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
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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
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IDAHO POWER COMPANY
EXHIBIT NO. 4
DARRELL R. TOMLINSON
Order No. 28695
Available on IPUC Internet Site