200402024th Response of ID Power to Irrigation Pumpers.pdf

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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'
FOURTH DATA REQUEST
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the Fourth Data Request of the Idaho Irrigation Pumpers Association to
Idaho Power Company dated January 2, 2004, herewith submits the following information:
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 49: Idaho Power relies on reporting from
the operating partners at each of the three thermal plants in which Idaho Power has an
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page
ownership share. The negative amount of $1 ,577 804 in account 500 in August 2003
results from a reversal of previous accruals for the Jim Bridger power plant as reported
by PacifiCorp as operator of the plant. These accruals were recorded in Idaho Power
books in the months of June and July 2003. In August , these accruals were credited
out of account 500 and charged to other maintenance accounts , primarily accounts 512
and 513.
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. 50: The Company s response to Staff Request 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.
RESPONSE TO REQUEST NO. 50: The actual operating and
maintenance expenses (excluding fuel) incurred by the operating partner at each of
thermal plants in which Idaho Power has an ownership share are reported to Idaho
Power in the month following the month in which the expenses are incurred. For
example , expenses incurred at Valmy in January will be summarized by Sierra Pacific
Power Company (the operating partner) and will be forwarded to Idaho Power later in
the month of February. Idaho Power will then record these costs in the business month
of February. Because actual costs are not available in January, using this example
Idaho Power books an estimate of the costs in January and then adjusts that estimate in
February to the actual amounts reported by the operating partner. An estimate is not
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 2
prepared for all accounts; only a few accounts are used in order to make the process
less cumbersome administratively.
This estimating process produced the negative values in accounts 502
and account 512 in August 2003 related to the Valmy plant. Due to a clerical error, the
estimates for Valmy were significantly higher in April , May, June, and July of 2003.
When the error was discovered and corrected , the true-up resulted in a negative
amount.
Without the estimating process, the amounts that would have been
booked to account 502 for the period from April 2003 through August 2003 would have
been $1 959 892 rather than the $1 855,455 that was actually recorded.
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. 51: The Company s response to Staff Request 85 lists a
negative value of $468,146 for Acct. 512 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.
RESPONSE TO REQUEST NO. 51: Please see the response to Request
No. 50 for a discussion of the process to estimate operation and maintenance
expenses. The same explanation is applicable to this response.
Without the estimating process, the amounts that would have been
booked to account 512 for the period from April 2003 through August 2003 would have
been $7 067 999 rather than the $6 857 283 that was actually recorded.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 3
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. 52: On pages 5 through 9 of the workpapers provided by
Brilz there is a column labeled "Customer Class . Please answer the following:
REQUEST NO. 52(a): Upon what basis does the Company classify any
of these distribution substations as belonging to a given customer class?
RESPONSE TO REQUEST NO. 52(a): Pages 4 through 9 of the
workpapers of Company witness Brilz identify the customer class from which a
Contribution in Aid of Construction (CIAC) was received for the construction of the
specified substation. Please refer to the testimony of Company witness Brilz, page 23
line 11 through page 24, line 13 for a description of how the CIAC amounts were utilized
in the cost-of-service study.
Except for the substations used to provide service to Micron and Simplot
under special contracts , no substations are specifically assigned to a particular
customer class. Substation investment is allocated to customer classes based on the
D20 allocation factor.
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. 52(b): Upon what basis does the Company classify any
of these distribution substations as belonging to the "system
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 4
RESPONSE TO REQUEST NO. 52(b): A Contribution in Aid of
Construction (CIAC) was classified as "system" in those situations where the actual
customer class from which the contribution was made could not be identified. "System
CIACs were allocated to all standard service schedule customer classes as detailed on
page 3 of the workpapers of Company witness Brilz.
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. 52(c): Why do most of the distribution substations not
have a customer class indicated?
RESPONSE TO REQUEST NO. 52(c): The substations listed on pages 4
through 9 of the workpapers of Company witness Brilz that do not have a customer
class indicated are substations for which no CIAC was received.
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. 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:
REQUEST NO. 53(a): A listing of the kV A rating of each one of the
distribution substations listed.
RESPONSE TO REQUEST NO. 53(a): The requested information is
included on the enclosed CD labeled "Fourth Production Request of Irrigation
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 5
t:'umpers . The rating of each Idaho Power-owned distribution substation transformer is
provided in MV A (1 000 kV A). Where no transformer for load service is installed in the
substation, the data field is left blank or indicates "no data
The response to this request was prepared under the direction of Maggie
Brilz, Pricing Director, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
REQUEST NO. 53(b): 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 1-hour peak demand is provided , please specify the
timeframe.
RESPONSE TO REQUEST NO. 53(b): The peak demand placed upon
each substation during each month is not available. The information included on the
enclosed CD labeled "Fourth Production Request of Irrigation Pumpers" provides
where available, the peak demand on each substation transformer for each of the past
three operating seasons. This peak demand is non-coincident and occurred at any time
during a three to four month period during the specified season. Additionally, these
peak demand readings are derived from real-time data, and as such represent
instantaneous values not one-hour peak demand values.
The response to this request was prepared under the direction of Maggie
Brilz, Pricing Director, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
REQUEST NO. 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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 6
With respect to 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.
RESPONSE TO REQUEST NO. 54: Please refer to Idaho Power
Company s Response to Idaho Irrigation Pumpers Association s Second Data Request
Request No. 41. As detailed in the referenced response, if poles support both primary
and secondary conductors, the poles are assigned to the primary component.
Approximately half of the secondary conductor is installed on primary poles.
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. 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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 7
RESPONSE TO REQUEST NO. 55: The value of $43,461 529 is the
investment in Services for FERC Account 369. This value is functionalized in the
Services category as detailed on Exhibit 37, page 8 , line 88 under the column
headed V.
Within the cost-of-service study, general plant is allocated to functional
categories based on the total Production , Transmission , and Distribution plant (PTD
allocator). The difference between the $43,461 529 value and the $47 559,362 value
on Exhibit 39, page 3 , line 95 is the amount of general plant investment functionalized
into the Services category. Please refer to Exhibit 37, page 13 under the column
headed V for the detail of the general plant functionalized to the Services category.
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. 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 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.
RESPONSE TO REQUEST NO. 56: The value of $37 387 617 is the
investment in Meters for FERC Account 370. This value is functionalized in the Meters
category as detailed on Exhibit 37, page 8 , line 89 under the column headed W.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 8
Within the cost-of-service study, general plant is allocated to functional
categories based on the total Production , Transmission, and Distribution plant (PTD
allocator). The difference between the $37 387 617 value and the $40,912 763 value is
the amount of general plant investment functionalized into the Meters category. Please
refer to Exhibit 37 , page 13 under the column headed W for the detail of the general
plant functionalized to the Meters category.
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. 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.
RESPONSE TO REQUEST NO. 57: The "Functions" listed on Exhibit 39
page 3 , lines 83 through 98 correspond with the functions in columns I through Y on
lines 8 and 9 of Exhibit 37. For example, the function "Substations - General" on
Exhibit 39 , page 3, line 83 corresponds to the function "Substations - General" on
Exhibit 37, page 2, column I , lines 8 and 9. The FERC accounts for which an allocation
to one or more of these functions is made can be found by reviewing the detail under
each of the functional column headings on Exhibit 37.
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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 9
REQUEST NO. 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). Using allocation factor D-
for these costs , Irrigators get just over 30% of these costs or approximately $22 million.
The IIPA believes that there is very little , if any, underground distribution system that
serves Irrigation customers. Please answer the following:
REQUEST NO. 58(a): If the Company believe that $22 million of Primary
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.
RESPONSE TO REQUEST NO. 58(a): Idaho Power s current property
accounting records do not identify investments in poles , overhead conductor
underground conduit, or underground conductor by customer class nor by customer
characteristics such as rural versus urban location , number of customers per feeder
average number of line miles per customer in each class, etc. Because this specific
data is not available, Idaho Power has historically allocated all of the investments in
FERC Accounts 364, 365 , 366, and 367 using the class non-coincident peak demand
(or coincident group peak demand) methodology described in the National Association
of Regulatory Utility Commissioners' Electric Utility Cost Allocation Manual. The non-
coincident peak demand cost allocation methodology recognizes that distribution
facilities must be constructed to meet customers' loads and allocates the costs
associated with the entire distribution system to customer classes based on the
maximum demands placed on the system by each class. The methodology does not
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 10
recognize class-specific characteristics or demographics. Should it be desirable to
recognize class-specific characteristics such as rural versus urban location or average
number of line miles per customer in each class , a methodology other than the non-
coincident peak demand methodology would need to be developed to recognize that
certain classes utilize , or do not utilize, the components of the distribution system in
class-specific ways. Such a change in methodology could be developed to recognize
that very little of the underground distribution system is used by the irrigation class while
at the same time recognizing that a larger proportion of the overhead system is used by
the irrigation class on a per-customer basis than by the other classes of customers.
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. 58(b): The IIPA would like to propose that Primary
Demand costs for underground facilities be allocated on a modified type of D-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?
RESPONSE TO REQUEST NO. 58(b): The Company does not agree
with the approach proposed by the IIPA to simply set the allocation factor for Primary
Demand related underground facilities for irrigation customers to zero without making a
corresponding adjustment to the allocation factor for Primary Demand related overhead
facilities. To simply set the allocation factor for Primary Demand related underground
facilities for irrigation customers to zero without making a corresponding adjustment to
the allocation factor for Primary Demand related overhead facilities would result in an
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 11
over allocation of the overhead facilities costs to the residential , commercial , and
industrial classes. Please refer to the Company s response to Request No. 58(a). If an
adjustment were to be made to the D20 allocation factor such that no Primary Demand
related underground facilities would be allocated to the irrigation class , a new allocation
factor that would recognize class-specific characteristics such as average number of
line miles per customer in the class and average number of customers per feeder would
need to be developed to allocate the costs associated with the overhead facilities.
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. 58(c): The IIPA would propose a similar modification to
20 for II underground Primary Customer related costs. Does the Company concur?
RESPONSE TO REQUEST NO. 58(e): The Company does not agree
with the modification proposed by the IIPA for the same reasons stated above in the
responses to Request Nos. 58(a) and 58(b).
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. 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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 12
RESPONSE TO REQUEST NO. 59: All of the workpapers and exhibits
that support the development of each of the allocation factors listed on Exhibit 39, page
41 are included with the Company s filing.
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. 60: Please provide the description/rationale of why the
particular allocation method was chosen for each of the allocation factors found on
Exhibit 39 page 41
RESPONSE TO REQUEST NO. 60: The methods used to allocate costs
to the various customer classes are described in the testimony of Company witness
Brilz on pages 3 through 20. The methods are based on the guiding principles
described in the National Association of Regulatory Utility Commissioners' Electric
Utility Cost Allocation Manual.
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. 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 of line transformers
that was actually out in the field at the time and available to serve customer load?
RESPONSE TO REQUEST NO. 61: Yes, this is the number of
transformers out in the field and available to serve customer load at year end.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 13
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. 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.
RESPONSE TO REQUEST NO. 62: The Company has not conducted
any studies in the last year that equates size, cost, and load factor of line transformers
to customer type.
The response to this request was prepared under the direction of Maggie
Brilz, Pricing Director, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
REQUEST NO. 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:
REQUEST NO. 63(a): 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?
RESPONSE TO REQUEST NO. 63(a): No.
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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 14
REQUEST NO. 63(b): If the response to "" above is negative , what
types of voltage transformations are taking place and for what type of customer?
RESPONSE TO REQUEST NO. 63(b): Primary transformers , typically
called "step" transformers, are used to change the voltage of the primary circuit and do
not directly serve any customers. They are used to "step" the primary voltage from the
substation supply (such as 34.5 kV) to a different primary voltage serving a portion of
the distribution feeder (such as 12.5 kV). They can be used to step the primary voltage
either up or down.
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. 63(c): 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?
RESPONSE TO REQUEST NO. 63(e): Not applicable.
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. 63(d): If possible , please break down the difference
between Primary and Secondary Line-Transformer costs into the number of
transformers and the total capacity associated with each in a manner similar to page
429 of the Form 1.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 15
RESPONSE TO REQUEST NO. 63(d): Idaho Power is no longer required
to include distribution information in FERC Form 1 as shown on page 429 of the 1999
Form 1 report. Consequently, the Company does not have the information available in
the form requested. Enclosed with this response is the Company s total investment in
transformers recorded in FERC Account 368 as of December 31 2002. The
transformer investment is identified by Primary and Secondary component and by
transformer size. The quantity of transformers and the original investment amount
each size category are detailed. For primary transformers, $7 657 195 of the total
system investment of $8,431 052 is attributed to the Idaho jurisdiction. For secondary
transformers , $181,408 199 of the total system investment of $199 741 797 is attributed
to the Idaho jurisdiction.
The response to this request was prepared under the direction of Maggie
Brilz, Pricing Director, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
REQUEST NO. 64: Please provide a breakdown of the number of line
transformers the Company has in service by size (or size category).
RESPONSE TO REQUEST NO. 64: Please refer to the Response to
Request No. 63(d).
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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 16
REQUEST NO. 65: Please provide a break down of the present cost
(purchase as well as installed , if available) of line transformers by size (or size
category) .
RESPONSE TO REQUEST NO. 65: Please refer to the Response to
Request No. 63(d).
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.
DATED at Boise, Idaho , this 3 ~ay of January, 2004.
G9 ff
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 17
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 3Dfl;\day of January, 2004, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO FOURTH 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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CERTIFICATE OF SERVICE , Page
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
O. Box 2720
Boise, ID 83701-2720
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Dennis E. Peseau , Ph.D.
Utility Resources , Inc.
1500 Liberty Street S. E., Suite 250
Salem, OR 97302
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Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise , ID 83701
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Jeremiah Healy
United Water Idaho , Inc.
O. Box 190420
Boise, ID 83719-0420
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William M. Eddie
Advocates for the West
O. Box 1 612
Boise, ID 83701
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Nancy Hirsh
NW Energy Coalition
219 First Ave. South, Suite 100
Seattle , WA 98104
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Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise , ID 83702
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Michael Karp
147 Appaloosa Lane
Bellingham , WA 98229
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CERTIFICATE OF SERVICE , Page 2
Michael L. Kurtz , Esq.
Kurt J. Boehm , Esq.
Boehm , Kurtz & Lowry
36 East Seventh Street, Suite 2110
Cincinnati , OH 45202
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
CERTIFICATE OF SERVICE, Page 3
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BARTON L. KLINE
IDAHO POWER COMPANY
CASE NO. IPC-O3-
FOURTH PRODUCTION REQUEST
IDAHO IRRIGATION PUMPERS ASSN.
TT A CHMENT TO
RESPONSE TO
REQUEST NO. 63(d)
ACCT SUB
CATEGORY
QTY AMOUNT
368
PRIMARY
SECONDARY
IDAHO POWER COMPANY
ACCOUNT 368
TRANSFORMERS ONLY
BALANCE AS OF December 31, 2002
UOP DESCRIPTION
68201624 XFRMR-IPH AUTO 16-49 KV A-PRI
68202424 XFRMR-IPH AUTO 50-74 KV A-PRI
68202624 XFRMR-IPH AUTO 75-99 KV A-PRI
68202824 XFRMR-IPH AUTO 100-166 KV A-PRI
68203624 XFRMR-IPH AUTO 167-499 KV A-PRI
68205024 XFRMR-IPH AUTO 500-1499 KV A-PRI
68206238 XFRMR-IPH AUTO 1500-2499 KV A-PRI
68207054 XFRMR-IPH AUTO 2500+ KVA-PRI
TOTAL PRIMARY
68010202 XFRMRIPH CONY 0-15 KV A-SEC
68011602 XFRMR-IPH CONY 16-49 KV A-SEC
68012402 XFRMR-IPH CONY 50-74 KV A-SEC
68012606 XFRMR-IPH CONY 75-99 KVA-SEC
68012806 XFRMR-IPH CONY 100-166 KVA-SEC
68013606 XFRMR-IPH CONY 167-499 KVA-SEC
68015002 XFRMR-IPH CONY 500-1499 KV A-SEC
68015650 XFRMR-IPH CONY 1500-2499 KVA-SEC
68015655 XFRMR-IPH CONY 2500+ KV A-SEC
68057450 XFRMR-3PH CONY 2500+ KV A-SEC
68101206 XFRMR-IPH PDMNT 0-15 KV A-SEC
68101616 XFRMR-IPH PDMNT 16-49 KV A-SEC
68102416 XFRMR-IPH PDMNT 50-74 KVA-SEC
68102616 XFRMR-IPH PDMNT 75-99 KVA-SEC
68102816 XFRMR-IPH PDMNT 100-166 KV A-SEC
68103616 XFRMR-IPH PDMNT 167-499 KVA-SEC
68151814 XFRMR-3PHPDMNT 16-111 KVA-SEC
68153014 XFRMR-3PH PDMNT 112-166 KV A-SEC
68154014 XFRMR-3PH PDMNT 167-499 KVA-SEC
68155014 XFRMR-3PH PDMNT 500-1499 KVA-
68156220 XFRMR-3PHPDMNT 1500-2499 KVA-SEC
68157020 XFRMR-3PH PDMNT 2500+ KV A-SEC
68251416 XFRMR-IPH SUB 0-15 KVA-SEC
68251616 XFRMR-IPH SUB 16-25 KVA-SEC
68252416 XFRMR-IPH SUB 26-50 KV A-SEC
68253616 XFRMR-IPH SUB 167-499 KV A-SEC
68300100 XFRMR-MISC-IPH-CONY 0-15 KVA-SEC
68300200 XFRMR-MISC-IPH-CONV 16-49 KV A-SEC
68300400 XFRMR-MISC-IPH-CONV 75 KVA-SEC
68300500 XFRMR-MISC-IPH-BUD 16-49 KVA-SEC
68300700 XFRMR-MlSC-IPH-BUD 50-74 KVA-SEC
68300800 XFRMR-MISC-IPH-BUD 75-99 KV A-SEC
68300900 XFRMR-MISC-IPH-BUD 100-166 KVA-SEC
68301100 XFRMR-MISC-IPH-BUD 167-499 KVA-SEC
68301400 XFRMR-MISC-IPH-BUD 500-1499 KV A-SEC
68301500 XFRMR-MISC-IPH-BUD 1500+ KVA-SEC
68302000 XFRMR-MISC- UG EMERGENCY-SEC
TOTAL SECONDARY
TOTAL
24.27,490.
90.194 741.53
88.180,654.
84.243,399.
207.655,236.
304.840,865.
285.540 852.
96.747,812.
178.8,431 052.
659.39,224 956.
51,689.32,619 582.
18,569.18,721,435.
947.248,019.
284.794 054.
464.709,770.
278.393,956.
21.00 599,127.
27.971,477.75
1.00 078.
192.99,941.93
833.908 660.
785.13,110 012.
7,480.13,820 395.
720.361 354.
938.735 774.
913.314 756.
1,494.334 124.
360.641,094.
069.611,573.
199.566 786.
213.5,452,476.
889.
99.48,277.61
108.397.
669.
151.09
73.45,727.
42.39,420.
60.889.
13.876.44
118.
26.23,898.
36.053.
11.40,924.
61,039.
1.00 054.
195,632.199,741 796.
196,810.208 172,848.