20230918Comments of the Commission Staff.pdf

RECEIVED
2023 September 18 3:41PM
IDAHO PUBLIC
UTILITIES COMMISSIONCHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
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
)
)
) COMMENTS OF THE
) COMMISSION STAFF __________________ )
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission, by and
through its Attorney of record, Chris Burdin, Deputy Attorney General, submits the following
comments.
BACKGROUND
On August 30, 2023, Rocky Mountain Power, a division of PacifiCorp ("Company")
filed an application ("Application") with the Idaho Public Utilities Commission ("Commission")
to decrease the Bonneville Power Administration's ("BPA") residential and small farm credit.
The Company requests that the Commission issue an order approving a Schedule 34 Residential
Exchange Program ("REP") credit of$0.007376 per kilowatt-hour ("kWh") for rate schedules 1,
6A, 7A, 10, 23A, 35A and 36, to be effective October 1, 2023, through September 30, 2025.
The Northwest Power Act of 1980 created the REP program administered by BP A. The
REP allows participating utilities, including the Company, to pass the benefits of the Federal
STAFF COMMENTS 1 SEPTEMBER 18, 2023
Columbia River Power System to eligible residential, small farm, and irrigation customers
through rate credits.
The Company represents that the current Schedule No. 34 REP credit is $0.010133 per
kWh. Application at 3-4. The Company states that this credit was established in 2021 based on
an annual BP A REP credit amount of $10.3 million. Id. at 4.
The Company states that over the next two years the annual BP A REP credit amount will
be $7.93 million per year. Id. The Company represents that calculating the credit amount with
the number of qualifying customers produces a new Schedule No. 34 credit rate of $0.007376
per kWh. Id.
STAFF ANALYSIS
The Residential and Small Farm Energy Credit Rate results from an agreement between
the Company and BPA regarding the REP. Under the REP, BPA provides a share of the benefits
of the federal Columbia River power system to the residential and small farm customers served
by six investor-owned utilities of the Pacific Northwest, including Rocky Mountain Power. The
benefit is calculated every two years and is implemented via a credit on qualifying customers'
bills. The Company's current residential and small farm credit rate is $0.010133 per kWh. The
proposed credit rate is $0.007376 per kWh. The Company's total allocation of the BPA REP
credit for fiscal year 2024 through 2025 (October 2023 through September 2025) decreased
approximately $11.9 million, from $86.6 million in 2023 to $74.7 million. Idaho's share of the
Company's total REP allocation also decreased slightly from 11.76% to 11.69%.
The BP A REP credit available to qualifying Idaho customers 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. The REP credit is $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 gigawatt hours, to produce the Schedule No. 34 rate of
$0.007376 per kWh.
Staff verified the initial inputs and independently recalculated the rate. Staff believes that
the Company correctly calculated the rate of $0.007376 per kWh and recommends the rate be
approved.
STAFF COMMENTS 2 SEPTEMBER 18, 2023
CUSTOMER NOTICE, PRESS RELEASE AND PUBLIC COMMENTS
The Company filed its Application on August 30, 2023, requesting an October 1, 2023,
effective date. The Application included both the customer notice and a press release. Staff
reviewed the documents and determined both meet the requirements of Rule 125 of the
Commission's Rules of Procedure. See IDAPA 31.01.01.125.
Customer notices are to be included in the September billing cycle, which begins
September 5, 2023, and ends October 4, 2023, after the requested effective date and after the
deadline for customer comments of September 18, 2023. Although the Company reported that
the local TV station in Pocatello, KPVI, mentioned the rate increase and that it is available on
their website, many, if not most of the customers will not receive the customer notice before the
deadline.
The Company's Application did not offer an explanation for the delay in filing the
adjustment and denying its customers an opportunity to submit comments timely. Customers
must have the opportunity to file comments and have those comments considered by the
Commission. Staff recommends that the Commission consider late filed comments from
customers.
As of September 15, 2023 , no customer comments had been filed.
STAFF RECOMMENDATION
Staff recommends that the Commission approve the proposed Electric Service Schedule
No. 34, Pacific Northwest Electric Power Planning and Conservation Act Residential and Farm
Kilowatt-Hour Credit of $0.0073 76 per kWh effective October 1, 2023, as filed.
Respectfully submitted this 18th day of September 2023.
Chris Burdin
Deputy Attorney General
i:umisc/comments/ PAC-E-23-1 9 Comments
STAFF COMMENTS 3 SEPTEMBER 18, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HA VE THIS 18th DAY OF SEPTEMBER
COMMENTS OF THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER
COMPANY, IN CASE NO. PAC-E-23-19, BY E-MAILING A COPY THEREOF, TO
THE FOLLOWING:
MARK ALDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DAT A REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST
STE 2000
PORTLAND OR 97232
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE