20230830Application.pdf

1407 W. North Temple, Suite 330 
Salt Lake City, UT 84116 

August 30, 2023

VIA ELECTRONIC FILING

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W Chinden Blvd.
Building 8 Suite 201A
Boise, ID 83714

Re: CASE NO. PAC-E-23-19
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
TO DECREASE THE BPA REP CREDIT EFFECTIVE OCTOBER 2023
THROUGH SEPTEMBER 2025

Dear Ms. Noriyuki:

Enclosed for electronic filing in the above-mentioned matter is Rocky Mountain Power’s
Application for approval to decrease the BPA REP credit in Electric Service Schedule No. 34
from $0.010133 per kWh to $0.007376 per kWh for qualifying customers as described in this
Application.

Informal inquiries may be directed to Mark Alder, Idaho Regulatory Affairs Manager at
[phone].

Sincerely,

Joelle R. Steward
Senior Vice President, Regulation and Customer & Community Solutions

Enclosures
CC: Terri Carlock

RECEIVED
2023 AUGUST 30, 2023 4:25PM
IDAHO PUBLIC
UTILITIES COMMISSION

Page 1
Joe Dallas (ISB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email: [e-mail]

Attorney for Rocky Mountain Power

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
DECREASE THE BPA REP CREDIT
EFFECTIVE OCTOBER 2023 THROUGH
SEPTEMBER 2025
) CASE NO. PAC-E-23-19
)
) APPLICATION OF
) ROCKY MOUNTAIN POWER
)

Rocky Mountain Power, a division of PacifiCorp (“Company” or “Rocky Mountain
Power”), in accordance with Idaho Code §61-502, §61-503, and RP 052, hereby respectfully
submits this application (“Application”) to the Idaho Public Utilities Commission (“Commission”)
to decrease the Bonneville Power Administration’s residential and small farm credit. In support of
this Application, Rocky Mountain Power states as follows:
1. Rocky Mountain Power provides electric service to retail customers in the states of
Idaho, Utah, and Wyoming. Rocky Mountain Power is a public utility in the state of Idaho and is
subject to the Commission's jurisdiction with respect to terms of electric service and prices to retail
customers pursuant to Idaho Code § 61-129. Rocky Mountain Power is authorized to do business
in the state of Idaho and provides retail electric service to approximately 88,780 customers in the
state.

Page 2
BACKGROUND
2. The Northwest Power Act of 1980 created the Residential Exchange Program
(“REP”), which is administered by Bonneville Power Administration (“BPA”). The REP provides
some of the benefits of the low-cost Columbia River Power System to participating utilities to pass
onto eligible residential, small farm and irrigation customers as credits on their electric bills.
3. Rocky Mountain Power, BPA, other investor-owned utilities, public utility districts,
and municipalities in the northwest are parties to the REP Settlement Implementation Agreement
that determined the level of REP benefits the Company receives. Through this agreement, BPA
provides REP benefits to utilities, which pass those benefits onto qualifying residential, small farm
and irrigation customers in Idaho, Oregon, and Washington.
4. Under the terms of the agreement, BPA has the right to review the Company’s
proposed eligible load and make determinations regarding the benefit eligibility of Rocky
Mountain Power’s customers. BPA has developed Customer Load Eligibility Guidelines
(“CLEG”) to provide guidance to participating utilities to help determine whether residential, small
farm, and irrigation customers are eligible to receive REP benefits.
5. To qualify to participate in the REP, BPA has provided the following CLEG
definitions: (1) A residence is a structure used by one or more persons for daily living and
associated activities; (2) A residence is eligible for REP benefits as long as its purpose is to provide
shelter on a non-transient basis (greater than 30 days); (3) A farm consists of one or more parcels
of land owned or leased by one or more persons or entities (including partnerships, corporations,
and any legal entity capable of owning farm land except the government as defined in the CLEG)
that is used primarily for agriculture; (4) Irrigation/pumping load used for farming and agricultural
purposes may receive REP benefits for up to a maximum of 222,000 kilowatt-hours per month per

Page 3
farm owner; and (5) Two or more parcels of farm land under the same ownership within the utility’s
service area, whether contiguous or non-contiguous, are treated as a single farm.
6. In 2001, parties in a BPA REP case negotiated a settlement for the allocation of
REP benefits covering the period from 2002 through 2008. This settlement was later appealed by
a group of northwest public utility districts, (“PUD”), claiming the settlement did not follow BPA’s
prescribed procedures for calculating the REP credits and that the settlement provided too large a
share of the REP benefits to investor-owned utilities (“IOUs”). The court ruled in favor of the
PUDs and ordered the parties to recalculate the REP benefits based on BPA’s prescribed
methodology.
7. During these negotiations, the Company continued to provide a REP credit to
customers, ultimately allocating more REP benefits than the Company had received from BPA,
which created a liability balance owed to the Company from customers. From 2007 until December
1, 2011, the BPA REP was cancelled for Rocky Mountain Power’s customers in Idaho.
8. Pursuant to the court order, the allocation of the BPA’s REP credit was recalculated,
and the participating IOUs were ordered to pay back the excess benefits they had received. The
agreement allowed the IOUs to refund the excess REP credits (“look back payment”) by netting
the look back payment against future REP benefits through BPA fiscal year 2021 which allowed
the IOUs to begin providing a small credit to qualifying customers. 2021 was the last year of the
look back payment.
BPA REP RATE
9. Currently Electric Service Schedule No. 34 - Pacific Northwest Electric Power
Planning and Conservation Act Residential and Farm Kilowatt-Hour Credit, (“Schedule 34”), is

Page 4
$0.010133 per kWh. This credit was established in 2021 based on an annual BPA REP credit of
$10.3 million.
10. BPA issued the final Average System Cost, (“ASC”), report for the REP for fiscal
year 2024 through 2025 (October 2023 through September 2025). While PacifiCorp’s ASC
increased, the increase was less than the other investor-owned utilities (“IOUs”). A comparison of
the ASC for the six northwest IOUs is provided in Table 1.
Table 1

11. PacifiCorp’s fiscal year 2024 through 2025 allocation of the BPA REP credit
decreased approximately $11.9 million, from $86.6 million in 2023 to $74.7 million. Idaho’s share
of PacifiCorp’s REP allocation, prior to any current balance adjustments, also decreased slightly
from 11.76 percent to 11.69 percent. The BPA REP credit available to qualifying Idaho customers
from October 1, 2023, through September 30, 2025, is $17.5 million, reduced by a negative REP
balance of $1.6 million in Idaho’s REP balancing account for a net amount of $15.86 million to
amortize over the next two years for an annual credit of $7.93 million per year. The $7.93 million
REP credit was divided by calendar year 2022 usage level of the qualifying customers of
approximately 1.07 GWh, to produce the Schedule No. 34 rate of $0.007376 per kWh.
RETAIL RATE DESIGN
12. Provided with this Application are three attachments for informational purposes: Attachment 1
summarizes the incremental increase to retail revenues associated with the BPA REP credit of
approximately $2,964,000 by rate schedule; Attachment 2 summarizes the calculation of Schedule
Utility FY2024-25 FY2022-23 Incr/(Decr)
Avista 70.61$ 62.93$ 7.68$
Idaho Power 66.03$ 58.17$ 7.86$
NorthWestern Energy 83.73$ 68.34$ 15.39$
PacifiCorp 84.08$ 77.61$ 6.47$
Portland General Electric 80.83$ 70.09$ 10.74$
Puget Sound 81.53$ 67.28$ 14.25$

Page 5
No. 34 rate; and Attachment 3 is a summary of the allocation between PacifiCorp states of the BPA
REP benefits.
COMMUNICATIONS
13. Included with this application is a copy of the press release which will be issued on August 30,
2023, and a copy of the Customer Notice which will be included with customers’ bills beginning
September 5, 2023, and will run for a full billing cycle.
14. Communications regarding this filing should be addressed to:
Mark Alder
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Email: [e-mail]

Joe Dallas (ISB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]

In addition, Rocky Mountain Power requests that all data requests regarding this
Application be sent in Microsoft Word to the following:
By email (preferred): [e-mail]

By regular mail: Data Request Response Center
PacifiCorp
825 Multnomah, Suite 2000
Portland, Oregon 97232

Informal questions may be directed to Mark Alder, Idaho Regulatory Affairs Manager at
[phone].

Page 6
MODIFIED PROCEDURE
15. Rocky Mountain Power believes that a hearing is not necessary to consider the issues presented
herein and respectfully requests that this Application be processed under Modified Procedure; i.e.,
by written submissions rather than by hearing, RP 201. If, however, the Commission determines
that a technical hearing is required, the Company stands ready to prepare and present testimony in
such hearing.
REQUEST FOR RELIEF
16. The Company respectfully requests that the Commission issue an order approving Schedule 34
credit of $0.007376 per kWh for rate schedules 1, 6A, 7A, 10, 23A, 35A and 36 effective October
1, 2023, through September 30, 2025.
WHEREFORE, Rocky Mountain Power respectfully requests that the Commission issue
an order authorizing that this matter be processed under Modified Procedure and approve the
change to Electric Service Schedule No. 34, Pacific Northwest Electric Power Planning and
Conservation Act Residential and Farm Kilowatt-Hour Credit, with an October 1, 2023, rate
effective date.

DATED this 30th day of August 2023.
Respectfully submitted,
ROCKY MOUNTAIN POWER

________________________
Joe Dallas (ISB# 10330)
825 NE Multnomah, Suite 2000
Portland, OR 97232
Telephone: [phone]
Email:[e-mail]

Attorney for Rocky Mountain Power

Exhibit 1
EXHIBIT 1
ROCKY MOUNTAIN POWER
ESTIMATED IMPACT OF PROPOSED REVENUES ON FORECAST PRESENT REVENUES
FROM ELECTRIC SALES TO ULTIMATE CONSUMERS
DISTRIBUTED BY RATE SCHEDULES IN IDAHO
HISTORIC 12 MONTHS ENDED DECEMBER 2022
Sch 34
Line Average Revenue ($000) Present Proposed Net Change
No. Description Sch. Customers MWH Present ($000) ($000) ($000) %
(1) (2) (3) (4) (5) (6) (7) (8) (9)
Residential Sales
1 Residential Service 1 60,148 596,356 68,127 ($6,043) ($4,399) $1,644 2.6%
2 Residential Optional TOD 36 10,371 176,206 17,438 ($1,785) ($1,300) $486 3.1%
3 AGA Revenue 2,602 1,219 $0 0.0%
4 Total Residential 70,519 775,164 $86,784 ($7,828) ($5,698) $2,130 2.7%
5 Commercial & Industrial
6 General Service - Large Power 6 1,134 313,326 24,875 $0 0.0%
7 General Svc. - Lg. Power (R&F) 6A 189 22,495 1,914 ($228) ($166) $62 3.7%
8 Subtotal-Schedule 6 1,323 335,821 26,789 ($228) ($166) $62 0.2%
9 General Service - High Voltage 9 18 238,732 14,047 $0 0.0%
10 Irrigation 10 5,267 615,969 55,647 ($2,431) ($1,770) $662 1.2%
11 General Service 23 8,455 209,850 19,749 $0 0.0%
12 General Service (R&F) 23A 2,562 39,844 3,931 ($404) ($294) $110 3.1%
13 Subtotal-Schedule 23 11,017 249,694 23,680 (404) (294) 110 0.5%
14 General Service Optional TOD 35 4 378 41 $0 0.0%
15 Special Contract 1 400 1 1,396,300 80,614 $0 0.0%
16 AGA Revenue (9,369) $2,176 $0 0.0%
17 Total Commercial & Industrial 17,629 2,827,525 $202,994 ($3,063) ($2,230) $833 0.4%
18 Public Street Lighting
19 Security Area Lighting 7 181 225 45 $0 0.0%
20 Security Area Lighting (R&F) 7A 121 98 23 ($1.0) ($0.7) $0.3 1.2%
21 Street Lighting - Company 11 60 187 80 $0 0.0%
22 Street Lighting - Customer 12 271 2,459 377 $0 0.0%
23 AGA Revenue (26) ($6) $0
24 Total Public Street Lighting 632 2,942 $520 ($1.0) ($0.7) $0.3 0.1%
25 Total Sales to Ultimate Customers 88,780 3,605,631 $290,298 ($10,892) ($7,929) $2,964 1.1%

Exhibit 2
EXHIBIT 2
ROCKY MOUNTAIN POWER
CALCULATION OF PROPOSED BPA CREDIT SCHEDULE 34 IN IDAHO
HISTORIC 12 MONTHS ENDED DECEMBER 2022
Total BPA Present Sch 34 Credit Proposed Sch 34 Credit
Description Sch. MWH MWH Rev ($000) (¢/kWh) Rev ($000) (¢/kWh)
(1) (2) (3) (4) (5) (6) (7) (8)
Residential
Residential Service 1 596,356 596,356 ($6,043)(1.0133)($4,399) (0.7376)
Residential Optional TOD 36 176,206 176,206 ($1,785) (1.0133) ($1,300) (0.7376)
Commercial & Industrial
General Svc. - Lg. Power (R&F) 6A 22,495 22,495 ($228) (1.0133) ($166) (0.7376)
Irrigation 10 615,969 239,948 ($2,431) (1.0133) ($1,770) (0.7376)
General Service (R&F) 23A 39,844 39,844 ($404) (1.0133) ($294) (0.7376)
Public Street Lighting
Security Area Lighting (R&F) 7A 98 98 ($1) (1.0133) ($1) (0.7376)
Total 1,450,967 1,074,946 ($10,892) (1.0133) ($7,929) (0.7376)

Exhibit 3
EXHIBIT 3llocation of Total PacifiCor REP BenefitFor FY-2024 and FY-2025B State
For October 1 2023 - Se tember 30 2024 FY-2024Total Pro osed Benefi Net REP Benefit
ualif in Initial REP Credi IOU Allocated REP Credi Current FY-202
State kWh(1)mount (2)¢/kWh mount $ ¢/kWh Balance 7-31-23 mount $
Ore on 6,475,025,299 $51,327,067 0.7927 $51,327,067 0.7927 $785,968 $50,541,099
Washin ton 1,842,662,358 $14,606,654 0.7927 $14,606,654 0.7927 $1,996,937 $12,609,717
Idaho 1,101,470,518 $8,731,279 0.7927 $8,731,279 0.7927 $1,604,039 $7,127,240
Total PacifiCor 9,419,158,175 $74,665,000 0.7927 $74,665,000 0.7927 $4,386,943 $70,278,057
Check $74,665,000 $74,665,000
For October 1 2024 - Se tember 30 2025 FY-2025Total Pro osed Benefi Net REP Benefit
ualif in mount REP Credi mount REP Credi Current FY-2025
State kWh(1)mount (2)¢/kWh mount $ ¢/kWh Balance 7-31-23 mount $
Ore on 6,475,025,299 $51,327,067 0.7927 $51,327,067 0.7927 $0 $51,327,067
Washin ton 1,842,662,358 $14,606,654 0.7927 $14,606,654 0.7927 $0 $14,606,654
Idaho 1,101,470,518 $8,731,279 0.7927 $8,731,279 0.7927 $0 $8,731,279
Total PacifiCor 9,419,158,175 $74,665,000 0.7927 $74,665,000 0.7927 $0 $74,665,000
Check $0 $0
For Two-Year Rate Period: October 1 2023 - Se tember 30 2025 BP 24NNUAL AVERAG Total Pro osed Benefi Net REP Benefit REP
ualif in mount REP Credi mount REP Credi 2-YR Rate Period Total Benefits
State kWh(1)mount (2)¢/kWh mount $ ¢/kWh Balance 7-31-23 mount $er Yea
Ore on 12,950,050,598 $102,654,134 0.7927 $102,654,134 0.7927 $785,968 $101,868,166 $50,934,083
Washin ton 3,685,324,716 $29,213,308 0.7927 $29,213,308 0.7927 $1,996,937 $27,216,371 $13,608,186
Idaho 2,202,941,035 $17,462,558 0.7927 $17,462,558 0.7927 $1,604,039 $15,858,519 $7,929,260
Total PacifiCor 18,838,316,349 $149,330,000 0.7927 $149,330,000 0.7927 $4,386,943 $144,943,057 $72,471,528

Proposed Tariffs
Ninth Eighth Revision of Sheet No. 34.1 I.P.U.C. No. 1 Canceling Eighth Seventh Revision of Sheet No. 34.1

Submitted Under Case No. PAC-E-23-19PAC-E-21-07
ISSUED: August 30, 2023November 8, 2021 EFFECTIVE: October
1, 2023January 1, 2022
ROCKY MOUNTAIN POWER ELECTRIC SERVICE SCHEDULE NO. 34 STATE OF IDAHO ______________ Pacific Northwest Electric Power Planning and Conservation Act Residential and Farm Kilowatt-Hour Credit ______________ APPLICATION AND AVAILABILITY: This Schedule is applicable and available to qualifying
Residential and/or Farm Customers of the Company under the jurisdiction of the Idaho Public Utilities Commission.
MONTHLY RATES: The monthly charges for service under each of the Electric Service Schedules shown below shall be reduced by the appropriate kilowatt-hour credit for all qualifying kilowatt-hours of residential and/or farm use. Kilowatt-Hour Credit Adjustments: Irrigation Customers: $0.00737610133 per kWh Schedule No. 10 Non-Irrigation Customers: $0.00737610133 per kWh Schedule Nos. 1, 6A, 7A, 23A 35A, 36

(continued)
Ninth Revision of Sheet No. 34.1 I.P.U.C. No. 1 Canceling Eighth Revision of Sheet No. 34.1

Submitted Under Case No. PAC-E-23-19
ISSUED: August 30, 2023 EFFECTIVE: October 1, 2023
ROCKY MOUNTAIN POWER ELECTRIC SERVICE SCHEDULE NO. 34 STATE OF IDAHO ______________ Pacific Northwest Electric Power Planning and Conservation Act Residential and Farm Kilowatt-Hour Credit ______________ APPLICATION AND AVAILABILITY: This Schedule is applicable and available to qualifying
Residential and/or Farm Customers of the Company under the jurisdiction of the Idaho Public Utilities Commission.
MONTHLY RATES: The monthly charges for service under each of the Electric Service Schedules shown below shall be reduced by the appropriate kilowatt-hour credit for all qualifying kilowatt-hours of residential and/or farm use. Kilowatt-Hour Credit Adjustments: Irrigation Customers: $0.007376 per kWh Schedule No. 10 Non-Irrigation Customers: $0.007376 per kWh Schedule Nos. 1, 6A, 7A, 23A 35A, 36

(continued)

Customer Notices
BPA Credit Adjustment to Idaho Customer Power Bills
Para más información en cómo este cambio impactará su factura, llame al 888-225-2611.
©2023 Rocky Mountain Power
Idaho Public Utilities Commission
www.puc.idaho.gov
11331 W. Chinden Blvd. Building 8,
Suite 201-A
Boise, ID 83714
Rocky Mountain Power offices
Rexburg – 127 East Main
Preston – 509 S. 2nd East
Shelley – 852 E. 1400 North
Montpelier – 24852 U.S. Hwy 89
On August 30, 2023, Rocky Mountain Power filed for an adjustment to the Bonneville Power
Administration credit in Idaho.
The company was authorized by the Idaho Public Utilities Commission to pass on a federal billing credit to
certain residential or farm customers in Idaho. The annual credit authorized for Rocky Mountain Power Idaho
customers has decreased from $10.3 million annually to $7.93 million annually. The authorized change in the
credit increases the annual power bill of a typical residential customer by $27.34. The credit will be effective from
October 1, 2023, through September 30, 2025.
The Bonneville Power Administration’s Residential Exchange Program is designed to share the benefits of the
Federal Columbia River Power System with residential and small farm customers who receive service from
investor-owned electric utilities in Idaho and other Pacific Northwest states. The program began in 1980 through
the Bonneville Power Administration, a federal power marketing agency under the U.S. Department of Energy.
The BPA benefits have significantly lowered the bills of qualifying residential and small farm customers during the
course of the program. The exchange benefits are passed directly to customers by Rocky Mountain Power and
have no effect on the utility’s revenues.
The following is a summary of the percentage impacts by customer class:
• Residential Schedule 1 – 2.6% increase
• Residential Schedule 36 – 3.1% increase
• General Service Schedule 6A – 3.7% increase
• Irrigation Service Schedule 10 – 1.2% increase
• General Service Schedule 23A – 3.1% increase
• Public Street Lighting 7A – 1.2% increase
We understand the impact that price increases have on our customers and will work to mitigate the impact of
the BPA credit change as much as possible. Customers can visit RockyMountainPower.net/Wattsmart for
tips and information on how to save energy and money.
The commission must approve the proposed changes before they can take effect. A copy of the company’s
application is available for public review on the commission’s website, www.puc.idaho.gov, under
Case No. PAC-E-23-19. Customers may also subscribe to the commission’s RSS feed to receive periodic
updates via email. The request is required to be available at the company’s offices in Rexburg, Preston, Shelley and
Montpelier, although the company urges customers to visit our website at RockyMountainPower.net/Rates
for more information.

FOR IMMEDIATE RELEASE
Media Hotline: [phone]

August 30, 2023

BPA credit adjustment to Idaho customer power bills

BOISE, Idaho—Rocky Mountain Power was authorized by the Idaho Public Utilities Commission to pass
on a federal billing credit to certain residential or farm customers in Idaho. The annual credit authorized
for Idaho customers of Rocky Mountain Power has decreased from $10.3 million annually to $7.93
million annually. The change to the authorized credit increases the annual power bill of a typical
residential customer by about $27.34 and takes effect beginning October 1, 2023 through September
30, 2025.

The Bonneville Power Administration Residential Exchange Program is designed to share the benefits of
the Federal Columbia River Power System with residential and small farm customers of investor-owned
electric utilities in Idaho and other Northwest states. The program began in 1980 through the Bonneville
Power Administration, a federal power marketing agency under the U.S. Department of Energy. The BPA
benefits have significantly lowered the bills of qualifying residential and small farm customers during the
course of the program. The exchange benefits are passed directly to customers by Rocky Mountain
Power and have no effect on the utility’s revenues.

The following is a summary of the percentage impacts by customer class:
• Residential Schedule 1 – 2.6% increase
• Residential Schedule 36 – 3.1% increase
• General Service Schedule 6A – 3.7% increase
• Irrigation Service Schedule 10 – 1.2% increase
• General Service Schedule 23A – 3.1% increase
• Public Street Lighting 7A – 1.2% increase

We understand the impact that price increases have on our customers and will work to mitigate the
impact of the BPA credit change as much as possible. Customers can visit
RockyMountainPower.net/Wattsmart for tips and information on how to save energy and money.

The commission must approve the proposed changes before they can take effect. A copy of the
company’s application is available for public review on the commission’s website, www.puc.idaho.gov,
under Case No. PAC-E-23-19. Customers may also subscribe to the commission’s RSS feed to receive
periodic updates via email. The request is required to be available at the company’s offices in Rexburg,
Preston, Shelley, and Montpelier, although the company urges customers to visit our website at
rockymountainpower.net/rates.

Idaho Public Utilities Commission Rocky Mountain Power offices
www.puc.idaho.gov
11331 W. Chinden Blvd. Building 8, Suite 201-A

– 509 S. 2nd East
– 852 E. 1400 North

# # #

About Rocky Mountain Power
Rocky Mountain Power provides safe and reliable electric service to more than 1.2 million customers in
Utah, Wyoming and Idaho. The company supplies customers with electricity from a diverse portfolio of
generating plants including hydroelectric, thermal, wind, geothermal and solar resources. Rocky
Mountain Power is part of PacifiCorp, one of the lowest-cost electricity providers in the United States,
with two million customers in six western states. For more information, visit:
www.rockymountainpower.net