20210625IIPA 1-3 to PAC.pdf

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 1
CASE NO. PAC-E-21-07

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 ROCKY MOUNTAIN POWER FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND
REGULATIONS
CASE NO. PAC-E-21-07

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

Idaho Irrigation Pumpers Association, Inc. (“IIPA”), by and through undersigned Counsel,
hereby submits its First Data Requests to Rocky Mountain Power, pursuant to Commission Rule
225, as follows:
IIPA 1 -1 On page 25 of McDougal’s direct testimony, lines 5-7, it states that page
3.1 of Tab 3 of Exhibit 40 contains temperature normalization adjustments. With respect to pages
3.1.3d and 3.1.4, please answer the following and provide tabular data in Excel format:
a. Where on these pages are the adjustments for temperature normalization
contained?
b. Please provide the meaning of the alphanumeric terms in the first column
entitled “Schedule”.
c. Please explain the meaning of the term “Unbilled” in the first column
entitled “Schedule”. Assuming that the “Unbilled” values listed are (primarily) for
RECEIVED
2021June 25, PM 2:55
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 2
CASE NO. PAC-E-21-07

December of 2020, how have the values for the “Unbilled” from December 2019 reflected
on these sheets? Please explain.
d. According to Footnote 2, the values in the column entitled “Reconciling
Adjustments” are “Type 1” adjustments. “Type 1” adjustments consist of a number of
different types of adjustments. For each “Schedule” please list the individual adjustments
that make up the total “Type 1” adjustments found for each “Schedule”.
e. According to Footnote 3, the values in the column entitled “Normalization”
are “Type 2” adjustments. “Type 2” adjustments consist of the difference between actual
revenues and “the calculated billing determinants developed by Pricing”. For each
“Schedule”, for each month, please provide the billing determinants, pricing and revenue
associated with both the actual revenues and the values provided by Pricing.
f. What is the meaning/purpose of the values in the column entitled
“blocking”?
g. Where are the “temperature normalizing adjustments”, what were the actual
and normalized temperatures for each “Schedule”, and what were the amounts of the
normalized revenue adjustments for each “Schedule”?
IIPA 1 -2 Exhibit 45 contains, by rate schedule and rate block, all of the Idaho
“normalized billing determinants” for 2019 and 2020. Information is sought with respect to the
development of these values. Please provide all data in Excel format.
a. For each billing unit listed for 2019 and 2020, please provide the actual
billing determinants for each month of 2019 and 2020.
b. For each billing unit listed for 2019 and 2020, please provide the weather
normalizing adjustment for each billing determinant for each month of 2019 and 2020.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 3
CASE NO. PAC-E-21-07

c. For each billing unit listed for 2019 and 2020, please provide the weather
normalizing adjustment for each month of 2019 and 2020.
d. For each billing unit listed for 2019 and 2020, please provide the normal
weather values and the actual weather values that were used to develop the weather
normalized adjustment for each month of 2019 and 2020.
e. What is the source data used to establish the normalized weather figures?
Over what period was this data gathered?
f. Please provide the source data utilized to develop the source data used for
weather normalization in this case.
g. What equation(s) were used to convert the normalized weather values into
normalized billing units in Exhibit 45?
h. For each billing unit listed for 2019 and 2020, please provide the value for
any non-weather normalizing adjustments used for each month of 2019 and 2020. Please
specify the reason for these normalizing adjustments.
IIPA 1 -3 For each month from January 2014 thru the most recent month available,
please provide all Idaho billing determinants in a format similar to Exhibit 45. Please provide in
Excel format.

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 4
CASE NO. PAC-E-21-07

WHEREFORE, this Intervenor requests that this Commission grant this Intervenor’s leave
to intervene in these proceedings and to appear and participate in all matters as may be necessary
and appropriate.
DATED this 25th day of June, 2021.
ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 5
CASE NO. PAC-E-21-07

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 25th day of June, 2021, 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, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
11331 W. Chinden Blvd.
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

Emily L. Wegener (Senior Attorney)
Ted Weston
Matthew D. McVee
PacificCorp/ dba Rocky Mountain Power
1407 WN Temple Ste 330
Salt Lake City, UT 84116
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Data Request Response Center
PacifiCorp/ dba Rocky Mountain Power
825 NE Multnomah, Ste 2000
Portland, OR 97232
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Anthony Yankel
Idaho Irrigation Pumpers Association, Inc.
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 6
CASE NO. PAC-E-21-07

Randall C. Budge
Thomas J. Budge
Monsanto, One of the Bayer Group of
Companies
Racine Olsen, PLLP
P.O. Box 1391
Pocatello, ID 83204-1391
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Ronald L. Williams
Attorney for PacifiCorp Idaho Industrial
Customers
Williams Bradbury, P.C.
P.O. Box 388, Boise, ID 83701
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Bradley G. Mullins
MW Analytics, Energy & Utilities
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
PIIC Electronic Service Only:
Val Steiner
Kyle Williams
Adam Gardener
[e-mail]
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Additional Bayer Representatives:
James Smith
Mike Velie
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)
Brian Collins
Maurice Brubaker
Brubaker @ Associates
[e-mail]
[e-mail]

U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S FIRST SET OF DATA REQUESTS – Page 7
CASE NO. PAC-E-21-07

_____________________________________
ERIC L. OLSEN