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Home My WebLink About20051221IIPA 3rd data requests to IPC.pdfJean Jewell, Secretary Idaho Public Utilities Commission O. Box 83720 Boise, Idaho 83720-0074 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 Dear Mrs. Jewell: LAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTERED BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD, SUITE 208 BOISE, IDAHO B3702 TELEPHONE' (208) 3B5-0011 FACSIMILE, (208) 433-0167 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 232-6101 FACSIMILE (208) 232-6109 IDAHO FALLS OFFICE www.racinelaw.net 477 SHOUP AVENUE SUITE 203A IDAHO FALLS, ID 83402TELEPHONE, (208) 528.6101 FACSIMILE' (208) S28-8109 SENDER'S E-MAIL ADDRESS, rcb(gjracinelaw.net 'ALSO MEMBER WY '" IL BARS "ALSO MEMBER UT BAR tALSO MEMBER D. C. BAR ttALSO MEMBER MO BARtttALSO MEMBER IL BAR ,ALSO MEMBER CA BAR December 19, 2005 , " ,-;"~' ;_. ,--- . Re:IPC-O5- u):: (J) c:) ::::) Enclosed herewith, please find the original and eight copies of the Idaho Irrigation Pumper Association, Inc.s Third Data Requests to Idaho Power Company in the above case. RCB:rr Enclosurescc: Service List . BUDGE !\/ EC! 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: (208) 232-6101 Fax: (208) 232-6109 " ! r.;; 8:01 i I I' ,' ,', " i' " "'- , co ' ' " ,LI!'C,) IA!i'iij SS, 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 THIRD DATA REOUESTS TO IDAHO POWER COMPANY IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys hereby submit these Third Data Requests to IDAHO POWER COMPANY as follows: 34. On page 4 of the December 1 2005 report entitled "Irrigation Peak Rewards" the 5th bullet point indicates that the highest load reduction of 40.3 MW occurred in the last half of June and the lowest reduction of 12.1 MW occurred in late August. Please answer the following: Please supply all data, assumptions and workpapers used to compile the 40. MWand 12.1 MW figures as well as data for all other hours ofthe irrigation season. On page 11 of that same document it is stated that 46 load research meters were installed on participating service points. Please supply in Excel format the individual readings for each hour of the irrigation season for each of these 46 load research meters. Please provide all assumptions, weighting factors, and equations used to go ITom this raw load research data to the final figures used for each hour of interruption for such things as Graph 1 and 2. IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - d. How does the population of these participating customers relate to the overall population ofthe irrigation class? Specifically, how many customers ofwhat size load (stratum) are found among the participating customers and how many customers of what size load (stratum) are not participating.e. How many customers in the irrigation load research program (not these 46 customers) are participating in the Irrigation Peak Rewards program? 35. On page 9 of the December 1 , 2005 report entitled "Irrigation Peak Rewards" there is a table that lists the billing demand of those enrolled in the program by area. Please provide a similar breakdown by area of the total amount of irrigation billing demand as well as a breakdown by size of customer. If possible, list the size ranges the same as those used in the Company s load research program for irrigators. If available, please provide a breakdown of the annual irrigation usage over each of the last five years as well as any other rate schedule data that may be available on a similar regional breakdown. 36.Mr. Keen s testimony at page 7 indicates that a significant portion ofthe Company load growth continues to occur in the Treasure Valley area. By Treasure Valley area, is he referring to the same Nampa/Melba/Kuna/Payette area listed in the December 1 , 2005 report entitled Irrigation Peak Rewards ? If not, please explain the difference. 37.On page 6 ofthe December 1 2005 report entitled "Irrigation Peak Rewards , there is a table that lists the number of service points enrolled by area. How many of those enrolled were new in the 2005 irrigation season? How many of those listed in the table participated in the peak clipping program in 2004? 38. It would appear that the number of customers participating in the peak clipping program in 2005 increased by a factor of 2 in the western part of the Company s service area, but by a factorof6-10 in the eastern portion of the Company s service area. To what does the Company attribute this uneven growth in the program between 2004 and 2005? 39. On page 7 ofthe December 1 , 2005 report entitled "Irrigation Peak Rewards" there is a table that lists the number of customers that chose various options by service area. To what does the Company attribute the fact that a far greater percentage of the customers in the eastern portion of the service area chose multiple day interruptions compared to the western portion of the service area? IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 2 40. On page 10 of the December 1 , 2005 report entitled "Irrigation Peak Rewards" there is a table that lists the "2004 Realization rates by period"a. Please supply all data and workpapers used to develop this table. Please supply in electronic format if available. Please provide any analysis conducted that supports the appropriateness or accuracy of the decision to use 2004 data for the 2005 report. Please provide a detailed explanation that demonstrates how the data for 2004 or 2005 was incorporated into the development of demand related allocation factors in the present rate case. 41.Please provide a detailed explanation that demonstrates how the data for 2004 or 2005 was incorporated into the development of the expenses and revenues associated with the Irrigation Peak Rewards program in the present rate case. 42. On pages 12 and 13 of the December 1 , 2005 report entitled "Irrigation Peak Rewards" there are graphs that list the hourly loads of interruptions. Please explain the 8-15 MW of load that is not interrupted on these graphs. 43.On page 9 of the December 1, 2005 report entitled "Irrigation Peak Rewards" there is a reference to a regression model that was developed. Please supply a copy of all inputs and outputs associated with this model. Was this model based upon 2004 or 2005 data? 44. On page 17 of the December 1 , 2005 report entitled "Irrigation Peak Rewards" the first bullet point indicates that there were more payments because pumps were operated for a longer period of time late into the irrigation season. Please provide an explanation, with examples, of how the level of payment is established. b. O? wh~~asis or assumptions was the budgeted incentive payment developed? DATED this 1" day of December, 2005. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED RANDALL C. BUDGE IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 3 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this -1!J:!- dciy 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(fYpuc.state.id.S. Mail/Postage Prepaid Barton L. Kline Monica B. Moen Idaho Power Company O. Box 70 Boise, Idaho 83707-0070 bkline(fYidahopower. com mmoen(fYidahopower. com Electronically and by S. Mail/Postage Prepaid John R. Gale Vice President, Regulatory Affairs Idaho Power Company O. Box 70 Boise, Idaho 83707-0070 rgale(fYidahopower. com Electronically and by S. Mail/Postage Prepaid ~~ fl /;&; RANDALL c. B DGE ' IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 4