20210520Reply Comments.pdf

Adam Lowney (ISB#I 0456)
McDowell Rackner Gibson PC
419 SW I lft Avenue, Suite 400
Portland, OR 97205
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTTNG APPROVAL OF $16.r
MILLON NET POWER COST DEFERRAL
) CASE NO. PAC-E-21-09
)) REPLY COMMENTS OF
) ROCKY MOUNTATN POWER
Emily Wegener (Idaho bar application pending)
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone No. [phone]
Mobile No. [phone]
Email : [e-mail]
Attorneysfor RoclE Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Pursuant to Rule 202.01(d) of the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission") and the Commission's April 2020 Notice of Modified Procedure,
Rocky Mountain Power a division of PacifiCorp ("RMP" or the "Company") hereby submits its
reply comments in the above-referenced case.
BACKGROUND
On March 31,2021the Company filed an application ("Application") with the Commission
pursuant to the approved energy cost adjustment mechanism ("ECAM") for approval of
approximately $16.1 million of deferred costs from the deferral period beginning January 1,2020
through December 31,2020 ("Deferral Period") with a 0.9 percent decrease to Electric Service
Schedule No. 94, Energy Cost Adjustment ("Schedule 94") for standard tariff customers. Tariff
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Contract 400 and 401 customers will see a 1.3 percent decrease. Commission Stafffiled comments
on May 13,2021, stating that the methodology used in the Company'sApplication "complies with
previous Commission orders," but requested a reduction to the Company's requested deferral after
correcting for a partial meter failure identified during their review.
REPLY COMMENTS
The Company appreciates Commission Staff's review of the 2021 ECAM and supports
their recommendation to approve the adjusted ECAM deferral amount of $12.0 million and the
revised Tariffs. The Company provides the following information concerning the revised deferral
request consistent with Commission Staff's recommendation.
Faulty Meter Adj ustment
On April 28, 2021, Commission Staff contacted the Company requesting a meeting to
discuss line losses. Staffalso provided a copy of their 5-year historical load comparison. As part
of analyzing the load data, the Company was able to identiff a partial meter failure at the
Treasureton substation that occurred between July 2019 and March 2020. This partial failure
under-stated the load leaving the state of Idaho which resulted in overstating Idaho's load at input.
Correcting the load data was simple and reliable because the meter failure was only for one of
three phases. Using the load from the other two phases allowed the Company to correct the error
accurately.
Many factors influence the amount of line losses experienced in any geographic location,
and therefore it was not immediately apparent to the Company that the anomaly in the line loss
numbers was an error in comparison to the historical average. Specifically, between 2010-2020,
Idaho's line losses fluctuated between 9 percent in 2010 to 6 percentin2016. Between 2010 and
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2018 Idaho's line loss averaged approximately 7.8 percent. The correction of the meter failure
reduced the 2020line loss percentage from 9.8% to 8.3Yo.
Commission Staff is concerned that even with this correction that the allocation
methodology may be faulty resulting in an unfair allocation to Idaho. The Company's system
average losses are not representative of the actual power flow in any specific geographic location
in the Company's control areas and so do not bear on Idaho's allocation. From year to year,
average losses will change as well as the losses specific to each jurisdiction. Changes in the source
of generation and Western Electricity Coordinating Council loop flow will impact the general flow
of power. Changes between the loads delivered at transmission and distribution voltages will also
impact the overall loss factor. Each jurisdiction has a unique generation, topology, and customer
mix that fluctuate annually. It is reasonable to expect each jurisdiction to compensate the Company
for the losses unique to that jurisdiction. As a beneficiary of the interconnected grid with basically
no generation in-state, it is fair for Idaho customers to compensate the Company for the reliability
and economic benefit that comes from the system.
2020 DeferualAmount
Table 1 summarizes the corrected 2020 Deferral Amount for calendar year 2020.
Table I -Annual ECAM Calculation
Calendar Year 2020 ECAM Deferral
NPC Differential
EITF 04-6 Adjwtrrcnt
LCAR
Total Deferral Before Sharing
$4,330,859
(127,464)
(1.076,170)
$ 3.t27,72s
Sharirg Band
Custonrer Reporsfo ility
Lake Sile 2 Resouce Adder
Production Tax Credits
RTM Adjusfircnt
REC Defenal
Interest on Deferral
Annual Deferral (Jan - Dec 2020)
90o/o
$
$
2,814,502
5.431,705
( 100,83 l )
4,43 1,895
8,557
482,919
$ 13,068,738
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Based on the revised deferral amounts for 2019 and 2020 and estimated Schedule 94
revenue collection from January ltt through May 31, 2021, the expected balance for rate design is
approximately $12.0 million as noted in Staff's recommendation and shown in Thble 2.
Table 2 -Account
CONCLUSION
The Company prepared the adjustments to the ECAM proposed by Staff and supports
Staff's recommendations to approve the revised tariffsheets for Electric Service Schedule No. 94
- Energy Cost Adjustment rates designed to collect $12.0 million with a rate effective date of
June 1,2021.
REOUEST FOR RELIEF
Rocky Mountain Power respectfully requests that the Commission issue an order
approving approximately $13.1 million ECAM deferral for the Deferral Period and approve an
overall 2.5 percent decrease to Idaho customer rates.
ECAM Defenal Balance
DeftnalBahnce - Dec 3l,2019
Anrual Deftnal (Jan - Dec 2020)
Interest
ECAM Revenue Collection- Schedule 94
Activity Throqh December 3l, 2020
Deprcciation Re gulatory fu set Balence
BegfufingBalarce
Anual Deftnal (Jan - Dec 2020)
ECAM Reverure Collection - Sctpduh 94
Activity Thrcugh December 3l, 2020
December 31, 2020 Balance For Collection
Sctredule 94 Colhction - Jan - May 2021
Interest
ExpectedBalance as ofJune 1,2021
$
$
$ 19,050,233
$ (150,512)
$ 18,899,721
$ 11,968,935
$ 24,397,925
12,585,818
482,919
(18,416,430)
(76,878)
2,039,800
Q,l13,434)
(6,994,766)
63,979
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DATED this 20m day of May 2021.
Respectfrrlly zubmitte4
ROCKYMOIJMAIN POWER
a
Emily Wegener (Idsho Bw Applicatlan Pendtng)
1407 WestNorth Temple, Suite 320
Salt Lake Citf Utah 84116
Telephone No. (80 l) 2204526
Mobile No. (385) 227 A47 6
Email: Emily.wegener@[,eeificorp.com
Attorneysfor Rocky Mountaln Power
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