200401225th Request of ID Pumpers to ID Power.pdf

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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 FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their
attorneys hereby smit this Fifth Data Requests to IDAHO POWER COMPANY as follows:
66. On page 14 ofthe workpapers provided by Brilz there is a listing of$203.87 as the average
cost of a single-phase Service. Please provide the complete study (and support data) that
established this figure. When was this study conducted?
67. What is the average length ofthe Service Drop (wire length) listed in Request 66 above?
68. Is the typical Service Drop for an Irrigation customer the distance from the line transformer
to the meter that is on the same pole?
69. What is the average length of a Service Drop for Irrigation customers?
70. On workpaper 16 provided by Brilz there is a column entitled "Idaho Inventory" with a
footnote referencing a "Cost of Metering Report". Please provide a copy of that report as
well as all supporting data.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 1
71. Please provide a listing of the types, sizes, capacity ranges, and costs of meters that are
presently installed.
72. Based upon the meter costs from workpaper 16 provided by Brilz and the number of
customers on workpaper 28 provided by Brilz, it can be calculated that the average cost of a
meter for Schedule 24 is $425 while it is $139 for Schedule 7. Both schedules are metered at
secondary voltage and both schedules basically provide 3-phase service. Why is there such a
difference in the average cost of meters for two rate schedules that are similar?
73. If the meter types, sizes, and capacity ranges are different for Schedule 7 and 24, please list
for each rate schedule the number of meters represented by each type, size, and capacity
range.
74. The historical monthly data regarding Account 500 expenses provided in response to
Irrigation Request #2 indicates that there was what would appear to have been correction(s)
made in FERC August 2001 where a negative value is recorded. With respect to the August
2001 entry for Account 500, please break down the reason for any correction(s), the amount
of any correct(s) and the month(s) for which the correction(s) is being made.
75. The historical monthly data regarding Account 500 expenses provided in response to
Irrigation Request #2 indicates that there was what would appear to have been correction(s)
made in January and February 2001. With respect to the January and February 2001 entries
for FERC Account 500, please break down the reason for any correction(s), the amount of
any correct(s) and the month(s) for which the correction(s) is being made.
76. The historical monthly data regarding subaccount 505003 expenses provided in response to
Irrigation Request #2 indicates that there was what would appear to have been correction(s)
made in April 2002. With respect to the April 2002 entry for subaccount 505003, please
break down the reason for any correction( s), the amount of any correct( s) and the month( s)
for which the correction(s) is being made.
77. With respect to subaccount 505001 , please explain why this subaccount was discontinued in
1999 and what happened to the expenses that would have normally been recorded in that
subaccount.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 2
78. From the Company s response to Irrigator Request 2 it can be calculated that Account 510
(Maintenance Supervision) expense for Boardman averages about 6 times greater than for
Bridger. Please explain why these expenses for Boardman run so high.
79. With respect to the Company s response to Irrigator Request 2 for Account 511 please
answer the following:
a. Why are there no entries for Maintenance of Structures at Boardman?
b. Why were the entries for Bridger discontinued in 1999? Where are these expenses now
recorded?
c. Why was the January 2003 entry over 10 times the average monthly expense experience
for the 40 preceding months?
80. With respect to the Company s response to Irrigator Request 2 for Account 512 please
answer the following:
a. Why are there no entries for Maintenance of Boiler Plant at Boardman?
b. It appears that correction(s) were made in January and March 2000 and July 2001 where
negative values are recorded for subaccount 512001. Please break down the reason(s) for
any correction(s), the amount of any correct(s) and the month(s) for which the
correction( s) is being made.
c. Why was the January 2003 entry over 10 times the average monthly expense experience
for the 40 preceding months? It appears that correction(s) were made in August 2003 in
subaccount 512003. With respect to the August 2003 entry for subaccount 512003
please break down the reason for any correction(s), the amount of any correct(s) and the
month(s) for which the correction(s) is being made.
d. Why was the average 2003 monthly expenses for Account 512 over 1.5 times the average
monthly expense experience in any year between 1998 and 2002?
81. With respect to the Company s response to Irrigator Request 2 for Account 513 please
answer the following:
a. Why are there no entries for Maintenance of Electrical Plant at Boardman?
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 3
b. It appears that correction(s) were made in April 2002 where a negative value is recorded
for subaccount 513003. Please break down the reason(s) for any correction(s), the
amount of any correct(s) and the month(s) for which the correction(s) is being made.
c. Why was the August 2003 entry over 5.5 times the average monthly expense experience
for the 67 preceding months?
d. Why was the average monthly expense for the first nine months of 2003 approximately
2.4 times the average monthly expense for the 5 previous years (1998 through 2002)?
82. With respect to the Company s response to Irrigator Request 2 for Account 514 please
answer the following:
a. Why are there no entries for Maintenance of Miscellaneous Steam Plant at Boardman
between March 1998 and April 2000? During this timeframe, where would such
expenses have been booked?
b. It appears that correction(s) were made in February, March, April, and May 1999
December 2000, and June 2003 where a negative value is recorded for subaccount
514001. Please break down the reason(s) for any correction(s), the amount of any
correct( s) and the month( s) for which the correction( s) is being made.
c. Why was the average monthly expense for the 2001-2003 timeframe over 4 times the
average monthly expense for the 3 previous years (1998 through 2000)?
83. With respect to the Company s response to Irrigator Request 2 for Account 538 please
answer the following:
a. It appears that correction(s) were made in September 2001 where a negative value is
recorded. Please break down the reason(s) for any correction(s), the amount of any
correct(s) and the month(s) for which the correction(s) is being made.
b. Why was the Acct. 538 expense for December 2002 lower than the average during that
timeframe while it was higher than the average in January 2003.
84. With respect to the Company s response to Irrigator Request 2 for Account 543 , it appears
that correction(s) were made in February 1999, December 2000, January 2001 , and June
2001 where a negative value is recorded for account 543. Please break down the reason(s) for
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 4
any correction(s), the amount of any correct(s) and the month(s) for which the correction(s)
is being made.
85. With respect to the Company s response to Irrigator Request 2 for Account 565 please
answer the following:
a. It appears that correction(s) were made in February and October 1999, January, April and
July 2000 and September 2002 where a negative value is recorded. Please break down
the reason(s) for any correction(s), the amount of any correct(s) and the month(s) for
which the correction(s) is being made.
b. Why was the Acct. 565 expense for the months of November 1999, March and June
2000, and August 2002 so much higher than the average during that timeframe?
c. Why were the average expenses for June through September 2003 on the order of 7 times
greater than the average expense for the three previous years?
d. How long into the future is whatever caused the June through September values to be so
high, expected to continue into the future?
e. What was the purpose of subaccount 565001 and why was it discontinued?
86. The Company s response to Irrigator Request 21 contains the following statement:
For accounting purposes, we estimate O&M expenditures for the month and then adjust
those estimates to the actual amounts in the following month when the actual amounts are
known. For simplicity, only a few accounts are used for estimating purposes; Account
502 is one of those accounts.
Please answer the following:
a. What are the "few accounts" used for estimating purposes?
b. Are the expense accounts not listed in "" above estimated, and if estimated, how are
they estimated?
c. For accounting purposes, why do some accounts consist of estimated values plus
corrections, while other accounts apparently do not?
87. On Exhibit 43 page 11 line 1 there is listed a total "in-season" bills of 43 907 for the
Schedule 24. Please provide a description of how this figure is developed as well as all
supporting data a workpapers that went into its development.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 5
88. On Exhibit 43 page 11 line 4 there is listed a total "in-season" demand of 3 040 024 for the
Schedule 24. Please provide a description of how this figure is developed as well as all
supporting data a workpapers that went into its development.
89. On Exhibit 43 page 11 line 10 there is listed a "Customer Adj.
" -
392 596 for the Schedule
24. Please provide a description of how this figure is developed as well as all supporting data
a workpapers that went into its development.
90. Please provide similar billing data as found on Exhibit 43 page 11 column 1 for 2002.
91. On Exhibit 43 page 13 line 1 there is listed a total "in-season" bills of 817.6 for the Schedule
25. Please provide a description of how this figure is developed as well as all supporting data
a workpapers that went into its development.
92. On Exhibit 43 page 11 line 5 there is listed a total "in-season" demand of 164 121 for the
Schedule 25. Please provide a description of how this figure is developed as well as all
supporting data a workpapers that went into its development.
93. On Exhibit 43 page 11 lines 8-11 there is listed various energy billing units for the Schedule
25. Please provide a description of how this figure is developed as well as all supporting data
a workpapers that went into its development.
94. Please provide similar billing data as found on Exhibit 43 page 13 column 1 for 2002.
DATED this 20th day ofJanuary, 2004.
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
~V)
RANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of January, 2004, I mailed a true and complete copy
of the foregoing document, postage prepaid, 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: Inordst~puc.state.id.
wstutzm~puc.state.id.
Peter 1. 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~aol.com
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUEST TO IDAHO POWER - 7
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
E-mail: joe~mcdevitt-miller.com
Jeremiah J. Healy
United Water Idaho, 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
Conley E. 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~hotmail.com
Michael Karp
147 Appaloosa Lane
Bellingham, Washington 98229
E-mail: michael~awish.net
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
37 E. Seventh St., Suite 2110
Cincinnati, OH 45202
E-mail: mkurtzlaw~aol.com
Thomas M. Power
Economics Dept., Liberal Arts Bldg 407
University of Montana
32 Campus Drive
Missoula, MT 59812
E-mail: tom.power~mso.umt.edu
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RANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FIFTH
DATA REQUESTS TO IDAHO POWER COMPANY - 8