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Home My WebLink About20110811IPC to IIPA 34-40.pdfJASON B. WILLIAMS Corporate Counsel iwilliamscæidahopower.com '?IDAa3POR~ An IDACORP Company August 10, 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 filing are an original and one (1) copy of Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s Third Data Request to Idaho Power Company in the above matter. .. Also enclosed are three (3) copies of a non-confidential disk and three (3) copies of a confidential disk containing information being produced in response to the above data request. Please handle the enclosed confidential information in accordance with the Protective Agreement executed in this matter. Very truly yours, .."vI¿0~Jason B. Willams JBW:csb Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, 10 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: (208) 388-5825 Facsimile: (208) 388-6936 Inordstrom(âidahopower.com dwalker(âidahopower.com jwilliams(âidahopower.com Attorneys for Idaho Power Company .. RECEIVED 201f AUG 10 PM 4= r 6 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 THIRD 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 Third Data Request to Idaho Power Company dated July 20, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY - 1 REQUEST NO. 34: The Company's response to IIPA request 3 contains data on a normalized basis. Please provide this similar data on an actual basis. RESPONSE TO REQUEST NO. 34: Please see the Company's response to the Department of Energy's Request No. 3-20. 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 THIRD DATA REQUEST TO IDAHO POWER COMPANY - 2 REQUEST NO. 35: The Company's response to IIPA request 4 contains data on a normalized basis. Please provide this similar data on an actual basis. RESPONSE TO REQUEST NO. 35: Please see the Excel file provided on the confidential CD for actual monthly energy sales by rate class on a calendar month basis for the years 2006 through 2010. Column A of each tab identifies the rate class and calendar month of the corresponding data in column B. For example, the first row of data on the "2006" tab shows a value of "101-0601" in column A. This equates to Idaho Rate 1 ("101"), for the calendar year 2006 ("06"), and the January calendar month ("01"). Each tab contains one of the five years of requested information, identifying each line of data using the above naming convention. Because this Excel file contains confidential customer information, it wil only be provided to parties that have executed the Protective Agreement. 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 THIRD DATA REQUEST TO IDAHO POWER COMPANY - 3 REQUEST NO. 36: Please explain the process the Company utilzes to weather normalize its sales data. Please explain how the process differs between rate schedules. Please explain how actual data is incorporated into the results. RESPONSE TO REQUEST NO. 36: Please see the attached PDF file. The response to this Request was prepared at the direction of 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 THIRD DATA REQUEST TO IDAHO POWER COMPANY - 4 REQUEST NO. 37: Please explain any changes in the Company's sales weather normalization process since the last rate case. RESPONSE TO REQUEST NO. 37: The weather normalization process has not changed since the Company's last general rate case, Case No. IPC-E-08-10 ("2008 Rate Case"). The only change to the weather normalization model since the 2008 Rate Case was the re-estimation of the weather adjustment regressions to update the coefficients of the weather variables used to weather adjust historical electricity sales. In addition, each year the weather "normals" are re-calculated over the most recent 30 years of verified historical data (verified by comparison to National Oceanic and Atmospheric Administration ("NOAA") publications). The response to this Request was prepared at the direction of 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 THIRD DATA REQUEST TO IDAHO POWER COMPANY - 5 REQUEST NO. 38: In the Company's response to IIPA request 15 there were five tabs to the spreadsheet provided. Please answer the following with respect to tab "2010": a. Line 1 lists the various months that are title for each column. Should these titles be 2009 instead of 201 O? b. The demand value for "Rate 24" for June is 23,274. What are the units of this value and how does it relate to the biling demands of the customers? c. The energy value for "Rate 24" for June is 7,626,519. What are the units of this value and how does it relate to the billng energy of the customers? RESPONSE TO REQUEST NO. 38: a. No. Data contained within the "2010" tab reflects 2010 data which was incorrectly labeled 2009 within the worksheet. b. The June demand value of 23,274 for Oregon Rate 24 customers represents the sum of each customets billng demand for the June billng month, measured in kilowatts. c. The June energy value of 7,626,519 for Oregon Rate 24 customers represents the sum of each customets biled energy for the June biling month, measured in kilowatt-hours. 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 THIRD DATA REQUEST TO IDAHO POWER COMPANY - 6 REQUEST NO. 39: In the attachment to Company's response to IIPA request 22 there was a reference to Rate 26 and Rate 30. To which rate schedules do these belong and to what demand response program? RESPONSE TO REQUEST NO. 39: Rate 26 refers to Micron Technology, Inc., and Rate 30 refers to the Idaho National Laboratory, operated by the United States Department of Energy. These customers are biled according to customer-specific electric service agreements. Both customers are participants in the Company's FlexPeak demand response program. 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 THIRD DATA REQUEST TO IDAHO POWER COMPANY - 7 REQUEST NO. 40: With respect to Attachment 4 of the Company's response to IIPA request 8, please answer the following with respect to providing definitions or clarity to the spreadsheet: a. Column "P" contains information regarding Company owned generation. The designations are either "Coal", "Hydro", or "Othet'. With respect to the "Coal" and "Othet' plants, please provide further identification regarding the name of the facilty producing the energy. b. Column "BB" contains designations such as "E" and "E Exchange". Please define what these terms mean and what is meant when a blank appears in one of these cells. c. Column "BC" contains terms such as "System-TEP", "PNM System", "SPPC", and "SCL". Please provide a definition for each term that appears in Column "Be". d. Please provide a definition for each term that appears in Column "BD". RESPONSE TO REQUEST NO. 40: a. Please see the attached Excel files. b. "E" is defined as energy and "E Exchange" is defined as energy exchange in the database. Blanks in this column are dependent on column "BD." If "BD" equals Daily Deal Profile, Bookout Deal Profile, or Losses Profile this column wil be blank. "BD" contains an internal database classification for each record. c. Column "BC" contains industry recognized points of delivery or points of receipt registered with North American Electric Reliabilty Corporation ("NERC"). The Company does not have a file with descriptions for the NERC Points. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY - 8 d. "BD" contains an internal database classification for each record. Schedule Deal Profile provides database information from the energy schedule. Losses Profile provides database information from the scheduled losses. Daily Deal Profile provides database information from the actual deaL. Bookout Deal Profile provides database information from energy schedules booked out. The response to this Request was prepared by Sandy Ward, Operations Accountant II, Idaho Power Company, in consultation with Matthew T. Larkin, Regulatory Analyst, Idaho Power Company, and Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 10th day of August 2011.\ ~ IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY - 9 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 10th day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INe.'s THIRD DATA REQUEST TO IDAHO POWER eOMPANY 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 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Don.Howell(âpuc.idaho.gov Karl T. Klein Deputy Attorney General Idaho Public Utiities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email KarI.Klein(âpuc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2ih Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email peter(ârichardsonandolearv.com greg(ârichardsonandolearv.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email dreading(âmindspring.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 U.S. Mail _ Overnight Mail FAX -2 Email elo(âracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY - 10 Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email tony(âyankel.net Kroger Co. Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email kboehm(âBKLlawfirm.com jrh(âbattisher.com Kevin Higgins Energy Strategies, LLC 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email khiggins(âenergystrat.com Micron Technology, Inc. MaryV. York HOLLAND & HART LLP 101 South Capital Boulevard, Suite 1400 Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email myork(âhollandhart.com tnelson(âholland hart. com madavidson(âhollandhart.com fschmidt(âhollandhart.com Richard E. Malmgren Senior Assistant General Counsel Micron Technology, Inc. 800 South Federal Way Boise, Idaho 83716 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email remalmgren(âmicron.com Department of Energy Arthur Perry Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Arthur.bruder(âhg.doe.gov Steven. porter(âhg .doe .gov IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY - 11 Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Place, Suite 310 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email detheridge(âexeterassociates.com Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email bmpurdy(âhotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email botto(âidahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email kmiller(âsnakeriverallance.org NW Energy Coalition Nancy Hirsh, Policy Director NW Energy Coalition 811 First Avenue, Suite 305 Seattle, Washington 98104 Hand Delivered U.S. Mail _Overnight Mail FAX -2 Email nancy(ânwenergy.org \ :: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S THIRD DATA REQUEST TO IDAHO POWER COMPANY - 12