20021231ID Irrigation Pumpers.pdf

Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
RECEIVED
FILED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF
INTERIM PROVISIONS FOR THE SUPPLY
OF ELECTRIC SERVICE TO MONSANTOCOMPANY
Case No. PAC-OI-
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INc.'
COMMENTS RE: ORDER NO.
29157
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), through counsel
of record, and hereby respectfully submits the following Comments to the Commission in response
to its Proposed Order No. 29157.
First, the Irrigators would like to correct an error in the Commission s characterization of Mr.
Yankel's direct testimony. At the top of page 10 of Proposed Order, the Commission states that:
Using 1 000 hours the Irrigators calculate a rate of25.45 mills/kWh. Tr. p. 730, Exh. 101." This
sentence is incorrect and should read: "Using 1 000 hours the Irrigators calculate a rate of 20.45
mills/kWh. Tr. p. 746 & 766, Exh. 301." This change will appropriately summarize Mr. Yankel'
testimony.
Second, the Irrigators have filed with the Commission in this case an Application for
Intervenor Funding ("Application ). The Irrigators' Application was apparently not addressed by
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'S COMMENTS RE: ORDER NO. 29157 - 1
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the Commission s Proposed Order because it was not final and due to the fact that it solicited
additional comments. The Irrigators reassert that their participation in this case has shed light on
important issues before the Commission for the reasons stated in Mr. Yankel' s direct testimony, the
Irrigators' Post Hearing Brief and in the Irrigators ' Application. Accordingly, the Irrigators
respectfully request that the Commission to address its Application in its forthcoming final order.
Finally, in its Proposed Order, the Commission determined that the interruptible energy rate
of 23.54 mills/kWh is fair, just and reasonable after giving appropriate credit for Monsanto
operating reserves and economic curtailment. However, in determining this rate the Commission
has relied primarily on market power purchases in pricing economic curtailment as a demand side
resource ("DSM"). The Irrigators believe that the proper approach should be to primarily look to
the avoided cost of building the peaker plant as testified by Mr. Yankel. (Yankel (Dir), Vol. VI
, p.
745 & 746, 1. 8-25 & 1-) By relying primarily on market power purchases, the Commission has
under priced the value of economic curtailment as a DSM resource based on current market
conditions and could expose PacifiCorp to significantly higher costs to acquire this resource in the
future in light of recent market volatility during the 2000/2001 energy crisis. Further, when the BP A
credit is reduced or when PacifiCorp files a new general rate case, the Irrigators will be asking the
Commission for rate relief in the form of some sort of interruptible tariff. Pricing interruptibility
primarily on market power purchases would give a disincentive to the Irrigators from even providing
economic curtailment as a DSM resource. Accordingly, the Irrigators ask the Commission to price
interruptibility primarily on the avoided cost of building a peaker unit.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'S COMMENTS RE: ORDER NO. 29157 - 2
Respectfully submitted this 30th day of December, 2002.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
ERIC L. OL
Attorney for Irrigators
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this day of December, 2002, I served a true, correct and
complete copy of the Idaho Irrigation Pumper s Association, Inc.s Comments Re: Order No. 29157
to each ofthe following, via U.S. Mail or hand delivery:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
E-mail: jjewell~puc.state.id.
Hand Deli very
John M. Eriksson
Stoel Rives LLP
201 S. Main St., Ste. 1100
Salt Lake City, Utah 84111
S. Mail
Mary S. Hobson
Stoel Rives LLP
101 South Capitol Blvd., Suite 1900
Boise, Idaho 83702-5958
Hand Delivery
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S COMMENTS RE: ORDER NO. 29157 - 3
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey
O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204-1391
Hand Delivery
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, Idaho 83276
S. Mail
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ERIC L. OLSE
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.S COMMENTS RE: ORDER NO. 29157 - 4