20210513Comments.pdf

MATT HI-INTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10655
-'-F-f' l1;f,:':.-''\. l.-1 !'',. -:-:. U1=-
I i', i'l: Dtl l.' l?. lrr.i Ir; ! i: -' lk
Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION REQUESTING
APPROVAL OF $16.1 MILLION NET POWER
COST DEFERRAL (ECAM)
CASE NO. PAC-8.21-09
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Matt Hunter, Deputy Attorney General, submits the following comments.
BACKGROUND
On March 37,2021, PacifiCorp dba Rocky Mountain Power ("Company") applied for
Commission authorization to adjust its rates under the Energy Cost Adjustment Mechanism
("ECAM"). The ECAM allows the Company to adjust its rates each year to capture the
difference between the Company's actual power supply expenses and the power expenses
embedded in base rates. The adjustment is a separate line item on customer bills that increases if
power supply costs are higher than the amount already included in base rates or decreases if
power supply costs are lower. The ECAM does not affect the Company's earnings. The
Company also seeks Commission approval of about $16.1 million of deferred costs.
The Commission approved the ECAM in2009. Order No. 30904. The ECAM allows
the Company to increase or decrease its rates each year to reflect changes in the Company's
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STAFF COMMENTS MAY t3,2021
power supply costs. These costs vary by year with changes in the Company's fuel (gas and coal)
costs, surplus power sales, power purchases, and associated transmission. Each month, the
Company tracks the difference between the actual net power costs ("NPC") it incurred to serve
customers, and the embedded (or base) NPC it collected from customers through base rates. The
Company defers the difference between actualNPC and base NPC into a balancing account for
later disposition at the end of the yearly deferral period. At that time, the ECAM allows the
Company to credit or collect the difference between actual NPC and base NPC through a
decrease or increase in customer rates. This year, the deferred NPC difference was about $14.3
million.
Besides the NPC difTerence, this year's ECAM includes: (l) the Load Change
Adjustment Revenues ("LCAR"); (2) an adjustment for coal stripping costs; (3) a true-up of
100% of the incremental Renewable Energy Credit revenues; (4) Production Tax Credits; (5) the
Lake Side 2 generation resource adder; and (6) a resource tracking mechanism. The ECAM
includes a"90ll0 sharing band" in which customers paylreceive 90Yo of the increase/decrease in
the difference between actual NPC and base NPC, LCAR, and the coal stripping costs; and the
Company incurs/retains the remaining 10%. The Company's Application includes the testimony
of witnesses who explain each of these items in detail.
With this ECAM Application, the Company ultimately seeks an order approving the
Company's: (l) defenal, for later recovery through rates, of $16.1 million in costs; and (2)
revised Electric Service Schedule 94,Energy Cost Adjustment, which would reflect the ECAM
adjustment and decrease the Company's Schedule 94 revenues by approximately $3.1 million.
As noted above, the Company states that if its proposal is approved, prices for customer
classes would decrease as follows:
o Residential Customers - (0.8%)
. Residential Schedule 36, Optional Time-of-Day Service - (0.9%)
o General Service Schedule 6 - (1.1%)
o General Service Schedule 9 - (1.2%)
o Irrigation Customers - (1.0%)
. Commercial or Industrial Heating Schedule 19 - (1.0%)
. General Service Schedule 23 - (0.9%)
. General Service Schedule 35 - (1.3%)
o Public Street Lighting - (0.4%)
. Industrial Customer, Schedule 400 - (1.3%)
o Industrial Customer, Schedule 401 - (1.3%)
2STAFF COMMENTS MAY 13,2021
Application, Meredith Direct, Exhibit No. 2. The Company asks that its proposed Schedule 94
take effect on June 1,2021.
STAFF'ANALYSIS
Deferral Analysis
Staff believes the Company's overall methodology complies with previous Commission
orders. However, Staff discovered an anomaly in data caused by a faulty meter between the
Idaho and Utah jurisdiction that inflated the amount of energy used to allocate net power costs to
Idaho used for net power costs. This inflated the amount of total Company net power costs
allocated to Idaho, and thus inflated the ECAM balance to be recovered from rate payers. As
requested, the Company provided a revised Exhibit l, Exhibit 2, and Tariffs to Staff on
May 11,2021. See Attachment A. Staffincludes the Company's revisions in our analysis
below. With limited time to review these revisions, Staff requests the opportunity to provide
supplemental comments no later than May 18,2021should any additional issues be discovered.
Staff also has concerns about the method used to allocate cost to Idaho for the ECAM, which is
discussed further below. Other than the faulty meter error, Staff believes that the Company used
accurate actual loads and prudently incurred actual costs and revenues. With the adjustment
mentioned above Staff recommends that the Commission authorize the 2020ECAM deferral as
shown below:
JSTAFF COMMENTS MAY 13,2021
Table I
Asaual ECAl't Calculation
Calendar Year 2020 ECAif't Deferral
NPC D$erential
EITF 04-6 Adjustrrcnt
I.CAR
Total Dderral Bdore Shaing
Sharing Basd
Customer Reponsibrlity
I"ake Sifu 2 Resoruce Adder
ProdrctioaTa:r Credits
RTM.Adjr:shent
REC Dd€rral
Iaterest on Dderratr
Annual Deferral (Jan - Dec 2020)
4,330,859
(127=46"$)
(1,076=r70)
$ 1.t27.225
9Pr6
$ 2,814,502
5.431,705
(100,83u
4,431,885
8,557
482,919
s 13.068"738
s
s
The meter error dates to July 2019. Therefore, Staff believes that it is appropriate to
adjust the beginning2}Z} deferral balance for the change in load attributed to Idaho and
therefore the NPC allocated to ldaho. This would reduce the beginning balance from $27.3
million to $24.4 million. This reduction of approximately $2.9 million as well as a summary of
other changes due to this revision is shown on Table No. 2 below:
4STAFF COMMENTS MAY 13,2021
EC-{-\I Deferra I Balance
Deferral Balance - Dec 31= l0l9
Annual Dderral (Jan - Dec 2030)
Interest
ECd\{ Reyenue Collection - Schedr:le 9-l
Activitl' Through Deceuber 31, 2020
Deceurber 31, 2020 Balance For Collection S 13,060.567
s13,t11,078 s 19.050,133 s (4.160,8-+5)
0
(0)
0
s 18.899,711 s (1.160.816)
(
S 0s (150,511)s (150"s12)
As Filed
s 17,186,181
13"778.459
562.667
( 18_4 r 6_410)
Reriserl
s 11.39;.925
11,585.818
483,919
(18,416=430)
Difference
s (2,888"457)
(r,192.il1)
(79.748)
0
s (?6.878)
2.019.E00
(r.1 13.131)
5 (76,878)
l=039.800
(1.113,{r-l)
s0
(l 7,366)
S (,l,I7S,2lU
Schedule 9-l Collection - Jan - \{a-v l0l1
Interest
Expected Balance as ofJune 1,2021
s (6,991,766)
81.i45
s 16,147,146
s (6,991.766)
6_1.919
s lI,96Sp35
Depreciation Regulatoq. lsset Balance
Beginning Balance
fuinual Deferral (Jan - Dec ?020)
ECA\,{ Revetrue Collection - Schedule 94
Activitl- Through Deceruber 3I, 1020
Table 2
Balauc Arcount
Staff reviewed the Company's external audit reports, journal entries, invoices, contracts,
and bills to customers. Staff also reviewed the Company's adjustment to actual costs. Staff
reconciled the general ledger amounts to the NPC provided in Exhibit No. I of Mr. Painter's
testimony. Staff reviewed the Company's hedge contracts and policies and believes they
reasonably safeguard price and fuel stability. Staff also reviewed the transactions and invoices
for the Energy Imbalance Market revenues. Additionally, Staff verified the calculations of the
RTM adjustment, which is included in the ECAM. Staff concludes that the ECAM deferral
shown in Attachment A revising Exhibit No. I is accurate and complies with ECAM orders.
Net Power Cost Deferual
The NPC adjustment within the ECAM allows the Company to collect or credit the
difference between NPC incurred to serve customers in Idaho and the NPC collected from Idaho
customers through base rates. Staff believes that with the adjustments correcting for the faulty
meter the calculations and the methodology the Company used to determine the NPC defenal
meet the intent of the ECAM and Commission orders and the deferral is calculated correctly.
For the 2020 deferral year, the NPC embedded in rates was set in Order No. 33668, Case
No. PAC-E-16-12, at $26.90 per MWh. The revenue collected through base rates is calculated
5STAFF COMMENTS MAY 13,2021
by multiplying $26.90 by 3,522,347 MWh of actual Idaho sales, for a total of $94.7 million. The
difference between base rate revenue and Idaho's share of actlal2020 NPC of $99.0 million, is
an under-collected balance of $4.3 million. This is approximately $ I .3 million less than the
Company had filed in its Application. The under collected balance is subject to a 90/10
customer sharing band, with the Company paying 10% of the NPC balance. After removing that
l}Yo,the amount to be collected through Schedule 94 rates is $3.9 million.
Emerging Issues Task Force ("EITF") 04-6 Adjustment
The EITF 04-6 adjustment is the difference between coal stripping costs the Company
incurred and recorded as stated in the accounting pronouncement EITF 04-6 and the amortization
approved by Order No. 30987 in Case No. PAC-E-09-08. The Company uses this account to
"undo" the effects of EITF 04-6 that requires the Company to expense coal stripping costs as
opposed to amortizing it over the coal produced from the section of open mines. The adjustment
decreases the deferralby $127,464. Staff reviewed the adjustment and believes it is accurately
calculated.
Load Change Adjustment Revenues
Staff believes the Company's LCAR adjustment complies with Order No. 33440. The
LCAR adjusts for the under- or over- recovery of fixed energy-classified production cost
(excluding NPC) because of the difference between sales used to determine base rates and the
Idaho sales from the deferral year.
The LCAR of $5.54 per MWh was set in Case No. PAC-E-16-12 and adjusted due to
changes in the corporate tax rate in Case No. GNR-U-18-01. Multiplying the LCAR by the
actual Idaho sales of 3,522,347 MWh shows that the Company collected $19.5 million of
energy-classified fixed production costs through base rates. The amount in base rates is greater
than the actual amount of energy-classified fixed production costs, $18.4 million, which is a
benefit of $l.1 million to customers.
Production Tax Credit ("PTC")
The Commission approved a settlement in Case No. PAC-E-15-09 that moved the PTC
true-up to the ECAM, with a $1.99 per MWh benefit to customers included in base rates. In
6STAFF COMMENTS MAY t3,2021
2020, base rates included a $7.0 million benefit from PTCs. However, the Company's actual
PTCs in 2020 allocated $7.1 million to Idaho customers. The $0.1 million difference between
the PTCs in base rates and the actual PTCs is a benefit to customers. Compared to last year's
PTCs this is a significant increase to the amount of PTCs the Company received. This difference
is explained by several new and repowered wind projects coming online in late 2019 and 2020.
Renewable Energy Credit ("REC")
In Case No. PAC-E-16-12, the Commission approved a $0.09 per MWh benefit to
customers for the REC revenues included in base rates. The difference between the embedded
amount and actual REC revenue is trued-up in the ECAM. Ln2020, base rates included
$316,068 in benefits from REC revenues. Idaho's share of the Company's actual REC revenues
was $307,510. The difference of $8,557 is added to the defenal balance.
Lake Side 2 Resource Adder
In Order No. 32910, the Commission approved a settlement that allows the Company to
recover its investment in the Lake Side 2 generation facility through the ECAM until its
investment is included in base rates in a future rate case. The adder allows the Company to
recover $1.99 per MWh of generation at Lake Side 2, up to $5.43 million per year. In2020,the
Company generated over 2.7 million MWh at Lake Side 2, allowing the Company to include the
maximum of $5.43 million in the deferral balance.
RTM Adjustment
In Order No. 33954, the Commission approved a settlement allowing the Company to
recover costs related to wind repowering projects through the ECAM. In2020, all of these
projects were online and generating electricity. The RTM adjustment properly reflects cost that
offset the repowering projects' benefits to customers found elsewhere in the ECAM, PTC
benefits, and NPC benefits. Based on the tefins of the RTM settlement, the Company included
$4.4 million in the deferral. Staff agrees with this number.
7STAFF COMMENTS MAY 13,2021
Tax Savings
The 2018 and 2019 ECAMs included a credit to the deferral balance from the Tax Cuts
and Jobs Act ("TCJA"). In Case No. PAC-E-20-03 the Commission approved a settlement to
modify the order for the treatment of the TCJA tax benefits. The remaining benefits will be used
to offset the plant balance and closing costs of the Cholla 4 coal generating plant, and to offset
the next rate increase. Therefore, there are no direct tax benefits included in the 2020 ECAM.
NPC Method Analysis
Staff evaluated the methods and inputs used to determine the base-to-actual deferral
amounts for NPC-related costs. As a result of its analysis, Staff identified a significant
discrepancy in Idaho's share of line losses that will require a total reduction of $4,178,211 in the
deferral amounts for the 2019 and 2020 ECAM years. In addition, Staff has concerns regarding
the Company's method for determining the amount of Actual Load at Input allocated to Idaho
and the resulting line losses allocated to Idaho customers for calculating the ECAM.
Faulty Meter Adjustments
Staff compared the difference between the amount of Idaho Actual Sales at Meter used to
determine the Company's recovery of NPC through base rates and the amount of Idaho Actual
Load at Input used to determine the unit cost of actual NPC, both of which are integral in
calculating the NPC-related base-to-actual deferral amounts. See Application, Painter Direct,
Exhibit 1 . The difference between these two amounts of load provides the amount of line loss
that the Company reflects in the ECAM as a necessary cost of delivering energy to Idaho
ratepayers. In this case, Staff determined that the amount of line loss was not reasonable and
required further investi gation.
Actual Sales at Meter is the amount of energy included in Idaho customer's bills, while
Actual Load at Input is the amount of energy that is metered into the State of Idaho at its borders
that is assumed to be consumed by Idaho customers. The difference between the two amounts is
the amount of line loss that occurs between energy provided to Idaho across its borders and the
amount of energy consumed at the customer's meter. The amount of line loss in this year's filing
was about 9.8 percent, which Staff did not believe was reasonable. By looking at the same data
over the past five years, Staff noticed that line losses increased from about 7Yo to about l0%
8STAFF COMMENTS MAY 13,2021
starting in2019, indicating that something had changed. Staff s analysis is illustrated in Figure
No. I below.
Figure No. l: 5-Year Historical Comparison ofldaho's Loads and Line Losses
PACIFICORP IDAHO - ECAM Energy Comparison
t2.a%
rc.0%
8.0%
6.0%
4.0%
2.A%
0.a%
3,900,000
3,800,000
3,700,000
; 3,600,000
5 3,500,000
3,400.000
3,300,000
3,200,000
--
oI
0)6-
201"6 2017 2018 2A$
lD Actual Sales @ Meter (MWh)
r lD Actual Annual Load @ lnput (MWh)
o e {vsp6ge System Percentage Losses Attributed to ldaho
2020
Staff notified the Company of the issue and as a result of its root cause analysis, the
Company determined that:
A meter on the line between the Treasureton, Idaho and Wheelon, Utah
substations had apartial failure on one phase of the three phases in July of 2019.
Initially the failure occurred intermittently and continued to increase until
ultimately the meter was only registering approximately 68 percent of the actual
energy. The line flow on this line is typically from Idaho to Utah, resulting in
the meter registering too little power leaving Idaho overstating Idaho load at
input.l
Along with results of its root cause analysis, the Company provided Staff with
recalculated exhibits for both this year's filing and last year's filing adjusting for the discrepancy
in Idaho's Actual Load at Input caused by the faulty meter. With the adjustment, the end result
is a $4,178,211 reduction in the deferral for both the 2019 and2020 ECAM deferral years and is
$2,888,457 and $1,289,754, respectively.
I Email from Company Representative, Ted Weston, dated 5llll202l
9STAFF COMMENTS MAY 13,202t
Idaho's Share of Line Loss
The Company uses a border method of allocation to determine each jurisdiction's share
of Actual Load at Input. At the most basic level, the amount of actual load allocated to a
jurisdiction is calculated by netting energy flow into and out of each jurisdiction while
accounting for the amount of energy generated within its borders over the same time period.
The Company's method can be depicted by the following equation:
Actual Load at Input : Input at borders -t Generation within borders - Output at borders
Although the Company can account for 100% of the load for the whole system using this
method, Staff is concerned that the energy flowing into and then out of the State to be consumed
by customers in other jurisdictions may be unfairly allocating line-loss-related actual costs to
Idaho for energy flowing through the State not consumed by Idaho customers.
Staff re-created Figure No. 1 with the adjustments due to the faulty meter as shown in
Figure No. 2 below. The line losses for the Company's entire system have been added to show a
comparison between system and Idaho line losses.
Figure No. 2: Revised S-Year Historical Comparison ofldaho's Loads and Line Losses
REVISED PACIFICORP IDAHO - ECAM Energy Comparison
3,900,000
3,800,000
3,700.000
3,600,000
3,500,000
3,400,000
3,300,000
3,200,000
c
o)oBa
L2.O%
LO.0%
8.0%
6.0%
4.0%
0.o%
20L6 2077 2018 2419
lD Actual Sales @ Meter (MWh)
n lD Actual Annual Load @ lnput (MWh)
o r {vsv6ge System Percentage Losses Attributed to ldaho
-
[ys16ge Systern Perce ntage Losses
2020
STAFF COMMENTS l0 MAY t3,2021
Although the faulty meter has reduced line losses in Idaho from about 9.8%o to about
8.3% in2020, Staff believes that Idaho customers may still be receiving an unfair allocation of
system line loss-related cost due to energy flowing through the State not consumed by Idaho
customers. Staff has identified three possible inter-related reasons.
First, Idaho is uniquely positioned in the Company's system where a significant amount
of its energy flows through the State in comparison to the amount of energy actually consumed
in Idaho.2 Second, Staff compared Idaho's line losses with the Company's line losses for its
entire system. As can be seen in Figure No. 2, system line loss in2020 was approximately 7 .ZYo
with Idaho's line loss being larger at about 8.3% (includes adjustments due to the faulty meter).
Third, Staff expects that Idaho's line losses should be consistently below system line losses due
to the amount of load being consumed at transmission level voltages. Approximately 40%o of
Idaho's load comes from a single industrial customer that takes service at transmission level
voltages, which typically have line losses between 3%o and 4o/o.
Staff plans to conduct a review of the Company's border method for allocating actual
loads in the ECAM to determine if Idaho is being charged an unfair amount of system line loss.
Any concerns found will be discussed with the Company with any agreed adjustments included
in the deferrals. If the treatment remains at issue, Staff recommends the Commission allow this
adjustment to be made for 2021in the next ECAM filing.
NPC Analysis
Staff analyzedthe Company's actual NPC to identi$, differences between base NPC and
actual NPC driving base-to-actual deferral amounts in this year's ECAM. The results of Staff s
analysis are reflected in the table below.
2ldaho's allocation of system energy is about 7%.
STAFF COMMENTS 11 MAY t3,2021
Source Adjusted Actual Base NPC
Base-to-Actual
Difference
Percentage
Difference
Wholesale Sales (revenue)($ 173,806,710)($334,520,634)$160,713,9233 -48.0%
Purchased Power / Net
Interchange (cost)$644,1 83,1 57 $604,970,83 I $39,212,326 6.5%
Coal(cost)s631,640,957 9780,404,471 ($ 148,763,514)-19.1%
Gas (cost)9263,097,477 $284,628,008 ($21,530,532)-7.6%
Other - Primarily Wind (cost)$ 146,968,316 $ 149,96s,098 ($2,996,782)-2.0o/o
Total System $1,512,083,197 st,485,447,775 s26,635,422 l.8o/o
During the deferral period, the amount of generation cost from its coal and natural gas-
fueled generation resources has declined from quantities assumed in base rates (see Case No.
PAC-E-16-12), which can be attributed to reduced generation output. Staff believes that these
reductions are a major cause of reductions in the amount of wholesale sales revenue and an
increase in the amount of purchased power used to serve the Company's load.
Proposed Rates
The Company provided Staff a revised Exhibit No. 2, showing the calculation of the new
rates based on the adjustments discussed above. The revised Exhibit No. 2 is included in
Attachment A to these comments. Staff verified that the rates in the Company's revised
Schedule 94,Energy Cost Adjustment, are calculated using the methodology approved in Order
No. 33440. The ending deferral balance is allocated on an equal cents per kilowatt-hour basis
and then fuither allocated for line losses based on the voltage level at which each customer class
receives service. This ensures that customers that take service at higher voltages (i.e.,
transmission) do not get charged for line losses that are lower than for primary and secondary
distribution customers whose line losses are higher due to taking service at lower voltages.
Using this method, the proposed rates in Schedule 94 are voltage-level specific: 0.354 cents per
kWh for secondary service, 0.342 cents per kWh for primary service, and 0.333 cents per kWh
for transmission service.
3 The positive amount for the wholesale sales base-to-actual difference represents a reduction in revenue from the
total actual amount of sales relative to the base amounts; whereas positive amounts for base-to-actual cost
components represent increases in actual cost as compared to base amounts.
STAFF COMMENTS t2 MAY 13,2021
The Company's provided Staff with revisions to Schedule 94, also included in
Attachment A to these comments, decreasing Company revenue by approximately 2.2%.
However, revenue decreases to specific classes will vary because of differences in rate design
among the classes. The overall revenue decrease for residential customers is just under 2%. A
typical residential customer using an average of 800 kWh per month would pay $1.74 less per
month or $20.88 less annually under the proposed rates.
CUSTOMER NOTICE AND PRESS RELEASE
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure. The notice was included with bills mailed to customers
between April2, 2021 and May 3, 2021, providing customers with a reasonable opportunity to
file timely comments with the Commission by the May 13, 2021 deadline. As of May 12,202I,
the Commission has received no comments from customers.
STAFF RECOMMENDATION
If the potential additional Staff comments do not provide any adjustments to the deferral,
Staff recommends the Commission:
. Approve the deferral amount of $12.0 million for recovery.
. Approve the rates as described in Attachment A, the revised Exhibit No. 2.
. Approve the revised Tariffs.
Respectfully submitted this 13rH day of May 2021.
M,I
Matt Hunter
Deputy Attorney General
Technical Staff: Joe Terry
Rick Keller
Kevin Keyt
Curtis Thaden
STAFF COMMENTS 13 MAY 13,2021
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Attachment A
Case No. PAC-E-21-09
Staff Comments
05ll3l2l Page I of 3
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ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP
I.P.U.C. No. I
Tenth Revision of Sheet No. 94.1
Canceling Ninth Revision of Sheet No. 94.1
ROCKY MOUNTAIN POWER
ELECTRIC SERVICE SCHEDULE NO.94
STATE OF IDAHO
Energy Cost Adjustment
AVAILABILITY: At any point on the Company's interconnected system.
APPLICATION: This Schedule shall be applicable to all retail tariff Customers taking service under the
Company's electric service schedules.
ENERGY COST ADJUSTMENT: The Energy Cost Adjustment is calculated to collect the
accumulated difference between total Company Base Net Power Cost and total Company Actual Net Power Cost
calculated on a cents per kWh basis.
MONTHLY BILL: In addition to the Monthly Charges contained in the Customer's applicable
schedule, all monthly bills shall have applied the following cents per kilowatt-hour rate by delivery voltage.
Delivery Voltage
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
Schedule
I
6
6A
7
7A
9
l0il
l2
l9
23
23A
24
35
35A
36
400
401
Secondary
0.1:4s+p per kWh
0.154+ll per kWh
0.111s7-1p per kWh
O.ll[sPp per kWh
0.lll+Pp per kWh
Primary
0.j4lr49p per kWh
0.i+:5*ep per kWh
0.){2.*190 per kWh
0.1!254e1, per kWh
0.i425+si, per kWh
0.i12s1et per kWh
0.3!t2*9F per kWh
Transmission
0.1-jj533l perkWh
0.3335?4O per kWh
03335€tsA perkWh
0.ji4'>"?'l p per kWh
0.i515++l per kWh
0.lJ:is7+l per kWh
0.i.54#|p per kWh
0.i54r}+f per kWh
O..jLt:?+l per kWh
O.i-VS7r p per kWh
O.l.l4>7l I per kWh
0.1"!57lp per kWh
0..if4.i++P per kWh
Attachment A
Case No. PAC-E-21-09
Staff Comments
05/13121 Page 3 of 3
Submitted Under Case No. PAC-E-20-02
ISSUED: April 1,2020 EFFECTM: June 1,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF MAY 2021,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. PAC-E-21.09, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: ted.weston@pacificor?.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pac i fi corp.com
ELECTRONIC ONLY
BRADLEY MULLINS
MW ANALYTICS
ENERGY & UTILITIES
E-MAIL : [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON PLLP
PO BOX l39l
POCATELLO TD 83204
E-MAIL: [e-mail]
[e-mail]
EMILY WEGENET\
ROCKY MOLINTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ELECTRONIC ONLY
Val. ste iner@itafos. com
[e-mail]
[e-mail]
BRUBAKER & ASSOCIATES
BRIAN C COLLINS
MAURICE BRUBAKER
16690 SWINGLEY RIDGE RD #I4O
CHESTERFIELD MO 63017
E-MAIL: bcollins@,consultbai.com
[e-mail]
SECRET
CERTTFICATE OF SERVICE