HomeMy WebLinkAbout200144_jh.docMEMORANDUM
TO: COMMISSIONER KJELLANDER
COMMISSIONER SMITH
COMMISSIONER HANSEN
FROM: JOHN R. HAMMOND
DATE: APRIL 4, 2001
RE: APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. IN CASE NO. IPC-E-01-3
On March 23, 2001, the Idaho Irrigation Pumpers Association filed an Application for Intervenor Funding in this case pursuant to Idaho Code § 61-617A and Commission Rule of Procedure 162.
APPLICATION
The Irrigators have provided the Commission with a summary of the expenses that they seek recovery for. These expenses are broken down into legal fees, witness fees and other costs and expenses as set forth in Exhibit A attached to the Application. The Irrigators seek recovery of $10,353.64 for expenses related to legal services performed by Randall C. Budge. The Irrigators also seek recovery of consulting fees in the amount of $7,496.21 incurred by using Tony Yankel.
This Application, however, did not come with an itemized statement or affidavit outlining these expenses. The Irrigators stated that they would provide one upon a request from the Commission. The Commission Staff has requested itemized statements from the Irrigators in order that the Commission will have better information on which to make a decision regarding intervenor funding in this case.
In support of its request for intervenor funding the Irrigators state that it has materially contributed to the decision in this case in the following manner:
By recommending that irrigation customer be paid a higher price for kWh saved which it believes would provide a greater level of participation and provide larger savings to the Company and ratepayers. Application at 1-2.
By arguing that the flat Mid-Columbia price utilized by Idaho Power’s Program was too low to measure its impacts.
By pointing out the relevant loss factor associated with delivering energy to irrigation customers of 11.79% which was not included in the Company’s calculations
By addressing the magnitude of the Company’s discounts based upon allege, risks, weather uncertainties and free riders.
By recommending that the Company be allowed to fully recover reduced actual marginal revenues associated with the program.
By encouraging irrigation customers to attend and testify in support of the Program at public hearings in this case which resulted in the flat 15¢ per kWh price and allowing Schedule 7 or 9 irrigation customers to also participate in the Program.
By spending substantial amounts of time prior to the filing of Idaho Power’s Program working with the Company to develop and implement conservation programs for the irrigation class.
The Irrigators assert that the expenses and costs incurred by the Irrigators are reasonable and were necessarily incurred. Furthermore, the Irrigators contend that these expenses and costs constitute a financial hardship for the Irrigators.
I believe that without an itemized statement outlining the expenses and costs that the Irrigators seek recovery of it is impossible to truly evaluate whether recovery of the full amount requested is justified. Randy Budge and his assistant are out the office until April 6, 2001. I expect he will provide the itemized statements of these expenses at this time.
This amount is broken down into two parts. $9.735.00 in legal fees resulting from 64.9 hours of legal work multiplied by the hourly rate of $150 an hour and $618.64 for costs.
The consulting fees are $6,600 (66 hours * $100 an hour) and $896.21 for costs.
MEMORANDUM 2