20231211Comments of the Commission Staff.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION TO )CASE NO.IPC-E-23-28
IMPLEMENT THE RESIDENTAIL AND )
SMALL FARM ENERGY CREDIT )
)COMMENTS OF THE
)COMMISSION STAFF
COMMISSION STAFF ("STAFF")OF the Idaho Public Utilities Commission,by and
through its Attorneyof record,Michael Duval,Deputy AttorneyGeneral,submits the following
comments.
BACKGROUND
On October 25,2023,Idaho Power Company ("Company")applied for authorization to
implement the Bonneville Power Administration's ("BPA")residential and small farm energy
rate credit from January 1,2024,through December 31,2025.The Company's proposed rate
credit would result in a $6,433,850 increase in credits compared with those currentlyapplied to
eligible Idaho customers'bills.The Company requested an effective date of January 1,2024.
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
STAFF COMMENTS 1 December 11,2023
Power System to eligible residential,small farm,and irrigation customers through credits on
their power bills.The Company and BPA are parties to a Settlement Implementation Agreement
for the REP.Throughthis agreement the Company passes REP benefits on to its eligible
customers.
STAFF ANALYSIS
Staff reviewed the Company's Application and the BPA Fiscal Year ("FY")2024-2025
Final Average System Cost Report,audited the initial inputs,and independently recalculated the
rate.The Company correctly calculated the rate of $0.003447 per kilowatt-hour ("kWh")based
on an Idaho jurisdictional annual allocation of REP benefits of $22,903,010.Staff recommends
the Commission approve the proposed Electric Service Schedule 98 -Residential and Farm
Energy Credit ("Schedule 98")as filed.
The current Schedule 98 rate is $0.002534 per kWh.This credit was established in 2021
based on an annual BPA REP credit of $16,987,887 to eligible Idaho customers through a credit
to their energy rates for two years beginning January 1,2022.The Company proposes
implementing a new rate credit of $0.003447per kWh,representing Idaho's portion of benefits
from the BPA REP.Residential and small farm customers will be eligible to receive
$22,948,931 annuallyon a system basis for calendar years 2024 and 2025.This annual amount
is a $2,948,931 increase per year from the 2022-2023 exchange period.
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 ("PF")Exchange Rate and upon a two-year
average of the utility's historic eligible residential and small farm loads.A utility's ASC and the
resulting benefits are determined through an ASC filing and review process administeredby
BPA and conducted every two years.BPA issued the FYs 2024-2025 (October 2023 through
September 2025)final ASC report for Idaho Power in July 2023.The Company's ASC for FY
2024-2025 is $66.03 per megawatt-hour ("MWh").The Company's ASC exceeds BPA's PF
Exchange Rate of $62.83 per MWh by $3.20 per MWh.This $3.20 per MWh difference results
in an annual benefit of $22,903,010 on a system basis for the FY 2024-2025 exchange period,an
increase of $2,948,931 per year from the FY 2022-2023 exchange period.
STAFF COMMENTS 2 December 11,2023
Rate Design
The Company 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 Company will pass the benefits through at the new
credit rate every month for qualifying residential and small farm electricityconsumption
beginning January 1,2024.Qualifying irrigation 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 correspond to a prior 12-month period ending September 30.Monthly
benefits for qualifyingirrigation customers are limited to each customer's actual monthly energy
consumption or 222,000 kWh,whichever is less.
CUSTOMERS NOTICE AND PUBLIC COMMENTS
The Company proposes to notify customers via bill message in compliance with Rule 125,
IDAPA 31.01.01.125.02 after receiving the Commission's approval.As of December 4,2023,
the Commission has received no comments from customers.
STAFF RECOMMENDATIONS
Staff recommends that the Commission approve a Schedule 98 as filed,providing
customers a credit of $0.003447 per kWh for rate schedules 1,3,5,6,7,8,9,15,and 24
effective January 1,2024,throughDecember 31,2025.
Respectfully submitted this l lth day of December 2023.
Michael Duval
Deputy AttorneyGeneral
Technical Staff:Ty Johnson
Curtis Thaden
i:umisc/comments/IPC-E-23-28 Comments
STAFF COMMENTS 3 December 11,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11th DAY OF DECEMBER 2023,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO
IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-28,BY E-MAILING A COPY
THEREOF,TO THE FOLLOWING:
LISA D NORDSTROM CONNIE ASCHENBRENNER
IDAHO POWER COMPANY IDAHO POWER COMPANY
PO BOX 70 PO BOX 70
BOISE ID 83707-0070 BOISE ID 83707-0070
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail] zthompson idahopower.com
SECRETARY
CERTIFICATE OF SERVICE