20140319Comments.pdf

Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORITY TO DECREASE RATES BY
$2.8 MILLION TO RECOVER DEFERRED
NET POWER COSTS THROUGH THE ENERGY
COST ADJUSTMENT MECHANISM
Case No. PAC-E-14-01
COMMENTS OF MONSANTO COMPANY
INTRODUCTION
COMES NOW Intervenor Monsanto Company ("Monsanto") through counsel and
submits these Comments with respect to the January 31,2014 Application of PacifiCorp, dlbla
Rocky Mountain Power ("RMP" or o'Company") seeking authorization to decrease rates by $2.8
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. 32979 dated
February 20,2014, 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's Petition to
Intervene was granted by Order No.32977 dated February 7,2014.
COMMENTS OF MONSANTOCOMPANY- I
MONSANTO COMMENTS
Based on a review of the testimony, exhibits and responses to data requests in this case,
Monsanto has found that several errors with Monsanto's monthly energy usage and ECAM rider
revenues paid over the period December 2012 through November 2013 in Exhibit I included
with the Company's filing. These errors are addressed below.
Monsanto Actual Enerw Usage
Last year's ECAM filing (Case No. PAC-E-13-03) covered the months of December
201I through November 2012. Monsanto's sales at customer meter in November 2012 shown
on ExhibitNo. 1 of Case No. PAC-E-13-03 was 100,500 MWH, of which 804 MWH were for
replacement energy. See Confidential Attachment to Monsanto Data Request 1.5. These
amounts correctly match Monsanto's November 2012 invoice.
This year's ECAM filing covers the months of December 2012 through November 2013.
RMP Exhibit I shows Monsanto's sales at customer meter in December 2012 of 100,500 MWH.
This is not correct. That 100,500 MWH sales figure is from November 2012, not December
2012. In December 2012, Monsanto's actual energy usage was 128,900 MWH based on
Monsanto's invoice from Rocky Mountain Power dated January 3,2013. In fact, the energy
sales for Monsanto included in Exhibit 1 sheet "ID Actual Loads", row 2l titled "Monsanto sales
@ customer meter (includes replacement)" are consistently off by a month over the entire period.
A comparison of the loads included in Exhibit 1 and Monsanto's correct loads are shown in
Attachment A to these comments.
Monsanto Replacement Enerw
Replacement energy is not subject to the Net Power Cost differential and must be
subtracted from Monsanto's metered energy. The Company's9,447 MWH shown in July is in
error and should be9,649 MWH. See July 2012 Corrected Version invoice of Monsanto
included in Attachment Monsanto 1.9 to RMP's response to Monsanto Data Request No. 1.9.
The corrected replacement energy amounts are shown in Attachment A to these comments.
COMMENTS OF MONSAITTO COMPAI\TY- 2
Monsanto ECAM Rider Revenues
Just as the Company's filing has Monsanto's energy sales off by a month, so too are the
ECAM revenues paid by Monsanto. For example, the ECAM revenues paid by Monsanto in
November 20l2were$174,468 as shown in the November 2012 column of last year's Exhibit I
filing in Case No. PAC-E-13-03. See Confidential Attachment to Monsanto Data Request 1.5.
This dollar amount correctly matches Monsanto's November 2012 invoice.
For December 2012, Monsanto paid ECAM revenues of $2 I 8,071 . However, the
Company erroneously included $174,468 of revenues for December 2012 in Exhibit 1. The
ECAM revenues are again off by a month. Furthermore, corrections were made to several of
Monsanto's bills in 2013, and those corrected amounts must also be incorporated into the ECAM
analysis. In summary, the Company included$.3,735,441 of ECAM revenues paid by Monsanto,
when the actual amount paid is $3,860,239 as shown in Attachment A to these comments.
The total impact of correcting the sales and ECAM revenues lowers Monsanto's ending
balance from the $13,401,935 proposed by the Company, down to $13,263,054.
REC Revenues
While no adjustment is proposed to the REC revenues included in the Company's filing,
Monsanto has a general comment regarding the Company's application.
The Company's filing is void of any detailed information supporting the renewable
energy credit ("REC") revenue received by the Company throughout the ECAM period. The
Company's witness Brian Dickman attests that the Company received approximately $15 million
in REC revenues during the period, but does not provide any supporting data that parties may use
to verify this claim. It is especially important that the decline in the Company's REC revenues
be fully disclosed and substantiated since the 2013 amount is less than}}o/o of the Company total
REC revenues built into base rates, and there is currently no financial incentive for the Company
to sell these RECs given any shortfall is made up 100% by Idaho ratepayers.
The Company has claimed in responses to data requests as part of this proceeding that
certain lucrative REC sales contracts have expired, but that it engages in regular reverse auctions
to sell its excess RECs. The Company has yet to provide sufficient information to prove that it is
working diligently to maximize the value of these excess RECs, which provide no benefit to
COMMENTS OF MONSANTO COMPANY - 3
Idaho ratepayers because Idaho has no state renewable mandate. If RECs that Idaho ratepayers
helped purchase do not get sold to third parties, they provide no value.
Furthermore, when certain renewable generation resources were added by the Company
to its portfolio in the recent past, RMP had to assume some critical threshold value of RECs in
order for the resources to be cost-justified. See e.g., Public Service Commission of Utah Docket
No.07-035-93, Report and Order On Revenue Requirement issued August 11, 2008. Now that
the cost ofthose resources are being paid for by Idaho ratepayers, the associated revenues from
the sale of RECs appear to be falling short of the threshold value projection. Since Idaho
ratepayers make the Company 100% whole on changes in REC revenue sales through the
ECAM, the ratepayers are shouldering both the resource investment plus taking on all the
downside risk of plummeting REC revenues. At the least, the Commission should require that
the Company fully disclose and justifu the dramatic decline in REC revenues in future filings
and how it plans to mitigate the adverse effects on Idaho ratepayers.
On-Going Requests for Ouarterlv Reports
Monsanto appreciates that the Company has provided ECAM reports on a quarterly basis.
This has enabled Monsanto to track and anticipate future rate impacts associated with ECAM
changes. Additionally, this advance information has provided Monsanto with a reasonable
opportunity to review andanalyze data and methodologies and attempt to identiff and resolve
problems in advance thus minimizing the time constraints and difficulties that otherwise arise
from the handling of the filings under modified procedure. Accordingly, Monsanto respectfully
requests that the Company continue to transmit copies of its quarterly ECAM reports, and other
relevant information relating to the ECAM filing to Monsanto and other interested parties.
RESPECTFULLY SUBMITTED this 20n day of March, 2014.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
COMMENTS OF MONSANTO COMPAIVY.4
I HEREBY CERTIFY that on this day of March,2ll4,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
P.O. Box 83720
Boise, lD 83720-0074
E-mail : jj [e-mail]
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail : ted.weston@fracifi corp.com
Yvonne R. Hogle
Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
E-mail : Yvonne. ho gel@p acifrcorp. com
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COMMENTS OF MONSANTO COMPANY - 5
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