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HomeMy WebLinkAbout20110718IPC to IIPA 27-33.pdfLISA D. NORDSTROM Lead Counsel Inordstromtmidahopower.com REGE ?fIDA~POR~ 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 -2 Hand Delivered U.S. Mail _ Overnight Mail 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 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email KarI.KleinCâpuc.idaho.gov 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 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email peterCârichardsonandoleary.com gregCârichardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email dreadingCâmindspring.com 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 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email eloCâracinelaw.net 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 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email tonyCâyankel.net Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email kboehmCâBKLlawfirm.com jrhCâbattfisher.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email khigginsCâenergystrat.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email remalmgrenCâmicron.com Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email myork(ëhollandhart.com tnelson(ëhollandhart.com madavidson(ëhollandhart.com Hand Delivered U.S. Mail -- Overnight Mail FAX -- Email Arthur.bruder(ëhq.doe.gov 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 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email detheridge(ëexeterassociates.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email bmpurdy(ëhotmail.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email botto(ëidahoconservation.org Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email kmiler(ësnakeriverallance.org ~ 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