Loading...
HomeMy WebLinkAbout20241125IIPA to FEA 1-4.pdf RECEIVED Monday, November 25, 2024 IDAHO PUBLIC Eric L. Olsen(ISB#4811) UTILITIES COMMISSION ECHO HAWK& OLSEN, PLLC 505 Pershing Ave., Ste. 100 P.O. Box 6119 Pocatello, Idaho 83205 Telephone: (208) 478-1624 Facsimile: (208)478-1670 Email: elo(a)echohawk.com Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION CASE NO. IPC-E-24-07 OF IDAHO POWER COMPANY TO INCREASE RATES FOR ELECTRIC IDAHO IRRIGATION PUMPERS SERVICE TO RECOVER COSTS ASSOCIATION, INC.'S RESPONSE ASSOCIATED WITH INCREMENTAL TO THE FIRST SET OF DATA CAPITAL INVESTMENTS AND CERTAIN REQUESTS OF FEDERAL ONGOING OPERATIONS AND EXECUTIVE AGENCIES MAINTENANCE EXPENSES Idaho Irrigation Pumpers Association, Inc., by and through counsel, hereby responds as follows to the Federal Executive Agencies First Production Request to Idaho Irrigation Pumpers Association, Inc. FEA REQUEST NO. 1: On page 2, lines 18-20, of Dr. Kaufman's Direct Testimony, he states "...it may be appropriate to place greater weight on winter demand peaks because winter demand is more costly to serve." Please provide all data, studies, analyses, and explanations to support this statement. IIPA RESPONSE TO FEA REQUEST NO. 1: 1. Idaho Power services its incremental capacity needs through battery storage. The load carrying capacity of battery storage is higher in summer than winter. Battery ELCC is lower in winter because winter peak needs to have a longer duration than summer peak. The figures below illustrate the difference between summer and winter ELCC. The lower ELCC of winter storage means that a larger nameplate capacity battery is needed IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 1 CASE NO.IPC-E-24-07 to serve winter demand relative to summer demand.A larger battery is more costly than a smaller battery. Figure 147.Summer storage ELCC 100% —2hr Bat ; 80% CL i -4hr Boa E 60% `0 —bhr BNt V 40% V W 20% —10hr PSH 0% 100 300 500 700 900 1,100 1,300 1,500 1,700 1,900 Nameplate MW added Figure 148.Winter storage ELCC 100 2hr Batt 80" a u E 4hr Batt c 60"` 0 V 40% —6hr Batt —1 Oh,PSH 0% 100 300 500 700 900 1,100 1,300 1,500 1,700 1,900 Nameplate MW added FEA REQUEST NO. 2: On page 3, lines 1-2, of Dr. Kaufman's Written Testimony, he states "...all customers within a margin of error of 5 percent should receive similar rate increases." a. Please explain what is meant by"margin of error" as used in Dr. Kaufman's testimony. b. Please provide all data, studies, calculations, statistical analysis, and explanations to support the view that cost of service studies have a 5 percent margin of error. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 2 CASE NO.IPC-E-24-07 c. Please provide any examples of where this measure of"margin of error"has been used in a rate case proceeding and any orders in which it has been adopted or approved. IIPA RESPONSE TO FEA REQUEST NO. 2: 2a. Margin of error refers to the distance of revenues from cost of service, expressed as a percentage, within which revenue is not significantly different from cost of service. 2b. The proposed margin of error of 5 percent reflects an error that other Commissions have found to be an appropriate level of margin of error for the purpose of applying uniform rate increases. The Direct Testimony of Larry Blank Table 2,demonstrates that cost of service studies are highly sensitive to chosen inputs. 2c. Washington Utility and Transportation Commission Docket UE-152253 Order 12 provides an example where a Commission states that cost of service studies have a margin of error of 5 percent and adopt a uniform rate spread on the basis of schedules being within the margin of error. See paragraphs 225 and 229. The Supreme Court of Idaho has found that "cost of service is but one criterion among many for consideration in forming a basis for rate differentiation between classes of service and between classifications of customers within a certain schedule."' The Idaho PUC has found that"All cost-of-service studies suffer from common defects. They attempt to reduce a dynamic system to a static one for purposes of study and thereby omit important considerations, and their results vary according to their originators' subjective assumptions underlying their objective arithmetic. We do not belittle the value of cost-of-service studies for rate setting purposes. But the limitations of the studies should be stated so that the results can be used with an awareness of their limitations. ... we recognize the subjective assumptions underlying all cost-of-service studies and the inevitable errors in any undertaking of such magnitude."IPUC Order No.21365.The IPUC has also found that"A cost- of-service study is an imperfect tool for assigning system and service costs to customer classes. The Commission has previously recognized that cost-of-service 1 Grindstone Butte Mut. Canal Co. v.Idaho Public Utilities Comm., 102 Idaho 175, 179-180(1981) IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 3 CASE NO.IPC-E-24-07 modeling is not an exact science, and that while most generally accepted cost-of- service methods are based on similar principles, they may lead to disparate results and recommendations for class revenue allocation. Thus, the Commission has repeatedly emphasized that a cost-of-service study is not a perfect tool for assigning system and service costs to customer classes." IPUC Order No. 33757 at 27. FEA REQUEST NO. 3: For Table 1 on page 4 of Dr. Kaufman's Written Testimony, please provide all workpapers with source data and formulae used to produce this table in executable, electronic format. IIPA RESPONSE TO FEA REQUEST NO. 3: 3. See the attached file "Attachment 10 - Response to Staff Request No. 3 - Tatum Exhibit No. 4 IIPA.xlsx" FEA REQUEST NO. 4: Please provide any examples from other rate cases in which the "COS Index" as calculated by Dr. Kaufman has been used for the determination of revenue spread and any orders in which this approach has been adopted or approved. IIPA RESPONSE TO FEA REQUEST NO. 4: 4. Idaho COS Index was calculated by IPC in Tatum Exhibit 4, not by Dr. Kaufman. Dr. Kaufman typically evaluates cost of service results using the parity ratio rather than the COS Index. The parity ratio is similar to the COS Index, but provides a more transparent measure of relative cost because it accounts for instances where system revenue under or over recovers system costs. The parity ratio is used in Washington Utility and Transportation Commission Docket UE-152253 Order 12 paragraphs 225 to 229. The Commission has considered the cost of service index and approved a uniform rate increase in IPUC Order No. 29790. IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 4 CASE NO.IPC-E-24-07 DATED this 25th day of November, 2024. ECHO HAWK& OLSEN ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 5 CASE NO.IPC-E-24-07 CERTIFICATE OF SERVICE I HEREBY CERTIFIY that on this 25th day of November, 2024, I served a true, correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Response to the First Production Requests of FEA to each of the following, via the method indicated below: Monica Barrios-Sanchez, Commission Secretary ❑ U.S. Mail Idaho Public Utilities Commission ❑ Hand Delivered P.O. Box 83720 ❑ Overnight Mail Boise, ID 83720-0074 ❑ Telecopy(Fax) monica.barriossanchezgpuc.idaho.gov ® Electronic Mail (Email) Chris Burdin ❑ U.S. Mail Deputy Attorney General ❑ Hand Delivered Idaho Public Utilities Commission ❑ Overnight Mail P.O. Box 83720 ❑ Telecopy(Fax) Boise, ID 83720-0074 ® Electronic Mail (Email) chris.burdingpuc.idaho.gov Lisa D. Norstrom ❑ U.S. Mail Donovan E. Walker ❑ Hand Delivered Megan Goicoechea Allen ❑ Overnight Mail Idaho Power Company ❑ Telecopy(Fax) 1221 W. Idaho Street (83702) ® Electronic Mail (Email) PO Box 70 Boise, ID 83707-0070 lnordstromgidahopower.com dwalker(a),idahopower.com mgoicoecheaallengidahopower.com dockets(aidahopower.com Tim Tatum ❑ U.S. Mail Connie Aschenbrenner ❑ Hand Delivered Matt Larkin ❑ Overnight Mail Idaho Power Company ❑ Telecopy(Fax) 1221 W. Idaho Street(83702) ® Electronic Mail (Email) PO Box 70 Boise, ID 83707-0070 ttatutngidahopower.com caschenbrennergidahopower.com mlarkinkidahopower.com IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 6 CASE NO.IPC-E-24-07 Lance Kaufman, Ph.D. ❑ U.S. Mail Idaho Irrigation Pumpers Association, Inc. ❑ Hand Delivered 2623 NW Bluebell Place ❑ Overnight Mail Corvallis, OR 97330 ❑ Telecopy(Fax) lance@ae isg insi ht.com ® Electronic Mail (Email) Peter J. Richardson ❑ U.S. Mail Richardson, Adams, PLLC ❑ Hand Delivered Industrial Customer of Idaho Power ❑ Overnight Mail 515 N. 27th St. ❑ Telecopy(Fax) P.O. Box 7218 ® Electronic Mail (Email) Boise, ID 83702 geter(&richardsonadams.com Dr. Don Reading ❑ U.S. Mail Industrial Customer of Idaho Power ❑ Hand Delivered 280 S. Silverwood Way ❑ Overnight Mail Eagle, ID 83616 ❑ Telecopy(Fax) dreading(&mindspring com ® Electronic Mail (Email) Matthew Nykiel ❑ U.S. Mail Attorney for Idaho Conservation League ❑ Hand Delivered 710 N. 6th St. ❑ Overnight Mail Boise, ID 83702 ❑ Telecopy(Fax) matthew.Liykiel@gmail.com ® Electronic Mail (Email) Brad Heusinkveld ❑ U.S. Mail Idaho Conservation League ❑ Hand Delivered 710 N. 6t' St. ❑ Overnight Mail Boise, ID 83702 ❑ Telecopy(Fax) bheusinkveld@idahoconservation.org ® Electronic Mail (Email) Peter Meier ❑ U.S. Mail U.S. Department of Energy ❑ Hand Delivered 1000 Independence Ave., S.W. ❑ Overnight Mail Washington, D.C. 20585 ❑ Telecopy(Fax) peter.meier@hq.doe.g_ov ❑ Electronic Mail (Email) IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 7 CASE NO.IPC-E-24-07 Emily W. Medlyn ❑ U.S. Mail U.S. Department of Energy ❑ Hand Delivered 1000 Independence Ave., S.W. ❑ Overnight Mail Washington, D.C. 20585 ❑ Telecopy(Fax) Emily.medlynghq.doe. og_v ® Electronic Mail (Email) Jim Swier ❑ U.S. Mail Micron Technology, Inc. ❑ Hand Delivered 8000 South Federal Way ❑ Overnight Mail Boise, ID 83707 ❑ Telecopy(Fax) iswier(&micron.com ® Electronic Mail (Email) Austin Rueschhoff ❑ U.S. Mail Thorvald A. Nelson ❑ Hand Delivered Austin W. Jensen ❑ Overnight Mail Kristine A.K. Roach ❑ Telecopy(Fax) Holland& Hart, LLP ® Electronic Mail (Email) Micron Technology, Inc. 555 17th Street Suite 3200 Denver, CO 80202 darueschhoff(a,hollandhart.corn tnelson(a,hollandhart.com awj ensen(&hollandhart.com karoach&hollandhart.com acleenhollandhart.com mamcillenghollandhart.com Ed Jewell ❑ U.S. Mail Deputy City Attorney ❑ Hand Delivered Boise City Attorney's Office ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) PO Box 500 ® Electronic Mail (Email) Boise, ID 83701-0500 eiewellkcityofboise.org boisecityattomey(i,,cityofboise.org Steven Hubble ❑ U.S. Mail Climate Action Senior Manager ❑ Hand Delivered Boise City Dept. of Public Works ❑ Overnight Mail 150 N. Capitol Blvd. ❑ Telecopy(Fax) P.O. Box 500 ® Electronic Mail (Email) Boise, ID 83701-0500 shubble(a),cityofboise.org IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 8 CASE NO.IPC-E-24-07 ERIC L. OLSEN IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF FEA—Page 9 CASE NO.IPC-E-24-07