20170301Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 5156
IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER F'OR APPROVAL OF THE 2Ol7INTER.
JURISDICTIONAL COST ALLOCATION
PROTOCOL
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Street Address for Express Mail
472W. WASHINGTON
BOISE, IDAHO 83702-59T8
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC.E-I7.01
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission comments as follows on PacifiCorp
dba Rocky Mountain Power's Application.
BACKGROUND
On February 1,2017, PacifiCorp dba Rocky Mountain Power applied to the Commission
for an Order that would extend the Company's2017 Inter-Jurisdictional Cost Allocation Protocol
(2017 Protocol) from December 31, 2018 through December 31, 2019. The Company has asked
that the case be processed by Modified Procedure, and that an Order issue by March 31,2017.
The Commission approved the2017 Protocol in October 2016. See Order No. 33623,
Case No. PAC-E-15-16. The Company and various stakeholders had negotiatedthe20lT
Protocol in an effon to equitably allocate PacifiCorpos costs to provide electric service to its
customers in the six states it serves, including Idaho. As approved, the 2017 Protocol has a
two-year term, and will be used to allocate PacifiCorp's costs from January 1,2017 through
December 31,2018.
STAFF COMMENTS FEBRUARY 28,20171
In its Application, the Company notes the 2017 Protocol was intended to be a short-term
allocation protocol that would allow the parties some time to study the potential affect of
changing energy policies before agreeing on a longer term allocation method. The Company
also notes, however, that although it continued to discuss the allocation issues with stakeholders
after the 2017 Protocol was approved, it is unlikely the parties will be able to agree on a new cost
allocation method to be presented and approved by the commissions before the 2017 Protocol
expires on December 31, 2018.
With this Application, the Company seeks to extend the term of the 2017 Protocol for
another year, through December 31, 2019, to afford the parties more time to explore allocation
issues and reach consensus on a new cost allocation method. The Company notes that the 2017
Protocol contemplates that it can be extended for another year, through December 3 1, 2019, if all
state commissions that approved it determine by March 31,2017, that it should be extended.
The Company thus asks the Commission to issue an Order by March 31,2017, that approves the
Application and extendsthe20lT Protocol through December 31,2019.
STAFF ANALYSIS
The Company conducted a year-long analysis of the practicality and cost impacts of an
alternative corporate structure. An initial strawman allocation option was also explored to
achieve similar results as corporate separation to recognize the increased autonomy state
Commissions and customers may want with generation resource decisions. The allocation
proposal would also allow economic dispatch to continue across the system with cost efficiencies
maintained. Both of these preliminary options were presented to the Multi-State Protocol (MSP)
Broad Review Group on December 14,2016, and the Commissioner Forum on January 25,20L7.
During both meetings, parties discussed the work required to fully evaluate an alternative cost
allocation method beyond 2018 and many parties expressed the concern that time was short
making the additional year necessary to complete this review.
Terri Carlock for the Commission Staff and Monsanto representatives participated in
both of the above meetings. Staff believes the extensive review required by parties and the time
for processing any filing will take additional time. The Commission in Order No. 33623
recognized this possibility when stating '0...\rye believe an extension of this Protocol through
2018 will likely be necessaty."
2STAFF COMMENTS FEBRUARY 28,2017
STAFF RECOMMENDATION
Staff recommends the one-year extension be approved making the2017 Protocol
effective through December 3 l, 2019.
Respecttully submitted this Z t /<day of Februuy 2017.
#( //?
Karl T. Klein
Deputy Attorney General
Technical Staff: Terri Carlock
i:umisc/comments/pacel7. lkllc comments
JSTAFF COMMENTS FEBRUARY 28,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF FEBRUARY 2017,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E.17.0I, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp. com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: Daniel. [e-mail]
SECRETAR
CERTIFICATE OF SERVICE