20140331Reply Comments.pdf

il RACI N E
OLSON
NYE
BUDGE
BAILEY
2Ol E. Center St.
P.O. Box 1391
Pocatello, lD a32O4
o 208.232.6101
F 208.232.6109
racinelaw.net
RANDALL C. BUDGE
[e-mail]
iaji'. .-r i trIB
March 27,2014
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
RE: IPUC Case No. PAC-E-14-01
Dear Ms. Jewell:
Enclosed you will find the original and eight (8) copies of Monsanto's Reply Comments. Please
file the same with the commission's records and return a file-stamped PDF copy to me. lf you
have any questions, please don't hesitate to call.
Thank you.
Sincerely,
k**at4 #." fru
RANDALL C. BUDGE
RCB:tscc: Service List
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
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
REPLY COMMENTS OF MONSANTO COMPAI{Y
INTRODUCTION
COMES NOW lntervenor Monsanto Company ("Monsanto") through counsel and
submits these Reply Comments with respect to the March 20, 2014 Comments of the
Commission Staff and the March 26,2014 Reply Comments of Rocky Mountain Power ("RMP"
or "Company''). Monsanto accepts and agrees with the Company's explanation on lagged
ECAM Revenues as explained in RMP's Reply Comments of March 26, 2014 at pages 4 and 5.
Monsanto will address below the Staff s claims to have "discovered an error in the application of
WLA ("Wholesale Loss Adjustment")", oS well as the Staffs new proposal for a base rate over-
collection adjustment.
'li-J
COMMENTS OF MONSAI\TO COMPAIIY - 1
WHOLESALE LOSS ADJUSTMENT
In their Comments, the Staff states that the WLA is removed from the Load Change
Adjustment (LCA) for June through November 2013:
"Additionally, in a settlement reflected in Commission Order No. 32910 pursuant
to Commission Order No. 32771, the wholesale line loss adjustment applied to
actual loads for Monsanto and Agrium for purposes of calculating the LCA is
removed from June 1,2013 through November 30, 2013 of the deferral period."
Comments of the Commission Stffi March 20, 2014, page 2.
The Staff Comments mischaracterize the settlement. The Stipulation and Order No. 32910 of
Case No. PAC-E-13-04 states that the WLA
calculation of the LCA:
for all deferral balances except for the
"Pursuant to Commission Order No. 32771 the Parties have agreed to modify the
ECAM calculation by removing the wholesale sales line loss adjustment from
Monsanto and Agrium's acfual load used to calculate all deferral balances except
for the Load Chanee Adjustment Revenue (LCAR) portion of the ECAM deferral.
This change will be effective for the ECAM deferral period starting June 1, 2013
and ending on November 30, 2013." Case No. PAC-E-13-04, Order No. 32910,
October 24, 2013, page 4, emphasis added
In addition, the Staff also believes RMP used the wrong WLAs in its Application in this
proceeding:
"While reviewing RMP's deferral calculations, Staff discovered an eror in the
application of the WLA per Commission Order Nos. 32597, 32771, and 32910.
The wrong WLAs were applied to January through May 2013 actual loads
resulting in an incorrect allocation of deferral amounts between Agrium,
Monsanto, and tariffcustomers. " Comments of the Commission Staff, March 20,
2014, page 7.
Monsanto does not agree with the Staff there has been a "misapplication" of the WLA by
RMP, and thus urges the Commission to reject the Staff s "correction" to the WLA. Monsanto
believes RMP has correctly updated the WLAs in this case pursuant to Order No. 32432 in Case
No. PAC-E -ll-lzt and has correctly applied those updated WLAs in its analysis. Specifically,
I Case No. PAC-E-I l-12, "In the Matter of the Application of PacifiCorp, DBA Rocky Mountain Power, for Approval
of Changes to Its Electric Service Schedules. The Order states: "The Parties agree to update the Idaho load in the 2012 ECAM
load change adjustment revenue C'LCAR") calculation to the 2010 actual load included in PAC-E-Il-12 for the 2012 ECAM
deferral calculation and use 201 I actual load reported in the Annual Results of Operations Report for the 2013 ECAM deferral
calculation. " Order No. 324j2, page 4
COMMENTS OF MONSAI\TO COMPANY - 2
the Company correctly applied the new and updated set of WLAs to Monsanto and Agrium's
base load and actual load in the LCAR portion, as well as to the months of January through May
for purposes of net power costs.
The Staff is attempting to change the agreed upon ECAM methodology by applyrng two
completely different sets of WLAs to Monsanto and Agrium's loads: (1) a prior set of WLAs
based on Case No. PAC-E-ll-12 applied to January through May actual loads for net power cost
deferral, and then (2) the new updated set of WLAs based on the Annual Results of Operation
Report for load changes. There is no need for two different sets of WLAs for the same months.
ln the Company's 2013 ECAM filing, the WLAs were updated for January through
November and applied to both the load change and net power cost deferral. ln the Company's
2014 ECAM filing, the WLAs were again updated for January through November and applied to
both the load change and net power cost deferral. The only change agreed to by Stipulation
among parties in Case No. PAC-E-13-4 was that commencing June 2013, the WLA would be
removed from Monsanto and Agrium's actual load used to calculate net power cost deferral
balances.2 Consequently, Monsanto asks the Commission to reject the Stafls "correction" to the
WLAs which is contrary to the Stipulation.
Base Rate Over-Collection Adiustment
The Staff recommends an entirely new adjustment methodology to perform an "after the
fact" check on deferral amounts from the ECAM. It appears the Staff has been working in
collaboration with the Company on a method to "check the accuracy of its deferral amounts." 3
Monsanto was not notified or included in any of these separate talks between Staff and the
Company. Though this new method of checking may prove useful, proposing such a new
methodology for the first time in Staffs Comments filed March 20, 2014 in Modified
Proceedings case with an expedited schedule such as this affords no opportunity for discovery,
critical review or meaningful response. Monsanto takes exception to this and any other new
2 Case No. PAC-E-13-04 Stipulation at pages 4 and 5, and in particular footnote I at page 5 states: "Accordingly,
the defenal period for the ECAM application to be filed February l, 2014 will reflect two different allocation
methodologies. The current allocation methodology will be used for the December 1,2012, through May 31, 2013
period. The proposed allocation will be used for the June 7,2013, through November 30, 2013 period,"
3 See page 8 of the Staff s Comments where it states: "Staff, in collaboration with the Company, proposed a method
to check the accuracy of its defenal amounts."
COMMENTS OF MONSAI\TO COMPANY.3
methodology being introduced in the manner presented under Modified Procedures which gives
rise to due process concerns because other effected parties have not been afforded a reasonable
opportunity to evaluate the proposed change and participate in the process.
On September 29, 2009, the Commission issued Order No. 30904 approving the
implementation of an annual ECAM for RMP. Perhaps now after five years, it is time for an in-
depth re-examination of the entire ECAM model. For example, the Commission Staffclaims it
has found that relatively small differences in line losses between base and actual loads can drive
large inaccuracies in deferral amounts. If this is so, then the whole ECAM structure should be
examined in a setting that allows all interested parties access to supporting analysis and
workpapers, with the opportunity to respond to any change in the ECAM method. That full
opportunity simply does not exist in this instant case and warrants a full review rather than
expedited review under Modified Procedure in the next ECAM filing.
RESPECTFULLY SUBMITTED this 27n day of March,2014.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
W * F^#g
RANDALL C. BUDGE
By
COMMENTS OF MONSANTO COMPAI\IY - 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 276 day of March,2Ol4,I serued 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,ID 83720-0074
E-mail : i ean. iewell@ouc. idaho. sov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
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]
U.S. Mail
E-Mail
E-Mail
W c.g^/f
RANDALL C. BUDGE
COMMENTS OF MONSANTO COMPANY - 5