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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO CONVERT SCHEDULE
54 - FIXED COST ADJUSTMENT - FROM
A PILOT SCHEDULE TO AN ONGOING,
PERMANENT SCHEDULE.
CASE NO. IPC-E-11-19
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
MICHAEL J. YOUNGBLOOD
1 Q.Please state your name and business address.
2 A.My name is Michael J. Youngblood. My business
3 address is 1221 West Idaho Street, Boise, Idaho.
4 Q.By whom are you employed and in what capacity?
5 A.I am employed by Idaho Power Company ("Idaho
6 Power" or "Company") as the Manager of Rate Design in the
7 Regulatory Affairs Department.
8 Q.Please describe your educational background.
9 A.In May of 1977, I received a Bachelor of
10 Science Degree in Mathematics and Computer Science from the
11 University of Idaho. From 1994 through 1996, I was a
12 graduate student in the Executive MBA program of Colorado
13 State Uni versi ty. Over the years, I have attended numerous
14 industry conferences and training sessions, including
15 Ed~son Electric Institute's "Electric Rates Advanced
16 Course. "
17 Q.Please describe your work experience with
18 Idaho Power.
19 A.I began my employment with Idaho Power in
20 1977. During my career, I have worked in several
21 departments and subsidiaries of the Company, including
22 Systems Development, Demand Planning, Strategic Planning,
23 and IDACORP Solutions. Most relevant to this testimony
24 though is my experience within the Regulatory Affairs
25 Department. i From 1981 to 1988, I worked as a Rate Analyst
YOUNGBLOOD, DI 1
Idaho Power Company
1 in the Rates and Planning Department where I was
2 responsible for the preparation of electric rate design
3 studies and bill frequency analyses. I was also
4 responsible for the validation and analysis of the load
5 research data used for cost-of-service allocations.
6 From 1988 through 1991, I worked in Demand Planning
7 and was responsible for the load research and load
8 forecasting functions of the Company, including sample
9 design, implementation, data retrieval, analysis, and
10 reporting.I was responsible for the preparation of the
11 five-year and twenty-year load forecasts used in revenue
12 proj ections and resource plans as well as the presentation
13 of these forecasts to the public and regulatory
14 commissions.
15 In 2001, I returned to the Regulatory Affairs
16 Department and have worked on special proj ects related to
17 deregulation, the Company's Integrated Resource Plan, and
18 filings with both the Idaho Public Utilities Commission
19 ("IPUC" or "Commission") and the Oregon Public Utility
2 0 Commission ("OPUC").
21 In 2008, I was promoted to my current position of
22 Manager of Rate Design for Idaho Power. It is in this
23 position that I am currently responsible for the management
24 of the rate design strategies of the Company, as well as
25 the oversight of all tariff administration.
YOUNGBLOOD, DI 2
Idaho Power Company
1 Q.What is the purpose of your testimony in this
2 matter?
3 A.In my testimony, I will discuss the Company's
4 proposal to remove the temporary "pilot" status of Schedule
5 54, Fixed Cost Adjustment ("FCA") and convert the FCA to an
6 ongoing, permanent tariff schedule. I will also discuss
7 the derivation of the Fixed Cost per Customer (" FCC") and
8 Fixed Cost per Energy (" FCE") rates which would result from
9 the functionalized and classified revenue requirement data
10 prepared as part of the Settlement Stipulation in IPUC Case
11 No. IPC-E-11-08, the Company's most recently filed general
12 rate case. If the Settlement Stipulation is approved and
13 the general base rates are adopted as filed, these would be
14 the FCC and FCE rates the Company would propose to be used
15 in determining the annual adj ustment under Schedule 54,
16 Fixed Cost Adjustment.
17 Q.Are there any others that will be providing
18 testimony in this matter?
19 A.Yes. Ralph Cavanagh, Energy Program Director
20 for the Natural Resources Defense Council, is also
21 providing testimony in support of converting the FCA to a
22 permanent tariff schedule. Mr. Cavanagh is a nationally
23 recognized advocate of energy efficiency, has been directly
24 involved with the initial development of the FCA as a
25
YOUNGBLOOD, DI 3
Idaho Power Company
1 pilot, and has remained supportive of the true-up mechanism
2 throughout its pilot status for the last five years.
3 Q.Please describe the Fixed Cost Adj ustment
4 mechanism.
5 A.The FCA is a rate mechanism designed to remove
6 the financial disincentive to utili ty acquisition of
7 demand-side management ("DSM") resources. The mechanism
8 accomplishes this goal by severing the link between energy
9 sales and the recovery of fixed costs. Currently, the FCA
10 applies only to Residential Service (Schedules 1, 3, 4, and
11 5) and Small General Service (Schedule 7). The annual FCA
12 amount is determined according to the following formula:
13 FCA = (CUST X FCC) - (NORM X FCE)
14 Where:
15 FCA = Fixed Cost Adjustment;
16 CUST = Actual number of customers, by class;
17 FCC = Fixed Cost per Customer, by class;
18 NORM = Weather-normalized energy, by class;
19 FCE = Fixed Cost per Energy, by class.
20 Q.What values are required to calculate the FCA
21 amount annually?
22 A.As outlined in the above formula, for each
23 class (Residential Service and Small General Service), the
24 actual number of customers, the fixed cost per customer,
25 weather-normalized energy, and the Fixed Cost per Energy
YOUNGBLOOD, DI 4
Idaho Power Company
1 are required to determine the FCA amount. Two of these
2 variables (CUST and NORM) are determined at the end of each
3 year based upon the Company's actual billing records. The
4 other two variables (FCC and FCE) are updated each time the
5 Company files a general rate case and are based on the
6 results of the class cost-of-service study.
7 Q.Why is the Company now proposing to make
8 Schedule 54, Fixed Cost Adjustment, an ongoing, permanent
9 tariff schedule?
10 A.As established in Order No. 30267 issued in
11 Case No. IPC-E-04-15, the FCA mechanism was originally
12 approved as a three-year pilot program running January 1,
13 2007, through December 31, 2009. In Order No. 31063, Case
14 No. IPC-E-09-28, the Commission extended the pilot for an
15 additional two years, beginning January 1, 2010. The FCA
16 pilot is currently scheduled to terminate December 31,
17 2011. The Company filed as part of its most recent general
18 rate case, Case No. IPC-E-11-08, its proposal to remove the
19 pilot status of the current FCA and establish an ongoing,
20 permanent tariff schedule. As part of the Settlement
21 Stipulation that was submitted in the general rate case on
22 September 23, 2011, Idaho Power moved the Commission to
23 remove the FCA issues from the rate case and initiate a
24 separate proceeding to consider the permanency of the FCA.
25 Order No. 32380 granted that motion and directed the
YOUNGBLOOD, DI 5
Idaho Power Company
1 Company to initiate anew, separate proceeding for the FCA
2 issues as soon as possible.
3 Q.What is the purpose of the FCA pilot?
4 A.The purpose of the FCA pilot is to test a
5 fixed cost adj ustment mechanism designed "to true-up the
6 collection of fixed costs per customer to recover the
7 difference between the fixed costs actually recovered
8 through rates and the fixed costs authorized for recovery
9 in the Company's most recent rate case." Case No. IPC-E-
10 04-15, Order No. 30267. Results from the first three years
11 of the pilot, and now the last year and a half of the
12 extended pilot, indicate that the true-up mechanism is
13 working as intended and operating to mitigate adverse
14 financial effects to the Company from DSM by ensuring that
15 the fixed costs authorized for recovery are being trued-up
16 via the FCA mechanism. The mechanism has proven to be fair
17 to both the customer and the Company, providing both a
18 refund and a surcharge throughout the pilot years. The
19 mechanism has also been proven to be reasonable as the
20 individual customer bill impacts, both up and down, have
21 been relatively small.
22 Q.Have customers benefited from the FCA pilot
23 during its implementation?
24 A.Yes. The FCA's true-up mechanism benefits
25 customers three ways. First, cost-effective energy
YOUNGBLOOD, DI 6
Idaho Power Company
1 efficiency and DSM programs can lower customer costs.
2 Customers benefit from the FCA true-up mechanism because
3 the Company is not financially harmed by decreases in
4 energy sales wi thin the residential and small general
5 service customer classes, nor is it financially benefited
6 from increases in energy sales. Thus, the FCA removes a
7 disincenti ve that would otherwise discourage the Company
8 from pursuing additional DSM programs and expenditures.
9 The implementation of the FCA pilot has facilitated
10 significant increases in the Company's promotion and
11 expenditures to pursue energy efficiency and DSM programs,
12 which have resulted in significant energy efficiency
13 savings. Exhibit No. 1 depicts how the Company has
14 increased the number of DSM programs and substantially
15 increased its level of expenditures for energy efficiency
16 and demand response programs since the inception of the FCA
17 pilot on January 1, 2007.
18 Q.What are the other ways customers have
19 benefited from the FCA pilot during its implementation?
20 A.The second way the FCA pilot has benefited
21 customers during its implementation is in the way the FCA
22 true-up mechanism stabilizes customer bills when loads are
23 increasing because the fixed cost component being recovered
24 through the energy rate is less than the total energy rate.
25 As a result, when average use per customer increases during
YOUNGBLOOD, DI 7
Idaho Power Company
1 a year, the resulting FCA provides a refund to customers
2 for fixed costs recovered by the Company which were above
3 the authorized level of recovery. Because of the
4 reciprocal nature of the FCA, the Company is not allowed to
5 keep the additional revenue as it did before the FCA was
6 implemented. Customers' bills are less with the FCA than
7 they would be without the mechanism.
8 Third, customers benefit from the FCA when loads are
9 decreasing because it gives the Company a better
10 opportunity to recover more of the fixed costs it incurs to
11 provide electric service to customers.
12 Q.Does anyone other than Idaho Power acknowledge
13 the benefits of the FCA?
14 A.Yes. In the Company's earlier filing to make
15 the FCA a permanent tariff schedule (Case No. IPC-E-09-28),
16 all the parties who commented, with the exception of the
17 American Association of Retired Persons ("AARP"), indicated
18 that they supported the FCA and recognized the positive
19 benefits customers obtained by implementation of the FCA.
20 In addition to the Staff and Intervenors in that case,
21 other entities in the state of Idaho also acknowledged the
22 benefits flowing from the FCA.
23 Q.What other entities acknowledged the benefits
24 flowing from the FCA?
25
YOUNGBLOOD, DI 8
Idaho Power Company
1 A.Governor Otter, in his March 19, 2009, letter
2 to the United States Secretary of Energy, written in
3 support of Idaho's effort to obtain stimulus funds, cited
4 the fact that he "has requested that the Commission
5 continue their successful decoupling efforts .." as
6 evidence that Idaho deserved a share of the $3.1 billion in
7 federal funding for the state energy program.
8 Another instance where the FCA was cited posi ti vely
9 was in the Commission and the Idaho Office of Energy
10 Resource's ("OER's") December 11, 2009, Joint Report to the
11 Legislature regarding the successful implementation of the
12 2007 Idaho En~rgy Plan ("Joint Report"). In the Joint
13 Report, the OER and the Commission specifically identified
14 the fact that the Commission had adopted one of the
15 nation's first electric decoupling mechanisms designed to
16 remove financial disincentives for Idaho Power to implement
17 energy cost efficiency programs. In its Report, the OER
18 and the Commission describe the FCA as a posi ti ve step to
19 encourage Idaho Power to aggressively and cost-effectively
20 pursue energy efficiency and DSM programs.
21 Q.Are there more examples where the benefits
22 flowing from the FCA have been acknowledged?
23 A.Yes. In Case No. GNR-E-08-04, the Commission
24 fulfilled its obligation under the Energy Independence and
25 Security Act of 2007 (16 USC § 2621 (17) (B) (i) )by
YOUNGBLOOD, DI 9
Idaho Power Company
1 considering policies that "remove the throughput incentive
2 and regulatory and management disincentives to energy
3 efficiency. " In that case, the Commission found that "it
4 has or is presently considering energy efficiency programs
5 such as fixed cost adj ustments, tiered rates, time of use
6 rates, seasonal rates, and decoupling" such that it has
7 "already adopted comparable standards for rate design
8 modifications to promote energy efficiency investments by
9 utilities. "(Order No. 30966, p. 6.)
10 Finally, the FCA is recognized by the financial
11 community as a posi ti ve indication of proactive regulation.
12 Various utility equity analysts have identified the FCA as
13 a posi ti ve attribute in assessing whether to recommend
14 buying IDACORP, Inc. stock. RBC Capital Markets, Wells
15 Fargo Bank, and Key Banc are equity research firms which
16 have identified the fact that Idaho Power has a decoupling
17 mechanism in place in the state of Idaho as an indication
18 of a posi ti ve regulatory environment in Idaho.
19 Q. You have stated that the FCA has performed as
20 intended. Please explain your statement further.
21 A. During the workshops that led up to the
22 submittal of the Stipulation in Case No. IPC-E-04-15 which
23 created the FCA, the workshop participants developed a list
24 of criteria that any regulatory mechanism for decoupling
25
YOUNGBLOOD, DI 10
Idaho Power Company
1 utility energy sales from fixed cost recovery should meet.
2 The criteria developed by the participants are as follows:
3 a.Stakeholders are better off than they
4 would be without the mechanism.(Stakeholders include both
5 customers and shareholders.)
6 b.Cross-subsidies are minimized across
7 customer classes.
8 c.Financial disincentives are removed.
9 d.The acquisition of all cost-effective
10 DSM is optimized.
11 e.Rate stability is promoted.
12 f.The mechanism is simple.
13 g.Administrative costs and the impacts of
14 the mechanism are known, manageable, and not subject to
15 unexpected fluctuation.
16 h.Short-term and long-term effects to
17 customers and the Company are monitored.
18 i.Perverse incentives are avoided.
19 j .A close link between the mechanism and
20 desired DSM outcomes is established.
21 Q.Does the Company believe that the FCA has met
22 the criteria originally established?
23 A.Yes.The FCA provides a symetrical
24 (surcharge/credit) true-up mechanism for when the fixed
25 cost recovery per customer varies above or below a
YOUNGBLOOD, DIll
Idaho Power Company
1 Commission-established base. Since the FCA was first
2 implemented, customer rates have both increased and
3 decreased as a result of the FCA. As a result, the Company
4 has become indifferent to reduced energy consumption and
5 demand from the participating customer classes. Idaho
6 Power's recovery of fixed costs is more stable as are its
7 customers' bills.
8 Q.Has implementation of the pilot FCA affected
9 the Company's efforts toward promoting energy efficiency
10 and DSM acti vi ties?
11 A.Since the inception of the pilot FCA, the
12 Company has actively pursued new opportunities to promote
13 energy efficiency and DSM. By removing the financial
14 disincenti ve to invest in DSM programs, the FCA has
15 provided the Company an opportunity to enhance and expand
16 its portfolio of cost-effective demand-side resources.
17 Q.Please summarize the Company's DSM investments
18 and energy savings since inception of the FCA pilot.
19 A.In total, the Company increased its level of
20 investment toward energy efficiency and demand response
21 programs annually since the inception of the FCA pilot on
22 January 1, 2007. Exhibit No. 1 demonstrates the Company's
23 enhanced DSM investment and energy impacts from 2006 to
24 2010. A complete description of all energy efficiency
25
YOUNGBLOOD, DI 12
Idaho Power Company
1 acti vi ties can be found in the Company's Demand-Side
2 Management Annual Reports, which are filed annually with
3 the Commission.
4 Q.What types of programs has the Company
5 utilized to promote energy and demand savings by customers?
6 A.Idaho Power has utilized four types of
7 programs to promote energy and demand savings:(1) Demand
8 Response, (2) Energy Efficiency, (3) Market Transformation,
9 and (4) Other Programs and Acti vi ties.
10 Q.How has the Company enhanced its efforts in
11 Demand Response and Energy Efficiency programs?
12 A.The Company has enhanced its efforts to
13 acquire Demand Response and Energy Efficiency by continuing
14 to support existing and proven programs and by aggressively
15 pursuing new cost-effective DSM programs. For instance,
16 from 2006 to 2010, the estimated reduction in demand
17 related to the Company's Demand Response programs increased
18 from 38.1 megawatts ("MW") to 336.2 MW. Energy savings
19 resulting from the Company's Energy Efficiency programs
20 increased from 67,026 megawatt-hours ("MWhs") in 2006 to
2 1 1 8 7 , 6 2 6 MWh in 2 0 1 0 .
22 Q.Has the Company enhanced its efforts in Market
23 Transformation and Other Programs and Activities?
24 A.Yes. The Company continues to financially
25 support Market Transformation through membership and
YOUNGBLOOD, DI 13
Idaho Power Company
1 coordinated acti vi ties with the Northwest Energy Efficiency
2 Alliance ("NEEA"). The Company's membership and
3 participation with NEEA has enhanced the Company's ability
4 to pursue appliance code standards and increased energy
5 efficiency requirements in Idaho building codes.
6 The Company has enhanced its involvement in Other
7 Programs and Acti vi ties through research, development,
8 education, and program marketing. More specifically, the
9 Company has increased the broad availability of efficiency
10 and load management programs, increased customer awareness
11 through the Residential Energy Efficiency Education
12 Initiative, and contracted with third-party consultants to
13 verify program specifications and energy savings. In
14 addition, Idaho Power has updated Company facilities with
15 energy efficient equipment and building products to
16 internally promote and encourage energy efficiency.
17 Q.What other ini tiati ves has the Company pursued
18 to encourage energy efficiency since inception of the pilot
19 FCA?
20 A.In the Company's 2008 general rate case, Case
21 No. IPC-E-08-10, several new price-based rate designs were
22 approved in support of the Company's obj ecti ve of
23 encouraging the wise and efficient use of electricity.
24 Year-round tiered block rates, expanded time-of-use
25 pricing, and the introduction of load-factor pricing were
YOUNGBLOOD, DI 14
Idaho Power Company
1 all efforts toward encouraging the efficient use of
2 electricity.
3 Q.Does the FCA only recover the fixed costs
4 directly associated with DSM programs?
5 A.No. While the intent of the FCA is to remove
6 the financial disincentive for the utility to invest in DSM
7 acti vi ties, there are other factors which may affect the
8 Company' s ability to recover its fixed costs, both
9 positively and negatively. It is difficult to determine
10 with precision the exact amount of unrecovered fixed costs
11 directly resulting from DSM acti vi ties. However, as a
12 practical matter, the same financial disincentive extends
13 to other load reducing acti vi ties as well. Some of these
14 non-DSM related variables include building code changes,
15 federal weatherization programs, tax incentives and
16 appliance rebates, federal marketing programs,
17 technological changes, substitutions between gas and
18 electric equipment, rate design changes consistent with
19 energy efficiency, shifts in the economy, customer
20 education and information, and other behavioral changes.
21 Idaho Power can assist in promoting many of the above-
22 mentioned non-DSM program initiatives that benefit
23 customers. The Company should be encouraged to pursue all
24 legitimate load reducing activities and the FCA mechanism
25 should appropriately capture all of the impacts to fixed
YOUNGBLOOD, DI 15
Idaho Power Company
1 cost recovery that flow from these acti vi ties. Removing as
2 many disincentives to load reduction acti vi ties as possible
3 is in the public interest.
4 Q.Does this mean that the Company is allowed to
5 benefit from acti vi ties that are not directly DSM related?
6 A.No. Under the current structure of the FCA
7 mechanism, the Company is only allowed to recover the level
8 of fixed costs previously authorized by the Commission in
9 its last general rate case. If the Company recovers more
10 than the level of fixed costs authorized, it will provide a
11 refund to the customers for the amount over-recovered. The
12 Company only recovers the authorized level of fixed costs,
13 no more and no less.
14 Q.Is the Company proposing to expand the FCA to
15 classes other than the Residential and Small General
16 Service classes?
17 A.No, not at this time. In this case, the
18 Company is only proposing to make the FCA an ongoing
19 permanent tariff schedule for the Residential classes
20 (Schedules 1, 3, 4, and 5) and Small General Service
21 customers (Schedule 7).
22 Q. How does the Company propose to distribute the
23 annual Residential and Small General Service FCA balances
24 if Schedule 54 is changed to a permanent tariff?
25
YOUNGBLOOD, DI 16
Idaho Power Company
1 A.For the first four years of the FCA pilot,
2 either the Commission ordered or the Company proposed to
3 recover or refund the FCA deferral balance equally to both
4 classes. Under the proposed permanent tariff, the Company
5 proposes to true-up the Residential and Small General
6 Service FCA by combining the deferral balances of each
7 class and implementing rates for each class that represent
8 a uniform percent change. This method of recovery or
9 refund is consistent with the first four years of the FCA
10 Pilot. In addition, by combining the Residential and Small
11 General Service FCA balances and determining the rate
12 adders based on an equal FCA rate adjustment for each
13 class, the overall rate impact to customers in these
14 classes is a more representative total amount of the
15 required fixed cost recovery for each class.
16 Q.Upon conversion to a permanent FCA, are you
17 proposing any other changes to the pilot FCA provisions set
18 forth in Case No. IPC-E-04- 15, Order No. 30267?
19 A.Yes. Under the pilot, the Company was
20 required to document each year specific ways it had
21 increased its investment in energy efficiency and DSM as a
22 result of the FCA mechanism. The Company believes that
23 this increased commitment to invest in energy efficiency is
24 now evident and a separate annual reporting requirement is
25 duplicative and no longer needed with the permanent
YOUNGBLOOD, DI 17
Idaho Power Company
1 Schedule 54. If questions arise as to the Company's
2 commitment toward the acquisition of all cost-effective
3 DSM, one can simply review the Company's DSM Annual Report
4 which is filed with the Commission in March of each year.
5 The Company will continue reporting the monthly FCA balance
6 as it now does and will continue to file annual
7 applications seeking approval of the FCA true-up balances.
8 All other provisions will remain the same.
9 Q.What effective date is the Company proposing
10 for converting Schedule 54 from a pilot schedule to a
11 permanent schedule?
12 A.The Company is proposing to make Schedule 54
13 an ongoing, permanent schedule immediately following the
14 completion of the extended pilot which ends December 31,
15 2011. Therefore, the Company proposes that Schedule 54
16 become a permanent tariff schedule , effective January 1,
17 2012.
18 Q.Have you updated the FCC and FCE rates that
19 would be in effect if the Commission approves the
20 Settlement Stipulation in IPC-E-11-08 and the base rates
21 resul ting from the approval were to be made effective
22 January 1, 2012?
23 A.Yes. I have updated the FCC and the FCE rates
24 using the functionalized and classified revenue requirement
25 data developed for the Settlement Stipulation. The updated
YOUNGBLOOD, DI 18
Idaho Power Company
1 FCC and FCE rates have been included on the revised
2 Schedule 54, Fixed Cost Adjustment.
3 Q.Please describe the process used to determine
4 the FCC and FCE rates for the FCA mechanism.
5 A.The FCC and FCE rates submitted are based upon
6 the 2011 test year and the functionalized and classified
7 revenue requirement data prepared as part of the Settlement
8 Stipulation in IPUC Case No. IPC-E-11-08. These rates most
9 accurately represent the Company's current fixed costs.
10 Exhibit No.2, Tables I, II, and III detail the
11 computational process that was used to determine these
12 class-specific fixed cost amounts.
13 The first step in this process is a determination of
14 the 2011 test year fixed cost recovery embedded in the
15 energy charges for Residential Service and Small General
16 Service customers. As can be seen in Exhibit No.2, Table
17 III, column J, for Residential Service, $258,560,620 of
18 fixed costs are to be recovered from the residential
19 customers through energy charges. For Small General
20 Service, $10,222,650 of fixed costs are to be recovered
21 from the energy charges.
22 Q.Do these fixed cost amounts for the
23 Residential and Small General Service customer classes
24 include more than their actual class cost-of-service?
25
YOUNGBLOOD, DI 19
Idaho Power Company
1 A.Yes. There is a difference between the class
2 cost-of-service numbers and the amount of requested revenue
3 requirement. This difference is a result of the cross-
4 class subsidies that are currently present in the Company's
5 rate structure. The total cross-class subsidies as well as
6 the fixed cost portion of those subsidies are identified in
7 Exhibit No.2, Table II.
8 Q.Why is it important to include these fixed
9 cost subsidies for the Residential and Small General
10 Service classes?
11 A.When fixed costs are recovered through a
12 volumetric rate, the effects of any conservation program
13 that reduces energy consumption results in a loss in the
14 recovery of those fixed costs. In the case of both the
15 Residential and Small General Service customer classes, the
16 reduction of energy consumption through conservation
17 measures not only prevents the Company from recovering the
18 fixed costs associated with those classes, but in addition,
19 prevents the fixed cost recovery of the subsidies which are
20 incorporated in their energy rates.
21 Q.How are the class-specific fixed cost amounts
22 established in the initial step used to derive the updated
23 FCC rates?
24 A.The determination of the FCC rate utilizes the
25 annual average number of customers for the Residential
YOUNGBLOOD, DI 20
Idaho Power Company
1 customer class and Small General Service customer class.
2 As can be seen in Exhibit No.2, Table III, column A, the
3 2011 average number customers is 397,403 for the
4 Residential customer class and 28,351 for the Small General
5 Service customer class.
6 Wi th these two principal base level values, the FCC
7 rate can be determined. The annual fixed costs recovered
8 through the energy charges divided by the 2011 average
9 number of customers results in an annual fixed cost
10 recovery per customer, or the FCC rate, shown in Exhibit
11 No.2, Table III, column K. For the Residential class, the
12 annual fixed cost recovery per customer is $ 650.63
13 ($258,560, 620 / 397,403). For the Small General Service
14 class, the annual fixed cost recovery per customer is
15 $360.57 ($10,222,650 / 28,351).
16 Q.How are the class-specific fixed cost amounts
17 established in the initial step used to derive the updated
18 FCE values?
19 A.The determination of the FCE rate utilizes the
20 Residential and Small General Service weather-normalized
21 energy consumption for the 2011 test year. As can be seen
22 in Exhibit No.2, Table III, column B, the 2011 weather-
23 normalized annual energy consumption for the Residential
24 customer class is 5,010,676,610 kilowatt-hours ("kWh") and
25
YOUNGBLOOD, DI 21
Idaho Power Company
1 annual energy consumption for the Small General Service
2 class is 148,946,670 kWh.
3 Wi th these additional principal base level values,
4 the FCE rate can be determined. The annual fixed cost
5 recovered through the energy charges divided by the
6 normalized energy results in an annual fixed cost recovery
7 per kWh, or the FCE rate, shown in Exhibit No.2, Table
8 III, column L. For the Residential class, the fixed cost
9 recovery per kWh is $0.051602 ($258,560,620 /
10 5,010,676, 610). For the Small General Service class, the
11 annual fixed cost recovery per kWh is $ 0.068633 ($ 10,222,650
12/148,946,670).
13 Q.Is the methodology used to establish the FCC
14 and FCE rates in this proceeding the same as that used
15 previously to establish the FCC and FCE rates in Case Nos.
16 IPC-E-07-08 and IPC-E-08-10?
17 A.Yes, it is.
18 Q.How do the FCC and FCE computed in this filing
19 compare to the FCC and FCE established in the Company's
20 last general rate case, Case No. IPC-E-08-10, Order No.
21 30754.
22 A.Both the FCC and FCC rates are greater than
23 those currently in effect, which were established using the
24 functionalized classified revenue requirement data in the
25 Company's last filed general rate case, Case No. IPC-E-08-
YOUNGBLOOD, DI 22
Idaho Power Company
1 10, Order No. 30754. The Company has made significant
2 investments in its infrastructure since that time, and the
3 newly calculated FCC and FCE rates reflect those fixed
4 costs that are being recovered through the Residential and
5 Small General Service energy charges. The magnitude of the
6 amount of fixed costs being recovered through a volumetric
7 rate emphasizes the Company's need to have an FCA true-up
8 mechanism in place.
9 Q.Does this conclude your direct testimony in
10 this case?
11 A.Yes, it does.
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YOUNGBLOOD, DI 23
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
CASE NO. IPC-E-11-19
IDAHO POWER COMPANY
YOUNGBLOOD, DI
TESTIMONY
EXHIBIT NO.1
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Exhibit No. 1
Case No. IPC-E-11-19
M. Youngblood, IPC
Page 1 of 1
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-11-19
IDAHO POWER COMPANY
YOUNGBLOOD, DI
TESTIMONY
EXHIBIT NO.2
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t
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.
Un
i
f
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m
T
a
r
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f
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h
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s
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.
Re
q
u
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m
e
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t
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s
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e
d
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o
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t
s
%
o
f
T
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t
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l
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o
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t
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+
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E+
A
Re
s
i
d
e
n
t
i
a
l
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e
r
v
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c
e
1,
3
,
4
&
5
38
1
,
4
5
5
,
1
5
0
88
,
6
8
7
,
8
1
7
39
,
4
9
1
,
9
4
2
14
5
,
5
0
8
,
2
9
6
27
3
,
6
8
8
,
0
5
6
71
.
7
%
2
Sm
a
l
l
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e
n
e
r
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l
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e
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v
i
c
e
7
15
,
5
0
4
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9
2
7
2,
0
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9
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7
7
4
95
6
,
0
9
5
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2
0
9
,
6
5
2
12
,
2
4
5
,
5
2
0
79
.
0
%
3
La
r
g
e
G
e
n
e
r
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l
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e
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v
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c
e
9
18
5
,
7
6
4
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5
7
9
49
,
5
1
3
,
1
0
7
21
,
2
9
6
,
5
6
5
40
,
8
2
7
,
0
3
9
11
1
,
6
3
6
,
7
1
1
60
.
1
%
4
Du
s
k
/
D
a
w
n
L
i
g
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t
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n
g
15
48
4
,
2
7
0
14
,
0
0
1
(1
,
2
4
8
)
37
3
,
9
1
1
38
6
,
6
6
3
79
.
8
%
5
La
r
g
e
P
o
w
e
r
S
e
r
v
i
c
e
19
85
,
4
2
0
,
3
4
2
23
,
7
6
4
,
6
1
6
10
,
5
0
9
,
6
2
7
8,
5
1
6
,
7
2
9
42
,
7
9
0
,
9
7
2
50
.
1
%
6
Ir
r
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g
a
t
i
o
n
S
e
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v
i
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e
24
12
5
,
6
2
4
,
2
1
8
32
,
0
0
6
,
9
7
5
15
,
0
2
2
,
2
2
0
41
,
1
0
4
,
4
1
5
88
,
1
3
3
,
6
1
0
70
.
2
%
7
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m
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t
e
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d
S
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r
v
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40
1,
0
7
9
,
8
9
5
17
2
,
9
0
8
76
,
7
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3
48
7
,
8
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6
73
7
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3
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8
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L
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41
1,
9
9
3
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6
66
,
3
5
5
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1
1,
4
8
8
,
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7
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8
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9
Tr
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42
26
5
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9
43
,
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3
23
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6
7
8
11
4
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9
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2
18
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10
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s
26
,
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9
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&
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2
72
,
4
1
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9
1
5
16
,
2
4
3
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7
6
1
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9
3
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1
3
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3
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11
To
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87
0
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8
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ID
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1,
3
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4
&
5
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6
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8
3
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7
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2
38
1
,
4
5
5
,
1
5
0
14
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9
2
8
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6
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a
l
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,
9
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2
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7
1
15
,
5
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6
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3
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5
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11
,
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15
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4
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0
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5
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3
4
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,
4
2
0
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2
,
6
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6
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24
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7
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6
,
5
9
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,
7
0
3
8
Mu
n
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41
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3
,
4
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9
3
,
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0
6
90
9
,
9
3
3
9
Tr
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g
42
16
6
,
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1
26
5
,
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9
(9
8
,
3
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10
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e
c
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a
l
C
o
n
t
r
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t
s
26
,
2
9
,
3
0
&
3
2
62
,
5
7
0
,
6
1
2
72
,
4
1
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11
To
t
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87
0
,
0
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2
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0
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1
(1
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We
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g
h
t
e
d
A
v
e
r
a
g
e
Fi
x
e
d
C
o
s
t
%
of
S
h
o
r
t
-
F
a
l
l
58
.
9
%
D
E
F
G
Re
v
e
n
u
e
Fix
e
d
C
o
s
t
Fi
x
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d
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o
s
t
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o
r
t
-
F
a
l
l
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e
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f
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r
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o
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o
f
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v
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e
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t
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e
r
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o
r
t
-
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a
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l
To
t
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l
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t
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o
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t
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F
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l
Ta
b
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,
C
o
l
.
F
Ex
F
X
(5
4
2
,
6
5
6
)
79
.
0
%
(4
2
8
,
5
8
0
)
X
(1
8
,
2
4
0
,
9
6
2
)
7
0
.
2
%
(1
2
,
7
9
7
,
2
2
8
)
X X
(9
8
,
3
4
8
)
6
8
.
7
%
(9
,
8
4
2
,
3
0
3
)
3
6
.
8
%
(2
8
,
7
2
4
,
2
6
8
)
(6
7
,
5
4
5
)
(3
,
6
2
5
,
4
3
7
)
(1
6
,
9
1
8
,
7
9
1
)
ID
A
H
O
P
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W
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R
C
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M
P
A
N
Y
De
v
e
l
o
p
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n
t
o
f
F
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d
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t
A
d
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u
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t
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n
t
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20
1
1
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s
t
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a
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b
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e
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De
r
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t
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o
f
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d
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s
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.
1
1
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8
.
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2
3
,
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0
1
1
A
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C
D
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F
20
1
1
20
1
1
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a
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e
s
Sh
a
r
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o
f
To
t
a
l
Li
n
e
Sc
h
e
d
u
l
e
Av
g
.
N
u
m
b
e
r
o
f
No
r
m
a
l
i
z
e
d
CO
S
CO
S
Re
v
e
n
u
e
Ba
s
e
R
a
t
e
No
.
Un
i
f
o
r
m
T
a
r
i
f
f
S
c
h
e
d
u
l
e
s
No
.
Cu
s
t
o
m
e
r
s
(k
W
h
)
Fi
x
e
d
C
o
s
t
Va
r
i
a
b
l
e
C
o
s
t
Sh
o
r
t
-
F
a
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l
/
S
u
b
s
i
d
y
Re
v
e
n
u
e
Ta
b
l
e
i
,
C
o
l
.
E
Ta
b
l
e
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of October 2011 I served a true and
correct copy of the within and foregoing DIRECT TESTIMONY OF MICHAEL J.
YOUNGBLOOD IN SUPPORT OF THE APPLICATION FOR AUTHORITY TO
CONVERT SCHEDULE 54 (FIXED COST ADJUSTMENT) TO A PERMANENT
SCHEDULE upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Donald L. Howell, II
Karl T. Klein
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
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_ Overnight Mail
FAX
-2 Email Don.Howelicæpuc.idaho.gov
Karl. Kleincæpuc. idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
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-2 Email petercærichardsonandoleary.com
greg(grichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hill Road
Boise, Idaho 83703
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-2 Email dr(gbenjohnsonassociates.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
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29814 Lake Road
Bay Vilage, Ohio 44140
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The Kroger Co.
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Kevin Higgins
Energy Strategies, LLC
215 South State Street, Suite 200
Salt Lake City, Utah 84111
Micron Technology, Inc.
MaryV. York
HOLLAND & HART, LLP
101 South Capital Boulevard, Suite 1400
Boise, Idaho 83702
Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
The United States Department of Energy
Arthur Perry Bruder, Attorney-Advisor
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Dwight D. Etheridge
Exeter Associates, Inc.
10480 Little Patuxent Parkway, Suite 300
Columbia, Maryland 21044
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Attorney at Law
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-2 Email bmpurdyaìhotmail.com
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Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, Idaho 83701
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Nancy Hirsh, Policy Director
NW Energy Coalition
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Hoku Materials, Inc.
Dean J. Miler
McDEVITT & MILLER LLP
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Hoku Materials, Inc.
One HokuWay
Pocatello, Idaho 83204
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~Æs=~
V-Willams
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