20040518Reply Comments.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Phone: [phone]
FAX: [phone]
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UTILITIES COr'1r'1ISSION
Attorneys for Idaho Power Company
1221 West Idaho Street
Boise , Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OFTHE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT POWER COST
ADJUSTMENT RATES FOR ELECTRIC
SERVICE TO CUSTOMERS IN THE STATE
OF IDAHO FOR THE PERIOD MAY 16, 2004
THROUGH MAY 31 2005
CASE NO. IPC-04-
IDAHO POWER'S REPLY
TO THE COMMENTS OF
COMMISSION STAFF
COMES NOW Idaho Power Company ("Idaho Power" or "the Company), by
and through its attorneys, and hereby replies to the Comments of the Commission Staff
filed on May 14, 2004.
In reviewing Staff's Comments , Idaho Power has identified two areas where
it believes additional information may be useful to the Commission in making its final
determination in this case.
IDAHO POWER'S REPLY TO THE COMMENTS OF THE COMMISSION STAFF, Page
Additional Credit for Schedules 7, 19 and 24.
As Staff notes, as a result of the Settlement Stipulation which
concluded last year s PCA, three rate classes are scheduled to receive a credit. Staff in
its Comments proposes that those customer classes should receive an additional credit.
Staff states in its Comments on p. 4 that its recommendation for additional credits for
Schedule 7, 19 and 24 customers is based on its computation of an overcollection based
on May 2003 actual sales. Discussions between the Company and Staff have confirmed
that only the Schedule 7 computations were based on May 2003 actual sales. The
Company has recomputed the additional credits based on the Staff's methodology and
using actual May 2003 sales and the results of that recomputation are shown on
Attachment 1 to these Reply Comments.
Valmy Unit 2 Outage.
In its Comments Staff discusses at some length the outage of the
second unit at the Valmy Plant that occurred last summer. Idaho Power generally
concurs with Staff's summary of the events associated with the outage. However, Idaho
Power questions whether Staff's statement on p. 8 of its Comments that "the PCA was
established to adjust for changes in water conditions and energy market prices. In other
words, weather-related conditions and power supply costs beyond the control of the
company" correctly characterizes the PCA methodology in its entirety. Idaho Power
respectfully submits that Staff's characterization of the PCA methodology unduly narrows
the scope of the PCA, and in so doing, fails to acknowledge that the Company
generating units often perform with a reliability that exceeds industry norms. The
IDAHO POWER'S REPLY TO THE COMMENTS OF THE COMMISSION STAFF, Page 2
Company believes that the PCA methodology as adopted intended to balance above-
average and below-average performance.
In any event, Idaho Power stands ready to provide the Commission with
additional information regarding last summer's outage of the Valmy #2 unit either
informally or formally as a part of a new docket.
Respectfully submitted this 18th day of May, 2004.
'--
BA TON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER'S REPLY TO THE COMMENTS OF THE COMMISSION STAFF, Page 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of May, 2004, I served a true
and correct copy of the within and foregoing IDAHO POWER'S REPLY TO THE
COMMENTS OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
. P.O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, Idaho 83701-2720
Hand Delivered
S. Mail
Overnight Mail
FAX
Richard E. Malmgren
Micron Technology, Inc.
8000 S. Federal Way
Boise, Idaho 83716-9632
Hand Delivered
S. Mail
Overnight Mail
FAX
CERTIFICATE OF SERVICE
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