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LAWRENCE A. GOLLOMP
United States Department of Energy
1000 Independence Avenue S.
Washington, D.C. 20585
(202) 586-4219
E-mail: lawrence.gollomp(fY doe.gov
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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 PLANT
INVES TMENT IN ITS RATE BASE
CASE NO. IPC-O5-
COMMENTS OF THE UNITED STATES
DEPARTMENT OF ENERGY
COMES NOW the United States Department of Energy ("DOE") on behalf of the
Idaho Operations Office and on behalf of other Federal Executive Agencies, all of whom
are customers of Idaho Power Company ("IPC"), and by and through counsel, and in
response to Order No.29748, respectfully submits the following comments:
BACKGROUND
On March 2, 2005, IPC filed an Application with the Idaho Public Utilities
Commission ("Commission ) to increase rates on June 1 , 2005 , to recover the cost of its
new Bennett Mountain generating facility, which is scheduled to enter service a few
months before that date. IPC initially sought an increase in its annual revenue
requirement of $13 482 366, or 2.63 percent, associated with its $58 million investment
in the Bennett Mountain project. A correction to the Company s combined income tax
rate in a March 22 2005 , amended filing lowered IPC's incremental revenue requirement
to $9,403 003 , or 1.84 percent. IPC proposes to increase retail rates to all customers by
the same percentage amount.
COMMENTS
The Company s proposal to apply an equal 1.8 percentage rate increase to all
customers would perpetuate the interclass subsidy currently embedded in IPC's rate
structure. In IPC's last general rate case, Docket No. IPC-03-, the Commission
approved a 5.23 percent increase in retail rates. However, to reduce the subsidies from
other classes of customers to the Irrigation class, the Commission approved a much larger
than average increase of 13.95 percent for Irrigation customers. Even with this step
toward reducing the interclass subsidy in the last rate case, however, the cost of service
index for residential and small commercial rate classes, and DOE's Idaho National
Engineering and Environmental Laboratory (INEEL) remained at 105 percent. (Appendix
, Order No. 29505 issued May 25 , 2004). Stated differently, allowed revenues for each
of these rate classes was 5 percent above cost of service rate levels. By contrast, the cost
of service index for Irrigation customers was only 76 percent, so rate revenue for
Irrigation customers was 24 percent below cost of service. In the absence of a full cost
of service analysis, it is reasonable to infer that, under the Company s proposed equal
percentage rate increase, little or no progress would be made toward reducing the
interclass rate subsidy.
DOE believes a reasonable and straightforward approach for allocating IPC'
proposed $9.4 million increase among customer rate classes is to employ the same
distribution of rate increases used by the Commission in IPC's last rate case, in Docket
No. IPC-03-13. Appendix C of Order No. 29505 identifies the percentage rate increase
for each customer class. Residential customers, for example, received a 5.98 percent rate
increase, which was 0.75 percentage points (or 14.3 percent) above the 5.23 percent
system average. Irrigation customers, on the other hand, received a 13.95 percent rate
increase, which was 8.72 percentage points (or 167 percent) above the system average.
This approach should continue the progress toward cost-based rates that underlies the
Commission s decision in Order No. 29505.
Respectfully submitted
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Avenue, S. W.
Washington, D.C. 20585
UNITED STATES DEPARTMENT OF ENERGY
COMMENTS
MAY 5, 2005
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Jean Jewell
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From:
Sent:
To:
Subject:
Ed Howell
Monday, May 02, 2005 7:00 PM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WWW Form Submission:
Monday, May 02, 2005
5: 59: 35
Case: ipc-e-05-10
Name: Stanley B. Davis
Street Address: 200 Main
City: Salmon
State: Idaho
ZIP: 83467
Home Telephone: 208-756-4561 (work 756-3214)
E-Mail: mayorofsalmon~ci tyofsalmon. com
Company: Idaho Power
mailing list yes no: yes
Comment desc ipt on: s Mayor of Salmon, I would like to request any rate increase inareas i pacted by dams and the loss of anonormous fish that School Districts be exempt
from the rate increase. As you are aware places like Salmon have had to go through a lot
to survive economicaly. A new rate increase to build a new power plant is not just.. We
have paid a 100 times over and not raising school districts power bills would be a token
that would be well excepted.
Thank you,
Stan Davis
Mayor
Ci ty of Salmon
Transaction ID: 521759.
Referred by: http: / /www.puc. state. id. us/ scripts/polyform. dll/ ipuc
User Address: 64.91.118.122
User Hostname: 64.91.118.122
Jean Jewell
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From:
Sent:
To:
Subject:
Ed Howell
Wednesday, May 04 200510:30 AM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WWW Form Submission:
Wednesday, May 04, 2005
9:30:11 AM
Case: IPC-E-05-
Name: Rick Lamica
Street Address: 6 Conifer Cir
City: Boise
State: Idaho
ZIP: 83716
Home Telephone: 208 336-2266E-Mail: rlamica~netzero. net
Company: Idaho Powermailinglist _yes _no: P9
Comment description: Here we go again. No additional conservation plans just acquire more
capaci ty and increase rates. This is endless, I wish I could put in for an increase as
much as Id Power does. Up down up down, isn t there a process that could help these up or
down that rates stabilize for awhile. It's like watching OPEC and their price per barrel,
I can t believe that the PUC doesn t have anything else to do. I feel for the fix and low
income customers who get stepped on again. Thanks Rick.
Transaction 10: 54930.Referred by: http: / /www. puc. state. id. us/ scripts/polyform. dll/ ipuc
User Address: 64.136.27.225
User Hostname: 64.136.27.225
Jean Jewell
v" 5/'1/05'110 A)J.;/10 s H
From:
Sent:
To:
Subject:
Ed Howell
Wednesday, May 04 20058:48 AM
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WWW Form Submission:
Wednesday, May 04, 2005
7:47:54 AM
Case: TPC:O~-
Name: Bob Jost
Street Address: 351 Golconda Drive
Ci ty: Hailey
State: Idaho
ZIP: 83333
Home Telephone: 208-788-9765E-Mail: bdj ost~msn. com
Company: Idaho Powermailinglistyesno:
Comment description: Dear Comission:
I would like to encourage you to denie Idaho Powers request for a rate increase this year(to begin on June 1,05). The recent rate increses over the past two years have had a huge
impact on family homes in Idaho and more will be a huge burden on the average guy inIdaho. To ask the consumer to pay for the Bennett Mountain proj ect is not a fair deal.Bob Jost
Transaction ID: 54747.Referred by: http: / /www. puc. state. id. us / scripts /polyform. dll / ipucUser Address: 65.54.97.175User Hostname: 65.54.97.175
Jean Jewell
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From:
Sent:
To:
Subject:
Ed Howell
Tuesday, May 03, 20052:51
Jean Jewell; Ed Howell; Gene Fadness; Tonya Clark
Comment acknowledgement
WWW Form Submission:
May 03, 2005
Case TrC -f,-O5'-/D J LPC (E:OS' j ifName: . Harris
Street - Addres s: 7470 Grande Vallej 0 Dr.
City: Fruitland
State: Idaho
ZIP: 83619
Home Telephone: (208) 452 5232
E-Mail: rcgc~fmtc. com
Company: Idaho power
Comment description: I received a brochure from Idaho Power indicating they wererequesting a rate increase .pertaining to their income tax and for the construction of the
Bennett Mountain Power Plant. I think their request to raise their rates to pay for. their
income taxes is outrageous. I can not ask anyone to pay my taxes and wonder why this is
not considered in their plans to run their company. I understand their need to make a
profit, but not on the backs of their consumer. Pertaining to their request for Bennett
Mountain, I thought I had heard where they were requesting a rate increase from their
consumers in Oregon to build a power plant in Idaho. I know we are in our sixth year of
drought, but remember when they paid the farmers not to pump water to conserve electricity
and subseqently requested a rate increase as they claimed to have lost money on thisventure. I think their request is not in order and hope you deny their request,
Transaction 10: 531351.
Referred by: http: / /www.puc. state. id. us/ scripts/polyform. dll/ipuc
User Address: 208.187.168.
User Hostname: 208.187.168.