200401054th Request of 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]
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 FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys
hereby submit this Fourth Data Requests to IDAHO POWER COMPANY as follows:
49.The Company s response to Staff Request 85 lists a negative value of$1 577 804 for
Acct. 500 expense for August 2003. Please provide specific detail regarding the reason for this
adjustment(s) and the exact amount of the adjustment(s), not just the net amount.
50.The Company s response to S taffRequest 85 lists a negative value of $1 138 140 for
Acct. 502 expense for August 2003. Please provide specific detail regarding the reason for this
adjustment(s) and the exact amount of the adjustment(s), not just the net amount.
51.The Company s response to Staff Request 85 lists a negative value of$468, 146 forAcct.
512 expense for August 2003. Please provide specific detail regarding the reason for this adjustment( s)
and the exact amount ofthe adjustment(s), not just the net amount.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS TO IDAHO POWER COMPANY - 1
52.On pages 5 through 9 ofthe workpapers provided by Brilz there is a column labeled
Customer Class . Please answer the following:
Upon what basis does the Company classify any of these distribution substations
as belonging to a given customer class?
Upon what basis does the Company classify any of these distribution substations
as belonging to the "system
Why do most ofthe distribution substations not have a customer class indicated?
53.With respect to each of the substations listed on pages 5 through 9 of the workpapers
provided by Brilz, please provide in electronic form the following:
A listing of the K va rating of each one of the distribution substations listed.
What is the peak demand placed upon each substation during each month from
January 2002 through the most recent month available? If anything other than a I-hour peak demand is
provided, please specify the timeframe.
54.On page 12 of the workpapers provided by Brilz there is listed values for Accounts 364
and 365 broken down into primary and secondary. Withrespectto Account 364 (Poles) the investment
in secondary appears to be approximately 8.4% while for Account 365 (Overhead Conductors) the
investment in secondary appears to be approximately 16.9%. Under the simple assumption that a primary
pole carries a primary conductor and that a secondary pole carries a secondary conductor, one would
expect the ratio primary to secondary costs for Account 364 to equal that of Account 365. Please explain
the large difference that exists in the Company s numbers.
55.Company Exhibit 57 is the Functionalization and Classification of Costs. On page 6 line
369 is listed a total Plant in Service cost of Services of$43,461 529. Company Exhibit 39 is the Allocation
to Classes. On page 3 line 95 is listed the total Plant in Service cost of Meters of$47 559 362. The
difference between these two figures is developed within the Company s computer model. Please provide
in hard copy, a detailed reconciliation between these two figures, based upon the values listed in Exhibit
37.
56.Company Exhibit 37 is the Functionalization and Classification of Costs. On page 6 line
370 is listed a total Plant in Service cost of Meters of$36 387 ,617. Company Exhibit 39 is the Allocation
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS TO IDAHO POWER COMPANY - 2
to Classes. On page 3 line 96 is listed the total Plant in Service cost of Meters of$40 912 763. The
difference between these two figures is developed within the Company s computer model. Please provide
in hard copy, a detailed reconciliation between these two figures, based upon the values listed in Exhibit
37.
57.Company Exhibit 39 is the Allocation to Classes. On page 3 lines 83 through 98 there are
listed various "Functions" such as "substations-General"
, "
Lines-Primary Demand", etc. Please provide
a listing of which FERC accounts fit under each of these Functions.
58.Exhibit 37 page 7 lines 85 and 86 list Primary Demand related costs of$7 673 334 for
Account 366 (Underground Conduit) and $54 141 128 for Account 367 (Underground Conductors).
U sing allocation factor D- 20 for these costs, Irrigators get just over 30% of these costs or approximately
$22 million. The IIP A believes that there is very little, if any, underground distribution system that serves
Irrigation customers. Please answer the following:
If the Company believe that $22 million ofprimary Demand related plant in service
costs should be allocated to Irrigation customers, then please provide data to support such wide spread
usage of the underground distribution system by the Irrigation Class.
The IIP A would like to propose that Primary Demand costs for underground
facilities be allocated on a modified type ofD-20 that places the value for Irrigation at zero. If the
Company does not agree with this approach, what type of an allocation factor does the Company propose?
The IIP A would propose a similar modification to C-20 for all underground
Primary Customer related costs. Does the Company concur?
59.On Exhibit 39 page 41 are listed various allocation factors. Please provide all workpapers
that support the development of each of these allocation values used for each customer class.
60.Please provide the description/rationale of why the particular allocation method was chosen
for each ofthe allocation factors found on Exhibit 39 page 41.
61.On page 429 of the Company s 1999 Form 1 on line 14 there are listed 185 417 line
transformers. Is this the number ofline transformers that was actually out in the field at the time and
available to serve customer load?
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS TO IDAHO POWER COMPANY - 3
62.Please provide a copy of all studies the Company has conducted in the last year that
equates size, cost, and load factor of line transformers to customer type.
63.Page 13 of the workpapers provided by Brilz indicates that $47 529 633 of line
transformers is associated with Primary. Please answer the following:
Does the designation of Primary in this case mean that the line transformers are
operating with the "low" side of the transformer providing energy to what is considered a customer (without
additional intervening transformers) that is being served from what is considered a Primary voltage?
If the response to "" above is negative, what types of voltage transformations are
taking place and for what type of customer?
If the response to "" above is positive, what is the rationale for allocating any of
these costs to any customer group other than those taking service at Primary Voltage?
If possible, please break down the difference between Primary and Secondary
Line-Transformer costs into the number oftransformers and the total capacity associated with each in a
manner similar to page 429 of the Form 1.
64.Please provide a breakdown of the number ofline transformers the Company has in service
by size (or size category).
65.Please provide a break down of the present cost (purchase as well as installed, if available)
of line transformers by si~r size category).
DATED this day of January, 2004.
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
flL~
RANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS TO IDAHO POWER COMPANY - 4
CERTIFIC OF SERVICE
I HEREBY CERTIFY that on this day ofJ anuary, 2004, 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: lnordst(illpuc.state.id.
wstutzm(illpuc. state. id. us
Peter 1. 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(illaol.com
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS TO IDAHO POWER COMPANY - 5
Dean 1. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
E-mail: joe(illmcdevitt-miller.com
Jeremiah 1. Healy
United Waterldaho, 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(illaol.com
~"
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS TO IDAHO POWER COMPANY - 6