20061012IPC to NWEC 11, 12.pdf

IDAHO
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POWE R CID
LISA D. NORDSTROM
Attorney
An IDACORP Company
October 12 , 2006
HAND DELIVERED
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise , Idaho 83720-0074
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Re:Case No. IPC-06-
Petition For Modification of Load Growth Adjustment
Rate Within the Power Cost Adjustment Methodology
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company s Response to the Second Production Request of NW Energy Coalition
regarding the above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter
to me in the enclosed self-addressed stamped envelope.
Very truly yours7(~Lisa D. Nordstrom
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Enclosures
Telephone [phone], Fax [phone], E-mail LNordstromfBJidahopower.com
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BARTON L. KLINE ISB #1526
LISA D. NORDSTROM ISB #5733
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
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Attorneys for Idaho Power Company
Express Mail Address
1221 West Idaho Street
Boise , Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR
MODIFICATION OF THE LOAD
GROWTH ADJUSTMENT RATE
WITHIN THE POWER COST
ADJUSTMENT METHODOLOGY
CASE NO. IPC-06-
IDAHO POWER COMPANY'
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF NW
ENERGY COALITION
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company ) and , in
response to the Second Production Request of NW Energy Coalition to Idaho Power
Company dated September 29 2006, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF NW ENERGY COALITION -
REQUEST FOR PRODUCTION NO. 11:
Please provide actual-or in their absence, best estimates-of the average fixed
costs per customer that the Company incurs to serve new customers for each of the three
(3) most recent years that are available. Please break down these costs by customer
class for each class that would be affected by the PCA mechanism at issue in this docket.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
Actual fixed costs by customer class are not determined on a regular basis. The
Company s best estimate of the average fixed costs per customer would be derived by
completing a cost-of-service study. The cost-of-service study is one part of the
analyses completed in preparing for a general rate case. The information from the
cost-of-service studies for the Company s two most recent general rate cases, IPC-
03-13 and IPC-05-, will provide the Company s "best estimate" for the fixed costs per
customer in the most recent years.
The table below shows the number of customers and the class fixed costs for
each of the last two general rate case filings. The difference between the two rate
cases would be the Company s best estimate of the average fixed costs per customer
that the Company incurs to serve new customers in recent years.
Residential
Customers
Class Fixed Costs
IPC-O3-13 IPC-O5-28 Change
334 917 359 802 24 885
$132,442 770 $152 131 314 $19,688,544
Incremental Fixed Cost per New Customer $791.
Small Commercial
Customers
Class Fixed Costs
IPC-E-O3-13 IPC-E-O5-28 Change
33,618 34 310 692
$11 545 342 $13,435 685 $1 890,344
Incremental Fixed Cost per New Customer $2 731.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF NW ENERGY COALITION - 2
Large Commercial IPC-O3-IPC-E-O5-Change
Customers 213 587 374
Class Fixed Costs $45,408 759 $56,109 964 $10 701 205
Incremental Fixed Cost per New Customer $28,612.
Industrial IPC-O3-IPC-O5-Change
Customers 116 116
Class Fixed Costs $17 611 901 $22 696,177 $5,084 276
Incremental Fixed Cost per New Customer Nt
Irrigation IPC-O3-IPC-O5-Change
Customers 737 15,085 348
Class Fixed Costs $52 606,270 $51 362 375 ($1 243,896)
Incremental Fixed Cost per New Customer ($3,574.41)
Total Company IPC-O3-IPC-O5-Change
Customers 400 601 426,899 299
Class Fixed Costs $259 615,042 $295 735,516 $36,120,473
Incremental Fixed Cost per New Customer $1,373.
These computations are based on net investment after customer contributions in
aid of construction.
The response to this request was prepared by Mike Youngblood , Pricing Analyst
, Idaho Power Company, in consultation with Lisa D. Nordstrom , Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF NW ENERGY COALITION - 3
REQUEST FOR PRODUCTION NO. 12:
Please provide the same information requested in the previous question net of any
line extension revenues. In calculating the line extension revenues per customer per
year, assume an appropriate amortization time period.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
The question references line extension revenues which the Company believes is
a reference to customer contributions in aid of construction. Such contributions are
direct offsets to investment for ratemaking purposes. Please see Response to Request
for Production No. 11.
The response to this request was prepared by Mike Youngblood , Pricing Analyst
, Idaho Power Company, in consultation with Lisa D. Nordstrom , Attorney II , Idaho
Power Company.
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DATED this /.1...day of October, 2006 , at Boise , Idaho.
~ Ii li;~LISA D. NORDS ROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF NW ENERGY COALITION - 4
CERTIFICATE OF SERVICE
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I HEREBY CERTIFY that on this 12-day of October, 2006, I served a true
and correct copy of the within and foregoing document upon the following named
parties by the method indicated below, and addressed to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720-0074
) U.S. Mail , Postage Prepaid
(X) Hand Delivered
) Facsimile
(X) Email Scottwoodburv(g)puc.idaho.qov
Peter J. Richardson
Richardson & O'Leary PLLC
515 N. 2ih Street
Boise, Idaho 83702
(X) U.S. Mail, Postage Prepaid
) Facsimile [phone]
(X) Email peter(g1richardsonandolearV.com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83702
(X) U.S. Mail, Postage Prepaid
) Facsimile
(X) Email dreadinq(g1mindsprinq.com
William M. Eddie
Advocates for the West
610 SW Alder St, Suite 910
Portland, OR 97205
(X) U.S. Mail , Postage Prepaid
) Facsimile
(X) Email billeddie (g1 rmcLnet
Nancy Hirsh
NW Energy Coalition
219 First Ave South, Suite 100
Seattle, Washington 98104
(X) U.S. Mail , Postage Prepaid
) Facsimile
) Email
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington , DC 20585
(X) U.S. Mail, Postage Prepaid
) Facsimile
(X) Email Lawrence.qollomp(g1hq.doe.qov
Dale Swan
Exeter Associates, Inc.
5565 Sterret Place , Suite 310
Columbia , MD 21044
(X) U.S. Mail , Postage Prepaid
) Facsimile
(X) Email dswan (g1 exeterassociates.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION REQUEST
OF NW ENERGY COALITION - 5