20100826Application.pdf

LISA D. NORDSTROM
Lead Counsel
Inordstromt.lidahopower.com
e¡IDA~POR~
An IDACORP Company
August 26, 2010
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-10-23
IN THE MATTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR AUTHORITY TO MODIFY SPECIAL CONTRACT ELIGIBILITY BY
REDUCING THE UPPER LIMIT OF POWER REQUIREMENTS FOR
LARGE LOAD CUSTOMERS
Dear Ms. Jewell:
Enclosed for filng please find an original and seven (7) copies of Idaho Power
Company's Application in the above matter.
In addition, enclosed are nine (9) copies of Michael J. Youngblood's testimony filed
in support of the Application. One copy of Mr. Youngblood's testimony has been
designated as the "Reporter's Copy." In addition, a disk containing a Word version of Mr.
Youngblood's testimony is enclosed for the Reporter.
Very truly yours,
;fi# Ii n ",Lbo.
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
InordstromCâidahopower.com
dwalkerCâidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
DE..Ç t\J¡-..\./'-"
20m AUG 26 Pl1 4: 03
iI)p~HO
UTiLITIES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO MODIFY SPECIAL
CONTRACT ELIGIBILITY BY REDUCING
THE UPPER LIMIT OF POWER
REQUIREMENTS FOR LARGE LOAD
CUSTOMERS.
)
) CASE NO. IPC-E-10-23
)
) APPLICATION
)
)
)
)
Idaho Power Company ("Idaho Powet' or "Company"), in accordance with Idaho
Code §§ 61-305,61-306, 61-307, 61-622, and 61-623 and RP 52 and 131-134, hereby
respectfully makes Application to the Idaho Public Utilties Commission ("I PUC" or the
"Commission") for an Order authorizing reducing the upper limit for large power service
under Schedule 19, agricultural irrigation service under Schedule 24, and point of
delivery service requirements in Rule C from 25,000 kW to 20,000 kW. The Company
requests that the tariff modifications become effective on or before January 1,2011.
APPLICATION - 1
In support of this Application, Idaho Power represents as follows:
I. PROPOSED SCHEDULE 19 AND SCHEDULE 24 MODIFICATIONS
1. Since Order No. 16688 was issued in Case No. U-1006-159 in 1981, the
Commission has authorized Idaho Power to serve customer loads from 750 kW to
25,000 kW under Schedule 19. Schedule 19, Large Power Service, is currently
available and mandatory for customers who register a metered demand of 1,000 kW or
more per billng period for 3 or more consecutive biling periods during the most recent
twelve consecutive biling periods, up to a maximum demand of 25,000 kW. Schedule
24, Agricultural Irrigation Service, is applicable to agricultural use customers operating
water pumping or water delivery systems used to irrigate agricultural crops or pasturage
for loads up to 25,000 kW. A customer is not eligible for Schedule 19 or Schedule 24
service if its aggregate power requirement at one or more points of delivery on the same
premises exceeds 25,000 kW. Point of Delivery Service requirements in Rule C state
that a special contract is required when an aggregate power requirement exceeds
25,000 kW. In accordance with the schedule provisions and Rule C, these customers
are required to make special contract arrangements with the Company. The Company,
with this Application, proposes to reduce the 25,000 kW eligibilty limit to 20,000 kW for
both schedules and Rule C.
2. Idaho Power has filed this request in response to the continued high
interest from potential large industrial load customers to take service from Idaho Power
and responsible planning and development on the part of Idaho Power, which has a
lack of capacity and other constraints on its system. At a time when the abilty of Idaho
Powets generation and transmission system to serve new load is constrained, the size
APPLICATION - 2
and operating characteristics of potential large loads can be very expensive to serve.
By lowering the size limit, the Company can address service to growing or new load
within a special contract, allowing for specific cost-of-service information as well as the
unique operating characteristics of customers of this size to be considered and captured
within the terms of the agreement. Special contracts can provide some protection to the
Company's customers from unintended system impacts that large loads may impose
because of their size and their time, nature, and pattern of use.
3. In conjunction with this Application, Idaho Power has filed the direct
testimony of Michael J. Youngblood. Mr. Youngblood's testimony provides additional
detail and presents evidence to support the Company's Application. As shown in
Exhibit No. 1 to Mr. Youngblood's accompanying testimony, the Company's proposed
change wil not affect any current Schedule 19 or 24 customers of Idaho Power. This
exhibit shows the maximum monthly kW demand of Idaho Power's ten largest retail
tariff customers (other than current special contract customers) within its Idaho
jurisdiction for the past five years, 2005 through 2009. The highest monthly billng
demand of any customer was just over 16,000 kW.
4. Idaho Power currently has approximately 110 Schedule 19, Large Power
Service, customers in its Idaho service territory. ¡The Company also currently has four
special contract customers: (1) Micron Technology, Inc., (2) the United States
Department of Energy's Idaho National Laboratory, (3) the JR Simplot Company, and
(4) Hoku Materials, Inc. These four customers range in size from 30 to 85 MWs of load.
Currently, the Company has approximately 75 potential new customers system wide
with loads greater than 1 MW and one potentially at 240 MW that have expressed
APPLICATION - 3
interest in obtaining service from Idaho Power. Of the larger ones, a single customer
with a load of about 60 MW appears likely at this time to require service.
5. The most recent special contract, Hoku Materials, Inc., approved by the
Commission on March 16, 2009, by Order No. 30748 in Case No. IPC-E-08-21 was
developed with several regulatory goals for large load service in mind. These goals, as
stated in Company witness Ric Gale's testimony in the aforementioned case, strive to
meet the Company's obligation to serve large load customers in its service territory
while protecting the Company and its many other retail customers from adverse system
impacts that new large loads could impose in an environment when system capacity is
limited and/or constrained. These goals are to: (1) provide requested service
consistent with system capabilty and the reliabilty needs of existing customers; (2)
provide options to the customer when the Company is unable to provide service as
requested; (3) mitigate the rate impact on existing customers by developing a rate
structure that includes a marginal price component for an initial term of the service
agreement; (4) require upfront contributions to capital expenditures associated with
facilties that specifically serve the large load customer; and (5) provide a means to
quantify known and measurable amounts of additional load for Integrated Resource
Planning. The Company's request in this case better enables it to manage the impacts
of potential new large loads on its system in satisfaction of these goals.
6. Attached as Exhibit NO.2 to Company witness Michael J. Youngblood's
testimony is a copy of the relevant tariff pages from Schedule 19, Schedule 24, and
Rule C, containing the Company's proposed changes. In addition, attached as Exhibit
APPLICATION - 4
NO.3 to Company witness Michael J. Youngblood's testimony is a copy of the relevant
tariff pages showing the proposed changes in legislative format.
II. MODIFIED PROCEDURE
7. Idaho Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed
under Modified Procedure, Le., by written submissions rather than by hearing. RP 201
et seq. If, however, the Commission determines that a technical hearing is required, the
Company stands ready to present its testimony and support the Application in such
hearing.
II. COMMUNICATIONS AND SERVICE OF PLEADINGS
8. Communications and service of pleadings with reference to this
Application should be sent to the following:
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
InordstromCâidahopower.com
dwalker(iidahopower.com
Gregory W. Said
Michael J. Youngblood
Darlene Nemnich
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
gsaid(iidahopower.com
myoungblood(iidahopower.com
dnemnich(iidahopower.com
IV. REQUEST FOR RELIEF
9. Idaho Power respectfully requests that the Commission issue an Order:
(1) authorizing that this matter may be processed by Modified Procedure and (2)
approving the Company's proposed modifications to Schedule 19, Schedule 24, and
Rule C as shown in Exhibit No.2, effective on or before January 1, 2011.
APPLICATION - 5
DATED at Boise, Idaho, this 26th day of August 2010.£~Q.~
LISA D. NORDSTR .
Attorney for Idaho Power Company
APPLICATION - 6