20220907Comments.pdf

CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 8026
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ELECTRIC SERVICE
SCHEDULE 191 _CUSTOMER EFFICIENCY
SERVICES RATE
Street Address for Express Mail:
1 I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. PAC.E.ZZ.IO
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Claire Sharp, Deputy Attorney General, submits the following comments.
BACKGROUND
On July 8,2022, PacifiCorp d/b/a Rocky Mountain Power ("Company") applied to the
Commission for authority to increase its Electric Service Schedule l9l-the Customer
Efficiency Services Rate ("Schedule 191"), to align revenue collections with demand-side
management ("DSM") expenditures. Application at 1. If approved, the Schedule 191 rate would
increase from2.25%oto2.5%o, effective October 1,2022. Id. The Company requested its
Application be processed by Modified Procedure. If approved, this rate increase will result in an
approximate $2.76 per year increase to the average residential customer using 783 kilowatt-hours
per month.
The Company has offered DSM programs to customers since 1970. Since 2006, the
Company has recovered its DSM program costs from customers through Schedule 191.
STAFF COMMENTS SEPTEMBER 7 ,2022
As of April30,2022, the Company states that the balance for Schedule l9l is over-
collected by $255,450. However, due to increased DSM program expenses and the rollout of
new programs, the Company projects that the DSM balancing account will be $1.16 million
under-collected by the end of 2024 without adjustment. Application at3.
The Company proposes a Schedule l9l rate increase from 2.25%to2.5%o, effective
October 1,2022. Id. at 1. The Company expects a gradual alignment of the DSM balancing
account over a three-year period. Id. at 3.
Previous Changes to Schedule 191
The Schedule I9I rate was established in2O06 at arate of L5%u In May 2008, the rate
was increased to 3.72%. In July 2010, the rate increased further to 4.72%o. A few months later in
December 2010, the rate was decreased to 3.4%o after the Company began phasing the Idaho
Irrigation Load Control program costs to a system allocation rather than direct assignment to
Idaho. Two years later, the rate was decreased again to 2.loh. In March 2016, the rate increased
to 2.7Yo, and in March 2019, the rate was decreased to its current level of 2.25ohto refund an
overfunded balance over 3 years.
Previous Application to Adjust Schedule 191
On April 1,2022, the Commission rejected the Company's previous Application to adjust
Schedule l9l from 2.25%to 2.75o/o, because the Company included programs pending
Commission approval in forecasted DSM calculations. See Order No. 35363. The Commission
subsequently approved the Company's Wattsmart Battery Demand Response ("DR") program in
Case No. PAC-E-21-16, Order No. 35370, and the Company has adjusted its DSM expenditures
accordingly.
In Case No. PAC-E -21-16, Staff expressed concern that the significant cost of solar plus
battery systems may lead to the Company's Wattsmart Battery DR program not achieving is
participation estimates. Case No. PAC-E-21-16, Staff Comments at 4-5. Lowerparticipation
could affect program expenditures and result in an over-collected rider balance. Staff
recommends the Company carefully monitor the participation and expenditures of the pilot
program.
2STAFF COMMENTS SEPTEMBER 7 ,2022
The Company has not yet filed a case for approval of the Wattsmart Business DR
Program. Staff confirmed that expenses for this program are not included in the Company's
forecasted DSM expenses used to establish the 2.5o/o Schedule 191 rate proposed in this filing.
Staff encourages the Company to adjust the tariffrider accordingly when the Commission issues
an order on the Company's anticipated DR program.
STAFF ANALYSIS
Staff reviewed the Application and responses to production requests and supports the
Company's request to increase the Schedule 191 Customer Efficiency Service Rate. Staff
anticipates that the new proposed rate adjustment of 2.5oh will align the Schedule 191 revenues
with the Company's projected DSM expenditures through 2024. In its Application, the Company
provided a forecast of the DSM revenues and expenditures for the next three years (2022-2024).
See Attachment A. The Company anticipates that DSM expenditures will increase from $4.7
million in2022 to $5.3 million in2023 and $5.6 million in2024. The current Schedule l9l
revenue of $4.7 million will be insufficient to cover the Company's budgeted DSM expenditures.
As of April30,2022,the DSM balancing account was $255,450 over collected. If the
Schedule 191 rate continues at2.25Yo, while maintaining current expenditures, the balance of the
account will be $ 1 .16 million underfunded by the end of 2024. The proposed 2.5% Schedule
191 rate will provide sufficient revenue to cover the Company's forecasted expenses of its
existing programs and address the overfunded balance to customers by the end of 2024.
CUSTOMER RELATIONS
Customer Notice and Press Release
The Company's press release and customer notice were included with its Application.
Staff reviewed the documents and determined that both meet the requirements of Rule 125 of the
Commission's Rules of Procedure. IDAPA 3 I .0 I .01 . I 25. The notice was included with bills
mailed to customers in the July or August 2022billine cycles, providing customers with a
reasonable opportunity to file timely comments with the Commission by the September 7,2022,
deadline. As of August 18, no customer comments had been filed.
3STAFF COMMENTS SEPTEMBER 7 ,2022
STAX'X' RECOMMENDATION
After examining the proposed increase to Schedule 191, Staffrecommends that the
Commission approve the Company's Application and tariffs as filed, inoreasing the Schedule
191 Customer Efficiency Services Rate to 2.5%.
4 \^1
Respectfully submitted this | '
day of Septe mber 2022.
Claire Sharp
Depuff Auorney General
Technical Staff: Laura Conilogue
Jason Talford
Jolene Bossard
i:umisc./commentilpaoe22- I 0csloji$b cou$ffts
4STAFF COMMENTS SEPTEMBERT,2!022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7th DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING COMMENTS OF TIIE COMMISSION STAf,'F, IN
CASE NO. PAC-8.22.10, BY E-MAILING A COPY THEREOF, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
idahodockets@f'acifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONILY:
datareq uest@naci fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE