HomeMy WebLinkAbout20230315Application.pdfMEGAN GOICOECHEA ALLEN
Corporate Counsel
mgoicoecheaallenidahopower.com
March 15, 2023
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-23-09
Idaho Power Company’s Application for Authority to Implement Fixed Cost
Adjustment (“FCA”) Rates for Electric Service from June 1, 2023 Through May
31, 2024.
Dear Ms. Noriyuki:
Attached for electronic filing, please find Idaho Power Company’s Application in the
above-entitled matter.
In addition, please find attached the Direct Testimony of Pawel P. Goralski filed in
support of the Application. A Word version of the testimony will also be sent in a separate
email for the convenience of the Reporter.
Accompanying this filing is the Company’s Press Release and Customer Notice.
If you have any questions about the attached documents, please do not hesitate to
contact me.
Sincerely,
Megan Goicoechea Allen
MGA:sg
Enclosures
RECEIVED
Wednesday, March 15, 2023 11:18:27 AM
IDAHO PUBLIC
UTILITIES COMMISSION
APPLICATION - 1
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-2664
Facsimile: (208) 388-6936
mgoicoecheaallen@idahopower.com
lnordstrom@idahopower.com
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
AUTHORITY TO IMPLEMENT FIXED
COST ADJUSTMENT (“FCA”) RATES
FOR ELECTRIC SERVICE FROM JUNE 1,
2023 THROUGH MAY 31, 2024.
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CASE NO. IPC-E-23-09
APPLICATION
Idaho Power Company (“Idaho Power” or “Company”), in accordance with Idaho
Code § 61-502 and Commission Rule of Procedure1 52, hereby respectfully makes
application to the Idaho Public Utilities Commission (“Commission”) for an order
authorizing Idaho Power to implement Fixed Cost Adjustment (“FCA”) rates for electric
service from June 1, 2023 through May 31, 2024, and to approve the Company’s
corresponding Schedule 54, Fixed Cost Adjustment. With this filing the Company
proposes a $9,976,903, or 1.56 percent, decrease for Residential and Small General
1 Hereinafter cited as RP.
APPLICATION - 2
Service customers. If the FCA is approved as filed, a typical residential customer using
950 kilowatt-hours per month will see an approximate $1.66 decrease to their monthly
bill.
In support of this Application, Idaho Power represents as follows:
I. BACKGROUND
1. Idaho Power and the Commission have long agreed that promotion of cost-
effective energy efficiency and demand-side management (“DSM”) “is an integral part of
least-cost electric service.” 2 Unfortunately, traditional rate design that recovers fixed costs
through each kilowatt-hour (“kWh”) sold discourages utilities from reducing their sales
volumes through investment in energy efficiency and DSM.
2. In acknowledging that investments in cost-effective energy efficiency could
be hindered by the inherent financial disincentives, the Commission also recognized that
“opportunities exist[ed] for improvements in operating efficiency that would benefit the
Company shareholders and its customers” and opened an investigation in Case No. IPC-
E-04-15 to consider options for a performance-based mechanism that adjusts revenues
when annual energy consumption is either above or below normal.3 The FCA mechanism
is the collaborative result of that case.
3. In Order No. 30267,4 the Commission approved a stipulation for the
implementation of a three-year FCA pilot program applicable to Residential Service
(Schedules 1, 3, 4, and 5) and Small General Service (Schedule 7) customers.
2 In the Matter of the Investigation of Financial Disincentives to Investment in Energy Efficiency by Idaho Power
Company, Case No. IPC-E-04-15, Order No. 30267, p. 13 (Mar. 12, 2007).
3 Id., Order No. 29558, p. 1 (Aug. 10, 2004) (citing Order No. 29505, p. 68-69).
4 Id.
APPLICATION - 3
4. On October 1, 2009, the Company filed an application seeking authority to
convert Schedule 54, the FCA tariff schedule, from a pilot program to an ongoing,
permanent program, asserting that the mechanism had fulfilled the purpose of removing
disincentives to energy efficiency investments undertaken by the Company to the benefit
of its customers.5 At that time, however, the Commission found it was too early to
determine whether the objectives of the FCA were being met and denied Idaho Power’s
request as a result. Instead, it extended the pilot program for an additional two-year
period.6
5. During the fifth year of the pilot program, the Company filed another
application seeking authority to convert the FCA to an ongoing, permanent program.7 This
time the Commission approved the Company’s request to convert the FCA to a
permanent program for the Residential and Small General Service customers, and though
it ultimately directed that the FCA mechanism continue with its then-existing methodology,
it also noted that it would continue to review the FCA to ensure its ongoing effectiveness.8
6. The Commission subsequently opened another docket to re-evaluate the
FCA mechanism, Case No. IPC-E-14-17, ultimately approving a settlement stipulation
that changed the methodology to calculate the level of actual fixed costs recovered used
to determine the FCA.9 The modification to the calculation of the actual level of fixed costs
recovered replaced weather-normalized billed sales with actual billed sales and began
with the determination of the 2015 FCA.
5 In the Matter of the Application of Idaho Power Company for Authority to Convert Schedule 54- Fixed Cost
Adjustment – From a Pilot Schedule to an Ongoing, Permanent Schedule, Case No. IPC-E-09-28.
6 Id., Order No. 31063, p. 8-9 (Apr. 29, 2010).
7 In the Matter of the Application of Idaho Power Company for Authority to Convert Schedule 54- Fixed Cost
Adjustment – From a Pilot Schedule to an Ongoing, Permanent Schedule, Case No. IPC-E-11-19.
8 Id., Order No. 32505, p. 9 (Mar. 30, 2012) and Order No. 32731 p. 4-5 (Jan.31, 2013).
9 In the Matter of the Commission’s Inquiry into Idaho Power Company’s Fixed Cost Adjustment Mechanism, Case
No. IPC-E-14-17, Order No. 33295, p. 5-6 (May 15, 2015).
APPLICATION - 4
7. More recently, the Commission approved, at the Company’s request,
another modification to the FCA mechanism that instituted separate and reduced fixed
cost tracking and recovery for new Residential and Small General Service customers
added to the Company’s system starting January 1, 2022.10 Through this modification,
the authorized level of fixed cost recovery for new customers excludes generation and
transmission-related fixed costs but continues to include distribution and other customer-
related fixed costs. The approved modification is included in the determination of the 2022
FCA deferral calculation.
8. In this filing, the Company requests recovery of the 2022 FCA balance and
approval of the corresponding rates.
II. FCA MECHANISM
9. The FCA mechanism enables Idaho Power to separate, or “decouple,” its
fixed cost revenues from its volumetric energy sales and provides symmetry through a
surcharge or credit when fixed cost recovery per customer, on an actual billed sales basis,
varies above or below a Commission-established base. In other words, the FCA provides
a “true-up” of the collection of fixed costs per customer to recover the difference between
the level of fixed costs recovered on an actual billed sales basis by the Company through
rates and the level of fixed costs authorized for recovery in the Company’s most recent,
applicable general rate case.
10. The FCA removes the financial disincentive that exists when the Company
invests in DSM resources and energy efficiency activities. On a system-wide basis, Idaho
Power achieved 169,889 megawatt-hours of incremental annual energy efficiency
10 Idaho Power Company’s Application for Modification of the Fixed Cost Adjustment Mechanism, Case No. IPC-E-
21-39, Order No. 35273, p. 4 (Dec. 28, 2021).
APPLICATION - 5
savings in 2022, which are enough energy to power approximately 14,900 average
homes a year in Idaho Power’s service area. These energy savings are more particularly
described in the 2022 DSM Annual Report filed in Case No. IPC-E-23-10. The Company
also invests in significant DSM educational and awareness activities and marketing
efforts, which are also described in the DSM Annual Report, that are likely to result in
energy savings experienced by the customer but are not quantified or claimed as part of
Idaho Power’s annual savings.
11. The FCA works identically for both the Residential and Small General
Service classes. For each class, the number of customers is multiplied by the fixed cost
per customer rate (“FCC”), which is established as part of determining the Company’s
authorized revenue requirement in its most recent general rate case. The product of this
calculation establishes the “authorized fixed cost recovery” amount. This authorized fixed
cost recovery amount is then compared to the amount of fixed costs actually recovered
by Idaho Power. To determine the “actual fixed costs recovered” amount, the Company
multiplies the actual billed sales for each class by the fixed cost per energy rate (“FCE”),
as established in the Company’s most recent applicable general rate case. The difference
between these two numbers (the “authorized fixed cost recovery” amount minus the
“actual fixed costs recovered” amount) is the fixed cost adjustment for each class.
12. As a result of Case No. IPC-E-21-39, the FCC and FCE are bifurcated for
new and existing customers, with new customer components labeled as “FCC-Dist” and
“FCE-Dist,” and the differences between authorized and actual fixed cost recovery are
calculated independently for existing and new customers in order to determine the total
FCA deferral. The 2022 FCA deferral is recovered through a single FCA rate applicable
APPLICATION - 6
to all Residential customers, new and existing, and a single FCA rate applicable to all
Small General Service customers.
III. PROPOSED 2023-2024 FCA RATE ADJUSTMENT
13. The determination of the FCA deferral balance and corresponding rates are
described in the Direct Testimony of Pawel P. Goralski (“Goralski Testimony”) filed
contemporaneously with this Application.
14. As shown on Exhibit No. 4 of the Goralski Testimony, the proposed FCA is
$24,076,901.44 for the Residential class and $988,173.87 for the Small General Service
class, for a total amount of $25,065,075.31. Goralski Testimony at 14. The proposed FCA
deferral balance is less than the current FCA deferral balance currently collected in
customers’ rates. Accordingly, with this Application, Idaho Power is proposing an FCA
rate decrease for the Residential and Small General Service classes, which would result
in an annual decrease of 1.56 percent from current billed revenue for the affected
customer classes. Goralski Testimony at 17. This decrease equates to new FCA rates of
0.4402 cents per kWh for the Residential class and 0.5541 cents per kWh for the Small
General Service class. Goralski Testimony at 16.
15. Idaho Power requests that the FCA rates become effective on June 1, 2023,
coincident with the Company’s annual Power Cost Adjustment, and with the
commencement of seasonal rates, and that the FCA rates remain in effect until May 31,
2024.
16. The proposed FCA tariff (clean version), Schedule 54, is attached hereto as
Attachment 1 to this Application. The Schedule 54 tariff in legislative format is attached
hereto as Attachment 2.
APPLICATION - 7
IV. MODIFIED PROCEDURE
17. Idaho Power believes that a technical hearing is not necessary to consider
the issues presented herein and respectfully requests that this Application be processed
under Modified Procedure; i.e., by written submissions rather than by hearing. RP 201, et
seq. The Company has, however, contemporaneously filed the Goralski Testimony and
stands ready to present its testimony and support the Application if the Commission
determines that a technical hearing is required.
V. COMMUNICATIONS AND SERVICE OF PLEADINGS
18. In conformance with RP 125, this Application will be brought to the attention
of Idaho Power’s customers by means of both a press release to media in the Company’s
service area and a customer notice distributed in customers’ bills, both of which
accompany this filing. The customer notice will be distributed over the course of the
Company’s current billing cycles, with the last notice being sent on or about April 25,
2023. Idaho Power will also keep its Application, testimony, and exhibits open for public
inspection at its offices throughout the state of Idaho. Idaho Power believes the above
procedures satisfy the Rules of Practice and Procedure of this Commission; however, the
Company will, in the alternative, bring the Application to the attention of its affected
customers through any other means directed by this Commission.
19. Communications and service of pleadings with reference to this Application
should be sent to the following:
APPLICATION - 8
Megan Goicoechea Allen
Lisa D. Nordstrom
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
mgoicoecheaallen@idahopower.com
lnordstrom@idahopower.com
dockets@idahopower.com
Connie Aschenbrenner
Pawel P. Goralski
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
caschenbrenner@idahopower.com
pgoralski@idahopower.com
VI. REQUEST FOR RELIEF
20. Idaho Power respectfully requests that the Commission issue an order: (1)
authorizing that this matter be processed by Modified Procedure and (2) authorizing Idaho
Power to implement Fixed Cost Adjustment rates for electric service from June 1, 2023,
through May 31, 2024, as described above.
DATED at Boise, Idaho, this 15th day of March 2023.
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-09
IDAHO POWER COMPANY
ATTACHMENT 1
SCHEDULE 54
(CLEAN)
Idaho Power Company Sixteenth Revised Sheet No. 54-2
Cancels
I.P.U.C. No. 29, Tariff No. 101 Fifteenth Revised Sheet No. 54-2
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs
Effective – June 1, 2023 1221 West Idaho Street, Boise, Idaho
SCHEDULE 54
FIXED COST ADJUSTMENT
(Continued)
FIXED COST PER ENERGY RATE (Continued)
Residential FCE
Effective Date Rate
January 1, 2012 5.1602¢ per kWh
Residential FCE-Dist
Effective Date Rate
January 1, 2022 2.5199¢ per kWh
Small General Service FCE
Effective Date Rate
January 1, 2012 6.8633¢ per kWh
Small General Service FCE-Dist
Effective Date Rate
January 1, 2022 4.8783¢ per kWh
ALLOWED FIXED COST RECOVERY AMOUNT
The Allowed Fixed Cost Recovery amount is computed by summing 1) the product of the average
number of existing Residential and Small General Service customers multiplied by the appropriate
Residential and Small General Service FCC rate and 2) the product of the average number of new
Residential and Small General Service customers multiplied by the appropriate Residential and Small
General Service FCC-Dist rate.
ACTUAL FIXED COSTS RECOVERED AMOUNT
The Actual Fixed Costs Recovered amount is computed by summing 1) the product of the actual
energy load for existing Residential and Small General Service customers multiplied by the appropriate
Residential and Small General Service FCE rate and 2) the product of the actual energy load for new
Residential and Small General Service customers multiplied by the appropriate Residential and Small
General Service FCE-Dist rate.
FIXED COST ADJUSTMENT
The Fixed Cost Adjustment (FCA) is the difference between the Allowed Fixed Cost Recovery
Amount and the Actual Fixed Costs Recovered Amount divided by the estimated weather-normalized
energy load for the following year for Residential and Small General Service Customers.
The monthly Fixed Cost Adjustment for Residential Service (Schedules 1, 3, 4, 5, and 6) is 0.4402
cents per kWh. The monthly Fixed Cost Adjustment for Small General Service (Schedules 7 and 8) is
0.5541 cents per kWh.
EXPIRATION
The Fixed Cost Adjustment included on this schedule will expire May 31, 2024.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-23-09
IDAHO POWER COMPANY
ATTACHMENT 2
SCHEDULE 54
(LEGISLATIVE)
Idaho Power Company Fifteenth Sixteenth Revised Sheet No. 54-2
Cancels
I.P.U.C. No. 29, Tariff No. 101Fourteenth Fifteenth Revised Sheet No. 54-2
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. 35410 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective – June 1, 20223 1221 West Idaho Street, Boise, Idaho
SCHEDULE 54
FIXED COST ADJUSTMENT
(Continued)
FIXED COST PER ENERGY RATE (Continued)
Residential FCE
Effective Date Rate
January 1, 2012 5.1602¢ per kWh
Residential FCE-Dist
Effective Date Rate
January 1, 2022 2.5199¢ per kWh
Small General Service FCE
Effective Date Rate
January 1, 2012 6.8633¢ per kWh
Small General Service FCE-Dist
Effective Date Rate
January 1, 2022 4.8783¢ per kWh
ALLOWED FIXED COST RECOVERY AMOUNT
The Allowed Fixed Cost Recovery amount is computed by summing 1) the product of the average
number of existing Residential and Small General Service customers multiplied by the appropriate
Residential and Small General Service FCC rate and 2) the product of the average number of new
Residential and Small General Service customers multiplied by the appropriate Residential and Small
General Service FCC-Dist rate.
ACTUAL FIXED COSTS RECOVERED AMOUNT
The Actual Fixed Costs Recovered amount is computed by summing 1) the product of the actual
energy load for existing Residential and Small General Service customers multiplied by the appropriate
Residential and Small General Service FCE rate and 2) the product of the actual energy load for new
Residential and Small General Service customers multiplied by the appropriate Residential and Small
General Service FCE-Dist rate.
FIXED COST ADJUSTMENT
The Fixed Cost Adjustment (FCA) is the difference between the Allowed Fixed Cost Recovery
Amount and the Actual Fixed Costs Recovered Amount divided by the estimated weather-normalized
energy load for the following year for Residential and Small General Service Customers.
The monthly Fixed Cost Adjustment for Residential Service (Schedules 1, 3, 4, 5, and 6) is
0.61530.4402 cents per kWh. The monthly Fixed Cost Adjustment for Small General Service (Schedules
7 and 8) is 0.7788 5541 cents per kWh.
EXPIRATION
The Fixed Cost Adjustment included on this schedule will expire May 31, 20234.