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STATE OF IDAHO
BEFORE THE PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION IDAHO POWER COMPANY
FOR AUTHORITY TO INCREASE ITS INTERIM AND
BASE RATES AND CHARGES FOR ELECTRIC SERVICE
: CASE NO. IPC-O3-
SUMMARY OF POSITION OF
THE KROGER CO.
Now comes Kroger Co. ("Kroger ), and pursuant to Rule 105 of the Utility Information Customer Rules
provides a summary of its recommendations and testimony in the above-captioned matter.
Kroger has made the following determinations concerning Idaho Power Company s (the Company
Application For Authority to Increase its Rates. With respect to rate spread, Idaho Power proposes a significant
subsidy to the Irrigation class. According to the Company s cost-of-service analysis, it would require a 67 percent
increase in Irrigation base rates for this class to fully recover its costs if the Company s requested overall base-rate
increase of 18 percent is approved. To mitigate the impact of the base-rate increase for this class, the Company
proposes to cap the Irrigation increase at 25 percent, with the difference spread to the other rate classes. Kroger
agrees that mitigating the impact of a large rate increase for this class is reasonable, but proposes some
modifications to the Company s proposal that: (1) would apply in the event the Company s proposed rate increase
is reduced by the Commission, and (2) provide for an additional phase-in toward cost-of-service rates in
subsequent years.
With respect to rate design, Kroger generally agree with Idaho Power s approach to weighting any rate
increases relatively more heavily on the demand charge, as opposed to the energy charge, for those rate schedules
with demand meters. This approach reflects the composition of the Company s underlying costs, and thus is
consistent with cost causation.
Idaho Power proposes to make time-of-use rates mandatory for Schedule 19 in order to send improved
price signals. The Company also has an optional time-of-use rate for Irrigation service that is in place on a pilot
basis. Yet there are no time-of-use options available for Schedule 9, which consumes 26 percent of the retail
energy on the Company s system. Kroger recommends adopting a voluntary time-of-use option for Schedule 9
that offers peak, mid-peak, and off-peak energy prices that properly reflect tirne-of-use cost differences. At a
minimum, such a rate should be made available to Schedule 9 customers on a pilot project basis.
With respect to all other issues raised by the Company or other intervenors, Kroger neither supports nor
opposes them.
Respectfully submitted
David F. Boehm, Esq.
Michael L. Kurtz, Esq.
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 2110
Cincinnati, Ohio 45202
Ph: (513)421-2255 Fax: (513)421-2764
Mail: dboehmlaw0!aol.com
COUNSEL FOR THE KROGER CO.
March 29, 2004
BOEHM, KURTZ & LOWRY
ATTORNEYS AT LAW ;,:ECEiVEO36 EAST SEVENTH STREET- i'
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SUITE 2110 '
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CINCINNATI, OHIO 45202
TELEPHONE (513) 421-225fOlPj It;;': 3 I
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TELECOPIER (513) 421-2764
iiiSSIOi4
VIA OVERNIGHT MAIL
March 29, 2004
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
In re: Case No. IPC-03-
Dear Ms. Jewell:
Please find enclosed the original and nine (9) copies of the Summary of Position of The Kroger Co. dba
Fred Meyer and Smith's filed in the above-referenced matter.
Copies have been served on all parties on the attached certificate of service. Please place this document
of file.
David F. Boehm, Esq.
BOEHM, KURTZ & LOWRY
MLKkew
EneL
CERTIFICATE OF SERVICE
I hereby certify that true copy of the foregoing was served by electronic mail, unless otherwise noted, this
29th day of March, 2004 to the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Peter 1. Richardson, Esq.
Richardson & 0 'Leary
99 E. State St., Suite 200
O. Box 1849
Eagle, ID 83616
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
Lisa Nordstrom
Weldon Stutzman
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington, P.O. Box 83720
Boise, ID 83720-0074
Randall C. Budge
Eric L. Olsen
Racine, Olson Nye, Budge
Baily, Chartered
201 E. Center, P.O. Box 1391
Pocatello, ID 83204-1391
John R. Gale
VP-Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Lawrence A. Gollomp
Assistant Attorney General
United State Department of Energy
1000 Independence Ave., SW
Washington, DC 20585
Dennis Goins
Potomac Management Group
5801 Westchester St.
Alexandria, VA 22310-1149
Dean 1. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
Jeremiah 1. Healy
United Water Idaho, Inc.
O. Box 1290420
Boise, ID 83719-0420
William M. Eddie
Advocates for the West
O. Box 1612
Boise, ID 83701
Nancy Hirsh
N W energy Coalition
219 First Ave., South Suite 100
Seattle, WA 98104
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
Thomas M. Power
Economics Department, LA 407
University of Montana
32 Campus Drive
M' sou1a , MT 59812
Brad M. Purdy
Attorney at Law
2019N.17th Street
Boise, ID 83702
Michael Karp
147 Appaloosa Lane
Bellingham, W A 98229
David F. Boehm, Esq.