20170504Motion for Procedural Relief.pdf

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CAMILLE CHRISTEN, ISB NO. IOT77
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 W. WASHTNGTON STREET (83702-591 8)
P.O. BOX 83720
BOISE, ID 83720-0074
Telephone: [phone]
E-mail: [e-mail]. gov
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE RATES FOR
ELECTRIC SERVICE TO RECOVER COSTS
ASSOCIATED WITH THE NORTH VALMY
PLANT
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Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE RATES FOR
ELECTRIC SERVICE DUE TO REVISED
DEPRECIATION RATES FOR ELECTRIC
PLANT.IN.SERVICE
CASE NO. IPC.E-16-23
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CASE NO.IPC.E.I6-24
MOTION FOR
PROCEDURAL RELIEF
The Staff of the Idaho Public Utilities Commission, now moves for an Order, under
IDAPA 31.01 .01.256.03 and .274, vacating the comment deadlines in the above-captioned cases
and providing Notice of Settlement Stipulations and Notice of Comment Deadlines.
On October 21, 2016, Idaho Power Company filed an Application asking the
Commission to adopt revised depreciation rates for its electric plant-in-service and
correspondingly adjust Idaho jurisdictional base rates, with a requested effective date of June 1,
2017. Application (Case No. IPC-E-23) at l. The Company concuffently filed an Application
requesting Commission authorization to accelerate the depreciation schedule for the North
Valmy power plant, establish an associated balancing account, and adjust customer rates, also
with a requested effective date of June 1,2017 . See Application (Case No. IPC-E-16-24) at l.
MOTION FOR
PROCEDURAL RELIEF I
In November 2016, the Commission issued an Order providing Notice of the
Application and setting a deadline for interventions. Order No. 33650. The Commission granted
petitions to intervene in both cases from the Idaho Irrigation Pumpers Association, Inc. (IIPA),
Micron Technology, Inc., the Idaho Conservation League (ICL) and Sierra Club, the U.S.
Department of Energy and the Federal Executive Agencies, and the Industrial Customers of
Idaho Power. Order Nos. 33659, 33660, 33670, 33671, 33672, 33710, 33673, 33674, 33676,
and33746.
The parties conferred and agreed to process the Application via Modified Procedure
with agreed comment deadlines, which the Commission adopted. Order No. 33690. The parties
also agreed to meet to discuss potential settlement options.
ln the course of settlement discussions, the parties indicated that they wanted more
time to consider potential settlement options and to develop comments if a settlement is not
reached. Consequently, on two occasions the parties agreed to revise the comment deadlines for
both cases. On both occasions Staff moved the Commission to adopt the revised schedule and
the Commission found good cause to do so. Order Nos. 33745 and 33759. The comment
schedule currently in place is as follows:
May 4,2017 Deadline for comments from parties and the public
May I1,2017 Deadline for parties' cross-answering comments
May 18,2017 Deadline for Company reply comments
Order No. 33759.
On May 3,2017, all parties agreed or did not object to settlement stipulations that
fully resolve the issues in each case. The Company has filed the Settlement Stipulations and
Agreed Motions to Approve the Settlement Stipulations. The parties agree or do not object that
the existing comment deadlines should be vacated and that a new deadline for comments from
parties - if any - in support of the settlements be set for May 18,2017, or 14 days from the date
of this Motion. The parties also agree or do not object to a deadline for public comments of May
25,2017, or 14 days from the Commission's May I I decision meeting at which it will consider
this Motion. (Issuing the Notices requested by this Motion with a service date of May 1 1,2017,
the same day as the Commission's decision meeting, will ensure that the public has a l4-day
comment period.)
MOTION FOR
PROCEDURAL RELIEF 2
Although a l4-day public comment period is shorter than the standard 2l-day
comment period, it has been much longer than 2l days since the Company's Applications were
filed. Thus, parties and members of the public have had time to consider and comment on the
issues presented by the Applications. (Six public comments have been submitted to date in the
Valmy case. No public comments have been submitted in the revised depreciation case.)
Further, some of the elements of the Settlement Stipulations, such as extending the amortization
period for Valmy costs past the agreed plant closure dates for accounting purposes, were
discussed hypothetically at the informational workshop Staff held for the public on March 21,
2017, (indeed, two of the public comments discussed that approach favorably). Finally, the
proposed comment deadlines - rather than later deadlines - will allow more time to achieve the
Company's requested effective date in both cases of June 1,2017.
The Company proposed the June l, 2017 effective date in effort to align with other
proceedings before the Commission impacting customer rates, such as the Company's annual
Fixed Cost Adjustment and Power Cost Adjustment cases. Aligning all rate changes on a single
date - June I - would ensure as few rate changes as possible for customers.
For these reasons, Staff believes there is good cause to establish a deadline of 14 days
from the date of this Motion for comments (if any) in support of the settlement from the parties,
and a deadline of 14 days from the Commission's next decision meeting at which this Motion
will be considered, for public comments regarding the settlement. As such, Staff respectfully
moves the Commission to vacate the existing schedule in Case Nos. IPC-E-16-23 and IPC-E-16-
24. Staff also requests that the Commission issue a Notice of Settlement Stipulations and Notice
of Comment Deadlines - dated the day of its decision meeting, May I l, 2017 - adopting a
deadline of May 18, 2017, for any comments from parties in support of the settlement, and a
deadline of May 25,2017 for public comments regarding the settlement.
Respectfully submitted this 4s day of May 2017.
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Camille Christen
Deputy Attorney General
N:IPC-E-I6-23 IPC-E-16-24 cc3 Motion
MOTION FOR
PROCEDURAL RELIEF J
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4ft DAY OF MAY 2017, SERVED
THE FOREGOING MOTION FOR PROCEDURAL RELIEF, IN CASE NOS. IPC-E-16.
23 AND IPC.E.I6-24, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail : lnordstrom@ idahooower. com
dockets@ idahopower. com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
E-mail: [e-mail]
THORVALD A NELSON
FREDERICK J SCHMIDT
EMANUEL T. COCIAN
BRIAN T HANSEN
HOLLAND & HART LLP
6380 S FIDDLERS GREEN CIR STE 5OO
GREENWOOD VILLIAGE CO 80111
E-mail : [e-mail]
fschmidt@ho I landhart. com
etcocian@ho llandhart. com
bthansen@ho llandhart. com
E.MAIL ONLY
[e-mail]
[e-mail]
kmtrease @hollandhart. com
MATTHEW T. LARKIN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-mail: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-mail: [e-mail]
PETE BENNETT
MICRON TECHNOLOGY INC
8OOO S FEDERAL WAY
BOISE ID 83707
E-mail: [e-mail]
STEVEN PORTER
US DEPT OF ENERGY
1OOO INDEPENDENCE AVE SW
ROOM 6D-033
WASHINGTON DC 20585
E-mail: steven.porter@.hq.doe. gov
CERTIFICATE OF SERVICE
PETER J zuCHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-mail : [e-mail]
DR DON READINU
6070 HILL ROAD
BOISE ID 83703
E-mail : [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
PO BOX 844
BOISE ID 8370I
E-mail: [e-mail]
TRAVIS RITCHIE
SIERRA CLUB
2101 WEBSTER ST
STE I3OO
OAKLAND CA946I2
E-mail : [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE