20040211Comment.pdf

Jean Jewell
From:
Sent:
To:
Subject:
Ed Howell
Tuesday, February 10, 2004 3:37 PM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WWW Form Submission:
Tuesday, February 10 , 2004
3:37:17 PM
Case: IPC-E-03-13 (Idaho Power rate increase)
Name: David Chamberlain
Street - Addres s: 2636 W. Sugar Cres t Dr.
City: Eagle
State: ID
ZIP: 83616
Home Telephone: [phone]
E-Mail: dave - robyn82 ~yahoo. com
Company: Idaho Power
mai1ing 1ist yes no: yes
Comment description: I am opposed the general rate increases proposed by Idaho Power.While not an expert in regulated utili ties accounting, I have the following comments;
1) I womewhat understand the Rate of Return on Common Equity theory and its use in
determining rates. However , I don t completely understand the theory of using just 1
test year.It seems that the company did not need any additional requests or need to
use the ADITC in previous years and had some surplus to refund to users in 1996-99 because
of excess ROE. It is evident or compelling that the test year 2003 drives the need for
significantly higher base rates to achieve a reasonable return.
2) I understand the need to maintain reasonable credit ratings and borrowing ability.
also understand that in looking at rate increases you exclude non-regulated IdaCorp
company financial impacts. However , I also understood from Mr. Lobb that IdaCorp results
do somewhat impact credit ratings. Maybe I misunderstood. But if results of the
irresponsible and stupid , bordering unethical , management practices of IdaCorp do impact
Idaho Power ratings then I would suggest a complete divorce of Idaho Power. The
underlying economics of Idaho Power are stable and sound. IdaCorp is erratic and
irresponsible done for "shareholder diversification.The two should not be allowed to
mix in any way.
3) While I cannot yet set details for Idaho Power s Q4 , 2003 financial results it seems
that they are still sound with an adequate return. I fail to see the underlying
structural need for so significant an increase in base rates or the $2.50 to $10 proposedincrease.
4) The PCA seems an adequate mechanism for dealing with market pricing volatility whenpurchasing supplemental power. Mr. Keen s testimony seemed to mix the two. I support the
PCA. I do not see the underlying structural change.
5) 2003/2004 has the potential for a substantially improved water/snowpack year.thi s change if you wai ted 6 months?
6) The top 3 industrial customers have a substantially reduced rate already and are notrecei ving a proportional increase. I would suggest substantial increases in their rates.
Mr. Keen referred to the IRP and public input requesting better contingency planning, more
investment in infrastructure to avoid the 2000/prob1ems. I don t know the details of that
plan , those inputs , or what FERC may be requiring. But it seems that we are now paying a
significant increase for an over-reaction perhaps to that problem. Again , part of that
problems seems associated with greed , poor management , (of which IdaCorp was also a part),
illegal behavior , and perhaps poor regulatory oversight. It does not seem to be caused by
a lack of infrastructura1 investments. It seems we have had to pay twice. Once for the
high rates driven by those behaviors and now a second time to invest in infrastructure in
case management & individuals ever become irresponsible and go unregulated again. That
seems wrong.7) Having been a controller at Hewlett Packard for several years I understand rising cost
Would
pressures and reduced income pressures that are a constant tension. I would expect Idaho
Power to be very aggressive in scaling fixed costs and pursuing efficiencies that can
offset some of the investment and inflationary pressures.
Bottom line. I do not see or undestand the underlyingsiginificant increase. I see a very sound Idaho Power
and managerial reasons for the increase. I am perhaps
the IdaCorp relationship and what I think of it's verypast.
economic reasons for the
company. I see a lot of political
overly and wrongly suspicious of
shady and poorly managed recent
I realize this input is late in the process but can perhaps be of some value.
Dave Chamberlain
Transaction ID: 2101537.Referred by: http: / /www.puc. state. id. us/ scripts/po1yform. d11/ ipuc
User Address: 161.114.181
User Hostname: 161.114.181