20090105Intervenor Funding Application.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
DAVID E. ALEXANDER
LANE V. ERICKSON
PATRICK N. GEORGE
scon J. SMITH
STEPHEN J. MUHONEN
BRENT L. WHITING
JUSTIN R. ELLIS
JOSHUA D. JOHNSON
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN
THOMAS J. BUDGE:
CANDICE M. MCHUGH
JONATHAN M. VOL YN
MARK A. SHAFFER
RACINE OLSON NYE BUDGE & BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: (208) 433-167
www.racinelaw.net
IDAHO FAL OFFICE
477 SHOUP AVENUE
SUITE203A
IDAHO FALLS, 108342
TELEPHONE: [phone]
FACSIMILE: (208) 528-109
TELEPHONE [phone]
FACSIMILE [phone]
COEUR D'ALNE OFFICE
250 NORTHWEST
BOULEVARD, SUITE 106
COEUR D'ALENE, 1083814
TELEPHONE: [phone]
SENDER'S E-MAIL ADDRESS:efo(§racinefaw.net
All OFFES TOll FREE
[phone]
LOUIS F. RACINE (1917-2005)
WILLiAM D. OLSON. OF COUNSEL
Januar 2, 2009 ~e:;,
C-:::z
Iui
;:m
(")mJean Jewell
IPU C Commission Secretar
472 W. Washington
Boise, Idaho 83702
::::
"BNCJ
Re: IPC-E-08-10
Dear Mrs. Jewell:
Enclosed for filing you will find the original and seven (7) copies of the Application for
Intervenor Funding of The Idaho Irrgation Pumpers Association, Inc.
ERIC L. OLSEN
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Enclosures ;l.~ci ~e ic?",t-el""..+ rAt~~(litly.f¡I-e. H.-v't i-c;(eJ .Ji.,~~ "iei+P.c: Service List (via regular mail) 7l""(cs ¿ø;c"l", nf~-llA
N:\RCB\l5 i 85\IC-E-08- i O\iean jewell Ii.. i .2.09.wp
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Vå'ÎU I~AL
.-;:.'...Eric L. Olsen, ISB #4811 ¡.
~i~~: g~¡~~È~~' BUDGE & innq JAtl -5 AM 9:25
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Attorneys for Intervenor
Idaho Irrgation Pumpers Association, Inc.
BEFORE TH IDAHO PUBLIC UTIITIES COMMSSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
)
)
)
)
)
CASE NO. IPC-E-08-10
APPLICATION FOR INRVENOR FUING OF
THE IDAHO IRGATION PUMERS ASSOCIATION, INC.
COMES NOW the Idaho Irrgation Pumpers Association, Inc. ("Irrigators"), by
and through counsel of record, Eric L. Olsen, and hereby respectfully makes application
to the Idaho Public Utilities Commission ('"Commission") for intervenor fuding,
pursuat to Idaho Code § 61-617A and IDAPA 31.01.01.161 through .165, in Idaho
Power Company's ("IPC") general rate case, as follows:
(A) A sumar 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 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 sumary and are incorporated
by reference.
(B) The Irrigators' Vice President, Sidney F. Erwin, its legal counsel, Eric L.
Olsen, and its consultant, Anthony J. Yanel, P.E., fully paricipated in these
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - i
proceedings. Furher, Irrgator's President, Mark Mickelsen, its Executive Director,
Lynn Tominaga, its Board Member, Dean Stevensen, and other members of irrigation
class provided testimony at the public hearngs held in Pocatello, Twin Falls, and Boise,
Idaho. Procedurally, this case was a full blown rate case with direct and rebuttal
testimony being fied and all paries preparing for and attending the technical hearngs
held on December 16th through December 19th, 2008.
Irrgators' Vice President, Sidney F. Erwn, testified that the expansion of ground
water pumping corresponded with the surplus of cheap, clean electricity available from
IPC's Hells Canyon complex. He testified that irrigation pumping has also expanded due
to the switch from flood to more effcient sprinkler irrgation. However, he testified that
the growth of additional ground water pumping has been static since the 1992 when a
moratorium on new ground water rights was decreed. This lack of irrgation water right
growth has corresponded with a lack of growth of electrcity demand within the Irrigation
Class for the last two decades and into the foreseeable futue.
As a paricipate in past and present integrated resource planing committees, Mr.
Erwin testified that the primar cause of growt on IPC's system and the corresponding
need for this current rate increase is the residential and commercial load growth in the
Treasure Valley. He also noted that IPC's class cost of service study assigns a
disproportionate amount of growth related costs to the Irrgation Class notwithstanding
the fact that the Irrigation Class is not causing the growt and he urges the Commission
that this needs to be corrected.
Mr. Erwn also testified that he has paricipated in IPC's Irrigation Peak Reward
Program ("Program"). His paricipation in this Program provides him with a voluntar
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 2
means of controlling his electricity costs, while at the same time reducing Irrgation Class
load and corresponding summer peak costs allocated to the Irrgation Class. IPC's
system is also benefited by the Program's reduction of approximately 40 MW of system,
sumer peak load, which helps slow the pace of growth related costs driving the need for
rate increases. He further testified that the Commission is curently considering changes
to the Program that would allow IPC the ability, at its options, to interrpt electricity to
paricipating irrgator's pumps during critical sumer peak hours. This change has the
potential to significantly benefit the IPC system by reducing summer peak load by an
estimated 112 to 200 MW and fuher slow growth related costs.
The Irrgators' consultant, Anthony J. Yanel, testified that there has been very
rapid growth on the IPC's system. However the Irrigation Class load has been flat for the
last 25 years. The cost of growth affects all aspects of the IPC's operations. IPC's cost
of service study allocates costs of growth on the assumption that all classes are growing
equally. This erroneous assumption results in the Irrgation Class and other static classes
getting allocated a disproportionate amount of growth related costs notwithstanding the
fact that they are not causing the bulk of these growth related costs. As a means of
addressing the growth issue, Mr. Yankel testified that IPC's cost of service study should
be modified to match the marginal cost allocation factors with the customer classes
causing the increase in these marginal costs. His proposed modifications utilize cost of
service principals and are applied prospectively in a nondiscriminatory maner. When
the impact of disproportionate growth is properly taken into account, the Irrigation Class
rate of retur is above the system average and he asks the Commission to give the
Irrgation Class a below average rate increase.
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 3
Mr. Yanel also testified that the Irrgation Peak Rewards Program ("Program") is
curently being revised to allow IPC to interrpt paricipating irrgators' pumps at their
option during sumer peak times in June and July. This revision to the Program should
greatly increase paricipation levels and become a major resource for IPC to use in
controllng its sumer peak load. These changes should be in place for next sumer's
Irrgation season and system peak loads. Thus, Mr. YaneI urged the Commission that
any consideration of cost of service and revenue responsibility for the Irrgation Class
should reflect the fact that there wil be major changes to the system peak loads when
these rates are in effect as well as the Irrgation Class' contribution to those peak loads.
Mr. Yanel further testified that IPC has historically allocated Sales For Resale
revenues on a simplistic basis (anual energy usage and/or generation demand
responsibility). Data and computing techniques are available today to match these sales
on an hourly basis with the cost causation that makes these sales possible. An example is
presented as to how this can be done and a recommendation is made to consider such
techniques for future cases to benefit all customer classes.
(C) The expenses and costs incured by the Irrgators set fort in Exhibit A
and accompanying attchments are reasonable in amount and were necessarly incured.
The expenses and costs were incured in reviewing the Company's fiing and intervenor
testimony (direct and rebuttal), preparing and reviewing approximately 35 Irrgators data
requests and responses, drafting and filing direct testimony, drafting and fiing rebutt
testimony, preparing cross examination questions for varous witnesses, and paricipating
in the public and technical hearngs held by the Commission. Without incurng these
APPLICATION FOR INTERVENOR FUNING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 4
expenses and costs, the Irrgators would not have been able to fully paricipate in this
matter.
(D) The costs described in Paragraph (A) above constitute a financial hardship
for the Irrigators. The Irrigators curently have approximately $5,000.00 in the ban with
outstanding accounts payable from the IPC-E-08-23 case, this case (through the technical
hearings), the PAC-E-08-07 case and expenses of operations totaling approximately
$45,000.00.
The Irrigators are an Idaho nonprofit corporation qualified under I.R.C. §
501(c)(5) representing farm interests in electric utility rate matters affecting farers in
southern and central Idaho. The Irrigators rely solely upon dues and contributions
voluntarly paid by members, together with intervenor fuding, to support activities.
Each year mailings are sent to approximately 7500 Idaho Irrgators (approximately two-
thirds in the Idaho Power Company service area and one-thrd in the RMP service area),
soliciting anual dues. The Irrgators recommend members make volunta contrbutions
based on acres irrgated or horsepower per pump. Member contributions have been
fallng which is believed to be attbutable to the curent depressed economy and
increased operating costs and threats, paricularly 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 participation in rate cases. The Executive Director,
Lynn Tominaga, is the only par-time paid employee, receiving a retaner plus expenses
APPLICA TION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 5
for office space, office equipment, and secretaral services. Officers and directors are
elected anually and serve without compensation.
It has been and continues to be a financial hardship for the Irrgators to fully
paricipate in general rate cases such as this one due to the time and expense that has to
be incured to fully paricipate in such a case. As a result of the Irrgators' financial
constraints, paricipation in case review, fiing of testimony and cross-examination has
been selective and, primarly, on a limited basis to the extent possible.
(E) The Irrgators' positions urged to be adopted by the Commission
materially differed from those addressed by the Commission Staff and other paries on
several important points. First, the Irrgators 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
and based on cost of service principals. No other pary addressed this issue head on. If
this issue is not addressed, then the growth issue will continue to be dealt with on a
piecemeal basis like IPC is doing with the revisions to its Rule H Tarff for new service
attachments and distribution line installations and alterations (IPC-E-08-22) and with the
new proposed Hoku Facility energy contract that prices portions of the energy to cover
the marginal costs incured for the increased load Hoku will put on IPC's system (IPC-E-
08-21). Second, as a outgrowth of the 2007 rate case, the Irrgators have brought to the
Commission revisions to the IPC Peak Rewards Program that should signficantly
increase paricipation and should significantly shave peak summer load and slow the
costs of growth on IPC's system to benefit all customer classes. Finally, with the
changes in technology, the Irrigators urged that the Commission to fuher look at how
APPLICA nON FOR INTERVENOR FUNDING OF THE
IDAHO IRRGA nON PUMPERS ASSOCIA nON, INC - 6
sales for resale are determined. Specifically, data and computing techniques are available
today to match these sales on an hourly basis with the cost causation that makes these
sales possible. The Irrgators urged the Commission to look into this matter further to see
if costs and benefits of sales for resale can be better assigned to the classes causing the
costs or those classes that are allowing the benefits to be obtained. The Commission
Staff did not address these issues.
(F) The Irrgators' paricipation addressed issues of concern to the general
body of users or consumers on IPC's system. All customer classes have an interest in
finding a method to equitably pay for the cost ofIdaho Power's system growt. Furher,
the Peak Rewards Program has enabled IPC in the past to shave approximately 40 of load
during the sumer system peak and will in the futue shave more than 112 MW of load
durng the summer system peak if the proposed changes are adopted. 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. Finally, looking at the
sales for resale issues ensures that costs and benefits of sales for resale wil be properly
assigned to all customer classes.
(G) The Irrgators represent the irrgation class of customers under Schedule
24.
Based on the foregoing, it is respectfully submitted that the Irrgators 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 IDAP A
31.01.01.161 through .165.
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 7
DA TED this 2nd day of Januar, 2009.
APPLICA nON FOR INTERVENOR FUNDING OF THE
IDAHO IRRGA nON PUMPERS ASSOCIA nON, INC ~ 8
ERIC L. OLSEN, Attorney for
Idaho Irrigation Pumpers Assn., Inc.
CERTIFICATE OF MAING
I HEREBY CERTIFY that on this2nd day of Januar, 2009, I served a true,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
i jewell (ßpuc .state.I d. us
U.S. MaillPostage Prepaid
E-Mail
Facsimile
_ ..vernight Mail
V Hand Delivered
Baron L. Kline
Lisa D. Nordstrom
Donovan E. Walker
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
bkline(ßidahopower.com
Inordstrom(ßidahopower .com
dwalker(ßidahopower.com
v U.S. MaillPostage Prepaid..-Mail
Facsimile
Overnight Mail
Hand Delivered
John R. Gale
Vice President, Regulatory Affairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
rgale(ßidahopowef .com
v-.S. MaillPostage Prepaid
~E-Mail
Facsimile
Overnight Mail
Hand Delivered
Peter J. Richardson
RICHARDSON & O'LEARY PLLC
515 N. 2ih Street
Boise, ID 83702
peter(ßrichardsonandolear .com
.i¿ ßS. MaillPostage Prepaid
v: E-Mail
Facsimile
Overnight Mail
Hand Delivered
Don C. Reading
6070 West Hil Road
Boise,ID 83703
dreading(ßmindspring.com
~ lLS. MaillPostage Prepaid/"E-Mail
Facsimile
Overnght Mail
Hand Delivered
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 9
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise,ID 83702
bmpurdycmhotmail.com
Lot R. Cooke
Arhur Perr Bruder
Offce of the General Counsel
United States Deparment of Energy
1000 Independence Ave. SW
Washington, DC 20585
Lot. Cooke(iq .doe.gov
Arhur.Bruder(ßhq .doe. gov
Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
detheridge(ßexeterassociates.com
Michael L. Kurz
Kur J. Boehm
BOEHM, KURTZ & LOWRY
36 East 7th St., Suite 1510
Cincinnati, OH 45202
rnurz(ßBKLlawfrm.com
kboehr(ßBKLlawfrm.com
Kevin Higgins
Energy Strategies, LLC
Parkside Towers
215 South State Street, Suite 200
Salt Lake City, UT 8411 1
khiggins(ßenergystrat.com
Conley E. Ward
GIVENS PURSLEY LLP
P.O. Box 2720
Boise,ID 83701-2720
cew(ßgivenspursley.com
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 10
~ U.S. MaillPostage Prepaid~-Mail
Facsimile
Overnight Mail
Hand Delivered
i/ !l.S. MaillPostage Prepaid~E-Mail
Facsimile
Overnight Mail
Hand Delivered
v U.S. MaillPostage Prepaid~Mail
Facsimile
Overnight Mail
Hand Delivered
~ !1. MaillPostage PrepaidV"-Mail
Facsimile
Overnight Mail
Hand Delivered
~ U.S. MaillPostage Prepaid~E-Mail
Facsimile
Overnight Mail
Hand Delivered
v ~S. Mail/Postage PrepaidV E-Mail
Fac1imile
Overnight Mail
Hand Delivered
Dennis E. Peseau, Ph.D.
Utility Resources, Inc.
1500 Libert Street SE, Ste. 250
Salem, OR 97302
dpeseau(fexcite.com
Weldon Stutzman
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise,ID 83702
Weldon.Stutzman(fPUC.idaho.gov
Ken Miler
Snake River Allance
P.O. Box 1731
Boise,ID 83701
kriller(fsnakeriveralliance.org
~.S. Mail/Postage Prepaid~-Mail
Facsimile
Overnight Mail
Hand Delivered
V-U.S. Mail/Postage Prepaid~-Mail
Facsimile
Overnight Mail
Hand Delivered
APPLICATION FOR INTERVENOR FUDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - i i
EXIIT A
SUMY OF EXPENSES INCURD BY IRGATORS
IN CASE NO. IPC-E-07-08
1. Legal Fees:
Eric L. Olsen (Parner): 148 hrs CÐ $175.00
Pam Mottishaw (Paralegal): 1.8 hrs CÐ $75.00
$27,380.00
$ 135.00
Costs:
Tele. Conf./Long distance:
Postage:
Travel/Mileage
Lodging & Meals
$ 0.00
$ 16.32
$ 273.78
$ 676.93
Total Work and Costs:$28.482.03
2. Consultat Anthony J. Yanel:
376 hrs CÐ $125 per hour $47,000.00
Expenses:
Travel, room and meals $ 1001.67
Total Work and Costs:$48,001.67
TOTAL FEES AN EXPENSES:
APPLICATION FOR INTERVENOR FUNDING OF THE
IDAHO IRRGATION PUMPERS ASSOCIATION, INC - 12
$76,483.70
ATTACHMNT 1
Trans Hours
Date Atty Rate to Bil Amount
7/9/2008 ELO 185 0.5 92.50 REVIEW FIRST DATA REQUESTS AND SEE THAT SAME
ARE SERVED
7/28/2008 ELO 185 0.4 74.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
IDAHO POWER RATE CASE AND PRELIMINARY ISSUES
7/31/2008 ELO 185 0.2 37.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
IDAHO POWER RATE CASE
8/6/2008 ELO 185 0.2 37.00 CONFERENCE WITH NJ RE: PREPARATION OF SECOND
DATA REQUESTS
8/6/2008 ELO 185 0.2 37.00 REVIEW VOICEMAIL AND EMAIL BART KLINE RE:
PRODUCTION REQUEST
8/7/2008 ELO 185 0.1 18.50 REVIEW AND FINALIZE SECOND DATA REQUESTS
8/18/2008 ELO 185 0.1 18.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
IPCO'S TREATMENT OF REDUCED DEMAND IN THE PE
REWARD PROGRAM PROGRAM
8/25/2008 ELO 185 0.1 18.50 SEE THAT THIRD SET OF INTERROGATORIES ARE
PREPARED
8/29/2008 ELO 185 0.1 18.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
NAMES OF SUBSTATIONS
10/6/2008 ELO 185 2 370.00 REVIEW COMPANY TESTIMONY
10/7/2008 ELO 185 2.4 444.00 CONTINUED REVIEW OF COMPANY TESTIMONY
10/8/2008 ELO 185 2.1 388.50 REVIEW AND REVISE YANKEL TESTIMONY; TELEPHON
CONFERENCE WITH TONY YANKEL RE: TESTIMONY AN
GETIING LAY TESTIMONY; OUTLINE LAY TESTIMONY
10/8/2008 ELO 185 2.6 481.00 CONTINUED REVIEW OF TATUM TESTIMONY; TELEPHO
CONFERENCE WITH SID ERWIN RE: PROVIDING
TESTIMONY; TELEPHONE CONFERENCE WITH YANKEL
RE: SAME AND PRIOR ISSUES WITH GROWTH ARGUME
10/9/2008 ELO 185 1 185.00 CONTINUED REVIEW OF COMPANY TESTIMONY
10/10/2008 ELO 185 0.7 129.50 DRAFT LAY TESTIMONY OF SID ERWIN
10/14/2008 ELO 185 3 555.00 CONTINUE REVIEW OF COMPANY TESTIMONY
10/15/2008 ELO 185 1.4 259.00 CONTINUE REVIEW YANKEL DRAFT TESTIMONY;
TELEPHONE CONFERENCE WITH BRENDA TOMINAGA RE
RECENT IRP MEETING; TELEPHONE CONFERENCE WIT
LYNN TOMINAGA RE: FILING OF TESTIMONY
10/15/2008 ELO 185 0.5 92.50 CONTINUE REVIEW YANKEL'S DRAFT TESTIMONY
10/16/2008 ELO 185 4.3 795.50 CONTINUE REVIEW OF YANKEL'S DRAFT TESTIMONY;
TELEPHONE CONFERENCE WITH SID ERWIN RE:
GROWTH TESTIMONY; CONFERENCE WITH TONY
YANKEL RE: REVIEW OF TESTIMONY
10/17/2008 ELO 185 4.1 758.50 DRAFT TESTIMONY OF SID ERWIN; REVIEW PCA
WORKSHOP MATERIALS RE: WATER SUPPLY ISSUES;
RESEARCH INFORMATION ON PRIOR IPC POSITIONS
THE WATER ISSUE; DRAFT TESTIMONY OF SID ERWI
10/20/2008 ELO 185 4.9 906.50 CONTINUE DRAFTING ERWIN TESTIMONY
10/21/2008 ELO 185 7.8 1,443.00 CONTINUE REVIEW COMPANY TESTIMONY AND PRIOR
TESTIMONY OF PARTIES ON ISSUES; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: REVIEW OF
TESTIMONY TO BE FILED IN THIS CASE
10/22/2008 ELO 185 5.3 980.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
FINAL CHANGES TO HIS TESTIMONY; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: SAME AND
FINALIZE TESTIMONY; CONTINUED REVIEW OF COMP
TESTIMONY; CONTINUE DRAFTING OF ERWIN
TESTIMONY
10/23/2008 ELO 185 9.5 1,757.50 FINISH REVIEW OF COMPANY TESTIMONY; CONTINUE
FINALIZING YANKEL TESTIMONY AND EXHIBITS; FI
DRAFTING OF ERWIN TESTIMONY AND EMAIL FOR
REVIEW
10/24/2008 ELO 185 7 1,295.00 FINALIZE TESTIMONY AND EXHIBITS AND SEE THAT
ARE FILED AND MAILED OUT
10/27/2008 ELO 185 2 370.00 ORGANIZE IIPA FILE; REVIEW INTERVENOR TESTIM .
10/28/2008 ELO 185 1.2 222.00 REVIEW STAFF TESTIMONY
11/11/2008 ELO 185 0.2 37.00 PREPARE DISCOVERY RESPONSES TO IPC
11/17/2008 ELO 185 0.5 92.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE: IP
RATE CASE STRATEGY; 11:30 TO 12:06; TELEPHON
CONFERENCE WITH SID ERWIN RE: STATUS OF RATE
CASE AND TESTIMONY
11/20/2008 ELO 185 1.6 296.00 PREPARE IIPA'S DISCOVERY RESPONSES TO IPC
11/21/2008 ELO 185 1.4 259.00 CONTINUED PREPARATION OF DISCOVERY REQUEST
AND SEE THAT SAME IS SERVED
11/21/2008 PM 75 1.8 135.00 COLLATED MATERIALS FOR DISCOVERY RESPONSES
AND SENT OUT
11/25/2008 ELO 185 0.3 55.50 REVIEW EMAIL ABOUT CONFERENCE CALL; RESPONSE
WITH COPY OF NOTICE OF PUBLIC HEARINGS
12/1/2008 ELO 185 0.6 111.00 TELEPHONE CONFERENCE WITH DEAN STEVENSON
RE: IPC RATE CASE AND TESTIFYING AT PUBLIC
HEARINGS; TELEPHONE CONFERENCE WITH DAVE
PICKET RE: SAME
12/2/2008 ELO 185 2.2 407.00 REVIEW AND FINALIZE YANKEL REBUTTAL TESTIMONY
12/3/2008 ELO 185 2.7 499.50 CONFERENCE CALL WITH TONY YANKEL; CONTINUED
REVIEW AND REVISION OF YANKEL'S REBUTTAL
TESTIMONY; FINALIZE REBUTTAL TESTIMONY AND SE
THAT SAME IF FILED AND SERVED ON THE PARTIES
12/4/2008 ELO 185 3.8 703.00 PREPARE TESTIMONY SUMMARY FOR PUBLIC
HEARINGS
12/5/2008 ELO 185 1.4 259.00 FINALIZE TESTIMONY SUMMARY; CORRECT YANKEL'S
REBUTTAL TESTIMONY; TELEPHONE CONFERENCE
WITH LYNN TOMINAGA RE: GETTING TESTIMONY
SUMMARY AND TAKING TO TWIN FALLS PUBLIC
HEARING
12/8/2008 ELO 185 3.9 721.50 TELEPHONE CONFERENCE WITH TONY YANKEL
DEVELOPMENT OF CROSS EXAMINATION OF
COMPANY, STAFF AND INTERVENOR WITNESSES;
CONTINUED REVIEW OF REBUTTAL TESTIMONY;
REVIEW AND RESPOND TO E-MAIL RE: SCHEDULING
OF WITNESSES FOR HEARING; CONTINUED REVIEW OF
REBUTTAL TESTIMONY; PREPARE FOR PUBLIC
HEARINGS; ATTEND PUC PUBLIC HEARINGS ON RATE
CASE AT POCATELLO CITY HALL
12/9/2008 ELO 185 0.4 74.00 E-MAIL DEAN STEVENSON RE: TWIN FALLS HEARING
TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
TWIN FALLS PUBLIC HEARINGS AND PROVIDING
TESTIMONY SUMMARY
12/10/2008ELO 185 2.9 536.50 CONTINUED REVIEW OF REBUTTAL TESTIMONY;
12/11/2008 ELO 185 8.5 1,572.50 CONTINUED REVIEW OF REBUTTAL TESTIMONY AND
PREPARE CROSS EXAMINATION OF WITNESSES
12/12/2008 ELO 185 1.6 296.00 CONTINUED REVIEW OF REBUTTAL TESTIMONY AND
PREPARE CROSS EXAMINATION OF WITNESSES;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
TESTIMONY; TELEPHONE CONFERENCE WITH SID
ERWIN RE: TESTIMONY
12/13/2008 ELO 185 0.6 111.00 CONTINUED PREPARATION CROSS EXAMINATION FOR
HEARINGS
12/14/2008 ELO 185 12 2,220.00 CONTINUED PREPARATION FOR TECHNICAL HEARINGS
AND PREPARE CROSS EXAMINATION FOR WITNESSES
12/15/2008 ELO 185 3.5 647.50 TRAVEL TO BOISE, ID
12/15/2008 ELO 185 5.2 962.00 PREPARE FOR TECHNICAL HEARINGS
12/16/2008 ELO 185 9 1,665.00 ATTEND AND PARTICIPATE IN TECHNICAL HEARINGS
12/16/2008 ELO 185 1.8 333.00 ATTEND AND PARTICIPATE IN PUBLIC HEARINGS
12/17/2008 ELO 185 8.5 1,572.50 ATTEND AND PARTICIPATE IN TECHNICAL HEARINGS
12/18/2008 ELO 185 6.2 1,147.00 ATTEND AND PARTICIPATE IN TECHNICAL HEARINGS
12/19/2008 ELO 185 1.5 277.50 PART. IN TECHNICAL HEARINGS VIA CONF. CALL
1/2/2009 ELO 185 4 740.00 PREPARE INTEVENOR FUDING APPLICATION
TOTAL FEES 149.8 27,515.00
COSTS
12/11/2008 16.32 POSTAGE 12/03 - JEAN JEWELL -IDAHO PUBLIC UTILITIES
12/23/2008 273.78 RT MILEAGE POCATELLO-BOISE -12/15-12/18 - ELO
12/23/2008 676.93 LODGING AND MEALS WHILE IN BOISE - 12/15-12/18 - ELO
TOTAL COSTS 967.03
ATTACHMNT 2
bO
.Sæ0
Date C)Description0...
July 1 2 Read testimony and review exhbits of Keen, Gale, and Brilz.
2 4 Read testimony and review exhbits ofBrilz, Drake, Keen.
3 4 Read testimony and review exhbits of Smith, Miller, and Schwendiman.
7 5 Read testimony and review exhbits of Said and Tatum.
8 6 Develop additional interrogatories regarding meter reading errors and accuracy;
review assicated data and cases in the last 18 months dealing with the same;
discussion with Barker of the Staf regarding outage information that is
15 3 Review hourly company data regarding all input and uses of the power to the
system; become familiar with the documents and manipulate data so as to put it
in usable form.
16 3 Review 2008 update to the Company's IR from 2006; observe changes that
impact the direction of the rate case for allocation purposes and for load
management purposes.
17 2 Manipulate data regarding Januar 2006 purchases and sales as well as
generation on an hourly basis in order to put it into a form that can be used to
define which classes use generation and which classes have excess generation
that can be used to sell power off system.
18 2 Manipulate data regarding January 2006 purchases and sales as well as
generation on an hourly basis in order to put it into a form that can be used to
define which classes use generation and which classes have excess generation
that can be used to sell power off system.
21 2 Manipulate data regarding January 2006 purchases and sales as well as
generation on an hourly basis in order to put it into a form that can be used to
define which classes use generation and which classes have excess generation
that can be used to sell power off system.
24 2 Manpulate data regarding January 2006 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarzes use
by day and by hour.
25 2 Manpulate data regarding January 2006 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarizes use
by day and by hour.
29 3 Manpulate data regarding June 2006 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarzes use by day and
by hour.
30 4 Manipulate data regarding June 2006 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarizes use by day and
by hour.
31 4 Manpulate data regarding June 2006 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarzes use by day and
by hour; balance hourly usage with allocated generation.
Aug 1 3 Manipulate data regarding June 2006 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarzes use by day and
by hour; balance hourly usage with allocated generation.
14 6 Manipulate data regarding June 2006 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarizes use by day and
by hour; balance hourly usage with allocated generation.
15 6 Review data responses to Irrgators; review specific data regarding customers
that had incorrect meter readings and compare with what is known from other
information; review load data and hourly resource data in order to develop a
means of comparng it with data responses regarding distribution outages.
18 6 Review load research data and impact of Irrgation Peak Rewards Program;
conversation with Olsen regarding treatment of Irrgation Peak Rewards
Program and data in this case; attempt to quantitY impact of the Company's
proposed treatment.
19 7 Manipulate data regarding Jan 2007 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarizes use by day and
by hour; balance hourly usage with allocated generation.
20 8 Manipulate data regarding Feb and Mar 2007 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarzes use
by day and by hour; balance hourly usage with allocated generation.
21 8 Manpulate data regarding Apr May 2007 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarzes use
by day and by hour; balance hourly usage with alocated generation.
22 8 Manpulate data regarding June July 2007 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarzes use
by day and by hour; balance hourly usage with allocated generation.
25 8 Manipulate data regarding Aug Sept 2007 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarzes use
by day and by hour; balance hourly usage with allocated generation.
26 8 Manpulate data regarding Oct Nov 2007 purchases and sales as well as
generation on an hourly basis in order to put it into a form that summarizes use
by day and by hour; balance hourly usage with allocated generation.
27 8 Manipulate data regarding Dec 2007 purchases and sales as well as generation
on an hourly basis in order to put it into a form that summarizes use by day and
by hour; balance hourly usage with allocated generation; Discussion with
Irrgation Board regarding direction of case and the treatment of the load
28 7 Redevelop data regarding summarzing different function such as generation,
retail, purchases MWh, purchases cost, sales MW, and sales dollars into
summary forms by day and by hour of the day. IdentitY highest monthly values
for each category for each hour of the day.
29 6 Develop summaries of wholesale data by combining sales and purchase data on
the basis of both cost and total energy. Check for and correct errors in data.
Print out data in a reviewable form.
30 3 Review Irrgation Peak Rewards Program as proposed by Idaho Power for next
Irrgation season; compare the Company option program to that being run by
PacifiCorp.
Sept 9 4 Review data regarding outages from specific Irrgator substations (Duffn and
BUBR) in order to see if there is a correlation with high load times; review
outage data of all substations in the aggregate.
10 4 Review Company data responses; develop method of calculating impact of
usage by classes for which data was not provided on the need for purchase
power or the ability to sell into the wholesale market.
12 4 Review Company data responses; develop method of calculating impact of
usage by classes for which data was not provided on the need for purchase
power or the ability to sell into the wholesale market.
15 3 Review data response to questions proposed by the Industrial users for impact
on overall system costs and also impact upon the Irrgators.
16 5 Review data regarding interrptions on the Company's distribution system;
review/establish usage ofIrrgators on an hourly basis from the load research
17 3 Review load research data and convert it to hourly use data for the Irrgators as
a class/schedule.
18 7 Review load research data and convert it to hourly use data for the Irrgators as
a class/schedule.
19 2 Review load research data and convert it to hourly use data for the Irrgators as
a class/schedule.
30 6 Review load research data and convert it to hourly use data for the Irrgators as
a class/schedule.
Oct 2 3 Review responses to data requests sent by Irrigators and others; review August
2008 IR presentation.
3 5 Develop testimony regarding the impact of using hourly data to allocate Sales
for Resale revenues and Purchase Power costs.
4 5 Compare impact of using hourly data to allocate Sales for Resale revenues and
Purchase Power costs compared to the normalized way the company did it in
the filing; finalize testimony regarding the impact of using hourly data to
allocate Sales for Resale revenues and Purchase Power costs.
6 5 Go through old data and develop testimony for this case regarding the impact of
growth on the system and the lack of growth by the Irrgators.
7 6 Develop an exhbit that weights generation and transmission demand data as
well as energy data for purposed of putting it into a cost of servce study;
incorporate data into the Company's cost of servce study and make all
necessary adjustments so that the study wil take the data; write testimony
8 5 Review various outage data and formulate groupings to evaluate data; combine
with data from recent discovery request #35 to evaluate the general location of
outages; assess the value of the data and resulting relationships.
9 6 Review varous outage data and formulate groupings to evaluate data; combine
with data from recent discovery request #35 to evaluate the general location of
outages; assess the value of the data and resulting relationships.
10 7 Develop data associated with the impact of capacity available at specific hours
for use as Sales for Resale; develop testimony regarding same.
11 4 Develop data associated with the impact of capacity available at specific hours
for use as Sales for Resale; wrte testimony regarding same.
13 8 Review Peak Rewards program and its impact on cost of servce; develop two
cost of servce studies that reflect impact of Peak Rewards program; wrte
testimony regarding impact of Peak Rewards program.
14 7 Finalize draf testimony and exhbits; conversation with Hessing regarding
testimony in the last case.
18 6 Rework testimony; clean up exhbits and put in final form.
21 1 Review final draf, conversation with Olsen regarding direction.
24 2 Review of testimony of Sid Erwn; multiple discussions with Olsen regarding my
testimony and that of Erwin.
Nov 3 2 Review testimony of CAP A; review orders and entries put out by the
Commssion in other cases.
".
4 4 Review testimony of Micron witness Peseau regarding cost allocation and rate
spread; Review Peseau's testimony regarding revenue requirement and review
basis ofinforration he presented; Review testimony of DOE wintess Goins
regarding allocation of costs and spread of revenue requirement.
S 4 Review testimony of Industnal witness Reading and some of the Staf witnesses
and develop comments on the testimony.
6 3 Review more testimony of the Staff as well as a number of data responses that
were not reviewed dunng the last month.
7 3 Review recent data responses of the Company With emphasis on issues that
impact irrgation allocations and demand side management issues.
10 4 Develop responses to the Company's discovery request to the Irrgators
including finding cases where testimony was filed, reviewing past testimony that
was filed, and developing a listing of the testimony and issues.
11 3 Review a number of discovery responses that were received over the last month
that had not been reviewed; review Staf testimony as a basis for filing rebuttal
testimony regarding cost allocation.
12 4 Review data from previous cases to follow Hessings assertion that the
"disparty" in rates will continue in the future; try to determne how the dispanty
functioned in the past in order to see if it is the same as now.
13 4 Review a number of discovery responses that were received over the last month
that had not been reviewed; review company testimony as a basis for filing
rebuttal testimony regarding cost allocation.
28 7 Review the development of the exhbit prepared by Hessing in the last case and
attempt to make the same adjustments, but including data from this case;
analize the impact of the Hessing example in this case.
Dec 1 8 Review the development of the exhbit prepared by Hessing in the last case and
attempt to make the same adjustments , but including data from this case;
analize the impact of the Hessing example in this case.
2 8 Wnte rebuttal testimony regarding revenue spread; address testimony of
Hessing in the last case and his example of growth in just one class; address
testimony of Staf witnesses Lobb and Hessing from this case; address direct
testimony ofPeseau and Reading from this case.
3 6 Conversations with Olsen regarding testimony; rewrte testimony; finalize
4 7 Review all of the rebuttal testimony filed in the case; prepare for what I expect
to have to address on crossexarnation; develop thoughts on our approach to
cross of other winesses and the areas to address.
.
5 8 Review testimony of Company witness Tatum regarding my proposed cost of
servce method for addressing growth and develop suggested crossexamination.
8 8 Review testimony of Kroger witness Higens and develop suggested
crossexarnation regarding his comments on cost allocation as well as his
comments on my sales for resale proposal.
9 8 Review testimony of Department of Energy witness Goins regarding his
comments on my proposed allocation of growth related costs and his suggestion
that I used vintage pricing; develop suggested crossexarnation for Goins.
10 6 Review testimony of Staf witness Hessing regarding his thoughts on the ability
or desirablility to allocate the cost of growth and develop suggested
crossexarnation.
11 3 Discussions with Olsen regarding crossexamination; review of testimony of
witnesses Reading and Peseau.
15 6 Review testimony of others; review my testimony; prepare for
16 8 Travel to Boise for the hearing; review testimony of others in preparation of
being cross-examined; attend hearng; meet with Olsen regarding directions of
the hearing.
17 8 Attend hearing and submit to crossexamination; assist in crossexamination of
witnesses; discussions with Irrigators regarding direction of case.
18 6 Prepare for hearng; attend hearing.
Total 376
;"1 _~
TRAVEL EXPENSE
Date Lodging Meals Transportation
16-Dec $45.00 $519.99 AirLine
17-Dec $45.00
18-Dec $45.00
19-Dec $45.00 $312.68 car
$34.00 parking
Subtotals $0.00 $135.00 $866.67
Total Travel Expense $1,001.67