20170920Comments.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83120
BOISE, IDAHO 83720-0074
[phone]
BARNO. 10177
IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER TO INCREASE THE BPA REP CRE,DIT
EFFECTIVE OCTOBER 2OI7 THROUGH
SEPTEMBER 2019
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC.E-17.10
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Camille Christen, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 3 3 86 1 on August 29 , 2017 , in
Case No. PAC-E-I7-10, submits the following comments.
BACKGROUND
On August 78,2017, PacifiCorp dba Rocky Mountain Power applied to the Commission
for authorization to increase the Bonneville Power Administration (BPA) residential and small
farm energy credit rate. Application at 1. The Company indicates that this rate represents an
increase in the annual credit of $648,000 to qualiffing customers (that is, those customers will
receive an additional decrease in their rates). Id. at3-4. The Company requests that the new rate
be effective October 1,2017 through September 30,2019, and requests that the Application be
processed under Modified Procedure. Id. at 5.
STAFF COMMENTS SEPTEMBER20,2OIT1
ilf;CIIVED
ll.ril r.l"i' II Pi"l ?: 0E
The Application includes attachments that provide supporting documentation, including a
summary of the impact on retail revenues (Attachment 1), a summary of the calculation of the
proposed credit rate (Attachment2), a summary of the allocation of PacifiCorp's BPA
Residential Exchange Program benefits between the states in which PacifiCorp operates
(Attachment 3), and clean and legislative copies of the tariff schedule for the credit rate,
Schedule 34 (Attachment 4). Id. The Application summarizes the REP and a description of the
customers eligible to receive benefits. Id. at2-3.
STAFF ANALYSIS
The residential and small farm energy credit rate results from an agreement between the
Company and BPA regarding the Residential Exchange Program (REP). Under the REP, BPA
provides a share of the benefits of the federal Columbia River power system to the residential
and small farm customers served by six investor-owned utilities of the Pacific Northwest,
including Rocky Mountain Power. This benefit is calculated every two years and is
implemented via a credit on qualifying customers' bills.
The Company's current residential and small farm credit rate is $0.007762 per kilowatt-
hours (kwh). The proposed credit rate is $0.008403 per kWh.
The proposed credit rate includes annual REP benefits from BPA of $6.7 million plus an
additional undistributed balance in the Company's Idaho residential exchange balancing account
of $1.8 million annually. Thus, the total annual credit to customers is $8.5 million, a credit
increase of $648,000 over the current credit. The Company's residential customers consume
approximately 800 kilowatt-hours per month, on average. The current monthly summer
residential bill for a residential customer using 800 kilowatt-hours is $97.09. The proposed rate
change results in a bill of $96.58 - a decrease of $0.51 (0.53%) - in the summer monthly bill
for this customer. The current monthly winter residential bill for a residential customer using
800 kilowatt-hours is $72.22. The proposed rate change results in a bill of $71 .71 - a decrease
of $0.51 (0.71%) - in the winter monthly bill for this customer.
The calculation of the residential and small farm credit rate starts with the benefit amount
determined by BPA - in this case, $9.1 million per year. This benefit is reduced by the
"look-back" adjustment that nets the excess benefits the Company received in2002 to 2008. In
this case, the look-back adjustment is $2.4 million. The net result is a credit for qualifying
STAFF COMMENTS SEPTEMBER20,2OIT2
customers of $6.7 million. Since both of these figures are provided on a system wide basis the
Company allocates this amount to each state based on the average kWh sales by that state's
approved customers.
To this net credit of $6.7 million, the Company adds any undistributed balance from the
REP balancing account - in this case, $1.8 million per year. Thus, the total annual credit to
qualifying customers is $6.7 million plus $ 1.8 million, or $8.5 million.
The Company calculates the proposed residential and small farm credit rate of $0.008403
by dividing the total annual credit of $8.5 million by the calendar year 2016 historical usage
level of qualifying customers of 1 .01 GWh.
Staff has audited the initial inputs and independently recalculated the rate. Staff believes
that the Company correctly calculated the rate of $0.008403 per kWh and recommends this rate
be approved.
CUSTOMER NOTICE AND PRESS RELEASE
Rocky Mountain Power filed its Application on August 1 8, 201 7 . The Company filed its
press release and customer notice with the Commission on September 12,2017. Staff reviewed
both documents and determined that they do not comply with Rule 125 of the Commission's
Rules of Procedure. IDAPA 3 I .0 I .0 1 . 1 25. Rule s 125 .04 and 125 .05 require the press release
and customer notice to be filed with the Company's Application. The customer notice and press
release also do not give the overall dollar amount of the proposed decrease as required by Rule
125.01 .b.
The notice was included with customer bills beginning September 6 and ending
September 27. Some customers will not have a reasonable opportunity to file comments on or
before the Commission's comment deadline of September 20,2017 . Because this year's BPA
credit increase results in a reduction to customer rates, it is less likely that customers will object
to the proposed rate changes. However, customers may want to file comments and have them
considered. Therefore, Staff recommends that the Commission accept late filed comments in
this case.
CUSTOMER COMMENTS
As of September 20,2017,the Commission has received no comments from customers.
JSTAFF COMMENTS SEPTEMBER20,2OIT
STAFF RECOMMENDATION
Staff recommends that the Commission approve the new residential and farm energy rate
Schedule 34, with a credit rate of $0,008403 per kWh effective October 1,2017. Staff also
recommends that the Commission accept late filed comments in this case.
Respectfully submitte d this 2 6 }L day of September 2017 .
*( 1/L
Camille Christen
Deputy Attorney General
Technical Staff: Joseph Terry
Bentley Erdwurm
Daniel Klein
i:umisc/comments/pace I 7. I 0ccjtbedk comments
4STAFF COMMENTS SEPTEMBER20,2OIl
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF SEPTEMBER 2077,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-I7-10, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi corp.com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL : Daniel.solander@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp.com
CERTIFICATE OF SERVICE