20070723IIPA to IPC 1, 1-18.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
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. ALEXANDER
LANE V. ERICKSON
PATRICK N. GEORGE
SCOTT J. SMITH
STEPHEN J. MUHONEN
BRENT L. WHITING
JUSTIN R. ELLIS
JOSHUA D. JOHNSON
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN
THOMAS J. BUDGE
CANDICE M. MCHUGH
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Re:IPC-O7-
Dear Jean:
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
www.racinelaw.net
SENDER'S E-MAIL ADDRESS: eloC1!Jracinelaw.net
July 19, 2007
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE: [phone]
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, ID 83402TELEPHONE: [phone]
FACSIMILE: [phone]
COEUR '0 ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE 106A
COEUR D'ALENE, ID 83814TELEPHONE: [phone]
ALL OFFICES TOLL FREE(877) 232-6101
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON. OF COUNSEL
':',
c':?
(/):- .
(.1,
Enclosed please find the original and three (3) copies ofIdaho Irrigation Pumpers Association, Inc.
First Data Request to Idaho Power Company
ELO :rr
Enclosurescc: Idaho Power
Barton L. Kline
Monica B. Moen
John R. Gale
S:~A
ERIC L. 0/::;;;'0
Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
L:,!LF ) /
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-O7-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'S FIRST DATA
REQUEST TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and
through its attorneys, hereby submits this First Data Request to Idaho Power Company,
pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure
IDAPA 31.01.01 , as follows:
IIPA 1-Please provide a copy ofthe Company s Chart of Accounts.
lIP A 1-For all FERC Expense Accounts listed in Exhibit 25 , please
provide by subaccount, by month, the actual expenses that were incurred from July 2003
through the most recent month available. Please provide this information in both hard
copy as well as an electronic version.
lIPA 1-Please supply in electronic format for each month since January
2004 the billing month usage of Schedule 24 and 25 customers in the Idaho jurisdiction.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST FOR IDAHO POWER - 1
lIPA 1-Please supply in electronic format for each month since January
2004 the calendar month usage of Schedule 24 and 25 customers in the Idaho
jurisdiction.
lIPA 1-Please supply in electronic format for each month since January
1994 the billing month usage of each of the rate categories listed in Exhibit 43 (except
Schedule 24 and 25) in the Idaho jurisdiction.
lIPA 1-Please supply in electronic format for each month since January
1994 the calendar month usage of each of the rate categories listed in Exhibit 43 (except
Schedule 24 and 25) in the Idaho jurisdiction.
lIP A 1-With respect to the Company s Load Research data, please provide
in Excel or Access format, for each sample customer with valid data that was sampled
between January 2003 and the most recent month available the following:
a. Customer identification number;
b. Customer rate schedule;
c. Strata to which it belongs;
d. Raw hourly usage data;
e. Raw hourly usage data modified to reflect losses;
f. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in
the Company s cost of service study in this case;
g. Please provide copies ofthe formulas (and data) used to expand the Load
Research data (strata weighting factors etc.) up to the population as a
whole as used in the class cost of service study in this case.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST FOR IDAHO POWER - 2
lIPA 1-Please provide for each month from January 2003 to the most
recent month available a copy of the monthly checks that the Company makes regarding
how well the Load Research sample data reflects the actual population usage. Also
supply for one month and one rate schedule an explanation of how the numerical data in
these reports is used to reflect accuracy of sample.
lIPA 1-Please provide a copy of the bill frequency distribution for each
month from January 2004 through December 2006 for Schedules 1 , 7, 9, 19, 14 25.
lIPA 1-10:Please provide a copy of the bill frequency distribution for each
month ofthe test year for Schedules 1 , 7 , 9 , 19, 14 25.
lIP A 1-11:Please provide in electronic format, on an hourly basis, for the
period January 1 , 2004 through the most recent month available the following data:
a. Total system input;
b. System input from Company owned generation (stating hydro, coal, and
other generation separately);
c. System input from firm purchases, stating each purchase separately by
source and type of purchase (LF, IF, SF, etc.
d. The cost of each firm purchase listed in "" above;
e. System input from non-firm and/or economy purchases, stating each
purchase separately;
f. The cost of each non-firm and/or economy purchase listed in "E" above;
g. System input from exchanges into the system, stating each exchange
separately;
h. System input from Unit purchases;
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST FOR IDAHO POWER - 3
Other system inputs, stating for each "other" input the type and the source
of the input;
System losses;
k. Requirements Wholesale sales (RQ);
Long-term firm Wholesale sales (LF), stating each on separately;
m. Intermediate-term firm Wholesale sales (IF), stating each one separately;
n. Short-term Wholesale sales (SF), stating each one separately;
o. Unit sales, Wholesale (LU) or otherwise, stated separately;
p. Non-firm and/or economy Wholesale sales (OS), stated separately;
q. The revenue collected each hour from each non-firm and/or economy
purchased listed in "P" above.
r. Exchanges out ofthe system, stating each exchange separately;
s. Other system outputs, stating for each "other" output the type and
recipient of the output;
Inadvertent power flows into or out of the system;
u. The power available (at input level) to supply retail load once Wholesale
Exchange, Wheeling, and Inadvertent has been subtracted;
v. Losses assigned to each retail jurisdiction;
w. Losses assigned to Wholesale sales;
x. Total retail load by jurisdiction.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST FOR IDAHO POWER - 4
lIPA 1-12:Please provide a copy of any marginal cost analysis that the
Company has performed since 2003.
lIP A 1-13:From January 2004 through the most recent month available, what
was the date and time of the monthly system peak?
lIP A 1-14:During the hour of the monthly peak from January 2004 through
the most recent month available, please provide the following:
a. How many megawatts of generation were out of service for planned
maintenance?
b. How much electricity was generated from Company owned hydro?
c. How much electricity was purchased from Company owned thermal
power?
d. How much electricity was purchased from QF suppliers?
e. How much electricity was brought in or sent out through exchanges? How
much (non-QFO electricity was purchased and at what price? Please list
each transaction separately, stating name of seller, MWH purchased
purchase price, and type of purchase (LF, RQ, SF , OS , etc.
f. How much electricity was sold off-system and at what price? Please list
each transaction separately, stating name of seller, MWH sold, sale price
and type of sale (LF, RQ, SF , OS, etc.
g.
How much load was interrupted via the Irrigation Load Management
program or other similar programs? Please specify each program
separately.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST FOR IDAHO POWER - 5
lIPA 1-15:F or each of the next three years, what are the dates of scheduled
maintenance, name of the units being maintained, and the megawatts being taken out of
service?
lIP A 1-16:With respect to the system, as well as class, demands and energies
listed on Exhibit 40, if the values listed are not actual (or directly derived from load
research data for the exact hour), please provide a description as well as all data used to
derive the values listed in Exhibit 47.
lIP A 1-17:On page 8 of Tatum s workpapers there are various values listed
under the column entitled "DA364". Please answer the following:
a. What is the source of the figure under "Ratio Computation" for Primary of
168 550 439?
b. Please describe the methodology of dividing Acc1. 364 into its primary
component (168 550 439). Please give examples.
c. If a pole or tower carried both primary and secondary lines, what portion
ofthe pole would be assigned to the primary component (168 550 439)?
d. If a line transformer were on a pole or a tower such that the primary line
ends at this particular pole and the secondary line starts at this pole, what
portion of the pole would be assigned to the primary component
(168 550,439)?
e. If a pole or tower were used as part of a Service Drop, would it be
assigned to Account 364 or Account 369?
f. Please provide a copy of the study that developed the System Customer
Component of36.22% and the System Demand Component of63.78%.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST FOR IDAHO POWER - 6
lIPA 1-18:How many miles of primary and secondary conductor are found in
the Idaho Jurisdiction? Please describe how these figures are derived.
DATED this 19th day of July 2007.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By:
J/& l/o
fQt
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST FOR IDAHO POWER - 7
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 19th day of July, 2007, 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 (original and 3)
Idaho Public Utilities Commission
O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
E-mail: jjewell~puc.state.id.S. Mail/Postage Prepaid
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
bk1ine~idahopower. com
mmoen~idahopower. com S. Mail/Postage Prepaid
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
rgale~idahopower . com S. Mail/Postage Prepaid
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST FOR IDAHO POWER - 8