20150520Reply Comments.pdf

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LISA D. NORDSTROTUI
Lead Couneel
I [e-mail]
May 20, 2015
VIA HAND DELIVERY
Jean D. Jewe!!, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Case No. IPC-E-15-14
2015-2016 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,tr*t,@
Lisa D. Nordstrom
LDN:kkt
Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ ida hopower. co m
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER
COST ADJUSTMENT ('PCA") P7q155
FOR ELECTRIC SERVICE FROM JUNE 1,
2015, THROUGH MAY 31,2016.
CASE NO. |PC-E-15-14
IDAHO POWER COMPANY'S
REPLY COMMENTS
Pii l+: lB
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ldaho Power Company ("ldaho Powe/' or "Company") respectfully submits the
following Reply Comments in response to comments filed by the ldaho Public Utilities
Commission ("Commission") Staff ("Staff') on May 15,2015. ln these Reply Comments,
ldaho Power acknowledges Staffs review and confirmation of the calculations included
in the Company's initial filing, and supports Staffs proposed adjustment to the PCA
deferral balance related to the settlement stipulation ("Stipulation") filed in Case No.
IPC-E-15-15.
I. BACKGROUND
On Apri! 15, 2015, ldaho Power applied to the Commission for an order
approving an update to Schedule 55 based on the quantification of the 2015-2016 PCA
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
to become effective June 1,2015, for the period June 1,2015, through May 31 ,2016. lf
approved as filed, the 2015-2016 PCA would result in an overall revenue decrease of
approximately $10.1 million, or a 0.91 percent decrease over current billed revenue.
On April 28,2015, ldaho Power filed an application ("Application") in Case No.
!PC-E-15-15, requesting Commission approval of a Stipulation entered into between
Idaho Power and Staff regarding certain computational modifications to the true-up
portion of the PCA. As detailed further in the Company's Application in that case, the
Stipulation reflects the culmination of informa! discussions between Idaho Power and
Staff following the closure of Case No. IPC-E-14-16, which was initially opened in 2014
to explore the issue of a potential line-loss bias inherent in the Company's existing PCA
deferral methodology. To address the issue of line-loss bias and to improve the overall
accuracy of the PCA deferral, the Stipulation entered into between ldaho Power and
Staff details modifications necessary to transition from the existing Load Change
Adjustment ('LCA") to a Sales-Based Adjustment ("SBA"), as well as a modification to
the determination of monthly interest accrued on the PCA deferral balance. Because
the PCA modifications agreed upon in the Stipulation are to become effective as of
January 1,2015, approval of the Stipulation would result in a reduction of $1,470,797.50
to the PCA deferral included in the Company's 2015-2016 PCA rates filed in this docket.
On May 15, 2015, Staff filed comments in this docket recommending that the
Commission approve the Company's proposed PCA rates as modified to include the
SBA true-up adjustment. Staff also recommended that the Commission approve the
Company's proposed revenue-sharing amounts, including PCA revenue sharing of
$7,999,145 and a pension balancing account contribution of $16,693,134, as well as the
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
requested $4 million in Energy Efficiency Rider funds to be credited to customers as a
reduction to the 2015-2016 PCA rates. Staff recommended a June 1 effective date for
rates reflecting the above-mentioned SBA adjustment, which Staff provided in
Attachment C to its comments.
II. IDAHO POWER'S REPLY
ldaho Power acknowledges Staffs review and agrees with Staffs conclusion that
the filed PCA components appropriately calculate 2015-2016 PCA rates under the
currently-approved methodology. ldaho Power also supports Staffs recommendation to
adjust the filed $10.1 million reduction to current revenues to include the additional
$1,470,797.50 reduction resulting from the implementation of the terms of the
Stipulation effective January 1, 2015.
As mentioned above, the Stipulation addresses two primary modifications: (1)
transitioning from the LCA to the SBA and (2) modifying the determination of monthly
interest on the PCA deferral balance. By converting to the SBA as of January 1, 2015,
the impact on the PCA deferral balance for the months of January through March 2015
is a reduction of $1,495,026. The modification to the interest determination, on the
other hand, results in an increase to the PCA deferral balance for those same months in
the amount of $24,228.50. The combination of these two adjustments, reflecting the
implementation of all terms of the Stipulation filed in Case No. IPC-E-15-15, results in
the net reduction to the PCA defenal balance of $1 ,470,797.50. ldaho Power supports
this adjustment, and believes Staff appropriately incorporated the terms of the
Stipulation into the Company's filed 2015-2016 PCA rates.
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
ilt. coNcLusroN
ldaho Power acknowledges Staffs review and confirmation of its filed PCA
components, and maintains that the figures comprising its initial filing appropriately
reflect the existing PCA methodology. ldaho Power also expresses its support for
Staffs proposed reduction of $t ,470,797.50 to the filed PCA defenal balance, and
affirms that this adjustment accurately quantifles the January 1,2015, implementation of
the PCA deferral modifications detailed in the Stipulation filed in Case No. IPC-E-15-15.
For these reasons, ldaho Power respectfully requests that the Commission
approve the 2015-2016 PCA rates as detailed in Attachment C to Staffs comments filed
in this proceeding.l
DATED at Boise, ldaho, this 20th day of May 2015.
1ln calculating revised Schedule 55 rates reflecting the proposed $1.47 million SBA adjustment,
ldaho Power's rate calculation model quantified tariff rates that varied in the sixth decimal place from
rates listed in Attachment C to Staffs comments, likely due to rounding differences. ldaho Power agrees
with Staffs general quantification of these rates, and believes the issue of rounding can be addressed in
the context of the Company's compliance filing contingent upon the Commission's final order in this case.
IDAHO POWER COMPANY'S REPLY COMMENTS - 4
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20 day of May 2015 I served a true and conect
copy of IDAHO POWER COMPANY'S REPLY COMMENTS upon the following named
parties by the method indicated below, and addressed to the following:
Gommission Staff
Karl T. Klein
Deputy Attomey General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial 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, Idaho 83703
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