20210728IIPA 27-28 to PAC.pdf

Eric L. Olsen (ISB# 4811)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello,Idaho 83205
Telephone: [phone]
Facsimile: (208) 478-167 0
Email: [e-mail]
Attorney for Intervenor ldaho lrrtgation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
L i.Jt
IN TIIE MATTER OF THE APPLICATION
OF ROCI(Y MOT]NTAIN POWER FOR
AUTIIORITY TO INCREASE ITS RATES
AI\D CHARGES IN IDAIIO AND
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDTILES AND
REGULATIONS
i :;.j jr.. itj PH 3:0h
CASE NO. PAC.E.ZI.O7
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FrFTH SET
oF DATA REQUESTS
Idaho lrrigation Pumpers Association, Inc. ("IIPA''), by and through undersigned Counsel,
hereby submits its Fifth Set of Data Requests to Rocky Mountain Power, pursuant to Commission
Rule 225, as follows:
IIPA 5 - 27 As a follow-up to the Response to IIPA Interrogatory 2, please answer the
following:
A. Request IIPA 1 -2 A. sought information regarding the actual billing
determinants for each month of 2019 and2020. This request is for the general records
and information developed by the Company and does not need to be specifically tied to
the general rate case (GRC). The information is requested on a calendar month basis as
well as a billing month basis. Please provide this monthly information from January
2014 through the most recent month available.
B. Requests IIPA 1 -2B. and IIPA I -Z C. sought information regarding
weather normalized adjustments for each month for 2019 and2020. In the response to
IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.'S FIFTH SET OF DATA REQUESTS-Page 1
CASENO. PAC-E-2I-07
IIPA Interrogatory 1-1, it was demonstrated that weather normalization adjustments were
available by "Schedule". The Attachment IIPA 1- 2.1to the company's response to IIPA
lnterrogatory l-2cc lists normal HDD and CDD data by month. Additionally,
Attachment IIPA 1-2.3 contains monthly kWh and $ weatherization adjustments by
schedule. Tab TempMWH-2020 contains similar adjustments for 2020. Please provide
the weather normalizing adjustments for each "Schedule" from January 2014 through the
most recent month available (in a format similar to Attachment IIPA l- 2.3) that are kept
by the Company for various purposes, in addition to a GRC.
C. Attachment IIPA-l lists for Schedule 07RESD0001 a temperature
adjustment of 1,829,347 kWh and $132,152. Attachment IIPA 1 2.1 lists HDD and CDD
days for 2019. For each schedule with kWh and $ temperature adjustments please
demonstrate by month the equations/calculations and weather data used to produce the
adjustments in Attachment IIPA l- 2.1.
D. Please provide similar monthly data to that requested in C. above, for the
period January 2020 through the most recent month available. This is a continuing
request.
E. Please provide data "normal" HDD, CDD, and AvgDB, for each month
between January 2020 through the most recent month available that are kept by the
Company for various purposes, in addition to a GRC.
IIPA 5 - 28 As a follow-up to the Response to lnterrogatory IIPA 2 - 4, , please answer
the following:
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIFTH SET OF DATA REQIIESTS - Page 2
CASE NO. PAC.E.2I-07
A. For each Type 1 "Normalization" kWh Adjustment listed under tabs 2019
and2020 please list for each Schedule, the amount of the adjustment and list the reason
for each adjustment.
B. For each Type I Revenue Adjustment listed under tabs 2019 and2020
please list for each Schedule, the amount of the adjustment and list the reason for each
adjustment. Please reconcile these adjustments with those listed in "A" above.
C. For each Type2 Revenue Adjustment listed under tabs 2019 and2020
please list for each Schedule, the amount of the adjustment and list the reason for each
adjustment.
D. Please explain why there were "LJnbilled" kWh and Revenue figures for
the Industrial class and the Contract customer only.
E. Please explain why there were "Unbilled" kWh and Revenue figures only
for the Industrial class and the Contract customer only in 2019 and2020.
F. Under tab2020 there is listed an Unbilled Adjustment of -123,534,400
kWh for the Industrial class and an adjustment of +123,534,400 kWh for the Contract
customers. Please explain why these adjustments were necessary.
G. Under tab 2019 there is listed an Unbilled Adjustment of +l13,496,399
kWh for the Industrial class and a positive adjustment of -113,496,399 kwh for the
Contract customers. Please explain why these adjustments were necessary.
H. Please explain how these "Unbilled" adjustments between these two years
are related to each other.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIFTH SET OF DATA REQUESTS - Page 3
CASE NO. PAC-E-2I.07
DATED this 28e day of July, 2OZl.
ECHO HAWK & OLSEN
ERIC L. OLSEN
IDAEO IIRIQTTION PLM?.Bf,S AS6OCIATIONT INC.'S nFT H SET Of DATA REQIIESTS - P.ge 4
CASENO. PAC-E.zI{7
CERTIFICATE OF SERVICE
I HEREBY CERTIFIY that on this 286 day of July,202l,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
I l33l W. Chinden Blvd.
Building 8, Suite 201-A
Boise, lD 83714
ian.noriyuki sov
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
emi lv. wesener@pacifi corp. com
ted. weston@pacificorp. com
matthew. mcvee@paci fi corp. com
Data Request Response Center
PacifiCorpl dba Rocky Mountain Power
825 NE Multnomah, Ste 2000
Portland, OR97232
datareq u est@paci fi corp. com
Dayn Hardie
John Hammond, Jr.
Deputy Attorneys General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8, Suite 201-
A (83714)
[e-mail]. gov
John.hammond@puc. idaho. gov
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIFTH SET OF DATA REQUESTS - Page 5
CASE NO. PAC.E-2I-07
Anthony Yankel
Idaho Irrigation Pumpers Association, Inc.
12700 Lake Avenue, Unit 2505
Lakewood, OH 44107
[e-mail]
Bradley G. Mullins
MW Analytics, Energy & Utilities
brmullins@mwanalytics. com
Randall C. Budge
Thomas J. Budge
Monsanto, One of the Bayer Group of
Companies
Racine Olsen, PLLP
P.O. Box 1391
Pocatello, ID 83204-l 39 1
[e-mail]
[e-mail]
Ronald L. Williams
Attorney for PacifiCorp Idaho Industrial
Customers
Williams Bradbury, P.C.
P.O. Box 388, Boise, ID 83701
ron@wi ll i amsbradbury. com
PIIC Electronic Service Only:
Val Steiner
Kyle Williams
Adam Gardner
Val. Steiner@itafos. com
[e-mail]
[e-mail]
Additional Bayer Representatives:
James Smith
Mike Veile
j [e-mail]
mike. vei lel@,baver. com
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IDAHO IRRIGATION PUMPERS ASSOCIATION,INC.'S FIFTH SET OF DATA REQUESTS- Page 6
CASE NO. PAC-E-2I.07
Brian Collins
Maurice Brubaker
Brubaker @ Associates
bcollins@consultbai. com
mbrubaker@ consultbai. com
Benjamin J. Otto
Idaho Conservation League
710 N. 6tr St.
Boise,Idaho 83702
botto@i dahoconservation. ore
Brad M. Purdy
Attomey atLaw
219 N. 17tr St.
Boise, ID 83702
[e-mail]
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U.S. Mail
Hand Delivered
Ovemight Mail
Telecopy (Fax)
Electronic Mail (Email)
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ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIFTH SET OF DATA REQUESTS - Page 7
CASE NO. PAC-E-21-07