20080724Comments.pdf

Peter J. Richardson ISB 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
PO Box 7218
Boise, Idaho 83700
Telephone: [phone]
Fax: [phone]
peter~richrdsonandolear .com
Attorneys for the Industrial Customers of Idaho Power
3= 4 ¡
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR AN ) CASE NO. IPC-E-08-13
ACCOUNTING ORDER AUTHORIZING THE)
INCLUSION OF POWER SUPPLY EXPENSES)
ASSOCIATED WITH THE PURCHASE OF ) COMMENTS OF THE INDUSTRIAL
CAPACITY AND ENERGY FROM PPL ) CUSTOMERS OF IDAHO POWER
ENERGYPLUS, LLC, IN THE POWER COST )ADJUSTMENT )
)
COMES NOW, the Industrial Customers of Idaho Power") by and through its attorney
of record, Peter J. Richardson, and pursuant to Notice of Application and Notice of
Comment/Protest Deadline and hereby provides its comments on Idaho Power Company's
(Idaho Power) Application.
I
SUMMARY
The ICIP files its Comments to bring to the Commission's attention a discrepancy in the
natural gas price forecast used by Idaho Power Company in justifying the price it agreed to pay
PPL EnergyPlus (PPL) and the natual gas price forecast it uses to set the avoided cost rates it
pays to QFs under this Commission's avoided cost setting methodology.
Comments ofthe Industrial Customers ofIdaho Power IPC-E-08-13
1
COMMENTS
The attched Exhibit A was prepared by the ICIP's consultant, Dr. Don Reading. It incorporates
the gas forecast Idaho Power uses in this docket to justify the price it agreed to pay PPL into the
Commission's avoided cost modeL. No other changes were made to the avoided cost
methodology or inputs. As can be seen, the impact of using Idaho Power's forecast for justifying
the cost of the PPL purchase for just the two years of that agreement is quite dramatic.
The ICIP is concerned that the use of inconsistent natual gas price forecasts leads to
irrational resource choices. For example, additional higher cost company-acquired resources
may not be necessar if QFs were paid the higher price used by Idaho Power to justify the PPL
contract. In addition use of consistent natural gas forecasts makes more DSM measures cost
effective and may lower the demand for power. In addition the 2007 IRP has stale gas prices as
welL.
Whle the ICIP does not oppose the Company's application, it respectfully requests that,
if the Commission approves rate recovery for the costs associated with the PPL agreement that it
apply the natural gas forecast used to justify that approval for all of the Company's other
processes that make use of a natural gas forecast. This would include, among other things,
setting avoided cost rates and calculating cost effective DSM measures.
Comments of the Industrial Customers of Idaho Power IPC-E-08-13
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Respectfully submitted this 24th day of July 2008
BytZMA
Peter Richardson ISB 3195
RICHARDSON & O'LEARY PLLC
Attorneys for the Industrial Customers of Idaho Power
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 24th day of July, 2008, a tre and correct copy of the
within and foregoing COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER, was served by personal service to:
Baron Kline
Donovan E. Walker
Idaho Power Company
1221 WestIdaho Street
Boise, Idaho
JohnR. Gale
Courney Waites
Idaho Power Company
1221 West Idaho Street
Boise, Idaho
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 West Washington
Boise, Idaho
~lJPeter Richardson
Comments ofthe Industrial Customers ofIdaho Power IPC-E-08-13
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