary, p Vl (p. 434 of
Supplement 2: Evaluation of ldaho Power's Demand-Side Management2012 Annual Report).
IDAHO POWER COMPANY'S REPLY COMMENTS - 11
Company believes that lClP's proposal to modify the Energy Efficiency Rider
percentage is well beyond the scope of this proceeding and should be rejected by the
Commission, it is important that the record in this case properly characterizes the facts
with regard to the referenced order.
lClP incorrectly represents Order No.33016 as stating that "The Company has
made what the Commission has termed, 'a business decision' footnote omitted] to
curtail its DSM programs, while at the same time it proposes to continue to collect from
ratepayers funds for programs it does not intend to implement."16 Page 5 of Order No.
33016 actually states, "ldaho Power made a business decision to suspend its demand
response programs." ln fact, with Commission approval, ldaho Power temporarily
suspended two out of three of its demand response ("DR') programs, which
successfully saved customers nearly $10 million at a time when there was no near-term
need identified for those programs. The temporary suspension allowed ldaho Power
and stakeholders to collaboratively determine how these programs should be designed
and implemented in the future. The result of this collaborative process was a settlement
stipulation in Case No. IPC-E-13-14 that was approved by the Commission in Order No.
32923. Consistent with the terms of the settlement stipulation, all three DR programs
are currently active and will be used in the summer of 2014.
lClP's recommendation to reduce the Energy Efficiency Rider in this case has no
basis in fact. The Company has not discontinued any of its DSM programs and the
incentive expenses associated with the DR programs referenced by ICIP are not funded
by the Energy Efficiency Rider. However, should lClP continue to believe that a
reduction in the Energy Efficiency Rider percentage is warranted, it may file an
'u lclP Comments, p.4.
IDAHO POWER COMPANY'S REPLY COMMENTS - 12
application with the Commission requesting such a reduction. This would allow all
interested parties an opportunity to consider the request and participate in the filing.
C. Staff's Proposal to Refund the Enerqv Efficiencv Funds Adds Unnecessarv
Complexitv.
Staff recommends that the Commission approve the Company's request to
transfer $20 million from the Energy Efficiency Rider to offset this year's PCA.
However, Staff recommends that the transferred funds be credited to customers as a
reduction to the "Energy Efficiency Services" line item of the bi!! for the upcoming PCA
year, using the rates for each customer class as the Company calculated." Staff points
out that the financial effect on customers' bills is the same under both the Company's
and the Staffs refund methods.ls Staffs recommendation is unnecessarily complex
and could result in customer confusion.
Reintroducing the combination of a fixed charge per kilowatt-hour ("kWh") with
the energy efficiency percentage is counter to concerns expressed by Staff in a
previous case. In Case No. IPC-E-11-19, Staff addressed the concept of combining a
fixed charge per kWh and the Energy Efficiency Rider, which is based on a percentage
of base rate billing components. ln its Comments, Staff stated the difference between
the Energy Efficiency Rider at 4 percent of base rate charges and the Fixed Cost
Adjustment ("FCA") as a fixed charge per kWh increases the complexity of the
calculation for customers trying to verify that their bills are correct.le ln that same case,
Staff recommended that the FCA component be removed from the Energy Efficiency
Services line item, as a simple step to improve customers' understanding of the
" Staff Comments, p. 18.
" rd.
" Case No. IPC-E-11-19, Staff Comments, p. 11.
IDAHO POWER COMPANY'S REPLY COMMENTS. 13
components that make up the total bill.2o The Company agrees with Staff's previously
stated view and believes that reintroducing a fixed charge per kWh to the Energy
Efficiency Rider would add unnecessary complexity to customers' bills.
ln Case No. !PC-E-1O-27, the Commission authorized the recovery of DSM-
related expenses through the PCA line item.21 ln this case, instead of increasing the
PCA rates due to a deficit in Energy Efficiency Rider funds, as was approved by the
Commission in Order No.32217, the Company is requesting to reduce the PCA rates
due to a current surplus in Energy Efficiency Rider funds. As previously stated, the
financial effect on customers' bills is the same under both the Company and the Staff's
refund methods. The added complexity of Staffs proposal is unwarranted. The
Company continues to recommend that its proposa! for mitigating the PCA be approved
as filed.
V. CUSTOMER COMMUNICATION
The Companv's Customer Notice Complies with Gommission Rules of Procedure
and is a Low-Gost Method of Notification.
Staff expressed concern about the timing of the Company's customer notice
regarding the PCA.22 Rule 125.O3 of the Commission Rules of Procedure allows for
customer notices to be mailed to customers as bill stuffers over the course of a billing
cycle. ldaho Power is in compliance with this Rule and normally includes the customer
notices as a bill stuffer in customers' bills. The Company uses this approach simply
because it is a cost-effective method of notifying customers of rate changes associated
with the PCA mechanism. For estimating purposes, using the current United States
20 Case No. IPC-E-11-19, Staff Comments, pp. 10-11.
" Order No. 32217, p .6.
" Staff Comments, p. 21.
IDAHO POWER COMPANY'S REPLY COMMENTS - 14
Postal Service postage rate of 49 cents per piece of First-Class mail, sending a
separate mailer to 460,000 customers would cost more than $225,000 in postage alone.
The Company avoids this incremental cost by including the customer notices in the bills
that are already being mailed.
lf the Commission prefers that ldaho Power incur the additional costs of a
separate direct mailing to facilitate customer notice of its PCA filing, the Company would
expect to recover such costs from customers. Staff also expressed concern that the
Company includes information about its fuel mix in its PCA customer notices.23 While
the Company believes that the fuel mix information is pertinent to the PCA filing
because the fuel mix is the significant driver of the PCA, the Company once again is not
opposed to working with Staff to determine the appropriate information to include in
PCA customer notices.
VI. CONCLUSION
The Company welcomes the opportunity to explore perceived improvements to
the PCA mechanism that could be applied prospectively. However, it would be
inappropriate and inconsistent with past Commission practice to retroactively apply
Staff's proposed change to the PCA methodology presented in this case. The
Company disagrees with ICL's claim that the surplus balance in the Energy Efficiency
Rider is a result of "lacklusted' DSM acquisition.
Based on an extensive review of the Company's case, the Staff has verified that
the Company correctly calculated the proposed base rates in a manner that complies
with Order No. 33000 and concluded that the Company correctly calculated the
proposed PCA rates according to the Commission-approved PCA methodology. ldaho
Power reaffirms its request that the Commission issue an order that (1) approves the
23 ld.
IDAHO POWER COMPANY'S REPLY COMMENTS - 15
Company's calculation of new base rates resulting in approximately $99.3 million of
additional base rate recovery of net power supply expense annually in compliance with
Order No. 33000; (2) approves the 2014-2015 PCA recovery amount of approximately
$87.5 million, as the measured deviation from newly established base rates, resulting in
a net increase in annual billed revenue of approximately $27.1 million; and (3) approves
a one-time PCA mitigation measure intended to lessen the impact of this yea/s PCA on
customers by utilizing an additional $16 million of surplus DSM Energy Efficiency Rider
funds to offset this year's PCA collection resulting in an adjusted net increase of
approximately $1 1 .1 million to become effective June 1,2014.
Respectfully submitted this 21't day of May 2014.
IDAHO POWER COMPANY'S REPLY COMMENTS - 16
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on the 21" day of May 20141 served a true and correct
copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Karl T. Klein
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-0074
lndustria! Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
ldaho Conseruation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
Boise, ldaho 83702
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, ldaho 83204-1391
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
_Hand Delivered
U.S. Mail
Overnight Mail
FAXX Emai! [e-mail]
FAXX Email [e-mail]
ldaho lrrigation Pumpers Association _Hand Delivered
Eric L. Olsen U.S. Mail
RACINE, OLSON, NYE, BUDGE, & _Overnight Mail
IDAHO POWER COMPANY'S REPLY COMMENTS - 17
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 4r'.140
_Hand Delivercd
_U.S. Mail
Ovemight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S REPLY COMMENTS . 18
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-14-05
IDAHO POWER COMPANY
ATTACHMENT 1
IDAHO POWER COMPANY
MODIFIED STAFF BASE RATE OVER COTTECTION ADJUSTMENT
COMPAJTIY MODIFICANOilS HIGHUG}ITED FI GRAY
Adjustment for Non-QF Deferral ldaho otal
\ctual ldaho Non-QF NPSE (Sl s238.430.561 s226.s09.033
lecovery of Actual ldaho Non-QF NPSE
Recovery of Actual Non-QF NPSE through Base Rates
ldaho Non-QF NPSE Embedded in Base Rates (S)
Annual ldaho Base Sales from 2011 GRC (Sales @ Customer Meter - MWh)
Non-QF NPSE Base Rate (S/MWh)
ldaho Actual Sales for PCA Deferral Period (@ Customer Meter - MWh)
s125,890,058 s119,595,555
r ? acR Rei
S8.86
t3.847.795
Revenue Collected through Base Rates (S)5L22,686,7LG 5L22,686,7tG
Recovery of Actual ldaho Non-QF NPSE through PCA
Company Proposed Non-QF Deferral (before Sharing - $)
Non-QF NPSE portion of LCAR (S/MWh)
Load Chanee (MWh)
Company Proposed LCA Deferral - NPSE Portion Only ($ - Before Sharing)
fotal Recovery of Actual Non-QF NPSE
)ver/(Under) Collection before Sharing
)verl(Under) Collection with Sharing
s112,540,503
S8.10
36,467
s106,913,478
( S280,s74( s 29s,34 1
Sharing =9SYo
5229,379,620
52,8to,s87
s2,670,0s8
Adjustment lor fixed Production CoStot
\ctual ldaho Enercv-Classified Fixed Production Cost (Sl s109,080,s3s S109.o80,s3s
lecovery of ldaho Energy-Classified Fixed Production Cost
Recovery of Actual Energy-Classified Fixed Production Cost through Base Rates
ldaho Energy-Classified Fixed Production Cost Embedded ln Base Rates (S)
Annual ldaho gase Sales from 2011 GRC (Sales @ Customer Meter - Mwh)
Energy-Classified Fixed Production Cost Base Rate (S/MWh)
ldaho Actual Sales for PCA Deferral Period (@ Customer Meter - MWh)
s109,080,s3s
13.498.89i
s8.08
L3.847.795
Revenue collected through Base Rates (S)S111,899,916 S111,899,916
Recovery of Energy-Classified Flxed Production Cost through PCA
Fixed Cost Portion of LCAR (S/MWh)
Load Chanee (MWh)
Company Proposed LCA Deferral - Fixed Cost Portion Only (S - Before Sharing)
fotal Recovery ldaho Fixed Cost Portion of Energy Classified Production Rev Req
)ver/(Under) Collection before Sharing
)ver/(Underl Collection with Sharing
s7.36
36,467
(s 268,3 2e)
Sharing =9SYo
$754,977
S111^645p04
52,s64,469
52,436,246
for QF Deferral
\ctual QF NPSE s133.003.093 s125.352.938
lecovery of QF NPSE
Recovery of QF NPSE in Base Rates
Demand-Related QF Costs Embedded in Base Rates (IIot Subiect to LCAn)
Energy-Related QF Costs Embedded in Base Rates (Subiect to LCARI
Annual ldaho Base Sales from 2011 GRC (Sales @ Customer Meter - Mwh)
Energy-Related QF cost Base Rate (S/MWh)
ldaho Actual Sales for PCA Deferral Period (@ Customer Meter - MWh)
s28,987,7L9
s33,863,73s
s2zs3&333
532,L70,s48
13.498.89i
S2zs3&333
s2.38
73.U7.795
Enerty-Related Revenue Recovered through Base Rates (S)s33.002.0s3 s33.002.0s3
Recovery of QF NPSE through PCA
Company Proposed QF Deferral ($ - before sharing)
QF NPSE portion of LCAR (S/MWh)
Load Chanse (MWh)
Company Proposed LCA Deferral - QF NPSE Portion Only (S - Before Sharing)
Sharine for LCAR Onlv
rotal Recovery of qF NPSE (Sl
Cver/(Under) Collection before sharing ($)
Cver/(Under) Collection with sharing ($l
s70,1s1,639
s2.18
36,467
(s79,44s)
566,644,O57
s75.473
Sharing =too%
(57s,473
5t27,ro8,977
S7s6,033
s7s5,033
Mjustment for DSM lncentive Deferral (llot Subject to ICARI so
Total Over Collection Adiustment Ss,852,335