20091222SRA Comments.pdf

~
'"
Comments of the Snake River Alance R E C E \ V E 0
On Application of Idaho Power Company For An Accounting Order tô~ 3: I. 8
Additional Accumulated Deferral Income Tax RateSnû9.
And An Order Approving a Rate Case Moratorium !f.. '_', v ¡'i)t?,;,;
~ L. f': ,',','.... '...;,i.i.;',.r i-'Submitted by \ ¡""\\ ITIES l~\,hn;\¡¡0'J l.~Ken Miler, Clean Energy Program Director, Snake River Alance
December 22, 2009
The Snake River Allance appreciates the opportnity to comment on IPC-E-09-30 and
Idaho Power Company's application for an accounting order to amortize additional
accumulated deferral income tax credits and an order approving a rate case moratorium.
The Snake River Alliance submits these comments on behalf of its members, many of
whom are customers of Idaho Power Co. and most of whom are customers of Idaho's
investor-owned utilties.
The Allance believes the application for a moratorium in general rate case increases
though Januar 2012, as well as the proposed sharng of cerain percentages ofthe
anticipated 2010 power cost adjustment, among other things, is appropriate and would
serve the best interests of the company and its Idaho customers. In our view, the result of
the setlement between Idaho Power and varous stakeholder groups is creative and
should lead to outcomes that are preferable to what might have resulted from a contested
general rate case. Our concer about this application is the process from which it arose.
The Allance and its member believe a docket of this significance might have been better
handled though a more transparent process rather than being limited to meetings
between the company and select customer groups. We appreciate that settlements in
general rate cases are generally preferable to protracted and expensive formal
proceedings. However, we find it somewhat awkward that a settlement was reached in
the absence of a filing and without the benefit of input from any interested pary choosing
to provide it. As the Allance expands utilty education and outreach efforts for our
members and constituents, a growing number ofthem desire to paricipate at some level
in regulatory matters in which they have an interest. We realize the general public has an
opportity to comment on this docket and we have encouraged them to do so.
Nonetheless, we agree with the obseration by intervenor Community Action Parerhip
Association ofIdaho in its application for intervenor status on Page 2: "This case has
followed a somewhat unusual procedural path." We also agree with CAP AI's observation
that some paricipants in the settlement discussions opted against executing the
settlement, but in the Allance's case that decision was based not on the result of the
settlement but the process-related concers expressed above. We commend Idaho Power
for its wilingness to initiate the settlement discussions and to seek alteratives to fiing a
general rate case.
Given the sticker shock that has beset customer of Idaho Power and other regulated
utilties in Idaho over the past few years, we agree that a general rate case moratorium,
brief as this one might be as compared to that in IPC-E-95-11, is appropriate. We realize
#
J(
that customers may stil be presented with rate increases though other mechanisms
specifically excluded from this settlement. But we do not anticipate filing of another
energy efficiency tarff rider adjustment within this perod and the next fuel cost
adjustment (FCA) filing wil likely be minor. So the possible impacts of increases outside
the scope of this agreement wil likely not be significant. We would expect that, while the
company was considering filing a 20 percent rate increase in lieu of this settlement, the
passing of two year between possible general rate cases will not result in a crppling rate
increase in 2012.
Regarding the proposed sharng of what wil be a substantial favorable power cost
adjustment in June 2010, the Allance has long supported treating anual PCAs separate
from rate cases for obvious reasons. The melding of the 2010 PCA for puroses of this
rate case moratorium seems reasonable, however, given the expected extraordinar size
of the coming PCA. It seems that customers will receive welcome relief though the
PCA, while at the same time providing helpful base rate recover for Idaho Power.
The proposed acceleration in amortizing accumulated deferred investment tax credits
(ADITC) is likewise acceptable in light of the limits agreed to in the settlement: A
maximum of$15 milion this year and a ceilng of $45 milion from 2009-2011,
providing Idaho Power's retu on equity falls below 9.5 percent, as well as the amount
of accumulated credits curently on Idaho Power's books as represented by Company
Witness John R. Gale's direct testimony at Page 9, lines 7-11. Unlike the 1995 settlement
that contained a similar provision that was not trggered, we expect ths element of the
settlement may come into play in this case.
Ultimately, the Alliance believes the revenue sharng, PCA sharng, and rate case
moratorium components of the settlement in this case sere the company and its
customers as well as possible in our curent economic times.
Finally, the Allance takes no position on Idaho Power's request that this application be
processed by Modified Procedure.
Respectfully submitted,
jL~~
Ken Miler
Clean Energy Program Director
Snake River Allance
Box 1731
Boise, ID 83701
[phone]
kmiler(qsnakerverallance.org