20211027Application.pdf

USA D. NORDSTROM
Lead Counsel
[e-mail]
October 27,2021
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
Re: Case No. IPC-E-21-36
Application to lmplement the Residentia! and Small Farm Energy Credit
Eftc{ive January 1, 2022 Through December 31, 2023
Dear Ms. Noriyuki:
Attached for electronic filing, pursuant to Order No. 35058, is ldaho Power Company's
Application in the above entitled mafter.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely
iii:iIivHo
iilil CiT 27 P$ 3:00
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Lisa D. Nordstrom
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P.O. Box 70 (83707)
tzlt W. H.ho St.
Boisc, lD 8:1702
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Enclosures
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO PO\A/ER
COMPANY'S APPLICATION TO
IMPLEMENT THE RESIDENTIAL AND
SMALL FARM CREDIT EFFECTIVE
JANUARY 1,2O2?THROUGH
CASE NO. IPC-E-21-36
APPLICATION
DECEMBER 31 2023
ldaho Power ("ldaho Power" or "Company") respectfully applies to the ldaho
Public Utilities Commission ("Commission") pursuant lo ldaho Code S 61-502, S 61-
503, and RP 052, and hereby respectfully submits this application ('Application') to
implement the Bonneville Power Administration's ("BPA') residential and small farm
credit of 0.2534 cents per kilowatt-hour ("kwh') effective January 1, 2022 through
December 31, 2023. The credit rate represents a $5,942,001 decrease to eligible
customers in ldaho as compared to the BPA fiscal year 2020-2021 period.
ln support of this Application, ldaho Power represents as follows:
APPLICATION.l
I. BACKGROUND
1. ldaho Power is a public utility supplying retail electric service to
approximately 600,000 customers in southern ldaho and eastern Oregon. ldaho Power
is subject to the jurisdiction of this Commission in ldaho and to the jurisdiction of the Public
Utilaty Commission of Oregon.
2. Under the terms and conditions of the Pacific Northwest Electric Power
Planning and Conservation Act (commonly known as the "NW Power Act"), BPA has
established a Residential Exchange Program ("REP") that permits Northwest
investor-owned utilities ("lOUs") to exchange power they have purchased or
generated for lower-cost power generated by BPA.I The exchange itself is a paper
transaction through which benefits from the federal Columbia River power system are
passed to qualifoing residential and small-farm customers of participating Northwest
lOUs.
3. REP implementation has been litigated multiple times since the NW
Power Act was enacted. ldaho Power, BPA, other IOUs, public utility districts, and
municipalities in the Northwest are parties to the REP Settlement lmplementation
Agreement2 that determined the level of REP benefits the Company receives for the
period October 1,2011 through September 30,2028.
II. BPA REP RATE
4. Currently the rate in Electric Service Schedule 98 - Residential and Farm
Energy Credit, ("Schedule 98"), is $0.003617 per k\ /h. This credit was established in
I 't6 U.S.C. S 839c(c). See Assoc. of Pub. Agency Cusfomers v. Bonneville Power Admin. (APAC v.
BPA),733 F.3d 939,945 (gth Cir.2013).
2 The ldaho Commission approved the REP Settlement Agreement in April 2011.
APPLICATION- 2
2019 based on an annual BPA REP credit ot$22,929,888 to eligible ldaho customers.
The current rate was approved by the Commission at its public decision meeting held
on December 17 ,2019 and was effective January 1, 2020.
5. Although the Settlement Agreement established fixed annual benefits in
total for BPA fiscal years 2012 through 2028, these benefits are allocated to the
utilities based upon each utility's Average System Cost ('ASC") in comparison to
BPA's Priority Firm Exchange Rate ("PF Exchange Rate'),3 and upon a two-year
average of the utility's historical eligible residential and small farm loads. A utility's
ASG and the resulting benefits are determined through an ASC filing and review
process administered by BPA and conducted every two years.
6. As a result of the ASC review conducted for BPA's Fiscal Years ('FY")
2020 and 2021, ldaho Power's ldaho and Oregon residential and small farm
customers received $22,292,128 of annual benefits for the two-year period beginning
October 1,2019. On November 15,2019, ldaho Power filed Tariff Advice No. 19-11
with the Commission to increase the rate on Schedule 98 effective January 1, 2020,
whereby ldaho residential and small farm customers would receive a credit on their
power bills for the period January 1, 2020 through December 31, 2021. That tariff
advice was approved by the Commission at its public decision meeting held on
December 17,2019.
3 APAC v. BPA,733 F.3d at 945-46.
APPLICATION.3
7. BPA issued the FY 2022-2023 (October 2021 through September 2023)
final ASC report for ldaho Power in July 2021.4 Table 1 below shows a comparison
of the ASCs for the six Northwest lOUs between the current and most recent period.
Table 1
Utilitv FY2O22-239 F12020-21 lncr/(Decr)
Avista
ldaho Power
NorthWestern Energy
PacifiCorp
Portland General Electric
Puget Sound
$ 62.93 $$ 58.17 $
$ 68.34 $$ 77.61 $$ 70.0e $$ 67.28 $
$ (4.67)
$ (6.24)
$ ('14.57)
$ (1.821
$ (7.44)
$ $.441
67.60
u.41
82.91
79.43
77.53
75.72
8. ldaho Power's final ASC for the FY 2022-2023 exchange period is
$58.17 per megawatt-hour ("M\ /h'). Because ldaho Power's exchange period ASC
exceeds BPA's PF Exchange Rate (currently $55.26 per M\A/h) by $2.9t per M\A/h,
the Company's ldaho and Oregon residential and small farm customers are eligible
to receive $19,934,079 annually for the FY 2022-2023 exchange period, a decrease
of $2,338,049 per year from the FY 2020-2021 exchange period.
III. RETAIL RATE DESIGN
9. Three attachments accompany this Application. Attachment 1
summarizes the jurisdictional allocation of the BPA REP benefits of $19,954,079, and
Attachment 2 summarizes the calculation of the Schedule 98 credit rate. Clean and
a The ldaho Power Comoanv FY 2022-2023 FinalAveraoe Svstem Cost Reoort can be accessed online.
hftps://www.bpa.qov/Finance/ResidentialExchanqeProqram/FY%2020222023%20Utilitv%20Filinqs/ASC-
22-lP-01.pdf
s BP-22 Rate Proceeding Final Proposal Power Rates Study Documentation, BP-22-FS-BPA-014, a|142
(July 2021). https://ratecase.bpa.qov/openfile.aspx?fileName=BP-22-FS-BPA-
01A+PRS+Documentation+7. 1 6.2 1 .pdf&contentType=application%2fodf
APPLICATION-4
legislative versions of the proposed Schedule 98 tariff can be found in Attachment 3
to the Application.
10. ldaho Power will continue to pass through the benefit amount on a
uniform cents per k\A/h basis to all qualifoing electric energy delivered to ldaho
customers taking service under Schedules 1,3,5,6,7,8,9, 15, and 24. The
calculation of the new BPA Credit rate for qualiffing customers, based on the new
benefit amount determined by the FY 2022-2023 ASC proceeding, can be found in
Attachment 2.
11. Benefits at the new credit rate will be passed through on a monthly basis
for qualiffing residential and small farm usage commencing January 1, 2022.
However, benefits for qualiffing irrigation usage will continue to be accrued monthly
and passed through to irrigation customers each December, concurrent with the
Company's annual ldaho k\Alh and property tax rebate program. The irrigation
benefits distributed each Decemberwillcorrespond to a prior 12-month period ending
on September 30. For example, irrigation benefits distributed in December 2021 are
based on usage from October 2020 through September 2021. Monthly benefits for
qualifying irrigation customers are limited, for any single customer, to their actual
monthly energy or 222,000 k\ rh, whichever is less.
lv. coMMuNlcATloNs
12. Communications and service of pleadings, with reference to this Application
should be sent to the following:
APPLICATION. S
Lisa D. Nordstrom
Lead Counsel
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
ln o rdstrom@ ida h opowe r. com
[e-mail]
Connie Aschenbrenner
Rate Design Senior Manager
ldaho Power Company
P.O. Box 70
Boise, ldaho 83707
caschenbren [e-mail]
[e-mail]
13. Pursuant to Commission Rule of Procedure ('RP") 125.02,ldaho Power
will bring this tracker adjustment occasioned by federal action to the aftention of
customers via bill message in compliance with RP 125 afrer approval by the Commission.
V. MODIFIED PROCEDURE
14. ldaho Power believes that it would be appropriate to process this case by
means of Modified Procedure (i.e., by written submissions rather than by hearing) in
accordance with the provisions of RP 201-210 ef seg.
VI. REQUEST FOR RELIEF
15. For the reasons set forth above, ldaho Power respectfully requests that
the Commission issue an order approving a Schedule 98 credit of $0.002534 per kWh
for rate schedules 1,3,5,6,7,8,9, 15, and24 effective January 1,2022, through
December 31,2023
DATED at Boise, ldaho, this 27th day of October 2021
&;!.("*t.-*,
LISA D. NORDSTROM
Aftorney for ldaho Power Company
APPLICATION.6
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO, IPC.E-21-36
IDAHO POWER COMPANY
ATTACHMENT 1
ANNUAL ALLOCATION OF REP BENEFITS
FY2022-FY2023
ldaho Porcr Co.ipany
Attadrment I
Annual Afiocation of REP BonefitB
FY202:2-FY2023
Annual Allocetlon of REP Bcncftr Ff20in -Ff2UZg
Annurl D,olhr Bonofrtr by
lionth, Clar & Jurlrdlcllon
Grand
Tot!t
1,103,316.24
1,2E2,9il.25
1,630,275.10
1,729,E3/..42
1,623,E05.80
't,5't 2,034.45
1,239,605.99
1,0f,,,240.22
1,127,620.&
1,324,175.O2
1,615,705.62
231,650.07
57,035.60
't0,2v.75
7,755.13
7,06E.79
6,gEE.94
48,56s.92
278,82534
w,u7.4
509,6E8.E1
530,,f97.86
1,53/.,078.21
1,339,000.09
1,6/t0,500.85
1,737,580.85
1,630,E74.59
1,521,A23.35
1,28E,171.91
1,373,085.58
1,.f92,507.80
1,833,E63.63
2,1$,205.18
I 12 5.16 I
$ 34,50S.59
I .17,317.86
I 62,0ss.11
t 05,706.61
t 61,S24.75
$ 56,800.32
$ 43,E44.0S
$ 35,025.,f6
$ 35,r72.3r
$ .10,170.34
$ 45,202.52
$ .02,525.8s
10,1E5.44 $ 44,7E5.03
1,38E,90 t 4E,6E6.76
456.52 $ 62,511.63
375.47 $ 66,'t72.0E
289.06 $ 62,213.81
305.47 $ 5t,'.t11.75
1,322.05 $ 45,166.14
r3,663.52 3 4E,68E.98
17,150.02 E 52,622.33
30,991.22 S 71,161.56
37,140.S3 $ E6,343.64
30,176.1E E 72,702.06
$ '1,379,781.24$ 1,388,676.E5
$ 1,703,021./tg
$ 1,803,76'1.93
t 1,693,0EE.40
$ 1,57E,735.1E
$ 'l,333,33E.05
$'1,421,754.56
$ 1,s4s,190.13
t 1,905,025.30
$ 2,252,il7.32
$'1,969,178.34
Tot l Annu.l BPA Fbcrl Y.ar Benoftrl t 16,717,828.6.1 I 2,81t,08423 t9.zt5.9ta88 3 67+1r1.U 113.1U.77 3 7t8.166.0t 3 t9.95tL078.87
BEFORE THE
IDAHO PUBLIC UTILITIES GOMMISSION
cAsE NO. IPC-E-21-36
IDAHO POWER COMPANY
ATTACHMENT 2
SCHEDULE 98 RATE GALGULATION
FY2022 -FY2023
ldaho Power Company
Attachment 2
Schedule 98 Rate Calculation
FY2022-FY2023
Schedule 98 Rate Calculation FY2022 -FY2023
Billlng
Month
ldaho
REP Benefit
Dollars
Total Projected
Ellglble Loads (kWh)
ldaho
19,23s,912.86
(2,146,786.90)
101
6,666,715,094
6,739,760,843
_6,703,237,999_
$ 16,987,886.90
6,703,237,969
$ 0.002534
Annual ldaho REP Benefits:
ResidentiaUSmall Farm True Up:
lrrigation True Up:
2022-2023 Tota! ldaho Annual Benefit:
T otal 2022 E lig ible Load
T olal 2023 E lig ible Load
2022-2023 Avg Eligible Load
2022-2023 Total ldaho Annual Benefit:
2022-2023 Avg Eligible Load: +
2022-2023 Schedule 98 Credit Rate ($ per kWh)
$
$
Jan-22 $
Feb-22 $
Mar-22 $
Apr-22 $
May-22 $
Jun-22 $
Jul22 $
Aug-22 $
Sep-22 $
Oct-22 $
Nov-22 $
Dec-22 $
1,737,589.85
1,630,874.59
1,521,623.39
1,288,171.91
1,373,065.58
1,492,567.80
1,833,863.83
2,146,203.48
1,896,476.28
1,3y,976.21
1,339,990.09
1,640,509.85
66r'.,203,243
590,434,617
512,573,711
452,il9,578
461,443,568
513,745,371
651,133,831
724,6',t8,8U
627,198,5',14
46/.,888,572
42,587,953
561,337,272
Total-22 19.235.912.86 6.666.715.094
672,277,108
599,253,425
518,587,718
456,478,667
465,814,617
518,901,575
659,405,209
734,666,823
634,861,108
468,533,239
45,181,761
565,799,592
Jan-23
Feb-23
Mar-23
Apr-23
May-23
Jun-23
Jul-23
Aug-23
Sep-23
Oct-23
Nov-23
Dec-23
1,737,589.85
1,630,874.59
1,521,623.39
1,288,171.91
1,373,065.58
1,492,567.80
1,833,863.83
2,146,203.48
1,896,476.28
1,3U,976.21
1,339,990.09
1,640,509.85
$
$
$
$
$
$
$
$
$
$
$
$
Total-23 |6.739.760.84319.235.912.86
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPG.E.21.36
IDAHO POWER COMPANY
ATTACHMENT 3
SCHEDULE 98 TARIFF
(Glean and Legislative Formats)
ldaho Power Company Fourth Revised Sheet No. 98-2
Cancels
I.P.U.C. No. 29. Tariff No. 101 Third Revised Sheet No. 98-2
SCHEDULE 98
RESIDENTIAL AND SMALL FARM
ENERGY CREDIT
(Continued)
CREDIT ADJUSTMENT
An energy credit rate will be determined on an annual basis by dividing the sum of the totalfiscal
year Credit, derived from the Settlement Agreement, plus a true up from the prior year Credit, if
applicable, by the sum of the calendar year projected Qualifoing Electric Energy as described above.
The current energy credit rate is 0.2534 cents per kWh.
For residential and smal! farm Customers, the adjustment credit will be reflected on Customers'
monthly bills.
For irrigation Customers, the adjustment credit will be issued in December of each year.
IDAHO
lssued per Order No.
Effective - January 1,2022
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho
ldaho Power Company +hi+dFoulh Revised Sheet No.9&2
Cancels
|.P.U.C. No. 29. Tariff No. 101Seeend'Third Revised Sheet No. 9&2
SCHEDULE 98
RESIDENTIAL AND SMALL FARM
ENERGY CREDIT
(Continued)
CREDIT ADJUSTMENT
An energy credit rate will be determined on an annual basis by dividing the sum of the totalfiscal
year Credit, derived from the Settlement Agreement, plus a true up fiom the prior year Credit, if
applicable, by the sum of the calendar year projected Qualifying Electric Energy as described above.
The current energy credit rate is 0.253436{J cents per kWh.
For residential and small farm Customers, the adjustment credit will be reflected on Customers'
monthly bills.
For irrigation Customers, the adjustment credit will be issued in December of each year.
IDAHO
lssued per Order No.- NevemOer-tS-:gfg
Effective - Januarv 1, 2022-Janua+y-#2020
ACvi€e-N€#€t{4
lssued by IDAHO POWER COMPANY
Timothy E. Tatum, Vice President, Regulatory Affairs
1221 West ldaho Street, Boise, ldaho