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Home My WebLink About20110823IPC to Staff 140-141.pdf1SIDA~PO~ An IDACORP Company LISA D. NORDSTROM Lead Counsel Inordstromt.idahopower.com August22,2011 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83720 Re: Case No. IPC-E-11-08 General Rate Case Dear Ms. Jewell: Enclosed for filing are an original and one (1) copy of Idaho Power Company's Response to the Sixth Production Request of the Commission Staff to Idaho PowerCompany in the above matter. . Very truly yours, ~ j) Yl oJ Lisa D. Nordstrom LDN/kkt Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise. 10 83702 LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) JASON B. WILLIAMS Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(ãidahopower.com dwalker(ãidahopower.com jwilliams(ãidahopower.com R. r: (; i: I. '\ !~.,," ;0.) l_.r'1 20" 'iir 2') pi...j L. 1.2f j l ti-_.v_L. l. y- 4- Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR ELECTRIC )SERVICE IN IDAHO. ) ) ) ) ) CASE NO. IPC-E-11-08 IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Sixth Production Request of the Commission Staff to Idaho Power Company dated August 2, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO. 140: In this filing the Company is proposing to allocate all costs that have previously been allocated to the FERC Jurisdiction to the Idaho and Oregon Retail Jurisdictions. The Company is also proposing to allocate all FERC Jurisdictional revenue to Idaho and Oregon as an offset to the costs. What is the revenue requirement difference to the Idaho Jurisdiction of this proposed change? Please provide the Jurisdictional Separation Study ("JSS") that quantifies the Idaho Revenue Requirement under existing methodology and the calculation of the Idaho revenue requirement difference between the current and proposed methodologies. Please provide the spreadsheets with working formulae. RESPONSE TO REQUEST NO. 140: The Idaho revenue requirement is $4,785,633 higher based on the proposed change to the Federal Energy Regulatory Commission ("FERC") jurisdiction compared to the existing methodology. Please see the attached Excel file showing the JSS under the current methodology and the proposed (as filed) methodology. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO. 141: Please explain the reasons for the proposed change described in Request No. 140. RESPONSE TO REQUEST NO. 141: Under the Company's traditional jurisdictional allocation methodology, it was assumed for the allocations that each jurisdiction's transmission and distribution responsibility was proportional to the demand that each jurisdiction placed on the Company's system. The identical allocation methodology was applied uniformly by the Company for both its retail and firm transfer customers. In 2006, the Company was authorized by FERC to implement a formula rate for transmission service provided under its Open Access Transmission Tariff ("OATT"). It should be noted that Idaho Power itself is the Company's largest transmission customer because its retail customers are subject to the OATT formula rates as authorized by FERC when the Company buys and sells on behalf of its retail customers. The FERC's OA TT formula rate calculation does not synchronize with the Company's currently approved allocation methodology in significant ways. Under the formula rate, FERC prescribes defined classifications of plant and expenses authorized for functionalization as transmission and thereby bilable to its firm transfer customers under the rates of the Company's OA TT. This FERC-specific functionalization of transmission plant and expenses has become divergent from the Company's current JSS model in the following areas: 1. The OA TT rate does not allow for inclusion of any distribution facilities or expenses and therefore allocation of distribution-related costs to the IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 Company's firm transfer customers should be removed from the retail ratemaking modeL. 2. The OA TT rate specifically excludes Load Dispatching Expenses so they should not be allocated to firm transfer customers in the retail rate making modeL. 3. The OATT rate specifically excludes generator step-up stations and generator interconnection facilities so they should not be allocated to firm transfer customers in the retail ratemaking modeL. The OATT rate formula's divergence from the Company's currently approved ratemaking methodology manifests itself in a host of ways, creating many opportunities for double-counting or exclusions if attempting to harmonize the two differing methodologies into a single allocation method. The response to this Request was prepared by Kelley Noe, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 22nd day of August 2011. æ12~LISA D. NOR TROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22nd day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Donald L. Howell, II Karl T. Klein Deputy Attorneys General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX X Email Don.Howell(ãpuc.idaho.gov Karl. Klein(ãpuc. idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2ih Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email peter(ãrichardsonandolearv.com greg(ãrichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email dr(ãbenjohnsonassociates.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED 201 East Center P.O. Box 1391 Pocatello, Idaho 83204-1391 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email elocaracinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email tonycayankel.net IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 The Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology, Inc. MaryV. York HOLLAND & HART LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 The United States Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Dwight D. Etheridge Exeter Associates, Inc. 10480 Little Patuxent Parkway, Suite 300 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX X Email kboehmcaBKLlawfirm.com jrhcabattfisher.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email khigginscaenergystrat.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email myorkcahollandhart.com tnelsoncaholland hart. com madavidsoncaholland hart. com fsch m idtca holland ha rt. com i nbuchanancaholland hart. com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email remalmgrencamicron.com Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Arthur.brudercahq.doe.gov Steven. portercahq .doe. gov Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email detheridgecaexeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email bmpurdycahotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email bottocaidahoconservation.org Snake River Allance Ken Miller Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email kmilercasnakeriverallance.org NW Energy Coalition Nancy Hirsh, Policy Director NW Energy Coalition 811 First Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email nancycanwenergy.org æ,l),'f"~Lisa D. Nordstro~ IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7