20080711IIPA to IPC 1-23.pdf

LAW OFFICES OF
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.D.
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
JONATHAN M. VOLYN
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: (208) 39!5~001 1
FACSIMILE: [phone]
ww.racinelaw.net
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, 1083402
TELEPHONE: [phone]
FACSIMILE: [phone]
TELEPHONE [phone]
FACSIMILE [phone]
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD. SUITE tOSA
COEUR D'ALENE, ID 83814
TELEPHONE: [phone]
SENDER'S E-MAIL ADDRESs:ELO!§racinelaw.net
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON, OF COUNSEL
July 9,2008
---Jean D. Jewell, Secretar
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074 '?-
C;í
Re: Case No. IPC-E-08-10
Dear Mrs. Jewell:
Enclosed for fiing in the captioned matter, please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's First Data Requests to Idaho Power Company.
t:~
ELO:rr
Enclosures
cc: Serce List
ERIC L. OLSEN
IL
Eric L. Olsen ISB# 4811
RACINE, OLSON, NY,BUDGE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
~.tdjO
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 CHAGES FOR ELECTRIC SERVICE )
TO ELECTRIC CUSTOMERS IN THE )STATE OF IDAHO. )
)
CASE NO. IPC-E-08-10
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA
REQUESTS TO IDAHO POWER COMPAN
IDAHO IRRGATION PUMERS ASSOCIATION, INC. ("IIPA"), by and
through its attorneys, hereby submits ths First Data Requests to Idaho' Power Company,
pursuant to Rule 225 of the Idaho Public Utility Commission's Rules of Procedure,
IDAPA 31.01.01, as follows:
1. Please provide a copy of the Company's Char of Accounts.
2. For all FERC Expense Accounts listed in Exhbit 41, please provide by subaccount,
by month, the actual expenses that were incured from Januar 2007 though the most
recent month available. Please provide ths information in electronic verion.
3. Please supply in electronic format for each month since Januar 2006 the biling
month usage of each of the rate categories listed. in Exhbit' 69 in the Idaho
jursdiction. See responses to Irgator Requests 3-6 (fist set) in Case E-07-08.
4. Please supply in electronic format for each month since Januar 2006 the calendar
month usage of each of the rate categories listed in Exhbit 69 inthe Idaho
jursdiction. See responses to Irgator Requests 3-6 . (first set) in Case E"07 -08.
IDAHO. IRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMPAN - 1
5. 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
Januar 2007 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 servce study in ths case;
g. Please provide copies of the 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 serce study in ths case;
h. Please indicate which (if any) of the Irgators sampled in the Company's load
research data that was provided in "d" above were on Schedule 23.
6. Please provide for each month from Januar 2007 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 numercal data in these reports is
usedto reflect accuracy of sample.
7. It is the Irgators understanding that the Company collects a separate sample of
hourly load data for customers on Schedule 23inorderto spot-check the perormance
of tlieIrgation Peak Rewards Program. Please supply ths hourly data for all such'
customers between Januar 2004 and the most recent month available.. Please
indicate if there is some overlap with ths data andthe'Company's load research data,
and if there is, indicate which sample customers overlap.
8. Please provide in electronic format, on an hourly basis, for the period Januar 1, 2007
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); .
IDAHO IRRGATION PUMPERS'ASSOCIArION,.INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMPANY- 2
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 "c" above;
e. System input from non-firm and/or economy purchases, statig 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;
i. Other system inputs, stating. for each "other" input the tye and the source of the
input;
J. System losses;
k. Requirements Wholesale sales (RQ);
1. Long-ter firm Wholesale sales (LF), stating each on separately;
m. Intermediate-ter firm Wholesale sales (IF),. stating each one separately;
n. Short-term Wholesale sales (SF),.stating each one separately;
o. Unit sales, Wholesale (LU) or otherise,. 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 of the system, stating each exchange separately; .
s. Other system outputs, stating for each "other" output the type and recipient of the
output;
t. Inadverent power flows into or out of the system;
u. The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadverent has been subtracted;
v. Losses assigned to each retail jursdiction;
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
FIRT DATA REQUESTS TO IDAHO POWER COMPANY- :3
w. Losses assigned to Wholesale sales;
x. Total retalload by jursdiction;
9. Please provide a copy of any margial cost analysis that the Company has perormed
since E-07-08.
10. From Januar 2007 through the most recent month available, what was the. date and
time of the monthly system peak?
11. Durg the hour of the monthly peak from Janua 2007 though the most recent
month available, please provide the followig:
a. How many megawatts of generation were out of serice for planed maintenance?
b. How much electrcity was generated from Company owned hydro?
c. How much electrcity was purchased from Company owned, theral power?
d. How much electrcity was purchased from QF suppliers?
e. How much electrcity 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,MW purchased, purchase price,
and type of purchase (LF, RQ, SF, OS, etc.)?
f. How much. electrcity was sold off-system and at what price? Please list each
transaction separately, stating name of seller, MW sold, sale price, and type of
sale (LF, RQ, SF, OS, etc.)?
g. How much load was interrpted via the Irrgation Load Management program or
other similar.programs? Please specify each program separately.
12. Regarding Mr. Tatu's workpapers 40-43:
a. Are these values on a "calendar" or "biling" month basis?
b. If these values are at "sales level", please supply these same values in electronic
format at "generation.level".
c. If these values are on a "biling month" basis, please supply in electronic format
the same information on a "calendar Month" basis.
IDAHO.lRGATION PUMPERS ASSOCIATION; INC.'8
FIRST DATA REQUESTS TO IDAHO POWER COMPANY-4
13. Mr. Tatu's workpapers at page 35 and 36 discuss modifications to the demand
estimates for the Irgation customers. Please supply in electronic format the data
(and associated changes) that occur in each of the thee steps that he addresses.
14. Regarding Exhibit 55, page 27, line 828, why is the uncollectible value for the
Irgators negative?
15. Regarding the testimony of Ms. Brilz at page .13 regarding the meter reading accuracy
of99.8 percent since2003, please provide for each year since 2003:
a. Please explain how an accuracy figue is obtainedlcalculated(i.e. what data is
used).
b. Please provide in electronic format the data used to substatiate the 99.8% figue.
c. Regarding the data that represents the 0.2% eror, please provide in electronic
format a listing of each meter that was reading too high, the rate. schedule
involved, the factor bywhich it was off, the amount of kWh eror, and the lengt
of time the error existed.
d. Regarding the data that represents the 0.2% eror, please provide in electronic
format a listing of each meter that was reading too low, the rate schedule
involved, the factor by which it was off, the amount of kWh eror, and the lengt
of time the eror existed.
16. On page 14 of the testimony of Ms. Brilz there is a discussion of 15 incidences where.
incorrect multipliers resulted in incorrect bilings. For each of those 15 cases, please
provide:
a. The amount of extra kWh the meter read or the amount of kWh the meter under
read for each month of the eror.
b. The monetar resolution of the incorrect meter reading-how much money (by
month) waspaid (or to be paid) by the customer, or credited to the customer.
17. If the meter reading error associated with Case No. IPC-E-07-01wäs not a par of the
response to Interogatory 16 above, please provide similar inormation for Case No.
IPC-E-07 -01.
18. If the meterrèading eror associated with CaseNo.IPC- E-07-16 was not a par of the
response to Interrogatory 16 above, please provide simlar information for Case No.IPC-E-07-16. .
19; If the meter reading erors associated with other customers similar to that inCase No.
IPC-E-07-16 was not apar of the response to Interrogatory 16 above, please provide
similar information as requested in Interogatory 16 above.
IDAHO IRGATION PUMPERS ASSOCIATION,INC.'S
FIRST DATA REQUESTS TO IDAHO POWER COMPAN - 5
20. On page 17 of the testimony of Ms. Brilz there is a discussion of system perormance
standards that were developed for Schedules 7 and 9.
a. Please provide a copy ofthese performance standards and how they relate to the
employee incentive program.
b. What are the specific reliability tagets for ths group of customers?
c. What are the reliabilty results for each of the last five years for this group of
customers?
d. What are the reliabilty results for each of the last fi'Ve years for the other rate
schedules in Idaho?
21. Please provide in electronic format outage data for each substation and each circuit in
each substation for each of the last five years:
a. The date, time and duration of any outage.
b. The number of customers impacted by rate schedule.
c. The estimated kW of load impacted.
d. Any other data the Company routinely keeps regarding outages such as cause of
the outage.
22. Please provide electronically any SAIDI, SAIFI, MAID!, or CAIDI information that
the Companý has collected over the past five years. Such data should be provided at
the least aggregated level it is maintained by the Company.
23. Exhbit 9 lists SAIFI data by week. There are noticeable increases in these values
around the 34th week of 2006 and the 24th week of 2007. These increases appearto be
sustained and not mere one weék occurences. What explanation does the. Company have
for these increased levels to have continued from week to week?
DATED this .sday of July, 2008.
RACINE, OLSON, NYE, BUDGE&
BAILEY ERED
RIeL. OLSEN, Attorney for
Idaho Irgation Pumpers
Association, Inc.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIST DATA REQUESTS TO IDAHO POWER COMPAN -6
.
CERTIFICATE OF MAIING
I HEREBY CERTIFY that onthis · Crih day of July, 2008,1 sered a tre,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
jean D.Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washigton Street
Boise, Idaho 83720-0074
j j ewel1(ffpuc. state. id. us U .S.Mail/PostagePrepaid
Baron L. Kline
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
bklineWlidahopower.com
InordstromWlidahopower.com
dwalkerWlidahopower.com
U.S. Mail/Postage Prepaid
JohnR. Gale
Vice President, Regulatory Affairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
rgaleWlidahopower.com U.S. Mail/ostage Prepaid
Anthony Yanel
29814 Lake Road
Bay Vilage, OR 44140
E-mail: tony(yane1.net
viaE-mail
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIST DATA REQUESTS TO IDAHO POWER COMPAN - 7