20110712IPC to IIPA 1-26.pdf

LISA D. NORDSTROM
Lead Counsel
Inordstromtâidahopower.com
es11W~POR~
An IDACORP Company
July 11, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83720
Re: Case No. IPC-E-11-08
General Rate Case
Dear Ms. Jewell:
Enclosed for filng are an original and three (3) copies of Idaho Power Company's
Response to the Idaho Irrigation Pumpers Association, Inc.'s First Data Request to Idaho
Power Company in the above matter.
Very truly yours,
efif£i:J ~
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise. ID 83707
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
Inordstrom((idahopower.com
dwalker((idahopower.com
jwilliams((idahopower.com
Attorneys for Idaho Power Company
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20B JUL II PM 4: 42
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 IN IDAHO. )
)
)
)
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)
CASE NO. IPC-E-11-08
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST DATA
REQUEST TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the First Data Request of the Idaho Irrigation Pumpers Association, Inc., to
Idaho Power Company dated June 20, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO.1: Provide a copy of the Company's Chart of Accounts.
RESPONSE TO REQUEST NO.1: Please see the Excel file provided on the
enclosed CD.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 2
REQUEST NO.2: For all FERC Expense Accounts listed in Exhibit 25, please
provide by subaccount, by month, the actual expenses that were incurred from January
2008 through the most recent month available. Please provide this information in
electronic version.
RESPONSE TO REQUEST NO.2: Please see the Excel files provided on the
enclosed CD for the expenses, by month, for January 2008 through March 2011.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 3
REQUEST NO.3: Please supply in electronic format for each month since
January 2006 the billng month billng determents (and associated revenue) of each of
the rate categories listed in Exhibit 29 in the Idaho jurisdiction. Also please provide a
listing of the various rates that were in effect over this period for each of these rate
categories.
RESPONSE TO REQUEST NO.3: Historical billng determinants are provided
in electronic format for 2008 through 2010 in the Excel file included on the enclosed CD.
Data for 2006 and 2007 is only available in hard copy format and has therefore been
provided as PDF files on the enclosed CD. Please note that these detailed monthly
biling determinants reflect weather normalized usage and are prepared for the specific
purpose of deriving normalized test year retail revenues. Revenue associated with
each category of biling determinant reflects annualized historical rates applied to
normalized biling determinants. The enclosed CD also contains an Excel workbook
providing historical rates in effect from June 1, 2005, to May 31, 2011.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 4
REQUEST NO.4: Please supply in electronic format for each month since
January 2006 the calendar month biling determents (and associated revenue) of each
of the rate categories listed in Exhibit 29 in the Idaho jurisdiction.
RESPONSE TO REQUEST NO.4: Biling determinants listed in Exhibit 29 are
prepared on a biling month basis not a calendar month basis. Billng month
determinants and associated revenue from January 2006 through 2010 were provided
in the Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA")
Request No.3. However, the Company does prepare total monthly energy by rate
class on a calendar month basis. An Excel file containing this information has been
provided on the enclosed CD.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 5
REQUEST NO.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 January 2006 and the most recent month available the following:
a. Customer identification number;
b. Customer rate schedule;
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 of the 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 Irrigators sampled in the
Company's load research data that was provided in "d" above were on Schedule 23.
RESPONSE TO REQUEST NO.5: In response to Requests 5.a, 5.b, 5.c, and
5.d, the customer identification numbers, rate schedule, stratum, and hourly usage data
are included on the enclosed CD in the Excel workbooks with "hourly," the sample
identifier, and the corresponding year in the file name.
Raw hourly usage data modified to reflect losses (5.e) does not exist. However,
the hourly usage data coincident with the system peaks or the group peaks may be
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 6
adjusted to reflect losses using the system loss coefficients contained in the "RefTables"
spreadsheet of the workbook Demands2011 RC11 Factors.xlsx.
In response to Request 5.f, the Company did not calibrate the hourly Load
Research data. Please see the Company's Response to IIPA's Request No. 22 for
information about the modifications to the demand estimates for the Irrigation
customers.
In response to Request 5.g, the formulas (and data) used to expand the Load
Research data up to the population as a whole, as used in the class cost-of-service
study in this. case,are contained in the Excel workbooks
Demands2011RC11Factors.xlsx and StratumWeights.xlsx provided on the enclosed
CD. Additional documentation of the formulas and methodology are provided in Mr.
Larkin's workpapers on pages 50 through 55.
In response to Request 5.h, all of the Schedule 23 customers were removed from
the Load Research sample as described in Mr. Larkin's workpapers at page 56. The
data for these Irrigation Peak Rewards Program participants is provided separately in
the Company's Response to IIPA's Request No.7.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 7
REQUEST NO.6: Please provide for each month from January 2006 to the
most recent month available a copy of the monthly checks that the Company makes
regarding how well the Load Research sample data reflects the actual 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.
RESPONSE TO REQUEST NO.6: The relative precision of the ratio estimates
from January 2006 through December 2010 is contained in the monthly Load Research
summary reports provided on the enclosed CD. Data for 2011 is not yet available. To
provide an example of how this numerical data is used, the relative precision for the
maximum coincident demands of Rate 24 in July 2007 can be found on page 5 of
Rate24Summary200 7-0 7. doc. For the group coincident demand, the relative precision
at the 90 percent confidence level was +/- 8.032 percent. For the coincident demand at
the supplied hour of the monthly system peak, the relative precision at the 90 percent
confidence level was +/- 7.763 percent.
For convenience, all of the relative precision values are tabulated in the
RelativePrecision.xls file contained on the enclosed CD.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 8
REQUEST NO.7: It is the Irrigators understanding 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 Irrigation Peak Rewards Program. Please supply
this hourly data for all such customers between January 2006 and the most recent
month available. Please indicate if there is some overlap with this data and the
Company's load research data, and if there is, indicate which sample customers
overlap.
RESPONSE TO REQUEST NO.7: The hourly data from participants in the
Irrigation Peak Rewards Program is provided on the enclosed CD. There are two Excel
workbooks for each year. One workbook contains participants which were never in the
Load Research sample. The second workbook contains participants who were
originally in the Load Research sample but were removed for this yeats modified
analysis procedure as determined by Mr. Larkin's testimony. There is no overlap
between these two groups or between either of these groups and the irrigators whose
hourly data were provided in the Company's Response to IIPA's Request No. 5.f. The
three groups of irrigators are mutually exclusive.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 9
REQUEST NO.8: Please provide in electronic format, on an hourly basis, for
the period January 1, 2008 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 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;
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 "othet' input the type and the
source of the input;
j. Jurisdictional (Idaho and Oregon) sales;
k. System losses;
i. 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;
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 10
o. Short-term Wholesale sales (SF), stating each one separately;
p. Unit sales, Wholesale (LU) or otherwise, 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 "othet' output the type 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 retail jurisdiction;
x. Losses assigned to Wholesale sales;
y. Total retail load by jurisdiction.
RESPONSE TO NO. 8.a-k and m-v: Please see the Excel files provided on the
enclosed CD. To use these Excel files, utilze the drop-down menus found on line 6.
For instance, clicking on the arrow on line 6 of column A wil show the drop-down menu
for system load data. To view the system load data, select "system load" from the
menu. This selection wil bring up the system load data starting in column Z. The
specific responses are identified by the column headings on line 5.
The data requested in 8.j is unavailable on an hourly basis.
The response to this Request was prepared by Sandy Ward, Operations
Accountant II, Idaho Power Company, in consultation with Matthew T. Larkin,
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 11
Regulatory Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
RESPONSE TO REQUEST NO. 8.1 and w-y:
i. The requested data for Requirements Wholesale sales does not exist.
The wholesale customer sales in the rate case test period are zero.
w. Hourly losses assigned to each retail jurisdiction are not available. Loss
factors for peak demand and energy by voltage for each jurisdiction are contained in the
"RefTables" spreadsheet of the workbook Demands2011 RC11 Factors.xlsx provided in
the Company's Response to IIPA's Request No. 5.g. These are system loss factors by
voltage level and are not calculated on an hourly basis.
x. Hourly losses assigned to wholesale sales are not available. Loss factors
for peak demand and energy by voltage are contained in the "RefTables" spreadsheet
of the workbook Demands2011 RC11 Factors.xlsx provided in the Company's Response
to IPPA's Request No. 5.g. These are system loss factors by voltage level and are not
calculated on an hourly basis.
y. Hourly retail load by jurisdiction is not available. The spreadsheet labeled
Demands2010Actual.xlsx provided on the enclosed CD contains the monthly energy
and coincident demand information for 2010 with and without losses. The monthly
energy and coincident demand information for the test year has been provided in the
Demands2011 RC11 Factors.xlsx file provided in the Company's Response to IIPA's
Request NO.5.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 12
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 13
REQUEST NO.9: From January 2006 through the most recent month available,
what was the date and time and magnitude of the monthly system peak?
RESPONSE TO REQUEST NO.9: The "System Peak" spreadsheet in the
MonthlySystemPeaks.xlsx workbook provided on the enclosed CD lists the monthly
system peaks from January 2006 through May 2011.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 14
REQUEST NO. 10: From January 2006 through the most recent month
available, what was the date and time and magnitude of the monthly system peak that
would have occurred, had there been no curtailment of Residential, Commercial, and/or
Irrigation load?
RESPONSE TO REQUEST NO. 10: The "SystemPeakWithoutDRCurtailment"
spreadsheet in the MonthlySystemPeaks.xlsx workbook provided on the enclosed CD in
the Company's Response to IIPA's Request No.9 lists the monthly system peaks from
January 2006 through December 2010 that would have occurred had there been no
curtailment of Residential, Commercial, and/or Irrigation load. Data for the beginning of
2011 is not yet available.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -15
REQUEST NO. 11: For each month from January 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 figures.
RESPONSE TO REQUEST NO. 11: Please see the Excel file provided by the
Company's in its Response to IIPA's Request NO.4.
The. information in the response to this Request was prepared by Matthew T.
Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D.
Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 16
REQUEST NO. 12: During the hour of the monthly peak from January 2008
through the most recent month available, please provide the following:
a. How many megawatts of generation were out of service for planned
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 interrupted via the Irrigation Load
Management program or other similar programs? Please specify each program
separately.
RESPONSE TO REQUEST NO. 12.a-f. Please see the Excel files provided on
the enclosed CD.
The response to this Request was prepared by Sandy Ward, Operations
Accountant II, Idaho Power Company, in consultation with Matthew T. Larkin,
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -17
Regulatory Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
RESPONSE TO REQUEST NO. 12.g: Please see the Excel files provided on
the enclosed CD.
The response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -18
'REQUEST NO. 13: Regarding Mr. Larkin's workpapers page 10 of 81 for the
State of Idaho:
a. Are these values on a "calendat' or "billng" 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 "billing month" basis, please supply in
electronic format the same information on a "calendar Month" basis.
RESPONSE TO REQUEST NO. 13:
a. These values are on a biling month basis.
b. Please see Table III of the Excel workbook provided on the enclosed CD.
c. Please see Tables II and III of the Excel workbook provided on the
enclosed CD for calendar month sales at the customer and generation levels,
respectively.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 19
REQUEST NO. 14: Regarding Mr. Larkin's workpapers pages 1-3 of 81 for the
State of Idaho:
a. Are these values on a "calendat' or "billng" 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 "billng month" basis, please supply in
electronic format the same information on a "calendar Month" basis.
RESPONSE TO REQUEST NO. 14:
a. These values reflect biling month usages.
b. Idaho Power does not prepare detailed billng components at the
generation leveL.
c. Idaho Power does not prepare detailed biling components on a calendar
month basis.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 20
REQUEST NO. 15: Regarding Mr. Larkin's work papers page 7 of 81 for the
State of Idaho:
a. Are these values on a "calendat' or "billng" 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.
RESPONSE TO REQUEST NO. 15:
a. These values reflect billng month usage.
b. "BLC" stands for "Basic Load Capacity."
c. Please see the Excel file provided on the enclosed CD.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 21
REQUEST NO. 16: Regarding Mr. Larkin's work papers page 22 of 81, please
provide in electronic format the hourly data for all three years of data used to develop
these load duration curves for each rate group listed.
RESPONSE TO REQUEST NO. 16: Please see the Excel files provided by the
Company in its Response to IIPA's Request NO.5.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 22
REQUEST NO. 17: Regarding Mr. Larkin's work papers pages 46-47 of 81,
please provide in electronic format all underlying data (and assumptions) used to
develop the values listed.
RESPONSE TO REQUEST NO. 17: Please see Excel file
Demands2011RC11Factors.xlsx provided by the Company in its Response to IIPA's
Request NO.5.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 23
REQUEST NO. 18: Regarding Mr. Larkin's work papers page 48 of 81, please
provide in electronic format all underlying data (and assumptions) used to develop the
values listed.
RESPONSE TO REQUEST NO. 18: Please see Excel file
Demands2011 RC11 Factors.xlsx provided by the Company in its Response to IIPA's
Request No.5.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 24
REQUEST NO. 19: Please provide a copy of Idaho Power's FERC Form 1's for
2008,2009, and 2010.
RESPONSE TO REQUEST NO. 19: Please see the documents provided on the
enclosed CD.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 25
REQUEST NO. 20: Please provide a copy of Idaho Powets most recent IRP to
be filed this summer.
RESPONSE TO REQUEST NO. 20: Idaho Power filed its 2011 Integrated
Resource Plan ("IRP") with the Idaho Public Utilties Commission on June 30, 2011.
The IRP fiing included the main IRP document and three appendices: (1) Appendix A-
Sales and Load Forecast, (2) Appendix B - Demand-Side Management 2010 Annual
Report, and (3) Appendix C - Technical Appendix. Electronic copies of the IRP
documents are included on the enclosed CD.
The response to this Request was prepared by M. Mark Stokes, Manager, Power
Supply Planning, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 26
REQUEST NO. 21: Under which FERC accounts and/or subaccounts are the
capital, operation, and maintenance costs of wind turbine generators?
RESPONSE TO REQUEST NO. 21: Idaho Power does not currently own and
operate any wind turbine generators. Wind energy is procured via Public Utilty
Regulatory Policies Act of 1978 ("PURPA") contracts and long-term power purchase
agreements and is accounted for in FERC Account 555100, Purchased Power PURPA,
and FERC Account 555000, Other Purchased Power.
The response to this Request was prepared by Doug Jones, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 27
REQUEST NO. 22: Mr. Larkin's work paper page 56 of 81 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.
RESPONSE TO REQUEST NO. 22: The requested data is contained in the
AdjustingCensusSamplePeaks.xlsx workbook provided on the enclosed CD.
This response to this Request was prepared by Mary Graesch, Load Research
Leader, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 28
REQUEST NO. 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 kW of load impacted.
d. Any other data the Company routinely keeps regarding outages
such as cause of the outage.
RESPONSE TO REQUEST NO. 23: Excel file 2007-2010 Outage Data
Customers by Rate included on the enclosed CD contains the actual outage detail and
breakdown of customers by rate code for every outage since the beginning of 2007.
Idaho Power does not track the estimated kilowatts of load impacted.
The to this Request was prepared by Paula Penza, Finance Team Leader, Idaho
Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 29
REQUEST NO. 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.
RESPONSE TO REQUEST NO. 24: Excel file 2007-2010 Feeder History
provided on the enclosed CD contains the SAIDI, SAIFI, and CAIDI indices calculated in
quarterly and rollng four quarter increments by state and feeder for the past four years,
2007 through 2010. The SAIDI, SAIFI, and CAIDI indices are the only index
calculations that Idaho Power has maintained for this time period.
The response to this Request was prepared by Perry Van Patten, Delivery
Reliabilty and Maintenance Manager, Idaho Power Company, in consultation with Lisa
D. Nordstrom, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 30
REQUEST NO. 25: For each month of 2006 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.
RESPONSE TO REQUEST NO. 25: Total billng demands by rate schedule
from 2006 through 2010 are provided by the Company in its Response to IIPA's
Request NO.3. This information is not tracked on a calendar month basis.
The response to this Request was prepared by Matthew T. Larkin, Regulatory
Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 31
REQUEST NO. 26: Please provide an electronic version of all (spreadsheet
based) exhibits and work papers with formulas intact in excel format.
RESPONSE TO REQUEST NO. 26: All workpapers and exhibits were provided
in electronic format on the disk containing Idaho Powets initial filng, which was mailed
to Messrs. Olsen and Yankel on June 7, 2011. In addition, please see the workpaper
and exhibit Excel files, with formulas intact, provided on the enclosed CD.
The response to this Request was prepared by Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 11 th day of July 2011.
~l).tJ~ïS NORDS ROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 32
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11 th day of July 2011 I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO THE
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO
IDAHO POWER COMPANY upon the following named parties by the method indicated
below, and addressed to the following:
Commission Staff
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Karl T. Klein
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
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2¡th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
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greg((richardsonandoleary.com
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 33
Anthony Yankel
29814 Lake Road
Bay Vilage, Ohio 44140
Kroger Co.
Kurt J. Boehm
BOEHM, KURTZ & LOWRY
36 East Seventh Street, Suite 1510
Cincinnati, Ohio 45202
Kevin Higgins
Energy Strategies, LLC
215 South State Street, Suite 200
Salt Lake City, Utah 84111
Micron Technology, Inc.
Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
MaryV. York
Thorvald A. Nelson
Mark A. Davidson
HOLLAND & HART LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Vilage, Colorado 80111
Department of Energy
Arthur Perry Bruder, Attorney-Advisor
United States Department of Energy
1000 Independence Avenue SW
Washington, DC 20585
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Steven. porter((hg.doe.gov
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 34
Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
Columbia, Maryland 21044
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Community Action Partnership
Association of Idaho
Brad M. Purdy
Attorney at Law
2019 North 17th Street
Boise, Idaho 83702
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-l Email bmpurdy((hotmail.com
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
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X Email botto((idahoconservation.org
Ll).llll~
Lisa D. Nordstro
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY - 35