20231025Application.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]

October 25, 2023

VIA ELECTRONIC FILING

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074

Re: Case No. IPC-E-23-28
In the Matter of the Application of Idaho Power Company’s Application to
Implement the Residential and Small Farm Credit Effective January 1, 2024
through December 31, 2025

Dear Ms. Noriyuki:

Enclosed for electronic filing please find Idaho Power Company’s Application in the
above matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Very truly yours,

Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
2023 OCTOBER 25, 2023 3:00PM
IDAHO PUBLIC
UTILITIES COMMISSION
APPLICATION- 1
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION TO
IMPLEMENT THE RESIDENTIAL AND
SMALL FARM CREDIT EFFECTIVE
JANUARY 1, 2024 THROUGH
DECEMBER 31, 2025.
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CASE NO. IPC-E-23-28

APPLICATION

Idaho Power ("Idaho Power" or "Company") respectfully applies to the Idaho
Public Utilities Commission ("Commission") pursuant to Idaho Code § 61-502, § 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 0.3447 cents per kilowatt-hour (“kWh”) effective January 1, 2024 through
December 31, 2025. The credit rate represents a $6,433,850 increase to eligible
customers in Idaho as compared to the BPA fiscal year 2022-2023 period.
In support of this Application, Idaho Power represents as follows:

APPLICATION- 2
I. BACKGROUND
1. Idaho Power is a public utility supplying retail electric service to
approximately 620,000 customers in southern Idaho and eastern Oregon. Idaho Power
is subject to the jurisdiction of this Commission in Idaho and to the jurisdiction of the Public
Utility 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 (“IOUs”) to exchange power they have purchased or
generated for lower-cost power generated by BPA.1 The exchange itself is a paper
transaction through which benefits from the federal Columbia River power system are
passed to qualifying residential and small-farm customers of participating Northwest
IOUs.
3. REP implementation has been litigated multiple times since the NW
Power Act was enacted. Idaho Power, BPA, other IOUs, public utility districts, and
municipalities in the Northwest are parties to the REP Settlement Implementation
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 $0.002534 per kWh. This credit was established in

1 16 U.S.C. § 839c(c). See Assoc. of Pub. Agency Customers v. Bonneville Power Admin. (APAC v.
BPA), 733 F.3d 939, 945 (9th Cir. 2013).

2 The Idaho Commission approved the REP Settlement Agreement in April 2011.
APPLICATION- 3
2021 based on an annual BPA REP credit of $16,987,887 to eligible Idaho customers.
The current rate was approved by the Commission in Order No. 35269 on December
27, 2021 in Case No. IPC-E-21-36 and was effective January 1, 2022.
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
ASC 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”)
2022 and 2023, Idaho Power’s Idaho and Oregon residential and small farm
customers received $19,954,079 of annual benefits for the two-year period beginning
October 1, 2021. On October 27, 2021, Idaho Power filed Case No. IPC-E-21-36 with
the Commission to decrease the rate on Schedule 98 effective January 1, 2022,
whereby Idaho residential and small farm customers would receive a credit on their
power bills for the period January 1, 2022 through December 31, 2023. The
Commission approved the credit rate in Order No. 35269 on December 27, 2021.

3 APAC v. BPA, 733 F.3d at 945-46.
APPLICATION- 4
7. BPA issued the FY 2024-2025 (October 2023 through September 2025)
final ASC report for Idaho Power in July 2023.4 Table 1 below shows a comparison
of the ASCs for the six Northwest IOUs between the current and most recent period.
Table 1
Utility FY2024-255 FY2022-23 Incr/(Decr)
Avista $ 70.61 $ 62.93 $ 7.68
Idaho Power $ 66.03 $ 58.17 $ 7.86
NorthWestern Energy $ 83.73 $ 68.34 $ 15.39
PacifiCorp $ 84.08 $ 77.61 $ 6.47
Portland General Electric $ 80.83 $ 70.09 $ 10.74
Puget Sound $ 81.53 $ 67.28 $ 14.25

8. Idaho Power’s final ASC for the FY 2024-2025 exchange period is
$66.03 per megawatt-hour (“MWh”). Because Idaho Power’s exchange period ASC
exceeds BPA’s PF Exchange Rate (currently $62.83 per MWh) by $3.20 per MWh,
the Company’s Idaho and Oregon residential and small farm customers are eligible
to receive $22,903,010 annually for the FY 2024-2025 exchange period, an increase
of $2,948,931 per year from the FY 2022-2023 exchange period.
III. RETAIL RATE DESIGN
9. Three attachments accompany this Application. Attachment 1
summarizes the jurisdictional allocation of the BPA REP benefits of $22,903,010, and
Attachment 2 summarizes the calculation of the Schedule 98 credit rate. Clean and

4 The Idaho Power Company FY 2024-2025 Final Average System Cost Report can be accessed online
under Utility Filings by Fiscal Year, FY24-25, FY 2024-2025 ASC Reports, Idaho_FY24-25 Final ASC
Report https://www.bpa.gov/energy-and-services/power/residential-exchange-program/asc-utility-filings.

5 BP-24 Rate Proceeding Final Proposal Power Rates Study Documentation, BP-24-FS-BPA-01A, at 136
(July 2023). https://ratecase.bpa.gov/openfile.aspx?fileName=BP-24-FS-BPA-
01A+Power+Rates+Study+Documentation.pdf&contentType=application%2fpdf

APPLICATION- 5
legislative versions of the proposed Schedule 98 tariff can be found in Attachment 3
to the Application.
10. Idaho Power will continue to pass through the benefit amount on a
uniform cents per kWh basis to all qualifying electric energy delivered to Idaho
customers taking service under Schedules 1, 3, 5, 6, 7, 8, 9, 15, and 24. The
calculation of the new BPA Credit rate for qualifying customers, based on the new
benefit amount determined by the FY 2024-2025 ASC proceeding, can be found in
Attachment 2.
11. Benefits at the new credit rate will be passed through on a monthly basis
for qualifying residential and small farm usage commencing January 1, 2024.
However, benefits for qualifying irrigation usage 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 will correspond to a prior 12-month period ending
on September 30. For example, irrigation benefits distributed in December 2023 are
based on usage from October 2022 through September 2023. Monthly benefits for
qualifying irrigation customers are limited, for any single customer, to their actual
monthly energy or 222,000 kWh, whichever is less.

APPLICATION- 6

IV. COMMUNICATIONS
12. Communications and service of pleadings, with reference to this Application
should be sent to the following:
Lisa D. Nordstrom
Lead Counsel
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]

Connie Aschenbrenner
Rate Design Senior Manager
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
[e-mail]
[e-mail]

13. Pursuant to Commission Rule of Procedure (“RP”) 125.02, Idaho Power
will bring this tracker adjustment occasioned by federal action to the attention of
customers via bill message in compliance with RP 125 after approval by the Commission.
V. MODIFIED PROCEDURE
14. Idaho 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 et seq.
VI. REQUEST FOR RELIEF
15. For the reasons set forth above, Idaho Power respectfully requests that
the Commission issue an order approving a Schedule 98 credit of $0.003447 per kWh
for rate schedules 1, 3, 5, 6, 7, 8, 9, 15, and 24 effective January 1, 2024, through
December 31, 2025.
DATED at Boise, Idaho, this 25th day of October 2023.

LISA D. NORDSTROM
Attorney for Idaho Power Company

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-28

IDAHO POWER COMPANY

ATTACHMENT 1

ANNUAL ALLOCATION OF REP BENEFITS
FY2024-FY2025
Attachment 1
Annual Allocation of REP Benefits FY2024 - FY2025
Annual Dollar Benefits by
Month, Class & Jurisdiction
Idaho
Residential &
Small Farm
Idaho
Irrigation
Idaho
Total
Oregon
Residential &
Small Farm
Oregon
Irrigation
Oregon
Total
Grand
Total
October 1,197,258.37$ 242,068.31$ 1,439,326.68$ 35,954.39$ 9,953.39$ 45,907.78$ 1,485,234.46$
November 1,301,581.03$ 46,762.41$ 1,348,343.45$ 45,167.57$ 1,777.79$ 46,945.36$ 1,395,288.81$
December 1,670,524.11$ 11,492.15$ 1,682,016.25$ 62,016.71$ 491.23$ 62,507.94$ 1,744,524.20$
January 2,074,521.86$ 8,989.36$ 2,083,511.21$ 79,922.45$ 491.38$ 80,413.84$ 2,163,925.05$
February 1,963,802.78$ 8,295.74$ 1,972,098.52$ 74,017.53$ 412.03$ 74,429.57$ 2,046,528.09$
March 1,768,661.71$ 10,106.67$ 1,778,768.38$ 67,788.41$ 458.12$ 68,246.54$ 1,847,014.91$
April 1,422,615.44$ 74,695.48$ 1,497,310.92$ 49,105.53$ 3,096.80$ 52,202.34$ 1,549,513.26$
May 1,286,623.06$ 302,256.26$ 1,588,879.32$ 43,375.73$ 16,725.43$ 60,101.16$ 1,648,980.48$
June 1,285,110.11$ 451,975.71$ 1,737,085.82$ 39,481.07$ 25,909.02$ 65,390.09$ 1,802,475.91$
July 1,848,187.25$ 601,357.85$ 2,449,545.11$ 55,277.02$ 40,546.47$ 95,823.48$ 2,545,368.59$
August 1,976,553.78$ 559,093.99$ 2,535,647.78$ 58,229.24$ 40,292.62$ 98,521.86$ 2,634,169.63$
September 1,502,622.59$ 460,249.96$ 1,962,872.55$ 45,940.43$ 31,173.44$ 77,113.88$ 2,039,986.43$
Total Annual BPA Fiscal Year Benefits 19,298,062.11$ 2,777,343.88$ 22,075,405.98$ 656,276.09$ 171,327.75$ 827,603.84$ 22,903,009.83$

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-28

IDAHO POWER COMPANY

ATTACHMENT 2

SCHEDULE 98 - RATE CALCULATION
FY2024-FY2025
Attachment 2
Schedule 98 Rate Calculation FY2024 - FY2025
Total REP Oregon Idaho Total Projected
Billing Benefit REP Benefit REP Benefit Eligible Loads (kWh)
Month Dollars Dollars Dollars Idaho
Jan-24 2,163,925.05$ 80,413.84$ 2,083,511.21$ 662,341,913
Feb-24 2,046,528.09$ 74,429.57$ 1,972,098.52$ 610,684,527
Mar-24 1,847,014.91$ 68,246.54$ 1,778,768.38$ 553,334,120
Apr-24 1,549,513.26$ 52,202.34$ 1,497,310.92$ 472,765,680
May-24 1,648,980.48$ 60,101.16$ 1,588,879.32$ 482,552,733
Jun-24 1,802,475.91$ 65,390.09$ 1,737,085.82$ 526,323,593
Jul-24 2,545,368.59$ 95,823.48$ 2,449,545.11$ 648,088,873
Aug-24 2,634,169.63$ 98,521.86$ 2,535,647.78$ 728,904,780
Sep-24 2,039,986.43$ 77,113.88$ 1,962,872.55$ 620,467,637
Oct-24 1,485,234.46$ 45,907.78$ 1,439,326.68$ 456,983,453
Nov-24 1,395,288.81$ 46,945.36$ 1,348,343.45$ 436,442,077
Dec-24 1,744,524.20$ 62,507.94$ 1,682,016.25$ 565,652,312
Total-24 22,903,009.83$ 827,603.84$ 22,075,405.98$ 6,764,541,698
Jan-25 2,163,925.05$ 80,413.84$ 2,083,511.21$ 663,497,006
Feb-25 2,046,528.09$ 74,429.57$ 1,972,098.52$ 612,787,007
Mar-25 1,847,014.91$ 68,246.54$ 1,778,768.38$ 555,693,448
Apr-25 1,549,513.26$ 52,202.34$ 1,497,310.92$ 475,597,001
May-25 1,648,980.48$ 60,101.16$ 1,588,879.32$ 486,175,621
Jun-25 1,802,475.91$ 65,390.09$ 1,737,085.82$ 531,318,004
Jul-25 2,545,368.59$ 95,823.48$ 2,449,545.11$ 655,655,960
Aug-25 2,634,169.63$ 98,521.86$ 2,535,647.78$ 738,467,256
Sep-25 2,039,986.43$ 77,113.88$ 1,962,872.55$ 628,967,525
Oct-25 1,485,234.46$ 45,907.78$ 1,439,326.68$ 463,003,144
Nov-25 1,395,288.81$ 46,945.36$ 1,348,343.45$ 442,238,008
Dec-25 1,744,524.20$ 62,507.94$ 1,682,016.25$ 573,314,350
Total-25 22,903,009.83$ 827,603.84$ 22,075,405.98$ 6,826,714,329
Annual Idaho REP Benefits: 22,075,405.98$
Residential/Small Farm True Up:531,160.17$
Irrigation True Up:815,170.72$
2024-2025 Total Idaho Annual Benefit: 23,421,736.87$
Total 2024 Eligible Load: 6,764,541,698
Total 2025 Eligible Load: 6,826,714,329
2024-2025 Avg Eligible Load: 6,795,628,013
2024-2025 Total Idaho Annual Benefit: 23,421,736.87$
2024-2025 Avg Eligible Load: ÷ 6,795,628,013
2024-2025 Schedule 98 Credit Rate ($ per kWh)0.003447$

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

CASE NO. IPC-E-23-28

IDAHO POWER COMPANY

ATTACHMENT 3

TARIFF SCHEDULE 98
Idaho Power Company Fifth Revised Sheet No. 98-2
Cancels
I.P.U.C. No. 29, Tariff No. 101 Fourth Revised Sheet No. 98-2
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. Timothy E. Tatum, Vice President, Regulatory Affairs
Effective – January 1, 2024 1221 West Idaho Street, Boise, Idaho

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 total fiscal
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 Qualifying Electric Energy as described above.
The current energy credit rate is 0.3447 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 Power Company Fourth Fifth Revised Sheet No. 98-2
Cancels
I.P.U.C. No. 29, Tariff No. 101 Third Fourth Revised Sheet No. 98-2
IDAHO Issued by IDAHO POWER COMPANY
Issued per Order No. 35269 Timothy E. Tatum, Vice President, Regulatory Affairs
Effective – January 1, 20224 1221 West Idaho Street, Boise, Idaho

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 total fiscal
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 Qualifying Electric Energy as described above.
The current energy credit rate is 0.25340.3447 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.