20051125IIPA 1st request to Idaho Power.pdf

LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL-
JOHN B. INGELSTROM
DANIEL C. GREEN--
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
MITCHELL W. BROWN
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.
DAVID E. ALEXANDERtt
LANE V. ERICKSON"
LISA M. CHRISTONttt
PATRICK N. GEORGE
SCOTT J. SMITH
LISA A. WOOD, CPA
STEPHEN J. MUHONEN
BRENT L. WHITING
LISA R. TANNER;
JUSTIN R. ELLIS
JOSHUA D. JOHNSONttt
JONATHON S. BYINGTON
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO B3702
TELEPHONE' [phone]
FACSIMILE, [phone]
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 63204-1391
TELEPHONE [phone]
FACSIMILE (20B) 232-6109 IDAHO FALLS OFFICE
www.racinelaw.net
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, ID 83402
TELEPHONE, [phone]
FACSIMILE' [phone]
SENDER'S E-MAIL ADDRESS, rcb(ij)racinelaw.net -ALSO MEMBER WY & IL BARS
"ALSO MEMBER UT BAR
tALSO MEMBER D- C. BAR
ttALSO MEMBER MO BAR
tttALSO MEMBER IL BAR*ALSO MEMBER CA BAR
November 22, 2005
, ,." ;,:_" ~ -
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Dear Mrs. Jewell:
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1.1.)
Re:IPC-O5-
Enclosed herewith, please find the original and eight copies of the Idaho Irrigation Pumper
Association, Inc.s First Data Requests to Idaho Power Company in the above case.
RCB :rr
Enclosurescc: Service List
RANDlLL ~. BUDGE
i:f~!\;
Randall C. Budge, ISB No. 1949
Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204-1391
Phone: [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 RATES AND CHARGES
FOR ELECTRIC SERVICE TO ELECTRIC
CUSTOMERS IN THE STATE OF IDAHO
CASE NO. IPC-O5-
1. Mr. Keen s testimony at page 6 indicates that six distributions substations have been
added since the beginning of2004. Please provide the following information
regarding those distribution substations:
a. What is the name of each substation?
b. What is the location of each substation? Please list county as well as city or town
that is served by the substation.
c. What is the capacity of each substation?
d. What was the cost of each substation?
2. Mr. Keen s testimony at page 6 indicates that approximately 30 miles of new sub-
transmission lines have been added to integrate the six new distributions substations.
Please provide a map(s) showing the location ofthese new sub-transmission lines as
well as the cost of these lines.
3. Mr. Keen s testimony at page 7 indicates that a significant portion ofthe Company
load growth continues to occur in the Treasure Valley area. Please answer the
following:
a. How does the Company define the "Treasure Valley area" and in particular the
portions of the "Treasure Valley area" that is associated with this "significant
portion of the Company s load growth"
b. What data does the Company have available to quantify this load growth (rate
base additions) by area (i., by taxing district, city boundaries, county lines, etc)?
c. Please provide a copy of all information that has been distributed to the "Treasure
Valley Electric Plan Community Advisory Committee
4. Mr. Pengilly s testimony at page 42 provides information regarding the impact of
moving 680 non-agricultural customers from the irrigation rate schedules to a general
service rate schedule. Please provide a list of energy and demand usage (and other
appropriate data used) for each ofthese 680 customers that served as the basis for the
results that are shown. Please provide this information in electronic format.
5. At page 16 of Mr. Baggs' testimony there is a discussion regarding the data
management aspects ofthe Phase One ofthe AMR Project. Ifthe Company has
available AMR data for irrigation customers:
Please supply that data by customer on an hourly basis in electronic format.
b. If the irrigation customers in the Phase One of the AMR Project are not typical of
the general irrigation class in the Idaho Power service area, please provide an
explanation regarding the differences.
6. Please provide a copy of all model runs and other support data that was used to
prepare the Company s exhibits in electronic format. If certain procedures are
required to run things like the Company s class cost of service study, please provide a
copy of those procedures as well.
7. Please provide a copy of all input data to Exhibits 20 and 21 in both hard copy and
electronic format.
8. For each month since January 2003 , please supply the monthly usage of schedule 24
and 25 customers in the Idaho Jurisdiction and the system as a whole.
9. With respect to the Company s Load Research data, please provide for each sample
customer with valid data that was sampled between January 2003 and the most recent
month available the following:
a. Customer identification number;
b. Customer rate schedule;
c. Strata to which it belongs;
d. Raw hourly usage data;
e. Raw hourly usage data modified to reflect losses;
f. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company s cost of service study in this case.
g. Please provide copies of the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of service
study in this case.
10. Please provide for each month from January 2003 forward a copy ofthe monthly
checks that the Company makes regarding how well the Load Research sample data
reflects the actual population usage.
11. Please provide for each month from January 2003 forward a listing of the calendar
month usage for the Schedule 24 and Schedule 25 in the Idaho Jurisdiction.
12. Please provide a copy of any monthly Load Research summary reports that have been
produced between January 2003 and the present.
13. Please provide a copy of the bill frequency distribution for each month of the test year
for Schedules 1 , 7, 9, 19 , and 25.
14. Please provide in electronic format, on an hourly basis, for the period January 1 , 2003
through the most recent month available the following data:
a. Total system input;
b. System input from Company owned generation (stating hydro, coal, and other
generation separately);
c. System input from firm purchases, stating each purchase separately by source and
type of purchase (LF, IF, SF);
d. The cost of each firm purchase listed in "C" above;
e. System input from non-firm and/or economy purchases, stating each purchase
separately;
f. The cost of each non-firm and/or economy purchase listed in "E" above;
g. System input from exchanges into the system, stating each exchange separately;
h. System input from Unit purchases;
1. Other system inputs, stating for each "other" input the type and the source of the
input;
System losses;
k. Requirements Wholesale sales (RQ);
l. Long-term firm Wholesale sales (LF), stating each one separately;
m. Intermediate-term firm Wholesale sales (IF), stating each one separately;
n. Short-term firm Wholesale sales (SF), stating each one separately;
o. Unit sales, Wholesale (LU) or otherwise, stated separately;
p. Non-firm and/or economy Wholesale sales (OS), stated separately;
q. The revenue collected for each hour of each non-firm and/or economy purchase
listed in "P" above;
r. Exchanges out of the system, stating each exchange separately;
s. Other system outputs, stating for each "other" output the type and the recipient of
the output;
t. Inadvertent power flows into or out of the system;
u. The power available (at input level) to supply retail load once Wholesale
Exchange, Wheeling, and Inadvertent has been subtracted;
v. Losses assigned to each retail jurisdiction;
w. Losses assigned to wholesale sales;
x. Total firm retail (non-special contract) load by jurisdiction (assuming that this
data is not directly metered on an hourly basis, please indicate which data in this
response can be added or subtracted each hour to derive this information);
y. In the aggregate, the total firm special contract customer load by jurisdiction (If
need be, use identification codes to specific individual special contract customer
loads. )
15. For each firm wholesale sale that took place in 2003 (through the most recent month
available) please list for each month:
a. The name of the entity sold to;
b. The type (FERC classification) ofthe contract;
c. The pricing mechanism (fixed, rate schedule, market index, formula, etc.
d. The amount of energy sold;
e. The dollars paid for demand charges;
f. The dollars paid for energy charges; and
g. The total dollars paid.
, For each firm wholesale purchase that took place in 2003 (through the most
recent month available) please list for each month:
a. The name of the entity purchased from;
b. The type (FERC classification) ofthe contract;
The pricing mechanism (fixed, rate schedule, market index, formula, etc.
The amount of energy purchased;
The dollars paid for demand charges;
The dollars paid for energy charges; and
The total dollars paid.
17. Please provide a copy of each Marginal Cost Study that has been presented to the
Commission or the Commission Staff for each year since 2002.
18. With respect to the marginal demand costs used in Exhibit 46 , what is the exact
source of these numbers (historic/current contract values, projections, current values
of indexed prices, etc.
19. With respect to the marginal energy costs used in Exhibit 46, what is the exact source
of these numbers (historic/current contract values, projections, current values of indexed
prices, etc.)? Are these prices for firm energy?
20. With respect to the demand values listed on Exhibit 46, what was the date
and time that each peak occurred?
21. For each of the last five years, what was the date and time ofthe monthly
system peak?
22. During the hour of the monthly peak for each of the last five years, please
provide the following:a. How many megawatts of generation were out of service for planned
maintenance?b. How much electricity was generated from Company owned hydro?
How much electricity was purchased from Company owned thermal
power?
How much electricity was purchased from QF suppliers?
How much electricity was brought in through exchanges?f. How much (non-QR) electricity was purchased and at what price?
Please list each transaction separately, stating name of seller, MWH purchased
purchase price, and type of purchase (LF, RQ, SF , OS , etc.
g.
How much electricity was sold off-system and at what price? Please
list each transaction separately, stating name of purchaser, MWH sold, sale price
and type of sale (LF, RQ, SF, OS, etc.
23. For each ofthe next three years, what are the dates of scheduled maintenance
name of the units being maintained, and the megawatts being taken out of service?
24. With respect to the system, as well as class, demands and energies listed on
Exhibit 46, if the values listed are not actual (or directly derived from load research
data for that exact hour), please provide a description as well as all data used to derive
the values listed in Exhibit 46.
25. Please provide the hourly load data for each of the Company s distribution
substation from January 1 2002 though the most recent month available.
26. How many miles of primary and secondary conductor are found in the Idaho
Jurisdiction? Please describe how this figure is derived.
27. On page 13 of Brilz workpapers there are various values listed for distribution
accounts. Please answer the following:a. Please describe the methodology of dividing these accounts into
primary and secondary components. Please give examples.
b. Please provide a general explanation regarding what is meant by the
primary component verse the secondary component.c. Can the direct assignments listed be traced to specific rate schedules
in the Company s cost of service study?
28. On page 16 of Brilz workpapers there are various values listed for Account 369.
Please answer the following:a. How were the figures of$219.33 and $307.37 for the average cost of
single-phase and three-phase customers derived? Please supply supporting study.b. What do the figures of$219.33 and $307.37 for the average cost of
single-phase and three-phase customers represent as far as the average length of a
Service?
What is the average length of a Service for an Irrigation customer?
DATED this 23rd day of November, 2005.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By: fb&RANDALL C. BUDGE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day of November, 2005, I served a
true and correct copy of the foregoing document to each of the following, via the method
indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
E-mail: iiewell~'puc.state.id.S. Mail/Postage Prepaid
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
bk1ine~idahopower. com
mmoenav,idahopower. com S. Mail/Postage Prepaid
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
rgale~idahopower.com S. Mail/Postage Prepaid
RANDALL C. BUDGE