20060117IPC response IIPA 3rd request.pdf

IDAHO POWER COMPANY
PO, BOX 70
BOISE, IDAHO 83707
BARTON L. KLINE
Senior Attorney
An IDACORP Company
January 13 , 2006
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Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
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Re:Case No. IPC-05-
Idaho Power Company s Response to Idaho Irrigation
Pumpers Association s Third Data Requests
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of the
Company s Responses to the Idaho Irrigation Pumpers Association s Third Data
Requests regarding above-described case.
I would appreciate it if you would return a stamped copy of this transmittal
letter to me in the enclosed self-addressed stamped envelope.
~y yours
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Barton L. Kline
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Enclosures
Telephone [phone] Fax [phone] E-mail BKline(ijJidahopower.com
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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]
BKline (fj) idahopower.com
MMoen (fj) idahopower.com
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Attorneys 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 BASE
RATES AND CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF IDAHO
CASE NO. IPC-05-
IDAHO POWER COMPANY'
RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD
DATA REQUEST
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company
and in response to the Third Data Request of the Idaho Irrigation Pumpers Association to
Idaho Power Company dated December 19 , 2005 , herewith submits the following
information:
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page
REQUEST NO 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 40.3 MW and 12.1 MW figures as well as data for all other hours
of the irrigation season.
b. 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 from this raw load research data to the final figures used
for each hour of interruption for such things as Graph 1 and 2.
How does the population of these participating customers relate to the
overall population of the irrigation class? Specifically, how many
customers of what size load (stratum) are found among the
participating customers and how many customers of what size load
(stratum) are not participating.
How many customers in the irrigation load research program (not
these 46 customers) are participating in the Irrigation Peak Rewards
program?
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 2
RESPONSE TO REQUEST NO. 34: Idaho Power filed an objection to
this request with the Commission on January 5 , 2006.
The response to this request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 3
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 35: Idaho Power filed an objection to
this request with the Commission on January 5 , 2006.
The response to this request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 4
REQUEST NO. 36: Mr. Keen s testimony at page 7 indicates that a
significant portion of the Company s load growth continues to occur in the Treasure
Valley area. By Treasure Valley area, is he referring to the same
NampaMelba/KunalPayette area listed in the December 1 2005 report entitled
Irrigation Peak Rewards ? If not, please explain the difference.
RESPONSE TO REQUEST NO. 36: As provided in the response to the
Idaho Irrigation Pumpers Association s First Data Request, Response to Request No.
, Idaho Power defines the "Treasure Valley Area" as primarily Ada and Canyon
Counties. However, due to the connectivity of the transmission system, Idaho Power
extends this definitional boundary to include the Ontario and Payette areas. In general
the Treasure Valley area referred to by Mr. Keen is the same area referred to as the
Nampa/Melba/Kuna/Payette area in the December 1 2005 "Irrigation Peak Rewards
program report with the exception of Ontario. The Ontario area is not included in the
Nampa/Melba/Kuna/Payette area referred to in the "Irrigation Peak Rewards" program
report.
The response to this request was prepared by David L. Sikes, Planning
Manager, Idaho Power Company, and Maggie Brilz, Director of Pricing, Pricing and
Regulatory Services , 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 THIRD DATA REQUEST Page 5
REQUEST NO. 37: On page 6 of the 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?
RESPONSE TO REQUEST NO. 37: Idaho Power filed an objection to
this request with the Commission on January 5 2006.
The response to this request was prepared by Barton L. Kline , Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 6
REQUEST NO. 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 factor of 6-1 0 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?
RESPONSE TO REQUEST NO. 38: Idaho Power filed an objection to
this request with the Commission on January 5 , 2006.
The response to this request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 7
REQUEST NO. 39: On page 7 of the 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?
RESPONSE TO REQUEST NO. 39: Idaho Power tiled an objection to
this request with the Commission on January 5 , 2006.
The response to this request was prepared by Barton L. Kline , Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 8
REQUEST NO. 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.
b. 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.
RESPONSE TO REQUEST NO. 40: Idaho Power filed an objection to
this request with the Commission on January 5 2006.
The response to this request was prepared by Barton L. Kline , Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 9
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 41: No direct expenses associated with
the Irrigation Peak Rewards Program are included in the current case. All incremental
expenses directly associated with the Irrigation Peak Rewards Program are funded
through the Energy Efficiency Rider and therefore are not included in the test year.
few employees , including the Company s Energy Efficiency Leader and Agricultural
Representatives, may have some involvement in the program as part of their every day
job responsibilities. However, these pre-existing positions have historically been , and
continue to be as part of the current rate case , included in the Company s overall salary
expenses. There are no revenues associated with the Irrigation Peak Rewards
program.
The response to this request was prepared by Maggie Brilz, Director of
Pricing, Pricing and Regulatory Services , 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 THIRD DATA REQUEST Page 10
REQUEST NO. 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 8-1 5 MW of load that is not interrupted on these
graphs.
RESPONSE TO REQUEST NO. 42: Idaho Power filed an objection to
this request with the Commission on January 5 , 2006.
The response to this request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 11
REQUEST NO. 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?
RESPONSE TO REQUEST NO. 43: Idaho Power filed an objection to
this request with the Commission on January 5 , 2006.
The response to this request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 12
REQUEST NO. 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.
a. Please provide an explanation , with examples , of how the level of
payment is established.
b. On what basis or assumptions was the budgeted incentive payment
developed?
RESPONSE TO REQUEST NO. 44: Idaho Power filed an objection to
this request with the Commission on January 5, 2006.
The response to this request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 13
DATED at Boise , Idaho , this 13th day of January, 2006.
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BART N L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of January, 2006 , I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA
REQUEST upon the following named parties by the method indicated below, and
addressed to the following:
Donald L. Howell , II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
don.howell (fj) puc.idaho.qov
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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
rcb(fj) racinelaw.net
elo(fj) racinelaw.net
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Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
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Peter J. Richardson
Richardson & O'Leary
515 N. 27th Street
O. Box 7218
Boise ,. ID 83702
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Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise , ID 83703
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Lawrence A. Gollomp
Assistant General Counsel
United States Dept. of Energy
1000 Independence Avenue, SW
Washington , D.C. 20585
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CERTIFICATE OF SERVICE , Page
Dennis Goins
Potomac Management Group
O. Box 30225
Alexandria , VA 22310-8552
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aol.com
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.
Utility Resources , Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
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William M. Eddie
Advocates for the West
1320 W. Franklin Street
O. Box 1612
Boise , ID 83701
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rmci. net
Ken Miller
NW Energy Coalition
5400 W. Franklin, Suite G
Boise , ID 83705
kenmiller1 (fj) cableone.net
Michael L. Kurtz
Kurt J. Boehm
Boehm , Kurtz & Lowry
36 East Seventh Street , Suite 1510
Cincinnati, Ohio 45202
mkurtz (fj) bkllawfirm.com
kboehm (fj) bkllawfirm.com
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BARTON L. KLINE