20080207Intervenor Funding Petition.pdf

Eric L. Olsen, ISB No. 4811
RACIN, OLSON, NY, BUDGE &
BAIEY, CHATERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TH MATTER OF THE APPLICATION OF )
IDAHO POWER FOR AUTHORITY TO )
INCREASE ITS BASE RATES AN CHAGES )
FOR ELECTRCAL SERVICE TO ELECTRIC )
CUSTOMERS IN THE STATE OF IDAHO )
)
CASE NO. IPC-E-07-08
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRGATION PUMPERS ASSOCIATION, INC.
COMES NOW the Idaho Irrgation Pumpers Association, Inc. ("Irrgators"), by and through
counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public
Utilities Commssion ("Commssion") for intervenor funding, pursuant to Idaho Code § 61-617 A and
IDAPA 31.01.01.161 through .165, in Idaho Power's general rate case, as follows:
(A) A summary of the expenses that the Irrgators request to recover broken down into
legal fees, consultant fees and other costs and expenses is set forth in Exhbit "A" attached hereto and
incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to Exhbit
"A" in support of said summary and are incorporated by reference.
(B) The Irrigators' President, Mark Mickelsen, Irrigators' member, Jeff PaW, legal
counsel, Eric L. Olsen, and consultant, Anthony 1. Yankel, P.E., fully participated in these
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - i
ORIGINAL
proceedings. Procedurally, this case went forward like a full blown rate case with direct and rebuttal
testimony being filed and all parties preparing for a hearing. Notwithstanding, the case was settled
on the eve of hearing through a stipulation of the parties on the majority of the issues presented in
this case. The stipulation was presented to the Commssion on January 23,2008.
The Irrigators' President, Mark Mickelsen, argued to the Commission that the irrgation class
is getting a disproportionate share of the mounting system growth costs without regard of the fact
that the irrigation class, as a whole, has not growing. He also pointed out that the irrigation class
already received a 4% to 6% rate increase in 2007 due the unexpected loss of the BP A credit.
Finally, he urged that the Peak Reward Program needs to be improved. The improvements he urged
the Commission to adopt were an increase in the amount of the interruptibility credit, a relaxing of
participation standards with a view to encourage more participation, and the implementation of a
dispatchable interruptibility program similar to that on the Rocky Mountain Power system.
Irrigators' member, JeffPahl, testified before the Commssion that he has been paricipating
in the Peak Rewards Program by providing curtailment one day per week since 2005. He urged that
an increase in the amount of the curtailment credit would be needed in order to justify him providing
additional interrption under the Peak Rewards Program. The increase is needed to cover additional
labor costs and justify exposing himself to possible yield loss due to insuffcient watering during the
irrigation season.
The Irrigators' consultant, Anthony Yankel, emphasized to the Commssion that the cost of
system growth is driving Idaho Power's need for rate increases. However, Idaho Power's cost of
service study does not incorporate into its methodology a mechanism to allocate the costs of growth
to those customer classes that are causing the growth on the system. As a consequence, the cost of
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 2
service study in this case allocated disproportionate costs to the Irrgators, as well as other static
customer classes. Mr. Yankel also pointed out that Idaho Power's current load research data does
not reflect the amount of curtailment being provided by the Peak Rewards Program. He also pointed
out to the Commssion that the Peak Rewards Program provides a greater benefit to the Idaho Power
system than is currently being recognized in the curtailment credit being paid and that the curtailment
credit must be increased significantly to be in line with the benefits being provided the Idaho Power
system and encourage greater participation. Mr. Yanel further urged the Commssion to require
Idaho Power to continue on with the irrgation time-of-day program and establish time-of-day rates
that would send the appropriate price signals to irrigators on the Idaho Power system.
The stipulation presented to the Commssion in this case was the result of active participation
ofMr. Mickelsen, Mr. Pahl and other Irrgator board members, Mr. Olsen, and Mr. YankeL. Key
elements of the Irrgators' positions, such as the cost of service/growth issues, were reflected in the
stipulation by the fact of the even rate spread between all customer classes, besides the residential
class. Under stipulation, the Irrgators' positions on the Peak Rewards Program will be the subject
of subsequent study this coming year between the Irrigators, Idaho Power, Commission Staff and
other interest parties, with the ultimate goal of providing changes and improvements for
implementation in the 2009 irrigation season. The Irrgators actively participated in all settlement
conferences and in the techncal hearing before the Commssion, and also joined in urging the
Commssion to adopted the settlement that had been reached between most parties.
(C) The expenses and costs incurred by the Irrigators set forth in Exhbit A and
accompanying attachments are reasonable in amount and were necessarily incurred. The expenses
and costs were incurred in reviewing the Company's filing and intervenor testimony, preparing and
APPLICATION FOR INERVENOR FUNDING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 3
reviewing approximately 40 Irrgators data requests and responses, drafting and filing direct
testimony, drafting and filing rebuttal testimony, drafting stipulation language, drafting cross-
examination questions for the Company and intervenor witnesses, and participating in the settlement
discussions that resulted in the settlement stipulation that was presented to the Commission.
(D) The costs described in Paragraph (A) above constitute a financial hardship for the
Irrgators. The Irrigators currently have approximately $42,768.46 in the bank with outstanding
accounts payable from the last rate case and other small matters totaling approximately $63,821.08.
In addition, the Irrigators have outstanding accounts payable for legal and consultant fees and costs
in this case total $51,528.56 as set out in Exhbit "A" and accompanying attachments.
The Irrigators are an Idaho nonprofit corporation qualified under I.Re. § 501(c)(5)
representing farm interests in electric utility rate matters afecting 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 mailings are sent
to approximately 7500 Idaho Irrigators (approximately two-thirds in the Idaho Power Company
service area and one-third in the RM service area), soliciting annual dues. The Irrigators
recommend members make voluntar contributions based on acres irrigated or horsepower per
pump. Member contributions have been fallng which are believed to be attributable to the depressed
agricultural economy and increased operating costs and threats, particularly those relating to water
right protection issues.
From member contributions the Irrgators must pay all expenses, which generally include
mailing expenses, meeting expenses and shared offce space in Boise, Idaho, in addition to the
expenses relating to paricipation in rate cases. The Executive Director, Lynn Tominaga, is the only
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 4
part-time paid employee, receiving a retainer plus expenses for offce space, offce equipment, and
secretarial services. Offcers 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 offinancial constraints, participation in past rate cases
and in this case has been selective and, primarily, on a limited basis. The Irrigators also have just
finished participating in the Rocky Mountain Power general rate case, which has added financial strain
on the organzation.
(E) The Irrigators' positions urged to be adopted by the Commission materially differed
from those addressed by the Commssion Staff and other parties on several important points. First,
the Irrigators addressed the growth issue on Idaho Power system and proposed a method to allocate
a portion of the growth costs to the customer classes causing the system growth in a way not to
penalize other static customer classes. Second, the Irrgators also continue to advocate for
improvement to the Peak Rewards Program. The Irrgators provided direct testimony that the
curtailment credit amounts must be increased to encourage greater paricipation, to bring the credit
in line with the benefit received by Idaho Power system, and help shave the critical summer peak that
Idaho Power is facing on its system. In the Stipulation, Idaho Power, the Irrigators, Commission
Staff and other interested parties wil be meeting this year to improve the to address the issues raised
by the Irrigators. The Commssion Staff did not address these load control issues that the Irrgators
had raised. Finally, the Irrigators urged the continuation ofIdaho Power's time-of-use irrgation rate.
The Irrigators believe that this type of voluntary program could also help reduce Idaho Power's
summer peak. The Commssion Staff did not address this issue.
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 5
(F) The Irrgators' participation addressed issues of concern to the general body of users
or consumers on Idaho Power's system. All customer classes have an interest in finding a method
to equitably pay for the cost ofIdaho Power's system growth. Further, the Peak Rewards Program
has enabled Idaho Power to shave approximately 40 to 50mwh of load during the summer system
peak. This reduction in peak load benefits all Idaho Power customer classes by reducing the overall
system costs. This translates into lower rate increases when rate cases are fied. Continuation and
expansion of the Peak Rewards Program may also defer the building of additional generation plant
as indicated Idaho Power's most recent Integrated Resource Plan. Avoiding these type of costs is
also a benefit to all ofIdaho Power's customers.
(G) The Irrgators represent the irrgation class of customers under Schedule 10.
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 in the maximum amount
allowable pursuant to Idaho Code § 61-617 A and ID AP A 31.01.01. 161 through .165.
DATED this 6th day Of~2008.
RACIN, OLSON, NY, BUDGE &
BAIEY, CHATERED
BYún~LmERIC .OL T
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 6
CERTIFICATE OF SERVICE
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I HEREBY CERTIFY that on this ~ day of~, 2008, I~erved a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Application for Intervenor Funding
to each of the following, via U S. Mail or private courier, e-mail or hand delivery, as indicated below:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
E-mail: jean.jewell§puc.idaho.gov
Barton L. Kline
Lisa D. Nordstrom
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline(fidahopower.com
E-mail:lnordstrom(fidahopower.com
Weldon Stutzman
Neil Price
Deputy Attorney Generals
Idaho Public Utilities Commssion
472 W. Washington (83702)
P.O. Box 83720
Boise, ID 83720-0074
E-mail: weldon.stutzman§puc.idaho.gov
E-mail: neiL.price(fpuc.idaho.gov
Peter 1. Richardson, Esq.
Richardson & O'Leary
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
E-mail: peter§richardsonandoleary.com
Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, ID 83703
E-mail: dreading§mindspring.com
Hand Delivery
via E-mail
US. Maillostage Prepaid
via E-mail
US. Maillostage Prepaid
via E-mail
US. Mail/Postage Prepaid
via E-mail
U.S. Maillostage Prepaid
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 7
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony(iyankel.net
Michael L. Kurtz, Esq.
Kurt 1. Boehm, Esq.
Boehm, Kurtz & Lowry
36 E. Seventh Street, Suite 1510
Cincinnati, Ohio 45202
E-mail: mkrtz§FKLlawfrm.com
E-mail: kboehm(iBKLlawfirm.com
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
E-mail: cew(igivenspursley.com
Lot H. Cooke
Acting Assistant General Counsel
United States Department of Energy
1000 Independence Avenue, S.W.
Washington, D.C. 20585
E-mail: Lot.cooke§hq.doe.gov
Denns Goins
Potomac Management Group
5801 Westchester Street
P.O. Box 30225
Alexander, VA 22310-1149
E-mail: DGoinsPMG(icox.net
Arhur Perr Bruder
United States Department of Energy
Offce of the General Counsel
1000 Independence Ave. S.W.
Washington, D.C. 20585
E-mail: Arhur.Bruder§HQ.doe.gov
via E-mail
US. Maillostage Prepaid
via E-mail
US. Maillostage Prepaid
via E-mail
US. Maillostage Prepaid
via E-mail
US. Maillostage Prepaid
via E-mail
US. Maillostage Prepaid
via E-mail
US. Maillostage Prepaid
APPLICATION FOR INERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 8
Denns E. Peseau, Ph.D.
Utility Resources, Inc.
1500 Liberty Street, Suite 250
Salem, Oregon 97302
E-mail: dpeseau§excit.com
via E-mail
US. Maillostage Prepaid
Dale Swan
Exeter Associates, Inc.
5565 Sterrett Place Suite 310
Columbia, Maryland 21044
E-mail: dswan§exeterassociates.com
via E-mail
US. Maillostage Prepaid
JohnR Gale
Vice President, Regulatory Afairs
Idaho Power Company
1221 W. Idaho St.
P.O. Box 70
Boise, ID 83707-0070
E-mail: rgale§idahopower.com
via E-mail
US. Maillostage Prepaid
!l~~ERICL.õL ~~
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 9
EXHmITA
SUMMARY OF EXPENSES INCURRD BY IRGATORS
IN CASE NO. IPC-E-07-08
1. Legal Fees:
Eric L. Olsen (Partner):
Dave Bagley (Associate):
Sally Beitia (Paralegal):
81.5 hrs (f $175.00
2.5 hours (f $145.00
3.0 hours (f $75.00
Costs:
Tele. Conf./Long distance:
Postage:
Travel/leage
Total Work and Costs:
2. Consultant Anthony J. Yankel:
287 hrs (f $125 per hour
Expenses:
Travel, room and meals
Total Work and Costs:
TOTAL FEES AND EXPENSES:
$14,262.50
$ 362.50
$ 225.00
$ 84.87
$ 0.00
$ 718.69
$15,653.56
$35,875.00
$0.00
$35,875.00
$51,528.56
RACINE OLSON NYE BUDGE & BAILEY, CHARTERED
IDAHO IRRIGATION PUMPERS ASSOCIATION
710.1518532
Fee Hours
Date Att Rate to Bil Amount
6113/2007 ala 175 0.2 $35.00 TELEPHONE CONFERENCE WITH MARK MICKELSON;
TELEPHONE CONFERENCE WITH RICK GALE RE: RATE
CASE
6113/2007 ELO 175 0.4 $70.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE: IPC
CASE FILING AND STRATEGY RE: SAME; CALL BARTO
KLINE RE: GETTING ELECTRONIC COPY OF FILING
6118/2007 ELO 175 0.2 $35.00 REVIEW IPCO FILING AND SEE THAT FILING IS
ORGANIZED FOR REVIEW
6119/2007 ELO 175 0.2 $35.00 REVIEW EMAIL FROM TONY YANKEL; EMAIL BART KlI
RE: GETTING E-COPY OF FILING
6/2112007 ELO 175 0.5 $87.50 CONFERENCE WITH RANDY LOBB RE: IPCO RATE CASE
ISSUES
6/29/2007 ELO 175 2.3 $402.50 CONFERENCE WITH MARK MICKELSEN AND IDAHO
POWER REPRESENTATIVES ABOUT CURRENT RATE
CASE AND STATUS OF PEAK REWARDS PROGRAM
7/112007 ELO 175 0.2 $35.00 SEE THAT PETITION TO INTERVENE IS PREPARED
7/212007 DB 145 0.7 $101.50 REVIEW AND REVISE PETITION TO INTERVENE (ROCK
MOUNTAIN POWER); SEE THAT PETITION IS FILED
7/19/2007 DB 145 1.8 $261.00 REVISE FIRST DATA REQUEST AND SEE THAT SAME IS
FILED AND SERVED TO APPROPRIATE PARTIES
7/23/2007 ELO 175 0.8 $140.00 REVIEW IP'S RESPONSE TO STAFFS DATA REQUESTS;
CONTINUED REVIEW OF IP FILING; REVIEW IDAHO
POWER PROPOSED SCHEDULING AND FORWARD ON TO
TONYYANKEL
7/24/2007 ELO 175 1.1 $192.50 REVIEW IDAHO POWER FILING
7/27/207 ELO 175 0.7 $122.50 REVIEW SECOND DATA REQUESTS AND SEE THAT SAME
ARE SENT OUT; FINALIZE DATA REQUESTS
7/31/2007 ELO 175 0.4 $70.00 REVIEW IDAHO POWER PROTECTIVE AGREEMENT;
EXECUTE EXHIBIT A; EMAIL SAME TO IDAHO POWER
8/212007 ELO 175 0.3 $52.50 FINALIZE SECOND DATA REQUEST AND SEE THAT SAM
IS SENT
8/6/2007 ELO 175 0.1 $17.50 REVIEW STAFF DATA REQUEST AND FORWARD TO
YANKEL
8/10/2007 ELO 175 0.3 $52.50 REVIEW SCHEDULING ORDER AND CALENDAR THE SAME
8/14/2007 ELO 175 0.3 $52.50 TELEPHONE CONFERENCE WITH JEFF PHAUL RE:
PROVIDING PRE-FILED TESTIMONY IN IDAHO POWER
CASE
8/2212007 ELO 175 0.3 $52.50 SEE THAT IDAHO POWER DATA REQUESTS ARE
PREPARED AND SERVED ON COMPANY; EMAILIIPA
MEMBER E: GIVING LAY TESTIMONY IN RATE CASE
8/24/2007 ELO 175 0.3 $52.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUE SON IDAHO POWER RATE CASE
9172007 ELO 175 1.4 $245.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
FINAL DATA REQUESTS TO IDAHO POWER; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: SAME;
FINALIZE DATA REQUESTS AND SEE THAT SAME ARE
SERVED UPON IDAHO POWER
9/17/2007 ELO 175 $175.00 EMAILL YNN TOMINAGA RE: IRRIGATOR CONFERENCE
CALL; TELEPHONE CONFERENCE WITH LYNN TOMINAGA
RE: SAME; TELEPHONE CONFERENCE WITH JEFF PAHL
RE: MEETING; TELEPHONE CONFERENCE WITH DAVE
PICKETT RE: IIPA MEETING ON IDAHO POWER RATE
ATTACHMENT 1
CASE; TELEPHONE CONFERENCE WITH DEAN
STEVENSON RE: IIPA MEETING ON IDAHO POWER RAT
CASE
9/18/2007 ELO 175 0.9 $157.50 TELEPHONE CONFERENCE WITH STAFF RE: ISSUES
WITH IDAHO POWER RATE CASE FILING; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME
10/10/2007 ELO 175 0.2 $35.00 REVIEW YANKEL DRAFT TESTIMONY
10/15/2007 ELO 175 0.6 $105.00 CONTINUED REVIEW OF DRAFT TESTIMONY; TELEPHON
CONFERENCE WITH TONY YANKEL RE: IDAHO POWER
CASE AND REVIEW OF TESTIMONY; CALL AND LEAVE
MESSAGE WITH JEFF PAHL
10/15/2007 ELO 175 0.6 $105.00 CONTINUED REVIEW OF YANKElS DRAFT TESTIMONY
10/16/2007 ELO 175 3 $525.00 CONTINUED REVIEW OF YANKEL DRAFT TESTIMONY;
TELEPHONE CONFERENCE WITH TONY YANKEL AND
REVIEW TESTIMONY; TELEPHONE CONFERENCE WITH
MARK MICKELSEN RE: ISSUES IN IDAHO POWER RATE
CASE; REVIEW EMAIL RE: PROPOSED CHANGE OF
SCHEDULING ORDER
10/17/2007 ELO 175 0.8 $140.00 REVIEW EMAILS FROM INTERVENORS RE: CHANGE IN
IDAHO POWER SCHEDULING; EMAIL PARTIES RE:
IRRIGATOR POSITIONS; TELEPHONE CONFERENCE WIT
TONY YANKEL RE: SAME
10/17/2007 ELO 175 0.3 $52.50 TELEPHONE CONFERENCE WITH RANDY LOBB RE:
IDAHO POWER RATE CASE; CALL AND LEAVE MESSAGE
WITH WELDON STUTZMAN RE: SETTLEMENT
NEGOTIATION
10/23/2007 ELO 175 $175.00 PREPARE FOR IDAHO POWER SETTLEMENT
DISCUSSIONS
10/24/2007 ELO 175 3 $525.00 TRAVEL TO BOISE FOR SETTLEMENT DISCUSSIONS (0
WAY)
10/24/2007 ELO 175 3.2 $560.00 PREPARE FOR SETTLEMENT MEETINGS; ATTEND IDAHO
POWER SETTLEMENT MEETINGS; CALL AND LEAVE
MESSAGE WITH YANKEL RE: SAME; TELEPHONE
CONFERENCE WITH LYNN TOMINAGA RE: SAME;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES RAISED IN IDAHO POWER RATE CASE
11127/2007 ELO 175 0.7 $122.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
STATUS OF IDAHO POWER DIRECT TESTIMONY
11/30/2007 ELO 175 1 $175.00 REVIEW YANKEL DRAFT DIRECT TESTIMONY
1213/2007 ELO 175 4.9 $857.50 REVIEW YANKEL DRAFT DIRECT TESTIMONY; LEGAL
RESEARCH RE: CASE ON DISCRIMINATORY RATES
1214/2007 ELO 175 2.2 $385.00 CONTINUED REVIEW OF YANKEL DRAFT DIRECT
TESTIMONY; EMAIL YANKEL RE: TESTIMONY COMMENT
CALL AND LEAVE MESSAGE WITH JEFF PAHL RE:
TESTIMONY; TELEPHONE CONFERENCE WITH MARK
MICKELSEN RE: TESTIMONY AND CONFERENCE CALL
1215/2007 ELO 175 1.2 $210.00 CONFERENCE CALL WITH TONY YANKEL AND MARK
MICKELSEN; CONFERENCE CALL WITH JEFF PAHL AND
TONYYANKEL
1216/2007 ELO 175 1.1 $192.50 TELEPHONE CONFERENCE WITH TONY YANKEL AND
REVIEW FINAL COMMENTS ON TESTIMONY; TELEPHONE
CONFERENCE WITH LYNN TOMINAGA RE: STATUS OF
CASE AND FILING DEADLINE; DRAFT TESTIMONY OF
MARK MICKELSEN
121/2007 ELO 175 0.4 $70.00 GATHER EXHIBITS FOR YANKEL TESTIMONY; FINAlIZ
YANKEL DIRECT TESTIMONY; TELEPHONE CONFERENCE
WITH DEAN STEVENSON RE: PROVIDING TESTIMONY
1219/2007 ELO 175 3 $525.00 DRAFT TESTIMONY OF JEFF PAHL; CONFERENCE WITH
JEFF PAHL RE: SAME AND FINALIZE TESTIMONY
12110/2007 SAB 75 2.1 $157.50 CONFERENCE WITH ATTORNEY OLSEN RE: EXHIBITS
AND FILING; ORGANIZE EXHIBITS; LETTER TO JEWE
CERTIFICATE OF SERVICE; CREATE SEARCHABLE DIS
FOR REPORTER
12110/2007 ELO 175 4.5 $787.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
FINALIZING TESTIMONY; CONTINUED DRAFTING OF
TESTIMONY OF MARK MICKELSEN AND TELEPHONE
CONFERENCE WITH STEPHANIE MICKELSEN RE: SAME;
TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
REVIEW OF TESTIMONY; FINALIZE TESTIMONY AND
EXHIBITS AND SEE THAT SAME IS FILED
1211112007 SAB 75 0.5 $37.50 TELEPHONE CONFERENCE WITH IPUC CLERK; CREATE
SEARCHABLE DISK
1211212007 SAB 75 0.4 $30.00 EMAIL FROM IPUC RE: EXHIBITS TO YANKEL TESTIM
CLARIFY FOR CLERK
12119/2007 ELO 175 1.9 $332.50 PARTICIPATE IN IDAHO POWER SETTLEMENT
CONFERENCE; TELEPHONE CONFERENCE
12126/2007 ELO 175 2.3 $402.50 REVIEW DISCOVERY REQUEST; CALL AND LEAVE
MESSAGE WITH YANKEL; TELEPHONE CONFERENCE
WITH TONY YANKEL RE: REBUTTAL TESTIMONY; SEE
THAT YANKElS WORK PAPERS ARE PROVIDED TO
PARTIES TO CASE
12131/2007 ELO 175 0.7 $122.50 PREPARE DISCOVERY RESPONSE TO IDAHO POWER
AND SEE THAT SAME IS SERVED
1/212008 ELO 175 2.9 $507.50 REVIEW DRAFT OF YANKEL REBUTTAL TESTIMONY;
REVIEW LEGAL RESEARCH ON DISCRIMINATORY RATES
AND AUTHORITY OF COMMISSION
1/3/2008 ELO 175 1.9 $332.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
REVIEW OF REBUTTAL TESTIMONY; TELEPHONE
CONFERENCE WITH RANDY LOBB RE: ISSUES IN THE
RATE CASE
1/4/2008 ELO 175 2.8 $490.00 REVIEW FINAL REBUTTAL TESTIMONY; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME; FINAlIZ
REBUTTAL TESTIMONY AND SEE THAT SAME IS FILED
SEE THAT DISK OF TESTIMONY IS SENT TO COMMISS
1172008 ELO 175 0.4 $70.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
REVIEW OF PARTIES; REBUTTAL TESTIMONY
1/8/2008 ELO 175 0.5 $87.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES RAISED BY STAFF ON GROWTH ISSUES
1/8/2008 ELO 175 0.5 $87.50 TELEPHONE CONFERENCE WITH BRENDA TOMINAGA RE:
STATUS OF IDAHO POWER RATE CASE; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: CONTINUED
REVIEW OF REBUTTAL TESTIMONY
1110/2008 ELO 175 0.3 $52.50 REVIEW E-MAIL RE: SETTLEMENT CONFERENCE;
TELEPHONE CONFERENCE WITH CONNIE BUCY RE:
GETTING MS WORD COPY OF TESTIMONY
111112008 ELO 175 1.2 $210.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
STATUS OF IDAHO POWER SETTLEMENT; TELEPHONE
CONFERENCE WITH TONY YANKEL E-MAIL E-COPY OF
DIRECT REBUTTAL TESTIMONY TO CONNIE BUCY; CAL
AND LEAVE MESSAGE WITH RANDY LOBB; TELEPHONE
CONFERENCE WITH RANDY LOBB RE: IDAHO POWER
CASE AND SETTLEMENT ISSUES
1114/2008 ELO 175 0.8 $140.00 TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
STATUS OF IDAHO POWER CASE AND SETTLEMENT
ISSUES; TELEPHONE CONFERENCE WITH TONY YANKEL
RE: UPCOMING SETTLEMENT CONFERENCE AND IPC
INTERRUPTIBllITY CREDIT PRICING
1115/2008 ELO 175 2.7 $472.50 REVIEW VOICEMAIL FROM PETER RICHARDSON;
CONFERENCE WITH TONY YANKEL RE: SETTLEMENT
NEGOTIATIONS; PREPARE FOR SETTLEMENT
NEGOTIATIONS; REVIEW REBUTTAL TESTIMONY OF
COMPANY AND INTERVENORS
1/16/2008 ELO 175 3 $525.00 TRAVEL ONE WAY TO BOISE
1/16/208 ELO 175 3.9 $682.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
SETTLEMENT ISSUES; TELEPHONE CONFERENCE WITH
PETER RICHARDSON RE: SETTLEMENT ISSUES; ATTEN
IDAHO POWER SETTLEMENT CONFERENCE; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: TERMS OF
SAME AND PEAK REWARDS ISSUES; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SETTLEMENT
TERMS; CONTINUE WITH SETTLEMENT CONFERENCE
1117/2008 ELO 175 0.9 $157.50 TELEPHONE CONFERENCE WITH DEAN STEVENSON RE:
IDAHO POWER SETTLEMENT AND PEAK REWARDS
PROGRAM WORKING GROUP; TELEPHONE CONFERENCE
WITH JEFF PAHL RE: SAME; TELEPHONE CONFERENCE
WITH LYNN TOMINAGA RE: RESULTS OF SETTLEMENT
NEGOTIATIONS
1118/2008 ELO 175 3.5 $612.50 DRAFT SETTLEMENT AGREEMENT LANGUAGE FOR PEAK
REWARDS PROGRAM IN STIPULATION; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: COMMENTS ON
SETTLEMENT STIPULATION; REVIEW COMMENTS FROM
BOARD MEMBER; TELEPHONE CONFERENCE WITH BART
KLINE AND MAGGIE BRILZ RE: CHANGES TO
SETTLEMENT STIPULATION
1/2212008 ELO 175 0.4 $70.00 REVIEW REVISED STIPULATION
1/23/2008 ELO 175 3 $525.00 TRAVEL TO BOISE FROM POCATELLO
1/23/2008 ELO 175 1.3 $227.50 PREPARE FOR AND ATTEND AND PARTICIPATE IN IDA
POWER HEARING TO PRESENT SETTLEMENT
STIPULATION
215/2008 ELO 175 1.5 $262.50 PREPARE APPLICATION FOR INTERVENOR FUNDING
216/2008 ELO 175 1.5 $262.50 CONTINUE PREPARE APPLICATION FOR INTERVENOR
FUNDING AND FILE
TOTAL FEES 87 $14,850.00 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
2007 IDAHO POWER GENERAL RATE CASE FILING
Cost
Date Amount
10/17/2007 $84.87 TELECONFERENCE CHARGES
11/15/2007 $226.98 RT MILEAGE POCATELLO-BOISE - 10/24 - ELO
214/2008 $491.71 RT MILEAGE POCATELLO-BOISE -1/16 AND
1123 - ELO; MEALS IN BOISE - ELO
TOTAL COSTS $803.56 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
2007 IDAHO POWER GENERAL RATE CASE FILING
UlOI.5æ0
Date Co Descriptioni:..
June 25 4 Review testiony and exlbits of Lamont Keen, Steven Keen, Lori
Smith, and Schwendian.
29 2 Review fig in preparation for conference cal; attend meetig with
Irrgators and Idaho Power by phone to discuss Idaho Powers position
on the rate case and other issues related to rates and costs of servce.
July 6 2 Review testiony and exlbits ofBri as well as testiony of Gale;
compare Bri exlbits to those of the last case.
9 6 Develop intial set of interrogatories regardi bilg usage data, load
research data bil frequency data, system supply and sales, margial
cost data, scheduled maitenance, development of distrbution data.
10 2 Review data regardig Ditrbution substations fonnd in Tatu's
exlbit and compare it to similar data provided by Bri in the last case.
25 1 Review data responses to Industral Customers Request Set 3 and
manpulate the costs of servce studies provided.
Aug 1 4 Review cost of serce studies provided by the Company in ths case as
well as the development of alocation factors.
3 6 Review the Company's last two IRP's for costs associated with growt
and the DSM programs that have been developed to reduce the
increase in energy and the increases that are takg place in peak
8 6 Review other data regardig tie of day rates tht may be usefu for
smaler farers for which the Company does not want to include in its
irgation load management program; review possible impacts of these
10 6 Review usage data thoughout each month by hour to develop
relationships between tie of day and day of the week; develop
patterns of usage from hourly data by day of the week; develop
scenaros regardig how farers can shift usage into ties when their
13 7 Review usage data thoughout each month by hour to develop
relationships between tie of day and day of the week; develop
patterns of usage from hourly data by day of the week; develop
scenaros regardig how farers can shift usage into ties when their
Page 1 ATTACHMENT 2
Ul
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Date Co Descriptione:
21 8 Review data responses on Micron regadig usage levels of varous
classes by month in order to see how data fit with the Company's fied
usage data; compile historic usage data ofIrrgators in Idao and
Oregon and compare with that presented in the FERC Form l's: review
losses and impact oflosses in the Company's fig with the losses that
have historicaly be recorded in the FERC Form l's.
22 6 Review responses to Irrgatots fist data set; review Idaho Powers
hourly purchases and prices; review the extent to which load research
data covers varous customer sizes.
Sept 6 3 Review data responses regardig Irrgator set 2 regardig PCA
predicted costs under varous scenaros; analyze data provided with
responses in order to show consistency between responses.
7 7 Review data associated with the company's response 2- 1 to the
Irrtors and compare how the montly projections for 2007
compared with the actuals for 2006 with respect to average usage,
maxum usage, and light-load and heavy load usage; develop
interrogatories to cover problems or inconsistencies uncovered.
10 2 Review response to LIP A 2-2 and develop relationships between what
the model predicted for 2007 on an hourly basis with the actu results
of2006 by hour and by month for peak, average and on-peak and off-
12 4 Analyze hourly system costs data in order to form relationships
between usages and costs by hour of the day and day of the week.
27 2 Review recent data responses from the Company regardig the
Irrgators and the US Deparent of Energy.
28 8 Review data regardig load management program for Irrgators: review
past sumares of irgation load management that were prepared by
the Company; review hourly information regardig usage of Irrgation
customers on Schedule 23.
Oct 1 7 Review al past data responses to the Irgators; review diection of data
responses for Micron and the US Deparent of Energy; calculate
costs of purchase power and suilus sales durg the hour of the
system peaks for the last four years.
Page 2
UlOI.5æ0
Date Co Descriptioni:-
2 8 Develop overa diection oftestiony regardi problems with
normaled sales data for power cost calculations, lopsided growt,
inappropriate or lack of interrptions when they should have occured,
reflections on why cost-of-servce results do not reflect cost causation,
and credit for Schedule 23 customers; develop mstorical backgromid to
list mstoric usage over varous classes and the mstoric alocation of
costs and bilg determinants for Irrgators.
3 8 Develop testiony regardig lutoric usage, mstoric alocation factors
and the mis-match; review and develop data to support chanes in
alocation factors and amomit of plant alocated over the last 14 years.
4 7 Develop data and exlbits that establih a weightig for growt that is
reflective of the next ten years out and is in lie with the Company's
support behid its base case alocation method.
5 8 Develop testiony regardig the weightig of alocation factors that
wi reflect the growt that is to take place along the system and how
that fits in with the Company's Base Case alocation method; develop
testiony regardig the problems with the curaient customers in
the load research data beig too few on the days of the peak as well as
8 8 Develop testiony regardig the BP A credit; develop testiony
regardig the irgation peak rewards program, includig the success it
has enjoyed or the lack there o( a development of a proper level of
credit based upon both the Company's avoided capacity costs and the
report that was pedormed by a consultant for PaciCorp.
9 8 Work on developing numbers for the level of the credit that can be
provided for the Irrgation Peak Rewards program; develop appropriate
testiony that outles the method for ths calculation of a credit.
10 8 Develop testiony regardi the development of a tie-of-day rate for
Irrators; review draft testiony and tighten up the draft as far as
wrtig errors are concerned.
11 6 Develop additional backgromid and support for the $94/kW margial
cost of avoided capacity arguent.
12 8 Develop load research data in a form where it can be analyzed to
determine what the Irrgation class as a whole uses on an hourly basis
so that a tie-of-day analysis can be performed in order to develop a
rate that is neutral if there is no smft in load.
Page 3
Date
15
Nov 26
16
17
25
27
28
29
29
30
Ul
.~æo
Co
e:Description
Contiue to work over load research data in order to develop an
average iigator usage pattern for a tie of day scenaro; develop a
tie of day rate based upon average usage pattern and other concepts
or stated goals of a good tie of use program.
8
8 Review other margial cost data in support of the $98/kWh fie used
in the testiony; utied the margial cost data that was provided in
the case as a workpaper for generation; star to put testiony into fial
7 Work to fiale testiony; discussion with Olsen regardig lu
suggested changes.
1 Review proposals regardig where testiony is going as presented by
the pares in the prehearg conference.
5 Review previous draft oftestiony; review testiony of Company
witness Tantu; review the development of the varous cost of serce
studies developed by the Company in th case.
6 Review mstoric usage levels between the Irrgators and the rest of the
Company; review the treatment of bilg deterrenants in ths and
previous cost of servce studies fied by the Company.
7 Review relationsmp oflutoric usage and costs of instalg new
facilties; review report of workshop group that looked into alocations;
wrte testiony regardig growt issues; look into additional way to
measure growt (5 year data verse 10 year data).
7 Review costs ofDSM projects and the cost basis for other planed
resource additions regardi levelied costs; review 2006 and the 2004
IRP's for the costs of varous programs that are being considered and
8 Review costs ofDSM projects and the cost basis for other planed
resource additions regardig levelied costs; review 2006 and the 2004
IRP's for the costs of varous programs that are being considered and
implemented; converations with the Company regardig the treatment
of costs associated with the Residential and Commercial"in-place"
DSM programs; wrte testiony.
8 Review the Company's concern regardig free-rider and develop a
method that would speak to the Company's concern without hur al
customers; fiale rates and rate desig to be charged for customers
curai; address the difference in recommendations in ths case and
the stipulation in the PacifiCorp case; wrte testiony.
Page 4
UlOI.5æ0
Date Co Descriptione=
Dec 3 7 Make fial review of data responses and data I developed in order to
insure that the testiony is factualy based.
4 6 Make fial review of data responses and data I developed in order to
insure that the testiony is factualy based.
5 2 Conversations with Olsen and Mick1eson regardi the Idaho Power
testiony; mak corrections to testiony.
6 6 Final review oftestiony; make appropriate changes and corrections.
7 6 Review tie-of-day material being discussed by Idaho Power for the
smaler commercial customers; review Dr. Peseau's testiony
regardig forecast test year, revenue adjustments, and his proposed
changes in cost-of-servce studies; review accompanyig exhbits.
10 1 Review Dr. Peseau's testiony regardig cost of servce studies.
12 1 Conversations with Olsen; attempt to connect with conference cal;
review of Hessing testiony.
20 1 Review testiony of Readig and make notes regardig agreement and
disageement.
21 2 Review testiony of Denns Goins and Kevi Higgis and make notes
regardi agreement and diageement.
26 2 Review data requests from Idaho Power; review my testiony
regardig what was being sought; develop data responses; discussion
27 8 Review testiony of other pares; outle differences of position
between them and my Direct testiony; wrte rebuttal testiony.
28 8 Review testiony of other pares; outle differences of position
between them and my Direct testiony; wrte rebuttal testiony.
Jan 4 i Discussions with Olsen regardig draft testiony; rewrtig some of
the testiony.
5 2 Discussions with Olsen regardig draft testiony; rewrtig and
fialg the testiony.
Page 5
Date
7
15
16
18
Total 287
Ul
.lfæo
Co
i=Description
Read rebuttal testiony of Company, Peseau, and Hessin; discuss
with Olsen.
2
2 Review varous load control options, prices, ties, of the varous
Company's and formulate information to Olsen to use; conversations
with Olsen regadig same as well as stipulation discussion points.
2 Multiple conversations with Olsen regardig stipulation; attend
stipulation conference via phone.
1 Review proposed language in stipulation and that proposed by Olsen;
discussion with Olsen.
287 hours (g $125 per hour = $35,875
Page 6