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IIILIT IE~; CGr\I"liSSION
April 26, 2004
To Idaho Power and the Public Utilities Commission:
I am writing on behalf of the Hat Butte Mutual Canal Company. We are strongly opposed to the
proposed irrigation rate hike. Although the need for raising rates may indeed be necessary, the
division of the increase is inequitable. The amount of power used by irrigators has remained
virtually unchanged over the past ten years. During the same period , the amount of power used
by homes and businesses has increased substantially. Your proposed rate changes do not even
remotely mirror this breakdown of the increase in usage, with the greatest increase going to
irrigation. If new facilities are required to keep up with this growth , then those who are creating
the increased demand need to pay for the facilities.
----
Gerrit Siebelink
President, Hat Butte Mutual Canal Company
13735 MISSOURI AVE' NAMPA , IDAHO' 83686
PHONE: 208-467-9712 . FAX: 208-466-6222
~~CE!VED
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April 14 2004
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State ofIdaho
Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
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Subject: Proposed Idaho Power Rate Increases
Dear Sirs:
, the undersigned ratepayers, oppose the proposed rate increase, which we understand would
be from 17 to 25%. As we watch power rates go up we see the level of service going down.
understand that your staffhas recommended a rate increase of about 3%.
In our area any increase puts an additional financial burden on the elderly on fixed incomes, low
income working families, small business owners, and farmers and ranchers who are already
struggling.
We do not understand the intricacies of rate setting but we strongly believe that rate payers
should not be burdened with costs that should rightfully be assigned to stockholders or
developers. We urge you to listen to your staff, honor your responsibilities to us, the ratepayers
and deny the proposed increase.
Respectfully requested
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April 14 2004
State ofIdaho
Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
JT iLlrltS-c'6i,
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SSION
Subject: Proposed Idaho Power Rate Increases
Dear Sirs:
, the undersigned ratepayers, oppose the proposed rate increase, which we understand would
be ITom 17 to 25%. As we watch power rates go up we see the level of service going down.
understand that your staff has recommended a rate increase of about 3%.
In our area any increase puts an additional financial burden on the elderly on fixed incomes, low
income working families, small business owners, and farmers and ranchers who are already
struggling.
We do not understand the intricacies of rate setting but we strongly believe that rate payers
should not be burdened with costs that should rightfully be assigned to stockholders or
developers. We urge you to listen to your staff, honor your responsibilities to us, the ratepayers
and deny the proposed increase.
Respectfully requested
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, . lpal1b Power says1rni~t raise
rateS to pay for power'pJap.tSn.e~d-
~dto keep up with groWth.Th:e feal
i11justice of the rate hikes. is that ini-
,gators arenottheicarise'fodhe
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Raising energy rateS 25p~i:cent
On irrlgatorswi1l dainagctli~ #~qii~
my aJ1dseri()~sly~paq: liveW:J.oods
ttir()~ghout the state., O~p~haIf of'
Idahb's agriculnful1coqilill,liUty,
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, Public UtilitiesC()1Ilti1ission and ask
the1Il tq rejedihe25percellt ri.t~
hike.
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. Ralph C.Burton is preSident and chief
executive officer ofAmalgamatedSugM'
Company LLC.
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0 Dear Commissioners & Staff
iT \ \ ,, ice C rl ;~l1~ ~Ru for allowing me to ,comment on the Id~o. Power rate increase
-' 1 IL-l \ 'terse #i~C-03-13. My name IS DavId Bergh and I am WrItIng on behalf of myself
and the Sugarbeet Growers of Elmore and Owyhee counties, I am a partner with
my father on a 2300 acre farming operation in Elmore county and I also serve on
the board of directors of 'The Elwyhee Sugarbeet Growers Association' which
represents beet growers from Murphy to Glenns Ferry.
Myself and the majority of sugarbeet growers in our Association operate
high lift irrigated farms. Our district averages approximately 17 000 sugarbeet
acres annually with a direct economic impact to these two rural counties of nearly
$17 million from sugarbeets alone. With the average dollar rolling over 5 to 6
times in these communities the overall economic impact is approaching $100
million.
In southern Idaho the majority of rural economies are structured around
production agriculture, which in turn is structured around current input costs. To
upset this balance is to put all of this in jeopardy These small towns have virtually
no other industries to fall back on. Bear in mind that the Elwyhee District
represents only about 7% of the total sugarbeet acres raised in southern Idaho,
There are many other areas that will also be adversely affected all across the state,
I give you these facts to help illustrate the magnitude of the potential impact this
rate increase may have on these rural communities
As ag producers we are a captive market for Idaho Power. Weare also at
the mercy of the commodity markets when it comes to selling our product and
therefore we have no means by which to pass on this cost increase, Profit margins
have been, and continue to be, virtually non existent in production agriculture right
now and to expect producers to absorb this increase is unrealistic and
inappropriate. On these high lift operations our power costs are already the largest
single input cost in raising a crop, The increase in our pumping cost has far
outpaced increases in other input costs, in many cases by a factor of 2 or 3 times
the rate of other costs,
As sugarbeet producers we are somewhat unique in the fact that we have all
invested substantial amounts of money to purchase our sugar company and form a
grower owned co-op, The Snake River Sugar Company, to help us survive in a
very competitive global industry. In the case of the Elwyhee Beet Growers
Association, growers purchased a combined total of roughly 17 000 shares (gJ, $400
per share for a total investment of nearly $6.8 million in our district alone. These
shares not only give us the right to deliver beets to our co-op, they also obligate
to deliver our shares of production every year or face a severe financial penalty or
share forfeiture for failure to deliver, As shareholders we can not pick and choose
whether we want to raise beets or not each season, We must raise our beet shares
each and every year. This is pertinent to this issue because we are rapidly
approaching the point at which we can no longer cash flow a sugarbeet crop on
high lift operations. In some cases we are beyond this point already. Growers are
being forced to forfeit shares and liquidate their fanning operations because they
can no longer continue to raise sugarbeets, or for that matter any other crop, at a
loss. Most other rotational crops have already become unprofitable" due to low
commodity prices and excessive power costs. This power increase puts a large
number of sugar beet acres in my district, as well as other areas, in jeopardy. This
has the potential to put our co-op at a serious economic disadvantage and could
ultimately lead to the failure of the sugarbeet industry in southern Idaho.
I believe Idaho Power has failed to adequately present their case requesting
a 47% increase to achieve COS rates for irrigators. In testimony presented on
behalf of the Idaho Irrigation Pumpers Association Mr. Yankley presented a
number of issues regarding non- transparency and flawed methodologies in Idaho
Power s case. I don t see where these issues have been addressed adequately
enough by IPUC staff to justify this rate increase or any rate increase for that
matter. I am not going to pretend that I am an expert in energy and or PUC
matters but I am an experienced business man and I have read testimony from all
sides in this case and I am left feeling very uneasy about a number of issues
regarding this case, The way in which Idaho Power allocates overhead cost to
different rate schedules appears to be somewhat flawed and very vague in some
areas. Common sense would indicate that the increase in load and demand Idaho
Power is experiencing would be due to 100 000 new customers and the required
equipment and manpower to satisfy that load and demand. As an irrigator class
we have paid demand charges for many, many years to help cover the increased
load and demand resulting from our usage, Our load and demand has been steady
or even declining in the past several years, To penalize irrigators for this cost is
inappropriate, This cost increase needs to be passed on to the rate payers that are
causing the increase, mainly new residential hookups.
In Southwest Idaho, irrigators are also idling acreage, This season
approximately 25 000 acres will be idled leaving an extra 75 000 acre feet of water
in the Snake River, This is a win/win situation for Idaho Power in the fact that we
are decreasing load and demand for Idaho Power and at the same time leaving
water in the snake river for Idaho Power to generate additional hydroelectric
energy at no additional cost to the company and yet as irrigators we receive no
credit or even an acknowledgment from Idaho Power that this is occurring,
I would also like to add that a guaranteed 11 % return on equity is
inappropriate for a public utility in today s economy. Take a poll of any number
of private business and see what kind of returns they are experiencing and I think
you will find very few that are achieving this kind of return on equity, In a
capitalistic economy reward should be tied to risk. Idaho power has virtually no
financial risk and yet they are seeking returns greater than many other business
sectors, most of which have great risk in the marketplace. It is unfathomable to me
how the IPUC can allow a public utility to profit at these levels on the backs of
struggling ratepayers. Idaho Power is a monopolistic entity and as such it cannot
be allowed to profit at these levels unless it is also exposed to downside risk.
They can t have it both ways.
Another issue that needs to be addressed is the timing of this or any other
rate increase, Ag producers have to make plans to plant a crop well in advance of
May the 15th. Budgets have been set and approved and crops are planted and
many large input costs are incurred well in advance of this date. We are
committed to a full irrigation season without knowing what we will pay fot energy
costs. For Idaho Power or the IPUC to make major rate changes after the fact is
unfair and inappropriate to producers and their lenders. We need time to plan
ahead and to make adjustments before a crop is planted and a grower is committed
for an entire irrigation season. Therefore I would request that any rate increase
levied against irrigators not go into effect until the next irrigation season. This is
the only way that we as irrigators can adequately plan ahead and make adjustments
in our operations.
This rate increase request is a matter of financial life and death for my
industry and as such I would ask that as a commission you seriously consider not
granting any base rate increase nor any increase in demand charges to the irrigator
class at this time. As Idaho Power customers your commission is the only
representation we have as ratepayers. Weare relying on you to insure that we are
treated fairly and equitably by the public utilities. Our future as Ag producers is
in your hands.
I would invite each of you on the commission to tour some high lift areas in
these counties and personally witness the number of acres already idled due to
high power costs. I stand ready to assist if you are willing to see for yourselves
what is happening in these rural ag communities. You could be instrumental in
stimulating growth within rural Idaho if you are willing to do the right thing and
treat irrigators appropriately by not granting any increase in rates to Idaho Power
in this case.
Thank you for your time and consideration in this matter.
~ff
David E. Bergh /
Bergh Farms LLC & Elwyhee Beet Growers Association
6025 Highway 30 E
Mountain Home, ill 83647
208/573-3542
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