20240903IIPA to IPC 1-22.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 1
CASE NO. IPC-E-24-07
Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS
ASSOCIATED WITH INCREMENTAL
CAPITAL INVESTMENTS AND CERTAIN
ONGOING OPERATIONS AND
MAINTENANCE EXPENSES
CASE NO. IPC-E-24-07
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.’S FIRST SET
OF DATA REQUESTS
Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its First Data
Requests to Idaho Power Company, pursuant to Commission Rule 225, as follows:
IIPA 1-1: Please refer to “Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit
No. 4” and “Attachment - Response to ICIP Request No. 2”, which indicates that the response to
Staff Request No. 3 does not include underlying workpapers. Please provide all workpapers
underlying the attachments provided in response to Staff Request No. 3.
IIPA 1-2: Please refer to “Attachment - Response to ICIP Request No. 2” tab
“AllocFactor_Input”. Please provide all workpapers used to calculate the values on this tab.
IIPA 1-3: Please provide the following data for each new customer with demand greater than
1 MW that has been energized or is expected to be energized in 2024 or 2025:
a. Rate Schedule
b.Expected annual load
c. Date service began or is expected to begin.
IIPA 1-4: Please refer to “Response to Staff Request No. 35 - Attachment 1 - Load
Forecasting Methodology.pdf” page 5 which states “Individual forecasts of customers with
unique energy service agreements that exceed 20 megawatts (“MW”) in size are provided to
the Company from the customer.” Please provide the 2023, 2024, and 2025 actual and forecasted
load by month and delivery point, for each individually forecasted customer.
RECEIVED
Tuesday, September 3, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 2
CASE NO. IPC-E-24-07

IIPA 1-5: Please refer to “Attachment - Response to ICIP Request No. 2” tab “AS_Table 9”.
Please explain what the 411.4 - Investment Tax Credit Adjustment represents and why it is
appropriate to allocate this cost using the P111P factor.

IIPA 1-6: Please refer to “Attachment 14 - Response to Staff Request No. 3 - Larkin Exhibit
No. 9 - Revenue Growth Offset.xlsx”.
a. How were the 2023 ID kWh Sales calculated? Does the value represent actual
sales, normalized actual sales, 2023 GRC test period sales, or some other measure
of sales?
b. Please explain how the Mill Rate was calculated.
c. Please explain how Incremental 2024 sales were calculated.
d. Please provide supporting workpapers for the hardcoded values in this file.
e. Please provide actual, and weather normalized sales by month and customer class
from 2013 to present.
f. Please provide the most recent load forecast currently in use by IPC’s IRP team.
g. Please provide the load forecast used in IPC’s most recently completed IRP or
IRP update.
h. Please explain the difference between the 2024 sales on this sheet and normalized
energy of 15,032,559,714 kwh in Attachment 9 - Response to Staff Request No. 3
- Application Attachment 3.

IIPA 1-7: Please refer to “Attachment 14 - Response to Staff Request No. 3 - Larkin Exhibit
No. 9 - Revenue Growth Offset.xlsx”.
a. Please confirm that IPC’s revenue forecast only accounts for incremental revenue
attributable to rate base and labor.
b. Please explain why IPC does not include all incremental revenue in the revenue
growth offset.

IIPA 1-8: Please refer to “Response to Request for Production No. 5 - Confidential
Attachment - Capital Projects Completed Thru May 2024 list”.
a. Please explain why the amounts in rows 3616 to 3619 are negative. Is it IPC’s
intention to exclude incremental rate base associated with these types of assets?
b. Please provide each load request indicated in the description for the following
work orders
i. 27599593
ii. 27610080
iii. 27620766
iv. 27620765
v. 27650842
vi. 27586408
vii. 27643697
viii. 27615513
ix. 27621630

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 3
CASE NO. IPC-E-24-07

IIPA 1-9: Please refer to Tatum Direct page 9 line 6 to 20.
a. Please provide the final approved revenue requirement from the 2023 GRC by
component.

IIPA 1-10: Please provide actual 2023 expenses by FERC account and subaccount.

IIPA 1-11: Please provide IPC’s rate base by month from December, 2022 to January, 2024.

IIPA 1-12: Please provide IPC’s results of operations by state for 2022 and 2023.

IIPA 1-13: Please provide IPC’s 2023 and 2024 budget at the most granular level available.

IIPA 1-14: Please refer to “Attachment 3 - Response to Staff Request No. 3 - Larkin
Workpaper 3 - Incremental Plant Determination.xlsx.”
a. Please confirm that IPC’s revenue requirement is based on forecasted 2024 end of
year plant balance. If not confirmed please explain what period is represented in rate
base.
b. Please explain why IPC does not use the 13 month average reported in tab “Elec Plant
In Service” column BT.
c. Does IPC’s revenue growth adjustment reflect annualization of December, 2024
load? If no, please explain how revenue growth is consistent with using end-of-year
2024 plant balances.
d. Please provide the data in columns D and E for 2025.
e. Please identify revenue requirement workpapers supporting the proposed base
revenue of $1,458,265,770.
IIPA 1-15: Please refer to Attachment 1 - Response to Staff Request No. 3 - Larkin
Workpaper 1 - Accumulated Reserve.
a. Please explain how IPC forecasts retirements.
b. Please explain how IPC forecasts salvage.
c. Please explain how IPC forecasts removal costs.
d. Please provide actual retirements, salvage, and removal by FERC account and month
for 2024.
IIPA 1-16: Please provide IPC’s actual and forecasted regulated capital structure by month
from January 31, 2022 to December 31, 2025.

IIPA 1-17: Please refer to Attachment 6 - Response to Staff Request No. 3 - Larkin
Workpaper 6 - Results of Operations Model.xlsx tab “JSS – PF”. Please provide the source for
the hard coded numbers in this sheet.

IIPA 1-18: Please provide workpapers reconciling the forecast estimates in Response to Staff
Request No. 35 with the forecasted energy in “Attachment 9 - Response to Staff Request No. 3 -
Application Attachment 3”.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 4
CASE NO. IPC-E-24-07

IIPA 1-19: Please refer to “Response to Staff Request No. 35 - Attachment 6 – Irrigation”.
a. Please provide all documentation available to IPC regarding the Palmer Z-Index.
b. Please explain why the Palmer Z-Index is assumed to be zero in 2024.
c. Please provide the Palmer Z-index by month from 2002 to present.
d. Please provide the most current forecast of the Palmer Z-index available to IPC.
e. Please provide the calculation of the Weighted Growing Degree Days Base 50
variable.
f. Please explain how weights are calculated for the Weighted Growing Degree Days
Base 50 variable.
g. Please explain the rational for including the Residential Customers Added Per Year
variable. Please include an explanation for why annual additions is preferred over
total customers and provide explain why IPC finds it reasonable to forecast a negative
relationship between residential customer additions and irrigation load.

IIPA 1-20: Please refer to “Attachment 5 - Response to Staff Request No. 3 - Larkin
Workpaper 5 - O&M Labor.xlsx”
a. Please provide the data on tab “Labor Development” column I for 2024 to present.
b. Please provide the data on tab “2023 Actual Payroll-SourcePg1” for 2021, 2022, and
2024 to present.
IIPA 1-21: Please refer to Tatum Direct page 21 lines 3 to 7.
a. Please confirm that IPC is requesting labor costs expected for 2025.
b. Has IPC accounted for revenue growth expected for 2025? If yes, please identify the
associated workpapers. If no, please explain how this is consistent with 2025 labor
costs.

IIPA 1-22: Please refer to the Response to Staff Request 35. Please provide the load forecast
for 2025 by rate schedule.

DATED this 3rd day of September, 2024.
ECHO HAWK & OLSEN

_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 5
CASE NO. IPC-E-24-07

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 3rd day of September, 2024, I served a true, correct
and complete copy of the Idaho Irrigation Pumpers Association, Inc.’s First Set of Data Requests
to each of the following, via the method indicated below:

Monica Barrios-Sanchez, Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]

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Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
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Lisa D. Norstrom
Donovan E. Walker
Megan Goicoechea Allen
Idaho Power Company
1221 W. Idaho Street (83702)
PO Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Tim Tatum
Connie Aschenbrenner
Matt Larkin
Idaho Power Company
1221 W. Idaho Street (83702)
PO Box 70
Boise, ID 83707-0070
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[e-mail]
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 6
CASE NO. IPC-E-24-07

Lance Kaufman, Ph.D.
Idaho Irrigation Pumpers Association, Inc.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]
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Peter J. Richardson
Richardson, Adams, PLLC
Industrial Customer of Idaho Power
515 N. 27th St.
P.O. Box 7218
Boise, ID 83702
[e-mail]
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Dr. Don Reading
Industrial Customer of Idaho Power
280 S. Silverwood Way
Eagle, ID 83616
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Matthew Nykiel
Attorney for Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
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Brad Heusinkveld
Idaho Conservation League
710 N. 6th St.
Boise, ID 83702
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Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 7
CASE NO. IPC-E-24-07

Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart, LLP
Micron Technology, Inc.
555 17th Street Suite 3200
Denver, CO 80202
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[e-mail]
[e-mail]
[e-mail]
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Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]

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Steven Hubble
Climate Action Senior Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST SET OF DATA REQUESTS – Page 8
CASE NO. IPC-E-24-07

_____________________________________

ERIC L. OLSEN