20130314Comments.pdf

W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT 0. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
FREDERICK J. HAHN, III
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
DAVID B. ALEXANDER
CANDICE M. MCHUGH
CAROL TIPPI VOLYN
JONATHAN M. VOLYN
THOMAS J. BUDGE
BRENT L. WHITING
DAVE BAGLEY
JASON E. FLAIG
FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R. CAHOON
NOLAN E. WITTROCK
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LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON, OF COUNSEL
.)ONATHON S. BYINOTON, OF COUNSEL
March 13, 2013
Mrs. Jean Jewell, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702-5918
Overnight Mail and Email ([e-mail] )
Re. PAC-E-13-03 (ECAM)
Dear Jean:
Enclosed for filing in the captioned matter please find the original and three copies of
Monsanto Company's Comments in Case No. PAC-E-13-01. Thank you for your assistance.
RCB:rr
Enclosures
cc: Ted WestonIRMP
Yvonne Hog1eIRMP
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
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7913 MAR I4 AM 9:5t
JJ
CJ
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO INCREASE RATES BY )
$2.2 MILLION TO RECOVER DEFERRED NET ) Case No. PAC-E-13-03
POWER COSTS THROUGH THE ENERGY )
COST ADJUSTMENT MECHANISM )
)
COMMENTS OF MONSANTO COMPANY
INTRODUCTION
COMES NOW Intervenor Monsanto Company ("Monsanto") through counsel and
submits these Comments with respect to the February 1, 2013 Application of PacifiCorp, d/b/a
Rocky Mountain Power ("Company") seeking authorization to increase rates by $2.2 million to
recover deferred net power costs through the Energy Cost Adjustment Mechanism (ECAM).
Monsanto's Comments are in response to the Commission's Order No. 32478 dated February 20,
2013, giving notice of the Application, that this matter will proceed under Modified Procedure,
authorizing interested persons to file written comments in support or opposition, and providing
rights or participation by filing a Petition to Intervene. Monsanto previously timely filed its
Petition to Intervene dated February 27, 2013.
COMMENTS OF MONSANTO COMPANY -I
MONSANTO COMMENTS
Based on review of the testimony, exhibits and responses to data requests in this case,
Monsanto agrees with the Company's calculations and propose no adjustment to the proposed
ECAM deferral account balances or ECAM rates. Monsanto has three general comments to
make regarding the Company's application.
First, consistent with Monsanto's previous comments in the prior ECAM application,
Case No. PAC-E-12-3 and as noted in the Commission's Order No. 32597, Monsanto requests
that treatment of interrupted energy in the ECAM be preserved for debate and resolution in the
Company's next general rate case filing.
Second, we also ask that the Company continue to transmit copies of its quarterly ECAM
reports, and other relevant information relating to the ECAM filing to all interested parties,
including Monsanto subject to confidentiality. The Commission previously determined that
providing relevant information on a quarterly basis will enable" a full and insightful analysis of
the Company's ECAM Application..." Order No 32554 at 8. As a result the Commission
directed the Company to transmit copies of its quarterly ECAM reports, and other relevant
information relating to the ECAM filing, to all interested parties, including Monsanto. Order No.
32597 at 8. Accordingly, the Commission should make it clear that this information should
continue to be provided to Monsanto and other interested parties in the future. Since ECAM
proceedings are typically handled by modified procedure this will enable customers to track
potential rate impacts and analyze the calculations in advance and thus facilitate timely and
meaningful review and comment.
Third, Monsanto requests that one particular component of the ECAM calculation
warrants additional review in the next general rate case. This area of concern is with the
"monthly adjustment factors for moving wholesale energy sales." These monthly adjustment
factors are determined by comparing the monthly Idaho jurisdictional energy loads to the
monthly customer class loads from the cost of service study. The methodology for determining
these factors, as well as their application, was developed as the result of discussions between the
parties in the last ECAM filing, Case No. PAC-E-12-03.
Based on energy loads from the most recent general rate case, Case No. PAC-E-1 1-12,
the monthly adjustment factors used for this ECAM filing show huge swings, from a high of
COMMENTS OF MONSANTO COMPANY -2
23% down to a low of negative 13.6%:
January 0.19%
February -1.07%
March 2.61 %
April 4.56%
May 16.62%
June 23.00%
July 14.22%
August -13.63%
September -8.76%
October -2.75%
November 10.47%
In contrast, the adjustment factors the parties looked at in Case No. PAC-E-12 -03 ranged from a
high of 7.3% to a low of roughly 0% (- 0.007%). Clearly the factors in this ECAM application
are much more divergent.
The Company maintains the adjustment factors are primarily attributable to moving
wholesale energy, and generally speaking, are also attributable to the different methods used to
develop jurisdictional loads and cost of service loads. These factors are important to Monsanto
as they are applied to the actual loads of Monsanto in determination of their Net Power Cost
("NPC") deferral balances. Obviously, these adjustments can substantially alter the amount of
NPC balances, particularly when a large positive monthly adjustment factor is paired with a large
monthly NPC rate. Monsanto recommends that the huge swings in these factors warrant special
review in the next general rate case as to the nature and source of such discrepancies and
whether it makes sense to adjust Monsanto's actual loads by these factors for the Net Power Cost
deferral balance.
RESPECTFULLY SUBMITTED this 13 6 day of March, 2013.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By
RANDALL C. BUDGE
COMMENTS OF MONSANTO COMPANY -3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this l3 " day of March, 2013, I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary (original and 7)
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702 Overnight Mail
E-mail: [e-mail] U.S. Mail
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: [e-mail] E-Mail
Yvonne R. Hogle
Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111 E-Mail
E-mail: Yvonne.hogelpacificorp.com
RANDALL C. BUDGE
COMMENTS OF MONSANTO COMPANY -4