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Home My WebLink About20211021Comments.pdfJOHN R. HAMMOND, JR. (ISB #5470) RrLEY NEWTON (rSB #l1202) DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-007 4 (208) 334-03 s7 1334-03 t8 IN THE MATTER OF THE APPLICATION OF CAPITOL WATER CORPORATION TO CHANGE ITS SCHEDULE NO.3 PURCHASED POWER COST ADJUSTMENT RATE ,.i i: t:: I ,r/*i ,.'. , ;"ii ?i pff 3:0J tQr.^r rL'9rL.i! Street Address for Express Mail: I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A BOISE, TD 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ) ) ) ) ) ) ) CASE NO. CAP-W-21.01 COMMENTS OF THE COMMISSION STAFF STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of record, John Hammond, Jr., Deputy Attorney General, submits the following comments. BACKGROUND On September 8, 2021, Capitol Water Corporation ("Company") applied with the Commission for authoization to change its Schedule No. 3, Purchased Power Cost Adjustment ("PPCA") rate from 2.06%to 0.92%o, effective November 15,2021. The Company's Schedule No. 3 PPCA rate provides a mechanism for the Company to recover its cost of electricity related to Idaho Power Company's ("Idaho Power") electric rate schedules that have been approved by the Commission. Application at 1. The Commission approved the Company's current base rates by Order No. 30762 in Case No. CAP-W-08-02. Id. In that Order, the Commission adopted a three (3) year average of 7,454,401 kilowatt hours ("kwh") of electricity consumption at an average cost of 5.191 to establish rates for the ISTAFF COMMENTS ocToBER 21,2021 Company. Id. The Company states that, "together these produce a total cost of electric power for the [Company] of $75,483.41." Id. The Company states that its "actual power costs in the calendar year 2020 were $81,505" which is $6,022 more than embedded in the Company's base rates. Id. The Company proposes to recover these additional electric power costs by replacing the Company's currently approved Schedule No.3 Purchased Power Cost Adjustment rate of 2.060/o with a new Schedule No. 3, PPCA rate of 0.92%. Id. STAFF REVIEW AND ANALYSIS Staff reviewed the Company's Application and supporting documents and recommends the Commission approve a PPCA rate of 0.89% instead of the 0.92% proposed by the Company. This is a decrease of 1.1 7o/o from the current PPCA rate of 2.06%. Staff s proposed PPCA rate reduces the current $13,426 incremental revenue produced by the current PPCA rate to $5,817 if the proposed PPCA rate of 0.89o2 is approved by the Commission. The Company's actual power expenses for the calendar year 2020 were $81,300. The Company reported power expenses of $81,505 in its Application, which is $205 greater than verified by Staff. In its calculation of the 2020 calendar year annual power costs, the Company included $205 in late fees it was charged by Idaho Power. Late fees are not directly related to the Company's electric expense usage and customers should not pay additional amounts through rates because the Company's didn't pay its power bills on time. Staff has adjusted the Company's request by removing the $205 in late fees as shown on Attachment A. Rate Design With the proposed change in the PPCA, the monthly bill for an unmetered customer with a %-inch service line would decrease by $0.32 (from $29.28 to $28.96) in May through September and $0.15 (from $12.91 to $12.76) in all other months. The bill for a metered customer will vary with water usage and the PPCA portion of the bill will decrease by l.l7%. These bill calculations exclude the City of Boise franchise fee and the Idaho Department of Environmental Quality fee. 2STAFF COMMENTS ocroBER 2t,2021 PPCA Methodoloey In Order No. 33876, Case No. CAP-W-I7-01, the Commission approved changes to the PPCA method. The Company compares its actual charges directly from Idaho Power to the energy cost embedded in base rates to calculate the PPCA. By using this approach, PPCA filings are completed in-house without the need for a consultant. Only the costs related to the supply of metered energy are used in the calculation of the PPCA. Costs related to late payment fees or services beyond the delivery of metered energy should be excluded from the calculation. The current PPCA method can maintain its simplicity and remain accurate without a true- up if the number of customers remains stable over time. Overall, since 201 7 , the Company acquired 78 new customers, indicating the Company has experienced a relatively stable customer count. System Efficiency In Case No. CAP-W-20-07, Staff expressed concerns about the electrical efficiency of Well Nos. 5 and 6. Monitoring the efficiency of the wells is important, because the adjustment mechanism allows a pass-through of electricity costs to ratepayers. Customers should not have to pay for higher electricity costs due to preventable inefficiencies. In Response to Staff s Production Request No. 2, the Company stated that it cleaned Well No. 5 and rebuilt the pump and motor in March 2020, to improve the efficiency of and extend the life of the well. Additionally, the Company performed routine maintenance on all remaining wells. Staff calculated the efficiency of each well on a gallon-per-kilowatt hour basis by dividing water consumption in gallons by energy consumption in kilowatt hours and then compared the 2019 and 2020 resulting efficiency of each well. ,See Table No. l. Table No. l: Pump Efficiencv Comparison between 2020 and20l9 J 2020 Pump Efficiency (eaUon/kWh) 2019 Pump Efficiency (eallon/kWh)Difference Well #3 317.66t179 311.186420r 2% Well #4 397.6230695 433.7402212 -8% Well #5 556.5702036 380.5868110 46% Well #6 533.2999529 505.1343322 6% Well #7 744.3638958 740.3139140 t% STAFF COMMENTS ocToBER 21,2021 The results show that the efficiency of Well No. 5 has increased by 46Yo and the efficiency of Well No. 6 has increased by 6Yo. The efficiencies of all other wells, except Well No. 4,have also shown improvement. Staff recommends that the Company continue to monitor all wells but focus on Well No. 4 to determine if there are issues hampering its efficiency and perform corrective action to address any issues identified. The Company stated in Response to Staff s Production Request No, 2 that "it is always the Company's plan to refurbish one well per year, given the need for the repairs balanced with the finance ability of the Company." Staff recommends the Company include a description of these efforts in the future filings, along with water consumption and energy consumption data to demonstrate the effectiveness of its efforts. CUSTOMER NOTIFICATION The Company filed its customer notice and press release with its Application. Staff reviewed the documents and determined that they met the requirements of Rule 125 of the Commission's Rules of Procedure. (IDAPA 3l.01.01 .125). The notice was included with customers' October l, 202l,billing statements. The Company sent a press release to the Idaho Statesman and the Idaho Business Review at the time of the Application's filing on September 8,2021. As of Wednesday, October 20,2021, the Commission has received one comment that recommended the Company forego the de minimis decrease to keep the quality of service at a high level. STAFF RECOMMENDATION Staff recommends that the Commission: 1. Authorize a PPCA rate of 0.89o/o, aPPCA decrease of l.l7o/o; 2. Authorize a new Schedule No. 3 incorporating Staff proposed rates; 3. Order the Company to continue monitoring all wells but focus on Well No. 4 to determine if there are issues hampering its efficiency and perform corrective action to address any issues identified; and 4STAFF COMMENTS ocToBER 21,2021 4, Order the Company to inelude a desoiption of refurbishment efforts in future filings, along with water consrunption and energy consurnption data to demonshate the effectiveness of its efforts. Respectfully submitted this 2lrP day of Octoba 2021" Jr. Attonrey General J Technical Staff: Johan Kalala-Kasanda Kattry Stockton Yao Yin Chris Hecht i:umisc:oomment/eapw2 I jhrqikklqycwh commeffs 5STAFF COMMENTS OCTOBER 2I,2O2L Ol,raogoJ o'-ctr- **g FfF{Qc,ooccc JJJ r{IaI ? CL U.ci6zcLO(E(,e8b^ G =R Esgm .6aJErIdzj96 =_E$5=:X^i:EvararEEEEEE ;1fl NNoro<r> F{o0lrl{,} If,t8EEH e i6zaE5i'gEE =g g: E'o =oo= aLO.^seg668>>9oooG,G,A (E(ELts!ioEEgEEI!EEgC)u(,s cE €o)o F{ EoG,es 3R.8 t -CEE'-9q 9,:T E6(J)uLOIt -G (J?E8EoEE;E'=HE6 o tr qc tro-(Jo,qr-o, -gFceFgc,b<9rdEe!H=!<o-=eu= Nmtlatt)N ofco oG, (u6.!o !'l n88lRNGl(Osiqo:cn3o-f r..8)R8i{Or(of\@-o9qn u'i- o N Fl<r\ ramc6ta sf dlnor\1r| <li ct (no6dl \tr{lnooF<l| {r NoI6o =ICL IJ cizo r!(J N(O o(r1 c;z o:E' o oo- oan Flrn(o<t| 6m F{rn(o<,\ xcl aElol EIol(Jl EIa!l t^t r C)lENIoel E;I =ol?!l EEEIe gEl EE EI EisIBgdEdblee EllE o urlilccl6g g -E rlf!luol E$l Attachment A Case No. CAP-W-21-01 Stajf Commentsl0l2ll2l Page I of 2 Capltol Water Corporation ldaho Power Cost Spreadsheet - 2020 Revised with late Fees Charses Removed Office Shop wellill o{Ltl2o o:/lil2o otltsl2o Wellfz oLlLilzo Wellfl3 ol'lL4l20 Well lr4 Wellf5 Wellfl6 oVLTlzO Oilt6l20 O,/ttl2o Total $ - Wthout Late Late Totals - wlthFees Fees Late FeesAII KWH 32560 66,850.001845.03 5 4,376.47 WellfT oytTl2oDate KWH Charges Late Fee Date KWH Charges Late Fee 2831 ?51.78 11.18 021L2/20 02/L2120 24L7 62 232.L8 12.05 5654875 1o2.71 46.41 02172120 o3l72l20 OzlL3l2O 02118/20 0zlI-slzo O2lL3l2O9l8 1s s9 2320 23580 2600109.81 6.88 46.69 334.32 t38/,.32 311.46 S 4,375.47 5 4,209.72 5 4,209.72 S 3,428.s8 S 3,428.s8 s 3,913.43 s 3,913.43 S s,446.09 5 5,440.09 5 7,s32.70 5 7,532.70 s 9,5s5.6e s 9,5s5.59 5 L2,974.32 5 L2,974.32 s 12,587.91 s L2,7L7.66 130 8359.8s 5 g,C44.qt 75 S 4,478.26 5 c,qta.za $ 4,326.23 $ q,tza.zz S 81,300 zos $ 8r,i04,62 Attachment A Case No. CAP-W-2l-01 Staff Commentsl0l2ll2l Page 2 of 2 L4 6.76 2680 25340 2440 351.09 1457.29 304.22 Date KWH Charges Late Fee Date KWH Charges Late Fee Date KWH Charges Late fee Date KWH Charges Late Fee 2040 215.01 50 L0.72 55 45.3 151 150.99 2520 343.57 2350 775.52 10560 781.91 740() 961.52 1350 220.U c3lrslzo 29540 1709.09 03113120 03/12/20 O3h2/20 O3h2l2O O3/L2/20 031t9120 0317il20 A3lLz/20 02h8l20 31000 L772.OL 63095 47130 40130 74254 105552 125078 183129 t8/]679 t23670 57573 60554 13792 u/Lo/20 ulLolzo1146 40L29.26 9.62 94.49 6.65 ulI:olzo ul1;olzo620 1377.58 6.65 o4lLolzo ult6l20 ultslzo MlL0/20 320 150.7 ulL6l2o 28080 \il7.49 0slil20 oslL!2o 05/t!20 0shtl20 oSlLLlzO 0shsl20 OslL4l2O OslLtlzl87s0 1350 21860 4040 554.95 557.84 L374.35 648.11 585 74.26 zo 7.43 13265 osltsl20 37360 2069.7942.71 5.65 of,ltolzo o6l]lolzo o6lt1l2o o6ltol20 06lLol20 o6lL6l2o o6hsl?:0 06170120225 26 6 t4 21s60 1640 23950 1892039.74 A.L2 L7.3 6.76 1307.39 791.3 1599.98 1440.3 o7lLllzo 07/Lo/20 07113120 0il10/20 0ilLo/20 06lL6/20 39200 2327.81 Date KWH Charges Late Fee Date KWH CharBes Late Fee 493 72.47 5 L7.36 22325 L528.73 22 7.74 L2 6.59 07 lL6l20 07 llslzl 07 lt1/205500 29300 23880 1143.84 2L44.7t L928.24 07h6l2o 43440 2N7.Ot osltllzo oshLl2o o8lt2p0 cEhLlzo o6l7Ll20 D8ltilzo o8l74lzo 08lL!207279 2L 6 L2 30291 25480 35880 47840161.4 7.62 t7.36 6.59 1967.06 2234.58 2587.68 3246.65 o8h7l20 42320 2745.38 Date KWH Charges Late fee Date KWH Chartes Late Fee oelLLl2o oglrllzo1348 25155.23 8.081.61 0.08 LOl72l20 t0lLzlao237 2L40.94 7.52 o9lt4l2o 0elLtl20 oglLllzo @lL6l2o o9/tsl20 @/1u20 09/16120 45120 2774.2L 27.45 7 t7.45 o.L7 33255 2074.86 L9.67 L4 5.82 0.07 2il40 34780 43580 2158.02 2454.92 2928.3222.35 25.88 32.47 LOlL3lzO Lllt2lzo612L7.3 5.59 tol 15120 LOI Lslzl Lol L2l2o7440 29280 2L520 1035.87 1904.L7 7484.7821.8 24.8r LuLil?O Lut6l20 tilL].l2l L0lL2/20 24394 M79.Or 1920 314.28 2320 499.22 10176120 40760 2393.s7 28.01 tut7l20 30320 1857.63 18980 1243.41 18780 1187.56 Date KWH Charges Late Fee Date KWH Chartes Late Fee 1211u20 84 r54.76 3120 378.89 840 \72.r4 LzlL7l20 34720 208/.7 Ltll2l20 LuL2/20 tiltu2o tutLl2o LL/tzl2Ou9 33 286 L4 315183.11 9.01 45.94 6.82 408.84 LzltLlzl tzltl.l2l rz/filzo r2hLl20 2086 225.7r r2lL7 l2O t2l76l20 t2ltll20 t4850 Total all KwH Tot l cost 50 10.95 104.7 6.82 1131794 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 2I't DAY OF OCTOBER 2021, SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN CASE NO. CAP-W-2I-OI, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING: ROBERT PRICE PRESIDENT CAPITOL WATER CORP 2626ELDORADO BOISE ID 83704 E-MAIL : capitolwatercom@yahoo. com S CERTIFICATE OF SERVICE