20170201Application.pdf

February 1, 2017
VIA OVERNIGHT DELIVERY
Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83 702
Re: CASE NO. PAC-E-17-01
f ~cr:1vEo
?G 11 f C: -I , 9: 4 0 1407 West North Temple, Suite 310
Salt Lake City, Utah 84116
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
TO EXTEND THE 2017 PROTOCOL THROUGH DECEMBER 31, 2019
Dear Ms. Hanian:
Please find enclosed an original and seven (7) copies of Rocky Mountain Power's Application in
the above referenced matter.
Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.
Very truly yours,
Jeffrey K. Larsen
Vice President, Regulation
CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of February, 2017, I caused to be served, via e-mail, a
true and correct copy of its Application in PAC-E-17-01 to the following:
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
201 E. Center
P.O. Box 1391
Pocatello, ID 83204-1391
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah Street, Suite 2000
Portland, Oregon 97232
[e-mail]
James R. Smith (E-mail only)
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
[e-mail]
Daniel Solander
Rocky Mountain Power
1407 W. North Temple, Suite 320
Salt Lake City, Utah 84116
[e-mail]
Karl Klein
Deputy Attorney General
Idaho Public Utilties
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
[e-mail]
Brubaker & Associates
16690 Swingly Ridge Road, #140
Chesterfield, MO 630 I 7
[e-mail]
Ted Weston
Rocky Mountain Power
1407 W. North Temple, Suite 330
Salt Lake City, Utah 841 I 6
[e-mail]
Senior Coordinator, Regulatory Operations
Daniel E. Solander (ISB No. 8931)
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
E-mail: [e-mail]
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY MOUNTAIN
POWER TO EXTEND THE 2017
PROTOCOL THROUGH DECEMBER 31,
2019
CASE NO. PAC-E-17-01
APPLICATION
Rocky Mountain Power, a division of PacifiCorp ("Company" or "Rocky Mountain
Power"), hereby submits this application to the Idaho Public Utilities Commission (the
"Commission") requesting the Commission approve the extension of the 2017 Protocol for one
year, through December 31, 2019. In support of its Application, Rocky Mountain Power states as
follows:
INTRODUCTION
1. Rocky Mountain Power is a division of PacifiCorp, an Oregon corporation, which
provides electric service to retail customers through its Rocky Mountain Power division in the
states of Idaho, Wyoming, and Utah. Rocky Mountain Power is a public utility in the state of
Idaho and is subject to the Commission's jurisdiction with respect to its prices and terms of electric
service to retail customers pursuant to Idaho Code § 61-129. The Company provides retail electric
service to approximately 75,000 customers in the state.
COMMUNICATION
2. Communications regarding this Application should be addressed to:
Ted Weston
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Daniel E. Solander
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
Fax: [phone]
Additionally, the Company respectfully requests that all data requests regarding this matter be
addressed to one or more of the following:
By email (preferred)
By regular mail
[e-mail]
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
BACKGROUND
3. On October 14, 2016, the Commission issued Order No. 33623 in Case No. PAC-
E-15-16, approving the settlement of PacifiCorp' s interjurisdictional cost allocation issues known
as the 2017 Protocol. The 2017 Protocol was entered into with the understanding that it would be
a limited-term agreement, effective January 1, 2017, through December 31 , 2018, with an option
for a one year extension to allow parties more time to study the impact of emerging policies on
interjurisdictional allocation of costs and revenues. Section II of the 2017 Protocol provides that it
may be extended for one additional year, through December 31 , 2019, if all state commissions that
approved it determine it should be extended, by no later than March 31 , 2017.
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4. As approved by the Commission, the 2017 Protocol essentially employs the 2010
Protocol Method as previously modified and approved by the Commission, with the addition of an
annual Equalization Adjustment of $0.150 million to Idaho's 2017 Protocol revenue requirement.
5. In Section I of the 2017 Protocol, the Company committed to continued evaluation
of alternative inter-jurisdictional allocation methods, including consideration of corporate
structure alternative and distribution of the results of its analysis no later than March 31, 2017.
The Company conducted a year-long effort to analyze the practicability and cost impacts of an
alternative corporate structure. The Company also developed an alternative allocation concept
that would achieve results similar to structural separation for generation, while retaining the
current company structure and economic dispatch across the system, and increasing state
autonomy in resource decisions. The Company presented the results of the analysis to the Multi­
State Protocol ("MSP") Broad Review Workgroup on December 14, 2016, and to the
Commissioner Forum on January 25, 2017.
6. While stakeholders have reengaged m MSP discussions and are reviewing
alternatives, based on the discussions at the Commissioner Forum, it seems unlikely that the parties
will be able to reach consensus on a proposal to be presented to the commissions with adequate
time for approval before December 31, 2018, the currently scheduled expiration of the 2017
Protocol. Accordingly, Rocky Mountain Power respectfully requests that the Commission approve
the Company's request to extend the term of the 2017 Protocol for one additional year as
contemplated by the Parties to the 2017 Protocol Agreement, through December 31, 2019. This
will allow the Company and the parties sufficient time to continue to evaluate allocation
alternatives and reach agreement on a new interjurisdictional cost allocation methodology that
would replace the 2017 Protocol beginning January 1, 2020.
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MODIFIED PROCEDURE
7. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under Modified
Procedure, i.e., by written submissions rather than by hearing. RP 201 et. seq. If the Commission
determines a hearing is necessary in accordance with RP 121(d), the Company stands ready to
present the Application and direct testimony of a Company witness in support thereof.
CONCLUSION
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission: (1)
issue an order authorizing that this matter be processed by Modified Procedure; and (2) approve
this Application extending the terms of the 2017 Protocol through December 31, 2019, with a
decision from the Commission prior to March 31, 2017.
DATED this l51 day of February 2017.
Attorney for Rocky Mountain Power
Respectfully submitted,
ROCKY MOUNTAIN POWER
Daniel E. Solander
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Facsimile No. [phone]
E-mail: [e-mail]
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