20210921Comments.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO INCREASE
THE BPA RATE CREDIT EFFECTIVE
OCTOBERI,2O2I THROUGH
SEPTEMBER 30,2023
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Street Address for Express Mail:
I 133I W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC.E,.2I-IB
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Dayn Hardie, Deputy Attomey General, submits the following comments.
BACKGROUND
On August 30,2021, PacifiCorp dba Rocky Mountain Power ("Company") applied to
the Commission requesting an order approving an increase for the Company's current Electric
Service Schedule 34-Pacifrc Northwest Electric Power Planning and Conservation Act
Residential and Farm Kilowatt-Hour Credit rate ("Schedule 34"). Under the Company's
proposal, Schedule 34 customers would receive a Residential Exchange Program ("REP")
credit of $0.010133 per Kilowatt-Hour ("kWh").1 The Company requested an effective date of
October 1,2021.
I The currently authorized Schedule 34 rate credit is $0.008403 per kWh. This credit is authorized through
September 30,2021.
ISTAFF COMMENTS SEPTEMBER 2I ,2021
STAFF ANALYSIS
The Residential and Small Farm Energy Credit Rate results from an agreement between
the Company and Bonneville Power Administration ("BPA") regarding the REP. Under the
REP, 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. The Company's current residential and
small farm credit rate is $0.008403 per kWh. The proposed credit rate is $0.010133 per kWh.
The Company's allocation of the BPA REP credit for fiscal year2022through2023
(October 2021through September2023) increased approximately $18.7 million, from $67.9
million in 2019 to $86.6 million. In addition,202l was the last year of the $4.3 million look
back payment. These changes result in a net increase to the Company's REP credit of $23.0
million ($18.7 million increase plus $4.3 million look back payment).
In 2001, parties in a BPA REP case negotiated a settlement for the allocation of REP
benef,rts for the period 2002 through 2008. This settlement was appealed by a group of
northwest public utility districts ("PUD"), and the court ruled in favor of the PUDs. Pursuant to
the court order, the allocation of the BPA's REP credit was recalculated, and the participating
investor owned utilities ("lOU") were ordered to pay back excess benefits that had been
received. The agreement allowed the companies to refund the excess REP credits - the look
back payments - by netting the look back payment against future REP benefits through BPA
fiscal year 2021. This allows investor-owned utilities to provide a small credit to qualiffing
customers.
The BPA REP credit available to qualifuing Idaho customers is $20.3 million plus an
undistributed balance of $0.2 million in Idaho's REP balancing account for a total of $20.5
million to amortize over the next two years. The REP credit is $10.3 million per year. The
$10.3 million REP credit was divided by calendar year 2019 usage level of the qualiffing
customers of approximately l.l Gigawatt hours, to produce the Schedule No. 34 rate of $0.01033
per kWh.
The average residential customer on Schedule I using 801 kwh per month would see a
decrease of $1.38 or l.7Yo. The bill impact for Schedule 36 Residential Optional Time-of-Day
customers using 1428 kW is a decrease of $2.47 or 2.lYo per month.
2STAFF COMMENTS SEPTEMBER 2I ,2021
Staff has audited the initial inputs and independently recalculated the rate. Staff believes
that the Company correctly calculated the rate of $0.010133 per kWh and recommends the rate
be approved.
CUSTOMER NOTICE, PRESS RELEASE AND PUBLIC COMMENTS
No notice is required because the Company is not proposing an increase in rates due to
the change in the REP credit. As of September 21,2021, the Commission has received no
comments from customers.
STAFF RECOMMEITDATION
Staffrecommends that the Commission approve Electric Service Schedule No. 34,
Pacific Northwest Electric Power Planning and Conservation Act Residential and Farm
Kilowatt-Hour Credit of $0.010133 per kWh effective October 1,2021.
Respecttully submitted this Zl*day of September 2021.
Deputy Attorney General
\
Technical Staff: Kathy Stockton
Curtis Thaden
i:umisc/comments/pace2 l. I 8dhhsct comments
JSTAFF COMMENTS SEPTEMBERZI,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. PAC-8.21.I8, BY E.MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datarequest@fraci fi com.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE