20081216Intervenor Funding Petition.pdf

Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
pç:t't: ;OO~'ih. v ,';;_ í..1
2Uûe DEC l 6 AM 8: 24
Attorneys for Intervenor
Idaho Irrgation Pumpers Association, Inc.
BEFORE TH IDAHO PUBLIC UTITS COMMSSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY'S PETITION FOR )
APPROVAL OF CHANGES TO THE )
IRRGATION PEAK REWARDS PROGRAM )
)
CASE NO. IPC-E-88-23
APPLICATION FOR INERVENOR FUING OF
TH IDAHO IRGATION PUMERS 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 Commission ("Commission") for intervenor fuding, pursuat to Idaho Code § 61-617 A
and IDAPA 31.01.01.161 through .165, regarding the expenses and costs associated with the
Irrgators paricipation in the above referenced matter, as follows:
(A) A summar of the expenses that the Irrgators request to recover broken down into
legal fees, consultant fees and other costs and expenses is set fort 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 sumar and are incorporated by reference.
(B) As part of the stipulation settling the 2007 rate case, Idaho Power, the Irrgators and
Commission Staff agreed to address the issues that the Irrigators had raised in that proceeding
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - i
regarding improving Idaho Power's Peak Rewards Program (the "Program"). On June 11,2008, the
parties gathered in Heyburn, Idaho to initially discuss suggested changes to the Program.
Presentations were made by both Idaho Power and Irrgator representatives at that meeting. After
the initial meeting, Idaho Power prepared a proposal to modifY the existing Program to include a
dispatchable option. Several conference calls were held to vet the specifics of the dispatchable
program proposal with Idaho Power, the Irrgators and Commission Staff. The paries discussions
where set out in the Stipulation that was incorporated into the Petition that Idaho Power fied with
the Commission on November 10, 2008.
The Irrgators' President, Mark Mickelsen, its Vice President, Sidney Erwin, its Executive
Director, Lyn Tominaga, and Board Member, Dean Stevensen, its legal counsel, Eric L. Olsen, and
its consultat, Anthony J. Yanel, P.E., all fully paricipated in the meetings and conference calls
that resulted in the Stipulation and Petition in this case. The Irrgators have also fied supporting
testimony for the Stipulation.
The Stipulation calls for the continued offering of the timer-based load control program and
the addition of a new dispatchable load control program via one-way or two-way communication
devices. Under the new dispatchable program, Idaho Power can interrpt paricipating irrgation
pumps for a specified number of hours per week between June 15 and July 31 ("Progr Season").
In exchange for allowing Idaho Power to interrpt service, paricipating customers wil receive a bil
credit in their monthly bils they obtain durng the Program Season. The Stipulation's terms and
conditions were worked out collaboratively between the Irrgators, Idaho Power, and Commission
Staff. The Irrgators believe that the addition of the dispatchable program will expand the amount
of summer peak being shaved above the curent 40 MW enjoyed to potentially well over 200 MW
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 2
as now being realized under the Rocky Mountain Power dispatchable program. The Irrgators
believe that this new dispatchable program is cost effective demand response program that should
be adopted by the Commission.
(C) The expenses and costs incurred by the Irrgators set forth in Exhibit A and
accompanying attachments are reasonable in amount and were necessarily incured. The expenses
and costs were incured in corresponding and collaborating with Idaho Power and the Commission
Staff, gathering information and reviewing documentation regarding the Program, preparng for,
delivering, and attending the June 11, 2008 presentation, drafting a memorandum setting out the
Irigators' concerns with Idaho Power's proposals, and reviewing and commenting on the
Stipulation and revisions to rate schedules.
(D) The costs described in Paragraph (A) above constitute a financial hardship for the
Irrgators. The Irrgators curently have approximately $20,000.00 in the ban with outstading
accounts payable from paricipation in this case, the current Idaho Power rate case and the Rocky
Mountain Power Rate case totaling approximately $30,000.00. These payables will increase
dramatically due to the fact that the current Idaho Power rate case is going to a full hearng next
week.
The Irrgators are an Idaho nonprofit corporation qualified under I.R.C. § 501(c)(5)
representing far interests in electric utility rate matters affecting farers in southern and central
Idaho. The Irgators rely solely upon dues and contrbutions 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-third
in the RMP service area), soliciting anual dues. The Irrgators recommend members make
APPLICATION FOR INERVENOR FUING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 3
voluntar contributions based on acres irrigated or horsepower per pump. Member contrbutions
have been falling which are believed to be attibutable 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 office space in Boise, Idaho, in addition to the
expenses relating to paricipation in rate cases. The Executive Director, Lynn T ominaga, is the only
par-time paid employee, receiving a retainer plus expenses for offce space, offce equipment, and
secretarial services. Officers and directors are elected anually and serve without compensation.
It has been and continues to be a financial hardship for the Irrigators to fully paricipate in
this review and settlement regarding the Irrgation Peak Rewards Program. As a result of financial
constraints, paricipation in review and settlement has been selective and, primarly, on a limited
basis.
(E) The positions that the Irrgators have urged the Commission to adopt were supported
and adopted by the Commission Staff in the Stipulation. In paricular, the Irrgators worked hard to
get broad input from the irrgation community at the June 11, 2008 meeting by getting a broad cross
section of irrgators to attend. The Irrigators closely reviewed Idaho Power's proposals on the
dispatchable program and made suggested changes to the new program, such as, not limiting
paricipation to irrigators with certain pump horsepower thresholds, keeping the installation costs
to a reasonable theshold to encourage paricipation, agreeing to greater weekly interrption than
found on the Rocky Mountain Power program (15 hours versus 12 hours), and requiring that the new
program be actively marketed by Idaho Power providing irrgation customers information how much
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMER ASSOCIATION, INC. - 4
they would save by joining the new program based on the previous year's usage levels. These items
where all aimed at ensuring suffcient paricipation in the new dispatchable program.
(F) The Irrigators' paricipation addressed issues of concern to the general body of users
or consumers on Idaho Power's system. The Peak Rewards Program has enabled Idaho Power to
shave approximately 40 MW ofload durng the sumer system peak. This reduction in peak load
benefits all Idaho Power customer classes by reducing the overall system costs. Idaho Power
estimates that the dispatchable program should raise the shaved load to approximately 112 MW. The
Irrigators believe that amount of interrption will be more like what is curently on the Rocky
Mountain Power system or over 200 MW. This will program help slow down the need for new
generation capacity on the Idaho Power system and hopefully help reduce the frequency of Idaho
Power's general rate cases.
(G) The Irrgators represent the irrigation class of customers under Schedule 24.
Based on the foregoing, it is respectfully submitted that the Irrgators are a qualifYng
intervenor and should be entitled to an award of costs of intervention in the maximum amount
allowable pursuant to Idaho Code § 61-617A and IDAPA 31.01.01.161 though .165.
DATED this the ~day of December, 2008.
RACINE, OLSON, NYE, BUDGE &
BAILE , HA TERED
APPLICATION FOR INERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 5
CERTIFCATE OF SERVICE
I HEREBY CERTIFY that on this (~ay of December, 2008, I served a true, correct and
complete copy of the Idaho Irrgation Pumpers Association, Inc.'s Application for Intervenor Funding
to each of the following, via u.s. Mail or private courer, e-mail or hand delivery, as indicated
below:
Jean Jewell U.S. Mail/Postage Prepaid
Idaho Public Utilities Commission
472 W. Washington Street
P.O. Box 83720
Boise, Idaho 83720-'0074
E-mail: jean.jewell(ßpuc.idaho.gov
Baron L. KlineDonovan Walker U.S. Mail/ostage Prepaid
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0070
E-mail: bkline(ßidahopower.com
E-mail: dwalker(ßidahopower.com
Weldon Stutzman U.S. Mail/Postage prepaid
Neil Price
Deputy Attorney Generals
Idaho Public Utilities Commission
472 W. Washington (83702)
P.O. Box 83720
Boise,ID 83720-0074
E-mail: weldon.stutzman(ßpuc.idaho.gov
E-mail: neil.price(ßpuc.idaho.gov
APPLICATION FOR INTERVENOR FUING OF IDAHO IRGATION PUMERS ASSOCIATION, INC. - 6
EXIIT A
SUMY OF EXPENSES INCURD BY IRRGATORS
INCASE NO. IPC-E-07-08
1. Legal Fees:
Eric L. Olsen (Parer): 50.0 hrs ~ $175.00 per hour
Jason E. Flaig (Associate): 5.4 hrs ~ $125.00 per hour
Costs:
Total Work and Costs:
2. Consultant Fees:
Anthony J. Yanel:147 hrs ~ $125 per hour
Expenses:
Travel, room and meals
Total Work and Cots:
TOTAL FEES AN EXPENSES:
$ 8,750.00
$ 675.00
$0.00
$ 9.425.00
$18,375.00
$ 1,072.88
$19.447.88
$28,872.88
Attachment 1
RACINE OLSON NYE BUDGE & BAILEY, CHARTERED
IDAHO IRRIGATION PUMPERS ASSOCIATION
710.1518532
FEE HOURS
DATE ATTORNEY RATE TO BILL AMOUNT DESCRIPTION
4/17/2008 ELO 175 0.5 $87.50 CALLAND LEAVE MESSAGES WITH SID IRWIN, JEFF
PAHL AND MARK MICKELSEN RE: IDAHO POWER
WORKSHOP ON PEAK REWARDS PROGRAM; CALL AND
LEAVE MESSAGE WITH TIM TATUM WITH IDAHO
POWER; TELEPHONE CONFERENCE WITH TIM TATUM
RE: SCHEDULING MEETNG
4/18/2008 ELO 175 1.5 $262.50 DRAFT EMAIL TO MEMBERS AND EXECUTIVE
COMMITTEE RE: IPC PEAK REWARDS WORKSHOPS;
TELEPHONE CONFERENCE WITH RANDY LOBB RE:
SAME AND PCA; EMAIL TONY YANKEL RE: SAME; CA
AND LEAVE MESSAGE WITH MAGGIE BRILZ
4/21/2008 ELO 175 0.5 $87.50 CALL AND LEAVE MESSAGE WITH SID ERWIN;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
UPCOMING WORK SHOP ON PEAK REWARDS; CALL
AND LEAVE MESSAGE WITH MAGGI BRILZ; TELEPHON
CONFERENCE WITH DAVE SCHUNKE OF PUC STAFF
4/22/2008 ELO 175 0.9 $157.50 TELEPHONE CONFERENCE WITH DAVE SCHUNKE RE:
COLLABORATIVELY WORKING ON INTERRUPTION
WORKSHOP
RATE DESIGN ISSUES
4/24/2008 ELO 175 1.1 $192.50 TELEPHONE CONFERENCE WITH SID ERWIN RE: IDAH
POWER PEAK REWARDS PROGRAM
4/30/2008 ELO 175 0.4 $70.00 TELEPHONE CONFERENCE WITH SID ERWIN RE: IPC
PEAK REWARDS PROGRAM AND UPCOMING MEETING
5/2/2008 ELO 175 0.7 $122.50 TELEPHONE CONFERENCE WITH SID ERWIN RE: IDAH
POWER PEAK REWARDS PROGRAM
5/5/2008 ELO 175 0.8 $140.00 GET INFORMATION FOR SID ERWIN ON RMP
DISPATCHABLE PROGRAM
5/5/2008 ELO 175 0.4 $70.00 TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
UPDATE ON IIPA MATTERS; TELEPHONE CONFERENCE
WITH RANDY LOBB RE: INTERRUPTIBILITY
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
SAME; PARTICIPATE IN CONFERENCE CALL WITH
IDAHO POWER RE: SAME
5/13/2008 ELO 175 0.5 $87.50 TELEPHONE CONFERENCE WITH SID ERWIN PEAK
REWARDS ISSUES
5/14/2008 ELO 175 1.$192.50 GET INFORMATION FOR PEAK REWARDS WORKSHOP;
TELEPHONE CONFERENCE WITH SYDNEY ERWIN RE:
INFORMATION; REVIEW AND REVISE COMMENTS ON
PCA FILING
5/15/2008 ELO 175 0.4 $70.00 GATHER ADDRESSES FOR OFFICERS AND DIRECTORS
AND EMAIL SAME TO IDAHO POWER
5/20/2008 ELO 175 1.5 $262.50 REVIEW PEAK REWARDS INFORMATION IN
PREPARATION FOR CONFERENCE CALL
5/21/2008 ELO 175 2 $350.00 PREPARE FOR IIPA MEETING; PARTICIPATE IN
CONFERENCE CALL WITH IIPA'S EXECUTIVE BOARD
5/29/2008 ELO 175 0.3 $52.50 REVIEW DRAFT OF PEAK REWARDS PRESENTATION
FEE HOURS
DATE ATTORNEY RATE TO BILL AMOUNT DESCRIPTION
6/2/2008 ELO 175 0.1 $17.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
IDAHO POWER AND PACIFICORP INTERPRETABILITY
PROGRAMS
6/3/2008 ELO 175 0.4 $70.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
REVIEW OF PRESENTATION AND CONFERNECE WITH
IDAHO POWER; EMAIL LYNN AND SID RE: IPC
PRESENTATION
6/10/2008 ELO 175 2.5 $437.50 REVIEW IDAHO POWER PRESENTATION FOR PEAK
REWARDS MEETING; TELEPHONE CONFERENCE WITH
TONY YANKEL RE: SAME AND FORWARD EMAIL TO
YANKEL AND OTHER BOARD MEMBERS; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: SAME;
TELEPHONE CONFERENCE WITH SID IRWIN RE:
MEETING AND ISSUES TO BE ADDRESSED
6/11/2008 ELO 175 6 $1,050.00 PREPARE FOR MEETING WITH IPC; ATTEND PEAK
REWARDS MEETNG
6/11/2008 ELO 175 2 $350.00 TRAVEL TO AND FROM BURLEY
6/13/2008 ELO 175 0.4 $70.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE: IP
MEETNG AND GETTING DISCOVERY INFORMATION
7/31/2008 ELO 175 0.3 $52.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
RMP INTERRUPTIBILITY PRICING ISSUES
8/13/2008 ELO 175 0.8 $140.00 CALL AND LEAVE MESSAGE WITH TIM TATUM OF IDA
POWER RE: PEAK REWARDS PROGRAM MEETING
FOLLOWUP; TELEPHONE CONFERENCE WITH TIM
TATUM RE: SAME; TELEPHONE CONFERENCE WITH
LYNN TOMINAGA RE: SAME
8/14/2008 ELO 175 0.4 $70.00 REVIEW THE DISPATCHABLE INFORMATION
8/15/2008 ELO 175 1.9 $332.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
IDAHO POWER PEAK REWARDS PROGRAM; EMAIL
LYNN TOMINAGA RE: POSSIBLE EDITORIAL ARTICLE
TELEPHONE CONFERENCE WITH SID IRWIN RE:IPC
PEAK REWARDS PROGRAM; TELEPHONE
CONFERENCE WITH BRENDA TOMINAGA RE:
PREPARING EDITORIAL
8/26/2008 ELO 175 0.7 $122.50 PARTICIPATE IN CONFERENCE CALL RE: PEAK
REWARDS PROGRAM AND IPCO RATE CASE
8/27/2008 ELO 175 0.2 $35.00 TELEPHONE CONFERENCE WITH TIM TATUM RE:
STATUS OF COMPANY PROPOSAL FOR DEMAND
RESPONSE PROGRAM
9/2/2008 ELO 175 0.7 $122.50 REVIEW IPC DISPATCHABLE PROGRAM PAPER; REVIE
YANKEL'S COMMENTS RE; SAME; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: IPC PEAK
REWARDS RESPONSE; EMAIL IPC INFORMATION TO
DEAN STEVENSON
9/5/2008 ELO 175 0.3 $52.50 TELEPHONE CONFERENCE WITH TONYYANKEL RE:
PCA WORKSHOP AND PEAK REWARDS PROGRAM
9/8/2008 ELO 175 0.6 $105.00 CONFERENCE CALL WITH IIPA EXECUTIVE BOARD RE
REVIEW OF CHANGES TO PEAK REWARDS PROGRAM
9/8/2008 ELO 175 2.2 $385.00 PARTICIPATE IN CONFERENCE CALL WITH IPC AND
STAFF; CONFERENCE CALL WITH EXECUTIVE
COMMITTEE RE: SAME
9/10/2008 ELO 175 0.8 $140.00 REVIEW NOTES FORM MEETING; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: IIPA PEAK
FEE HOURS
DATE ATTORNEY RATE TO BILL AMOUNT DESCRIPTION
REWARDS PROGRAM
9/17/2008 ELO 175 2.5 $437.50 DRAFT ISSUES MEMORANDUM SETTING OUT IIPA'S
CONCERNS WITH IPC PEAK REWARDS PROPOSAL
9/18/2008 ELO 175 0.2 $35.00 TELEPHONE CONFERENCE WITH TONY YANKEL
REVIEW OF PEAK REWARDS MEMORANDUM
9/24/2008 ELO 175 0.3 $52.50 EMAIL TIM TATUM AT IPC RE: RESPONDING TO
PROPOSAL; TELEPHONE CONFERENCE WITH SIDS
WIFE RE: MEMORANDUM AND RESEND MEMORANDUM
TO NEW EMAIL ADDRESS
9/24/2008 ELO 175 1 $175.00 TELEPHONE CONFERENCE WITH SID ERWIN RE:
COMMENTS ON MEMORANDUM; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: SAME;
REVISE MEMORANDUM AND EMAIL IT OUT
9/26/2008 ELO 175 0.6 $105.00 FINALIZE MEMORANDUM ON PEAK REWARDS
PROPOSAL; EMAIL MEMORANDUM TO IPC AND
COMMISSION STAFF; ORGANIZE FILE
9/30/2008 ELO 175 0.7 $122.50 CALL EXECUTIVE BOARD; TELEPHONE CONFERENCE
WITH TIM TATUM RE: CONFERENCE CALL RE: IIPA'
COMMENTS ON PROGRAM PROPOSAL
10/1/2008 ELO 175 2.6 $455.00 TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
CONFERENCE CALL ON PEAK REWARDS PROGRAM;
TELEPHONE CONFERENCE WITH SID ERWIN RE: SAME
PREPARE FOR CONFERENCE CALL; TELEPHONE
CONFERENCE WITH IIPA EXECUTIVE BOARD; IPC
REPRESETNTAIVES AND COMMISSION STAFF
10/23/2008 ELO 175 1.5 $262.50 REVIEW STIPULATION AND MATERIALS; FORWARD ON
10/30/2008 ELO 175 2.6 $455.00 FINALIZE REVIEW OF STIPULATION AND SUPPORTIN
DOCUMENTS AND EMAIL COMMENTS TO DONOVAN
WALKER
11/4/2008 ELO 175 0.5 $87.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
PREPARATION OF TESTIMONY FOR PEAK REWARDS; CALL
AND LEAVE MESSAGE WITH DONOVAN WALKER RE: SAME
11/5/2008 ELO 175 0.5 $87.50 REVIEW YANKEL TESTIMONY AND EMAIL COMMENTS
11/6/2008 ELO 175 0.5 $87.50 FINALIZE TESTIMONY SUPPORTING THE STIPULATION FOR
FILING
11/18/2008 ELO 175 0.1 $17.50 TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
STATUS OF PEAK REWARDS FILING
11/24/2008 ELO 175 0.2 $35.00 REVIEW COMMISSION SCHEDULE AND DECISION MEMO
RE: PEAK REWARDS FILING; EMAIL WELDON STUTZMAN
RE: SAME
11/25/2008 ELO 175 0.2 $35.00 REVIEW VOICE MAIL FROM DONOVAN WALKER RE:
PROCEDURAL ISSUES; CALL AND LEAVE MESSAGE RE: SAME
12/3/2008 JEF 125 0.2 $25.00 DRAFTED APPLICATION FOR INTERVENOR FUNDING
12/8/2008 JEF 125 4.5 $562.50 CONTINUED DRAFTNG APPLICATION FOR INTERVENOR
FUNDING; CONFERENCE WITH ELO AND DANA RE:
APPLICATION PREPARATION AND ITEMIZED TIME ENTRIES
12/9/2008 JEF 125 0.7 $87.50 CONTINUED DRAFTNG THE APPLICATION FOR
INTERVENOR FUNDING
12/12/2008 ELO 175 3.1 $542.50 FINALIZED APPLICATION FOR INTERVENOR FUNDING
TOTAL FEES 55.4 $9,425.00 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
2008 IDAHO POWER GENERAL RATE CASE FILING
Attachment 2
Date IPCo
Apri 21
22
23
24
28
May 13
14
15
20
16
19
Description
3 Review historic positions put out by Idaho Power regarding the Peak Rewards
program.
7 Review PacifCorp's study regarding varous DSM measures published in July
2007; review PacifCorp's 2007 IR for cost of new generation and simarties to
the special DSM study; Review Idaho Powers 2005 IR regardig cost of new
generation and DSM.
6 Review PacifCorp's study regardig varous DSM measures published in July
2007; Review Idaho Powers 2005 IR regarding cost of new generation and
DSM; Review Idaho Power's cases regarding certifcate of convenience and
necessity for the rate basing of the Evander Andrews expansion project and how
the need and cost impacts may have related to the Irgation Peak Rewards
program.
6 Review the Order in Idaho Power's application for a Residential Ai Conditioner
Cyclig Program; review an independent study of the results of the Residential Air
Conditioner Cyclig Program find data sources that describe the present level of
the Residential program.
6 Review fidigs and other material regardig interrptibilty programs and wrte a
sumtion of possible directions to pursue.
2 Review study regarding the costs and the benefits of the load managent
programs tht was prepared for PacifCorp last sumer.
4 Develop calculations and manpulate data for 2007 of al irgation bils for each
month in order to consolidate by size and load factor.
4 Develop calculations and manpulate date for 2007 of al irgation bils for each
month in order to consolidate by size and load factor.
4 Develop calculations and mapulate date for 2006 of al irgation bills for each
month in order to consolidate by size and load factor.
4 Develop calculations and manpulate data for 2007 of al irgation bils (non-
company redacted version) for each month in order to consolidate by size and load
factor.
5 Compare results of the 2007 Irgation monthly biling data for the two versions of
the data supplied by the Company; highlght differences in the two sets of data by
size and load factor; analize data in more detail to determe the difference
between the data sets; wrte memo regarding findings; further conversations .with
Idaho Power regarding the data.
Date IPCo Description
21 3 Prepare for and paricipate in conference call with Olsen and the Irrgation Board
regarding the peak rewards program.
23 3 Develop comparsons of Irgation peak curtaiment programs in Idaho Power and
PacifiCorp; review historica studies as well as tars.
27 6 Develop PowerPoint resentation that depicts how the Idaho Power and the
PacifiCorp Irgation curaiment programs work and develop supporting
materials.
28 6 Develop PowerPointresentation that depicts how the Idaho Power and the
PacifCorp Irrgation curtent programs work and develop supporting
materials.
June 2 5 Review data requests and requests sent to Idaho Power; revew spreadsheet data
sent by the Company that would be the foundation of their phone conversation;
prepare for and attend phoneconveration with Idaho Power personel regarding
the 2007 Irgation Peak Rewards program data; phone conversation with Idaho
Power; review of data sent by the company in light of the conversation that took
place.
6 4 Review PowerPoint and mae :f adjustments for sending to Idao Power and
the Staf
7 6 Travel from Cleveland to Boise for meetigs in Idao regardig Irgation Peak
Rewards program meetig with Idaho Power.
10 2 Prepare for and meet with Staf regardig the proposed presentation and
Irgator's position regardig Idaho Power's Peak Rewards Program.
11 9 Travel to and from as well as attend meeting in Burley with the Company, invited
irrgators, and the Staf
12 6 Travel from Boise to Cleveland; review material provided by Idaho Power at the
meeting and assess its impact upon the direction we wish to take regarding the
Irrgation Peak Rewards program.
July 16 3 Review 2008 update to the Company's IR from 2006; observe changes that
impact the direction of the rate case for load maagement purposes.
Aug 18 6 Review load research data and impact of Irrgation Peak Rewards Program;
conversation with Olsen regarding treatment of Irgation Peak Rewards Program
and data in rate case; attempt to quantif impact of the Company's proposed
treatment.
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.
Date IPCo Description
Sept 1 2 Finaze thoughts regarding Idaho Powers proposed Peak Rewards Program
chages for next year and wrte a summar/response for the Irgators.
6 6 Review IPCo's proposed Company Option Peak Rewards Program and develop
numbers and impacts of the proposal~ ru through the Company's cost of servce
study in order to calculate the impact ofIPCo's proposal to remove the impact of
the Peak Rewards Program from the study, i.e. use data as if the interrption
never happened.
8 4 Prepare for meeting with Irrgators regarding Company proposed peak rewards
program~ attend phone conference of Irgators regardig proposed peak rewards
program~ attend phone meeting with Company and Staf regardig pea rewards
program~ follow-up conversation With Irrgators regarding proposed peak rewards
program.
Oct 1 2 Prepare for meeting and attend meeting with IPCo, Staf and the Irgators
regarding the proposed peak rewards program design.
11 4 Develop data associated with the impact of capacity avaiable at specifc hours for
use as Sales for Resale.
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.
27 2 Review proposed fig by IPCo regarding the new Irgation load magement
program includig tar changes, discussion of issues, IR avoided cost, and
proposed stipulation.
Nov 5 4 Draf testimony regardig support for the Idaho Peak Rewards program based
upon the cost!enefit study provided by the Company and other data sources
regarding the program.
6 2 Review Idao Power's proposed Pea Rewards program and finale testimony
based upon the cost!enefit study provided by the Company.
Total 147
. '
TRVEL EXPENSE
Date Lodgig Meals Tranporttion
13-Jun $45.00 $625.20 AiLine
14-Jun $45.00
15-Jun $45.00 $312.68 car
Subtotals $0.00 $135.00 $937.88
Total Travel Expense $1,072.88