20140714IIPA 1-5 IPC.pdf

il RACI N E
OLSON
NYE
BU DGE
BAILEY
2O1 E, Center St.
P.O. Box'1391
Pocatello, lD 83204
o 208.232.6101
F 208.232.6109
racinelaw.net
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Eric L. Olsen, LL.M
[e-mail]
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July 11,2014
Jean J. Jewell, Secretary
ldaho Public Utilities Commission
P.O. Box 83720
Boise, ldaho 83720-0084
Re; Case No. IPC-E-14-14
Dear Mrs. Jewell:
Enclosed for filing in the captioned case please find the original and seven copies of
IDAHO IRRIGATION PUMPERS ASSOC'ATION,
'A'C,'S
F'RSI DATA REQUEST TO DAHO
POWER COMPANY.
Thank you for your assistance.
Assistant to
ERIC L. OLSEN
ELOTI
Enclosuresc: Service List (Via Email)
Eric L. Olsen (ISB#: 4811)
RACINE, OLSON, NYE,
BUDGE & BAILEY, CHARTERED
P.O. Box 1391
Pocatello, Idatro 83204-139 I
Telephone : Q08)232-6101
Fax: [phone]
Email: [e-mail]
Attorneys for ldaho Inigation Pumpers Association, Inc.
IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION TO
EXTEND ITS ACCUMULATED
DEFERRED INVESTMENT TAX
CREDITSIREVENUE SHARING
MECHANISM BEYOND 2OI4
DFr'tr1'ilttF:,1,-q.rL.r\ I L
20lq JUL tti AH g: h I
u T r Ll?ipsockr,ii i I s r c r o
BEFORE TIM IDAHO PUBLIC UTILITIES COMIVIISSION
CASE NO.IPC.E.I4.I4
IDAIIO IRRIGATION PUMPERS
ASSOCIATION, rNC.'S X'IRST DATA
REQUEST TO IDAHO POWER
COMPAIIY
l. On page 3 of the Application there is listed approximately $51 million of "Offset to
Pension Balancing Accounf'. Please answer the following:
What has been the year ending amount of the Pension Balancing account for each
year from 2008 through2}l3 for the total Company and for the Idaho
jnrisdiction?
On a total Company basis and an Idaho jurisdictional basis, what has been the
amount of pension expense that was collected in base rates each year from 2008
through 2013?
Per the Stipulation in Case NO. IPC-E-09-30 @aragraph 5.2 (d), the Company
was allowed to increase rates for Pension Expense Recovery. For each of the
yerlrs 2008 through2}l3, what total Pension Expense Recovery was built into
rates for the total Company and for the Idaho jurisdiction?
Per the Stipulation in Case NO. IPC-E-09-30 (Paragraph 5.2 (d), the Company
was allowed to increase rates for Pension Expense Recovery. When was each
change made, and what were the annual amounts of the rate change for the total
Company and for the Idaho jurisdiction?
IDAHO IRRIGATTON PITMPERS ASSOCIATION, INC.',S FIRST
DATA REQIIEST TO IDAHO POWER COMPAI\IY - Page I
b.
,:l
3.
4.
5.
Regarding the *Idaho Jurisdictional ROE" values listed onpage 3 of the Application,
please answer the following:
a. Please provide a general description of how these values were derived. Explain if
the base data used comes from FERC Form I data or some other source. Explain
how costs and revenues are allocated to the Idaho jurisdiction.
b. Are net power costs or components of net power cost normalized in any way?
c. Are there expenses included in the calculation that have been partially or totally
disallowed by the Commission in previous rate cases since 2000?
d. Please provide in Excel format the data and calculation that produced each of
these ROE's for 2008 through 2013.
Please provide in Excel format the derivation of the "Reduction to Rates" figures and the
"Offset to Pension Balancing Account" figures listed on page 3 of the Application?
With respect to the figures listed on page 3 of the Application, for the years 201I through
2013, please list the financial benefit realized by the Company.
According to page 4 of the Application, "the Company expects to use less than $5 million
of additional ADITC in2014." What are the most significant changes that brought about
this "expected use of less than $5 million of additional ADITC in20l4" compared to
2011 through2013?
DATED tfri, l/+L day of July ,2014.
IDATTO IRRTGATTON PUMPERS ASSOCTATTON, INC.',S FIRST
DATA REQUEST TO IDAIIO POWER COMPAI\IY -Page2
,l 't
CERTIT'ICATE Of,' SERYICE
I HEREBY CERTIFY that on tfri, -lfhfuy of July, 2014Iserved a true, correct and
complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. for Leave to
Intervene to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as
indicated below:
Jean D. Jewell, Secretary
Idatro Public Utilities Commission
P.O. Box 83720
472W. Washington Steet
Boise, Idalro 83720-007 4
ij ewell@Auc. state.id.us
LisaD. Nordstuom
Timothy Tatum
Regulatory Dockets
Idaho Power Company
P.O. Box 70
Boise,ID 83707
lnordstrom@idahopower. com
ttatum@ idahopower. com
dockets@i dahopower. com
Peter J: Richardson
RICHARDSON ADAMS, LLP
515 n 7ffi Street
P.O. Box 7218
Boise,ID 83702
peter@richardsonadams. com
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreadin g@mindsprine. com
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATAREQUEST TO IDAIIO POWERCOMPAI{Y-Page 3
Hand Delivered