20110622IIPA 1-26 to IPC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTEREDW. 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
Jean D. Jewell, Secreta
Idaho Public Utilties Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-II-08
Dear Ms. Jewell:
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racinelaw.net
SENDER'S E-MAIL ADDREss:elo!§racinelaw.net
June 20, 2011
BOISE OFFICE
'0' SOUTH CAPITOL
BOULEVARD, SUITE 20B
BOISE, IDAHO 83702
TELEPHONE: [phone]"FACSIMILE: (208) 433--187
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203-
IDAHO FALLS, ID 83402TELEPHONE: [phone]
FACSIMILE: (208) 528-6'09
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE iDeA
COEUR D'ALENE, ID 83814TELEPHONE: [phone]
LOUIS F. RACINE 0917-2005)
WILLIAM D. OLSON. OF COUNSEL
ALL OFFICES TOLL FREE
(677) 232-6'0'
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Enclosed for fiing 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.
ELO:rg
Enclosures
cc: Service List
Eric L. Olsen ISB# 4811
RACINE, OLSON, NY, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
I.. 'ìRECE\\' t:L
201 i Jm! 22 ri,t"' 8~ 28
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC
SERVICE TO ITS CUSTOMERS IN THE
STATE OF IDAHO
) CASE NO. IPC-E-11-08
)
) IDAHO IRRGATION PUMPERS
) ASSOCIATION, INC.'S FIRST
) DATA REQUEST TO IDAHO POWER
) COMPANY
)
1. Provide a copy of the Company's Char of Accounts.
2. For all FERC Expense Accounts listed in Exhbit 25, please provide by subaccount,
by month, the actual expenses that were incured from Januar 2008 though the most
recent month available. Please provide ths information in electronic version.
3. Please supply in electronic format for each month since Januar 2006 the biling
month biling determents (and associated revenue) of each of the rate categories listed
in Exhbit 29 in the Idaho jurisdiction. Also please provide a listing of the varous
rates that were in effect over this period for each of these rate categories.
4. Please supply in electronic format for each month since Janua 2006 the calendar
month biling determents (and associated revenue) of each of the rate categories listed
in Exhibit 29 in the Idaho jursdiction.
5. With respect to the Company's Load Research data, please provide in Excel or
Access format, for each sample customer with valid data that was sampled between
Janua 2006 and the most recent month available the following:
a. Customer identification number;
b. Customer rate schedule;
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 1
c. Strata to which it belongs
d. Raw hourly usage data;
e. Raw hourly usage data modified to reflect losses;
f. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company's cost of service study in this case;
g. Please provide copies ofthe formulas (and data) used to expand the Load
Research data (strata weighting factors etc.) up to the population as a whole as
used in the class cost of service study in this case;
h. Please indicate which (if any) of the Irrgators sampled in the Company's load
research data that was provided in "d" above were on Schedule 23.
6. Please provide for each month from Janua 2006 to the most recent month available
a copy of the monthy checks that the Company makes regarding how well the Load
Research sample data reflects the actu population usage. Also supply for one month
and one rate schedule an explanation of how the numerical data in these reports is
used to reflect accuracy of sample.
7. It is the Irgators understading that the Company has collected a separate sample of
hourly load data for customers on Schedule 23 in order to spot-check the performance
of the Irrgation Peak Rewards Program. Please supply ths hourly data for all such
customers between Januar 2006 and the most recent month available. Please
indicate if there is some overlap with ths data and the Company's load research data
and if there is, indicate which sample customers overlap.
8. Please provide in electronic format, on an hourly basis, for the period Januar 1, 2008
though 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
type of purchase (LF, IF, SF, etc.)
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;
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPAN 2
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;
1. Other system inputs, stating for each "other" input the tye and the source of the
input;
J. Jursdictional (Idaho and Oregon) sales;
k. System losses;
1. Requirements Wholesale sales (RQ);
m. Long-term firm Wholesale sales (LF), stating each on separately;
n. Intermediate-term firm Wholesale sales (IF), stating each one separately;
o. Short-term Wholesale sales (SF), stating each one separately;
p. Unit sales, Wholesale (LU) or otherwse, stated separately;
q. Non-firm and/or economy Wholesale sales (OS), stated separately;
r. The revenue collected each hour from each non-firm and/or economy purchased
listed in "P" above.
s. Exchanges out of the system, stating each exchange separately;
t. Other system outputs, stating for each "other" output the typ and recipient of the
output;
u. Inadvertent power flows into or out of the system;
v. The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadvertent has been subtracted;
w. Losses assigned to each retal jursdiction;
x. Losses assigned to Wholesale sales;
y. Tota retail load by jursdiction;
9. From Januar 2006 through the most recent month available, what was the date and
time and magnitude of the monthy system peak?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 3
10. From Januar 2006 through the most recent month available, what was the date and
time and magntude of the monthly system peak that would have occured, had there
been no curailment of Residential, Commercial, and/or Irrgation load?
11. For each month from Januar 2006 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 figues.
12. Durng the hour of the monthy peak from Januar 2008 though 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 tye of
purchase (LF, RQ, SF, OS, etc.)?
f. How much electrcity 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.
13. Regarding Mr. Larkin's workpapers page 10 of 81 for the State of Idaho:
a. Are these values on a "calendar" or "biling" month basis?
b. If these values are at "sales level", please supply these same values in electronic
format at "generation level".
c. If these values are on a "biling month" basis, please supply in electronic format
the same information on a "calenda Month" basis.
14. Regarding Mr. Larkin's workpapers pages 1-3 of81 for the State ofIdaho:
a. Are these values on a "calendar" or "biling" month basis?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 4
b. If these values are at "sales level", please supply these same values in electronic
format at "generation level".
c. If these values are on a "biling month" basis, please supply in electronic format
the same information on a "calendar Month" basis.
15. Regarding Mr. Larkin's work papers page 7 of81 for the State ofIdaho:
a. Are these values on a "calendar" or "biling" month basis?
b. What does "BLC" stand for?
c. Please supply in electronic format the underlying data for each of the four years of
data used to establish these averages.
16. Regarding Mr. Larkin's work papers page 22 of81, please provide in electronic
format the hourly data for all thee years of data used to develop these load duration
cures for each rate group listed.
17. Regarding Mr. Larkin's work papers pages 46-47 of81, please provide in electronic
format all underlying data (and assumptions) used to develop the values listed.
18. Regarding Mr. Larkin's work papers page 48 of81, please provide in electronic
format all underlying data (and assumptions) used to develop the values listed.
19. Please provide a copy ofIdaho Power's FERC Form l's for 2008,2009, and 2010.
20. Please provide a copy ofIdaho Power's most recent IR to be filed this sumer.
21. Under which FERC accounts and/or subaccounts are the capital, operation, and
maintenance costs of wind tubine generators?
22. Mr. Larkin's work paper page 56 of81 there is a discussion of the modifications to
the demand estimates because of demand response programs. Please supply in
electronic format the data (and associated changes) that occur in each of these steps
that he addresses.
23. Please provide in electronic format outage data for each substation and each circuit in
each substation for each of the last four years:
a. The date, time and duration of any outage.
b. The number of customers impacted by rate schedule.
c. The estimated k W of load impacted.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 5
d. Any other data the Company routinely keeps regarding outages such as cause of
the outage.
24. Please provide electronically any SAIDI, SAIFI, MAIDI, or CAIDI information that
the Company has collected over the past four years. Such data should be provided at
the least aggregated level it is maintained by the Company.
25. For each month of2006 and 2007 please provide in electronic format, by rate
schedule, the sum of the individual customer biling demands. If possible, please
supply this data on a calendar as well as a biling month basis.
26. Please provide an electronic version of all (spreadsheet based) exhibits and work
papers with formulas intact in excel format.
RACIN OLSON NYE BUDGE
& BAIL HARTERED
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPAN 6
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this i 0'0 day of June, 2011, I served a tre,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
~.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnght Mail
Hand Delivered
Jean D. Jewell, Secreta
Idaho Public Utilities Commission
P.O. Box 83720
472 W / Washington Street
Boise, Idaho 83720-0074
j jewell (ßpuc. state.id. us
Lisa D. Nordstrom
Donovan E. Walker
Jason B. Wiliams
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0072
Inordstrom(ßidahopower .com
dwalker(ßidahopower.com
j willams(ßidaopower. com
U.S. Mail/ostae Prepaid
V E-Mail
Facsimile
Overnight Mail
Hand Delivered
GregW. Said
Director State Reguation
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0071
gsaid(ßidahpower .com
ll.S. Mail/ostage Prepaid
VE-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/ostae Prepaid
7É-Mail
Facsimile
Overnight Mail
Hand Delivered
Peter J. Richardson
Gregory M. Adams
Richardson & O'Lear, PLLC
515 N 27th Street
P.O. Box 7218
Boise, Idaho 83702
peter(ßrichardsonandolear.com
greg(ßrichardsonandolear.com
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPAN 7
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
dreading(imindspring.com
U.S. Mail/Postage Prepaid~Mail
Facsimile
Overnight Mail
Hand Delivered
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 8