20060201IPC response IIPA 4th requests.pdf

IDAHO POWER COMPANY
O, BOX 70
BOISE, IDAHO 83707
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January 3"1; 2006'"
BARTON L. KLINE
Senior Attorney
An IDACORP Company
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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 Fourth Data Requests
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of the
Company s Response to the Idaho Irrigation Pumpers Association s Fourth Data
Request 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
(JJocJ~
Barton L. Kline
BLK:jb
Enclosures
Telephone [phone] Fax [phone] E-mail BKlinefiYidahopower.com
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 (ij) idahopower.com
MMoen (ij) idahopower.com
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Attorneys for Idaho Power Company
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Street Address for Express Mail
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1221 West Idaho Street
Boise, Idaho 83702
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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'
FOURTH DATA REQUEST
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company
and in response to the Fourth Data Request of the Idaho Irrigation Pumpers Association to
Idaho Power Company dated January 6, 2006, herewith submits the following information:
REQUEST NO 45: Regarding the Company s response to Irrigator
Request 3b, please answer the following:
Please supply a copy of this 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.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page
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
figure since connection , annual estimates, etc.
What do the suffixes (B , P , S, CB , SB, M , etc.) mean under the
rate" column?
What is the significance/relationship of the first few lines that list the
Feeder" as "
RESPONSE TO REQUEST NO. 45(a): The requested information in
electronic format is included on the CD labeled "Fourth Production Request of Irrigation
Pumpers - Responses" included with this response.
The response to this request was prepared by David L. Sikes, Planning
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
RESPONSE TO REQUEST NO. 45(b): The full name of each of the
substations and the county in which each substation is located are included with this
response. The four-letter location code, or DIGIT4, of each substation corresponds to
the first four letters of the feeder designation included on the Response to Request No.
3(b). The Company s records do not contain information regarding the nearest
city/town.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 2
The response to this request was prepared by David L. Sikes, Planning
Manager, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
RESPONSE TO REQUEST NO. 45(c): The first entry for each feeder is
the name of the feeder. The name consists of the four-letter location code and a two-
digit numerical identifier. The second entry is the rate code indicating the service
schedule under which the service points served by the feeder are billed. The data in the
New Service" column are the counts of the service points within each rate for each
feeder. Entries which do not have an entry in the "Rate" column are typically un-
metered services and are not assigned a Rate Code in the Company s Geographic
Information, System data base. The final column is the kWh usage within each rate for
each feeder. For un-metered services the kWh usage shown in the column is zero.
The response to this request was prepared by David L. Sikes, Planning
Manager, Idaho Power Company, in consultation with Barton L. Kline , Senior Attorney,
Idaho Power Company.
RESPONSE TO REQUEST NO. 45(d): The kWh figures represent the
energy for the selected customers for the period , in this case between 1/01/2004 and
11/30/2005. There is always some overlap or exclusion based upon meter read dates
and the query dates. For example , if a meter existed and was read 2 January 2004 the
kWh for that meter read would be included even though the actual consumption was for
the time period prior and up to the actual meter reading. Similarly at the end of the
defined period , energy may not be included if the meter was read after the period. If a
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 3
new metered Service Point was added in between the dates, the figure would represent
the kWh since connection.
The response to this request was prepared by David L. Sikes, Planning
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
RESPONSE TO REQUEST NO. 45(e): The suffixes represent certain
information related to the rate within the Company s customer information system. The
suffixes P and S designate the service level within the rate , with P designating Primary
Service Level and S designating Secondary Service Level. A "B" in the suffix indicates
that the rate is coded with a BPA designation. This coding is meaningful for the
irrigation rate schedules only and indicates eligibility for the BPA Small Farm Energy
Credit. For all other rate schedules, any B designation is simply a holdover from the
Company s previous customer information system. The designation "C" on Schedule 24
is used for those accounts that have five horsepower or less of connected load and
indicates that the billing demand is determined based on the number of horsepower.
The designation "C" on Schedule 84 indicates that the net-metering service is for
commercial customers. The designation "M" indicates that the service is metered.
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.
RESPONSE TO REQUEST NO. 45(t): The service points with a "0" in the
Feeder column were not yet associated with a feeder in the Geographic Information
System when the query was performed.
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 4
The response to this request was prepared by David L. Sikes, Planning
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
REQUEST NO. 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 of test year usage?
Do the weighting factors reflect demand values or energy values?
How does the Company address strata migration within its load
research sample?
RESPONSE TO REQUEST NO. 46(a): Stratified random sampling is the
selection process whereby a population (or sample frame) is partitioned into two or
more subpopulations (strata) and an independent simple random sample is drawn from
each stratum. The stratum weights are determined by each stratum s share of the
population. Two of the load research samples used to develop cost-of-service demand
allocators in this case were stratified.
The weighting factors were developed when the samples were designed.
The Schedule 9 sample was designed in 2000 using billing data for the 12 months
ending June 2000. The Schedule 24 sample was designed in 2002 using billing data
from May through September 2000. Irrigation billing data from 2001 was not used
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 5
because consumption was affected by the temporary Irrigation Load Reduction
Program. (See Case IPC-01-3).
RESPONSE TO REQUEST NO. 46(b): At Idaho Power once the sample
frame has been partitioned , the strata have been defined , each customer (service point)
has been assigned to one and only one stratum, and a separate random sample of
each stratum has been selected , the stratification process is complete. Customers are
not subsequently moved to a different stratum , and stratum weights do not change.
Each stratum contains a certain percentage of the total sample frame, and each stratum
sample represents that portion of the entire frame.
The stratum weights are appropriate for estimating ratios of the weighted
average demand and energy values per customer in the original sample frame during
the test year. These ratios may then be applied to the actual test year billed energy
adjusted to calendar month consumption to determine system coincident and group
peak demands. Alternatively, five-year median ratios may be applied to normalized
calendar month energy for the test year to arrive at surrogate normalized demand
values.
RESPONSE TO REQUEST NO. 46(c): The weighting factors reflect the
percentage of the sample frame population in each stratum and are used to estimate
both demand values and energy values. Customers were assigned to strata based on
their maximum monthly billed kWh during the time period used for sample design.
RESPONSE TO REQUEST NO. 46(d): Some customers shift their usage
patterns over time to the point where they would no longer be in their original stratum if
the sample frame were restratified based on current usage. Some degree of shifting
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 6
usage by sample customers is expected and reflects normal changes in the population.
The Company does not migrate customers to new strata for analysis but does recognize
that shifting usage patterns may cause the strata to become less internally
homogeneous as the sample ages and may lead to a deterioration of the relative
precision of the sample estimates.
While post-stratification is possible, it can introduce a degree of complexity
and produce biased results. The Company prefers to replace the load research samples
before post-stratification becomes necessary. In general, the samples are replaced
every four years. The Schedule 24 sample was replaced in 1998 and 2002, and a new
sample is planned for 2006. The Schedule 9 sample was replaced in 1997 and at the
end of 2000. Because the Company was planning to recommend changes to the
Schedule 9 eligibility criteria as part of the current rate case, it was determined that a
new Schedule 9 sample should be identified at the conclusion of the case rather than in
early 2005. Therefore, a new Schedule 9 sample is planned for the end of this year
after the Commission has determined the outcome of the Company s Schedule 9 rate
design proposal.
The response to this request was prepared by Paul Werner, Load
Research Team Leader, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
REQUEST NO. 47: Regarding the Company s response to Irrigator
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?
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 7
RESPONSE TO REQUEST NO. 47: The "REP" files are text files
produced by the LodeStar system, and it should be possible to open them using a text
program such as Microsoft Notepad. For convenience, the files have been reformatted
and are included on the enclosed CD labeled "Fourth Production Request of Irrigation
Pumpers - Responses" as "DOC" files that can be opened with Microsoft Word.
The response to this request was prepared by Paul Werner, Load
Research Team Leader, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 48: Bookouts are a simple way to
eliminate the physical tagging of energy when a party has purchases and sales that
occur at the same point in time, at the same location, for the same volume creating a
net position of zero. When a bookout occurs , the transactions are billed as normal
however no energy is tagged and no energy physically flows. There are no financial
implications for bookouts , they are simply a way to reduce the unnecessary workload
associated with physically tagging transactions whose volumes net to zero. The
financial obligations are unchanged regardless of whether the energy actually flows or
not. A bookout can be used to describe both preschedule and real time transactions.
Bookouts are reported in FERC Form 1 as sales for resale and purchased
power recorded in FERC Accounts 447 and 555 , respectively. Since bookouts are
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 8
normal sales and purchases , they are treated as such in the Company s PCA
calculations. Bookouts do not occur in the Company s power cost modeling.
The response to this request was prepared by David Bean , Controller
Power Supply, Idaho Power Company, and Gregory W. Said , Manager, Revenue
Requirement, Idaho Power Company, in consultation with Barton L. Kline , Senior
Attorney, Idaho Power Company.
REQUEST NO. 49: 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.
RESPONSE TO REQUEST NO. 49: Line 1020, Deal # 157605 included
in the data file provided in the Response to Request No. 22(g) showed the incorrect
price for the transaction; however, the total dollars shown for the transaction were
correct. There was an after-the-fact correction made to this transaction during the
checkout process to record the correct transaction dollar amount; a correction to the
price was not made at the same time. The file included on the CD labeled "Fourth
Production Request of Irrigation Pumpers - Responses" provided with this response
reflects the correction to the price. All other data included in the file provided in the
Response to Request No. 22(g) is correct.
The response to this request was prepared by David Bean , Controller
Power Supply, 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 FOURTH DATA REQUEST Page 9
DATED at Boise , Idaho, this 31st day of January, 2006.
~~~
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO IDAHO IRRIGATION
PUMPERS ASSOCIATION'S FOURTH DATA REQUEST Page 10
IDAHO POWER COMPANY
CASE NO. IPC-O5-
FOURTH DATA REQUEST
0 F THE ID AH 0 IRRI G A TI 0 N
PUMPERS ASSOCIATION, INC.
TT A CHMENT TO
RESPONSE TO
REQUEST NO. 45 b
IDAHO POWER COMPANY
Response to Request No. 45(b)
DIGIT4
AIKN
ALMA
AMDM
ARTN
BCRT
BKAT
BKCK
BKFT
BKHN
BLDR
BOBN
BOIS
BOMT
BRDR
BTLR
BUBG
BUGU
BUHL
CACK
CARO
CATR
CDAL
CDWL
CHUT
CMBG
CNCK
CNCL
COVR
CSCD
CWVY
DALE
DESN
DIXI
DRKE
DTRC
DUFN
DWSY
EAGL
EDEN
EKHN
ELMR
EMET
ETGT
FALS
FATP
FILR
FSGL
FTHL
STA NAME
Aiken
Alameda
Amsterdam
Artesian
Bethel Court
Black Cat
Bannock Creek
Blackfoot
Buckhorn
Boulder
Boise Bench TS
Boise
Bowmont
Border
Butler
Bruneau Bridge
Blue Gulch
Buhl
Canyon Creek
Cairo
Crater
Cloverdale Trans Station
Caldwell
Chestnut
Cambridge
Crane Creek
Council
Clover
Cascade
Cow Valley
Dale
Deen
Dixie
Durkee
Dietrich
Duffin
Drewsey
Eagle
Eden
Elkhorn
Elmore Transmission Station
Emmett
Eastgate
Falls
Flat Top
Filer
Fossil Gulch
Fort Hall
CN TYNA ME
BINGHAM
BANNOCK
TWIN FALLS
TWI N FALLS
ADA
ADA
POWER
BINGHAM
CASSIA
VALLEY
ADA
ADA
CANYON
TWIN FALLS
ADA
ELMORE
TWI N FALLS
TWIN FALLS
ELMORE
MALHEUR
BINGHAM
ADA
CANYON
CANYON
WASHINGTON
GEM
ADAMS
TWIN FALLS
VALLEY
MALHEUR
GOODING
POWER
ELMORE
BAKER
LINCOLN
MINIDOKA
HARNEY
ADA
JEROME
BLAINE
ELMORE
GEM
TWIN FALLS
POWER
JEROME
TWIN FALLS
GOODING
BINGHAM
IDAHO POWER COMPANY
Response to Request No. 45(b)
DIGIT4
GARY
GEMM
GFRY
GGRU
GOWN
GRVE
HALY
HAVN
HBND
HDLK
HDSP
HFWY
HGSN
HGTN
HILL
HLND
HMDL
HOLY
HOPE
HRPR
HSTN
HTHL
HULN
HYDA
ILND
JKSN
JMSN
JNCN
JNTA
JNVY
JPLN
JROM
KCHM
KNYN
KRMR
KUNA
LAKE
LCNS
LCST
LKFK
LIME
LMHI
LNDN
LNSG
MCAL
MDRS
MDVA
MLBA
STA NAME
Gary
Gem
Glenns Ferry
Gooding Rural
Gowen
Grove
Hailey
Haven
Horseshoe Bend
Hidden Lake
Hidden Springs
Halfway
Hagerman
Huntington
Hill
Highland
Homedale
Holly
Hope
Harper
Huston
Hothole
Hulen
Hydra
Island
Jackson
Jamieson
Julion
Juntura
Jordan Valley
Joplin
Jerome
Ketchum
Kenyon
Kramer
Kuna
Lake
Lincoln
Locust
Lake Fork
Lime
Lemhi
Linden
Lansing
McCall Sub & Storage Yard
MIDROSE STATION
Midvale
Melba
CNTYNAME
ADA
CANYON
ELMORE
GOODING
ADA
ADA
BLAINE
BINGHAM
BOISE
VALLEY
ADA
BAKER
GOODING
BAKER
CANYON
BANNOCK
CANYON
MALHEUR
MALHEUR
MALHEUR
CANYON
OWYHEE
BINGHAM
JEROME
CASSIA
CASSIA
MALHEUR
MINIDOKA
MALHEUR
MALHEUR
ADA
JEROME
BLAINE
CASSIA
BINGHAM
ADA
TWI N FALLS
LINCOLN
ADA
VALLEY
BAKER
LEMHI
CANYON
CANYON
VALLEY
CANYON
WASHINGTON
CANYON
IDAHO POWER COMPANY
Response to Request No, 45(b)
DIGIT4
MLNR
MNHM
MOON
MORA
MPRK
MRBT
MRDN
MRLD
NHBT
NMPA
NWMS
NWPM
NYSA
OCHD
OIDA
OKLY
OLM
ONTO
OYDM
PAET
PAUL
PNCK
PNGE
PNUF
POCO
PRIN
PRMA
PTVY
RKFD
RKVL
RSET
RSFK
SAMN
SCOT
SCSU
SHSH
SIPN
SLVR
SMFY
SOPK
SRCK
STAR
STAT
STRD
TERY
TFSN
THCK
TMKC
STA NAME
Milner
Mountain Home City
Moonstone
Mora
Map Rock
Malheur Butte
Meridian
Moreland
Notch Butte
Nampa
New Meadows
New Plymouth
Nyssa Sub
Orchard
Ore-Ida
Oakley
Ola
Ontario
Owyhee Dam
Payette
Paul
Pine Creek
Pingree
Portneuf
Pocatello
Perrine
Parma
Pleasant Valley Tap
Rockford
Rockville
Russet
Ross Fork
Salmon
Scott Valley
Sinker Creek
Shoshone
Siphon
Silver
Smiths Ferry
South Park
Sailor Creek
Star
State
Stoddard
Terry
Twin Falls
Three Creek
Tamarack CSPP
CN TYNA ME
TWIN FALLS
ELMORE
BLAINE
ADA
CANYON
MALHEUR
ADA
BINGHAM
JEROME
CANYON
ADAMS
PAYETTE
MALHEUR
ELMORE
MALHEUR
CASSIA
GEM
MALHEUR
MALHEUR
PAYETTE
MINIDOKA
BAKER
BINGHAM
BANNOCK
BANNOCK
JEROME
CANYON
POWER
BINGHAM
MALHEUR
TWIN FALLS
BINGHAM
LEMHI
VALLEY
OWYHEE
LINCOLN
BANNOCK
BLAINE
VALLEY
TWIN FALLS
ELMORE
ADA
ADA
ADA
BANNOCK
TWIN FALLS
OWYH EE
ADAMS
IDAHO POWER COMPANY
Response to Request No. 45(b)
DIGIT4
TMRK
TNDY
TNML
TOPN
TYHE
UNTY
USTK
VALE
VLVU
VTRY
WARE
WBUT
WESR
WNDL
WWCK
WYEE
ZLOG
S TA NA ME
Tamarack
Tendoy Transm Line Reg Station
Ten Mile
Toponis
Tyhee
Unity
Ustick
Vale
VALLIVUE STATION
Victory
Ware
Wilson Butte
Weiser
Wendell
Willow Creek
Wye
Zilog
CNTYNAME
ADAMS
LEMHI
ADA
GOODING
BANNOCK
BAKER
ADA
MALHEUR
CANYON
ADA
CANYON
JEROME
WASHINGTON
GOODING
PAYETTE
ADA
CANYON
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31st 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 FOURTH 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 (ij) 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(ij) racinelaw.net
elo (ij) racinelaw. net
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Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
yankel (ij) attbLcom
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Peter J. Richardson
Richardson & O'Leary
515 N. 27th Street
O. Box 7218
Boise ,. ID 83702
peter(ij) richardsonandolearv.com
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Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
dreadinq (ij) mindsprinq.com
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Lawrence A. Gollomp
Assistant General Counsel
United States Dept. of Energy
1000 Independence Avenue, SVV
Washington , D.C. 20585
Lawrence.Gollomp(ij) 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 (ij) aol.com
Conley E. Ward
Givens , Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
cew (ij) qivenspu rsleV.com
Dennis E. Peseau , Ph.D.
Utility Resources , Inc.
1500 Liberty Street S., Suite 250
Salem , OR 97302
dpeseau (ij) excite.com
William M. Eddie
Advocates for the West
1320 W. Franklin Street
O. Box 1612
Boise , ID 83701
billeddie(ij) rmci.net
Ken Miller
NW Energy Coalition
5400 W. Franklin , Suite G
Boise, ID 83705
kenmiller1 (ij) cableone.net
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
36 East Seventh Street, Suite 1510
Cincinnati , Ohio 45202
mkurtz (ij) bkllawfirm.com
kboehm (ij) bkllawfirm.com
CERTIFICATE OF SERVICE , Page 2
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B RTON L. KLINE