20211203Comments.pdf

ldaho Public Utilities Commission
Office of the SecretarvRECEIVED
DEC 0 3 2021RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Boise, ldaho
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney forthe Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF IDAIIO POWER
COMPATTY'S APPLICATION TO
IMPLEMENT THE RESIDENTIAL AI\[D
SMALL FAR}I ENMRGY CREDIT
CASE NO. IPC.E-2I36
COMMENTS OF THE
COMIVIISSION STAFF
STAIT'OF the Idaho Public Utilities Commission, by and through its Attomey of
recor4 Riley Newton, Deputy Attorney General, submits the following comments.
BACKGROT}NI)
On October 27,202l,Idaho Power Company ("Company') applied for authorization to
implement the Bonneville Power Administration's ("BPA') residential and small farm energy
rate credit from January 1,2022, through December 31,2023. The Company's proposed rate
credit would result rna$5,942,001 decrease in credits compmed with those currently applied to
eligible Idaho customers' bills. The Company requested an effective date of January 1,2022.
The residential and small farm energy rate credit results from the Company's agreement
with BPA regarding the Residential Exchange Program ('REP'). The BPA administers the REP.
The REP allows participating utilities to pass the benefits of the low-cost Federal Columbia
River Power System to eligible residential, small farm, and irrigation customers through credits
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ISTAITF COMMENTS DECEMBERS,2O2I
on their power bills. The Company and BPA are parties to a Settlement Implementation
Agreement for the REP. Through this agreement the Company passes REP benefits on to its
eligible customers.
STAFF ANALYSIS
The rate in Electric Service Schedule 98 - Residential and Farm Energy Credit
("Schedule 98") is currently $0.003617 per Kilowatt-hour ("kWh"). This rate-established in
2019-is based on an annual BPA REP credit of $22,929,888 to eligible ldaho customers
through a credit to their energy rates for two years beginning January 1,2020.
The Company proposes implementing a rate credit of $0.002534 per kwh, representing
the Company's Idalrc portion of benefits from the BPA REP. Residential and small farm
customers will be eligible to receive $19,954,079 annually on a system basis forthe BPA fiscal
year 2022-2023 Wriod. This annual amount is a $2,338,049 decrease per year from the 2020-
2021 exchangeperiod.
Average System Cost
The REP benefits are allocated to the utilities based upon each utility's Average System
Cost ("ASC") in comparison to BPA's Priority Firm Exchange Rate and upon a two-year
average of the utility's historicd eligible residential and small farm loads. A utility's ASC and
the resulting benefits are determined through an ASC frling ad review process administered by
BPA and conducted every two years. BPA issued the Fiscal Year ("FY')2022-2023 (October
2021 through September 2023) final ASC report for Idaho Power in July 2021. The Company's
ASC for FY 2022-2023 is $58.17 permegawatt-hour ("MWh"). The Company's ASC exceeds
BPA's PF Exchange Rate of $55.26 per MWh by $2.91 per MWh. This $2.91 per MWh
difference results in an annual benefit of $19,954,079 on a system basis for the FY 2022-2023
exchange period, a decrease of $2,338,049 per year from the FY 2020-2021 exchange period.
Rate Design
The Company will continue to pass through the benefit amount on a uniform cents per
kWh basis to all qualifring electric energy delivered to Idaho customers taking service under
Schedules l, 3, 5, 6,7o8,9,15, atd24- The Company will pass the benefits through at the new
2STAFF COMMENTS DECEMBER 3,2421
credit rate every month for qualifring residential and small fann electicity consumption
treginning January \2A22. Qualiffing inigation consumption will continue to be accrued
monthly and passed through to irrigation customers each December, concurrent with the
Company's annual Idaho kWh and property tax rebate program. The irrigation benefits
distributed each December correslrond to a prior l2-month period ending September 30.
Monthly benefits for qualifuing inigation customers are limited to each customer's actual
monthly energy consumption or222,N0 kwh, whichever is less.
StaffAudit
Staffreviewed BPA's FY 2022-2023 Final Average System Cost Report for the
Company, audited the initial inputs, and independently recalculated the rate. Staffnotes that the
Company correctly calculated the mte of $0.002534 per kwh, based on an Idaho jurisdictional
annual allocation of REP benefits of $19,235,913 and recommends the rate be approved.
CUSTOMER NOTICE AI\D PUBLIC COMMENTS
The Company proposes to notifu customers via bill message in compliance with Rule
l25,IDAPA 31.01.01 .125.02 afterthe Commission's approval. As of December 3, 202l,the
Commission has received no comments from customers.
STAXT' RECOMMENDATIONS
Staffrecommends that the Commission approve a Schedule 98 credit of $0.002534 per
kWh forrate schedules 1,3,5,6,7,8,9, 15, and24 effective January l,20zz,through
December 31,2023.
JSTAFF COMMENTS DECEMBER3,2O2I
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Reryectfullysbmitrodthis 3 day ofDecemberZUZI.
44/k
RileyNerryton
DeFSy Afiomey Creneral
Tochnical Statr Kathy Stoohon
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4STAFF COMMENTS DECEMBER 3,2021
CERTIHCATE OF SERVICE
I IIEREBY CERTTFY TIIAT I HAVE THIS 3'd DAY OF DECEMBER 202I,
SERVED TIrE FOREGOING COMMENTS OF TEE COMMIIISION , IN CASE
NO. IPC-E-2I.36, BY E.II{AILING A COPY THEREOF, TO TIIE FOLLOWING:
LISANORDSTROM
IDAHO POWERCOMPAI\TY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: lnordstrom@idahopower. com
dockets@idatropower. com
CONNIE ASCIIENBRENNER
RATE DESIGN SEMOR MGR
IDAHO POWERCOMPA}IY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
ahompson@ idatropower. com
CERTTTICATE OF SERVICE