20110815Comments.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
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LOll AUG 15 PH 2: 45
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL )
OF AN AGREEMENT FOR ELECTRIC )
SERVICE BETWEEN IDAHO POWER )
COMPANY AND THE UNITED STATES )DEPARTMENT OF ENERGY )
)
CASE NO. IPC-E-1l-13
COMMENTS OF THE
COMMISSION STAFF
The Staff of the Idaho Public Utilties Commission comments as follows on Idaho Power
Company's July 7, 2011 Application to approve an agreement for electric service between Idaho
Power Company and the United States Deparment of Energy.
BACKGROUND
On July 7, 2011, Idaho Power Company applied to the Commission for an Order
approving a new special services agreement (the "2011 Agreement") between Idaho Power and
the U.S. Deparment of Energy (DOE) for electric service at the Idaho National Engineering
Laboratory. If approved, the 2011 Agreement wil tae effect on September 15,2011.
The Commission approved Idaho Power's curent special services agreement with the
DOE in 2006. The 2006 Agreement had a one-year term, subject to four, one-year renewal
options. Each option was exercised with the Commission's approval. This extended the 2006
Agreement's term through May 2011. As that date approached, however, the paries asked the
Commission to fuher extend the 2006 Agreement's term to allow the parties more time to
STAFF COMMENTS 1 AUGUST 15,2011
negotiate a new special services agreement. The Commission approved the paries' request and
extended the term through September 14, 2011. See Application at 2.
COMPANY PROPOSAL
The proposed Agreement (2011 Agreement) is generally similar to the 2006 Agreement.
There is some additional definition and clarifying language, with the primary substantive
changes being:
. Term: The 2011 Agreement changes the term from a one-year term with
four one-year options, to a single five-year term that (if approved) wil
begin on September 15, 2011, and expire on September 14, 2016. See
2011 Agreement, § 1.1 (Term of Authorization);
. Contract Demand: Idaho Power notes that the initial contract demand
amount is 45 MW, with a maximum contract demand ceilng of 55 MW. l
The DOE may ask Idaho Power for additional demand above 55 MW,
which may be granted at Idaho Power's discretion. The 2011 Agreement
enables the Company to assess a contract demand charge to the DOE in an
effort to allow "for more flexible rate design and for consistency with
other large special contract customers." If assessed, the contract demand
charge wil be contained in Schedule 30. See 2011 Agreement §§ 4 and 6;
Application at 3; and
. Schedule 30: The paries anticipate that Idaho Power's pending general
rate case (IPC-E-ll-08) will result in new rates. Accordingly, while the
2011 Agreement wil not immediately change Idaho Power's Schedule 30
rates, the paries expect the Schedule 30 rates wil be modified after the
Commission issues its .final Order in the rate case. See Application at 3;
2011 Agreement, § 6.1
STAFF RECOMMENDATION
The Staffhas reviewed the Company's Application and believes that approval is in the
public interest. The Staff recommends approval of the Application with an effective date of
September 15,2011.
i The Decision Memorandum and Notice of Application state that "The 2011 Agreement increases the contract
demand ceilng." This statement is incorrect. The 2006 and 2011 Agreements set the initial contract demand level
at 45,000 kw, while enabling DOE to demand up to 55,000 kw upon 12 months written notice. Amounts above
55,000 kw are allowed at the Company's discretion. See 2006 Agreement, § 4.1; 2011 Agreement §§ 4.1, 6.5, and
6.61.
STAFF COMMENTS 2 AUGUST 15,2011
Respectfully submitted this
Technical Staff: Keith Hessing
i:umisc/commentsipcel l.3kkh comments
STAFF COMMENTS
r.- l.I J,- day of August 2011.
:t 11L
Karl T. Klein
Deputy Attorney General
3 AUGUST 15,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF AUGUST 2011,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. IPC-E-II-13, BY E-MAILING AND MAILING A COPY THEREOF,
POSTAGE PREPAID, TO THE FOLLOWING:
JASON B. WILLIAMS
DONOV AN E. WALKER
LEGAL DEPARTMENT
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, IDAHO 83707
E-MAIL: jwiliams(iidahopower.com
dwalker(iidahopower.com
MICHAEL J. YOUNGBLOOD
MANAGER - RATE DESIGN
REGULATORY AFFAIRS DEPARTMENT
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, IDAHO 83707
E-MAIL: myoungblood(ßidahopower.com
Jo~SECRETAR.
CERTIFICATE OF SERVICE