20160315Reply Comments.pdf

ROCKY MOUNTAINPO'I'ER RECEIVED
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1407 West North Temple, Suite 310
Salt Lake Ci$, Utah 84'116
March 15,2016
YIA OWRNIGHT DELIVERY
Jean D. Jewell
Commission Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Re: CASE NO. PAC-E-16-05
IN THE MATTER OF THE APPLICATION OF ROCKY MOT]NTAIN POWER
REQUESTTNG APPROVAL OF THE $16.7 MTLLON NET POWER COST
DEFERRAL AND AUTHORITY TO DECREASE RATES BY $9.0 MILLION
Dear Ms. Jewell:
Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Reply
comments in the above referenced matter
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
U4tY.L'{,,,\},r/ u1,J
Jeffrey K. Larsen
Vice President, Regulation
Enclosures
CC: Steven D. Spinner
James R. Smith
Randall C. Budge
Katie Iverson
Yvonne R. Hogle (ISB# 8930)
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
E-mail : wonne.ho gle@pacificorp. com
Attorneyfor RoclE Mountain Power
IN THE MATTER OF TIIE APPLICATION
OF ROCKY MOT]NTAIN POWER
REQUESTTNG APPROVAL OF THE $16.7
MILLON IIET POWER COST DEFERRAL
AI\ID AUTHORITY TO DECREASE RATES
BY $9.0 MILLION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.16.O5
REPLY COMMENTS OF
ROCKY MOUNTAIN POWER
BACKGROT]ND
On February l, 2016, the Company filed an application ("Application") with the Idaho
Public Utilities Commission ("Commission") pursuant to the Company's approved energy cost
adjustment mechanism ("ECAM") for authority to adjust its Schedule 94, ECAM rates by $9.0
million and approval of approximately $16.7 million deferred net power costs from the deferral
period beginning December 1,2014 through November 30,2015 ("Deferral Period").
The Company requested approval to add $16.7 million into the ECAM balancing account
for the Deferral Period, which would bring the total ECAM balance to approximately $23.8
million as of November 30, 2015. The Company proposed to adjust Schedule 94 to collect
approximately $14.5 million over the period beginning April l, 2016 through March 31, 2017,
representing a decrease of $9.0 million over the current Schedule 94 rate.
Rocky Mountain Power Reply Comments Page I
On March 9,2015, Monsanto filed comments and did not propose any specific monetary
adjustments but stated it would support a monthly back cast adjustment versus an annual
adjustment.
Staff of the Commission ("Staff') filed comments on March 10,2015 responding to the
Application. Staff proposed two adjustments to the Company's deferred balance associated with
the back cast adjustment adopted by the Commissionr in the 2014 ECAM filing. First, Staff
proposed changes to correct an error in the back cast calculation, and second, Staffproposed the
back cast adjustment be accounted for monthly.
REPLY COMMENTS
Changes to Back Cast Adjustment
Staff recommended that the Commission decrease the Company's proposed deferral by
$51,343 to account for errors in the calculation of the back cast adjustment relating to the
separation of the Deer Creek mine depreciation from Base net power costs ('NPC") beginning
January 1,2015. The Company does not oppose this adjustment.
Monthly Back Cast Adjustment
Staff recommends and Monsanto supports that the back cast adjustment be accounted for
on a monthly basis. This change only affects the interest calculation in the balancing account;
therefore, Staff recommends that the Commission decrease the Company's proposed balancing
account 57,907 in addition to the decrease to the deferral due to the back-cast adjustment
mentioned above. The Company opposes this adjustment because the proposed monthly
approach is inconsistent with the annual back cast adjustment recommended by Staff and
approved by the Commission in the 2014 ECAM. Additionally, base rates are set in a general
rate case using annual NPC and annual billing determinants. Idaho's base billing determinants
' Order No. 33008, Case No. PAC-E-14.01.
Rocky Mountain Power Reply Comments Page2
were 3,328,058 megawatt-hours and the Company's billing determinants and collections did not
exceed the base NPC and megawatt-hours until November 2015. Monthly calculations of over-
collection of NPC are impossible given actual megawatt-hours didn't actually exceed base level
NPC until November 2015; therefore, it would be highly inappropriate to approve Staffs
monthly back cast adjustment.
CONCLUSION
The Company does not oppose Staffs proposed adjustment to reduce the defenal by
$51,343 to account for errors in the calculation of the back cast adjustment relating to the
separation of the Deer Creek mine depreciation from Base net power costs ('NPC") beginning
January 1,2015. The Company opposes Staff s recommendation that the back cast adjustment be
accounted for on a monthly basis for the reasons described above.
The Company recommends that, due to the minimal impact that Staffs proposed
adjustment would have on the rate design, the Commission approve Electric Service Schedule
No. 94 as filed in Exhibit No. 3 to the Company's Application.
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission:
(l) approve a deferral balance of $16,577,736 (before interest) which includes StafPs proposed
reduction of $51,343;
(2) reject StafPs recommendation to spread the back cast monthly; and
(2) approve the Electric Service Schedule No. 94 effective April l, 2016.
DATED this 15ft day of March,20l6.
ecWL
Atforney for Rocky Mountain Power
Rocky Mountain Power Reply Comments Page 3
CERTIFICATE OF SERVICE
I hereby certify that on this 15tr of March, 2016,I caused to be served, via e-mail, a true
and correct copy of the Reply Comments in PAC-E-I6-05 to the following:
Randall C. Budge Brubaker & Associates
Racine, Olson, Nye, Budge & Bailey, Chartered 16690 Swingly Ridge Road, #140
201E. Center Chesterfield, MO 63017
P.O. Box l39l [e-mail]
Pocatello, ID 83204-1391
rcb@racinelaw.n"t
James R. Smith (E-mail only) Ted Weston
Monsanto Company Rocky Mountain Power
P.O. Box 816 1407 W. North Temple, Suite 330
Soda Springs,ldaho 83276 Salt Lake City, Utah [e-mail] [e-mail]
Yvonne Hogle Data Request Response Center
Rocky Mountain Power PacifiCorp
1407 W. Norttr Temple, Suite 320 825 NE Multnomah Street, Suite 2000
Salt Lake City, Utah 84116 Portland, [e-mail] [e-mail]
/JA
Amy Eissler
Coordinator, Regulatory Operations