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HomeMy WebLinkAbout20120503IPC to IIPA 6-12.pdfHO RECEIVEP _PAIER An IDACORP Company I -MAN 3 p 29 LISA D. NORDSTROM Li G Lead Counsel iN Inordstrom(idahopower.com ,)T1T .çOMMS U May 3, 2012 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street Boise, Idaho 83702 Re: Case No. IPC-E-12-14 Langley Gulch Recovery - Response Idaho Irrigation Pumpers Association, Inc.'s Second Data Request Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Second Data Request to Idaho Power Company in the above matter. Also enclosed are four (4) copies each of non-confidential and confidential disks containing information being produced in response to IIPA's Second Data Request. Please handle the enclosed confidential information in accordance with the Protective Agreement executed in this matter. Very truly yours, Lisa D. Nordstrom LDN :csb 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 Inordstrom(idahopower.com jhiItonidahopower. corn RECEIVED 2UI2 MAY -3 PM h: 29 IDAHO PUBLV t rII rC? LI I' Attorneys for Idaho Power Company BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND ITS RATE BASE TO RECOVER ITS INVESTMENT IN THE LANGLEY GULCH POWER PLANT CASE NO. IPC-E-12-14 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 Power" or "Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s Second Data Request to Idaho Power Company dated April 12, 2012, 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. 6: Mr. Tatum's testimony (beginning on page 10, line 16) describes the manner in which the net benefit of Langley Gulch to the Company's power supply costs was developed. The testimony goes on to state that the Company used the "net power supply expense, which was based on a 2010 test year." Regarding that base case, please provide the following: a.What was the monthly generation level load (Idaho Retail, Oregon Retail, and Wholesale) that was used for each month of that 2010 test period? b.What were the monthly sales level loads for each Idaho rate schedule and Special Contract customer? C. What were the monthly sales level loads for each Oregon rate schedule customer? d. What were the price(s) of natural gas that were used in this base case? RESPONSE TO REQUEST NO. 6: a. Please see the attached Excel file (Attachment 1). b-c. Please see the attached Excel file (Attachment 2). Figures in this attachment reflect customer-level sales corresponding to the generation-level sales provided in the Company's response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Request No. 6.a. However, it should be noted that the 2010 test year referenced in this Request was used for the sole purpose of updating base net power supply expenses in Case No. IPC-E-10-01; customer-level rates were not set as part of that proceeding. Consequently, the customer-level sales provided in Attachment 2 were never utilized for ratemaking purposes. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -2 d. Please see the Company's response to the Industrial Customers of Idaho Power's Request for Production No. 2. The Excel file labeled "AURORA Inputs" includes a "fuel input" worksheet that contains the natural gas prices that were used in this analysis. The response to this Request was prepared by Matthew 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 SECOND DATA REQUEST TO IDAHO POWER COMPANY -3 REQUEST NO. 7: Mr. Tatum's testimony (beginning on page 10, line 19) describes the manner in which the net benefit of Langley Gulch to the Company's power supply costs was calculated "with the original 2010 load and resource inputs" by calculating a "revised base level net power supply expense". Please answer the following: a.Is it correct that the loads used in the "revised" power supply expense calculation are the same as those listed in the response to "6 a-c" above? If not, please supply values similar to those requested in "6 a-c" above, except for the "revised" calculation. b.Is it correct that the natural gas prices used in the "revised" power supply expense calculation are the same as those listed in the response to "6 d" above? If not, please supply values similar to those requested in "6 d" above, except for the "revised" calculation. C. Why did the Company choose to perform these calculations on the basis of the original 2010 load and resource inputs as opposed to the 2011 test year loads used in Case No. IPC-E-11-08 or the June 1, 2012 through May 31, 2013 test year loads used in Case Nos. IPC-E-12-08 and IPC-E-12-13? RESPONSE TO REQUEST NO. 7: a. The loads used in the "revised" power supply expense calculation are the same as those included in the Company's response to the IIPA's Request No. 6.a. Monthly sales level energy is not used in the development of base level power supply expenses. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -4 b. Yes. The natural gas prices included in the "revised" power supply expense calculation are the same as those used in the Company's response to the IIPA's Request No. 6.d. C. The Company chose to perform the analysis based on the 2010 load and resource inputs because those inputs were used to set the Company's current base level power supply expenses in Case No. IPC-E-1 0-01. The Company did not believe it was appropriate to use the Langley Gulch power plant proceeding to update its base power supply expense components. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, 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. 8: Please rerun the "revised" power supply expense calculation as discussed on page 10, line 19 of Mr. Tatum's testimony with loads based upon Company Exhibit 2 in Case No. IPC-E-12-13 and with whatever natural gas prices the Company believes to be "current". Please supply in electronic format the Company's Power Supply cost for each of the 81 years examined in a manner similar to Company Exhibit I in Case No. IPC-E-10-01. RESPONSE TO REQUEST NO. 8: In response to this Request, the Company performed the requested analysis. The precision of the results of the requested analysis should not be viewed as an endorsement of the inputs or the results of the analysis by Idaho Power. No other changes were made to the inputs used in Case No. IPC-E-10-01, which established the Company's current base level power supply expenses. The attached Excel file contains a revised power supply expense run using the loads that correspond with the sales values from Exhibit No. 2 in Case No. IPC-E-1 2-1 3. Natural gas prices were also updated to reflect the same gas prices used in the Company's current Operating Plan. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, 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 -6 REQUEST NO. 9: Please provide actual monthly sales and customer count data for each customer grouping in Oregon and Idaho from January 2005 through the most recent month available. Please supply monthly wholesale sales data as well. RESPONSE TO REQUEST NO. 9: Please see the attached Excel file. Customer counts in the Idaho jurisdiction for the "Industrial" category do not include the Company's special contract customers taking service under Schedules 26, 29, 30, and 32. Additionally, irrigation customer counts include customers who deactivate their accounts during off-season months when electricity usage is not required. The response to this Request was prepared by Matthew 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 SECOND DATA REQUEST TO IDAHO POWER COMPANY -7 REQUEST NO. 10: Please supply in electronic format for each month since January 2008 the billing month normalized billing determents (and associated revenue) of each of the rate categories in the Idaho jurisdiction. RESPONSE TO REQUEST NO. 10: Historical monthly billing determinants for all Idaho customer classes excluding Schedules 26, 29, and 30 ("Special Contracts") for January 2008 through December 2011 are provided in the attached Excel file (Attachment 1). Historical monthly billing determinants for the Company's Special Contracts are provided in the confidential Excel file (Attachment 2) provided on the confidential CD. The confidential CD will only be provided to those parties that have executed the Protective Agreement in this proceeding. Please note that these detailed monthly billing determinants reflect weather normalized usage and are prepared for the specific purpose of deriving weather normalized historical retail revenues. Revenue associated with each category of billing determinant reflects annualized year-end historical rates applied to normalized billing determinants. Because normalized historical billing determinants are calculated at the end of each calendar year, first quarter data for 2012 is not yet available. The response to this Request was prepared by Matthew 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 SECOND DATA REQUEST TO IDAHO POWER COMPANY -8 REQUEST NO. 11: Please supply in electronic format for each month since January 2008 the billing month normalized billing determents (and associated revenue) of each of the rate categories in the Oregon jurisdiction. RESPONSE TO REQUEST NO. 11: Historical monthly billing determinants for all Oregon customer classes excluding Schedules 9 and 19 at the transmission voltage level ("Schedules 9T and 19T") for January 2008 through December 2011 are provided in the attached Excel file (Attachment 1). Historical monthly billing determinants for Schedules 9T and 191 reflect single-customer usage and are therefore confidential. Information for these two customers is provided in the confidential Excel file (Attachment 2) provided on the confidential CD. The confidential CD will only be provided to those parties that have executed the Protective Agreement in this proceeding. Please note that these detailed monthly billing determinants reflect weather normalized usage and are prepared for the specific purpose of deriving weather normalized historical retail revenues. Revenue associated with each category of billing determinant reflects annualized year-end historical rates applied to normalized billing determinants. Because normalized historical billing determinants are calculated at the end of each calendar year, first quarter data for 2012 is not yet available. The response to this Request was prepared by Matthew 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 SECOND DATA REQUEST TO IDAHO POWER COMPANY -9 REQUEST NO. 12: Please supply in electronic format for each month since January 2008 the billing month normalized billing determents (and associated revenue) for wholesale sales. RESPONSE TO REQUEST NO. 12: Historical monthly billing determinants for Raft River Rural Electric Coop, Inc. ("Raft River") are provided in electronic format for January 2008 through December 2010 are provided in the confidential Excel file provided on the confidential CD. The confidential CD will only be provided to those parties that have executed the Protective Agreement in this proceeding. Please note that these detailed monthly billing determinants reflect weather normalized usage and are prepared for the specific purpose of deriving weather normalized historical revenues. Revenue associated with each category of billing determinant reflects annualized year-end historical rates applied to normalized billing determinants. Because the Company's contract with Raft River expired in 2011, historical weather normalized billing determinants were not prepared beyond the 2010 calendar year. The response to this Request was prepared by Matthew Larkin, Regulatory Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 3rd day of May 2012. c LISA D. NORDSTRM 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 -10 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 3rd day of May 2012 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 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 Dr. Don Reading Ben Johnson Associates, Inc. 6070 Hill Road Boise, Idaho 83703 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 Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered U.S. Mail Overnight Mail FAX X Email don. howell(ãDuc.idaho.qov Karl. kIeincpuc.idaho.qov Hand Delivered U.S. Mail Overnight Mail FAX X Email petercrichardsonandolearv.com ireqrichardsonandoleary.com _Hand Delivered U.S. Mail _Overnight Mail FAX X Email dread ingmind spring. com Hand Delivered U.S. Mail Overnight Mail FAX X Email eIo(racineIaw.net Hand Delivered U.S. Mail Overnight Mail FAX X Email tonyyankel.net IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -11 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 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 X Email tneIson(hoI land hart. com fschmidthoIIandhartcom sakrundell(hoI land hart. corn lnbuchanan(Tholland hart.com Hand Delivered U.S. Mail Overnight Mail FAX X Email remaImgren2micron.com (0, L L aud, Christa Bearry, Legal Assistant (j IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO IDAHO POWER COMPANY -12