20040319Yankel Rebuttal.pdf

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BEFORE THE IDAHdPUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS INTERIM
AND BASE RATES AND CHARGES FORELECTRIC SERVICE
CASE NO. IPC-03-
IDAHO IRRIGATION PUMPERS
REBUTTAL TESTIMONY
ANTHONY J. YANKEL
March 19, 2004
PLEASE STATE YOUR NAME, ADDRESS, AND EMPLOYMENT.
I am Anthony J. Yankel. I am President ofYankel and Associates, Inc. My
address is 29814 Lake Road, Bay Village, Ohio, 44140.
ARE YOU THE SAME ANTHONY Y ANKEL THAT FILED DIRECT
TESTIMONY IN THIS CASE?
Yes. I am filing rebuttal testimony in order to address oversights or
inaccuracies in the testimony that was filed on February 20 2004 by various intervenors
and the Commission Staff.
PLEASE SUMMARIZE THE TESTIMONY OF OTHER
INTERVENORS AS THEY ADDRESSED THE COMPANY'S COST-OF-SERVICE
RESULTS AS IT IMPACTED THE IRRIGATORS.
None of the other Intervenors have made a significant attempt to analyze
or scrutinize the validity of the Company s cost-of-service study. Instead, they blindly
accept the results (which help their customer class) and argue that the rate increase should
be placed entirely on the back of the Irrigators. Unfortunately, in this case there is a
glaring lack of review and validation ofthe Company s cost-of-service study compared
with other general rate cases.
Yankel, Reb
Irrigators
PLEASE GIVE AN EXAMPLE OF THIS LACK OF SCRUTINY OF
THE COMPANY'S COST-OF-SERVICE MODEL AND ITS INPUTS.
Dr. Peseau, on behalf of Micron, points out that (contrary to the
Company s claim) Idaho Power never used an "averaged" weighted 12-CP allocator for
generation and transmission demand costs where the average was 50% based upon a
marginal cost weighting and 50% based upon an unweighted 12-CP method. Dr. Peseau
is correct.
He goes on to state that:
I can only assume that Idaho Power Company made the decision to change
allocation methods in this case to understate the severity of the problem
with irrigation rates.
I fully agree with this statement as well. I made a similar statement in my direct
testimony regarding this switch in Company methodolog;. I found a similar desire on
the part of the Company to temper results with respect to its transmission allocator by
using a 3-CP method, when a review ofthe Company s 2002 IRP (in combination with
its espoused methodology) would result in a l-CP method3 . It would appear that the
Company is picking and choosing data and methods that fit its desired results.
Dr. Peseau s lack of scrutiny is demonstrated by the results he advocated. Based
upon his "correction" of the averaging that Idaho Power utilized, Dr. Peseau proposed
that the demand allocator for generation for the Irrigators be increased by 19%4 and the
I Direct testimony of Peseau at page 23 lines 4-
2 Direct testimony of Yanke 1 at page 27.3 Direct testimony of Yanke 1 at page 30.
1984/0.1670 = 1.188
Yankel, Reb
Irrigators
allocator for transmission plant be increased by 33%. As most people involved in
ratemaking understand, this is a dramatic shift in costs to this class. However, the results
of the cost-of-service run that Dr. Peseau made (using Idaho Power s model) showed that
these changes had a minimal effect on the results to the Irrigation class, with the desired
rate from the Irrigators now being calculated to be 68.74 millslkWh compared to the
62.15 millslkWh calculated by the Company.
As it turns out, the Company s cost-of-service study is flawed, but Dr. Peseau and
others did not bother to question the results, or any of the input that goes into this model.
THE COMMISSION STAFF DID A SENSITIVITY STUDY WITH THE
COMPANY'S COST-OF-SERVICE STUDY TO DETERMINE HOW SENSITIVE
THE IRRIGATION CLASS WAS TO SOME OF THE ASSUMPTIONS AND/OR
DATA USED. PLEASE COMMENT ON THE THREE COST-OF-SERVICE
STUDIES THAT STAFF CONDUCTED FOR THIS PURPOSE.
The first study conducted by the Staff (Exhibit 120) calculates a required
increase for the Irrigation customers of 47.22%. This study merely mimics the
Company s cost-of-service study (but based upon an overall revenue increase of only
14%).
The Staffs second study (Exhibit 121) calculates a required increase for the
Irrigation customers of 44.45%. This study is based upon the assumption of weighting
only four months ofthe 12-coincident peaks (July, August, November, and December). I
5 0.2686 / 0.2021 = 1.329
Yankel, Reb
Irrigators
do not know why the Staff chose these four months, when the Company s 2002 IRP
suggests that there are capacity deficits in the four months of June, July, November and
December. I assume that if one leaves out the month of August versus the month of June
it would make little difference in the overall result, but this lack of sensitivity should not
be taken to mean that all is well with the method or underlying assumptions.
The Staffs third study (Exhibit 122) is an unweighted 12-CP method and it
calculated the required increase for the Irrigators at 29.38% or about 62% of the increase
needed ifthe Company s weightings were used. By comparison, my cost-of service
study computer run, using the same unweighted assumptions as the Staff, move the
increase needed down to 53% of that required by the Company s weighting factors. The
difference here is strictly a function of the model used and not the data or assumptions
that are inputted into the model. The Company s computer model has some internal
inconsistencies and one of the results of those inconsistencies is that it is not as sensitive
to change in allocation factors as it should be.
Q. DOES THE STAFF'S COST-OF-SERVICE STUDIES INCLUDE ANY OF
THE OTHER ADJUSTMENTS YOU MADE IN YOUR DIRECT TESTIMONY?
A. No , the Staffs cost-of-service studies do not attempt to normalize Irrigator (or
any class demand) to be consistent with sales and revenue levels, nor does it address the
fact that Irrigators do not use, for all practical purposes, the Company s underground
distribution system.
Yankel, Reb
Irrigators
THE STAFF'S POSITION ON USING WEIGHTING FACTORS
SEEMS TO BE SUMMARIZED AS FOLLOWS: "ANY ANALYSIS THAT DOES
NOT WEIGHT THE CRITICAL MONTHS MORE HEAVILY THAN SHOULDER
MONTHS DOES NOT CORRECTLY REFLECT FORWARD-LOOKING DEMAND
RELATED COSTS DO YOU AGREE WITH THIS STATEMENT?
No. First, if we are going to reflect "forward-looking demand related
costs" then we should be allocating them to classes that are causing those costs. Second
it is one thing to weight some months more heavily than others if, in fact, costs are more
heavily incurred in some months than in others, but costs in this case are certainly not
heavily incurred in five months with absolutely no marginal demand costs incurred in
seven other months. A 5-CP method simply does not reflect cost causation on the Idaho
Power system. Furthermore, if one looks at the "unweighted" data, it can be seen that
December, which is used in the Company s 5-CP method, has a lower demand than
January, February, May and September (which are not included). November is included
as one ofthe 5-CP', but there is only one month with a lower coincident peak.
January
February
March
April
May
June
July
August
September
October
November
December
6 Hessing Direct Testimony
(q2 page 15 lines 6-
989 MW
996
847
636
209
627
742
315
184
769
706
896
Yankel, Reb
Irrigators
IF ONE WERE GOING TO APPLY ADDITIONAL WEIGHTS TO
THESE FIGURES, WHERE SHOULD ONE TURN FOR DATA?
If one were to apply weights to these monthly coincident values that are
already self-weighting, then these weights should be based upon the costs that Idaho
Power actually pays for its last increment of power on the hour of each monthly peak.
Idaho Power has provided such data . Figure 9 below is the average8 ofthe highest
single price Idaho Power paid for short-term or intermediate-term firm power at the hour
of each monthly coincident peak during 2002 and 2003.
III
i6 20
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r::
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Figure 9
Highest Marginal Price Paid at Hour of System Peak
vs. Company Defined Marginal Cost
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nav Dee
60.
50.00 :.
40.00 ~
;::
c.. c:::::J Derived
30.00 i6
= -+-
Actual
20.00 ~
;:,
10.00 1:)
7 See Response to Irrigator Request 36.
8 For example the January figure is the average of the highest rate paid on January 29 2002 at 0800
($28.75/MW) and the highest rate paid on January 7, 2003 at 0800 ($36.788/MW) for an average of $32.
Yankel, Reb
Irrigators
As can be seen from Figure 9, all months but March and April have at the time of the
system monthly peak a price of more than $30/MW with the highest cost being in July at
under $52/MW. It is also interesting to note that although the Company did not assign
any marginal costs to the months of January, February, May, September, and October;
the actual marginal costs incurred at the times of these monthly peaks were very similar
to the actual marginal cost that was incurred during the August peaks. Furthermore, the
Company assigned less weighting to August than November and December in spite of the
fact that these months had higher marginal demand costs.
WHAT IMPACT WOULD USING WEIGHTING FACTORS BASED
UPON ACTUALLY INCURRED MARGINAL COSTS HAVE ON THE RESULTS OF
THE COST-OF-SERVICE STUDY THAT YOU RAN?
Although I do not believe that there should be any weighting of the
coincident peak values, I have produced a cost-of-service study using these actual
marginal costs in order to demonstrate how distorted the Company s weighting factors
are. I combined these with the normalization of all demand values and the removal of the
allocation of underground distribution plant to the Irrigators. The resulting rate of return
of 4.80% for the Irrigators compares favorably with the overall system average rate of
return of 4.97%. If the Staff insists that weighting factors must be used, then the
weighting factors should be based upon actual cost causation, as opposed to a theory that
is inconsistently applied and assigns zero costs in over half of the months.
Yankel, Reb
Irrigators
HAVE OTHER WITNESSES ADDRESSED THE APPROPRIATENESS
OF USING MARGINAL OR INCREMENTAL COSTS IN THE SETTING OF
RATES?
Yes. Dr. Power for AARP has extensively advocated considering the
marginal or incremental cost of future usage in the rate setting process-both cost-of-
service and rate design. He quotes Idaho Power President J. Lamont Keen as stating:
Clearly, growth has not paid for itself. The incremental costs of
adding, operating, and maintaining generation, transmission and
distribution plant are greater than the embedded costs associated with
generation, transmission and distribution plant that have been the basis
of Company rates over the last ten years.
I fully agree with Dr. Power that the embedded cost of serving present and future
customers will exceed the embedded costs. As pointed out by the Company, Idaho
Power has undergone significant growth over the last 10 years. As further pointed out
there have been reductions in load (specifically FMC and FERC Full Requirements
customers) that have balanced out this growth. Thus, in spite of the fact that the
normalized residential load has grown 17% since the last case and Schedule 9 load has
grown 44%, there has been very little change in overall system load. Until recently this
scenario only caused large increases in distribution plant with much smaller increases in
generation and transmission plant. Now that the surplus created by eliminating most of
the FERC and FMC loads has been absorbed, significant increases in generation and
transmission plant costs will be required as well. Because incremental growth (past and
present) has had an impact since the last rate case, that growth should be reviewed.
Yankel, Reb
Irrigators
HOW HAS THE GROWTH IN THE IDAHO JURISDICTION BEEN
DISTRIBUTED SINCE THE LAST CASE?
The following graph shows the percentage load growth by class since the
last case.
Figure
Load Growth 1993-2003
1,400 000
200,000
000 000
800,000
:I:
600,000
:i1E
400,000
200,000
200 000
General General Large Power
Residential Service Service Service Irrigation
(1)(7)(9)(19)(24)DOE/INEL Simplot Micron Total
Jan 14%48%24%131%37%27%149%
Feb 17%13%52%21%39%16%30%143%
Mar 15%16%54%26%69%49%28%158%
Apr 17%21%52%30%37%12%28%122%
May 20%27%56%26%18%29%130%
Jun 22%31%56%32%14%15%111%
Jul 34%35%61%31%22%144%11%
Aug 31%20%62%24%17%68%27%131%16%
Sept 21%14%63%26%27%22%106%15%
Oct 13%19%50%23%17%27%28%128%
Nav 13%16%46%20%108%25%30%113%
Dee 15%46%24%727%35%27%142%
Yankel, Reb
Irrigators
As can be seen from Figure 10, the normalized energy for the Irrigation class has
remained virtually unchanged since the last case. The incremental growth and associated
costs over the last ten years has been associated with three customer classes and one
special contract customer. From the above table, it can be seen that there was a
disproportionate amount of this growth that took place during the summer months.
WILL THE IRRIGATORS BE A MAJOR CONTRIBUTOR TO
GROWTH AND INCREMENTAL COSTS IN THE FUTURE?
Under the Company s present forecast the Irrigation class is only expected
to grow at a rate of 0.4% per year compared to:
Residential
Commercial
Industrial
2.4%
2.4%
Under this forecast, the Irrigation class will contribute far less to incremental costs than
all of the other main customer groups. Because Dr. Power believes that "it is important
to find ways of signaling to customers the higher incremental cost associated with
providing them with the electric service they seek,,, I suggest that Dr. Power put more of
a cost burden on those classes that have caused the growth in the last 10 years and are
expected to continue to do so.
However, Dr. Power seems quite willing to ignore who is causing this growth
with its associated costs, and merely suggests that this increased burden be shoved off to
9 Dr. Power s direct testimony page 12 lines 8 and 9.
Yankel, Reb
Irrigators
the Irrigators. He goes so far as to diminish the impact his proposal would have by
declaring
Q. But in rural areas, where irrigated agriculture is a more dominant part of
the local economy, don t lower irrigation costs stimulate the local
economy?
A. That is unlikely. "Rural" no longer means "agricultural." Most rural
residents are not irrigators. Most rural businesses are not irrigated farms.
The rural economy is increasingly diverse and non-agricultural. The
economic connection between the rural economy and agriculture has
increasingly reversed so that the diversity in the non-agricultural local
economy, including the urban economies within commuting distance
supports farm families rather than the other way around. Farm and ranch
families increasingly supplement their household income and stay engaged
in agriculture by taking jobs in the non-agricultural sectors of the
surrounding economy. In that sense, promoting the non-agricultural
economy is crucial to the survival of family farms and ranches.
It is only appropriate to accurately define cost-of-service first and then make
regulatory judgments second. It appears as if Dr. Power and others have made no attempt
to define cost-of-service, but blindly accepted the Company s study because it offers
them a short-term benefit. I am not one to make predictions regarding rate impacts, but
reading between the lines of Dr. Power s statement, one may sense that the impact of his
suggestion could mean a drastic reduction, if not almost complete elimination of the
Irrigation class. With a possible 67% increase over 5-years, this is not at all unlikely.
WHAT WOULD BE THE IMPACT OF THE ELIMINATION OF THE
IRRIGATION CLASS?
10 Dr. Power s direct testimony beginning on page 23 line 23.
Yankel, Reb
Irrigators
I will leave to others the question of what would happen to the farm
economy in the Idaho Power service area. However, from a rate perspective, there are a
few things that will obviously happen.
There will be more electricity available on the Idaho Power system for the other
customers. As a matter of fact, there will be (on a normalized basis) about 1 798 000
MWH available or approximately the same amount as FMC made available when it
ceased operation. This amount of additional energy is enough to offset the expected
growth for the next five years. This would be a benefit to all of the other customer
classes because far less additions to generation and transmission plant would be required.
It would have very little impact upon the requirement for additional distribution plant.
WHAT HAPPENS AFTER FIVE YEARS?
Depending on how the Irrigation load would be eliminated, Idaho Power
may need one or more rate cases during this timeframe in order to just keep itself revenue
neutral. For discussion purposes, I will make a simplifying assumption that there will not
be a rate case for five years-the point at which there are no Irrigators and the point
where the growth of the other classes just catches up to the load lost from the Irrigation
class. I will make an additional simplifying assumption that there will be no increase in
any rate base or expenses between now and then. However, it should be remembered that
there was a 68% ($351.2 million II ) increase in Idaho jurisdictional distribution plant
investment (underground investment almost tripled by adding $100 million of
II Exhibit 20 page 6 line 191 in the last case lists the distribution investment in the Idaho jurisdiction at
$513 403 825.
Yankel, Reb
Irrigators
investment) over the last ten years, when there was negligible system load growth and no
Idaho Irrigation growth. Ifthe projected growth takes place and is offset by a reduction
in Irrigation load, this will have very little impact upon the $400 million in distribution
plant investment that is expected in the next 6 years 12. In summary, I am assuming that
load grows as projected, the Irrigation load goes to zero, and rate base and expenses stay
the same.
Basically, this amounts to reallocating present costs under the new load scenario.
The resulting energy and demand levels13 are detailed in Exhibit 313. The following is a
listing of the percentage changes that would be needed to the main energy and demand
allocators using the Company s weightings under such a scenario:
Energy (EI0)Demand (DI0)
Residential 16%40%
General Service- 7 26%20%
General Service-21%
Large Power-11%
DOE 47%
Simplot 29%
Micron 12%
WHY WOULD THERE BE SUCH A SIGNIFICANT SHIFT IN
DEMAND ALLOCA TORS IF THE GROWTH WAS RELATIVELY THE SAME FOR
EACH CUSTOMER GROUP?
12 Direct testimony of Keen at page 17 lines 1-
13 Demand values based upon the same load factor relationship that exists today.14 The negative growth figures reflect the actual experience over the last 10 years where some classes grew
in energy usage, but displayed decreases in peak demand.
Yankel, Reb
Irrigators
Although growth in energy may be relatively equivalent, growth in
coincident demand has been far more lopsided over the past 10 years. The need for such
significant and disproportionate changes to the demand allocators with no increase in
ratebase or expenses points up a shortcoming in the overall allocation process. Basically,
we are allocating embedded costs in an environment where growth is costing
substantially more per unit. At present, the Irrigation class is a major customer group and
has a large portion of costs (both historic as well as newer) allocated to it. If there were a
reliable method to separately allocate historic and recent costs, the revenue responsibility
for the Irrigation class would be a lot less-such a method does not exist. However, as
pointed out above, by removing this large class (that helps to absorb these newer costs
without causing them) a more exaggerated shift in revenue responsibility is made toward
the class or classes that are causing that growth. All this Commission can do is recognize
this shortcoming in its deliberations.
AFTER REVIEWING ALL OF THE DIRECT TESTIMONY OF STAFF
AND INTERVENORS , HAVE YOUR ORIGINAL RECOMMENDATIONS
CHANGED?
No. The Commission should not give a disproportionate increase in this
case, but establish a separate procedure to give various parties time to work out some of
the details and data problems with respect to cost-of-service. After those details have
been addressed, the Commission could then hold a hearing to address the disputed issues
and then adjust rates as appropriate. If a small increase were given as suggested by Staff
Yankel, Reb
Irrigators
this would be an ideal time to make such a review. To indiscriminately give a significant
rate increase to the Irrigation class based upon poor data and methodology would not
only be unjust and unreasonable, but it could cause disruptions of an irreversible nature.
Q. DOES THIS CONCLUDE YOU REBUTTAL TESTIMONY?
A. Yes.
Yankel, Reb
Irrigators
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 18th day of March, 2004, I mailed by UPS/Overnight
Mail a true and complete copy ofthe REBUTTAL TESTIMONY OF ANTHONY 1. YANKEL
in behalf of the Idaho Irrigation Pumpers Association, Inc., to each of the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
1221 W. Idaho
Boise, Idaho 83707-0070
John R. Gale
VP-Regulatory Affairs
Idaho Power Company
1221 W. Idaho
Boise, Idaho 83707-0070
Lisa Nordstrom
Weldon Stutzman
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington
Boise, Idaho 83702
Peter J. Richardson
Richardson & O'Leary
99 E. State Street, Suite 200
Eagle, Idaho 83616
Don Reading
Ben Johnson Associates
670 Hill Road
Boise, Idaho 83703
Lawrence A. Gollomp
Assistant General counsel
S. Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Dean J. Miller
McDevitt & Miller, LLP
420 W. Bannock
Boise, Idaho 83701
Jeremiah J. Healy
United WaterIdaho, Inc.
O. Box 190420
Boise, ID 83719-0420 (US Mail)
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701 (US Mail)
Nancy Hirsh
Northwest Energy coalition
219 First Ave. South, Suite 100
Seattle, W A 98104
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
Boise, Idaho 83701
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste 250
Salem, Oregon 97302
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
Michael Karp
147 Appaloosa Lane
Bellingham, Washington 98229
Thomas M. Power
Economics Dept Liberal Arts Bldg 407
University of Montana
32 Campus Drive
Missoula, MT 59812
Michael L. Kurtz
Kurt 1. Boehm
37 E. Seventh St., Ste 2110
Cincinnati, OH 45202
Exhibit 313
Page10f2
Distribution of Energy Usage After 5-Years of Growth
Energy increase by year
General General Area Large Power Unmetered Municipal Traffic
Residential Service Service Lighting Service Service Street Light Control DOE/INEL Simplot Micron Total
(1)(7)(9)(15)(19)(40)(41)(42)
Year
706,461 306,628 3,470,391 779 174 367 18,534 20,601 10,870 215,238 200,722 684,868 815,458
819,416 319 199 612 677 057 226,552 19,294 446 316 220,403 205,540 701,304 12,164,204
935,082 332 286 760 797 346 279,989 20,085 325 11,780 225,693 210,473 718 136 523,992
053,524 345 910 914 990 647 334,708 20,908 23,241 263 231 110 215,524 735,371 12,895,196
174 808 360,093 075,504 961 390,741 766 194 765 236,656 220,697 753,020 13,278,205
113%122%122%122%113%122%122%122%113%113%113%100%
Projected Spread of monthly energy
General General Area Large Power Unmetered Municipal Traffic
Residential Service Service Lighting Service Service Street Light Control DOE/INEL Simplot Micron
(1)(7)(9)(15)(19)(40)(41)(42)
Jan 439.257 12,145 322 178 386 191 511 803 685 108 49,460 20,006 383 110,921
Feb 448,797 485 305,122 102 150,567 513 514 297 20,085 19,983 61,673 036,138
Mar 383,733 27,596 335 882 522 198,588 727 911 032 921 133 721 103,766
Apr 340,852 30,629 287 875 786 225,643 696 197 128 13,541 19,294 437 952,997
May 372 376 40,928 329,647 560 198,433 262 110 935 18,094 20,834 63,514 012 504
Jun 401,721 50,045 342,248 840 245,452 877 075 135 503 343 53,457 111,696
Jul 764,518 66,106 425 251 637 251,462 557 896 057 495 16,021 72,726 603,725
Aug 656,703 003 426,621 559 186,495 886 924 041 71,079 19,538 65,157 463,007
Sept 388,018 19,497 403,538 771 207 781 965 121 119 330 467 50,768 098,374
Oct 254,372 28,948 309,324 509 196,060 876 803 960 31,488 20,382 63,569 909,291
Nov 327,178 28,104 293,513 796 155,759 920 781 033 32,292 391 54,997 918,766
Dec 489,056 13,963 310 867 559 192 470 875 257 957 491 19,768 70,701 154,964
266,581 372 450 092,067 026 2,400,222 21,957 24,275 12,802 299,509 219,159 759,103 13,476,148
115%126%123%123%113%123%123%123%142%112%113%102%
39.08%76%30.37%06%17.81%16%18%09%22%63%63%100.00%
Projected Spread of weighted monthly energy
General General Area Large Power Un metered Municipal Traffic
Residential Service Service Lighting Service Service Street Light Control DOE/INEL Simplot Micron weights
(1)(7)(91 (15)(19)(40)(41)(42)
Jan 627 248 404,431 10,728,532 12,839 377,310 60,045 56,123 36,881 647,020 666,192 377,056 36,993,676 33.
Feb 13,217,066 662 171 985,856 449 4,434,203 006 029 38,183 591,512 588,507 816,278 30,514 259 29.45
Mar 703,846 841 671 10,244,407 15,910 056,941 52,677 58,277 484 766,604 614 061 278,986 33,664,864 30.
Apr 424,551 846,891 959,747 729 239,036 46,896 60,754 183 374,402 533,483 560,492 26,350 361 27.
May 11,271,821 238,903 978,413 16,940 006,572 38,186 882 28,303 547 709 630,632 922,560 30,648,502 30.
Jun 13,393,387 668,513 11,410,544 28,013 183,373 62,593 69,172 842 183,461 244 807 782,247 063,951 33.
Jul 30,718,333 656,150 086,571 25,587 10,103,758 575 76,167 42,452 100,231 643,713 922 119 64,437,656 40.
Aug 26,839,465 307,944 436 006 855 622 067 063 78,653 561 904,984 798,532 662,972 59,793,102 40.
Sept 13,530,192 679,877 14,071,379 26,878 245,309 68,503 73,965 39,019 290,453 504,447 770,279 38,300,302 34.
Oct 050,873 916,189 790,108 16,103 205,293 59,373 070 30,397 996,604 645,076 011,962 28,779,049 31.
Nov 10,885,213 935,033 765,168 26,497 182,108 63,871 59,265 34,382 074,353 711 690 829,765 30,567 345 33.
Dec 17,219,662 491 651 10,945,633 19,676 776,852 66,025 79,478 33,685 848,206 696,026 489,374 40,666,268 35.
180,881 657 12 649,424 138,402 364 265,475 80,432 822 731 813 806 836 426,373 10,481 318 7,277,164 25,424,088457,779,333
E10S 15.50%23%10.03%02%66%04%05%03%70%37%61%35.23%
E10W 24.01%53%20.20%04%11.91%12%13%07%59%22%94%64.77%
total 39.51%76%30.23%06%17.57%16%18%09%29%59%55%100.00%
present 34.18%20%24.92%05%15.80%13%15%08%56%1.46%98%
change 116%126%121%116%111%123%117%116%147%109%112%
Exhibit 313
Page20f2
Distribution of Monthly Demands After 5-Years of Growth
Demand increase by year
General General Area Large Power Un metered Municipal Traffic
Residential Service Service Lighting Service Service Street Light Control DOE/INEL Simplot Micron Total
(1)(7)(9)(15)(19)(40)(41)(42)
15%24%nfa 22%nfa 15%10%24%-6%
Projected Spread of monthly Demand
General General Area Large Power Un metered Municipal Traffic
Residential Service Service Lighting Service Service Street Light Control DOE/INEL Simplot Micron
(1)(7)(9)(15)(19)(40)(41)(42)
Jan 060,107 43,050 474,861 nfa 249,783 606 nfa 286 23,390 29,251 68,001 952,334
Feb 992,739 43,394 482,139 nfa 260,837 548 nfa 246 29,875 28,991 67,795 909,565
Mar 969,453 263 466,189 nfa 241,857 664 nfa 291 12,026 28,517 67,943 794,204
Apr 612,098 14,477 453,923 nfa 225,146 555 nfa 277 29,431 29,054 67,940 435,901
May 100,421 20,007 537,287 nfa 268,576 536 nfa 888 21,665 26,794 73,304 052,478
Jun 253,023 64,680 575,831 nfa 237,998 542 nfa 369 25,189 15,908 76,624 253,164
Jul 616,501 238 574,676 nfa 266,330 325 nfa 384 23,119 28,409 76,740 588,246
Aug 314,958 60,293 529,858 nfa 250,956 563 nfa 384 16,954 28,889 73,750 279,605
Sept 077,941 34,607 535,375 nfa 249,360 543 nfa 367 18,788 26,213 74,346 020,540
Oct 958,777 13,830 394,167 nfa 263,987 513 nfa 370 17,472 29,451 70,910 752,477
Nov 701,860 45,218 431 993 nfa 240,695 575 nfa 365 22,919 26,858 70,903 1 ,544,385
Dec 065,382 293 454,532 nfa 261,807 518 nfa 347 27,992 29,299 70,869 971,039
12,723,261 399,873 910,830 nfa 017,333 30,488 nfa 16.574 268,820 327,635 859,125 23,553,939
increase 124%67%101%92%122%115%83%124%94%
54.02%70%25.09%12.81%13%07%14%39%65%100.00%
10S 17.77%53%13%21%03%02%28%31%96%30.23%
10W 36.25%17%17.96%60%10%05%86%08%68%69.77%
Projected Spread of monthly Weighted Generation Demand
General General Area Large Power Unmetered Municipal Traffic
Residential Service Service Lighting Service Service Street Light Control DOE/INEL Simplot Micron Total weights
(1)(7)(9)(15)(19)(40)(41)(42)
Jan nfa nfa
Feb nfa nfa
Mar nfa nfa
Apr nfa nfa
May nfa nfa
Jun 709,623 275,493 11,355,379 nfa 693,328 50,132 nfa 26,998 496,723 313,699 511,023 44,432,398 19.
Jul 33,461 579 25,637 895,793 nfa 513,031 48,134 nfa 28,647 478,560 588,069 588,518 53,576,693 20.
Aug 25,207,745 155,826 10,157,375 nfa 810,826 49,127 nfa 26,529 325,004 553,812 1,413,784 43,700,026 19.
Sept nfa nfa
Oct nfa nfa
Nov 10,682,316 688,218 574,928 nfa 663,374 39,186 nfa 20,768 348,834 408,775 079,147 23,505,547 15.
Dec 16,939,568 910,953 227,055 nfa 162,734 40,035 nfa 21,417 445,072 465,861 126,821 31,339,518 15.
111,000,831 4,004,854 47 210,530 nfa 22,843,293 226,614 nfa 124,359 094,192 330,216 6,719,294 196,554,183
10S 42.42%22%17.00%64%07%04%66%74%30%72.10%
10W 14.05%81%02%98%04%02%40%44%12%27.90%
total weight,56.47%04%24.02%11.62%12%06%07%19%42%100.00%
10S 30.09%87%12.07%42%05%03%47%53%63%
10W 25.15%99%12.49%79%07%04%63%76%90%
Average 55.25%87%24.56%12.22%12%07%10%29%53%100.00%
present 39.34%33%23.03%12.79%09%05%14%00%53%
change 140%80%107%96%136%134%97%129%100%