20120420Iverson Direct.pdf

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EFORE THE IDAHO PUBLIC UTILITIES
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR AUTHORITY )
TO INCREASE RATES BY $2.6 MILLION TO ) CASE NO. PAC-E-12-03
RECOVER DEFERRED NET POWER COSTS )
THROUGH THE ENERGY COST ADJUSTMENT )
MECHANISM )
Direct Testimony of
Kathryn E. Iverson
On Behalf of
Monsanto Company
April 19, 2012
Project 9578
=
kIJ&UEL &ASSOaATES INC.
—
ROCKY MOUNTAIN POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-12-03
Table of Contents to the
Direct Testimony of Kathryn E. Iverson
I.INTRODUCTION AND QUALIFICATIONS ..................................................................I
II.PURPOSE OF TESTIMONY AND SUMMARY OF CONCLUSIONS ............................ 2
Ill. BASE LOADS FROM CASE NO. PAC-E-1O-07 .......................................................... 4
IV. ACTUAL LOADS ....................................................................................................... 12
Appendix A
Exhibits:
Exhibit 200 - Idaho Base Load by Month As Calculated By the Company
Exhibit 201 - Corrected Split of Idaho Base Loads
Exhibit 202 - PAC-E-10-07 Base Loads: Comparison of Company and
Corrected
Exhibit 203 - Idaho Actual Load by Month As Calculated By the Company in Its
Reply Comments
Exhibit 204 - Idaho Actual Load by Month Adjusted for "Extra" Losses
Exhibit 205 - Idaho ECAM Deferral With Corrected Base Loads and Actual
Loads
ROCKY MOUNTAIN POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC-E-12-03
Direct Testimony of Kathryn E. Iverson
I I. INTRODUCTION AND QUALIFICATIONS
2 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3 A My name is Kathryn E. Iverson; 17244W. Cordova Court, Surprise, Arizona 85387.
4 Q WHAT IS YOUR OCCUPATION AND BY WHOM ARE YOU EMPLOYED?
5 A I am a consultant in the field of public utility regulation and employed by the firm of
6 Brubaker & Associates, Inc. (BAt), regulatory and economic consultants with
7 corporate headquarters in St. Louis, Missouri.
8 Q WOULD YOU PLEASE STATE YOUR EDUCATIONAL BACKGROUND AND
9 EXPERIENCE?
10 A I have a Bachelor of Science Degree in Agricultural Sciences and a Master of
11 Science Degree in Economics from Colorado State University. I have been a
12 consultant in this field since 1984, with experience in utility resource matters, cost
13 allocation and rate design. More details are provided in Appendix A to this testimony.
14 Q ON WHOSE BEHALF ARE YOU TESTIFYING IN THIS PROCEEDING?
15 A I am appearing on behalf of Monsanto Company ("Monsanto"), a special contract
16 customer of Rocky Mountain Power ("RMP" or "Company").
Iverson, Di— I
Monsanto Company

I II. PURPOSE OF TESTIMONY AND SUMMARY OF CONCLUSIONS

2 Q WHAT IS THE PURPOSE OF YOUR TESTIMONY?

3 A On February 1, 2012 the Company filed for authority to establish the energy cost

4 adjustment mechanism ("ECAM") rate for all customer classes including Monsanto

5 and Agrium, Inc. ("Agrium") based on the deferral period beginning December 1,

6 2010 through November 30, 2011. This ECAM filing is the first time for including

7 Monsanto and Agrium loads in calculating the ECAM balances. See Direct

8 Testimony of Greg Duvall, page 10. Monsanto filed comments on the Company's

9 filing on March 19, 2012.1 The Company filed reply comments on March 22, 2012.

10 On March 30, 2012 the Commission filed Order No. 32507, and an errata to that

11 order on April 3, 2012.

12 The purpose of my testimony is to provide supporting technical detail on

13 Monsanto's Motion for Reconsideration of the Commission's Order. In this testimony,

14 I will: (1) explain the actual and base loads used by the Company in its ECAM filing,

15 (2) discuss why those loads are in error, and (3) provide the corrected ECAM

16 amounts to Monsanto, Agrium and the other Idaho tariff customers based on the

17 corrected loads.

18 Q ARE YOU SPONSORING ANY EXHIBITS IN CONNECTION WITH YOUR
19 TESTIMONY?

20 A Yes. I am sponsoring Exhibit 200 through Exhibit 205. These exhibits were

21 prepared either by me or under my supervision and direction.
On March 30, 2012, Monsanto also filed a "Reply" to RMP's reply comments. As noted in Order No.
32507 at page 9, Monsanto's "Reply" was not considered because it was filed after the Commission's
deliberations had been made in this case and because procedural Rules do not provide a party to
respond to a Reply. In that "Reply", Monsanto attempted to present to the Commission the line loss
issue adjustments discussed in this testimony and the excess outage adjustment discussed in the
testimony of Mark Widmer.
Iverson, Di —2
Monsanto Company

Q WOULD YOU PLEASE SUMMARIZE YOUR FINDINGS AND CONCLUSIONS?

2 A My findings and conclusions are as follows:

3 Base Loads from Case No. PAC-E-10-07

4 • A fundamental issue before the Commission in this proceeding is how to properly

5 split the monthly Idaho jurisdictional base load among customer classes (i.e., the

6 McDougal monthly energy amounts shown on page 10.14 of his Exhibit No. 2 in

7 Case No. PAC-E-10-07). The Company's filing does not accurately split base

8 loads between Monsanto, Agrium and the remaining tariff customers.

9 • The Company failed to remove buy-back or replacement energy from the Idaho

10 jurisdictional base load, thus the tariff customer base load has been unfairly
11 overstated by 30,964 MWH of buy-back or replacement energy in Load Change

12 Adjustment Revenues portion of the ECAM.

13 • The Company has used an incorrect base load of Monsanto at meter which does

14 not comport with Order No. 32196 of Case No. PAC-E-10-07.

15 • In Case No. PAC-E-10-07, the Company testified there were losses included in

16 Mr. McDougal's Idaho jurisdictional base load not associated with Idaho retail

17 sales. Those "extra" losses must be fairly allocated to all customer classes for

18 purposes of splitting the base loads between Monsanto, Agrium and the

19 remaining tariff customers.

20 • The Company has unfairly and arbitrarily increased the base loads of Monsanto
21 and Agrium by a loss factor not reflective of their service. The Company's use of

22 the 9.88% loss factor effectively requires Monsanto and Agrium alone to pick up

23 the costs of the "extra" losses.

24 • I recommend that monthly adjustments be made to monthly customer energy at

25 input from Case No. PAC-E-10-07 in order to fairly bring all customer classes to

26 the Idaho jurisdictional base load used by the Company in the ECAM filing. This

27 adjustment will fairly treat all customer classes and allocate the "extra" losses to

28 all customer classes without arbitrarily penalizing or benefitting either Monsanto,

29 Agrium or the remaining tariff customers.

30 Actual Loads
31 • Likewise, the monthly actual loads must also be adjusted to account for additional

32 losses in order for the Load Differential to be a proper comparison. Without this

33 adjustment to both the base and actual loads, the Load Differential would in effect

34 be a comparison of apples to oranges.

35 • As a result of correcting the base loads and adjusting the actual loads, the tariff

36 customers ending balance is $16,252,752, or a reduction of $14,523 from the

37 Company's Revised Exhibit I which was attached to its March 22, 2012 reply

38 comments. Monsanto's ending balance is $6,848,532 (a reduction of $407,631

39 from the Company's Revised Exhibit 1) and Agrium's ending balance is $476,156

40 (a reduction of $41,402 from the Company's Revised Exhibit 1). The ending
41 balances for Monsanto and Agrium are before amortization.
Iverson, Di —3
Monsanto Company
III. BASE LOADS FROM CASE NO. PAC-E-10-07
I Q WHAT BASE LOADS ARE USED BY THE COMPANY IN ITS ECAM FILING?
2 A The Company used Idaho jurisdictional monthly base loads which were taken from
3 page 10.14 of Exhibit No. 2 to Mr. Steven McDougal's direct testimony in Case No.
4 PAC-E-1 0-07.
5 Q WERE THESE IDAHO JURISDICTIONAL MONTHLY BASE LOADS SPLIT
6 BETWEEN CUSTOMER CLASSES IN CASE NO. PAC-E-10-07?
7 A No, they were not. Only a total Idaho jurisdictional number was presented in Mr.
8 McDougal's Exhibit No. 2, page 10.14 for each of the months.
9 Q DO YOU AGREE THESE ARE THE CORRECT BASE LOADS FOR PURPOSES
10 OF THE ECAM FILING?
11 A Yes, I agree with these monthly base load amounts in total as the starting point.
12 However, those monthly base loads by themselves are insufficient for purposes of the
13 ECAM calculation. First, the monthly base load amounts must have replacement
14 energy (i.e., buy-through energy) removed since those sales are not a component of
15 the ECAM. Second, the monthly Idaho base load amount must be split into three
16 customer classes: Monsanto, Agrium and the remaining tariff customers. The
17 Company has erred in both these steps.
18 Q PLEASE EXPLAIN WHY REPLACEMENT ENERGY SHOULD BE REMOVED
19 FROM BASE LOADS.
20 A The Company has agreed, and the Commission ordered, that replacement energy
21 (also known as buy-through energy) consumed by Monsanto when it buys through
22 curtailment events rather than physically curtail its load should not be a part of ECAM.
Iverson, Di —4
Monsanto Company
I See Order No. 32507, pages 7 and 10. The Company has correctly removed the

2 replacement energy from both the Monsanto and Idaho jurisdictional actual loads, as

3 well as the Monsanto base load. However, it has not removed the replacement

4 energy from the Idaho jurisdictional base load. I calculate that this error causes the

5 tariff customers' base load to be higher by 30,964 MWH, and erroneously raises the

6 tariff customers' Load Change Adjustment Revenues by approximately $279,000.
7 Q PLEASE EXPLAIN WHY MR. MCDOUGAL'S IDAHO JURISDICTIONAL MONTHLY

8 ENERGY SALES MUST BE SPLIT BETWEEN MONSANTO, AGRIUM AND

9 TARIFF CUSTOMERS.

10 A As described in the testimony of Mr. Gregory Duvall in this case, the ECAM balances

11 for Monsanto and Agrium must be tracked separately through their three-year

12 amortization periods. See Duvall Direct, page 10. Furthermore, one of the

13 components of the ECAM is the Load Change Adjustment Revenues where base

14 loads are compared to actual loads in order to ascertain monthly Load Differentials

15 which are then multiplied by the LCAR (Load Change Adjustment Rate). Since Case

16 No. PAC-E-10-07 did not split Mr. McDougal's Idaho jurisdictional base loads

17 between customers, it is critical to develop a method for doing so in this ECAM
18 proceeding.
19 Q HOW HAS THE COMPANY SPLIT THE BASE LOAD INTO THE THREE
20 CUSTOMER CLASSES, THAT IS, MONSANTO, AGRIUM AND TARIFF
21 CUSTOMERS?
22 A The easiest way to explain how the Company has done this split is to simply walk
23 through their calculations. Exhibit 200 shows each of the Company's steps in
24 splitting the McDougal monthly energy into the three classes. The Company first
Iverson, Di —5
Monsanto Company

I starts on line I with the McDougal Idaho jurisdictional monthly base loads. Line 2 is

2 what the Company believes is Monsanto's base loads at the meter. Line 3 is the loss

3 factor applied to Monsanto's base loads, and Line 4 is Monsanto base load at input .2

4 Line 5 is Monsanto's replacement or buy-through energy at meter, and Line 6 is again

5 the loss factors and Line 7 the replacement energy at input.3 Line 8 is Line 4 plus

6 Line 7 and is what the Company uses as Monsanto's monthly base loads.4

7 Lines 9, 10 and 11 depict Agrium's loads at meter, losses, and load at input,

8 respectively. Line 11 is what RMP uses for Agrium's base loads.5

9 Line 12 is the tariff customer's component and it is Line I minus Line 8 minus

10 Line 11.6 This clearly demonstrates how the Company failed to exclude the

11 replacement energy from the Idaho jurisdictional load

12 Q DO YOU AGREE THAT MONSANTO LOADS SHOWN ON LINE 2 OF EXHIBIT 200

13 REFLECT THE BASE LOADS OF CASE NO. PAC-E-10-07?

14 A No. The Company pulled line 2 from row 41 of sheet "Energy-2010" from Attachment

15 1. 18, a spreadsheet that was provided in Response to Monsanto Data Request 1.18

16 in Case No. PAC-E-10-07. The Company should have pulled Monsanto's loads from

17 row 59 instead. Consequently, the Company understated Monsanto's base loads at
18 meter in their ECAM filing. Even though this understatement is against Monsanto's
2 Note that my line 4 matches the Company's "Monsanto Total MWh at Input" shown on RMP's sheet
"ID Base Load" found in Revised Exhibit I attached to their reply comments.
Note that my line 7 matches the Company's "Monsanto Replacement MWh" shown on RMP's sheet
"ID Base Load" found in Revised Exhibit I attached to their reply comments.
Note that my line 8 matches the Company's "Total Monsanto Load" shown on RMP's sheet "ID Base
Load" found in Revised Exhibit I attached to their reply comments.
Note that my line 11 matches the Company's "Agrium El Paso Sub MWh at Input" shown on RMP's
sheet "ID Base Load" found in Revised Exhibit I attached to their reply comments.
6 Note that my line 12 matches the Company's "Idaho Tariff Load at Input" shown on RMP's sheet "ID
Base Load" found in Revised Exhibit I attached to their reply comments.
Iverson, Di —6
Monsanto Company
I favor, I believe in all fairness that this error should be pointed out to the Company and
2 the Commission.
3 Q HOW DO YOU KNOW RMP UNDERSTATED MONSANTO'S BASE LOAD PRIOR
4 TO THE REMOVAL OF BUY-THROUGH ENERGY?
5 A It is easily verifiable with Attachment A from Order No. 32196 of Case No. PAC-E-10-
6 07. Attachment A shows Monsanto's total energy use at the meter (including
7 replacement energy) for the test period was 1,385,173 MWH. This matches row 59 of
8 RMP's Response to Monsanto Data Request 1. 18, Attachment 1.18. The Company's
9 Monsanto load used in the ECAM filing, on the other hand (Line 2 of Exhibit 200),
10 totals only 1,363,100 MWh.
11 Q DO AGREE WITH THE REPLACEMENT (I.E., BUY-THROUGH) ENERGY SHOWN
12 ON LINE 5 OF EXHIBIT 200 FOR CASE NO. PAC-E-10-07?
13 A Yes. I agree the Company has pulled the correct information for replacement energy
14 at meter from Case No. PAC-E-10-07.
15 Q DO YOU AGREE WITH THE LOSS FACTORS SHOWN ON LINES 3,6 AND 10 OF
16 EXHIBIT 200 FOR CASE NO. PAC-E-10-07?
17 A No. The Company's use of a loss factor of 9.884906% for Monsanto and Agrium is
18 unsupportable. This is in direct contrast to losses of 3.605% used in Case No. PAC-
19 E-10-07 for transmission customers, and to losses of 3.605% used for their actual
20 load in the ECAM.
Iverson, Di —7
Monsanto Company

I Q WAS THERE ANY COMMISSION ORDER THAT CAME OUT IN CASE NO. PAC-E-

2 10-07 THAT FOUND MONSANTO AND AGRIUM'S LOSSES TO BE 9.884906%?

3 A No.

4 Q WHAT IS THE DIRECT CONSEQUENCE OF USING A LOSS FACTOR OF 3.605%

5 ON THE ACTUAL LOADS AND 9.884906% ON BASE LOADS FOR MONSANTO

6 AND AGRIUM?

7 A Because of the two different loss factors, even if actual loads were 100% exactly

8 equal to base loads, there would still be a load change adjustment cost of over

9 $820,000 to Monsanto and of over $60,000 to Agrium. That is, even if Monsanto and

10 Agrium's actual usage was exactly equal to the base load assumed in the general

11 rate case, these customers would still pay a significant LCAR component of the

12 ECAM. This is a totally unacceptable consequence of the Company's ECAM

13 calculations that is neither fair, reasonable or just.

14 Q HOW DO YOU PROPOSE TO SPLIT THE MCDOUGAL IDAHO JURISDICTIONAL

15 MONTHLY BASE LOADS FOR PURPOSES OF THE ECAM CALCULATION?

16 A I believe the most fair, reasonable and just method to split the loads is to start from

17 the monthly base loads provided by the Company in the class cost of service study at

18 the meter and at input. Those monthly amounts are shown in Exhibit 201. Lines 1-6

19 show the loads at meter which match Attachment I to Order No. 32196 of Case No.

20 PAC-E-10-07. Lines 7-12 show the loads at input which reflect the losses as ordered

21 in that general rate case: Monsanto and Agrium at 3.605%, primary losses of 6.475%

22 and secondary losses of 10.418%.
Iverson, Di —8
Monsanto Company
I Q LINE 13 OF YOUR EXHIBIT SHOWS MR. MCDOUGAL'S MONTHLY IDAHO
2 JURISDICTIONAL BASE LOAD ENERGY. DO HIS MONTHLY IDAHO
3 JURISDICTIONAL ENERGY AMOUNTS MATCH THE MONTHLY BASE LOADS
4 AT INPUT SHOWN ON LINE 12?
5 A No, and we should not expect the two to match.
6 Q WHY IS THAT?
7 A In Case No. PAC-E-10-07, Mr. McDougal explained that there were losses included in
8 his monthly Idaho jurisdictional base loads which were not associated with Idaho
9 retail sales. He claimed that those "extra" losses were associated with moving energy
10 for wholesale sales that benefitted all Idaho ratepayers. See page 41 of Mr.
11 McDougal's Rebuttal testimony.
12 Those "extra" losses total 94,791 MWh over the entire year as shown on line
13 14, column (13). The "extra" losses as a percentage adjustment to energy at input,
14 vary from roughly 0% in February to a high of 6% in March.
15 As an example, let's look at January. In Case No. PAC-E-10-07, the total
16 energy sales at input was 287,186 MWh which we can easily split out as Monsanto at
17 131,255 MWh, Agrium at 9,791 MWh and tariff customers at 146,140 MWh. These
18 amounts tie back to Attachment A to the order in that case and the losses agreed to
19 in that case. Mr. McDougal's monthly Idaho jurisdictional load, however, is 293,666
20 MWh, or 2.26% higher than energy sales at input. The only fair way to allocate those
21 "extra" losses of 6,480 MWh (293,666 - 287,186) is to adjust all customer classes'
22 enemy at input by the same 2.26%, so that all classes are sharing the "extra" losses
23 based on their energy at input. For January, this means Monsanto, Agrium and the
24 tariff customer base loads at input are all raised by 2.26% so that Monsanto is now at
25 134,216 MWh, Agrium at 10,012 MWh and tariff customers at 149,438 MWh.
Iverson, Di —9
Monsanto Company

I Q WHY DO YOU SAY THIS IS THE ONLY FAIR WAY?

2 A If those "extra" losses are arbitrarily assigned to just Monsanto and/or Agrium through

3 a simple 9.88% jurisdictional wide loss factor, as the Company has done, Monsanto

4 and Agrium would be unfairly burdened with the "extra" losses in every month. We

5 know that Monsanto and Agrium have the lowest losses of all Idaho jurisdictional

6 customers because they take service at transmission voltage. Yet the Company's

7 arbitrary assignment of 9.88% losses to Monsanto and Agrium ignores this

8 fundamental fact as well as ignores the monthly variation in losses. The only fair way

9 to allocate the "extra" losses is to apply the monthly adjustments to each class's

10 energy at input such that all customers share equitably the cost of those extra losses.

11 Looked at another way, the Company 9.88% loss factor to Monsanto and

12 Agrium can be broken down as a 3.605% loss factor for the transmission losses, and

13 another "extra" loss factor of 6.061 %7 each and every month to recover those "extra"

14 losses associated with moving energy for wholesale sales. Based on Monsanto and

15 Agrium's loads at input, that's an additional 91.597 MWh 8 of "extra" losses the

16 Company has allocated to Monsanto and Agrium - or almost 97% of Mr.

17 McDoucial's total "extra" losses of 94,791 MWh. Clearly, the Company's method
18 results in an unfair and unreasonable burden to Monsanto and Agrium and should be
19 rejected.
(1.03605)x (1.06061) = 1.09884906.
6.061% x (1,511,192 MWh of Monsanto and Agrium including transmission losses of 3.605%) =
91,597 MWh. Furthermore, even if we use the Monsanto loads at meter that the Company
erroneously thought was correct (1,363,100 less 28,015 MWh), RMP has still allocated 90,207 MWh of
those "extra" losses just to Monsanto and Agrium. [(1,335,085 Monsanto + 101,450 Agrium)] x
1.03605 x 6.061% = 90,207 MWh.
Iverson, Di - 10
Monsanto Company

I Q PLEASE CONTRAST YOUR PROPOSED SPLIT OF MR. MCDOUGAL'S

2 MONTHLY IDAHO JURISDICTIONAL LOADS WITH THE COMPANY'S.

3 A Exhibit 202 shows the monthly base loads for both the Company's as well as my

4 corrected figures. Note that my corrected figures have removed the replacement

5 energy from the tariff customers and furthermore fairly allocates the "extra" losses to

6 all customer classes.

7 Q IN ORDER NO. 32507, THE COMMISSION FOUND ON PAGE 9 THAT "ONCE

8 MONSANTO'S BASE LOAD IS ESTABLISHED IN A GENERAL RATE CASE AND

9 EMBEDDED IN BASE RATES, IT SHOULD NOT BE CHANGED IN THE ECAM."

10 DOES YOUR SPLIT OF MR. MCDOUGAL'S MONTHLY IDAHO JURISDICTIONAL

11 LOADS IN ANY WAY CHANGE BASE LOADS AS ESTABLISHED IN THE

12 GENERAL RATE CASE?

13 A No, it does not, and if anything, it corrects the incorrect base loads the Company has

14 used for Monsanto in the ECAM filing. Furthermore, as I explained previously, Mr.

15 McDougal's monthly Idaho jurisdictional base load was not split by customer class in

16 the general rate case, so it is necessary to perform that step in the ECAM filing. My

17 proposal is an improvement upon the Company's since it: (1) removes replacement

18 energy from the tariff customers, (2) is based on the customer loads found in

19 Attachment A to Order No. 32196, (3) reflects the appropriate losses to all customer

20 classes, and most importantly, (4) allocates the "extra" losses for moving wholesale

21 sales to all customer classes on the basis of their energy at input.
Iverson, Di - 11
Monsanto Company
I IV. ACTUAL LOADS
2 Q WHAT ACTUAL LOADS HAS THE COMPANY USED IN ITS ECAM FILING?
3 A Exhibit 203 shows the actual loads calculated by RMP in its revised Exhibit I
4 attached to its reply comments. The Company corrected the transmission loss factor
5 for Monsanto and Agrium to 3.605%, and properly removed replacement energy from
6 both the jurisdictional total as well as Monsanto.
7 Q DOES THIS MEAN YOU AGREE WITH THE COMPANY'S ACTUAL LOAD
8 CALCULATION FOR PURPOSES OF THE ECAM?
9 A No. Since base loads include "extra" losses associated with moving energy for
10 wholesale sales, unless the actual loads have been likewise adjusted there will be a
11 mismatch between the base loads and actual loads. In other words, since we must
12 compare base loads to actual loads for purposes of the LCAR, we must ensure that
13 we are comparing apples to apples. If the base loads have been increased upwards
14 for those "extra" losses associated with moving energy for wholesale sales, then we
15 must likewise adjust the actual sales each month to account for "extra" losses. The
16 adjusted actual sales are shown in my Exhibit 204.
17 Q WHAT ARE THE RESULTS OF THE ECAM WITH YOUR CORRECTIONS TO
18 BASE LOAD AND ACTUAL LOADS?
19 A Exhibit 205 provides the calculation of the ECAM ending balances with corrected
20 loads. Note that these calculations are based on the Company's Revised Exhibit I
21 from their reply comments, and do not take into account other adjustments (such as
22 wind integration) the Commission ordered be made to the ECAM. Furthermore,
23 Exhibit 205 does not take into account the excess outages adjustment which Mr.
Iverson, Di— 12
Monsanto Company
I Widmer has made in his testimony accompanying Monsanto's Motion for
2 Reconsideration.
3 Table I presents the results of my corrected loads and compares this to the
4 ECAM ending balances filed by the Company in its reply comments.
TABLE I
ECAM Ending Balances
RMP's Revised
Exhibit I Corrected Change
Tariff Customers $16,267,275 $16,252,752 ($14,523)
Monsanto 7,256,163 6,848,532 (407,631)
Agrium 517,558 476,156 (41,402)
Total $24,040,996 $23,577,440 ($463,556)
5 Q DOES THIS CONCLUDE YOUR TESTIMONY IN THIS CASE?
6 A Yes.
Iverson, Di - 13
Monsanto Company
Appendix A
Kathryn E. Iverson
Page 1
Qualifications of Kathryn E. Iverson
I Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A Kathryn E. Iverson; 17244 W. Cordova Court, Surprise, Arizona 85387.
3 Q PLEASE STATE YOUR OCCUPATION.
4 A I am a consultant in the field of public utility regulation with Brubaker & Associates,
5 Inc., energy, economic and regulatory consultants.
6 Q PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND WORK
7 EXPERIENCE.
8 A In 1980 I received a Bachelors of Science Degree in Agricultural Sciences from
9 Colorado State University, and in 1983, I received a Masters of Science Degree in
10 Economics from Colorado State University.
11 In March of 1984, I accepted a position as Rate Analyst with the consulting
12 firm Browne, Bortz and Coddington in Denver, Colorado. My duties included
13 evaluation of proposed utility projects, benefit-cost analysis of resource decisions,
14 cost of service studies and rate design, and analyses of transmission and substation
15 equipment purchases.
16 In February 1986, I accepted a position with Applied Economics Group, where
17 I was responsible for utility economic analysis including cogeneration projects,
18 computer modeling of power requirements for an industrial pumping facility, and
19 revenue impacts associated with various proposed utility tariffs. In January of 1989, I
20 was promoted to the position of Vice President. In this position, I assumed the
21 additional responsibilities of project leader on projects, including the analysis of
22 alternative cost recovery methods, pricing, rate design and DSM adjustment clauses,
BRUBAKER & ASSOCIATES, INC.
Appendix A
Kathryn E. Iverson
Page 2

I and representation of a group of industrial customers on the Conservation and Least

2 Cost Planning Advisory Committee to Montana Power Company.

3 In March 1992, I accepted a position with ERG International Consultants, Inc.,

4 of Golden, Colorado as Senior Utility Economist. While at ERG, I was responsible for

5 the cost-effectiveness analysis of demand-side programs for Western Area Power

6 Administration customers. I also assisted in the development of a reference manual

7 on the process of Integrated Resource Planning including integration of supply and

8 demand resource, public participation, implementation of the resource plan and

9 elements of writing a plan. I lectured and provided instructional materials on the key

10 concept of life-cycle costing seminars held to provide resource planners and utility

11 decision-makers with a background and basic understanding of the fundamental

12 techniques of economic analysis. My work also included the evaluation of a marginal

13 cost of service study, assessment of avoided cost rates, and computer modeling

14 relating engineering simulation models to weather-normalized loads of schools in

15 California.

16 In November of 1994, I accepted a position with Drazen-Brubaker &

17 Associates, Inc. In April, 1995 the firm of Brubaker & Associates, Inc. was formed. It

18 includes most of the former DBA principals and Staff. Since joining this firm, I have
19 performed various analyses of integrated resource plans, examination of cost of
20 service studies and rate design, fuel cost recovery proceedings, as well as estimates

21 of transition costs and restructuring plans.
22 Q HAVE YOU EVER TESTIFIED BEFORE A REGULATORY BODY?
23 A Yes. I have testified before the regulatory commissions in Colorado, Georgia,
24 Michigan, Montana, Oregon, Texas, Washington and Wyoming.
BRU BAKER & ASSOCIATES, INC.
ROCKY MOUNTAIN POWER
Idaho Base Load By Month As Calculated By the Comøanv
PAC-E-08-07 PAC-E-10-07
--- --- ......- ............. - ............ - ... -------- ..... - ..... ---- ...... ----- ... ........ ---- ........... ........ - ............. ------- ...... - .... - ..... - ..... - ......... - ............ ---- ......... -----...... PAC-E-10-07
Description Dec-08 Dec-10 Jan-10 Feb-10 Mar-10 Apr-10 May-10 Jun-10 Jul-10 Aug-10 Sep-10 Oct-10 Nov-10 Jan-Dec 10
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14)
Idaho Load atInput 287.203 280,662 293,666 246,395 269,155 262,615 314,969 361,447 420,354 376,659 292,587 269,155 264,722 3,652,385
2 Monsanto Total MVvh at Meter
3 Loss Factor
4 Monsanto Total MVVh at Input
5 Monsanto Replacement MWn at Meter
6 Loss Factor
7 Monsanto Replacement MIMi
8 Total Monsanto Load
9 Agrium El Paso Sub MIMi at Meter
10 Loss Factor
11 Agrium El Paso Sub MIMi at Input
12 Idaho Tariff Load at Input (In l-1n8-lnhl)
102,600 113,000 126,100 107,000 113,000 113,000 113,000 113,000 113,000 113,000 113,000 113,000 113,000
1.04543 1.09864906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09864906
107,261 124,170 138,565 117,577 124,170 124,170 124,170 124,170 124,170 124,170 124,170 124,170 124.170
(8,241.0) (7,651.4) - (81.4) - (53.6) (107.2) (3,806.0) (1,786.0) (1,889.0) (2,904.4) (3,581.4) (6,154.2)
1.04543 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906
(8,615) (8,408) - (89) - (59) (118) (4,182) (1,963) (2,076) (3,191) (3,935) (6,763)
98,646 115,762 138,565 117,487 124,170 124,111 124,052 119,988 122,207 122,094 120,978 120,235 117.407
10.157 8,500 9,450 8,500 8,500 8,500 8,500 7,000 8,500 8,500 8,500 8,500 8,500
1.04543 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906 1.09884906
10,618 9,340 10,384 9,340 9,340 9,340 9,340 7,692 9,340 9,340 9,340 9,340 9,340
177,939 155,560 144.717 119,568 135,644 129,164 181,576 233,768 288,806 245.224 162,268 139,580 137,975
1.363,100
1,497,841
(28,015)
(30,784)
1,467,057
101,450
111,478
2,073,850
Note: The two December amounts are prorated: 27 days of the Dec 2008 amounts, and 4 days of the Dec 2010 amounts
Exhibit _(200)
Page 1 of I
ROCKY MOUNTAIN POWER
Corrected Split of Idaho Base Loads
Aug Nov Dec Total (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13)
Idaho Class Loads from PAC-E-10-07 at meter
1 Monsanto Load At Meter 126,688 107,469 113,268 113,351 113,354 114,426 117,990 118,022 114,371 114,534 116,169 115,532 1,385,173
2 Monsanto Replacement - 81 - 54 107 3,806 1,786 1,889 2,904 3,581 6,154 7,651 28,014
3 Monsanto without replacement 126,688 107,387 113,268 113,297 113,247 110,621 116,204 116,133 111,467 110,952 110,015 107,881 1,357,159
4 Agrium At Meter 9,450 8,500 8,500 8,500 8,500 7,000 8,500 8,500 8,500 8,500 8,500 8,500 101,450
5 Tariff Customer At Meter 133,310 115,339 116,591 117,153 159,999 212,041 255,821 216,102 143,355 116,118 116,260 137,162 1839,250
6 Total AtMeter 269,448 231,308 238,359 239,003 281,853 333,467 382,311 342,624 266,226 239,151 240,929 261,194 3,325,873
Idaho Class Loads from PAC-10-07 at input
7 Monsanto Load AtInput 131,255 111,343 117,351 117,437 117,440 118,551 122,244 122,277 118,494 118,662 120,357 119,697 1435,109
8 Monsanto Replacement - 84 - 56 111 3,943 1,850 1,957 3,009 3,711 6,376 7,927 29,024
9 Monsanto without replacement 131,255 111,259 117,351 117,381 117,329 114,608 120,393 120,320 115,485 114,952 113,981 111,770 1,406,085
10 Agrium At Input 9,791 8,806 8,806 8,806 8,806 7,252 8,806 8,806 8,806 8,806 8,806 8,806 105,107
11 Tariff Customer At Input 146,140 126,348 127,744 128,267 175,456 232,823 281,094 237,289 157,253 127,184 127,401 150,380 2,017,378
12 Total At Input 287,186 246,498 253,901 254,510 301,702 358,626 412,144 368,372 284,554 254,653 256.565 278,883 3,557,594
13 McDoupal's Base Loads 293,666 246,395 269,155 262,615 314,969 361,447 420,354 376,659 292,587 269,155 264,722 280,662 3,652,385
14 Additional Losses for Wholesale Energy 6,480 (103) 15,253 8,105 13,266 2,821 8,210 8,286 8,033 14,502 8,158 1,779 94,791
15 Adjustment to Loads AtInput 2.26% -0.04% 6.01% 3.18% 4.40% 0.79% 1.99% 2.25% 2.82% 5.69% 3.18% 0.64% 2.66%
Idaho Class Loads from PAC-1O-07 at Input Adjusted for Additional Losses for Wholesale Ener
16 Monsanto Load At Input 134,216 111,297 124,401 121,177 122,604 119,484
17 Monsanto Replacement - 84 - 57 116 3,974
18 Monsanto without replacement 134,216 111,213 124,401 121,120 122,488 115,510
19 Agrium At Input 10,012 8,803 9,335 9,087 9,194 7,309
20 Tariff Customer At Input 149,438 126,296 135,418 132,351 183,171 234,654
21 Total AtInput 293,666 246,395 269,155 262,615 314,969 361,447
124,679 125,027 121,839 125,420 124,184 120,461 1,473,347
1,887 2,001 3,094 3,922 6,579 7,978 29,797
122,792 123,026 118,745 121,498 117,605 112,483 1,443,549
8,982 9,005 9,055 9,308 9,086 8,863 107,908
286,693 242,627 161,692 134,427 131,452 151,339 2,071,131
420,354 376,659 292,587 269,155 264,722 280,662 3,652,385
Exhibit _(201)
Pagel of 1
ROCKY MOUNTAIN POWER
PAC-E-10-07 Base Loads: Comparison of Company and Corrected
PAC-E-10-07
PAC-E-10-07
Description Dec-10 Jan-10 Feb-10 Mar-10 Apr-10 May-10 Jun-10 Jul-10 Aug-10 Sep-10 Oct-10 Nov40 Jan-Dec 10
(1) (2) (3) (4) (5) (8) (7) (8) (9) (10) (11) (12) (13)
1 Companys Split of Base Load:
2 Tariff Customer
3 Replacement Energy
4 Tariff Customer
5 Monsanto
6 Agrium
7 Total
8 Corrected Split of Base Load:
9 Tariff Customer
10 Replacement Energy
11 Tariff Customer
12 Monsanto
13 Agrium
14 Total
15 Chanae from Company's:
16 Tariff Customer
17 Replacement Energy
18 Tariff Customer
19 Monsanto
20 Agrium
21 Total
147,152 144,717 119,478 135,644 129,105 181,459 229,585 286,843 243,148 159,076 135,645 131,212 2,043,066
8,408 - 89 - 59 118 4,182 1,963 2,076 3,191 3,935 6,763 30,784
155,560 144,717 119,568 135,644 129,164 181,576 233,768 288,806 245,224 162,268 139,580 137,975 2,073,850
115,762 138,565 117,487 124,170 124,111 124,052 119,988 122,207 122,094 120,978 120,235 117,407 1,467,057
9,340 10,384 9,340 9,340 9,340 9,340 7,692 9,340 9,340 9,340 9,340 9,340 111,478
280,662 293,666 246,395 269,155 262,615 314,969 361,447 420,354 376,659 292,587 269,155 264,722 3,652,385
151,339 149,438 126,296 135,418 132,351 183,171 234,654 286,693 242,627 161,692 134,427 131,452 2,069,558
151,339 149,438 126,296 135,418 132,351 183,171 234,654 286,693 242,627 161,692 134,427 131,452 2,069,558
112,483 134,216 111,213 124,401 121,120 122,488 115,510 122,792 123,026 118,745 121,498 117,605 1,445,097
8,863 10,012 8,803 9,335 9,087 9,194 7,309 8,982 9,005 9,055 9,308 9,086 108,038
272,685 293,666 246,311 269,155 262,558 314,853 357,473 418,466 374,657 289,493 265,233 258,144 3,622,693
4,187 4,721 6,818 (227) 3,246 1,712 5,069 (150) (522) 2,616 (1,218) 240 26,492
(8,408) - (89) - (59) (118) (4,182) (1,963) (2,076) (3,191) (3,935) (6,763) (30,784)
(4,221) 4,721 6,728 (227) 3,188 1,594 886 (2,113) (2,597) (575) (5,153) (6,523) (4,292)
(3,279) (4,349) (6,275) 231 (2,992) (1,564) (4,478) 584 932 (2,233) 1,264 198 (21,960)
(478) - (373) (537) (5) (253) (147) (383) (358) (336) (285) (32) (254) (3,440)
(7,978) - (84) - (57) (116) (3,974) (1,887) (2,001) (3,094) (3,922) (6,579) (29,692)
Exhibit - (202)
Page 1 of I
ROCKY MOUNTAIN POWER
Idaho Actual Load By Month As Calculated By the Company In Its Reply Comments
Description Dec-10 Jan-11 Feb-Il Mar-11 Apr-11 May-Il Jun-11 Jul-11 Aug-11 Sep-Il Oct-li Nov-li
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (II) (12)
Total Idaho Jurisdictional Load (incl.
1 Monsanto buy-through) 280,752 300,879 260,406 274,689 259,461 280,701 353,088 496,921 346,717 277,691 270,554 275,075
2 Less Monsanto buy-through (5,484) (9,346)
3 Total Idaho Jurisdictional Load 280,752 300,879 260,406 274,689 259,461 280,701 353,088 496,921 346,717 277,691 265,070 265,728
4 Monsanto Sales 112,200 125,300 105,400 123,700 120,100 120,800 122,500 125,700 119,100 89,600 127,700 122,200
5 Less Monsanto buy-through (5,293) (9,021)
6 Transmission Loss % (1) 4.422% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605%
7 Monsanto Load 117,161 129,817 109,200 128,159 124,430 125,155 126,916 130,231 123,394 92,830 126,820 117,259
8 Agrium (El Paso Sub) Sales 9,903 10,357 9,148 10,147 9,820 9,492 4,654 8,971 9,198 9,215 9,736 9,257
9 Transmission Loss % (1) 4.422% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605% 3.605%
10 Agrium Load 10,341 10,731 9,477 10,513 10,174 9,834 4,821 9,295 9,530 9,547 10,087 9,591
11 Tariff Customer Loads 153,250 160,331 141,729 136,017 124,858 145,712 221,350 357,395 213,794 175,314 128,163 138,879
(1) This transmission loss percentage is a weighted average of 4.543% and 3.605% due to timing of the ECAM.
Exhibit - (203)
Page 1 of 1
ROCKY MOUNTAIN POWER
Idaho Actual Load By Month Adiusted For "Extra" Losses
Description Dec-10 Jan-11 Feb-Il Mar-Il Apr-Il May-Il Jun-11 Jul-11 Aug-Il Sep-Il Oct-II Nov-Il
(1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12)
1 Comoanvs Actual Loads
2 Tariff Customer 153,250
3 Monsanto
4 Agrium
5 Total 153,250
160,331 141,729 136,017 124,858 145,712 221,350 357,395 213,794 175,314 128,163 138,879
129,817 109,200 128,159 124,430 125,155 126,916 130,231 123,394 92,830 126,820 117,259
10,731 9,477 10,513 10,174 9,834 4,821 9,295 9,530 9,547 10,087 9,591
300,879 260,406 274,689 259,461 280,701 353,088 496,921 346,717 277,691 265,070 265,728
6 Actual Loads Adjusted For "Extra" Losses
7 Tariff Customer 153,250
8 Monsanto
9 Agrium
10 Total 153,250
163,949 141,670 144,188 128,834 152,119 223,091 364,514 218,603 180,263 135,462 143,294
132,746 109,154 135,859 128,392 130,658 127,914 132,826 126,169 95,451 134,042 120,987
10,973 9,473 11,145 10,498 10,267 4,859 9,480 9,744 9,817 10,661 9,896
307,668 260,298 291,191 267,724 293,044 355,865 506,819 354,516 285,530 280,165 274,177
Exhibit (204)
Page 1 of I
ROCKY MOUNTAIN POWER
Idaho ECAM Deferral With Corrected Base Loads and Actual Loads
December 2010 through November 2011
Line
No. Dec-10 Jan-I11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-111 Aug-11 Sep.11 Oct-11 Nov-11 Total
I Base NpC Rate ($IMW,)- See (1)below 16.93 14.76 14.63 15.38 16.64 17.06 17.31 21.60 22.89 20.75 17.28 17.77
2 Total Company Adjusted Actual NPC ($) 95,757,018 107,401,699 102,209,579 99,507,678 96,035,896 96,927,539 103,624,344 140,645,161 147,796,095 122,984,469 110,065,405 121,246,771
3 Actual Retail Load (MWd 5,261.325 5,299026 4.692,843 4,882,154 4,531,018 4,505,487 4.632,662 5,367,046 5.321,022 4,680,341 4.621,700 4,859,771
4 Actual NPC ($/M%M) = Line 2 / Line 3 1820 20.27 21.78 20.38 21.20 2151 22.37 26.21 27.78 26.28 23.81 24.95
5 NPC Differential $/MW1 = Line 4- Line 1 1.27 6.51 7.15 5.00 4.55 4.46 5.05 4.61 4.88 5.53 6.54 7.18
6 Actual Tariff Customer Load Adjustedto account for Mcoor,gars "extra". 153,250 163.949 141,670 144,188 128,834 152,119 223,091 364,514 218,603 180,263 135,462 143,294 2,149,237
7 Actual Monsanto Load I lassos, 132,746 109,154 135,859 128,392 130,658 127,914 132,826 126,169 95.451 134,042 120,987 1,374,199
8 Actual AiumLoad 10,973 9,473 11,146 10.498 10,267 4,859 9,480 9,744 9,817 10,661 9,896 106.812
9 Actual Idaho Load (MW1) 153,250 307,668 280,298 291,191 267,724 293,044 355,865 506,819 354,516 285,530 280,165 274,177 3,630,247
10 Tariff Customer NPC for Deferral = Line 5" Line 6 193,993 903,600 1,013,259 721,202 586,838 878,060 1.127.512 1,680,020 1,067,387 996,924 885,789 1,028,739 10,883,322
11 Monsanto NPC for Deferral = Line s" Line 7 731,629 780,696 679,539 584,823 582,399 646,485 612,184 616,055 527,880 876,506 868,593 7,506,789
12 AoflumNPC for Deferral = Line S" Line 8 60,476 67,756 55,743 47,816 45.763 24,559 43,692 47,577 54.290 69,715 71,043 588,431
13 Total NPC Differential for Deferral ($) 193,993 1,695,705 1,881,711 1,456,485 1,219,476 1,306,222 1,798,556 2,335,896 1,731,019 1,579,094 1,832,010 1,968,375 18,978,541
14 Tanff Customer Base Load Adjusted toaccountforMcoaugals extra 175,051 149,438 126,296 135,418 132,361 183,171 234,664 286,693 242,627 161,692 134,427 131,462 2,093,270
15 Monsanto Base Load losses, and correctedfor proper energy sales 134,216 111,213 124,401 121,120 122,488 115,510 122,792 123,026 118,745 121,498 117,805 1,332,614
16 Aarium Base Load byclass Replacement energy removed from 10.012 8,803 9,335 9,087 9.194 7,309 8.982 9,005 9,055 9,308 9,086 99,176
17 Total Base Load Tariff Custornec 175,051 293,666 246,311 269,155 262,558 314,853 357,473 418,466 374,657 289,493 265,233 258,144 3,525,060
18 Tariff Customer Load Differential = Line 6- Line l4 (21,801) 14,511 15,375 8,770 (3,517) (31,052) (11,563) 77,821 (24,024) 18,570 1,034 11,842 55,967
19 Monsanto Base Load Differential = Line 7- Line l5 (1,470) (2,058) 11,457 7,273 8,170 12,404 10,034 3,143 (23,294) 12,544 3,382 41,585
20 Acaium Base Load Dtfferential = Line 8- Line l6 961 671 1,809 1.411 1,073 (2,450) 498 739 782 1,353 809 7.636
21 Difference Base Load to Actual Load (21,801) 14,002 13,987 22,037 5,166 (21,809) (1,608) 88,353 (20,141) (3,963) 14,932 16,034 105,188
22 Load Change Adjustment Rate (LCAR) ($/MWH) (2) 1805 21.89 21.89 21.89 5.47 547 647 5.47 5.47 5.47 5.47 547
23 Tariff Customer LCA = -Line l8x Line 22 393,453 (317,642) (336,554) (191,980) 19,239 169,854 63,247 (425,681) 131,409 (101,579) (5,658) (64,776) (666,667)
24 Monsanto Base LCA = -Line 19 x Line 22 32,178 45,056 (250,800) (39,782) (44,689) (67,852) (54,886) (17,192) 127,421 (68,614) (18,501) (357,663)
25 AarlumBaaeLCA = -Line 2Ox Line 22 (21,039) (14,681) (39,601) (7,717) (5,869) 13.402 (2,724) (4,045) (4,166) (7,404) (4.426) (98,269) 26 Load Change Adjustment Revenues 393,453 (308,503) (306,179) (482,381) (28,260) 119,296 8,797 (483,290) 110,172 21,676 (81,675) (87,704) (1,122,599)
27 SO2 Allowances Sales - - ($78,000) ($41,737) ($4,505) $0 ($40,509) $0 $0 $0 $0 $0
28 Idaho SE Factor 65570% 635750A 8.3575% 6.3575% 6.3575% 6.3575% 6.3575% 63575% 6.3575% 6.3575% 6.3575% 6.3575%
29 Idaho Allocated S02 Allowance Sales = Line 27 x Line 28 - - (4,959) (2,653) (286) - (2,575) - - - - - (10,474)
30 Idaho Allocated ElTF04-CDefen'alAotustment 33,727 (11,997) (20,948) (11,103) (50,550) (33,494) (33,248) 47,975 31,771 46,838 78,031 30,412 107,414
31 Total Adjustments 33,727 (11,997) (25,906) (13,756) (50,836) (33,494) (35,824) 47,975 31,771 46,838 78,031 30,412
32 Tariff Customer -ID Load % 54.59% 53.29% 54.43% 49.52% 48.12% 51.91% 62.89% 71.92% 81.66% 63.13% 48.35% 52.26%
33 Monsanto - IDLoad% 43.15% 41.93% 46.66% 47.96% 44.59% 35.94% 26.21% 35.59% 33.43% 47.84% 44.13%
34 Agtium - IDLoad% 3.57% 364% 3.83% 3.92% 3.50% 1.37% 187% 2.75% 3.44% 3.81% 3.61%
35 Tariff Customer Adjustments = Line 3lx Line 32 18,410 (6,393) (14,100) (6,812) (24,483) (17,387) (22,458) 34,504 19,591 29,570 37,729 15,894 64,085
38 Monsanto Adjustments = Line 3lx Line 33 (5,176) (10,864) (6,418) (24,379) (14,934) (12,877) 12,573 11,307 15,657 37,333 13.420 15,643
37 AartumAcfivabneeits = Line 3lx Line 34 (428) (943) (526) (1,993) (1.173) (489) 897 873 1.610 2,969 1,098 1,895
38 Total Adjustments 18,410 (11,997) (25,906) (13,756) (501836) (33,494) (35,824) 47,975 31,771 46,838 78,031 30,412 81,623
39 Tariff Customer NPC Differential + LCA + SO:= Sum of Lines 10, 23, 35 605,855 579,565 662,606 522,411 581,612 830,527 1,168,302 1,288,844 1,218,387 924,915 917,859 979,857 10.280,740
40 Monsanto NPC Differential + LCA + S02 + El = Sum of Lines 11, 24, 36 - 758,630 814,888 422,321 520,661 522,777 565,755 569,871 610,169 670,958 845,225 863,512 7,164,769 41 AanumNPC Differential +LCA+S02+EITF= Sum of Lines l2,25,37 - 39,009 52,132 15,615 38,106 38,720 37,472 41,865 44,406 51,734 65,281 87,714 492,056
42 Total NPC Differential + LCA + S02 + EITF 605,865 1,377,204 1,529,626 960,347 1,140,380 1,392,024 1,771,529 1,900,581 1,872,962 1,647,607 1,828,366 1,911,083 17,937,565
Exhibit 205
Page 1of2
43 Customer I Company Sharing ratio 90.0% 90.0% 90111/6 90.0% 90.0% 90.0% 90.0% 90.0% 90.0% 90.0% 90.0% 90.0%
44 Tariff Customer NPC Differential + LCA + S= Line 39 x Line 43 545,270 521.608 596,345 470,170 523,451 747,474 1,051,471 1,159,960 1,096,548 832,423 826,073 881.871 9,252,666
45 Monsanto NPC Differential + LCA + 802 + 1= Line 40 x Line 43 - 682,767 733,399 380,089 468,595 470,499 509,180 512,884 549,152 603,862 760,703 777,161 6,448,292
46 Annum NPC Differential + LCA + 902 + E11= Line 41 x Line 43 - 35,108 46,919 14,054 34,296 34,848 33,725 37,679 39.965 46,561 58,753 60,943 442,851
47 Customer I Company Sharing (90110) 545,270 1,239,484 1,376,663 864,313 1,026,342 1,252,822 1,594,376 1,710,523 1,685,666 1,482,846 1,645,529 1,719,975 16,143,808
48 Renewables Generation (MWhs) 155,931
49 Renewable Adder Rate per MIMi $55.00
50 Total Renewable Resources Adder = Line 48 x Line 49 8,576,210
51 Idaho SG Factor 6.0479%
52 Idaho Allocation = Line 50 x Line 51 518,681
53 Idaho Tariff Customers Percent 54.59%
54 Renewable Resources Adder = Line 52 x Line 53 283.124 283,124
55 Idaho Actual Renewable Energy Credit Revenues ($) (156,409) (383,764) (476,676) (702,633) (649,126) (705,294) (578,135) (81049) (96,023) (182,551) (671,459) (649,714)
56 Idaho Base Renewable Enemy Credit Revenues (3) (75,604) (585,930) (585,930) (585,930) (585,930) (585,930) (585,930) (585,930) (585,930) (585,930) (585,930) (585,930)
57 REC Revenue Adjustment ($) = Line 55-Line 56 (80,805) 202,166 109,255 (116,702) (63,195) (119,363) 7,795 504,882 489,907 403,379 (85,529) (63,784) 1188,006
58 Tariff Customer REC Revenue Adjustment = Line 32 x Line 57 (44,108) 107,729 59,463 (57,787) (30,411) (61,961) 4,887 363,120 302,088 254,664 (41,354) (33,335) 822,996
59 Monsanto REC Revenue Adjustment = Line 33 x Line 57 87,227 45,815 (54,449) (30,307) (53,220) 2,802 132,318 174,354 134,847 (40,920) (28,146) 370,321
60 AariumREC Revenue Adiustment = Line 34 x Line 57 7,210 3,976 (4,466) (2,478) (4,182) 106 9,444 13,465 13,868 (3,255) (2,302) 31,387
61 Total REC Revenue Adjustment ($) (44,108) 202,166 109,255 (116,702) (63,195) (119,363) 7,795 504,882 489,907 403,379 (85,529) (63,784) 1,224,703
62 Interest Rate 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00% 1.00%
63 Tariff Customer Balancing Account(S)
64 Beginning Balance Excluding Unamortized LGA
65 Unamortized 2010 Load Growth Adjustment
65 Incremental Deferral = Line 44
66 Renewable Resources Adder = Line 54
67 REC Revenue Adjustment = Line 58
68 Less: Monthly ECAM Rider Revenues
69 Interest
70 Tariff Customer Ending Balance(S)
71 Monsanto Balancing Account(S)
72 Beginning Balance
73 Incremental Deferral = Line 45
74 REC Revenue Adjustment = Line 59
75 Less: Monthly ECAM Rider Revenues
76 Interest
77 Monsanto Ending Balance($)
78 Agrlum Balancing Account($)
79 Beginning Balance
80 Incremental Deferral = Line 46
81 REC Revenue Adjustment = Line 60
82 Less: Monthly ECAM Rider Revenues
83 Interest
84 Agrlum Ending Balance(S)
85 Total ECAM Deferral Balance = Sum of Lines 70, 77, 84
11,181,331 11,840,000 12,337,746 12,874,978 13,179,042 13,362,178 13,361,489 13,590,768 13,554,154 13,575,487 13,617,167 13679,621
2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721 2,378,721
545,270 521,608 596,345 470,170 523,451 747,474 1,051,471 1,159,960 1,096,548 832,423 826,073 881,871
283,124 - - - - - . - - - - -
(44,108) 107,729 59,463 (57,787) (30,411) (61,961) 4,887 363,120 302,088 254,664 (41,354) (33,335)
(137,186) (143,643) (131,060) (121,152) (322,939) (699,313) (840,287) (1,572,981) (1,390,584) (1,058,715) (735,616) (887,582)
11,570 12,051 12,482 12,833 13,036 13,112 13,207 13,287 13,281 13,307 13,350 13,457
14,218,721 14,716,467 15,253,698 15.557,762 15,740,898 15,740,210 15,969,488 15,932,875 15,964,208 15,995,887 16,058,341 16.252,752 16,252,752
- 770,315 1,550,495 1,877,563 2,317,599 2,736,984 3,251,460 3,899,641 4,626,698 5,369,570 6,094,127
682,767 733,399 380,089 468,595 470,499 509,180 512,884 549,152 603,862 760,703 177,161
87,227 45,815 (54,449) (30,307) (53,220) 2,802 132,318 174,354 134,847 (40,920) (28,146)
321 967 1,428 1.747 2,105 2,494 2,978 3.551 4,163 4,775 5,391
770,315 1,550,495 1,877,563 2,317,599 2,736,984 3,251,460 3,899,641 4,626,698 5,369,570 6,094,127 6.848,532 6,848,532
-
35,108
7,210
18
42,336
48,919
3,976
56
93,288
14,054
(4,466)
82
102,957
34,296
(2,478)
99
134,874
34,848
(4,182)
125
165,665
33,725
106
152
199,649
37,679
9,444
186
246,957
39,965
13,465
228
300,616
46,561
13,868
276
361,321
58,753
(3,255)
324
417,143
60,943
(2,302)
372
42,336 93,288 102,957 134,874 165,665 199,649 246,957 300,616 361,321 417,143 476,156 476,156
14,218,721 15.529,118 16,897.482 17,538,283 18,193,372 18,642,859 19,420,597 20,079,472 20,881,521 21,728.778 22.569,611 23.577,440 23,577,440
(1)Base NRC Rate and Load from Case No. PAC-E-08-07 $982 million through 12127/2010, from Case No. PAC-E-11-07 $1,024.8 million since 12/2812010
(2)Represents Load Growth Adjustment in months December 10- March 11, then revised to Load Change Adjustment beginning in April 2011.
Exhibit 206
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