200312172nd Request of Irrigation Pumpers to Idaho 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]
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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 SECOND
DATA REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc., by and through their attorneys
hereby submit this Second Data Requests to IDAHO POWER COMPANY as follows:
20.The expenses for FERC Account 557 seem to fluctuate widely from year to year~ Please
provide an explanation of what occurred in each year from 1992 to the present that caused such dramatic
SWIngs.
21.The expenses for FERC Account 502 seem to fluctuate widely from year to year. Please
provide an explanation of what occurred in each year from 1992 to the present that caused such dramatic
SWIngs.
22.Since 1994 the expense associated with Account 500 (Supervision) have been generally
decreasing.
What has caused this decreasing trend?
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY-
The actual expenses for the first six months of the test year are three times what the
projected expenses are for the remainder of the test year. For the first six months of2003, please provide
a detailed explanation as well as all supporting documents regarding why these expenses increased so
23.
dramatically over this timeframe.
Since 1994 the expense associated with Account 512 (Boiler Maintenance) have been
generally steady. Please provide an explanation of what changes occurred in the test year to have these
expenses approximately 50% greater than the long-term average.
24.Since 1997 the expense associated with Account 536 (Water for Power) have been
generally decreasing. What has caused this decreasing trend and please provide an explanation of what
changes occurred in the test year to have these expenses realize such a dramatic increase.
25.
26.
years?
27.
test year?
28.
test year?
29.
Why has Account 586 (Meters) increased so dramatically in the last couple of years?
Why has Account 904 (Uncollectib1es) increased so dramatically in the last couple of
What has caused the substantial increase in Account 924 (property insurance) during the
What has caused the substantial increase in Account 926 (Employee Benefits) during the
What has caused the substantial increase in Account 935 (Maintenance of General Plant)
30.
during the first six months of the test year?
Please provide a copy of each Marginal Cost Study that has been presented to the
Commission or the Commission Staff for each year since 1995.
31.With respect to the marginal demand costs used in Exhibit 40, what is the exact source of
these numbers (historic/current contract values, projections, current values of indexed prices, etc.
32.With respect to the marginal energy costs used in Exhibit 40, what is the exact source of
these numbers (historic/current contract values, projections, current values of indexed prices, etc.)? Are
these prices for firm energy?
33.Please provide a copy ofthe Company s 2002 Integrated Resource Plan (IRP). Please
identify specific areas in this Plan that identify the months of capacity deficit.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 2
34.
each peak occurred?
With respect to the demand values listed on Exhibit 40, what was the date and time that
35.
36.
following:
For each ofthe last five years, what was the date and time of the monthly system peak?
During the hour of the monthly peak for each of the last five years, please provide the
How many megawatts of generation were out of service for planned maintenance?
How much electricity was generated from Company owned hydro?
How much electricity was purchased from Company owned thermal power?
How much electricity was purchased from QF suppliers?
How much electricity was brought in through exchanges?
How much (non-QR) electricity was purchased and at what price? Please list each
transaction separately, stating name of seller, MWH purchased, purchase price, and type of purchase (LF
RQ, SF, OS, etc.
transaction separately, stating name of purchaser, MWH sold, sale price, and type of sale (LF, RQ, SF
How much electricity was sold off-system and at what price? Please list each
, etc.
37.
the units being maintained, and the megwatts being taken out of service?
F or each ofthe next three years, what are the dates of scheduled maintenance, name of
38.
39.
Please provide copies of all IRP's filed by the Company between 1995 and 2002.
With respect to the system, as well as class, demands and energies listed on Exhibit 40
ifthe values listed are not actual (or directly derived from load research data for that exact hour), please
provide a description as well as all data used to derive the values listed in Exhibit 40.
40.
for a Hidden Springs Substation. Please provide:
On page 5 of the Brilz workpapers is a listing for a Sailor Creek Substation as well as one
The hourly load data for each substation for 2002.
The approximate percentage of each substation (percent customers, percent peak
demand, and percent energy) used by various customer classes.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 3
41.On page 12 ofBrilz workpapers there are various values listed under the column entitled
DA364". Please answer the following:
153 854,405?
What is the source of the figure under Ration Computation for Primary of
Please describe the methodology of dividing Acct. 364 into its primary component
(153 854 405). Please give examples.
If a pole or tower carried both primary and secondary lines, what portion of the
pole would be assigned to the primary component (153 854 405)?
If a line transformer were on a pole or a tower such that the primary line ends at
this particular pole and the secondary line starts at this pole, what portion ofthe pole would be assigned
to the primary component (153 854,405)?
If a pole or tower were used as part of a Service Drop, would it be assigned to
Account 364 or Account 369?
Please provide a copy of the study that developed the System Customer
Component of36.25% and the System Demand Component of63.75%.
On page 12 of the workpapers, the total Secondary Direct Assignment is listed as
$12 208 967 while the figure on Exhibit 39 page 3 line 87 is $13 360 114. Please reconcile these two
figures.
42.How many miles of primary and secondary conductor are found in the Idaho Jurisdiction?
43.
Please describe how this figure is derived.
On page 13 ofBri1z workpapers there are various values listed for Account 368. Please
answer the following:
What is the source ofthe figures 51 716 055 and 204 373 052?
Please describe the methodology of dividing Acct. 368 into its primary component
(47 529 633). Please give examples.
Please provide a general explanation regarding what is meant by the primary
component versus the secondary component when it comes to line transformers.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 4
How do the values on this page of$11 4 73 741 for Direct Assignment relate to
figure on Exhibit 39 page 3 line 90 of$12 555 559 for direct assignment of line transformers?
How do the values on this pageof$176 355 283 for Other Secondary relate to
figures on Exhibit 39 pager 3 lines 91 plus 92 of$123 026 789 and $69 956,409 respectively (totaling
$192 983 198) for Other Secondary for line transformers?
44.On page 14 ofBrilz workpapers there are various values listed for Account 369. Please
answer the following:
How were the figures of$203 .87 and $287.83 for the average cost of single-phase
and three-phase customers derived? Please supply supporting study.
What do the figures of$203. 87 and $287.83 for the average cost of single-phase
and three-phase customers represent as far as the average length of a Service?
What is the average length of a Service for an Irrigation customer?
45.Please provide a copy of any cost -of-service studies the Company may have supplied to
the Commission or Commission Staff since the last rate case.
DATED this 15th day of December, 2003.
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
By ~M to ~2rRANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th 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 ofthe following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline(illidahopower.com
mmoen(illidaho power.com
John R. Gale
VP-Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: rgale(illidahopower.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: Inordst(illpuc.state.id.
wstutzm(illpuc. state.id. us
Peter J. Richardson, Esq.
Richardson & O'Leary
99 E. State St., Suite 200
O. Box 1849
Eagle, Idaho 83616
E-mail: peter(illrichardsonand oleary. com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
E-mail: dreading(illmindspring. com
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
E-mail: yanke1(illattbi.com
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
E-mail: lawrence.gollomp(illhq.doe.gov
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Mail: dgoinspmg(illaol.com
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 6
Dean 1. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
E-mail: joe(illmcdevitt-miller.com
Jeremiah J. Healy
United Water Idaho, Inc.
O. Box 190420
Boise, Idaho 83719-0420
E-mail: jerry.healy(illunitedwater.com
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
E-mail: billeddie(illrmci.net
Nancy Hirsh
NW Energy Coalition
219 First Ave. South, Suite 100
Seattle, Washington 98104
E-mail: nancy(illnwenergy.org
Conley E. Ward
Givens Pursley LLP
601 W. Bannock St.
O. Box 2720
Boise, ID 83701-2720
E-mail: cew(illgivenspursley.com
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste 250
Salem, Oregon 97302
E-mail: dennytemp(illyahoo.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdy(illhotmail.com
Michael Karp
147 Appaloosa Lane
Bellingham, Washington 98229
E-mail: michael(illawish.net
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
37 E. Seventh St., Suite 2110
Cincinnati, OH 45202
E-mail: mkurtzlaw(illaol.com
~ ~,.
RANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 7