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Home My WebLink About20110819IPC to IIPA 41-44.pdfLISA D. NORDSTROM Lead Counsel Inordstrom(âidahopower.com 1SIDA~POR~ An IDACORP Company August 18, 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 one (1) copy of Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s Fourth 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, cK~lJ.11~ Lisa D. Nordstrom LDN/kkt Enclosures 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 ZOl! AUG 18 PM 4: 51 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 FOURTH 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 Fourth Data Request to Idaho Power Company dated July 28, 2011, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 1 REQUEST NO. 41: On page 21 of IPCo's Appendix A of its 2011 IRP it is stated that: "Throughout the forecasted period, the expected-case irrigation load is forecast to slowly rise from 197 aMW in 2011 to 207 aMW in 2030, an average annual compound growth rate of 0.3 percent." Contrary to this "slow rise", on page 44 of IPCo's Appendix A of its 2011 IRP it is stated that the projected Irrigation sales wil decrease 2.4% from the previous year. Contrary to the projection for 2011, all of the other years are projected to have a much lower percentage change. Please explain what parameters within the forecasting process are causing the (sic) large of a change in projected irrigation load between 2010 and 2011. RESPONSE TO REQUEST NO. 41: Historical weather normalized loads and forecasted loads are derived using two different methodologies. The data presented on the row labeled "2010" on page 43 of Appendix A to the 2011 Integrated Resource Plan ("IRP") reflects weather normalized historical data, while the data presented on the row labeled "2011" on page 44 represents the first year of projected load derived using the Company's regression methodology. The 2.4 percent decrease between 2010 and 2011 is larger than the annual percentage fluctuations between 2011 and beyond because it is a comparison between historical data and forecast data rather than a comparison between two forecast years. 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 FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 2 REQUEST NO. 42: There seems to be an error in the Company's cost of service model with respect to the allocation of some costs to the Irrigation class. Please correct any problem that the Company is aware of and provide a corrected copy of the cost of service study in executable Excel format. RESPONSE TO REQUEST NO. 42: Please see the Company's response to Staff's Production Request No. 31. 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 FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 3 REQUEST NO. 43: Please update the response to IIPA request 8 for the months of June and July 2011. RESPONSE TO REQUEST NO. 43: Please see the attached Excel fie. 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. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 4 REQUEST NO. 44: Please provide in electronic format a listing of the date, time, and estimated magnitude of all actual hourly curtailments/interruptions that occurred in each jurisdiction during 2009, 2010, and 2011 through the most recent month available separated by rate schedule or special contract customer group.If outright curtailments/interruptions are treated differently than "buy-throughs", please state each separately. RESPONSE TO REQUEST NO. 44: The requested customer load reduction information is confidential and wil be provided on the confidential CD to those parties that have executed the Protective Agreement in this matter. The confidential CD contains Excel spreadsheet Response IIPA's Request No. 44_DR by hour.x/sx. This spreadsheet contains six tabs: "2009 ALL_GenLevel," "2009 ID GenLevel," "2009 OR GenLevel," "2010 ALL GenLevel," "2010 ID GenLevel," and- - - - "20100R_GenLevel." The tabs labeled "AILGenLevel" show system load reduction for all of Idaho Power's demand response programs offered in the applicable year, by hour and by rate schedule at generation leveL. All Irrigation Peak Rewards participants are served under rate Schedule 24 and all AlC Cool Credit participants are served under rate Schedules 1 and 84. When applicable, for FlexPeak Management participants, the load reduction is grouped by rate schedule. The tabs labeled "ID_GenLevel" and "OR_GenLevel" show the jurisdictional demand reduction from Idaho Power demand response programs at generation leveL. Idaho Power does not have any "buy-through" arrangements with any customers. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 5 The 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 18th day of August 2011. ~£2tl~IS~NORDSROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 18th day of August 2011 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH 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 Karl T. Klein Deputy Attorneys General Idaho Public Utilities Commission 472 West Washington (83702) P.O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email Don.Howell(âpuc.idaho.gov Karl. Klein(âpuc. idaho .gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 2th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email peter(ârichardsonandoleary.com greg((richardsonandoleary.com Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hil Road Boise, Idaho 83703 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email dr((benjohnsonassociates.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 ~ Email elo((racinelaw.net Anthony Yankel 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email tony((yankel.net IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 7 The 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 ~ Email kboehm((BKLlawfirm.com jrh((battfisher.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 ~ Email khiggins((energystrat.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 ~ Email myork((hollandhart.com tnelson(( holland hart. com madavidson((hollandhart.com fschmidt((hollandhart.com In buchanan((holland hart. 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 ~ Email remalmgren((micron.com The United States Department of Energy Arthur Perr Bruder, Attorney-Advisor United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email Arthur.bruder((hq.doe.gov Steven.porter((hq .doe.gov Dwight D. Etheridge Exeter Associates, Inc. 10480 Little Patuxent Parkway, Suite 300 Columbia, Maryland 21044 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email detheridge((exeterassociates.com IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 8 Community Action Partnership Association of Idaho Brad M. Purdy Attorney at Law 2019 North 1 7th Street Boise, Idaho 83702 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email bmpurdy((hotmail.com Idaho Conservation League Benjamin J. Otto Idaho Conservation League 710 North Sixth Street (83702) P.O. Box 844 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email botto((idahoconservation.org Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered U.S. Mail _ Overnight Mail FAX ~ Email kmiller((snakeriverallance.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 ~ Email nancy((nwenergy.org gi!~hlm Lisa D. Nordstro IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY - 9