20220513Comments.pdf

PIIC COMMENTS Page 1
59501.0001.14754822.2
Ronald L. Williams, ISB No. 3034
Jonathan D. Wheatley, ISB No. 11537
HAWLEY TROXELL ENNIS & HAWLEY LLP
877 West Main Street
Boise ID, 83701
Telephone: [phone]
[e-mail]
[e-mail]

Attorneys for PIIC

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF ROCKY MOUNTAIN
POWER’S APPLICATION REQUESTING
APPROVAL OF $28.4 MILLION ECAM
DEFERRAL
)
)
)
)
)
Case No. PAC-E-22-05

PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS COMMENTS

Pursuant to Idaho Public Utilities Commission (the “Commission”) Order No. 35376
issued on April 20, 2022, PacifiCorp Idaho Industrial Customers (“PIIC”) hereby submits these
comments on the 2021 Energy Cost Adjustment Mechanism (“ECAM”) deferral of Rocky
Mountain Power (“RMP”). As a threshold matter, PIIC has had little time to review and evaluate
RMP’s 2021 ECAM filing. Notwithstanding, PIIC has identified three issues which it requests
Commission Staff investigate further.
1. Facebook (“Utah Customer”) Load Adjustment
In the workpapers of Witness Painter Titled “PAC-E-22-05 Painter Wkpr1_2022 ID
ECAM CONF,” Tab “ID Actual Loads”, Excel Row “13” there is an adjustment to total
company load titled “Facebook Adj.” PIIC’s understanding is that this relates to a Utah
Customer load which is being provided a special contract based on the price of a dedicated
renewable resource. When calculating total company load used to calculate the ECAM
RECEIVED
2022 May 13, AM 10:33
IDAHO PUBLIC
UTILITIES COMMISSION

PIIC COMMENTS Page 2
59501.0001.14754822.2
surcharge, RMP removes the Utah Customer’s load, which results in an increase in costs
allocated to Idaho. This appears to be a new adjustment that was not considered in RMP’s most
recent rate case and raises several important policy and allocation issues. Specifically, PIIC is
concerned that RMP’s treatment of the Utah Customer load is not consistent with the 2020
Protocol Agreement.
Under the 2020 Protocol Agreement, and its predecessors, the cost and benefits of new
resources acquired for state specific initiatives are situs assigned. Situs resources are not used to
offset the load requirements of a particular state. Nor can they be used to offset the amount of
generation and transmission costs allocated to a state—if they were, Idaho would get an
allocation credit for its situs assigned qualifying facility resources. PIIC is not aware of any
provision in the 2020 Protocol that allows RMP to use the generation from a dedicated resource
to carve-out the loads of specific customers from the jurisdictional allocation factors. In fact,
Section 3.1.6 of the 2020 Protocol specifically states that “loads of Special Contract customers
will be included in Load-Based Dynamic Allocation Factors.” Further, Section 3.1.8 of the 2020
Protocol also seems to specifically prohibit this treatment for customers that opt-out of cost-of-
service rates.
This issue is particularly concerning to PIIC because in RMP’s 2021 General Rate Case,
there was a major transmission substation included in RMP’s pro forma plant additions, which
was specifically constructed to serve the Utah Customer. RMP included the cost of this new
substation in Idaho rates as a system resource. Notwithstanding, under RMP’s allocation
treatment, which carves out the load requirements of the Utah Customer from Utah’s allocation
factors, the Utah Customer is not assigned any incremental transmission costs for the new
substation. That is not a reasonable result.

PIIC COMMENTS Page 3
59501.0001.14754822.2
Idaho did not approve the agreement for the Utah Customer, nor does it otherwise
recognize any other economic benefits from the Utah Customer’s load. PIIC requests that the
Utah Customer load and its dedicated resources be considered consistent with the 2020 Protocol.
Specifically, PIIC recommends the Utah Customer load be included in the adjusted total
company load used to calculate the ECAM balance. PIIC also requests that the dedicated
resources used to serve the Utah customer be treated as a situs resource and marked to market,
just like Idaho’s situs assigned qualifying facility resources.
2. Navajo Tribal Utility Authority (“NTUA”) Partial Requirements Load
RMP has a FERC contract with NTUA for partial requirements services of approximately
29 MW of capacity and requirements of 258,726 MWh. These amounts may be found on Pages
310-311, Line 4 of PacifiCorp’s 2021 FERC Form 1. The agreement is a FERC jurisdictional
contract, although given its terms, PIIC’s understanding is that the contract has been included as
an adjustment to Utah’s allocation factors in the past. In Attach IPUC Audit 12, Tab “Energy”, it
can be observed that the 258,726 MW of annual requirements are not included in the FERC
jurisdictional loads, which amounted to just 21,278 MW. PIIC’s understanding, however, is that
the NTUA partial requirements were also not included in Utah’s metered loads in Attach IPUC
Audit 12, Tab “Metered Loads.” In other cases, RMP has performed a separate adjustment to
increase Utah’s loads for the NUTA contract in cells “G26:G37” of Attach IPUC Audit 12, Tab
“Energy”. In this case, however, RMP has not made an adjustment to include the NTUA partial
requirements loads in the adjusted total company load used to calculate the ECAM deferral.
PIIC therefore, recommends that adjusted total company loads be increased by 258,726 MW to
account for the NTUA partial requirements load.

PIIC COMMENTS Page 4
59501.0001.14754822.2
3. Lakeside II Outages
In the deferral period, and over the past several years, Lakeside II has had poor
availability and an unusual number of major outages. Lakeside II is RMP’s newest gas plant,
and accordingly, one would expect that it would have the best availability of any resource on
RMP’s system. PIIC’s understanding is that there may have been problems with the construction
of the facility, which is located on wetlands near Utah Lake. Given the timeline for comments,
PIIC has not been able to further investigate the outages at Lakeside II, nor the impact of
potential construction or other defects leading to its poor availability in recent years. PIIC,
however, requests that the Commission Staff further investigate these outages, including
evaluation of root cause analyses and other supporting information.
PIIC appreciates the opportunity to provide these comments and respectfully requests the
Commission consider the issues identified above.
Dated this 13th day of May, 2022.
Respectfully submitted,
Ronald L. Williams
Hawley Troxell
Attorneys for PIIC

PIIC COMMENTS Page 5
59501.0001.14754822.2
CERTIFICATE OF MAILING

I HEREBY CERTIFY that on this 13th day of May, 2022, I caused to be served a
true and correct copy of the foregoing document upon the following individuals in the
manner indicated below:

Jan Norkyuki
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720, Boise ID 83720-0074
11331 W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise, ID 83714

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
[e-mail]

Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720, Boise ID 83720-0074
11331 W. Chinden Blvd, Bldg. 8, Suite 201-A
Boise, ID 83714

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
[e-mail]

Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
[e-mail]

Emily L. Wegener
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 Email:
[e-mail]

Data Request Response Center
PacificCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
[e-mail]

PIIC COMMENTS Page 6
59501.0001.14754822.2
T.J. Budge
Racine Olson
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail: [e-mail]

Bradley G. Mullins
MW Analytics, Energy & Utilities

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail:
[e-mail]

Eric L. Olsen
Echo Hawk & Olsen PLLC
505 Pershing Ave., Suite 100
PO Box 6119
Pocatello, ID 83205

 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail: [e-mail]

PIIC Electronic Service Only:

Val Steiner
Kyle Williams
Jonathan Wheatley
 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail: [e-mail]
[e-mail]
[e-mail]

Bayer/P4 Electronic Service Only:

Mike Veile:
Brian C. Collins
Greg Meyer
 U.S. Mail, Postage Prepaid
 Hand Delivered
 Overnight Mail
 E-mail: [e-mail]
[e-mail]
[e-mail]

_____________________________________
Ronald L. Williams