200312011st Response of Idaho Power to Staff.pdf

BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
F?ECEIVED
FILED
'.~
...J
2003 NOV 2~ PM 3: 53
iJliLL:
UTlUTIES C0t1r11 SSION
Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS INTERIM)
AND BASE RATES AND CHARGES FORELECTRIC SERVICE.
CASE NO. IPC-03-
IDAHO POWER COMPANY'
RESPONSE TO FIRST
PRODUCTION REQUEST OF
COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the First Production Request of the Commission Staff to Idaho Power
Company dated October 29,2003, herewith submits the following information:
REQUEST NO.1: Please provide a narrative description of the analysis
performed to determine normalized test year power supply expenses and revenues.
RESPONSE TO REQUEST NO.1: For purposes of determining net
power supply expenses for the test year, the AURORA model was used. Two separate
power supply simulations were run , one that reflects changes in net power supply
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page
expense determinants that have occurred since the last test year (1993); and a second
simulation that reflects these changes and known and measurable power supply
adjustments, as well. Both simulations are based on the same test year load and the
same hydro data.
For each of the two simulations , the model was run from an Excel macro
that the Company contracted with EPIS to develop. The macro allows the user to run
up to 76 hydro conditions, grouped into five pentiles , and to specify a range of gas
prices for each pentile. For each hydro year within a pentile , the macro develops a gas
price from within the specified range. The model was run for76 hydro conditions
grouped into five pentiles , and the results were averaged. The hydro conditions
corresponding to the years 1928 through 2003, were grouped based on the level of
modeled annual hydro generation on the Idaho Power Company system for the test
year, using the Company s hydro generation model. Because the region does not
model the period of record from 1928 through 2003, the hydro data provided by EPIS
was expanded to encompass 76 conditions for all areas in the northwest. The range of
gas prices applicable to each pentile was developed by spreading the overall gas price
range to hydro conditions using hydro generation as the basis for interpolation. The
minimum and maximum for each pentile was then identified.
The specific elements of net power supply expense that are modeled in
AURORA are fuel costs , market purchased power costs and surplus sales revenue.
Certain elements of net power supply expense are not modeled within AURORA and
are , therefore, handled after the simulations are completed. They are the fixed costs of
fuel at Danskin, the transmission cost associated with surplus sales , and , with respect
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 2
to the simulation with known and measurable adjustments, the cost of the PPL-
Montana purchase.
The response to this request was prepared by Patty S. Nichols , Rate
Analyst, Pricing and Regulatory Services, Idaho Power Company, in consultation with
Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO.2: Please provide all input data sets in electronic format
used to make the two Aurora model runs that produced the results contained in
Company Exhibits 32 and 33. Also provide any macros, spreadsheets or other
executable code used to compile input or output data or to run the model or associated
spreadsheets. All spreadsheets should be in Excel 2000 format.
RESPONSE TO REQUEST NO.2: Because Staff has a license for the
Aurora model , the following models , spreadsheets and macros have previously been
provided to Staff:
Aurora Version 6.
Original Excel Macro Output (read only)
a ID Macro Revised August 7 Tiber PPL 0812
a ID Macro Revised August 7 WITHOUT Tiber PPL 0813
Executable Excel Macros (read/write) and Associated Aurora Files
COpy 3 ot ID Macro Revised August 7 Tiber PPL 0812
With Tiber & PPL A.apt
Output Macro 8.7 With Tiber & PPL.mdb
COpy 3 OF ID Macro Revised August 7 WITHOUT Tiber PPL 0813
Without Tiber & PPL A.apt
Output Macro 8.7 WITHOUT Tiber PPL
North American DB 6.mdb
Run Instructions
Exhibit 32
Exhibit 33
The response to this request was prepared by Patty S. Nichols, Rate
Analyst, Pricing and Regulatory Services , Idaho Power Company, in consultation with
Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 3
REQUEST NO.3: Please provide a narrative description of the weather
normalization performed to determine normalized test year loads used in power supply
modeling and in rate design as energy billing determinants. Please include a copy of
the load research study used by the Company and all spreadsheets, data, output or
other analysis used in the normalization process. Cite the source of the input data and
list any assumptions used in the analysis. All spreadsheets should be in Excel 2000
format. If the model used is not an Excel Spreadsheet model , please provide a copy of
all input, output and intermediate results.
RESPONSE TO REQUEST NO.3: Idaho Power Company did not use a
load research study in the preparation of weather-normalized loads in this case. The
weather-normalization is not performed in Excel. A narrative description of the weather-
normalization process , along with regression data and analyses of the weather-
normalization process, is contained in a document that is voluminous and as such will
be made available for review in a discovery room at Idaho Power. Any party desiring to
review documents in the discovery room should call Myrna Aasheim at 388-3558 to
arrange a time for the room to be made available.
The response to this request was prepared by Gregory W. Said, Director
Revenue Requirement, Pricing and Regulatory Services, Idaho Power Company, in
consultation with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO.4: For Company Exhibits 30 through 61 , A-S and A-
please provide all spreadsheet exhibits in Excel 2000 format. These should include but
not be limited to the executable Jurisdictional Separations Study, the Class Cost of
Service Study and the rate design spreadsheet models used by the Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 4
RESPONSE TO REQUEST NO.4: The enclosed CD labeled "First
Production Request of Staff, Request No.4" includes Exhibit Nos. 21-, 50, and 61.
Due to the format of the Excel spreadsheets, it is not possible to isolate Exhibit Nos. 30
and 31 from Exhibit Nos. 21-29. Exhibit Nos. 48 , 49 , 51 through 60 , and page 1 of
Exhibit No. 50 are not available in Excel format. Also included on the CD is the macro
FUNCOST. This macro facilitates the printing of the various sections of the Class Cost-
of-Service Study included in the file Exhibit - 41 - 42.
The response to this request was prepared by Maggie Brilz, Pricing
Director, Pricing and Regulatory Services , Idaho Power Company, in consultation with
Barton L. Kline , Senior Attorney, Idaho Power Company.
DATED at Boise, Idaho , this 26th day of November, 2003.
IcY
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of November, 2003 , I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF upon the
following named parties by the method indicated below, and addressed to the following:
Lisa D. Nordstrom
Weldon B. Stutzman
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
- U.S. Mail
Overnight Mail
FAX [phone]
Randall C. Budge
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey
O. Box 1391; 201 E. Center
Pocatello, ID 83204-1391
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX [phone]
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX [phone]
Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle , 10 83616
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX [phone]
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise , 10 83703
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX [phone]
Lawrence A. Gollomp
Assistant General Counsel
U. S. Department of Energy
1000 Independence Avenue , SW
Washington, D.C. 20585
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX [phone]
Dale Swan
Exeter Associates , Inc.
5565 Sterret Place , Suite 310
Columbia, MD 21044
Hand Delivered
~ U.S. Mail
Overnight Mail
FAX [phone]
CERTIFICATE OF SERVICE , Page
Conley E. Ward
Givens, Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise , 10 83701-2720
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
Dennis E. Peseau , Ph.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem , OR 97302
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, 10 83701
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
Jeremiah Healy
United Water Idaho, Inc.
O. Box 190420
Boise , 10 83719-0420
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
William M. Eddie
Advocates for the West
O. Box 1612
Boise, 10 83701
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
Nancy Hirsh
NW Energy Coalition
219 First Ave. South , Suite 100
Seattle, WA 98104
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise ID 83702
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
Michael Karp
147 Appaloosa Lane
Bellingham , WA 98229
Hand Delivered
----2L- U.S. Mail
Overnight Mail
FAX [phone]
(1M~
BARTON L. KLINE
CERTIFICATE OF SERVICE , Page 2
IPC- E-O3-
First Production Response of Qwest to Staff
Request No.4 on diskette