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Home My WebLink About20150623IIPA 1-12 to PAC.pdfEric L. Olsen (ISB#: 4811) RACINE, OLSON, NYE, BUDGE & BAILEY, CIIARTERED P.O. Box l39l Pocatello, Idaho 83204-1391 Telephone: (208)232-6101 Fax (208)232-6109 Email: elo@racinelaw.com Attorneysfor ldaho lrrigation Pumpers Association, Inc. IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER TO MODIFY THE ENERGY COST ADruSTMENT MECHANISM AND INCREASE REATES BY $I0.2 MILLION, OR APPROXIMATELY 3.9 PERCENT ill n- I 'rJ,lr ,-' .,."J BEFORE TI{E IDAHO PUBLIC UTILITIES COMMISSION CASE NO. PAC.E-I5-09 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S IIRST DATA REQUEST TO PACIFICORP 1. Please supply in electronic format the monthly total company expenses charged to each of the various components that make up the ECAM since July 2009. (Accounts 447, 501,503, 555, and 565, aswell as the LCAR, S02 sales, DSM, andREC. 2. Please supply in electronic format the monthly Idaho jurisdictional expenses charged to each of the various components that make up the ECAM since July 2009. (Accounts 447,501,503, 555, and 565, as well as the LCAR, S02 sales, DSM, and REC. 3. Please supply in electronic format the monthly Idaho jurisdictional values (since July 2009) that would have been incorporated inthe calculation of Exhibit 2 of Mr. Wilding's testimony. 4. Please supply in electronic format the monthly Idaho jwisdictional values (since July 2009) that were incorporated in a document similar to Exhibit 2 of Mr. Wilding's testimony, but based upon the methodology approved by the Commission (including the 90-10 sharing and any other components that are proposed to be included/excluded in Exhibit 2. 5. On page 4 of the Application, it is stated: 'Therefore, the Company proposes to update the level of base NPC consistent with the level reported in the Annual Results." Please answer the following: IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO PACIFICORP - Page I a. Is the NPC that is presently used and calculated in the 2011 general rate case, based upon a normalized test year? b. Does the Company's statement that it proposes the new NPC to be 'bonsistent with the level reported in the Annual Results", mean that it would be using actual data as opposed to normalized? According to the Application at page 4: "By updating base NPC and allowing that level of expense to be included in base rates beginning January 1,2016, the ECAM will be better aligned to track annual fluctuations in NPC rather than long-term recovery ofNPC currently being collected through the arurual ECAM surcharge." Assuming that the level of the NPC begins to fall on January 1,2016, how would increasing base NPC in this sase, cause the ECAM to be "better aligned to track annual fluctuations inNPC? Please provide amathematical example that demonstrates why the Staff s base rate over- collection adjustrnent should be eliminated. P1ease explain the differences that cause the Company to want to eliminate the DSM and S02 sales from the ECAM and yet want to introduce the production tax credits into the ECAM. 9. According totheApplication atpage 5,the "sharingband has historically penalized the Company". Please quantiff the impact ofthe sharing baud for each year that the ECAM has been in effect. 10. For each of the years in which the ECAM has been in effect, please provide an explanation and quantification of how the LCR has been asymmetrical. 11. For each ofthe years inwhich the ECAM has been in effect, what has been the amount of irrigation load control costs and other DSM cost that were included? 12. Please provide in electronic format for the period January l,20ll through the most recent month available hourly data similar to that provided in IIPA Request 9 in PAC- E-10-07. DATED *n n*!-day of June, 2015. IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO PACIFICORP -Page2 6. 7. 8. CERTIF'ICATE OT' SERVICE Yvonne R. Hogle, Senior Counsel Rocky Mountain Power 201 SouthMain, Suite2300 Salt Lake City, Utah 84111 yvonne.ho gle@pacifi corp. com Ronald L. Williams Williams Bradbury PC l0l5 W. Hays Street Boise, lD 83702 ron@will iamsbradbury. com Val Steiner Agrium Us IncA.{u-West Industries 3010 CondaRoad Soda Springs, Idaho 83276-5301 val. steiner@agrium. com Christina Zamora Community Action Partnership Assoc. of Idaho 3350 W. Americana Terrace, Suite 360 Boise, Idaho 83706 czatnot@.capu.org. ,,,, IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO PACIFICORP- Page 3 Irrigation Pumpers Association, Inc. for Leave to U.S. Mail or private courier, e-mail or hand US Mail/Postage Prepaid Email Facsimile y'-Overnight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail Hand Delivered US MaillPostage Prepaid Email Facsimile Overnight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Ovemight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail Hand Delivered // I I HEREBY CERTIFY that on thi#Lfibg'of June, 2015 I served atrue, correct and complete copy of the Petition of Idaho Intervene to each of the following, via delivery, as indicated below: Jean D. Jewell, Secretary Idaho Public Utilities Commission P.O. Box 83720 472W. Washington Street Boise, Idaho 83720-0074 jjewell@puc. state.id.us TedWeston Rocky Mountain Power 201 South Main, Suite 23009 Salt Lake City, Utah 84111 ted.weston@pacifi corp. com Jim Duke Idahoan Foods 357 Constitution Way Idaho Falls, Idaho 83742 iduke@idahoan.com Randall C. Budge Racine OlsonNye Budge & Bailey P.O. Box 1391 Pocatello,Idaho 83204 rcb@racinelaw.net Data Request Response Center PacifiCorp 825 NE Mulfiromah Street, Suite 2000 Portland, OR 97232 datarequest@fraci fi corp. com Brubaker & Associates 16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017 bcollins@ consultbai.com James R. Smith Monsanto Company P.O. Box 816 Soda Springs,lD 83276 i im.r. smith@monsanto.com IDAIIO IRRIGATION PT]MPERS ASSOCIATION, INC.'S FIRST DATA REQIIEST TO PACIFICORP - Page 4 US Mail/Postage Prepaid Email Facsimile Ovemight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail Hand Delivered US Mail/Postage Prepaid Email Facsimile Overnight Mail