20230822IIPA 1-14 to IPC.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 1
CASE NO. IPC-E-23-11

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Attorney for Intervenor Idaho Irrigation Pumpers Association, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC
SERVICE IN THE STATE OF IDAHO AND
FOR ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.
CASE NO. IPC-E-23-11

IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.’S FIRST SET
OF DATA REQUESTS

Idaho Irrigation Pumpers, Inc., by and through counsel, hereby submits its First Data
Requests to Idaho Power Company, pursuant to Commission Rule 225, as follows:
IIPA 1 -1: Please provide hourly loads by schedule from January 1, 2018 to present. Please
indicate if these data represent load at the generator or at the customer’s meter. Please provide
such data separately for each jurisdiction.
IIPA 1 -2: Please provide all billing determinants used to calculate customer bills, by
schedule and month, from January, 2018 to present. Please provide such data separately for each
jurisdiction.
IIPA 1 -3: Please provide forecasted hourly loads by schedule for the test year and 2024.
Please include all workpapers, models, and source data used to forecast these loads. Please
provide such data separately for each jurisdiction.
IIPA 1 -4: Please provide all forecasted billing determinants used to calculate customer bills,
by schedule and month, for the test year and for 2024. Please provide all workpapers, models,
RECEIVED
Tuesday, August 22, 2023 2:47:22 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 2
CASE NO. IPC-E-23-11

and source data used to forecast these loads. Please provide such data separately for each
jurisdiction.
IIPA 1 -5: Please refer to Exhibit No. 35 - JSS - 2023 Test Year.xlsx.
a. Please provide the source for hard coded numbers in column F and provide all
supporting workpapers.
b. Please provide the source for hard coded numbers in cells G1048 to H1096.
Please provide all supporting workpapers.
IIPA 1 -6: Please refer to Exhibit No. 31 - Major Plant Additions Annualized for 2023.xlsx.
Please provide the source for hard coded numbers in columns F, N, and R and provide all
supporting workpapers.
IIPA 1 -7: Please refer to Exhibit No. 34 - Development of System Revenue Requirement
2023 Test Year.xlsx. Please provide the source for hard coded numbers in columns D, E, F, G,
H, and I and provide all supporting workpapers.
IIPA 1 -8: Please refer to Exhibit No. 33 - Summary of Payroll-Related Annualizing
Adjustments.xlsx.
a. Please refer to sheet 2022 Actual Payroll-SourcePg1. Please provide this data
for 2019, 2020, and 2021.
b. Please provide the basis for the salary adjustment in sheet Payroll-Source
Page A cell k22 and identify all such similar adjustments made in 2019
through 2023.
c. Please refer to sheet Payroll Tax-Source Pg2. Please provide this data by
month from January, 2019 to present.
IIPA 1 -9: Please provide the following information for all generation resources:

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 3
CASE NO. IPC-E-23-11

a. Name of resource
b. Type of resource
c. Nameplate Capacity
d. Generation by hour from January 2019 to present
e. Net plant in service
f. For other production resources, whether the resource is considered a baseload
resource or peaker resource for purpose of cost functionalization and
classification.
IIPA 1 -10: Please provide the company’s market energy transactions from January1, 2019 to
present. Please provide the data at the most granular level available and include an information
that is normally maintained regarding these transactions, including but not limited to delivery
hour, direction, quantity, and price.
IIPA 1 -11: Please refer to Exhibit No. 38-43 - Series of Goralski Testimony Exhibits.xlsx.
Please provide the source and all supporting worksheets for the data in sheets “Tax Alloc” and
“Alloc Factor Input”.
IIPA 1 -12: Please refer to Exhibit No. 37 - Functionalization and Classification of Costs.xlsx.
a. Please explain why the company functionalizes 100 percent of production
plant in service to demand and none to energy.
b. Please provide the source for hard coded numbers in rows 913 to 936 and
provide all supporting workpapers.
IIPA 1 -13: Please refer to the Direct Testimony of Pawel P. Goralski page 10 lines 15 to 21.
a. Please provide the definition of fixed and variable costs used in this
testimony.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 4
CASE NO. IPC-E-23-11

b. Please also refer to page 6 lines 6 to 10. Does the Electric Utility Cost
Allocation Manual recommend classifying demand and energy costs based on
fixed and variable costs? If yes, please provide page citations to such
recommendations.
IIPA 1 -14: Please provide the company’s CCOS filed in is last general rate case.

DATED this 22nd day of August, 2023.

ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 5
CASE NO. IPC-E-23-11

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 22nd day of August, 2023, I served 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, email or hand delivery, as indicated
below:

Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Lisa D. Nordstrom
Donovan E. Walker
Megan Goicoechea
IPC Dockets
Timothy Tatum
Connie Aschenbrenner
Matt Larkin
Idaho Power Company
1221 W. Idaho Street (83702)
P.O. Box 70
Boise, ID 83707
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

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Dayn Hardie
Chris Burdin
Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. No. 8,
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
[e-mail]
[e-mail]
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 6
CASE NO. IPC-E-23-11

Michael Heckler
Courtney White
Clean Energy Opportunities for Idaho Inc.
3778 Plantation River Dr., Suite 102
Boise, ID 83703
[e-mail]
[e-mail]

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Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
[e-mail]

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Peter J. Richardson
Richardson, Adams, PLLC
515 N. 27th Street
Boise, ID 83702
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Dr. Don Reading
280 S. Silverwood Way
Eagle, ID 83616
[e-mail]

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
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Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street Suite 3200
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 7
CASE NO. IPC-E-23-11

Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Tom Arkoosh
Arkoosh Law Offices
913 W. River St., Suite 450
P.O. Box 2900
Boise, ID 83701
[e-mail]
[e-mail]

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Ed Jewell
Darrell Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
PO Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]

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Wil Gehl
Energy Program Manager
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
[e-mail]

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Marie Callaway Kellner
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
[e-mail]
[e-mail]

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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 8
CASE NO. IPC-E-23-11

Peter Meier
U.S. Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
[e-mail]

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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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F. Diego Rivas
NW Energy Coalition
1101 8th Ave. Helena, MT 59601
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_____________________________________
ERIC L. OLSEN