200305301st Request of ID Irrigation Pumpers to Idaho Power.pdf

Eric L. Olsen (ISB# 4811)
Racine, Olson, Nye, Budge & Bailey,
Chartered
O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204-1391
Phone: [phone]
Fax: [phone]
E-mail: elo(fYracinelaw.net
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Attorneys for Idaho Irrigation Pumpers Association
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO IMPLEMENT A POWER
COST ADJUSTMENT (PCA) RATE FOR
ELECTRIC SERVICE FROM MAY 16, 2003
THROUGH MAY 15, 2004.
Case No. IPC-03-
FIRST DATA REQUESTS OF THE IDAHO IRRIGATION
PUMPERS ASSOCIATION TO
IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, by and through their attorneys, hereby
submit its First Data Requests to IDAHO POWER COMPANY, as follows:
Has the true-up been consistently applied to each of the following rate schedules: 1 , 3 , 7
, 15 , 19 , and Special Contract rates 26, 28, 29 and 30? If it has not been
consistently applied, please provide an explanation of the differences, the target kWh involved, and the
target revenues involved.
Was the true-up ever applied to the FMC "Special Purchases
Was the true-up ever applied to anything in addition to that listed in requests 1 and 2
above?
FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY - 1
In the Company s May 12 2003 Reply Comments in this case at page 13 , there is a
reference to $13 million being under-collected in the last two years. Please supply all calculations and
assumptions used to derive this figure. If the calculations are contained in a spreadsheet, please provide
this in electronic form as well as hard copy.
In the bottom portion of page 1 of Attachment 1 to the Company s May 12 2003 Reply
Comments in this case is a listing of True-up dollars and kWh. Please provide this information in electronic
format, as well as all supporting documentation. Please provide an explanation of any assumption that went
into these calculations or the choice of data that was utilized.
If not already provided in "5" above, please provide (in electronic format) by PCA period
the monthly (or partial month) actual usage level of each rate schedule used to derive the total PCA period
actual usage kWh listed in the center column of Attachment 1, page 1.
Please provide any documents in the Company s possession that contain an overview of
each kWh Normalization Process currently being used by the Company.
Please provide a copy (electronically and in hard copy) of the normalization equations used
for each of the Company s rate schedules from 1993 to the present.
Please provide a copy (electronically and in hard copy) of all input data used to normalize
sales levels for each rate schedule for each year ITom 1993 through 2002 as well as the resulting normalized
sales levels.
10.Please provide an explanation of any changes made to any of the Company s kWh
normalization procedures since 1993.
11.Please provide an explanation of why the normalized sales for the Idaho jurisdiction have
been on the decline over the last few years.
DATED this L-gMday of May, 2003.
RACINE, OLSON, NYE, BUDGE & BAILEY
CHART
FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7:'i ay of May, 2003, I mailed a true and correct copy
of the foregoing document to each of the following:
Commission Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
Gregory W. Said
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
FIRST REQUEST FOR INFORMATION AND PRODUCTION OF DOCUMENTS
TO IDAHO POWER COMPANY - 3