20190913Comments.pdf

DA\T{ HARDIE,
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO MAINTAIN
ITS CURRENT BPA RESIDENTIAL
EXCHANGE PROGRAM CREDIT FROM
OCTOBER 1,2019 THROUGH
SEPTEMBER 30, 2021.
REC EIVED
2019 SEP l3 Pl,l l: 52
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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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CASE NO. PAC-E-19-10
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Dayn Hardie, Deputy Attorney General, submits the following comments.
BACKGROUND
On August 13,2019, PacifiCorp dba Rocky Mountain Power ("Rocky Mountain" or
"Company") applied to the Commission for an order approving no change to the Company's
current Electric Service Schedule 34-Pacific Northwest Electric Power Planning and
Conservation Act Residential and Farm Kilowatt-Hour Credit ("Schedule 34"). Under the
Company's proposal, Schedule 34 customers would continue to receive a Bonneville Power
Administration ("BPA") Residential Exchange Program ("REP") credit of $0.008403 per
Kilowatt-Hour ("kWh"). The Company requested its Application be processed by Modified
Procedure, and proposed an effective date of October 1,2019. The proposed credit would
continue through September 30,2021, a period of 24 months.
1STAFF COMMENTS SEPTEMBER I3,2019
The Company states that it will receive a smaller allocation of REP benefits for the
upcoming 2019-21 period, and that it calculated an associated REP credit of $0.008156 per kwh,
slightly lower than the current credit of $0.008403 per kWh. The Company states that changing
the credit would only have small impact on customers. Rocky Mountain Power customers would
receive a slightly lower credit, which would result in slightly higher bills. If the lower credit
were applied, aggregate bills would increase by approximately $248,000 annually. Because of
the relatively small impact on customers, the Company has proposed no change to the credit.
The Company has provided Attachments to the Application pertaining to the calculation of the
lower credit it has opted not to propose.
The REP credit results from an agreement between the Company and BPA regarding the
Residential Exchange Program. Under the program, 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.
STAFF ANALYSIS
Staff recommends that the Commission approve the Company's proposal that the
Residential Exchange Program credit of $0.008403 per kwh, the current level of the Schedule 34
credit, remain unchanged during the 24-month period following the October 1,2019 effective
date. The current rate level was established by Order No. 33896 dated September 29,2017.
Staff agrees that customers pay slightly lower bills if the credit is maintained at the current level.
Staff understands that the Company is not giving up its right to recover the approximately
$248,000, which may be added to the balancing account for future recovery.
Based on the difference between the proposed current and recalculated credits $0.000247
per kWh ($0.008403 minus $0.008156), atypical residential customer using 800 kwh per month
will save approximat ely 20 cents per month if the credit is maintained. Staff has reviewed the
inputs to the rate calculations presented in the Application and attached workpapers and
confirmed the results. Staff believes that the Company correctly calculated the rate credits
presented in the Application.
2STAFF COMMENTS SEPTEMBER 13,20I9
The Company proposes to distribute $8.2 million in REP payments annually to its
Schedule 34 customers, from October 1,2019 through September 30,2021. This proposed rate
credit includes $7.8 million in annual REP benefits plus a $1.6 million undistributed balance in
the Company's Idaho REP balancing account, reduced by a look-back payment of $1.2 million.
According to the Company's rate design, using 1.0 Gigawatt-Hour as the historical usage
level of Schedule 34 customers with the proposed distribution of $8.2 million, the REP rate
credit would be the aforementioned $0.008156 per kwh.
CUSTOMER NOTICE, PRESS RELEASE AND PUBLIC COMMENTS
No notice is required because the Company is not proposing a change in the REP credit.
As of September II,2019, the Commission has received no comments from customers.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's proposal that the
Residential Exchange Program credit of $0.008403 per kwh, the current level of the Schedule 34
credit, remain unchanged during the 24-month period commencing at the October 1,2019
effective date.
\?+\Respectfully submitted this day of September 2019.
Deputy Attorney General
Technical Staff: Bentley Erdwurm
Jolene Bossard
Kathy Stockton
i :umisc/comments/pace l 9. I Odhbeklsjb comments
nJSTAFF COMMENTS SEPTEMBER 13,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF SEPTEMBER 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-Ig-IO, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWNG:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pacifi corp. com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL : daniel. [e-mail]
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CERTIFICATE OF SERVICE