20130313Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6864
2O13MR ¶3 PH (:20
U-,
Jf • I ' .-
Ci TiL1TE- COM33.
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-13-03
POWER FOR AUTHORITY TO INCREASE )
RATES THROUGH THE ENERGY COST )
ADJUSTMENT MECHANISM (ECAM). ) COMMENTS OF THE
) COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Neil Price, Deputy Attorney General, and in response to the Notice of
Application, Notice of Intervention Deadline and Notice of Modified Procedure issued in Order
No. 32748 on February 20, 2013, in Case No. PAC-E-13-03, submits the following comments.
BACKGROUND
On February 1, 2013, PacifiCorp dba Rocky Mountain Power ("RMP" or "Company")
submitted its annual Energy Cost Adjustment Mechanism ("ECAM") filing in accordance with
Idaho Code §§ 61-502 and 61-503 and Rule of Procedure 52. The Company's filing proposes no
rate increase for Tariff Customers. However, the filing proposes increases for the Company's
Special Contract Customers, Monsanto and Agrium. The proposed increases are 2.6% and 2.4%,
respectively. The Company requests an effective date of April 1, 2013, for the proposed increases
in Idaho rates.
STAFF COMMENTS 1 MARCH 13, 2013
HISTORY
On September 29, 2009, the Commission issued Order No. 30904 approving the
implementation and submission of an annual ECAM filing by the Company. The costs included
in the ECAM are net power costs ("NPC"), as defined in the Company's general rate cases and
modeled by the Company's GRID model. Base and actual NPC are tracked in specific FERC
accounts. The ECAM process allows the Company to credit or collect most of the difference
between the actual NPC incurred to serve its Idaho customers and the NPC collected through base
rates.
The ECAM includes five additional components: the load growth adjustment ("LGA") or
load change adjustment ("LCA"), a credit for SO2 allowance sales, an adjustment for the
treatment of coal stripping costs, a true-up of renewable energy credit ("REC") revenues, as
authorized by the Commission in Order No. 32196, and interest on account balances. The ECAM
includes a 90 percent (customers)/1 0 percent (Company) "sharing band" wherein customers
pay/receive 90 percent of the increase/decrease in actual NPC compared to base NPC and RMP
incurs/retains the remaining 10 percent. Cost differences in the LCA, SO2 revenues and coal
stripping cost components are also shared. REC revenue differences are not shared.
After Commission approval of a deferral amount, RMP places the amount into an ECAM
balancing account for recovery from or rebate to customers. This is accomplished through the
design and implementation of ECAM rates.
ROCKY MOUNTAIN POWER'S FILING
2011 —2012 DEFERRAL
RMP is requesting a Commission Order approving the recovery of approximately $15.9
million of deferred ECAM costs accumulated during the period of December 1, 2011 through
November 30, 2012. Deferrals are calculated and tracked for three separate customer groups,
Monsanto, Agrium and all other Idaho customers who are the "Tariff Customer" group. The
breakdown of the $15.9 million deferral balance is shown in Attachment A, lines 1 through 11.
Attachment A contains the same information as Table 1 in Company witness Brian Dickman's
testimony.
For the deferral period, the NPC differential for deferral was approximately $18.4 million
before 90/10 sharing (line 2). Higher summer irrigation usage led to a LCA reduction in the
STAFF COMMENTS 2 MARCH 13, 2013
deferral balance by approximately $0.7 million before sharing (line 3). Credits for the sale of
S02 allowances received by the Company were also included in the deferral amount (line 4).
Additionally, Idaho's allocated differences between the coal stripping costs incurred by the
Company and recorded on the Company's books pursuant to accounting pronouncement EITF
04-6, and the amortization of the coal stripping costs when the coal was excavated were also
deferred (line 5).
In addition to the ECAM components discussed above, the deferral balance includes the
difference between actual REC revenues during the deferral period and the amount of REC
revenues included in base rates (line 9). The 90/10 sharing band does not apply to the REC
revenue difference. The entire Idaho share of the REC revenue difference is passed on to
customers.
BALANCING ACCOUNT ACTIVITY
Lines 15 through 24 of Attachment A show the result when the proposed deferral is
combined with existing December 1, 2012 account balances, ECAM revenues and interest.
The deferred ECAM balance of approximately $25.5 million as of November 30, 2012, is
derived from the following calculation: 90% x (deferred NPC + LCA + S02 revenues + coal
stripping costs adjustment) + REC revenues + interest charges. The sum of the three groups'
(Tariff Customers, Monsanto and Agrium) ending balances result in the ECAM deferral balance
of approximately $25.5 million (line 24)
PROJECTED RECOVERY
Lines 28 through 37 show projected ECAM revenue through March 2014 for all three
customer groups. The revenues are divided into two parts, revenue from existing rates which are
expected during the four month period December 2012 through March 2013 (line 32) and revenue
expected from proposed rates during the 12 month period April 2013 through March 2014 (line
35). These amounts added to the balancing account produce expected balances on April 1, 2014
of -$554,734 for Tariff Customers, $6,587,313 for Monsanto and $468,358 for Agrium (line 36).
These amounts exclude any amounts that may be deferred during the 2013 ECAM year since
these amounts are not known and not projected.
STAFF COMMENTS 3 MARCH 13, 2013
ECAM RATES
RMP's Application seeks to revise Schedule 94, Energy Cost Adjustment, to recover
approximately $15.2 million in total deferred net power costs for the collection period of April 1,
2013 through March 31, 2014 (Attachment A, line 35). RMP states that this amount represents an
increase of approximately $2.2 million over current Schedule 94 rates. See Order No. 32597. As
previously discussed, the proposed increase will apply exclusively to Monsanto and Agrium. The
Company is proposing no increase to other customer's rates.
RMP calculated Monsanto ($6.3 million) and Agrium's ($.5 million) share in the deferral
period (Attachment A, line 11). This filing includes the first amortized payment of a three year
amortization of those amounts, approximately $2.1 million for Monsanto and approximately $0.1
million for Agrium.
ECAM filings made in 2012 and 2013 and that will be made in 2014 do not include rates
for Monsanto and Agrium that are designed to recover their full deferral balances. The 2012 and
2013 deferral amounts are to be recovered over three years and the 2014 deferral amount is to be
recovered over two years. (Order No. 32432, p. 4, 5) For this reason Monsanto and Agrium
deferral account balances are not intended to be fully recovered in a single year by ECAM rates
proposed in this case. Lines 42 through 47 of Attachment A show the calculation of Monsanto
and Agrium amounts recovered by this year's ECAM rates.
Maintaining current rates for tariff customers provides rate stability and is expected to
reasonably recover the deferral balance. RMP calculates a projected over collection of $555,000
which, if it materializes, will be trued up in the future.
STAFF ANALYSIS
The Company's proposal to not increase ECAM rates for Tariff Customers produces a 0%
increase in this filing but continues the collection of approximately $10.5 million in ECAM
revenues. This represents a surcharge of 4.3 percent above base rates. The continuation of the
Tariff Customer surcharge is largely driven by a decline in Wholesale Sales Revenue as shown in
Table 2 on Page 9 of Company witness Brian Dickman's testimony. In ECAM calculations
Wholesale Sales Revenue reduces Net Power Costs. The reduction in Wholesale Sales Revenue
is a direct result of lower electric market prices which are correlated to lower natural gas prices.
In his testimony Mr. Dickman says that actual natural gas prices were approximately 38 percent
STAFF COMMENTS 4 MARCH 13, 2013
lower than the natural gas prices used to establish base NPC in the deferral period (Dickman
Direct, Page 11). Of course, lower natural gas prices and lower electric market prices also lead to
lower Purchased Power Expense which partially offsets lost Wholesale Sales Revenue. This is
also shown in Mr. Dickman's Table 2. Lower natural gas prices are the main driver of the
continued Tariff Customer surcharge. Lower natural gas prices are also the main driver in the
deferrals assigned to Monsanto and Agrium in this case.
Staff has reviewed the Company's ECAM filing, audited actual revenues and expenses
that occurred during the ECAM period, and proposes two changes. While responding to a Staff
Audit Request the Company discovered that some ECAM revenue had been double counted. A
portion of Monsanto's ECAM revenue was correctly credited to the Monsanto balancing account
and the same amount was incorrectly credited as Tariff Customer ECAM revenue. The correction
of this error affects only the Tariff Customer balancing account. The double counted revenue was
$1,252,995.
During the process of preparing these comments, Staff reviewed Commission Order No.
32432 which was issued in the Company's last general rate case (PAC-E-1 1-12). Staff believes
that the language in the order requires the ECAM to track differences between actual and
authorized customer load control costs. The Company did not include this in its filing. The order
contains the following language.
7. The Parties agree that Idaho's share of the customer load control service
credit will be tracked in the ECAM. The Parties agree that $1,045,423 (RMP
Exhibit 2 page 4.4. 1) is Idaho's base amount to be tracked in the ECAM for
2012 and 2013.
(Order No. 32432, p. 5)
The "ULTIMATE FINDINGS OF FACT AND CONCLUSIONS OF LAW' section of
that same order contains the following language.
Further, the Commission finds that $1,045,423 shall be Idaho's base amount
to be tracked in the ECAM for 2012 and 2013,
(Order No. 32432, p. 21)
STAFF COMMENTS 5 MARCH 13, 2013
Staff has calculated the effect of including the customer load control deferral amounts in
the ECAM. Order No. 32432 was not effective until January 10, 2012, therefore, there is no
deferral amount in December 2011 and January 2012 is prorated. These calculations are shown
on Attachment B. This attachment shows a reduction in Customer Load Control costs of $9,757
before sharing and interest considerations.
Confidential Attachment C shows the detailed results of incorporating the two ECAM
changes proposed by the Staff. These results are summarized in Attachment D. Attachment D
follows the same format as Attachment A, except there is an unnumbered line inserted between
lines 4 and 5 to include the customer Load Control Adjustment. This amount before sharing and
interest considerations decreases costs to the three customer groups by a total of $9,757.
Removing the double count of Monsanto ECAM revenues affects only the Tariff Customer group
and increases the amount in the balancing account by $1,252,995 before interest. This revenue
decrease is included in the amounts shown on line 20 of Attachment D.
Despite the Staff proposed changes to the deferral balance and to the balancing account,
no change is proposed in the rates recommended by the Company in this filing. The effect of
including customer load control differences in the ECAM is small and would reduce rates for all
three customer groups a negligible amount. The correction of the revenue double count is
substantial but only impacts the Tariff Customer group. The Company has already provided
notice to its Tariff Customers that rates are not changing. Before Staff's changes, the Tariff
Customer balancing account on April 1, 2014 was expected to show a customer credit of
$554,734 (Attachment A, line 36). With Staff's changes, the same account shows a surcharge
amount of $696,139 (Attachment D, line 36). The amounts not included in rates in this case will
be carried forward in the balancing account for future recovery.
Attachment E to these comments provides a brief history of deferral amounts, account
balances and ECAM rates from the first year of ECAM implementation in 2009 through last
year's ECAM.
CONSUMER COMMENTS
The Customer Notice and Press Release were included in Rocky Mountain Power's
Application. Both were compliant with Procedural Rule 125, IDAPA 31.01.01.125.
STAFF COMMENTS 6 MARCH 13, 2013
According to RMP, Customer Notices were mailed with cyclical billings beginning March
4, 2013 and ending April 1, 2013. The final date for filing comments is March 13, 2013. This
means more than one-half of those customers receiving notices in their billings would be unable
to send in comments before the deadline. In fact, some customers wouldn't receive the
notification until after the new rates are effective. According to the Company, the reason for the
delay was that an external printer delayed printing the inserts. A decision was then made to start
inserting notices at the beginning of the next billing cycle rather than starting at the end of the
February billing cycle. Staff recommends that RMP be reminded of its obligation to send notices
in a timely manner so that customers will have an opportunity to comment. In this particular case,
only two customers will be impacted by this Application, Monsanto and Agrium. RMP informed
Staff that those two customers had been notified personally before the Application was filed. For
that reason, Staff does not recommend sanctions in this case.
Customer Comments
Customers were given until March 13, 2013 to file comments. As of March 13, 2013, no
customers had filed comments.
STAFF RECOMMENDATION
Staff recommends that the following deferral balances for the period December 1, 2011
through November 30, 2012 be approved for recovery from ratepayers:
Tariff Customers $9,052,139
Monsanto $6,345,072
Agrium $463,254
The total amount recommended for recovery from Idaho customers is $15,860,465. These
amounts are shown on Attachment D, line 11.
Staff also recommends that the Schedule 94 ECAM rates proposed by the Company be
approved effective April 1, 2013. Approval of these rates constitutes a 2.6% increase to
Monsanto, a 2.4% increase to Agrium and no increase to Tariff Customers.
Staff further recommends that the Commission remind the Company of its obligation to
send notices in a timely manner so that customers will have an opportunity to comment.
STAFF COMMENTS 7 MARCH 13, 2013
Respectfully submitted this 15-'~day of March 2013.
Neil Price
Deputy Attorney General
Technical Staff: Patricia Harms
Keith Hessing
Marilyn Parker
i:umise:eomments/pace 13 .3npphkhmp comments
STAFF COMMENTS 8 MARCH 13, 2013
Monsanto & Agrium Rate Recovery
Monsanto Agrium Total
2,355,099 159,371 2,514,470
2,116,107 154,493 2,270,601
4,471,206 313,865
Monsanto/Agrium Amortization
2012 ECAM Balance (2011 Deferral) -3 Yr Amortization
2013 ECAM Balance (2012 Deferral) - 3 Yr Amortization
2014 ECAM Balance (2013 Deferral) - 2 Yr Amortization
Rate Design Total
2
3
4
5
6
7
8
9
1(
11
1:
1
15
if
1
IE
15
2(
21
2
2
2
25
2€
2
2
25
3(
31
3
3
3
35
3€
3
3
35
4(
41
4
4
4
45
4€
4.;
COMPANY FILING
Deferrals
Tariff
ILCA
Customers Monsanto Agrium Total
NPC Differential for Deferral 10,481,031 7,320,329 557,414 18,358,774
(601,098) (90,098) (22,411) (713,607)
S02 (1,212) (512) (40) (1,764)
EITF 04-6 Adjustment (11,520) (16,269) (2,230) (30,019)
9,867,201 7,213,450 532,734 17,613,384
90% 90% 90% 90%
Customer Reponsibility 8,880,481 6,492,105 479,460 15,852,046
REC Deferral 176,961 (143,783) (15,980) 17,197
12/1/11 to 11/30/12 Deferrals 9,057,441 6,348,322 463,480 15,869,243
Balancing Account Activity
Tariff
Customers Monsanto Agrium Total
12/1/11 to 11/30/12 Deferrals 9,057,441 6,348,322 463,480 15,869,243
Prior Deferral Balance 16,352,216 6,812,973 471,163 23,636,352
ECAM Revenue Collection (12,780,472) (1,407,870) (96,019) (14,284,361)
Interest 153,150 100,182 7,023 260,355
Activity Through November 30, 2012 3,724,894 5,505,285 382,167 9,612,346
November 30, 2012 Balance For Collection 12,782,335 11,853,607 845,648 25,481,589
rruJLeu rwwvet y
Tariff
Customers Monsanto Agrium Total
November 30, 2012 Balance For Collection 12,782,335 11,853,607 845,648 25,481,589
Schedule 94 Collection - Dec 2012 - March 2013 (2,886,335) (795,088) (63,425) (3,744,847)
Expected Balance as of April 1, 2013 9,896,000 11,058,519 782,223 21,736,742
Schedule 94 Collection - April 2013 - March 2014 (10,450,734) (4,471,206) (313,865) (15,235,804)
Expected Balance as of April 1, 2014 (Excluding (554,734) 6,587,313 468,358 6,500,937
Incremental 2013 Deferral)
Attachment A
Case No. PAC-E-13-03
Staff Comments
03/13/13
PAC-E-1 3-03
CUSTOMER LOAD CONTROL PROGRAMS
ECAM CALCULATIONS
Description Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Total
2011 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012 2012
Base
Idaho Irrigation Load Control
Utah Irrigation Load Control
Utah Cool KeeDer Proaram
Total 1,701,564 516,008 370,621 380,601 264,478 1,345,726 3,511,411 2,575,243 2,570,499 1,170,307 289,827 2,576,295 17,272,581
Jurisdictional Allocation 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525 0.060525
Idaho Total 102,987 31,231 22,432 23,036 16,008 81,450 212,528 155,867 155,579 70,833 17,542 155,930 1,045,423
Actual
Idaho Irrigation Load Control
Utah Irrigation Load Control
Utah Cool Keeper Program
Total
Jurisdictional Allocation
Idaho Total
244,989
310,119
1,128,670
1,683,777
0.060525
101,911
194,494 211,467
(3,704) 145,281
319,824 9,998
510,614 366,746
0.060525 0.060525
30,905 22,197
201,257
75,315
100,051
376,623
0.060525
22,795
204,916
10,849
45,950
261,714
0.060525
15,840
270,342 2,429,843 2,416,050

81,926 74,632 112,114

979,391 970,230 20,160
1,331,658 3,474,705 2,548,323
0.060525 0.060525 0.060525

80,599 210,307 154,237
2,422,593
94,448
26,588
2,543,629
0.060525
153,953
(123,988) 164,452

1,252,529 95,997

29,532 26,348
1,158,073 286,797
0.060525 0.060525

70,092 17,358
240,058 8,876,472
77,003 2,326,508
2,232,304 5,889,045
2,549,364 17,092,024

0.060525 0.060525

154,300 1,034,495

Difference (1,077) (326) (234) (241) (167) (851) (2,222) (1,629) (1,626) (740) (183) (1,630) (10,928)
Difference in ECAM 0 (232) (234) (241) (167) (851) (2,222) (1,629) (1,626) (740) (183) (1,630) (9,757)

Allocator - % of Total 0.0985 0.0299 0.0215 0.0220 0.0153 0.0779 0.2033 0.1491 0.1488 0.0678 0.0168 0.1492 1.000000
Notes:
Rates requiring this calculation were implemented 1/10112. Therefore, December 2011 is excluded and January amounts are prorated.
Since only annual amounts were given in the case that established ECAM tracking, the base amounts were spread by month in the same proportion as the actual amounts.
cC1DC>
00 '
Rocky Mountain Power
Idaho ECAM Deferrals
Case No. PAC-E-13-03
Corrected Revenue Double Count
Include Customer Load Control (CLC) Adjust. Units Dec-11 Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Total
I Met Power Costs
2 Base NPC Rate $/MWh
3
4 Total Co. Adj. Actual NPC; Exci Integration Adj. $
5
6 Intra-Hour Wind Integration Cost $IMWh
7 Third Party Wind MWH
8 Third Party Wind Adjustment $ 238,853 381.854 234,043 374,443 229,582 234,252 244,214 186,971 183,422 156,513 308,621 325,926
9
10 Total Company Adj. Actual NPC $ 133,705,356 118.212,202 110,932,549 113,013,621 110.825,589 118.709.086 123,139,865 146,967,483 158,721,503 130,008,232 122,963,719 111,042,540
ii
12 Adjusted Actual Load MWH 1j1UJ1lt 4i6f fl
13 Actual NPC $/MWh 24.66 22.53 23.09 23.63 25.39 25.44 24.68 26.66 28.68 27.83 26.21 23.25
14
15 NPC Differential $IMWh 7.67 5.21 4.38 6.20 5.62 6.13 5.36 3.07 3.53 4.34 5.13 2.24
16
17 Actual Tariff Customer Load for NPC Def. MWH 4 18 Actual Monsanto Load for NPC Deferral MWH
19 Actual Agrium Load for NPC Deferral MWH
20 Actual Idaho Load for NPC Deferral MWH 293,501 276.248 267,002 260,992 237,199 369,143 442,557 467,632 393,160 283.826 256.827 242.465 3,790.552
21
22 Tariff Customers NPC for Deferral $ 1,216,781 774.671 592.732 757,424 723,708 1,290,256 1,518,154 944,714 968,803 740,254 689.957 263.583 10,481,038
23 Monsanto NPC for Deferral $ 954,586 610,296 535,512 795,242 553.631 901.842 833,693 458,530 390,886 452,424 577,909 255.779 7.320330
24 Agrium NPC for Deferral $ 78,829 53.958 41.025 64,864 56,327 70.031 19,385 32.571 29,591 37,795 48.859 24,179 557.416
25 Total MPG Differeetial for Deferral $ 21250.196 1.438.926 1.189.269 11617.531 1,3•666 2.262.129 2.371.233 1.435.615 1.389.279 1.230.474 1.316.725 543.542 18.358.784
28
27
28ILoad Change Adjustment
29 Base Tariff Customer Load for LCA MWH
30 Base Monsanto Load for LCA MWH
31 Base Agrium Load for LCA MWH
32 Total Base Load for LCA MWH 280.663 297,032 261,555 272,026 258,025 317,877 338,863 507,943 368.820 280,652 244,045 251,806 3,679.306
33
34 Actual Tariff Customer Load for LCA MWH 158.709 148,723 135,350 122.212 128,715 210,549 283,342 307,685 274,167 170.750 134.576 117,580
35 Actual Monsanto Load for LCA MWH ,,- 117,166 122,284 128,314 98,466 147,166 155,597 149,339 104,358
36 Actual Agrium Load for LCA MWH 10,282 10,359 9,368 10,466 10.018 11.428 3,618 10,608 8.374 8,718 9,530 10,786
37 Actual Idaho Load for LCA MWH 301,046 276,248 267,002 260,992 237,199 369.143 442,557 467,632 396.278 283,826 264,455 243.385 3,809,763
38
39 Tariff Customer Load Differentials MWH 7,370 (6,448) 590 (6,090) 10,310 55,306 78,067 (39,193) 25,228 (693) (6,420) (6.138)
40 Monsanto Load Differentials MWH 11.594 (14,827) 4,306 (5,157) (31.318) (3,887) 24,342 (1,358) 2,267 3,510 27,117 (119)
41 Agrium Load Differentials MWH 1,419 491 551 214 182 (153) 1,285 240 (37) 357 (287) (164)
42 Total Difference - Base Load to Actual Load MWH 20,383 (20,784) 5,447 (11,033) (20,826) 51.266 103,694 (40,311) 27,458 3,174 20.410 (8.421) 130.457
43
44 Load Change Adjustment Rate (LCAR) $/MWh
45
46 Tariff Customer LCA $ (40,314) 35,271 (3,227) 33,312 (56.396) (302,524) (427.026) 214,386 (137,997) 3,791 35,117 44,515 (601.093)
47 Monsanto LCA $ (63,419) 81,104 (23,554) 28.209 171,309 21,262 (133.151) 7,428 (12,400) (19.200) (148,330) 651 (90,091)
48 Agrium LCA $ (7.762) (2,686) (3,014) (1,171) (996) 837 (7,029) (1.313) 202 (1,953) 1,570 897 (22,416)
49 Total LCARevenues (111.495) 113.688 (29.795) 60.351 113.918 (280.425) (567.206) 220.501 (150.195) (17.362) (111.643) 46.063 (713.600)
50
Attachment C
Case No. PACE1303
Staff Comments
03/13/13 Page 1 of
Rocky Mountain Power
Idaho ECAM Deferrals
Case No. PAC-E-13-03
Corrected Revenue Double Count
Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Total
53 S02 Allowance Sales $
54 Idaho SE Factor % .-
55 Idaho Allocated SO2 Allowance Sales $ 0 0 0 0 (118) 0 0 0 (1.649) 0 0 0 (1,764)
56 Idaho Customer Load Control Adjustment $ 0 (28) (294) (241 187) (651) (2 (1,829) (1,828) (740) (189) (1,630) (9,755)
57 Idaho Allocated EITF 04-6 Defferral Adjustment $ - 9øI_ Ill S 98)1 I I i1IT' I L.... (30,020) 58 Total Adjustments $ (4,657) (1,622) (1,895) (25,589) (49,036) (1,349) 23.359 12,578 (9,797) 4,885 3,383 8,201 (41,539)
59
60 Tariff Customer Load % 54.07% 53.84% 50.69% 46.83% 54.26% 57.04% 64.02% 65.80% 69.73% 60.16% 52.40% 48.49%
61 Monsanto Load % 42.42% 42.41% 45.80% 49.16% 41.51% 39.87% 35.16% 31.94% 28.14% 36.77% 43.89% 47.06%
62 Agrium Load % 3.50% 3.75% 3.51% 4.01% 4.22% 3.10% 0.82% 2.27% 2.13% 3.07% 3.71% 4.45% 63 Total Idaho Load % 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00% 100.00%
64
65 Tariff Customer Adjustments $ (2.518) (873) (961) (11,982) (26,609) (769) 14,955 8.276 (6,832) 2,939 1,773 3,977 (18,625)
66 Monsanto Adjustments $ (1,976) (688) (868) (12,581) (20,356) (538) 8,213 4.017 (2.756) 1,796 1,485 3,859 (20,392)
67 Agrium Adjustments $ (163) (61) (66) (1,026) (2,071) (42) 191 285 (209) 150 126 365 (2,521)
68 TotatMjustrnents $ (4.857) (1.622) (1.895) (25.589) (49.036) (1.349) 23.359 12.578 (9,797) 4.885 3.383 8201 (41.539) 69
70
71 ISub-Totals and Sharing I
72 Tariff Customer- NPC, LCA, S02, EITF, CLC $ 1,173,949 809,068 588,544 778,754 640,703 986,963 1.106.083 1,167,376 823,974 746.984 726,847 312,075
73 Monsanto - NPC, LCA, S02, EITF, CLC $ 889.191 690,712 511,091 810,870 704.585 922,566 708,755 469,975 375.729 435,021 431.063 260,290
74 Agnum - NPC, LCA, S02, EITF, CLC $ 70.904 51,212 37,944 62,668 53.260 70,827 12,547 31,543 29,584 35,993 50,555 25.441
75 Total - NPC, LCA, S02, EITF, CLC $ 2,134,044 1,550,992 1.137,579 1,652,292 1,398.548 1,980,355 1,827,386 1.668,894 1,229,287 1.217,997 1,208.465 597.806 17,603,645
76
77 Sharing /
78
79 Tariff Customer - NPC, LCA, S02, EITF. CLC $ 1,056,554 728.162 529,689 700,879 576,633 888.267 995,475 1,050,638 741,577 672,286 654,162 280,867 8,875,188
80 Monsanto - NPC, LCA, S02, EITF, CLC $ 800.272 621,641 459.981 729,783 634,126 830.309 637,880 422.977 338,156 391,519 387.957 234,261 6.488,863
81 Agrium - NPC, LCA, S02, EITF. CLC $ 63,814 46.090 34,150 56,401 47,934 63,744 11,293 28.389 26,626 32,393 45,499 22,897 479,230
82 Idaho Customer Totaj-NPC.LCA.502.ELTF.0 $ 1.920.840 1.335.893 1.023.821 1.487.063 1.255.593 1.752.320 1.844.647 1.502.005 1106359 1098196 1067819 8'R078 18643961
84
85IREC Revenues
86 Actual Idaho REC Revenues
87 Base Idaho REC Revenues
88 REC Revenue Adjustment
89
90 Tariff Customer REC Revenue Adjustment
91 Monsanto REC Revenue Adjustment
92 Agrium REC Revenue Adjustment
93 Total REC Revenue Adiustment

(190,631) (33,775)

(39,333) (70.603) (57,204) (76,750) (97,141) (108,731) (21,624) 355,638 311,495 155,080

(30,858) (55.622) (51,682) (80,582) (74,312) (75,999) (11,875) 172,614 125.680 94,781

183,812) (159,922) 17.196

(96,317) (77,552) 176,969

(80,675) (75,256) (143,785)
CD
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Rocky Mountain Power
Idaho ECAM Deferrals
Case No. PAC-E-13-03
Corrected Revenue Double Count
Include Customer Load Control (CLC) Adjust. Units Dec-il Jan-12 Feb-12 Mar-12 Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Total
96I13alancing Account Calculations I
97 Annual Interest Rate 9' 4
98
99 Tariff Customer Balancing Account
100 Beginning Balance $ 16,580,225 16,439,102 16,229,393 16,207,554 16,095,208 15,986,957 15,633,513 15,326.338 14,922,577 14,615,430 14,446,087
101 Incremental Deferral $ 1.066,554 728,162 529,689 700.879 576,633 888,267 995,475 1,050,638 741.577 672,286 654.162 280,867
102 REC Revenue Adjustment $ (39,333) (70,603) (57.204 (76,750 (97.14l,,,____,j108.731 j21,624 355.638 311,495 155.080 96,317 (77,552)
103 Less Monthly ECAM Rider Revenue $ _44 F '48) (II 527 478)
104 Interest $ 13,716 13,752 13,606 13,510 13.454 13,362 13,170 12,895 12,598 12.302 12.104 11,861 156,331
105 Tariff Customer Ending Balance $ 16,580,225 16,439,102 16,229,393 16,207,554 16,095,208 15,986,957 15,633,513 15,326,338 14,922,577 14,615,430 14,446.087 14.033.216 14,033,216
106
107 Monsanto Balancing Account
108 Beginning Balance $ _ 1 7,588,386 8,160,964 8,576,234 9,232,853 9,800,595 10,408,447 10,830,147 11,221,248 11,473,686 11,753,328 11,877,252
109 Incremental Deferral $ 800,272 621,641 459,981 729,783 634.126 830.309 637.880 422.977 338,156 391,519 387.957 234,261
110 REC Revenue Adjustment $ (30.858) (86,522) (61.682) (80.5821 (74,312) (75 999) 111.87 125,680 94,781 (80,675 (75,256)
111 Less Monthly ECAM Rider Revenue $ 17 8) (1407870)
112 Interest $ 5.998 6,559 6,971 7.417 7.927 8,417 8,846 9,184 9,452 9.674 9.842 9,882 100,171
113 Monsanto Ending Balance $ 7.588,386 8,160.964 8,576.234 9,232.853 9,800,595 10,408,447 10,830,147 11.221,248 11.473.686 11.753.328 11.877,252 11.850,351 11,850,351
114
115 Agrium Balancing Account
116 Beginning Balance $ 111nallilift 532,847 574,481 605,163 655,516 696,453 739.726 735,845 772,468 794,561 820,199 844,445
117 Incremental Deferral $ 63,814 46,090 34,150 56,401 47,934 63,744 11,293 28,389 26,626 32.393 45,499 22.897
118 REC Revenue Adjustment $ j2,548) (4.918) (3.952) J73) (7.561 (5.902) (276j__ 12,261 9414 7,918 6,8211 7i,A 119 Less Monthly ECAM Rider Revenue $ ( 4 _1 (96,018)
120 Interest $ 418 461 491 525 563 598 615 628 653 673 693 704 7,022
121 Agrium Ending Balance $ 532,847 574,481 605,163 655,516 696,453 739.726 735.845 772.468 794,561 820,199 844,445 845,420 845.420
122
123 Total ECAM Deferral Balance $ 24.701.457 25,174,547 25,410,790 26,095.923 26,592,256 27.135.131 27,199,506 27.320,053 27,190,824 27,188.957 27,167.783 26,728.986 26.728,986
:
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STAFF PROPOSAL
Remove Monsanto Revenue Double Count & Add Irrigation Load Control
Deferrals
omer Load Control
04-6 Adjustment
Differential for Deferral
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2.
2'
2
2:
2
3'
3
3,
a
3,
a
3'
3,
3:
a
4'
4
4.
4.
4
4'
4
4
Prior Deferral Balance
ECAM Revenue Collection
Interest
Activity Through November 30, 2012
November 30, 2012 Balance For Collection
Customer Reponsibility
Renewable Resource Adder
REC Deferral
12/1/11 to 11/30/12 Deferrals
12/1/11 to 11/30/12 Deferrals
r 30, 2012 Balance For Collection
Tariff
Customers Monsanto Agrium Total
10,481,031 7,320,329 557,414 18,358,774
(601,098) (90,098) (22,411) (713,607)
(1,212) (512) (40) (1,764)
(5,892) (3,611) (251) (9,754)
(11,520) (16,269) (2,230) (30,019)
9,861,309 7,209,839 532,483 17,603,630
90% 90% 90% 90%
8,875,178 6,488,855 479,234 15,843,267
0 0 0 0
176,961 (143,783) (15,980) 17,197
9,052,139 6,345,072 463,254 15,860,465
ng Account Activity
Tariff
Customers Monsanto Agrium Total
9,052,139 6,345,072 463,254 15,860,465
16,352,216 6,812,973 471,163 23,636,352
(11,527,478) (1,407,870) (96,019) (13,031,366)
156,331 100,171 7,022 263,524
4,981,069 5,505,274 382,166 10,868,510
14,033,208 11,850,346 845,421 26,728,974
Projected Recovery
Tariff
Customers Monsanto Agrium Total
14,033,208 11,850,346 845,421 26,728,974
(2,886,335) (795,088) (63,425) (3,744,847)
11,146,873 11,055,258 781,996 22,984,127
(10,450,734) (4,470,122) (313,789) (15,234,646)
696,139 6,585,135 468,207 7,749,481
Monsanto & Agrium Rate Recovery
Monsanto Agrium Total
2,355,099 159,371 2,514,470
2,115,024 154,418 2,269,442
4,470,122 313,789
94 Collection - Dec 2012- March 2013
Balance as of April 1, 2013
94 Collection - April 2013 - March 2014
Balance as of April 1, 2014 (Excluding
tal 2013 Deferral)
anto/Agrium Amortization
ECAM Balance (2011 Deferral) -3 Yr Amortization
ECAM Balance (2012 Deferral) -3 Yr Amortization
ECAM Balance (2013 Deferral) - 2 Yr Amortization
Rate Design Total
Attachment D
Case No. PAC-E-13-03
Staff Comments
03/13/13
PACIFICORP
IDAHO ECAM HISTORY
CASE NO. PAC-E-13-03
Ioescription I Deferral I Balancing Accounts I Rates
Case No. Final 1
NPC LCA S02 EITF 04-6 Renewable REC Goose Cr Interest Total I
Tariff Monsanto Agrium Secondary I
Primary Transmission Monsanto Agrium
Order (90%) (90%) (90%) (90%) Adder or Irr. LC Customers (/kWh) (/kWh) (/kWh) (/kWh) (/kWh)
PAC-E-10-01 31033 109,354 1,349,814 (108,506) NA 811,412 NA (156,434) 7,500 2,013,140 2,013140 0 0 0.100 0.093 0.091 NA NA
Ending Balance 2,013,140
PAC-E.11-07 32216 Beginning Balance 2,013,140
ECAM Revenue (1,271,007) 0 0
5,466,170 4,757,441 (84,515) (97,729) 2,696,763 NA NA 79,788 12,817,918 12,817,918 0 0 0.569 0.550 0.535 NA NA
PAC-E-12-03 32507 Beginning Balance 13,560,051 0 0
ECAM Revenue (7,821,058) 0 0
Tariff Customers 9,230,430 73,859 w/EITF 55,764 275,989 821,409 NA 155,773 10,613,223 10,613,223 0.569 0.550 0.535
Monsanto 6,687,351 (292,353) w/EITF 15,455 0 372,771 NA 29,750 6,812.974 6,812,974 0.175
Agrium 524,255 (88,442) w/EITF 1,824 0 31,635 NA 1,891 471,164 471,164 0.164
Ending Balance 16,352,216 6,812,974 471,164
PAC-E-13-03 Beginning Balance 16,352,216 6,812,974 471,164
Notes
PAC-E-10-01 Deferrals for the 6 month period July 1, 2009 through November 30, 2009.
PAC-E-1 1-07 All of the LGA (LCA) is approved for deferral but only one-half of it is included in the rate calculation. The unrecovered balance is carried forward with interest for future recovery.
Rates are designed to recover $10,421,000.
PAC-E-12-03 The approved Monsanto and Agnum deferral balances are ordered to be amortized over 3 years for rate calculations. The unrecovered balance is carried forward with interest for future recovery.
Rates are designed to recover $10,451,000 form Tariff Customers, $2,410,000 from Monsanto and $171,000 from Agrium.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF MARCH 2013,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-13-03, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguest(pacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
P0 BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
YVONNE HOGLE
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: Yvonne. hogie(pacificorp.com
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
SECRETAI
CERTIFICATE OF SERVICE