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HomeMy WebLinkAbout20011019Application.pdfTelephone (208) 388-2674, Fax (208) 388-6936 LARRY D. RIPLEY Senior Attorney October 18, 2001 HAND DELIVERED Ms. Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P. O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-01-____ Application For Order Approving Costs To Be Included in 2002/2003 PCA Year for Irrigation Load Reduction Program and Astaris Load Reduction Agreement Dear Ms. Jewell: Please find enclosed for filing an original and seven (7) copies of the Company's Application for an order approving the costs to be included in the 2002/2003 PCA year for the Irrigation Load Reduction Program and the Astaris Load Reduction Agreement. Also enclosed are nine (9) copies of the testimony and exhibits of Ms. Maggie Brilz and Mr. Darrell R. Tomlinson, with one copy designated as the Reporter's Copy. Once a court reporter has been retained, please advise me and I will forward the testimony to the court reporter via e-mail. Copies of the Company's Application, testimony and exhibits have been mailed to potentially interested parties as per the attached Certificate of Mailing. I would appreciate it if you would return a stamped copy of this transmittal letter for our files. Very truly yours, Larry D. Ripley LDR:jb Enclosures CERTIFICATE OF MAILING, Page 1 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 18th day of October, 2001, I mailed a true and correct copy of IDAHO POWER COMPANY'S APPLICATION and the TESTIMONY AND EXHIBITS OF MAGGIE BRILZ AND DARRELL R. TOMLINSON in Case No. IPC-E- 01-___ to the following named individuals: John Hammond, Deputy Atty. General ____ Hand Delivered Idaho Public Utilities Commission ____ U.S. Mail 472 West Washington Street ____ Overnight Mail P. O. Box 83720 ____ FAX Boise, Idaho 83720-0074 Lisa D. Nordstrom, Deputy Atty. General ____ Hand Delivered Idaho Public Utilities Commission ____ U.S. Mail 472 West Washington Street ____ Overnight Mail P. O. Box 83720 ____ FAX Boise, Idaho 83720-0074 Donald L. Howell, Deputy Atty. General ____ Hand Delivered Idaho Public Utilities Commission ____ U.S. Mail 472 West Washington Street ____ Overnight Mail P. O. Box 83720 ____ FAX Boise, Idaho 83720-0074 Conley Ward ____ Hand Delivered Givens Pursley LLP ____ U.S. Mail 277 North 6th Street, Suite 200 ____ Overnight Mail P.O. Box 2720 ____ FAX Boise, Idaho 83701 Alan W. Seder ____ Hand Delivered Astaris LLC ____ U.S. Mail 622 Emerson Road, 5th Floor ____ Overnight Mail St. Louis, Missouri 63141 ____ FAX Randall C. Budge ____ Hand Delivered Racine, Olson, Nye, Budge & Bailey ____ U.S. Mail P.O. Box 1391 ____ Overnight Mail Pocatello, Idaho 83204-1391 ____ FAX Anthony Yankel ____ Hand Delivered 29814 Lake Road ____ U.S. Mail Bay Village, Ohio 44140 ____ Overnight Mail ____ FAX CERTIFICATE OF MAILING, Page 2 Peter J. Richardson ____ Hand Delivered Richardson & O’Leary ____ U.S. Mail 99 E. State Street, Suite 200 ____ Overnight Mail P.O. Box 1849 ____ FAX Eagle, Idaho 83616 Stuart Trippel ____ Hand Delivered Trippel Mast Consulting LLC ____ U.S. Mail 506 Second Avenue, Suite 1001 ____ Overnight Mail Seattle, Washington 98104-2328 ____ FAX Richard E. Malmgren, Esq. ____ Hand Delivered Micron Technology, Inc. ____ U.S. Mail 8000 South Federal Way, MS 507 ____ Overnight Mail P.O. Box 6 ____ FAX Boise, Idaho 83707-0006 ______________________________________ LARRY D. RIPLEY APPLICATION, Page 1 LARRY D. RIPLEY ISB #965 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Phone: (208) 388-2674 FAX: (208) 388-6936 Attorney 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 APPLICATION ) OF IDAHO POWER COMPANY FOR AN ) CASE NO. IPC-E-01-___ ORDER APPROVING THE COSTS TO BE ) INCLUDED IN THE 2002/2003 PCA YEAR ) APPLICATION FOR THE IRRIGATION LOAD REDUCTION ) PROGRAM AND ASTARIS LOAD ) REDUCTION AGREEMENT ) ) Application is hereby made to the Idaho Public Utilities Commission (the "Commission") by Idaho Power Company ("Idaho Power" or “the Company”) for an order approving the costs to be included in the 2002/2003 PCA year for the Irrigation Load Reduction Program and Astaris Load Reduction Agreement. In support of this Application, Idaho Power represents as follows: I. Idaho Power is an Idaho Corporation, whose principal place of business is 1221 West Idaho Street, Boise, Idaho 83702. APPLICATION, Page 2 II. Idaho Power operates a public utility supplying electric service in Southern Idaho and Eastern Oregon. Idaho Power is subject to the jurisdiction of this Commission in Idaho and to the jurisdiction of the Oregon Public Utility Commission in Oregon. Idaho Power is also subject to the jurisdiction of the Federal Energy Regulatory Commission (the "FERC"). III. On March 29, 1993, by Order No. 24806 issued in Case No. IPC-E-92-25, the Commission approved the implementation of an annual Power Cost Adjustment procedure. IV. On May 25, 2001, by Order No. 28699, the Commission issued its final order approving the Irrigation Load Reduction Program, which authorized payments for irrigation customers that committed to reduce energy consumption between March 1, 2001, and November 30, 2001, by at least 100,000 kWh. A copy of Order No. 28699 is included with this Application as Attachment 1. V. In Order No. 28699 the Commission found that the direct costs and reduced revenue impacts of the Irrigation Load Reduction Program should be treated as a purchased power expense in the Company’s Power Cost Adjustment (PCA) mechanism. APPLICATION, Page 3 VI. In Order No. 28699 the Commission also stated on Page 12 of that order that “Idaho Power and the parties shall develop and present a proposal to the Commission recommending a procedure to calculate the amount of revenue impact that should be passed through the Company’s PCA mechanism.” VII. A meeting was held with interested parties on September 27, 2001, at Idaho Power’s Corporate Headquarters during which the Company’s proposed methodology for computing the reduced revenue was discussed. VIII. The reduced revenue methodology calculation includes three components: The energy component addresses the revenue impact associated with the reduction in billed kWh as a result of the Irrigation Load Reduction Program. The demand component addresses the revenue impact associated with the reduction in billed kW as a result of the Program. The load reduction offset component reverses the load change adjustment to power supply expenses included in the PCA methodology. IX. As a part of this Application, the Company is requesting that the Commission approve the methodology for the calculation of the reduced revenue as set forth in the testimony of Maggie Brilz, which testimony is attached to this Application and referred to as if set out in full herein. APPLICATION, Page 4 X. The Idaho jurisdictional portion of the Irrigation Load Reduction Program costs to be included in the PCA computation through September 2001 is $58,592,015.96 including interest. XI. Commission Order No. 28695, a copy of which is included with this Application as Attachment 2, approved the inclusion of Astaris Load Reduction Agreement payments in the Company’s PCA. The payments to Astaris through September 2001 that should be included in the PCA, with interest, are $42,212,092.34. XII. Accordingly, the total amount of the Irrigation Load Reduction Program and the Astaris Load Reduction Agreement payments through September 2001 to be included in the 2002/2003 PCA is $100,804,108.30. XIII. As the Company books additional costs to the PCA for the Irrigation Load Reduction Program and the Astaris Load Reduction Agreement, the Company requests authorization to provide updated costs so that the Commission can issue an order authorizing the total amount to be deferred to the 2002/2003 PCA for the year 2001. The Company, in making this request, recognizes that it may not be practical for the Commission to issue an order approving the December deferrals before the Company closes its financial records for the year 2001 in January 2002. APPLICATION, Page 5 XIV. The Company will file a second application requesting an order approving the amounts deferred for the Irrigation Load Reduction Program and the Astaris Load Reduction Agreement to be included in the 2002/2003 PCA year that will not be included in the Commission’s order issued in this proceeding. XV. Simultaneous with the filing of this Application, the Company has filed its direct case consisting of the testimony and exhibits of witnesses Maggie Brilz and Darrell R. Tomlinson. The Company stands ready for immediate consideration of this Application, if it is the Commission's determination that a hearing should be held. XVI. Idaho Power respectfully requests that this Application be processed under RP 201, et al, allowing for consideration of issues to be processed under Modified Procedure, i.e., by written submission rather than by an evidentiary hearing. XVII. Communications with reference to this Application should be sent to the following: Larry D. Ripley Maggie Brilz Senior Attorney Director of Pricing Idaho Power Company Idaho Power Company P.O. Box 70 P.O. Box 70 Boise, ID 83707 Boise, ID 83707 WHEREFORE, Idaho Power Company respectfully requests (1) that the Commission issue its order approving the methodology for the calculation of the reduced revenue as a result of the Irrigation Load Reduction Program, and (2) for an order APPLICATION, Page 6 approving the costs to be included in the 2002/2003 PCA year for the Irrigation Load Reduction Program and the Astaris Load Reduction Agreement in the amount of $100,804,108.30. The Company further requests authority to supplement its filing in this proceeding as additional costs are incurred in the year 2001 for the Irrigation Load Reduction Program and the Astaris Load Reduction Agreement. DATED at Boise, Idaho, this 18th day of October, 2001. ________________________________ LARRY D. RIPLEY Attorney for Idaho Power Company ATTACHMENT 1 Order No. 28699 Available on IPUC Internet Site ATTACHMENT 2 Order No. 28695 Available on IPUC Internet Site BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR AN ) ORDER APPROVING THE COSTS TO BE ) CASE NO. IPC-E-01-___ INCLUDED IN THE 2002/2003 PCA ) YEAR FOR THE IRRIGATION LOAD ) REDUCTION PROGRAM AND ASTARIS ) LOAD REDUCTION AGREEMENT ) ) IDAHO POWER COMPANY DIRECT TESTIMONY OF MAGGIE BRILZ BRILZ, DI 1 Idaho Power Company Q. Please state you name and business address.1 A. My name is Maggie Brilz. My business address2 is 1221 West Idaho Street, Boise, Idaho.3 Q. By whom are you employed and in what4 capacity?5 A. I am employed by Idaho Power Company as6 Director of Pricing.7 Q. Please describe your educational background.8 A. In May of 1980, I received Bachelor of Arts9 Degrees in Economics and Psychology from Smith College in10 Northampton, Massachusetts. In 1998 I completed the11 University of Idaho’s Public Utilities Executive Course in12 Moscow, Idaho. I have also attended numerous seminars and13 conferences on pricing issues related to the utility14 industry and have attended seminars and courses involving15 public utility regulation.16 Q. Please describe your business experience with17 Idaho Power Company.18 A. I started employment with Idaho Power19 Company in November of 1984 as a Financial Analyst in the20 Planning Department. In 1986 I accepted the position of21 Rate Analyst in the Rate Department. My duties as a Rate22 Analyst included the development of alternative pricing23 structures, the analysis of the impact on customers of rate24 design changes, the preparation of cost-of-service studies,25 BRILZ, DI 2 Idaho Power Company and the administration of the Company's tariffs. In July of1 1993 I was promoted to Rate Design Supervisor. In that2 capacity, I also became responsible for the overall rate3 design activities of the Rate Department. In October of4 1996 I was promoted to my current position of Director of5 Pricing in the Pricing & Regulatory Services Department.6 Q. Were you involved with the creation and7 implementation of the Irrigation Load Reduction Program?8 A. Yes.9 Q. Have you previously testified before the10 Commission regarding the Irrigation Load Reduction Program?11 A. Yes. I presented testimony before the12 Commission at the public hearing held on March 13, 2001 in13 Case No. IPC-E-01-03.14 Q. What is the purpose of your testimony in this15 proceeding?16 A. The purpose of my testimony in this17 proceeding is to describe the costs associated with the18 Company’s Irrigation Load Reduction Program which are being19 treated as purchased power expenses in the Power Cost20 Adjustment (PCA) as per Order No. 28699 issued May 25, 2001.21 Exhibit No. 1 is a copy of that Order. My testimony also22 details the methodology which the Company believes is23 appropriate for computing the reduced revenue impact of the24 Irrigation Load Reduction Program.25 BRILZ, DI 3 Idaho Power Company Q. Would you please briefly describe the1 Irrigation Load Reduction Program?2 A. Yes. The Irrigation Load Reduction Program,3 or the “Buy-Back” program, is a voluntary load reduction4 program available to customers taking irrigation service5 under the Company’s Schedule 24 who commit to reducing6 energy consumption between March 1, 2001 and November 30,7 2001 by at least 100,000 kWh. The Company filed an8 application with the Idaho Public Utilities Commission on9 February 7, 2001 requesting authority to initiate the10 Program. On February 20, 2001 the Commission issued Order11 No. 28647 allowing the Company to solicit competitive bids12 from customers desiring to participate in the Program.13 Customers wanting to participate were required to submit14 their bids by 5:00 p.m. on Wednesday, February 28, 2001. On15 March 13, 2001 the Commission held a public hearing on the16 Company’s application. The Commission issued Interlocutory17 Order No. 28676 on March 14, 2001 approving the Company’s18 request to accept bids and implement the Program and19 requiring the Company to pay 15¢ per kWh for all kWh of20 energy reduction provided by participants whose bids were21 accepted. The Commission issued Order No. 28699 approving22 the Program on May 25, 2001 (Exhibit No. 1).23 Q. Does Order No. 28699 (Exhibit No. 1) address24 the treatment of the costs associated with the Irrigation25 BRILZ, DI 4 Idaho Power Company Load Reduction Program for PCA cost recovery purposes?1 A. Yes. Order No. 28699 (Exhibit No. 1) states,2 “The Commission further finds that the direct costs and lost3 revenue impacts of this Program may be treated as a4 purchased power expense in the Company’s Power Cost5 Adjustment (“PCA”) mechanism. “ (See page 12). The6 Commission also stated on page 12 of Order No. 28699, “Idaho7 Power and the parties shall develop and present a proposal8 to the Commission recommending a procedure to calculate the9 amount of revenue impact that should be passed through the10 Company’s PCA mechanism.”11 Q. How are the direct costs associated with the12 Program determined?13 A. The direct costs are the payments to14 customers for the energy reductions provided. The direct15 costs are determined by multiplying the reduced kWh (energy16 savings) provided by the Program participants by the 15¢ per17 kWh purchase price approved by the Commission.18 Q. Has the Company met with interested parties19 to develop a procedure to calculate the reduced revenue20 impact associated with the Program?21 A. Yes. A meeting was held with interested22 parties on September 27, 2001, at Idaho Power’s corporate23 headquarters during which the Company’s proposed methodology24 for computing the reduced revenue impact was discussed.25 BRILZ, DI 5 Idaho Power Company Q. Would you please describe the methodology the1 Company is proposing to calculate the reduced revenue2 impact?3 A. Yes. The methodology includes the4 calculation of three reduced revenue components. The Energy5 Component addresses the revenue impact associated with the6 reduction in billed kWh as a result of the Irrigation Load7 Reduction Program. The Demand Component addresses the8 revenue impact associated with the reduction in billed kW as9 a result of the Program. The Load Reduction Offset10 Component reverses the load change adjustment to power11 supply expenses included in the PCA methodology.12 Q. Please explain the Energy Component.13 A. The reduced revenue associated with the14 reduction in kWh usage is based on the kWh of energy15 reduction for which customers receive payment. The reduced16 revenue is computed by multiplying the kWh of energy17 reduction by the energy charge applicable for the specific18 billing period.19 Q. Please explain the Demand Component.20 A. The reduced revenue associated with the21 reduction in billed kW is computed only for the in-season22 billing periods of June through September, since this is the23 period during which the demand charge is imposed. Because24 the billed kW is directly related to the installed25 BRILZ, DI 6 Idaho Power Company horsepower at each metered service point, the basis for the1 computation is the difference between the billed kW for the2 billing period this year compared to the billed kW for the3 same billing period last year. By utilizing the billed kW4 at each metered service point last year as the basis for the5 computation of the reduced revenue, the most accurate6 representation of the level of billed kW the Company would7 otherwise have experienced this year is captured. The8 reduced revenue is computed by multiplying the difference in9 billed kW by the demand charge.10 Q. Please explain the Load Reduction Offset11 Component.12 A. The PCA methodology includes a load change13 adjustment to power supply expenses to reflect additional14 revenues with load growth or reduced revenues associated15 with load decline. The rate for the load change adjustment16 within the PCA methodology has been set at 16.84 mills/kWh.17 The Load Reduction Offset Component, which utilizes the same18 rate of 16.84 mills/kWh, eliminates a potential double19 counting of reduced revenue associated with the load change20 that would occur in the PCA methodology in the absence of21 this offset adjustment.22 Q. What is the basis for the Load Reduction23 Offset Component?24 A. The basis for the Load Reduction Offset25 BRILZ, DI 7 Idaho Power Company Component is the same kWh of energy reduction used as the1 basis for determining the Energy Component.2 Q. Is an adjustment required prior to computing3 the Load Reduction Offset Component?4 A. Yes. An adjustment for losses is required.5 Q. Please describe the adjustment for losses6 that is required.7 A. The load change expense adjustment8 incorporated in the PCA methodology is calculated at the9 load, or generation, level rather than at the customer, or10 metered, level. Therefore, in order to reverse the load11 change expense adjustment, the Load Reduction Offset12 Component needs to be calculated at the generation level13 rather than at the metered level.14 Q. What is the loss factor to be used for the15 irrigation class?16 A. The loss factor to be used for energy sales17 to the irrigation class as provided to me by the Company’s18 Customer and Load Research Department is 10.8%.19 Q. How is the Load Reduction Offset Component20 calculated?21 A. The Load Reduction Offset Component is22 calculated by multiplying the kWh of energy reduction for23 which customers receive payment by 1.108 to adjust for the24 10.8% losses and then by 16.84 mills/kWh to fully reverse25 BRILZ, DI 8 Idaho Power Company the load change expense adjustment incorporated in the PCA1 methodology.2 Q. Is the proposed methodology for computing the3 reduced revenue impact you have described in your testimony4 the same methodology presented at the meeting held with5 interested parties on September 27?6 A. Yes it is, with the exception of the7 inclusion of losses in the calculation of the Load Reduction8 Offset Component. The Company added this adjustment to its9 recommended methodology subsequent to the meeting held on10 September 27.11 Q. Did you prepare an exhibit which demonstrates12 the calculation of the Energy Component, the Demand13 Component, and the Load Reduction Offset Component as part14 of your testimony?15 A. Yes. I prepared Exhibit No. 2, which16 illustrates the calculation of the reduced revenue17 components for the month of August. Exhibit No. 2 consists18 of three pages. Each page addresses one of the three19 components of reduced revenue.20 Q. Please explain Page 1 of Exhibit No. 2.21 A. Page 1 details the calculation of the reduced22 revenue associated with the Energy Component for the23 Company’s Idaho jurisdiction for the August posting to the24 PCA. As Page 1 illustrates, adjustments to prior months’25 BRILZ, DI 9 Idaho Power Company energy savings as well as the recording of the current1 month’s energy savings are made during August. For example,2 line 1, column B on Page 1 shows a reduction of 343 kWh of3 energy savings for the month of April which are posted as an4 adjustment in August. Line 2, column B shows an increase of5 226,550 kWh of energy savings for the month of May which are6 posted as an adjustment in August. These adjustments result7 from changes made to the kWh billed to customers and can8 result from a number of causes such as incorrect meter9 readings and billing errors. Line 5 shows the 125,131,62110 kWh of energy savings provided during the August billing11 period. The revenue impact for each month is computed by12 multiplying the kWh of energy reduction by the applicable13 rate in effect at that time. For example, during the April14 billing period, the effective energy rate was 3.6891¢ per15 kWh. During the August billing period, the effective energy16 rate was 4.1831¢ per kWh. For both the May and June billing17 periods, customer billings are prorated between the pre-May18 1 and May 1 PCA energy charges since both these billing19 periods include usage consumed in the month of April. The20 new rate proration factors shown in column G identify the21 portion of usage for the May and June billing periods22 charged at the energy rates that became effective on May 1.23 Q. Please explain Page 2 of Exhibit No. 2.24 A. Page 2 details the calculation of the reduced25 BRILZ, DI 10 Idaho Power Company revenue associated with the Demand Component for the1 Company’s Idaho jurisdiction for the August PCA posting.2 Lines 1 and 2 show adjustments to prior months’ reduced3 demand which are posted as adjustments in August. Line 34 shows the 236,099 kW of reduced demand during the August5 billing period multiplied by the $3.58 demand charge.6 Q. How was the 236,099 kW of reduced demand for7 August computed?8 A. As described earlier, the reduced demand is9 calculated as the difference between the 2000 billed kW and10 the 2001 billed kW for the metered service points included11 in the Program. For August 2000, the billed kW for the12 metered service points included in the Program was 424,87313 kW. For August 2001, the comparable billed kW was 188,77414 kW. The difference between 424,873 kW and 188,774 kW is15 236,099 kW.16 Q. Please explain Page 3 of Exhibit No. 2.17 A. Page 3 details the summation of the reduced18 revenue Energy Components and Demand Components for the19 total Company. It also shows the calculation of the Load20 Reduction Offset Component. The Total Reduced Revenue shown21 in column E of $6,176,390.52 and the 16.84 Load Reduction22 Offset Adjustment shown in column F of $2,382,539.5523 represent the values to be booked to the Company’s PCA using24 the methodology recommended by the Company.25 BRILZ, DI 11 Idaho Power Company Q. Have the entries previously booked to the PCA1 for the Load Reduction Offset included the adjustment for2 losses described earlier in your testimony?3 A. No. The monthly entries booked to the PCA to4 date for the Load Reduction Offset do not include the5 adjustment for losses which I previously described in the6 calculation of the offset amount.7 Q. Does a “catch-up” adjustment need to be made8 to the PCA to record the impact of the losses on the offset9 amount?10 A. Yes, it does. Since the September postings11 to the PCA have already been made, a “catch-up” adjustment12 that will take into account the amount of losses associated13 with the energy savings since the beginning of the Program14 through September will be made in October. The calculation15 of the entries to record the Load Reduction Offset for16 October forward will include the adjustment for losses.17 Q. Have the Direct Payments to Customers, the18 Total Reduced Revenue, and the Load Reduction Offset that19 have been posted to the PCA through September of this year20 been calculated using the methodology you have described in21 your testimony?22 A. Yes. On a monthly basis I have calculated23 the Program costs using the methodology I have described and24 have provided these costs to Mr. Tomlinson for posting to25 BRILZ, DI 12 Idaho Power Company the PCA.1 Q. What methodology will you use to calculate2 the remaining costs through the end of the Program?3 A. I will use the methodology I have described4 in my testimony, with the inclusion of the adjustment for5 losses in the Reduced Revenue Offset Component, to calculate6 the remaining monthly costs associated with the Program.7 Q. Does the calculation of the reduced revenue8 impact include the impact associated with the Program9 participants in the Company’s Oregon service territory?10 A. Yes, it does. The revenue impact associated11 with the participants in the Company’s Oregon service12 territory is calculated using the same methodology as that13 used to compute the revenue impact associated with the14 Company’s Idaho customers participating in the Program.15 Q. Why is it appropriate to include the reduced16 revenue impact associated with the Company’s Oregon17 participants in the Total Reduced Revenue and Load Reduction18 Offset calculations?19 A. The Irrigation Load Reduction Program was20 designed to reduce the amount of energy the Company would21 otherwise be required to buy on the wholesale market in22 order to meet system demand. As such both the Idaho and23 Oregon Programs are viewed as “system” resources. Like any24 other system resource, i.e., purchased power, the costs25 BRILZ, DI 13 Idaho Power Company associated with the Program are properly identified at the1 system level and jurisdictionalized in the PCA.2 Q. How will the costs associated with the Oregon3 customer participation impact Idaho customers?4 A. The jurisdictional allocation built into the5 PCA mechanism will allocate 15% of the total system program6 costs to non-Idaho jurisdictions. Because of this7 allocation, costs associated with both the Oregon and Idaho8 Programs will be properly allocated to jurisdictions via the9 PCA methodology.10 Q. Does this conclude your testimony?11 A. Yes, it does.12 IDAHO POWER COMPANY EXHIBIT NO. 1 MAGGIE BRILZ Order No. 28699 Available on IPUC Internet Site IDAHO POWER COMPANY EXHIBIT NO. 2 MAGGIE BRILZ IDAHO POWER COMPANY Irrigation Load Reduction Program Calculation of Reduced Revenue Energy Component (A)(B)(C)(D)(E)(F)(G)(H) Pre-May 1 May 1 Pre-May 1 May 1 New Rate Line Out-of-Season Out-of-Season In-Season In-Season Proration Reduced No.kWh Savings Rate Rate Rate Rate Factor Revenue 1 April-Adj.(343) 0.036891 (12.65) 2 May-Adj.226,550 0.036891 0.049587 0.2407 9,049.98 3 June-Adj.(125,430) 0.029135 0.041831 0.9520 (5,170.42) 4 July-Adj (546,677) 0.041831 (22,868.05) 5 August 125,131,621 0.041831 5,234,380.84 6 TOTAL 124,685,721 5,215,379.69 Idaho Jurisdiction August PCA Posting Exhibit No. 2 Page 1 of 3 IDAHO POWER COMPANY Irrigation Load Reduction Program Calculation of Reduced Revenue Demand Component Idaho Jurisdiction August PCA Posting (A)(B)(C)(D) Line No.kW $/kW Revenue 1 June - Adj.35 3.58 125.30 2 July - Adj.79 3.58 282.82 3 August 236,099 3.58 845,234.42 4 TOTAL 845,642.54 Exhibit No. 2 Page 2 of 3 IDAHO POWER COMPANY Irrigation Load Reduction Program Summary of Reduced Revenue Including Load Reduction Offset Component August PCA Posting (A)(B)(C)(D)(E)(F)(G)(H) Total Total Saved kWh Line Total Reduced 16.84 Offset Saved Adjusted No.Idaho Oregon Prairie Revenue Adjustment kWh for Losses 1 April-Adj.(12.65) (12.65) (6.40) (343) (380) 2 May-Adj.22,360.53 22,360.53 4,227.13 226,550 251,017 3 June-Adj.2,207,884.89 391.76 2,208,276.65 (2,340.36) (125,430) (138,976) 4 July-Adj.(4,887.60) 1,315.02 (3,572.58) (10,200.29) (546,677) (605,718) 5 August 442.20 83,621.01 6,131.25 90,194.46 2,390,859.47 128,136,307 141,975,028 6 TOTAL 2,225,787.36$ 84,936.03$ 6,523.01$ 6,176,390.52$ 2,382,539.55$ 127,690,407 141,480,971 Exhibit No. 2 Page 3 of 3 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR AN ) ORDER APPROVING THE COSTS TO BE ) CASE NO. IPC-E-01-___ INCLUDED IN THE 2002/2003 PCA ) YEAR FOR THE IRRIGATION LOAD ) REDUCTION PROGRAM AND ASTARIS ) LOAD REDUCTION AGREEMENT ) ) IDAHO POWER COMPANY DIRECT TESTIMONY OF DARRELL R. TOMLINSON TOMLINSON, DI 1 Idaho Power Company Q. Please state your name, business address and1 present occupation.2 A. My name is Darrell R. Tomlinson and my3 business address is 1221 West Idaho Street, Boise, Idaho. I4 am employed as a Team Leader in the Financial Accounting5 Department at Idaho Power Company.6 Q. What is your educational background?7 A. I graduated in 1971 from Boise State8 University, Boise, Idaho, receiving a Bachelor of Business9 Administration degree. Since becoming employed at Idaho10 Power Company I have attended several courses involving11 financial reporting and ratemaking.12 Q. Please outline your experience with Idaho13 Power Company?14 A. In 1976, I was employed by the Company and15 assigned to the Property Accounting Department as a Senior16 Accountant. In 1977, I transferred to the Corporate17 Accounting and Budget Department. In 1979, I transferred to18 the Rate Department as a Planning Analyst. In 1981, I19 transferred to the Financial Services Department as a20 Financial Analyst. In 1992, I transferred to the Corporate21 Accounting and Reporting Department as a Business Analyst.22 In April 2001, I was promoted to Team Leader in the23 Financial Accounting Department.24 Q. What are your duties as a Team Leader in the25 TOMLINSON, DI 2 Idaho Power Company Financial Accounting Department?1 A. I am involved with the financial reporting2 requirements of the department including the responsibility3 for PCA accounting. I am also the coordinator for the4 Finance Department where I act as a liaison with the Pricing5 and Regulatory Services department.6 Q. What is the purpose of your testimony?7 A. The purpose of my testimony is to describe8 the accounting entries utilized to book the costs associated9 with the Irrigation Load Reduction Program and the Astaris10 Load Reduction Agreement that are included in the PCA.11 Q. Can you describe the components utilized to12 include the costs of the Irrigation Load Reduction Program13 in the PCA?14 A. Yes, the three components associated with the15 Irrigation Load Reduction Program include the Direct16 Payments to Customers and Total Reduced Revenue which17 includes a Load Reduction Offset Component as described by18 Ms. Brilz.19 Q. What account is used to book the costs20 associated with the Irrigation Load Reduction Program?21 A. The Direct Payments to Customers for their22 load reductions and the Total Reduced Revenue including the23 Load Reduction Offset Component are all booked to Account24 182.379. Detailed demonstration of these amounts is25 TOMLINSON, DI 3 Idaho Power Company reflected in Exhibit No. 3.1 Q. Did you prepare Exhibit No. 3?2 A. Yes.3 Q. Please describe Exhibit No. 3.4 A. Exhibit No. 3 is the workpaper which supports5 the Irrigation Load Reduction Program costs and Astaris Load6 Reduction Agreement costs included the PCA True-Up Report.7 Q. Please explain the detail associated with the8 Irrigation Load Reduction Program in Exhibit No. 3.9 A. Exhibit No. 3, lines 3-7, columns C-I reflect10 costs by month associated with the Irrigation Load Reduction11 Program that are provided to me by Ms. Brilz and included in12 the monthly PCA True-Up Report. Line 5, column P is the13 Total Reduced Revenue of $19,835,635.54 through September.14 Line 6, column P details the posting of the Load Reduction15 Offset Adjustment of -$7,046,583.28 through September. As16 detailed by Ms. Brilz, the postings to date for the Load17 Reduction Offset do not include the adjustment for losses.18 The -$7,046,583.28 shown on line 6, column P is the value of19 the Load Reduction Offset adjustment computed using the20 actual energy reductions recorded through September. These21 two lines plus Line 4, which details the posting of the load22 reduction payments to program participants of23 $63,162,233.22, equal the total program costs for the24 Irrigation Load Reduction Program through September of25 TOMLINSON, DI 4 Idaho Power Company $75,951,285.48 as shown on Line 7, column P. The total1 Irrigation Load Reduction Program cost of $75,951,285.48 is2 then multiplied by 90% to represent the 90/10 sharing3 between customers and the company. The resulting value is4 then multiplied by 85% to determine the Idaho jurisdictional5 portion of the programs cost as reflected on line 10 of6 $58,102,733.39.7 Q. Please describe Exhibit No. 4.8 A. Exhibit No. 4 is a copy of the Commission’s9 Order No. 28695 approving the inclusion of Astaris Load10 Reduction Agreement payments in the PCA.11 Q. What account is used to book the payments12 associated with the Astaris Load Reduction Agreement?13 A. The direct payments per the Astaris Load14 Reduction Agreement are booked to Account 182.377.15 Q. Please explain the detail associated with the16 Astaris Load Reduction Agreement payments in Exhibit No. 3.17 A. The payments of $54,575,050.78 to Astaris18 through September, 2001, for the load reduction are19 reflected on line 25, column P of Exhibit No. 3. The total20 payments through September are then multiplied by 90% to21 represent the 90/10 sharing of power supply costs between22 customers and the Company. The resulting value is then23 multiplied by 85% to determine the Idaho jurisdictional24 portion of the expense as reflected on line 28, column P in25 TOMLINSON, DI 5 Idaho Power Company the amount of $41,749,913.85.1 Q. Can you explain the interest calculated on2 lines 20 and 38, columns C-I of Exhibit No. 3?3 A. Yes, the interest is calculated by applying4 the Idaho allowed rate of 6% interest to the program costs5 beginning balance.6 Q. What is the total amount of costs associated7 with the Irrigation Load Reduction Program and the Astaris8 Load Reduction Agreement to be included in the PCA through9 September 2001?10 A. Through the month of September, the11 Irrigation Load Reduction Program cost is $58,592,015.96,12 the Astaris Load Reduction Agreement cost is $42,212,092.34,13 for a total of $100,804,108.30, as reflected on lines 22 and14 40, column P of Exhibit No. 3. It should be noted that15 these amounts include interest.16 Q. Will the Company provide additional monthly17 data as it becomes available?18 A. Yes, the data through September was available19 at the time this testimony was prepared and as additional20 monthly data is booked in the year 2001 it will be provided.21 Q. Will the Company file a second application to22 recover the balance of costs associated with the Irrigation23 Load Reduction Program and the Astaris Load Reduction24 Agreement attributable to the 2002/2003 PCA year?25 TOMLINSON, DI 6 Idaho Power Company A. Yes.1 Q. Does this conclude your testimony?2 A. Yes, it does.3 IDAHO POWER COMPANY EXHIBIT NO. 3 DARRELL R. TOMLINSON 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 A B C D E F G H I O P PCA Programs Cost March April May June July August September Totals March 2001 thru March 2002 Actual Irrigation - Acct 182379 Voluntary load reduction payments $0.00 0.00 6,843,557.85 8,398,211.72 16,218,244.31 19,133,569.98 12,568,649.36 63,162,233.22 Revenue reduction $0.00 0.00 1,805,493.44 2,930,802.91 5,398,476.35 6,176,390.52 3,524,472.32 19,835,635.54 Revenue Reduction Load Offset $0.00 0.00 0.00 0.00 (3,529,666.57)(2,150,306.45)(1,366,610.26)(7,046,583.28) Total Irrigation $0.00 0.00 8,649,051.29 11,329,014.63 18,087,054.09 23,159,654.05 14,726,511.42 75,951,285.48 Sharing Percentage 90%90%90%90%90%90%90%90% Idaho Allocation 85%85%85%85%85%85%85%85% Total Irrigation $0.00 0.00 6,616,524.24 8,666,696.19 13,836,596.38 17,717,135.35 11,265,781.24 58,102,733.39 Principal Balances Beginning Balance ***$0.00 0.00 0.00 6,616,524.24 15,283,220.43 29,119,816.81 46,836,952.16 Amount Deferred $0.00 0.00 6,616,524.24 8,666,696.19 13,836,596.38 17,717,135.35 11,265,781.24 58,102,733.39 Ending Balance $0.00 0.00 6,616,524.24 15,283,220.43 29,119,816.81 46,836,952.16 58,102,733.39 Interest Balances Accrual thru Prior Month $0.00 0.00 0.00 0.00 33,082.62 109,498.72 255,097.81 Monthly Interest Rate **6.0%6.0%6.0%6.0%6.0%6.0%6.0% Monthly Interest Inc/(Exp)$0.00 0.00 0.00 33,082.62 76,416.10 145,599.08 234,184.76 489,282.57 Interest Accrued to date $0.00 0.00 0.00 33,082.62 109,498.72 255,097.81 489,282.57 Balance in Account 182.379 Actual Astaris - Acct 182377 Load reduction payments $0.00 7,537,706.09 7,230,985.80 7,581,563.60 9,659,244.04 12,155,326.00 10,410,225.25 54,575,050.78 Sharing Percentage 90%90%90%90%90%90%90%90% Idaho Allocation 85%85%85%85%85%85%85%85% Total Astaris $0.00 5,766,345.16 5,531,704.14 5,799,896.15 7,389,321.69 9,298,824.39 7,963,822.32 41,749,913.85 Principal Balances Beginning Balance ***$0.00 0.00 5,766,345.16 11,298,049.30 17,097,945.45 24,487,267.14 33,786,091.53 Amount Deferred $0.00 5,766,345.16 5,531,704.14 5,799,896.15 7,389,321.69 9,298,824.39 7,963,822.32 41,749,913.85 Ending Balance $0.00 5,766,345.16 11,298,049.30 17,097,945.45 24,487,267.14 33,786,091.53 41,749,913.85 Interest Balances Accrual thru Prior Month $0.00 0.00 0.00 28,831.73 85,321.97 170,811.70 293,248.04 Monthly Interest Rate **6.0%6.0%6.0%6.0%6.0%6.0%6.0% Monthly Interest Inc/(Exp)$0.00 0.00 28,831.73 56,490.25 85,489.73 122,436.34 168,930.46 462,178.49 Interest Accrued to date $0.00 0.00 28,831.73 85,321.97 170,811.70 293,248.04 462,178.49 Balance in Account 182.377 Exhibit No. 3 Case No. IPC-E-01-_ D. Tomlinson, IPCo-Dir Page 1 of 1 IDAHO POWER COMPANY EXHIBIT NO. 4 DARRELL R. TOMLINSON Order No. 28695 Available on IPUC Internet Site