The use of the ECAC to recover the difference between estimated and actual variable power costs was approved in PacifiCorp's prior general rate case.8 Thus the only issues in this proceeding involve the application of the ECAC to the actual variable power costs incurred by PacifiCorp and confirmation of those costs. In its September 4, 2009, protest, DRA stated that it would review the assumptions underlying PacifiCorp's proposed offset rate as well as PacifiCorp's proposed cost allocation, rate design, and supporting assumptions.9 Over the course of its investigation, DRA satisfied itself that PacifiCorp accurately tracked variable power costs and properly accounted for them. DRA therefore concluded that PacifiCorp's ECAC application was reasonable.
8 DRA did not propose to audit PacifiCorp's accounts, but has the right to audit them in a subsequent ECAC filing or as part of PacifiCorp's next general rate case.
9 On September 14, 2009, PacifiCorp responded to DRA's protest by submitting two documents. The first document was entitled "Reply of PacifiCorp to Protest of the Division of Ratepayer Advocates"; the second was entitled "Response of PacifiCorp to Protest of the Division of Ratepayer Advocates." But for their titles these documents appear to be identical.