20210714IIPA 6-20 to PAC.pdf

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

Idaho Irrigation Pumpers Association, Inc. (“IIPA”), by and through undersigned Counsel,
hereby submits its Third Set of Data Requests to Rocky Mountain Power, pursuant to Commission
Rule 225, as follows:
IIPA 3 - 6 In Meredith’s workpaper there is a spreadsheet entitled: Table 1 - Year Over
Year Load and Avg Price Change. Under the “Summary” tab it suggested that the original
worksheet included data for 2016 - 2018. Please provide all of this data in the same format as
provided for 2019 and 2020 for Table 1, including graphs. If similar data is available for 2014 and
2015, please provide that also.
IIPA 3 - 7 McDougal’s Exhibit 39, page 1.0, line 2 lists General Business Revenues at
$271,491,123 and McDougal’s Exhibit 40, at page 46 lists the same total Idaho adjusted test year
revenue. In Meredith’s workpaper there is a spreadsheet entitled: Table 1 - Year Over Year Load
and Avg Price Change. On tab “2019” of that workpaper it lists the total adjusted revenue as
$271,416,358. Please explain the basis for the small difference between the two values.
RECEIVED
2021July 14, PM 4:53
IDAHO PUBLIC
UTILITIES COMMISSION

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

IIPA 3 - 8 Why are the billing determinants and revenues used by Meredith for cost-
of-service purposes not being used by McDougal for revenue requirement purposes?
IIPA 3 - 9 With respect to the Company’s Load Research data please provide, for each
sample customer the valid data that was sampled between January 2014 and the most recent month
available, the following in Excel:
A. Customer identification number;
B. Customer rate schedule;
C. Strata to which it belongs and weighting factors of each strata;
D. Raw hourly usage data (i.e., unadjusted, simply the data originally gathered
for each sample);
E. Raw hourly usage data modified to reflect losses;
F. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company’s cost of service study in this case.
G. Please provide any weatherization adjustments that are applied.
H. Please provide copies of the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of
service study in this case. This information should include number of
customers in the population of each class.
IIPA 3 - 10 Previously the Company developed hourly calibrations that calibrated the
Load Research data such that the summation of the (population expanded) Load Research data
and the Census data equaled the Company’s “Operations Stat” or border loads. The Company
may no longer be applying these calibrations to the Load Research data, but the data is still of

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

interest. On an hourly basis from January 2014 through the most recent month available, please
provide:
A. The ““Operations Stat” or border loads for the Idaho Jurisdiction by location;
B. The summation of the (population expanded) Load Research data and the
Census data that would reflect what the Company measured or estimated as its
internal customer load for each rate schedule or customer group;
C. The hourly load for each rate schedule or special contract customer that is
measured or calculated on a census basis as opposed to using load research
data;
D. Any other load that is contained in “A” above but is not addressed in “C”
above (please specify the type of load); and
E. Any information such as difference in measuring techniques or timing of the
data that needs to be addressed when comparing the above data.
IIPA 3 - 11 Please provide for each month from January 2014 forward a copy of the
results of all checks that the Company makes regarding how well the load research data reflects
the actual population usage.
IIPA 3 - 12 For the Irrigation load research samples, what is the range (kW or kWh)
cut-off for each stratum?
IIPA 3 - 13 This filing used “normalized” and weather-normalized data for developing
allocation factors in the jurisdictional allocations and presumably the class cost-of-service study.
For each rate schedule, please provide all workpapers as well as a description of the flow
(manipulation) of data from historic load research or consensus data to projected test year

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

energy, coincident demands, and non-coincident demands. Please supply this data in Excel
format.
IIPA 3 - 14 Please provide in electronic format for the period January 1, 2014 through
the most recent month available, relevant hourly temperature data, HDD data, CDD data, or
other relevant data that the Company uses to make weather normalization adjustments for the
Idaho jurisdiction’s energy and monthly coincident peak values.
IIPA 3 - 15 Please provide in electronic format a listing of the date, time, and
estimated magnitude of all actual hourly curtailments/interruptions that occurred during 2014
through the most recent month available in Idaho separated by rate schedule or special contract
customer. If outright curtailments/interruptions are treated differently than “buy-throughs”,
please state each separately.
IIPA 3 - 16 Please provide in electronic format a listing of the date, time, and
estimated magnitude of all actual hourly curtailments/interruptions that occurred during 2014
through the most recent month available in each of the other jurisdictions. If outright
curtailments/interruptions are treated differently than “buy-throughs”, please state each
separately.
IIPA 3 - 17 Please provide, in electronic format, outage data for each substation and
each circuit in each substation from January 2014 thru the present:
A. The date, time and duration of any outage.
B. The number of customers impacted by rate schedule.
C. The estimated kW of load impacted.
D. Any other data the Company routinely keeps regarding outages such as cause
of the outage.

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

IIPA 3 - 18 Please provide electronically any SAIDI, SAIFI, MAIDI, or CAIDI
information that the Company has collected since 2014. Such data should be provided at the
least aggregated level it is maintained (not necessarily gathered) by the Company.
IIPA 3 - 19 For each substation listed in Meredith workpaper entitled “Idaho Monthly
Sub Peaks CY2020”, please provide in electronic format:
A. The capital cost recorded of the Company’s continuing property records;
B. The depreciation reserves associated with each substation;
C. The monthly peak demand from January 2014 thru the present;
D. The total capacity of the substation for each month from January 2014 thru the
present; and
E. The capital additions for each year for 2014 thru the anticipated end of 2021.
F. Any breakdown of the number of customers served by class.
IIPA 3 - 20 Please provide in electronic format, on an hourly basis, for the period
January 1, 2014 through the most recent month available the following data:
A. Total system input;

B. System input from Company owned generation (stating hydro, coal, wind, and
other generation separately);

C. System input from firm purchases, stating each purchase separately by source
and type of purchase (LF, IF, 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;

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

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 sales;

K. System losses;

L. Requirements Wholesale sales (RQ);

M. Long-term firm Wholesale sales (LF), stating each on separately;

N. Intermediate-term firm Wholesale sales (IF), stating each one separately;

O. Short-term Wholesale sales (SF), stating each one separately;

P. Unit sales, Wholesale (LU) or otherwise, stated separately;

Q. Non-firm and/or economy Wholesale sales (OS), stated separately;

R. The revenue collected each hour from each non-firm and/or economy
purchased listed in “Q” 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. Inadvertent power flows into or out of the system;

V. The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadvertent has been subtracted;

W. Losses assigned to each retail jurisdiction;

X. Losses assigned to Wholesale sales;

Y. Total retail load by jurisdiction;

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

DATED this 13th day of July, 2021.
ECHO HAWK & OLSEN
_____________________________________
ERIC L. OLSEN

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S THIRD SET OF DATA REQUESTS – Page 8
CASE NO. PAC-E-21-07

CERTIFICATE OF SERVICE

I HEREBY CERTIFIY that on this 13th day of July, 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)
Bradley G. Mullins
MW Analytics, Energy & Utilities
[e-mail]

U.S. Mail
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Telecopy (Fax)
Electronic Mail (Email)

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S THIRD SET OF DATA REQUESTS – Page 9
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)
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
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Electronic Mail (Email)
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise, Idaho 83702
[e-mail]

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Telecopy (Fax)
Electronic Mail (Email)

IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.’S THIRD SET OF DATA REQUESTS – Page 10
CASE NO. PAC-E-21-07

Brad M. Purdy
Attorney at Law
219 N. 17th St.
Boise, ID 83702
[e-mail]
U.S. Mail
Hand Delivered
Overnight Mail
Telecopy (Fax)
Electronic Mail (Email)

_____________________________________
ERIC L. OLSEN