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Home My WebLink About20090225Comments Supporting Stipluation.pdfLAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTERED W. MARCUS W. NYE RANDALL C. BUDGE JOHN A. BAILEY, JR. JOHN R. GOODELLJOHN B. INGELSTROM DANIEL C. GREEN BRENT O. ROCHE KIRK B. HADLEY FRED J. LEWIS ERIC L. OLSEN CONRAD J. AIKEN RICHARD A. HEARN, M.D.DAVID E. ALEXNDER LANE Y. ERICKSON PATRICK N. GEORGE SCOTT J. SMITH STEPHEN J. MUHONEN BRENT L. WHITING JUSTIN R. ELLIS JOSHUA D. JOHNSON JONATHON S. BYINGTON DAVE BAGLEY CAROL TIPPI VOLYN THOMAS J. BUDGE CANDICE M. MCHUGH JONATHAN M. VOLYN MARK A. SHAFFER Jean D. Jewell, Secretar Idaho Public Utilities Commission PO Box 83720 Boise, Idaho 83720-0074 Re: Case No. PAC-E-08-07 Dear Ms. Jewell: 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 232-6101 FACSIMILE (208) 232-6109 ww.racinelaw.net SENDER'S E-MAIL ADDREss:elo(graclnelaw.net Februar 25,2009 BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD, SUITE 208 BOISE, IDAHO 83702 TELEPHONE: (208) 395-0011 FACSIMILE: (208) 433-0167 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 203A IDAHO FALLS. 1083402 TELEPHONE: (208) 528-6101 FACSIMILE: (206) 528-6109 COEUR D'ALENE OFFICE 250 NORTHWEST BOULEVARD, SUITE106A COEUR D'ALENE, 1083814 TELEPHONE: (208) 765-6888 ALL OFFICES TOLL FREE(877) 232-6101 L.OUIS F. RACINE (1917-2005) WILLIAM D. OLSON, OF COUNSEL ~~-r~~ -0::;;..-Cf Enclosed for filing in the captioned matter, please find the origial and eight (8) copies of Idaho Irrigation Pumpers Association, Inc. 's Comments in Support of Stipulation. ELO:nj Enclosures cc: Serce List Sincerely,~ ) f fì fi ('i ,. ,.:~.. II..I- Eric L. Olsen, ISB #4811 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 ZUU9 FEB 25 PH 4: r 6 Attorneys for Interenor Idaho Irrgation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR APPROVAL OF CHANGES TO ITS ELECTRIC SERVICE SCHEDULES ) ) ) ) ) CASE NO. PAC-E-08-7 IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT OF STIPULATION IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("LIP A"), by and though its attorneys, hereby respectfully submits following comments in support of the Stipulation fied in this case on February 5,2009. BACKGROUND On September 19,2008, Rocky Mountain Power ("RMP") fied an Application seeking authority to increase the Company's base rates for electrc service by $5.9 milion annually (an increase of approximately 4.0%). Because of contracts that are presently in place, this increase was proposed to be collected from all but RMP's two special contract customers in Idaho. By customer class, the increase was proposed to be based on the Company's cost of servce study and was proposed to be distrbuted as follows: IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S COMMENS IN SUPPORT OF STIPULATION - 1 f Customer Class Residential Schedule 23/23A Schedule 6/6A/8/35 Schedule 9 Schedule 19 Irrgation Street Lighting Increase 4.73% 0.00% 7.96% 7.96% 2.31% 2.31% 0.00% The lIP A is an Idaho nonprofit corporation that was organized in 1968 to represent agrcultual interests in electric utilty rate matters affecting farers in southern and central Idaho. During its existence and participation in rate proceedings, the lIP A and its membership has witness perods of excess power supplies, energy shortages, loss of the BPA credit, and growth on RMP's system. RMP is now in the early stages ofa large and sustained expansion program. This building program is planed to signficantly increase the amount of Generation, Transmission, and Distribution plant the Company has in servce. The construction of these new facilities is necessitated by the customer growth on the system and the growth in usage (on-peak and off-peak) per customer. A settlement of this case has been proposed by the affected parties. Each pary that signed the stipulation presumably did so because it felt that the outcome of the settlement would be as good as or better than the possible results of a fully litigated case. Ths is not to say that the lIP A (or other parties) fully agree with each specific term of the Stipulation, but that "in total" the Stipulation provides an acceptable result. With this in mind, the IIPA hereby gives the following comments in support of the Stipulation. IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT OF STIPULATION - 2 REASONS FOR SUPPORT For much of this past decade, the irrgation class has been singled out as a customer class that has needed above average rate increases. Ths perceived need to give disproportionate rate increases to the irgation class is not so much been tied to the growth or cost of growth that the Irrgators have placed upon the system. Rather, the proposed increases are more byproduct ofRMP's cost of serice study that simply assign/allocates costs based upon usage at the hour of the system peaks as opposed to assignng costs to those who are causing the increased costs to occur at the time of the system peaks. The irrgation class has been in the unfortate position of taking servìce during the summer where RMP's growth (and therefore costs) has been rising rapidly in order to meet the ever increasing air-conditioning load. The Irgators have been working with RMP since 2002 to develop and refine irrgation load management programs. In the last year of so, we helped develop a new set of parameters such that that the load management programs are now capable of taking over 200 MW off of the summer, system peak. This level of load control is larger than for any other customer class on the entire system. There are several sets of benefits that flow from such a level ofload control. First, in the long ru, this curailment program significantly reduces the need for peak resources, resulting in lower generation and transmission costs for the entire system. Second, when RMP's load is high and purchased power costs are high, RMP can avoid some or all of these expensive purchases by curailng the Idaho Irrgation load--nce again lowering the operating costs to the entire system. Equally important, when market prices are high, the Company could take advantage of these curailment opportities to IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT OF STIPULATION - 3 sell power into the market at a signficant profit--nce again lowering the operating costs of the entire system. The above described system benefits are at the margin-much higher than the average system costs. However, the Company's jurisdictional separation model allocates these benefits on an average cost basis. Because the system peak has been lowered as a result of the load management programs and because the Idaho contrbution to the system peak is lowered, all Idaho customers receive a benefit in the form of a lower jurisdictional revenue requirement. Likewise, the irrgation class receives an average cost benefit due to the allocations in RMP's class cost of service modeL. From a conceptual basis, it is obvious that both the Idaho jurisdictional revenue requirement as well as the irrgation class' share of that increase has been reduced because of the curtailment programs. Thus, the rate increase being requested of the Idaho jurisdiction was only 4.0% and the percentage increase for the Irrgators was even less at 2.31 %. It was incumbent upon the lIP A as well as the Commission Staff to insure that these benefits fully flowed to the proper customers (the Idaho Jurisdiction as a whole and the irrgation class specifically). From the Irrgator's perspective, it is believed that the jurisdictional revenue increase of3.1 % to the non-contract customers as specified in the Stipulation, with an increase to the Irrgation class of 1.73 %, is a reasonable result given the varety of factors and information considered during the course of this case. This is not to say that any of RMP's filing or methodology employed is appropriate for future use, simply that the "black box" settlement proposed produced an acceptable result for purposes of this case. IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT OF STIPULATION - 4 The lIP A believes that the proposed settlement is in the best, overall interest of all paries and that the terms ofthe Stipulation are fair, just and reasonable. The lIP A urges that the Commission accept the Stipulation as proposed. DATED this 25th day of Februar, 2009. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED BY~*fur)ß/ Idaho Irrgation Pumpers Assn., Inc. IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT OF STIPULATION - 5 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 25th day of Februar, 2009, I sered a tre, correct and complete copy of the foregoing document, to each of the following, via the method so indicated: Jean D. Jewell, Secretar Idaho Public Utilties Commission P.O. Box 83720 472 W. Washington Street Boise, Idaho 83720-0074 j j ewell(ipuc.state.id. us U.S. Mail/Postage Prepaid E-mail Facsimile Overght Mail X Hand Delivered Ted Weston PacifiCorp/dba Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake City, Utah 84111 ted. weston(ipacificorp.com X U.S. Mail/Postage Prepaid X E-mail Facsimile Overnight Mail Hand Delivered Daniel Solander PacifiCorp/dba Rocky Mountain Power 201 S. Main Street, Suite 2300 Salt Lake City, Utah 84111 Daniel.solander(ipacificorp.com X U.S. Mail/Postage PrepaidX E-mail Facsimile Overight Mail Hand Delivered Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington P.O. Box 83720 Boise, Idaho 83720-0074 scott. woodbur(ipuc.idaho. gov X U.S. Mail/Postage PrepaidX E-mail Facsimile Overight Mail Hand Delivered Randall C. Budge Racine Olson Nye Budge & Bailey, Chd 201 E. Center P.O. Box 1391 Pocatello, Idaho 83204-1391 rcb(iracinelaw.net U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail X Hand Delivered Katie Iverson Brubaker & Associates 17244 W. Cordova Cour Surprise, AZ 85387 kiverson(iconsu1tbai.com X U.S. Mail/Postage Prepaid X E-mail Facsimile Overnight Mail Hand Delivered IDAHO IRGATION PUMERS ASSOCIATION, INC.'S COMMNTS IN SUPPORT OF STIPULATION - 6 Electronic Copies Only James R. Smith Monsanto Company P.O. Box 816 Soda Springs, Idaho 83276 Jim.r .smith(imonsanto.com Brad M. Purdy 2019 N. 17th Street Boise, Idaho 83702 bmpurdy(ihotmail.com ConleyE. Ward Michael C. Creamer Givens Pursley LLP 601 W. Banock St. P.O. Box 2720 Boise, Idaho 83701-2720 cew(igivenspursley.com Denis Paseau, Ph.D. Utility Resources, Inc. 15000 Liberty St. SE, Suite 250 Salem, OR 97302 dpeseaulÊexcite.com x x X X X X X E-mail Hand Delivered U.S. Mai1/Postage Prepaid E-mail Facsimile Overght Mail Hand Delivered Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overnight Mail Hand Delivered Hand Delivered U.S. Mail/Postage Prepaid E-mail Facsimile Overght Mail Hand Delivered ¿-~~/ Eli IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S COMMENTS IN SUPPORT OF STIPULATION - 7