20050512Reply comments.pdf

BARTON l. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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UflLITIES COl.lt'1ISSION
Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
DUE TO THE INCLUSION OF THE BENNETT)
MOUNTAIN PROJECT INVESTMENT IN REVENUE REQUIREMENT.
CASE NO. IPC-05-
REPLY COMMENTS OF IDAHO
POWER COMPANY
The Commission Secretary has provided Idaho Power with copies of the
comments filed in this case. Based on the Company s review of those comments, Idaho
Power believes that it is necessary to provide limited reply comments addressing the
proposals contained in the comments of (1) the United States Department of Energy
DOE") and (2) the Public Works Department of the City of Boise , Idaho ("City
REPLY COMMENTS OF IDAHO POWER COMPANY, Page
The Commission Should Not Expand the Scope of This Proceedinq
Neither the DOE nor the City comment on the revenue requirement
portion of this case, but instead propose that the Commission adopt rate designs that
are different than the uniform percentage increase Idaho Power has proposed.
Without commenting on the merits or demerits of the proposals made by
City and DOE, Idaho Power requests that the Commission not expand the scope of this
proceeding to include rate design issues.
Idaho Power is requesting that the Commission issue its order allowing
the rates associated with the addition of the Bennett Mountain Project to become
effective on June 1 , 2005. If the Commission decides to consider rate design issues at
this point in the process , it will be impossible for the Company to include the Bennett
Mountain investment in rates on June 1 , 2005.
In the past, Idaho Power has on several occasions filed applications
between general rate cases requesting authority to increase its rates by a uniform
percentage by class to include a single new generating unit. In those prior applications
the Commission has accepted the Company s proposal that each class of customers
rates be increased on a uniform percentage basis until the next general rate case when
rate design can be addressed on a comprehensive basis.
It Is Not Necessary To Consider Rate Desiqn In This Case
Idaho Power has publicly indicated that it intends to file a new general rate
case using 2005 as a test year. As a result, the uniform percentage increase requested
by the Company in this case will only be in place for a relatively short period of time
before a comprehensive review of rate design takes place in a general rate case. A
REPLY COMMENTS OF IDAHO POWER COMPANY , Page 2
comprehensive review of the Company s total rate design , including the addition of the
Bennett Mountain Project as a peaking resource , will be considered in this general rate
application.
Neither DOE nor City has requested that the Commission convene a
hearing to address rate design issues.
For all of these reasons, the Company respectfully requests that the
Commission accept the Company s proposal to increase rates on a uniform percentage
by class and defer discussion of the rate design changes as proposed by DOE and City
until the Company s next general rate case.
DATED at Boise , Idaho , this 12th day of May, 2005.
BARTON L. KLINE
Attorney for Idaho Power Company
REPLY COMMENTS OF IDAHO POWER COMPANY, Page 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of May, 2005, I served a true
and correct copy of the within and foregoing REPLY COMMENTS OF IDAHO POWER
upon the following by the method indicated below and addressed as follows:
Donald L. Howell , II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Charles Mickelson, PE, Director
Public Works Department
City of Boise
O. Box 500
Boise , Idaho 83701-0500
Hand Delivered
S. Mail
Overnight Mail
FAX
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Avenue, S.
Washington, DC 20585
Hand Delivered
S. Mail
Overnight Mail
FAX
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BARTON L. KLINE
CERTIFICATE OF SERVICE