20060111IIPA 4th data requests to IPC.pdf

Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
LOUIS F. RACINE (1917-2006)
WILLIAM D. OLSON
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL'
JOHN B. INGELSTROMDANIEL 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. ALEXANDERttLANE 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. ELLISJOSHUA 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 83702TELEPHONE' [phone]
FACSIMILE, [phone]
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 83402TELEPHONE, [phone]
FACSIMILE, [phone]
SENDER'S E-MAIL ADDRESS: rcb(Qjracinelaw.net 'ALSO MEM8ER WY .. IL BARS
"ALSO MEMBER UT BAR
tALSO MEMBER D. C. BAR
ttALSO MEMBER MO BAR
tttALSO MEMBER IL BAR,ALSO MEMBER CA BAR
January 5 , 2006
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Enclosed herewith, please find the original and eight copies of the Idaho Irrigation Pumper
Association, Inc.s Fourth Data Requests to Idaho Power Company in the above case.
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Enclosurescc: Service List
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aL C. BUDGE
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Randall C. Budge, ISB No. 1949
Eric L. Olsen, ISB No. 48ll
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 20l E. Center
Pocatello, Idaho 83204-139l
Telephone: [phone]l 01
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-
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INe., by and through their attorneys
hereby submit these Fourth Data Requests to IDAHO POWER COMPANY as follows:
45.Regarding the Company s response to Irrigator Request 3 b, please answer the
following:
Please supply a copy ofthis information in electronic format.
Please provide the full names of each of the substations listed as well as the
County in which it is located and the nearest city/town.c. It appears that the first entry for each feeder may be some sort of composite
value for each feeder. Please explain the significance of those first entries and how the values for
new service" relate to the other values listed for the feeder.
What do the "kWh" figures represent? Are they annual figures, figures since
connection, annual estimates, etc.
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS
TO IDAHO POWER COMPANY -
column?
as "
What do the suffixes (B , P, S, CB, SB, M, etc.) mean under the "rate
What is the significance/relationship of the first few lines that list the "F eeder
46. Please provide an explanation regarding the development of the load research
weighting factors. Specific information is requested regarding:
When the weighting factors were developed?
What steps are taken to ensure that the weighting factors are reflective oftest
year usage?
sample?
Do the weighting factors reflect demand values or energy values?
How does the Company address strata migration within its load research
47. Regarding the Company s response to Irrigator s Request 12, there were a number
of attachments provided with the extension REP". We were unable to open these files. Could they
be provided in some other format?
48. With respect to the Company s response to Irrigator Request 14, please explain what
Bookouts" are and where they show up in the Company s FERC Form 1 , in the power cost model
and in the PCA calculation.
49.
appears to have inappropriate numbers supplied for the price of these sales. Please supply the correct
The data provided in the Company s response to Irrigator Request 22 g for June 2004
values.
DATED this ftJ day of January, 2006.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
~L tC
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS
TO IDAHO POWER COMPANY - 2
46. Regarding the Company s response to Irrigator request 3 b, please answer the
following:
a. Please supply a copy of this information in electronic format.
b. Please provide the full names of each of the substations listed as well as the
County in which it is located and the nearest city/town.
c. It appears that the first entry for each feeder may be some sort of composite value
for each feeder. Please explain the significance of these first entries and how the
values for "new service" relate to the other values listed for the feeder.
d. What do the "kWh" figures represent? Are they annual figures, figures since
connection, annual estimates, etc.
e. What do the suffixes (B , P , S, CB, SB, M, etc.) mean under the "rate" column?
f. What is the significance/relationship ofthe first few lines that list the "Feeder" as
4 7. Please provide an explanation regarding the development of the load research
weighting factors. Specific information is requested regarding:
a. When the weighting factors were developed?
b. What steps are taken to insure that the weighting factors are reflective oftest year
usage?
c. Do the weighting factors reflect demand values or energy values?
d. How does the Company address strata migration within its load research sample?
48. Regarding the Company s response to Irrigator s Request 12, there were a number of
attachments provided with the extension "REP". We were unable to open these files.
Could they be provided in some other format?
49. With respect to the Company s response to Irrigator Request 14, please explain what
Bookouts" are and where they show up in the Company s FERC Form 1 , in the
power cost model, and in the PCA calculation.
50. The data provided in the Company s response to Irrigator Request 22g for June 2004
appears to have inappropriate numbers supplied for the price of these sales. Please
supply the correct values.
CERTIFICATE OF MAILING
J1F,I HEREBY CERTIFY that on this day of January, 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.u.s. Mail/Postage Prepaid
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
bkline~idahopower. com
mmoen~idahopower. 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~idahopower.com
Electronically and by
S. MaillPostage Prepaid
(:,
RANDALL C. BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION'S FOURTH DATA REQUESTS
TO IDAHO POWER COMPANY - 3