20061002NEWC to IPC 1.pdf

Law Office of William M. Eddie
610SW Alder St. Suite 910
Portland, OR 97205
Ph: 503-542-5245
Fax: [phone]
Cell: 208-484-7908
September 29 2006
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
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€A)Please find enclosed for filing three (3) copies each of the SECOND PRODUCT~N 0
REQUESTS OF NW ENERGY COALITION and NWEC'S RESPONSE TO FIRsT
PRODUCTION REQUEST OF IDAHO POWER COMPANY in the matter referenced
above. I have included a cover page of each document to be conformed and returned to
me.
Re: IPC-O6-
Dear Ms. Jewell:
William M. Eddie
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William M. Eddie (ISB# 5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland, OR 97205
Ph: [phone]
Fax: [phone]
bill (fYeddi ela wfirm. com
RECEIVED
2006 OCT -2 AM 8: 31
IDAHO ,)UELiC
UTILITIES COMI"'J!SSIOi,j
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICA TION OF THE LOAD GROWTH
ADJUSTMENT FACTOR WITHIN THE POWER)
COST ADJUSTMENT (PCA) METHODOLOGY
CASE NO.IPC-06-
NW ENERGY COALITION'S RESPONSE TO THE FIRST PRODUCTION
REQUEST TO IDAHO POWER COMPANY
COMES NOW, NW Energy Coalition and, in response to Idaho Power
Company s First Request For Production To NW Energy Coalition dated September 26
2006, submits the following information:
REQUEST NO.1: In his answer on page 6 at line 2, NW Energy Coalition
witness Weiss testifies that the addition of a single kilowatt hour of load increases Idaho
Power s revenues by "about 6.5 cents, because this is how much extra the customer pays
for the kWh." Mr. Weiss goes on to note in a footnote to the above-referenced testimony
that he has "assumed that the additional kilowatt hour is priced at the higher, marginal
block rate." Please identify the source ofthe 6.5 cent per kWh amount cited in the
above-referenced testimony and footnote.
RESPONSE TO REQUEST NO.
The 6.5 cent/kWh figure is an approximate figure based on the current residential
summer-time marginal block base rate of 6.1 06 cents/kWh, plus an assumed 0.4
NWEC'S RESPONSE TO FIRST PRODUCTION REQUEST OF IDAHO POWER
COMPANY--
cents/k Wh to reflect revenues from the $4.00 service charge averaged over a typical
residential usage rate of 1000 kWh/month. In reviewing his testimony, Mr. Weiss
believes it is appropriate for purposes of his illustration to include 0.4 cents/kWh as
revenues received from each kWh of load growth attributable to the addition of a new
customer. However, for load growth attributable to existing customers it would be more
appropriate to assume in his illustration that Idaho Power receives 6.106 cents/kWh in
revenue from each additional kWh. Mr. Weiss intends to makes this clarification at
hearing; it does not impact the substance of his testimony.
The response to this request was prepared by Steven Weiss in consultation with
William Eddie.
DA TED this 29th day of September, 2006.
William M. Eddie
On behalf of NW Energy Coalition
NWEC'S RESPONSE TO FIRST PRODUCTION REQUEST OF IDAHO POWER
COMPANY-- 2
CERTIFICATE OF SERVICE
I hereby certify that on this 29TH day of September 2006, true and correct copies
of the foregoing NW ENERGY COALITION'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF IDAHO POWER COMPANY were delivered to the
following persons via ns. Mail:
Jean Jewell (3 copies)
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Barton Kline
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Lawrence Gollomp
Assistant General Counsel
S. Dept. of Energy
1000 Independence Ave., SW
Washington, DC 20585
Dale Swan
Exeter Assoc., Inc.
5565 Sterret Place, Suite 310
Columbia, MD 21044
NWEC'S RESPONSE TO FIRST PRODUCTION REQUEST OF IDAHO POWER
COMPANY-- 3