20130304IIPA 1-16 to IPC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE 4k,B4IY.
W. MARCUS W. NYE LJA NLIL\
RANDALL C. BUDGE
JOHN A. BAILEY, JR. BOISE OFFICE
JOHN R. GOODELL 201 EAST CENTER STREfl.1..J J M fl 0 101 SOUTH CAPITOL
JOHN B. INGELSTROM POST OFFICE BOX 1391tUL,. ii?41\ + -+U BOULEVARD, SUITE 300
DANIEL C. GREEN POCATELLO, IDAHO 83204-1391 BOISE, IDAHO 83702
BRENT 0. ROCHE - - -------- TELEPHONE: [phone]
FACSIMILE [phone] KIRK B HADLEY
FRED J LEWIS
- -
TELEPHONE [phone],4
'TrILJT ERIC L. OLSEN FACSIMILE (208) 232-6I - IDAHO FALLS OFFICE
CONRAD J. AIKEN 477 SHOUP AVENUE
RICHARD A. HEARN, M.D. SUITE 107
LANE V. ERICKSON www.racinelaw.net POST OFFICE BOX 50698
FREDERICK J. HAHN, III IDAHO FALLS, ID 83405
PATRICK N. GEORGE TELEPHONE: [phone]
SCOTT J. SMITH FACSIMILE: [phone]
JOSHUA D. JOHNSON
DAVID E. ALEXANDER ALL OFFICES TOLL FREE
STEPHEN J. MUHONEN [phone]
CANDICE H. MCHUGH SENDER'S E-MAIL ADDRESS: [e-mail]
CAROL TIPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN LOUIS F. RACINE (1917-2005)
THOMAS J. BUDGE WILLIAM D.OLSON, OF COUNSEL
BRENT L. WHITING
DAVE BAGLEY
JASON E. FLAIG February FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
JEFFREY A. WARR
Jean J. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0084
Re: Case No. IPC-E-12-29
Dear Mrs. Jewell:
Enclosed for filing in the captioned case please find the original and seven copies of
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRSTDATA REQUEST TO
IDAHO POWER COMPANY
Thank you for your assistance.
ELO:tjl
Enclosures
c: Service List (Via Email)
Eric L. Olsen (ISB#: 4811) *
RACINE OLSON NYE, , ' ?IhIHKDM 0 BUDGE & BAILEY, CHARTERED
P.O. Box 1391 IDAHOp n Pocatello, Idaho 83204-1391 i L IT! ECC
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S REQUEST TO
TEMPORARILY SUSPEND THE A/C
COOL CREDIT AND IRRIGATION
PEAK REWARDS DEMAND RESPONSE
PROGRAMS
CASE NO. IPC-E-12-29
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST DATA
REQUEST TO IDAHO POWER
COMPANY
1.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.
2.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.
3.Please provide from January 1, 2010 through the most recent data available, hourly
data similar to that provided in response to Irrigator Request 8 in Case IPC-E-11-08.
In addition, please provide a breakout of each of the Company's gas fired units.
4.How long have all of the Residential customers had AM! metering?
5.How long have all of the Irrigation customers had AM! metering?
6.Please provide on an hourly basis for all summer months when Residential AMI
metering has been available, the combined Residential hourly load.
7.Please provide on an hourly basis for all summer months when Irrigation AMI
metering has been available, the combined Irrigation hourly load.
8.Please provide on an hourly basis for all summer months when Residential AMI
metering has been available, the calculated combined Residential hourly air
conditioning load of those customers that were on the A/C Cool Credit program.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUESTS TO IDAHO POWER COMPANY
Please explain the calculation used to determine the "calculated" air conditioning
load.
9.Please provide on an hourly basis for all summer months when Irrigation AMI
metering has been available, the combined Irrigation hourly load of those customers
that were on the Irrigation Peak Rewards Dispatchable Program.
10.Please list for each hour during 2012 when curtailment occurred for either the
Residential, Commercial, or Irrigation customers the estimated/calculated level of
load reduction at both the customer level as well as the generation level.
11.Please provide a copy of the 2004 Summit Blue Consulting, LLC report that
calculates the impact of realized rates of Irrigation load reductions.
12.Please provide in electronic format the load research data used to develop the 2004
Summit Blue Consulting, LLC report.
13.Please provide a copy of any more recent studies of the realization rates for Irrigation
load control.
14.Please provide in electronic format the hourly AM! data for each Irrigator for the
summer of 2012.
15.For each of the annual peak loads listed in the response to Staff Request 1, please list
the percentage of operating reserves that were held by the Company, as well as the
units and the MW available from each.
16.For each of the annual peak loads listed in the response to Staff Request 1, please list
the percentage of spinning reserves that were held by the Company, as well as the
units and the MW available from each.
DATED this gay of Mai'efr, '013.
RACINE OLSON NYE BUDGE
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUESTS TO IDAHO POWER COMPANY 2
CERTIFICATE OF SERVICE
V4 r I HEREBY CERTIFY that on this of 31 served a true,
correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s First Data
Request to Idaho Power Company to each of the following, via U.S. Mail or private
courier, e-mail or hand delivery, as indicated below:
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
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
Courtney Waites
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
Donald L. Howell, II
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
P.O. Box 83720
Boise, ID 83720-0074
don.howell(puc.idaho.gov
Benjamin J. Otto
Idaho Conservation League
710 N Sixth Street
Boise, ID 83702
botto2iidahoconservation.org
- U.S. Mail/Postage Prepaid
tE-Mail
Facsimile
Overnight Mail
Hand Delivered
_____ U.S. Mail/Postage Prepaid
-E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
- E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid _____
E-Mail
Facsimile
Overnight Mail
Hand Delivered
IDAHO IRRIGATION PUMPERS ASSOCIATION, 1NC.'S FIRST
DATA REQUESTS TO IDAHO POWER COMPANY 3
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ID 83701
kmil1er2isnakerivera1liance.org
U.S. Mail/Postage Prepaid
i—E-Mail
Facsimile
Overnight Mail
Hand Delivered
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUESTS TO IDAHO POWER COMPANY 4