20060127IPC supp response IIPA 3rd request.pdf

IDAHO POWER COMPANY
O. BOX 70
BOISE, IDAHO 83707
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BARTON L. KLINE
Senior Attorney
An IDACORP Company
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January 26 , 2006
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-05-
Idaho Power Company s Supplemental 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 Supplemental Responses to the Idaho Irrigation Pumpers Association
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.
Very truly yours
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9/3?Barton L. Kline
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Enclosures
Telephone [phone] Fax [phone] E-mail BKline~idahopower.com
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BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
BKline (Q) idahopower.com
MMoen (Q) 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'S
SUPPLEMENTAL RESPONSE TO
IDAHO IRRIGATION PUMPERS
ASSOCIATION'S THIRD DATA
REQUEST
On January 5 2006 the Company filed objections to a portion of the Idaho
Irrigation Pumpers Association s (IIPA) Third Data Request to Idaho Power. After
discussions between Idaho Power and the IIPA to clarify the requests , Idaho Power
agreed to provide responses to Request No. 34(b) and (e) and Request No. 37.
Responses to Request Nos. 36 and 41 were previously provided on January 13, 2006.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO
IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page
REQUEST NO 34: On page 4 of the December 1 2005 report entitled
rrigation 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:
a. 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 fincH figures used
for each hour of interruption for such things as Graph 1 and 2.
d. 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.
e. 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 SUPPLEMENTAL RESPONSE TO IDAHO
IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 2
RESPONSE TO REQUEST NO. 34(b): The 15-minute interval data for
the 46 service points on which a load research meter was installed during the 2005
Irrigation Peak Rewards program is included on the CD labeled "Third Production
Request of Irrigation Pumpers - Responses" included with this response.
RESPONSE TO REQUEST NO. 34(e): For the 2005 Irrigation Peak
Rewards program, 19 participating service points were included in the 2005 load
research sample.
The response to this request was prepared by Quentin Nesbitt, Senior
Agricultural Engineer, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO
IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 3
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: Of the 893 service points identified
on page 6 of the report, 783 were new to the Irrigation Peak Rewards program in the
2005 irrigation season. One hundred and ten of the service points listed in the table
participated in the peak clipping program in 2004.
The response to this request was prepared by Quentin Nesbitt, Senior
Agricultural Engineer, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO
IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 4
DATED at Boise, Idaho, this 26th day of January, 2006.
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BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO IDAHO
IRRIGATION PUMPERS ASSOCIATION'S THIRD DATA REQUEST Page 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 26th day of January, 2006, I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'
SUPPLEMENTAL RESPONSE TO IDAHO IRRIGATION PUMPERS ASSOCIATION'
THIRD DATA REQUEST upon the following named parties by the method indicated
below, and addressed to the following:
Donald L. Howell, II
Cecelia A. Gassner
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
don.howell (Q) puc.idaho.qov
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FAX [phone]
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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(Q) racinelaw.net
elo(Q) racinelaw.net
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Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
yankel (Q) attbi.com
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Peter J. Richardson
Richardson & 0' Leary
515 N. 27th Street
O. Box 7218
Boise ,. ID 83702
peter(Q) richardsonandolearv.com
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Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise , ID 83703
dreadinq (Q) mindsprinq.com
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Lawrence A. Gollomp
Assistant General Counsel
United States Dept. of Energy
1000 Independence Avenue , SW
Washington , D.C. 20585
Lawrence.Goliomp (Q) hq.doe .qov
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CERTIFICATE OF SERVICE, Page
Dennis Goins
Potomac Management Group
5801 Westchester Street
O. Box 30225
Alexandria, VA 22310-1149
dqoinsPMG (Q) aol.com
Conley E. Ward
Givens, Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise , ID 83701-2720
cew (Q) qivenspu rslev .com
Dennis E. Peseau , Ph.
Utility Resources, Inc.
1500 Liberty Street S., Suite 250
Salem, OR 97302
dpeseau (Q) excite.com
William M. Eddie
Advocates for the West
1320 W. Franklin Street
O. Box 1612
Boise, ID 83701
billeddie (Q) rmcLnet
Ken Miller
NW Energy Coalition
5400 W. Franklin, Suite G
Boise , ID 83705
kenmiller1 (Q)cableone.net
Michael L. Kurtz
Kurt J. Boehm
Boehm , Kurtz & Lowry
36 East Seventh Street , Suite 1510
Cincinnati , Ohio 45202
mkurtz(Q) bkllawfirm.com
kboehm (Q) bkllawfirm.com
CERTIFICATE OF SERVICE, Page 2
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BARTON L. KLINE