HomeMy WebLinkAbout20110718IPC to IIPA 27-33.pdfLISA D. NORDSTROM
Lead Counsel
Inordstromtmidahopower.com
REGE
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An 10ACORP company
July 15, 2011
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties 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 Second Data Request to
Idaho Power Company in the above matter.
Also enclosed are four (4) copies of a disk containing documents being produced in
response to the Idaho Irrigation Pumpers Association, Inc.'s Second Data Request.
Very truly yours,~!/1i~
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, 1083707
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: (208) 388-5825
Facsimile: (208) 388-6936
InordstromCâidahopower.com
dwalkerCâidahopower.com
jwilliamsCâidahopower.com
Attorneys for Idaho Power Company
RECEIVED
ioii JUL 15 PM 4: 48
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. )
)
)
)
)
)
CASE NO. IPC-E-11-08
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC.'S SECOND
DATA REQUEST TO IDAHO POWER
COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the Idaho Irrigation Pumpers Association, Inc.'s Second Data Request to
Idaho Power Company dated June 24, 2011, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO. 27: On pages 2 and 3 of Ms. Nemnich' (sic) work papers there is
listed values of 36% for "On-Peak Summet' usage and 64% for "Off-Peak Summet'
usage. Please indicate the source of these values as well as supply all hourly data that
was used to develop these figures.
RESPONSE TO REQUEST NO. 27: The values of 36 percent for "On-Peak
Summet' usage and 64 percent for "Off-Peak Summet' usage were derived from the
Company's 2009 residential hourly load research sample. By averaging the three
average weekday and average weekend/holiday hourly profiles for the summer months
of June, July, and August provided by the 2009 residential hourly load research data, a
summer weekday average residential load profile and a summer weekend/holiday
residential load profile was determined. (Please see the "Avg Daily Usage" tab of the
Excel file provided on the enclosed CD.) These daily averages were used to estimate
the monthly and then annual energy used during On-Peak and Off-Peak hours during
the summer months. (Please see the "Daily Usage Totals" and "% in block" tabs of the
Excel file provided on the enclosed CD.) The 36 percent and 64 percent represent the
ratio of kilowatt-hours ("kWh") used during the On-Peak summer and Off-Peak summer
time periods, respectively.
The response to this Request was prepared by Darlene Nemnich, Senior Pricing
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 SECOND DATA REQUEST TO IDAHO POWER COMPANY - 2
REQUEST NO. 28: Exhibit 46 page 1 lists the proposed average monthly
revenue for Schedule 1 usage of 1,000 kWh at $80.41. Exhibit 46 page 2 lists the
proposed average monthly revenue for Schedule 4 usage of 1,000 kWh (with 4 kWh of
Energy Watch energy per summer month) at $79.21. The Company's testimony
presented the logic of how these rates were derived, but did not specifically address
differences in cost-of-service.
a. Please explain from a cost-of-service point of view the basis for the
$14.40 annual difference in revenue for these two schedules ($1.20 per month times
12).
b. Please explain the basis for the assumption of 4 kWh of Energy
Watch energy per summer month. Is there an assumed load profile that results in only
4 kWh of Energy Watch energy per summer month, or is there an assumed load profile
with a specific reduction in energy usage to only 4 kWh of Energy Watch energy per
summer month?
c. Please provide any assumptions or load profiles that are assumed
that serve as the basis for the proposed schedule 4 rates.
RESPONSE TO REQUEST NO. 28:
a. The difference of $14.40 derived by comparing the line item on page 1
(Schedule 1) of Exhibit No. 46 and page 2 (Schedule 4) of Exhibit No. 46 is not based
on cost-of-service analysis between the two separate rate designs, nor are they
intended to represent "average monthly revenue" for either Schedule 1 or Schedule 4.
In fact, it would be difficult to do a direct comparison between the exhibit sheets for the
two rate schedules without an understanding or assumption of the load profile for a
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 3
specific customer. The exhibit sheets are only intended to provide a sample bil
calculation at varying levels of usage. For example, page 1 of Exhibit No. 46 provides
sample calculations for an individual with an average consumption of 1,000 kWh per
month during each of the summer months, or an average consumption of 1,000 kWh
per month during each of the non-summer months. Rare would be the individual who
would use the same level of energy every month all year long, but if he/she did, it would
equate to the annual average monthly amount. However, these bil calculations do not
depend on the time of day when the 1,000 kWh were consumed. If the customer used
all 1,000 kWh during the night (off-peak) or all 1,000 kWh during the afternoon (on-
peak), his/her average monthly bil would be the same.
For page 2 (Schedule 4) of Exhibit No. 46, it does make a difference. However,
for purposes of the sample bil calculations shown on Exhibit No. 46, an assumption is
made that the customer uses 36 percent of the average 1 ,000 kWh consumption for
each of the summer months during the on-peak hours and 64 percent of the average
monthly consumption during the off-peak time period. In addition, it is assumed that 4
kWh during each summer month are priced at the critical peak rate of 40 cents per kWh.
In part, Schedule 4 is intended to give customers an incentive to modify their
consumptive behavior by shifting their energy consumption from on-peak to off-peak
hours by enabling them to reduce their monthly bilL. These exhibit sheets were not
intended to present a cost-of-service point of view between the two separate rate
schedules.
b. The 4 kWh of Energy Watch energy per summer month for a customer
using 1,000 kWh was derived from the 2011 Test Year energy for Schedule 4
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 4
developed by Mr. Larkin. It is calculated by dividing the total annual kWh forecasted for
the Energy Watch events (606 kWh) by the total summer energy (148,289 kWh + 606
Energy Watch kWh = 148,895 kWh). This ratio of .004 (606 / 148,895 = .004) was
applied to the assumed 1,000 kWh of monthly summer usage to derive 4 kWh of Energy
Watch energy per summer month for a customer using 1,000 kWh (.004 X 1,000 kWh =
4 kWh). The 2011 Test Year energy for Schedule 4 is based upon allocation ratios
derived from 2010 actual usage applied to the 2011 residential energy forecast. There
was not an assumed load profile used to determine the 4 kWh of Energy Watch energy
per summer month.
c. There was not an assumed load profile which served as the basis for the
proposed Schedule 4 rates. As described in Ms. Nemnich's testimony on pp. 19-26, the
basic rate design structure for Schedule 4 was the same as the Company's time-of-day
residential pricing proposal for Schedule 5. The Company then reduced the energy
charge rates uniformly by 5 percent. This reduction provides a financial incentive to
customers by providing a lower rate during all non-critical peak hours for the option of
the Company charging significantly higher rates during critical peak hours. The critical
peak pricing is intended to encourage customers to reduce their consumption during the
Energy Watch events when they are called.
The response to this Request was prepared by Darlene Nemnich, Senior Pricing
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 SECOND DATA REQUEST TO IDAHO POWER COMPANY - 5
REQUEST NO. 29: Exhibit 46 page 1 lists the proposed average monthly
revenue for Schedule 1 usage of 1,000 kWh at $80.41. Exhibit 46 page 3 lists the
proposed average monthly revenue for Schedule 5 usage of 1,000 kWh (assuming the
36% on-peak usage during summer months and 48% mid-peak during the non-summer
months per Nemnich work paper page 3) at $82.78.
a. Assuming that the on-peak and mid-peak usages are the same,
please explain why the Schedule 5 customer would pay $28.44 more per year than a
Schedule 1 customer.
b. The Company's testimony presented the logic of how these rates
were derived, but did not specifically address differences in cost-of-service. Please
explain from a cost-of-service point of view the basis for the $28.44 annual difference in
revenue for these two schedules ($2.37 per month times 12).
c. Please provide any assumptions or load profiles that are assumed
that serve as the basis for the proposed schedule 5 rates.
RESPONSE TO REQUEST NO. 29:
a. There would not be a financial incentive for a customer who consumed
energy as described above to voluntarily move to Schedule 5 from Schedule 1.
Because the hours for the summer on-peak time period are less than the hours for the
non-summer mid-peak time period, in order to assume that the on-peak and mid-peak
usages were the same, as described above, would entail an assumption that the
amount of kWhs of energy consumed per hour during the on-peak summer months is
significantly greater than the amount of kWhs consumed per hour during the non-
summer mid-peak time period. This customer would pay a higher bil than the Schedule
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 6
1 customer, and would be paying an amount more indicative of the costs incurred by the
Company to provide energy for that customer during the heavy load hours. However, if
that customer were wiling to modify his/her consumptive patterns so that he/she would
shift his/her energy consumption to the off-peak time periods, his/her bil would go down
and be below that of a Schedule 1 customer who used the same amount of energy.
The Schedule 1 customer cannot affect his/her energy bil by shifting his/her usage to
an off-peak time period.
b. The difference of $28.44 derived by comparing the line item on page 1
(Schedule 1) of Exhibit No. 46 and page 3 (Schedule 5) of Exhibit No. 46 is not based
on cost-of-service analysis between the two separate rate designs, nor is it intended to
represent "average monthly revenue" for either Schedule 1 or Schedule 5. Please see
the Company's Response to the Idaho Irrigation Pumpers Association Inc.'s ("IIPA")
Data Request No. 28 for further explanation of the characteristics of the tables
presented in Exhibit No. 46.
c. There was not an assumed load profile which served as the basis for the
proposed Schedule 5 rates. All of the assumptions used to develop the rate design for
Schedule 5 are provided in Ms. Nemnich's testimony on pp. 10-19.
The response to this Request was prepared by Darlene Nemnich, Senior Pricing
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 SECOND DATA REQUEST TO IDAHO POWER COMPANY - 7
REQUEST NO. 30: With respect to any type of load data gathered by the
Company for Schedules 4 and 5, that is a part of or similar 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 data before it is applied to develop the allocation factors or other analysis used
by the Company;
g. Please provide copies of the formulas (and data) used to expand
the Load data (strata weighting factors etc.) up to the population as a whole.
RESPONSE TO REQUEST NO. 30: Idaho Power has not gathered nor
processed any Load Research interval data for Schedule 4 or 5 customers nor is there
a Rate 4 or 5 Load Research sample. However, the Company does have hourly
interval data by customer for the summer seasons (June-August) for the years 2006-
2008 that was collected as part of the process to prepare the annual Energy Watch,
Time-of-Day Report required in compliance with Idaho Public Utilties Commission Case
No. IPC-E-07-05, Order No. 30292. This data is provided in the six Excel files (2006,
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 8
2007, and 2008 EW data and 2006, 2007, and 2008 TOD data) included on the
enclosed CD.
a. The customer identification is located in the first column of the provided
Excel files.
b. The name of each Excel file is an indication of the rate schedule
associated with the data. The Excel 2006, 2007, and 2008 EW data files (3 files)
contain data for Schedule 4 customers. The Excel 2006, 2007, and 2008 TOD data
files (3 files) contain data for Schedule 5 customers.
c. The data is not part of a stratum.
d. The raw hourly usage data is provided in columns c through z and
identified by their respective hour.
e. The raw hourly data was not modified to reflect losses.
f. There were no additional calibrations applied to the data.
g. The data was not used to expand up to the population as a whole.
This response to this request was prepared by Darlene Nemnich, Senior
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 SECOND DATA REQUEST TO IDAHO POWER COMPANY - 9
REQUEST NO. 31: On Nemnich's work paper 3 there is listed on lines 3-5
various usage amounts for the various time periods covered by the current rates. On
the second set of lines marked 3 and 5 are usage amounts for the new/proposed time
periods:
a. Is the data in the first set of lines 3-5 taken from actual biling data?
b. If the answer to "a" above is negative, please describe how these
usage figures were developed.
c. If the answer to "a" above is negative, please supply for the period
2005 through the most recent month available actual monthly data for Schedule 5
customers in a manner similar to Exhibit 29 page 1.
d. Does the usage data in the second set of lines 3 and 5 reflect the
exact same usage as in the first set of lines 3-5 during a somewhat different set of
hours, or is there an assumption built into the second set of values that there is a shift in
some usage? If a shift is usage in incorporated, please describe this shift and explain
how the magnitude of the shift was calculated.
RESPONSE TO REQUEST NO. 31:
a. No. The usage data in lines 3-5 under column (1) is normalized energy
usage data based upon allocation ratios from 2010 actual data.
b. The process employed to develop these usage figures is described in the
Direct Testimony of Mr. Matthew T. Larkin from page 4, line 4, through page 6, line 9.
C. Actual historical usage is provided on the enclosed CD for June 2005
through 2010. Data for June 2005 through 2007 is only available in hard copy format
\
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 10
and therefore has been provided as PDF documents on the enclosed CD. Data for
2008 through 2010 is provided in the Excel spreadsheet provided on the enclosed CD.
d. Idaho Power did not assume any shift in usage as a direct result of the
change in rate structure. The total number of kWhs in the second set of lines 3 and 5,
totaling 251,942, is equal to the total number of kWhs in the first set of lines 3-5.
However, whereas the first set of lines show usage broken out by three time period
blocks (On-Peak, Mid-Peak, and Off-Peak), the second set of lines allocate the total
kWhs over only two time period blocks (On-Peak and Off-Peak). Ms. Nemnich's direct
testimony, pp. 12-15, discusses Idaho Powets proposal for moving from a three time
period time-of-day structure to a two time period time-of-day structure. Instead of simply
adding the Mid-Peak and Off-Peak hours together to arrive at a new Off-Peak value,
Idaho Power reallocated the total hours into the two time blocks. The new allocation
percentages are shown in column 2 in the second set of lines 3 and 5 (On-Peak usage
is 36 percent of total and Off-Peak usage is 64 percent of total). The source of the new
allocation percentages is explained in the Company's Response to IIPA's Data Request
No. 27.
The response to this Request was prepared by Darlene Nemnich, Senior
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 SECOND DATA REQUEST TO IDAHO POWER COMPANY -11
REQUEST NO. 32: On Nemnich's work paper 2 there is listed on lines 5-7
various usage amounts for the various rate blocks covered by the current rates. On the
second set of lines marked 3 and 5 are usage amounts for the new/proposed time
periods:
a. Is the data in the first set of lines 5-7 taken from actual biling data?
b. If the answer to "a" above is negative, please describe how these
usage figures were developed.
c. If the answer to "a" above is negative, please supply for the period
2005 through the most recent month available actual monthly data for Schedule 4
customers in a manner similar to Exhibit 29 page 1 .
d. Does the usage data in the second set of lines 3 and 5 reflect the
exact same usage as in the first set of lines 5-7 during a somewhat different set of
hours, or is there an assumption built into the second set of values that there is a shift in
some usage? If a shift is usage in incorporated, please describe this shift and explain
how the magnitude of the shift was calculated.
RESPONSE TO REQUEST NO. 32:
a. No. The usage data in lines 5-7 under column (1) is normalized energy
usage data based upon allocation ratios from 2010 actual data. Please note data in
lines 5-7 of page 2 of Ms. Nemnich's workpapers is for the current Non-Summer time
period, while lines 3 and 4 are for the current Summer time period.
b. See the Company's Response to IIPA's Data Request No. 31.b.
c. See the Company's Response to IIPA's Data Request No. 31.c.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 12
d. Idaho Power did not assume any shift in usage as a direct result of the
change in rate structure. The total number of kWhs in the second set of lines 3 and 5,
totaling 148,289, is equal to the total number of kWhs in the first line 4. The Energy
Watch Hours, 606 kWhs, remain the same in the current structure (first line 3), as in the
proposed structure (second line 3). However, whereas the current summer usage of
148,289 kWhs (in line 4) is all one rate, the proposed summer usage (in the second set
of lines 3 and 5) allocates the 148,289 kWhs over two time periods (On-Peak and Off-
Peak Summer hours). Ms. Nemnich's direct testimony, pp. 12-15, discusses Idaho
Power's proposal for moving from the existing structure to a two time period time-of-day
structure with a critical peak time period overlaid on top of the summer On-Peak. The
new allocation percentages are shown in column 2 in the second set of lines 3 and 5
(On-Peak usage is 36 percent of total and Off-Peak usage is 64 percent of total). The
source of the new allocation percentages is explained in the Company's Response to
IIPA's Data Request No. 27.
The response to this Request was prepared by Darlene Nemnich, Senior
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 SECOND DATA REQUEST TO IDAHO POWER COMPANY - 13
REQUEST NO. 33: For each of the Demand Response programs operated by
the Company (Irrigation Peak Rewards, Residential Cool Credit, and FlexPeak
Management), for 2008, 2009, and 2010, please list the dates and hours when demand
was interrupted. Also, provide an estimate of the level of demand that was interrupted
during each hour.
RESPONSE TO REQUEST NO. 33: The dates, hours, and estimated level of
demand response for each of the Demand Response programs operated by the
Company (dispatchable and timer options for Irrigation Peak Rewards, AlC Cool Credit,
and FlexPeak Management) for 2008, 2009, and 2010 are included in the Excel file
DemandResponseEstimate_2008-2010.xlsx provided on the enclosed CD.
This response to this Request was prepared by Pete Pengily, Customer
Research & Analysis Leader, Idaho Power Company, in consultation with Mary
Graesch, Load Research Leader, Idaho Power Company, and with Lisa D. Nordstrom,
Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 15th day of July 2011.
~f)~Mu
LISA D. NO~ TROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 14
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of July 2011 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND 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 Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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FAX
-2 Email Don.HoweIlCâpuc.idaho.gov
Karl T. Klein
Deputy Attorney General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
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Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
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gregCârichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hil Road
Boise, Idaho 83703
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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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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 15
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(ëhq .doe.gov
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 16
Dwight D. Etheridge
Exeter Associates, Inc.
5565 Sterrett Place, Suite 310
Columbia, Maryland 21044
Community Action Partnership Association
of Idaho
Brad M. Purdy
Attomey at Law
2019 North 1ih Street
Boise, Idaho 83702
Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
Snake River Allance
Ken Miller
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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~ 1) '!ø"oo
Lisa D. Nordstro
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY - 17