20030611Trippel Direct.pdf

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UTILI T ItS ' COhi.JiiSSIO~~
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
KIMBALL PROPERTIES LIMITED
PARTNERSHIP AND HEWLETT
PACKARD COMPANY
COMPLAINANT S
CASE NO. IPC-E-OO-12
VS.
IDAHO POWER COMPANY AN IDAHO
CORPORATION.
DIRECT TESTIMONY AND EXHIBITS OF
STUART A.T. TRIPPEL
ON BEHALF OF
KIMBALL PROPERTIES LIMITED PARTNERSHIP
AND HEWLETT PACKARD COMPANY
TABLE OF CONTENT
QUALIFICATIONS .......................................
INTRODUCTION AND OVERVIEW OF TESTIMONY. . . . . . . . . . . . . . . 3
FACTUAL BACKGROUND ...................................
COST ALLOCATION ISSUES ..............................
Trippel , Di
Hewlett Packard andKimball Properties
address
Washington
PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
My name Stuart A.Trippel.My business
506 Seattle,Second Sui teAvenue,1001,
98104-2328.
WHAT IS YOUR OCCUPATION?
I am a principal in Trippel/Mast Consulting LLC,
a management consulting and consulting engineering firm that
provides services public and pri vate clients the
fields of public utili ties and process industries.
TESTIMONY?
ARE YOU SPONSORING ANY EXHIBITS WITH THIS
Yes.I am sponsorlng Exhibit Nos. 1 through 11.
QUALIFICATIONS
PLEASE DESCRIBE YOUR QUALIFICATIONS TO TESTIFY
AS AN EXPERT IN THIS PROCEEDING.
I have been a management consultant in the field
of public utility regulatory economics and related matters
for nineteen years.complete resume,including
educational background and employment history, is presented
as Exhibit No.
ARE YOU FAMILIAR WITH THE IDAHO PUBLIC UTILITIES
COMMISSION AND ELECTRICITY ISSUES IN THE STATE OF IDAHO?
Trippel, Di
Hewlett Packard and
Kimball Properties
Yes.have provided consul ting services
interested parties on numerous matters that have come before
the Idaho Public Utili ties Commission (the Commission
" )
over the past nine years.I have also prepared analyses and
presented informational workshops to parties with interest
in the Idaho electric utility industry during that time.
HAVE YOU PREVIOUSLY APPEARED EXPERT
WITNESS BEFORE THIS COMMISSION?
Yes.I was admitted as an expert before this
Commission and was cross-examined in the recent avoided cost
docket (Docket No. GNR-E-02-0 1) and the PCA energy cost bond
case (Docket Nos. IPC-E-02-2 and -3).I have also assisted
in the preparation of testimony and exhibits (sponsored by
another witness) in other contested proceedings, as well as
comments several notice-and-comment
( "
modified
procedure ) processes , since 1994.
INTRODUCTION AND OVERVIEW OF TESTIMONY
WHOSE BEHALF ARE YOU TESTIFYING THIS
PROCEEDING?
testifying behalf the Kimball
Properties Limited Partnership
( "
Kimball"and the Hewlett
Packard Company ("HP"
WHAT IS THE PURPOSE OF YOUR TESTIMONY?
Trippel , Di
Hewlett Packard and
Kimball Properties
The purpose of my testimony lS to present the
factual circumstances under which HP was required to pay a
contribution in aid of construction for a new substation
located just thewest Boise Towne Square shopping
complex.I also offer an opinion on the appropriateness of
the pa ymen t .
WHY SHOULD THE CIRCUMSTANCES UNDER WHICH HP WAS
CHARGED A CONTRIBUTION IN AID OF CONSTRUCTION BE OF INTEREST
TO THIS COMMISSION?
in my opinionHP was,unfairly singled out to
partially pay for the construction of a new substation known
as the Bethel Court Substation.
WHY DO YOU SAY THAT HP WAS UNFAIRLY SINGLED OUT
FOR PAYMENT OF ITS CONTRIBUTION IN AID OF CONSTRUCTION?
will show,Idaho Power Company (" Idaho
Power or the Company
" )
has an arbitrary and irrational
policy regarding payments from industrial customers for the
construction of substation and transmission lines.
ARE THERE OTHER REASONS THAT CAUSE YOU TO STATE
THAT HP WAS UNFAIRLY SINGLED OUT?
Yes.addi tion having arbi trary and
irrational policy, Idaho Power does not apply that policy on
consistent meansbasiswhich that not only
arbi trary and irrational but also capricious and
discriminatory.
Trippel , Di
Hewlett Packard andKimball Properties
FACTUAL BACKGROUND
WHAT HAS LED HP'COMPLAINT AGAINST IDAHO
POWER FOR RE FUND ITS CONTRIBUTION AID
CONSTRUCTION?
Beginning in 1999, Kimball began construction of
four buildings located on North Sailfish Place, West Golden
Trout Street, and North Kimball Place in the city of Boise.
These four buildings are commonly referred to as the Kimball
Business Park.
WHAT IS THE RELATIONSHIP BETWEEN KIMBALL AND HP?
directly reimbursed Kimball for the
construction of the Kimball Business Park , and HP currently
occupies all four buildings.These buildings are served
with electric power from Idaho Power under the Company
Schedule 19,the large industrial customer rate schedule.
Idaho Power determined that it was necessary to construct a
substation to provide electric thenewservlceto HP
Kimball Business Park to serve future loads in the area,
and to readj ust some existing loads.
WHERE IS THE KIMBALL BUSINESS PARK?
located between Emerald Street the
south and Franklin Road to the north.It is a little over
one mile west of the Boise Towne Square shopping center.
Trippel, Di
Hewlett Packard andKimball Properties
occupies what it refers to as buildings 26 28 and 29
located at 303 N. Kimball Place, 333 N. Sailfish Place , 9390
Golden Trout Dr.and 9415 Golden Trout Dr.
respectively.
DOES HP DISPUTE THE NECESSITY OF CONSTRUCTING A
NEW SUBSTATION TO SERVE FACILITIES IN THE KIMBALL BUSINESS
PARK AREA?
No.Al though other al ternati ves were explored
by Idaho Power,the decision to construct the substation
appeared the Company transmission and distribution
engineers to be the best solution to providing power to the
area.
WHERE IS THE BETHEL COURT SUBSTATION LOCATED?
The Bethel Court Substation located just
south Franklin Road adj acent Unionthe Pacific
railroad tracks.Attached as Exhibit No.2 is a map showing
all of Idaho Power s substations in a seven-mile radius of
Bethel Court.Exhibi t No.shows,Bethel Court
located almost exactly in the center of the Boise-Meridian
metropoli tan area.There are a total of 15 substations in
this area.Indeed,if we take a close look, the fact that
the Bethel Court Substation is in the heart of Idaho Power
service territory becomes even more dramatic.
Trippel , Di
Hewlett Packard andKimball Properties
Q. PLEASE EXPLAIN.
Exhibi t showing the Bethel Courtmap
Substation in relation to the closest substations in each
direction.The Bethel Court Substation is almost exactly in
the denselycenter developed thepartvery
Boise/Meridian areaurban bounded Ustickthe Wye
Cloverdale and Victory Substations.It is hard to imagine
that HP,and only responsible for the need for
addi tional electrical capacity in this area.
ARE THERE OTHER INDUSTRIAL CUSTOMERS THE
SEVEN-MILE RADIUS SHOWN ON EXHIBIT 2?
according confidentialYes,Idaho Power
response to discovery, I have learned that there are thirty
Schedule that those thirtycustomersarea.
Schedule 19 customers, only HP has been required to pay for
a portion of a new substation.
It is interesting to note that this is the first new
substation notbuiltthatseven-mile radius,
counting over twentytheHewlettSubstation,Packard
years.That seems remarkable.
WHY I S THAT REMARKABLE?
Looking the consideringand themaps
unprecedented growth that has taken place in Boise over the
last twenty remarkable that otheryears,new
substations were not built earlier.Exhibit No.4 is a list
Trippel, Di
Hewlett Packard andKimball Properties
of the substations in this area by year of construction.
The Hewlett Packard Substation for its Chinden Blvd. complex
is left off the list because it was constructed to serve a
single customer and was paid for by that customer.In that
respect it is different from the rest of the substations on
Exhibit No.
ARE YOU SUGGESTING THAT IDAHO POWER HAS NOT
UPGRADED ITS SUBSTATION CAPACITY IN THIS AREA WITHIN THE
PAST TWENTY YEARS?
No.Upgrades must have been made to keep up
wi th the rapid growth in the Boise area.Referring again to
Exhibit No.4, however , there seems to be a lumpy pattern of
substation construction.There flurry new
construction followed period acti vi ty.The
company was actively building substations in this area
the 1960s,and then acti vi ty occurred for almost
decade.Then the late 197 Os saw several new substations
followed by two decades of no acti vi ty.Now , there are two
new substations constructed in the early 2000s - Joplin and
Bethel time-clustered patternCourt.The appears to be
repeating.
DID IDAHO POWER REQUIRE HP TO PAY FOR THE BETHEL
COURT SUBSTATION?
Yes,Exhibi tpart.No.copy
correspondence from Gregory Hall of Idaho Power,in which
Trippel, Di
Hewlett Packard andKimball Properties
Idaho Power informed HP that before it would proceed with
the new substation, a contribution in the amount of $561,824
would have paid.$490,824thatamount,was
directly related to the substation , and $71,000 was for new
distribution facilitates to serve the HP properties.HP has
no dispute with Idaho Power over payment of the $71,000 for
distribution facilities.
. THE $490 824HOWDIDIDAHOPOWERARRIVE
FIGURE?
The second Exhibi t (whichNo.page
actually labeled "Page 1") contains a breakdown of the cost
of the Bethel Court substation.Idaho Power determined that
it would pro-rate the Substation s total cost by the ratio
of HP's load to the total substation capacity.Since HP was
estimated to have a load of 4 megawatts, and the capacity of
the substation is 20 megawatts,Idaho Power charged HP for
one-fifth, or 20 percent, of the cost of construction.
DID HP PAY THE REQUESTED AMOUNT?
but didYes under protest,while
reserving the right to challenge that payment later. Exhibit
No.6 is a copy of the letter of transmittal from Winston
the general manager of Kimball Properties,Moore,to Larry
Ripley, attorney for Idaho Power , indicating that a check in
the $561,824amoun t deli vered Idaho Powerwas
Trippel, Di
Hewlett Packard and
Kimball Properties
October 1999.the check attachedcopy
Exhibi t
IF HP DISPUTED THE CHARGE , WHY DID IT PAY THE
BILL , EVEN IF IT DID SO "UNDER PROTEST"
It would have been extremely disruptive to HP'
business operations to delay occupancy of the facilities for
which the electric power was needed.Had it done
would have been left even more financially disadvantaged
than it is now.HP made an appropriate business decision
overall , while reali zing that it would need to approach the
Commission to resolve this specific dispute at a later time.
COST ALLOCATION ISSUES
WHY YOU CALL IDAHO POWER'SYSTEM
APPORT IONING THE COSTS NEW FACILITIES ARBITRARY AND
IRRATIONAL?
Idaho Power policy charging industrial
customers for new transmission and substation facilities is
arbi trary and irrational because it allocates an excessive
cost to the comes on-line nearest the time ofload that
construction, regardless of the size of the load.In other
words, costs are allocated based on when one connects to the
system and not on a uniform system based upon obj ecti ve cost
allocation criteria.
Trippel , Di
Hewlett Packard andKimball Properties
WHAT DO YOU MEAN?
had itsconstructed facilities
location where there was sufficient capacity to serve its
load, then under Idaho Power s system of cost apportionment,
the Company would havenot assessed charge forany
substation or transmission upgrades.
WHAT IS ARBITRARY ABOUT SUCH A SYSTEM?
If a new industrial customer were now to locate
in the Kimball Business Park , then that new customer would
chargednot anything for the Bethel Courtuse
Substation (beyond,naturally,what. is already embedded in
Schedule 19 rates for general substation service).It was
nothing other than a matter of timing that caused HP to be
assessed almost half a million dollars for a substation that
others may now use without also making contributions in aid
construction for substation capacity.This
inherently arbitrary policy.
IS IT NOT THE CASE HOWEVER THAT BUT FOR HP
THE BETHEL COURT SUBSTATION WOULD NOT HAVE BEEN NECESSARY
AND THAT WOULD HAVE BEEN INEFFICIENT BUILD
SUBSTATION SIZED ONLY FOR HP'S LOAD?
Because the locationthenature the
substation and the Kimball Business Park that question is
very difficult to answer.This is a relatively dense area
that contains mix large commercial and industrial
Trippel , Di
Hewlett Packard andKimball Properties
facilities.The Bethel Court substation delivers power to
than justcustomers If HP wereHP.themany more sole
customer in a remote location then the situation would be
different.The key point is that it is only by an accident
of timing that HP was charged for this substation facility.
HOW DO YOU KNOW THAT THE BETHEL COURT SUBSTATION
DELIVERS POWER TO MANY MORE CUSTOMERS THAN JUST HP?
The Idaho Power system is an integrated electric
grid on which power flows over the path of least resistance.
Generically as new transmission and substation facilities
are added those facilities support the entire system.
CAN YOU POINT ANYTHING THAT SUGGESTS THE
BETHEL COURT SUBSTATION IS BENEFITING THE IDAHO POWER SYSTEM
AS A WHOLE?
Yes.Attached,Exhibi t two-page
feeder map of the Bethel Court Substation and its immediate
environs.This document provided dur ingwas our
meetings with Idaho Power personnel at their headquarters in
Boise.It was prepared by Idaho Power and shows how the
Bethel Court Substation integrates into the Kimball Business
Park and surrounding areas.The first page of Exhibit 8 is
labeled in the lower right hand corner as "FEEDER MAP BCRT-
011" and the second page of Exhibit 8 is similarly labeled
FEEDER MAP BCRT-012"
WHAT IS THE DIFFERENCE IN THE TWO MAPS?
Trippel , Di
Hewlett Packard and
Kimball Properties
First should point that BCRT"theout
abbreviation Idaho has assignedPower reference the
Bethel Court Substation.The first page of Exhibit (BCRT-
011 )is a close up diagram of the BCRT feeder line as
extends into the Kimball Business Park.The second page of
Exhibi t 8 (BCRT-012) shows the larger area with the Kimball
Business Park detail omitted.The Blue box , labeled "BCRT"
at the bottom of these maps just North of Bethel Court and
just CourtSouththerailroadtrackstheBethel
Substation which transmissiontaps line running
parallel to the railroad tracks which is indicated on BCRT-
012 by the red box and adj acent circle.That the substation
serves the Kimball Business Park and surrounding area can be
seen on BCRT-011 by the broken blue line, which represents a
distribution feed from the substation,running North
connect to the distribution system at the South end of
Sailfish Pl.
HOW CAN ONE TELL WHICH CUSTOMERS ARE SERVED BY
THE DISTRIBUTION SYSTEM CONNECTED THE BETHEL COURT
SUBSTATION?
Again,I would refer you to Exhibit On the
first page of that Exhibit (BCRT-011) you can see where the
broken blue lines lead from the street to red boxes and red
hourglass shapes.Those are the points at which Idaho Power
Trippel , Di
Hewlett Packard and
Kimball Properties
del i vers customer premise.electrici ty an individual
Beyond those red icons are the customer-owned facilities.
The maps contain a wealth of other information that
is not relevant for our purposes.
WHAT DO YOU CONCLUDE FROM YOUR REVIEW OF AND
UNDERSTANDING OF EXHIBIT 8?
I am not an engineer, but I have reviewed these
with engineer and with Idaho Power personnelmaps
responsible for maintaining these maps.However,one does
not have to be an engineer to see that this substation is
indeed the heart large commercial/ industrial
complex.also clear thisthat substation
interconnected many more customers than just the
facilities.also clear because
interconnected such densely developed area that
continues develop,that this substation supports Idaho
Power s general distribution system.
HOW DENSELY DEVELOPED IS THE AREA IN WHICH THE
HP FACILITIES ARE LOCATED?
The business park has approximately
commercial buildings some of which are very large.When I
refer to the business park I am just including the streets
of Sailfish Golden Trout,Kimball Place,the 9000
block of Emerald, the circle at the end of Mitchell St.(300
block) and Bethel Court.This is very compact area and all
Trippel , Di
Hewlett Packard and
Kimball Properties
of the buildings in it are within approximately 1 000 feet
of at least one of the four HP buildings.
HAVE YOU CONDUCTED AN INVENTORY OF THE BUILDINGS
IN THIS AREA?
Exhibi tYes.list all the
buildings in the area.The list identifies the building,
the date of construction and the number of square feet in
building.each Exhibi t shows that al though
occupies the largest single building in the area,it only
occupies a small minority of the space.There is almost
600 000 square feet of office and industrial space occupied
in the immediate vicinity of the HP buildings.Of that HP
occupies only approximately 200,000 square feet.
CAN YOU IDENTIFY THE LOCATION THE
BUILDINGS ON EXHIBIT 8?
haveYes.created Exhibi t enlarging
that portion the first Exhibi t (BCRT-011)page
showing just the Kimball Business Park.I have inserted the
key number from Exhibit 9 on Exhibit 10 (the enlarged map of
the business park)indicating the approximate location of
each building in the area.
WHERE ARE THE BUILDINGS LOCATED YOUR
EXHIBIT 10?
easilyOne identify the HP buildingsfourcan
Exhibi t 10.and 20.They are key numbered as 13,15,
Trippel, Di
Hewlett Packard and
Kimball Properties
All four of the HP buildings are located toward the bottom
of the map.
In order to obtain the information used to develop
Exhibi t 9 we physically inspected the area and identified
the address each building.then submi tted the
addresses the City Boise Planning Department
order to obtain copies of building permits showing date of
construction and/or occupancy along with the total square
feet in each building.In a couple of cases,the City
records were incomplete - as a result there is no square
footage or occupancy date for three buildings;
WHAT ARE YOU ABLE TO CONCLUDE LOOKING AT YOUR
EXHIBITS AND AND ESPECIALLY THE DATE
CONSTRUCTION OF THE VARIOUS BUILDINGS?
Assuming Idaho Power is correct, that additional
electrical capacity was needed in this thenarea
clear that HP is minor player in creating that need. As can
be seen on Exhibit 9, there is close to 600 000 square feet
of office space in this area.Of that 600 000 square feet
of office space HP is responsible for only approximately
200,000.Of that 200,000 square feet, approximately 30,000
was constructed was1993which well before the four
buildings Idaho Power identified as causing the need for the
Bethel Court Substation.
Trippel, Di
Hewlett Packard andKimball Properties
It is also important for the Commission to consider
the fact that a maj ori ty of the office space in this area
has been constructed either contemporaneously with or after
the HP facilities were constructed.
HOW DO YOU KNOW THAT?
I prepared Exhibit from the data collected
and reported Exhibit showing just the buildings
constructed beglnning 1999 which the year began
occupying its first building the business park.
WHAT DOES EXHIBIT 11 SHOW?
It shows us that ten new office buildings containing
approximately 226,000 square feet of office space have been
constructed in the business park area since 1999.This is
in addition to HP's approximately 200,000 square feet.
WHY THE TIMING OF NEW GROWTH IN THE AREA
IMPORTANT?
This is important because it shows that the Bethel
Court Substation is being used to serve a broad base of new
customers.In effect HP is subsidizing other ratepayers by
paying for a portion of a substation being used to support
Idaho Power s overall system.This assertion is supported
by the fact that the maj ori ty of the new square feet of
construction in the immediate vicinity of the HP facilities
has come on line either contemporaneous with or after the
construction of the Bethel Court Substation.
Trippel, Di
Hewlett Packard andKimball Properties
HOW DO THESE NEW BUILDINGS RELATE TO THE BETHEL
COURT SUBSTATION?
All thoseten office buildings are
electrically connected with the grid that directly
supported by the Bethel Court substation.Looking back to
Exhibi t 8 and following the dotted blue lines leading from
the Bethel Court Substation confirms this assertion.
WILL OTHER INDUSTRIAL CUSTOMERS WHO TAKE SERVICE
IN THE AREA OF THE BETHEL COURT SUBSTATION IN THE FUTURE
ALSO BE CHARGED FOR THEIR PRO RATA SHARE OF THE SUBSTATION
CAPACITY?
According to Idaho Power s policy,No.if the
capacity is available,then no substation or transmission
contribution is asked from new industrial customers.
YOU STATED EARLIER THAT IDAHO POWER'S POLICY IS
NOT ONLY ARBITRARY BUT IS ALSO IRRATIONAL.HOW I S THE
POLICY BOTH ARBITRARY AND IRRATIONAL?
It is arbitrary because two identical industrial
customers will be treated very differently, depending solely
on the timing of each request for service.It is irrational
because the decision to assess the first customer and not
subsequent hascustomer relationshipany cost
causation.
HOW MANY INDUSTRIAL CUSTOMERS HAVE PAID FOR
SUBSTATIONS?
Trippel, Di
Hewlett Packard and
Kimball Properties
Three that I am aware of.Micron Technology has
substation dedicated to its facility.What used to be
known as Micron Electronics in Nampa also has a substation
dedicated its facili ty.Hewlet t Packard Chinden
Boulevard also has a substation dedicated to that facility.
There may be others, but surprisingly,Idaho Power does not
keep records specifically tracking instances which
customers are charged for substation construction.We can,
however, conclude that between the years of 1970 and 2000 no
new industrial customer that came on-line in the seven-mile
radius shown Exhibi t No.required pay forwas
substation construction because substationnew was
constructed in that time period.It is inherently arbitrary
and irrational to force HP to pay for a substation in the
heart rapidly developing when otherarea new
industrial customer the has been similarlysamearea
charged since at least 1979.
ARE THERE MANY INDUSTRIAL CUSTOMERS THAT
SEVEN-MILE RADIUS OF THE BETHEL COURT SUBSTATION?
One would expect there to be a number of large
customers Boise.the heart urban sucharea
Indeed,in response to our discovery Idaho Power revealed
that there thirty industrial Schedulecustomers 19)are
within that seven-mile radius.Of those thirty industrial
Trippel, Di
Hewlett Packard and
Kimball Properties
customers with the seven-mile radius,only has been
required to pay for a portion of a substation.
YOU REFER TO IDAHO POWER'POLICY. WHAT IS
YOUR UNDERSTANDING OF THE ORIGIN OF THAT POLICY?
Idaho Power has no written policy on how to and
when to assess industrial customers a fee for construction
of transmission or substation facilities.My understanding
is that the Company chooses to charge industrial customers
for such facili ties hoc basis and that any
consistency such unwritten policy depends
indi vidual Company personnel verbally informing new
personnel of the policy and how it implemented.This
subj ects the policy - such as it is - to the vicissitudes of
communication , personal memory, and individual whim.
ARE THERE OTHER PROBLEMS WITH THE COMPANY'
UNWRITTEN POLICY?
It seems obvious that it has not been approved
by this Commission - if it were approved by the Commission
then we would have the benefit of a written policy.
addi tion, since it is administered on an ad hoc basis based
solely on individual personnel's memories,it is likely to
be subj ect to inconsistent administration.Finally, without
the benefit of a written policy,new industrial customers
are disadvantaged because they simply don t know in advance
Trippel , Di
Hewlet t Packard andKimball Properties
when whether they will required forpay new
substation capacity.
CAN YOU SUGGEST HOW IDAHO POWER SHOULD HANDLE
TRANSMISSION AND SUBSTA~ION CONSTRUCTION COSTS?
Yes.The current approach to ratemaking is not
tenable and is not a fair method to apportion costs.Any
policy should be dependen t upon the location of the new
substation and transmission facili ties.When located
urban and suburban areas such that the substation can be
integrated into the overall system to support the general
body ratepayers,then the general body ratepayers
should pay for the substation and transmission facilities.
Clearly the Bethel Court substation falls into that
category.
WOULD EVER APPROPRIATE ASK NEW
INDUSTRIAL CUS TOMER CONTRIBUTE THE COST NEW
TRANSMISSION AND SUBSTATION FACILITIES?
Yes.would generally appropriate
circumstances in which the new customer takes all of the
capaci ty of the new substation or new transmission line.
would also be appropriate when the new facilities are remote
from the load centers and when it would be unlikely that the
new facilities would provide any benefits for the system
a whole.
Trippel , Di
Hewlett Packard andKimball Properties
Stuart A. T. Trippel has over 15 years' experience as a management consultant and
consulting econQmist in the fields of regulatory affairs, managerial and cost accounting, and
economic analysis. He has worked on a wide variety of projects with industrial clients, public
utilities, law firms, and trade associations, including the following studies and analyses:
Rates, cost-of-service, and other managerial accounting studies
Cost-benefit analyses, feasibility studies, and reviews
Expert witness testimony and litigation support
Regulatory analysis in the United States and Canada (including Federal Energy
Regulatory Commission and state and provincial regulatory commissions)
Complex rate case intervention (e., Bonneville Power Administration), including
analysis, testimony, and case management
Activity-based costing analysis
Assistance with electricity direct access issues, including analysis and commission
applications
Requests for proposals for power supply (issuance and evaluation)
Contract and other negotiations, including periodic review and monitoring
Legislative analysis and monitoring
Specialized research (economic, regulatory, and legal)
Due diligence research and company intelligence
Forecasting
Valuation studies
Exhibit 1
Trippel. Di
Surveys (design and analysis)
Seminars and courses (development and delivery)
Risk management
Environmental cost evaluation
Integrated resource planning
Demand-side management program development
Trippel, Di.
Mr. Trippel was previously vice president and shareholder of a mid-sized regional consulting
firm and, prior to that, a member of the economics department of a large national engineering
design and environmental services firm. He was also a member of the management advisory
services group of a regional public accounting firm and, while in college, provided research
assistance as an independent consultant to professors testifying on antitrust and other issues in
regulatory economics.
In addition to his consulting work, Mr. Trippel is an associate faculty member in the
Business Administration Division at Shoreline Community College, near Seattle, Washington
where he teaches introductory accounting courses.
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MAPS WERE IN CL UD ED IN THIS
FILING ARE IN THE FILE
Idaho Power Company
Substations Within Seven-Mile Radius of Bethel Court
Ranked by Year of Construction
Substation Year In Service Capacity MV A
Name
191 Os
Boise 1919
1950s (five new substations)
Meridian 1951
WYE 1951
Eagle 1952
Butler 1957
State 1959
1960s (four new substations)
Ustick 1962
Grove 1964
Mora 1966
Cloverdale 1969
1970s (three new substations)
Locust Grove
Victory
Gary
1978
1979
1979
1980s (no new substations)
1990s (no new substations)l
Bethel Court
Joplin
2000
2001
1 HP - 1990 13.1 MV A dedicated to HP campus.
Exhibit No.
HP Versus Idaho Power
S. Trippel
Source, Answer of Idaho Power
To Production Request ofHP
10-18-1999 11 : 47AM 1- kU'1 W 1-( r1uORE'. COI')PAf'.iY 208 32~ 7523 . ~
F. GrcgOlY Hall
Delivery Servic.;.s Leader
Delivery Services Department
RECEi V'ED aCT ~ 5 1999
[phone]
fax [phone]
e-mail gt~ghall(i~ijdah(Jpowcr.()OITl
Mr, Jonathan Seel
WH Moore Company
600 N. Steelhead
Boise, 1083704
Oct. 14, 1999
Re: Hewlett Packard Customer Service Center
303 N. Kimball
8oise, 10
Dear Mr. Seel
As discussed yesterday, please be advised that we require the contribution for the
construction of the Bethell Court substation and the distribution line extension by October 29
1999. This payment is necessary for us to proceed with the project and remain on schedule.
Therefore, in order to proceed, we request the following payments:
Pro-rata share of new substation:
New distrIbution line along railroad track~:$490,1324
000
Total amount requested:$561 824
Thank you and please do not hesitate to call should you have any questions.
Si~rely,
-:Jc;4
Exhibit 5
Trippel , Di.
Source:
HP Files
Summary
,'(
Bethel Court Project Costs 10/6/99
land Procurement
Property
Surveying
labor
195 000
000
000
000
210 000
Transmission
Design
Material
Installation
000
600
200
SUB-TOTAL 109 800
Station
Design
Material
Installation
040
115 226
370 308
SUB-TOTAL $ 1 553 574
Grand Total:873 374
Customer Contribution:
4 MW divided by 20 MW = .20 = 20%
873 374 X 20% =374 675
Tax Gross up ~ 31 116 149
Total 490 824
Distribution line from substation to business subdivision
Design
Material
Installation
Railroad easment
44,400
600
000
SUB-TOTAL 000
Page 1
H. MOORE
Real Estate Development
600 N, STEELHEAD WAY. SUITE 144 (83704)
O, BOX 8204
BOISE. IDAHO 83707,2204
TELEPHONE [phone]/ FAX 323'7523
October 29 , 1999
Larry Ripley
General Counsel's Office
Idaho Power Company
1221 W Idaho St
Boise ID 83707
Dear Mr. Ripley:
Re: Bethell Court substation and related distribution line extension
Enclosed as requested in Greg Hall's letter of October 14 is our check for $561 824 in paymentof the fees regarding the above facilities.
As mentioned in Mr. Hall's earlier letter of October 1 and in previous discussions with Idaho
Power, our request for electric service to the custorrer support service center we are providingfor Hewlett-Packard Company prompted Idaho Power to analyze the substation and distribution
capacity in the area, resulting in its determination that an increase in that capacity was needed.Based on this determination, Idaho Power has assessed the amount enclosed herewith , inaddition to $83 183 previously paid , as a condition to its providing the requested service.
Because both HP and we share a concern that the assessments are not equitable and maynot
conform to applicable regulations, we are tendering the enclosed payment in order to ensure
that the project remains on schedule, but with the understanding that we and HP reserve the
right, either individually or jointly, to dispute the assessments and to receive any refund arising
from the settlement thereof.
At the time of the initial notification to us of the amount due , Idaho Power established January 12000, as the due date for payment based on its schedule calling for construction to begin on
that date. In a subsequent letter dated October 14, the due date was accelerated to October
29. For the benefit of our client and ourselves , we will appreciate an explanation of this change.
In closing, please understand that we have enjoyed our relationship with Idaho Power and look
forward to continuing on that same basis, notwithstanding that disagreements such as the
present one may in good faith arise from time to time.
Sincerely,
KIMBALL PROPERTIES LIMITED
PARTNERSHIP
Enclosure
cc: Ed Hess (HP)
Mark Perry (HP)
Peter Richardson (attorney for HP)
Exhibit 6
Trippel, Di.
Source
HP Files
Wo H. MOORE
TRUST ACCOUNT
O, Box 8204 . Boise . Idaho 83707-2204
[phone]
s. BANK
PLAZA BRANCf101 S. CAPITOL ~
BOISE. IDAHO 8:;800 US BANKS
92.3721231 20
2079
DATE AMOUNT
Oct-29-$561 824.
PAY
TO THE
ORDER
Idaho Power
H. MOORE COMPANY PAID TO:Idaho Power
I Oct-
29-207TRUST ACCOUNT
O, Box 8204 . Boise, Idaho 83707-2204 PAID ON Kimball Properties LP 2079(208) 323-1919 BEHALF OF:
INVOICE NO,INVOICE DATE REFERENCE AMOUNT PAID
Oct-14-Substation/distribution fee 561 824.
I CHECK AMOUNT
561 824.
Exhibit 7
Trippel , Di.
Source
HP Files
MAP S WERE IN CL UD ED IN THIS
FILIN G ARE IN THE FILE
Construction in the Kimball Business Park
Or in the Immediate Vicinity of the Kimball Business Park
Map Address Square Approx. Date of Name of
Key # Feet Construction!Business
Occupancy or Bldg
9769 W. Emerald 515 1/99
9632 W. Emerald
9576 W. Emerald (#1)160 8/99
9576 W. Emerald (#2)160 8/99
9543 W. Emerald 100 11/99 Sailfish Place
9357 W Emerald 306 3/99 Westpark Medical
9324 W. Emerald 000 12/90 Sears Credit
9288 W Emerald 050 5/91 Spur Products
9196 W. Emerald 200 1 % Pinnacle Square
10.9140 W. Emerald 380 1/01 Westpark Market
11.351 Mitchell S1. Ste 102 500 5/00 Business Interiors
12.350 N. Mitchell S1.43,426 10/00 Cottonwood Plaza
13.333 N. Sailfish PI 276 9/00 HP #27
14.300 N. Sailfish PI 773 4/97 Derr Medical
15.9415 W. Golden Trout St Dr.600 6/00 HP #29
16.9390 N.. Golden Trout S1.34,400 9/00 HP #28
17.502 N. Kimball PI.125 12/97 Life Care Center
18.456 N. Kimball PI.124 1/01 Kimball Plaza
19.303 N. Kimball PI 124 10/99 HP # 26
20.275 N. Kimball PI
21.9700 Bethel C1.000 4/93 HP #25
22.9600 Bethel C1.500 3/93 Morrow Cns1.
23.9550 Bethel C1.Hubble Office
Total Square Feet 581 679Total HP Square Feet 168 400
(The total for HP does not include the HP building on Bethel Court since that building was
constructed in 1993 - well before the need for the Bethel Court Substation was identified.
Exhibit No.
Trippel, Di
Source: Records
City of Boise
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Construction in the Kimball Business Park
Since 1999
Map Address
Key#
Square Approx. Date of Name ofFeet Construction! BusinessOccupancy or Bldg
9769 W. Emerald 515 1/99
9576 W. Emerald (#1)160 8/99
9576 W. Emerald (#2)160 8/99
9543 W. Emerald 100 11/99 Sailfish Place
9357 W Emerald 306 3/99 Westpark Medical
9196 W. Emerald 200 1 % Pinnacle Square
10.9140 W. Emerald 380 1/01 Westpark Market
11.351 Mitchell St. Ste 102 500 5/00 Business Interiors
12.350 N. Mitchell St.426 10/00 Cottonwood Plaza
18.456 N. Kimball PI.124 1/01 Kimball Plaza
Total (not including HP)204 871
Exhibit
I These numbers correspond to the numbers on Exhibit 10 indicating the relative location of the
new construction to the Bethel Court Substation and the HP buildings.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the II th day of June, 2003, a true and correct copy of the
within and foregoing DIRECT TESTIMONY AND EXHIBITS OF STUART TRIPPEL ON
BEHALF OF KIMBALL PROPERTIES LIMITED PARTNERSHIP AND HEWLETT
PACKARD COMPANY , Case No. IPC-00-, was served by hand delivery to:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Gregory W. Said
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83702
l)J9-d~ rr'J - (~)Jyj-~
) ~
Nina M. Curtis
Legal Assistant
IPIC Intervention - IPC-O3- 7