20150313Comments.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:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE RATES BY $10.7
MILLION TO RECOVER DEFERRED NET
POWER COSTS THROUGH THE ENERGY
COST ADJUSTMENT MECHANISM (ECAM).
q,
!-' (-
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.Ts.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
Modified Procedure issued in Order No. 33235 on February 25,2015, in Case No. PAC-E-I5-01,
submits the following comments.
BACKGROUND
On February 2,2015, PacifiCorp dba Rocky Mountain Power ("Rocky Mountain" or
"Company") submitted its annual Energy Cost Adjustment Mechanism ("ECAM") filing in
accordance with ldaho Code $$ 6l-502 and 61-503, and Rule of Procedure S2,IDAPA
31.01.01.052.
Rocky Mountain explained in its Application that the Commission established an annual
ECAM through Order No. 30904. 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.
STAFF COMMENTS MARCH I3,2OI5
Base and actual NPC are booked into specific FERC accounts outlined in the Application. The
ECAM process allows the Company to credit or collect the difference between the actual NPC
incurred to serve its Idaho customers and the NPC collected through rates. Rocky Mountain
defers the difference into an ECAM balancing account.
The Company fuither noted that the ECAM includes five additional components: the Load
Growth Adjustment Rate ("LGAR") or Load Change Adjustment Rate ("LCAR"), a credit for
SO2 allowance sales, an adjustment for the treatment of coal stripping costs, a renewable resource
adder for the renewable resources that are not yet in rate base and a true-up of renewable energy
credit ("REC") revenues, as authorized by the Commission in Order No. 32196. The ECAM
includes a 90 percent (customers)/10 percent (Company) "sharing band" wherein customers
paylreceive the increase/decrease in actual NPC compared to base NPC and Rocky Mountain
incurs/retains the remaining 10 percent.
Rocky Mountain states that the Base NPC in this case originated from the 201I stipulation
approved by the Commission. The Base NPC was set at $1.385 billion for the Deferral Period.
OVERVIEW OF COMPANY APPLICATION
Rocky Mountain's Application seeks to revise Schedule 94, Energy Cost Adjustment, to
recover approximately $23.3 million in total deferred net power costs over the collection period
beginning April 1,2015 through March 31,2016 with a recovery of total deferred net power costs
of $16.6 million for the period beginning December 1,2013 through November 30,2014
("Deferral Period") as illustrated in the table below.
Estimated De ferrrd ECAM Balance forCollection
Balances for Collections allocated by Class Sch 400 Sch lo1 Tariff Customer Total
Unamortized Pre\,,ious Balance
ECAM Rider Rerenues
WLA Adjustment
lnterest on defurrals pnor lo 1211113
' $13,170,906' $997,6s1 ' $9,535,217' $20J09J74' l$s,0s2,4t71' ($393,965)' ($z,zoo,ota)' ($13,s46,3G0)
' $63,000 ' $4,soo ' ($o7,5oo)' $o
November 30, 2014 Balance For Collection
8.198'
484
lnterest
Expected Balance for Collection as of April l, 2015 $6,175,247 ' $461,577 ' $69,178 ' $6,706,002
lncremental Un-allocated Balances for Collection Total Company
' $29,624' $1,785' $2,938' $29,348
Total Company Reco\ery br NPC Deftnal
lnterest on debnal fom 12l1l13lhru 11130114
' $'16,528,428
' 106,134
Balance
Total Balance for Collection $23,3lo,564
STAFF COMMENTS MARCH I3,2OI5
The proposed $23.3 million recovery represents an increase of approximately $10.7
million in estimated revenue or a 3.9 percent increase over current Schedule 94 rates approved in
Commission Order No. 33008 (Case No. PAC-E-14-01). Of this amount, $6.8 million is
allocated to Monsanto, $0.5 million is allocated to Agrium, and $3.4 million is allocated to
remaining tariff customers representing an increase of 8.1 percent, 8.0 percent, and I .9 percent,
respectively, over current rates. The Company states further that the recovery amount includes an
amortization of Monsanto Company's ("Monsanto") and Agrium Inc.'s ("Agrium") share of
2012-2014 deferrals.
The total deferral amount of $16.6 million is made up of several components illustrated in
the summary table below. A copy of Company Exhibit No. I showing the detail of these
calculations is included as Confidential Attachment A to these Comments.
Summarv Table of ECAM Deferral
NPC Difierential for Deferral
LCAR
so2
Load Control
EITF 04€ Adjustment
Total
Customer Responsibility
REC Deferral
Backcast
lnterest
Annual Deferral (Dec 2013 - Nov2014)
12,735,507
(61e,
(71
963,027
l5::13,012,449
90%
11,711,204
6,064,558
(1,247,334
1 06,1 34
16$-3a"56z
The NPC deferral amount is calculated on a monthly basis by subtracting the monthly
Base NPC rate from the Actual NPC rate. The NPC rate is calculated by dividing monthly NPC
by the corresponding monthly load to express the costs on a dollar per megawatt-hour (MWh)
basis. According to the Company, the average Base NPC was $23.73 per MWh and the Actual
NPC averaged $27.05 per MWh, a difference of $3.32 MWh. The monthly incremental
difference is then multiplied by Idaho's actual load each month for the Deferral Period. For the
l2-month period ending November 30,2014, the NPC differential for deferral was approximately
$12.7 million before application of the 90110% sharing band. The LCAR decreased the deferral
balance by $619,086, before sharing, due to higher loads during the Deferral Period.
STAFF COMMENTS MARCH I3,2OI5
Credits for SO2 allowance sales revenues received by Rocky Mountain were also included
as an offset to the NPC deferral ($71 before sharing). Additionally, Idaho's share of incremental
load control costs, pursuant to Commission Order No. 32432, is tracked in the ECAM and
resulted in an adjustment increasing the deferral by approximately $1.0 million before sharing.
The difference between including 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, decreased the deferral by
$66,928 before sharing.
The total NPC deferral adjusted for the aforementioned LCAR, SO2 revenue, load control,
and EITF 04-6 is $13.0 million before application of the sharing band and $l1.7 million after its
application. Additionally, the deferral balance reflects the difference between actual REC
revenues during the Deferral Period and the amount of REC revenues included in base rates. The
REC revenue true-up included in the ECAM is symmetrical but no sharing band is applied.
During the Deferral Period, actual REC revenue was approximately $6.0 million lower than the
amount in base rates on an Idaho-allocated basis.
Pursuant to Order No. 33008, Rocky Mountain performed a backcast calculation in order
to establish whether there was an over/under-collection of NPC, load control costs, and RECs,
reducing the total deferral by approximately $1.2 million and making the net deferral $16.5
million before interest. Approximately $0.1 million of interest was accrued on this balance
during the deferral period for a final deferral of $ 16.6 million.
STAFF REVIEW
Staff s review focused on three different areas of the Application. First, Staff reviewed
the Application to assess the overall validity of the electricity producing cost factors driving the
deferral amount during the deferral period as compared to costs at the time base rates were set.
Second, Staff reviewed the method and basis used to calculate the cost deferral amounts, account
balances, and rates to ensure they were accurately calculated and consistent with previous
Commission orders. Third, Staff performed an audit of contracts, invoices, and other actual cost
components to ensure the Company's filing was thorough and accurate. The major findings from
Staffls review are listed below:
STAFF COMMENTS MARCH I3,2OI5
1.The Company adjusted for $1.25 million in over-recovery using Staff s "backcast
method" per Commission Order No. 33008, but failed to adjust for the over-recovery
of LCAR-related costs resulting in a proposed adjustment that would further reduce
the Company's deferral by $240,725.
The Company's method did not properly allocate costs and revenues between
Monsanto, Agrium, and remaining tariff customers when designing ECAM rates
resulting in less than a O.lYo change in revenue impact to any one customer class.
Collections and actual costs (including the offset of wholesale sales) used to compare
against base costs were audited with no major inconsistencies that change the filing.
Staff s analysis finds that the transactions recorded to the specific FERC accounts used
to record against Actual NPC and as adjusted by the Company in its filing are
appropriate for recovery.
The subsequent sections provide additional details of the above findings with a thorough
analysis of the following components of the ECAM: (1) the Company's proposed deferral, (2)
balancing accounts tracking ECAM deferrals, collections, and interest, and (3) proposed ECAM
rates.
Analvsis of Deferral
Results of Audit
Staff performed a thorough audit, including on site audits at the Company's Portland and
Salt Lake City offices. Staff reviewed intemal audit work papers, control processes, as well as
journal entries, invoices, and contracts. The audit included a review of the adjustments made to
actual costs the Company incurred. Staff reconciled the general ledger amounts to the net power
costs as provided for in the Company's Exhibit No. 1. In all material aspects, Staff believes that
the NPC provided in the Company's Exhibit No. I are accurate and in compliance with ECAM
policies.
Analysis of Cost/Revenue Dffirences
The two largest components of the Company's ECAM deferral are adjustments due to
variances between the amounts of NPC and REC revenue included in base rates versus actual
amounts incurred during the deferral period ($10 million and $6.4 million, respectively).
,)
J.
STAFF COMMENTS MARCH 13,2OI5
Regarding NPC differences, Staff performed an analysis of the costs contained in the
Company's filing as reflected in the table below. Although the NPC figures do not precisely
reflect those included in the "Black Box" settlement in Case No. PAC-E-11-l2,it does provide a
rough comparison of individual cost categories.
As was the case in last year's ECAM, the largest contributing factors to the difference
between base and actual NPC continues to be decreased revenue from wholesale sales and coal
fuel expense. There was a 33 percent difference in the amount of energy the Company was able
to sell compared to the amount used to determine base rates, even though unit prices averaged2
percent higher. The ability to sell is dependent on prices the Company can obtain on the open
market as compared to the cost to produce electricity. In addition, as indicated by the Company,
several long-term contracts previously included in base NPC have since expired.
The second largest factor is the 16 percent increase in total coal fuel expense over what
was included in base rates. This increase appears to be driven by higher coal mining costs and
coal purchase prices as indicated by a l5 percent overall increase in the unit cost. Total purchased
power expense also increased 7 percent and the total amount purchased decreased 42 percent from
amounts included in base rates. Staff believes this is reasonable given higher unit prices than
those assumed in base rates. Lower natural gas prices, which have driven significantly higher
levels of natural gas generation, continue to moderate higher costs in other categories. Overall,
Staff believes the NPC reflected in the Company's filing were reasonably incurred.
Regarding the $6.4 million adjustment for REC revenue, $6.5 million was assumed in
base rates and less than $0.5 million in RECs were actually sold. Staff believes this is reasonable
given the collapse in open market REC purchase prices since base rates were established.
Net Power Cost Analysis % Chanqe NPC Base-to-Actual
NPC ($)l Enerov (MWh)l Unit Cost ($/MWh
/y'holesale Sales Rerenue
rurchased Power Expense
3oal Fuel Expense
\atural Gas Expense
Nheeling, Hydro and Other Expense
-32o/o
7%
16%
2%
5%
-33%
42o/o
1o/o
77o/o
$o/o
2%
85o/o
15%
43o/o
12o/o
Net Tota 25o/"'110/o
STAFF COMMENTS MARCH I3,2OI5
Deferral Calculation Methodology
The Company's proposed $16.5 million (minus interest) deferral amount includes $1.25
million in adjustments from a "backcast" verification step ordered by the Commission (Order No.
33008) in Case No. PAC-E-14-01 and reflected in the table below. This step is performed as a
check to ensure that the amount of revenue the Company recovers through base rates and the
ECAM is no more or no less than actual NPC.
2015 ECAM Doferral Summary
NPC Adjustment
Energy Classilied Production Cost minus NPC (LCAR)
S02 Allowance Re\€nue
DSM Load Control Program Cost Adjustment
EITF 04{6 Adjustment
REC Re\renue
Total Deferral less lnterest (Dec. 2013 thru Nov. 20141 17,775,762 16,528,428
However, the Company failed to include an adjustment for the over-recovery of LCAR
related costs (Energy-Classified Production Cost minus NPC) that was included in the
adjustments ordered by the Commission in last year's ECAM. See Order No. 33008 at 14-15.
Staff proposes an adjustment to the Company's filing that reduces the deferral amount by an
additional $240,725 for LCAR-related cost. This would reduce the overall deferral amount to
916,287,703 (minus interest). The adjustment is summarized in the table above and more fully
detailed in Confidential Attachment B.
Staff believes the Company's calculation method demonstrates inherent flaws as
demonstrated by the apparent inaccuracy of approximately $1.5 million ($1.25 million "backcast"
adjustment included in the Company's filing plus Staff s $240,725 adjustment) in this year's
ECAM and the approximate $600,000 inaccuracy reflected as the "base-rate over-collection
adjustment" in last year's ECAM. Analyzing the difference between the two methods, Staff
believes that the inaccuracy is attributable to three causes, two of which are inherent in the
Company's methodology and outlined below:
1. By using loads at generation instead of using loads at the point of sale, the
Company's method creates an error caused by base-to-actual line loss differences.
The source of this enor was detailed in Staff s Comments in Case No.
PAC-E-14-01.
(63.7s)
866,724 (41,U41
(60,23s)
6,064.558 286,788
STAFF COMMENTS MARCH I3,2OI5
2. The recovery of costs embedded in base rates employed in Staff s adjustments are
calculated using embedded rates that are the same for each month unless base rates
change during the deferral period. This realistically reflects revenue the Company
receives through base rates for recovery of NPC. The Company's method
calculates the deferral using the difference between actual unit costs and base unit
costs which vary each month. The Company's method and Staff s method are not
mathematically equivalent. Furtheffnore, Staff believes the Company's method
does not accurately represent how revenue through base rates is actually realized
since base rates do not change from month to month unless there is a general rate
case.
The source of the third error can be found in the inclusion of loads that are not consistent
with loads used to determine base rates. In the stipulation for general rate case PAC-E-11-12,
Order No.32432 at 4,the Commission ordered the Company to "use 2011 actual loads reported
in the Annual Results of Operations Report for the 2013 ECAM defenal calculation" as base
loads for the purpose of calculating the deferral for the Load Change Adjustment without
changing the LCAR. Staff believes that because the LCAR is used to calculate over/under
recovery of costs embedded in base rates, use of loads other than those used to calculate base rates
are inherently inaccurate.
One option is to continue using the Company's method and employ Staff s "base rate
over-collection adjustment" method to verify and correct inaccuracies in future ECAM filings.
Staff s method corrects for all three errors outlined above. Another option is to change the
Company's ECAM calculation method to reflect Staff s adjustment methodology so that
adjustments for this type of error are no longer required. Staff believes that continuing to use the
Company's current method with the correction adjustment is not only inefficient, but adds a layer
of complexity that makes it difficult for intervening parties to follow. Staff recommends that the
Company change its method to calculate the deferral in next year's ECAM consistent with Staff s
adjustment methodology. Confidential Attachment C shows Staff s proposed deferral calculation
without the use of adjustments.
STAFF COMMENTS MARCH I3,2OI5
Analvsis of Balancins Accounts
Starting this past deferral period (December 1,2013), Agrium and Monsanto's deferral
amounts were combined with remaining customer classes per Commission Order No. 32910.
Staff believes that monthly deferral amounts plus interest were accurately tracked for allocation
and collection through the rate design.
Staff also believes the Company properly and accurately maintained separate amortized
balances for Monsanto, Agrium, and tariff customers. These separate balances include amortized
amounts for 2012 through 2014ECAM deferrals, collection of ECAM rider revenues, the WLA
adjustment stipulated in Commission Order No. 33094, and interest at the Commission approved
rate ofone percent.
Analvsis of Proposed Rates
Staff reviewed the Company's proposed rate design and believes that balances of past
amortization amounts for Agrium, Monsanto, and tariff customers were not properly separated
from current deferral amounts when designing rates. To ensure rates are properly constructed, a
separate rate should have been calculated for the three groups of customers for past amortization
amounts (plus interest) plus estimated collections occurring from December 1, 2014 through
March 31,2015 based on current ECAM rates. These rates should have been added to another set
of rates calculated for deferral amounts (plus interest) from December 1,2013 through November
30,z}l|for every customer class allocated on a line loss differentiated equal cents per kilowatt-
hour basis per Commission Order No. 32910.
If the Commission authorizes Staff s adjustment for the over-collection of LCAR-related
expense and Staff s method for calculating rates, customers will see a 1.8 percent overall increase
in rates as opposed to the 1.9 percent overall increase proposed in the Company's Application. In
turn, the Company will accrue approximately $230,000 less in revenues over the collection period
beginning April l, 2015 through March 3I,2016. A copy of Staffls rate design including the
adjustment for the over-collection of LCAR-related expense is included as Attachment D to these
comments.
STAFF COMMENTS MARCH I3,2OI5
CUSTOMER RELATIONS
The Company's press release and customer notice were included in the Application. Staff
reviewed both documents and found several deficiencies. The press release and customer notice
did not include information required by the Commission's Rules of Procedure (IDAPA 3 1 .01 .0 I ).
Rocky Mountain Power's notice and press release did not inform customers that they may
subscribe to the Commission's RSS feed to receive periodic updates via email about the case, as
required by Rule 125.01.d. The customer notice and press release also did not indicate that the
filing could be viewed on the Commission's website, as required by Rule 125.01.c. The customer
notice also did not inform customers of the overall percentage change from current rates, as
required by Rule 125.01.a.
The Rules of Procedure were revised last year, with changes becoming effective on
February 15,2014. Staff recommends that the Company review the updated Rules of Procedure
and include all required information in its customer notices and press releases in the future.
The customer notice was included with bills mailed to customers beginning February 9,
201 5 and ending March 9 , 2015. Customers have the opportunity to file comments by March 1 3,
2015. As of March 12, the Commission had received two comments opposing the rate increase.
STAFF RECOMMENDATIONS
Staff recommends that a total deferral amount of $16,287,703 ($16,393,738 with interest)
for the period of December 7,2073 through November 30,2014 be approved for recovery from
ratepayers.
In addition, Staff recommends that:
1. The Company should change its ECAM deferral calculation methodology so that it
is consistent with Staff s "base rate over-collection adjustment" method as
illustrated in Attachment C.
2. The Company should maintain separate balancing accounts for Monsanto, Agrium,
and tariff customers for amortized amounts from2012 through 2014 ECAM
deferrals until the amounts are fully collected.
3. Schedule 94 ECAM rates, as illustrated in Attachment D, should be approved by
the Commission with an effective date of April1,2015.
4. The Company should file tariffs that reflect Commission approved rates.
STAFF COMMENTS 10 MARCH I3,2OI5
Respecttully submitted this \?Yday of March 2015.
Technical Staff: Joe Terry
Mike Louis
Daniel Kline
i:umisc:commcntVpace I 5. I npjtnlsddk comment
Deputy Attorney General
t1STAFF COMMENTS MARCH I3,2OI5
ATTACHMENT A
IS CONFIDE,NTIAL
AND PROTECTEI)
UNDERTHE
PROTE,CTIVE
AGREEME,NT
ATTACHMENT B
IS CONFIDENTIAL
AND PROTECTEI)
TINDER THE
PROTECTIVE
AGREEMENT
ATTACHMENT C
IS CONFIDENTIAL
AND PROTECTED
UNDERTHE
PROTE,CTIVE
AGREEME,NT
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Attachment D
Case No. PAC-E-15-01
Staff Comments 3 I 13 l20l 5
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY oF MARCH 2015,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E.15.0I, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOLINTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
(Confi dential Attachments)
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL : [e-mail]
Q.{on- C onfi dential Attachments)
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
(Non-Confi dential Attachments)
ELECTRONIC ONLY
JIM DUKE
IDAHOAN FOODS
E-MAIL: jduke@,idahoan.com
(lrtron-Confi denti al Attachments)
WONNE HOGLE
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 841I I
E-MAIL: [e-mail]
(Confi dential Attachments)
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX l39l
POCATELLO ID 83204
E-MAIL : [e-mail]
(Non-Confi dential Attachments)
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
(lt{on-Confi dential Attachments)
ELECTRONIC ONLY
VAL STEINER
AGRIUM US INCAIU.WEST INDUSTRIES
E-MAIL : [e-mail]
(Non-Confidential Attachments)
CERTIFICATE OF SERVICE