20040311Staff Comments.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP FOR EXEMPT WHOLESALE
GENERATOR DETERMINATIONS RELATING)
TO THE SKOOKUMCHUCK HYDRO- ELECTRIC PLANT.
CASE NO. PAC-O4-
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
Attorney of record, Scott Woodbury, Deputy Attorney General, and in response to the Notice of
Application, Notice of Modified Procedure and Notice of Comment/Protest Deadline issued on
February 20, 2004, submits the following comments.
BACKGROUND
On February 12, 2004, PacifiCorp (Company) filed an Application with the Idaho Public
Utilities Commission (Commission) regarding the proposed sale by PacifiCorp of its ownership
interest in the Skookumchuck Hydroelectric Project, a I-megawatt (MW) generation facility
located in the state of Washington. The facility is co-owned by PacifiCorp, Avista Corporation
Public Utility District No.1 of Snohomish County, Puget Sound Energy, Inc., City of Tacoma
City of Seattle and Public Utility District No.1 of Grace Harbor County (collectively the
Owners
STAFF COMMENTS MARCH 11 , 2004
The Skookumchuck Project (Project) is an earth-filled dam and a small, 1 MW
hydroelectric facility located in the vicinity ofCentralia, Washington on property adjacent to the
Centralia Power Plant, a large coal-fired generating facility. The Skookumchuck Dam was
constructed in 1973 as a water storage facility for the Centralia Power Plant. In 1991 , a generating
plant with a capacity of approximately 1 MW was constructed at the dam.
PacifiCorp has entered into a Purchase and Sale Agreement to sell the Skookumchuck
Hydroelectric Plant to 2677588 Washington, LLC, a Washington Limited Liability Company and
a direct wholly-owned subsidiary of TransAlta USA, Inc. (TransAlta). TransAlta is the indirect
owner of the Centralia Power Plant and the Centralia Coal Mine. In 2000, the Owners sold the
Centralia Power Plant to a direct wholly-owned subsidiary of TransAlta, TECW A Power, Inc., and
PacifiCorp sold the Centralia coal mine to another direct wholly-owned subsidiary of TransAlta
TECW A Fuel, Inc. The Commission approved the sale ofPacifiCorp s share ofthe Centralia
Power Plant and Coal Mine in Order No. 28296. TransAlta Centralia Generation LLC, a direct
wholly-owned subsidiary ofTECW A Power, Inc., now owns and operates the Centralia Power
Plant as an Exempt Wholesale Generator (EWG).
PacifiCorp proposes to sell and transfer to Washington LLC the dam, powerhouse water
rights, land, easements and other assets of the Project, including certain fixtures, contracts and
other rights. Washington LLC intends to operate the Skookumchuck Project as an EWG within
the meaning of Section 32 ofthe Public Utility Holding Company Act of 1935 (PUHCA). To
qualify as an EWG, Washington LLC must be engaged exclusively in the business of owning or
operating an "eligible facility" and selling electric energy at wholesale. If the costs of a generation
facility were included in the rates of a regulated utility on October 24, 1992 (the date of enactment
of Section 32 ofPUHCA), then in order for the facility to be considered an "eligible facility,
every state Commission having jurisdiction over such rates must specifically determine that
allowing the facility to become an eligible facility (1) will benefit consumers, (2) is in the public
interest, and (3) does not violate state law. 15 USC. 979z-5a(c). Washington LLC , PacifiCorp
contends, cannot process its EWG Application with the FERC until all of the Company
regulatory commissions have made the three determinations required by Section 32 ofPUHCA.
STAFF COMMENTS MARCH 11 , 2004
ST AFF ANALYSIS
Compliance with State Law
PacifiCorp contends that the sale of the Skookumchuck Project to Washington, LLC and
allowing the generating facilities to become an "eligible facility" will not violate Idaho state law.
Because the Project assets are located in the state of Washington, the Company contends that
Idaho s property transfer statute Idaho Code 961-328 is not applicable to the contemplated sale.
Idaho Code 961-328 states in part:
No electric public utility... owning, controlling or operating any property
located in this state which is used in the generation, transmission, distribution
or supply of electric power and energy to the public shall merge, sell, lease
assign or transfer. .. any such property or interest therein, or the operation
management or control thereof... except when authorized to do so by order
of the public utilities commission. (Emphasis added.
Commission Staffhas reviewed the referenced U.S. Code language regarding Exempt
Wholesale Generators (see Attachment A, 15 USCA 9 79z-5a). The ownership interest of
PacifiCorp in the Skookumchuck facilities are a part of the utility s rate base in Idaho on which
PacifiCorp receives a return on investment and is now and has been included in the rate base of
PacifiCorp since or prior to October 24, 1992. Based on Staffs review of the Idaho Code, Staff
represents that it has discovered no Idaho laws that address the issues raised by this request, and
none prohibit or limit the authority of Washington, LLC as an EWG to operate Skookumchuck as
a wholesale facility.
As discussed in these comments, Staff notes further that although the Project is located in
Washington, this transaction complies with the intent and meets the standards of Idaho Code 9 61-
328. In compliance therewith, Staff represents that:
(a) That the transaction is consistent with the public interest;
(b) That the cost of and rates for supplying service will not be increased
by reason of such transaction; and
( c) That the applicant for such acquisition or transfer has the bona fide
intent and financial ability to operate and maintain said property in the
public service.
Benefits to Customers
The aggregate sale price of the transaction is approximately $7.57 million, adjusted for
changes in PacifiCorp s net book value ofthe facilities from September 30 2003 to the closing
STAFF COMMENTS MARCH 11 , 2004
date. See Section 2.3(a) of the Sale Agreement. PacifiCorp s share of this amount is 47.5%. The
sale price is determined in such a manner that PacifiCorp will receive its net book value of the
assets being transferred. After taxes and closing costs, PacifiCorp estimates a net loss from the
sale of$68 613.
Despite the relatively small projected financial loss on the sale, Staff believes there are
other factors that should also be considered. First, as one of the Owners, PacifiCorp must pay its
proportionate share of the ongoing costs of the Project. The Company s analysis and market price
forecast predicts that ratepayers will see lower costs if the Project is sold because the projected
cost of power from the Project substantially exceeds the projected cost of market power.
According to PacifiCorp, the Project's bus-bar cost in fiscal year 2003 (12 months ending
March 31 , 2003) was approximately $255 per MWh. Market prices are not forecast to approach
that level for any extended period of time in the near future. According to PacifiCorp, the
expected impact ofthe sale is to lower the Company s future revenue requirement by removing
the Project from the Company s rate base and revenue requirement. The Company calculates the
expected present value of the future reduction in Idaho revenue requirement is approximately
$700 000 on a present value basis. Staff accepts these calculations for the sale analysis.
Second, PacifiCorp notes that the proposed transaction eliminates the risk that the
Company will be required to fund its share of expenditures for ensuring the structural integrity of
the Skookumchuck Dam. The Company believes it is likely that the FERC will mandate dam
modifications to meet stability criteria. PacifiCorp s share of this investment is estimated to be $4
million.
Third, the Skookumchuck Project has an electrical capacity of only 1 MW. Moreover
because the Project is operated for purposes of supplying cooling water to the Centralia Power
Plant, PacifiCorp states that it has relatively low energy output. Over the last eight years, the
average annual production has been approximately 3 000 MWh per year, and over the last four
years the output has been limited to about 1 000 MWh/year. This represents a very low capacity
factor for a hydroelectric plant. PacifiCorp s share ofthe Plant's output is extremely small in
comparison to the Company s other generating resources.
Finally, the Project no longer represents "core business" assets to any ofthe current
Owners because they no longer have any ownership interest in the Centra1ia Steam Plant.
Operation of such a small plant located so far from any other PacifiCorp facilities is problematic.
STAFF COMMENTS MARCH 2004
In summary, PacifiCorp contends that the benefits from the proposed sale outweigh the
risks of rising costs of continuing to own and operate the Proj ect. Continued operation of the
Project as a hydroelectric project, the Company contends, would be uneconomic, and such
operation would not be in the public interest. Staff agrees. All things considered, Staff believes
that selling the Project is a lower cost long-term option than continuing to invest in and operate
and maintain the Project.
PacifiCorp states that it is informed that Washington LLC will continue operation of the
Project to provide cooling water supply to the Centra1ia Power Plant and that it will produce
power from the Project either as an EWG or as a Qualifying Facility under PURP A. None of the
electrical output ofthe Project will be used to serve PacifiCorp s retail customers, except perhaps
indirectly through the wholesale power markets. The facility is interconnected with the
distribution system of Puget Sound Energy, Inc. (PSE) and historically all of the power from the
Project has been sold to PSE.
Public Interest Standard
PacifiCorp contends that the transfer of the Skookumchuck Project to Washington LLC is
in the public interest because it will benefit PacifiCorp s customers by lowering the Company
cost of providing electrical service. In addition, PacifiCorp states the transfer will give TransAlta
greater control of the water flows in the Skookumchuck River for providing cooling water to the
Centralia Power Plant, thus increasing the electrical output of the Centralia Power Plant for the
benefit of all electricity consumers.
As always, the public interest standard can be rather difficult to define, but in this case
Staff believes the appropriate measure of whether the public interest standard is met is the effect of
the sale on PacifiCorp s ratepayers. Staff agrees that the Company s ratepayers will not be
harmed by the sale, thus Staff believes that the sale does, in fact, meet the public interest standard.
Ratemaking Treatment
PacifiCorp, as co-owner of the Project with a 47.5% interest has been one of the primary
parties in the sales negotiation. Negotiation costs and all other costs of the sale are being directly
assigned to a work order associated with the sale. Labor costs for legal and technical services
represent the largest component of the sales cost for PacifiCorp.
STAFF COMMENTS MARCH 11 , 2004
Because the Project is being sold at PacifiCorp s book value, the gain or loss on the sale of
the Project is determined by the sales cost and any reimbursement offsets. PacifiCorp does not
propose to recover any of the costs of sale, i.e. loss on the sale, from customers. If a test year
includes these costs, they will be normalized out of the results. PacifiCorp states that if a gain
should occur on the sale, that it will be passed 100% to customers.
Staff recommends PacifiCorp be directed to file the final accounting entries associated
with the sale within 45 days of closing. PacifiCorp accepts this recommendation. Any revenue
requirement reduction from not operating the Project will be reflected in PacifiCorp s results of
operation. As such, Staff represents that this change will be reflected in a future PacifiCorp rate
proceeding.
STAFF RECOMMENDATION
Staff recommends approval of the Company s Application to transfer the Skookumchuck
Project to Washington LLC. In addition, to allow the Project to become an "eligible facility
within the meaning of Section 32 ofPUHCA, Staff recommends that the Commission s Order
specifically state that the proposed sale (1) will benefit consumers, (2) is in the public interest, and
(3) does not violate Idaho state law. Staff also recommends the final accounting entries be filed
with the Commission within 45 days of closing.
Respectfully submitted this 7f,
1/
day of March 2004.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
Terri Carlock
i:umisc:comments/paceO4. 1 swrps
STAFF COMMENTS MARCH 11 2004
FROM:STOEL R lUES LLP 88-12-99FRX NO.583 228 2488
Citation
IS USCA s 79z.
15 U.CA. ~ 797.-
Found Documem Rank I of
UMTED 5T A TES CODE ANNOTATED
TITLE 15. COMMERCE AND TRADECHAPTER lC..PUBLIC UTILITY HOLDING COMPANlES
Copr, '0 West 1999. No Claim to Orig, U.S, GOY!. Works
Current through P.L. 106-20. approved 4-
~ 79z-5a. Exempt wholesale generators
(a) Defrnitions
For puI'J)Oses of tbis section--
(1) Exempt wholesale generator
18 : 28~P , e::
Page 1
Database
USCA
The term "c::tempt wholesale generator" means any person determined by the Federal Energy RegulatoryCommission to be engaged directly. or indirced)' through one: or more affiliates as defined in section79b(a)(1l)(B) of this title, and exclusively in the business of owning or operating. or both owning and operating,all or pan of one or more eligible facilities and selling electric energy at wholesale. No person shall be deemed to
be an exempt wholesale generator under this section unless ~uch person has applied to the Federal Energy
Regulatory Commission for a determina.tion under this paragraph. A person applying in good faith for such adetermination shall be deemed an exempt wholesale generator under this section, "",'ith all of the e~ernptionsprovided by this section, until the Federal Energ:-' Regulatory Commi$sjon makes such determination. TheFederal Encrg)' Regulatory Commission shall make such determination within 60 days of its receipt of suchapplication and shall notify the C:ommis...ion whenever a determination is made under this paragraph that an)'person is an e:tempt wholesale generator. Not later than 12 months after October 24. 1992 , thl:: Federal EnergyRegulatory Commission shall promulgate rules implementing the provisions of this paragraph, Applications fordetermiruHion filed after the effective date of such rules shall be subject thereto.
(2) Eligible facility
The term "eligible facility " means a facility, wherever located, which is ~ither--
(A) used for the generation of electric energy exclusively for sale at wholesale , or
(B) used for the generation of electric energy and leased to one or mor~ public utilir:' companies; Provided.That any such lease shall be treated as a sale of electric energy at wholesale for purposes of sections 824d and824e of Title 16.
Such term shall not include any facility for which consent is required under subsection (c) of this section if suchconsent has not been obtained, Such term includes interconnecting transmission facilities necessary to effect a saleof electric energy at wholesale, For purposes of this paragraph. the term "facility" may include a ponion of afacility subject to the limiutions of subsection (d) of this section and shall include a facility the conmuction of
which has not been commenced or completed.
(3) Sale of electric energy at wholesale
The term "sale of electric energy at wholesale" shall have the same meaning as provided in section 824(d) of
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15 USCA s 19z-Page 2
Title 16.
(4) Retail rates and ch;J.rges
The tenn "retail rates and charges . means rate$ and charges for the sale of electric energy directly to consumers,
(h) Foreign retail sales
Notwithstanding paragraphs (1) and (2) of subsection (a) of this section. retail sales of electric: energy producedhy a facility located in a foreign country sh:1l1 not prevent such facility from being aneligiblc facility. or prcvcnt a
person owning or operating. or both ownins and operating, such facilit)' from being an exempt wholes:1legenerator if none of the electric energy generated by such facility is sold to consumers in the United States.
(c) State consent for existing rate-based facilities
If a rate or charge for. or in connection with, the construction of a facility, or for electric energy produced by a
facility (other than any portion of a rate or charge which repretient~ recovery of the Cost of a wholesale rate orcharge) was in effect under the laws of any State a.~ of Octobc! 24. 1992, in order for the facility to be consideredan eligible facility, every State commission ha..'ing jurisdiction over any $uch rate or charge must make a specificdetermination that alloviing such facility to be an eligible facility (1) will benefit consumers
, (2) is in the publicint~r~sl. and (3) docs not violate Scate law; Provided. That in the case of such a rate: or charge which is a rate ort:harge of an affiliate of a registered holding company:
(A) such det~rminalion with respect to the facility in question shal! be required from every State commissionhaving jurisdiction over th~ retail rates and charges of the affiliates of such registered holding compl1I1)'
; nnd
(8) the approval of the Commission under this chaptcr shall not be required for the transfer of the facility to an
exempt wholc;sale generator,
(d) Hybrids
(1) No exempt wholesale generator may own or operate a ponion of an)' facility if any other portion of thefacility is owned or operated by an electric utility company that is an affiliate or associate company of suchexempt wholesale: generator.
(2) Eligible facility
NoN.;ithsranding paragraph (1). an exempt wholesale generator may o"'n or operate a portion of a facilityidentified in paragraph (I) if such poniull has bt:come an eligible facility as a result of the operation of subsection(c) of this section.
(e) Exemption of EWGS
An exempt wholesale generator shall not be comidered an electric Utiliry company under ~ection 79b(a)(3) of thistitle and. whether or not a subsidiary company. an affiliate, or an associate company of a holding company, ane~empt wholesale generator shall be exempt from all provision$ of this chapter.
(f) Ownership of EWGS by exempt holding companies
Nolwithstanding any provision of this chapter. a holding company that i$ exempt under section 19c of this titleshall be permitted, withoUt condition or limitation under this chapter, to acquire and maintain an interest in thebusiness of one or more exempt wholesale generators.
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FROM:STOEL R lUES LLP FRX NO.583 228 2488 88- t 2-99 18 : 29..P ,
15 USC/\ s 79z-Page 3
(g) Ownership of EWGS by registered holding companies
Nocwilbsunding any provision of this chapter and the Commission s jurisdiction as provided under subsection (h)
of this section, a registered holding compJ!11)' shall be permitted (\J,.'ithout the need to apply for, or receiveapproval from tbe Commission. and otherwisl: without condition under this chapter) to acquire and hold thesecurities. or an interest in the business. of one or more eAempt wholesale generators.
(h) Financing and other relationships between EWGS and registered holding I:ompanies
The issu.ancc of securities by a registered holding company for purposes of fmancing the acquisition of an c;cmpt
wholesale: generator. the guarantee of securities of an exempt wholesale generator by a registered holdingcompany. the entering intO service . sales or construction contracts. and the creation or maintenance of any otherrelationship in addition to that describea in subsection (g) of this section between an exempt wholesale generatorand a registered holding company, its affiliates and associate companies. shi1l1 remain subject to the jurisdiction ofthe Commission under this chapter: Provided, That--
(1) section 79k of this title shall not prohibit the ownership of an interest in the business of one or more exempt
whC'1le~ale generator~ hy a registered holding company (regardless of where facilities ourDed or operated by suehexempt whole5alc generators are locatcd), and such ownership by a registered holding company shall bc deemcd
consistent with the operation of an integrated public utility ~y~tem;
(2) the o\.rnership of an interest in the business of one or more exempt wholesale generators by a registeredholding company (regardless of where facilities owned or operated by such exempt wholesale generators arelocated) shall be considered as reasonably incidental. or economically necessary or appropriitu:, to the operationsof an integrated public utility system:
(3) in determining whether to approve (A) the issue or sale of a security by a registered holding company forpurposes of financing the acquisition of an exempt wholesale generator, or (B) the guarantee of a security of anexempt ~'hnle~ale gener:!ror by a registered holding company, the Commis~ion ~hall not make a finding that such
security is not reasonably adapted 10 the earning power of such company or to the security structUre of suchcompany and other companies in the same holding company system, or that the circumstances are such as tocC'nstitute thc making of such guarantee an improper risk fOT such compan)'. unless the Commission first find:; thatthe issue: or sale of such securit),. or the making of the guarantee. would hayc a substantial adverse impact on the
financial integrity of the registl:red holding company $ystem:
(4) in determining whether to approve (A) the issue or sale of :& security by a registered holding company forpurposes other than the acquisition of an exempt whole:sale generator , or (B) otbertransactions hy such registeredholding company or by itS subsidiaries other than with respect to exempt wholesale gener.ator~. the Commission
shall not consider the cffe!;t 1)( the capitalization or earnings of any subsidiary which is an exempt wholesalegenerator upon the regi~tered holding company system. unless the approval of the issue or sale or othertransaction. togelher with the effect of such capitalization and earnings , would have a substantial advent impacton the financial integrity of the registered holding company system:
(5) me Commission shall make its decision under paragraph (3) to approve or disapprove the issue or sale of a
security or the guarantee of a security within 120 days of the filing of a declaration concerning such issue. sale orguarantee; and
(6) the Commissicm shall promulgate regulations with respect to the actions which would be considered. forpurposes of this subsection, to have a substantial adverse impact on the financi.u integrity of the registered holding
company system; such regulations shall ensure that the action has no ad,,'erse impact on any Utility subsidiary orits customers. or on the ability of State commissions to prorect ~uch subsidiary or Customers. and shall take intoaccount the amount and type of capital invcslcd in exempt \J,.'holesale generators, the ratio of such capital to thetotal capital invested in utility operalions. the availability of books and records, and the flIlancial and operating
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15 USCA s 19z-Page 4
experience of the registered holding company and the exempt wholesale generator: tbe Commission shallpromulgate such regulations within 6 months after October 24, 1992: after such 6-month period the Commissionshall not approve any actions under paragraph (3), (4) or (5) except in accorc1mce with such issued regulations,
(i) Application of chapter to other eligible facilities
!D the case of any person engaged directly and e~clusively in the business of o~ or operating (or both owningand operating) aU or part of one or more eligible facilities. an advisory leaer issued -by the Commission sufIundcr this chapter after October 24, 1992, or an order issued by the Commission under this chapter after October, 1992. shall not be required for the purpose , or have the effect. of exempting such person from treatment as anelectric utility company under section 79b(a)(3) of this title or cxc:mptiug su.c:h person from any pt'ovision of this -chapter.
(j) Ownership of exempt wholesale gencraIOr5 and q112lifying facilities
The ownership by a person of one or more exempt wholesale generators shall not result in such person being
coasidered as being primarily engaged in the generation or sale of electtic power within the meaning of sections796(t7)(C)(ii) and 796(18)(B)(ii) of Title 16.
(Ie) Protection against abusive aftUiatc: transactions
(l) Prohibition
After October 24, 1992 , an elcctric utility company may not cnter into a contract to purchase dearie cnergy wholesale from an exempt wholesale generator if the exempt wholesale generator is iIn affiliate or IlSsociatecompany of the electric utility company.
(2) State aurhority to exempt from prohibition
Notwithstanding paragraph (1). an electric utiliI)' company may emer into a conrractto purchase electtic energy
at wholesale from an exempt wholesale gcna:rator that is 3II. affIliate or associate company of the electric utilitycompany-
(A) if every State commission having jurisdiction OVer the retail rates of such electric Utility company makeseach of the following specific determinations in advance of the electric utility company entering into such contract:
(i) A determination that such commission bas sufficient regulatory authority. resources and access to books and
records of the electric utility company and any relevant associate. affiliate or subsidiaI)' company to exercise itsduties under this subparagraph.
(ii) A detc:rminatioD that the transaction.-
(I) will beDefit consumers
(II) does not violate any State law (including where: applicable. least cost pl:mning),
(III) would not provide the exempt wholesale genct'11tor any unfair competitive Qd"':mt:tg~ by virtue of itsaffiliation or association with the electric utility company. and
(IV) i$ in the public interest: or
(B) if such electric utility company is not subject to State commission retail rate regulation and the purchased
electric energy:
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15 USCA s 79z-
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(i) would nO( be resold ro any affiliate or associate: company. or
(ii) the purcha..~d electric energy would be resold to ;u'J afflliatc or associate company and every S~tecommission having jurisdiction over the retail rates of such afflliate or associate company makes each of thedeterminations provided under subparagraph (A), including the determination concerning a State commissionduties,
(I) Reciprocal arrangementS prohibited
Reciprocal arrangements amol1g companies that are nOt afnUalt:s or associate companies of each orner that arc:entered into in order (0 avoid the provisions of this section
2Il'c prohihitcd.
CREDIT(S)
1997 Main Volume
(Aug. 26, 1935. c. 687 , Title I, S 32, as added Oct. 24. 1992, Pub,L. 102-486,
Copr. iO West 1999 No Claim to Orig. U,S, GOVt, Works
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11 TH DAY OF MARCH 2004
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE
NO. PAC-04-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
ROBERT LIVELY
MANAGER REGULATION
ACIFICORP
201 S MAIN ST SUITE 2300
SALT LAKE CITY UT 84111
JAMES F FELL
JAMES C PAINE
STOEL RIVES LLP
900 SW FIFTH AVE SUITE 2600
PORTLAND OR 97204
DATA REQUEST RESPONSE CENTER
ACIFICORP
825 NE MUL TNOMAH SUITE 800
PORTLAND OR 97232
E- MAILED TO datarequest~JJacificorp, com
~~~~
SECRETARY
CERTIFICATE OF SERVICE