19900907Corrected p 8, Position Statement.pdf

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DAVIS WRGHT TRMAIE
LAW Ol'FlCES
REGEl DlI
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JEl'l'ERSON PuCE . 350 N. 9TH, SUITE 400 . BoISE, IDAHO 83702
[phone] SEP 7 Pl1 ~ 38
PETER J. RICHARDSON o i't;L:LiG
September 7, 1990 u-ri LiTlE'S .C (Ì ;~lti11S S l 0 f"Jn~
Ms. Myrna J. Walters
Commission Secretary
Idaho Public utilities Commission
472 W. Washington
Boise, ID 83702
Re: Statement of Position and Issues of the Industrial
Customers of Idaho Power
Case No. IPC-E-90-2 and Case No. IPC-E-90-8
Dear Ms. Walters:
Enclosed is the original and seven copies of a new page 8 of
the above referenced Statement of position and Issues of the
Industrial Customers of Idaho Power. This replacement page 8
corrects a typographical error and in no way changes the context
of the document. Would you please replace the original page 8
with this new page 8 in documents we filed with you on September
5, 1990?
By copy of this letter, we serve the parties of record. If
you have any questions, please do not hesitate to contact me.
Sincerely,
DAVIS WRIGHT TREMAINE(jJ:~
Peter J. Richardson
np
Enclosures
FAX: [phone]
ANCHORAGE, ALSKA . BELLEVUE, WASHINGTON . Los ANGELES, CALIFORNIA
PORTLAND, OREGON' RiCHLAD, WASHINGTON' SEATTLE, WASHINGTON' WASHINGTON, D.C.
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In addition, a revision of the Company's power costs will have
other related implications. For example, income tax expenses will
be altered. Simply "rate basing" the actual construction costs of
Swan Falls and Milner ignores these considerations and will result
in rates that do not match, and will probably exceed, costs.
IV. IDAHO POWER HA HOT MAE TH REQUISITE SHOWING FOR TH
GRAINGOF PR-APPROVAL OF RATE MAING TRTM FOR
THSE FACILITIES
One of the principal issues that must be addressed
whenever a new resource is considered is the issuance of a
certificate of public convenience and necessity.A second
important issue deals with rate making treatment. For example, is
the cost of the new resource less than or equal to the cost of
other resources available to the utility?If the new resource
costs more than identified alternatives, or if alternative
resources provide better service at the same, or lower cost, the
utility's request for a certificate, or rate recognition must be
rejected.As stated above, the utility's avoided cost is one
measure of the cost of these alternatives. At a minimum Idaho
Power must pass the threshold test of demonstrating that its new
generating facility will produce power at less than, or equal to
its avoided cost.
Idaho Power must obtain a certificate of public
convenience and necessity prior to beginning construction of any
new generating facility. I.C. § 61-526 (1976). In granting that
STATEMENT OF POSITION
AND ISSUES OF THE ICIP - PAGE 8