20220330Farr Direct.pdf

BEFORE TEE IDAHO PI]BLIC UTILNIES COMITflSSION
IN TIIE IT{ATTER OF TIIE APPLICATION
OT' ROCI(Y MOT]NTAIN POWER
REQITESTING APPROVAL OF $28.4
MILLON NET POWER COST DEFERRAL
) cAsE NO. PAC-F,-2245
)) DTRECT TESTTMOnY OF
) JUSTIN B. X'ARR
ROCKY MOTINTAIN POWER
CASE NO. PAC.EA245
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Please state your name, business address, and present position with PaciliCorp,
dba Rocky Mountain Power ("the Company").
My name is Justin B. Farr. My business address is 1407 West North Temple Street,
Suite 330, Salt Lake City, Utah 84116. I am currently employed as Assistant Revenue
Requirement Manager.
Qualifications
Briefly describe your education and business experience.
I have a Bachelor of Science degree in Economics and a Master of Business
Administration degree from the University of Utah. I began employment at
PacifiCorp in October 2013 and have held various positions within finance and
regulation. Prior to employment at PacifiCorp, I was employed for eight years at
Energy Strategies, LLC and between 2017 and2019l led financial planning and
analysis at Magnum Development.
Please explain your responsibilities as Assistant Revenue Requirement Manager.
My responsibilities include the calculation of the Company's revenue requirement, the
preparation of business plan regulatory results and the preparation of the Company's
Renewable Energy Credit ("REC") filings in various states.
Have you testified in previous proceedings?
Yes. I have provided testimony in regulatory proceedings in Utah.
PURPOSE OF TESTIMONY
What is the purpose of your testimony?
I explain and support the Company's request, through this Energy Cost Adjustment
Mechanism (*ECAM"), for recovery of collectively $17.7 million before carrying
Farr, Di-l
PacifiCorp
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charge, for projects authorized to be included and deferred through the approved
Resource Tracking Mechanism (*RTM").These amounts are included in the ECAM as
shown in Mr. Jack Painter's Testimony, Exhibit l, line 33.
RESOURCE TRACKING MECHANISM
Please briefly describe the background and purpose of the resource tracking
mechanism (*RTM').
In Case No. PAC-E-17-06, this Commission approved a stipulation allowing the
Company to use the RTM as a component of the ECAM to recover the repowering
costs of certain Company-owned wind generation assets ("Repowered") and
incremental energy production.l Per the stipulation, the RTM and ECAM capture the
costs and benefits of the Repowered wind facilities until they are recovered in base
rates through a general rate case.
On July 20,2018, the Commission approved a stipulation in Case No. PAC-E-
17-07 allowing the Company to use the RTM and ECAM to track new investment,
energy production, and Production Tax Credits ("PTCs") associated with the Aeolus-
to-Bridger/Anticline transmission line and the Ekola Flats, TB Flats I and II, and Cedar
Springs wind projects, and related network upgrades (collectively "Energy Vision 2020
projects"), subject to a cap on the total annual costs set to the amount ofannual project
benefits.2
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I In the Matter of the Application of Rocly Mountain Powerfor Binding Rotemaking Treotmentfor llind
Repowering, Case No. PAC-E-17-06, Stipulation (November 24,2017); OrderNo. 33954 (December28,2017).
2 In the Matter of the Application of Roclcy Mounlain Power for a Certi/icate of Public Convenience and
Necessity and Binding Ratemaking treatmentfor New Wind and Transmission Facilities, Case No. PAC-E-
1707, Stipulation at 3, fl 9 (May 9,2018); Order No. 34104 (July 20,2018) (approving May 9 stipulation).j In
the Matter of Rocly Mountain Power's Application to Increase lts Rates and Charges in ldaho andfor
Approval of Proposed Electric Service Schedules and Regulations, Case No. PAC-E-20-03, Order No. 34884 at
8 (December 31,2020) ("We further find it reasonable to include Foote Creek I and Pryor Mountain wind
projects in the RTM.")
Farr, Di-2
PacifiCorp
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ln Case PAC-E-20-03 the Commission approved similar treatment for the Pryor
Mountain and Foote Creek I wind resources, matching costs and benefits with costs
capped at the benefit level.3
Which projects are included in the RTM and this ECAM?
The RTM is split into three parts, shown as Exhibit 4a,4b, and 4c to account for the
differences between the sefflement for Repowered wind assets approved as part of Case
No. PAC-E-17-06, the settlement for the Energy Vision 2020 projects approved as part
of Case No. PAC-E-17-07, and the inclusion of Pryor Mountain and Foote Creek I as
approved in Case No. PAC-E-20-3. Below is a description of the assets included in the
exhibits.
o Exhibit 4a includes the Repowered wind projects. The Repowered projects
produced an Idaho-allocated net benefit of $2.57 million.
o Exhibit 4b includes the Energy Vision 2020 projects. Together these projects
produced an Idaho-allocated net benefit of $2.43 million.
o Exhibit 4c includes the Pryor Mountain and Foote Creek I wind projects. These
combined wind projects produced an Idaho-allocated net benefit of $1.24
million.
The combination of these projects produced an ldaho-allocated net benefit of $6.24
million for customers.
3 In the Matter of Roclcy Mountain Power's Application to Increase hs Rates and Charges in ldaho andfor
Approval of Proposed Electric Service Schedules and Regulatiors, Case No. PAC-E-20-03, Order No. 34884 at
8 (December 31,2020) ("We further find it reasonable to include Foote Creek I and Pryor Mountain wind
projects in the RTM.")
Farr, Di-3
PacifiCorp
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Has the Company calculated the deferral for these projects under the RTM
guidelines that were agreed to in the stipulations and approved by the
Commission?
Yes. The deferral calculations follow the design and operation of the RTM as approved
in final Order Nos. 33954,4 34l\4,s and 34884.6 The RTM, along with the ECAM, will
capture and match all the costs and benefits of the included projects through
December 31,2021, at which time the RTM will no longer be necessary because the
capital costs will be recovered in base rates.
What are the costs and benefits associated with Repowered wind, Energy Vision
2020, Pryor Mountain and Foote Creek I that the Company has included in the
RTM deferral?
The Company has included the following items in the RTM on a monthly basis
beginning when a project is placed into service:
. The pre-tax return on investment;
. Operation and maintenance expense;
. Depreciationexpense;
. Property taxes;
. Wind taxes, if assessed;
. Net Power Cost ('NPC") benefits;
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a In the Matter of the Application Roclry Mountain Powerfor Binding Ratemaking Treatmentfor lYind
Repowering, Case No. PAC-E-I7-06, Testimony of Jeffrey K. Larsen (July 5, 2017); Stipulation (November 24,
201 7); Order No 33954 (December 28, 2017).
s In the Matter of the Application RoclE Mountain Power for Binding Ratemaking Treatmentfor Wind
Repowering, Case No. PAC-E-I7-06, Testimony of Jeffrey K. Larsen (July 5, 2017); Stipulation (November 24,
2017); Order No 33954 (December 28,2017).
6 In the Matter of RoclE Mountain Power's Application to Increase ils Rates and Charges in ldaho andfor
Approval of Proposed Electric Service Schedules and Regulatiors, Case No. PAC-E-20-03, Order No. 34884.
Farr, Di-4
PacifiCorp
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. Wheeling Revenue; and
. PTC benefits.
Has the Company prepared an exhibit showing the calculated amount of the
deferral under the approved RTM guidelines?
Yes. Exhibit No. 4a, 4b and 4c show the calculation of the December 31, 2021 RTM
deferral balance which results in a $17.7 million charge to be collected from customers
through the ECAM.
Line 18 of Exhibit No.4a and Line 17 of Exhibit No.4b and Exhibit No.4c show
that the projects included in the RTM produced a net revenue requirement of $3.1
million. Why is the Company seeking recovery of $17.7 million through the
ECAM?
The RTM was approved to match all the costs and benefits associated with the approved
projects and pass those onto customers. Absent the RTM, the ECAM only captures
some of the benefits and does not include any of the costs incurred to produce those
benefits. The ECAM will retum to customers 100 percent ofthe PTCs of $13.1 million,
and 90 percent ofNPC benefit of $10.9 million, shown on lines 2l and24fromExhibit
4a and lines 20 and 23 from Exhibit 4b and Exhibit 4c, respectively. Combined, the
ECAM would return to customers $24.0 million of benefits, absent the RTM. Due to
the sharing band in the ECAM, l0 percent of the NPC benefits would not have been
passed onto customers absent the KIM. Further, the ECAM does not capture any of the
costs incurred by the Company to Repower the wind facilities and build the Energy
Vision 2020, Pryor Mountain, and Foote Creek I wind projects. The purpose of the
RTM is to capture those costs and match them with the benefits. The $6.25 million,
Farr, Di-5
PacifiCorp
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shown on line 27 of Exhibit 4, represents Idaho's share of the net benefit produced by
these projects. The $17.7 million RTM deferral allows the Company to match and
recover the net costs associated with these projects that generate the $24.0 million
energy and PTC benefits included in the ECAM.
a. Has the Company included a carrying charge on the RTM deferral balance in
Exhibit No.4?
A. No. Since the RTM deferral balance is subject to the same carrying charge as the other
ECAM components, the monthly RTM deferral balance is summed with those other
ECAM components and the carrying charge is calculated on the total deferred balance.
a. What is the revenue requirement that is deferred for consideration in the next rate
case?
A. The settlement in Case No. PAC-E-17-07 states that "Any costs above this cap will be
deferred as a regulatory asset for recovery to be set in the next general rate case."7 The
settlement in Case No. PAC-E-20-03 has similar language, subject to a prudency
review.8 Based on the language in these settlements, the Company is deferring for
recovery in the next general rate case $2.7 million in202l on line 24.5 of Exhibit 4b,
plus the $1.6 million beginning balance as shown on line 33 of Exhibit 4b from Case
No. PAC-E-21-07, for a combined $4.3 million on line 35 of Exhibit 4b. In addition,
the Company is deferring and will seek recovery in the next general rate case
7 In the Matter of the Application of RoclE Mountain Power for a Certificate of Public Convenience and
Necessity and Binding Ratemaking treatmentfor New Wind and Transmission Facilities, Case No. PAC-E-
1707, Stipulation at 5, !f 14 (May 9,2018); OrderNo. 34104 (July 20,2018) (approving May 9 stipulation).
8 In the Matter of Rocly Mountatn Power's Application lo Increase its Rates and Charges in ldaho andfor
Approval of Proposed Electric Service Schedules and Regulations, Case No. PAC-E-20-03, Order No. 34884 at
8.
Farr, Di-6
PacifiCorp
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approximately $0.1 million from line 24.5 on Exhibit 4c related to Pryor Mountain and
Foote Creek l.
Does this conclude your direct testimony?
Yes.
Farr, Di-7
PacifiCorp
Case No. PAC-E-22-05
Exhibit No. 4
Witness: Justin B. Farr
BEFORE THE IDAHO PI.]BLIC UTILITIES COMMISSION
ROCKY MOIJNTAIN POWER
Exhibit Accompanying Direct Testimony of Justin B. Farr
March2022
Rocky Mountain Power
Exhibit No. 4 Page 1 of 3
Case No. PAC-E-22-05
\Mtness: Justin B. Farr
Line No.
PacifiCorp
ldaho - Exhibit t+a
Wnd Reporirering - Monlhly RTM Deienal Cal@lation
Rovenue Requirement
For the Month Endlng Docomber 31, 2021
$.Dollars
Plrnt Revenue Roquit€m3nl
Capilal lnveslrnent
Depreciation Reserve
Accumulated DIT Balance
Net Rate Base (previous month)
Reference
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2
3
4
Footnote 'l
Foolnote 1
Footnote 1
sum of lines 1-3
SG
SG
SG
SG
SG
SG
GPS
SG
SG
SG
SG
5
6
Pre-Tax Rate of Retum
Pre-Tax Retum on Rate Base
line 36
line 4 'line 5
7I
9
10
1'l
'12
13
17 Depreciation Eeense Adrus-fnent
18 Rev, Roquiromont
Adju3tment for ECAM Pr$-through19 PTC Revenue Requirement20 Percenlage included in ECAM (100%)
21 ECAM Pasethrough
NPC lncremental Savings
Percentage included in ECAM (90%)
ECAM Pasethrough
Wtolesale Wtleeling Revenue
Operation & Maintenance
Depreciation
Property Taxes
Wnd Tax
Total Plant Revonuo Requircmenl
Net Powar Cost
NPC lncremental Savings
PTC Bonefit
PTC Benefit
Gross up for taxes
PTC Revenue Requirement
R3v. Reqt aft.r ECAM Pr3s-through
Author'rzed Capped Dotorral
Totll Dcro]ral .lD Share
Net Customer (Benefltl
Foolnote 3
Footnote 3
line 14 '(line 34 - 1)
sum of lines 14 and l5
Fmtnote 6 & 7
sum of lines 12, 13, 16, 17
line'16
lD ECAM Sharing 0,6
line 19'line 20
line 13
lD ECAM Sharing %
line 22 'line 23
line 18 - line 21 - line 24
line 26 - line 25
Foolnote 5
sum of lines 21, 24, 26
line 32 of previous year
Foolnote 5
Footnote 3
Footnote 2
sum of lines 28-31
(1(1-tax rate))
Foohote 2
Case No. PAC-E-ltug
Rate as percent of net
plant in PAC-E-lilg
Case No. PAC-E-It09
Case No. PAC-E-IS09
Foolnote 4
Footnote 3
Footnote 3 & 6
Footnote 3
Footnote 3sm of lines &i1
5_
14
15
16
22
23
24
25
25.5
26
27
Doferral Balance - lO Shars
28 Beginning Defenal Balance29 Monthly Defenal30 Defenal Collection3l Carrying Charge32 Ending Deferral B.lance
33u
35
36
37
38
39
FederaYstate Combined Tax Rate
Net to Gross Bump up Fador = (1('l{ax rate))
Deien€d Balance Carrying Charge
Pretax Retum
Pmperty Tax Rate
24.5866%
1.3260
0.00%
9.003%
0.78%
ldsho SG Factor
ldsho GPS Faclor
6.0136%
5.7974%
Footnotes:
1) Ending monthly capital balance oflhe previous rnonth.
2) Th6 RTM deferral balance is induded in the ECAM carrying charge
calculation and is lherefore zero here.
3) Equals the monthly sum of all projects
4) Not Applicable for Repowering
5) The RTM is capped until the next general rate c€se so that, afier taking into account the
wind repow€ring benefits that will flow through the Companys ECAM, it will
not operate to surcharge @stomers.
6) Adual depreciation epense will be ad,iusted by the impacl of the retired assets
until the next depreciation study
7) Deprcciation Epense for the replaced equipmeil otnenlly in rates is removed
as an incrernental revenue requirement savings.
toEt
Company Factor Factor%ldaho Allcrte.
1,041,407,917
(60,570,060)
1i08 530 894)
62,626,1 07
(3,U2,441"
a6 526 614'
(1
54,310,298
7 ,797,255
(1
3,266,004
452,072
(27 (1,671
(41
(1,671
5,682,583
Rocky Mountain Power
Exhibit No. 4 Page 2 ot 3
Case No. PAC-E-22-05
Wtness: Justin B. Farr
PrcifiCoip
ldrho - Exhlbit,lS
EV 202G Mmthly RTM Detsnl Calolalin
Rov€nG RoquiEmant
Forthe l{onth Endlng D@mb.r 31, 2021
'.Doll.E
Lin6 No.
Pllnt RewnB Rcqulment
Capital lnvestnent Total
Cspital lnvostrnsnt abovo C8p'l Capitalin RTM2 Deprcietion Resile3 A@mulatod DIT Balane4 Net Rate Bes6 (previas month)
Refsm@
Foohoto 1
Fo&rc[e 1
Fod|d6'l
sm of lines 1-3
SG
SG
SG
SG
SG
SG
GPS
SG
SG
SG
7I
9
10
't1
12
Fofiot€ 4
Foohote 3
Fooinot€ 3 & 6
F@hote 3
F@U|ote 3
sum of lines All
5
6
Pr&Td Rat6 of Roturn
PrsTu R6tum ff Rete Base
lino 36lin64'lin65
Cas No. PAGE-21{7
Line 24.5
\ ,holesl6 Whosling Revtrue
Opo€tion & Mainbnare
D€precistion
PEperty Tuos
\Mnd Ta
ild Pomr C6t
NPC SevinOs
PTC Benrtit
PTC Benefit
Gose up ior taxa3
PTC R€venuo RoquiBmenl
13 F@hote 3
FootnoiB 3
lin€ 14'(line 37 - l)
sum of lires 14 and 15
sum of lims 12, 13, 16
lin6'16
lD ECAM Shanng %
lins 18'liElg
lim 13
lD ECAM Sharing %
lins 2'l' liB22
line 17 - line 20 - line 23
lin6 25 - line 24
Footnote 5
Final Order No. 34104
sum of lires 20, 23, 25, 26
lim 32 ol pEviow y6ar
F@hote 5
F@tsloto 3
Footnote 2
sum of lires 2&3'l
14
15
16
18
19
20
17 Rov. RcqulEmont
Adjultmont tor ECAil Pr$-thtough
PTC Revenu€ RequiBment
P€rentage includod in ECAM (10O%)
ECAM Paslthrcugh
NPC Ssvings
Pe@ntags includ.d in ECAM (90%)
ECAM Pasgthrcugh
Rov. Roqt. rflcr ECAM P$s-thrcugh
Authqiad C.pp.d mml
Totll D.fsml - lD Sh.B
Annual $300,000 Boneft p@idsd by Company
N.t C$toms (Bmcfit)
I)aiaml Brlrno - lO Sh.c28 Boginning D€teml BdaM29 Monthly Dsierel30 Defaml Colloclion31 Carrying Charga32 Endlng D.6!ml Brlrn6
D.{bml to bc colle-t d in Nrxt GRC33 Beginning Authqized Capped Def€ralU AulhorizedoappodD€ErEl35 NotAlnhorlt.d C:ppod D.f.ml
FedeEustato Cmbimd Tu Rato
N6t to GrGs Bump up Fector= (1(1-t8x Et€))
Debrsd Balan6 Canying ClE g€
ftatax Retm
ftoperty Til Rate
ldsho SG Fsctor
ldaho GPS Fectq
Cappod Capital lnvostnst Amount
21
22
23
24
24.5
25
26
27
36
37
38
39
40
4',l
42
/t3
(l(1-tax 6te))
F@trtoE 2
C8s No. PAGE-1Sg
Rate as pq6t of mt
plEnt in PACE-IS9
Cas6 No. PACE-1$09
CaEe No. PAGE-1'09
Fots|oto 7
24.5864%
1.3260
0.00%
9.234%
0.78%
6.0'136%
5.7974%
1.946.400.m0
Foohotes:
1) Ending monthly €pital balam d th€ pnvio6 month.
2) Th€ RTM defml balance is included in th8 ECAM €nying charg€
elculalitr and is th€BbB zerc he€.
3) Equals lhe mothly sum ot all prcjels
4) Vrtsling Revtrue is based m the 2021 IRP
5) Tho RTM E €pp€d stil th€ next gffeEl 6ts €se so that, afrs teking into 8@unt th€m wind gseElim bn€fits thet will nil thrcugh tho Cmpany6 ECAM, it will
not opoEte to surchatge dstqn€G.
0) Annul $300,000 Bemfit proid€d by Compeny stipulaled in Finel or&r No. 34104
7) Cepped C8pital Final Ord6r No. 341(N
Tot l
ComDanv F.ctor F.ctor ta ldrho
All@rtGd
1,837,844,681
(25,378,S68)
aR1 t70 SAAI
fi0,508,60r
(1,526,190)
13 216 o.AI
162,4(]5,2W
(ie,909,,1s8)
11,1{4,@8
9,415,7U
12,540,939
(1
670,158
3,031,8ry3
727,@9
219-sala-479
(129,785,831)
(59,883,422)
Itg 5r3lml
(7
(3,601
gs,/r06,672)(4,17s,212"
tu,3tJ.//6 5W.r6
$,n5,212)
1009(
(7
12,392,491
--(2.?U@
9.664.095
(3O0,00o)
(7,483)
9,368,095
(7,483)
9.353.124
n,627,78s)
t2.721.60'3\
Rocky Mountain Power
Exhibit No. 4 Page 3 of 3
Case No. PAC-E-22-05
VMtness: Justin B. Farr
PecifiCorp
ldaho - Exhlblt.lc
Pryor Mountain & Foote Creek l- Monthly RTM Defenal Calculation
Revenue Requirement
For the Month Ending Decembot 31, 2021
$-Dollars
Line No.Referonce
1
2
3
4
5
6
Plsnt Revenue RgqulrEment
Capital lnvesitment
Depreciation Reserve
Accumulated DIT Balance
Net Rate Base (previous month)
Foohote'l
Footnote 1
Footnote 'l
sum of lines l-3
SG
SG
SG
SG
SG
SG
GPS
SG
SG
SG
Pre-Tax Rale of Retum
Pre-Tax Relum on Rate Base
line 36
line4'line5
7I
9
10
11
12
Foohote 4
Footnote 3
Footnote 3 & 6
Footnote 3
Footnote 3
sum of lines &i l
Vvholesale \/vheeling Revenue
Operation & Maintenance
Depreciation
Property Taxes
Wnd Tax
Total Plant Rev6nue Requiromcnt
Not PowEr Co3t'13 NPC Savings
PTC Benelit14 PTC Beneft15 Gross- up for taxes16 PTC Revenue Requirement
17 Rev, Requlrement
Adju3tment for ECAM Pass-through18 PTC Revenue Requirement19 Percentage induded in ECAM (10O%)20 ECAM Pass-through
Footnote 3
Footnote 3
line 14'(line 33 - 1)
sum of lines l4 and 15
sum of lines 12,'13, 16
line 16
lD ECAM Sharing %
line 18 ' line 19
line 13
lD ECAM Sharing o/o
line 21 'line 2?.
line 17 - line 20 - line 23
line 25 - line 24
Footnote 5
sum of lines 20, 23, 25
Iine 31 of previous year
6
5.
6
21
22
?3
NPC Savings
Percentage induded in ECAM (90%)
ECAM Pass-through
ReY. Reqt aftor ECAM Pas3-through
Authorized Capped Detenal
Total Deferral - lD Shar€
Net Cuotomer (Benelit)
Deferral Balance - lD Share
Beginning Deferral Balance
Monthly Deferral
Defenal Colledion
Carrying Charge
Ending Deferral Balance
Federal/State Combined Tax Rate
Net to Gross Bump up Fador = (1(1-tax rate))
Defened Balance Carrying Charge
Pretax Retum
Property Tax Rate
ldaho SG Fador
ldaho GPS Fador
(1/(1-tax rate))
Foolnole 2
Case No. PAC-E-1S09
Rate as percent of net
plant in PAC-E-'l $09
Case No. PAC-E-1 5-09
Case No. PAC-E-1t09
24
24.5
25
26
27
28
29
30
31
32
33
34
35
36
37
38
Footnole 5
Footnote 3
Footnote 2
sum of lines 27-30
24.5866%
1.3260
0.00%
9.2y%
O.78o/o
6.0136%
5.7978Yo
Footnotes:
1) Ending monlhly capital balance of the previous monlh.
2) The RTM deferral balance is induded in the ECAM carrying ciarge
calculation and is therefore zero here.
3) Equals the monlhly sum of all projects.
4) Not Applicable for Pryor Mountain & Foote Creek I projeds.
5) The Amount of Recovery for Pryor Mountain and Foote Creek I to be induded in the next general rate case so that, afler taking into account the
wind generation benefits that willflolr through the Company's ECAM, it wall nol operate to surdrarge @$omers.
Jan - Dec 202t
Totirl
Company Fector Factor96 ldaho Allocatod
388,870,851
(s,ss1,849)
(9.618.3051
23,385,1 38
(333,866)
(578.406)
373,700,697
9.231o/a
22,472,885
9.234o/o
34,507,2AA
1,908,457
14,143,607
560,808
2,075,130
't14,767
850,540
32,515
3,Olz,tt z
(43,647,488)
(19,626,250)
r6.398.6341
(2,624,785)
(1,180,244)
(384.788)
(26,024,EE4)(1,565,O32)
16,55:l,2't2 (1,1 1n,6oo)
(1,565,032)
10006
(1,565,032)
(2,624,785\
900/6
(2.362.3071
2,81O,473
(127,162
2,6u3,311
t'l.244.u2}J
2,683,311