20090722Petition for Reconsideration, etc.pdf

Michael C. Creamer, ISB #4030
Conley E. Ward, ISB # 1683
GIVENS PURSLEY LLP
601 W. Banock St.
Post Offce Box 2720
Boise, Idaho 83701-2720
Telephone: [phone]
Facsimile: 208-388-1300
I 0495-1161752 IJDO
RECE '""l,;
2069 JUL 22 PH~: 10
IDAHO PUBliC . ¡
UTILITIES COMMISSION
Attorneys for Interenor Building Contractors
Association of Southwester Idaho
BEFORE THE IDAIO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-08-22
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPAN FOR AUTHORITY TO
MODIFY ITS RULE H LINE EXTENSION
TAR RELATED TO NEW SERVICE
ATTACHMENTS AN DISTRIBUTION
LINE INSTALLATIONS
BUILDING CONTRACTORS
ASSOCIATION OF
SOUTHESTERN IDAHO'S
PETITION FOR
RECONSIDERATION AND/OR IN
THE ALTERNATI FOR
CLARFICATION AND PETITION
FOR STAY
Building Contractors Association of Southweste Idaho ("Building Contractors"), by
and though its attorneys of record, Givens Puley LLP, and pursuat to Idaho Code § 61-626
and IDAP A 31.01.01.331, 325 and 324 respecively, petitions the Idaho Public Utilties
Commission ("Commssion") for reconsideration of its Order 30853 ("Order") in the aoove-
captioned matter with respet to those Commission findigs and conclusions regarding terinal
facilities allowances, pe-lot refuds and the tie perod in which vested interest refuds may be
made. The Order approves an inherently discriminatory rate strctue for line extensions by
imposing unequa charges on customer receivig the same level and conditions of serice. Ths
BUIDING CONTRCTORS ASSOCIATION OF SOUTHWSTERN IDAHO'S PETmON FOR
RECONSIDERATION AND/OR IN mE ALTERNATIV FOR CLARICATION AND PETITION FOR
STAY-Pagl
discrination exists both as betwee existng customers and new customer and as among new
customer depending only upon whether they receive serce inside or outside of a subdivision
and the number of new customers to be sered by the requested facilties.
The Order does not acknowledge any grounds for not extending the vested-interest refud
peod from five to ten year other than that Staff opposes it. In its 1997 order concerng Idaho
Power Company's ("Company") line extension ta:t the Commission approved a ten-year
refud for platted, undevelope subdivisions beause it recognzed the unque circumstances
affecting those developments. The curent economic climate also presents unque circustances
which, if they contiue for any extended perod, quite likely will result in a windfall to the
Company and its existig customer and an additional uneimbured line extension cost to
developer. Building Contrctors request a hearng at which pares may cross-examine those
persons who filed testimony and examine member(s) of the Commission Staff with priar
responsibility for preparng Staffs Comments.
If reconsidertion is not granted~ then for judicial ecnomy, Building Contractors request
in the alterative that the Commssion clarfy the Orer to: 1) clearly confirm that the
Commssion now is rejecting its heretofore, longstanding policy that new customers ar entitled
to a Company level of investment equa to that made to sere existig customer in the sae
class; 2) to confirm that the Commission recgnzes and intends the disparty in Company
investment (and customer charges) as between existing and new customer and as among new
customer inside and outside of subdivisions crated by the Order; and 3) to enumerate the
Commssion's reasoning for its momentous change in policy.
Becuse imposition of the Order wil have immediate and significat fiancial impacts on
cerain Building Contractors' membernamely those membe who are, or wil be, requesting
BUIDING CONTRCTORS ASSOCIATION OF SOUTHSTERN IDAHO'S PETmON FOR
RECONSIDERATION AND/OR IN mE ALTERNATIV FOR CLARCATION AND PETmON FOR
STAY-Page 2
line extensions durng the pendency of this matter-Building Contractors also request a stay of
those portons of the Orer affecing the cuent teral facilities allowance, customer refuds
and vested interest refuds.
GROUNS FOR RECONSIDERATION
In its 1997 Order 26780 in Case No. IPC-E-95-18, the Commission considered the sae
Company line extenion taff at issue today. There, the Company sought to "shift more of the
cost of new serce attachments and distrbution line installations or altertions from the system
revenue requirement to new customer requesting the constrction." Order 26780 at 3. The
reason given by the Company for the proposed change was to "keep all customer on a level
playing field (by ensurng) everone pays the average rate base embedded in rates," and because
"the anticipated revenues from the new customer are not suffcient to cover the costs of new
distrbution facilties." Order 26780 at 5 (suarzing Company position). The Commssion
Staff agreed with the Company's position that "the Company's investment in facilities for each
new customer should be equal to the embedded costs of the same facilties used to calculate
rates, and those costs in excess of embedded costs should be borne by the customer requesting
serice. . . ." Order 26780 at 5 (sumarzing Staff position). Building Contractors opposed the
proposed tarff amendments.
The Commission specifically concluded that
new cutomer are entitled to have the Company provide a level of investment equal to
that made to sere existing customers in the same class. Recover of those costs in
excess of embedded costs must also be provided for and the impac on rates of existig
customer is an importt par of our considertion.
BUIDING CONTRCTORS ASSOCIATION OF SOUTSTERN IDAHO'S PETITION FOR
RECONSIDERATION AND/OR IN mE ALTERNATIV FOR CLARICATION AND PETITION FOR
STAY-Page 3
Order 26780 at 13 (emphasis added). The Commission also acknowledged that "requirig the
payment of all costs above embedded investment from new customers could have severe
economic effects." Id.
Today the Company proposes a change to the Rule H tarff allowances and refuds
simply to reduce Company expense and an alleged but undemonstrated upward pressure on rates
without any pretene of maintaining a level playing field or crediting revenues from new
customer. If that wer the purse, all that would be necessar is a relatively simple tre-up of
embedded distrbution costs, curent materals, labor and overhead costs and an allocation as
beteen the terinal facilties and line extensions. See Order 26780 at 13 (whether the
allowance is applied in exact proportons toward the terinal facilities component, the line
extension component, or both, is not crtical, but the amount is).
With little comment and no concession to prior precedent or policy or the disparte effect
the Orer wil have on new customers, the Commission has approved a flat $1,780 ternal
facilties allowance and discontinued pe-lot refuds with subdivisions. Consequently~
although the estimated per customer embedded cost for distrbution ranges between $1,002
(2008IPCo GRC cost of serce study) and $1,232 (Staff estimate), the Company investment in
distrbution for new cutomer wil var from $1,780 for a customer requesting serce to a
single location outside a subdivision to as low as $149 for a customer receiving identical serce
with a sixty-lot subdivision. Ths is because the $1,780 terinal facilties allowance approved
by the Commission, beng the only allowance reognized, must be apprtoned among the new
customer who share those terinal facilities (i.e., the tranformer), and a transformer seres
anywhere from one to ten customer.
BUIDING CONTRCTORS ASSOCIATION OF SOUTSTERN IDAHO'S PETITION FOR
RECONSIDERTION AN/OR IN mE ALTERNATIVE FOR CLAICATION AND PETITION FOR
STAY-Page 4
Staff overlooked ths fact when it stated its supprt for line extension rules that "provide
a new customer allowance that can be support by electrc rates paid by that customer over
time,"l when it deemed the $1 A44 cost of overhead terinal facilties (i.e., tranformer) to be
"fairly close" to the Company's averge investment of$1,232 for existing customer, and then,
for simplicity's sake, recommended that overhead ternal facilties become the surogate for
appropriate Company investment pe new customer. In other words, Staff mistakeny
categorized a $ 1,780 "per transformer" allowance as a "per new customer allowance, which it
clearly is not.
The effect ths mischaracterzation has on the Company investment pe new cutomer (or
converely, on the charge to a new customer to recve serce) is ilustrted in the following
table, which is derved from data provided in Attachment 9 to Staffs Comments.
Comparison of Existing Rule H with Company and Staff Proposals
Subdivision example 1 2 3 4 5
Design Number 61114 67186 60197 24482 27729
No. of Lots 3 10 32 60 101
Average embedded cost
(Staff comments at 5 )$ 1,232.44 $ 1,232.44 $ 1,232.44 $ 1,22.44 $ 1,22.44
Total design cost per lot $3,524 $1,512 $1,576 $1,209 $1,433
Total allowance (Company)1
Eligible for Refud (Staff $3,560 $1,780 $7,120 $8,900 $17,800
Company investment per lot
Staf $1,187 $178 $222 $149 $176
Company $1,187 $178 $222 $149 $176
Existing Ru1e H $1,959 $1,279 $1,159 $1,061 $1,050
i I.e., at least equa to embeded costs, wheter tht be $ i, i 00 or $ i ,232.
BUIDING CONTRCTORS ASSOCIATION OF SOUTHESTERN IDAHO'S PETITION FOR
RECONSIDERTION AND/OR IN mE ALTERNATIV FOR CLARFICATION AND PETITION FOR
STAY-PageS
Developer (Customer) investment per lot
Staff $2,337 $1,334 $1,354 $1,060 $1,257
Company $2,337 $1,334 $1,354 $1,060 $1,257
Existing Rule H $1,565 $233 $417 $148 $383
Total developer investment plus embeded cost per lot
Sta $3~69 52,566 $2,586 $2,292 $2489
Company $3,569 52,566 52,586 $2,92 52,489
Existing Rule H $2,797 $1,465 $1,649 $1,380 $1,615
Over-recovery of cost
Staf $45 $1,055 $1,010 $1,084 $1,056
Company $45 $1,055 $1,010 $1,084 $1,056
Existing Rule H ($727)($46)$73 $172 $182
Soure: Sta Attchment 9, Page 2 of 4; Staff comments at 5.
Company investent per lot is total design cost per lot less developer (customer) investment per lot
As the above table shows, depnding on the subdivision example used, per cutomer Company
investment in multiple-lot subdivisions rages from $149 to $1,187. Only the theelot
subdivision example prouces a pe customer Company invesent approximatig its averge
embeded cost. Consequently, the Order raises the new customer' investment in distrbution to
make up the difference, excet for new customer outside subdivisions who apparently wil
receive a windfall as compared to existig customer and new customer withn subdvisions.2
2 The data in th above table also shows tht th approved new taff reults in the Company collecti frm "new
customer," though their contrbutions to lie extenion costs and rates, almost 200% of its line extenion costs. If
upward pressure on rates exists, it must be attbutble to inreasd generation and trmission costs, which new
customers now will be payig, in par thugh. their li extenion chaes. Ths ru afoul of Idaho State
Homebuilders v. Washington Water Power, 107 Idao 415,690 P.2d 350 (1984) and Boise Water Corp. v. Public
Utilities Comm 'n, 128 Idao 534, 916 P.2d 1259 (1996)
BUIDING CONTRCTORS ASSOCIATION OF SOUTHWSTERN IDAHO'S PETITION FOR
RECONSIDERTION AND/OR IN THE ALTERNATIV FOR CLAICATION AND PETITION FOR
STAY -Page 6
The extent of the increased cost to new customer withn subdivisions depends priarly
on the number of platted lots receiving electrcal serice. What should be of parcular interest to
the Commission is the fact that the shift in costs to the new customers approved by the Orer
actuly ca result in the Company's recovered costs et¡çeeing the actu new distrbution
facilities cost. Ths is ilustrated in the char below which compares total new customer
investment to total facilities costs in a sixty-lot subdivision based on data from the above table.
Copany C" R.. ,. lo(.io)
$2.50
$50
-Tot Cost
- Recver Cost
$2,00
$1.5
$1.00
$-
1995 Rule H Or 3053
That result should not be surrising since, as even Staffhas obsered
. . . Idaho Power has done no analysis to prove that growt is not paying for itself,
nor has the Company done any analysis to deterine speifically what amounts of
allowances and refuds can alleviate upward presure on rates. . . The Company
concludes that a reduction in Company investment in new distrbution plant is
necessar and proposes a reduction in allowances based strctly on policy without
supporting analysis.
BUIDING CONTRACTORS ASSOCIATION OF SOUTHWESTERN IDAHO'S PETITION FOR
RECONSIDERATION AND/OR IN THE ALTERNATIV FOR CLARICATION AN PETITION FOR
STAY-Page 7
Staf Comments at 3. In other words, the Company's proposed allowance is a shot in the dark
that is as likely to miss a "grwt pays for itself' target as hit it.
The Commssion perhaps did not apprehend the distiction between "per trformer"
investment and "per new customer investment" when it found in the Order that
. . . the overall distrbution allowance provided to developer, whether in the form
of a subsequent refud or an upfront reducton in developer contrbution (i.e.,
allowances), is properly based on the amount of distrbution investment that can
be supported by new customer rates. The Company has reasnably calcuate
that amount in its upfront, per lot distrbution allowance. Any additional
distrbution cost refud to the developer would exceed the distrbution investment
that new customer rates could support. Therfore, the Commssion finds it fai,
just and reaonable to accept the Company's pe lot distrbution allowance and
elimate lot refuds.
Order at 12. The Company's and Staffs $1,780 terinal faciliies allowance patently is not a
per lot distrbution allowance.
If the Company's investment of $1,780 in distrbution facilties to sere a single new
customer outside a subdivision can be recovered through rates charged to that new customer
(which for puroses of this Petition, Building Contrctors concee), then on what fact or legal
basis can new customer within subdivisions be charged as much as $1,631 more for eleccal
serice than existig customer and the single new customer outside a subdivision?
'.
From a factul stadpoint, the Commission has acknowledged Staffs "concer that Idaho
Power had not provided any analysis to deterine specfically what amounts of allowances and
refuds would alleviate upward pressure on rates," and that "to properly establish an allowance,
a refud and the potential for additional customer contrbution, a detailed analysis of distrbution
investment embeded in existing electrc rates must be conducted." Order at 4. Despite Staffs
concer~ and the lack of any subsequent analysis by the Company, the Order, nevereless, finds
that "(tJhe Company has reasonably calculated (the amount of distrbution investment that can be
BUIDING CONTRCTORS ASSOCIATION OF SOUTHWSTERN IDAHO'S PETmON FOR
RECONSIDERATION AND/OR IN mE ALTERNATIV FOR CLARICATION AND PETITION FOR
STAY -PageS
supported by new customer rates) in its upfront, per lot distrbution allowance." Order at 12
(emphasis added). The lack of substatial evidence to suprt ths finding, and the fact that the
Company is not proposing a "per lot distrbution allowance" render the Commission's decision
in ths regard arbitrar and capricious. See Oregon Short Line R.R. v. Idaho Public Utiites
Comm 'n, 47 Idaho 482, 276 P. 970 (1920) (order based on fiding made without evidence, or
upon a finding made upon evidence which clearly does not support it, is an arbitrar act against
which the cours afford relief).
A legal basis for the disparty in pe new customer Company investment (and converly,
per new customer line-extension charges) is equally lacking. Idaho State Homebuilders v.
Washington Water Power, 107 Idaho 415,690 P.2d 350 (1984) and Boise Water Corp. v. Public
Utilties Comm 'n, 128 Idaho 534, 916 P.2d 1259 (1996) hold that any differences in rates and
charges must be justified by a corresponding classification of customer that is based on factors
such as cost of serce, quatity of electrcity used, differences in conditions of serce or the
tie, natue or patter of use. Neither the Company's nor Staffs comments nor the
Commission's Order touch on these factors.
The curent disparty in pe cutomer Company investment and converely per new
customer line extenion charges will not pass ths test. Parcularly not when the Commission
acknowledges that new customer are entitled to a level of Company investment in distrbution
that can be supported by rates (i.e., the same level of investment as received by existing
cutomer), and paricularly not when the resultig varable level of Company investment is
driven solely by whether the new customer is situted inside or outside a subdivision or withn a
relatively larger or smaller subdivision.
BUIDING CONTRCTORS ASSOIATION OF SOUTSTERN IDAHO'S PETION FOR
RECONSIDERATION AND/OR IN THE ALTERNATIV FOR CLAICATION AN PETmON FOR
STAY-Page 9
Grted, not all "discrimination" in rates and chages is improper, but where the
Commission establishes the kind of discrmination present here, it must demonstrate that the
differences in rates and charges are based on one or more of the factors enumerated in
Homebuilders. Its decision also must be based on substantial, competent evidence and the
Commssion must explain the reasning it employed. Boise Water Corp., 128 Idaho at 537
(citing Washington Water Power v. Idaho Public Utiities Comm 'n, 101 Idaho 567, 617 P.2d
1242 (1980). None of the enumerated factors have be acknowledged by the Order, let alone
used to rationalize the new disparate line extension charges and allowances, or to explain why
the highy varable Company investent/new customer charge is consistent with the principle
that new customers are entitled to a level of distrbution investment that can. be supprted by
rates. Almost by definition, the Order in ths regard is arbitr and capricious, exceeds the
Commssion's authority, and violates the new customer's right to non-discrminatory rates and
charges under Homebuilders and Boise Water Corp.
For the foregoing reasons, Building Contrctors repectfully request the Comission's
reconsideration of Order 30853, and that the Commission provide for an evidentiar hearing at
which the pares' witnesses may be examed and/or crss-examined on thei pre-filed
testimony and all matters within the scope of sae, the purose of which would be to establish
an approprate value of cuent Company embeded costs for distrbution facilties, a metod to
tre up those costs over time, and a fair method for line extension costs, allowances and refuds
to be paid going forward.
GROUNS FOR REQUEST FOR CLARFICATION
Commission Rule 325 allows a petition for clarfication to be combined with a pettion
for recnsidertion or to be stated in the alterative. Building Contrctors seek clarfication in
BUIDING CONTRCTORS ASSOCIATION OF SOUTSTERN IDAHO'S PETmON FOR
RECONSIDERATION AND/OR IN mE ALTERNATIV FOR CLARICATION AND PETITION FOR
STAY - Page 10
the alterative. If reconsideration is not granted beause the Commission stands by the decision
and reulting disparate charges for new customers, Buildig Contractors request that the
Commission clarfy for the record that the Commssion now is rejecting its heretofore
longstanding policy that new cutomer are entitled to a Company investment in distrbution
facilties equal to that made to sere existing customer in the same class, and that the
Commission recognzes and intends the disparty in Company investment (and customer
charges) as beteen exsting and new customer and as among new customer inside and outside
subdivisions created by the Order. Building Contrctors also believe the Commssion should
enumerate its justification for the depar from existing policy and for the discrinatory effect
on Company customer. Building Contrctors believe ths clarfication is necssary to clearly
defie the basis for, and scope of, the new policy. This will be important to Building Contractors
and its members not only in the context of ths proceeding but also future Company applications
to amend its Rule H tarff.
GROUNS FOR PETITION FOR STAY
Building Contrctors have submitted evidence by way of Exhibit 203, sponsore by Dr.
Slaughter and prepared by NAH based on research conducted in the Boise-Nampa
Metropolita Statistical Area. Exhbit 203 and Dr. Slaughter's testimony docuented the
advere economic effects of increased housing costs on the numbe of households that can afford
to purchase a home and, by implication, the advere effects on new customer and Building
Contrctors' member of reducing the Company's investment in distrbution facilities below
embedded costs. For the sixty-lot subdivision example in the above table, assuing a Company
embeded cost of $ i ,002, ths imposes an approximately $5 i,oo additional cost to the
developer. For the one hundred lot example, the additional cost is nealy $83,000. Ths in a
BUIDING CONTRCTORS ASSOCIATION OF SOUTHWSTERN IDAHO'S PETITION FOR
RECONSIDERATION AN/OR IN THE ALTERNATIV FOR CLAICATION AND PETmON FOR
STAY -Page 11
maret where development capital is scarce and expensive, and the alleged impact of customer
growt on rates has dropped signficantly.
Building Contractors submit that the advere impact on its membe and the public of
imposing the line extension tarff on ters approved by the Order far outweigh any prejudice to
the Company and its existig customers that would occur if the Commission's Order were stayed
peding a fial decision on this Petition. Requests for line extensions likely are being or wil be
submitted to the Company in the next few months and would be subject to the lower Company
contrbution and higher developer contrbution. Building Contrctors therefore respectfuly
request the Commssion grant a stay of the effective date of those portions of the Company's
Rule H taff relating to the calculation and payment of allowances and refuds, includig vested
interest refuds, pending a final decsion on the merts.
CONCLUSION
Idaho Power Company's requested line extension tarff amendments and Order 30853
appoving them are far more than an adjustment of rates and charges to address one factor
puttng upward pressue on utility rates. The taff amendments, as approved, constitute a
marked change in Commission policy by which new customers heretofore have been "entitled to
have the Company provide a level of investent equa to that made to sere existing cutomer
in the same class."
Under Order 30853 new customer are entitled only to a Company investment equal to
whatever the quotient is when the revised terinal facilities allowance is divided by the number
of new customers sered. In other words, under Order 30853 Company investment (and new
customer charges) now bear no relationship to embedded costs, increaed facilties costs,
inflation, or alleged upward pressure of growt on rates attbutable to distrbution facilties
BUIDING CONTRCTORS ASSOCIATION OF SOUTSTERN IDAHO'S PETION FOR
RECONSIDERATION AND/OR IN THE AL TERNATIVFOR CLARICATION AND PETITION FOR
STAY -Page 12
serg new customers. Nor do the resulting varable rates and charges new customer pay as
betee themselves and existing or other new customer have any relationship to factors such as
actal cost of servce, quantity of electrcity used, or differences in conditions of serce or the
tie, natue or patter of use. The resut is an unawful, aritrar and discrminatory charge that
is not based on any rational customer classification. The Order should be reconsidered.
If reconsideration is dened, Building Contractors is at least entitled to clarfication of the
basis for, and scope of, the Commission's decision-neither of which are curently included in
the Order and par of the admistrative record.
In the meantime, to avoid the likely advere economic impacts of the appoved tarff
provisions on those Building Contractors members who may be requesting line extensions, the
tarff provisions dealing with allowances and refunds should be stayed pending a final
Commssion order.
Restfuly submitted ths 2200 day of July, 2009.
GIVENS PURSLEY LLP
B~d&;;
Michael C. Creaer
Attorneys for Intervenor Building Contractors
Association of Southwestern Idaho
BUIDING CONTRCTORS ASOCIATION OF SOUTHWESTERN IDAHO'S PETIION FOR
RECONSIDERATION AND/OR IN THE ALTERNATIV FOR CLARICATION AN PETITION FOR
STAY -Page 13
CERTIFICATE OF SERVICE
I hereby cerify that on the 2200 day of July, 2009, a tre and correct copy of the
foregoing was sered upon the following individual(s) by the means indicated:
Origial and Seven Copies Filed:
Jean D. Jewell, Secretar
Idaho Public Utilities Commssion
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Servce Copies:
Lisa D. Nordstrom
Baron L. Kline
Idaho Power Company
POBox 70
Boise, il 83707-0070
Inordstromcgidahopower.com
bklinecgidahopower.com
Scott Sparks
Gregory W. Said
Idaho Power Company
POBox 70
Boise,ID 83707-0070
ssparkscgidahopower.com
gsaidcgidahopower.com
Krstine A. Sasser
Deputy Attorney General
Idaho Public Utilities Commssion
472 W. Washigton
PO Box 83720
Boise, ID 83720-0074
krs.sasserCfuc.idaho.gov
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BUIDING CONTRCTORS ASSOCIATION OF SOUTSTERN IDAHO'S PETITION FOR
RECONSIDERATION AND/OR IN mE ALTERNATIV FOR CLARICATION AND PETITION FOR
STAY - Page 14
Mattew A. Johnson
Davis F . VanderVelde
White, Peterson, Gigray, Rossman, Nye &
Nichols, P .A.
5700 E. Franlin Rd., Ste. 200
Nampa, ID 83687
mjohnson(fwhitepeteron.com
dvanderelde(fwhitepeteron.com
Attorneys for The City of Nampa and The
Association of Canyon County Highway
Districts
Michael Kurt
Kur J. Boehm
Boehm, Kurz & Lowry
36 E. Seventh St., Ste. 1510
Cincinnati, OH 45202
mk(!KLlawfi.com
Kboehm(fBKLlawfirm.com
Attorneys for The Kroeger Co.
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 S. State St., Ste. 200
Salt Lake City, UT 84111
khiggins(fenergystrat.com
Representing The Kroeger Co.
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BUILDING CONTRCTORS ASSOCIATION OF SOUTHWSTERN IDAHO'S PETITION FOR
RECONSIDERATION AND/OR IN THE ALTERNATIV FOR CLARICATION AN PETITION FOR
STAY - Page 15