20130408IIPA 17-28 to IPC.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT 0. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
FREDERICK J. HAHN, III
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
DAVID E. ALEXANDER
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL TIPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN
THOMAS J. BUDGE
BRENT L. WHITING
DAVE BAGLEY
JASON E. FLAIG
FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
JEFFREY A. WARR
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED
BOISE OFFICE
201 EAST CENTER STREET 101 SOUTH CAPITOL
POST OFFICE BOX 1391 BOULEVARD, SUITE 300
POCATELLO, IDAHO 83204-1391 BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: [phone]
TELEPHONE [phone]
FACSIMILE [phone] IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
www.racin&aw.net POST OFFICE BOX 50695
IDAHO FALLS, ID 83405
TELEPHONE: [phone]
FACSIMILE: [phone]
ALL OFFICES TOLL FREE
[phone]
SENDER'S E-MAIL ADDRESS: [e-mail]
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON, OF COUNSEL
April 4, 2013
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 ASSOCL4 TION, INC. 'S SECOND BA TA REQUEST TO
IDAHO POWER COMPANY
Thank you for your assistance.
ERICL.
ELO:tj!
Enclosures
c: Service List (Via Email)
Eric L. Olsen (ISB#: 4811)
RACINE, OLSON, NYE,
BUDGE & BAILEY, CHARTERED
P.O. Box 1391
Pocatello, Idaho 83204-1391
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 SECOND DATA
REQUEST TO IDAHO POWER
COMPANY
17.With respect to the Response to Irrigator Request 1, was the sales data provide, actual or
normalized, and was it calendar or billing data? If available, please provide this same data as
actual, calendar data.
18.Please supply the same data as in the Response to Irrigation Request 2, for the Idaho
jurisdiction.
19.With respect to the Response to Irrigator Request 3 (Attachments 5, 6, and 7), are the kWh
figures normalized or actual and are they billing or calendar data?
20.With respect to the Response to Irrigator Request 3, (Attachment 3), please explain how to
identify each of what appears to be five different gas fired units in Column "P". Please
explain how to separate the data for each unit, or provide another copy of this response with
these individual units identified.
21.With respect to the Response to Irrigator Request 4, what is the reason that 0.75% of the
residential customers do not have AJV1I meters?
22.With respect to the Response to Irrigator Request 5, what is the reason that 6.5% of the
irrigation customers do not have AMI meters? Is this 6.5% of the customers generally
representative of the irrigation population with respect to size and usage?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND
DATA REQUESTS TO IDAHO POWER COMPANY
23.With respect to the Response to Irrigator Request 6, it is stated: "Residential customers
billing data is captured via several methods, including AM! as well as ...". Please explain
how the AM! data is used to capture Residential customer billing data.
24.With respect to the Response to Irrigator Request 6, it states that the "residential hourly mean
load shape [is] derived from the sample and scaled to the customer class." Please provide the
load shapes that were derived from the sample. Also please provide the scalar values used.
25.With respect to the Response to Irrigator Request 6, please provide for each of the summer
monthly peak hours the residential load as derived from the AM! data.
26.With respect to the Response to Irrigator Request 7, please provide for each of the summer
monthly peak hours the irrigation load as derived from the AM! data.
27.With respect to the Response to Irrigator Request 8, please supply for all summer hours the
entire residential load (Air conditioning and non-air conditioning) for those customers on the
A/C Cool Credit program. It would be preferred that this data come from AMI metering, but
it unavailable, please supply it on the basis of load research data.
28.With respect to the Response to Irrigator Request 9, please answer the following:
a.What was the number of total participant meters?
b.What was the summer kWh of the customers that did have interval meters, but not AM!
meters?
c.Please provide the combined interval data for those customers that did not have AM!
data, but had interval data.
d.What was the combined billing demand for those customers that had AM! metering?
e.What was the combined billing demand for those customers that had interval metering?
f.What was the combined billing demand for those customers that had neither AM! nor
interval metering?
g.What was the monthly kWh of the customers that did not have interval meters, nor AM!
meters?
h.What was the number of customers that had interval data, and how many customers had
neither interval nor AM! data?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND
DATA REQUESTS TO IDAHO POWER COMPANY 2
RACINE OLSON NYE BUDGE
&
Ill I.J
28. Regarding Attachment 3 of the Response to IIPA Request 3.a to 3.v_2012, please answer the
following:
a.On July 26, 2012 there are six gas units listed. Please give the name/designation for
each.
b.On a day such as July 25, 2012 when there are only four gas units listed, what is the
status of the two gas units that are not listed? Do they in any way contribute to the
Company's reserves?
c.On a day such as July 25, 2012 there are two units listed that have a negative output of 3
MWH. What is the status of these two gas units? Do they in any way contribute to the
Company's reserves?
d.On a day such as July 25, 2012 there is one unit listed that has a negative output of 118
MWH. What is the status of this unit? Does it in any way contribute to the Company's
reserves?
DATED this ANa y of April, 2013.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND
DATA REQUESTS TO IDAHO POWER COMPANY 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this #)kday of April, 2013 I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Second 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
jiewellpuc.state.id.us
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
'US. Mail/Postage Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
- U.S. Mail/Postage Prepaid
L---E-Mail
Facsimile
Overnight Mail
Hand Delivered
- U.S. Mail/Postage Prepaid
L—EMail
Facsimile
Overnight Mail
Hand Delivered
U. . Mail/Postage Prepaid
-Mail
Facsimile
Overnight Mail
Hand Delivered
Benjamin J. Otto U.S. Mail/Postage Prepaid
Idaho Conservation League V1-Mail
710 N Sixth Street Facsimile
Boise, ID 83702 Overnight Mail
botto(2iidthoconservation.org Hand Delivered
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND
DATA REQUESTS TO IDAHO POWER COMPANY 4
Ken Miller
Snake River Alliance
P.O. Box 1731
Boise, ID 83701
kmiller(snakeriveraIliance.org
U.S. Mail/Postage Prepaid _____
MaiI
Facsimile
Overnight Mail
Hand Delivered

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S SECOND
DATA REQUESTS TO IDAHO POWER COMPANY 5