20041015Notice of Modified Procedure Order No 29612.pdf

Office of the Secretary
Service Date
October 15 2004
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE REMAND
CONCERNING IDAHO POWER COMPANY'
REQUEST TO RECOVER "LOST REVENUE"
FROM THE 2001 IRRIGATION LOAD
REDUCTION PROGRAM THROUGH THE PCA )
MECHANISM IN THE 2004/2005 PCA YEAR.
CASE NO. IPC-01-
(ON REMAND)
NOTICE OF MODIFIED
PROCEDURE
ORDER NO. 29612
On June 8 , 2004, the Idaho Supreme Court issued its amended remittitur in Idaho
Power Company v. Idaho pac 140 Idaho 139, 90 P.3d 889 (2004). In its Opinion, the Supreme
Court set aside the Commission s decision in Order Nos. 28992 and 29103 denying Idaho Power
Company s request to recover the "lost revenue" associated with the Company s implementation
of the Irrigation Load Reduction Program in 2001. Lost revenue represents a calculated amount
of revenue the Company might have received from the sale of power to irrigation customers if
the Load Reduction Program had not been in operation. Order No. 29103 at 1. In this Order, the
Commission solicits additional comments from the parties and interested persons regarding the
calculation of the lost revenue.
BACKGROUND
A. The Irrigation Load Reduction Program
During the energy crisis of 2000-2001 , Idaho was faced with two unique conditions:
the second worst drought on record and extremely high wholesale power costs. The drought
forced Idaho Power to purchase large amounts of high-cost power to meet its load requirements.
In an effort to reduce electric consumption and the purchase of wholesale power, the Company
initiated several load reduction programs, one of which was the Irrigation Load Reduction
Program. This Program was designed to provide monetary incentives to large irrigation
customers to reduce their electric consumption during the summer of 2001. Order No. 29103 at
2. Under the Program Idaho Power would make payments to irrigation customers that
committed to reduce their energy consumption by at least 100 000 kWh. Order No. 28699, Case
No. IPC-01-
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
In May 2001 the Commission issued Order No. 28699 authorizing Idaho Power to
implement the Program. The Commission s Order stated that the "direct costs and lost revenue
impacts of this Program may be treated as a purchased power expense" in the Company s Power
Cost Adjustment (PCA) mechanism. The Commission intended for the Company to track or
account for the direct costs (payments to irrigators) and the lost revenue separately until the
Company filed a later application seeking authority to recover these amounts. The Commission
sought to preserve judgment on the recovery of lost revenue until the subsequent case. The
Order also directed Idaho Power and the parties to develop and present to the Commission a
procedure for calculating the amount of lost revenue if recovery was permitted in the 2002 PCA
case. Id. at 12.
In September 2001 , Idaho Power met with all the parties in the case to discuss its
proposed methodology for computing the lost revenues. At this meeting, the Company outlined
a three-part methodology to calculate the lost revenue. Following this meeting, the Company
adjusted the proposed methodology. Order No. 28992 at
Although the Irrigation Load Reduction Program operated until the end of November
2001 , the Company in October 2001 filed an Application requesting the Commission issue an
Order authorizing the recovery of the direct costs and lost revenue in the 2002-2003 PCA year.
Case No. IPC-01-34. In its Application, the Company reported its direct costs and proposed
lost revenues as of September 30, 2001 and indicated it would provide a subsequent report with
end-of-program results. Application at 4. The Application included the prefile testimony of the
Company s Director of Pricing, Maggie Brilz. Her testimony explained the Company s three-
part methodology for computing the lost revenue.
B. The Company s Proposed Methodologyfor Lost Revenue
Ms. Brilz explained that the methodology has three components: (1) the energy
component; (2) the demand component; and (3) the load reduction offset component. First, the
energy component represents the reduction in revenue associated with the kilowatt hours (kWh)
bid into the Irrigation Load Reduction Program. The energy component is calculated by
multiplYing the kWh of reduced energy by the tariffed energy rate applicable for the specific
billing period. Brilz at 5. Second, the demand component is the reduced revenue associated
with the reduction in billed kW relating to the in-season billing periods of June through
September 2001. This is the period during which the irrigation demand charge is imposed.
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
Because the billed kW is directly related to the installed horsepower at each metered service
point, the basis for the computation is the difference between the billed k W for the billing period
this year ((2001)) compared to the billed kW for the same billing period last year ((2000)).Id.
at 5-6. The demand component is then computed by multiplying the difference in billed kW
between the two years by the demand charge.
Third, the load reduction offset component eliminates a potential double accounting
of reduced revenues associated with the load change that is embedded in the PCA methodology.
At the time, the rate for load change adjustment within the PCA was 1.684 cents per kWh. This
component also includes an adjustment for the delivery loss factor for energy sales to irrigation
customers taking power at the secondary voltage level. This delivery loss is calculated at the
generation level rather than at the customer, or meter level. The Company utilized a loss factor
of 10.8%. Id. at 6-7. Taken together, the load reduction offset component is calculated by
multiplYing the kWh of energy reduction for which customers received payment by 1.108 to
adjust for the 10.8% loss, and then by 1.684 cents per kWh to fully reverse the load change
adjustment incorporated in the PCA mechanism. Ms. Brilz s Exhibit 2 shows the calculation of
each component for the example month of August 2001.
After calculating the amount of lost revenue, two other adjustments were made.
Consistent with the PCA mechanism, the amount of lost revenue was reduced by 10% to account
for the 90/10 sharing adjustment in the PCA. In addition, the jurisdictional allocation process
further reduced the calculated amount by 15% to allocate costs to Oregon customers. Id. at 12-
13.
C. The Initial Comments
In November 2001 , the Commission issued a Notice of Modified Procedure seeking
comments on Idaho Power s proposed methodology used to calculate the lost revenue. Order
No. 28893. Comments were filed by the Idaho Irrigation Pumpers Association, the Commission
Staff, and more than 200 customers. The public comments from customers uniformly opposed
recovery of lost revenue. These comments follow on the heels of (the then) significant rate
Increases.
In a departure from past positions, the Irrigation Pumpers supported the recovery of
lost revenues in this case conditioned upon several adjustments. They explained that "the
reduced energy levels are far more known and measurable" under the Irrigation Load Reduction
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
Program than in most other conservation programs. Yankel Prefile at 2. Although supportive of
the concept, they urged the Commission to make several adjustments that would have reduced
the calculated amount by several million dollars.
The Staff also stated that the differences between this Program and traditional
conservation programs supported recovery of "at least a portion of lost revenues.Staff
Comments at 4. Staff recommended that the three-part methodology be used subject to further
audit once the Company submitted its final calculations of lost revenue after the Program ended.
Id. at 5.
In March 2002, the Company filed its updated calculations for the lost revenue based
upon the completed Irrigation Load Reduction Program. As shown in the Attachment to this
Order, the Company used its methodology to calculate that its lost revenue totaled $11 587 179.
Atch. 1 (Idaho Power Atch. 3 , lines 31 and 35 , Col. P, March 1 , 2002). The carrYing charges at
6% interest totaled $428 008 through March 31 , 2002. Id. line 41 , Col. P. Thus, the Company
proposed to recover $12 015 187 in lost revenue, from customers in the PCA. Id. line 45, Col. P.
In April 2002, the Commission issued Order No. 28992 allowing recovery of the
Program s direct costs but rejecting the Company s request for recovery of lost revenues. The
Commission explained that its prior Order did not guarantee or authorize the recovery of lost
revenue but merely recognized that the issue of recovery would be considered at a later time.
Because the Commission denied the recovery of lost revenue, it did not address the proposed
methodology. On reconsideration, the Commission affirmed its decision to deny lost revenue.
Order No. 29103. The Company then filed its Notice of Appeal with the Supreme Court in
October 2002.
D. The Motion to Stay and the Carrying Charges on Appeal
Contemporaneously with its appeal, the Company also filed a Motion for Stay. In its
Motion, Idaho Power expressed concern that without staying the Commission s Order Nos.
28992 and 29103, the Company might be precluded from later recovering the disputed amount of
lost revenue. Motion to Stay at 2-3. The Company did not seek the immediate recovery of lost
revenue but stated it would seek recovery of lost revenue at a later date should it prevail on
appeal.
The Company also noted in its Motion that it had ceased accruing any carrYing
charges on the lost revenue amounts as of March 31 , 2002. Id. at 3. Moreover, the Company did
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
not propose to accumulate any additional carrying charges during the pendency of the appeal.
Id. However, Idaho Power acknowledged that if the Commission or the Court were to determine
that additional carrYing charges, if any, would be appropriate, it would gladly accept them. Id.
In Order No. 29143 , the Commission found that a stay was unnecessary to preserve
the Company s right to recover lost revenue should it prevail on appeal. The Commission found
a stay was not necessary because the dispute concerned a finite deferral account. If the Company
prevailed on appeal, recovery of the lost revenue would occur in a future PCA case. The
Commission also noted that Idaho Power did not propose to accumulate any additional carrYing
charges during the appeal. Id. at 3. Because Idaho Power does "not propose to accumulate any
additional carrying charges during the pendency of the appeal " the Commission found that a
stay was not necessary. Order No. 29143 at 6.
E. The Court's Opinion
On appeal, the Court set aside the Commission s decision to deny recovery of lost
revenues. The Court held that the Commission s Order No. 28699 that found lost revenues "may
be treated as a purchased power expense " demonstrated that the Commission did "intend to
allow Idaho Power to include lost revenue in the PCA.Idaho Power Company v. Idaho pac
140 Idaho at 142, 90 P.3d at 892. Having ruled that Idaho Power is entitled to lost revenue, the
Court concluded that the "only question left to be resolved at the end of the program was a
determination of how those lost revenues would be computed.Id.
DISCUSSION
On remand from the Court, the Commission s task now is to determine how the lost
revenue should be computed and settle upon an amount. As indicated above, the Commission
did not address the Company s proposed methodology in the underlying case because the
Commission found the Company was not in entitled to lost revenue. Using its proposed
methodology, Idaho Power calculated the amount of lost revenue at the time of the appeal totaled
$12 015 187 ($11 587 179 in computed lost revenue and $428 008 in carrying charges at 6% up
to March 31 , 2002). See Attachment 1 to this Order.
In this Order, the Commission again seeks coriunents from the parties and interested
persons regarding Idaho Power s proposed methodology for calculating lost revenue. Although
the Commission recognizes that it has already invited public comments in November 2001 , we
find it is appropriate to again solicit public comments. In particular, at the time the previous
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
comments were received (November 2001), the Company had not yet filed its end-of-program
amounts. Consequently, the Staffs and the Pumpers recommended adjustments were not
applied to the final proposed amounts calculated by the Company in March 2002.
NOTICE OF MODIFIED PROCEDURE
YOU ARE HEREBY NOTIFIED that the Company witness Maggie Brilz
explanation of the components of the lost revenue methodology and her supplemental
calculations of the proposed lost revenue amount are available for public inspection during
regular business hours at the Commission offices. The Company s final calculations of lost
revenue are also attached to this Order.These documents can also be viewed on the
Commission s website (www.puc.state.id.) by clicking on "File Room
" "
Electric Cases " then
on Idaho Power, then scroll down to Case No. IPC-01-34 (on Remand).
YOU ARE FURTHER NOTIFIED that the Commission has determined that the
public interest may not require a formal hearing in this matter and will proceed under Modified
Procedure pursuant to Rules 201 through 204 of the Idaho Public Utilities Commission s Rules
of Procedure, IDAP A 31.01.01.201 through .204.
YOU ARE FURTHER NOTIFIED that the Commission invites interested persons to
comment on Idaho Power s three-part methodology, the carrYing charges, and other issues
relevant to the calculation of lost revenue.
YOU ARE FURTHER NOTIFIED that any person desiring to state a position on this
matter may file a written comment in support or opposition with the Commission within twenty-
one (21) days from the service date of this Notice. The comment must contain a statement of
reasons supporting the comment. Persons desiring a hearing must specifically request a hearing
in their written comments. Written comments concerning this Notice shall be mailed to the
Commission and Idaho Power at the addresses reflected below:
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
Street Address for Express Mail:
Larry Ripley
Maggie Brilz
Idaho Power Company
PO Box 70
Boise, ID 83707-0070
Mail: mbrilz~idahopower. com
472 W. Washington Street
Boise, ID 83702-5983
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
These comments should contain the case caption and case number shown on the first page of this
document.Persons desiring to submit comments via e-mail may do so by accessing the
Commission s home page located at www.puc.state.id.. Click the "Comments and Questions
icon, and complete the comment form, using the case number as it appears on the front of this
document. These comments must also be sent to Idaho Power at the e-mail address listed above.
YOU ARE FURTHER NOTIFIED that if no additional written comments or protests
are received within the time limit set, the Commission will consider this matter on its merits and
enter its Order without a formal hearing. If additional written comments are received within the
time limit set, the Commission will consider them and, in its discretion, may set the same for
formal hearing.
YOU ARE FURTHER NOTIFIED that Idaho Power may file a reply to the
comments within 35 days from the date of this Order.
YOU ARE FURTHER NOTIFIED that the parties to Case No. IPC-01-34 remain
parties to this case on remand.
YOU ARE FURTHER NOTIFIED that all proceedings in this remand case will be
held pursuant to the Commission s jurisdiction under Title 61 of the Idaho Code and that the
Commission may enter any final Order consistent with its authority under Title 61.
YOU ARE FURTHER NOTIFIED that all proceedings in this remand matter will be
conducted pursuant to the Commission s Rules of Procedure, IDAPA 31.01.01.000 et seq.
ORDER
IT IS HEREBY ORDERED that parties or persons interested in commenting on
Idaho Power s lost revenue methodology, carrying charges or other relevant issues are invited to
submit written comments with the Commission no later than 21 days from the date of this Order.
IT IS FURTHER ORDERED that Idaho Power may file reply comments no later
than 35 days from the date of this Order.
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
DONE by Order of the Idaho Public Utilities Commission at Boise, Idaho this
/ ~
day of October 2004.
0k6L JJ
MARSHA H. SMITH, COMMISSIONER
ATTEST:
~lJ
J a D. Jewe
Commission Secretary
vldlO:IPCEO134 dh
NOTICE OF MODIFIED PROCEDURE
ORDER NO. 29612
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