20080107Brilz rebuttal.pdf

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ZOOS JAN -4 PH 4; 29
IDAHO PU ICUTILITIES C ISSIO¡ .
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
TO ELECTRIC CUSTOMERS IN THE STATE
OF IDAHO.
CASE NO. IPC-E-07-08
IDAHO POWER COMPAN
DIRECT REBUTTAL TESTIMONY
OF
MAGGIE BRILZ
1 Q.
2 A.
3 Q.
Please state your name.
My name is Maggie Brilz.
Are you the same Maggie Brilz that has
4 previously presented direct testimony?
5 A.
6 Q.
Yes, I am.
Have you had the opportunity to review the
7 pre-filed direct testimony of Micron Technology, Inc.
8 witness Dr. Peseau, Industrial Customers of Idaho Power
9 (ICIP) witness Dr. Reading, Idaho Irrigation Pumpers
10 Association (IIPA) witness Mr. Yankel, Kroger Company
11 witness Mr. Higgins, U. S. Department of Energy witness Dr.
12 Goins, and Commission Staff witness Mr. Hessing?
13 A.
14 Q.
15 A.
Yes, I have.
What is the scope of your rebuttal testimony?
16 the intervening parties and the Commission Staff regarding
My testimony will focus on issues raised by
17 the Company's investigation into a "virtual peaker program",
18 time-of-use rates, the Irrigation Peak Rewards program, the
19 allocation of revenue to the various customer classes, and
20 ra te design.
21 part in addressing issues raised by the parties does not
It should be noted that any omission on my
22 indicate my concurrence with those issues.
23 Q.Are you sponsoring any exhibi ts wi th your
24 direct rebuttal testimony?
25 A.I am sponsoring Exhibi t No. 64 andYes.
BRILZ, DI REB 1
Idaho Power Company
1 Exhibi t No. 65.
2 Distributed Generation
3 Q.Industrial Customers of idaho Power witness
4 Dr. Reading stated that he believes idaho Power has not
5 fully complied with the Commission's Order No. 30201 issued
6 in the Evander Andrews natural gas peaking plant case, Case
7 No. IPC-E-06-09, in which the Company was directed to
8 investigate and submit a report for the implementation of a
9 "virtual peaking plant" program. Do you agree with Dr.
10 Reading's assessment?
11 A.No, I do not.
12 Q.Would you please describe the actions Idaho
13 Power has taken regarding its investigation of a "virtual
14 peaker program"?
15 A.Yes.Beginning in early 2007, Idaho Power
16 began investigating the potential for a "virtual peaker
17 program" in which customer-owned backup generation would be
18 interconnected onto the Company's distribution system with
19 the capability to be remotely dispatched. As part of the
20 Company's research the programs offered by other utilities,
21 most notably those offered by Portland General Electric
22 (PGE) and Madison Gas and Electric (MGE), were reviewed.
23 The Company chose PGE's program model to use as the basis
24 for our program development.
25 Q.Did the Company perform a financial analysis
BRILZ, DI REB 2
Idaho Power Company
1 to determine if such a program would be feasible for Idaho
2 Power?
3 A.Yes. An initial analysis that took into
4 account an estimate of the various costs involved in the
5 interconnection and operation and maintenance of backup
6 generators was performed by the Company's Power Supply
7 department.
8 Q.What did the initial analysis indicate?
9 A.The initial analysis indicated that there was
10 enough potential benefit associated with the "virtual peaker
11 program" to continue pursuing its investigation.
12 Q.Wha t were the next steps taken?
13 A.The initial analysis concluded that the
14 Company would need to make an investment in infrastructure
15 of approximately $1 million in order to integrate custorner-
16 owned generators onto our system with the capability to be
17 remotely dispatched. Because of the magnitude of this
18 investment and the potential complexity of the
19 interconnection of some of the generators onto the Company's
20 system, it was decided that an in-depth analysis of the
21 interconnection costs, targeting generators of different
22 sizes, ages, and locations was necessary in order to provide
23 more accurate data for the feasibility analysis. On June 1
24 the Company filed its report with the Commission detailing
25 the proposed program design, the results from the initial
BRILZ, DI REB 3
Idaho Power Company
1 feasibility analysis, and the Company's planned next step to
2 conduct an "Engineering Analysis Pilot Program" in which
3 four to six customers would be identified to work with the
4 Company to develop in-depth interconnection cos t data.
5 Q.Has this in-depth "Engineering Analysis pilot
6 Program" of interconnection costs been completed?
7 A.Yes, it has.
8 Q.Please describe the process undertaken to
9 conduct this analysis.
10 A.In order to conduct the interconnection
11 analysis it was necessary to identify interested customers
12 and secure their approval for an on-site investigation. In
13 order to gauge customer interest in a "virtual peaker
14 program" and solicit participation in the on-site
15 investigation, idaho Power' s Delivery Service
16 Representatives (DSRs) in spring 2007 contacted those
17 customers whom they knew had existing generation, . those
18 customers who had expressed an interest in adding
19 generation, and those customers whom they thought might
20 have generation. Based on the leads obtained through the
21 customer contacts by the DSRs, the Company held numerous
22 customer meetings and conference calls in May and June 2007
23 detailing the potential program. Additionally, in an
24 effort to gain more awareness of the program, the Company
25 met with the ICIP and requested the ICIP forward the names
BRILZ, DI REB 4
idaho Power Company
1 of any customers who might be interested in participating.
2 The Company also described the program during meetings held
3 with industrial customers in June to explain the recently
4 filed general rate case and the energy efficiency
5 opportunities offered by the Company.
6 Q.Did the ICIP forward the names of any
7 interested customers to the Company?
8 A.Yes. The ICIP forwarded the names of two
9 customers.
10 Q.How many customers were contacted about the
11 program either directly by a DSR or through a meeting or
12 conference call?
13 A.All together Idaho Power talked to forty-five
14 customers about the potential for a "virtual peaker
15 program". Of those customers, twelve expressed an interest
16 in having more in-depth talks. ul timately five customers
17 committed to allowing the Company to perform an on-site
18 interconnection cost analysis.
19 Q.Did Idaho Power conduct the on-site
20 interconnection cost analysis or did it engage the services
21 of a consultant?
22 A.The Company determined that it would be more
23 economical and timely to engage the services of a
24 consultant to perform the on-site cost analysis.
BRILZ, DI REB 5
Idaho Power Company
1 Q.Please describe the steps taken to perform
2 this analysis.
3 A.The Company issued a Request for Proposals
4 (RFP) in order to obtain the most competitive price for the
5 cost analysis. The RFP was issued on July 23. The
6 successful candidate, Power Engineers, was selected through
7 this process. A negotiated contract was finalized on
8 August 24 and the on-site work was conducted between
9 September 18 and September 24. The cost data associated
10 with the on-site analysis was provided to the Company on
11 November 14. Upon receipt of the interconnection cost data
12 from Power Engineers, the Company updated its ini tial
13 financial analysis to incorporate the detailed
14 interconnection cost data.
15 Q.What did the results from the updated
16 financial analysis indicate?
17 A.The results from the updated financial
18 analysis indicate there is enough potential benefit
19 associated with the program to continue pursuing its
20 investigation.
21 Q.What action is the Company now taking to
22 complete its investigation of the "virtual peaker program"?
23 A.The Company is now investigating air quality
24 and permitting issues with respect to diesel generators.
25 The Company has had initial discussions with the Department
BRILZ, DI REB 6
Idaho Power Company
1 of Environmental Quality to better understand the
2 permitting process and requirements.In addi t i on the
3 Company is gathering information on diesel generator
4 emissions to better assess the potential permi tting costs
5 and air quality issues.
6 Q.Do you believe the Company's actions
7 regarding its investigation of a "virtual peaker program"
8 demonstrate a serious commitment to pursuing distributed
9 generation as a resource?
10 A.Yes, I do.Idaho Power must fully understand
11 the complex interconnection and environmental ramifications
12 associated with such a "virtual peaker program" before it
13 can safely and cost-effectively integrate distributed
14 generation onto its system. The Company's investigation is
15 expected to be completed this spring.
16 Time-of-Use Rates
17 Q. Time-of-use rates were mentioned by several
18 parties. The ICIP expressed its opposition to mandatory
19 time-of-use rates for Schedule 19 customers. The IIPA and
20 Kroger both expressed a desire to establish voluntary time-
21 of-use rates for irrigation customers and Schedule 9 Primary
22 and Transmission service level customers , respectively.
23 Please begin by addressing the issues raised by the ICIP.
24 A.The ICIP argues against time-of-use rates
25 because of its belief that Schedule 19 customers are not
BRILZ, DI REB 7
idaho Power Company
1 able to adjust load usage patterns to maximize the potential
2 savings of moving load to off-peak times.
3 Q.Is load shifting the only objective of time-
4 of-use rates?
5 A.No. Although providing a price signal to
6 encourage customers to shift usage from higher-cost periods
7 to lower-cost periods is one objective of time-of-use rates,
8 providing prices that more accurately reflect the costs to
9 serve throughout the day is another objective. The improved
10 pricing provided by time-of-use rates better matches
11 customers' usage profiles and the costs to serve those
12 customers.
13 Q.Can customers benefit from time-of-use rates
14 without shifting their loads?
15 A.Yes. Customers who have a lower-cost usage
16 profile benefit from time-of-use rates without shifting any
17 load. Conversely, customers who have a higher-cost usage
18 pattern, e. g., those customers who use proportionately more
19 energy during the on-peak period, pay more under time-of-use
20 rates than they do under a flat, average rate.
21 Q.Have you identified any general
22 characteristics of customers whose usage patterns result in
23 a benefi t under time-of-use rates without implementing any
24 shift in load?
25 A.Yes. When the Company first proposed time-
BRILZ, DI REB 8
Idaho Power Company
1 of-use rates for Schedule 19 customers in Case No. IPC-E-03-
2 13, it performed an analysis as part of its rate design
3 process to determine the impact of the proposed time-of-use
4 rates on each customer taking Schedule 19 service at that
5 time.The results of the analysis showed that customers
6 with high load factors, and particularly customers whose
7 usage peaked in the non-Summer months, benefited most from
8 time-of-use rates compared to flat, average rates. Of the
9 40 customers who benefited from the time-of-use rates (as
10 compared to the average, flat rate) with no change in usage
11 pattern, 25 customers, or over 60 percent, were food
12 processors and large manufacturing facilities.
13 Q.Do you agree with the ICIP's recommendation
14 that time-of-use rates be offered only on a voluntary basis
15 to Schedule 19 customers?
16 A.No. Voluntary time-of-use rates generally
17 attract participation from customers whose electric bills
18 would be lower without any change in consumption. Although
19 the lower electric bills reflect the fact that the
20 customers' usage patterns are less expensive to serve than
21 the class average, the fact that no load shifting occurs
22 results in a reduction in revenue from the industrial class
23 without any corresponding system benefit in the form of
24 reduced power supply costs. Given that Schedule 19
25 customers' loads are of considerable size, voluntary time-
BRILZ, DI REB 9
Idaho Power Company
1 of-use rates for this class of customers would have the
2 potential to create a significant revenue deficit. I believe
3 time-of-use rates on a mandatory basis are appropriate for
4 customers taking service under Schedule 19 and I recommend
5 the Commission not adopt the ICIP' s proposal to make the
6 rates voluntary.
7 Q.The IIPA witness Mr. Yankel recommends that a
8 time-of-use rate for irrigation customers be established as
9 part of this proceeding. Do you agree with this
10 recommendation?
11 A.No. The Company is planning on implementing
12 Advanced Metering Infrastructure (AMI) throughout our
13 service territory beginning in late 2008. Full
14 implementation is scheduled to be complete by December,
15 2011. AMI will provide the platform for a numer of time-
16 variant pricing options, including time-of-use rates
17 (although additional time and investment will be required to
18 address constraints within the Company's Customer
19 Information System before time-variant pricing can be
20 offered on a large-scale basis). Given the significant
21 investment in metering equipment that will be necessary as
22 part of the AMI implementation, it does not make sense to
23 install time-of-use metering today to only have it replaced
24 within the next three years when AMI is installed. Rather,
25 it is more reasonable to postpone consideration of a time-
BRILZ, DI REB 10
idaho Power Company
1 of-use rate for irrigation customers until AMI is installed.
2 Q.Are you willing to consider time-of-use rates
3 for irrigation customers when AMI is available?
4 A.Yes.I believe a reasonably structured time-
5 of-use rate for irrigation customers could provide benefits
6 to both irrigation customers and to the system as a whole.
7 The Company would be willing to work with the IIPA to
8 develop a time-of-use rate for irrigation customers when the
9 metering and billing infrastructure is in place to support
10 such a rate.
11 Q.Kroger's witness Mr. Higgins recommends that
12 Schedule 9 customers taking service at either primary or
13 transmission service level be allowed to migrate to Schedule
14 19 in order to have the opportunity to take service under
15 time-of-use rates. Do you agree with Mr. Higgins's
16 recommendation?
17 A.I do not agree wi th Mr. Higgins's
18 recommendation to allow Schedule 9 customers desiring to
19 receive service under time-of-use rates to migrate to
20 Schedule 19 since this migration could have a negative
21 impact on cost-of-service results for Schedule 19 customers
22 due to the differences in usage patterns between the
23 Schedule 9 and Schedule 19 customers as a whole. However, I
24 do support making time-of-use rates available to Schedule 9
25 Primary and Transmission service level customers on a
BRILZ, DI REB 11
Idaho Power Company
1 voluntary basis as part of this case. This group of
2 customers currently has the metering infrastructure in place
3 to allow for time-of-use rates.
4 Q.Do you have a recommended proposal for
5 voluntary time-of-use rates for Schedule 9 customers?
6 A.Yes. I propose a time-of-use rate structure
7 that has the same billing components and time periods as the
8 time-of-use rate structure currently available under
9 Schedule 19. Under this rate structure the Service Charge,
10 Basic Charge, Demand Charge, and On-Peak Demand Charge for
11 the Schedule 9 Primary and Transmission service level time-
12 of-use option would be the same as the corresponding service
13 level charges for Schedule 19. The Energy Charges for
14 Schedule 9 would be approximately five percent greater than
15 the Energy Charges for Schedule 19. This proposal for time-
16 of-use rates for Schedule 9 Primary and Transmission service
17 level customers maintains the same relationship between
18 Schedule 9 and .?chedule 19 charges as is currently in place
19 today and as is proposed as part of this case. In addition,
20 this proposal provides customers who have lower-cost usage
21 profiles, and customers who are willing and able to shift
22 usage to lower-cost time periods, an opportunity to reduce
23 their bills with minimal revenue impact to the Company.
24 Q.Are you sponsoring an exhibit that details
25 your proposed time-of-use rates for Schedule 9?
BRILZ, DI REB 12
Idaho Power Company
1 A.Yes. Exhibit No. 64 details my proposal for
2 time-of-use rates for Schedule 9. Also included on the
3 exhibit are my proposed standard rates for Schedule 9 and my
4 proposed rates for Schedule 19 under the existing time-of-
5 use structure. These rates for Schedule 9 and Schedule 19
6 are taken from Exhibi t No. 59 and are inc 1 uded on Exhibi t
7 No. 64 for comparative purposes.
8 Q.Are there any issues you believe need to be
9 taken into consideration in the design of time-of-use rates
10 for Schedule 9?
11 A.Yes. Customers taking service under
12 Schedules 9 and 19 move from one schedule to the other as
13 their load increases or decreases. I believe it is
14 important that the rates on these two schedules allow for a
15 smooth transition. I also believe that the pricing between
16 the two schedules should be sufficient to eliminate any
17 incentive' for customers on Schedule 9 to increase their
18 consumption in order to become eligible for Schedule 19.
19 Q.Does your proposal accomplish these
20 objectives?
21 A.Yes, it does.
22 Irrigation Peak Rewards Program
23 Q.IIPA witness Mr. Yankel recommends that
24 changes be made to the Company's Irrigation Peak Rewards
25 demand response program as part of this general rate case
BRILZ, DI REB 13
Idaho Power Company
1 proceeding. Do you agree that a general rate case is the
2 appropriate forum in which to make changes to this program?
3 A.No, I do not.
4 Q.What do you believe is the appropriate forum
5 in which to make changes to the Irrigation Peak Rewards
6 program?
7 A.The Company has a highly informed and engaged
8 advisory body, the Energy Efficiency Advisory Group (EEAG),
9 that meets regularly to provide input to the Company on the
10 design and implementation of energy efficiency and demand
11 response programs. The EEAG is comprised of representatives
12 from the residential, commercial, irrigation, and industrial
13 customer classes, from special interest groups such as AAP
14 and the NW Energy Coalition, from technical groups such as
15 the Northwest Planning and Conservation Council and the
16 idaho Office of Energy Resources, and from the Idaho and
17 Oregon commissions. I believe that the appropriate forum
18 for making changes to the Irrigation Peak Rewards Program is
19 within the EEAG framework.
20 Q.Does the Company work wi th any other groups
21 to solicit input and feedback on its programs?
22 A.Yes. The Company has convened numerous
23 customer-specific stakeholder groups to gather input and
24 feedback on the various programs it is designing and
25 implementing.
BRILZ, DI REB 14
idaho Power Company
1 Q.Would you please describe what these groups
2 are?
3 A.Yes. Stakeholder groups are an amalgam of
4 representatives from the same customer class who are asked
5 to provide input and feedback in a manner similar to that of
6 the EEAG. These groups are formed on an ad hoc basis as the
7 need arises. Input obtained through stakeholder groups is
8 incorporated into the program planning process and is
9 brought before the EEAG for consideration.
10 Q.Has the Company ever used an irrigation
11 stakeholder group?
12 A.Yes. An irrigation stakeholder group was
13 used in June, 2005 to provide input on the redesign of the
14 Company's Irrigation Efficiency Rewards program. A
15 stakeholder group was also used in June, 2006 to provide
16 input on the redesign of the Irrigation Peak Rewards
17 program. The IIPA fully participated in the June, 2006
18 stakeholder meeting in which issues and ideas relating to
19 the irrigation Peak Rewards program were presented and
20 discussed.
21 Q.Has the Company convened stakeholder meetings
22 involving any other customer groups?
23 A.Yes. The Company has held a number of
24 industrial-customer stakeholder meetings over the past
25 several years. As with the irrigation-customer stakeholder
BRILZ, DI REB 15
Idaho Power Company
1 meetings, these sessions provide very useful information on
2 program design and implementation issues.
3 Q.Would the Company be willing to convene a
4 stakeholder meeting with the IIPA to review potential
5 changes to the Irrigation Peak Rewards program and other
6 potential program offerings to then be taken to the EEAG for
7 consideration?
8 A.Yes.The Company welcomes the opportuni ty
9 to work with its customers to develop and refine programs
10 that benefit both individual customers and the Company's
11 system as a whole.
12 Revenue Requirement Allocation
13 Q.Several parties have made recommendations for
14 how the Commission should determine the revenue requirement
15 allocation for the various customer classes.In particular,
16 Dr. Reading recommends an equal percentage increase to all
17 customer classes. Dr. Peseau recommends an equal percentage
18 increase to all customer classes except for the irrigation
19 class for which he recommends an increase equal to twice the
20 system average. Do you agree with an equal percentage
21 increase approach as proposed by Dr. Reading and Dr. Peseau?
22 A.No, I do not.
23 Q.Please explain why you do not agree with this
24 approach.
25 A.I believe cost-of-service results should be
BRILZ, DI REB 16
Idaho Power Company
1 used as a starting point in establishing the revenue
2 requirement allocation for the various customer classes. An
3 equal percentage increas~ ignores the cost-of-service
4 results and arbitrarily allocates the increase in revenue to
5 the customer classes.
6 Q.Mr. Yankel recommends no increase be given to
7 the irrigation class, an average increase be given to the
8 residential class, and increases larger than the average
9 increase be given to the Schedule 9 and Schedule 19
10 customers. Do you believe the Commission should consider
11 Mr. Yankel' s recommendation when determining the revenue
12 requirement for each customer class?
13 A.No, I do not.
14 Q.Please explain why not.
15 A.As Mr. Tatum has stated in his direct
16 rebuttal testimony, Mr. Yankel' s Growth Corrected study as
17 presented in this case produces results that are not
18 reasonable. For this reason, I recommend that the Commission
19 rej ect the results of Mr. Yankel' s Growth Corrected study
20 and his proposal to not increase the revenue requirement for
21 the irrigation class when determining the class revenue
22 requirement allocation.
23 Q.Dr. Goins and Dr. Reading have recommended
24 using different factors to determine the energy and demand
25 classifications of the production plant and purchased power
BRILZ, DI REB 17
Idaho Power Company
1 (Account 555) expenses. Dr. Peseau has recommended a
2 variation on the calculation of the summer and non-summer
3 monthly weighted costs for deriving allocation factors. Do
4 the results from the cost-of-service studies submitted by
5 these three witnesses differ significantly from the results
6 you used as the basis for your revenue requirement
7 allocation detailed on your Exhibit No. 58?
8 A.No. As Mr. Tatum has acknowledged in his
9 direct rebuttal testimony, there are a numer of methods
10 which could be used to classify production plant and
11 purchased power (Account 555) expenses between the energy-
12 related and demand-related components. In addition, there
13 are a number of ways that factors could be derived to weight
14 summer and non-summer peak period demand. Not surprisingly,
15 each alternative method affects the cost-of-service results
16 for the various customer classes differently. However, the
17 overall cost-of-service results submitted by Dr. Goins, Dr.
18 Reading, and Dr. Peseau, although they differ in absolute
19 magnitude, show the same general results as that submitted
20 by Mr. Tatum and used as the basis for the revenue
21 allocation I recommended and detailed on Exhibit No. 58.
22 Exhibi t No. 65 shows a comparison of the results from the
23 preferred 3CP/12CP cost-of-service study prepared by Mr.
24 Tatum and the results from the cost-of-service studies
25 prepared by Dr. Goins, Dr. Reading, and Dr. Peseau. The
BRILZ, DI REB 18
idaho Power Company
1 results from the cost-of-service study performed by Mr.
2 Hessing are also included for illustrative purposes.
3 Q.What information can be gleaned from Exhibit
4 No. 65?
5 A.As Exhibit No. 65 shows, regardless of the
6 methodology used to classify production plant and purchased
7 power expenses as energy- or demand-related or to weight the
8 sumer and non-summer peak usage, the percentage increase in
9 revenue identified for the residential customer class never
10 exceeds one-eighth of the overall percentage increase in
11 revenue reques ted by the Company.Similarly, the percentage
12 increase in revenue identified for the irrigation class is
13 never less than three times the overall percentage increase
14 in revenue requested by the Company. The revenue increase
15 identified for small commercial customers, Schedule 7, does
16 not vary by more than a few percentage points for any of the
17 cost-of-service studies presented in this case.For
18 Schedule 9, Sch~dule 19, and Special Contract customers, the
19 increase identified decreases as more costs are classified
20 as demand-related, with the impact more significant for
21 Schedule 19 and Special Contract customers.
22 Q.Based on this information do you support
23 recommendations by any other party for deriving the revenue
24 requirement allocation for the various customer classes?
BRILZ, DI REB 19
Idaho Power Company
1 A.Yes. Both Dr. Goins and Mr. Hessing recommend
2 using the results from cost-of-service studies to guide the
3 determination of class revenue requirement, although Dr.
4 Goins recommends using the results from a modified 3CP/12CP
5 study while Mr. Hessing recommends using the results from
6 the Base Case study.I agree wi th both Dr. Goins and Mr.
7 Hessing that cost-of-service results, with caps, should be
8 used in determining class revenue requirement. I continue
9 to support the four-step sequential approach I recommended
10 and detailed on Exhibit No. 58 utilizing the results from
11 the Company's 3CP/12CP cost-of-service study. However, in
12 the alternative, I would support the approaches recommended
13 by Dr. Goins and Mr. Hessing as these two approaches take
14 into consideration cost-of-service results.
15 Rate Design
16 Q.Other than the issue of time-of-use rates
17 raised by Mr. Higgins and Mr. Yankel, do any other parties
18 make recommendations regarding rate design?
19 A.Yes . Given the small increase in revenue
20 requirement supported by Staff, Mr. Hessing recommends that
21 for customer classes where Staff recommends an increase, the
22 energy rates be increased to obtain the desired revenue
23 requirement with no changes to the non-energy rates, except
24 for the irrigation customer class, Schedule 24. Mr. Hessing
25 recommends a uniform percentage increase to all rate
BRILZ, DI REB 20
Idaho Power Company
1 components for the irrigation class.
2 Q.DO you agree wi th Mr. Hessing's
3 recommendation?
4 A.I agree with Mr. Hessing's recommendation to
5 increase only the energy component for Schedule 1 and
6 Schedule 7 as this recommendation is the same as that which
7 I have proposed. However, I do not agree wi th Mr. Hessing's
8 recommendation to increase only the energy component for all
9 other rate schedules, except Schedule 24.
10 Q.What do you recommend instead?
11 A.I continue to recommend that the
12 relationships between the demand and energy components on
13 and between Schedules 9 and 19 be established as proposed on
14 Exhibit No. 59. I also recommend that the rate design for
15 Schedule 24 reflect the proportional increases in the
16 customer-, demand-, and energy-related charges as detailed
17 on Exhibit No. 59. As Mr. Hessing pointed out in his direct
18 testimony, customers who take service under Schedules 7, 9,
19 and 19 qualify for a specific schedule based on the size of
20 their load and can move from one schedule to another as
21 their load increases or decreases. The rate design approach
22 I detailed on Exhibit No. 59 will maintain the relationship
23 between 'the rate components for Schedules 7, 9, and 19 thus
24 facilitating the smooth transition between schedules. It
BRILZ, DI REB 21
idaho Power Company
1 will also provide irrigation customers with the price signal
2 to minimize peak demand and increase load factor.
3 Q.Did Mr. Hessing recommend that any increase
4 for the Special Contract customers also be placed only on
5 the energy component?
6 A.I am not clear on Mr. Hessing's proposal for
7 the Special Contract customers. However, I continue to
8 recommend that the existing rates for the Special Contract
9 customers simply be increased uniformly to recover the
10 revenue requirement approved by the Commission.
11 Q.Does this conclude your rebuttal testimony?
12 A.Yes, it does.
BRILZ, DI REB 22
Idaho Power Company
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Case No. IPC.E-07-D8
M, Brilz. IPCo
Page 2 of2
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