19900831Position Statement.pdf

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OWEN H. ORNDORFF
ORNDORFF & PETERSON
1087 West River Street
Suite 230
Boise, Idaho 83702
Telephone: [phone]Fax: [phone]
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY FOR AUTH- )
ORITY TO RATEBASE THE INVESTMENT )
REQUIRED FOR THE REBUILD OF THE )
SWAN FALLS HYDROELECTRIC FACILITY )
)
CASE NO. IPC-E-90-2
STATEMENTS OF POSITION
OF AFTON ENERGY, INC.
COMES NOW, Afton Energy, Inc. ("Afton") through its attorneys
Orndorff & Peterson, and offers the following statements of
position with respect to the above case.
1. Afton has excess capacity and energy available to sell
Idaho Power Company ("Idaho Power") from an existing plant at
avoided costs yet to be determined based on a twenty year contract
which will provide ratepayers significant security guaranteeing
performance.
2. Idaho Power proposes that the costs of building the Swan
Falls project should be paid by ratepayers by including the Swan
Falls proj ect in the ratebase. Afton assumes that Idaho Power's
charges will be front end loaded with depreciation charges and
return on equity in addition to the normal cost of capital and
operating expenses.
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3. The Public utility Regulatory Policies Act of 1978
("PURPA") and Idaho's implementation of PURPA specifically grant
to PURPA qualified facilities an avoided cost based on Idaho
Power's avoided, incremental plant. Given a qualified facility
receives a level paYment over its contract life verses Idaho
Power's front end loaded costs, qualified facilities offer the
least cost al ternati ve for new generation.
4 . Given the foregoing, Afton Energy's position is that it
wants a level playing field on which it has the same ability to
provide Idaho Power's ratepayers capaci ty and energy measured
against a twenty year contract, cash escrow guaranteeing
performance, and other provisions applying to qualified facilities.
To the extent that Idaho Power asserts that the Swan Falls proj ect
has unique project values such as senior water rights that justify
higher prices than available from qualified facilities, Idaho
Power's shareholders should pay for such unique benefits and not
ratepayers through higher energy costs. Idaho Power's shareholders
will own the Swan Falls proj ect together with the water rights and
the costs in excess of competi ti ve generation al ternati ves should
be fully allocated to Idaho Power's shareholders.
5. Idaho Power's ratepayers should pay for least cost
electrical generation and not generation resources which have an
inflated price with significant front end costs. Any other public
policy of acquiring generation resources other than a least cost
methodology can only result in unnecessary increases in ratepayer
costs and damage to the Idaho economy.
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DATED 31st day of August, 1990.
Re~fUlly.
BY'f
Owen H.Attorneys nergy, Inc.
,CERTIFICATE OF MAILING
I hereby certify that on this 31st day of August, 1990, I have
served a true and correct copy of the within and foregoing COMMENTS
OF AFTON ENERGY, INC., postage prepaid and addressed as follows:
Larry Ripley
Evans, Keane, Koontz, Boyd,
Simko & Ripley
c/o Idaho Power Company
1220 West Idaho Street
P.O. Box 70
Boise, ID 83707
Steven L. Herndon
Idaho Power Company
1220 West Idaho StreetP. O. Box 70
Boise, Idaho 83707
Michael S. Gilmore
Brad M. Purdy
Idaho Public utilities
Commission
Statehouse Mail
Boise, Idaho 83720-0001
Grant E. Tanner
Davis Wright Tremaine
1300 SW Fifth Avenue
Suite 2300
Portland, OR 97201
Peter J. Richardson
Davis Wright Tremaine
Jefferson Place, Suite 400
350 N. Ninth
Boise, Idaho 83702-5471
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Harold C. Miles
Idaho Consumer Affairs, Inc.
316 15th Avenue South
Nampa, Idaho 83651-4319
R. Scott Pasley
Assistant General Counsel
J. R. Simplot Company
P.O. Box 27
Boise, Idaho 83707-0027
David H. Hawk
Director, Energy NaturalResources
J. R. Simplot Company
P.O. Box 27
Boise, Idaho 83707-0027
James N. Roethe
Pillsbury, Madison, & Sutro
P.o. Box 7880
San Francisco, CA 94120
R. Michael Southcombe
Clemons, Cosho & Humphres, P.A.
815 West Washington
Boise, Idaho 83702-5590
DATED this 31st day of August, 19
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