20081121IIPA to IPC 1-4.pdf

LAW OFFICES OF
W. MA~CUS W. NYE
RANDALL C. ElUDGE
JOHN A. ElAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
DAVID E. ALEXANDER
LANE V. ERICKSON
PATRICK N. GEORGE
SCOTT J. SMITH
STEf'HEN J. MUHONEN
BRENT L. WHITING
JUSTIN R. ELLIS
JOSHUA D. JOHNSON
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TI PPI VOL YN
THOMAS J. BUDGE
CANDICE M. MCHUGH
JONATHAN M. YOLYN
MARK A. SHAI'FER
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO Ð3204.13S1
TELEPHONE f20S) 232.6101
FACSIMILE 120S) 232-61 OS
ww.racinelaw.net
SENDER'S E-MAIL ADDRESS:eloliraclneIaW.net
November 21, 2008
Jean Jewell
IPUC Commission Secretary
P.O. Box 83720
Boise, Idaho 83720-0084
Re: IPC-E-08-JO
Dear Mrs. Jewell:
BOISE OFFIC&¡
101 SOUTHCAPlTOL
BOULEVARD, $UITE 208
80188, ID"HO 83702
TELEPHONE. (108) 38$'0011
FACSIMILE: (208). 43:S"01 &7
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE203AIDAHO FALLS, lD 83402'lltLEPHONI!: (208) :528"8101
FACSIMILE: 1208) 528'61011
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUlTS106A
COEUR D'ALENE. Ib 83814
TELEPHONE~ (20El) 766"68..8
ALL OFFICES TOLL FREE
(877) 232-8 101
~I)IS I".RlCB: lItU7-2OS)::LlAM D. 7. OF COUNSEL- ø:c- %-\0 0mæ: .c(1$ No0:2
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Enclosed for filing you wil find the three (3) copies of the Idaho Irrigation Pumpers
Association, Inc's Response to Idaho Power Company's First Production Request. The workpapers
and electronic files are contained on the CD Rom attached as Exhibit 1.
Thank you for your continuing assistance.
Sincerely,
ERIC L. OLSEN
ELO/nj
Enclosures
c: Service List (via mail and/or Hand delivery)
M¡" i: (". C.~.¡¡Vt~:n
Eric L. Olsen, ISB #4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E, Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
zona NOV 21 pi~ ,2: 32
Attomeys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
)
)
)
)
)
)
)
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-E-08-10
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S RESPONSE TO
IDAHO POWER COMPAN'S FIT PRODUCTION REQUEST
COMES NOW, Idaho Irrgation Pumpers Association, Inc. ("LIP A"), and in
response to Idaho Power Company's First Production Request to the Idaho Irrigation
Pumpers Association, Inc. dated October 31, 2008, hereby submits the following
information:
REQUEST NO.1: Please provide copies of testimony and exhibits or comments
Anthony Yanke) has prepared and/or presented in all utilty revenue requirement cases
during the past three years, Testimony and comments presented in cases in which Idaho
Power was a pary do not need to be provided.
RESPONSE TO REQUEST NO. 1: Attached hereto as Exhibit I is a CD Rom.
In the subfolder "Testimony" is contained Mr. Yankels testimony in revenue
requirement cases for the past three years.
.IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S RESPONSE
TO DAHO POWER COMPANY'S FIRST PRODUCTION REQUEST - 1
REQUEST NO.2: Please identitY by case number, jurisdiction, and date all
utility revenue requirement cases in which Anthony Yankel has paricipated, prepared,
and/or presented testimony, exhibits, or comments for the past four years.
RESPONSE TO REQUEST NO.2: Attached hereto as Exhibit 2 is a list of
cases responsive to Request NO.2.
REQUEST NO.3: Please provide copies of all electronic files, with formulas
intact, that were used or relied on to develop the analyses and/or schedules suppoi1ing
Anthony Yankel's testimony.
RESPONSE TO REQUEST NO.3: Attached as Exhibit 1, is a CD Rom, In the
Subfolder "Electronic Files & Workpapers" are all of Mr. Yankel's electronic fies lIsed
or relied on to develop his testimony.
REQUEST NO.4: Please provide copies of all workpapers and supporting
documents Anthony Yankel relied on to support his testimony, exhibits, and any analysis
contained therein.
RESPONSE TO REQUEST NO.4: Attached as Exhibit 1, is a CD Rom. In the
Subfolder ..Electronic Files & Work papers" are all of Mr. Yanel's workpapers and
supporting documents used or relied on to develop his testimony.
DATED thisi/~y of November, 2008.
ERIC L. OLSEN, Attorney for
Idaho Irrigation Pumpers Assn., Inc.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S RESPONSE
TO DAHO POWER COMPANY'S FIRST PRODUCTION REQUEST - 2
.....~.~:.~':.:~:.. .
CERTIFICATE OF MAG
I HEREBY CERTIFY that on this -i i,l day of November, 2008, I served a
true, correct and complete copy of the foregoing document, to each of the following, via
the method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
P.O. Box 83720
472 W, Washington Street
Boise, Idaho 83720-0074
¡jewel i (fuc.state.id. us
-1
X-
Baron L. Kline
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
bktine(fidahopower.com
lnordstrom(iidahopower .com
dwalker(fidahopower .com
)S
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
P.O, Box 70
Boise, Idaho 83707-0070
rgale(iidahopower.com -t
Peter J. Richardson
RICHARDSON & O'LEARY PLLC
515 N. 2ih Street
Boise,ID 83702
peter(árichardsonandoleary.com
t-
Don C. Reading
6070 West Hil Road
Boise,ID 83703
dreading(ßindspring.com
l-
lDAHO IRRGATION PUMPERS ASSOCIATION, INC. 'S RESPONSE
TO DAHO POWER COMPANY'S FIRST PRODUCTION REQUEST - 3
U.S. Mail/ostage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
Brad M. Purdy -J U.S. Mail/Postage Prepaid
Attorney at Law E-Mail
2049 N. 171h St.Facsimile
Boise,ID 83702 Overnight Mail
bmpurdy(ihotmail.com Hand Delivered
Lot R. Cooke l-U.S. Mail/Postage Prepaid
Aithur Pen)' Bruder E-Mail
Offce of the General Counsel Facsimile
United States Deparment of Energy Overnight Mail
1000 Independence Ave. SW Hand Delivered
Washington, DC 20585
Lot.CookeCfhq.doe.gov
Arthur .Bruder§hq.doe. gOY
Dwight Etheridge t-U.S. MaillPostage Prepaid
Exeter Associates E-Mail
5565 Sterrett Place, Suite 310 Facsimile
Columbia, MD 21044 Overnight Mail
detheridge(âexeterassociates. com Hand Delivered
Michael L. Kurtz t.U,S, Mail/Postage Prepaid
Kurt J. Boehm E-Mail
BOEHM, KURTZ & LOWRY Facsimile
36 East 7th S1., Suite 1510 Overnight Mail
Cincinnati, OH 45202 Hand Delivered
mkurtz(âBKLlawtìrnl.com
kboehmaBBKLlawfirm.com
Kevin Higgins X-U.S. Mail/Postage Prepaid
Energy Strategies, LLC E-Mail
Parkside Towers Facsimile
215 South State Street, Suite 200 Overnight Mail
Salt Lake City, UT 84111 Hand Delivered
khiggins(âenergystrat.com
Conley E. Ward P-U.S. Maii/Postage Prepaid
GIVENS PURSLEY LLP E-Mail
P.O. Box 2720 Facsimile
Boise,ID 83701-2720 Overnight Mail
cew(â.gi venspursley.com Hand Delivered
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. 'S RESPONSE
TO DAHO POWER COMPANY'S FIRST PRODUCTION REQUEST - 4
Dennis E. Peseau, Ph.D.
Utilty Resources, Inc.
1 500 Liberty Street SE, Ste. 250
Salem, OR 97302
dpeseau(cexcIte.com
--U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
Weldon Stutzman
Neil Price
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washington St.
Boise, ID 83702
Weldon. Stutzman(â)PU C.idaho. gov
:t U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand DeliveredA-
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, iD 83701
kiuill er(isnakeriveralliance.org
iL U.S. MaillPostage PrepaidE-Mail
Facsimile
Overnight Mail
~J Hand Delivere~b.
RieL. OLSEN
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S RESPONSE
TO DAHO POWER COMPANY'S FIRST PRODUCTION REQUEST - 5
(EXHIBIT 1 IS A
COMPACT DISK WHICH
CONTAINS ANTHONY YANKEL'S
ELECTRONIC FILES, TESTIMONY AND
WORK PAPERS)
Exhibit 1
Exhibit 2
Idaho Power Case No. IPC-E-OS-I0
This case was initiated in the sumer of2008. The client was the Idao Irrgation
Pumpers Association repreented by Mr. Eric Olsen, P, O. Box 1391, Pocatello,
Idaho, 83204, [phone]. The basic areas addrssed were:
. Disproportonate growth on the system
. Allocation of Sales For Resle and Purchase Power based on usage
. Irrigation Peak Rewards Program
A Commission Opinion has not been issued at this time.
American Electric Power Case No. 08-917-EL-SSO
This case was intiated in the sumer of2008. The client was the Ohio Offce of
the Consumers' Counel represented by Ms. Maureen Grady, 10 West Broad
Street, 18th Floor, Columbus, Ohio, 43215, [phone]. The basic areas
addressed were:
· Tariffs and Rates as a par of the ESP plan
A Commission Opinion has 110t been issued at ths time.
Duke Energy Ohio Case No. 08-920-EL-SSO
Ths case was initiate in the sumer of 2008. The client was the Ohio Offce of
the Consumers' Counsel represented by Ms. An Hotz, 10 West Broad Street, 18th
Floor, Columbus, Ohio, 43215, [phone]. The basic areas addressed were:
· Tariffs and Rates as a par of the ESP plan
A settlement was adopted in ths case that was beneficial to the positions being
advocated by the client.
FirtEnergy Case No. 08-935-EL-SSO
This cae was initiated in the sumer of2008. The client wa the Ohio Offce of
the Consumers' Counsel represented by Mr, Jeff Small, 10 West Broad Stret, 18th
Floor, Columbus, Ohio, 43215, [phone]. The basic aras addressed were:
· The generation prices offered by the Company as a par of its Electric
Securty Plan;
· The market history of the First Energy EDUs;
· The Company's caculation of the Plan's benefit; and
. Tariffs and Rates as a par of the ESP plan.
A Commission Opinion has not been issued at this time.
Columbia Gas Of Ohio Case No. 08-0072-GA-AIR
This case was initiated in the sumer of2008. The client was Honda of America
represented by Jonatha Airey ofVorys, Sater, Seymour and Peas, 52 Eat Gay St.
Columubus, Ohio 43216, [phone]. The basic areas addressed were:
· Columbia Gas of Ohio's cost of service study and the rates proposed for
Large General Service and Lage General Service,
A settlement was adopted in ths cae that was beneficial to the positions being
advocated by the client.
Duke Energy Ohio Case No. 07-589-GA-AIR
This case was initiated in the summer of 2007, The client was the Ohio Offce of
the Consumers' Counel represented by Mr. Lary Sauer, 10 West Broad Street,
18th Floor, Columbus, Ohio, 43215, [phone]. The basic areas addressed
were:
· The impact on Residential Sales ("RS") and Residential Choice ("RFT")
customers ofnumencal errors and data problems in the Company's cost of
service calculations;
· The impact on the cost of servce of Residential RS and RFT customers as
well as the Company's overall revenue requirement of using an
inppropriately low estimation of the norm space heating load;
· The appropriateness of the Accelerated Mai Replacement Progr
("AMRP") progra, as well as the need for an appropriate price cap,
given the history of the AMRP cost recovery, and in light of the revenue
requiment in ths case;
· The appropriateness of a Sales Decoupling Rider, given the informtion
presented in this case; and
· The appropriateness of the PUCO Stas ("Staff") concept to move
towards the elimination of the commodity component of the Residential
base rates and collect most of the base revenue reuirement in a customer
charge.
A number of the numerical errrs were adopted by the Company and the
Commssion Sta for inclusion in the rate settg process. Some issues were
setted. The Commission adopted the PUCO Statrs proposed rate design that
placed a very large porton of the Residential revenue requirement on a fixed
customer charge.
2
Idaho Power Case No. IPC-E-07-08
This cae wa initiated in the sumer of 2007, The client was the Idaho Irigation
Pumpers Association represented by Mr. Enc Olsen, P. O. Box 1391, Pocatello,
Idaho, 83204, [phone]. The basic areas addressed were:
· Disproportonate growt on the system
· Irgation Load Research data and curlment
· BPA credit
· Irrigation Peak Rewards Program
· Irrgation Time-of-Day rates
A settlement was adopted in this case that was beneficial to the positions being
advocated by the client.
PacifiCom Docket 06-035-21
Ths case was initited in 2006. The client was the Utah Commttee of Consumer
Services represented by Dan Gimble, Uta Committee of Consumer Services, 160
East 300 South, Salt Lake City, Utah 84111, [phone]. The basic areas
addressed were:
· Cost-of-service results for the Residential, Small Commericial, and
Irrigation customer classes
· Biling determinant problems associated with rate design
· Growt adjustment
A settlement was adopted in this cae that was beneficial to the positions being
advocated by the client. The issue of the customer charge was litigated. The
Commission adopted a customer charge that was half way between the position of
the Committee and that advocated by the Company and the Division.
Idaho Power Case No. IPC-E-05-28
This cae was initiated in the sumer of 2005. The client was the Idaho Irrigaton
Pumpers Association represented by Mr. Randy Budge, P.O. Box 1391, Pocatello,
Idaho, 83204, [phone]. The basic ar addrssed were:
. Power supply costs
· Disproportionate growt and allocation of growth between classes
· Irrgation Load Curailment progr
3
A settlement was adopted in this case tht was beneficial to the positions being
advocated by the client.
Elyna Foundr vs. Ohio Edison Company Case No. 05-796-EL-CSS
Ths cae was intiated in 2005. The client is Elyra Foundry Inc. The contact
person is Mr. Craig I. Smith Attorney at Law, 2824 Coventr Rd.t Cleveland, Ohio
44120, [phone]. The basic areas addressed were:
· The inappropriate allocation of purchase power costs in order to divert costs
from afliated competitive market transactions
. The inappropriate setting of a hierarchy withn the interruptible class by
treating all customers the sanie while charging them different rates.
This Commission decided that the utility could interrpt Elyria Foundr in the
maner it which it had been doing.
Cincinate Gas & Electrc Case No. 05-0059-EL-AIR
Ths case was initiated in the summer of2005. The Client was the Ohio
Association of School Business Offcials et.al.t represented by Glen Drasse~
Bricker & Eckler, 1375 East Ninth Street, Suite 1500, Clevelandt Ohio, 44114.
[phone]. The basic areas addressed were:
· Cost of service differential for Schools
· Rate design and pricing to reflect school loads
A settement was adopted in this case that was beneficial to the positions being
advocated by the client.
Dayton Power and Light Case No. 05-276-EL-AIR
This case was initiated in the spring of2005, The client was Cargil Inc.
represented by Craig I. Smith, 2824 Coventr Road, Clevelandt Ohio 44120, 216-
407-0890. The basic areas addressed were:
· The application was inconsistent with the stipulation filed in a previous
case.
· The Shopping Credit in the RSS was developed counter to logic.
· The RSS rate was counter-productive to the development of a competitive
market.
A settlement was adopted in ths case tht was beneficial to the positions being
advocated by the client.
4
Vectren Case No. 04-571~GA-AIR
This case was initiated in the sumer of 2004. The client wa Honda of America
represented by Howard Petrcoff ofVorys, Sater, Seymour and Peas, 52 East Gay
S1. Columubus, Ohio 43216, [phone]. The basic areas addressed were:
(
· A comparson of rates for similar customers by other utilties reguated by
the Ohio Commission
· A review of the Company's cost of service results
· Recommend a rate design that is reflective of cost of service for large
volume customers.
A settlement was adopted in this case that was beneficial to the positions being
advocated by the client.
PacifiCoi: Docket No. 04-035-42
This case was initiated I11 June 2004. The client was the Utah Comniittee of
Consumer Services, Dan Gimble, Uta Committee of Consumer Services, 160 Eas
300 South, Salt Lae City, Uta 84111, [phone], The basic areas
addressed were:
· Proposed changes to the Net Power Cost Model to reflect purchases and
sales associated with Wholesale Short-Tenn~Fenn trsactions.
· Cost-or-servce results for the Residential, Small Commericial,and
Irrigation customer classes
· Biling determnant problems associated with rate design
· Growt adjustment
Avista Corporation Case No. A VU-E-04-01
This Case was intiated in 2004. The client was Coeur Silver Valley (a mining
interest in Nortern Idaho) represented by The basic areas addressed were:
· TIie allocation/assignent of Primar Distrbution related costs
· Rate design when one customer on the rate schedule is larger than all other
customers combined.
TIie Commission's decision was favorable to both positions that were advocated.
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