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Home My WebLink About20120419IPC 1-9 to IIPA.pdfIDHO iPOWER® An IDACORP Company RECEIVED L: 49 LISA D. NORDSTROM Lead Counsel lnordstrom(äidahoDower.com !T1TN'. M.: April 19, 2012 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83720 Re: Case No. IPC-E-12-13 In the Matter of the Application of Idaho Power Company for Authority to Share Revenues with Customers in Conformance with Order Nos. 30978 and 32424 Dear Ms. Jewell: Enclosed for filing are an original and three (3) copies of Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s First Data Request to Idaho Power Company in the above matter. Also enclosed are four (4) copies of a non-confidential disk and four (4) copies of a confidential disk containing information being produced in response to the Idaho Irrigation Pumpers Association, Inc.'s First Data Request. The confidential disk should be handled in accordance with the Protective Agreement executed in this matter. Very truly yours, Lisa D. Nordstrdm LDN:kkt Enclosures 1221 W. Idaho St. (83702) P.O. Box 70 Boise, ID 83707 LISA D. NORDSTROM (ISB No. 5733) JULIA A. HILTON (ISB No. 7740) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstromidahopower.com ihiItonidahoDower.com RECEfVED 2912 APR 19 PM L:!9 IDAHO PUU•C UTILITIES COMMSSJoH Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER COMPANY'S APPLICATION FOR AUTHORITY TO SHARE REVENUES WITH CUSTOMERS IN CONFORMANCE WITH ORDER NOS. 30978 AND 32424 CASE NO. IPC-E-12-13 IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s First Data Request to Idaho Power Company dated March 29, 2012, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -1 REQUEST NO. 1: Please supply an electronic copy (where applicable in Excel format with all equations intact) that support Exhibits I and 2. RESPONSE TO REQUEST NO. 1: Although it is unclear, the Company is assuming that the Idaho Irrigation Pumpers Association, Inc. ("IIPA") is requesting electronic workpapers supporting Exhibit Nos. I and 2. Given this assumption, please see the Excel file provided on the non-confidential CD containing the September 30, 2011, jurisdictional separation study ("JSS"). 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -2 REQUEST NO. 2: Please supply an electronic copy in Excel format with all equations intact of Exhibits I and 2. RESPONSE TO REQUEST NO. 2: Please see the Excel files provided on the non-confidential CD. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -3 REQUEST NO. 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. RESPONSE TO REQUEST NO. 3: a. For a copy of the full September 30, 2011, JSS, please see the Excel file provided in the Company's response to IIPA's Request No. I above. Corresponding workpapers are provided on the non-confidential CD as Attachment I to this response. The results of the Idaho jurisdictional return on equity ("ROE") determinations for 2009 and 2010 were submitted before the Idaho Public Utilities Commission ("Commission") and made available for review by Commission Staff and intervening parties in Case Nos. IPC-E-10-12 and IPC-E-11-06, respectively. In both cases the year-end ROE determinations were approved without modification. The Company does not believe these studies are relevant to the current proceeding, and all workpapers supporting these studies are not readily available. However, for 2009 and 2010, the Company is providing the full JSS runs for each year, the final year-end ROE determinations, and the workpapers containing summary year-end data utilized in the final ROE determinations. These files are provided on the non-confidential CD as Attachments 6 through 11 to this response. If there is any specific additional IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -4 information the IIPA would like to request relating to the 2009 and 2010 studies, the Company will accommodate to the best of its ability. b. The jurisdictional allocation factors utilized in the September 30, 2011, JSS can be found in Table 14 of the attachment provided in the Company's response to IIPA's Request No. 1 above. Supporting documentation and the underlying data used to determine the allocation factors listed in Table 14 are provided in Attachments 2 through 5. Because Attachments 2 through 4 contain confidential information, they will be provided on a confidential CD to those parties that have executed the Protective Agreement in this proceeding. For reasons listed in the Company's response to 3.a. above, the requested information has only been provided as it pertains to the year-end 2011 ROE determination. It should also be noted that Attachments I and 5 have been modified to remove customer-specific information to eliminate the need to designate these files as confidential. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -5 REQUEST NO. 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? RESPONSE TO REQUEST NO. 4: The methodology utilized in the year-end 2011 ROE determination was the same as that used for the 2009 and 2010 determinations. In all three years, year-end data was used to determine the Idaho jurisdictional ROE for revenue sharing purposes. The third quarter JSS was solely used to develop allocation factors to apportion final year-end system financial results to the Idaho jurisdiction. Consistent with prior years, the Company does not intend to update this filing with year-end 2011 Federal Energy Regulatory Commission ("FERC") Form 1 allocation factors. Third quarter data is utilized for the limited purpose of developing allocation factors that reflect the most current information available at the time of filing while minimizing the lag between year-end and the filing of the sharing calculation. FERC Form I allocation factors are not finalized until approximately April 1 of the following year. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -6 REQUEST NO. 5: According to page 6 of Mr. Larkin's testimony, the Company used "jurisdictional allocation factors from the 2010 Federal Energy Regulatory Commission Form I filing." With respect to this statement: a.Which, if any, of the allocation factors associated with Exhibits I and/or Exhibit 2 came from this source? b.What specific data in the 2010 FERC Form I 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? RESPONSE TO REQUEST NO. 5: a.None of the allocation factors in Exhibit Nos. I or 2 were taken directly from the 2010 FERC Form 1. Allocation factors from the 2010 FERC Form I served as inputs to the September 30, 2011, JSS, provided as an attachment to the Company's response to If PA's Request No. I above. The results of the September 30, 2011, JSS were then utilized to develop the percentage values listed in the "IDAHO %" columns of Exhibit No. 1. b.Please refer to the Excel file provided as an attachment to the Company's response to IIPA's Request No. 1 above. With the exception of lines 1044 and 1049, Table 14 of this file contains the data utilized from the 2010 FERC Form I filing. Lines 1044 and 1049 reflect retail sales revenue and energy efficiency rider funds, respectively, which were both directly assigned to each retail jurisdiction based on year- to-date financial information as of September 30, 2011. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -7 c. Demand-related allocation factors from the 2010 FERC Form I were determined by averaging the contribution of each rate class on a jurisdictional basis to the 12 monthly system peaks for the 2010 calendar year. Class contributions to system peak demands were calculated based on actual load research data from 2010 utilizing the same methodology from previous FERC Form I filings. The application of this methodology is detailed in confidential Attachment 4 provided in the Company's response to IIPA's Request No. 3 above. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -8 REQUEST NO. 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 I data. Is this correct? RESPONSE TO REQUEST NO. 6: Yes. All revenues and expenses in the final ROE determination reflect year-end 2011 figures. The results of the September 30, 2011, JSS were used for the sole purpose of developing the Idaho-specific percentages used to apportion year-end system financial results to the Idaho jurisdiction. The exception to this allocation process is retail revenues, which were directly assigned to the Idaho jurisdiction according to actual year-end booked amounts. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -9 REQUEST NO. 7: Please explain why the Idaho share of Total Combined Rate Base" on Exhibit I is 92.6% while it was over 95% in Case No. IPC-E-1 1-08. (See page I of Company Exhibit 26 in Case No. IPC-E-1 1-08). RESPONSE TO REQUEST NO. 7: In preparing the 2011 test year utilized in Case No. IPC-E-1 1-08, the Company introduced a modification to the JSS model to better synchronize its retail ratemaking process with the formula rate authorized by FERC for transmission service provided under its Open Access Transmission Tariff. Under this new methodology, all investments, expenses, and revenues associated with Firm Transfer and Resale customers were assigned to the Company's two retail jurisdictions. Prior to this change in methodology, Firm Transfer and Resale customers were treated as separate jurisdictions in the JSS model, receiving allocations of associated investment, expenses, and revenues. The JSS methodology in this proceeding reflects the Commission-approved methodology from previous ROE determinations for revenue sharing purposes as well as the 2010 FERC Form I filing. The 92.6 percent share of rate base in Exhibit No. I reflects the existence of these additional Firm Transfer and Resale jurisdictions, while the approximately 95 percent Idaho share of rate base in Case No. IPC-E-1 1-08 reflects the consolidation of the JSS into two retail jurisdictions. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY -10 REQUEST NO. 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. RESPONSE TO REQUEST NO. 8: The Idaho-specific percentage of "Other Operating Revenues" of 89.0 percent, found on line 14 of Exhibit No. 1, was calculated based on the results of the September 30, 2011, JSS model, provided as an attachment to the Company's response to llPA's Request No. I above. Table 4 of the September 30, 2011, JSS contains the allocation of operating revenues. As shown in this table, the various categories of operating revenues were assigned to jurisdictions according to the allocation factors listed in the column labeled "ALLOC/SOURCE." With the exception of line 346 "RETAIL," all other line items in Table 4 comprise "Other Operating Revenues." By summing the results of the allocations in the provided JSS, the Idaho-allocated portion of "Other Operating Revenues" represents $126,636,926 of the system total of $142,257,884, or 89.0 percent. Data used to determine the allocation percentages of the various factors utilized in Table 4 can be found in Table 14 of the same model. Supporting documentation for Table 14 was provided in the attachments to the Company's response to IIPA's Request No. 3 above. 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 FIRST DATA REQUEST TO IDAHO POWER COMPANY - 11 REQUEST NO. 9: Please provide a copy of the Company's FERC Form I when it becomes available. RESPONSE TO REQUEST NO. 9: Please see the PDF file provided on the non-confidential CD. The response to this Request was prepared by Darrell Berg, Finance Team Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 19th day of April 2012. USA L I. DNORDSTROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 19 th day of April 2012 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST 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 Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street (83702) P.O. Box 7218 Boise, Idaho 83707 Hand Delivered U.S. Mail Overnight Mail FAX X Email don. howelkpuc.idaho.gov karl.kleinpuc.idaho.gov Hand Delivered U.S. Mail Overnight Mail FAX X Email Deter(richardsonandolearv.com greci(richardsonandoleary.com Dr. Don Reading Ben Johnson Associates, 6070 Hill Road Boise, Idaho 83703 Hand Delivered Inc. U.S. Mail Overnight Mail FAX X Email dread ingmindspring.com Micron Technology, Inc. Thorvald A. Nelson Frederick J. Schmidt Sara K. Rundell HOLLAND & HART, LLP 6380 South Fiddlers Green Circle, Suite 500 Greenwood Village, Colorado 80111 Hand Delivered U.S. Mail Overnight Mail FAX X Email tnelson(äthol land hart. com fschmidthollandhart.com sa kru ndel lholland hart.com lnbuchanan(@hollandhart.com Richard E. Malmgren Hand Delivered Senior Assistant General Counsel U.S. Mail Micron Technology, Inc. Overnight Mail 800 South Federal Way FAX Boise, Idaho 83716 X Email remalmqrenmicron.com IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -13 Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED 201 East Center P.O. Box 1391 Hand Delivered U.S. Mail Overnight Mail FAX X Email elo(racinelaw.net Pocatello, Idaho 83204-1391 Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 _Hand Delivered U.S. Mail _Overnight Mail FAX X Email tonycyankel.net KIN-P.M. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO IDAHO POWER COMPANY -14