20051214IIPA 2nd data request to IPC.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 83702
TELEPHONE, [phone]
FACSIMILE' (2081 433-0167
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
www.racinelaw.net
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, ID 83402
TELEPHONE' (2081 528-6101
FACSIMILE, (2081528.6109
SENDER'S E-MAIL ADDRESS, rcbC1!Jracinelaw.net "ALSO MEMBER WY '" IL BARSHALSO MEMBER UT BAR
tALSO MEMBER D. C. BARttALSO MEMBER MO BAR
tttALSO MEMBER IL BAR
*ALSO MEMBER CA BAR
December 12, 2005
0 C
, ", '
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Dear Mrs. Jewell:
.. -..." .-~..::::..:-:-
: i
(.Ii
(.Ii
c::'
f'J
Re:IPC-O5-
Enclosed herewith, please find the original and eight copies of the Idaho Irrigation Pumper
Association, Inc.s Second Data Requests to Idaho Power Company in the above case.
RCB:rr
Enclosurescc: Service List
~cerely,
~ ,
RAND L~. BUDGE
, ~ ~
\i E~ D
Randall C. Budge, ISB No. 1949
Eric L. Olsen, ISB No. 48ll
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
:1. 0,1'1
" '
;' , lJ' I '
-:...
. u,~ Li C
:..: ,
.CC:::;:ssro:!
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-
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND
DATA REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys
hereby submit these Second Data Requests to IDAHO POWER COMPANY as follows:
29. Regarding Exhibit 21, the year 1928 shows a runoff figure of 6.660 438. Please
answer the following:
Is this figure in acre-feet?
Why is this figure less than the figure of 6 966 928 for 1928 found on Exhibit
35 in Case No. IPC-03-13?
What is the source of information or method is used to calculate the runoff
figures in this case and contrast that with the source of information or method
used in Case No. IPC-03-13?
30. Exhibit 22 lists for the 1993 test year a "Normalized Power Supply expense" of
$48 039 000, a "Normalized CSPP" expense of$34 114 160, and Nonnalized System Firm Load"
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS
TO IDAHO POWER COMPANY - 1
of 13 952 283 Mwh. Please reconcile these amounts with the figures from Case IPC-93-08 of
$18 733 020 power supply expense, $32 031 700 CSPP expense, and sales of 10 171 546 MWH.
31.
for the various substations. Please answer the following:
Regarding pages 5 and 6 of Ms. Brilz workpapers, there is listed the net investment
32.
There are two different entries for the Don Substation with different values
for each (one on page 5 and one on page 6). 'What is the difference between
these two entries?
Other than Simplot, what load does the Don Substation serve?
'What is the capacity of the Don Substation, what percentage of this station
capacity does Simplot use, what percentage of this station capacity does
Astaris use, and what percentage of this station capacity is used by other
customers?
Why isn t this plant associated with the Don Substation directly assigned or
at least a large portion of it to Simplot and/or Astaris?
Please supply supporting data that shows how the direct assignment of
343 736 of substation costs to Simplot was developed (page 2)?
Regarding the Dram and Micron Substations, what load other than the
Micron load is served by these substations?
Why isn t the entire cost ofthese substations directly assigned to Micron?
Please supply supporting data that shows how the direct of assignment of
$14 599 997 of substation costs to Micron was developed (pagel)?
For each of the substations listed on pages 5 and 6 please provide the relative
percentage of these substations that is serving the specific "customer class
listed in the far right-hand column.
Regarding page 13 of the workpapers of Ms. Brilz, the line for the Primary
component of the "Ration Computation" includes figures such as 161 711 547, etc. For each of
these figures, please break out the proportion that is only Primary based and the portion that supports
both Primary and Secondary.
33. Regarding page 22 of the workpapers of Ms. Brilz, the metering report for the State
of Idaho has a cost per meter for Schedule 24 customers of $309 per meter and for Schedule 25 of
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS
, TO IDAHO POWER COMPANY - 2
$304 per meter. Please explain how the figures on this page are derived and why time of use meters
would be cheaper than standard (presumably vintaged) meters.
DATED this day of December, 2005.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
RANDALL C. BUDGE
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this f2-day of December, 2005, I served a true, correct
and complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
E-mail: jjewell~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
mmoen~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
IDAHO IRRIGATION PUMPERS ASSOCIATION'S SECOND DATA REQUESTS
TO IDAHO POWER COMPANY - 3