20090812Answer to Joint Renewed Motion.pdf

eslDA~POR~
An IDACORP Company
BARTON L. KLINE
Lead Counsel
August 11, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-03
LANGLEY GULCH POWER PLANT
Dear Ms. Jewell:
Enclosed for filing are an original and seven (7) copies of Idaho Power Company's
Answer to Joint Renewed Motion to Stay Proceeding in the above matter.
Very truly yours,~tL-
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (83707)
1221W.ldaho St.
Boise, 10 83702
BARTON L. KLINE (ISB No. 1526)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: 208-388-6936
bkline(âidahopower.com
Inordstrom(âidahopower.com
R\ECEf'¡i:ri. " \1 i. ii..r
2009 AUG II PH~: 56
Attorneys 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 IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE LANGLEY GULCH POWER PLANT.
)
) CASE NO. IPC-E-09-03
)
) IDAHO POWER COMPANY'S
) ANSWER TO JOINT RENEWED
) MOTION TO STAY PROCEEDING
)
COMES NOW, Idaho Power Company ("Idaho Power" or "Company") and,
pursuant to RP 57, hereby answers the Renewed Motion to Stay of the Industrial
Customers of Idaho Power ("ICIP"), the Idaho Irrigation Pumpers Association
("Irrigators"), Snake River Allance, the Idaho Conservation League, the Northwest &
Intermountain Power Producers Coalition ("NIPPC"), and the Community Action
Partnership Alliance, hereinafter collectively "Intervenors."
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 1
I.
INTRODUCTION
On May 29,2009, Intervenors filed their Motion to Stay this proceeding. On two
occasions after that initial filing, the Commission advised the parties that it would take
the Motion to Stay under advisement and issue its decision in due course. Those
rulings notwithstanding, Intervenors have renewed their Motion.
The Renewed Motion does not present any new issues or arguments that were
not addressed at considerable length in either the original Motion to Stay or the
testimony and exhibits that Intervenors presented to the Commission at the technical
hearing.
As a result, this Answer wil not be a point-by-point refutation of the Renewed
Motion. However, there are several assertions made in the Intervenors' Renewed
Motion that require a brief response.
II.
INTERVENORS ARE NOT REALLY RECOMMENDING A TEN-MONTH DELAY
Intervenors have not been consistent in specifying what they want the
Commission to do in this proceeding. In several places in the Renewed Motion,
Intervenors state that they are only asking the Commission to stay these proceedings
for ten months. They have cited the ten-month delay period repeatedly in the various
press interviews in which they have participated. However, the Commission action they
are actually requesting is quite different. For example, two of the Intervenors, the
Industrial Customers of Idaho Power ("ICIP") and the Northwest & Intermountain Power
Producers Coalition ("NIPPC"), recommend that the Commission deny the Company's
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 2
Certificate of Public Convenience and Necessity ("CPCN"), wait until after the
Commission has fully reviewed and accepted the 2009 IRP, conduct a formal
proceeding to develop new generic guidelines for utilty competitive requests for
proposals, and then issue a completely new RFP applying the new guidelines. Only
after all of those steps had been completed could the Company come back for a CPCN
and start to acquire a needed resource. (TR. 841.) Intervenors are not suggesting a
ten-month delay. They are proposing a delay that could extend for years. Such a delay
presents substantial risk to the Company's customers. Mr. Bokenkamp addressed that
risk in his testimony as follows:
A. If it takes a year to develop the (competitive bidding)
guidelines, two years to complete the RFP process, and
approximately three years for project design and construction,
a resource like Langley Gulch would not be online and
available to serve customer loads before mid-2015.
Q. Would that be a problem for the Company and its
Customers?
A. Yes. Idaho Powets load-resource balance in 2012 is
already tenuous. Waiting three to four years to add a
base load resource wil increase those risks substantially. In
addition, it wil compromise the Company's abilty to integrate
wind and other intermittent resources if they continue to
develop at the pace Idaho Power expects to see. (TR. 309.)
Even a ten-month delay carries the very real potential to cause a much longer
delay in the on-line date of a resource needed in 2012. Confidential Exhibit No. 26
shows that after November 1, 2009, at least one of the key contracts that the Company
has negotiated for the Langley Gulch project could be cancelled by the contractor. If it
is cancelled, a whole new resource acquisition process wil have to be initiated. If that
occurs, two things could happen: (1) customers could lose the very favorable pricing
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 3
that the Company was able to obtain for Langley Gulch as a result of this RFP and (2)
depending on how long it takes to obtain a CPCN for a replacement resource and how
long it takes to build the replacement resource, it is almost certain that the Company wil
not be able to count on the availabilty of a new generation resource in 2012 when its
load forecast shows it wil be needed.
II.
LONG-LEAD TIME RESOURCES REQUIRE THE USE OF FORECASTS
In their Renewed Motion to Stay, Intervenors present their explanation of the
reason for the difference between the Company's position that it will need a new
base load resource in 2012 and their position that the Company wil not need a new
base load resource in 2012 as follows: "The reason for these divergent views is based
on the Company's use of its forecast data, while the Intervenors have relied upon actual
information." (Renewed Motion to Stay, p. 7.) The "actual information" Intervenors refer
to are historic 2008 and 2009 loads. They urge the Commission to require the
Company to stop its pursuit of Langley Gulch until "actual information," Le., historic
loads, confirms that a new generating resource will absolutely be needed at a specific
point in time in the future.
It would be wonderful if Idaho Power could plan resources the way Intervenors
recommend. If the Company could wait until it absolutely, positively knew what its loads
would be at a point in the future and could then acquire a precisely-sized resource "just
in time," life would certainly be a lot simpler. Unfortunately, whether built by the
Company or by a third-party under a power purchase agreement or tolling agreement, it
wil take at least three years to construct a new base load generating resource. As a
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 4
result, responsible resource planning requires the Company (and the Commission) to
look forward to 2012 to anticipate and plan for the needs of both its existing customers
and the potential loads of new customers that will exist at that time. Therefore, the
Company must rely on its forecasts of loads and portolio of potential resources to strike
a load and resource balance that will allow the Company to satisfy its legal obligation to
serve its loads and to do so at the lowest reasonable cost consistent with prudent utility
planning criteria.
In their Renewed Motion for Stay, Intervenors make it clear that if the Company's
August 2009 load forecast shows a continuing need for a resource like Langley Gulch
by 2012, then the Intervenors wil assign no credibiliy to the forecast.1 (Renewed
Motion, pp. 10-11.) In the Renewed Motion, Intervenors argue that instead of looking at
the Company's forecast of loads for 2012, the Commission should instead focus on
whether the Company's actual loads in 2009 are lower than they were in 2008.
(Renewed Motion, p. 10.) If they are lower, Intervenors argue this proves that the
Company load forecasts are wrong and a new baseload resource will not be needed in
2012 (Renewed Motion, p. 11). Such a simplistic approach is neither logical nor
reasonable. There are numerous reasons why actual loads in 2009 might be lower than
loads in 2008. The reason often mentioned is the effect of the recession; however,
precipitation, temperatures, commodity prices, and shifting world markets for computer
chips and polysilcon have all played a role in 2008 and 2009 energy sales. In addition,
i The Company does not routinely file its annual load forecast with the Commission for its review
and approvaL. In odd-numbered years, the annual load forecast is used in developing the Integrated
Resource Plan ("IRP"). In even-numbered years, the Company is required to make an informational IRP
update filing in Oregon and a copy of the Oregon updated IRP is provided to the Commission. The
Company will file its 2009 IRP by year-end. The Company will provide the 2009 load forecast results and
2009 load/resource balance to its IRP advisory committee in the next few weeks.
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 5
it is very likely that the Company wil be asked to serve some new large loads between
now and 2012. The Intervenors' recommendation that the Commission only look at
historic loads ignores that very real possibilty.
The more responsible approach for the Commission to take is to assess how well
the Company has done recently in forecasting its future loads. Mr. Bokenkamp
presented testimony in this case describing how the Company has continuously
updated its load forecasts as the changes in the credit markets and the resulting
economic recession has unfolded. (TR. 281.) He also presented evidence, including a
load/resource balance, based on the Company's May 2009 load forecast showing the
continuing need for Langley Gulch in 2012. (TR. 281-282 and Exhibit No. 10.)
On July 28, 2009, the Commission, through its Staff, directed the Company to
prepare and file as a post-hearing response to a data request, a document comparing
monthly weather normalized energy sales from August 2008 through July of 2009 with
the forecasted monthly data from the August 2008, December 2008, and May 2009 load
forecasts that Mr. Bokenkamp referred to in his testimony. A copy of the response to
the Commission information request is enclosed with this Answer as Attachment NO.1.
Attachment No. 1 shows that the Company's load forecasts have been updated
regularly and have done a good job of responding to the rapidly changing conditions
brought about by the current economic crisis. For example, a comparison of weather
adjusted actual loads to the May 2009 load forecasted loads shows the forecast
deviation from actual was 3.4 percent in May 2009, 4.9 percent in June 2009, and 1.3
percent in July 2009. The deviation in July would have been even less if Hoku had
operated as it had told the Company it would.
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 6
When looking at Idaho Power's actual system load, the peak day this summer
occurred on July 22,2009, when the hourly average system load (without the impact of
demand response programs) reached 3,136 MW. For the entire month of July, average
system load was 1,865 aMW (1,387,374 MWh), which is just 24 aMW lower than
predicted in the May 2009 load forecast (1,405,565) shown in Attachment NO.1. While
Intervenors attempt to cast doubt on Idaho Power's load forecast, actual results through
July show the May 2009 load forecast has done a good job of predicting the Company's
actual loads during a volatile period. Therefore, Attachment No. 1 adds additional
support to the testimony already in the record in this case that the Company's May 2009
forecast of 2012 loads is reasonable, that the load/resource balance evidence
presented in Exhibit No. 10 and Mr. Bokenkamp's testimony is reliable, and the
evidence Idaho Power presented in this case can reasonably be relied upon to support
a decision to issue a CPCN for Langley Gulch in time to allow the resource to be
constructed so it can be available in 2012.
iv.
INTERVENORS ARE RECOMMENDING A DANGEROUS STRATEGY
In the Renewed Motion, Intervenors recommend that the Commission adopt a
strategy that assumes that Idaho Power wil not need a new baseload resource to serve
customer loads in 2012. Intervenors recommended strategy is based on the
assumptions that (1) the current recession wil cause Idaho Powets loads to remain flat
for an unknown but extended period of time (Renewed Motion, p. 11.), (2) that the
Company can acquire all the resources it needs for the next few years from demand-
side management and renewable resources (Renewed Motion, p. 5.), and (3) Idaho
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 7
Power can continue to rely on its ability to purchase a substantial amount of power from
surplus generation sellers located in the Pacific Northwest and the Desert Southwest to
be delivered to the Company using non-firm transmission on the existing transmission
system. Both the Irrigators and the ICIP assert in their testimonies that the Company
has been relying on large wholesale purchases imported on non-firm transmission for
years so there is no reason to assume it cannot continue to do so. (TR. 1005 and TR.
606-607.)
In contrast, Idaho Power has presented evidence in support of its strategy that to
provide adequate, reliable service in 2012, it needs to immediately move to add a
baseload resource located near its load center. The Company presented evidence that
Langley Gulch is the least-cost baseload resource that meets these criteria.
Both Idaho Powets and the Intervenors' proposed strategies carry some risk.
However, the risk profiles of the two competing strategies are asymmetricaL. If the
Commission accepts Idaho Powets strategy and authorizes the Company to proceed
with the construction of the Langley Gulch project, there is the risk that in 2012, the
Company may not need all of the output of the Langley Gulch project to serve its native
load. Until such time as the Company's native load grows to match the additional
resource capacity provided by Langley Gulch, customers may pay slightly higher rates
than they would have if Langley Gulch had been constructed later. The risk that
customers may pay these additional costs is mitigated by the fact that the Company can
sell surplus energy generated by Langley Gulch on the wholesale market. Ninety-five
percent of surplus sales revenues are used to decrease customer rates. The risk that
additional cost may be incurred is also mitigated by the increased reliability Langley
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 8
Gulch wil provide and by the potential for reducing the Company's reliance on more
expensive wholesale purchases delivered using non-firm transmission.
In contrast, if the Commission adopts the strategy proposed by the Intervenors,
the risk to the Company's customers and its entire southern Idaho service area is
substantially greater. First, any new large customers seeking to locate plants or
facilties in Idaho Power's service territory must be advised that the Company does not
have firm resources sufficient to serve their loads on a year-round basis and that future
additional firm resource availabilty is uncertain. Undoubtedly, this will hamper
economic development in Idaho Power's service area.
Second, Idaho Power will be forced to continue to rely heavily on the use of non-
firm transmission to serve critical summer loads. As both Mr. Bokenkamp and Mr.
Porter noted in their testimonies, Idaho Power is already uncomfortable with its current
level of reliance on the uncertain availability of non-firm transmission to serve its current
electrical loads, particularly during the summer. (TR. 287-288 and TR. 540, 594-595.)
Mr. Porter described the problem succinctly in his response to a question from
Commissioner Kempton.
Also, once again, another summer of not having to rely on
non-firm transmission, which is a bear. I've spent many
years in operations and i can tell you that it is not prudent to
operate this system relying on non-firm transmission. It's the
first thing to get cut and it's not just for problems on our
system. If there's problems on other systems due to the
rules and regulations in the WECC, our transmission can get
cut for other people's problems and that happens and it's a
nightmare trying to operate it and keep the lights on relying
on non-firm transmission. I just don't think that's prudent to
continue to do it to the extent we are, so there's a lot of
benefits in bringing it back to the summer of 2012 for the
customers. (TR. 540.)
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 9
Simply put, if the Commission adopts Intervenors' strategy, the risk associated
with the Company's reliance on non-firm transmission to serve load wil be exacerbated
and the risk of reduced reliability and load curtailment wil increase.
Finally, if the Commission adopts Intervenors' strategy and in 2012 and
thereafter the Company experiences adverse water conditions, extraordinarily high
temperatures, forced outages at distant generating plants, loss of transmission
capability, loop flows, or any combination of these risks, the unavailabilty of Langley
Gulch may cause the Company to curtail service to customers.
In short, the magnitude of risk and the magnitude of the costs that customers
could incur if the Commission adopts Intervenors' strategy are much higher than the
cost exposure customers assume if Idaho Power is permitted to build Langley Gulch.
Staff witness Sterling's testimony shows that Staff recognizes the cost/risk ratio. "In my
opinion, the risks of an early online date versus a late online date are not symmetric.
The costs and risks of bringing the plant online too late far outweigh the costs of
bringing the plant online too soon." (TR. 1037.)
v.
CONCLUSION
Despite the criticisms leveled against the Company's RFP process, principally by
a trade association that represents at least one of the losing bidders in the RFP, and
therefore has a strong motivation to see the prior RFP thrown out, Idaho Power
conducted a fair and cost-effective RFP process. (TR. 910.) As Mr. Sterling noted in
his testimony, the losing short-listed bidders were capable, experienced developers.
(TR 1068). In this RFP, the other short-listed bidders simply were not sufficiently
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 10
aggressive in reducing their costs to win the bid. The lowest cost base load resource
submitted in the RFP was the Langley Gulch project. Based on standard revenue
requirement comparisons, Langley Gulch wil provide a superior value to Idaho Powets
customers for a long time to come.
Idaho Power acknowledges that this is a very big case. Addition of the Langley
Gulch project to the Company's resource portfolio will have a significant impact on the
Company's revenue requirement and on customer rates, but so wil all other courses of
action, including doing nothing.
The Company is also asking the Commission to support the Company's efforts to
finance the Langley Gulch project in a manner that minimizes the rate impact on
customers. The turmoil in the financial markets has substantially abated but uncertainty
on the part of lenders and credit rating agencies is stil prevalent. The ratemaking
assurances the Company has requested pursuant to Idaho Code § 61-541 are still
needed and desired in concert with the potential CPCN order.
Idaho Power feels so strongly that Langley Gulch is needed that it has exposed
itself to potential financial loss to ensure that the Company has the ability to serve its
customers' loads in 2012. The Company did not make that decision to take on the
financial risk lightly or inadvertently. Idaho Power is convinced that a resource wil be
needed in 2012 and it was willing to take on the financial exposure to ensure that
equipment and engineering expertise would be available to supply that need.
Both the Company and the Commission have a legal obligation to ensure that
Idaho Power's customers have adequate and reliable supplies of electricity. By issuing
A CPCN for the Langley Gulch project, the Commission can make a strong contribution
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 11
to providing electrical service reliability, enhanced economic development opportunity,
and a more secure energy future for Idaho Powets customers in southern Idaho.
Respectfully submitted this 11 th day of August 2009.
~.
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of August 2009 I served a true and
correct copy of the within and foregoing document IDAHO POWER COMPANY'S
ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING upon the following
named parties by the method indicated below, and addressed to the following:
Commission Staff
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho
Power and Northwest and
Intermountain Power Producers
Coalition
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
Snake River Allance
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Idaho Irrigation Pumpers
Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
P.O. Box 1391
201 East Center
Pocatello, Idaho 83204-1391
-- Hand Delivered
U.S. Mail
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FAX
-- Email Scott.Woodbury(âpuc.idaho.gov
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FAX
-- Email peter(ârichardsonandoleary.com
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-- Email dreading(âmindspring.com
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-- Email kmiler(âsnakeriverallance.org
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-- Email elo(âracinelaw.net
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING -13
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
.- U.S. Mail
_ Overnight Mail
FAX
.- Email tony(âyankel.net
Idaho Conservation League
Betsy Bridge
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
Hand Delivered
.- U.S. Mail
_ Overnight Mail
FAX
.- Email bbridgeCáwildidaho.org
Northwest and Intermountain
Power Producers Coalition
Susan K. Ackerman
9883 NW Nottage Drive
Portland, Oregon 97229
Hand Delivered
.- U.S. Mail
_ Overnight Mail
FAX
.- Email Susan.k.ackermanCácomcast.net
Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1 ¡th Street
Boise, Idaho 83702
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FAX
.- Email bmpurdy(âhotmail.com
~IÓ-
Barton L. Kline
IDAHO POWER COMPANY'S ANSWER TO JOINT RENEWED MOTION TO STAY PROCEEDING - 14
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-09-03
IDAHO POWER COMPANY
ATTACHMENT NO.1
BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: 208-388-6936
bklineCfidahopower.com
InordstromCfidahopower.com
Attorneys 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 IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE LANGLEY GULCH POWER PLANT.
)
) CASE NO. IPC-E-09-03
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE COMMISSION'S
) POST-HEARING INFORMATION
) REQUEST
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the Commission's July 28, 2009, post-hearing information request, herewith
submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE
COMMISSION'S POST-HEARING INFORMATION REQUEST-1
REQUEST: As per Commission request and as a follow-up to an offer of
evidence at hearing by Company witness Ric Gale, please provide weather normalized
monthly energy sales from August 2008 through July 2009. In addition, please provide
the August 2008, December 2008, and May 2009 monthly energy forecasts that were
made for 2009 conditions of 50% load probabilty. Include a brief narrative to describe
and discuss the data.
RESPONSE TO REQUEST: The requested information is enclosed and
includes:
1. Weather Normalized Energy Sales - January 2008 through July
2009;
2. Sales Forecast - August 2008;
3. Sales Forecast - December 2008; and
4. Sales Forecast - May 2009.
Idaho Power prepares an annual load forecast. It is used for several different
purposes, including resource planning, financial forecasting, and preparation of the
Operating Plan for risk management purposes. During the course of a year, the load
forecast may be updated to account for new information and material changes.
In Mr. Bokenkamp's testimony in this case, he discussed the three load forecasts
that are presented in this Response. The earliest of the three forecasts, the August
2008 forecast, was used to start the preparation of the 2009 IRP, which wil be filed by
the end of this year.
The December 2008 forecast is an update to the August 2008 forecast that was
performed in response to the deteriorating conditions that were becoming evident in the
Company's service area at that time. The December 2008 update adjusted the
IDAHO POWER OOMPANY'S RESPONSE TO THE
COMMISSION'SCPOST-HEARING INFORMATION REQUEST - 2
residential and commercial sector to reflect a prolonged slowdown in housing and
consumer spending. Residential new customer growth rates (initially forecasted to
decline until the first quarter of 2009) were extended to continue the decline into 2010
and later rebound to the point of the original new customer forecast in 2016.
Commercial customer growth counts were lowered based on a model driven by
residential customer growth.
Because economic conditions continued to degrade, the Company performed
another update to its load forecast in May of 2009. This update addressed the forecast
loads for special contract customers. In this update, the load forecast was reduced
again, with the largest reductions (94 aMW and 97 MW during peak hours) occurring in
late 2009.
Load forecasts are generally differentiated to reflect a range of load uncertainty
due to weather. The three case load forecasts prescribed in this Response assume
median temperatures and median precipitation, Le., there is a 50 percent chance that
loads wil be higher or lower than the expected case loads due to colder-than-median or
hotter-than-median temperatures or wetter-than-median or dryer-than-median
precipitation.
The weather normalized energy sales and forecast energy sales in each of the
three sales forecasts are reported in megawatthours ("MWhs"). In addition, the weather
normalized energy sales and energy sales in the three forecasts are sales that occur on
a billing month basis and do not include line losses. The Company's weather-
adjustment model adjusts actual biling month electricity sales for abnormal weather,
IDAHO POWER COMPANY'S RESPONSE TO THE
COMMISSION'S POST-HEARING INFORMATION REQUEST - 3
and the resulting weather-adjusted biled sales are the most accurate data to compare
to forecast data to measure forecast accuracy.
Weather-adjusted sales for July 2009 were just 18,191 MWh (24 aMW) lower
than predicted in the May 2009 forecast, a 1.3 percent difference. In addition, the May
2009 forecast included 6,696 MWh in July 2009 for Hoku Materials, Inc. ("Hoku"), a
customer that has recently reconsidered their initial ramp-up schedule and are now
expected to begin operation in December of 2009. Excluding Hoku, the July 2009
forecast would have only been 0.8 percent higher than the July 2009 weather adjusted
sales figure. Excluding Hoku, the December 2008 and August 2008 forecasts would
have only been 1.7. percent and 2.3 percent, respectively, higher than the July 2009
weather adjusted sales figure.
The recession that began in December 2007 turned out to be far more severe
than expected. As a result, each successive Idaho Power load forecast was lowered as
economic conditions . worsened. The recession also caused the delay in the rollout
plans that Hoku had originally planned. Conditions also changed at Micron Technology
and their loads contracted by 30 percent. The national economy is now bottoming and
the latest economic forecasts project that the recession wil be over by late this year.
With the recession nearing its end, the economic growth prospects for southern Idaho
are good.
The response. to this Request was prepared by Barr Smith, Planning Analyst,
Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE
COMMISSION'SPOS,-~HEARING INFORMATION REQUEST - 4
DATED at Boise, Idaho, this 11th day of A~&-_
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE
COMMISSION'S POST-HEARING INFORMATION REQUEST - 5
CERTIFICATE OF SERVICE
I HEREBY CËRTIFY that on this 11th day of August 2009 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION'S
POST-HEARING INFORMATION REQUEST upon the following named parties by the
method indicated below, and addressed to the following:
Commission Stàff
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho
Power and Northwest and
Intermountain Power Producers
Coalition
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
Snake River Allance
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
Idaho Irrigation Pumpers
Association, I nco
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE
& BAILEY,CHARTERED
P.O. Box 1391
201 East Center
Pocatello, Idaho 83204-1391
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IDAHO POWER COMPANY'S RESPONSE TO THE
COMMISSION'S POST ~HEARING INFORMATION REQUEST - 6
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Village, Ohio 44140
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-2 Email tony(âyankel.net
Idaho Conservation League
Betsy Bridge
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
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-2 Email bbridge(âwildidaho.org
Northwest and Intermountain
Power Producers Coalition
Susan K. Ackerman
9883 NW Nottage Drive
Portland, Oregon 97229
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-2 Email Susan.k.ackerman(âcomcast.net
Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 1 ¡th Street
Boise, Idaho 83702
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-2 Email bmpurdy(Çhotmail.com
(1/~
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE
COMMISSION'S POST-HEARING INFORMATION REQUEST-7
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-09-03
IDAHO POWER COMPANY
RESPONSE TO COMMISSION'S
POST-HEARING INFORMATION REQUEST
We
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