200312031st Request of ID Irrigation Pumpers to ID Power.pdf

Randall C. Budge, ISB No. 1949
Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
HECEIVED 0FILED
Lnn3 DEC - 3 AM 9:
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UTiLITIES COHt11SSIOH
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
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 FOR ELECTRIC SERVICE.
CASE NO. IPC-O3-
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST
DATA REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys
hereby submit this First Data Requests to IDAHO POWER COMPANY as follows:
Please provide the Company s Chart of Accounts.
For all FERC Expense Accounts listed in Exhibit 26, please provide by sub account, by
month, the actual expenses that were incurred :/Tom January 1998 through the most recent month available.
Please provide this information in both hard copy as well as an electronic version.
F or all FERC Expense Accounts listed on Exhibit 26, please provide by account (and sub
account if available) the annual budgeted amount for each year between 1998 through 2002, as well as for
each month of2003. Please provide similar budget information for 2004 and indicate if the budget for
2004 has been finalized. Please provide this information in both hard copy as well as an electronic version.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -
Are there any adjustments made in Exhibit 26 or elsewhere in the Company s filing to
remove non-reoccurring expense? Please indicate where these can be found and the magnitude of each
adjustment.
Please provide a copy of all input data to Exhibits 32 and 33 in both hard copy and
electronic format.
For each month since January 1994, please supply the monthly usage of Schedule 24 and
25 customers in the Idaho jurisdiction.
Please provide a copy ofthe Company s FERC Form 1 for 2001 and 2002.
With respect to the Company s Load Research data, please provide for each sample
customer with valid data that was sampled between January 2000 and the most recent month available the
following:
Customer identification number;
Customer rate schedule;
Strata to which it belongs;
Raw hourly usage data;
Raw hourly usage data modified to reflect losses;
On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company s cost of service study in this case;
Please provide copies of the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of service
study in this case.
Please provide for each month :/Tom January 2000 forward a copy of the monthly checks
that the Company makes regarding how well the Load Research sample data reflects the actual population
usage.
10.Please provide for each month :/Tom January 2000 forward a listing of the calendar month
usage for the Schedule 24 and Schedule 25 in the Idaho Jurisdiction.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 2
11.Please provide a copy of any monthly Load Research summary reports that have been
produced between January 2000 and the present.
12.Please provide a copy of the bill :/Tequency distribution for each month of the test year for
Schedules 1 , 7, 9, 19 24 and 25.
13.Please provide a description of the Company s rationale, as well as all supporting
documents, or the basis for setting the summer energy charge forresidential customers 25% higher than
the non-summer energy charge.
14.Referencing page 50 line 12 of the testimony ofBrilz, please supply all justification and data
that supports the approximate 16% differential between summer and non-summer energy costs for
Schedule 19.
15.Referencing page 51 lines 13-16 of the testimony ofBrilz, please supply all justification and
data that supports the 20% differential between summer and non-summer "energy-related costs" for
Schedule 19.
16.Referencing page 52 lines 1-9 of the testimony ofBrilz, please supply all justification and
data that supports the approximate 2.4686 cents "value of seasonal, non time-of-use differentiated summer
energy charge" for Schedule 19.
17.Please provide in electronic format, on an hourly basis, for the period January 1 2001
through the most recent month available the following data:
Total system input;
System input :/Tom Company owned generation (stating hydro, coal, and other
generation separately);
System input :/Tom firm purchases, stating each purchase separately by source and
type of purchase (LF, IF, SF);
The cost of each firm purchase listed in "C" above;
System input :/Tom non- firm and/or economy purchases, stating each purchase
separately;
The cost of each non-firm and/or economy purchase listed in "E" above;
System input :/Tom exchanges into the system, stating each exchange separately;
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 3
System input :/Tom Unit purchases;
Other system inputs, stating for each "other" input the type and the source of the
input;
System losses;
Requirements Wholesale sales (RQ);
Long-term firm Wholesale sales (LF), stating each one separately;
Intermediate-term firm Wholesale sales (IF), stating each one separately;
Short-term firm Wholesale sales (SF), stating each one separately;
Unit sales, Wholesale (LU) or otherwise, stated separately;
Non-firm and/or economy Wholesale sales (OS), stated separately;
The revenue collected for each hour of each non-firm and/or economy purchased
listed in "P" above;
Exchanges out of the system, stating each exchange separately;
Other system outputs, stating for each "other" output the type and recipient of the
output;
Inadvertent power flows into or out of the system;
The power available (at input level) to supply retail load once Wholesale
Exchange, Wheeling, and Inadvertent has been subtracted;
Losses assigned to each retail jurisdiction;
Losses assigned to wholesale sales;
Total firm retail (non-special contract) load by jurisdiction;
Each firm special contract customer load by jurisdiction. (If need be, use
identification codes to specific individual special contract customer loads.
Interruptible special contract customer load;
aa.Total firm retail (non-special contract) losses (by jurisdiction if applicable);
Total firm special contract losses (by jurisdiction if applicable);bb.
cc.Total interruptible special contract losses.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 4
18.
recent month available) please list for each month:
F or each firm wholesale sale that took place in 200 1 , 2002, and 2003 (through the most
19.
The name of the entity sold to;
The type (FERC classification) of the contract;
The pricing mechanism (fixed, rate schedule, market index, formula, etc.
The amount of energy sold;
The dollars paid for demand charges;
The dollars paid for energy charges; and
The total dollars paid.
most recent month available), please list for each month:
F or each firm wholesale purchase that took place in 2001 , 2002, and 2003 (through the
The name of the entity purchased :/Tom;
The type (FERC classification) of the contract;
The pricing mechanism (fixed, rate schedule, market index, formula, etc.
The amount of energy purchased;
The dollars paid for demand charges;
The dollars paid for energy charges; and
g.
The total dollars paid.
DATED this 2nd day of December, 2003.
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 2nd day of December, 2003, I served by U. S. Mail, postage
prepaid, and/or bye-mail a true and complete copy ofthe foregoing document, to each of the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline~idahopower.com
mmoen~idaho power.com
John R. Gale
VP -Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: rgale~idahopower.com
Lisa Nordstrom
Weldon Stutzman
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, Idaho 83720-0074
E-mail: lnordst~puc.state.id.
wstutzm~puc. state.id.
Peter J. Richardson, Esq.
Richardson & O'Leary
99 E. State St., Suite 200
O. Box 1849
Eagle, Idaho 83616
E-mail: peter~richardsonand oleary. com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
E-mail: dreading~mindspring. com
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
E-mail: yankel~attbi.com
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
E-mail: lawrence.gollomp~hq.doe.gov
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Mail: dgoinspmg~ao1.com
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 6
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
E-mail: joe~mcdevitt-miller.com
Jeremiah 1. Healy
United WaterIdaho, Inc.
O. Box 190420
Boise, Idaho 83719-0420
E-mail: jerry.healy~unitedwater.com
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
E-mail: billeddie~rmci.net
Nancy Hirsh
NW Energy Coalition
219 First Ave. South, Suite 100
Seattle, Washington 98104
E-mail: nancy~nwenergy .org
ConleyE. Ward
Givens Pursley LLP
601 W. Bannock St.
O. Box 2720
Boise, ID 83701-2720
E-mail: cew~givenspursley.com
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste 250
Salem, Oregon 97302
E-mail: dennytemp~yahoo.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdy~hotmai1.com
Michael Karp
147 Appaloosa Lane
Bellingham, Washington 98229
E-mail: michael~awish.net
RANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 7