20120323Reply Comments.pdf

ROCKY MOUNTAIN
POWER
A DIVISION OF PACIRCORP
March 22, 2012
VIA ELECTRONIC FILING
AND OVERNIGHT DELIVERY
RECEWE 0
2U2 MAR 23 AM tO: 30
IDAHO PUBLIC UTIUTS C)MMISS1ON
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Re: Case No. PAC-E-12-03
In the Matter of the Application of Rocky Mountain Power for Authority to Increase
Rates by $2.6 Million to Recover Deferred Net Power Costs Through the Energy Cost
Adjustment Mechanism
Dear Ms. Jewell:
Please find for electronic filing Rocky Mountain Power's reply comments in the above
referenced matter. The Company has also shipped for overnight delivery an original and nine
copies of its reply comments along with a CD containing the reply comments and Exhibit 1 in
executable format.
All formal correspondence and questions regarding this Application should be addressed to:
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Yvonne Hogle
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Fax: [phone]
Email: Yvonne.hogle(pacificorp.com
Communications regarding discovery matters, including data requests issued to Rocky Mountain
Power, should be addressed to the following:
By E-mail (preferred): [e-mail]
By regular mail: Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 2000
Portland, OR 97232
Idaho Public Utilities Commission
March 22, 2012
Page 2
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
I K. [~O I. lCen,
Vice President, Regulation & Government Affairs
Enclosures
CERTIFICATE OF SERVICE
I hereby certify that on this 22m1 of March, 2012, I caused to be served, via e-mail and
U.S. Mail, a true and correct copy of the foregoing document in PAC-E-12-03 to the
following:
James R. Smith (E-mail Only)
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
E-Mail: jim.r.smith(àmonsanto.com
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-Mail: [e-mail]
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey,
Chartered
201 E. Center
P.O. Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]
Carrie Meyer
Coordinator, Regulatory Operations
Mark C. Moench
Yvonne R. Hogle
Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
Telephone: [phone]
Fax: [phone]
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF PACIFICORP DBA
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE RATES BY
$2.60 MILLION TO RECOVER
DEFERRED NET POWER COSTS
THROUGH THE ENERGY COST
ADJUSTMENT MECHANISM
CASE NO. PAC-E-12-03
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
COMES NOW PacifiCorp, dba Rocky Mountain Power ("RMP" or the
"Company"), and, pursuant to Rules 56 and 256 of the rules of Procedure of the Idaho
Public Utility Commission (the "Commission"), hereby submits reply comments in the
above referenced case.
Background
On February 1, 2012 the Company filed an application ("Application") for
authority to adjust Schedule 94, Energy Cost Adjustment Mechanism ("ECAM") rate by
$2.6 million, establishing the ECAM rate for all customer classes including Monsanto
Company ("Monsanto") and Agrium, Inc. ("Agrium") based on the deferral period
beginning December 1, 2010 through November 30, 2011 ("Deferral Period").
1
The Company requested approval to add $18.1 million into the ECAM balancing
account for the Deferral Period, which would bring the total balance of the account to
$24.1 million as of November 30, 2011. The Company proposed to adjust Schedule 94 to
collect approximately $13.0 million over the period beginning April 1, 2012 through
March 31, 2013, representing an increase of $2.6 million over the current Schedule 94
rate.
On March 12, 2012, Monsanto filed a Motion to Extend Comment Deadline. On
March 19, 2012, Monsanto filed comments responding to the Application. Monsanto's
comments addressed losses in base load and actual load, treatment of replacement energy,
wind integration, and liquidated damages.
On March 20, 2012, Staff of the Idaho Public Utilities Commission ("Staff) filed
comments responding to the Application. Staffs audit of the Application identified an
error with the line loss factor used to adjust Actual loads from sales level to input.
Comments
The Company disagrees with Monsanto's assertion that, if the Company and
Staff do not agree with Monsanto's adjustments, the disagreement would necessitate
filing testimony and setting hearings on this issue. The Company, through its
Application, testimony, exhibits and work papers has presented its case. Staff and
Monsanto have reviewed the information along with the information provided by the
Company in response to several discovery requests and an on-site audit performed by
Staff. Both Staff and Monsanto have prepared and filed comments with the Commission.
These reply comments describe which of Monsanto's adjustments the Company believes
are appropriate and why they should or shouldn't be accepted. The Company believes
that the Commission has adequate information with the record in this case to make a
determination on the issues that were raised by Monsanto and Staff, and that there is no
need to file additional testimony or schedule a hearing in this Case.
Issues
1. Losses in Base Load and Actual Load
RMP agrees with Monsanto and Staff that the Company inadvertently did not
update the line loss factor used to adjust Idaho Actual loads from sales to input level and
used a line loss factor of 4.543% rather than 3.605%, effective December 28, 2010 to
align with the effective date of Case PAC-E-10-07. Table 1 is a summary of the line loss
impact from updating Actual loads based on a 3.605% line loss factor.
Table 1 - Line Loss Correction
Tariff Customers (51,734)
Monsanto 45,922
Agrium 3,807
Total Deferral (2,005)
RMP also agrees that different line loss factors were used for Base Loads in Case
PAC-E-10-07, but does not agree with Monsanto that this was an error or that any
adjustment should be made to Base Loads. As noted in the direct testimony of Peter
Eelkema in that case, 2009 actual loads were abnormally low for two reasons; (1)
Monsanto had furnaces down most of the year using approximately seventy to seventy-
three percent of normal usage and, (2) due to wetter than normal conditions, irrigation
load was significantly lower than normal.
Monsanto claims that had the Base Load for Monsanto been developed using the
line loss factor of 3.605 "Monsanto and Agrium 's Load Differentials reflect a more exact
3
difference between Base Loads and Actual Loads". The Company does not agree with
that assertion. First, all of the Base data in the ECAM is determined as part of a general
rate case. Monsanto, Staff and all other parties to the case had the opportunity to review
and determine the exactness of the Base Loads, NPC and all other components. It is not
appropriate nor is it a part of the ECAM review to revise any of the Base information that
has already been established in a prior case. Monsanto is attempting to re-litigate an
issue that has already been litigated, in violation of due process. These Base loads were
the basis for jurisdictional allocations, net power costs, cost of service and rate design in
that case. A party cannot arbitrarily change any of the Base components of the ECAM.
Second, even assuming the Commission were to ignore due process rights, a comparison
of Monsanto's Base Load of 1,351,296 MWh for January through November from Case
PAC-E-10-07 to Actual Load, adjusted for the correct line loss factor of 3.605%, yields a
difference of 2,255 MWhs, less than two-tenths of a percent difference from the Base
Load forecast in the general rate case. Monsanto's proposal would reduce its Base Load
to approximately 1,274,000 MWhs, creating load differential of approximately 75,000
MWhs. This would significantly increase the difference between Actual and Base load
and would only serve to allocate costs away from Monsanto to the Tariff Customers.
Base loads are determined and set as part of a general rate case, not in the ECAM
Application.
2. Treatment of ReDlacement Energy
The Company agrees with Monsanto's position that replacement energy
consumed by Monsanto when it buys through curtailment events rather than physically
curtail its load should not be part of the ECAM. As explained by Monsanto, replacement
'Monsanto's Comments, page 3 line 2-3.
4
energy was removed from Monsanto Base load but was not removed from Monsanto
Actual load. A review of Monsanto invoices reveals that it bought, through curtailment,
in October and November 2011, 5,293 MWh and 9,021 MWh, during curtailment events
in the respective months.2 This replacement energy should be removed from Monsanto
Actual load as well as actual Idaho jurisdictional load to properly compute the ECAM
deferral. Table 2 below shows the impact on the ECAM balance when the replacement
energy is removed from Actual load, resulting in a reduction of $19,666. The impact of
the Company's adjustment differs from the amounts calculated by Monsanto because
Monsanto did not account for October 2011 replacement energy in its calculation.
Table 2 - Replacement Energy Correction
Tariff Customers (797)
Monsanto (18,812)
Agrium (56)
Total Deferral (19,666)
3. Wind Integration Costs for Wholesale Wheeling Customers
The Company objects to Monsanto's adjustment to remove the non-owned wind
integration costs from the ECAM deferral balance. The Company's actual incurred costs
are indisputable and it is inappropriate for Monsanto to arbitrarily remove any costs from
the Company's prudently incurred actual costs without showing why they were not
"prudently" incurred. In addition, Monsanto's proposed adjustment to remove costs
associated with these facilities fails to recognize that any future revenues associated with
the Company's proposed Schedule 3A should also be removed based on the matching
principle.
2 The October 2011 replacement energy was inadvertently not included on the October 2011 invoice, but a
correction was included with the November 2011 invoice reflecting replacement energy in October 2011.
5
Contrary to Monsanto's comments, Commission Order No. 32196 in Docket No.
PAC-E- 10-07 ("2010 GRC"), and the Commission's following statement: "we find also
that the responsibility for recovery of wind integration costs from wholesale transmission
customers resides with the Company, not its retail customers 3." does not require the
Company to remove non-owned wind integration costs from the ECAM deferral balance.
The Company does not believe that this language was intended to prohibit the recovery of
prudent power supply costs that were incurred as a result of its role as a balancing area
authority. Rather, the Company understands this language to indicate that it has an
obligation to ensure that it receives compensation through its Open Access Transmission
Tariff (OATT) rates for all services it provides to its wholesale customers, including
integration. The record in the 2010 GRC does not support the notion of a Commission
finding that the Company was negligent in pursuing a transmission rate case with the
Federal Energy Regulatory Commission ("FERC").
More importantly, the Commission's decision in the 2010 GRC was to exclude
wind integration costs from the Company's Base NPC, excluding contractual wind
integration costs paid by the Company to Bonneville Power Administration. At that time,
Staff estimated the power supply expense associated with wind integration costs at
approximately $34.2 million 4 on a total system basis. The Commission went on to state
that "we are not happy with this end result, because we believe these integration costs
belong in base rate. 5" The Commission further commented that the ECAM was where
the Company must recover its wind integration costs, with the knowledge that a portion
of these prudently incurred costs would be automatically disallowed due to the imposed
See Order No. 32196, page 30.
4 See Order No. 32196, page 27.
5 See Order No. 32196, page 30.
sharing bands of the ECAM structure. The Company has already incurred a 10 percent
disallowance on its prudently incurred wind integration costs, which the Commission
believed should have been reflected within the Company's Base NPC. Therefore, the
Company believes it would be unreasonable for the Commission to further disallow wind
integration costs beyond the already imposed 10 percent sharing band.
In addition, Monsanto's estimation of non-owned wind integration costs is
incorrect and therefore inappropriately inflates Monsanto's calculation of the non-owned
wind integration costs that it proposes to remove from actual net power costs. Monsanto
used the sum of the inter- and intra-hour wind integration rates calculated in the Oregon
Transition Adjustment Mechanism ("2013 Oregon TAM") Docket UE 245 of
$3.87IMWh to calculate its adjustment. The non-owned wind facilities interconnected to
the Company's system are responsible for providing their own inter-hour wind
integration services. Therefore, Monsanto over-estimated its adjustment by using a wind
integration rate that included both the inter- and intra-hour wind integration cost
components that are included in the 2013 Oregon TAM rate provided above. The 2013
Oregon TAM wind integration inter-hour cost component is $0.89/MWh, the intra-hour
cost component is $2.98/MWh, not $3.87/MWh as used by Monsanto. If the Commission
determines that intra-hour wind integration costs should be excluded Table 3 below
shows the impact on the ECAM balance when the intra-hour cost component of
$2.98/MWh is removed.
7
Table 3 - Non-owned Wind Integration Excluding Inter-hour Integration
Tariff Customers (98,296)
Monsanto (67,041)
Agrium (5,194)
Total Deferral (170,530)
Finally, the Company is meeting its obligation to recover costs from its wholesale
transmission customers, and filed its transmission rate case with FERC on May 26, 2011,
under Docket No. ER1 1-3643. In that case, the Company proposed a new Schedule 3A
that will apply to all transmission customers delivering energy from generators in the
Company's balancing authority areas to other balancing authority areas, including the
non-owned wind facilities Monsanto used to calculate its adjustment. Monsanto's
proposed adjustment to remove costs associated with these facilities would also require
the removal of any future revenues associated with the Company's proposed Schedule 3A
based on the matching principle. The Company believes that this was not the intention of
the Commission in its resolution of the 2010 GRC.
4. Liquidated Damages
Monsanto proposes that the liquidated damages be recognized as an offset to
NPC rather than the project cost. However, accounting guidelines require that proceeds
received for liquidated damages go to property plant and equipment not NPC in almost
all circumstances. The underlying principle in the account guidelines is that unless the
customer provides the vendor with an identifiable benefit, the payment received from the
vendor is a reduction of the purchase price of the goods purchased from the vendor and
6 AICPA Guideline TPA 2210.28 —Accountina for Certain Liauidated Damaues
TIS Section 22 10.2828 relates to accounting for liquidated damages by the buyer of property, plant, and
equipment (PP&E). It states that the buyer should record liquidated damages as a reduction in the cost of
PP&E.
8
not an offset to net power costs. None of the Company's contracts specify NPC as the
benefit or determent for a variance in the delivery schedule of the project. Further,
language that references NPC in construction contract liquidated damages is not the
industry standard and it is very doubtful that any of the Company's vendors would allow
for the inclusion of such language. Thus, the costs get recorded as a reduction in the
purchase price of the project.
From a non-accounting, regulatory perspective, crediting NPC would be very
challenging. Either the capital projects in rate base that are associated with the liquidated
damages would need to be booked above the amount the Company actually paid in cash
to the contractor for the project. Or, another alternative would be to create a regulatory
asset. Either approach would result in customers paying an on-going rate of return over
multiple years for cash outlays that the Company never incurred. It is the Company's
historical practice and, consistent with accounting guidelines, to record liquidated
damages as an offset to the plant associated therewith. The Company has already reduced
electric plant in-service for the full amount of the liquidated damages. If Monsanto's
adjustment were accepted, it would double count the credit to the customers.
Conclusion
In conclusion, the Company agrees with Staff and Monsanto that the line loss
factor for actual loads should be corrected from 4.4543% to 3.605% effective December
28,2010. This reduces the deferral balance by $2,005 as summarized in Table 1. The
Company also agrees with Monsanto that its replacement energy should have been
removed from Actual NPC, reducing the total deferral balance by $19,666 as summarized
by Table 2.
The net effect of these corrections is a reduction of $21,671 which reduces the
ECAM deferred balance from $18,133,815 to $18,112,144. Table 4 summarizes the net
impact by customer group of the adjustments that the Company believes should be made
to its original Application.
Table 4- Summary Table of ECAM Deferral - Dec 2010 through Nov 2011
Tariff
Customers Monsanto Agnum Total
NPC Differential for Deferral 10,604,372 7,290,840 571,035 $ 18,466,247
LGAR/LCAR (371,075) 307,671 (35,191) (98,594)
S02 /ELIF-06 Adjustment 64,085 15,643 1,895 81,623
Total 10,297,383 7,614,154 537,739 $ 18,449,276
900/0 90% 90% 900/0
Customer Responsibility 9,267,644 6,852,739 483,965 $ 16,604,348
Renewable Resource Adder 283,124 0 0 283,124
REC Deferral 822,996 370,321 31,387 1,224,703
Interest (440) 376 32 (32)
Total Company NPC Deferral 10,373,325 7,223,435 515,384 18,112,144
For the reasons set forth above, the Company does not support adjustments to the
Base load, third party wind integration costs, or the liquidated damages. Finally, the
Company respectfully requests that the Commission approve the Company's Electric
Service Schedule No. 94 as filed in Exhibit 3. Due to the small amount of adjustments
proposed and the three-year amortization of Monsanto and Agrium' s deferred balance,
any adjustments ordered would have minimal impact to the rate. Also because the ECAM
is a balancing account, any over- or under-collection is trued up by next year's rate
design; thus, updating rates does not seem necessary.
WHEREFORE, Rocky Mountain Power respectfully requests that:
(1)the Commission process this Application under Modified procedure;
(2)the Commission approve the revised deferral of $18,112,176; and
10
(3) the Commission approve Electric Service Schedule No. 94 as filed effective April 1,
2012.
DATED this 22nd day of March, 2012.
NA1( C
ark C. Moench
Yvonne R. logic
Attorneys for
Rocky Mountain Power
11
Case No. PAC-E-12-03
Revised Exhibit No. 1
Witness: Gregory N. Duvall
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOUNTAIN POWER
Revised Exhibit Accompanying Direct Testimony of Gregory N. Duvall
March 2012
Idaho ECAM D.fstaI
December2010 through November 2011
Una
No. Dec-IS Jan-Il Feb-li Mar-411 Apt-11 May-11 Jan-ii ltd-Il Aag-111 Sep-li 0t-1t Nov-Il
I Base 1/PC Rate ($/MWS) -See ('I) below 16.93 14.76 14.63 1528 18.64 17.06 17.31 21.80 22.89 20.75 17.28 17.77
2 Total Company Adjusted Actual NPc($ 95,757,018 107,401,686 102,209,579 96,807,678 89,035,896 96,927,539 103,624,344 145,649,181 147,798,095 122,994,489 110,085,405 121,246,771 3 Actual R.fal Load iMbM,1 5,261 328 5,299 028 843 4,862 154 4,531,018 4,505,457 4,632,982 6.397 048 5.321 022 4. 850 341 4 ,821,700 4 ,895,7 71 4 Actual NPC (8/MctTh( Line 2/ Lim 2 1.28 2&27
4,652,
21.78 2)2.30 21.25 21.51 22.37 2.21 2'T8 2.29 2351 24.80
5 1/PC Differential $/MiMr = Line 4-Line I 1.27 8.51 7.18 8.00 4.58 4-48 0.05 4,611 4.58 0.93 5.54 7.19
8 Actual Tariff Customer Load 153,290 180,331 141,729 136,017 124,658 145,712 221,350 357,385 213,794 175,314 128,163 138.875 7 Actual Monsanto Load 129,817 105,200 125,188 124,430 125,105 126,815 130,231 123,354 92,830 128,020 117,259 8A40relAorbonLaad 15,731 9,477 10,513 10,174 5,934 4,821 5,296 5,030 9,547 10,087 9,551 o Actual Idaho 1.0.4 (M/Mi 153,290 360,978 090,488 274,889 288,401 200,781 352,908 499,531 345,717 277501 285,876 255,728
11 T.rlffCaatamerNPCforDelerrel aUna SLinet 193,953 883,682 1,013,881 890,331 568,724 849,500 1,115,712 1,647,210 1,043,005 068,554 538,083 997,037
11 MonaaeteNPC lerDeferral Line S * Line? 716,485 781,321 841,030 586,773 557,889 641,439 600,228 602,501 513,387 825,280 541,827 12 AGdam, 0880 far Deferral Lim S • Line 55,141 67,754 52,664 46,340 43,835 24,367 42,838 48,531 52,800 05,855 58,854
IS Total UPC Differential for Deferral (8) 193,883 1,055,288 1,892,400 1,373,845 9,181,838 1,281,254 1,788,819 2,250,275 1,592,837 1,835,742 1,733,302 1,907,718
14 Tariff Customer Sam Load 175,051 144,717 115,568 135,644 128,154 181.576 233,787 285,809 245,224 162,296 135,580 157,975 16 Monsanto Base Lao. 135,565 117,487 124,170 124,111 124,052 119,898 122,257 122,084 123,978 120,235 117,407 18 Aarlum Base Load 10.354 9,340 9,340 8,340 8,345 7,852 9,340 8,340 9.340 9.340 8,340 17 Total Base Load 175,051 283,888 248,348 385,188 252,818 314,098 351,447 420,354 878,808 292,887 258,188 284,722
18 TarittCustsnrer Load Differentia 0 Une6- Line 14 (21,601) 15,694 27,182 372 (4,306) (35,860) (92,417) 68,599 (31,430) 13,046 (11,417) 904 15 Monsanto Base Load D6feranoa = Line 7-Line It (8,748) (8,288) 3,580 315 1,103 8,928 8,024 1,298 (25,948) 0,586 (948) 20 Auahon5esaLoadD906alle Line S_Line 16 348 137 1,173 533 494 (2,871) (40) 189 207 747 285
21 Difference Base Load to Actual Loac 1215011 1,213 14,811 8,935 (3,184) (84,298) (5,389) 79,657 (29,941) (14,855) (4,088) 1.
22 Load Change Adjustment Rate (LcAR)($1MwH)(2' 18.55 21.85 21,58 21.55 6.47 5.47 5.47 0.47 0.47 9.47 547 5.41
23 TarlffCustomerLCA -Line l8x Line 22 393,453 (341,795) (485,122) (5,183) 23,554 196,180 87,920 (375,151) 171,923 (71,360) 82,453 (4,543) 24 Monsanto Ban l_CA -Line 150 Line 22 151,469 181,418 (87,325) (1,743) (0,032) (37,888) (43,592) (7,107) 953,972 (30,021) 891 25 AerWes B LCA -LIne 200 Line 22 (7,594) (3,532) (25,672) (4,089) (2,702) 15,702 245 (1.030) 1,I$2) 055) (9.370) 25 Load Change AdJe.tmentRaneeam 353,483 (167,053) (dde,109) (421,194) 47,252 167,440 45,736 (410,824) 163,765 Si,40i AS47 (5,002)
27 So2 Allowances Sales . - ($75,505) ($41,737) ($4,505) 55 (940,505) $5 55 90 80 $0 28 Idaho BE Facto, 8.5870% 6.3570% 6.3575% 0.3575% 6.3575% 6.3575% 0.3075% 0.3075% 8,3575% 9.3575% 5.3575% 6.3575% 28 Idaho Allocated 502 A8owsnce Sale, = Line 270 Una 26 - - (4,059) (2,653) (258) - )2,575) - - - 30 NohoAIO6ElTFS4-8DafefralAdb.a9n.n 33,727 11 (,697) (20,848 (11,153 (50,065 33,494 (33,248 47,975 31,771 46,838 78,531 30,412
31 Total Adjuslniehis 33,727 (11,857) (25,858 (13,750 (50,030 53,484 (38,524 47,575 31,771 45,050 75 ,0 1
30!3
32 Tenlffcusto,ner - lDLoed% 54.55% 53,29% 54.43% 49.52% 48.12% 51.51% 62.88% 71.62% 61.65% 63,13% 40.30% 52.20% 35 Monssnio-lDLoad'tt 43.15% 41.93% 46.80% 47.06% 49.59% 35.54% 20.21% 35.55% 33.43% 47.54% 44.13% 34 Agrlum- tDLoed% 3.57% 3.64% 3.52% 3,82% 3,50% 1.37% 1.57% 2,79% 3.44% 3.51% 3.81%
35 Tariff Customer Adjaatmaslo = 1.10531 n Uric 52
Lin 31

Una 3C
15,410 (8,303) (14,150) (8,912) (24,463) (17,387) (22,458) 34,504 15,581 28,570 37,729 15,564 36 Mer.aantoAdla.tnrent. (6,176) (13,864) (9,415) (24,379) (14,834) (12,577) 12,073 11,307 15,657 37,333 13,420 37 AectamAdle*sbnmde LIne3l n Una 38 (438) (843) (528) (1,505) (I,173) (469) 997 873 1,610 2,980 1,088
38 Total Adjustments 10,410 (11,887) (25,969) (13,788) (65,536) (33,454) (35,824) 47,578 31,771 48,838 75,831 30,412
55 Tariff Customer NPC Differential + LCA 0502 * 511/ = Sum or Line. 10,23,35 505,885 535,470 514,459 555,367 587,814 028,293 1,104,175 1,506,532 9,239,418 527,784 538.245 1,007,885
40 Monsanto 1/PC Differential n LCA + 802+ EITF Sum or Lines 11. 24.3a - 801,798 851,676 547,283 540,651 536,904 090,669 568,910 606,701 683,015 830,592 856,000 41 Aotiurr 1/PC D5isramtal LCA 8020 E117 = Sum of Lines 12,38,37 - 51,130 53,939 26,355 39,780 38.080 39,500 43,985 48.308 53.270 64,844 60.681 42 Total 1/PC D0ferensato LCA * 802 * 55FF 885,989 1,408,380 1,020,974 1,235,835 1,148,254 1505,157 1,754,421 1,819,427 1,805,408 1,904,688 1,833,881 1,932,825
43 Customer / Company Sharing ratS 90,0% 95.0% 04.0% 000% 84.0% 90,0% 95.6% 90.0% 84.0% 909% 98,0% 85.0%
44 Tariff Customer NPC Dtflerenit.I0LCA0802nEITFDefarra =Una SBoLine4? 545,275 451,523 463,013 558,830 811,533 745,464 1,047,757 1,175,879 1,111,677 834,988 844,420 607,190 45 Monsanto NPC DifferentIal LCA *5020 SlIP Deferra = LIne 400 Line 44 - 591,618 006,418 452,054 486,888 4933213 531,600 512,019 540,031 614,715 747,533 770,452 49 Adrlsm 1/PC Dlllsrmo LCA 0502, 01W era Line 41 o Line 42 - 48.017 57,455 23,747 38,810 36,564 35.822 38,587 41.731 47,850 58,359 61,723 47 Customer I Company Sharing (00/18 545,270 1,339,535 1,375,587 1,115,131 1,033,425 1,284,841 1,014,578 1,727,484 1,065,835 1,407,852 1,650,513 1,730,300
45 Renewubles Generation (MW/re 165,531
49 Renewable Adder Reto per MWh $05.00
50 Total Renewable Resources Add. Line 480 Line 40 9,576,210
51 Idaho 8(3 Factor 6.0479%
52 IdahoAinoalior +Line 530 Line 5l 918,001
53 sJarfffCu.5o.rers Parent, 04.59% 54 Renewable Resources Adder = Line 520 Line 52 283,124
ou
cl 0 mo -ox
( 0 705'
' 71Zj z 9
C 03 89 82 = CD
-4
1%)
Idaho ECAM Deferral
December 2010 through NOo,tnlaer 2011
Line
No.
55 Idaho Actual Renewable Energy Credo Revenues (6
98 Idaho Baa. Renewable Enemn C redit Ronemmo (S
57 REC Revenue Adjustment ($
59 TarIff Customer SEC Revenue Adjustment
59 Monsanto REC Revenue Adjustment
80 Aurben SEC Rownue AdkahnenI
61 Total REC Revenue Adjustment (S
82 Interest Rat.
63 Tariff Customer Balancing Amount (S
64 Beginning Balance Excluding Unenrcrtized Lot
85 UnamortIzed 2010 m Load GwthAdjustmemr
66 Incremental Went,
68 Renewable Resources Adder
87 REC Revenue Adjustment
68 1.0cc: Monthly ECAM Rider Revenuer 86 Interest
70 TantftCustomer Ending Balance cs:
71 Monsanto Baiseeleg Amount (S
72 Beginning Balance
73 Incremental Delerra
74 SEC Revenue Adjustment
78 Lees: Monthly ECAM Rider Revenuer
76 blared
77 Monsanto Ending Balance (6
78 Agdum Balancing Amount j$
79 BegInning Balance
80 Incremental Deform
81 SEC Revenue Adjuntinreol
82 Lens: Monthly SCAM Rider Revenuer
83 Interest
54 Agrtum Ending Balance (8
D.c-tO Jan.11 Feb.11 Mar-111 Apr-It May-ii Jun-11 Jul-Il Aug-111 Sep41 001.11 Nen.11
(186409) (353,764) (476,878) (702,533) (645,128) (708,294) (078,735) (81,048) (66,023) (182,551) (871,455) (845,714) (75,804) (585,530) (585.830) (588,535) (089,930) (555,530) (585,530) (685,530) (585,530) (585,530) (585,830) (565,930) = Line 55. Lure Be (80,806) 202,166 169,208 (115,702) (93,198) (118,383) 7,795 504,082 469,807 463,378 (85,828) (53,754)
LIne 320 Line 51 (44,106) 157,729 59,485 (57,757) (30,411) (61,661) 4,857 383,120 302,088 204,654 (41,354) (33,335) uUne33nLine57 87,227 45,815 (94,449) (30,307)
S Line 340 Une 51
(53,220) 2,802 132,318 174,354 184,947 145,820) (28,146)
7,210 3,976 (4,468) (2,478) (4.182) 106 8,444 73,485 13,868 (3,258) (2.302)

1.08% 1.00% 7.00% 1.00% 1.50% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.05%

11,181,231 11,840,000 12,298,045 12,701,855 13,134,485 13,30E,195 13,302,418 13,527,931 13,507,191 13,543,820 13,588,038 13,869,823

2,379,721 2,375,721 2,375,727 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 Una 44 545,270 481,523 463,013 858,830 511,033 745,484 1,047,787 1,170,879 1,111,877 834,988 844,420 907,180
LIne 54 283,124 . . . . .
Line 58 (44,108) 107,728 59,463 (57,757) (30,471) (61,981) 4,887 363,120 302,096 284,664 (41,354) (33,335

(737,766) (143,843) (131,060) (121,152) (322,939) (699,313) (840,287) (1,072,981) (1,390,584) (1,066,715) (735,618) (857,562
859,219 1,802,578 2,242,388 2,700,706 3,133,129 3,670,365 4,318,028 0,042,311 5,785,387 6,506,724 SUne45 816,819 858,418 452,854 486,588 403,213 531,600 812,018 548,031 814,715 747,533 770,452
Une59 87,227 45,815 (54,446) (30,307) (53220) 2,802 132,318 174,354 134,847 (40,920) (28,146)
375 1.725 1.885 2,059 2,430 2,834 3,327 3,688 4,614 5,125 5,733
899,218 1,852,578 3,242,388 3,706,798 3,133,128 3,870,295 4.318,029 5,843.311 8,758,307 6,508,124 1.208,103
53,249 114,750 134,134 167,592 199,527 239,437 294,683 340,140 402,268 457,731
Line 48 46,017 57,455 23,747 35,810 35,864 35,822 39,587 41,731 47,950 58,369 61,723 Una 60 7,210 3,576 (4,486) (2,478) (4,182) 105 8,444 13,460 13,888 (3,250) (2,302)
22
53,210
70 114,786
104
124,154 126
157,892
153
188,827
181
238,437 217
254.893
250
340,148
308
662,285
358
457,731
406
817,955
85 Total ECAM Deferral Balance SSum of Unnu 70,77,84 14.218.721 10,829,233 16.997.904 1708,712 18,862.164 19,513,790 19,812,483 26,468,823 21,394,842 22,188,414 23,013,390 24,010,996
(1)Bose NPC Rate and Load lromCase No. PAC-E.0&07$082 million through 1212772010, from Case No. PAC.0.11.07 91,024,8 million since 12/28120'
(2)Represents Load Growth A4.ostnrenl In months December 10- March 11, then rnvleed to Load Change Adjustment beginning In AprIl20
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