20071120Intervenor Funding Petition.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
MITCHELL W. BROWN
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
DAVID E. ALEXANDER
LANE V. ERICKSON
PATRICK N. GEORGE
SCOTT 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
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
BOISE OFFCE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: [phone]
ww.racinelaw.net
IDAHO FALLS O_ICE
477 SHOUP AVENUESUITE203A
IDAHO FALLS, ID83402
TELEPHONE: [phone]
FACSIMILE: [phone]
TELEPHONE [phone]
FACSIMILE [phone]
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE t06A
COEUR D'ALENE, ID 83814
TELEPHONE: [phone]
SENDER'S E-MAIL ADDRESS:elo(§racinelaw.net ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)WIL.LIAM D. OLSON, OF COUNSEL
November 19,2007
f'==-i.
Re: PAC-E-07-05
Jean Jewell, Secretar
Idaho Public Utilities Commission
472 W. Washington Street
Boise, Idaho 83702
Dear Mrs. Jewel:
Enclosed for filing please find the original and seven copies of Idaho Irrgation Pumper's
Association's Application for Intervenor Funding.. ..
Than you for your assistance.
ELO:kb
Enclosures
cc: Serice List (via e-mail &U.S.mail)
~
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]
IO=ll
Attorneys for Interenor
Idaho Irrgation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF CHANCES TO ITS ELECTRIC SERVICE )SCHEDULES )
)
CASE NO. PAC-E-07-05
APPLICATION FOR INTERVENOR FUNING OF
THE IDAHO IRRGATION PUMPERS ASSOCIATION, INC.
COMES NOW the Idaho Irrgation Pumpers Association, Inc. ("Irgators"), by and through
counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public
Utilities Commssion ("Commission") for intervenor fuding, pursuant to Idaho Code § 61-617A
and IDAPA 31.01.01.161 through .165, in Rocky Mountain Power's ("RMP") 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 Exhbit "A" attached hereto
and incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to
Exhbit "A" in support of said sumar and are incorporated by reference.
(B) The Irrgators' President, Mark Mickelsen, board member, Stan Searle, legal counsel,
Eric L. Olsen, and consultant, Anthony J. Yanel, P.E., fully paricipated in these proceedings.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 1
Procedurally, ths case went forward like a full blown rate case with direct and rebuttal testiony
being filed. Ths case also had greater signficance to the Irrgators given the devastating loss of the
BPA Credit in May of this year.
The Irrgators' President, Mark Mickelsen, urged the Commssion that the loss of the BP A
credit and RMP'sproposed rate increase wil cause serous rate shock to the irgation class going
forward. Mr. Mickelsen furter urged that one tool that the Irrgators have to help mitigate the loss
of the BPA Credit and RMP's pending rate increase is to paricipate in RMP's load control
programs. Mr. Mickelsen urged that the Commission mustincrease the credit paid to the Irrgators
who paricipate in the load control programs.
Irrgators board member, Stan Searle, testified that he did not paricipate in RMP's load
control programs in 2007 due to his determination that the credit RM gave to paricipants of the
programs did not outweigh the risks of coverng his sun planting costs and the possibilty oflosing
yields and crop quality if sufficient water was not applied to his crops. Mr. Searle testified that he
would paricipate in the load control programs in the futue if the credit for paricipation in these
programs is large enough to outweigh the risks of paricipation.
The Irrgators' consultant, Anthony Yanel, urged Commission that because of the situs
treatment of the load control credit given to Irrgators, the revenue requirement for Residential and
all other Idaho customers was unjustifiably increased, the more Irrgators join in the load control
programs. He recommended that the Commission treat the irrgation load control programs as
system benefit resources, and not as its present situs cost allocation. Mr. Yanel urged the
Commission that RM's load research data does not fully reflect the level of Irrgation load
curilment, and thus, RMP' s cost of service study attbutes too much demand to the Irrgators and
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 2
thus, increases the costs allocated to the irrgation class. Mr. Yanel recommended that the
Commission adjust the Company's coincident peak data for the Irgators in order to reflect the
actual level of load curailment that is takng place and thereby increase the rate of retu for the
Irrgators and therefore further recommending that the Irrgators get no more than 2/3 of the average
jursdictional percentage rate increase. Mr. Yanel fuher urged the Commission that the present
load control credit for Irrgation customers is considerably below the benefit provided to the system.
He recommended to the Commssion that the load control credit be increased by $40/kW-year, in
order to bring more Irrgators into the program, benefit the entire system at a cost less than avoided
cost, and to provide an overall benefit to the system that is greater than what is presently being
realized. Mr. Yanel fuher urged the Commission to establish time-of-day rates for the Irrgators
as an additional option that could both benefit the system and the customers that choose that rate.
After continuing to prepare for the techncal hearings, RM and the Irrgators reached an
agreement for the settlement ofthis case late in the evenig of November 4,2007. Ths was the
result of active paricipation of Mr. Mickelsen, Mr. Searle and other Irrgators board members, Mr.
Olsen, and Mr. YaneL. Key elements of the Irgators' positions that were put fort before the
Commission were included in the stipulation, principally the equal percentage rate increase for the
irrgation class and the paricipation based increase in the dispatchable load control credit. The
Irrgators were present at the techncal hearing before the commission on November 6,2007, and
urged the Commission to adopted the settlement that had been reached between all pares.
(C) The expenses and costs incured by the Irrgators set fort in Exhbit A and
accompanying attachments are reasonable in amount and were necessarly incured. The expenses
and costs were incured in reviewing the Company's filing and intervenor testimony, preparng and
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 3
reviewing approximately 84 Irrgators' data requests and responses, draftng and fiing direct
testimony, drafting sur rebuttl testimony, preparng sumar testimony and attending public
hearigs, drafting cross-examination questions for the Company and interenor witnesses, and
parcipating in the settlement discussions that resulted in the settlement stipulation that was
presented to the Commission.
(D) The costs descrbed in Paragraph (A) above constitute a financial hardship for the
Irgators. The Irrgators curently have approximately $16,000.00in the ban. Accounts payable
for legal and consultant fees and costs in this case total $66,027.12 as set out in Exhbit "A" and
accompanying attachments, none of which have been paid.
The Irrgators are an Idaho nonprofit corporation qualified under I.R. C. § 501 ( c)( 5)
representing far interests in electrc utilty rate matters affecting farers in southern and central
Idaho. The Irrgators rely solely upon dues and contrbutions voluntarly paid by members, together
with intervenor fuding to support activities and paricipate in rate cases. Each year mailings are
sent to approximately 7500 Idaho Irgators (approxiately two-thirds in the Idaho Power Company
serice area and one-thid in the RMP serce area), soliciting anual dues. The Irrgators
recommend members make voluntar contrbutions based on acres irgated or horsepower per
pump. Member contrbutions have been falling which are believed to be attbutable to the
depressed agrcultual economy and increased operating costs and theats, paricularly those relatig
to water right protection issues.
From member contrbutions 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, Lyn Tominaga, is the only
APPLICATION FOR INTERVENOR FUDING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 4
par-time paid employee, receiving a retaier plus expenses for office space, offce equipment, and
secretaral services. Offcers and directors are elected anually and serve without compensation.
It has been and continues to be a financial hardship for the Irrgators to fully participate in
all rate matters affecting its members. As a result of financial constraints, paricipation in past rate
cases and in this case has been selective and, priarly, on a limited basis. The Irrgators also have
been concurrently paricipating in the Idaho Power Company general rate case, which is adding
additional financial strain on the organization.
(E) The Irgators' positions urged to be adopted by the Commission materally differed
from those addressed by the Commission Staff and other pares on several importt points. First,
the principal tool the Irrgators have to help control their energy costs is volunta paricipation in
RMP's load control programs. The Irgators provided direct testimony that the load control credit
amounts must be increased to encourage greater paricipation, to help the Irrgators have a viable
option to use in mitigating the loss of the BP A Credit, and to bring the credit in line with the benefit
received by RM and the whole Pacifcorp system. In the Stipulation, RM has promised to provide
the Irrgators and Commission Staff with the methodology to value the credit in the futue. The
Commission Staff did not address these load control issues that the Irrgators had raised. Secondly,
the Irrgators urged the adoption of an irrgation time-of-use rate. The Irrgators believe that ths
tye of volunta program could also help reduce Idaho's peak electrcity use like the load control
programs curently in place. The Commission Staff did not address this issue.
(F) The Irrgators' paricipation addressed issues of concer to the general body of users
or consumers on RMP' s and Pacificorp' s system. The irrgation load control programs have enabled
RMP to shave approximately 50 to 75 mwh of load during the sumer system peak in 2006 and
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 5
2007. This reduction in peak load benefits all Idaho customer classes by reducing the overall system
costs allocated to Idaho. This translates into lower rate increases when rate cases are fied.
Continuation and expansion of the irrgation load control programs may also defer the building of
additional generation plant as indicated in Pacificorp' s 2007 Integrated Resource Plan. Avoiding
these tye of costs is also a benefit to all ofRM's Idaho tarff customers.
(G) The Irrgators represent the irrgation class of customers under Schedule 10.
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 § 61-617 A and ID AP A 31.01.01.161 through .165.
DATED ths 19th day of November, 2007.
RACINE, OLSON, NYE, BUDGE &BAILE ERED
By
APPLICATION FOR INERVENOR FUNING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of November, 2007, I sered a tre, 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 deliver, as
indicated below:
Jean Jewell
Idaho Public Utilties Commission
472 W. Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
E-mail: jean.jewellCfuc.idaho.gov
UPS Next Day Letter
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
E-mail: jim.r.smith(lmonsanto.com
E-Mail
Maurce Brubaker
Katie Iverson
Brubaker & Associates
1215 Fer Ridge Parkway, Suite 208
St. Louis, MO 63141
E-mail: mbrubaker(lconsultbai.com
E-mail: kiversonaYsconsultbai.com
U.S. Mail &
E-Mail
Anthony Yanel
29814 Lake Road
Bay Vilage, OH 44140
E-mail: tonYWNane1.net
U.S. Mail &
E-Mail
Idaho Irrgation Pumpers
Association, Inc.
c/o Lyn Tominaga
P.O. Box 2624
Boise,ID 83701-2624
E-mail: lyntominaga(lhotmai1.com
U.S. Mail &
E-Mail
Randall C. Budge
Racine, Olson, Nye, Budge
& Bailey, Chtd.
P.O. Box 1391
Hand Delivery &
E-Mail
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 7
Pocatello, Idaho 83204-1391
Email: rcb(ßracinelaw.net
Brian Dickman
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: brian.dickman(ßpacificorp.com
E-mail: justin.brown(ßacificorp.com
U.P.S.
Overght delivery &
E-Mail
Katherne A. McDowell
McDowell & Rackner
520 Southwest Sixth Ave.
Portland, Oregon 97204
E-mail: katherne(ßmcd-law.com
U.S. Mail &
E-Mail
Tim Buller
Agrum, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbuller~agrum.com
U.S. Mail &
E-Mail
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
608 W. Banock Street
P.O. Box 2720
Boise,ID 83701-2720
E-mail: cew(ßgivenspursley.com
U.S. Mail &
E-Mail
Denns Peseau, Ph.D.
Utility Resources, Inc.
1500 Libert Street S.B., Ste. 250
Salem, OR 97302
E-mail: dpeseaußYexcite.com
U.S. Mail &
E-Mail
Scott Woodbur
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washigton (83702)
P.O. Box 83720
Boise,ID 83720-0074
U.S. Mail &
E-Mail
APPLICATION FOR INERVENOR FUNING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. - 8
E-mail: scott. woodburØ2uc.idaho. gov
E-mail: neiLpriceØ4uc.idaho.gov
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise,ID 83702
E-mail: bmpurdy(fhotmail.com
U.S. Mail &
E-Mail
Kevin B. Homer, Esq.
Attorney at Law
1565 South Boulevard
Idaho Falls, ID 83404
kbh(fkhomerlaw.com
U.S. Mail &
E-Mail
Timothy Shur
411 S. Main
Firth, Idaho 83263
E-mail: tim(fidahosupreme.com
U.S. Mail &
E-Mail
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 9
EXHIBIT A
SUMMARY OF EXPENSES INCURRD BY IRRGATORS
IN CASE NO. PAC-E-07-05
1. Legal Fees:
Eric L. Olsen (Parer):
Dave Bagley (Associate):
Sally Beitia (Paralegal):
120.5 hrs ~ $175.00
1.6 hours ~ $145.00
6.8 hours ~ $75.00
Costs:
Tele. Conf.Long distance:
Postage:
Travel/ileage
Total Work and Costs:
2. Consultant Anthony J. Yanel:
349 hrs ~ $125 per hour
Expenses:
Travel, room and meals
Total Work and Costs:
TOTAL FEES AND EXPENSES:
$21,087.50
$ 232.00
$ 510.00
$ 218.84
$ 71.02
$ 282.76
$22.402.12
$43,625.00
$0.00
$43,625.00
$66,027.12
Attachment 1
Date Atty
6/1/2007 ELO
6/11/2007 ELO
6/12/2007 ELO
6/13/2007 ELO
6/18/2007 ELO
6/19/2007 ELO
6/21/2007 ELO
6/22/2007 ELO
6/25/2007 ELO
7/1/2007 ELO
7/2/2007 DB
7/12/2007 ELO
7/19/2007 DB
7/23/2007 ELO
7/27/2007 ELO
7/30/2007 ELO
7/30/2007 ELO
7/30/2007 ELO
7/31/2007 ELO
8/2/2007 ELO
8/3/2007 ELO
8/6/2007 ELO
RACINE OLSON NYE BUDGE & BAILEY, CHARTERED
IDAHO IRRIGATION PUMPERS ASSOCIATION
Rate Hours Amount Description
175 0.3 52.5 TELEPHONE CONFERENCE WITH MARK MICKELSON
RE: AFFECT OF BPA CREDIT LOSS AND ISSUES IN R
RATE CASE
175 0.4 70 CONFERENCE WITH LYNN TOMINAGA RE: RMP RATE CASE
175 0.1 17.5 CALL AND LEAVE MESSAGE WITH TONY YANKEL
175 0.5 87.5 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
RMP CASE FILING AND STRATEGY RE: SAME; CALL
BRIAN DICKMAN RE: GETTING ELECTRONIC COPY OF
FILING
175 0.2 35 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES IN RMP RATE CASE
175 0.7 122.5 REVIEW EMAIL FROM TONYYANKEL; EMAIL BRIAN
DICKMAN RE: GETING E-COPY OF FILING; TELEPHO
CONFERENCE WITH TONY YANKEL RE: GETTING RMP'S
FILLING IN SUPPORT OF 2006 STIPULATION; REVIE
FILES AND DICTATE LETER RE: SAME; EMAIL TONY
YANKEL 2005 DATA REQUEST FILES
175 0.5 87.5 CONFERENCE WITH RANDY LOBB RE: RMP RATE CASE
ISSUES
175 0.6 105 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
SUBMISSION OF DATA REQUESTS AND REVIEW THE
SAME; REVIEW MONSANTO LETTER RE: ANALYSIS OF
INTERRUPTIBILITY
175 0.3 52.5 PREPARE PETITION FOR INTERVENTION
175 0.2 35 SEE THAT PETITION TO INTERVENE IS PREPARED
145 0.4 58 REVIEW AND REVISE PETTION TO INTERVENE (IDAH
POWER); SEE THAT PETTION IS FILED
175 0.3 52.5 REVIEW MESSAGE FROM SCOTT WOODBURY RE:
SCHEDULING; EMAIL HIM RE: SAME
145 1.2 174 REVISE FIRST DATA REQUEST AND SEE THAT SAME I
FILED AND SERVED TO APPROPRIATE PARTIES
175 0.6 105 REVIEW RMP DISCOVERY RESPONSES TO
MONSANTO'S DATA REQUESTS; CONTINUED REVIEW
OF RMP FILING
175 0.1 17.5 EMAIL FIRST DATA REQUESTS TO PACIFICORP DATA
REQUEST RESPONSE CENTER
175 0.2 35 TELEPHONE CONFERENCE WITH TIM SCHURTZ TACT
TO TAKE IN RMP RATE CASE
175 0.1 17.5 CONFERENCE WITH SB RE: STATUS OF DATA
REQUESTS; ORGANIZING FILE RE: SAME
175 0.5 87.5 TELEPHONE CONFERENCE WITH TONYYANKEL RE:
ADDITIONAL INTERROGATORIES; SEE THAT THIRD SE
OF DATA REQUESTS ARE SENT OUT
175 0.4 70 REVIEW RMP PROTECTIVE AGREEMENT; EXECUTE
EXHIBIT A; EMAIL SAME TO RMP
175 0.8 140 TELEPHONE CONFERENCE WITH MARK MICKELSON
RE: RMP RATE CASE; TELEPHONE CONFERENCE WITH
TONY YANKEL RE: RMP RATE CASE ISSUES
175 1.6 280 REVIEW PACIFICORP DSM REPORT
175 0.4 70 TELEPHONE CONFERENCE WITH TONY YANKEL
Page 1 Irrigation Pumpers Fees
PACIFICORP DSM REPORT AND FINDINGS RE:
IRRIGATION INTERRUPTIBILITY PROGRAM
8/8/2007 ELO 175 0.5 87.5 REVIEW DATA REQUESTS AND SEE THAT SAME ARE
SENT OUT
8/8/2007 SAB 75 0.5 37.5 DRAFT FOURTH DATA REQUEST
8/10/2007 ELO 175 0.1 17.5 TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
WITNESS FOR LAY TESTIMONY IN RMP CASE
8/10/2007 ELO 175 0.4 70 REVIEW RMP SCHEDULING ORDER AND CALENDAR
SAME
8/13/2007 SAB 75 0.5 37.5 FINALIZE AND TRANSMIT FOURTH DATA REQUEST
8/14/2007 ELO 175 1.2 210 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
RMP DISCOVERY OBJECTION AND OTHER ISSUES IN
CASE; REVIEW COMMISSION RULES AND IRCP RE:
SCOPE OF DISCOVERY; TELEPHONE CONFERENCE
WITH MARK MICKELSEN RE: RATE CASE ISSUES;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
4TH DATA REQUESTS AND PRICING OF CREDIT;
REVIEW VOICE MAIL OF BRIAN DICKMAN; CALL AND
LEAVE MESSAGE; EMAIL TONY YANKEL RE: SAME
8/15/2007 ELO 175 0.3 52.5 REVIEW YANKEL'S COMMENTS RE: DSM REPORT AND
CREDIT PRICING AND FORWARD ON TO MARK
MICKELSEN; TELEPHONE CONFERENCE WITH MARK
MICKELSEN RE: SAME
8/16/2007 ELO 175 0.3 52.5 REVIEW FIFTH DATA REQUEST AND SEE THAT SAME I
FILED AND SERVED
8/17/2007 ELO 175 0.5 87.5 TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
MEETING WITH RMP AND STRATEGY ON RATE CASE
8/17/2007 ELO 175 0.3 52.5 FINALIZE FIFTH DATA REQUESTS AND SEE THAT SAM
ARE SERVED
8/22/2007 ELO 175 0.4 70 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES IN RMP RATE CASE
8/23/2007 ELO 175 0.3 52.5 ANALYZE ISSUES WITH RMPDATA REQUEST
8/24/2007 ELO 175 0.4 70 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES ON RUNNING GRID MODEL; TELEPHONE
CONFERENCE WITH BRIAN DICKMAN RE: GETING
COMPUTER TO RUN GRID MODEL AND RUNNING RAM
MODEL; EMAIL TONY YANKEL RE: SAME
8/28/2007 ELO 175 0.1 17.5 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
FINAL DISCOVERY FOR RMP RATE CASE
8/30/2007 . ELO 175 0.5 87.5 TELEPHONE CONFERENCE WITH TONYYANKEL RE:
STATUS OF RMP DATA REQUESTS; CONFERENCE WITH
RCB RE: MONSANTO'S POSITION IN INTERUPTABILIT
PRICING; REVIEW DATA REQUESTS AND SEE THAT SA
ARE ARE SERVED
9/5/2007 ELO 175 0.9 157.5 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES WITH RMP DATA RESPONSES; CALL AND LEAV
MESSAGE WITH JEFF LARSEN RE: SAME; SEE THAT
CONFERENCE CALL IS SET UP TO DISCUSS RATE
CASE; TELEPHONE CONFERENCE WITH MESSRS. BELL
AND BROWN AND TONY YANKEL RE: QUESTIONS ON
DATAPROVIDED FOR IIPA DATA REQUESTS
9/6/2007 ELO 175 0.1 17.5 TELEPHONE CONFERENCE WITH BART KLINE RE:
QUESTIONS ON THIRD DATA REQUEST
Page 2 Irrigation Pumpers Fees
9/10/2007 ELO 175 0.3 52.5 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
RMP RATE CASE TESTIMONY
9/11/2007 ELO 175 0.5 87.5 CONFERENCE WITH RCB RE: MONSANTO'S POSITION
ON PRICING OF INTERRUPTIBILlTY; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME
9/17/2007 ELO 175 1 175 TELEPHONE CONFERENCE WITH STAN SEARLE RE:
IIPAMEETNG AND PROVIDING TESTIMONY;
CONFERENCE WITH SB RE: FINDING CONTACT
INFORMATION FOR MATI LOGOMARSINO; REVIEW;
TELEPHONE CONFERENCE WITH ANN LOGOMARSINO
RE: RMP RATE CASE AND GIVING TESTIMONY RE: SA
9/17/2007 ELO 175 2 350 CONTINUED REVIEW OF RMP RATE CASE FILING
9/17/2007 SAB 75 0.4 30 SEARCH FOR CONTACT INFORMATION FOR HOWE,
AREA FARMER LOGOMARSINO OR SIMILAR NAME
9/18/2007 ELO 175 1 175 TELEPHONE CONFERENCE WITH STAFF RE: ISSUES
WITH RMP CASE FILING; TELEPHONE CONFERENCE
WITH TONY YANKEL RE: SAME
9/19/2007 ELO 175 1.6 280 REVIEW FILE IN PREPARATION FOR PREPARING
HEARING TESTIMONY; TELEPHONE CONFERENCE WITH
MATI LOGOMARSINO RE: AFFECT OF LOSS OF BPA
CREDIT ON OPERATIONS AND PROVIDING TESTIMONY
9/20/2007 ELO 175 3.8 665 PREPARE FOR IIPA MEETING ON RATE CASES;
CONFERENCE WITH STAN SEARLE RE: TESTIMONY
FOR RMP RATE CASE; ATIEND IIPA CONFERENCE CAL
ON RATE CASE
9/21/2007 ELO 175 2.2 385 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
RMP TESTIMONY; DRAFT TESTIMONY OF MARK
MICKELSEN; REVIEW YANKEL DRAFT TESTIMONY
9/24/2007 ELO 175 0.2 35 TELEPHONE CONFERENCE WITH TONY YANKEL
DIRECT TESTIMONY
9/25/2007 ELO 175 504 945 CONTINUED DRAFTING AND REVISING OF TESTIMONY
FOR STAN SEARLE AND MATI LOGOMARSINO; FINISH
DRAFTNG SEARLE DIRECT AND EMAIL SAME;
TELEPHONE CONFERENCE WITH STAN SEARLE RE:
SAME; EMAIL TOMINAGA AND MICKELSEN RE: PUBLIC
HEARINGS AND STRATEGY RE: SAME
9/25/2007 ELO 175 2.1 367.5 REVIEW DRAFTYANKEL'S DIRECT TESTIMONY;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
SAME
9/26/2007 ELO 175 0.2 35 TELEPHONE CONFERENCE WITH MS. LAGOMARSINO
RE: REVIEW OF TESTIMONY
9/26/2007 ELO 175 3 525 DRAFT DIRECT TESTIMONY OF MICKELSEN;
TELEPHONE CONFERENCE WITH MS. MICKELSEN RE:
SAME
9/26/2007 ELO 175 2.1 367.5 PREPARE TESTIMONY EXHIBITS; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: SAME
9/26/2007 ELO 175 0.5 87.5 TELEPHONE CONFERENCE WITH STAN SEARLE RE:
FINALIZING TESTIMONY
9/27/2007 ELO 175 3.1 542.5 REVIEW YANKEL FINAL DIRECT TESTIMONY;
TELEPHONE CONFERENCE WITH TONY RE: EXHIBITS;
TELEPHONE CONFERENCE WITH MRS.
LARGOMARSINO RE: DECLINING TO PROVIDE
TESTIMONY; FINALIZE SEARLE AND MICKELSEN
Page 3 Irrigation Pumpers Fees
TESTIMONY; FINALIZE YANKEL TESTIMONY AND
EXHIBITS; CONFERENCE WITH SAB RE: SERVING SAM
9/28/2007 SAB 75 1.1 82.5 ELECTRONIC TRANSMISSION OF DIRECT TESTIMONY
AND EXHIBITS; TELEPHONE CONFERENCE WITH JEAN
JEWELL; AMENDED NOTICE OF SERVICE
10/1/2007 ELO 175 1.2 210 REVIEW TESTIMONY OF SHURTZ AND AGRIUM'S
EXPERT; CONTINUED REVIEW OF RMP'S INITIAL FIL
TESTIMONY
10/1/2007 ELO 175 0.1 17.5 CONFERENCEWITH SB RE: GETIING ELECTRONIC
DISK OF TESTIMONY TO COMMISSION
10/5/2007 no 175 1.5 262.5 REVIEW APPLICATION OF PRO HAC VICE FOR RMP
LEGAL COUNSEL; REVIEW PACIFICORP'S 2007 IRP I
PREPARATION FOR HEARINGS
10/8/2007 ELO 175 0.3 52.5 TELEPHONE CONFERENCE WITH LYNN AND BRENDA
TOMINAGA RE: UPCOMING PUBLIC HEARINGS AND
GETIING MEMBERS TO SAME
10/8/2007 ELO 175 1.2 210 CONTINUED REVIEW OF PACIFICORP 2007 IRP
10/9/2007 ELO 175 0.5 87.5 REVIEW RMP DISCOVERY REQUESTS AND EMAIL
YANKEL RE: SAME
10/16/2007 ELO 175 0.3 52.5 TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
UPCOMING MEETING WITH ROCKY MOUNTAIN POWER
10/17/2007 ELO 175 1.8 315 TELEPHONE CONFERENCE WITH RANDY LOBB RE: RMP
RATE CASE; TELEPHONE CONFERENCE WITH TONY
YANKEL RE: SAME; REVIEW STAFFTESTIMONY
10/18/2007 ELO 175 3 525 PREPARE FOR RMP MEETING; CONFERENCE WITH
RMP REPRESENTATIVES AND IIPA BOARD MEMBERS
RE: SETILEMENT OPTIONS
10/18/2007 ELO 175 3,9 682.5 CONTINUED REVIEW OF STAFF TESTIMONY;
CONTINUED REVIEW OF RMP TESTIMONY IN
PREPARATION FOR HEARING
10/19/2007 ELO 175 2.7 472.5 CONTINUED REVIEW OF STAFF AND AGRIUM
TESTIMONY; REVIEW RMP TESTIMONY IN
PREPARATION FOR HEARING; TELEPHONE
CONFERENCE MARK MICKELSEN RE: RMP
SETILEMENT DISCUSSIONS; REVEIW LETIERS TO
EDITOR AND READER LETIERS
10/22/2007 SAB 75 1.9 142.5 RESEARCH REGIONAL NEWSPAPERS AND
MEMORANDUM TO ELO WITH INFORMATION ON
DEADLINES, ETC FOR OP-ED PIECES; LISTING OF
NEWSPAPERS OF GENERAL CIRCULATION
10/22/2007 ELO 175 2.9 507.5 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
DISCOVERY RESPONSES AND REBUTIAL TESTIMONY;
CONTINUED REVIEW OF AGRIUM'S TESTIMONY;
TELEPHONE CONFERENCE WITH SCOTI WOODBURY
RE: PROCEDURE FOR HEARINGS; FINALIZE DISCOVER
RESPONSES; TELEPHONE CONFERENCE WITH TONY
YANKEL RE:POSSIBLE REBUTIAL TESTIMONY;
TELEPHONE CONFERENCE WITH STAN SEARLE RE:
TESTIMONY; FINALIZE IIPA'S DISCOVERY RESPONSE
TORMP
10/23/2007 SAB 75 1.4 105 GATHER INFORMATION RE: PUBLICATION OF OP-ED
PIECES/REQUIREMENTS/DEADLINES
10/24/2007 SAB 75 1 75 MEMORANDUM TO ELO WITH COMPREHENSIVE
Page 4 Irrigation Pumpers Fees
INFORMATION RE: NEWSPAPERS OF GENERAL
CIRCULATION IN SNAKE RIVER BASIN; SOUTHEAST
IDAHO AND REQUIREMENTS AND DEADLINES FOR
OPINION PIECES
10/25/2007 ELO 175 2.6 455 REVIEW MONSANTO'S DISCOVERY RESPONSES;
TELEPHONE CONFERENCE WITH STEPHANIE
MICKELSEN RE: LETTERS TO EDITOR AS SEE THAT
SAME ARE FAXED FOR REVIEW; REVIEW RMP'S
REBUTTAL TESTIMONY
10/26/2007 ELO 175 1.2 210 CONTINUED REVIEW OF RMP REBUTTAL TESTIMONY;
TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
GETTING PR OPINION LETERS PUBLISHED
10/26/2007 ELO 175 0.2 35 TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
LETERS; TELEPHONE CONFERENCE WITH LYNN
TOMINAGA RE: SAME; CALLAND LEAVE MESSAGE WIT
JOE DANIELS ABOUT RMP HEARINGS IN GRACE
10/29/2007 ELO 175 4.4 770 RESPOND TO PROCEDURAL MEETNG E-MAIL FOR
STATUS CONFERENCE; CONTINUE REVIEW OF
COMPANY REBUTTAL TESTIMONY IN PREPARATION
FOR HEARING; TELEPHONE CONFERENCE WITH TONY
YANKEL RE: PREPARING SUR REBUTTAL TESTIMONY;
CONTINUED REVIEW OF COMPANY REBUTTAL AND
DIRECfTESTIMONY IN PREPARATION FOR HEARING
10/30/2007 ELO 175 4.5 787.5 PREPARE FOR RATE CASE; TELEPHONE CONFERENCE
WITH STAN SEARLE RE: SCHEDULING TESTIMONY AND
ATTENDANCE AT PUBLIC HEARINGS; PREPARE IIPA
TESTIMONY SUMMARY FOR PUBLIC HEARINGS;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
RMP SETTLEMENT NEGOTIATIONS POSITIONS;
TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
RIGBY HEARING; CONFERENCE WITH LYNN TOMINAGA
RE: SUMMARY OF TESTIMONY AND ATTENDING RIGBY
HEARING
10/31/2007 ELO 175 1 175 TELEPHONE CONFERENCE WITH MARK MICKELSON
RE: RESULTS OF PUBLIC HEARINGS AND RMP GETTIN
METHODOLOGY FOR CREDIT AMOUNT; REVIEW RMP
SETTLEMENT OFFER; REVIEW SUR REBUTTAL
TESTIMONY OF TONY YANKEL
11/1/2007 ELO 175 4.7 822.5 REVIEW RMP SETTLEMENT WORKSHEET; REVIEW
LOAD CONTROL TARIFFS; TELEPHONE CONFERENCE
WITH YANKEL RE: SAME; DRAFT COUNTER-PROPOSAL;
ARRANGE AND PARTICIPATE IN CONFERENCE CALL
WITH IIPA EXEèunVE COMMITTEE RE: RMP
SETTLEMENT OFFER; REVISE COUNTER-PROPOSAL;
TELEPHONE CONFERENCE WITH MARK MOENCH AND
JEFF LARSEN RE: SAME; CONFERENCE CALL WITH
MARK MICKELSEN AND RMP RE: COUNTEROFFER;
TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
SAME
11/1/2007 ELO 175 2.5 437.5 TRAVEL ONE WAY TO GRACE FOR HEARING; ATTEND
RMP RATE CASE PUBLIC HEARINGS IN GRACE
11/2/2007 ELO 175 5.4 945 REVIEW RMP AND STAFF WITNESSES FOR CROSS
EXAMINATION; MULTIPLE TELEPHONE CONFERENCES
PageS Irrigation Pumpers Fees
11/3/2007 ELO
11/4/2007 ELO
11/5/2007 ELO
11/6/2007 ELO
11/6/2007 ELO
11/19/2007 ELO
Bilable
175
WITH TONY YANKEL RE: SAME; PARTICIPATE IN STA
SCHEDULING CONFERENCE FOR RATE CASE;
TELEPHONE CONFERENCE WITH MARK MICKELSEN RE:
RMP COUNTEROFFER; MULTPLE CONFERENCE CALLS
WITH TONY YANKEL AND MARK MICKELSEN RE:
COUNTEROFFER; PARTICIPATE IN MULTIPLE
CONFERENCE CALLS WITH MARK MOENCH AND JEFF
LARSEN
8.7 1,522.50 CONTINUED REVIEW OF RMP DIRECT AND REBUTIAL
TESTIMONY; EMAIL AND TELEPHONE CONFERENCES
WITH JUSTIN BROWN RE: WITNESSES FOR CROSS
EXAMINATION AND PRESENTATION OF LIVE SUR
REBUTIAL TESTIMONY OF MICKELSEN AND YANKEL;
MULTIPLE TELEPHONE CONFERENCES WITH TONY
YANKEL RE: WITNESSES AND ISSUES TO RAISE CROS
EXAMINATION; REVIEW 2007 IRP AND 2007 DSM
REPORT; DRAFT CROSS EXAMINATION; TELEPHONE
CONFERENCE WITH MARK MICKELSEN RE: POSSIBLE
COUNTEROFFERS; TELEPHONE CONFERENCE WITH
RANDY LOBB RE: STAFF POSITION ON LOAD CONTROL
CREDIT
9.5 1,662.50 CONTINUED DRAFTING OF CROSS EXAMINATION RMP
WITNESSES; CONFERENCE CALL WITH TONY YANKEL
AND MARK MICKELSEN RE: TESTIFYING AT HEARING
AND SETILEMENT COUNTEROFFER; DRAFT
COUNTEROFFER FOR SETILEMENT; TELEPHONE
CONFERENCE WITH JUSTIN BROWN AND EMAIL SAME;
REVIEW AND COMMENT ON YANKEL SUR REBUTIAL
TESTIMONY; MULTIPLE TELEPHONE CONFERENCES
WITH YANKEL RE: CROSS AND REBUTIAL QUESTIONS;
MULTIPLE TELEPHONE CONFERENCE WITH MARK
MICKELSEN AND JEFF LARSEN RE: SETILEMENT
NEGOTIATIONS AND SETILE CASE; REVIEW REVISED
SETLEMENT TERMS SHEET AND EMAIL JEFF LARSEN
RE: SAME
2.1 367.5 REVIEW AND REVISE STIPULATION; TELEPHONE
CONFERENCE WITH JUSTIN BROWN RE: SAME; REVIEW
SUBSEQUENT DRAFTS OF SETILEMENT STIPULATION
AND SIGN AND EMAIL SIGNATURE PAGE; PREPARE FO
HEARING
3 525 TRAVEL TO BOISE (ONE WAY) FOR RATE CASE
HEARING
1.8 315 ATIEND PUC HEARING AND SUPPORT APPLICATION OF
STIPULATION FOR SETILEMENT OF RATE CASE
5.4 945 PREPARE APPLICATION FOR INTERVENOR FUNDING
175
175
175
175
175
128.9 21,829.50
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
PACIFICORP/RMP 2007 GENERAL RATE CASE
Page 6 Irrigation Pumpers Fees
TransDate Atty
6/29/2007 ELO
6/29/2007 ELO
6/29/2007 ELO
10/17/2007 ELO
10/17/2007 ELO
11/1/2007 ELO
11/19/2007 ELO
11/15/2007 ELO
11/15/2007 ELO
TOTAL
Cost Transaction File List
RACINE OLSON NYE BUDGE & BAILEY, CHARTERED
IDAHO IRRIGATION PUMPERS ASSOCIATION
Amount
19.72 POSTAGE
2.5 POSTAGE
24.4 POSTAGE
84.88 TELECONFERENCE CHARGES
33.63 TELECONFERENCE CHARGES
95.33 TELECONFERENCE CHARGES
24.4 POSTAGE
226.98 RT MILEAGE POCATELLO-BOISE
55.78 RT MILEAGE POCATELLO-GRACE
567.62
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
PACIFICORP/RMP 2007 GENERAL RATE CASE
Attachment 2
Date Hours Descrption
June 1 1 Review varous materal filed by UP &L regarding commitments; request
copies of the 2007 IRP.
12 4 Review historical FERC Form 1 data in order to develop relationships
between historic usages of varous customer classes and a maner similar
to that presented in IPCo.
15 5 Review cost of serce study results, allocators, and changes in allocation
factors and biling determinants from previous case.
18 4 Read portons of the filing and testimony ofWalje; review how Walje
testimony fits with where the irrgation load is and how the Idaho load has
developed.
19 4 Review testimony of McDougal and begin to develop interrogatories.
21 3 Review testimony ofWidmer:;review his listing of costs and cost
changes; compare changes in costs with historical records from other data
22 6 Review testimony of Tucker and Grffith as well as associated exhbits;
do calculations in order to check exhibits; develop and finalize fial set of
interrogatories.
July 2 7 Review testimony ofWalje and develop interrogatories regarding
distrbution plant in Idaho; Review McDougal testimony and develop
interrogatories regarding system wide new plant, the BP A credit and
3 4 Review McDougal testimony and develop interrogatories regarding
Irrgation Load Control, and DSM; review testimony of Widmer and
develop questions regarding net power costs.
16 7 Break out June and July data for Irgation load research for 2003 so as to
develop an individual profile of usage for Irrgators for the whole
sumer; use these profiles to review the abilty to develop time-of-use
rates for the irrgation class.
18 8 Break out August and September data for Irrgation load research for
2003 so as to develop an individual profile of usage for Irrgators for the
whole summer; use these profies to review the ability to develop time-of-
use rates for the irgation class.
19 7 Aggregate load research data for 2003 and substitute Monday loads for
Sundays and visa versa; determine impact of change of usage when
incorporating time of day rates.
20 8 Aggregate load research data for 2003 and substitute Thursday and Friday
loads for Satuday and Sundays and visa versa; determine impact of
change of usage when incorporating time of day rates.
Date Hours Description
23 7 Aggregate load research data for 2003 and substitute largest use loads for
Satuday and Sundays and visa versa; determne impact of change of
usage when incorporating time of day rates.
24 8 Review data responses to for Monsanto; review impact ofload growth on
Residential, Commercial, and Irrgation customers; develop
interogatories dealing with time of use.
26 3 Review data responseses to Staff Request 1 and data responses to
Monsanto Request 2.
27 3 Review responses to Staff data requests as well as responses to requests
made by Monsanto.
30 8 Develop interogatories related to Net Power Cost; the basis of the load
that goes into the Net Power Cost model; and the establishment of a
number of scenaros regarding shifting in time of use and the resulting
impact upon system costs and Idaho jursdictional costs; develop 4th set
31 4 Review the Company's responses to Monsanto's 2nd set of interrogatories
and review the varous attachments that support these responses.
Aug 2 4 Review different impacts of rates under existing Schedules 1 and 36 with
Schedule 10 and 72 in order to determine relative impacts of time of day
rates on the varous irrgation rate schedules.
6 7 Read the Company's recent report wrtten by Quantec regarding an
assessment oflong-term system-wide potential for demand side and other
supplemental resources. Review appendices as well.
7 7 Read the Company's recent report wrtten by Quantec regarding an
assessment oflong-term system-wide potential for demand side and other
supplemental resources. Review appendices as well. Develop
interogatories.
15 7 Review load research data from 2003 to develop patterns of usage for
different sided (strata) irgators in order to review the possibility of time
of day rates being an effective way to shift load.
20 3 Review load research data from 2003 to develop patters of usage for
different sided (strata) irrgators in order to review the possibility of time
of day rates being an effective way to shift load.
22 2 Review responses to Irgator's first data set; look for problems with the
responses and develop additional data requests as needed.
.'Date Hours
23 8
24
27
28
29
30
Description
Review data responses to Irrgator's first data request; develop a means of
extracting compressed files that were in Text and get them into Access
format; work unsuccessfully to extrat data from some file that were sent
that could not be extracted; request the data fies that were too large to be
broken down by year, instead of thee years together.
8 Review data responses to Agrum and Monsanto; review data responses to
Irgators; look into Revised Protocol and the basis for treating Monsanto
differently on a jursdictional basis than the Irrgators that are curailed.
8 Review background regarding the Revised Protocol method including the
testimony of Taylor and other witnesses for the Company in Case No.
P AC- E-02-3; review exhibits filed on Februar 28, 2005 regarding how
the Revised Protocol worked; review differences between the treatment of
special contract customers and DSM.
6 Review data responses to Irrgator requests and those of others: review
data given regarding maximum prices paid for purchase power between
data given to Irrgators response 1.11 and Monsanto response 2.50 and tr
to discer why the data for the same hours should be different.
8 Put together computer and components for GRID: review 300 pages of
manuals regarding the operation of the GRID program; conversations
with PacifiCorp employee regarding the rung of the GRID modeL.
8 Review Irrgation load research data in order to see how different sized
customers used energy differently from each other durg 2006; observe
and ask questions regarding why some Irgation samples were missing,
and what was done with the missing data; begin to sumarize data into
categories like average usage by hour and average usage by day of the
31 Review Irrgation load research data in order to see how different sized
customers used energy differently from each other durng 2006; begin to
summarze data into categories like average usage by hour and average
usage by day of the week; work with Laren Hale ofPacifiCorp in order to
lear how to run the GRID modeL.
Sept 4
5
6
7 Work with Laren Hale ofPacifiCorp in order to run GRID model; analize
varous rus and continue to work with Hale in order to correct problem.
7 Analize proposed modeling of 25 MW of irrgation curailment in GRID
in order to assess what was wrong with the results; review individual load
research data for irrgators in order to determine impact on results of the
customers that are under Schedule 72; review the impact of individual
residential load research data and attempt to follow how these number
flow though to the cost of service study.
1 Work with Scott Thornton ofPacifiCorp regarding load research data
problems.
. .Date Hours
7 2
8 4
10 6
11 7
12 4
13 8
14 7
15 . 4
17 8
18 8
Description
Review emails from PacifiCorp regarding data problems in the load
research data; change data and review impacts; conversations with load
research personel; conversations with company regarding additional
discover responses thatwere not able to be opened; conversation with
Hale regarding GRID problem.
Review GRID output for possible flaws in the model; review data
responses to the Staff regarding weather normalization and compare how
weather normalization occurs between Sch. 1, Sch. 36, and Sch. 23.
Work with PacifiCorp Hale in order to ru GRID in order to understand
the underlying reasons for the counterintuitive results of shifting on-peak
load; review varous outputs of the GRID model including hourly sales
and purchases under the original model run and under the assumption of
shifting some on-peak load to off-peak.
Review data responses; review hourly data from GRID model to assess
the appropriateness of the model to reflect what is transpirng on the
system and how the GRID model reacts to changes in load such as result
for the irgation load management program.
Review data regarding hourly usage of the most expensive purchases on
the system in order to develop a means of assessing this data on an hourly
basis as well as the same day of the week basis in order to understand the
patterns involved in the costs.
Outline testimony issues regarding the overall revenue requirement give
the GRID model; inaquities in the Revised Protocol; lack of
representation of the irgation load management program in the cost of
serce study; and the need to better price irrgation load management and
to develop a time of use rate for irrgators.
Writing testimony regarding the impact of the BP A credit loss and the off-
setting impacts of possible DSM options.
Writing testimony regarding the impact of the BP A credit loss and the off-
setting impacts of possible DSM options.
Develop load and cost data for Irrgation Load Curailment program
recommedation; calculate a balance between the level of the credit and the
amount of benefit to be provided to the system.
Write testimony regarding pssoble time-of day rates for Irrgators;
develop Irrgation load research data so as to be combined to reflect the
average hour usage of the average Irgation customer on any given day of
the week for puroses of pricing.
Date Hi
19 7
20
21
Description
Write testimony regarding pssoble time-of day rates for Irrgators;
develop Irrgation load research data so as to be combined to reflect the
average hour usage of the average Irgation customer on any given day of
the week for puroses of pricing' wrte summar for Irrgators review for
upcoming conference call with the Board in order to go over proposals.
8 Review data regarding Irrgation curailment program and time-of-day
rates; continue to develop numbers that reflect possible senaros for rates
for TOD; conference call with Irrgators regarding direction for rate
7 Review new data responses to Irgators and Monsanto; review impact of
Rivised Protocol on Idaho and develop testimony regarding same; look
into problems with GRID model; coordinate with Iverson regarding
GRID and other issues.
24 8 Review and continue to develop testimony regarding the load research
data and its impacts upon the Company's cost of serice study; develop
exhbits that show the lack of representation in the irrgation demand data
of the load curailment customers; develop allocation recommendation,
given the Company's position and the changed data provided by the
25 8 Develop alternative approach to calculating the credit for the irgation
load curilment program; review historic cost and paricipation
information regarding the irrgation load curtailment program.
26 8 Reread testimony; develop testimony that reflected the recent DSM
Report put out by the Company; make changes to insure that testimony
was interally consistent.
27 6 Review final testimony; correct wording erors; compile exhibit 305;
conversations with Olsen.
18 3 Settlement conference call with PacifiCorp; follow-up conversation with
Olsen; review of testimony of the Staff in the case.
19 3 Review testimony of Staff; review of testimony of other witnesses in
case; review Company's proposed settlement offer regarding credit to the
Irrgators and ways to price it.
22 5 Review Iverson testimony for Monsanto; review data regarding number
and times of Monsanto interrptions and compare with time of year, day
of week and time of day; develop list of hours of highest usage on the
system and compare with times of Monsanto interrptions.
23 4 Review testimony ofPeseau; develop position regarding how the credits
to Monsanto can be translated into the irgation credit; conversations
with Olsen regarding both issues.
26 4 Review rebuttl testimony of Company
..
Date Hours
29 4
30
31
Nov 1
2
3
4
Total 349
(q $125/hour
$43,625
Description
Review rebuttal testimony of Company; talk to Iverson regarding similar
positions regarding interrptibility credits.
1 Conversations with Olsen regarding settlement talks as well as direction
of our rebuttal to the Company.
4 Review Company rebuttal; develop data to support the $51 based upon
new information; draft rebuttaL.
4 Multiple conversations with Irrgators, Olsen, and PacifiCorp regarding
settlement; develop data and memo to support our positions.
3 Multiple conversations with Irgators, Olsen, and PacifiCorp regarding
settlement.
6 Develop cross examination positions for varous witnesses; develop
crossexamination questions for specific witnesses; do extensive review of
the Company's 2007 IRP as well as the DSM study that was published.
6 Finalize rebuttal testimony; converations with Irrgators; review
settlement offers; organize materals to take to Boise.