20020517IIPA Application for Intervenor Funding.pdf

Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
t(A;1..fb
RECEIVED fILED
2nn2HA y 11 PM It: 55
., ..., "'"p'
! AihJ t" vULiJ
UTiLITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP, DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF ITS
PROPOSED ELECTRIC SERVICE SCHEDULES)
Case No. PAC-O2-
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION. INC.
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), by and through
counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public
Utilities Commission ("Commission ) for intervenor funding pursuant to Idaho Code 9 61-617JA
and IDAPA 31.01.01.162 as follows:
(A)A summary of the expenses that the Irrigators request to recover broken down into
legal fees, witness fees and other costs and expenses is set forth in Exhibit "A" attached hereto and
incorporated by reference. Itemized statements are also attached to Exhibit "A" in support of this
summary .
(B)The Irrigators ' proposed findings and recommendations were set forth in the
Stipulation and in the Irrigators' closing Comments filed with the Commission in this case in
Th I , . (1&: response to the Company s filings and the Commission s notices. e mgators ;1lF
fJZ;-
fI1/!(
j1H
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 1
aligned with all other customer classes in seeking to limit the Company s recovery of its claimed
excess power supply costs to only those that were prudently incurred and properly recoverable. Via
the Stipulation, the Irrigators supported the Company s net recovery of approximately 22.7 million
in excess power supply costs as reasonable and appropriate given (1) the risks of a less favorable
result in light of the viability ofthe defenses further limiting such recover, (2) the Irrigators' limited
resources in going through a full contested hearing, and (3) the status settlements reached or in
progress in other jurisdictions on this issue.The Irrigators' consultant, Anthony Yankel
Consultant"), assisted the Irrigators in detennining settlement range for Company s claimed excess
power supply costs and participated via conference call in one of the settlement conferences.
The rate spread and rate design aspects of this case were of utmost importance to the
Irrigators in that the Company proposed, among other things, a potential cost of service increase of
up to 19.34% and replacement of the ABC rate schedule and accompanying load control benefits.
The Irrigators had to treat the Company s Application prior to any settlement as ifit would go
a full contested hearing and had its Consultant review the underlying data and methodology used for
the Company s proposed cost of service study. Necessarily, the Irrigators and its Consultant served
three Data Requests upon the Company for this purpose and incurred significant time in reviewing
the Company s Application to determine its merits. Via the Stipulation, the Irrigators agreed (1) to
the revision of the ABC tariff schedule to that of a firm rate and (2) to the use of a Modified Rate
Mitigation Adjustment ("RMA") feature that has the effect of making a substantial move for the
irrigation class toward perceived cost of service and redistributing the revenues to the benefit of the
other customer classes to principally mitigate the effect of Company s excess power supply costs.
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 2
The Irrigators' Consultant worked closely with the Irrigators to evaluate the merits ofthe settlement
of this issue and also interacted with the Company and the Commission Staff in the overall
settlement process.
(C)The expenses and costs incurred by the Irrigators set forth in Exhibit A attached are
reasonable in amount and were necessarily incurred (1) in communicating with representatives of
the Company, the Commission Staff, and the Irrigators' governing board , (2) in reviewing and
evaluating the Company s Application and exhibits , conducting discovery, negotiating and drafting
the Stipulation, and preparing Comments filed on behalf of the Irrigators, and (3) in generally
participating in these proceedings before the Commission.
(D)The costs described above constitute a financial hardship for the Irrigators. The
Irrigators currently have less than $14 000 in the bank and substantial accounts payable as a result
of participation in this case and several other cases filed recently by Idaho Power and PacifiCorp.
The Irrigators are an Idaho nonprofit corporation qualified under I.R.C. 9 50l(c)(5) representing
farm interests in electric utility rate matters affecting farmers in southern and central Idaho. The
Irrigators rely solely upon dues and contributions voluntarily paid by members, together with
intervenor funding to support activities and participate in rate cases. Each year a mailing is sent to
approximately 7500 Idaho Irrigators (approximately two-thirds in the Idaho Power Company service
area and one-third in the Utah Power Company service area), soliciting annual dues. The Irrigators
recommend that each member make a voluntary contribution ofthirty cents ($.30) per horsepower
for each pumping installation. Member contributions have been falling mainly due to the extremely
depressed agricultural economy. From member contributions the Irrigators must pay all expenses
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 3
which generally include mailing expenses, meeting expenses and shared office space in Boise, Idaho
in addition to the expenses relating to participation in rate cases. The Executive Director, Lynn
Tominaga, is the only part-time paid employee, receiving a small retainer plus expenses for office
space, office equipment, and secretarial services. Officers and directors are elected annually and
serve without compensation.
It has been and continues to be a financial hardship for the Irrigators to fully participate in
all rate matters affecting its members. As a result of financial constraints, participation in past rate
cases has been selective and on a limited basis.
(E)The positions set forth by the Irrigators in these proceedings as set forth in (B) above
were different from the positions taken by the Company, Commission Staff and other intervenors
with regard to the length and amount of the RMA.
(F)The Irrigators' participation addressed issues of concern to the general body of users
or consumers with respect to the negotiation of the amount of excess deferred power costs and the
willingness of the irrigation class as a whole to make a substantial move toward the perceived cost
of service for said class and the revenue from which was used to mitigate the recovery of the excess
power supply costs for all other consumer classes.
(G)The Irrigators represent the irrigation 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 pursuant to Idaho Code 9 61-
617A and IDAPA 31.01.01.162.
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 4
DATED this 17th day of May, 2002.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 5
CERTIFICATE OF MAILING
I hereby certify that on the /7 Aay, 2002, a true and correct copy ofthe foregoing
was served on the following via U RMail:
Scott Woodbury, Deputy Attorney General
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
Anthony 1. Yankel
29814 Lake Road
Bay Village, OH 44140
Randall C Budge
Racine, Olson, Nye, Budge & Bailey, Chtd.
O. Box 1391
Pocatello, ID 83204
James R. Smith, Senior Accounting Specialist
Monsanto Company
O. Box 816
Soda Springs, ID 83276
Tim Shurtz
411 South Main
Firth, ID 83236
Doug Larson
Vice President Regulation
PacifiCorp
201 S. Main, Suite 2300
Salt Lake City, UT 84140
James F. Fell
Erinn Kelley-Siel
John M. Eriksson
Stoel Rives LLP
201 S. Main Street, Suite 1100
Salt Lake City, UT 84110
Conley Ward
Givens Pursley
O. Box 2720
Boise, ID 83701
Elli
~~
Iv'
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 6
EXHIBIT A TO APPLICATION FOR INTERVENOR FUNDING
PAC-O2-
LEGAL - ERIC L. OLSEN:
Legal Fees: 117.9 hours C0 $135-$150
(See Attachment 1 for Detail)
Costs: travel, meals, lodging and
miscellaneous expenses:
Total:
CONSULTING FEES - TONY Y ANKEL:
Consulting Fees: 152 hours C0 $100
(See Attachment B for Detail)
Costs: Travel, meals, lodging, postage
photocopies and miscellaneous expenses:
Total:
TOTAL FEES AND EXPENSES:
071.68
$15 200
$16 107.
$17.178.
15.200.
32.378.
Date
01/07/02
01/10/02
01/12/02
01/30/02
01/31/02
Description
Conference regarding PacifiCorp Rate Case and effect on IIP A
Receive and review PacifiCorp new 2002 application, testimony and
exhibits; prepare file petition to intervene; telephone conference and
letter to PUC, letter to D. Larson, J. Erikson requesting service on
consultant; telephone conference with D. Larson Re: proposed
settlement conference;
Review PacifiCorp new application , testimony, exhibits.
Prepare file IIP A First Discovery Requests; telephone conference
with T. Yankel re: same.
Review Pumper s First Data Requests to UP&L and see that the
same are sent out
For Current Services Rendered
Total Current Work & Costs
Balance Due
Hours Total
1.50
1.00
1.00
673.
673.
$673.
ATTACHMENT
Date Descri tion Hours Total
01/07/02 Conference regarding PacifiCorp Rate Case and effect on IIP
01/10/02 Receive and review PacifiCorp new 2002 application, testimony and
exhibits; prepare file petition to intervene; telephone conference and
letter to PUC, letter to D. Larson, J. Erikson requesting service on
consultant; telephone conference with D. Larson Re: proposed
settlement conference;1.50
Review PacifiCorp new application , testimony, exhibits.1.00
01/12/02
Prepare file IIP A First Discovery Requests; telephone conference 1.00
01/30/02 with T. Yankel re: same.
Review Pumper s First Data Requests to UP&L and see that the
01/31/02 same are sent out
For Current Services Rendered 673.
Total Current Work & Costs 673.
$673.
Balance Due
Date
02/01/02
02/05/02
02/06/02
02/07/02
02/08/02
02/13/02
02/15/02
02/16/02
02/18/02
02/19/02
02/20102
02/25/02
Descri tion
Telephone conference with R. Lobb, T. Yanlee1 re: case preparation
settlement conference, discovery requests/ strategy.
Telephone conference with T. Yankel, L. Tominaga, B. Taylor, staff
re: pre-hearing conference and settlement conference issues.
Conference re: status of Rate Case and attending or PacifiCorp
workshop on restructuring.
Lunch re: background on PacifiCorp General Rate Cases; review
Second Data Requests; e-mail and call and leave message with Tony
Yanleel re: same; several telephone conferences with Tony Yankel
re: finalizing Second Data Requests.
Finalize IIP A Second Data Requests and see that same are served;
conference re: upcoming scheduling and settlement conference.
Review update letter to IIP A re: current Rate Cases before the PUC.
Telephone conference with B. Lively (PacifiCorp) re: issues for 2/19
settlement conference; conference re: upcomIng scheduling
conference; Telephone conference with Lynn Tominaga re: Utah
Power Rate Case and breakfast meeting re: same.
Conference re: positions to be taken in scheduling conference in
PacifiCorp Rate Case.
Receive and review Yankel preliminary analysis of Pacificorp
scheduling and settlement conference issues; prepare position and
issues for statement for 2/18 PUC scheduling/settlement conferences;
telephone conference with B. Lively (PacifiCorp) re: issues for
settlement conference.
Conference re: PacifiCorp case and Issues to be raised III
scheduling/settlement conference; travel to Boise; attend
PacifiCorp/PUC scheduling and settlement conference travel back to
Pocatello.
Review Third Data Requests prior to sending out.
Finalize Third Data Request and see that same are served; outline
draft letter to Board re: current settlement negotiations; review PAC
filing materials re: changes to COS design and other elements of the
filing
Hours Total
0.40
0.30
1.80
02/26/02
02/27/02
02/28/02
02/19/02
02/28/02
02/28/02
Continued review of PAC's filing and testimony of James Zhang;
continued drafting of status letter to IIP Board; telephone
conference with Tony Yankel re: status of case and scheduling call
in conference; conference re: same.
Telephone conference with B. Taylor re: case status and strategy,
issues and authority for settlement conference with PacifiCorp and
staff; meeting re: case analysis, settlement issues and strategy;
prepare draft letter to Board re: same; revise letter to IIP A Board;
conference re: same.
Finalize Board letter; telephone conference with Mark Michelson re:
conference call; call and leave message with Bob Lively at
PacifiCorp getting revised numbers; telephone conference with Bob
Lively re: getting revised numbers for show impact on larger
Irrigators of proposed COS redesign
F or Current Services Rendered
Travel to Boise
Long Distance Telephone Expense
Long Distance Telephone Expense
Total Costs
Total Current Work & Costs
Previous Balance
Balance Due
4.40
29.90 4 096.
321.00
333.49
429.
$673.
$5.103.49
Date
03/04/02
03/05/02
03/08/02
03/11/02
03/12/02
03/13/02
03/14/02
Descri tion
Receive and review Pacificorp Schedule 10C Exhibits and
evaluation of proposed COS studies, BP A credit, rate mitigation
adjustment on rates of irrigators; telephone conference regarding
case settlement issues; Multiple telephone conferences with B.
Lively/Pacificorp, T. Yanlee1, IIP A Board regarding settlement issues
and negotiations.
Review spread sheet from Bob Lively regarding changes to monthly
billing comparisons for irrigators
Conference regarding monthly billing comparIson numbers;
conference with Bob Lively regarding spread sheet showing
adjustments to rates; Conference call is IIP A Board regarding same
and upcoming settlement conference
Telephone conference with Lively regarding questions about
monthly billing comparisons
Review revised monthly billing comparison numbers;
Travel to Boise to attend Settlement Conference; Attend Settlement
Conference and reach settlement regarding amount of excess power
costs to be recovered; Various telephone conferences with Tony
Yankel regarding same; Travel back to Pocatello
Conference with Tony Yankel on status of settlement conference on
Pacificorp case; Telephone conference with Bob Lively regarding
changes in interruptability rate this late in the irrigation season; E-
mail Tony Yankel regarding Pacificorp s concerns over being unable
to implement new firm power rate schedule and idea of keeping the
ABC Tariff Rates in place for 2002 irrIgation season
Telephone conference with Tim Shurtz regarding status of his
intervention in the case and intent to raise motion on rate freeze
provision in earlier merger case and Pacificorp s ability to file a
general rate case
Dictate letter to IIP Board regarding status of settlement
negotiations; E-mail Bob Lively regarding monthly billing
comparIson
Review revised monthly billing comparison from Pacificorp
Revise letter to lIP Board regarding status of settlement
negotiations
Hours Total
10.
0.20
1.10
1"It'11-.I.r-.:::;I::.II::.I':::; .1.0"';)':::;I"'HI...11'tI::.J UL:::IUI't, NT I::. , ~UUI.JI::.&~~I:jt:i ~.j~ bll:j'j I-' .1::1'(
03/18/02 Receive and review Pacificorp proposed settlement stipulationexhibits; Telephone conference with B. Lively regarding analysis
proposed settlement in inigators rates; Review proposed stipulation
and attachments provided by PacificoIp and fOlWard same on to
Tony Yankel; Review proposed stipulation; conference regarding
revised schedule and telephone conference with Bob Uvelyregarding
same; Telephone conference with Tony and review schedules to
stipulation agreement; Rcview Tony Yankel's settlement numbers;
Telephon~ conference with Bill Taylor regarding conference on
meeting; Telephone conference with Mark Michelsen regarding the
meeting on the rate spread
03/19/02 Conference call with B. Taylor, M. Mickelson regarding proposed
settlement stipulation and exhibits with Pacificorp; Conference
regarding scheduled conference call with lIP A Board members;
Conference with DPA Executive Committee Members regarding
status of current negotiations on Pacificorp rate case 1.90
03/20/02 Travel to Boise to anend settlement conference; Attend settlement
conference with Pacificorp and staff and revise proposed stipulation~
Travel back to Pocatello
03/21/02 Conference regarding revision ofPacificorp s proposed stipulation;
Review the revised stipulation of the proposed settlement; forward
e-mails on to Tony Ywel and see that staffs proposed schedules are
faxed to Mr. Yanke!; Telephone conference with Tony Yankel
regarding results of settlement conference and negotiating strategies
going forward 1.30
03/22/02 mail Dave Taylor regarding conference call with Tony Yankel
about COS Study and lIP A's concerns; telephone conference with
Dave Taylor and Tony Yanke! regarding issue with respect to
Irrigator's cost of service study numbers; Telephone conference with
Tony Yankel regarding same
03/23/02 Receive and review staff rate spread exhibits to settlement
stipulation; Telephone conference with T. Ywel regarding
settlement "spread" issues
03/25/02 Review revised monthly billing comparison provided by Paciticorp;
Forward e-mail on to Tony Yankel for his review; Review staff's
proposal for the RMA spread in conjWlction with PCS and its effect
on Irrigator class; E-mail Pacificorp regarding changes to its monthly
billing comparisons for hrigators in light of staft"s new proposal;
Conference regarding IIPA position and settlement of the case
, In 1 ... I "'......'" ... U'
..........
,...n..... "I::. , U'-.:IU"'" 'I::.' ~U1.JUI::.Cx~
03/26/02
03/27/02
03/28/02
03/29102
03/05/02
03/20/02
03/31/02
Receive and review T. Yankel analysis ofPacificorp proposed rate
spread; Review TonyYankel's comments regarding size oCcost of
service increase and arguments to be made against the same;
Telephone conference with Tony Yankel regarding review of
comments regarding cost of service study; Telephone conference
Vlith Mark Michelsen regarding status of rate case and fax
infonnation up to him
Review Pacificorp s proposed stipulation and exhibits; Telephone
conference with Mark Michelsen regarding status of negotiations and
set time to meet with executive board; Telephone conference with
Randy Lobb regarding status of case with Pacificorp and Irrigator's
concerns; Review notes from conversation with Randy Lobb
Participate in Pacificorp-staffNo. 3 settlement conference regarding
rate spread and proposed settlement stipulation and exhibits;
Participate in staff, Pacificorp, and intervenor conference call;
Prepared for meeting UP A Executive Board; Telephone conference
with Doug Larson of Pacificorp regarding irrigator s concerns;
ConrerencewithMarkMichelsen and Bill TaylorofIIPAand various
telephone conferences with Tony Yankel, Bob Lively, Randy Lobb,
and various Pacificorp staff regarding rate design issues within the
irrigator class
Conference regarding status lIP A negotiations with Pacificorp;
Telephone conference with Mark Michelsen regarding statUS and
decision of the board on terms of stipulation; Telephone conference
with Tony Ywel regarding status of negotiations and other means
of addressing the issue of hit to large irrigators; Telephone
conference with Bob Lively regarding status of mgators position
with respect to proposed stipulated settlement
For Current Services Rendered
Travel to Boise
Airfare to Boise
Long Distance Telephone Expenses
Total Costs
Total Cum:nt Work & Costs
Previous Balance
Balance Due
':::;1::.10 &:...;)&:. eLl::)';:)
1.10
1.30
r- . 1::Jt:i
612.
321.00
321.00
683.
295.
$5,103.
Date Descri tion Hours Total
04/01/02 Call and leave message with Randy Lobb regarding IIP A position;
E-mail Bob Lively regarding same
04/02/02 Review revised stipulation; review revised schedule B amounts;
Telephone conference with Randy Lobb regarding requested
changes; Re-draft stipulation language 2.30
04/03/02 Review changes to stipulation from Bob Lively; forward same on to
Tony Yankel and review voicemail from Randy Lobb
Telephone conference with Randy Lobb regarding proposal of minor
reduction in RMA; Telephone conference with Bob Lively regarding
same and language defining large irrigator; Telephone Conference
with Mark Michelsen regarding status of settlement terms thereof;
Telephone conference with Bob Lively regarding approval of current
stipulation by IIP A; Telephone conference with Tony Y ankel
regarding terms of settlement and preparation of request for
intervenor funding 1.20
04/05/02 Review e-mail from Tony Yankel about inconsistency in schedule
94 and settlement agreement; Review revised stipulation and
accompanying schedules; E-mail Bob Lively regarding same and our
understanding of the agreement that had been reached; Review
revised schedule 94 sent from Bob Lively; Telephone conference
with Randy Lobb regarding stipulation 3.40
04/24/02 Review order regarding stipulation and hearing schedule; Organize
file and dictate letter to Board regarding status of case and upcoming
hearings 1.30
04/25/02 Telephone conference with Tony Yanleel regarding whether IIP A
needs to present testimony or not; Call and leave message with
Randy Lobb at PUC regarding hearings; Revise letter to lIP A Board
regarding settlement of case and commission hearings; Telephone
conference with Randy Lobb regarding status of hearings and issues
the commissioners wanted addressed 1.50
04/26/02 Telephone conference with Bob Lively at Pacificorp regarding status
of hearings 0.20
Conference with staff regarding upcoming hearings on settlement
and need to file testimony 0.20
04/29/02 E-mail Tony Yanleel regarding not providing testimony and getting
information for intervenor funding request
05/01/02
05/02/02
05/03/02
05/06/02
05/07/02
05/09/02
05/16/02
5/17/02
04/30/02
05/16/02
Telephone conference with Jim Fell of Stoel Rives regarding
spreading testimony on the record; Telephone conference with Tim
Shurtz regarding request for a continuance
Telephone conference with Mark Michelsen regarding upcoming
hearings on stipulation and testifying regarding IIP A's position at
Rigby Hearings
Review pre-filed testimony of Bob Lively and Randy Lobb inpreparation for technical hearing 1.
Review Petition to Intervene from Nu- West Industries, Inc.
Travel to Rigby, Idaho for initial workshop and public hearing;
Attend workshop; Conference with Mark Michelsen IIP A Board
Member regarding content of testimony; Attend public hearing;Travel back to Pocatello 5.
Travel to Preston to attend technical hearing; Attend technical
hearing and participate therein; Travel back to Pocatello 5.
Dictate draft of comments for closing technical hearing for
consideration of stipulation; Continued drafting of comments of
IIP A regarding reasons for supporting proposed stipulation and
treatment of Nu- West in alternatives of being a tariff or contract
customer and see that same are filed with commission and served on 4.
the parties
Prepare application for intervenor funding
Continued preparation of application for intervenor funding;
Telephone conference with Lynn Tominaga regarding same and see
that same is filed with commission
F or Current Services Rendered
Long Distance Telephone Expense
Mileage to Preston
Total Costs
Total Current Work & Costs
Previous Balance
Balance Due
35.725.
12.
42.
54.
779.
$12 399.
$17.1 78.
ATTACHMENT 2
Nov.
J an-02 10
Feb.
Date Hours
PacifiCorp BP A/COS/DefelTed Power Costs
Description
Review material supplied by legal counsel from meeting to outline
PacifiCorp s rate new case.
Review material from prior UP &L rate cases to determine how net
power costs were previously addressed.
Review treatment of net power costs in last Utah case and compare
differences between the two cases.
Review of Company filing as well as other materials filed by
PacifiCorp; conversation with legal counsel regarding direction of
case.
Review cost of service and power cost issues in filing in relationship
to other PacifiCorp cases in Utah and Oregon.
Review testimony of Watters as well as accompanying exhibits;
develop interrogatories regarding same.
Continued review of testimony of Watters and review of testimony of
Widmer as well as accompanying exhibits; compare to last filing in
Utah; develop interrogatories regarding service.
Continued review of testimony of Watters and Widmer as well as
accompanying exhibits; continued comparison to last filing in Utah
and Oregon; continued development of interrogatories regarding
same.
Review testimony of Taylor and the Company s cost of service study;
compare to the cost of service study filed in the last case in Utah;
develop interrogatories regarding same.
Continued review of testimony of Taylor and the Company s cost of
service study; continued comparison to the cost of service study filed
in the last case in Utah; continued development of interrogatories
regarding same.
Review cost of service data and develop cost of service study
alternatives that are different than PacifiCorp , focusing on system
coincident demand and power supply cost data.
PacifiCorp BP AlCaS/Deferred Power Costs
Date Hours Descri tIOn
Continued review of cost of service data and development of cost of
service study alternatives that are different than PacifCorp' s focusing
on non-coincident demand and distribution data.
Operate PacifiCorp s cost of service study computer model and
determine how it works.
Review the basis for allocation factors used in the Company s cas
study including the development of coincident peak data and
distribution peak data from the Company s load research data.
Continued review of the basis for allocation factors used in the
Company s COS study including the development of coincident peak
data and distribution peak data from the Company s load research
data.
Continued review of the basis for allocation factors used in the
Company s COS study including the development of coincident peak
data and distribution peak data; compare to results in Utah and note
differences including the use of different times of system coincident
peak for the same month.
Review Company s filing and develop interrogatories regarding cost
of service Issues.
Continued reVIew of Company s filing and development of
interrogatories regarding cost of service issues, noting in particular
differences with the filing in the last case.
Review COS data to determine problem areas in the model; attempt
to develop alternative to these problems.
Develop direction for legal counsel regarding settlement; determine
how PacifiCorp s Exhibit 17 works with respect to how the various
charges are related and discuss with legal counsel.
Mar.Review cost of service and direction for settlement; conference with
legal counsel and IIP A Board regarding what needs to be done at
settlement.
Date Hours
PacifiCorp BP A/COS/Deferred Power Costs
Description
Review various materials supplied by the Company and staff
regarding settlement; prepare for and attend settlement conference
over the phone.
Review data responses to Irrigators and Staff regarding cost of service
issues and Power Cost issues.
Review load research data as it relates to changed usage in this case;
review basis for energy and revenue values in this case that are
significantly higher than anything for irrigators in Idaho in the last 10
years.
Continued review ofload research data; continued review of basis for
energy and revenue values in this case that are significantly higher
than anything for irrigators in Idaho in the last 10 years; continued
formulation of position for settlement.
Continued review ofload research data; continued review of basis for
energy and revenue values in this case that are significantly higher
than anything for irrigators in Idaho in the last 10 years; continued
formulation of a position for settlement.
Various conversations with legal counsel regarding settlement and
review of materials supplied by PacifiCorp regarding settlement.
Conversations with legal counsel, review latest proposals with respect
to settlement for the impact on irrigation and other customers.
Various conversations with legal counsel, Dave Taylor of the
company, and Randy Lobb ofthe Staff; review new data spreadsheet
provided by the Company.
Conversation with legal counsel; review most recent staff proposed
settlement.
Review material supplied by the company in response to our concerns
regarding cost of service; develop a listing of cost of service issues
based on what was filed in this case and what the Company has
recently filed in Utah for the irrigators; prepare a position for
negotiations, conference call with legal counsel and Company.
April
Date Hours
Total 152
PacifiCorp BP AlCOS/Deferred Power Costs
Description
Meeting with Dave Taylor in Salt Lake to discuss various positions
in the case and how to settle the case.
Develop possible compromises based upon conversations with
Taylor; conversation with legal counsel and IIP A Board members
regarding possible compromise position.
Conversation with legal counsel regarding direction of settlement;
review of settlement proposal and possible spread scenarios of COS
and RMA.