20080808IPC to IIPA 1-23.pdf

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An IDACORP Company
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BARTON L. KLINE
Senior Attorney
August 7, 2008
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-08-10
General Rate Case
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies each of Idaho Power
Company's Response to the First Production Request of The Industrial Customers of Idaho
Power and Idaho Power Company's Response to the Idaho Irrigation Pumpers
Association, Inc.'s First Data Requests to Idaho Power Company.
In addition, also enclosed are two (2) CDs, four copies of each. The CDs contain
the Company's responses to production/data requests in which electronic/excel files were
requested and also for ease of production of the information.
Upon receipt of this filing, I would appreciate it if you would return a stamped copy of
this letter for my file in the enclosed stamped, self-addressed envelope.
Very truly yours,
ßtJtL
Barton L. Kline
Senior Attorney for Idaho Power Company
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Enclosures
P.O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
DONOVAN E. WALKER, ISB #5921
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
bkline(âidahopower.com
Inordstrom(âidahopower.com
dwalker(âidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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.
) CASE NO. IPC-E-08-10
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE IDAHO
) IRRIGATION PUMPERS ASSOCIATION,
) INC.'S FIRST DATA REQUESTS TO
) IDAHO POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), and in
response to the First Production Request of the Industrial Customers of Idaho Power
Company dated July 9,2008, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION NO.1: Please provide a copy of the Company's
Chart of Accounts.
RESPONSE TO REQUEST FOR PRODUCTION NO.1: The requested
information is provided on the enclosed CD.
This response to this Request was prepared by Lori Smith, Vice President of
Corporate Planning and Chief Risk Offcer, Idaho Power Company, in consultation with
Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO.2: For all FERC Expense Accounts listed
in Exhibit 41, please provide by subaccount, by month, the actual expenses that were
incurred from January 2007 through the most recent month available. Please provide
this information in electronic version.
RESPONSE TO REQUEST FOR PRODUCTION NO.2: This response wil be
made available as soon as possible after the 2nd Quarter Earnings Release.
This response to this Request was prepared by Lori Smith, Vice President of
Corporate Planning and Chief Risk Offcer, Idaho Power Company, in consultation with
Barton L. Kline, Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO.3: Please supply in electronic format for
each month since January 2006 the biling month usage of each of the rate categories
listed in Exhibit 69 in the Idaho jurisdiction. See responses to Irrigator Requests 3-6
(first set) in Case E-07 -08.
RESPONSE TO REQUEST FOR PRODUCTION NO.3: The requested
information is provided in an Excel file included with this response. Historical
normalized megawatt-hour sales are provided for all years with the exception of 2008,
which includes only test year data. Billng month data is included on Table I for each of
the requested years.
This response to this Request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO.4: Please supply in electronic format for
each month since January 2006 the calendar month usage of each of the rate
categories listed in Exhibit 69 in the Idaho jurisdiction. See responses to Irrigator
Requests 3-6 (first set) in Case E-07 -08.
RESPONSE TO REQUEST FOR PRODUCTION NO.4: The requested
information is provided in an Excel file included with this response. Historical
normalized megawatt-hour sales are provided for all years with the exception of 2008,
which includes only test year data. Calendar month data is included on Table II for
each of the requested years.
This response to this Request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO.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 January 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 service study in this 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 service study in this case;
h. Please indicate which (if any) of the Irrigators sampled in the Company's
load research data that was provided in "d" above were on Schedule 23.
RESPONSE TO REQUEST FOR PRODUCTION NO.5: In response to items
5.a, 5.b, 5.c, and 5.d, the customer identification numbers, rate schedule, stratum, and
hourly usage data are included on the enclosed CD in the Excel workbooks with "hourly"
in the file name.
Raw hourly usage data modified to reflect losses (5.e) does not exist. However,
the hourly usage data coincident with the system peaks or the group peaks may be
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 6
adjusted to reflect losses using the system loss coeffcients contained in the RefTables
spreadsheet of the workbook Demands08RCMedianFactors.xls
In response to item 5.f, the Company did not calibrate the hourly Load Research
data. See the response to Request No. 13 for information about the modifications to the
demand estimates for the Irrigation customers.
In response to item 5.g, the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of service
study in this case are contained in the following Excel workbooks:
1. Demands08RCMedianFactors.xls
2. StratumWeights.xls
3. MedianDemandFactors20032007.xls
and are on the enclosed CD. Additional documentation of the formulas and
methodology are provided in Mr. Tatum's workpapers on pages 35 through 39.
In response to item 5.h, all of the Schedule 23 customers were removed from the
Load Research sample as described in Mr. Tatum's workpapers at pages 35 and 36.
The data for these Peak Rewards program participants is provided separately in the
response to Request NO.7.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO.6: Please provide for each month from
January 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 numerical data in these reports is used to reflect accuracy of sample.
RESPONSE TO REQUEST FOR PRODUCTION NO.6: The relative precision
of the ratio estimates is contained in the monthly Load Research summary reports
provided on the enclosed CD. The relative precisions for the maximum coincident
demands of Rate 24 in July 2007 can be found on page 5 of Rate24Summary2007-
07.doc. For the group coincident demand, the relative precision at the 90 percent
confidence level was +/- 8.032 percent. For the coincident demand at the supplied hour
of the monthly system peak, the margin of error was +/- 7.763 percent.
For convenience, all of the relative precision values are tabulated in the
RelativePrecision.xls file on the CD.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION NO.7: It is the Irrigators understanding that the
Company collects a separate sample of hourly load data for customers on Schedule 23
in order to spot-check the performance of the Irrigation Peak Rewards Program. Please
supply this hourly data for all such customers between January 2004 and the most
recent month available. Please indicate if there is some overlap with this data and the
Company's load research data, and if there is, indicate which sample customers
overlap.
RESPONSE TO REQUEST FOR PRODUCTION NO.7: The hourly data from
participants in the Irrigation Peak Rewards Program ("IPR~") is provided on the
enclosed CD. There are two Excel workbooks for each year. One contains participants
who were never in the Load Research sample and the second contains participants who
were originally in the Load Research sample but were removed for this year's modified
analysis procedure. There is no overlap between these two groups or between either of
these groups and the irrigators whose hourly data was provided in response to Request
5.f. The three groups of irrigators are mutually exclusive.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION NO.8: Please provide in electronic format, on
an hourly basis, for the period January 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);
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, 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;
i. Other system inputs, stating for each "other" input the type and the source
of the input;
j. System losses;
k. Requirements Wholesale sales (RQ);
i. 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;
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -10
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. 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;
RESPONSE TO REQUEST FOR PRODUCTION NO. 8.a-j and I-u: The
requested information is provided on the enclosed CD.
To use these files, utilize the drop-down menus found on line 6. For instance,
clicking on the arrow on line 6 of column A wil show the drop-down menu for system
load data. To view the system load data, select "system load" from the menu. This
selection wil bring up the system load data starting in column Z. The specific
responses are identified by the column headings on line 5.
This response to this Request was prepared by Dave Bean, Power Supply
Controller, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 11
RESPONSE TO REQUEST FOR PRODUCTION NO. 8.k: The requested data
for Requirements Wholesale sales ("RQ") is included on the enclosed CD.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8.v: Hourly losses
assigned to each retail jurisdiction are not available. Loss factors for peak demand and
energy by voltage for each jurisdiction are contained in the RefTables spreadsheet of
the workbook Demands08RCMedianFactors.xls provided in response to Request No.
5.g. These are system loss factors by voltage level and are not calculated on an hourly
basis.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 8.w: Hourly losses
assigned to wholesale sales are not available. Loss factors for peak demand and
energy by voltage are contained in the RefTables spreadsheet of the workbook
Demands08RCMedianFactors.xls provided in response to Request No 5.g. These are
system loss factors by voltage level and are not calculated on an hourly basis.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 12
RESPONSE TO REQUEST FOR PRODUCTION NO. 8.x: Hourly retail load by
jurisdiction is not available. The spreadsheet labeled Demands2007Actual.xls on the
enclosed CD contains the monthly energy and coincident demand information for 2007
with and without losses. The monthly energy and coincident demand information for the
test year has been provided in Demands08RCMedianFactors.xls in the response to
Request NO.5.
The response to this Request was prepared by Paul Werner, Load Research and
Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -13
REQUEST FOR PRODUCTION NO.9: Please provide a copy of any marginal
cost analysis that the Company has performed since E-07 -08.
RESPONSE TO REQUEST FOR PRODUCTION NO.9: The 2008 marginal cost
analysis can be found in Mr. Tatum's workpapers, pages 46-53.
This response to this Request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -14
REQUEST FOR PRODUCTION NO. 10: From January 2007 through the most
recent month available, what was the date and time of the monthly system peak?
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The date and time of
the monthly system peak for January 2007 through the most recent month available is
attached hereto.
This response to this Request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -15
REQUEST FOR PRODUCTION NO. 11: During the hour of the monthly peak
from January 2007 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 11: The requested
information is provided on the enclosed CD.
This response to this Request was prepared by Dave Bean, Power Supply
Controller, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -16
RESPONSE TO REQUEST FOR PRODUCTION NO. 11.g: Idaho Power has
two demand response programs, the Irrigation Peak Rewards program and the AlC
Cool Credit program. These programs are offered during the summer months only. In
2007 for the system peak days in June, July, and August, the system load reduction
attributed to the Irrigation Peaks Rewards program in Idaho and Oregon excluding line
losses, was estimated to be 36.97, 35.10, and 28.62 Megawatts ("MW"), respectively.
The maximum estimated load reduction excluding line losses for the Irrigation Peak
Rewards program for 2007 was 37.44 MW. The estimated system load reduction
excluding line losses for the AlC Cool Credit program for the peak day in June 2007
was 8.56 MW. The AlC Cool Credit program did not cycle customers' air conditioners
on the system peak days in July or August 2007. The hour of monthly peak for June
2008, which is the most recent reported data, ended at 3:00 p.m. on Monday, June 30th.
Both the AlC Cool Credit and the Irrigation Peaks rewards programs operated on that
day. The AlC Cool Credit program operated from 3:00 p.m. to 7:00 p.m. and the
Irrigation Peak Rewards program operated from 4:00 p.m. to 8:00 p.m. Although
neither program was operating during the exact peak hour, both programs provided
peak load reduction on that day for their hours of operation. The AlC Cool Credit
program and the Irrigation Peak Rewards programs accounted for approximately 21.4
MW and 30.7 MW of load reduction excluding line losses, respectively.
This response to this Request was prepared by Pete Pengilly, Leader Customer
Research Analysis, Idaho Power Company, in consultation with Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 17
REQUEST FOR PRODUCTION NO. 12: Regarding Mr. Tatum's workpapers 40-
43:
a. Are these values on a "calendar" or "billng" 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 "billng month" basis, please supply in electronic
format the same information on a "Calendar Month" basis.
RESPONSE TO REQUEST FOR PRODUCTION NO. 12:
a. The values provided on Mr. Tatum's workpapers, pages 40-43, represent
the normalized kilowatt-hour sales for the 2008 test year by "biling" month.
b. The requested information is provided in electronic format on the enclosed
CD.
c. The requested information was provided in Response to Request for
Production NO.4.
This response to this Request was prepared by Timothy Tatum, Senior Pricing
Analyst, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -18
REQUEST FOR PRODUCTION NO. 13: Mr. Tatum's workpapers at page 35
and 36 discuss modifications to the demand estimates for the Irrigation customers.
Please supply in electronic format the data (and associated changes) that occur in each
of the three steps that he addresses.
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The data is contained
in the 124SAdjustedSCDFactors.xls and the 124SFactorsReview.xls workbooks on the
enclosed CD.
This response to this Request was prepared by Paul Werner, Load Research
and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline,
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY -19
REQUEST FOR PRODUCTION NO. 14: Regarding Exhibit 55, page 27, line
828, why is the uncollectible value for the Irrigators negative?
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: The response for this
Request is not complete and will be made available as soon as possible.
This response to this Request was prepared by Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 20
REQUEST FOR PRODUCTION NO. 15: Regarding the testimony of Ms. Brilz at
page 13 regarding the meter reading accuracy of 99.8 percent since 2003, please
provide for each year since 2003:
a. Please explain how an accuracy figure is obtained/calculated (Le. what
data is used).
b. Please provide in electronic format the data used to substantiate the
99.8% figure.
c. Regarding the data that represents the 0.2% error, please provide in
electronic format a listing of each meter that was reading too high, the rate schedule
involved, the factor by which it was off, the amount of kWh error, and the length of time
the error existed.
d. Regarding the data that represents the 0.2% error, please provide in
electronic format a liking of each meter that was reading too low, the rate schedule
involved, the factor by which it was off, the amount of kWh error, and the length of time
the error existed.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15:
a. The meter reading accuracy rate is obtained by dividing the number of
meter readings less the number of identified meter reading problems ("MRP") by the
number of meter readings. A meter reading problem is defined as any meter reading that
is adjusted for billng purposes.
b. The requested data is in the file "2003-2007 Mtr Read Accuracy" included
on the enclosed CD.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 21
c & d. Meter read problems ("MRP") are tracked within the Customer Information
System ("CIS") by adding a customer contact type of "MRP" to the customer's account.
The standard reporting used by the Company to analyze the meter reading accuracy
simply talles the number of. MRP customer contact types recorded each month and the
number of meter readings taken each month. The reporting does not capture the specific
customer information such as service location, service schedule, or kWh usage.
Consequently, the requested information is not available.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 22
REQUEST FOR PRODUCTION NO. 16: On page 14 of the testimony of Ms.
Brilz there is a discussion of 15 incidences where incorrect multipliers resulted in
incorrect billngs. 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 error.
b. The monetary resolution of the incorrect meter reading - how much
money (by month) was paid (or to be paid) by the customer, or credited to the customer.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: As stated in the
testimony, the meter readings were correct; however, due to a multiplier error the billngs
were misstated. The amounts shown on the enclosed CD are the resulting correction of
the multiplier error.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 23
REQUEST FOR PRODUCTION NO. 17: If the meter reading error associated
with Case No.IPC-E-07-01 was not a part of the response to Interrogatory 16 above,
please provide similar information for Case No. IPC-E-07-01.
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: This error was not a
meter error, but rather a billng error due to applying an incorrect multiplier. The billng
error due to an incorrect multiplier associated with Case No. IPC-E-07-01 is included
with the information provided in the Response to Request for Production No. 16.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 24
REQUEST FOR PRODUCTION NO. 18: If the meter reading error associated
with Case No. IPC-E-07-16 was not a part of the response to Interrogatory 16 above,
please provide similar information for Case No. IPC-E-07-16.
RESPONSE TO REQUEST FOR PRODUCTION NO. 18: This error was not a
meter error, but rather a billng error due to applying an incorrect multiplier. The billng
error due to an incorrect multiplier associated with Case No. IPC-E-07-16 is included
with the information provided in the Response to Request for Production No. 16.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 25
REQUEST FOR PRODUCTION NO. 19: If the meter reading errors associated
with other customers similar to that in Case No. IPC-E-07-16 was not apart of the
response to Interrogatory 16 above, please provide similar information as requested in
Interrogatory 16 above.
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: The file "CT Biling
Errors" included on the enclosed CD provides data associated with five CT multiplier
errors similar to that in Case No. IPC-E-07-16 that have been identified since the original
fifteen CT multiplier errors detailed in the Response to Request for Production No. 16
were identified.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 26
REQUEST FOR PRODUCTION NO. 20: On page 17 of the testimony of Ms.
Brilz there is a discussion of system performance standards that were developed for
Schedules 7 and 9.
a. Please provide a copy of these performance standards and how they
relate to the employee incentive program.
b. What are the specific reliability targets for this group of customers?
c. What are the reliability results for each of the last five years for this group
of customers?
d. What are the reliability results for each of the last five years for the other
rate schedules in Idaho?
RESPONSE TO REQUEST FOR PRODUCTION NO. 20:
a. The network reliability performance standard that has been developed for
the Schedule 7 and Schedule 9 customer classes is the same as the network reliability
component established as part of Idaho Power's Employee Incentive Program. This
performance standard is measured using the number of interruptions greater than five
minutes in duration experienced during the year ("SAIFI"). In addition to the required
performance levels included in the Response to Request for Production No. 20.b below,
this metric contains a hurdle of no more than 10 percent of customers subjected to more
than six interruptions. If this hurdle is not overcome, the Incentive Program payout for
the network reliability goal wil be zero.
b. The specific SAIFI reliability targets for this group of customers are:
Threshold
Target
Maximum
2.5 or fewer interruptions
2.1 or fewer interruptions
1.7 or fewer interruptions
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 27
c. The file "07-09 4 Year SAIFI" included on the enclosed CD shows the
weekly annualized SAIFI values for Schedules 7 and 9 since the beginning of 2005,
when Idaho Power initiated the project to implement a reliability component in the
Employee Incentive Program. Prior to 2005, Idaho Power did not calculate reliability
indices on a rate schedule basis.
d. The file "System S AIFI" included on the enclosed CD show quarterly
annualized SAIFI values for each quarter of the last five years for Idaho Power's
system. Idaho Power does not calculate reliability indices on a rate schedule basis for
other than Schedules 7 and 9.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 28
REQUEST FOR PRODUCTION NO. 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: The files labeled
"Outage Data Customers by Rate" for the years 2004 through 2008 included on the
enclosed CD contain the actual outage detail and breakdown of customers by rate code
for every outage since the beginning of 2004. Prior to 2004, Idaho Power did not have
an outage management system and did not collect detail regarding individual customers
involved in an outage. Idaho Power does not track the estimated kW of load impacted.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 29
REQUEST FOR PRODUCTION NO. 22: Please provide electronically any
SAlOl, SAIFI, MAIDI, or CAIDI information that the Company has collected over the past
five years. Such data should be provided at the least aggregated level it is maintained
by the Company.
RESPONSE TO REQUEST FOR PRODUCTION NO. 22: The file "5 Year
Feeder History" included on the enclosed CD contains the SAlOl and SAIFI indices
calculated in quarterly and rollng four-quarter increments by state and feeder since the
beginning of 2003. The SAlOl and SAIFI indices are the only index calculations that
Idaho Power has maintained for this time period.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 30
REQUEST FOR PRODUCTION NO. 23: Exhibit 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 appear to be sustained and not mere one week
occurrences. What explanation does the Company have for these increased levels to
have continued from week to week?
RESPONSE TO REQUEST FOR PRODUCTION NO. 23: The two occurrences
noted are in fact one week occurrences. The effect of these occurrences in each of the
two years, however, is reflected throughout the year due to the calculation of SAIFI on
an annualized basis. The System Average Interruption Frequency Index (SAIFI) is
calculated by dividing the summation of the total number of customers affected by
sustained outages each week by the total number of customers served. This
calculation is annualized on a weekly basis for weekly performance tracking.
This response to this Request was prepared by Maggie Brilz, Customer Service
Manager, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
\!
DATED at Boise, Idaho, this I day of August 2008.~\~
BARTON L. KLINE
Attorney for Idaho Power Company
LISA D. NORDSTROM
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 31
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7th day of August 2008 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 B. Stutzman
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 2ih Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
Idaho Irrigation Pumpers
Association, Inc.
Randall C. Budge
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391
201 East Center
Pocatello, Idaho 83204-1391
-.Hand Delivered
U.S. Mail
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FAX
~ Email Weldon.stutzman(âpuc.idaho.gov
-. Hand Delivered
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~ Email Neil.price((puc.idaho.gov
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~ Email peter((richardsonandoleary.com
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FAX
-X Email dreadingcæmindspring.com
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~ Email rcbcæracinelaw.net
eloßYracinelaw.net
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 32
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Kroger Co. I 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
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, Utah 84111
Micron Technology
Conley Ward
Michael C. Creamer
GIVENS PURSLEY, LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
Dennis E. Peseau, Ph.D.
Utility Resources, Inc.
1500 Liberty Street SE, Suite 250
Salem, Oregon 97302
Hand Delivered
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L Email tony(âyankel.net
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FAX
-l Email mkurtz(áBKLlawfirm.com
kboehm(âBKLlawfirm .com
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Email
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-- Email khiggins(âenergystrat.com
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-l Email cew(ágivenspursley.com
mcc(âgivenspursley.com
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-X Email dpeseau(áexcite.com
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 33
Departent of Energy
Lot R. Cooke
Arthur Perry Bruder
Ofce of the General Counsel
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
Routing Symbol GC-76
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Arthur. Bruder(âhg.doe.gov
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
Hand Delivered
~U.S.Mail
_ Overnight Mail
FAX
~ Email detheridge~exeterassociates.com
Community Action Partnership
Association Of Idaho
Brad M. Purdy
Attorney at Law
2019 North 17th Street
Boise, Idaho 83702
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~U.S.Mail
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FAX
~ Email bmpurdy~hotmail.com
-~~-~
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 34
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.IPC-E-08-1 0
IDAHO POWER COMPANY
RESPONSE TO REQUEST NO. 10
rdame of Respondent
This oo0rt Is:Date of Report Year/Period of Report
(1) An Original (Mo, Da, Yr)End of 2007/Q4daho Power Company (2)o A Resubmission 04/11/2008
MONTHLY PEAKS AND OUTPUT
~) Report the monthly peak load and energy outut. If the respondent has two or more power which are not physically integrated, furnish the required
formation for each non- integrated system.
(2) Report on line 2 by month the system's output in Megawatt hours for each month.
r Rep on ''' 3 by m_lbno..'1Æ ..ie fo, ""ale Inc"". ~ the m_~ omo,,, any .'''' "".. as""'' wi th ..ie
4) Report on line 4 by month the system's monthly maximum megawatt load (60 minute integration) associated with the system.
5) Report on lines 5 and 6 the specified information for each monthly peak load reported on line 4.
I
~
tiAME OF SYSTEM:Idaho Power Company
(¡ne Monthly Non-Requirments MONTHLY PEAKSales for Resale &
fO.
Month Total Monthly Energy Associated Losses Megawatt (See Instr. 4)DayofMonth Hour
(a)(b)(c)(d)(e)(f)
· 2~January 1,745,492 363,384 2,422 16 8AM
¡; 3C February 1,318,82€211,820 2,268 2 8AM
l31 March 1,463,248 372,625 2,023 1 7PM
, 32 April.1,297,58~212,871 1,937 30 6PM
" 3~May 1,455,145 92,335 2,484 31 7PM
1.34 June 1,736,261 207,301 3,009 28 6PM
I' 35 July 1,991,363 175,571 3,193 13 4PM
OJ 3E August 1,806,531 205,281 2,90 1 7PM
.37 September 1,462,172 226,921 2,695 3 7PM
"3€OCober 1,34,23(232,723 1,838 31 8AM
.....39 November 1,317,419 145,751 2,130 30 8AM
14C December i 1,607,042 239,628 2,287 11 8AM\,
,
141
i
TOTAL 18,544,317 2,686,211
I
I
l
l
l
l
I
I
CCDI' cnDU Nn 11i:n 1?..n\Paae 401b
IDAHO POWER COMPANY
MONTHLY SYSTEM PEAKS
FOR 2008
DAY & IPCO SYSTEM
DATE OF HOUR PEAK DEMAND
MONTH PEAK ENDING MW (*)
JANUARY Thurs. - 24th 8am 2,464
FEBRUARY Tues. - 5th 8am 2,270
MARCH Mon. - 3rd 8am 2,028
APRIL Tues. - 1st 8am 1,993
MAY Mon. - 19th 6 pm 2,577
JUNE Mon. - 30th 3pm 3,214
JULY
AUGUST
SEPTEMBER
OCTOBER
NOVEMBER
DECEMBER
Footnote: (*) IPCO System Peak demand does not contain loads
for any Oft-System sale customers.
Prepared by Load Research MNSYPK2008.xls Year 2008 7/24/2008