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Home My WebLink About20070919IPC to IIPA 3-1 to 3-5.pdfREGE -- IDAHOa..;!! POWER An IDACORP Company zmn SEP \ 9 Pi'1 3: \()J\\"tO Fj \..!~,, ~c" l\ TI;:':;:: CUP/H':':!;:"::;!""" ,~, .~ BARTON L. KLINE Senior Attorney September 19 , 2007 Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P. O. Box 83720 Boise , Idaho 83720-0074 Re:Case No. IPC-07- General Rate Case Filing Dear Ms. Jewell: Please find enclosed an original and two (2) copies of Idaho Power s Response to the Third Production Request of the Idaho Irrigation Pumpers Association , Inc. in the above-referenced matter. I would appreciate it if you would return a stamped copy of this transmittal letter in the enclosed self-addressed , stamped envelope. Very truly yours (1~=11 Barton L. Kline BLK:sh Enclosure O, Box 70 (83707) 1221 W. Idaho St, Boise, ID 83702 BARTON L. KLINE ISB #1526 LISA D. NORDSTROM ISB #5733 Idaho Power Company O. Box 70 Boise , Idaho 83707 Telephone: (208) 388-2682 FAX Telephone: (208) 388-6936 Attorney for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 RECf/' nrn Uu I r! 3: 46 '1"if2Al'fO " I,lilt lilr-t(, , . C';::, C 'f/iM1SSfO., 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-07- RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. COMES NOW , Idaho Power Company ("Idaho Power" or "the Company ) and, in response to Idaho Irrigation Pumpers Association, Inc.'s Third Set of Discovery Requests to Idaho Power Company dated August 22, 2007 , herewith submits the following information: RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION , INC., Page REQUEST FOR PRODUCTION NO. 3-Please indicate which (if any) of the Irrigators sampled in the Company s load research data that was provided as a part of the Company s response to Irrigator request 1-7 were on Schedule 23. RESPONSE TO REQUEST FOR PRODUCTION NO. 3- The requested information is provided on the enclosed CD. 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 and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company. RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION , INC., Page 2 REQUEST FOR PRODUCTION NO. 3-What is the criteria for separating Irrigators (by size) into the four strata that are found in the load research data provided in the response to Irrigator request 1- RESPONSE TO REQUEST FOR PRODUCTION NO. 3- The stratifying variable for the 2006 sample was the maximum monthly kWh billed during the period May-September, 2005. If a bill covered more than 30 days, the energy was normalized to 30 days. The upper boundaries of the first three strata were 000 kWh , 100 000 kWh, and 350 000 kWh , and the fourth stratum included all over 350 000 kWh. The stratifying variable for the 2002 - 2005 sample was the maximum monthly kWh billed during the period May-September, 2000. Bills from 2001 were not used because a significant number of customers participated in the buy-back program. The upper boundaries of the first three strata were 30 000 kWh, 125 000 kWh, and 500 000 kWh, and the fourth stratum included all over 500 000 kWh. 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 and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company. RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., Page 3 REQUEST FOR PRODUCTION NO. If Schedule 23 customers are sampled or metered in a manner similar to the Company s load research data for Schedule 24 please provide this data on an hourly basis for 2004-2006 listing also strata and weighting factors. RESPONSE TO REQUEST FOR PRODUCTION NO. The company does not have a statistical load research sample specific to Schedule 23. However, to monitor and spot-check the performance of the Irrigation Peak Rewards Program, some interval meters were installed. The hourly loads from each of these interval meters are provided on the enclosed CD. Since these meters are not part of a statistical sample, stratum weighting factors do not apply. 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 and/or Lisa D. Nordstrom, Attorney II, Idaho Power Company. RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., Page 4 REQUEST FOR PRODUCTION NO. 3-Please indicate which (if any) of the Irrigators sampled in the Company s load research data that was provided as a part of the Company s response to Irrigator request 1-7 were on Schedule 23. RESPONSE TO REQUEST FOR PRODUCTION NO. 3- Please see Response to Request No. 3-1 . 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 and/or Lisa D. Nordstrom , Attorney II , Idaho Power Company. RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION , INC., Page 5 REQUEST FOR PRODUCTION NO. 3-: What is the criteria for separating Irrigators (by size) into the four strata that are found in the load research data provided in the response to I rrigator request 1- RESPONSE TO REQUEST FOR PRODUCTION NO. 3- Please see Response to Request No. 3- 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 and/or Lisa D. Nordstrom, Attorney II , Idaho Power Company. DATED at Boise , Idaho, this ~ay of September, 2007. BARTO L. KLI N E Attorney for Idaho Power Company LISA D. NORDSTROM Attorney for Idaho Power Company RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., Page 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this .J4!day of September, 2007, I served a true and correct copy of the within and foregoing document upon the following named parties by the method indicated below , and addressed to the following: Commission Staff Weldon Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) O. Box 83720 Boise, Idaho 83720-0074 Donovan Walker Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) O. Box 83720 Boise , Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. Richardson & O'Leary 515 N. 2ih Street O. Box 7218 Boise, Idaho 83702 Don Reading Ben Johnson Associates 6070 Hill Road Boise, Idaho 83702 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen Racine , Olson , Nye , Budge & Bailey O. Box 1391 201 E. Center Pocatello, Idaho 83204 ---.2LHand Delivered - U.S. Mail Overnight Mail FAX ---X. Email Weldon.stutzman(g)puc.idaho.qov ---.2LHand Delivered - U.S. Mail Overnight Mail FAX ---X. Email Donovan.walker(g) puc.idaho.qov Hand Delivered ---2LU.S. Mail Overnight Mail FAX Email peter(g) richardsonandolearv.com Hand Delivered ---2LU.S. Mail Overnight Mail FAX Email dreadinq(g)mindsprinq.com Hand Delivered ---2LU.S. Mail Overnight Mail FAX Email elo(g) racinelaw.net RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION , INC., Page 7 Anthony Yankel 29814 Lake Road Bay Village , OH 444140 Kroger Co. Fred Meyer and Smiths Michael L. Kurtz Kurt J. Boehm Boehm , Kurtz & Lowry 36 East Seventh Street, Suite 1510 Cincinnati , Ohio 45202 The Kroger Co. Attn: Corporate Energy Manager (G09) 1014 Vine Street Cincinnati , Ohio 45202 Micron Technology Conley Ward Michael C. Creamer Givens Pursley 601 W. Bannock Street O. Box 2720 Boise, Idaho 83701 Dennis E. Peseau , Ph. Utility Resources, Inc. 1500 Liberty Street SE , Suite 250 Salem , OR 97302 Department of Energy Lot Cooke Arthur Perry Bruder Office of the Attorney General United States Department of Energy 1000 Independence Ave., SW Washington , DC 20585 Routing Symbol GC- 76 Hand Delivered X U.S. Mail Overnight Mail FAX Email tony(g)yankel.net Hand Delivered ~ U.S. Mail Overnight Mail FAX Email mkurtz(g)bkllawfirm.com kboehm (g) bkllawfirm.com Hand Delivered ---2L U.S. Mail Overnight Mail FAX Email Hand Delivered ---2L U.S. Mail Overnight Mail FAX Email cew(g) qivenspursleY.com mcc(g) qivenspursleY.com Hand Delivered ---2LU.S. Mail Overnight Mail FAX ---X. Email dpeseau(g)excite.com Hand Delivered - U.S. Mail ---.2L Overnight Mail FAX ---X. Email lotcooke(g)hq.doe.qov arthur.bruder(g) hq.doe.qov RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION , INC., Page 8 Dennis Goins Potomac Management Group 5801 Westchester Street O. Box 30225 Alexandria , VA 22310-8225 Hand Delivered ---2LU.S. Mail Overnight Mail FAX ---X. Email DGoinsPMG (g)cox.net Dale Swan Ammar Ansari Exeter Associates 5565 Sterrett Place, Suite 310 Columbia, MD 20904 Hand Delivered --2L U.S. Mail Overnight Mail FAX --2L Email dswan (g) exeterassociates.com aansari (g) exete rassociates. com fJjj Barton L. Kline RESPONSE OF IDAHO POWER TO THE THIRD PRODUCTION REQUEST OF THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., Page 9