20220118Comments.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11542
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER'S ANNUAL )CASE NO.PAC-E-21-21
TRANSMISSION REPORT AND AUTHORITY )
TO TERMINATE FUTURE REPORTS )
)COMMENTS OF THE
)COMMISSION STAFF
COME NOW the Staff of the Idaho Public Utilities Commission ("Staff'),by and
through its Attorneyof record,TaylorBrooks,Deputy AttorneyGeneral,and submit the
followingcomments.
BACKGROUND
On November 23,2021,PacifiCorp,d/b/a Rocky Mountain Power ("Company"),applied
with the Idaho Public Utilities Commission ("Commission")for authority to terminate the annual
reporting requirement implemented in Commission Order No.33313.
On December 19,2014,the Company and Idaho Power Company ("the Parties")jointly
filed an application with the Commission pursuant to Idaho Code §61-328 and Commission
Rule of Procedure 52,IDAPA 31.01.01.052,requesting an order approving the exchange of
certain transmission assets.
STAFF COMMENTS 1 JANUARY 18,2022
The Parties own and operate the Jim Bridger Power Plant and associated transmission
assets.On October 24,2014,the Parties entered into a Joint Purchase and Sale Agreement and a
Joint Ownership and Operating Agreement to reallocate their respective ownership interests to
better meet their load service obligations and improve operational efficiency.On June 5,2015,
the Commission issued Order No.33133,which:(1)approvedthe Parties'application finding
that the exchange of transmission facilities ("Transmission Facilities")satisfied the requirements
of Idaho Code §61-328;(2)required that the financial benefits from the exchange be returned to
customers;and (3)required the Company to file an annual report with the Commission
documenting changes to the Company's wheeling expenses associated with Idaho Power
Company ("Idaho Power").Case No.PAC-E-14-11,Order No.33313 at p.14.
The financial benefits from the Transmission Facilities exchange flow back to the
Company's customers through the Energy Cost Adjustment Mechanism ("ECAM").The ECAM
is also where actual transmission wheeling expenses are compared to the normalized levels in
base rates.
In compliance with Order No.33313,the Company reports that transmission wheeling
expense paid to Idaho Power from October 1,2020,through September 30,2021,was $16.3
million representing a $0.2 million increase compared to the prior reporting period.
The Company states that Order No.33313 recognized that the annual transmission report
was transaction-specific and would not be required indefinitely.Order No.33313 at 14.The
Company noted that the Commission stated that once the change in transmission revenues and
wheeling expenses were reflected in base rates,the Parties could request to discontinue filing the
annual reports required by Order No.33313.Id
On May 27,2021,the Company filed a general rate case with the Commission requesting
authorityto increase base rates in Idaho.'On October 25,2021,the parties filed a settlement
stipulation with the Commission resolving all issues in the rate case with new rates proposed to
be effective January 1,2022,subject to Commission approval.If approved,the Company asserts
that the financial benefits from the Transmission Facilities exchange will be included in base
rates,eliminating the need for continued tracking and reporting of wheeling expenses to the
Commission.
I See Case No.PAC-E-21-07.
STAFF COMMENTS 2 JANUARY 18,2022
On December 30,2021,the Commission issued Order No.35277 approving the
settlement stipulation and establishing new base rates effective January 1,2022.
The Company requests an order from the Commission (1)acknowledging that the
Company has complied with Order No.33313,and (2)authorization for the Company to stop
filing annual transmission wheeling reports associated with the Idaho Power transmission asset
exchange.
STAFF REVIEW
Staff has reviewed the Company's Application and additional details in the Company's
recent general rate case.Based on its review,Staff believes the Company has fully complied
with Order No.33313 and that annual filings reporting the transmission wheeling expense
associated with the Idaho Power transmission asset exchange are no longer necessary.
During the Company's annual ECAM filings,Staff reviewed the expenses recorded to
FERC account 565 -Transmission of Electricity by Others,or wheeling expense,along with
other variable net power cost expenses from the amount included in customers'rates.During
those cases,Staff audited a sample of expenditures and verified the Company recorded expenses
properly and that benefits from the Idaho Power transmission asset exchange were credited to
customers.
On December 30,2021,the Commission issued Final Order No.35277,Case No.
PAC-E-21-07,the Company's latest general rate case.In this case,a new base level of
Transmission Expenses has been established,thereby incorporating the change in the level of
expense paid by the Company to Idaho Power.During the general rate case,Staff had the
opportunity to review and audit the Company's new base level of transmission expenses.
Because the financial benefits from the Transmission Facility exchange are now included
in base rates,there is no need for continued tracking and reporting of these wheeling expenses.
Staff will continue to review wheeling expenses in the Company's annual ECAM filings.
STAFF COMMENTS 3 JANUARY 18,2022
STAFF RECOMMENDATIONS
Staff recommends the Commission issue an order approving the Company's Application
specifically:
(1)Acknowledging that the Company has complied with the conditions of Order No.33313,
which approved the transmission asset exchange,and
(2)Authorizingthe Company to stop filing annual transmission wheeling reports associated
with the Idaho Power transmission asset exchange.
Respectfully submitted this /g day of January 2022.
Technical Staff:Kathy Stockton
Kevin Keyt
Rick Keller
i:umisc/comments/pace21.21tbklskskrk comments
STAFF COMMENTS 4 JANUARY 18,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 187"DAY OF JANUARY 2022,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF,IN CASE
NO.PAC-E-21-21,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
TED WESTON EMILY WEGENER
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116 SALT LAKE CITY UT 84116
E-MAIL:[e-mail] E-MAIL:[e-mail]
DATAREQUESTRESPONSECENTER
E-MAIL ONLY:
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE