20040430Comments.pdf

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OPERATIONS
DEPARTMENT
200 W. Front Street
Boise, Idaho 83702
Dave Logan
Director
(208) 287-71 00
Fax [phone]
April 30, 2004
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
. Boise, Idaho 83720-0074
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY
TO INCREASE ITS INTERIM AND BASE RATES
AND CHARGES FOR ELECTRIC SERVICE.
CASE NO. IPC-O3-
Ada County would like to take this opportunity to comment on the current Idaho Power
rate case. Ada County has ~bout 20 electric accounts that combined, used over 13,000 000
kWh in 2003 with total electric costs for the year of approximately $600 000. Our facilities are
very diverse and include the Western Idaho Fairgrounds, EMS, Barber Park, Hidden Hollow
Sanitary Landfill, the Public Safety Building, and detention facilities such as the Ada County Jail
and Juvenile Court Services. Due to the diversity of our facilities, we are also on a wide range
of rate tariffs, including Rate 155, Rate7s, and Rate 9s.
We have estimated that if the rate increases were adopted as proposed, our Rate 9
accounts would increase anywhere from 10% to 31%, and our RateTs would increase 117% to
183%. Our 2 largest accounts will potentially move to a Rate 19 in 2004, and the full impact is
yet unknown. We believe time-of-userates are a good way to send pricing signals, however,
they are most beneficial for customers who have some flexibility regarding their . energy
consumption and can take advantage of off-peak discounts. Unfortunately, some of our largest
facilities are detention centers that operate 24/7 and cannot capitalize on time-of-userates.
In reviewing testimony submitted to-date, we found extensive comments from AARP and
CAP on the increase of the residential customer service charge from $2.51 to $10 and the affect
it will have on those who live ona fixed income. We concur with Dr. Power s direct testimony on
page 5 where he states
, "
All businesses have fixed costs. Most businesses do not try to cover
those fixed costs with fixed charges... They include those fixed costs in the charges they make
to customers and those charges tend to be proportional to the purchases that the customers
make." We also agree with comments made in the CAPAI and AARP Post Hearing Brief, page
, "
The uncertainty of revenue recovery for Idaho Power is primarily due to changes in weather
conditions. Butthe Company has already been significantly insulated from the variable through
the PCA. Adding to that a fixed monthly charge further locks in the Company s revenues... But
as a matter of public policy, this is not in the best interest of the Company s ratepayers.
Page 2
Ada County also operates on a "fixed income" and will face the same struggles to
maintain our buildings in optimum condition and provide our employees and the public clean,
safe facilities if more of an already restricted operating budget goes toward fixed costs over
which we have no control. We would support voluntary time-of-use rates for Schedule 9, as
described by Kevin Higgins on behalf of the Kroger Co, rather than increased fixed costs
through higher "service charges." We also support implementing the condition described in the
direct testimony of Dr Dennis Goins, on behalf of DOE, page 8, to "require IPC to prepare and
file semiannual reports for the first year in which the rate is in effect concerning the
implementation of the new TOU rate. At a minimum, these reports should include not only
analyses of how well customers understand and respond to the new rate, but also detailed
customer billing analyses that would enable to Commission to evaluate whether the rate is
creating unanticipated and unacceptable hardship on some customers.
There has been much testimony regarding the cap on the rate increase for the irrigation
class. United Water's Jerry Healy and other intervenors are of the opinion that rates should
accurately reflect cost of service for each customer class. We strongly concur and it is our
position that subsidies should be phased out over a reasonable period of time such that the
parties directly affected have time to prepare and respond.
Along the same lines, if the IPUC determines that a rate increase is appropriate at this
time , we would request that it be phased in over a 2 or 3-year period rather than a one-time
double-digit increase. In the future, we would prefer that all rate increases be planned and
announced providing customers with ample notice in order to adjust budgets and priorities. Ada
County operates on a fiscal year of October through September and our budgets are set by
April. Rate increases occurring after April put us in a difficult position to complete planned
projects and still maintain our facilities in the best condition possible.
We appreciate the opportunity to comment and the IPUC'consideration of our
comments. We look to the PUC staff and commissioners to make a fair and reasonable
decision based on all the information provided.
Respectfully,
L;;
Dave Logan ?:J'
Copies hand delivered to:
Idaho Power Company
Barton L Kline and John R Gale
1221 W Idaho Street
Boise, 10 83707
Board of Ada County Commissioners
Judy Peavey-Derr, Fred Tilman, Rick Yzaquirre
200 W Front Street
Boise, 10 83702