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Home My WebLink About20100505IIPA 1-10 to IPC.pdfJean D. Jewell, Secretar Idaho Public Utilities Commission PO Box 83720 Boise, Idaho 83720-0074 W. MARCUS W. "lYE RANDALL C. BUDGE JOHN A. BAILEY, JR. JC-HN R. GOODELL JÖHN B. INGELSTROM OANIEL C. GREEN '3RENT O. ROCHE KIRK B. HADLEY FRED J. LEWIS ERIC L OLSEN CONRAD J. AIKEN RICHARD A. HEARN, M.D. LANE V. ERICKSON DAVID E. ALEXANDER PATRICK "I, GEORGE SCOTT J. SMITH JOSHUA D. JOHNSON STEPHEN J. MUHONEN BRENT L WHITING JONATHON S. BYINGTON DAVE BAGLEY CAROL TIPPI VOLYN THOMAS J. BUDGE CANDICE M. MCHUGH JONATHANM. VOLYN MARK A. SHAFFER LAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTERED BOISE OFFICE f01 SOUTH CAPITOL BOULEVARD, SUITE 208 BOISE. IDAHO 83702TELEPHONE: (208) 395-0011 FACSIMILE: (208) 433-0167 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 2324101 FACSIMILE (208) 232-6109 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 203A IDAHO FALLS, ID.83402 TELEPHONE: (208) 528-6101 FACSIMILE: (208) 328-6109ww.racinelaw.net COEUR D'ALENE OFFICE: 250 NORTHWE:ST BOULEVARD, SOITE.106A COEUR D'ALENE. 1083814 TELEPHONE: (208) 785-6888 SENDER'S E-MAIL ADDREss:elo!Qracinelaw.net ALL OFFICES TOLL FREE(877)'232-6101 LOUIS F.RACINE (1917-2005) WILLIAM D. OLSON. OF COUNSEL May 3, 2010 '!N 0"' ,..'"'''1' Be: Case No. IPC-E-IO-12 Dear Ms. 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. ELO:rg Enclosures cc: Service List Sincerely, ., 4. Eric L. Olsen ISB# 4811 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 r~~. E f~~ i riTV l.' ¡9= 26 Attorneys for Idaho Irrgation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) AUTHORITY TO IMPLEMENT POWER COST ) ADJUSTMENTS ('"PCA") RATES FOR ) ELECTRIC SERVICE FROM JUNE 1,2010 ) THROUGH MAY 31, 2010 ) ) CASE NO. IPC-E-I0-12 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ('"IIPA"), by and though its attorneys, hereby submits these First Data Requests to Idaho Power Company ('"IPC"), pursuant to Rule 225 of the Idaho Public Utility Commission's Rules of Procedure, IDAPA 31.01.01, as follows: 1. In Rebuttal testimony in Case No. IPC-E-06-8, page 27, beginning on line 11, Company witness Said gave the following testimony: Q. Please summarize your rebuttal testimony. A. All paries agree that a principal purpose of the PCA load growth adjustment rate is to eliminate the potential for double recovery of power supply expenses. Idaho Power believes this should be the sole purose of the load growth adjustment. Idaho Irrigation Pumpers Association, Inc.'s First Data Requests to Idaho Power Company - i ~, Does the Company still believe that the sole purpose of the load growth adjustment in the PCA is to eliminate potential double recovery of power supply expenses? If not, please explain. 2. In this case the Expense Adjustment Rate for Growth (EAGR) or what is sometimes referred to as the Load Growth Adjustment Rate (LGAR) produces a positive increase in the cost of the PCA for April 2009 through March 2010 in the amount of $23,680,328.05 as listed on line 13 of Exhibit 1. Is this the first PCA fiing where the anual expense adjustment for the EAGR (found on line 13 of Exhibit 1) reflected a negative growth, where the energy consumed was less than that which was in the base rate calculation? If not, please specify the case where this was previously true and provide the exhibit from that case where this "negative" growth was demonstrated. 3. Is it a mathematical fact, (given a positive Expense Adjustment rate like the $26.63 per MWh in this case), that any decrease in load, below that last established in base rates, produces a result that increase the PCA amount to be paid in the following year? If no, why not? 4. In this case the EAGR is increasing the PCA revenue requirement by $23.7 millon. Please explain what power supply expenses this revenue increase of$23.7 milion is designed to recover. 5. Under the assumption that the EAGR is revenue related and designed to insure that there is no double recovery of power supply expense, and given the $26.63 per MWh rate used in this case: Idaho Irrgation Pumpers Association, Inco's First Data Requests to Idaho Power Company - 2 , a. Would a negative .rte of some value make sense within the context of the EAGR? b. If a negative rate made sense, what would it mean/reflect with respect to the expenses/costs on the system and/or the collection of revenues? 6. If the Company continues to believe that the sole purpose of the load growth adjustment is to eliminate the potential for double recovery of power supply expenses (as testified by Company witness Said in his rebuttal testimony in Case No. IPC-06-8 at page 27), is it true that Purpose is not related to the method/data used to calculate the rate itself (i.e. the calculation of the $26.63 per MWh rate)? If the Company believes that the purpose ofthe EAGR is dependent upon the maner in which the rate is calculated, please define the present purpose of the EAGR under the present rate of $426.63 per MWh that was developed in the stipulation in Case No. E- 08-19. 7. Ifthe Company believes that the purpose of the EAGR is to recover a certain level of expenses and/or costs: a. Please site the exact reference in Commission Orders or other evidence that support the Company's position that the EAGR is designed to recover certain revenues/costs. b. What are those costs and expenses to be recovered? c. What does it mean with respect to the recovery of those cost and expenses if the EAGR rate itself is positive? d. What does it mean with respect to the recovery of those cost and expenses if the EAGR rate itself is negative? Idaho Irrgation Pumpers Association, Inc.'s First Data Requests to Idaho Power Company - 3 j e. What does it mean with respect to the recovery of those cost and expenses if the growt (load change) is positive? f. What does it mean with respect to the recovery of those cost and expenses if the growt (load change) is negative? . 8. In this case the EAGR (at line 13 of Exhibit 1) results in an increase to the PCA of$23.7 milion to be collected from the ratepayers. From a regulatory perspective, what specific expenses/costs are the ratepayers being asked to pay for (coal costs, purchase power costs, return on rate base, lost revenue, etc.)? 9. In this case the EAGR (at line 13 of Exhibit 1) results in an increase to the PCA of$23.7 million to be collected from the ratepayers. This primarly comes about because under the , present form of the formula, a reduction in load (below the base load used in the last rate case) results in an increase in the PCA rate. How does this result differ from a guarantee of a certain minimum level of revenue recovery? 10. There were some changes to the EAGR that resulted from the Stipulation fied in Case No. IPC-08-19. Was there anything specific about that Stipulation that caused the anual EAGR adjustment to increase the PCA this year, as opposed to the EAGR calculations that were in effect prior to that Stipulation? Idaho Irrgation Pumpers Association, Inc.'s First Data Requests to Idaho Power Company - 4 ".. DATED thiS~c/day of May, 2010. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED RIC L. OLSEN, ttorney for Idaho Irrigation Pumpers Association, Inc. Idaho Irrgation Pupers Association, Inc.'s First Data Requests to Idaho Power Company - 5 .. CERTICATE OF SERVICE . ~I HEREBY CERTIFY that on this ~ day of May, 2010, I served a true, correct and complete copy of the foregoing document to each of the following, via U.S. Mail or private courer, e-mail or hand delivery, as indicated below: Jean D. Jewell, Secretar Idaho Public Utilities Commission P.O. Box 83720 472 W. Washington Street Boise, Idaho 83720-0074 j jewell(fpuc.state.id. us U.S. Mail/Postage PrepaidX E-mail Facsimile X Overnight Mail Hand Delivered Lisa D. Nordstrom Donavan E. Walker Idaho Power Company P.O. Box 70 Boise, ID 83707-0070 Inordstrom(fidahopower .com dwalker(åidahopower.com X U.S. Mail/Postage PrepaidX E-mail Facsimile Overnight Mail Hand Delivered Scott Wright Greg W. Said Director State Regulation Idaho Power Company P.O. Box 70 Boise, ID 83707-0071 swright(fidahopower.com gsaid(ßidahopower .com X U.S. Mail/Postage Prepaid X E-mail Facsimile Overnight Mail Hand Delivered Dr. Don Reading 6070 Hil Road Boise, ID 83703 dreading(fmindspring.com X U.S. Mail/Postage Prepaid X E-mail Facsimile Overnight Mail Hand Delivered Idaho Irrigation Pupers Association, Inc.'s Firt Data Requests to Idaho Power Company - 6 ~ ," Peter J. Richards Gregory Adams Richardson & O'Leary 515 N. 1 ih Street P.O. Box 7218 Boise, ID 83702 petercmrichardsonandoleary.com greg(Çrichardsonandoleary .com x U.S. Mail/Postage Prepaid X E-mail Facsimile Overnight Mail Hand Delivered Idaho Irrgation Pupers Association, Inc.'s First Data Requests to Idaho Power Company - 7