20140320Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO IMPLEMENT A NET
DECREASE IN RATES THROUGH ITS
ENERGY COST ADJUSTMENT MECHANISM
(ECAM).
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-I4.OI
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 Modified Procedure and Notice of Intervention Deadline issued in Order
No. 32979 on February 20,2014, in Case No. PAC-E-14-01, submits the following comments.
BACKGROUND
On January 31,2014, PacifiCorp dba Rocky Mountain Power ("RMP" or "Company")
submitted its annual Energy Cost Adjustment Mechanism ("ECAM") filing in accordance with
Idaho Code $$ 6I-502 and 61-503, and Rule of Procedure 52. The Company requests an
effective date of April 1,2014 for the proposed changes in Idaho rates.
On September29,2009, the Commission issued OrderNo. 30904 approving the
implementation of an annual ECAM. The primary component of the ECAM is net power costs
("NPC"). It is defined in the Company's general rate cases and modeled by the Company's GRID
STAFF COMMENTS MARCH 2O,2OI4
model. Base and Actual NPC are recorded in specific Federal Energy Regulatory Commission
(FERC) accounts. Other costs and revenue currently included in the ECAM are the following: a
Load Change Adjustment (LCA), a credit for sulfur dioxide (SO2) allowance sales, an adjustment
for the accounting treatment of coal stripping cost, an adjustment for DSMI Load Control
Program cost, and a true-up of renewable energy credit ("REC") revenue. All, except REC
revenue, are subject to a 90 percent (customers)/10 percent (Company) "sharing band" wherein
customers paylreceive the increase/decrease in actual cost/revenue compared to base cost/revenue
while RMP incurs/retains the remaining l0 percent. The ECAM process allows the Company to
credit or collect the difference between the actual cost/revenue incurred and cost/revenue
collected through base rates. RMP defers the difference into an ECAM balancing account.
In calculating this year's deferral, Commission Order No.32432 stipulates that the
Company use 2011 actual loads reported in the Company's Annual Results of Operations Report
as base load for the purpose of calculating this year's LCA. Additionally, in a settlement
reflected in Commission Order No. 32910 pursuant to Commission Order No. 32771, the wholesale
line loss adjustment applied to actual loads for Monsanto and Agrium for purposes of calculating the
LCA is removed from June I , 2013 through November 30, 2013 of the deferral period.
Following Commission approval of the deferral amounts, RMP will place Monsanto, Agrium,
and tariff customer's share into three separate balancing accounts for recovery from customers
through Schedule 94 ECAM rates. Rates must be designed to collect Monsanto and Agrium
deferral amounts based on amortization schedules defined in Commission Order No. 32432.
Rates are also designed so they are line loss adjusted for the different classes and allocated on a
per kilowatt-hour (kwh) basis.
OVERVIEW OF COMPANY APPLICATION
2014 ECAM Deferual
The Company requests a Commission Order approving recovery of approximately $12.8
million in total deferred costs in this year's ECAM filing for the deferral period of December 1,
2012 through November 30, 2013. According to the Application, the Company's Base NPC
originated from the 201I Stipulation approved by the Commission. The Base NPC was set at
$1.205 billion for the 2012 calendar year and $1.385 billion for the 2013 calendar year for a
STAFF COMMENTS MARCH 20,2014
combined Base NPC of $1.369 billion for the deferral period. A higher actual system NPC
resulted in an adjustment of approximately $9.8 million before applying the 90/10 sharing band.
RMP credits customers for over-recovery of energy-classified production cost (excluding
NPC) through the LCA due to higher than normal loads using the Load Change Adjustment Rate
(LCAR) of $5. 14 per megawatt-hour (MWh) established in Commission Order No. 32432. The
adjustment is approximately $l.2 million before sharing.
The Company credits a total of $176,329 subject to and before sharing through other
adjustments included in the ECAM. This includes: (l) credits to customers for revenue resulting
from the sale of sulfur dioxide (SO2) credits of $3,078, (2) credits to customers for over-recovery
of ldaho's allocation of incremental DSMI Load Control Program costs of $213,882, and (3) a
$40,631 surcharge to customers due to Financial Accounting Standards Board (FASB) Emerging
Issues Task Force (EITF) 04-6 accounting treatment of coal stripping costs. Finally, the defenal
balance reflects a surcharge amount of approximately $5.2 million for REC revenue not subject to
sharing.
RMP's ECAM deferral is summarized in the following table outlining Monsanto, Agrium,
and tariff customer's allocation of the total defenal amount.
Company Proposed Defe rral
(Dec.2012 thru Nov. 2013)
LCAR
SO2 Allowance Credit
ariff Cu$omers Monsanto
(1 ,1 93,524)
(3,078)
(213,882)lnigation Load Control Adjustment
EITF 04€ Adiustmenl 1
Total without Sharing 8,421,il1
90%Customer S
Total with 79,387
REC 5,230,394
7,234,690 5,1 56,080
Balancing Account Activity
The Company maintains three separate balancing accounts for Monsanto, Agrium and
tariff customers (see table below). With the proposed deferral, the total ending balance at the end
of the 2014ECAM deferral period on November 30, 2013 was approximately $24.3 million: $9.9
million for tariff Customers, $13.4 million for Monsanto, and $1.0 million for Agrium. Included
in the totals are prior ECAM deferrals of $26.7 million, ECAM collections of $15.5 million, and
5.784.623 3.714,394283) (264,254) (3,e87)
1,6ss) (1,310) (113)148,750) (60,791) (4,341)'t,737 41
961,681 2,105,280 163,432
STAFF COMMENTS MARCH 20,2014
interest of approximately $264,000. The Company estimates the ending balance on November
30,2013 of $24.3 million will be reduced by approximately $4.7 million when factoring in
estimated collections between November,30,20l3 and April, 1,2014. New ECAM rates are
expected to be in place on April I ,2014.
Balancing Account Activity and Projections
ariff Customers Monsanto
2014 ECAM Eleferral 12,809,781
26,729,003
(1 5,525,328)
264,055
ECAM Rercnue Collections
lnterest
Ending Balance through November 30, 2013
Schedule 94 Collection - Dec 2013 - March 2014
24,277,51'.1
(4,686,052)
Expected as of April 1, 20'14 11 ,901,886 19,591,459
Rate Design and Revenue Recovery
The Company is proposing to collect a total of approximately $13.2 million beginning
April 1 ,2014 and ending March 3L,2015. This amount represents a total decrease of
approximately $2.8 million over current Schedule 94 rates authorized by Order No.32771 (Case
No. PAC-E-13-03). For tariff customers, this will result in an overall projected rate reduction of
2.3 percent or approximately $4.3 million in reduced revenue. The Company proposes to increase
Monsanto's rates by 1.7 percent or $1.4 million in revenue; and to increase Agrium's rates2.l
percent or $130,000 in revenue.
The targeted tariff customer collection amount of $6.8 million includes the deferral
amount from this year's ECAM plus account balances from previous ECAM deferrals (including
interest) net of collections as of March30,2014. Targeted collection amounts for Monsanto ($6.0
million) and Agrium ($451,078) includes half of the deferral amount from this year's ECAM plus
amortized account balances due for collection from previous ECAM deferrals (including interest)
approved in Commission Order No. 32432 also net of collections as of March 30, 2014. The
resulting rates are illustrated in the Company's Exhibit 2, included as Attachment A to these
comments.
STAFF REVIEW
Staff s review of the Company's Application focused on three different areas. First, Staff
reviewed the overall Application and verified the validity of the proposed cost deferral relative to
7,234,690 5,156,080 419,01114,033,226 11,850,355 845,421
11,s32,615) (3,73s,441) (257,271)123,431 130,941 9,683732 13,401,935 1,016,844071,315) (1,500,049) (114,688)
STAFF COMMENTS MARCH 2O,2OT4
the Company's operating conditions and environment. Second, Staff reviewed the method and
basis used to calculate cost deferrals, account balances, and rates to ensure they were correctly
and accurately calculated, aligned to the primary intent of the ECAM, and consistent with
previous Commission Orders. Third, Staff performed an audit of contracts, invoices, and
documentation of other components of actual cost to ensure completeness and accuracy of the
information included in the Company's filing. As a result of this review, Staff highlights the
following:
1. The two largest factors driving the Company's proposed deferral is the base-to-
actual difference in NPC ($8.8 million) and REC revenue ($5.2 million). The
increase in these components is partially offset by the over-collection (credit) for
the customers' share of the LCAR adjustment.
The Wholesale Loss Adjustment (WLA) was misapplied in the Company's
calculation of the NPC deferral which results in an adjustment in the allocation
between Monsanto (increase $124,820), Agrium (increase $9,901), and tariff
customers (decrease $ 1 35,328).
Not accounting for differences in line losses between base and actual loads creates
an over-collection resulting in a proposed adjustment that reduces the Company's
proposed deferral amount by $584,220.
Due to Staff s adjustment to the defenal amount, Staff proposes reducing tariff
customer's rates by 2.6 percent over current rates, and only increasing Monsanto
and Agrium's rates by 1.6 percent and2.0 percent, respectively.
Actual costs (including the offset of wholesale sales) used to compare against the
base costs were audited with no major inconsistencies found that would change the
filing. Staff s analysis finds that transactions recorded to the specific FERC
accounts used to record Actual NPC and as adjusted by the Company in its filing
are appropriate for recovery.
The following sections provide additional details of the above finding through an analysis
of the major components of the ECAM: (l) the Company's proposed deferral, (2) the balancing
account tracking ECAM collections and deferrals, and (3) proposed ECAM rates.
2.
a-1.
4.
5.
STAFF COMMENTS MARCH 20,2OI4
Analvsis of Deferral
The two largest components of the Company's proposed deferral are the change in the
NPC ($9.8 million) and REC revenue ($5.2 million) base-to-actual differentials. Regarding NPC,
Staff performed an analysis based on figures contained in Company Exhibit 1 which is
summarized in the table below. Although the individual expense categories in the base do not
precisely reflect the "black box" settlement in Case No. PAC-E-17-l2,the comparison does
provide a rough approximation for factors driving the NPC defenal. Staff agrees with the
Company that the largest factor contributing to the NPC defenal is a 4l percent reduction in
actual wholesale sales revenue, 33 percent by volume, compared to what was assumed in base
rates. Staff believes this is reasonable given that market prices were 12 percent lower.
Another contributing factor was a nine percent increase in actual purchased power
expense. Staff calculated an average unit price that was over $53/MWh which was 62 percent
higher than that assumed in the base. Staff believes the higher than normal average unit price is
likely due to a larger proportion of peak-period real-time purchases than what was assumed in
base rates. The higher price explains why the Company reduced the amount of energy purchased
by 33 percent.
Total coal fuel expense increased by l1 percent. This is partially explained by a slightly
higher amount of coal-fired generation, but also due to a six percent higher coal cost than used in
the base. Reduced natural gas expense moderated increases in other NPC categories by
decreasing 18 percent from the base. This is mainly due to a37 percent decrease in the price of
natural gas since base rates were developed, which drove a32 percent increase in the amount of
natural gas generation. Based on this analysis, Staff believes the Company's NPC was
reasonable.
Net Power Cost Analysis % Chanoe NPC Base-to-Actual
NPC ($)l Enerov (MWh)l Unit cost ($/MWh)
Wholesale Sales Rewnue
Purchased Power Expense
Coal Fuel Expense
Natural Gas Expense
Wheeling, Hydro and Other Expense
41o/o -33Yo -12o/o
9o/o -33o/o 62Yo
11o/o 4o/o 60/o
-18% 32o/o -37o/o
-5o/o -11o/o 7o/o
STAFF COMMENTS MARCH 2O,2OI4
Regarding the $5.2 million true-up of REC revenue, there was $6.5 million of revenue
assumed in base rates and only $ 1.3 million in actual revenue. This is likely a direct result of
significantly lower REC prices since the 2011 rate case. Staff believes this is reasonable.
Staff has identified the following two adjustments to the Company's proposed deferral in
this year's ECAM: (1) an improper application of the Wholesale Loss Adjustment (WLA); and
(2) over-collection of revenue through base rates. The sum total of Staff s adjustments is a
decrease in the defenal of $584,827 $474,544 for tariff customers, $102,230 for Monsanto, and
$8,054 for Agrium. A summary of the adjustments and the impact to the Company's proposed
deferral is included in the following table.
Tariff Customer Monsanto
Proposed 12,809,781
WLA Adjustment
Base Rate Oler-collection
(607)
(58/.,220)
Total Adjustments (su,827)
Deferral with Staffs Adjustments 6,760,146 5,053,850 12.224.9U
Wholesale Loss Adjustment
While reviewing RMP's deferral calculations, Staff discovered an error in the application
of the WLA per Commission Order Nos. 32597,32771, and 32910. The wrong WLAs were
applied to January through May 2013 actual loads resulting in an incorrect allocation of deferral
amounts between Agrium, Monsanto, and tariff customers. Staff s correcting adjustments to
Company Exhibit I are shown in Attachment B to these comments. The following table provides
a summary of Staff s calculation of the adjustment.
Defurral with WLA
Base Rate Over-Collection Adjustment
Staff identified an issue in the Company's method of calculating the NPC deferral amount.
Staff discovered inaccuracies due to a difference between line losses that actually occur during the
(135,328) 124,820 9,90116) (227,050) (17,9s5)(474,544) (102,230) (8,
7,234,690 7,099,3625,156,080 5,280,9004'19,0't1 428,912
STAFF COMMENTS MARCH 20,2014
deferral period and line losses used to calculate base rates. This error affects any ECAM deferral
component that recovers cost or credits revenue through base rates. This includes deferrals for
NPC, LCA, DSM1 Load Control Program cost, and REC revenue.
Using NPC as an example, the Company's method currently "approximates" the amount
of the NPC deferral by multiplying the system base and actual unit NPC differential by actual
load measured at the point of generation. However, base rates are determined using jurisdictional
sales measured at the customer's meter; and the difference between load measured at generation
and sales measured at customer meter are line losses. If the Company's method is to accurately
adjust for the over-recovery or under-recovery of NPC through base rates, the line losses used to
calculate base rates and the line losses that actually occur must be equivalent. Additionally, Staff
has found that relatively small differences in line loss between base and actual loads can drive
large inaccuracies in deferral amounts when using the Company's current ECAM methodology
(e.9., a one percent line loss difference can cause approximately a six percent error in the NPC
deferral). In this year's ECAM, Staff calculated a 1.3 percent difference in the line loss between
base and actual loads.
Staff, in collaboration with the Company, proposed a method to check the accuracy of its
deferral amounts. It is based on the ECAM's primary purpose: a mechanism to adjust for the over
or under-recovery of ECAM-related actual cost through base rates. It was also used to determine
Staffls adjustments to the Company's proposed deferral amounts. The method can be expressed
by the following generic equation:
Actual Cost
(e.g., NPC)
: Revenue Recovery of Actual
Cost through Base Rates
ECAM Cost
Adjustment
Staff believes using this equation to calculate the deferral is more precise and mirrors the
ECAM's primary intent. It is functionally identical to the Company's current method but
eliminates inaccuracies caused by base and actual line loss differences by using sales at customer
meter to calculate revenue generated through base rates.
While developing the method used to calculate the adjustment, Staff has been careful to be
consistent with past orders and to maintain the limited "scope" of the ECAM by only including
those costs (and revenues) currently authorized for recovery minus sharing. Staff believes this is
Total Recovery
STAFF COMMENTS MARCH 2O,2OI4
both required by the Commission and in the public's interest. It keeps the scope of the ECAM
small, limiting guaranteed recovery to a small subset of costs that are substantial, highly
unpredictable, and subject to a high degree of volatility largely outside of the Company's control
while leaving all other costs subject to the benefits of traditional ratemaking.
The following table provides a summary of Staff s adjustment for base rate over-
collection. As reflected in the table, Staff recommends the total adjustment amount be allocated
between Agrium, Monsanto and tariff customers based on proportion of actual energy sold. This
complies with the method of allocation in the ECAM and in other power cost adjustment
mechanisms used by other utilities in Idaho. Details of the base rate over-collection adjustment
for each ECAM component can be found in the narrative below and in Attachment C to these
comments.
Base Rate Over-Collection Adiustment
NPC Debnal
LCA Debrral
lrrigation Load Control Cost Defurral
REC Rewnue Debrral
Total Tariff Customer
Adiustment ($) Allocation ($)
Monsanto Agrium
Allocation ($) Allocation ($)
(644,459)
(269,177)
(s5,488)
384,904
(374,192)
(156,292)
(32,218)
223,487
(250,461)
(104,612)
(21,565)
149,588
(1 9,807)
(8,273)
(1,705)
11,830
Total Adjus{ments
ldaho Actual Load Allocation Percentages
(584,2201 (339,21 6)
58.06%
1227,050t/
38.86%
(17,955)
3.07%
NPC Deferual Adjustment - To calculate an adjustment to the Company's proposed NPC
deferral, Staff subtracted the recovery of NPC through Idaho base rates from actual jurisdictional
NPC and then netted it against the Company's proposed NPC deferral. Using this method, Staff
proposes to reduce the NPC deferral amount by $716,066 before sharing and$644,459 after
sharing.
LCA Deferual Adjustment -The Load Change Adjustment Rate (LCAR) that was set in
general rate case PAC-E-I1-12 through Commission Order No.32432 was used to calculate the
Company's proposed LCA in the Company's Application. The current LCAR is the amount of
revenue the Company collects to recover the fixed cost (non-NPC) portion of energy-classified
production revenue requirement for every megawatt-hour the Company generates. By
multiplying the LCAR by the difference of base and actual Idaho load measured at the point of
generation, it is assumed that the amount of over or under-recovery of LCA related expense
through base rates can be determined. However, due to differences in base and actual line losses
and because the calculation uses loads measured at generation, the same inaccuracy identified for
the NPC deferral occurs for the recovery of LCA-related costs.
STAFF COMMENTS MARCH 2O,2OI4
Staff calculated an adjustment to the Company proposed LCA by directly calculating the
amount of LCA expense recovered through base rates and netting it against (1) actual
jurisdictional LCA-related cost, and (2) the LCA proposed by RMP. Staff eliminated the line loss
error by calculating the amount of LCA expense recovered through base rates using the
Commission approved LCAR based on Idaho jurisdictional cost and jurisdictional sales used to
determine base rates. Multiplying the re-formulated LCAR by Idaho actual sales determines the
amount of LCA-related revenue RMP earned through base rates. When netted against actual cost
and the Company's proposed LCA defenal, it provides the basis for Staff s adjustment: a
reduction of $299,086 before sharing and $269,177 after sharing.
Staff believes Idaho actual sales used to calculate the LCA adjustment must be adjusted
for curtailment consistent with current ECAM methodology to comply with previous Commission
orders. However, through discussions with RMP, the Company does not agree that actual loads
should be adjusted for curtailment. Nevertheless, in Reconsideration Order No. 32597, the
Commission found "that the proposed adjustment to Rocky Mountain's ECAM Application
presented by Stafl and agreed to by Monsanto and Rocky Mountain, are fair, just and
reasonable." Id. at 7. Furthermore, Staff believes that circumstances have not changed since the
Commission made its Order, nor does Staff believe the rationale for its proposed adjustment
interferes with or changes its relevancy. Additionally, in Reconsideration Order No. 32597:
Staff noted that per the Company's filing and in accordance with Order No. 32507, 'RMP
is currently able to recover energy-related fixed cost of load economically curtailed
through the Load Change Adjustment (LCAR) portion of the ECAM' .... Staff believes
that this must be corrected to avoid allowing the Company a 'double recovery of energy-
related fixed costs associated with load that is economically curtailed'..... Staff believes
that the choice to economically curtail is within the Company's control and should be
viewed as a'sunk cost embedded in rates.' Staff asserted that if Monsanto is curtailed
Rocky Mountain will almost certainly recover its fixed costs because it will either sell the
generation at a higher price or it will avoid a more expensive energy purchase. 'The
ability of RMP to fully recover the fixed energy costs associated with economic
curtailment without LCAR recovery forms the basis of Stafls proposed adjustment.'
Id. at 5.
DSMI Load Control Program Cost Adjustment - DSM1 Load Control costs were added to
the ECAM pursuant to Commission Order No. 32432. There was $l million of program costs
embedded in base rates and $831,541 in actual cost allocated to Idaho. The Company calculated
the deferral by taking the difference between the two amounts. Staff believes this calculation is
STAFF COMMENTS 10 MARCH 20,2014
inaccurate because it does not account for the larger amount of sales that actually occurred during
the deferral period over what was used in establishing base rates leading to an over-recovery
through base rate revenue. Staff applied the same methodology it used to calculate the NPC
deferral adjustment resulting in a reduction in the DSMI Load Control Program cost deferral of
$61,653 before sharing and $55,488 after sharing.
Renewable Energy Credit Revenue Defercal - REC revenue was authorized to be added to
the ECAM through Commission Order No. 32916. The Company's method calculates REC
revenue deferral in the same way the DSMI Load Control Program deferral is calculated which
Staff maintains is inaccurate. However, using Staffls methodology, the recommended adjustment
results in an increase to the Company's proposed deferral because in this case, the larger amount
of actual sales over the amount of sales used to determine base rates over-credits customers by
$384,904 after taking into account the Company's proposed deferral. REC revenue is not subject
to sharing through the ECAM.
Analvsis of Balancing Accounts
Staff reviewed Agrium, Monsanto and tariff customer's balancing accounts and believes
they are accurately tracking ECAM revenues, monthly deferral amounts, and a Commission
approved interest rate of one percent. If the Commission approves Staff s deferral adjustments,
these amounts should be subtracted from the ending balances of the Company's respective
balancing accounts as follows: $8,504 for Agrium; $102,230 for Monsanto, and $47 4,544 from
tariff customers.
In a settlement approved by Commission Order No. 32910, Agrium and Monsanto
deferrals will be combined with remaining customer classes starting December 1,,2013 and
allocated through line loss differentiated rates on a per kWh basis in next year's ECAM.
However, Monsanto and Agrium will have amortized balances that remain to be collected from
the 2012 through 2014 ECAM deferrals (plus interest). Staff recommends that the separate
balancing accounts be maintained until remaining amortized amounts from these deferrals are
fully collected based on the amortization schedules set forth in Commission Order No.32432.
1tSTAFF COMMENTS MARCH 2O,2OI4
Analysis of Proposed Rates
Staff thoroughly reviewed the Company's methodology to establish rates for
implementation starting April 1,2014 and ending March 31,2015. Staff believes the Company's
methodology and calculations properly comply with Commission Order No. 32432 for amortizing
Agrium and Monsanto ECAM balances.
However, if the Commission authorizes Staff s proposed deferral adjustments, Staff
believes the new ending balances justify reductions in the Company's proposed ECAM rates. In
the ECAM rate for tariff customers, Staff s adjustment would result ina2.6 percent decrease
instead of the 2.3 percent decrease proposed by the Company; a 1.6 percent increase instead of the
1.7 percent increase for Monsanto; and a 2.0 percent increase instead of the 2.1 percent increase
for Agrium. A copy of the Company's Exhibit 2rate calculations with Staffs deferral
adjustments is included as Attachment D to these comments.
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.
According to RMP, Customer Notices were mailed with cyclical billings beginning
February 7,2014 and ending March 7,2014. The final date for customers to file comments is
March 20,2014. As of March20,2074, no customers had filed comments.
Last year, RMP failed to send approximately one-half of its customers the required
customernoticeinatimelymanner. InOrderNo.32TTl,theCommissionremindedRMPof"the
importance of allowing an adequate time period for customers to review and file comments
regarding the Company's Application. We expect that this will not be an issue in subsequent
ECAM filings." Order at 6. Staff reports that timely notice was provided.
STAFF RECOMMENDATION
Staff recommends that a total deferral amount of 512,224,954 for the period of December
1,2012 through November 30,2013 be approved for recovery from ratepayers with an allocation
as follows:
STAFF COMMENTS t2 MARCH 2O,2OI4
Tariff customers $6,760,146
Monsanto $5,053,850
Agrium $410,957
Furthermore, Staff recommends that :
l. The Company utilize Staff s base rate over-collection adjustment methodology to perform
a check on deferral amounts in all future ECAM applications so that adjustments can be
made as necessary.
2. The Company maintain separate balancing accounts for Monsanto and Agrium amortized
deferrals until the amounts have been fully collected.
3. Schedule 94 ECAM rates as illustrated in Attachment D be approved by the Commission
effective April l, 2014. The new rates constitute a 2.6 percent reduction for tariff
customers, a 1.6 percent increase for Monsanto, and a 2.0 percent increase for Agrium
from current Schedule 94 rates.
4. The Company file tariffs that reflect Commission approved rates.
dIG
Neil Price
Deputy Attorney General
Respecttully submitted this ]..t90* of March 2014.
Technical Staff: Mike Louis
Keith Hessing
Patricia Harms
Nikki Karpavich
Marilyn Parker
i:umisc:comments/pace I 4. 1 npphswkhmlnkmp comments
STAFF COMMENTS l3 MARCH 2O,2OT4
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ATTACHMENT B
IS CONFIDE,NTIAL
AND PROTECTET)
UNDERTHE
PROTECTIVE
AGREEMENT
Staff Base Rate Over-collection Adjustments - PAC-E-14-1
to Net Power Cost Deferral
Amounls were stipulated for 2012 and 2013 in PAC-E-1 1-'12
Recovery of Aclual NPC through Base Rates
Annual Cost embedded in base rates (g)1
NPC Rate Embedded in Base Rates ($/MvVh)
Revenue Collecled through Base Rates ($)
Recovery of Aclual NPC through ECAM
Company Proposed NPC Defenal (before sharing)
76,555,188 87,555,188
Load Chango Adjustment (LCA)
December'12 - November'13
tual ldaho Production Revenue Requlrement mlnus NPC2
LCAR (effective April 1, 201 1 - $/MWh)
ldaho Base Load (A input (MVVh)
Total Actual ldaho Production R6venue Requirement minus NPC
overy of ldaho Productlon Revenue Requlrement minus NPC
Recovery of ldaho Produciion Revenue Requirement minus NPC through Base Rates
ldaho Produclion Revenue Requirement minus NPC embedded in Base Rates ($)
ldaho Base Load @ meter (MWh)
LCAR based on Load @ meter ($/MWh)
ldaho Ac{ual Load @ meter adiusted for curtailment (MWh)
Revenue Collected lhrough Base Rates ($)
Recovery of Aclual Production R.R. minus NPC through ECAM
Company Proposed LCA Oefenal (before sharlng)
Recovery of Actual Productlon R.R, mlnus NPC
Assumes ldaho Produclion Revenue Requirment minus NPC embedded in Base Rates are equal to Aclual cosl
Load Control Proqram Cost Deferral
Recovery of DSMI Cost in Base Rates
ldaho DSMI Cost Embedded in Base Rates ($)
ldaho Base Load @ meter (MWh)
DSM1 Cost Rate ($/MWh)
ldaho Actual Load (D meter without reolacement (MWh)
Revenue Recovered through Base Rates
Recovery of DSMl Cost through ECAM
Company Proposed DSM'l Defenal (before sharing)
Total Recovery of Actual DSMI Cost
REC Revenue
Oecember'12 - November'13
Credit of REC Revenue in Base Rates
ldaho REC Revenue Embedded in Base Rates ($)
ldaho Base Load CD meler (MWh)
REC Revenue Rate ($/MWh)
Revenue Credited through Base Rates
Credit of REC Revenue lhrough ECAM
Company Proposed REC Defenal (before sharing)
Credit of Actual REC Revenue
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY oF MARCH 2014,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC.E-I4-01, BY E-MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 8411 1
E-MAIL: ted.weston@pacifi com.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
d atareq ue st @paci fi corp. com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX l39l
POCATELLO ID 83204
E-MAIL: [e-mail]
YVONNE HOGLE
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: wonne.hoele@f'acifi corp.com
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: iim.r.smith@,monsanto.com
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#r40
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE