20170316IPC to IIPA 1.pdf

SEHM
LISA D. NORDSTROM
Lead Gounsel
I [e-mail]
March 16,2017
VlA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
47 2 W est Washi ngton Street
Boise, Idaho 83702
Re
LDN/KKI
Enclosures
Case No. IPC-E-16-23
Revised Depreciation Rates for Electric Plant-ln-Service
Response to the Idaho lrrigation Pumpers Association,
Requests to ldaho Power Company
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An TDACORP CompanY
Inc.'s First Data
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Dear Ms. Hanian
Enclosed for filing are an original and three (3) copies of ldaho Power Company' s
Response to the ldaho lrrigation Pumpers Association, lnc.'s First Data Requests to ldaho
Power Company in the above matter.
!f you have any questions aboutthe enclosed documents, please do not hesitate to
contact me.
Very truly yours,
X;flul^*tr.*-:
Lisa D. Nordstrom
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
I nord strom@ id a hopower. co m
Attomey for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORIW TO INCREASE ITS RATES
DUE TO REVISED DEPRECIATION RATES
FOR ELECTRIC PLANT-IN.SERVICE.
CASE NO. !PC-E-16-23
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST
DATA REQUESTS TO IDAHO
POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Powe/' or "Comp?ry"), and in
response to the First Data Requests of the ldaho lnigation Pumperc, lnc. to ldaho
Power Company dated February 23,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY. 1
REQUEST NO. 1: On page 5 of the Company's Application, it states: 'The
Company proposes to allocate the increase in depreciation expense using the
Jurisdictional Separation Study methodology consistent with that utilized to determine
the ldaho jurisdictional revenue requirement in Case No. IPC-E-1 1 -08." ln order to
clarify this statement, please answer the following:
a. Does the statement "using the Jurisdictional Separation Study
methodology consistent with that utilized to determine the ldaho jurisdictional revenue
requirement' refer to:
i. the fina! spread of the rate increase;
ii. the Company's original proposal in Exhibit 33 in Case No. IPC-E-1
1-8;
iii. some other "methodology'?
b. Assuming that "using the Jurisdictional Separation Study methodology
consistent with that utilized to determine the ldaho jurisdictiona! revenue requirement"
means as filed in Exhibit 33 in Case No. IPC-E-1 1-08, what input data was used in the
Separation Study:
i. lf the input data was primarily that used in Exhibit 33, what data
was changed?
ii. lf al! of the input data was updated, what timeframe was used?
iii. Were the allocation factors updated from those used in Exhibit 33?
iv. ln Exhibit 33 there was a large difference in the rates of retum for
the various classes. In Attachment 3 of the Application in this case the
percentage increase for the various classes was in a very narrow range (54% to
66%). How was this narrow of a range of proposed increases derived lfom "using
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, !NC'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY. 2
the Jurisdictional Separation Study methodology consistent with that utilized to
determine the ldaho jurisdictional revenue requirement"?
RESPONSE TO REQUEST NO. 1:
a. i. No.
ii. No.
iii. The Company's statement "using the Jurisdictiona! Separation
Study ("JSS') methodology consistent with that utilized to determine the ldaho
jurisdictional revenue requirement" in Case No. !PC-E-11-08 refers to the
allocation of costs between jurisdictions, not the allocation to customer classes.
As stated in Section 8 of the Company's Application, the Company is proposing
to recover the ldaho jurisdictional revenue requirement from customer classes
through a uniform percentage increase to all base rate components except the
service charge. The ldaho jurisdictional revenue requirement was determined by
applying the allocation factors from the JSS reflecting the settlement stipulation
approved in Case No. IPC-E-11-08 to the revenue requirement components
computed in this case. These allocation factorc and the related computation of
the revenue requirement can be found as Attachment 2 to the Company's
response to Micron's Request No 2-23.
b. i-iv See response to a. iii above.
The response to this Request is sponsored by Matt Larkin, Revenue
Requirement Manager, ldaho Power Company.
DATED at Boise, ldaho, this 16h day of March 2017.
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16h day of March, 2017,1 served a true and
correct copy to IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST DATA REQUESTS TO IDAHO
POWER COMPANY the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 8372O-OO7 4
Micron Technology, Inc.
Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
Brian T. Hansen
HOLLAND & HART, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
Pete Bennett
Micron Technology, lnc.
8000 South FederalWay
Boise, ldaho 83707
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Anthony Yanke!
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 44107
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fschm idt@holland hart.com
etcocian@holland hart.com
bhansen@ hollandhart. com
klhal l@holland hart. com
kmtrease@ holland hart.com
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 4
lndustrial Customers of ldaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON ADAMS, PLLC
515 North 27h Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, ldaho 83703
United States Department of Energy and
Federal Executive Agencies
Steven Porter
Office of the General Counsel (GC-76)
The United States Department of Energy
1000 lndependence Avenue, SW (Room 6D-033)
Washington, D.C.20585
ldaho Gonservation League
Benjamin J. Otto
ldaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, ldaho 83701
Sierra GIub
Travis Ritchie
Sierra Club
2101 Webster Street, Suite 1300
Oakland, California 94612
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T , Executive Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 5