20220316Comments.pdf

TAYLOR BROOKS
DEPUTY ATTORNEY GENERAL
TDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11542
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ELECTRIC SERVICE
SCHEDULE l9l-CUSTOMER EFFICIENCY
SERVICES RATE
CASE NO. PAC.E.22-03
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilities Commission ("Staff'), by and
through its Attomey of record, Taylor Brooks, Deputy Attorney General, and submits the
following comments.
BACKGROUND
On January 24,2022, Rocky Mountain Power Company, a division of PacifiCorp,
("Company") applied to the Commission for authority to increase its Schedule No. 191 -
Customer Efficiency Service Rate Adjustment ("Schedule l9l"Ffrom2.25 percent to2.75
percent. Application at l. The Company states that the increase will "better align revenue
collections with demand-side management ("DSM") expenditures while gradually balancing the
deferred account associated with acquiring and administering DSM programs in Idaho over the
next three years." Id. The Company requests that its Application be processed through Modified
Procedure and take effect April I ,2022. Id.
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STAFF COMMENTS MARCH 16,2022
The Company states that it has offered a variety of DSM programs to its customers since
the 1970s. Id. at2. DSM programs are designed with the goal to be cost-effective. ^Id. On
March 2,2006, the Commission approved cost recovery of DSM programs through Schedule
l9l applied to customer bills. Id. The Company represents that its proposed increase is
consistent with the Company's previous Schedule 191 rate adjustment approved in Case No.
PAC-E-I8-12. See Order No. 34255. In that case, the Company gradually balanced the DSM
account over the 2018-2021period. Application at 3. To monitor collections of Schedule 191,
the Commission implemented an annual reporting process. Id. As of December 31, 202l,the
Company reports that its Schedule 191 balance is over-collected by $180,721. Id However, the
Company estimates that its future DSM expenditures will exceed revenue collections. .Id
The Company is an electric corporation and a public utility as defined in ldaho Code
$$ 61-119 and 6l-129. The Company is authorized to do business in the State of Idaho and
provides electric service to approximately 86,500 customers. Application at l. The Commission
has jurisdiction over the Company and this matter under ldaho Codes $$ 61 -301, -307 , -502, -
622, and -623 et seq.
The Company's Application includes a summary of the projected monthly DSM
expenditures and Schedule 191 revenues collected through December 31,2024. See Application
at Attachment A. Using the approved2.25 percentage rate the Company anticipates that by the
end of 2024, the DSM balancing account will be under-collected by $2.7 million. Application at
3. However, the Company represents that if it adjusts the Schedule 191 rate to 2.75 percerrt.,the
balancing account will be over-collected by $217,005 by the end of 2l24-assuming the DSM
expenditures each year stay consistent. Id.; see also Application at Attachment B.
The Company estimates that adjusting the Schedule 191 collection rate to 2.75 percent
would result in a $5.52 per-year increase in the average residential customer's bill.r Id. at 4; see
also Attachment D.
I The average residential customer uses 783 kilowatt-hours of electricity per month.
2STAFF COMMENTS MARCH 16,2022
STAFF ANALYSIS
Staff has reviewed the Company's Application and supports its request to increase the
Schedule No. 191 Customer Efficiency Service Rate. Staff anticipates that the new rate will
align DSM revenues with the Company's projected program expenses. The Company provided a
forecast of the DSM revenues and expenditures for the next three years (2022-2024). The
Company anticipates that DSM expenditures will increase from $4.7 million in202l to $5.7
million in2022,2023 and2024. The increase in the Company's projected DSM expenses is
largely due to the Company's "anticipated addition of the new Battery Demand Response and
Wattsmart Business Demand Response programs." Response to Production Request No. 5.
Staff confirmed that the proposed rate adjustment of 2.75 percent would align the Company's
revenue needs for DSM expenditures through 2024. The Company's proposed rate adjustment
results in a $5.52 per-year increase for the average residential customer using 783 kWh per
month. Staff also determined that the Company properly applied the new rate adjustment to
customer classes.
ln Case No. PAC-E-21-16, the Company proposed a newBattery Demand Response
program and the projected expenses of the proposed program are included in the Company's
forecasted DSM expenditures. The Company also included $750,000 in annual expenses
associated with a proposed Wattsmart Business Demand Response Program. As of March 15,
2022, the Company has not filed a case for approval of the Wattsmart Business Demand
Response Program. Staff cautions that without approval of the pending Demand Response
programs, DSM program revenues could be inflated by more than a million dollars for each of
the next three years. Staff encourages the Company to adjust the tariff rider accordingly when
the Commission issues the orders on the Company's new demand response programs.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the Company's Application to increase
the Customer Efficiency Services Rate from 2.25 percentto 2.75 percent and approve the
proposed changes to the Company's Electric Service Schedule No. 191 effective April l, 2022,
as filed.
JSTAFF COMMENTS MARCH 16,2022
4+RespecttuIly submitted this lb day of March 2022.
General
Teehnical Staff: Taylor Thomas
Ty Johnson
i:umisc/commentilpacr223tbtqi oomments
4STAFF COMMENTS MARCH 16,2U22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l6th DAY OF MARCH 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAFF, IN
CASE NO. PAC.E-22-03, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
MICHAEL SNOW
ROCKY MOI.INTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@Facifi corp.com
michael. snow@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@paci fi corLcom
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL : [e-mail]
J, ,4"e-^
SECRETARY /
CERTIFICATE OF SERVICE