20231205Comments of the Commission Staff.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SS
[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 ROCKY MOUNTAIN )POWER'S APPLICATION TO REVISE )CASE NO.PAC-E-23-23
ELECTRIC SERVICE SCHEDULE NO.197 )
)COMMENTS OF THE
)COMMISSION STAFF
COMMISSION STAFF ("STAFF")OF the Idaho Public Utilities Commission,by and
throughits Attorneyof record,Chris Burdin,Deputy Attorney General,submits the following
comments.
BACKGROUND
On October 30,2023,PacifiCorp dba Rocky Mountain Power ("Company")filed an
application ("Application")with the Idaho Public Utilities Commission ("Commission")
requesting authorityto update Electric Service Schedule 197 ("Schedule 197").The Company
requests its Application be processed by Modified Procedure with a January 1,2024,effective
date.
The Company represents that Schedule 197 was developedto pass along a rate reduction
associated with the Tax Cuts and Jobs Act of 2017,"TCJA".Application at 1.The Company
requests to update the current Schedule 197 rate on January 1,2024,due to the remaining excess
STAFF COMMENTS 1 DECEMBER 5,2023
deferred income tax of $8.5 million being fully amortized.Id.The Company states that
Schedule 197 currentlyvaries from -0.268¢to -0.078¢per kilowatt hour ("kWh")depending on
the rate schedule.Id.The Company represents that the proposed change will result in a rate of
0.000¢per kWh for all rate schedules.Id
STAFF ANALYSIS
Staff reviewed the Company's Application,responses to Production Requests,supporting
documents,and prior cases and Commission orders.Staff recommends the Commission accept
the changes to Schedule 197 as proposed by the Company.Staff determined that all
requirements of Rule 125 have been followed by the Company when issuing customers notices
and press releases.Furthermore,Staff recommends the Commission consider any late filed
public comments.
Amortization of TCJA and Schedule 197
To record the amortization on the Company's books,the Company indicated that "the
monthly amortization is derived via a ratio of year-to-date (YTD)pre-tax book income divided
by a full year forecast of pre-tax book income".Response to Production Request No.2.The
Company then multipliesthis monthlypercentage by the "full-year forecast amortization
amount"to determine the monthly amortization amount.Response to Production Request No.2,
Attachment "IPUC 2".This results in the Company recording the amortization to their books in
the exact amount of $8.5 million over two years.
The monthly amortization recorded will differ from the credits issued to customers.The
total amount credited to each customer's bill is the product of their Schedule 197 rates and the
amount of kWh consumed.The actual amount of credits that has been returned to customers
throughOctober 2023 is indicated by the Company to be $7,970,394.Production Request No.4,
attachment "IPUC 4,16'SUPP".The Company estimates that the remaining amount to be
credited to customers through the remainder of 2023 will be $820,079based upon forecasted
consumption,bringing the final total to $8,790,473.Id.Staff believes that this forecast is
reasonable and does not anticipate this estimate to be substantially inaccurate over the fmal two
months of the year.The end result will be that the Company will slightly under-refund or over-
STAFF COMMENTS 2 DECEMBER 5,2023
refund customers,with the more likely scenario of over-refund.Staff does not have an issue
with either scenario given the immaterial impact of either result.
The settlement stipulation in Case No.PAC-E-21-07 stated:"the Parties agree to
amortize the remaining excess deferred income tax balance of $8.5 million over two years
through Electric Service Schedule No.197".Upon full amortization of the TCJA tax benefit,the
Company has submitted proposed tariff changes for Schedule 197.All customers'Schedule 197
rates would be set to $0.00,which will eliminate the schedule.Customer rates would still
comply with other authorized tariffs established in the Company's last general rate case (PAC-E-
21-07).
The Company has complied with the settlement stipulation to amortize the benefit to
customers over two years through Schedule 197.The Company has provided the necessary
information for Staff to determine that the obligation to return $8.5 million in excess deferred
income tax back to customers has been fulfilled.Staff recommends that the Commission accept
the Company's proposed changes to Schedule 197 as filed.
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 31.01.01.125.The notice was included with bills
mailed to customers beginning November 1,2023,and ending December 4,2023.
The Commission set a comment deadline of December 5,2023.As of December 4,
2023,one customer comment had been filed in opposition to the Company's proposed change
because rates will increase.Some customers in the last billing cycle may not have received
notices or had adequate time to submit comments before the comment deadline.Customers must
have the opportunityto file comments and have those comments considered by the Commission.
Staff recommends that the Commission consider comments filed late from customers.
STAFF RECOMMENDATION
Staff recommends that the Commission:
1.Authorize the Company's proposed changes to Schedule 197 as filed;and
2.Consider all comments on the record,includingthose filed late.
STAFF COMMENTS 3 DECEMBER 5,2023
Respectfully submitted this 5th day of December 2023.
Chris Burdin
Deputy AttorneyGeneral
Technical Staff:James Chandler
Curtis Thaden
i:umisc/comments/PAC-E-23-23 Comments
STAFF COMMENTS 4 DECEMBER 5,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF DECEMBER 2023,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF TO
ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-23-23,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL:[e-mail] PORTLAND OR 97232
E-MAIL:[e-mail]
DATAREQUESTRESPONSECENTER
E-MAIL ONLY:
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE