200401233rd Response of ID Power to ID Pumpers Part I.pdf

BARTON L. KliNE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
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 FORELECTRIC SERVICE.
CASE NO. IPC-03-
IDAHO POWER COMPANY'
RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD
DATA REQUEST
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company
and in response to the Third Data Request of the Idaho Irrigation Pumpers Association to
Idaho Power Company dated December 29 2003, herewith submits the following
information:
REQUEST NO. 46: With respect to the Company s response to Staff
Request 15, please answer the following:
REQUEST NO. 46(a): Please provide similar data from January 1997
through December 2000.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page
RESPONSE TO REQUEST NO. 46(a): Please see enclosed actual
booked unadjusted revenues, kWh's and customers (meters) for January 1997 through
December 2000.
The response to this request was prepared by Darrell R. Tomlinson
Finance Team Leader, Financial Research/Support, Idaho Power Company, in
consultation with Barton L. Kline, Senior Attorney, Idaho Power Company.
REQUEST NO. 46(b): 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?
RESPONSE TO REQUEST NO. 46(b): The requested information is
enclosed with this response.
The response to this request was prepared by Darrell R. Tomlinson
Finance Team Leader, Financial Research/Support, Idaho Power Company, in
consultation with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 46(c): 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?
RESPONSE TO REQUEST NO. 46(c): The requested information is
enclosed with this response.
The response to this request was prepared by Darrell R. Tomlinson
Finance Team Leader, Financial Research/Support, Idaho Power Company, in
consultation with Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 2
REQUEST NO. 46(d): What was the billing demand for the Idaho
irrigation customers for each month between January 1997 and the present?
RESPONSE TO REQUEST NO. 46(d): The requested information is
included with this response.
As part of the Company s annual usage reporting process for irrigation
customers, any billing adjustments made during the calendar year are identified and the
specific monthly billing demands are adjusted for reporting purposes. For example, if a
customer s July billing was adjusted through a transaction performed in October, the
annual usage reporting process would adjust the July usage included on the report to
reflect the adjustment actually performed in October. This process is necessary in order
to report the correct seasonal usage information for the irrigation class. The enclosed
billing demands are the values from the Company s annual usage reports.
Because the billing demands included with this response represent the
adjusted values , they will not match the billing demands shown on the Company s bill
frequency analyses. The bill frequency analyses reflect all usage and adjustments on
an actual billing month basis.
The response to this request was prepared by Maggie Brilz, Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
REQUEST NO. 46(e): What was the number of bills rendered (as
opposed to meter count) for the Idaho irrigation customers for each month between
January 1997 and the present?
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 3
RESPONSE TO REQUEST NO. 46(e): The Company does not record
the number of bills prepared by customer class. However, enclosed with this response
is a count of the number of customer charges billed to irrigation customers for the years
1997 through November 2003. The number of customer charges billed is prorated to
reflect partial month billings. For example , if a customer were connected for service for
only 15 days during the billing period , a half of a customer charge , or ., would be
included in the count.
The response to this request was prepared by Maggie Brilz, Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO. 46(1): The meter count data in Response to Staff Request
15 for the irrigators in the Idaho Jurisdiction averages 15,421 during the months of 2003
that were provided. Please reconcile these monthly numbers with the "2003 Avg.
Number of Customers" of 13 517 listed on Exhibit 43 , page 1 , line 7 for Schedule 24
customers.
RESPONSE TO REQUEST NO. 46(t): The meter count data provided in
response to Staff Request 15 for the irrigation customers in the Idaho jurisdiction
represents the number of meters attached to irrigation accounts at the end of each
month. The count includes data for both active and inactive accounts. The value
15,421 is the average of the actual monthly meter counts for January through
September 2003. The data provided on Exhibit 43, page 1 , line 7 for Schedule 24
customers excludes the data for inactive accounts and includes only the count of meters
attached to active irrigation accounts at the end of each month. The value 13 517 is the
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 4
estimated average of the annual number of active meters for irrigation customers for
2003 based on actual counts for January through May and estimated counts for June
through December. This latter method , i.e., including only active meters in the customer
count, is the method used to calculate the average number of customers for FERC
Form 1 reporting.
The response to this request was prepared by Maggie Brilz, Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO. 46(g): The meter count data in Response to Staff
Request 15 for residential customers in the Idaho Jurisdiction averages 334 718 during
the months of 2003 that were provided. Please reconcile these monthly numbers with
the "2003 Avg. Number of Customers" of 335 605 listed on Exhibit 43, page 1 , 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.
RESPONSE TO REQUEST NO. 46(g): The meter count data provided in
response to Staff Request 15 for residential customers in the Idaho jurisdiction
represents the number of meters attached to residential accounts at the end of each
month. The value 334 718 is the average number of meters actually attached to
residential accounts for January through September 2003. The data included on Exhibit
, page 1 , line 1 for Schedule 1 customers is the estimated average of the annual
number of meters for residential customers for 2003 based on actual counts for January
through May and estimated counts for June through December. For both the data used
as the basis for the response to Staff Request 15 and the basis for the value included
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 5
on Exhibit 43 , no distinction is made between active and inactive meters for residential
accounts. Therefore, the difference in the values is due to actual data versus estimated
data. The larger divergence in the similar numbers for the irrigation class is due to the
distinction between active and inactive meters as described in the response to Request
No. 46(f).
The response to this request was prepared by Maggie Brilz , Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 47: All appendices to the Company
2002 Integrated Resource Plan were provided in response to the Idaho Irrigation
Pumpers Association s Second Data Requests to Idaho Power Company, Request
No. 33.
The response to this request was prepared by Gregory W. Said , Director
of Revenue Requirement, Pricing and Regulatory Services, Idaho Power Company, in
consultation with Barton L. Kline , Senior Attorney, Idaho Power Company.
REQUEST NO. 48: As a part of this 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:
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 6
REQUEST NO. 48(a): For April 1986 there is listed under "Southsales
the figure of 3489.05103. Is this figure the result of taking the total irrigation sales for
the Southern Operating Center for April 1986 and dividing by the number of irrigation
customers in that region for the year of 3 880? If this is not how this figure was
developed , please explain what this figure represents and how it was developed.
RESPONSE TO REQUEST NO. 48(a): , the figure 3,489.051 is not the
result of taking the total irrigation sales for the Southern Operating Center for April 1986
and dividing by the number of irrigation customers in that region for the year of 3 880.
The figure 3,489.051 represents the actual billed electricity sales , in MWh , to the
Southern Operating Center in April 1986.
The response to this request was prepared under the direction of Gregory
W. Said , Director of Revenue Requirement , Pricing and Regulatory Services , Idaho
Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(b): 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?
RESPONSE TO REQUEST NO. 48(b): The "fitted" values represent the
results of the regression equation as explained by a number of independent or
explanatory variables. Once the regression equations have been specified and
estimated , it is the coefficients of the weather variables that are of primary importance to
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 7
the weather adjustment process. These coefficients measure the response of sales to
changes in those weather variables. For example, the coefficients of the growing
degree day variable in the Southern Operating Center irrigation equation represents the
number of KWh that one additional growing degree day would cause. By multiplying
this coefficient by the difference between the normal number of growing degree days for
a particular month and the number that actually occurred, the difference between actual
and normal KWh is determined.
The response to this request was prepared under the direction of Gregory
W. Said , Director of Revenue Requirement , Pricing and Regulatory Services, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(c): What customer count data is used for each of the
five regions for irrigation load for purposes of normalizing irrigation load in this case?
RESPONSE TO REQUEST NO. 48(c): The customer count data used in
the operating center irrigation equations was the maximum number of active irrigation
customers connected each year within each operating center.
The response to this request was prepared under the direction of Gregory
W. Said , Director of Revenue Requirement, Pricing and Regulatory Services, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(d): Does the Company have available the necessary
data to calculate the "fitted" irrigation load for January 2001 forward? If so , why was this
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 8
data not calculated/used? If the Company does not have all of the necessary data
available, what data is missing?
RESPONSE TO REQUEST NO. 48(d): Yes , that data is available.
However, the 2001 irrigation data was heavily impacted by the 2001 irrigation voluntary
load reduction program , which reduced irrigation sales by approximately 30 percent.
That program is nonrecurring. Regression models estimated over the 1986 through
2000 period yielded regression coefficients that best explained the weather variability of
irrigation sales.
The response to this request was prepared under the direction of Gregory
W. Said , Director of Revenue Requirement, Pricing and Regulatory Services, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(e): What customer count data is used for each area of
residential load for purposes of normalizing residential load in this case?
RESPONSE TO REQUEST NO. 48(e): The customer count data used in
the normalization process is the same data used to calculate the average number of
customers for FERC Form 1 reporting.
The response to this request was prepared under the direction of Gregory
W. Said, Director of Revenue Requirement , Pricing and Regulatory Services, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(1): What is the "System Residential Data Is it just
the Idaho residential customer, the entire system, or what?
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 9
RESPONSE TO REQUEST NO. 48(t): The "System Residential Data" is
the entire system, which is the Idaho and Oregon jurisdictional data combined.
The response to this request was prepared under the direction of Gregory
W. Said, Director of Revenue Requirement, Pricing and Regulatory Services, Idaho
Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(g): "System Residential Data" contains an input
variable listed under "USEPC" of 1 ,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.
RESPONSE TO REQUEST NO. 48(g): There are two reasons why the
residential use-per-customer figures are different. The first reason is that the Nevada
jurisdiction energy and customers have been removed prior to calculating the "USEPC"
figure in the "System Residential Data . As of April 2001 , Raft River Rural Electric
Cooperative , Inc. began serving the Company s former Nevada customers. All weather
adjustment model regressions exclude the Nevada jurisdiction historical data. The
second reason why the residential use-per-customer figures are different is because the
estimate of unbilled kWh is not included when calculating the "USE PC" figure in the
System Residential Data . The unbilled kWh was included when calculating the
residential use-per-customer in Response to Staff Request 15.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 1 0
The response to this request was prepared under the direction of Gregory
W. Said, Director of Revenue Requirement, Pricing and Regulatory Services , Idaho
Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(h): 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.
RESPONSE TO REQUEST NO. 48(h): There are three reasons why
these figures do not match. The first reason is that the actual sales figures reported in
the table "System Irrigation Weather Adjustment" is the entire system , which is the
Idaho and Oregon jurisdictional data combined , not just Idaho jurisdiction as reported in
Response to Staff Request 15. The second reason why the actual sales figures
reported in the table "System Irrigation Weather Adjustment" are different is because
the estimate of unbilled kWh is not included. The unbilled kWh was included in the
actual sales figures reported in Response to Staff Request 15. The third reason why
the actual irrigation sales figures are different is because the irrigation figures are
adjusted to reflect the cancelled and re-billed bills being re-distributed to the month the
usage actually took place.
The response to this request was prepared under the direction of Gregory
W. Said, Director of Revenue Requirement, Pricing and Regulatory Services, Idaho
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 11
Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power
Company.
REQUEST NO. 48(i): 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.
RESPONSE TO REQUEST NO. 48(i): Actual system irrigation sales
over the period January 2003 through May 2003 were set to actual billed system
irrigation sales. Actual system irrigation sales over the period June 2003 through
December 2003 were set to the prior June 2002 through December 2002 actual billed
system irrigation sales. The 2002 actual billed system irrigation sales figures used as
estimates for 2003 (June-December) were adjusted to reflect the cancelled and re-
billed bills being re-distributed to the month the usage actually took place.
The response to this request was prepared under the direction of Gregory
W. Said , Director of Revenue Requirement, Pricing and Regulatory Services , Idaho
Power Company, in consultation with Barton L. Kline , Senior Attorney, Idaho Power
Company.
DATED at Boise , Idaho , this 23rd day of January, 2004.
GM~
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 23rd day of January, 2004, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO THIRD PRODUCTION REQUEST OF IDAHO IRRIGATION
PUMPERS ASSOCIATION upon the following named parties by the method indicated
below, and addressed to the following:
Lisa D. Nordstrom
Weldon B. Stutzman
Deputy Attorneys General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
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Randall C. Budge
Eric L. Olsen
Racine , Olson , Nye , Budge & Bailey
O. Box 1391; 201 E. Center
Pocatello, ID 83204-1391
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Anthony Yankel
29814 Lake Road
Bay Village , OH 44140
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Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle , ID 83616
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Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
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Lawrence A. Gollomp
Assistant General Counsel
U. S. Department of Energy
1000 Independence Avenue, SW
Washington , D.C. 20585
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Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
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Conley E. Ward
Givens, Pursley LLP
601 W. Bannock Street
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Boise, ID 83701-2720
Dennis E. Peseau , Ph.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, ID 83701
Jeremiah Healy
United Water Idaho, Inc.
O. Box 190420
Boise , ID 83719-0420
William M. Eddie
Advocates for the West
O. Box 1612
Boise, ID 83701
Nancy Hirsh
NW Energy Coalition
219 First Ave. South , Suite 100
Seattle , W A 98104
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise , I D 83702
Michael Karp
147' Appaloosa Lane
Bellingham, WA 98229
Michael L. Kurtz, Esq.
Kurt J. Boehm , Esq.
Boehm , Kurtz & Lowry
36 East Seventh Street , Suite 2110
Cincinnati , OH 45202
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Kevin Higgins
39 Market Street, Suite 200
Salt Lake City, UT 84101
Thomas M. Power
Economics Department, LA 407
University of Montana
32 Campus Drive
Missoula, MT 59812
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wet BARTON L. KLINE