20170705Larsen Direct.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )CASE NO.PAC-E-17-06OFROCKYMOUNTAINPOWERFOR)BINDING RATEMAKING TREATMENT )DIRECT TESTIMONY OFFORWINDREPOWERING)JEFFREY K.LARSEN
ROCKY MOUNTAIN POWER
CASE NO.PAC-E-17-06
June 2017
l INTRODUCTION AND SUMMARY
2 Q.Please state your name,business address,and current position with PacifiCorp
3 d/bla Rocky Mountain Power ("Company").
4 A.My name is Jeffrey K.Larsen,and my business address is 1407 West North Temple,
5 Suite 310,Salt Lake City,Utah 84116.I am currentlyemployed as Vice President of
6 Regulation for Rocky Mountain Power.
7 Q.Please describe your education and professional background.
8 A.I received a Master of Business Administration degree from Utah State University in
9 1994,and a Bachelor of Science degree in Accounting from Brigham Young University
10 in 1985.I have also participated in the Company's Business Leadership Program
11 throughthe Wharton School,and an Advanced Education Program through the J.L.
12 Kellogg School of Management at Northwestern University.In addition to formal
13 education,I have also attended various educational,professional and electric industry-
14 related seminars and training programs during my career at the Company.I joined the
15 Company in 1985,and I have held various accounting,compliance,regulatory,and
16 management-relatedpositions prior to my current position.
17 Q.Have you provided testimony in previous regulatory proceedings?
18 A.Yes.I have filed testimony on various matters in the states of Utah,Idaho,Wyoming,
19 California,Washington,Oregon,and Nevada.
20 Q.What is the purpose of your testimony?
21 A.I explain the Company's requested ratemaking treatment for the wind repowering
22 project for which the Company is seeking approval in this Application.Specifically,
O 23 I describe and support the proposed accounting treatment for the replaced assets,and
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1 the matching of the costs and benefits of the wind repowering project through the
2 Energy Cost Adjustment Mechanism ("ECAM").
3 Q.Please summarize the proposed ratemakingtreatment for wind repowering.
4 A.The Company is seeking approval of binding ratemaking treatment for wind
5 repowering to allow the Company to act on the time-constrained economic opportunity
6 to upgrade most of its wind facilities and requalify for federal production tax credits
7 ("PTCs").Wind repowering will provide customers additional cost-effective
8 generation and tax benefits resulting from renewed PTC eligibility,and extend the life
9 of the repowered wind facilities by at least an additional 10 years.
10 The proposed ratemaking treatment,known as the Resource Tracking
11 Mechanism ("RTM"),is designed to capture customer benefits resulting from wind
12 repowering and match those benefits with the costs of repowering.The RTM would
13 operate until the costs and benefits of repowering are fully included in base rates
14 througha general rate case.The RTM would be included as a component of the ECAM.
15 The Company is proposing to cap the RTM until the next general rate case so that,after
16 taking into account the wind repowering benefits that will flow throughthe Company's
17 ECAM,it will not operate to surcharge customers.Once the full costs and benefits are
18 included in base rates,only the incremental fluctuations associated with production
19 levels of energy and PTCs would continue to be tracked in the ECAM,as they are
20 today,since these are entirely dependent on the variable output of the facilities.The
21 Company would begin deferring the costs and benefits associated with wind
22 repowering for each repowered wind facility in the month they go into service.
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l Q.Please summarize the accounting treatment that will be applied to the wind
2 equipment replaced by repowering.
3 A.The Company proposes to record the remaining book balances of replaced wind
4 equipment in the accumulated depreciation reserve ("ADR"),and continue to recover
5 these costs in rates.
6 Q.As the repowered wind facilities come into service,what are the annual,estimated
7 deferral balances that would flow throughthe RTM?
8 A.As described more fully later in my testimony and exhibits,the Company is projecting
9 estimated,annual revenue requirement benefits in Idaho of up to $1.5 million by 2022,
10 as summarized in Figure 1.The Company will capture the impacts of wind repowering
11 throughthe RTM until they are included in base rates.
Figure 1
RepoweringEstimated Revenue RequirementCost (Benefit)
$thousands
2019 2020 2021 2022
Total Company Revenue
1 -$5,897 $6,752 -$9,052 -$24,883Reauirement
2 Idaho Allocated -$355 $390 -$563 -$1,514
3 Idaho ECAM -$1,714 -$7,217 -$8,692 -$8,934
4 Idaho Deferral $1,360 $7,217 $8,129 $7,420
5 Net Customer Benefit -$355 $0 -$563 -$1,514
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1 Q.How do the revenue requirement benefits in Figure 1 relate to Company witness
2 Mr.Rick T.Link's analysis of revenue requirement savings from wind
3 repowering?
4 A.Mr.Link conducted a revenue requirement differential analysis,while my analysis is a
5 revenue requirement calculation based on his information.
6 Q.Is the bindingratemakingtreatment proposed in this Applicationfor approvalof
7 wind repowering projectthe same as proposed in the Company's concurrently
8 filed application for approval of the new wind resources and associated
9 transmission?
10 A.Yes.The Company proposes to use the RTM as a component of the ECAM for both
11 wind repowering and the new wind and transmission resources discussed in the
12 concurrently filed application.The Company proposes slight differences in the
13 treatment of the deferral balances,applying the surcharge cap to wind repowering only.
14 BINDING RATEMAKING AUTHORITY
15 Q.Does the Idaho Public Utilities Commission have binding ratemakingauthority?
16 A.Yes.Idaho Code §§61-541(2)provides that a public utility that proposes to construct,
17 purchase,or make major additions to an electric generation facility or transmission
18 facility:
19 May file an application with the commission for an order specifying in
20 advance the ratemaking treatments that shall apply when the costs of the
21 proposed facility are included in the public utility's revenue
22 requirements for ratemaking purposes.
23 The "requested ratemaking treatments may include nontraditional ratemaking
24 treatments or nontraditional cost recovery mechanisms."The Company's request for
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1 binding ratemaking treatment fairly and reasonably balances the interests of customers
2 and satisfies each of the five requirements as discussed in the Application.
3 Moreover,the Company's proposed ratemaking treatment ensures that rates
4 reflect both the costs and the benefits of the wind repowering project and is consistent
5 with established Commission precedent.Binding ratemaking treatment is warranted
6 because of the magnitude of the proposed investment and the customer benefits
7 resulting from the wind repowering project.
8 Q.Why is the Company seeking approvalof binding ratemakingtreatment for the
9 wind repowering project?
10 A.Wind repowering itself is an innovative and non-traditional project intended to take
11 advantage of the time-constrained opportunity to requalify for 100 percent PTC
12 benefits for customers.Wind repowering will provide additional low-cost energy for
13 customers by improving the efÏiciencyof wind turbine generators and extending their
14 useful life for at least an additional 10 years,as explained in the testimony of Company
15 witness Mr.TimothyJ.Hemstreet.The Company's request for approval under to Idaho
16 Code §§61-541(2)provides interested parties and the Commission the opportunityto
17 meaningfullyreview,before construction,whether the wind repowering project and
18 expenditures are reasonable,prudent,and in the public interest.The Company's
19 proposed RTM is a nontraditional approach that will properly match the timing of the
20 benefits and costs of this unique and time-constrained opportunity.Because wind
21 repowering is in the public interest,binding ratemaking treatment is appropriate and
22 reasonable.
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1 RESOURCE TRACKING MECHANISM
2 Q.Why are you requestingapprovalof the RTM?
3 A.The RTM is a nontraditional mechanism that advances the public interest by fairly
4 balancing the interests of customers and shareholders regarding the ratemaking impacts
5 of wind repowering.As the other Company witnesses discuss,wind repowering
6 provides a net benefit to customers through incremental,zero-fuel-cost wind generation
7 and additional PTCs,both of which offset the near-term costs.Without the RTM,a
8 portion (90 percent)of the incremental generation from wind repowering would
9 automatically flow through the ECAM,while 10 percent of these benefits and the costs
10 associated with the investments would not be captured in rates and would flow to
11 shareholders;100 percent of the PTCs would flow through the ECAM to customers.
12 The RTM seeks to align the costs and benefits so that customers receive the full net
13 benefits from the repowering project while shareholders receive appropriate cost
14 recovery of the prudent investment.On an annual basis until the next general rate case,
15 if the RTM results in a deferral of costs to customers,the deferral will not be greater
16 than the benefits customers receive from the wind repowering,as shown in Figure 1.
17 Q.Please describe the mechanics of the RTM in conjunction with the ECAM.
18 A.The ECAM tracks the actual energy and PTCs produced from the existing wind projects
19 compared to the amount included in base rates.Any variances of energy production
20 impacts Net Power Costs ("NPC")and PTCs.The incremental changes in NPC are
21 shared 90 percent by customers and 10 percent by Company shareholders,and PTCs
22 are tracked dollar-for-dollar with no shareholder sharing.The RTM would become a
O 23 component of the ECAM to isolate the incremental energy generated from the
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l repowered wind facilities and pass that NPC value back to customers,along with the
2 associated costs incurred by the Company to provide these benefits.Absent the RTM,
3 the ECAM would automatically pass throughall new PTCs and 90 percent of the value
4 of the incremental energy to customers,while Company shareholders would bear all
5 the costs until the next general rate case.
6 To fully match the costs with the benefits of the wind repowering project and
7 pass these net benefits entirely to customers,the Company proposes implementing the
8 RTM as a component of the ECAM.Upon completion of repowering at each wind
9 facility,the Company will begin monthlydeferrals of the associated costs and benefits
10 in the ECAM balancing account,which operates on a calendar-yearbasis.On April 1
11 each year,the Company will file the ECAM deferral balance from the prior calendar
12 year,to be included in rates beginning June 1,consistent with the current ECAM
13 schedule.RTM review would continue on the same schedule as a component of the
14 ECAM each year until the costs and benefits are fully included in base rates as part of
15 a general rate case.After a rate case,only the incremental NPC and PTC associated
16 with the variabilityof wind energy production will continue to be tracked in the ECAM,
17 as is done today.
18 Q.Why is it importantto incorporate the RTM in the ECAM?
19 A.Incorporating the RTM in the ECAM helps match the increased production benefits of
20 the repowered wind facilities,which will automatically flow,in part,through the
21 ECAM,with the costs of repowering.As wind facilities are completed and placed into
22 service,the RTM will calculate the monthly revenue requirement associated with
23 repowering and defer it with the incremental benefits,matching costs with benefits.
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l Also,by incorporating the RTM as a component of the ECAM,there is only one tariff
2 and a single line item on customer bills.
3 Q.What costs and revenues will be incorporated in the RTM?
4 A.The deferral for each of the repowered wind facilities will include the following
5 revenue requirement components:
6 Plant revenue requirement,consisting of:
7 Capital investment,
8 ADR
9 Accumulated Deferred Income Tax ("ADIT")
10 Operations and Maintenance Expense ("O&M")
11 Depreciation expense
12 Property taxes
13 Wyoming Wind Tax
14 NPC savings
15 PTCs
16 These items are summarized in Exhibit No.11.The Company will calculate the RTM
17 deferral as the difference between the value included in base rates for these items and
18 the new value taking into account the costs and benefits of repoweredwind facilities as
19 they are placed into service.
20 REVENUE REQUIREMENTCOMPONENTS OF RTM
21 Q.Please describe how the RTM will track rate base components,which include the
22 capital investment,ADR and ADIT.
O 23 A.After a repoweredwind resource is placed into service,the Company will defer the full
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1 amount of the capital investment,ADR and ADIT related to repowering in the RTM.
2 Once the Company has included some or all of the repowered wind resources in base
3 rates through a future general rate case,the amount in rates will become the "wind
4 base"plant balance that in the subsequent annual RTM filings would be subtracted
5 from the capital investment.The Company will use the net plant balance described
6 above to calculate a return on investment using the most recent Commission-approved
7 cost of capital and income tax rate.
8 Q.Please describe how the RTM will track depreciation expense.
9 A.The Company will include depreciation expense in the RTM deferral as the actual
10 monthlyplant-in-service balances associated with wind repowering,less the repowered
11 wind base plant in service balance,multipliedby the current depreciation rates.Until a
12 general rate case is filed,no wind base plant or depreciation expense associated with
13 the repowered wind resources is reflected in base rates,so the full amount would be
14 included in the RTM.
15 Q.Please describe how actual depreciation expense will be calculated.
16 A.The current depreciation rates will be applied to the gross electric plant-in-service
17 ("EPIS")balance,associated with wind repowering,to calculate the depreciation
18 expense.As existing equipment is replaced by repowering,the Company will transfer
19 the replaced assets from gross EPIS to the ADR,therebyreducing depreciation expense
20 on the existing investment until the next depreciation study,at which time the net plant
21 balance for wind resources will be reviewed and new depreciation rates set to recover
22 both the new and remaining replaced investment.Because the new repowering
23 investment is projected to be less than the replaced existing investment,the initial
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l depreciation expense after wind repowering will temporarily decrease until the
2 Company implements new depreciation rates from its next depreciation study.The
3 RTM deferral will reflect this decrease in depreciation expense.I provide more details
4 on the proposed ratemaking treatment for replaced equipment later in my testimony.
5 Q.Please estimate the amount of the temporary decrease in depreciation expense.
6 A.As of December 31,2016,the Company had approximately $2.0 billion gross
7 investment in wind with approximately $67 million of annual depreciation expense.
8 Approximately$1.2 billion of gross electric plant-in-service will be replaced as part of
9 the wind repowering project and transferred to the ADR.Wind repowering will cost
10 approximately $1.1 billion,so gross plant will decrease from $2.0 billion to $1.9
11 billion,thereby reducing annual depreciation expense from approximately $67 million
12 to approximately $64 million based on the current depreciation rates.
13 Q.What will happen to depreciation expense after the initial implementationof the
14 wind repoweringproject?
15 A.The reduction to depreciation expense will continue until the rates from the next
16 depreciation study are approvedby the Idaho Public Utilities Commission and included
17 in base rates.The depreciable lives and depreciation rates of all assets,including the
18 Company's wind assets,will be reviewed as part of the next depreciation study
19 anticipated to be filed with this Commission in the fall of 2018.As part of the
20 depreciation study,the depreciationrates will be revised to recover the remaining wind
21 plant balances,including the debit balance in the ADR,over the life of the assets.
22 Q.How will the RTM reflect incremental O&M expense?
O 23 A.As repowered wind resources are placed into service,the Company will compare the
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1 actual O&M expense for each wind resource to the 2014-2017 historical four-year
2 average of O&M expense by wind resource.The difference will be included in the RTM
3 deferral.
4 Q.Why did the Companyselect a four-year average of calendar years 2014 -2017?
5 A.A pre-repowering four-year historical average helps to smooth variations in O&M
6 expense that can occur year-to-year.Also,because repowering may impact facilities
7 during 2018 and 2019,these years should be excluded for an accurate reflection of the
8 average wind O&M before wind repowering.
9 Q.How will the RTM reflect property taxes?
10 A.The Company will calculate property taxes associated with the repowered wind
11 resources by taking the monthly average of the capital investment less ADR included
12 in the RTM deferral multiplied by the average property tax rate from the Company s
13 last general rate case.
14 Q.How will the RTM reflect Wyoming wind taxes?
15 A.The Company will calculate the Wyoming wind tax by taking the incremental
16 generation associated with wind repowering multipliedby the Wyoming wind tax rate.
17 NPC AND PTC BENEFITS IN THE RTM
18 Q.Please explainthe calculation of the incremental NPC benefits in the RTM.
19 A.Wind repowering will result in additional zero-fuel-cost energy,reducing total NPC.
20 Under the sharing bands of the ECAM,90 percent of the incremental NPC benefits of
21 wind repowering will be credited to customers,with 10 percent assigned to the
22 Company.Under the RTM,the Company is proposing to pass 100 percent of the NPC
O 23 benefits of repowering back to customers through a credit equal to the amount of the
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1 NPC benefits that would otherwise be absorbed by the sharing band,or 10 percent.
2 The Company will calculate the incremental NPC benefit in the RTM as the
3 increased generation achieved by repowering,applied to the total wind generation to
4 derive the incremental energy on a per-plant basis.The Company will then value the
5 incremental energy using a monthlymarket price less wind integration costs,and the
6 RTM will pass 10 percent of that value through to customers.The calculation is
7 described in Exhibit No.14.
8 The RTM will continue to credit the full incremental NPC benefits associated
9 with wind repowering until the repowered facilities are included in base rates.
10 Q.What market price will the Companyuse to value the incremental energy?
11 A.The market price used in the calculation will be dependent on the physical location of
12 the wind resource and the time of the generation.If the wind resource is located on the
13 west side of the Company's system,the monthly Mid-Columbia heavy load hour
14 ("HLH")and light load hour ("LLH")market price will be used.If the wind resource
15 is located on the east side of the Company's system,the monthlyFour Corners HLH
16 and LLH market price will be used.Additionally,the market price will be reduced by
17 the wind integration costs from the most recent integration study,which currently
18 would be from the Company's 2017 IRP.
19 Q.Please explain the calculation of the PTCs.
20 A.Currently,the IRS rate for PTCs is $24 per megawatt-hour,and PTCs are generally
21 applicable for a period of 10 years after a wind resource is operational.The PTC rate
22 is applied to the actual megawatt-hours of generation from the eligible wind turbines.
23 This produces a tax credit that can be used to offset the Company's income tax expense
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1 under IRS guidelines.To derive the revenue requirement value of the tax credit,the
2 pre-tax value must be grossed-up by the Company's tax gross-up rate.The Company
3 will use the tax gross-up rate from its most recent general rate case to calculate the
4 value of the PTCs from wind repowering.In Idaho the PTC's are included in the ECAM
5 per the stipulation in Docket PAC-E-15-09 and are not included in the RTM deferral.
6 Q.Do the base rates that are currentlyin place include PTCs for the existingwind
7 facilities?
8 A.Yes.These facilities qualified for PTCs when they initially began commercial
9 operation.A value based on the generationfrom these projects during the test period is
10 currently included in base rates and tracked in the ECAM.The Company is not
11 proposing to stop tracking the PTC variance between base rates and actual PTCs in the
12 ECAM,or to change the amount included in base rates.
13 Q.How will the Companytreat wind repoweringcosts incurred before the in-service
14 dates of the repowered facilities?
15 A.As described in the testimony and exhibits of Mr.Hemstreet and Mr.Link,the
16 Company will incur minor repowering costs before the in-service dates of the
17 repowered wind facilities.These costs were included in the Company's financial
18 analysis.Most of the costs are due to reduced generation from the facilities before and
19 during repowering,and the associated loss of PTCs.These costs will be included in the
20 ECAM,and will be shared between the Company and customers using the existing
21 90/10 sharing bands.Because these costs are part of the overall project,which will
22 benefit customers,it is appropriate that customers pay a portion of them.
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1 RTM CALCULATION AND STRUCTURE
2 Q.Have you prepared an exhibit that illustrates the calculation and structure of the
3 RTM on a year-by-year basis?
4 A.Yes.Exhibit No.12 provides an illustrative example of the calculation of the RTM on
5 an annual basis.The annual amounts will be the sum of the monthlyamounts shown in
6 Exhibit No.13,and the individual lines are described as part of that exhibit.
7 Q.Please explain Exhibit No.13.
8 A.Exhibit No.13 is an example of the RTM's monthly calculation.The RTM will be
9 adjusted after a general rate case to exclude amounts that are recovered as part of base
10 rates in the rate case to assure against double-recovery.For items partiallyrecovered in
11 base rates,such as capital investments included for part of the test period,the portion
12 included in the test period will be removed as of the effective date of the general rate
13 case.Page 5 of Exhibit No.13 includes an overview of the total plant revenue
14 requirement,net power cost,and PTC sections.
15 Once per year on a calendar-year basis,the Company will sum the monthly
16 RTM revenue requiremententries to prepare the annual RTM adjustment to be included
17 in the Idaho ECAM application for filing with the Commission on April 1,with a rate
18 effective date of June 1.
19 Q.How will the costs and benefits associated with the wind repowering projectbe
20 allocated to Idaho customers?
21 A.The Company will use Idaho's applicable inter-jurisdictionalallocation factors to
22 allocate total-company revenue requirement to Idaho based on the current
23 Commission-approved allocation methodology.The Company proposes that the
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l allocation factors used in the RTM match the allocation factors used in the calculation
2 of the ECAM.
3 Q.How will the Company calculate rates to credit or recover RTM balances?
4 A.The Company proposes to use the same class allocation and rate design as used for the
5 annual ECAM filing.
6 ACCOUNTING TREATMENT FOR REPLACED EQUIPMENT
7 Q.Please explain the Company's proposed accounting treatment for equipment
8 replaced by wind repowering.
9 A.As existing wind generation equipment is replaced during the repowering process,the
10 Company will follow accounting treatment consistent with FERC regulations and
11 allowed by generally accepted accounting principles.The original investment will be
12 transferred from FERC account 101,EPIS,to Account 108,ADR,by crediting EPIS
13 and debiting the ADR.This entry will not change the Company's net plant balance,but
14 it will shift the ADR from a negative to a positive balance.The remaining original
15 investment plus new capital additions will be depreciated using current depreciation
16 rates until the Company's next depreciation study.
17 Q.Is the Company requestingcontinued cost recovery of plant balances associated
18 with equipment replaced in the wind repowering project?
19 A.Yes.The existing net plant is currently in rates and should remain in rates.The
20 Company's decision to pursue the wind repowering project is dependent on the
21 Company continuing to recover its current investment in its wind facilities.The
22 equipment replacement does not change the net book balance of the existing assets
23 pre-repowering,and the incremental investment to repower these wind facilities will
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l be recovered through the RTM as a component of the ECAM until the costs are
2 captured through the general rate case process.
3 Q.How would the Companytreat any salvage value of the replaced equipment?
4 A.The Company would treat the salvage value of the equipment under the same
5 accounting guidelines.To the extent that any salvage value is obtained from the
6 equipment,then the valuewould be credited to the ADR,reducing the net plant balance.
7 INTER-JURISDICTIONAL COST ALLOCATION
8 Q.How will the Companyallocate the investment in the wind repowering project to
9 the state jurisdictionsPacifiCorp serves?
10 A.Currently,the Company's investment in wind generation resources is treated as a
11 system resource under the approved 2017 Protocol Allocation Agreement.That
12 approved methodology will continue for ratemaking purposes through2019.The same
13 treatment will apply to new investments that occur in that period.After that time period,
14 the then-applicable allocation methodology approved by the Commission would
15 govern.
16 The Company's analysis demonstrates that the wind repowering project
17 delivers system benefits,and the Company believes that the repowered wind facilities
18 should continue to be allocated across the six-state service territory on a system basis
19 unless there is an agreement through the Multi-State Process to do otherwise.
20 CONCLUSION
21 Q.Please summarize your testimony.
22 A.The wind repowering project presents an excellent opportunity to provide customers
O 23 with additional zero-fuel-cost wind energy for an extended period of time.To match
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1 investment and operational costs with the benefits of the repowered wind facilities until
2 the costs and benefits are fully included in base rates through a general rate case,the
3 Company proposes to implement the RTM as a component of the existing ECAM.The
4 matching of the costs and benefits through the RTM is fair to customers and
5 shareholders,and is consistent with the Commission's authority to allow binding
6 ratemaking treatment for non-traditional cost recovery mechanisms.The RTM would
7 become a component of the ECAM until the costs and benefits are fully included in
8 base rates through a general rate case,at which point the ECAM would continue to
9 track variances in NPC and PTC.
10 Additionally,allowingthe Company to assign replaced equipment to the ADR
11 from plant-in-service and continue rate recovery of the plant balances over the useful
12 life of the repowered wind investment life is just and reasonable and allows the
13 Company to pursue the wind repowering project.
14 Q.What is your recommendation to the Commission?
15 A.I recommend that the Commission approve the wind repowering project and the
16 Company's proposals for the ratemaking treatment of the wind repowering project,and
17 for the continued recovery of the replaced equipment.Approval will provide certainty
18 to the Company and enable it to move forward with the wind repowering project.
19 Q.Does this conclude your direct testimony?
20 A.Yes.
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