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Home My WebLink About20070820IIPA to PAC 5-1 to 5-4.pdfW. MARCUS W. NYE RANDALL C. BUDGE JOHN A. BAILEY, JR. JOHN R. GOODELL JOHN B. INGELSTROM DANIEL C. GREEN BRENT O. ROCHE KIRK B. HADLEY FRED J. LEWIS MITCHELL W. BROWN ERIC L.. OLSEN CONRAD J. AIKEN RICHARD A. HEARN, M. DAVID E. ALEXANDER LANE V. ERICKSON PATRICK N. GEORGE SCOTT J. SMITH STEPHEN J. MUHONEN BRENT L. WHITING JUSTIN R. ELLIS JOSHUA D. JOHNSON JONATHON S. BYINGTON DAVE BAGLEY CAROL TIPPI VOLYN THOMAS J. BUDGE CANDICE M. MCHUGH LAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTERED BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD, SUITE 208BOISE, IDAHO 83702 TELEPHONE, (208) 39S-0011 FACSIMILE' (208) 433-0187 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 203A IDAHO FALLS, ID 83402 TELEPHONE, (208) 528'8101 FACSIMILE' (208) 528-8109 TELEPHONE (208) 232-6101 FACSIMILE (208) 232-6109 www.racinelaw.net COEUR D'ALENE OFFICE 250 NORTHWEST BOULEVARD, SUITE l06A COEUR D'ALENE, ID 83814 TELEPHONE' (208) 765-6888 SENDER'S E-MAIL ADDRESS: elotIDracinelaw.net ALL OFFICES TOLL FREE(877) 232-6101 LOUIS F. RACINE (1917-2005) WILLIAM D. OLSON, OF COUNSEL August 17, 2007 r--J --" ;;:0 \'V (:) rr! IT'! Jean Jewell, Secretary Idaho Public Utilities Commission O. Box 83720 Boise, Idaho 83720-0074 Dear Jean: ...::. Re:PA C-O 7- Enclosed for filing please find the original and three (3) copies ofIdaho Irrigation Pumpers Association, Inc.s Fifth Data Request to Pacificorp. Sincerely, ) 8y KATHERINE J. BYBEE Assistant to Eric Olsen Enclosurescc: Service list (via e-mail) c:( Eric L. Olsen ISB# 4811 RACINE, OLSON, NYE, BUDGE & BAILEY C~TERED O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 q::- i 00_ ,,"- zao' .....-, .j !--- L: ION Attorneys for the Idaho Irrigation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF) ACIFICORP DBA ROCKY MOUNTAIN POWER FOR APPROVAL OF CHANGES TO ) ITS ELECTRIC SERVICE SCHEDULES CASE NO. P AC-07- IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.S FIFTH DATA REQUEST TO ACIFICORP IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("lIP A"), by and through its attorneys, hereby submits this Fifth Data Request to Pacificorp dba Rocky Mountain Power pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure, IDAPA 31.01.01 , as follows: IIPA 5-1: With respect to the Company s response to IPUC Request 25, here is a figure listed for Schedule 10 or -00 I %. Please answer the following: a. Does this figure mean that the actual usage was 8% higher or lower than the usage predicted by the sample? b. Were the sample results increase/decreased by the 8% figure in order to develop coincident and non-coincident demand data for the Irrigation class? c. Presumably the "sample" data is on a calendar month basis and the "population" data is on a billing month basis. How were (if at all) these two sets of data put on the same time basis? IDAHO IRRIGATION PUMPERS ASSOCIATION INC.S FIFTH DATA REQUESTS TO ACIFICORP - I d. What were the energy values there were being compared for the "sample" and for the population" that resulted in the difference in 8.001 %? e. Over what time frame was the "summer months , and what were the energy values there were being compared for the "sample" and for the "population" that resulted in the difference in 6.623%? f. Which sample customers were on Schedule 72 or 72A during the 2006 Schedule 10 load research study? Please simply provide the identification numbers used in the load research data. lIP A 2: Regarding the Company s response to IPUC request 27, it is stated that the Company conducted an analysis of Schedule 36 usage over a test period ended September 2005 and that load research data used in the study demonstrated "that Schedule 36 load often reaches its peak during off-peak hours, while Schedule I peaks during the on-peak hours. Please supply a list of the identification numbers in the load research data for customers that are presently on Schedule 36 as well as those that were on Schedule 36 during the referenced study. lIP A 3: Contained in the Company s response to IPUC 27-1 is an ID Residential Time-of- Use Program Analysis for 2005. Contained in that analysis are four graphs. Please supply in electronic format the data points for each of those graphs. IIPA 5-4: Regarding the Company s response to Monsanto request 2.50 please answer the following: a. The data for June 19 2006 at 1600 indicates under attachment C-2 that the highest price of short-term purchase on the eastern system was $95 per MWH, while under attachment l the highest price of short-term purchase on the entire system was only $72.25 per MWH. Why is the highest priced purchase on the "system , less than the highest price purchase in the "east system b. How many MW's were purchased at each ofthe "highest" prices listed for each hour in the data contained in attachments C-, C-, D-, and D-2 of response to Monsanto request 2.501 c. Regarding attachment C-, what was the name of the entity selling energy at the maximum price during each of the hours listed? d. In the Company s response to Monsanto request 1.17-2 there is listed times and dates of curtailments as well as the amount of replacement power purchased and at what cost. For the afternoon of June 19 2006 there was 67 MW's for 6 hours at a cost of$21 921 which translates into $54.53 per MWH. Please explain how the rate charged for IDAHO IRRIGATION PUMPERS ASSOCIATION INc.'S FIFTH DATA REQUESTS TO ACIFICORP - 2 replacement power is determined/developed and how it relates to the "highest" priCed energy listed in the Company s response to Monsanto 2.50? Respectfully submitted this I ih day of August, 2007. RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED ERIC L. OLSEN Attorneys for the Idaho Irrigation Pumpers Association, Inc. IDAHO IRRIGATION PUMPERS ASSOCIATION INC.S FIFTH DATA REQUESTS TO P ACIFICORP - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of August, 2007, I served a true correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Second Data Request to Pacificorp to each of the following, via U.S. Mail postage prepaid, e- mail or hand delivery: Jean Jewell (original and 3) Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, Idaho 83720-0074 E-mail: iean.iewell~puc.idaho.gov S. Mail and via E-mail Data Request Response Center PacifiCorp 825 NE Multnomah St., Suite 800 Portland, OR 97232 E-mail: datarequest~pacificorp.com via E-mail James R. Smith Monsanto Company O. Box 816 Soda Springs, ID 83276 E-mail: iim.r.smith~monsanto.com via E-mail Maurice Brubaker Katie Iverson Brubaker & Associates 17244 W. Cordova Court Surprise, AZ 85387 kiverson~sconsul tbai. com via E-mail Anthony Yankel 29814 Lake Road Bay Village, OH 44140 E-mail: tony~yanke1.net via E-mail Idaho Irrigation Pumpers Association, Inc. c/o Lynn Tominaga O. Box 2624 Boise, ID 83701-2624 E-mail: lynn tominaga~hotmai1.com via E-mail IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FIFTH DATA REQUEST TO P ACIFICORP - 4 Randall C. Budge Racine, Olson, Nye, Budge & Bailey, Chtd. O. Box 1391 Pocatello, Idaho 83204-13 91 Hand Delivery Brian Dickman Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, Utah 84111 Email: brian.dickman~pacificorp.com via E-mail Dean Brockbank Justin Brown Rocky Mountain Power 20 I South Main, Suite 2300 Salt Lake City, Utah 84111 E-mail: dean.brockbank~pacificorp.com E-mail: justin.brown~pacificorp.com via E-mail Tim Buller Agrium, Inc. 3010 Conda Road Soda Springs, Idaho 83276 E-mail: tbuller~agrium.com via E-mail Conley E. Ward Michael C. Creamer Givens Pursley LLP 608 W. Bannock Street O. Box 2720 Boise, ID 83701-2720 E-mail: cew~givenspursley.com via E-mail Dennis Peseau, Ph. Utility Resources, Inc. 1500 Liberty Street S., 8te. 250 Salem, OR 97302 E-mail: d eseau excite.com via E-mail fa- IDAHO IRRIGATION PUMPERS ASSOCIATION INC.S FIFTH DATA REQUEST TO P ACIFICORP - 5