20241125IIPA 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: [phone]
Facsimile: [phone]
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
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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
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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)
[e-mail] ® Electronic Mail (Email)
Brad Heusinkveld ❑ U.S. Mail
Idaho Conservation League ❑ Hand Delivered
710 N. 6t' St. ❑ Overnight Mail
Boise, ID 83702 ❑ Telecopy(Fax)
[e-mail] ® 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)
[e-mail].g_ov ❑ Electronic Mail (Email)
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.RESPONSE TO THE FIRST PRODUCTION REQUESTS OF
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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