20070910IIPA to IPC 4-1 to 4-8.pdf

Jean Jewell , Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise , Idaho 83720-0074
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 VOL YN
THOMAS J. BUDGE
CANDICE M. MCHUGH
Dear Jean:
LAW OFFICES OF
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMilE: [phone]
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
IDAHO FAllS, ID 83402
TELEPHONE: (208) 528-'0101
FACSIMilE: (208) 528-'0109www.racinelaw.net
SENDER'S E-MAIL ADDRESS: elo~racinelaw.net
COEUR '0 ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE 106A
COEUR D'AlENE, ID 83814
TELEPHONE: (208) 765-'0888
All OFFICES TOll FREE
[phone]
lOUIS F. RACINE (1917-2005)
WilLIAM D. OLSON, OF COUNSEL
September 7 2007
:--)
c'::'
c:;:::o
C::;:::
Z;~:~
--'(/)
r'I
I:)
:'t1
:c'
" .,
:'(i
Re:
!')
IPC-O7-
Enclosed please find the original and three (3) copies of Idaho Irrigation Pumpers
Association , Inc.s Fourth Data Request to Idaho Power Company.
ELO:sab
Enclosurescc: Service List
Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, C~TERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
F(EC=:~ . .
ZDJi SEP ! 8: 20
i!J/i-
UTii..!ES ISSiC:
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 C~GES FOR ELECTRIC SERVICE
TO ELECTRIC CUSTOMERS IN THE
ST ATE OF IDAHO.
CASE NO. IPC-07-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.S FOURTH DATA REQUEST
TO IDAHO POWER COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("lIP A"), by and through its
attorneys, hereby submits this Fourth 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:
lIP A 1: On pages 4-9 ofBrilz s workpapers in Case No. IPC-03-16 there is contained a
listing of data for individual distribution substations. Similar data is provided in page 4-7 of the
Tatum workpapers in this case. Please answer the following:
a. Please provide an electronic version of each of these sets of workpapers.
b. For each of the substations listed in the Tatum workpapers, please list the date it which it
recorded its maximum demand.
c. It is assumed that if a substation appears on the Tatum workpapers, but not on the Brilz
workpapers, then this would be considered a new substation since the 2003 rate case.
this assumption is incorrect for any of these substations, please indicate why names
would be different on each set of workpaper.
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
IDAHO POWER COMPANY -
d. Please explain why each of the following substations appear in the Brilz workpapers, but
not the Tatum workpapers: Gooding City, Homedale, and Meridian.
e. Please provide a list of the county in which each of the substations in Tatum
workpapers is located.
f. On page 4 of each set of workpapers there are several grouping of substations that have a
Customer Class" listed. Please explain the basis for this listing/identification compared
to no listing for majority of the substations.
g. The listing of substations on Tatum s workpapers does not completely agree with that
found on pages 426.x and 427.X of the Company s 2006 FERC Form 1. Please
reconcile the difference between these two lists.
h. The total values by Account found on page 7 of Tatum s workpapers differ slightly from
the values found on page 6 of Exhibit 49. What is the basis for the difference between
these two sets of data?
lIP A 4-2: What was the total amount of BP A credit paid out to the Idaho Irrigation
customers in 2006?
lIP A 4-3: What was the total amount of BP A credit paid out to the Idaho Residential
customers in 2006?
IIPA 4-4: How was the BPA credit paid out to Irrigation customers in 2006? Was it based
upon energy usage, size of customer, month of use, etc.
IIPA 4-5: Exhibit 29 page 30 lists Idaho energy usage at generation as 14,784 934 MWh.
This figure is in agreement with a comparable value on Exhibit 55 page 5 of the Company
class cost of service data. Exhibit 29 page 30 also lists Idaho energy usage at the customer level
as 13 475 244 MWh. This figure is almost in agreement with a comparable value on Exhibit 58
page 1 ofthe Company s class cost of service data. Please explain the following:
a. Why are the customer level usage figures on Exhibit 29 page 30 the same as those on
Exhibit 58 page I?
b. Does the Company s modeling of its power supply costs in this case include the
784 934 MWh of generation level energy found on Exhibit 29 page 30 as well as the
total system amount of 15 612 689? If not, what values were used for Idaho and System
Total usage at generation level? Where are these values found in the filing?
c. The total system energy losses listed on page 401 a of the 2006 FERC Form 1 are
254 358 MWh. These losses are associated with 13.9 million MWh of Retail load and
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
IDAHO POWER COMPANY - 2
an additional 5.7 million MWh of Sales for Resale. Subtracting the customer level value
of 13 475 244 MWh from the 14 784 934 MWh values on Exhibit 29 page 30, results in
losses of 1 309 690 MWH, which is greater than the losses recorded in the 2006 Form
for both Retail and Wholesale. Why are these losses in the filing so much greater than in
the Form I?
lIP A 4-6: As a part of the System energy usage listed on Exhibit 29 page 30 there is a
category of "TOT AL OTHER" which lists 2 286 267 MWH of usage at the Customer level and
only 827,764 MWH of usage at the Generation level.
a. Please provide a detailed explanation regarding why the customer level value is
approximately 3 times higher than the generation level value.
b. What value (at generation level) is used for "TOTAL OTHER" energy in the Company
power cost model run in this case, and where can it be found in the filing?
IIPA 4-7: In the Company s response 2-2 to the lIP A, it is indicated that for lightlheavy load
hour purposes that it considers there to be 6 holidays that are all light-load hours. Please name
each of these holidays.
IIPA 4-8: The Company s response to 2-1 to the IIPA contained hourly data regarding
Aurora HR Load Output" and "2006 Total System HR Load.
a. Is the hourly data under the tab "Aurora HR Load Output" the data upon which the power
supply costs in this case were based?
b. How do the timeframes and corresponding values compare between the tab "Aurora HR
Load Output" and the tab "2006 Total System HR Load"? Specifically, the first entry for
the tab "Aurora HR Load Output" is at 111/2007 Hour: 1 and has a value of 1 307 MW
and the first entry for the tab "2006 Total System HR Load" has a time of01-Jan-
00:00:00 and a value of 1,450 MW. It would appear that these are corresponding values
for the first hour of the year. All values and times appear to track each other until March
2006 at 2-3 a.m. when daylight savings time went into effect.
c. How are light-load and heavy load hours reflected in tab "Aurora HR Load Output" and
tab "2006 Total System HR Load" (given daylight savings time)?
d. The average usage during January 2006 was 1 680 MW, while under the Aurora model
the January 2007 average was 5.9% higher at 1 779 MW. What caused this increase of
9% over January of the previous year?
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
IDAHO POWER COMPANY - 3
e. The maximum usage during January 2006 was 2 079 MW, while under the Aurora model
the January 2007 maximum was 17.6% higher at 2 495 MW. What caused this increase
of 17.6% over January of the previous year?
f. By the Irrigators calculation, there were 308 heavy load hours in both January 2006 and
2007. The combined heavy load energy usage in the 2006 data was 558 213 MWH
while the 2007 showed and increase of7.0%--up to 597 396 MW. What caused this
increase to be so much larger than the average January energy increase of 5.9%?
g. The combined light load energy usage in the 2006 data was 691 836 MWH, while the
2007 showed and increase of 4.9%--up to 725 850 MW. What caused this increase to be
smaller than the average January energy increase of 5.9%?
Respectfully submitted this J'h day of September, 2007.
ERIC L. OLSEN
Attorneys for the Idaho Irrigation Pumpers
Association, Inc.
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this J'h day of September , 2007, I served a true
correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.s Second
Data Request to Pacificorp to each of the following, via U.S. Mail postage prepaid, e-
mail or hand delivery:
Jean Jewell (original and 3)
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
E-mail: iean.iewell~puc.idaho.gov
S. Mail and
via E-mail
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline~idahopower.com
E-mail: mmoen~idahopower.com
via E-mail
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E~mail: rgale~idahopower.com
via E-mail
Michael L. Kurtz, Esq.
Kurt J. Boehm , Esq.
Boehm, Kurtz & Lowry
36 E. Seventh Street, Suite 1510
Cincinnati, Ohio 45202
E-mail: mkurtz~FKLlawfirm.com
E-mail: kboehm~BKLlawfirm.com
via E-mail
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, Idaho 83701-2720
E-mail: cew~givenspursley.com
via E-mail
Lot H. Cooke
Acting Assistant General Counsel
via E-mail
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA
REQUEST TO IDAHO POWER COMPANY - 5
United States Department of Energy
1000 Independence Avenue, S.
Washington, D.C. 20585
E-mail: Lotcooket0hq.doe.gov
Dennis Goins
Potomac Management Group
5801 Westchester Street
O. Box 30225
Alexander, VA 22310-1149
E-mail: DGoinsPMGt0cox.net
via E-mail
Arthur Perry Bruder
United States Department of Energy
Office of the General Counsel
1000 Independence Ave. S.
Washington, D.c. 20585
E-mail: Arthur.Brudert0HO.doe.gov
via E-mail
Dennis E. Peseau, Ph.
Utility Resources , Inc.
1500 Liberty Street, Suite 250
Salem, Oregon 97302
E-mail: dpeseaut0excitcom
via E-mail
Dale Swan
Exeter Associates, Inc.
5565 Sterrett Place Suite 310
Columbia, Maryland 21044
E-mail: dswant0exeterassociates.com
via E-mail
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tonYt0yankel.net
via E-mail
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA
REQUEST TO IDAHO POWER COMPANY - 6