20040423Intervenor Funding.pdf

" ," ,- '; ,,:, \, ", " ,:..
Randall C. Budge, ISB No. 1949
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
., , .,/'
j fd ' ')0 (
-- .' , : " ;;.j ,
) i u I
" '
0 "
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS INTERIM AND BASE
RATES AND CHARGES FOR ELECTRIC SERVICE.
CASE NO. IPC-O3-
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION. INC.
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), by and through
counsel of record, Randall C. Budge, and hereby respectfully makes application to the Idaho Public
Utilities Commission ("Commission ) for intervenor funding pursuant to Idaho Code ~ 61-617 A and
IDAPA 31.01.01.161 through .165 as follows:
(A)A summary of the expenses that the Irrigators request to recover broken down into
legal fees, consultant fees and other costs and expenses is set forth in Exhibit "A" attached hereto
and incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to
Exhibit "A" in support of said summary and are incorporated by reference.
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 1
(B)The detail ofthe Irrigators ' proposed findings and recommendations are set forth in
the Direct and Rebuttal Testimony of witness Anthony 1. Yankel and the Irrigators' Post-Hearing
Brief filed herein which are incorporated by reference.
(C)The expenses and costs incurred by the Irrigators set forth in Exhibit A and
accompanying attachments are reasonable in amount and were necessarily incurred in reviewing
and evaluating Idaho Power s Application, Testimony and Exhibits, conducting discovery, analyzing
the Company s filing and supporting data, documents and studies, preparing testimony, evaluating
the testimony, exhibits and positions of Staff and Interventors and participating in all proceedings
and hearings and a filing Post-Hearing Brief, in addition to normal client communications regarding
the same.
(D)The costs described in (A) above constitute a financial hardship for the Irrigators.
The Irrigators currently have $59 752.81 in the bank, accounts payable forlegal and consultant fees
in this case of$75 554.40 as a result of participation in this case as set out in Exhibit ", none of
which have been paid; and, $7 253.35 in other accounts payable The Irrigators are an Idaho
nonprofit corporation qualified under LR. C. ~ 501 (c)( 5) representing farm interests in electric utility
rate matters affecting farmers in southern and central Idaho. The Irrigators rely solely upon dues and
contributions voluntarily paid by members, together with intervenor funding to support activities and
participate in rate cases. Each year a mailing is sent to approximately 7500 Idaho Irrigators
(approximately two-thirds in the Idaho Power Company service area and one-third in the Utah Power
Company service area), soliciting annual dues. The Irrigators recommend members make a
voluntary contributions based on acres irrigated or horsepower per pump.. Member contributions
have been falling which are believed to be attributable to the depressed agricultural economy and
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 2
increased operating costs and threats, particularly those relating to water right protection issues.
From member contributions the Irrigators must pay all expenses, which generally include mailing
expenses, meeting expenses and shared office space in Boise, Idaho, in addition to the expenses
relating to participation in rate cases. The Executive Director, Lynn Tominaga, is the only part-time
paid employee, receiving a retainer plus expenses for office space, office equipment, and secretarial
services. Officers and directors are elected annually and serve without compensation.
It has been and continues to be a financial hardship for the Irrigators to fully participate in
all rate matters affecting its members. As a result of financial constraints, participation in past rate
cases and in this case has been selective and, primarily, on a limited basis.
(E)The Irrigators ' positions differed materially from the positions taken by the
Commission Staff. For example, the Irrigators extensively analyzed and criticized the data and
methodologies used by the Company for purposes of its cost of service study. For the most part
Staff did not extensively analyze or criticize the data or methodologies, excepting the Company
const of service study results. Additionally, the Irrigators requested that any rate increase be spread
on an even percentage basis and that a separate proceeding be initiated to thoroughly investigate and
study data and cost of service issues. The Staff, on the other hand, supported a move of the
Irrigation class towards cost of service with a 15 percent cap.
(F)The Irrigators' participation addressed issues of concern to the general body of users
or consumers on Idaho Power s system.While all other Intervenors generally accepted the
Company s data and methodologies used for cost of service purposes, the Irrigators did not. The
Irrigators scrutinized and criticized the Company s data and methodologies, as well as the results.
Particularly, the Irrigators challenged the source and validity of the weighting factors in the
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 3
Company s W12CP. Additionally, the Irrigators scrutinized and criticized the Company s actual
and budgeted non-power cost accounts 500-953 expenses, concluding that expense data in the 2003
test year were excessive, supporting at least a $5.8 million expense reduction which, if accepted
would be of benefit to all ratepayers. The Irrigators also placed emphasis on factors other than cost
of service studies that should be considered by the Commission in setting rates. The Irrigators
presented a different perspective on the so-called "irrigation subsidy" to that presented by all other
Intervenors.
(G)The Irrigators represent the irrigation class of customers under Schedule 24.
Based on the foregoing, it is respectfully submitted that the Irrigators are a qualifying
intervenor and should be entitled to an award of costs of intervention pursuant to Idaho Code ~ 61-
617A and IDAPA 31.01.01.161 through .165.
DATED this 22nd day of April, 2004.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
(;
RANDALL C. BUDGE
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 4
CERTIFICATE OF SERVICE
;3.I HEREBY CERTIFY that on this ~nd day of April, 2004, I mailed a true and complete
copy of the foregoing document, postage prepaid, to each of the following:
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline(illidahopower.com
mmoen(illidaho power. com
John R. Gale
VP-Regulatory Affairs
Idaho Power Company
O. Box 70
Boise, Idaho 83707-0070
E-mail: rgale(illidahopower.com
Lisa Nordstrom
Weldon Stutzman
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, Idaho 83720-0074
E-mail: lnordst(illpuc.state.id.
wstutzm(illpuc. state. id. us
Peter 1. Richardson, Esq.
Richardson & O'Leary
99 E. State St., Suite 200
O. Box 1849
Eagle, Idaho 83616
E-mail: peter(illrichardsonand oleary. com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
E-mail: dreading(illmindspring.com
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
E-mail: yankel(illattbi.com
Lawrence A. Gollomp
Assistant General Counsel
United States Department of Energy
1000 Independence Ave., SW
Washington, D.C. 20585
E-mail: lawrence.gollomp(illhq.doe.gov
Dennis Goins
Potomac Management Group
5801 Westchester Street
Alexandria, VA 22310-1149
Mail: dgoinspmg(illaol.com
Dean J. Miller
McDevitt & Miller LLP
O. Box 2564
Boise, Idaho 83701
E-mail: joe(illmcdevitt-miller.com
Jeremiah J. Healy
United WaterIdaho, Inc.
O. Box 190420
Boise, Idaho 83719-0420
E-mail: jerry.healy(illunitedwater.com
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 5
William M. Eddie
Advocates for the West
O. Box 1612
Boise, Idaho 83701
E-mail: billeddie(illrmci.net
Nancy Hirsh
NW Energy Coalition
219 First Ave. South, Suite 100
Seattle, Washington 98104
E-mail: nancy(illnwenergy.org
Conley E. Ward
Givens Pursley LLP
601 W. Bannock St.
O. Box 2720
Boise, ID 83701-2720
E-mail: cew(illgivenspursley.com
Dennis E. Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste 250
Salem, Oregon 97302
E-mail: dennytemp(illyahoo.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
E-mail: bmpurdy(illhotmail.com
Michael Karp
147 Appaloosa Lane
Bellingham, Washington 98229
E-mail: michael(illawish.net
Michael L. Kurtz
Kurt J. Boehm
Boehm, Kurtz & Lowry
37 E. Seventh St., Suite 2110
Cincinnati, OH 45202
E-mail: mkurtzlaw(illaol.com
Thomas M. Power
Economics Dept. Liberal Arts Bldg 407
University of Montana
32 Campus Drive
Missoula, MT 59812
E-mail: tom.power(illmso.umt.edu
~~t
RANDALL c. BUDGE
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 6
EXHIBIT A
SUMMARY OF EXPENSES INCURRED BY IRRIGATORS
IN CASE NO. IPC-03-
Legal Fees:
Randall C. Budge:
Other Attorneys:
Paralegal:
Total:
157.80 hours at $175 =
9 hours
5 hours at $55 =
Costs:
Extraordinary postage and copying, long
distance phone:
Travel:
Lodging and Meals:
Total Work and Costs:
Consultant Anthony J. Yankel
439 hours at $100 per hour
Expenses:
Travel, room and meals
TOTAL FEES AND EXPENSES:
$27 615
415
275
$28 305
$ 1 057.
$ 180.
901.26
$30,444.46
$43 900
1209.
$75 554.40
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 7
ATTACHMENT
ITEMIZED STATEMENT FOR
LEGAL FEES AND COSTS
LAW OFFICES OF
RACINE, OLSON, NYE, BUDGE & BAILEY
CHARTERED
CENTER PLAZA - CORNER 1ST AND CENTER
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE ~08) 23~6101
TAX I. D. #82-031 6387
IDAHO IRRIGATION PUMPERS
C/O LYNN TOMINAGA, EXEC.
IDAHO WATER POLICY GROUP
PO BOX 2624
BOISE ID 83701-2624
ASSOCIATION
DIR.
Page: 1
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13 )
11/07/2003
RCB REVIEW AND EVALUATE IPCO GENERAL RATE
CASE FILING AND REQUEST FOR INTERIM
RELIEF; TELEPHONE CONFERENCE WITH IPCO
RE: INTERIM RELIEF REQUEST AND SERVICE
OF FILING ON T. YANKEL, HANDLING OF
DISCOVERY REQUESTS; TELEPHONE CONFERENCE
WITH STAFF RE: SCHEDULING CONFERENCE AND
HEARING ON INTERIM RELIEF REQUEST
(REQUEST FOR PHONE PARTICIPATION)
11/13/2003
RCB REVIEW IPCO, ICIP, STAFF BRIEFS RE:
INTERIM INCREASE REQUEST
PUBLIC UTILITIES HEARING ON INTERIM RATE
INCREASE, CASE SCHEDULING CONFERENCE;
LETTER TO BOARD OF DIRECTORS- CASE
STATUS REPORT AND STRATEGY
PARTICIPATE IN MOTION AND SCHEDULING
CONFERENCE FOR IDAHO POWER I S RATE CASE
FILING
RCB
ELO
12/01/2003RCB TELEPHONE CONFERENCE WITH T. YANKEL RE:
DISCOVERY REQUESTS; PREPARE SERVE FIRST
DISCOVERY REQUESTS UPON IPCO
12/02/2003RCB REVISE AND EDIT FILE IIPA FIRST REQUEST
FOR PRODUCTION OF DOCUMENTS; TELEPHONE
CONFERENCE WITH R. LOBB RE: STAFF REVIEW
DRAFT STATEMENT
HOURS
1. 00
1.00
1. 00
350.
175.
350.
175.
175.
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 2
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13)
HOURS
OF RATE CASE FILING AND ISSUES;
TELEPHONE CONFERENCE WITH T. YANKEL RE:
CASE ISSUES REVIEW/ ANALYSIS; REVIEW
IPCO TESTIMONY/EXHIBITS
12/03/2003RCB MEETING WITH IIPA BOARD RE: CASE REVIEW,
ISSUES, STRATEGY
12/15/2003RCB TELEPHONE CONFERENCE WITH T. YANKEL RE:
PROPOSED SECOND DISCOVERY REQUESTS TO
IPCO; PREPARE FILE IIPA SECOND DISCOVERY
REQUESTS
12/16/2003
RCB
1.60
TELEPHONE CONFERENCE WITH T. YANKEL RE:
DEVELOPMENT OF LOAD CONTROL PROGRAM AND
CREDIT PROPOSAL, ISSUES RELATING TO IPCO
COST OF SERVICE STUDY EVALUATION; REVIEW
AND EVALUATE PACIFICORP LOAD CONTROL
PROGRAM (PAC-E-01-04) AND ADAPTABILITY
TO IPCO; MEETING WITH M. MICKELSON RE:
PROPOSED IPCO LOAD CONTROL PROGRAM
12/17/2003RCB LETTER TO BOARD PROVIDING CASE
STATUS / STRATEGY REPORT
12/26/2003
RCB
12/30/2003
RCB
RCB
RECEIVE AND REVIEW IPUC ORDER RE: PUBLIC
WORKSHOPS; LETTER TO CLIENT RE: SAME;
PREPARE THIRD IIPA DISCOVERY REQUESTS
AND TELEPHONE CONFERENCE WITH T. YANKEL
RE : SAME
TELEPHONE CONFERENCE WITH R. GAIL, M.
BRILLS RE: PROPOSED IRRIGATOR LOAD
CURTAILMENT PROGRAM PROPOSAL
PREPARE FILE AND SERVE IIPA FOURTH DATA
REQUESTS; RECEIVE AND REVIEW IPCO DATA
RESPONSES TO IIPA, STAFF 1. 60
385.
525.
280.
140.
52.
140.
87.
280.
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 3
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13)
HOURS
01/02/2004RCB TELEPHONE CONFERENCE WITH T. YANKEL RE:
IIPA DATA REQUESTS AND RESPONSES,
PROPOSED LOAD CONTROL PROGRAM FOR IPCO 52.
01/12/2004RCB TELEPHONE CONFERENCE WITH H. HUYSER RE:
IPCO PROPOSED IRRIGATION CURTAILMENT
PILOT PROGRAM 35.
01/16/2004
RCB RECEIVE AND REVIEW IPCO DISCOVERY
RESPONSES (IRRIGATORS, MICRON, STAFF);
RECEIVE AND REVIEW IPCO PROPOSED
PROTECTIVE AGREEMENT FOR CONFIDENTIAL
DISCOVERY RESPONSES; TELEPHONE
CONFERENCE WITH AND FAX LETTER TO T.
YANKEL, B. KLINE PROTECTIVE AGREEMENT 1.20 210.
01/20/2004
RCB TELEPHONE CONFERENCE WITH T. YANKEL RE:
CASE PREPARATION AND DISCOVERY REQUESTS;
PREPARE FILE IIPA FIFTH DISCOVERY
REQUESTS TO IPCO; RECEIVE AND REVIEW
IPCO RESPONSES TO FEDERAL AGENCIES
DISCOVERY REQUESTS 1.40 245.
01/22/2004
RCB REVIEW TESTIMONY OUTLINE AND ROUGH DRAFT
TESTIMONY OF T. YANKEL; TELEPHONE
CONFERENCE WITH T. YANKEL RE: DRAFT
TESTIMONY, IPCO DISCOVERY RESPONSES,
LOAD RESEARCH DATA QUESTIONS 87.
01/23/2004
RCB PREPARE FILE IIPA SIXTH REQUEST FOR
PRODUCTION OF DOCUMENTS; REVIEW YANKEL
TESTIMONY OUTLINE AND DRAFT TESTIMONY;
TELEPHONE CONFERENCE WITH T. YANKEL RE:
SAME 1.40 245.
01/30/2004RCB TELEPHONE CONFERENCE WITH L. TOMINAGA
RE: CASE STATUS / STRATEGY, SCHEDULING
PUBLIC HEARINGS 35.
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 4
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13 )
HOURS
02/17/2004RCB REVIEW, REVISE AND EDIT DRAFT TESTIMONY
AND EXHIBITS OF T. YANKEL 350.
02/18/2004RCB REVIEW, REVISE AND EDIT DRAFT TESTIMONY
AND EXHIBITS OF T. YANKEL 137.
02/19/2004
RCB MULTIPLE TELEPHONE CONFERENCE AND EMAILS
WITH T. YANKEL RE: TESTIMONY AND
EXHIBITS; FINAL REVIEW, REVISION, EDIT,
AND FILING OF T. YANKEL TESTIMONY AND
EXHIBITS; TELEPHONE CONFERENCE WITH L.
TOMINAGA RE: IIPA TESTIMONY AND PUBLIC
HEARING SCHEDULE 700.
02/21/2004RCB RECEIVE AND PRELIMINARY REVIEW OF DIRECT
TESTIMONY OF STAFF AND INTERVENORS;
LETTER TO BOARD RE: REPORT OF T. YANKEL
AND OTHER TESTIMONY, CASE STATUS REPORT 1.80 315.
02/23/2004ELO REVIEW YANKEL DIRECT TESTIMONY n/c
02/24/2004ELO TELEPHONE CONFERENCE WITH LYNN TOMINAGA
RE: IRRIGATOR TESTIMONY AT PUBLIC
HEARINGS 52.
02/28/2004RCB RECEIVE AND REVIEW IPCO DISCOVERY
REQUESTS TO lIPS, OTHER INTERVENORS;
TELEPHONE CONFERENCE WITH T. YANKEL RE:
DISCOVERY RESPONSES 52.
03/01/2004
RCB RECEIVE AND REVIEW IPCO DISCOVERY
REQUESTS TO IIPA, OTHER INTERVENORS;
TELEPHONE CONFERENCE WITH T. YANKEL RE:
IIPA RESPONSES TO IPCO DISCOVERY
REQUESTS, IIPA REBUTTAL TESTIMONY;
TELEPHONE CONFERENCE WITH STAFF RE:
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 5
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13)
03/02/2004
ELO
SCHEDULING ISSUES
HOURS
TELEPHONE CONFERENCE WITH KEVIN
MICHAELSON RE: TESTIFYING AT UPCOMING
PUBLIC MEETINGS FOR IDAHO POWER RATE
CASE; CONFERENCE WITH RCB RE: SAME AND
TYPE OF TESTIMONY THAT WOULD BE USEFUL
AT PUBLIC MEETINGS
03/03/2004RCB TELEPHONE CONFERENCE WITH STAFF, T.
YANKEL RE: SCHEDULING WITNESSES FOR
HEARING
03/08/2004
RCB
03/12/2004
RCB
REVIEW, REVISE AND EDIT T. YANKEL
REBUTTAL TESTIMONY AND EXHIBITS;
TELEPHONE CONFERENCE AND LETTER TO T.
YANKEL WITH PROPOSED REVISIONS TO
TESTIMONY 1.20
PREPARE, REVISE AND EDIT FINAL YANKEL
REBUTTAL TESTIMONY AND EXHIBITS; LETTER
TO PUC AND PARTIES WITH REBUTTAL
TESTIMONY FILING; TELEPHONE CONFERENCE
WITH T. YANKEL RE: REBUTTAL TESTIMONY
AND RESPONSE TO IPCO DISCOVERY REQUESTS;
LETTER TO IIPA OFFICERS, BOARD RE:
REBUTTAL TESTIMONY, CASE STATUS; MEETING
WITH J. GEHRING RE: SUBMITTING PUBLIC
TESTIMONY ETC.
03/15/2004RLR PREPARE RESPONSE TO INTERROGATORIES AND
PRODUCTION REQUEST FROM IPCO FOR MEETING
PREPARE REBUTTAL TESTIMONY FOR SERVICE/
MAILING
RLR
03/16/2004RCB FINALIZE AND FILE T. YANKEL REBUTTAL
TESTIMONY AND EXHIBITS; PREPARE AND
SERVE IIPA RESPONSES TO IPCO DISCOVERY
RESPONSES
140.
45.
52.
210.
385.
137.
137.
420.
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 6
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13 )
HOURS
03/18/2004RCB REVIEW TESTIMONY AND EXHIBITS OF IPCO
WITNESSES AND PREPARE FOR HEARING
03/19/2004RCB REVIEW TESTIMONY AND EXHIBITS OF IPCO
WITNESSES AND PREPARE FOR HEARING
03/20/2004RCB REVIEW TESTIMONY AND EXHIBITS OF IPCO
WITNESSES AND PREPARE FOR HEARING
03/22/2004RCB REVIEW IPCO, STAFF TESTIMONY AND
EXHIBITS AND PREPARE FOR RATE CASE
03/23/2004RCB REVIEW IPCO, STAFF TESTIMONY AND
EXHIBITS AND PREPARE FOR RATE CASE
HEARINGS
03/24/2004RCB REVIEW TESTIMONY OF STAFF AND
INTERVENORS AND PREPARE FOR PUC HEARING
03/25/2004RCB REVIEW STAFF AND INTERVENOR TESTIMONY
AND PREPARE FOR PUC HEARINGS
03/26/2004RCB REVIEW REBUTTAL TESTIMONY OF IPCO,
STAFF, INTERVENORS AND PREPARE FOR PUC
HEARINGS
03/27/2004
RCB REVIEW IPCO, INTERVENOR REBUTTAL
TESTIMONY AND PREPARE FOR PUC HEARINGS;
MULTIPLE EMAIL AND TELEPHONE CONFERENCE
WITH T. YANKEL RE: CASE PREPARATION/
STRATEGY AND WITNESS CROSS-EXAMINATION
03/28/2004RCB REVIEW IPCO, INTERVENOR REBUTTAL
TESTIMONY AND PREPARE FOR PUC HEARINGS;
420.
350.
787.
525.
595.
787.
455.
665.
962.
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 7
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13 )
TELEPHONE CONFERENCE WITH T. YANKEL RE:
HEARING PREPARATION/ STRATEGY AND
WITNESS CROSS EXAMINATION
TRAVEL TO BOISE
HOURS
050.
525.
11. 00 925.
10.837.
RCB
03/29/2004RCB PREPARE FOR AND ATTEND PUC HEARINGS
03/30/2004RCB PREPARE FOR AND ATTEND PUC HEARINGS
03/31/2004LRT TELEPHONE CONFERENCE WITH RANDY RE:
RESEARCH ON THE COST OF SERVICE ANALYSISRCB PREPARE FOR AND ATTEND PUC HEARINGS 10.
11. 00
750.
04/01/2004
LRT RESEARCH CASES ADDRESSING COST OF
SERVICE ANALYSIS; PUC CASES APPLYING
OTHER FACTORS, AND DISCRIMINATORY
CHARGES TO NEW CUSTOMERS FOR COSTS OF
PROVIDING THEM SERVICE
PREPARE FOR AND ATTEND PUC HEARINGS
1.20 132.
575.RCB
04/02/2004RCB PREPARE FOR PUC HEARINGS; PREPARE DRAFT
POST- HEARING BRIEF 962.
04/03/2004RCB PREPARE DRAFT POST-HEARING BRIEF 700.
04/04/2004RCB PREPARE DRAFT POST-HEARING BRIEF;
PREPARE PUC HEARING 612.
04/05/2004RCB PREPARE FOR AND ATTEND PUC HEARING 400.
04/06/2004
RCB MEETING WITH EXECUTIVE DIRECTOR L.
TOMINAGA RE: CASE REPORT; MULTIPLE
TELEPHONE CONFERENCES AND LETTERS TO
BOARD RE: CASE REPORT
TRAVEL
490.
612.RCB
IDAHO IRRIGATION PUMPERS ASSOCIATION
Page: 8
04/22/2004
ACCOUNT NO: 710-1518521M
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13)
HOURS
04/07/2004RCB MULTIPLE LETTER TO IIPA BOARD MEMBERS,
OTHERS RE: RATE CASE HEARING OUTCOME,
ISSUES AND STRATEGIES; PREPARE, REVISE
AND EDIT POST-HEARING BRIEF 1. 80 315.
04/14/2004RCB PREPARE, REVISE AND EDIT IRRIGATORS
POST-HEARING BRIEF; TELEPHONE CONFERENCE
WITH AND LETTER TO T. YANKEL WITH
PROPOSED BRIEF 1.50 262.
04/15/2004RCB TELEPHONE CONFERENCE WITH T. YANKEL RE:
POST-TRIAL BRIEF, INTERVENOR FUNDING
APPLICATION 52.
04/21/2004RCB PREPARE, REVISE AND EDIT IIPA POST
HEARING BRIEF AND APPLICATION FOR
INTERVENOR FUNDING
FOR CURRENT SERVICES RENDERED
20 385.
165.7028,305.
ATTORNEY
LISA TANNER
ROBIN L. ROEBUCK
RANDALL C. BUDGE
ERIC L. OLSEN
RECAPTTnT ,ATTON
HOURS
1.30
157.
1. 60
HOURLY RATE
$110.
55.
175.
170.
TOTAL
$143.
275.
27,615.
272 .
12/18/2003
12/18/2003
12/18/2003
12/18/2003
12/31/2003
01/08/2004
01/30/2004
01/31/2004
02/19/2004
02/19/2004
02/26/2004
02/29/2004
POSTAGE
POSTAGE
POSTAGE
POSTAGE
LONG DISTANCE TELEPHONE EXPENSE
POSTAGE
POSTAGE
LONG DISTANCE TELEPHONE EXPENSE
PHOTOCOPIES - YANKEL TESTIMONY,
COpy CD'S - YANKEL WORK PAPERS
POSTAGE
LONG DISTANCE TELEPHONE EXPENSE
EXHIBITS
12.
12.
12.
12.
12.
13.
1.45
183.
230.
IDAHO IRRIGATION PUMPERS ASSOCIATION
IDAHO POWER 2003 GENERAL RATE CASE
(IPC-E-03-13 )
03/25/2004
03/31/2004
04/01/2004
04/06/2004
04/06/2004
04/06/2004
POSTAGE
LONG DISTANCE TELEPHONE EXPENSE
POSTAGE
RT MILEAGE POCATELLO- BOISE 3/28-4/6
LODGING IN BOISE 3/28-4/6
MEALS IN BOISE 3/28-4/6
TOTAL COSTS
TOTAL CURRENT WORK & COSTS
BALANCE DUE
Page: 9
04/22/2004
ACCOUNT NO: 710-1518521M
500.
39.
10.
180.
663.
238.
138.
30,444.
$30,444.
ATTACHMENT 2
ITEMIZED STATEMENT FOR
CONSUL T ANT FEES AND COSTS
t::
1+:;
Descri tionDate
Nov.Read Idaho Power s application and request of interim relief in order to
get an overview ofthe Issues in the case.
Read testimony of Keen in order to get a good background of where the
Company was coming from in this case.
Read testimony and exhibits of Smith and Obenchain. Develop a general
feel for how this revenue requirement testimony impacts all customers,
Develop possible areas of concern regarding expense categories used in
filing, compare with FERC Form 1 data; develop interrogatories designed
to follow-up on what was requested in the last case as well as get
additional data and clarification in this case.
Review Brilz testimony and exhibits. Check with past cases and past
Commission decisions for consistency. Check for changes In testimony and
areas where we had previous disagreement.
Review Brilz testimony and exhibits. Check with past cases and past
Commission decisions for consistency. Check for changes in testimony and
areas where we had previous disagreement.
Dec,Read remainder of testimony; review all data responses to Staff first and
second set of discovery; conversation regarding direction with Hessing,
Look up data in various FERC Form 1 's and use to develop a spreadsheet
regarding historic expenses and check this data out in order to review
trends that may exist ITom year to year,
Review past expense levels by FERC Account verse test year expenses for
abnormalities. Review test year expenses by month as opposed to by year
to see the changes on a monthly basis.
Check for consistancy and reliablity of the data provided by Idaho Power
on CD that supports various aspects of company filing.
Review Idaho Power s cost of service study to follow how allocators
impact the calculations and how these impacts are carried thoughout the
cost-of-service study,
IJ1
I::
Date
Jan-O4 5
Description
Review IPCo cost of service study to follow how allocators work; see if
allocators are consistant with what would expect if one were going to
treat these customers as interruptible or place a demand value on these
Review cost of service study to follow how allocators work; check
calculations for precision and to better understand what the Company is
basing its case upon. Develop interrogatories in order to clarify various
points or in order to demonstrate an alternative approach,
Review Idaho Power workpapers regarding the development of allocation
factors for distribution plant and A&G expenses.
Review Idaho Power s cost of service study in paper form as well as
electronic form and backup workpapers.
Review weather normalization equations and data supplied in response to
a Staff data request and used by the Company in this filing as well as in
past PCA cases.
Review Brilz workpapers; develop an understanding of how various items
were used to develop a1locators or classification ratios. Write
interrogatories regarding distribution allocators.
Review Brilz workpapers; write interrogatories based on responses to data
requests put in by the Staff
Review Brilz workpapers; develop and understanding of how various
items were used to develop allocators or classification ratios. Write
interrogatories regarding distribution allocators,
Review data responses to Irrigation set 1; analyzes data regarding
individual sub accounts between FERC Acct. 500 and Acct. 935. Develop
graphs and do trend analysis on individual accounts,
Review data responses to Irrigation set 1; analyzes data regarding
individual sub accounts between FERC Acct. 500 and Acct. 935. Develop
graphs and do trend analysis on individual accounts.
Review data responses to Irrigation set 1; analyzes data regarding
individual sub accounts between FERC Acct. 500 and Acct. 935. Develop
graphs and do trend analysis on individual accounts.
Date
rJ:J0()
t::
Description
Review data responses to Irrigation set 1; analyzes data regarding
individual subaccounts between FERC Acct. 500 and Acct. 935. Develop
graphs and do trend analysis on individual accounts.
Review data responses to Irrigation set 1; analyzes data regarding
individual sub accounts between FERC Acct. 500 and Acct. 935. Develop
graphs and do trend analysis on individual accounts.
In order to define demand costs, review Pacificorp s proposed charges for
next year s interruptions. Review how load research data is developed
based upon individual samples by hour.
Review, where possible, the detailed load research data and how the
summary data was developed. Then review how load research data is
brought forward into rate case.
Try to establish a means of normalizing demand values to be in line with
normalized energy values and review alternative proposals regarding how
to utilize load research data using normalized sales levels.
Attempt to gather appropriate data so as to check impact of using
normalized energy on the demand assigned to irrigation and residential
using the companies ratio method.
Review cost-of-service data as it relates to distribution pland and the
transfer of non-coincident peak data from load research data into the
Company s filing as it is applied to explain cost causation on the
Write draft testimony and prepare various graphs regarding the
normalization of the revenue requirement as it is associated with Account
500-935 expenses less fuel and purchase power expenses,
Review cost-of-service data; review basis for allocation factors including
the establishment of weighting in the Company s 2002 IRP; review transfer
of data from load research data into the Company s filing.
Review the equations and the transfer of data from load research data into
the Company s filing and how similar data was treated in previous years
based upon load research data.
I::
!..P
Descri tionDate
maintenance and other aspects of the Company s operatiOn impact
generation and requirements and availability; develop graphs assocatiated
with peak demand and maintenance at time of peak; outline related
testimony,
Attempt to run Company s cost-of-service program; conversation with
Staff regarding program problems; outline testimony regarding cost-of-
Attempt to run Company s cost-or-service program; conversation with
Staff regarding program problems; draft testimony regarding weighting
factors for demand.
Attempt to run Company s cost-of-service program; based upon the
inconsistent results I get from the Company s study, begin to outline my
own cost of service study program.
Feb Write my own cost of service study program,
Write my own cost of service study program,
Write my own cost of service study program,
Write my own cost of sefVIce study program; verifY results; begin using
program as a comparison to the Company
COITect problems with Idaho Power s cost-of-service study program;
begin to insert data that is different than used by the Company in its filed
cost-of-service study,
Review how Idaho Power uses its load research data to develop
coincident demand values and then develop coincident demand a1locators
for various classes based upon nonnalized demand data,
Write draft testimony regarding direction on rate design; look up rates
paid in Utah by irrigators; obtain necessary information to support what
has been going on in Utah.
Review history of weighting factors and see how they impact this case
differently than the last case; write testimony regarding use of marginal
weighting factors for both energy and demand,
::::
Date Description
Write draft testimony regarding normalized demand data, use of 12-
allocation. Coordinate with development of exhibits and data used to
establish normalized demands.
Review the Company s data responses regarding distribution cost
classification/allocation and draft testimony regarding problems with
distribution system and develop appropriate exhibits.
Finalize draft testimony; work on exhibits to insure that they are readable
and make sense as well as convey the needed information,
Work on draft testimony, develop summary and some overview testimony
of where I have gone in this case,
Review data supplied in my exhibits to insure that they were accurately
developed.
Review data supplied in exhibits to insure accuracy; insure that testimony
follows exhibit numbers and all documentation is presented or available,
Reread testimony; make corrections to testimony and exhibits; review
discovery that came in as it may apply to my testimony of other issues of
importance.
Review data response to data requests; reread testimony; make final
corrections to testimony and exhibits,
Review testimony and exhibits of industrial intervenors regarding Danskin
and rate design,
Review testimony of Hessing and see how the Company s model treats his
assumptions.
Review Staff testimony of Shunke s regarding rate design as well as that of
the DOE witness.
Review testimony of Micron witness Dr. Peseau.
Review testimony of Powers, do calculations on impacts to rates and rates
of return based upon his suggestion that Irrigation rates be increased over
equal amounts over the next five years,
vveanesaay, r\prll LI , LUU4 11 :U::S AM
Date
.......
April
lonyYankel [phone] r-Q~
- "
.i:'
Description
Work with Budge LO prepare for cross-examination of Pes car and Pow~r
Prepare to testify, auend hearing and testifY,
Work with Budge on cross-examination ofBrik Said, and Obinchain
regarding thcir Icbuttal testimony. Work with Budg~ H:gMding :'iomc
direction on our brief Work aL the Commission to do rcscarch rt~gardillg
material that could be used (hr cross-cxamination and for the brief
ReLuI'Il Lrip; finalize review of the rebuttal of Britz, Said, and Obenchain in
preparation for cross-examinaLioII.
Coversation with nudge, review various aspect aflhe case and organize
material to address Brief
Work on rewriting Brief
---