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Home My WebLink About20080922IPC to IIPA 33, 34.pdfesIDA""POR~ An IDACORP Company BARTON L. KLINE Lead Counsel September 22,2008 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 Third Production Request of The Industrial Customers of Idaho Power and Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s Third Data Requests to Idaho Power Company. In addition, also enclosed are four copies of a CD. The CD contains the Company's responses to production/data requests in which electronic/excel files were requested. Finally, enclosed in a separate envelope are four copies of a document containing confidential information which is being prov~ded in response to a production request. As you know, the confidential information can only be viewed by those parties who have signed the Protective Agreement. Upon receipt of this filng, I would appreciate it if you would return a stamped copy of this letter for my file in the enclosed stamped, self-addressed envelope.V7J~ Barton L. Kline Lead Counsel for Idaho Power Company BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, 10 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 bkline((idahopower.com Inordstrom((idahopower.com dwalker((idahopower.com RECEIVED 20D8 SEP 22 PH 3: 35 IDAHO PUBLIC UTILITIES COMMISSION 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 MAnER 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 THIRD 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 Third Data Requests to Idaho Power Company dated August 26, 2008, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY-1 REQUEST FOR PRODUCTION NO. 33: Beginning on page 37 of Mr. Tatum's workpapers is a discussion regarding the methodology for establishing coincident demand data using load research data. Please provide in electronic format all calculations used and all data used to develop coincident demand data for each month of 2006 and 2007. RESPONSE TO REQUEST FOR PRODUCTION NO. 33: The Demands2007 Actual.xls workbook provided in Idaho Powets Response to IIPA's First Data Request No. 8(x) contains a set of coincident demand data for each month of 2007. The last three spreadsheets in the workbook contain the inputs and formulas for the calculations discussed in Mr. Tatum's workpapers. The System Coincident Demand ("SCD") factors and Group Coincident Demand ("GCD") factors discussed in the workpapers are shown on the inputs spreadsheet. LodeStar, a proprietary commercial softare package for load research analysis, was used to compute the mean coincident and average demands of the load research samples, and these LodeStar outputs were used to calculate the SCD factors and GCD factors. The methodology and the data used by the LodeStar softare and discussed in the workpapers are ilustrated in the 2007 Monthly Customer Demands ("MCD") files on the enclosed CD. The coincident demand data in the Demands2007 Actual.xls workbook was not used in the Company's cost-of-service analysis in this case. The Demands2008RC08MedianFactors.xls workbook provided in Idaho Powets Response to IIPA's First Data Request NO.5 contains the coincident demand data for the test year that was used. The workbooks show different years, one actual and one forecast and IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY -2 normalized. In addition, the latter workbook reflects changes and updates that occurred after the former workbook was developed; for example, the lighting hours were adjusted in accordance with the new Schedule 15 tariff and the procedure for estimating irrigation coincident demands was modified as described in Mr. Tatum's workpapers. Monthly Customer Demand files for 2006 are not available. A set of 2006 coincident demand data is included in the D&EMaster06.xls workbook on the enclosed CD. Since the 2006 data was developed, the Company has reorganized the workbooks and changed some assumptions and procedures. The Company has not used this data in its cost-of-service studies. 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 THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST FOR PRODUCTION NO. 34: For each month of 2006 and 2007 please provide in electronic format, by rate schedule, the sum of the individual customer billng demands. If possible, please supply this data on a calendar as well as a billng month basis. RESPONSE TO REQUEST FOR PRODUCTION NO. 34: The requested information is provided on the enclosed CD. Customer billng demands are provided by billng month for each demand-metered customer class. Individual customer billing demands are not available on a calendar month basis. 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. DATED at Boise, Idaho, this -. day of September 2008. ßki!Y 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 THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 4 CERTIFICATE OF SERVICE r-~ I HEREBY CERTIFY that on this ~ 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 THIRD 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 Utilities 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 27th 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 -l Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Weldon.stutzman((puc.idaho.gov -l Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Neil.price((puc.idaho.gov Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email peter((richardsonandoleary.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email dreadingßRmindspring.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email rcb((racinelaw.net elo((racinelaw. net IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 5 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Village, 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 Libert Street SE, Suite 250 Salem, Oregon 97302 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email tony((yankel.net Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email mkurt((BKLlawfirm.com kboehm((BKLlawfirm .com Hand Delivered -l U.S. Mail _ Overnight Mail FAX Email Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email khiggins((energystrat.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email cew((givenspursley.com mccßRgivenspursley.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email dennvtemp((yahoo.com IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY - 6 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 Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, MD 21044 Hand Delivered U.S. Mail -l Overnight Mail FAX -l Email Lot.Cooke((hg.doe.gov Arthur. BruderßRhg.doe.gov Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email detheridge((exeterassociates.com Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 1th Street Boise, Idaho 83702 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email bmpurdy((hotmail.com Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email kmiler((snakeriverallance.org (W~ Barton L. Kline IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUESTS TO IDAHO POWER COMPANY-7