20161215Comments.pdf

Peter J. Richardson ISB No. 3195
Gregory M. Adams ISB No. 7454
Richardson Adams, PLLC
515 N. 2?1h Street
P.O. Box 7218
Boise, Idaho 83 702
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
R :CEIV ED
2t!&O[Cl5 PMti :11
IN THE MATTER OF THE APPLICATION OF)
IDAHO POWER COMPANY FOR DEFERRAL)
AND RECOVERY COSTS ASSOCIATED )
WITH PARTICIPATION IN AN ENERGY )
CASE NO. IPC-E-16-19
COMMENTS OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
IMBALANCE MARKET. )
) _________________ )
COMES NOW, The Industrial Customers of Idaho Power (ICIP), an Intervenor herein,
and pursuant to the Idaho Public Utilities Commission's (Commission) Notice of Modified
Procedure and Notice of Comment Deadline issued in Commission Order No. 33627 on October
14, 2016, and hereby lodges its Comments for the Commission's consideration.
IDAHO POWER'S APPLICATION
Idaho Power Company ("Company") filed its Application in this matter with the
Commission on August 19, 2016. It asks the Commission to issue an order:
(1) acknowledging the potential for long-term benefits related to Idaho Power's
participation in the western EIM [Energy Imbalance Market] (2) authorizing the
establishment of a regulatory deferral account to tract necessary incremental costs
associated with EIM participation, and (3) authorizing the Company to recover, in a
future rate proceeding, the estimated incremental costs of joining the EIM.
Application at p. 7.
The Company anticipates beginning participation in the western EIM in April of 2018, and
anticipates annual savings from such participation to be in the range of four to five million
dollars. It also anticipates incurring incremental costs of almost sixteen million dollars.
Incremental costs include start up costs associated with software, metering and associated labor
and software fees.
Specifically the Company asks the Commission to:
Issue an order acknowledging the expected customer benefits resulting from its
participation in the Western EIM, authorizing the Company to defer its Idaho
jurisdictional share of incremental costs related to participation in the western EIM, and
authorizing the Company to recover, in a future rate proceeding, the estimated
incremental costs of joining the EIM.
Application at p. 5.
ICIP RECOMMENDATIONS
The ICIP does not oppose the issuance of an order by this Commission "authorizing the
Company to defer its Idaho jurisdictional share of incremental costs related to participation in the
western EIM." Nor does the ICIP oppose the issuance of an order by this Commission
"acknowledging the expected benefits resulting from its [Idaho Power's] participation in the
Western EIM." Certainly, implicit in any order from this Commission authorizing deferral of
costs related to a new endeavor such as the EIM is an assumption (if not a hope) that such costs
will result in benefits to the ratepayers. That said, the ICIP strongly opposes any order from this
Commission authorizing rate recovery of any costs in a future proceeding that have yet to be
proven to have been prudently incurred.
The ICIP agrees that the Commission may enter a deferred account order to permit the
Company to begin to defer its jurisdictional share of EIM-related operations and maintenance
expenses and depreciation expenses related to capital investments necessary to implement EIM
ICIP Comments -IPC-E-16-19 2
for potential recovery from customers pursuant to a Commission order in a future rate case. The
prudence of the deferred EIM costs can only be determined in such future rate case, and the ICIP
reserves the right to contest said costs to be recovered notwithstanding its position relative to the
deferred accounting treatment of those expenses
DATED this 15h day of December, 2016
9 d;:)/~
Peter J. Richardson
RICHARDSON ADAMS, PLLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of December, 2016, a true and correct copy of
the within and foregoing COMMENTS OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER in Docket No. IPC-E-16-19 was served electronically and by U.S. Mail, to:
Julia Hilton
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83 707-0070
[e-mail]
[e-mail]
Matthew T. Larkin
Idaho Power Company
1221 West Idaho Street (83702)
Boise, Idaho 83 707-0070
[e-mail]
Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
4 72 West Washington
Boise, Idaho 83 702
[e-mail]
Kandi Walters
Administrative Assistant
ICIP Comments -IPC-E-16-19 3
Ben Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83 702
[e-mail]
Ken Miller
Snake River Alliance
223 N. 6th St., Ste. 317
PO Box 1731
Boise, Idaho 83 702
[e-mail]