20140411Reply Comments.pdf

KRISTINE A.SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION R 2:O:
P0 BOX $3720
BOISE,IDAHO 83720-0074 ‘iTT
[phone]
BAR NO.6618
Street Address for Express Mail:
472 W.WASHINGTON V
BOISE,IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLiCATiON OF )
IDAHO POWER COMPANY FOR APPROVAL )CASE NO.IPC-E-13-23
OF A SPECIAL CONTRACT WITH J.R.)
SIMPLOT COMPANY.)REPLY COMMENTS OF
)THE COMMISSION STAFF
____________________________________________________________________________________________)
COMES NOW the Staff of the Idaho Public Utilities Commission,by and through its
Attorney of record,Kristine A.Sasser,Deputy Attorney General,and in response to Idaho Power
Company and J.R.Simplot Company’s Comments submitted on March 28,2014,in Case No.
IPC-E-13-23,submits the following responsive comments.
BACKGROUND
Idaho Power filed an Application with the Commission on December 4,2013,requesting
that the Commission issue an Order approving special contract terms for electric service between
Idaho Power and J.R.Simplot Company’s new Caidwell facility.Simplot filed an answer on
February 5,2014,disputing Idaho Power’s contract language and initial rates.
On March 28,2014,Commission Staff,Idaho Power Company and J.R.Simplot Company
each filed comments.After reviewing Idaho Power’s and J.R.Simplot’s comments,Staff
modifies/clarifies its Comments as detailed below.
REPLY COMMENTS 1 APRIL 11,2014
STAFF RESPONSE
In comments filed on March 2$,2014,the Staff and JR.Simplot Company both proposed
an average contract rate based on the rate average of the existing three special contracts.
However,Staff and Simplot used different rates to calculate the average and therefore,calculated
different averages.Staffs average was 3.795 /kWh and Simplot’s average was 3.699 0/kWh.
The rates are different because Staff based its calculations on base revenues and sales in
the Langley Gulch case,Case No.IPC-E-12-14,and Simplot based its calculations on base
revenues and sales in Idaho Power’s 2013 PCA filing,Case No.IPC-E-13-10.The tariffed rates
(demand.energy and customer charges)are the same in both cases but energy and possibly
demand billing determinants are different.The Langley Gulch case used forecasted billing
determinants for June 2012 through May 2013.The PCA case used forecasted billing
determinants for June 2013 through May 2014.The different test years produced different
revenues and different energy sales amounts for existing special contract customers even though
the tariffed rates were the same in both years.Because special contract rates are different,the
average of the special contract rates are different.
Staff agrees that the calculation should be based on the most recent base revenues and
sales.In utilizing the rates from Idaho Power’s 2013 PCA,Staff supports an initial annual
revenue requirement of $7,800,827.The revenue requirement is the average rate times expected
sales (.03699 $/kWh X 210,890,146 kWh =$7,800,827).This revenue requirement is $1,147,290
less than the $8,948,117 proposed by Idaho Power.It is Staffs proposal that the J.R.Simplot -
Schedule 33 demand and energy rates be designed to produce $7,800,827 in annual revenue.
it is worth noting,two other filings will change all customers’rates on June 1,2014.Base
rates will change as the result of Commission Order No.33000 issued in Case No.IPC-E-l3-20
which requires Idaho Power to move some Net Power Supply Expense (NPSE)from the PCA into
base rates.PCA rates are also expected to change on that same day as a result of Idaho Power’s
annual PCA filing which is scheduled for April 15.These two changes will impact rates for all
customer classes including special contract customers and will change rates established in this
case for the new Simplot special contract.
REPLY COMMENTS 2 APRIL 11,2014
Respectfully submitted this I i day of April 2014.
AJA
Kristine A.Sasser
Deputy Attorney General
Technical Staff:Keith Hessing
i :urnisc:comments/ipce 13 .23kskh reply comments
REPLY COMMENTS 3 APRIL 11,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY Of APRIL 2014,
SERVED THE FOREGOING REPLY COMMENTS OF THE COMMISSION STAFF,
IN CASE NO.IPC-E-13-23,BY MAILING A COPY THEREOF,POSTAGE PREPAID,
TO THE FOLLOWING:
LISA D NORDSTROM PETER J RICHARDSON
IDAHO POWER COMPANY GREGORY M ADAMS
P0 BOX 70 RICHARDSON ADAMS PLLC
BOISE ID 83707-0070 515 N 27TH STREET
E-MAIL:[e-mail] BOISE ID $3702
E-MAIL:[e-mail]
[e-mail]
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SECRETARY /
CERTIFICATE OF SERVICE