20190207Comments.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 14
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
DECREASE ELECTRIC SERVICE
SCHEDULE 191 - CUSTOMER EFFICIENCY
SERVICES RATE.
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CASE NO. PAC-E-18-12
COMMENTS OF THE
COMMISSION STAFF
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROUND
On November 9, 2018, PacifiCorp dba Rocky Mountain Power ("Rocky Mountain" or
"the Company") filed an Application seeking authorization to decrease the collection rate applied
to customer bills for energy efficiency measures from2.7Yo to 2.25Yo. The Company states that
as of September 30, 2018, the balance in its account for energy efficiency measures is over-
collected by $2.1 million.
On November 29,2018, the Commission issued a Notice of Application, set an
intervention deadline of December 19, 2018, and suspended the Company's proposed effective
date of January 1, 2019. Order No. 34198. No parties intervened. On January 7,2019,the
Commission Secretary issued a Notice of Parties. Staff informally conferred with the Company
regarding procedure and scheduling.
I FEBRUARY 7 ,2019STAFF COMMENTS
Previous Changes to Schedule No. 191
The Schedule No. 191 rate was established in 2006 at a rate of l.5Yo. In May 2008, the
rate was increased to 3.72Yo. In July 2010, the rate increased further to 4.72Yo. A few months
later in December 2010, the rate was decreased to 3.4oh, after the Company began phasing the
Idaho Irrigation Load Control program costs to a system allocation rather than direct assignment
to Idaho. Two years later, the rate was decreased again to 2.lYo. In March 2016, the rate was
increased to its current2.To/o. At that time, Staff felt the 2.7Yo rate would remain in place until at
least January 2018.1
STAFF ANALYSIS
Staff has reviewed the Application and supports the Company's request to decrease the
Schedule No. 191 Customer Efficiency Services Rate. Staff anticipates the new rate will align
revenue for DSM programs with the Company's program expenses.
The Company's Application demonstrates the currently authorized rate in Schedule
No. 191 would result in revenues of approximately $5.2 million in20l9. App.at Attachment A.
The Company's current forecast for DSM expenditures in 2019 is $4.9 million, before
decreasing slightly to $4.8 million in2020 and202l. App.at Attachment B. Attachment A
summarizes the actual monthly DSM expenditures and Schedule No. 191 revenue collection
through September 31,2018, with an over-collection balance owed to customers of $2.1 million.
Attachment B contains the same balancing account analysis as Attachment A, except the
Schedule No. 191 rate is decreased to 2.25Yo. The Company projects that, assuming
Commission approval of the 2.25% rate for Schedule No. 191 revenue, the balance in the
deferred account will be under-collected by approximately $ 189,5 16 as of December 31,2021.
App.at Attachment B.
The Company and Staff met in October 201 8 to discuss DSM programs and the over-
collection of the balancing account. Staff suggested a modest decrease, similar to the request in
the Application, rather than a larger decrease that would lower customers' rates initially, but
likely require an increase in rates before 2021.
' See Staff Comments in Case PAC-E-16-02.
2STAFF COMMENTS FEBRUARY 7 ,2019
Customer Impacts
Staff investigated the trend in previous changes to Schedule No. 191 , cost allocation
between schedules, and customer impacts from the proposed changes. The proposed decrease to
2.25% in Schedule 191 rates would lower costs by about $5 per year for a residential customer
using 800 kwh per month. The proposed decrease is the smallest percentage point change in
Schedule 191 rates since inception of the rates.
The Company's DSM expenditures have been below past projections. Current
projections show an increase in expenditures in 2019 to $4.9 million from $4.2 million in 2018,
before decreasing slightly to $4.8 million in2020 and202l. Staff continues to encourage the
Company to pursue all available cost-effective methods of DSM, even if costs exceed projected
expenses.
Allocation between Schedules
Staff reviewed Attachment C of the Company's Application, which showed the effects of
the proposed adjustment to the various schedules. Staff determined that the Company properly
applied the new rate to customer classes.
Staff notes that Special Contract Schedules No. 400 and No. 401 are exempt from
Schedule No. 191. Accordingly, these customers are not eligible to participate in the Company's
commercial and industrial DSM programs.
STAFF RECOMMENDATION
After examining the proposed increase to Schedule No. l9l, Staff recommends that the
Commission approve the Company's Application to decrease Schedule No. 191 Customer
Efficiency Services Rates to 2.25Yo effective March 1,2019.
aJSTAFF COMMENTS FEBRUARY 7,2019
1vRespectfully submitted this day ofFebruary 2019
Deputy General
Technical Staff: Brad Iverson-Long
Cassie Koerner
i:umisc/comments/pacel8. l2ejckbl comments
4STAFF COMMENTS FEBRUARY 7,20T9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7.h DAY OF FEBRUARY 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMMISSION STAFF, IN
CASE NO. PAC-E-18-I2, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
MICHAEL S SNOW
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi corp.com
michael. snow@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi com.com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
ARY
CERTIFICATE OF SERVICE