20101223Comments.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, ID 83720-0074
Idaho Bar No. 3366
Tele: [phone]
Fax: [phone]
E-mail: don.howell($puc.idaho.gov
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Attorney for Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPROPRIATE )
DISPOSITION OF PROCEEDS FROM THE )
SALE OF IDAHO POWER COMPANY'S S02 )
EMISSION ALLOWANCES IN CALENDAR )
YEAR 2010 )
)
CASE NO. IPC-E-IO-20
COMMENTS OF THE
COMMISSION STAFF
COMES NOW the Staff of the Idaho Public Utilties Commission by and through its
counsel of record, Donald L. Howell, II, and provides the following comments in response to the
Commission's Notice of Modified Procedure in the above referenced proceeding.
Over the course of three reports, Idaho Power declared that it sold 20,000 surlus
sulfu dioxide (S02) emission allowances in Calendar Year 2010. In total, the Company
received net proceeds .of $543,000 (after deducting fees of $5,000). Third Report at 2. The
Company proposed to "share" the S02 proceeds 95% to customers and 5% to shareholders
consistent with prior Commission Orders. The Company also proposed to use Idaho's current
jurisdictional percentage and to use the accounting treatments approved in Commission Order
No. 29852.
STAFF COMMENTS
Staff has audited the three S02 reports submitted by Idaho Power and has verified
that Idaho Power has received net proceeds of $543,000. Consistent with the Commission's last
S02 Order No. 30790 issued May 1,2009, Staff recommends that the Commission allocate all of
the S02 proceeds to offset the Power Cost Adjustment (PCA) balance. Staff believes that
COMMISSION STAFF COMMENTS 1 DECEMBER 23, 2010
applying the S02 proceeds in the PCA mechanism appropriately benefits all Idaho Power
customers.
The net proceeds are jurisdictionally allocated to Idaho at 94.8% for January through
May 2010, and at 95% beginning June 2010. Accumulated interest is also added to the Idaho
S02 net proceeds. The total Idaho jurisdictional amount after the addition of interest is
$490,498.43. It is this amount that Staff recommends be used to offset or reduce the PCA
balance.
Staff also notes that after Idaho Power submitted its first S02 report there were six
public comments fied. These comments recommend that the Commission use a par of the S02
proceeds to continue funding the energy education and effciency programs in public schools.
More specifically, the Idaho Energy Education Project (IEEP) recommends that 8% of the S02
proceeds should be used to fud the Energy Efficiency and Education Program authorized by the
Commission in Order No. 30760. IEEP also suggests that a portion of the S02 proceeds be used
to implement the energy efficiency upgrades identified by students conducting in-school energy
audits.
After reviewing IEEP's comments, Staff asserts that using the proceeds for energy
education programs or to implement measures identified by energy audits would not be
appropriate at this time. In Order No. 30790, the Commission found that "it is not appropriate to
set aside additional S02 proceeds for energy education (programs L until the two-year pilot
project has been evaluated." Order No. 30790 at 3. As the Commission noted in its Notice of
Modified Procedure, the two-year pilot wil not be completed until June 2011. Order No. 32129
at 3. As of October 31,2010, almost $375,000 of the $500,000 funding allocated for the energy
education program is stil available for use. Additional fuding is not justified at this time.
Consequently, Staff believes that the most appropriate disposition of the CY 2010 S02 proceeds
would be to offset the PCA balance in the 2011 PCA case.
STAFF RECOMMENDATION
In summar, Staff recommends that the $490,498.43 in S02 proceeds and
accumulated interest be used to reduce the PCA balance in the 2011 PCA case.
COMMISSION STAFF COMMENTS 2 DECEMBER 23,2010
Respectfully submitted this 2:5 ~ day of December 2010.
Donald L. How , II
Deputy Attorney General
Technical Staff: Rick Sterling
Terri Carlock
bls:N: IPC-E-) 0-20_ dh_ Comments
COMMISSION STAFF COMMENTS 3 DECEMBER 23,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23rd DAY OF DECEMBER 2010,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-1O-20, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
LISA D. NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707.0070
E-MAIL: lnordstrom($idahopower.com
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SECRETARY
CERTIFICATE OF SERVICE