20200403Application.pdf

1407 West North Temple, Suite 330
Salt Lake City, Utah 84116

April 3, 2020

VIA ELECTRONIC DELIVERY

Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
11331 W Chinden Blvd.
Building 8 Suite 201A
Boise, ID 83714

Re: CASE NO. PAC-E-20-04
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
FOR A DEFERRED ACCOUNTING ORDER REGARDING COSTS INCURRED
DUE TO THE COVID-19 PUBLIC HEALTH EMERGENCY

Dear Ms. Hanian:

Please find attached Rocky Mountain Power’s electronic filing of this Application in the above
referenced matter. An original and seven (7) copies of the Application will be provide at a later
time.

Informal inquiries may be directed to Ted Weston, Idaho Regulatory Manager at (801) 220-
2963.

Very truly yours,

Joelle Steward
Vice President, Regulation

Enclosures

CC: Terri Carlock
RECEIVED
2020 April 3,PM2:28
IDAHO PUBLIC
UTILITIES COMMISSION
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Adam Lowney (ISB#10456)
McDowell Rackner Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

BEFORE THE IDAHO PUBLIC SERVICE COMMISSION

IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR A
DEFERRED ACCOUNTING ORDER
REGARDING COSTS INCURRED
DUE TO THE COVID-19 PUBLIC
HEALTH EMERGENCY
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CASE NO. PAC-E-20-04

APPLICATION FOR ACCOUNTING
ORDER
_____________________________________________________________________________

Pursuant to I.C. § 61-524 and IDAPA 31.01.01.052, Rocky Mountain Power, a division
of PacifiCorp, (“Rocky Mountain Power” or the “Company”), applies to the Idaho Public
Utilities Commission (“Commission”) for an accounting order authorizing the Company to
record a regulatory asset associated with costs incurred as part of the Company’s response to the
COVID-19 public health emergency.
In support of this Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power is a public utility in the state of Idaho and is subject to the
jurisdiction of the Commission with regard to its rates and service. Rocky Mountain Power also
provides retail electric service in the states of Utah and Wyoming.
2. Communications regarding this Application should be addressed to:

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By e-mail (preferred): [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

By mail: Data Request Response Center
Rocky Mountain Power
825 NE Multnomah St., Suite 2000
Portland, OR 97232

Ted Weston
Rocky Mountain Power
1407 W. North Temple, Suite 330
Salt Lake City, UT 84116
Telephone: [phone]
Facsimile: [phone]

3. In response to the COVID-19 public health emergency,1 Rocky Mountain Power
has suspended disconnections of service for non-payment on all non-managed accounts, is waiving
late fees for the same upon customer request, and has also suspended reconnection fees for non-
managed accounts. These actions are intended to assist customers facing extraordinary economic
pressures as a result of the pandemic, and to support Idaho’s ongoing efforts to limit and slow the
spread of the disease. Additional Company responses may eventually be needed as the emergency
continues.
4. Rocky Mountain Power seeks authorization from the Commission to defer, for
future amortization, certain costs incurred related to the Company’s response to the COVID-19
public health emergency. The Company anticipates that it will incur significant costs in responding
to the emergency. While the situation continues to evolve, currently the Company anticipates an
increase in bad debt expense resulting from higher levels of write-offs for uncollectible accounts

1 On March 13, 2020, Idaho Governor Brad Little declared a state of emergency under I.C. § 46-1008 in response to
the novel coronavirus (or “COVID-19”) pandemic, see, Emergency Declaration (available at,
https://gov.idaho.gov/wp‐content/uploads/sites/74/2020/03/covid‐19‐declaration.pdf).
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associated with the suspension of disconnection and waiver of late fees. The Company anticipates
that it may also incur costs associated with the suspension of reconnection fees and in additional
categories that cannot be predicted at this time due to the unprecedented nature of the ongoing
emergency. To account for the unanticipated costs of its response, the Company requests that the
Commission approve the establishment of a deferral account to record the incremental costs
associated with the increase in bad debt expense associated with the COVID-19 emergency. The
Company also intends to establish a tracking account to monitor additional costs associated with
the COVID-19 emergency, including any fees waived, for possible approval for deferral and
recovery in a future proceeding.
5. Even though it is not currently possible to fully anticipate the scope of the cost
impacts related to the COVID-19 emergency, the Company seeks authorization for deferred
accounting now because of the potential magnitude of the costs. The risks related to Rocky
Mountain Power’s response are also well outside ordinary business risks for the Company.
Deferred accounting will help the Company track the costs driven by COVID-19.
6. The Company is unable to fully estimate the total costs that will be incurred due to
its COVID-19 responses at this time, given the many unknowns, including how long the
emergency situation is likely to continue. However, preliminary estimates indicate that these costs
will be material.
7. The Company is proposing to use calendar year 2019 as its baseline for bad debt
expense. Costs incurred in excess of the baseline would be recorded in the deferral account. The
2019 baseline for Idaho bad debts are shown below in Table 1.

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Table 1
2019 Amount
Net Write-off $ 616,125
Retail Revenues $ 279,009,278
Uncollectible Rate 0.221%
8. PacifiCorp proposes to record the deferral as a regulatory asset in FERC Account
182.3 (Other Regulatory Assets), and credit the appropriate FERC accounts associated with the
expenses, such as FERC Account 904 (Uncollectible Accounts).
9. The Company proposes to record a carrying charge on the COVID-19 related
deferrals at the Commission approved customer deposit rate.
10. The Company acknowledges that the Commission’s approval of deferred
accounting treatment for COVID-19 related costs will not, in itself, constitute approval of ultimate
recovery of those costs. Recovery of the costs would be subject to a prudence review and a final
decision on rate recovery in a future regulatory filing.
11. In recognition of the unanticipated, and unprecedented nature of the COVID-19
emergency and potential need to include additional cost categories as the situation evolve, the
Company proposes to provide updates 30 days after the end of each quarter to the Commission
and any other interested parties. In these quarterly updates the Company commits to provide
deferral amounts for bad debt expense and any other related COVID-19 costs identified and being
tracked as of that time. To the extent the Company identifies any new costs related to its COVID-
19 response that it proposes to use deferred accounting for, the Company will separately file with
an explanation why deferral and potential recovery is appropriate, and what baseline will be used
to calculate the deferral for that cost category.
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WHEREFORE, Rocky Mountain Power respectfully requests an accounting order
authorizing it to record a regulatory asset to FERC Account 182.3 (Other Regulatory Assets).

DATED: April 3, 2020
Respectfully submitted,

______________________
Adam Lowney (ISB#10456)
McDowell Rackner Gibson PC
419 SW 11th Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power