20100409Reply Comments.pdf

f" i:
Benjamin J. Otto
Idaho Conservation League
PO Box 844
710 N 6th Street
Boise,ID 83701
Ph: [phone] x 12
Fax: [phone]
botto(iidahoconservation.org
Idaho Bar no. 8292
l"./ :'t,.~i
OM 4: 30?ÛIJû ~.PR -9 \ n
.. "" ~
Attorney for Idaho Cònservation League
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPAN FOR )
AUTHORITY TO CONVERT SCHEDULE 54-)
FIXED COST ADWSTMNT - FROM A )
PILOT SCHEDULE TO AN ONGOING, )PERMANENT SCHEDULE. )
)
)
CASE NO. IPC-E-09-28
REPLY COMMENT OF THE IDAHO
CONSERVATION LEAGUE
COMES NOW Idaho Conseration League ("ICL"), pursuant to Order No. 31037
extending the Reply deadline to April 9, 2010 filing this Reply to Comment on Idao Power
Company's ("Idaho Power") application to convert the Fixed Cost Adjustment ("FCA") from a
pilot schedule to a permanent rate schedule.
Along with the PUC Staff, thee intervening paries submitted comments concerning this
matter. All commentators identified the FCA mechanism as importt for removing the financial
disincentive to pursue energy effciency measures while also describing various unesolved
problems with the mechanism in it's is curent form. Because these issues speak to the hear of
the FCA mechanism, ICL believes that merely prolonging the pilot progr without providing a
specific foru to address these issues just kicks the ball down the road instead of moving
towards resolution.
I CL also notes that the Staff in their Comments in this docket expressed concern that the
Load Growt Adjustment Rate in the Power Cost Adjustment may allow Idao Power to over
recover forgone fixed costs. Staff Comments at 9. The Commission recently directed the Staff to
hold a workshop for all thee investor owned utilties to address the impact of the LGAR during
period of declining load growt. Order No. 31033 at 12, Case No PAC-E-IO-01 (March 31,
2010). Just as in that case, here Idao Power's FCA pilot program has revealed several ways in
which the mechanism is operating differently than anticipated when originally instituted. To be
sure, ICL recognizes the distinction between Power Cost Adjustments and Fixed Cost
Adjustments. However, the issue identified by the Commission in Order No. 31033 is the same
as the issue in the present docket - properly accounting for forgone fixed costs recovery caused
by decreased volumetric sales. ICL submits the Commission should direct the Staff to hold a
workshop to comprehensively address the issue of fixed costs recovery in times of declining
retail sales. ICL believes this workshop is an important step towards making the FCA a
permanent schedule.
Respectfully submitted this 9th day of April 2010,
ihac
Benjamin J. Oto
I.D. Bar # 8292
AttorneyÆnergy Associate
Idaho Conservation League
Reply Comments ofICL - IPC-E-09-28 - April, 9 2010 2
CERTICATE OF SERVICE
I hereby certify that on this 9th day of Apri, 2010 true and correct copies of the
foregoing REPLY COMMENTS OF IDAHO CONSERVATION LEAGUE were deliveredto the followig persons via the method of seivce noted: ~..,~~-:
\..
Hand delivery
Jean Jewell
Commission Secretar (Origial and seven copies provided)
Idao Public Utilties Commission
427 W. Washigton St.
Boise, ID 83702-5983
..-:ç.'
(f)-
Electronic Mai:
Baron L. Kline
Donova E. Waler
Idao Power Company
1221 West Idao Street
Boise, Idao 83707-0070
BKline(iidaopower.com
dwalker(idaopower.com
Scott D. Sparks
John R Gale
Idao Power Company
P.O. Box 70
Boise, Idao 83707
ssparks(iidahopower.com
rgae~idahopower.com
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID.83702
208-384-1299
bmpurdy(ghotmail.com
Ken Miler
Clean Energy Progr Director
Snake River Allance
PO Box 1731
Boise, ID 83701
kmiller(gsnakeriveralliance.org ~ âÆ
Benjamin J. Otto
Energy Associate for Idao Conservtion League