20190514Reply Comments.pdf

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iDAI-{O PUBLICTILITIE$ COMMISSION
An TDACORP Company
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
May 14,2019
VIA HAND DELIVERY
Diane M. Hanian, Secretary
ldaho Public Utilities Commission
472 W est Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-19-10
Fixed Cost Adjustment Rates for June 1,2019, through May 31 ,2020
ldaho Power Company's Reply Comments
Dear Ms. Hanian:
Enclosed for filing in the above matter are an original and seven (7) copies of ldaho
Power Company's Reply Comments.
Very truly yours,
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Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho 5t. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@ idahopower. com
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER FOR AUTHORIry TO
IMPLEMENT FIXED COST ADJUSTMENT
RATES FOR ELECTRIC SERVICE FROM
JUNE 1,2019, THROUGH MAY 31,2020
RECEIVED
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Trnr?1H##i'ffil8u,o*
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E-19-10
IDAHO POWER COMPANY'S
REPLY COMMENTS
ldaho Power Company ("ldaho Power" or "Company") respectfully submits the
following Reply Comments in response to comments filed by the ldaho Public Utilities
Commission ("Commission") Staff ("Staff') and the ldaho Conservation League ("lCL") on
May 7,2019.
Based on its audit and review, Staff recommends the Commission approve the
Company's request as filed and (1) accept the $34,788,276 Fixed Cost Adjustment
("FCA") deferral balance, (2) waive the 3 percent cap on annual FCA increases, and (3)
approve the requested FCA rates. ICL recommends "the Commission defer ldaho
Power's request to increase the FCA until all stakeholders have had an opportunity to
IDAHO POWER COMPANY'S REPLY COMMENTS - 1
ensure ldaho Power's proposal only covers prudently incurred, and fairly allocated, fixed
cost recovery"l and suggests the "current FCA is not addressing disincentives in the
current rate design."2 ln its Reply Comments, ldaho Power reiterates that the Company's
current FCA filing complies with the Commission-approved methodology and affirms the
effectiveness of the existing FCA mechanism.
I. REPLY COMMENTS
The FCA was approved by the Commission as a permanent rate mechanism
through Order No. 32505 in Case No. IPC-E-11-19. !n that order, the Commission
approved the methodology ldaho Power utilizes to determine the authorized level of fixed-
cost recovery and the actual level of fixed costs collected on an annual basis, as well as
the method for calculating the rates to recover from or refund to customers any differences
between the authorized level of collection and the actual level of collection. ln a
subsequent investigation of the FCA mechanism,3 ldaho Power and parties (including
ICL) entered into a settlement stipulation ("Settlement Stipulation") which outlined certain
clarifications and modifications to the FCA methodology, including clarification that
"concerns surrounding the calculation of the FCE and FCC" would be "more effectively
addressed when base rates are reset."4 The Commission issued Order No. 33295
approving the Settlement Stipulation as reasonable and in the public interest.s As
validated by Staffs audit in this current matter, the Company has complied with the
1 ICL Comments at 1.
2 ld. at2.
3 Case No. IPC-E-14-17.
a /d., Settlement Stipulation at 4
s Order No. 33295 at 5.
IDAHO POWER COMPANY'S REPLY COMMENTS - 2
Commission-approved methodology in its calculation of the 2018 FCA balance and the
calculation of the proposed June 1,2019, through May 31 ,2020, FCA rates.
The Company disagrees with ICL's characterization that the FCA mechanism is
not functioning as intended-the FCA has been and continues to be an effective
mechanism to remove the financial disincentive that would otherwise be associated with
ldaho Power pursuing all cost-effective energy efficiency. Through its demand-side
management programs, the Company promotes a portfolio of energy efficiency and
demand response programs available to all customer segments, participates in market
transformation efforts through the Northwest Energy Efficiency Alliance, and offers
several educational and behavioral initiatives, among other activities. ln 2018, the
Company achieved 183,378 megawatt-hours of incremental annual energy efficiency
savings, the fourth largest year of incremental savings since 2002.
II. CONCLUSION
ldaho Power appreciates the opportunity to respond to comments filed in this case
and respectfully requests that the Commission issue an order approving its Application
determining the 2018 FCA deferral balance of $34,788,276 has been correctly calculated
in conformance with Order No. 32505, waive the 3 percent cap on annual FCA increases,
and approve the requested FCA rates with an effective date of June 1,2019.
DATED at Boise, ldaho, this 14th day of May 2019.
D. NORD M
Attorney for !d
IDAHO POWER COMPANY'S REPLY COMMENTS - 3
Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 14th day of May 2019 I 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
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
47 2 W est Wash i ngton Street (837 02)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
X Hand Delivered
_U.S. Mail
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Ch , LegalAss
IDAHO POWER COMPANY'S REPLY COMMENTS - 4