20220330Painter Direct.pdf

BEFORE TTTE IDAIIO PI]BLIC UTILITIES COMIVIISSION
IN THE MATTER OT'THE APPLICATION
OT' ROCI(Y MOTINTAIT{ POWER
REQUESTING APPROVAL OF $28.4
MILLON NET POWER COST DEFERRAL
) cAsE NO. PAC-E-?:,0'
)) DIRECT TESTIMONY OF
) JACKPAINIER
ROCKY MOIINTNN POWER
cAsE NO. PAC-8a245
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Please state your name, business address, and present position with PacifiCorp
d/b/a Rocky Mountain Power (*Rocky Mountain Power" or the "Company").
My name is Jack Painter and my business address is 825 NE Multnomah Street, Suite
600, Portland, Oregon 97232. My title is Net Power Cost Specialist.
QUALIFICATIONS
Please describe your education and professional experience.
I received a Bachelor of Arts degree in Business Administration with a Finance major
from Washington State University in 2007.1have been employed by PacifiCorp since
2008 and have held positions in the regulation and jurisdictional loads departments. I
joined the regulatory net power costs group in2019 and assumed my current role as a
net power cost specialist in 2020.
Have you testified in previous regulatory proceedings?
Yes. I have previousiy provided testimony to the public utility commissions in Utah,
ldaho, Wyoming, Oregon, and Washington.
PURPOSE OF TESTIMONY
What is the purpose of your testimony in this proceeding?
My testimony presents and supports the Company's calculation of the Energy Cost
Adjustment Mechanism ("ECAM") balancing account for the l2-month period of
January l, 2021 through December 31,2021 ("Deferral Period"). More specifically, t
provide the following:
. A summary of the ECAM calculation, including changes made to comply with
Commission orders;
. Details supporting the addition of approximately $28.4 million to the deferral
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balance, including $10.7 million customers'share of ECAM costs, $5.4 million
Lake Side 2 Resource Adder, a $6.1 million increase in renewable energy
production tax credits ("PTCs"), $17.7 million resource tracking mechanism
("RTM") deferral, $535 thousand in reasonable energy price ("REP") qualified
facility ("QF") and energy imbalance market ("EIM") body of state regulators
("BOSR") costs, $102 thousand renewable energy credit ("REC") revenue
differentia l, and $226 thousand interest accrued ;
. Discussion of the main differences between adjusted actual net power costs
("Actual NPC") and net power costs in rates ("Base NPC"); and,
. Discussion about the Company's participation in the energy imbalance market
with the California Independent System Operator ("CAISO") and the benefits
from EIM that are passed through to customers.
What other witnesses present testimony for the ECAM and Thriff Schedule 94 in
this case?
Mr. Robert M. Meredith, Director, Pricing & Tariff Policy, provides testimony on the
proposed rates in Electric Service Schedule No. 94, Energy Cost Adjustment
("Schedule 94") and Mr. Justin B. Farr, Assistant Revenue Requirement Manager,
provides testimony on the RTM.
SUMMARY OF THE ECAM DEFERRAL CALCULATION
Please briefly describe the Company's ECAM authorized by the Commission.
In general, the ECAM tracks deviations between Actual NPC and Base NPC and defers
90 percent of the difference for later recovery.l Other items, described in detail later in
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I See Order No. 30904 in Case No. PAC-E-08-08 and Order No. 33,140 in Case No. PAC-E- 15-09.
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my testimony, are also tracked in the ECAM to true-up the amount in base rates to
actuals. These items include a resource adder for the Lake Side 2 gas generation plant,
PTCs, RTM deferral, and revenues from the sale of RECs.2 The balance that
accumulates over a defenal period is then passed on to customers as a rate surcharge
or credit. Schedule 94, described in Mr. Meredith's testimony, appears as a separate
Iine item on customers' bills, collects from or credits to customers the balance of
deferred costs. Schedule 94 is adjusted as needed in the Company's annual ECAM
filings.
The Company is required to file an application with the Commission annually
byApril I't to seek approval of the deferral amount and the new Schedule 94 rates,
which become effective June I't.
Are there any changes to the ECAM calculation?
Yes. The depreciation regulatory asset balancing account has been removed from
Exhibit No. I in the ECAM deferral calculation pursuant to Commission Order No.
34754,3 which affirmed parties' stipulation that the "Company would also stop
deferring incremental depreciation expense from PAC-E-13-02 currently recovered in
the Energy Cost Adjustment Mechanism effective December 31,2020."
ECAM DEFERRAL CALCULATION
Please describe the calculation of the ECAM deferral included in this filing.
Table I provides a summary of the total ECAM deferral and a breakdown of the
individual components of the ECAM. Exhibit No. I presents the detailed monthly
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2 See In the Matter of PacifiCorp DBA Rocly Mountain Powerb Application to Modify the Energr Cost
Adjustnent Mechanism and Increase Rates,PAC-E-15-09, Order No. 33440 at 5-6 (December 23,2015).
3 In the Matter of the Application of Rocly Mountain Power for Authorization to Change Depreciation Rates
Applicable to Electic Property, Case No. PAC-E-18-08, Order No. 34754 at 3, 7 (August 18,2020).
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calculation of the ECAM deferral.
Table I -2021ECAM Deferral
NPC Differential
EITF 04-6 Adjustrcnt
LCAR
Total Deferral Before Slnring
SluringBard
C ustonrer Reponsbility
Lake SiJe 2 Resource Adder
Production Tax Credits
RTM Adjustnent
REP QF/EIM BOSR Adjrctnent
REC Deferral
Interest on Defrrral
Annual Defenal (Jan - Dec202l)
$13,040,849
(144,329)
(1,026,323)
$ t 1,870,197
90%
10,683,178
5,431,705
(6,086,042)
17,733,989
535,1I I
(101,687)
225,928
$ 28,422,182
$
$
The first section of Table I summarizes the ldaho-allocated share of those items for
which Idaho customers and the Company share responsibiliry including: NPC
differential, Emerging Issues Task Force ("EITF") 04-6 adjustment, and load change
adjustment revenue ("LCAR") costs. The next section calculates the 90 percent
customers' share of these items and adds the following items which are refunded or
collected in full (i.e., 100 percent):. the Lake Side 2 resource adder, PTCs, RTM
deferral, REP QF and EIM BOSR costs, REC revenues, and interest on the deferral.
The total of these items equals the ECAM deferral.
Based on your calculations, what is the balance expected to be in the ECAM
deferral account as ofJune 112022?
The projected balance in the ECAM deferral account as of June l, 2022, is
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approximately $25.3 million. Table 2 summarizes the ECAM balancing account
activity starting with December 31, 2020,ECAM defenal balance of $19.1 million
approved in Case No. PAC-E-21-09. Approximately $28.4 million is added to the
balance from the annual defenal and interest during the Deferral Period, offset by
$17.5 million of ECAM revenue collections through the Deferral Period plus an
estimated collection of $4.6 million Schedule 94 revenues, net of interest, between
January and May of 2022.
Ihble 2 -Account
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Please describe the ECAM calculations in Exhibit No. 1.
The ECAM deferral is calculated monthly by comparing ldaho-allocated Actual NPC
to the Base NPC collected in rates and deferring the differences into an ECAM
balancing account. ExhibitNo. I includes details of the ECAM calculation.l have also
provided confidential work papers supporting this exhibit.
I{ow are the Base NPC and Actual NPC calculated?
The monthly Base NPC collected in rates, as set forth in Exhibit No. I line 6, is
calculated by taking the dollar-per-megawatt-hour Base NPC rate multiplied by the
actual Idaho retail sales. The Actual ldaho NPC, as set forth in Exhibit No. I line 15, is
calculated by dividing the monthly total Company Actual NPC in the Deferral Period
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ECAM Deferral Balance
Deftrral Bahrrce - Dec 31, 2020
Annual Deftrral (Jan - Dec 2021)
Interest
ECAM Revenue Collection - Scheduh 94
December 3l,2021 Balance For Collection
Schedule 94 Collectbn - Jan - May2022
lnterest
ExpectedBalance as ofJune 112022
29,940,189$
$
$ 25,309244
$ 19,050,233
28,196,254
225,928
(t7,532,227)
(4,745,587)
114,642
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by the actual monthly system megawatt-hours ("MWh") in the Deferral Period. The
total Company Actual NPC dollar-per-megawaff-hour basis is then multiplied by Idaho
actual monthly MWh to calculate Actual Idaho NPC.
Please describe how the NPC deferral is calculated.
The deferral is calculated monthly by subtracting the Base NPC collected in rates from
the Actual Idaho NPC. For the Deferral Period, the NPC differential was $13.0 million
before applying the 90 / l0 percent sharing.
What costs are included in the NPC differential for deferral?
The NPC differential for deferral captures all components of NPC as defined in the
Company's general rate case proceedings and modeled by the Company's production
dispatch model the Generation and Regulation Initiative Decision Tool ("GRID").
Specifically, Base NPC and Actual NPC include amounts booked to the following
Federal Energy Regulatory Commission ("FERC") accounts:
Account 447 - Sales for resale; excluding on-system wholesale sales and other
revenues that are not modeled in GRID
Account 501 - Fuel, steam generation; excluding fuel handling, start-up fuel
(gas and diesel fuel, residual disposal), and other costs that are
not modeled in GRID
Account 503 - Steam from other sources
Account 547 - Fuel, other generation
Account 555 - Purchased power; excluding the Bonneville Power
Administration ("BPA") residential exchange credit pass-
through if applicable
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Account 565 - Transmission of electricity by others
Are adjustments made to the Actual NPC before comparing them to Base NPC?
Yes. The Company adjusts Actual NPC to reflect the ratemaking treatment of several
items, including:
. out of period accounting entries booked in the Deferral Period that relate to
operations before implementation of the ECAM on July 1,2009;
. buy-through of economic curtailment by intemrptible industrial customers;
. revenue from a contract related to the Leaning Juniper wind resource;
. situs assignment of the generation from Oregon solar resources procured to
satisfu Oregon Revised Statute ("ORS") 757.370 solar capacity standard;
. situs assignment of Oregon allocated amortization related to a prepaid
wheeling expense;
. situs assignment of certain Utah solar resources and Schedule 32 and 34
contract costs;
. coal inventory adjustments to reflect coal costs in the correct period;
. legal fees related to fines and citations included in the cost of coal;
. adjustments related to liquidated damages that occurred outside the Deferral
Period (all liquidated damage fees per a coal supply agreement are booked
in accordance with generally accepted accounting principles);
. an adjustment for costs related to participation in the Western Power Pool's
("WPP") Western Resource Adequacy Program ("WRAP"); and,
. reasonable energy price adjustments to QFs.
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Why is the Juty 112009, cutoff used to determine out of period entries?
Since the ECAM took effect, customers'rates have been adjusted to recover essentially
all of the Company's actual net power costs, excluding any differences due to the 90 /
l0 percent sharing band. Consequently, any accounting entries made during the current
Deferral Period that relate to any operating period since the ECAM took effect, should
also be reflected in customer rates, whether they increase or decrease Actual NPC.
Accounting entries related to operating periods before the inception of the ECAM
should not impact the ECAM deferral.
What is the Western Power Pool ("WPP") Western Resource Adequacy Program
(*WRAP',X
The WPP WRAP is the new regional resource adequacy initiative that is being
implemented by many utilities and power producers across the west to ensure that the
region is better able to plan for its regional resource adequacy needs.
Please explain the WPPWRAP Fee.
There are three main components of the WRAP fee that are necessary to meet the
Company's resource adequacy requirements for the WPP WRAP. First, the WPP
WRAP provides facilitation and coordination services, which include the use of staff
resources provided by WPP Corporation in connection with the Phase 34, Scope of
Work. Second, WPP bills the participants the expenses the WPP Corporation incurs
directly to perform the Phase 34, Scope of Work, including costs associated with
contracting for a Program Operator. Finally, there are binding program preparation
costs including preparation for FERC filings, setting up an independent board and
preparing the WPP Corporation to undertake the obligations required to house the
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program as a public utility under the Federal Power Act.
Please describe the adjustment to the ECAM for the WPPWRAP Fees.
The total-Company cost for the Deferral Period was $129,720 and the Idaho allocated
share in the ECAM is $7,092 including interest.
In addition to comparing Actual NPC to Base NPC, what other components are
included in the ECAM?
Seven additionalcomponents are included in the ECAM calculations: (i) an adjustment
for deferred costs associated with coal mine stripping activities recorded under the
Financial Accounting Standards Board ("FASB") EITF 04-6; (ii) the LCAR
adjustment; (iii) a resource adder to collect the investment in the Lake Side 2 natural
gas generation facility; (iv) a true-up of PTCs; (v) the resource tracking mechanism
deferral; (vi) Idaho allocated REP QF and EIM BOSR costs; and (vii) a true-up of REC
revenues as authorized in Order No. 32196.
How is the adjustment for accounting pronouncement EITF 04-6 included in the
ECAM?
The calculation of coal stripping costs on Line 17 of Exhibit No. I reflects Idaho's
allocated differences between the coal stripping costs incurred by the Company during
excavation and recorded on the Company's books pursuant to the guidance of the
accounting pronouncement EITF 04-6, and the amortization of the coal stripping costs
as approved by the Commission in Case No. PAC-E-09-08, Order No. 30987. For the
Deferral Period, the total EITF 04-6 coal stripping deferral adjustment is a
$144 thousand decrease to the ECAM deferral balance before the 90 / l0 percent
sharing.
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Please describe the LCAR adjustment.
The calculation of the LCAR adjustment is a symmetrical adjustment for over- or
under-collection of the energy-related portion of the Company's embedded revenue
requirement for production facilities as specified in Case No. GNR-E- I 0-03, Order No.
32206. The LCAR accounts for variances in ldaho load that cause the Company to
collect more or less of these production-related costs. The LCAR rate of $5.54 per
MWh is used for the Deferral Period.
How is the LCAR adjustment calculated and what impact does it have on the
Deferral Period?
The LCAR adjustment assumes that the actual production-related costs of the LCAR
are equal to base, Exhibit No. I line 18. The actual production-related costs are then
compared to the LCAR revenue collection in rates, calculated by multiplying the LCAR
rate by the actual Idaho retail sales, Exhibit No. I line 21. The LCAR adjustment is the
difference between the actual production-related costs and the LCAR revenue, line 22
of Exhibit No. l, and is a $1.0 million decrease to the ECAM deferral balance before
the 90 / l0 percent sharing.
Please explain the sharing ratio between the Company and customers in the
ECAM.
The ECAM includes a symmetrical sharing ratio in which customers either pay or
receive 90 percent of the ECAM deferral balance, and the Company is responsible for
the remaining l0 percent. Line 24 of Exhibit No. I represents the customers' 90 percent
share of the monthly deferral shown on line 23 of Exhibit No. l. For the Deferral
Period, the customers'share of the deferred balance is $10.7 million. The remaining
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balance of $1.2 million associated with the Company's l0 percent share is not included
in the deferral balance as it is not recoverable from customers.
a. What is the amount of the Lake Side 2 resource adder in the current filing?
A. Pursuant to the stipulation in Case No. PAC-E-13-04, approved by Commission Order
No. 32910, the Company included a resource adder to recover the investrnent in the
Lake Side 2 generation plant which was not included in base rates during the Deferral
Period. The resource adder amounts to $1.99/\4Wh of the Lake Side 2 generation
capped at2,729,500 MWh or $5.4 million for the calendar year. The total Lake Side 2
resource adder on line 27 of Exhibit No. I for the Deferral Period was $5.4 million
based on3,292,396 MWh of generation, but limited to 2,729,500 MWh due to the cap.
a. What is the amount of the PTC true-up in the current filing?
A. The PTC Deferral, on line 32 of Exhibit No. l, is calculated by comparing the actual
ldaho-allocated PTC to the PTC customers receive through base rates. The PTC credit
in base rates is calculated by multiplying the approved PTC rate of $1.99/\rlWh by
Idaho retail sales. The difference is a $6.1 million decrease to the ECAM deferral.
a. Please explain the RTM deferral.
A. The RTM deferral, on line 33 of Exhibit No. l, is calculated per ExhibitNo. 4 described
in Mr. Farr's testimony. The RTM deferral during calendar year 2021 is $17.7 million.
0. Please explain the REP QFAdjustment.
A. As set forth in the2020 Protocol (*2020 Protocol"): "Forthe Interim Period, the energy
output of New QF PPAs will be dynamically allocated per this agreement using the SG
Factor, priced at a forecasted reasonable energy price defined below, and any cost ofa
New QF PPA above the forecasted reasonable energy price will be situs assigned to and
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allocated to the State of Origin."a The Idaho situs allocated cost in the ECAM is
$528 thousand.
Please explain the purpose of the EIM BOSR.
The EIM BOSR is a body that addresses the regional nature of the EIM through the
EIM governance process. The purpose of the EIM BOSR is to provide "a forum for
state commissioners to (l) select a voting member of the EIM Governing Body
Nominating Committee, (2) leam about and discuss the EIM and CAISO markets, and
(3) express a common position in CAISO stakeholder processes or the EIM Governing
Body on EIM issues."s
Please describe the new fee that is associated with the EIM BOSR.
As described by the EIM BOSR, the fee supports the BOSR's expenses and supportthe
body's goal that "consistent, and informed regulator engagement on regional market
operations and developments is crucial to efficient and sustainable markets that deliver
public benefits."6
Please describe the adjustment to the ECAM for the EIM BOSR Fees.
The ldaho allocated cost in the ECAM is $7,517.
What is the amount of REC revenue adjustment in the current filing?
The REC revenue adjustment, on line 39 of Exhibit No. l, is calculated by comparing
the actual ldaho-allocated REC revenue to the REC revenue credit customers receive
through base rates. The REC revenue credit in base rates is calculated by multiplying
a In the Matter of the Applicationfor Approval of the 2020 PaciJiCorpJnterjurisdictional Allocation Protocol,
Case No. PAC-E-19-20, OrderNo. 34640 atS 4.4.2.1,31 (April 22,2020).
5 EIM BOSR Energt Imbalance Marlrel Body of State Regulators,Western Interstate Energy Board ofoc2022),
https://www.westernenereyboard.ore/enerey-imbalance-market-body-of-state-resulators/.
6 ibid.
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the approved REC revenue rate of $0.0944Wh by tdaho retail sales. The difference is
a $102 thousand decrease to the ECAM deferral.
What is the total ECAM deferred balance calculated in Exhibit No. 1?
The total ECAM deferred balance as of December 31,2021,is $28.2 milliono shown
on line 40 plus $226 thousand of interest on line 50 of ExhibitNo. l, for atotal deferral
of $28.4 million.
Does the calculation of the ECAM deferral in this application comply with the
parameters of the Idaho ECAM as approved by the Commission?
Yes. Therefore, the Company recommends the Commission approve the ECAM
application for recovery of the $28.4 million prudently incurred ECAM costs.
DITT'ERENCES IN NPC
On a total-Company basis, what was the difference between Actual IYPC and Base
NPC for the Deferral Period?
On a total-Company basis, Actual NPC for the Deferral Period were $1.723 billion,
exceeding Base NPC for the Deferral Period by $238 million. Table 3 provides a high-
level summary of the difference between Base NPC and Actual NPC by category on a
total-Company basis.
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I Thble 3 - Net Power Cost Reconciliation ($ millions)
TOTAL
Base NPC s 1,485
Increase(Decrease) to NPC :
Who lesale S ales Revenue
Purchased Power Erpense
Coal Fuel Expense
Natural Gas Expense
Wheeling and Other Eryense
Total Incrc ase(De crcas e )
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$238
Adjusted Actual NPC $ 1,723
Please describe the Base NPC the Company used to calculate the NPC component
of the ECAM deferral.
The Base NPC were set in Case No. PAC-E-16-12 and became effective
January 1,2017. Base NPC used the l2-month test period of January 2016 through
December 2016 and set total-Company Base NPC at $1.485 billion.
Please describe some of the weather events that impacted NPC.
2021 was characterized by many extreme and unforeseeable weather events.
Collectively, they shaped actual NPC throughout the year. For instance, the Company
experienced a significant impact to NPC with the Western North America heat wave, a
13 day long extreme weather event that occurred between June 25, 2021 andJuly 7,
2021 that saw a temperature peak of ll9 degrees Fahrenheit in the Western United
States and had a significant impact on market prices for June and July as compared to
the same period in2020.
Additionally, ongoing drought has caused negative effects to NPC
because it impacts the availability of hydro resources . ln 2021 , actual generation from
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hydro resources were 1,022p72 MWhs, or 27 percent lower, than forecasted
generation. Unrealized hydro MWhs need to be replaced to meet customer demand
through system dispatch of other resources, reducing market sales, increasing market
purchases or any combination of these options. The estimated impact to total-Company
NPC of the decreased hydro MWhs due to drought is $48.9 million.
Please describe the primary differences between Actual NPC and Base NPC.
From an accounting perspective, and as shown in Table 3, Actual NPC were higher than
Base NPC due to a $153 million reduction in wholesale sales, a $l5l million increase
in purchased power expense, a $67 million increase in natural gas expense and a
$15 million increase in wheeling and other expenses. The items were partially offset
by a $148 million reduction in coal fuel expense.
Please explain the changes in wholesale sales revenue.
Wholesale sales revenue declined relative to Base NPC due to higher market prices and
a reduction in the wholesale sales volume of market transactions (represented in GRID
as short-term firm and system balancing sales). Of the $153 million decrease to
wholesale sales, revenue from market transactions represents the largest change to Base
NPC. Market transactions are $142 million lower than Base NPC due to higher market
prices and lower volume of market sales transactions. The average price of actual
market sales transactions was $13.96/T\{Wh, or 60 percent, higher than the average
price in Base NPC. Actual wholesale market volumes were 8,693 gigawatt-hours
("GWh"), or 66 percent, lower than the Base NPC. In addition, an expired contract
accounted for $9 million of the decrease in wholesale sales revenue.
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a. Please explain the changes in purchased power expense.
A. As the most significant driver, expenses from market transactions (represented in GRID
as short-term firm and system balancing purchases) increased by $184.8 million
compared to Base NPC. Actual market purchases were 2,768 GWh (39 percent) lower
than Base NPC, but the average price of actual market purchases transactions was
$57.60/IvIWh (230 percent) higher than Base NPC with the biggest impact tied to the
Westem North America heat wave in June and July and further compounded by
drought.
With the heat wave in June and July, compared to the same period in 2020, the
Mid-Columbia market hub saw an average increase in high load hour market prices of
620 percent and 560 percent respectively while the Four Corners market hub saw an
average increase in high load hour market prices of 464 percent and 150 percent,
respectively. The impact of higher market prices results in a NPC variance of $10.5
million above Base NPC on an Idaho-allocated basis.
Additionally, purchased power expense increased by $l5l million with a
$l2l million increase (57 percent) in QF transactions, partially offset by the expiration
of a long-term purchase power contract. Actual QF transaction volumes were
1,891 GWh (53 percent) higher than Base NPC. The expiration of the Hermiston
purchase power agreement ("PPA") reduced purchased power costs by $31.3 million.
a. Please explain the changes in wheeling expenses.
A. The increase in wheeling expenses relative to Base NPC was primarily due to an
increase in short-term firm wheeling expense of $11.8 million.
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0.
A.
Please explain the changes in coal fuel expense.
Coal fuel expense decreased because coal generation volume decreased 7,510 GWh
(19 percent) compared to Base NPC. Two closures with a 5,115 GWh (68 percent)
reduction in generation volumes significantly impacted the overall decrease. The
closure of Cholla in December 2020 represents a decrease of 2,391GWh (32 percent),
while the closure ofNaughton 3 as a coal unit in January 2019 combined with its higher
average actual cost of generation represents a decrease of 2,725 GWh (36 percent).
While the average cost of coal generation increased from $19.96lMWh in Base NPC
to $20.03/IvIWh in the Deferral Period, the lower generation volume results in an
overall decrease of $148 million in coal fuelexpense.
Please explain the changes in natural gas fuel expense.
The total natural gas fuel expense in Actual NPC increased by $67 million compared
to Base NPC mainly due to an increase in average cost of natural gas generation from
$23.0644Wh in Base NPC to $26.404dwh in the Deferral Period. Additionally, there
was an increase in gas generation volumes of 963 GWh (eight percent).
Natural gas market prices were also impacted by extreme weather events in
2021. Atthe Opal natural gas trading hub, average market prices in June and July 2021
as compared to the same period in 2020 were ll5 percent and 135 percent higher
respectively. Overall, gas prices at Opal were 137 percent higher in202l as compared
to2020.
Painter, Di-17
Rocky Mountain Power
a.
A.
I
)
3
4
5
6
7
8
9
a.
A.
o.
A.
IMPACT OF PARTICIPATING IN TIIE EIM
Are the actual benelits from participating in the EIM with CAISO included in the
ECAM deferral?
Yes. Participation in the EIM provides benefits to customers in the form of reduced
Actual NPC. The EIM benefits are embedded in Actual NPC through lower fuel and
purchased power costs. For 2021, CAISO's EIM benefits report shows $115.5 million
in EIM benefits for PacifiCorp and $391.4 million since the inception of the EIM.
Please summarize your testimony.
The ECAM deferral of $28.4 million, including interest, for the Deferral Period, was
accurately calculated in compliance with previous Commission orders. Therefore, I
respectfully request that the Commission approve this application as filed with rates
effective June l, 2022.
Does this conclude your direct testimony?
Yes.
Painter, Di-18
Rocky Mountain Power
l0
11
t2
13 a.
t4 A.
CaseNo. PAC-E-22-05
Exhibit No. I
Witness: Jack Painter
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ROCKY MOI.JNTAIN POWER
Exhibit Accompanying Direct Testimony of Jack Painter
March2022
Rod<y Mountain Power
Exhibit No. 1 Page 1 of 1
Case No. PAC-E-22-05
Wtness: Jack Painter
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