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Home My WebLink About20080905IPC to IIPA 24-32.pdf1SIDA~POR~ An IDACORP Company LISA D. NORDSTROM Senior Counsel September 4, 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 thi:ee (3) copies of Idaho Power Company's Response to The Idaho Irrigation Pumpers Association, Inc.'s Second Data Requests to Idaho Power Company. In addition, also enclosed are four copies of a CD containing the Company's response to production in which electronic/excel files were requested and also forease 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, ¡e;v¡Ç.11~ Lisa D. Nordstrom . Senior Counsel for Idaho Power Company LDN:csb 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: (208) 388-2682 Facsimile: (208) 388-6936 bklineCâidahopower.com InordstromCâidahopower.com dwalkerCâidahopower.com RECElVEO i. SEP -4 PM i.: i.3 \QA,l-sO i~J~\~SlON Ul\Lh t; 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 MATTEROF 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 SECOND DATA REQUESTS TO ) IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s Second Data Requests to Idaho Power Company dated August 7, 2008, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST FOR PRODUCTION NO. 24: In Case No. IPC-E-07 -08, the Company's response to Micron Request To Produce No. 18 contained two spreadsheets (Demands07RCMedianFactors.xls and MedianDemandFactors20022006.xls). Only PDF's of those spreadsheets were originally provided to the Irrigators. Please provide working copies of those spreadsheets. RESPONSE TO REQUEST FOR PRODUCTION NO. 24: The requested spreadsheets are provided 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, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 2 REQUEST FOR PRODUCTION NO. 25: Please provide similar spreadsheets as requested in "24" above that have been updated for this case. RESPONSE TO REQUEST FOR PRODUCTION NO. 25: The requested spreadsheets have been provided in Idaho Power's response to the Idaho Irrigation Pumpers Association's Data Request NO.5. This response to this Request was prepared by Paul Werner, Load Research and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST FOR PRODUCTION NO. 26: Street-lighting and Dusk-to-Dawn lighting are not metered, but usage is determined by known hours of the day without sunlight. Please list for each day of the year, the hours without sunlight when these customers are using electricity. RESPONSE TO REQUEST FOR PRODUCTION NO. 26: The Excel workbook on the enclosed CD contains the requested information. The daily lighting on and off times were calculated using sunrise/sunset tables for Boise from the U.S. Naval Observatory ("USNO") website. The spreadsheet contains two sets of lighting on/off times. Prior to March 1, 2008, the tariff sheets for Schedule 15, Dusk to Dawn Customer Lighting, were based on 4,105 hours of lighting per year and the on/off times were assumed to be 30 minutes after sunset and 30 minutes before sunrise. The lighting hour assumptions were revised in the current tariff sheet for Schedule 15, which states, "Lamps are energized each night from 20 minutes after sunset until 20 minutes before sunrise, thereby providing approximately 4,059 hours of Premises lighting per year." The Company has used the current assumptions to calculate the five-year median coincident demand factors for the 2008 test year. This response to this Request was prepared by Paul Werner, Load Research and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST FOR PRODUCTION NO. 27: Please supply for each hour of 2006 and 2007 the estimated usage at sales and generation level for: a. Area Lighting Schedule 15 b. Unmetered Service Schedule 40 c. Street Lighting Schedule 41 d. Traffc Lighting Schedule 42 e. The combined Special Contract Customers (DOE/Simplot/Micron) RESPONSE TO REQUEST FOR PRODUCTION NO. 27: Estimated usage for each hour of 2006 and 2007 for the unmetered rate schedules (a-d) is not available. The only hourly consumption values estimated to develop the allocation factors used in the Company's cost-of-service study in this case are the hourly usage at the hour of the monthly system peak (system-coincident demand) and the hourly usage at the hour of the monthly group peak (group-coincident demand). These two coincident hourly demands were provided by month for 2007 at customer and generation level in the Demands2007 Actual.xls workbook provided in Idaho Power's response to the Idaho Irrigation Pumpers Association's Data Request NO.8. The methodology and assumptions for 2008 and future years are documented on page 39 of Mr. Tatum's workpapers. The methodology has not changed since the last rate case, but prior to March 1, 2008, the tariff sheets for Schedule 15 were based on 4,105 hours of lighting per year and the on/off times were assumed to be 30 minutes after sunset and 30 minutes before sunrise. As shown on the RefTables spreadsheet in Demands2007 Actual.xls, the values from the tariff sheets in effect in 2007 were used to calculate the coincident demands in that workbook. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 5 The usage of the Special Contract Customers (DOE/Simplot/Micron) for each hour of 2006 and 2007 has not been prepared and is not available. Only the peak hours are used in the cost-of-service study. This response to this Request was prepared by Paul Werner, Load Research and Forecasting Leader, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 6 REQUEST FOR PRODUCTION NO. 28: Please supply in electronic format for each month since January 2006 the calendar usage of each of the rate schedules/groupings listed in Exhibit 59. RESPONSE TO REQUEST FOR PRODUCTION NO. 28: The requested information is provided in electronic format on the enclosed CD. Monthly biled energy sales are not converted to calendar month sales until year-end. As a result, the calendar month energy sales data is not available for 2008. The historical energy sales data for the three Special Contract customers has been combined into a single category to preserve the confidentiality of each customer's actual biling data. This response to this Request was prepared by Timothy Tatum, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY-7 REQUEST FOR PRODUCTION NO. 29: Please supply in electronic format for each month since January 2006 the biling usage of each of the rate schedules/groupings listed in Exhibit 59. RESPONSE TO REQUEST FOR PRODUCTION NO. 29: The requested information is provided in electronic format on the enclosed CD. The historical energy sales data for the three Special Contract customers has been combined into a single category to preserve the confidentiality of each customer's actual biling data. This response to this Request was prepared by Timothy Tatum, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 8 REQUEST FOR PRODUCTION NO. 30: In the Company's response to the Irrigation First Set, Request 11 in case IPC-E-07 -08 there were a number of input sources listed in a cryptic fashion. Please provide a fuller description of the following line items that were used: a.BORD_ADJ_GROSS_MWH JBRG_ADJ_ GROSS_MWH VALMY OFF SYSTEM b. c. d.VALMY IPCO SHARE SYSTEM GRO- - - e.HYDRO PLNT GEN HEGROSS MWH- - - - f.BMPR USE HEGROSS MWH- - - g. h. DNPR PLNT HEGROSS MWH- - - i. DNPR_PLNT _ USE_HEGROSS_MWH COGENS_MWH (FALLS & FOSSIL) LG COG EN GROSS MWH- - -j. k.NON IPCO GEN ADJ GROSS MWH- - - - - i.SM COGEN GROSS MWH- - - m.TIBER DAM MWH- - n.VAGN BROTHERS MWH- - RESPONSE TO REQUEST FOR PRODUCTION NO. 30: INPUT SOURCE DESCRIPTION a. BORD_ADJ_GROSS_MWH b. JBRG_ADJ_GROSS_MWH c. VALMY OFF SYSTEM d. VALMY _IPCO_SHARE_SYSTEM GRO e. HYDRO_PLNT_GEN_HEGROSS_MWH f. BMPR_USE_HEGROSS_MWH g. DNPR_PLNT _HEGROSS_MWH BOARDMAN GENERATION BRIDGER GENERATION VALMY GENERATION VALMY GENERATION HYDRO GENERATION BENNETI MOUNTAIN PLANT USE DANSKIN GENERATION IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 9 h. DNPR_PLNT _USE_HEGROSS_MWH i. COGENS_MWH (FALLS & FOSSIL) j. LG_COGEN_GROSS_MWH k. NON_IPCO_GEN_ADJ_GROSS_MWH i. SM_COGEN_GROSS_MWH m. TIBER_DAM_MWH n. VAGN_BROTHERS_MWH DANSKIN PLANT USE VARIOUS TELEMETERED COGENERATORS VARIOUS LARGE COGENERATORS LUCKY PEAK GENERATION VARIATION VARIOUS SMALL COGENERATORS COGENERATOR COGENERATOR This response to this Request was prepared by Dave Bean, Power Supply Controller, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY -10 REQUEST FOR PRODUCTION NO. 31: In the Company's response to the Irrigation First Set, Request 7 in case IPC-E-07-08 there was a spread sheet (RATE 19SHourly2006) listing what appeared to be hourly load research data for a single Secondary Schedule 19 customer with the designation "M0236". Please explain what this data represents and if the usage levels here are to be combined for cost of service purposes with the Primary Schedule 19 customers, or if some other treatment is appropriate. RESPONSE TO REQUEST FOR PRODUCTION NO. 31: Idaho Power serves only one customer under Schedule 19 at the secondary voltage leveL. The referenced Excel file named "Rate19SHourly2006" includes the hourly loads for the single Schedule 19-5econdary customer for 2006. In the current case, Case No. IPC-E-08-10, Idaho Power provided similar data for 2007 in the response to the Idaho Irrigation Pumpers Association's Request NO.5. In both Case No. IPC-E-07-08 and Case No. IPC-E-08-10, the Schedule 19-5econdary service level customer's test year loads were combined with the Schedule 19-Primary and Transmission service level loads in the derivation of the demand and energy allocation factors shown on Exhibit Nos. 59 and 68. The allocation factors shown on Exhibit Nos. 59 and 68 are used in the allocation of generation and transmission-related costs. For the allocation of distribution-related costs, only Schedule 19-Primary and Secondary service level customer loads were used. The development of the distribution cost allocation factors that were derived using these loads is detailed on page 33 of Mr. Tatum's workpapers. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 11 This response to this Request was prepared by Timothy Tatum, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY -12 REQUEST FOR PRODUCTION NO. 32: In the Company's response to the Irrigation First Set, Request 7 in case IPC-E-07-08 there was a spread sheet (RATE19THourly2006) listing what appeared to be hourly load research data for three Transmission Schedule 19 customers with the designations "M0055" "M0196", and M0393". Please explain what this data represents and if the usage levels here are to be combined for cost of service purposes with the Primary Schedule 19 customers, or if some other treatment is appropriate. RESPONSE TO REQUEST FOR PRODUCTION NO. 32: The referenced Excel file named "Rate19THourly2006" includes the hourly loads for each of the Company's Schedule 19-Transmission service level customers for 2006. In the current case, Case No. IPC-E-08-10, Idaho Power provided similar data for 2007 in the response to the Idaho Irrigation Pumpers Association's Request NO.5. In both Case No. IPC-E-07 -08 and Case No. IPC-E-08-10, the Schedule 19-Transmission service level customers' test year loads were combined with the Schedule 19-5econdary and Primary service level loads in the derivation of the demand and energy allocation factors shown on Exhibit Nos. 59 and 68. The allocation factors shown on Exhibit Nos. 59 and 68 are used in the allocation of generation and transmission-related costs. The Schedule 19-Transmission service level customer loads were not used in the allocation of distribution-related costs. This response to this Request was prepared by Timothy Tatum, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY -13 /-- . DATED at Boise, Idaho, this i day of September 2008. ~f2~ LISA D. NORDST .. Attorney for Idaho Power Company BARTON L. KLINE 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 SECOND DATA REQUESTS TO IDAHO POWER COMPANY - 14 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this L day of September 2008 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY 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 Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Neil Price Deputy Attorney General Idaho Public Utilitjes Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 2th Street P.O. Box 7218 Boise, Idaho 83702 Dr. Don Reading Ben Johnson Associates 6070 Hill 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 _ Overnight Mail FAX -. Email Weldon.stutzmanCâpuc.idaho.gov -. Hand Delivered U.S. Mail _ Overnight Mail FAX -. Email Neil.priceCâpuc.idaho.gov Hand Delivered -lU.S. Mail _ Overnight Mail FAX -. Email peterCârichardsonandolearv.com Hand Delivered -lU.S. Mail _ Overnight Mail FAX -l Email dreadingCâmindspring.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -. Email rcbCâracinelaw.net eloCâracinelaw. net IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY -15 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 -lU.S. Mail _ Overnight Mail FAX -. Email tonyCâyankel.net Hand Delivered -lU.S. Mail _ Overnight Mail FAX -. Email mkurt~BKLlawfirm.com kboehm~BKLlawfirm.com Hand Delivered -lU.S. Mail _ Overnight Mail FAX Email Hand Delivered -lU.S. Mail _ Overnight Mail FAX -l Email khiggins(ienergystrat.com Hand Delivered -lU.S. Mail _ Overnight Mail FAX -. Email cew(igivenspursley.com mcc(igivenspursley.com Hand Delivered -. U.S. Mail _ Overnight Mail FAX -l Email dpeseau(iexcite.com IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY -16 Department of Energy Lot R. Cooke Arthur Perry Bruder Offce of the General Counsel United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Routing Symbol GC-76 Hand Delivered U.S. Mail -l Overnight Mail FAX -X Email Lot.Cooke(ihg.doe.gov Arthur. Bruder(ihg .doe.gov Dwight Etheridge Exeter Associates 5565 Sterrett Place, Suite 310 Columbia, MD 21044 Hand Delivered -. U.S. Mail _ Overnight Mail FAX -. Email detheridge(iexeterassociates.com Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered -. U.S. Mail _ Overnight Mail FAX -. Email bmpurdy(hotmail.com Snake River Allance Ken Miller Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered -. U.S. Mail _ Overnight Mail FAX -. Email kmiller(isnakeriverallance.org ~~~~~dstrom~ IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUESTS TO IDAHO POWER COMPANY -17