20151106SNA Comments.pdf

SNA}<E FTIVEFIALLIANGE
IOAHO'S NUGLEAT \NATCHOOG & CLEAN ENERGY ADVOCATE
November 6,201s
To: Idaho Public Utilities Commission
From: Ken Miller, Clean Energy Program Director, Snake River Alliance
Re: Snake River Alliance Comments In the Matter of PacifiCorp DBA Rocky Mountain Pfrwer's Application
to Modify the Energy Cost Adjustment Mechanism and Increase Rates, Case No. PAC-E-15-09.
0n behalf of our members in Rocky Mountain Power's Idaho service territory, the Snake River Alliance
appreciates this opportunity to provide comments on the above-referenced case, filed with the Public
Utilities Commission on May 27,20L5. These comments are submitted to the Commission in response to
its Notice of Proposed Settlement Stipulation, Notice of Modified Procedure, and Notice of Schedule,
ORDER NO. 33403.
The Snake River Alliance is not a party to PAC-E-15-09, but has reviewed the documents filed in this case,
including the stipulation filed on Oct. L5,20L5. The Alliance appreciates that Rocky Mountain Power
(RMP), Idaho Public Utilities Commission stafl and parties Monsanto Company and PacifiCorp Idaho
Industrial Customers were able to reach a proposed settlement stipulation that the Alliance believes is in
the best interest of Rocky Mountain Power customers. The parties agree that Idaho retail revenues
should increase by $10.2 million (3.9 percent) effective fanuary 7,20t6. (Notice of Proposed Settlement
Stipulation ,P.2). The Alliance supports the stipulation and believes it is in the best interest of Rocky
Mountain Power customers for reasons outlined below.
RMP satisfied PUC staff and the parties that a portion of the company's variable power supply expenses
should be transferred into permanent base rates. As it has in earlier, unrelated cases in which a utility
has sought ratemaking treatment for certain demand side management (DSM) expenses, the Alliance
supports allowing the utility to recover ongoing and permanent power costs through base rates rather
than through the Energy Cost Adjustment Mechanism (ECAM). (Application, P. 4). The ECAM will
continue to identify expenses, particularly fuel and power purchases that vary annually due to such
variables as weather and market prices.
While there will be a ratepayer impact should the Commission approve this settlement, the projected
increase of $2.35 a month for the average RMP residential ratepayer is almost certainly far lower than a
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possible rate increase that could occur should this case be fully litigated as a general rate case.
The Alliance also appreciates that parties agreed to a two-year RMP "stay-out" that will forestall the next
base rate increase to no sooner than Jan. 1,2018. We believe that avoiding the need to litigate a rate case
is almost always in the best interest of all parties and customers, and this is such a case.
The amount proposed to be shifted into permanent base rates, while not insignificant, is reasonable. We
note that of the $10.2 million currently collected through RMP's annual ECAM, $6.5 million is attributed
to revenues from the trading of Renewable Energy Credits (RECs) that the company will no longer
realize. The $3.2 million in power supply expenses that would be moved into base rates reflects expenses
for fuel and power purchases. The parties agreed in this settlement that the $3.2 million in power supply
expenses is reasonable and accounted for, and the Alliance has no reason to believe otherwise. We also
support terms of the settlement that spread the amount across all rate schedules (Settlement,P.2).
We also support RMP's willingness to "file an application for review by interested parties and for
approval by the Commission no Iater than September t,20L6, proposing the change to base rates, the
NPC from the 2015 annual results of operations report, the associated rate changes and spreads to
customer classes, and updated electric service schedules." (Settlement, P. 3). And given that revenues
from SOZ allowance sales have fallen to next to nothing ($71 in 20L4), we support the decision to remove
them from being tracked in the ECAM.
The Alliance again appreciates this opportunity to comment on PAC-E-15-09, and we recommend that the
Commission approve the proposed settlement. Again, we commend the Company and all parties to this
case for their efforts to strike the compromise that led to this proposed settlement and that avoided the
need for a protracted general rate case.
Respectfully submitted,
k<*->-'t l^
Ken Miller
Clean Energy Program Director
Snake River Alliance
P.0. Bo 1731
Boise,lD 83701
(208) 344-eL6L
kmill er(D snakeriverall iance.org
Hand Delivered
fean fewell
Commission Secretary
Idaho Public Utilities Commission
4T2W.Washington St.
Boise,lD 83702
Via E-Mail
Yvonne Hogle, Regulatory Counsel
Roclqy Mountain Power
201 S. Main, One Utah Center,23'a Floor
Salt Lake ciry, uT B4LLL
E-Mail: Yvonne.hogle@pacifi corp.com
Ted Weston, Idaho RegulatoryAffairs Manager
Rocl<y Mountain Power
201 S. Main, One Utah Center,23'd Floor
salt Lake city, uT 84L71
E-Mail: ted.weston@pacifi corp.com