20120330IIPA to IPC 1-9.pdf

RECEIVED Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE & 201 2 MAR' ' BAILEY, CHARTERED •JU Rfl 8
P.O. Box 1391; 201 E. Center fDAI*iO PUBLIC
Pocatello, Idaho 83204-1391 UTI[ 1FS COMMISSION
Telephone: [phone]
Fax: [phone]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR
) CASE NO. IPC-E-12-13
AUTHORITY TO SHARE REVENUES )
WITH CUSTOMERS IN CONFORMAI ICE ) IDAHO IRRIGATION PUMPERS
WITH ORDER NOS. 30978 AND 32424
) ASSOCIATION, INC.'S FIRST
STATE OF IDAHO ) DATA REQUEST TO IDAHO POWER
) COMPANY
1. Please supply an electronic copy (where applicable in Excel format with all equations
intact) that support Exhibits 1 and 2.
2. Please supply an electronic copy in Excel format with all equations intact of Exhibits
land 2.
3. According to Mr. Larkin's testimony at page 6, the Company prepared a similar
jurisdictional ROE for 2009 and 2010. Please provide for 2009, 2010, and 2011:
a.The full jurisdictional separation studies used. Please include all workpapers.
b.The jurisdictional allocation factors used, the base data used for the
jurisdictional allocation factors, and the source data for this data.
4. It appears from Mr. Larkin's testimony at page 6 that for 2009 and 2010 that the
Company used year-end data to calculate ROE. However, for 2011, some data was
taken from "third quarter financial information as of Sept 30, 2011." Does the
Company plan to update this filing with all year-end values? If not, why not?
5. According to page 6 of Mr. Larkin's testimony, the Company used "jurisdictional
allocation factors from the 2010 Federal Energy Regulatory Commission Form 1
filing." With respect to this statement:
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY
a.Which, if any, of the allocation factors associated with Exhibits 1 and/or
Exhibit 2 came from this source?
b.What specific data in the 2010 FERC Form 1 was used in order to develop
these allocation factors?
c.How did the Company develop demand related allocation factors and where
did this data come from?
6.It would appear from the designation on Exhibit I that "Update figures in RED" that
all of the total Company revenue numbers and total Company expense numbers have
been updated to December 31, 2011, but the rate base and the allocation values are all
based upon September 30, 2011 data and the allocation factors are based upon 2010
FERC Form 1 data. Is this correct?
7.Please explain why the Idaho share of Total Combined Rate Base" on Exhibit 1 is
92.6% while it was over 95% in Case No. IPC-E-ll-08. (See page 1 of Company
Exhibit 26 in Case No. IPC-E-1 1-08)
8.Please supply a detailed description as well as all supporting documents used to
develop the allocation factor for "Other Operating Revenues" found on line 14 of
Exhibit 1.
9.Please provide a copy of the Company's FERC Form 1 when it becomes available.
DATED this Of day of March, 2012.
RACINE OLSON NYE BUDGE
& BAILEY, CHARTERED
BY:
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1-7 day of March, 2012, I served a true,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W/ Washington Street
Boise, Idaho 83720-0074
[e-mail]
Lisa D. Nordstrom
Donovan E. Walker
Jason B. Williams
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0072
[e-mail]
[e-mail]
jwilliams(idahopower.com
Greg W. Said
Director State Regulation
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0071
gsaid(,idahpower.com
Brad M. Purdy
Attorney at Law
2019 N. 17' Street
Boise, Idaho 83702
[e-mail]
Mail/Postage Prepaid
( E-Mail
Facsimile
__X '_Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-Mail
Facsimile
Overnight Mail
Hand Delivered
Arthur Perry Bruder
Attorney-Advisor
United States Department of Energy
1000 Independence Ave. SW
Washington, DC 20585
[e-mail]
U.S. Mail/Postage Prepaid
X E-Mail
Facsimile
Overnight Mail
Hand Delivered
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 3
Dr. Don Reading U.S. Mail/Postage Prepaid
6070 Hill Road E-Mail
Boise, Idaho 83703 Facsimile
dreading(mindspring.com Overnight Mail
Hand Delivered
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary, PLLC
515 N 27th Street
P.O. Box 7218
Boise, Idaho 83702
[e-mail]
greg(richardsonandoleary.com
Richard E. Malmgren
Sr. Asst. General Counsel
Micron Techology, Inc.
800 South Federal Way
Boise, Idaho 83716
rema1mgren(micron.com
Mary V. York
Thorvald A. Nelson
Mark A. Davidson
Holland & Hart, LLP
6800 S. Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
& ;C4 L.c h 1
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO IDAHO POWER COMPANY 4