20190429IPC to IIPA 1-2.pdf

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An loAcoRP company
April 29, 2019
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-18-16
Study of Fixed Costs of Providing Electric Service to Customers
ldaho Power Company's Response to the ldaho lrrigation Pumpers
Association's First Set of Data Requests
Dear Ms. Hanian:
Enclosed for filing are an original and three (3) copies of ldaho Power Company's
Response to the ldaho !rrigation PumpersAssociation's ("llPA") First Set of Data Requests.
Also enclosed are one (1) non-confidentia! disk and one (1) confidential disk
containing information provided in response to llPAs requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
lf you have any questions about the enclosed documents, please do not hesitate to
contact me.
Very truly yours,
LISA D. NORDSTROM
Lead Counsel
[e-mail]
LDN:kkt
U4*
Lisa D. Nordstrom
Enclosures
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 nordstrom @ ida hopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF IDAHO
POWER COMPANY TO STUDY FIXED COSTS
OF PROVIDING ELECTRIC SERVICE TO
CUSTOMERS
CASE NO. rPC-E-18-16
IDAHO POWER COMPANY'S
RESPONSE TO THE IDAHO
IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST SET
OF DATA REQUESTS
COMES NOW, ldaho Power Company ("ldaho Power" or "Company"), and in
response to the ldaho lrrigation Pumpers, lnc.'s ('llPA") First Set of Data Requests to
ldaho Power Company dated April 8, 2019, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 1
ir,l 4n nlt t. a -i,l;ilJ t*rt tl;1-.J
REQUEST NO. 1: For each hour (specify hour ending or hour beginning) in
2017 and 2018 the calculated load (load research, census, or other) for each of the
Company's rate schedules, keeping ldaho and Oregon separate.
RESPONSE TO REQUEST NO. 1: Please see the attachment provided in
response to this request for the 2017 and 2018 hourly calculated load for each of the
Company's rate schedules.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Leader, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS .2
REQUEST NO. 2: Please provide in electronic format, on an hourly basis, for
the period January 1, 2017 through December 31, 2018 the following data: (This is the
same type of data that was provided in the Response to lrrigator's Request 9 in case
rPC-E-11-08)
a. Total system input;
b. System input from Company owned generation (stating hydro, coal, and
other generation separately) ;
c. System input from firm purchases, stating each purchase separately by
source and type of purchase (LF, lF, SF, etc.)
d. The cost of each firm purchase listed in "c" above;
e. System input from non-firm and/or economy purchases, stating each
purchase separately;
f. The cost of each non-firm and/or economy purchase listed in "E" above;
g. System input from exchanges into the system, stating each exchange
separately;
h. System input from Unit purchases;
i. Other system inputs, stating for each "other" input the type and the source
of the input;
j Jurisdictional (ldaho and Oregon) sales;
k. System losses;
l. Requirements Wholesale sales (Ra);
m. Long-term firm Wholesale sales (LF), stating each on separately;
n. lntermediate-term firm Wholesale sales (lF), stating each one separately;
o. Shortterm Wholesale sales (SF), stating each one separately;
p. Unit sales, Wholesale (LU) or othenruise, stated separately;
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 3
q. Non-firm and/or economy Wholesale sales (OS), stated separately;
r. The revenue collected each hour from each non-film and/or economy
purchased listed in "P" above.
s. Exchanges out of the system, stating each exchange separately;
t. Other system outputs, stating for each "other" output the type and
recipient of the output;
u. lnadvertent power flows into or out of the system;
v. The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and lnadveltent has been subtracted;
w. Losses assigned to each retailjurisdiction;
x. Losses assigned to Wholesale sales; and
y. Total retail load by jurisdiction.
RESPONSE TO REQUEST NO. 2:
a-i, k, m-v: Please see Confidential Attachments 1 and 2 to this request for the
2017 and 2018 data, respectively. To use these Excel files, utilize the drop-down
menus found in row 7 to filter the data. For instance, clicking on the arrow in row 7 of
Column A, allows the reader to see the drop-down menu for system load data.
Selecting "system load" from the menu will display the system load data by day for
hours 1 through 24 in columns R through AW. The column heading in row 5 identifies
the specific Request No. (a-i, k, m-v) for which each column corresponds. The
confidential attachments will be made available to those parties who have signed the
Protective Agreement in this matter.
j: The data requested in j is not available on an hourly basis.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 4
l, w-y:
I: The requested data for Requirements Wholesale sales does not exist. The
wholesale customer sales in the requested period are zero.
w: Hourly losses assigned to each retail jurisdiction are not available. System
loss factors are calculated by voltage level and are not calculated on an hourly basis.
Please see Attachment 4a to the Company's response to Staff's Request No. 1 for the
annual loss factors for peak demand and energy by voltage for each jurisdiction.
x: Hourly losses assigned to wholesale sales are not available. System loss
factors are calculated by voltage level and are not calculated on an hourly basis. Please
see Attachment 4a to the Company's response to Staffs Request No. 1 for the annual
loss factors for peak demand and energy by voltage for each jurisdiction.
y: Hourly retail load by jurisdiction is not available; however, the 2017 and 2018
calculated load for each of the Company's rate schedules for both ldaho and Oregon
was provided in the Company's response to Request No. 1.
The response to this Request is sponsored by Jordan Prassinos, Load Research
and Forecasting Leader, ldaho Power Company.
DATED at Boise, ldaho, this 29th day of April 2019.
LISA D. NOR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of April, 2019, I served a true and
correct copy to IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO
IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS thE
following named parties by the method indicated below, and addressed to the following:
Gommission Staff
Edward Jewell
Deputy Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
ldaHydro
C. Tom Arkoosh
ARKOOSH LAW OFFICES
802 West Bannock Street, Suite LP 103
P.O. Box 2900
Boise, ldaho 83701
ldaho Conservation League and NW
Energy Coalition
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, Idaho 83702
ldaho lrrigation Pumpers Association,
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
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erin. [e-mail]
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lnc.
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 6
Vote Solar
Briana Kobor
Vote Solar
358 South 700 East, Suite 8206
Salt Lake City, Utah 84102
David Bender
Earthjustice
3916 Nakoma Road
Madison, Wisconsin 537 11
Al Luna
Nick Thorpe
1625 Massachusetts Avenue, NW, Suite 702
Washington, DC 20036
Gity of Boise
Abigail R. Germaine
Deputy City Attorney
Boise City Attorney's Office
150 North Capitol Boulevard
P.O. Box 500
Boise, ldaho 83701-0500
ldaho Clean Energy Association
Preston N. Carter
GIVENS PURSLEY LLP
601 West Bannock Street
Boise, ldaho 83702
Sierra Glub
Kelsey Jae Nunez
KELSEY JAE NUNEZLLC
920 North Clover Drive
Boise, ldaho 83703
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IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 7
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Zack Waterman
Michael Heckler
ldaho Sierra Club
503 West Franklin Street
Boise, ldaho 83702
Avista Corporation
David J. Meyer
Avista Corporation
1411 East Mission Avenue, MSC 27
P.O. Box 3727
Spoka ne, Wash i ngto n 99220-37 27
Patrick D. Ehrbar
Avista Corporation
1411 East Mission Avenue, MSC 27
P.O. Box 3727
Spokane, Wash i n gto n 99220-37 27
Pacificorp d/b/a Rocky Mountain Power
Yvonne R. Hogle
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Ted Weston
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
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michael. p. [e-mail]
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loe. miller@avistacorp. com
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rly owell,
IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION
PUMPERS ASSOCIATION, INC'S FIRST SET OF DATA REQUESTS - 8
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