200312303rd Request of ID Irrigation Pumpers to ID Power.pdf

t~ECEiVED 12)
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]
( ;U~L
zaD3 DEC 30 Mi fO:
, .- '. -
1'-'UTiL illES' CcJf'i~'1ISS!ON
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 THIRD
DATA REOUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys
hereby submit this Third Data Requests to IDAHO POWER COMPANY as follows:
46.With respect to the Company s response to Staff Request 15, please answer the following:
Please provide similar data from January 1997 through December 2000.
Assuming that the revenues listed on these pages include PCA revenues, what was
the general PCA rate in effect between January 1997 and the present?
Assuming that the revenues listed on these pages include PCA revenues, what was
the PCA rate for irrigation customers in effect between January 1997 and the present?
What was the billing demand for the Idaho irrigation customers for each month
between January 1997 and the present?
IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY -
What was the number ofbills rendered (as opposed to meter count) for the Idaho
irrigation customers for each month between January 1997 and the present?
The meter count data in Response to Staff Request 15 for the irrigators in the Idaho
Jurisdiction averages 15,421 during the months of2003 that were provided. Please reconcile these
monthly numbers with the "2003 Avg. Number of Customers" of13 517 listed on Exhibit 43, page 1 , line
7 for Schedule 24 customers.
The meter count data in Response to Staff Request 15 for residential customers
in the Idaho Jurisdiction averages 334 718 during the months of2003 that were provided. Please reconcile
these monthly numbers with the "2003 Avg. Number of Customers" of335 6051istedonExhibit43, page
, line 1 for Schedule 1 customers. Explain why these two values are so close while there is such a large
divergence in the similar numbers for the irrigators.
47.If not previously supplied in response to Irrigator Request 33 , please supply a copy of all
appendices to the Company s 2002 Integrated Resource Plan.
48.As a part ofthis case, the Company has supplied workpapers associated with its sales
normalization calculations. As a part of those workpapers there was what appears to be model input data
for the "irrigation-Southern Operating Center." Please provide the following:
For April 1986 there is listed under "Southsales the figure of3489.051O3. Is this
figure the result oftaking the total irrigation sales for the Southern Operating Center for April 1986 and
dividing by the number of irrigation customers in that region fortheyearof3 880? Ifthis is not how this
figure was developed, please explain what this figure represents and how it was developed.
In an earlier section of the document there are listed for "Irrigation-Southern
Operating Center" monthly values for "actual"
, "
fitted", and "residual". Do the "fitted" values come out of
the equation that is used to provide normalized usage data in this case? If not, what further adjustments
are made to the "fitted" data before it is used for purposes of normalizing usage data for this case?
What customer count data is used for each of the five regions for irrigation load for
purposes of normalizing irrigation 10ad in this case?
IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 2
Does the Company have available the necessary data to calculate the "fitted"
irrigation load for January 200 1 forward? If so, why was this data not calculated/used? Ifthe Company
does not have all of the necessary data available, what data is missing?
What customer count data is used for each area of residential load for purposes
of normalizing residential load in this case?
What is the "System Residential Data ? Is it just the Idaho residential customer
the entire system, or what?
System Residential Data" contains an input variable listed under "USEPC" of
57213 for January 2001. Response to Staff Request 15 lists the Total Company residential usage for
January 2001 as 518 642 696 kWh and the total number of residential meters as 328 602 for an average
use per residential meter of 1.57833. Please reconcile the difference between these two "usage per
customer" figures.
In "Tables of Adjustments and Weather Deviations" under the table labeled
System Irrigation Weather Adjustment" there is an actual sales figure listed of 464 508 for July 2003.
Please reconcile this figure with that of 490 151 MWH for the Idaho Jurisdiction listed in the Response to
Staff Request 15 for July 2002.
Please explain the source of the data for the "actual sales" figures contained in
Tables of Adjustments and Weather Deviations" under the table labeled "System Irrigation Weather
Adjustment" when these tables were developed before all of the 2003 data could have been collected.
DATED this 29th day of December, 2003.
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
RANDALL C. BUDG
IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 29th day of December, 2003, I served by U. S. Mail, postage
prepaid, and/or bye-mail a true and complete copy of the 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(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: yankel(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(illao1.com
IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 4
Dean J. 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(illhotmai1.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(illao1.com
IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 5