20070104Application.pdf

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2007 JAN -4 AH 9: 33 201 South Main, Suite 2300
Salt lake City, Utah 84111
IDA,HC F'UEi,
UTILITieS C()i\ii~,HSSIO:.
January 4, 2007
VIA OVERNIGHT DELIVERY
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702-5983
PA e--67
Attention:Jean D. Jewell
Commission Secretary
Re:In the Matter of the Application of Rocky Mountain Power for Approval of
Reductions in Bonneville Power Administration Regional Exchange Credits
Rocky Mountain Power, a division ofPacifiCorp, hereby submits for filing an original and seven
copies of its Application of Rocky Mountain Power for Approval of Reductions in Bonneville
Power Administration Regional Exchange Credits.
Service of pleadings, exhibits, orders and other documents relating to this proceeding should be
served on the following:
Brian Dickman
Manager, Idaho Regulatory Affairs
201 South Main, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: [phone]
E-mail: Brian.Dickman~PacifiCorp.com
Dean Brockbank
Senior Counsel
201 South Main, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: [phone]
E-mail: Dean.Brockbank~PacifiCorp.com
It is respectfully requested that all formal correspondence and Staff requests regarding this
matter be addressed to:
By E-mail (preferred):datarequest~pacifi corp. com
By Fax:[phone]
By regular mail:Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 800
Portland, OR 97232
Sincerely,
If(fr~-k'.~1 p.
/\,
Jeffrey K. Larsen
Vice President, Regulation
Enclosures
~ ('. i: \1 r- n
j ,
'" l... ",.. '
Dean Brockbank
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
FAX: [phone]
Dean.Brockbank~Pacifi Corp. com
2001 JAN - 4 AM 9: 33
IDAHO i~I \K)LIC
UTILITIES COlvH,'HSSIOi
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
FOR APPROVAL OF REDUCTIONS IN
BONNEVILLE POWER ADMINISTRATION
REGIONAL EXCHANGE CREDITS
PA c---07-
APPLICATION OF
ROCKY MOUNTAIN POWER
Pursuant to Idaho Code ~~ 61-301
, -
307
, -
622, and -623 , Rocky Mountain Power, a
division ofPacifiCorp ("RMP" or the "Company ), applies to the Idaho Public Utilities
Commission (the "Commission ) for approval of a revised Electric Service Schedule No. 34
submitted herewith. The proposed revisions reflect the reduced regional exchange credits
received from the Bonneville Power Administration ("BP A") in Idaho. The Company seeks
changes to sections ofthe Rocky Mountain Power s Schedule 34 to revise the Kilowatt-Hour
Credit Adjustment for all qualifying kilowatt-hours of residential and/or farm use. In support
this Application, PacifiCorp states as follows:
Rocky Mountain Power does business as a public utility in the state of Idaho and
is subject to the jurisdiction ofthe Commission with regard to its public utility operations.
Rocky Mountain Power also provides retail electric service in the states of Utah and Wyoming.
This Application is filed pursuant to the Idaho statutes referenced above. In
particular, Idaho Code ~ 61-623 empowers the Commission to address the propriety of requested
rate schedule increases, sections 61-307 and -622 require Commission approval prior to any
increase in rates and section 61-301 requires Idaho retail electric rates to be just and reasonable.
APPLICA nON OF ROCKY MOUNTAIN POWER -
Communications regarding this Application should be addressed to:
Brian Dickman
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Fax: (80l) 220-2798
E-mail: brian.dickman~pacificorp.com
Dean Brockbank
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Fax: [phone]
E-mail: dean.brockbank~pacificorp.com
In addition, PacifiCorp respectfully requests that all data requests regarding this matter be
addressed to:
Bye-mail (preferred)
By regular mail
datarequest~pac ifi corp. com
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
By facsimile [phone]
Informal inquires also may be directed to Brian Dickman at [phone].
As a regional utility, Rocky Mountain Power is entitled to participate in the
Residential Exchange Program (the "REP"), which extends the benefits of low-cost Federal
power to residential and small farm consumers served by investor-owned utilities in the region.
See section 5(c) ofthe Northwest Power Act, 16 U.C. ~ 839(c). The REP is administered by
BP A. In 2000, BP A offered the region s investor-owned utilities the option of entering into a
settlement ofthe REP (the "REP Settlement") in lieu of the traditional REP. All ofthe region
investor-owned utilities, including PacifiCorp, entered into the REP Settlement.
Upon initiation of the REP program, and as required by the REP Settlement, the
Company established balancing accounts tracking the differences in the program credits
APPLICA nON OF ROCKY MOUNTAIN POWER - 2
provided to the Company s customers and the monetary payments received from BPA pursuant
to the REP Settlement. As of October 2006, the Idaho balancing account showed a surplus of
$7.2 million (i. e.Rocky Mountain Power paid out $7.2 million less in benefits to Idaho
residential and small farm customers than Rocky Mountain Power had received from BP A).
In 2004 PacifiCorp reached agreement with BPA regarding the calculation of the
REP credits effective October 1 2006 through September 30, 2011 (the "FY 2007-2011
Agreement"). Per the terms of the FY 2007-2011 Agreement, REP benefits passed on to RMP
customers are less than benefits previously received from October 1 , 2001 through September
2006. The Company is proposing a reduction to the Schedule 34 credit amount to reflect the
change in the net credit received from BP A to be passed on to RMP customers. The Company is
also seeking Commission authorization to correct the surplus in the BP A balancing account in a
manner that would ease the customer impact of the current reduction in REP benefits and
mitigate future changes in REP benefit levels. PacifiCorp proposes to apply $1 million from the
existing Idaho balancing account toward the change in the 2007 BP A credit. This will moderate
the 2007 price change while preserving the positive amount in the Idaho balancing account for
subsequent years.
Pursuant to guidelines received from BP A and provided with this Application as
Exhibit 5, RMP is also proposing that certain long-term care facilities served by the Company be
eligible to receive REP benefits. Qualifying long-term care facilities would include those not
providing full medical care similar to hospitals or medical clinics and where the average patient
stay is 30 days or longer. The Company has identified eligible facilities served by Rocky
Mountain Power and has included them in the calculation of the proposed Schedule 34 credit
amount. Pending Commission approval, the Company will notify each eligible facility and will
move each to the applicable service schedule (i.e. Schedule 6A rather than Schedule 6, or
Schedule 23A rather than Schedule 23).
The Company submits the following exhibits providing additional support for the
relief requested in this Application:
APPLICA nON OF ROCKY MOUNTAIN POWER - 3
(a) Application Exhibit 1: Exhibit 1 shows the net impact by rate schedule of
the proposed revision to Schedule 34;
(b) Application Exhibit 2: Exhibit 2 reflects the calculation of proposed
Schedule 34 based on normalized twelve months ended September 2005;
(c) Application Exhibit 3: Exhibit 3 is a balancing account study reflecting
the Company s BPA balancing account history from October 2003 to October
2006. The Exhibit shows the $7.2 million surplus as of October 2006;
(d) Application Exhibit 4: Exhibit 4 reflects the Company s Schedule 34 and
shows the proposed tariff changes, pursuant to Rule of Procedure 121.01a; and
(e) Application Exhibit 5: Exhibit 5 presents the guidance received by RMP
from BP A regarding eligibility of long-term care facilities.
Rocky Mountain Power stands ready for immediate consideration of this
Application and requests that this filing be processed under Modified Procedure. Rocky
Mountain Power respectfully requests that the proposed reduction to the Schedule 34 BP A credit
be effective on February 15 2007, to permit proper notice pursuant to Idaho Code ~ 61-307. The
proposed tariffs in Application Exhibit 4 would be effective on February 15 2007 unless
suspended by the Commission. Due to the nature of this filing, the Company does not believe a
hearing will be necessary.
WHEREFORE, PacifiCorp respectfully requests that the Commission enter its Order
authorizing the reduction of the Schedule 34 BP A credit to further reflect the net effect of the
annual credit received from BP A with the annual credit passed on to Idaho residential and small
farm customers.
DATED this 4th day of January, 2007.
Respectfully submitted
Dean Brockbank
Attorney for Rocky Mountain Power
APPLICATION OF ROCKY MOUNTAIN POWER - 4
APPLICATION EXHIBIT
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EXHIBIT 3
ROCKY MOUNTAIN POWER - STATE OF IDAHO
RESIDENTIAL EXCHANGE BALANCING ACCOUNT STUDY
October 2003 - October 2006 Study
BPA Variance Customer Interest Accumulated
Month Payments Booked Credits Booked Balance
Balance Forward ($6 020 373)
Oct-939 595 ($142 675)796 920 ($5 877 698)
Noy-939 595 ($1 248 215)691 380 ($4 629 483)
Dec-939 595 ($1 040 716)898 879 ($3 588 767)
Jan-939 595 ($849 118)090 477 ($2 739 649)
Feb-939 595 ($1 143 558)796 037 ($1 596 091)
Mar-939,595 ($1 387 894)551 702 ($208 197)
Apr-939 595 ($1 578 265)361 330 103 371 171
May-939 595 ($41 426)898 170 190 413 787
Joo-939 595 025 463 965 059 ($611 676)
Jul-939 595 031 780 971 375 ($3 643 456)
Aug-939 595 453 556 393 152 ($6 097 012)
Sep-939 595 $718 775 658 370 ($6 815 787)
Subtotal $35 275 144 I $797 707 $36 072 851 293
Oct-931 564 ($549 360)382 204 ($6,266 428)
Noy-931 564 ($1 390 832)540 732 ($4 875 596)
Dec-931 564 ($994 892)936 672 ($3 880 704)
Jan-931 564 ($1 038 376)893 188 ($2 842 328)
Feb-931 564 ($1 355 205)576 359 ($1,487 124)
Mar-931 564 ($1 623 788)307 775 $278 $136 942
Apr-931 564 ($1 787 520)144 044 182 928 644
May-931 564 ($1 510 877)420 687 405 447 927
Joo-931 564 ($669 219)262 345 $10 190 127 335
Jul-931 564 194 347 125 911 948 940 936
Aug-931 564 632 557 564 121 735 312 114
Sep-931 564 $521 288 452 852 307 $793 133
Subtotal $35,178 766 I ($7 571 876)$27 606 890 $37 044
Oct-931 564 ($856 390)075 174 229 654 752
Noy-931 564 ($1 689 252)242 312 $10 762 354 766
Dec-931 564 ($1 251 440)680 124 $16 038 622 244
Jan-931 564 ($1 302 684)628 880 $21 364 946 292
Feb-931 564 ($1 395 602)535 962 $24 896 366 790
Mar-931 564 ($1 500 380)431 184 $33 985 901 156
Apr-931 564 ($1 739 131)192 433 $41 188 $10 681,474
May-931 564 ($1 167 640)763 924 $49 068 $11 898 182
Joo-931 564 $498 657 430 221 $46 757 $11 446 282
Jul-931 564 915 286 846 849 $41 761 572 758
Aug-931 564 631 166 562 730 $35 066 976 658
Sep-931 564 $984 006 915 570 $29 907 022 558
Oct-775 504 ($188 588)586 916 $31 915 243 061
Subtotal $36 954 270 ($6 061 992)$30 892 278 $387 935
Totals $107 408 180 ($12 836 161)$94 572 019 $427 273
APPLICATION EXHIBIT 4
~~~\~~OUNTAIN
Co No.First Revision of Original Sheet No. 34.
Cancelin Ori inal Sheet No. 34.
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO. 34
STATE OF IDAHO
Pacific Northwest Electric Power Planning and Conservation Act
Residential and Farm Kilowatt-Hour Credit
APPLICATION AND AVAILABILITY: This Schedule is applicable and available to qualifying
Residential and/or Farm Customers of the Company under the jurisdiction of the Idaho Public Utilities
Commission.
MONTHLY RATES: The monthly charges for service under each of the Electric Service
Schedules shown below shall be reduced by the appropriate monthly kilowatt-hour credit adjustment shown
per kilowatt-hour for all qualifying kilowatt-hours of residential and/or farm use.
Kilowatt-Hour Credit Adjustments:
Irrigation Customers:
Schedule No. 10
$0.031516026415 per kWh
Non-Irrigation Customers:$0.019216016757 per kWh
Schedule Nos. 1 , 6A, 7A, 23A
35A, 36, 19 with 6A
19 with 23A, 19 with 35A
(Continued)
I Submitted Under Advice Letter No. 0 016-%
I ISSUED: i\ugust 11 , 2006January 4 2007 EFFECTIVE: September 15 , 2006Februarv 15.2007
~I~OUNTAIN
C. No.First Revision of Sheet No. 34.
Canceling Original Sheet No. 34.
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.
STATE OF IDAHO
Pacific Northwest Electric Power Planning and Conservation Act
Residential and Farm Kilowatt-Hour Credit
APPLICATION AND AVAILABILITY: This Schedule is applicable and available to qualifying
Residential and/or Fann Customers of the Company under the jurisdiction of the Idaho Public Utilities
Commission.
MONTHLY RATES: The monthly charges for service under each of the Electric Service
Schedules shown below shall be reduced by the appropriate monthly kilowatt-hour credit adjustment shown
per kilowatt-hour for all qualifying kilowatt-hours of residential and/or fann use.
Kilowatt-Hour Credit Adjustments
Irrigation Customers:
Schedule No.1 0
$0.026415 per kWh
Non-Irrigation Customers:$0.016757 per kWh
Schedule Nos. 1 , 6A, 7A, 23A
35A, 36, 19 with 6A
19 with 23A, 19 with 35A
(Continued)
Submitted Under Advice Letter No. 07-
ISSUED: January 4 2007 EFFECTIVE: February 15 2007
APPLICATION EXHIBIT
Department of Energy
Bonneville Power Administration
O. Box 3621
Portland, Oregon 97208-3621
POWER SERVICES
December 8, 2006
In reply refer to: PFR-
Mr. Scott Brattebo, Director Regulatory
PacifiCorp
825 N.E. Multnamah, Suite 600
Portland, OR 97232
DearM
Re: Residential Exchange Program Settlement Agreement, BPA Contracts: 01PB-12229,
0 I PB-l 0854, 03PB-11262, and 04PB-11468, and Recent Determination Decision and
Eligibility Guidelines
Yau recently made a request to Paul A. Brodie that BP A issue a Residential Exchange Program
(REP) Eligibility Determination that provided guidance on how to allocate the metered load
between nursing homes and hospitals where they are part of ajoint-use-facility. Enclosed is a
copy of BPA's decision on the treatment of nursing home loads associated with ajoint-use-
facility.
In order to help ensure uniform and consistent treatment, we ask that PacifiCorp please review its
application of the REP credit to nursing homes that are eligible to receive the credit. BPA is
sending a copy of this determination decision to each investor-owned utility and the state
commissions to help ensure consistent nursing home eligibility determinations. In addition to the
eligibility decision, we have also included a copy ofBPA'Customer Load Eligibility Guidelines
for your reference to help guide your staff in making decisions concerning eligible loads. In
those instances where a fact situation has not been encountered before, or where the policy
outlined in the guidelines does not clearly address the facts surrounding an eligibility
determination question, please consult BP A in making the eligibility determination. In the event
that a retail customer feels that they qualify for the REP Settlement Credit after having been
denied the credit by an investor-owned utility, they are entitled to a final eligibility determination
by BPA.
We look forward to working with you and your staff regarding eligibility determinations in
addition to addressing any questions or concerns that you might have on procedures and policies
used to account for and distribute REP Settlement benefits. If you have questions concerning
BPA's REP Settlement Program, please call Paul Brodie at [phone]. Thank. you for your
help in supporting the administration of this important program.
---
Mark O. endr ,
Vice President for Northwest Requirements Marketing
2 Enclosures
cc:
John R. Gale, Vice President for Regulatory Affairs, Idaho Power Company
Randy Lobb, Administrator Utilities Division, Idaho Public Utilities Commission
. "
December 8, 2006
Residential Exchange Program (REP) Settlement Load Eligibility Determination
Eligibility of Nursing Homes. Long-Term Care Facilities. and Assisted Living Care
Facilities to Receive the REP Credit
Section 3(18) ofthe Northwest Power Act defines "residential use" or "residential load"
as "all usual residential, apartment, seasonal dwelling and farm electrical loads or uses,
but only the first four hundred horsepower during any monthly bi11ing period of farm
inigation and pumping for any farm." Exhibit A of the REP Settlement Agreements also
helps to define eligible residential loads, but is silent regarding nursing homes and
hospitals. BPA'Customer Load Eligibility Guidelines, however, provide the following
guidance on qualifying loads:
Nursine Home - The loads associated with nursing homes are eligible to receive
the Residential Exchange program credit. When the average length of stay is
30 days or longer and does not provide full medical care similar to the medical
facilities, equipment, and staff normally provided by hospitals, clinics, or similar
institutions.
Hospitals - The loads associated with hospitals are ineligible to receive the
Residential Exchange Program credit. These loads are neither a farm nor a
residence.
The electrical loads for nursing homes, long-term care facilities, and assisted living care
facilities generally qualify for the REP credit. A general guideline is that when the
average length of stay is 30 days or longer, the dwelling or facility qualifies as a
residence. Residences that qualify for the credit can be single family or multi-family
dwellings. If the assisted living facility provides full medical care that is similar to the
medical facilities, equipment, and staffing of a hospital, then that portion of the facility
electrical loads would be ineligible. Generally, most of the load associated with an
assisted living facility would qualify for the credit.
As the demographics of our society change with the "graying of America " more and
more people wi11 be choosing to live in retirement centers and assisted living facilities.
These facilities are the new residences of an increasing share of the population. The
residents of these facilities are intended to receive a benefit from lower electrical rates
due to the REP credit. It is also important that there is a level playing fIeld associated
with the ownership and operation of the facilities receiving the REP credit to ensure that
there is not a competitive advantage or disadvantage due to disparate policies of utilities
receiving REP benefits.
In order to ensure that all eligible residential ratepayers who are served by qualifying
investor-owned utilities receive REP benefits and to ensure that there is a level playing
field for the nursing home industry in the Pacific Northwest, it is important that all
utilities participating in the REP Settlements review their regulatory practices
surrounding the eligibility of these facilities.
Guidance in Determining the Eligibility of Loads Associated with Joint Use Facilities
There area number of nursing home and care facilities in the region that are physically
connected to hospitals or clinics providing higher levels of medical care. These occur for
the most part in smaller rural communities that cannot afford to run separate facilities.
Frequently the electric loads associated with the nursing home facility and the hospital
are metered through a single meter. The utility administering the REP needs to make a
reasonable attempt to separate the metered load associated with the nursing home facility
in determining the loads that are eligible to receive the credit. BP A was asked to furnish
guidance in developing a method to determine the portion of the metered load that
qualifies for the credit.
One simple approach for estimating the portion of metered loads attributed to a nursing
home facility is to base it on the square footage of the facility that is connected to nursing
home care in relation to the total square footage of the nursing home and hospital areas
combined. The first step in thisca1culation is to determine the square footage of the
common areas of the joint facility such as administrative offices, maintenance facilities,
food preparation areas, laundry facilities, and similar common areas. This amount should
be subtracted from the total square footage of the combined nursing home and hospital
facility. The second step is to determine the square footage that is directly used for the
nursing home. The third step is to determine the square footage that is used directly for
the hospital. The fourth step is to take the ratio of the nursing home square footage to the
combined nursing home and hospital areas. The ratio determined by the fourth step is
applied to the total facilities metered load (nursing home, hospital and common areas).
This determines the REP-eligible load of the nursing home. This allocation approach
assumes that the square footage of the direct usage areas (hospital or nursing home) is a
reasonable indicator of what function (hospital or nursing home) the power used in the
common area is supporting. An example of this allocation approach is presented below:
Example:A small rural town in southern Idaho has a combined hospital and
nursing home facility that has a single electric meter. The total facility comprises
100,000 square feet. A review of the facility by the Investor-Owned Utility
customer service representative disclosed that 60 000 square feet were directly
used by functions associated with the hospital, 30,000 square feet were directly
used in providing nursing home care, and 10,000 square feet were associated with
common areas (food preparation areas, maintenance and storage, laundry
facilities, and administrative offices). Ninety-percent of the facility (90,000 sq. ft.
divided by 100,000 sq. ft.) was associated with direct usage. The nursing borne
care portion comprised 33 percent (one-third) of the direct use areas (30,000/
....,- ,
. '
(30,000 + 60,000). The customer service representative determined that one-third
of the total monthly metered amount would be eligible load qualifying for the
REP credit.
The above allocation method of square footage was chosen for its simplicity and ease of
use. For other joint use facilities, the utility administering the REP credit should develop
a method for determining the allocation of the metered energy into eligible load
qualifying for the REP credit versus ineligible load that does not qualify for the REP
credit and apply the methodology on a consistent basis to all joint use facilities.
Determination: Nursing homes, assisted living facilities, and similar facilities qualify for
the REP Credit. Nursing homes, assisted living facilities, and similar facilities that are
physically connected to a hospital facility also qualify for the REP Credit. Where both
the nursing home facility (qualifying load) and the hospital facility (non-qualifying load)
have their electrical power requirements metered through a single meter, utilities should
use the foregoing allocation method to detennine that portion of the metered energy that
is attributable to the qualifying load.
Wa.
Paul A. Brodie, CPA,
Residential Exchange Settlement -
Benefits Oversight Function