20110110IIPA 1-17 to IPC.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, 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.
LANE V. ERICKSON
DAVID E. ALEXANDER
PATRICK N. 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
JONATHAN M. VOLYN
MARK A. SHAFFER
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
www.racinelaw.net
SENDER'S E-MAIL ADDRESS:elo(Qracinelaw.net
January 7,2011
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-I0-6
Dear Ms. Jewell:
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD. SUITE 208
BOISE. IDAHO 83702
TELEPHONE: [phone]
FACSIMlL:E: [phone]
IDAHO FALLS OFFICE
477.$HOUP AVENUESUITE 203A
IDAHO FALLS, 1083402
TELEPHONE: [phone]
FACSIMILE: [phone]
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE ,OSA
COEUR D'ALENE, ID 83814
TELEPHONE: [phone]
ALL OFFICES TOLL'FREE
[phone]
LOUIS F. RACINE ( 1917-2005)WILLIAM D. OLSON, OF COUNSEL
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Enclosed for filing in the captioned matter, please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's First Data Request To Idaho Power Company.
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Enclosures
cc: Service List
.
Eric L. Olsen ISB# 4811
RACIN, OLSON, NY, BUDE &
BAILEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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zon JÁN '0 Pl1 3: l 1
Attorneys for the Idaho Irrgation Pumpen Association, Inc.
BEFORE THE IDAHO PUBLIC UTITS COMMSSION
IN THE MATTER OF THE APPLICATION) CASE NO. IPC-E-I0-46OFIDAHOPO~RCOMæAN )
REQUESTING APPROVAL OF ) IDAHO IRGATION PUMERS
REVISIONS TO THE IRGATION PEAK) ASSOCIATION, INC.'S FIT
REWARS PROGRA, SCHEDULE 23 ) DATA REQUEST TO IDAHO PO~R
)COMæAN
)
1. The current Schedule 23 under the heading of "Demand Credit" states: "This amount
may be prorated for the number of days during the Months of June, July, and August
that fall in the Customer's biling cycle to correspond with the Program Season."
This interrogatory is focused upon the words "may be prorated".
a. In the past, has the Company prorated the demand credits?
b. If the Company has prorated the demand credits, were all demand credits
prorated? If not, what approximate percentage was not prorated?
c. Upon what basis did the Company prorate some demand credits and not others?
d. Regarding the customers under the Dispatchable Option, how many does the
Company have with specific daily/hourly data that can be used for determining
the "Program Season" usage? How many kW are involved with these customers?
2. Under the existing Schedule 23, for a customer taking service under the Dispatchable
Option 1 or 2 with the following parameters, please list each of the Demand and
Energy Credits that would be provided. Please provide all calculations and
assumptions used to develop these figures.
IDAHO IRGATION PUMæERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO IDAHO PO~R COMæAN 1
..
a. 100 k W demand
b. Meter readings occurrng on the first of the month with no specific provision to
calculate the actual usage each hour.
c. 168 hours of operation between June 1 and June 14
d. 300 hours of operation between June 15 and June 30
e. 300 hours of operation between July 1 and July 15
f. 168 hours of operation between July 16 and July 31
g. 168 hours of operation between August 1 and August 15
h. 100 hours of operation between August 16 and August 31.
3. Under the existing Schedule 23, for a customer taking service under the Dispatchable
Option 1 or 2 with the following parameters, please list each of the Demand and
Energy Credits that would be provided. Please provide all calculations and
assumptions used to develop these figures.
a. 100 k W demand
b. Meter readings occurrng on the first of the month with no specific provision to
calculate the actual usage each hour.
c. 234 hours of operation between June 1 and June 14
d. 234 hours of operation between June 15 and June 30
e. 234 hours of operation between July 1 and July 15
f. 234 hours of operation between July 16 and July 31
g. 168 hours of operation between August 1 and August 15
h. 100 hours of operation between August 16 and August 31.
4. Under the existing Schedule 23, for a customer taking service under the Dispatchable
Option 1 or 2 with the following parameters, please list each of the Demand and
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO IDAHO POWER COMPAN 2
~
Energy Credits that would be provided. Please provide all calculations and
assumptions used to develop these figures.
a. 100 k W demand
b. Meter readings occurrng on the first of the month with no specific provision to
calculate the actual usage each hour.
c. 300 hours of operation between June 1 and June 14
d. 168 hours of operation between June 15 and June 30
e. 100 hours of operation between July 1 and July 15
f. 0 hours of operation between July 16 and July 3 i
g. 0 hours of operation between August 1 and August 15
h. 0 hours of operation between August 16 and August 31.
5. In the existing Schedule 23 the Demand and Energy credits are to be calculated based
upon the "usage that occurs during the calendar months of June, July, and August of
each year." For 2009 and 2010, what was the total demand credit for June, July, and
August? What was the total energy credit for June, July, and August in 2009 and
2010?
6. Please provide a graph similar to Exhibit 1 page 1 (with support data presented in
tabular form) for each day durng 2009 and 2010 when there was an
interrption/curailment to either the Residential, Commercial, or Irrigation
customers. Please include in tabular form the timing and magnitude of each
interrptions as listed on Exhibit 1 page 1.
7. Please provide in electronic format, on an hourly basis, for the period Januar 1, 2009
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
typ of purchase (LF, IF, SF, etc.)
IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO IDAHO POWER COMPAN 3
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);
1. 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;
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;
1. 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;
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPAN 4
"
8. From Januar 2005 through the most recent month available, what was the date and
time and magnitude of the monthly system peak?
9. From Januar 2005 through the most recent month available, what was the date and
time and magnitude of the monthly system peak that would have occured, had there
been no curtailment of Residential, Commercial, and/or Irrgation load?
10. For each month from Januar 2005 through the most recent month available, what
was the amount of Retail energy used and the amount of Wholesale energy used?
Please indicate how losses are addressed or not addressed in the above figures.
11. Durng the hour of the monthly peak from Januar 2008 through the most recent
month available, please provide the following:
a. How many megawatts of generation were out of service for planed 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-QF 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 interrpted via the Irrgation Load Management program or
other similar programs? Please specify each program separately.
12. In this case the Company is proposing to put Schedule 23 customers on a varable
credit basis where only 40% of the existing rate wil be paid out as a fixed fee and the
other 60% wil be considered varable where, depending upon usage, 0-0% of the
credit wil be issued. What are the Company's plans to provide a similar
fixed/varable credit for Residential and/or Commercial demand response programs?
13. IPCo's 2009 DSM Report fied March 15,2010, at the bottom of page 8 states:
Next to distributed generation, the company's demand response programs
are the least -cost resource for meeting sumer peak loads over the 20-
year IRP planing period.
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO IDAHO POWER COMPAN 5
With respect to this statement, please provide the cost data that supports this
statement by specifically providing the levelized cost (or whatever data the
Company used) to define the 20-year cost of:
a. A single-cycle combustion turbine;
b. Distributed generation (please list size of units anualized);
c. The Irrigation demand response program;
d. The Residential demand response program; and
e. The Commercial/industrial demand response program.
14. Please provide a copy of all data and studies in the Company's possession that review
the actual usage for Residential, Commercial, and Irrgation demand response
customers that demonstrates their usage on day when curailments are not called and
the usage on the entire day of those days when curtilments are called.
15. Are the forecasted load duration curves on Exhibit 1 page 3 based upon normal or
95th percentile loads?
16. Both pages 3 and 4 of Exhibit 1 demonstrate that some of the data in the forecasted
load duration cures are not parallel, i.e. some of the graphs overlap. Why are some
of the load duration curves steeper in the 0-10 hour (highest hour) timeframe than
other years?
17. On page 6 lines 4-15 of Mr. Pengily's testimony it is stated that in 2010 that IPCo
enhanced its traditional 2011 IRP analysis. Please provide a copy of all information
associated with this enhancement that lead to "'the proposed Program modifications"
that were "'a direct result of that review."
RACINE OLSON NYE BUDGE
& BAILE TERED
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO IDAHO POWER COMPAN 6
CERTICATE OF MAING
I HEREBY CERTIFY that on this ~ day of Januar, 2011, I served a tre,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
P.o. Box 83720
472 W / Washington Street
Boise, Idaho 83720-0074
jj ewell (ßpuc . state .i d. us
~.
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0072
Inordstrom(ßidahopower.com
dwalker(ßidahopower .com
'6)t(
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
Greg W. Said
Scott Sparks
Director State Regulation
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0071
gsaid(ãidahpower .com
ssparks(ßidahopower .com
~U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIT DATA REQUEST TO IDAHO POWER COMPAN 7