20101216Application for Intervenor Funding.pdf

W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.D.
LANE V. ERICKSON
DAVID E. ALEXANDER
PATRICK N. GEORGE
SCOTT J. SMITH
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
BRENT L. WHITING
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN
THOMAS J. BUDGE
CANDICE M. MCHUGH
JONATHAN M. VOLYN
MARK A. SHAFFER
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED BOISE OFFICE
t01 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone] t 1
FACSIMILE: [phone]
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, 10 83402
TELEPHONE: [phone]FACSIMILE: [phone]ww.radnelaw.net
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE tOBA
COEUR D'ALENE, 1083814
TELEPHONE: [phone]
SENDER'S E-MAIL ADDREss:elo!§racinelaw.net
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)
WILLIAM.D. OLSON. OF COUNSEL
December 16, 2010
Jean D. Jewell, Secretar
Idaho Public Utilties Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. PAC-E-IO-07
Dear Ms. Jewell:
t?~
Enclosed for fiing in the captioned matter, please find the original and seven (7) copies of
the Application for Intervenor Funding of the Idaho Irrigation Pumpers Association, Inc.
ELO:rg
Enclosures
cc: Service List
Sincerely,
) 99- FOA
~CL.~EN
I=
Q
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]
20W DEC f 6 Pr1 3: 27
Attorneys for Intervenor
Idaho Irrgation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICA nON OF )
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF CHANGES TO ITS ELECTRIC SERVICE )
SCHEDULES AND A PRICE INCREASE OF )
$27.7 MILLION, OR APPROXIMATELY 13.7 )PERCENT )
)
CASE NO. PAC-E-IO-07
APPLICATION FOR INTERVENOR FUNDING OF
THE IDAHO IRRGATION PUMPERS ASSOCIATION, INC.
COMES NOW the Idaho Irrgation Pumpers Association, Inc. ("Irrgators"), by and though
counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public
Utilities Commission ("Commission") for interenor funding, pursuant to Idaho Code § 61-617 A
and IDAPA 31.01.01.161 through .165, regarding the fees and costs associated with the Irgators
paricipation in the above referenced matter, 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 fort in Exhbit "A" attached hereto
and incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to
Exhibit "A" in support of said summar and are incorporated by reference.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC.-1
(B) Rocky Mountain Power ("RMP" or "Company"), a division ofPacifiCorp, provides
power to thousands of individuals and entities thoughout Idaho and is now in the middle of a large
expansion program. This building program is planed to signficantly increase the amount of
Generation, Transmission, and Distrbution plants that PacifiCorp has in its servce terrtory.
Notwithstanding the great recession, the constrction of these new facilties is considered justified
based on anticipated need in the futue and the Company's and PacifiCorp's obligation to sere and
not the inability to meet current demand in these depressed economic times.
RMP fied its application ("Application") seeking authority to put into rate base Idaho's share
of the $4 bilion of the new investments and $87 milion of increased net power costs. This
amounted to a requested increase in revenue requirement of approximately $24.9 milion or a 12.3%
average increase over RMP's curent rates.
The Irrgators have paricipated in all facets of this case and filed the direct testimony of its
expert Anthony Yane1 and sur rebuttal testimony of its President, Mark Mickelsen. The positions
that the Irrgators have asked the Commission to adopt are as follows:
1. Although RMP recognzes that the 2009 Irgation sales were quite low because of
"an unusually wet spring", its weather normalization process does not address
precipitation. Using RMP' s weather normalized Irgation sales for the 11 years prior
to 2009, it can be projected that in 2010 that the weather normalized Irgation sales
should have been 545,000 MWH (17.7%) higher than used in the Company's filing.
The test year Irgation revenue as well as the Idaho Jurisdictional revenue would be
increased $7 milion if a realistic weather normalized Irrgation sales figue would
have been used.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 2
2. RMP has assigned too much cost responsibilty to the Idaho jurisdiction based upon
the energy allocation factor used for Idaho. This energy factor is based upon the
same forecast sales data as used to develop the Idaho revenue, but a different
(greater) set oflosses is applied to these sales than is calculated in the RMP's loss
study for Idaho. PacifiCorp uses somethng referred to as "Border Load" to calculate
Idaho's losses for jurisdictional allocation puroses. This Border Load method
effectively measures all losses that occur in Idaho. However, only 23 % of all of the
electrcity that enters the Idaho jursdiction is consumed in Idaho, with the rest of it
simply passing through to non-Idaho customers. Idaho customers should not be
charged for losses associated with energy that is simply passing through Idaho to
sere others.
3 The IIP A concludes that although the Irgation Load Control Program is a major
benefit to the system (provides a great savings for all system customers), the Idaho
customers are paying signficantly more than the benefit that they are receiving. The
LIP A recommends that in the long ter (by the next rate case) that this program be
treated more as a system benefit where the curilments are "sold" to the system at
their tre value. For puroses of this case, a more realistic reduction/credit should
be given to Idaho in the Company's jurisdictional allocation model that reflects the
actual curtailment that was available durng the test year as opposed to the limited
(lower) amount that was used in the RM's filing. Use of actual 2010 curailment
levels as opposed to levels lower than what were even available in 2009 results in a
reduction of the revenue requirement by 2.5 milion.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 3
4. The IIP A has concerns about the Load Growth Adjustment Rate ("LGAR") that is a
part of the Company's ECAM proceeding, but the rate is set in ths, a general rate
case. The LGAR was originally established to keep the RMP from double recovery
of growth related power supply costs. An unforeseen problem has arisen with respect
to the fact that it was never conceived that load would be decreasing as opposed to
increasing between rate cases. Under such circumstances, the LGAR acts as a
decoupling mechanism and actually increases rates when load is lost. IIP A
recommends that the Commission specify that the LGAR is not a symetrcal
adjustment and that it only is used when there is growth between rate cases.
5. The lIP A believes that in light of the adjustments for irrgation sales and the
problems with PacifiCorp's loss study, the Irgators believe that RMP's cost of
serice study (as was the jursdictional model) does not have an adequate level of test
year sales to the Irgators. The Irgators also point out that the class cost of servce
study does not reflect the peak load reduction capabilty that is available, or even as
used in the jurisdictional study. The Irgators do not present specific adjustments
to this study, but simply recommend adoption of the RMP's proposed increase to the
Irgators that is set at 70% of the jurisdictional average increase.
6. The Irrgators want the Commission to bifurcate the consideration of changes to the
Irrgation Load Control Program to allow the Staff, Irrgators and other interested
paries proper time to review the same. In the event the Commission wil address
RMp's proposed changes in its pending order, then the Irrgators ask that the
Commission (l) limit paricipation to pumps having 30 HP or less, (2) allow the
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 4
inclusion of additional language in the tarff similar to Idaho Power's paricipation
selection language, but with the understanding to use it prudently, (3) allow a fixed
opt out penalty of$0.005 per kWh of monthly biling like Idaho Power, and (4) make
RMP live up to the terms of its letter agreement to keep the pricing of the Load
Control Program at $30 per kW for the 2011 and 2012 irrgation seasons.
(C) The expenses and costs incurred by the Irrgators set forth in Exhibit A and
accompanying attachments are reasonable in amount and were necessarly incurred. The expenses
and costs were incured in reviewing the RMP's filing, developing data requests, reviewing data
requests, preparng direct and surrebuttal testimony, preparng for cross examination ofRMP's and
interenor witnesses and paricipating in the techncal hearngs.
(D) The costs descrbed in Paragraph (A) above constitute a financial hardship for the
Irrgators. The Irrgators currently have approximately $33,005 in the ban with outstanding
accounts payable from paricipation in other cases and this case totaling approximately $51,350.
The Irrgators are an Idaho nonprofit corporation that was organized in 1968 to represent
agrcultual interests in electrc utilty rate matters affecting farers in souther and central Idaho.
The Irrgators rely solely upon dues and contrbutions voluntarily paid by members, together with
interenor fuding, to support activities. Each year mailings are sent to approximately 7,500 Idaho
Irrgators (approximately two-thirds in the Idaho Power Company serce area and one-third in the
RMP service area), soliciting anual dues. The Irrgators recommend members make voluntar
contrbutions based on acres irrgated or horsepower per pump. Member contrbutions have been
fallng presumably due to the curent depressed economy, increased operating costs and threats
relating to water right protection issues.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 5
From member contrbutions the Irrgators must pay all expenses, which generally include
mailng expenses, meeting expenses and shared offce space in Boise, Idaho, in addition to the
expenses relating to paricipation in rate cases. The Executive Director, Lyn Tominaga, is the only
par-time paid employee, receiving a retainer plus expenses for office space, office equipment, and
secretaral services. Offcers and directors are elected annually and sere without compensation.
It has been and continues to be a financial hardship for the Irrgators to fully paricipate in this
review and settlement. As a result of financial constraints, paricipation in this review and settlement
has been selective and, primarly, on a limited basis.
(E) The Irrgators' positions urged to be adopted by the Commission materally differed
from those addressed by the Commission Staff and other paries on several important points. First,
the Irrgators addressed the differential of Jurisdictional Sales and Jursdictional Allocations.
PacifiCorp's case had 2.66% more energy/kWh responsibilty attbuted to Idaho in the jurisdictional
allocation model than what was attrbuted to Idaho for the calculation of jursdictional revenues.
The reason for this differential was traced to the fact that Pacificorp assigned too much line losses
to the Idaho jursdiction. When the proper amount of energy was run through the JAM and RAM
models, RM proposed rate increase should be reduced by $5,394,641. Ths issue was not addressed
by Staff or other intervenors.
The Irrgators also pointed out that the test year sales/revenue for the numbers for the
residential class were suspect due to the same reasons that Irrgation sales revenue were too low.
This issue was not addressed by Staff, but was mentioned by other intervenors.
Since this case wil set base net power supply costs, the Irrgators asked to Commission to find
that the application ofthe LGAR in RMP's ECAM should not be applied symetrcally so that in
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 6
periods of declining load it does not act like a decoupling mechansm and impute revenue to recover
RMP's fixed costs. This issue was not addressed by Staff or other intervenors.
Finally, the Irrgators supported a system allocation of the costs of the Irrgation Load Control
Program. In the interim, the Irrgators put forth the proposition to increase the credit flowing to
Idaho in the JAM model for actual curtailment available in 2010 rather than the 2009 amounts. This
change would result in a reduction in revenue requirement of approximately $2.5 milion. This issue
was not addressed by Staff or the other interenors.
(F) The Irrgator's proposed adjustments resulting from the appropriate amount of
transmission losses attrbutable to Idaho and getting a more appropriate interption credit in the
JAM model for the Load Control Program result in the reduction ofRMP's proposed rate increase
of approximately $7.8 milion. These reductions directly affect the whole body of customer classes
on RMP's Idaho system by benefitting all with a lower average rate increase.
(G) The Irrgators represent the irrgation class of customers under Schedule 24.
Based on the foregoing, it is respectfully submitted that the Irrgators are a qualifyng
interenor 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.
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC.. 7
DATED ths the J L14dayofDeCember, 2010.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRIGATION PUMPERS ASSOCIATION, INC. - 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 16th day of December, 2010, I sered a true, correct and
complete copy of the Idaho Irgation Pumpers Association, Inc. 's Applicationfor Interenor Funding
to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as indicated
below:
Jean D. Jewell, Secretar
Idaho Public Utilties Commission
P.O. Box 83720
472 WI Washington Street
Boise, Idaho 83720-0074
j jewell~uc.state.id. us
U.S. Mail/Postage Prepaid
_~_E-Mail
Facsimile
Overnight Mail
x Hand Delivered
Ted Weston
Idaho Regulatory Affairs Manager
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted. weston~acificorp.com
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overight Mail
Hand Delivered
Electronic Copies Only:
Mark C. Moench
Daniel E. Solander
PacifiCorp/dba Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
mark.moench(ipacificorp.com
daniel.solander(ipacificorp.com
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overnght Mail
Hand Delivered
Data Request Response Center
Pacificorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
dataequest(ipacificorp.com
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overight Mail
Hand Delivered
Scott Woodbur
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washington (83702)
PO Box 83720
Boise, Idaho 83720-0074
scott. woodbur(ipuc.idaho. gov
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overight Mail
Hand Delivered
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 9
Randall C. Budge
Racine Olson Nye Budge & Bailey Chtd.
P.O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204
rcbWracinelaw.net
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overght Mail
~_ Hand Delivered
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
kiversonWconsultbai.com
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overght Mail
Hand Delivered
Electronic Copies Only:
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, il 83276
Jim.r.smithWmonsanto.com
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overight Mail
Hand Delivered
Tim Buller
Jason Hars
Agrum Inc.
3010 Conda Road
Soda Springs, ID 83276
TBullerWagrium.com
JAHarisWagrium.com
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overight Mail
Hand Delivered
Benjamin J. Otto
Idaho Conseration League
710 N. 6th Street
POBox 844
Boise, Idaho 83702
bottoWidahoconservation.org
U.S. Mail/Postage Prepaid~_E-Mail
Facsimile
Overnight Mail
Hand Delivered
Melinda J. Davison
Davison Van Cleve, P.C.
333 SW Taylor, Suite 400
Portland, OR 97204
mjdWdvclaw.com
U.S. Mail/Postage Prepaid
x E-Mail
Facsimile
Overnight Mail
Hand Delivered
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC. -10
Ronald L. Wiliams
Wiliams Bradbury, P.e.
1015 W. Hays St.
Boise, Idaho 83702
ron0)willamsbradbui.com
U.S. Mail/Postage Prepaid
--_ E-Mail
Facsimile
Overnght Mail
Hand Delivered
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
bmpurdy0)hotmail.com
U.S. Maillostage Prepaid
--_ E-Mail
Facsimile
Overnight Mail
Hand Delivered
Fó,
LSEN
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRGATION PUMPERS ASSOCIATION, INC.-11
EXHIBIT A
SUMMARY OF EXPENSES INCURRD BY
IRRGATORS IN CASE NO. PAC-E-IO-07
1. Legal Fees:
Eric L. Olsen (Parner): 122.4 hrs t§ $185.00 per hour $ 22,644.00
Costs: Postage/travel/hotel/meals $ 1.655.98
Total Legal Fees & Costs:$ 24,299.98
2. Consultant Fees:
Anthony J. Yanel: 100 hrs t§ $125 per hour $ 60,625.00
Costs: Travel & Meals $ 1,930.34
Total Consultant Fees & Cost $62.555.34
TOTAL FEES AND EXPENSES:$86,855.32
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. - 12
Attachment 1
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. -13
Detail Fee Transaction File List
RACINE, OLSON, NYE, BUDGE & BAILEY CHARTERED
Trans Hours
Date Att Rate to Bil Amount Description
6/1/2010 ELO 185 0.40 74.00 REVIEW AND REVISE PETITION TO INTERVENE AND SEE
THAT SAME IS FILED
6/11/2010 ELO 185 0.10 18.50 EMAIL TED WESTON YANKElS CONTACT INFORMATION
FOR ACCESS TO THE GRID MODEL
6/12/2010 ELO 185 1.0 222.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE: HIS
OBSERVATIONS ON REVIEW OF RATE CASE; DRAFT
EMAIL TO EXECUTIVE BOARD RE; ISSUES RAISED BY
RATE CAE; TELEPHONE CONFERENCE WITH LYNN
TOMINAGA RE: SAME
6/15/2010 ElO 185 1.60 296.00 EXECUTE PROTECTIVE AGREEMENT AND EMAIL
SIGNATURE PAGE TO RMP'S COUNSEL; PREPARE DATA
REQUESTS; TELEPHONE CONFERENCE WITH JUDY
ERWIN RE: CONFERENCE CALL; EMAIL EXECUTIVE
COMMITIEE RE: CONFERENCE CALL; REVISE DATA
REQUESTS AND SEE THAT SAME ARE SERVED ON
PARTIS
6/17/2010 ELO 185 1.0 203.50 PREPARE FOR AND PARTIOPATE IN IIPA CONFERENCE
CALL WITH EXECUTIVE BOARD CONFERENCE CALL;
REVEIW EMAIL FROM RMP COUNSEL RE: DATA
REQUESTS
7/7/2010 ELO 185 0.30 55.50 SEE THAT DATA REQUESTS ARE PREPARED
7/12/2010 ELO 185 0.20 37.00 REVIEW NOTICE OF PARTIES AND ORDERS FOR
INTERVENTION
7/19/2010 ELO 185 0.30 S5.s0 REVIEW 3RD DATA REQUESTS AND SEE THAT SAME ARE
SENT OUT
8/9/2010 ELO 185 0.20 37.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
STATUS OF REVIEW AND ISSUES TO RAISE IN DIRECT
TESTIMONY AND NEED FOR FURTHER DISCOVERY
8/13/2010 ELO 185 1.60 296.00 REVIEW PACIFICORP DIRECT TESTIMONY IN
PREPARATION FOR HEARINGS
8/16/2010 ELO 185 0.90 166.50 CONTINUED REVIEW OF RMP DIRECT TESTIMONY
8/17/2010 ELO 185 1.20 222.00 CONFERENCE WITH MARK MICKELSEN RE: ISSUES WITH
INTERRUPT1BILlTY PROGRAM AND RMP RATE CASE
8/19/2010 ELO 185 0.70 129.50 CONTINUED REVIEW TESTIMONY OF WITNESS
MCDOUGAL
8/20/2010 ELO 185 1.10 203.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
INFORMATION ABOUTM$P ALLOCATION IN RMP RATE
CASE; CONTINUED REVIEW OF RMP DIRECT TESTIMONY
8/23/2010 ELO 185 0.20 37.00 EMAIL TONY YANKEL RE: ISSUES WITH RMP RATE CASE
REVIEW
8/24/2010 ELO 185 0.20 37.00 SEE THAT DATA REQUESTS ARE SENT OUT; REVIEW
DATA REQUESTS AND SEE THAT SAME ARE PREPARED
AND SENT; TELEPHONE CONFERENCE WITH TONY
YANKEl RE: REVIEW OF LGAR FOR NEW POWER COSTS
8/25/2010 ELO 185 0.50 92.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
OTHER ISSUES TO EXPLORE IN DATA REQUESTS; EMAL
TONY YANKEL RE: ECAM CAE; REVIEW EMAIL ABOUT
CLARIFICATIONS OF DATA REQUESTS
8/31/2010 ELO 185 0.20 37.00 TELEPHONE CONFERENCE WITH TONY RE: RMP RATE
CASE ISSUES
9/72010 ELO 185 0.10 18.50 CALL AND LEAVE MESSAGE WITH TONY YANKEL
9/8/2010 ELO 185 1.40 2S9.OO CONFERENCE CALL WITH TONY YANKEL AND WITH
STAFF REGARDING ISSUE OF ALLOCATION OF COSTS
ASSOCIATED WITH LOAD CONTROL PROGRAM
9/9/2010 ELO 185 0.50 92.50 TELEPHONE CONFERENCE WITH TONY YANKEL
REGARDING ISSUES WITH RMP RATE CAE AND
UPCOMING CONFERENCE CALL WITH RMP ANALYST; GET
AND EMAIL DATA REQUEST INFORMATION FOR TONY
FOR REVIEW
9/17/2010 ELO 185 0.40 74.00 REVIEW DATA RESPONSES IN RMP CASE; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: STATUS OF
REVIEW
9/22/2010 ELO 185 0.20 37.00 TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
STATUS OR ROCKY MOUNTAIN RATE CASE
9/24/2010 ElO 185 0.30 55.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES TO ADDRESS IN DIRECT TESTIMONY
9/29/2010 ELO 185 0.70 129.50 CONFERENCE RE: ISSUES WITH RMP RATE CAE
10/1/2010 ELO 185 1.70 314.50 CONTINUED REVIEW OF COMPANY TESTIMONY; SEE
THAT MISSING DATA REQUESTS ARE SENT TO TONY
YANKEL FOR REVIEW
10/4/2010 ElO 185 0,60 111.00 TELEPHONE CONFERENCE WITH LYNN TOMINAGA RE:
EXECUTIVE COMMITTEE CONFERENCE CALL;
TELEPHONE CONFERENCE WITH SID ERWIN RE: SAME;
CALLAND lEAVE MESSAGE WITH YANKELAND MARK
MICKELSEN; EMAil CONFERENCE CAll INFORMATION
10/5/2010 ElO 185 0.70 129.50 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
ISSUES TO BE RAISED IN DIRECT TESTIMONY
10/6/2010 ELO 185 0.20 37.00 EMAil EXECUTIVE COMMITTEE RE: DRAFT TESTIMONY
ADVANCE OF CONFERENCE CALL
10/11/2010 ElO 185 3.60 666.00 REVIEW AND REVISE YANKEL DIRECT TESTIMONY
10/13/2010 ELO 185 5.00 925.00 REVIEW AND REVISE YANKEl'S DIRECT TESTIMONY;
CONFERENCE WITH YANKEL RE: DIRECT TESTIMONY;
PREPARE EXHIBITS FOR FILING
10/14/2010 ELO 185 2.10 388.50 FINALIZE DIRECT TESTIMONY OF TONY YANKEL AND
THAT SAME IS FILED AND SERVED ON THE PARTIES
10/19/2010 ELO 185 0.60 111.00 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
POSITIONS OF OTHER PARTIES IN RATE CASE;
TELEPHONE CONFERENCE WITH DANIEL SOLANDER RE:
GmlNG COPIES OF WORK PAPERS; TELEPHONE
CONFERENCE IWHT TONY YANKEl RE: GETTING COPIE
OF WORK PAPERS FOR OTHER PARTIES
10/20/2010 ELO 185 0.30 55.50 TELEPHONE CONFERENCE WITH TONY YANKEl RE:
REVIEW OF OTHER PARTY'S TESTIMONY
10/21/2010 ElO 185 1.00 185.00 REVIEW OTHER INTERVENOR DIRECT TESTIMONY
10/22/2010 ELO 185 1.20 222.00 CONTINUED REVIEW DIRECT INTERVENOR TESTIMONY
10/25/2010 ELO 185 0.20 37.00 REVIEW COMMISSION ORDER RE: MONSANTO
INTERRUPTI81l1TY HEARINGS; EMAIL TONY YANKEL
SAME
10/25/2010 ELO 185 0.80 148.00 CONTINUED REVIEW OF INTERVENOR DIRECT
TESTIMONY
10/27/2010 ELO 185 2,50 462.50 CONTINUED REVIEW OF INTERVENOR DIRECT
TESTIMONY
11/1/2010 ELO 185 0.90 166.50 PREPARE FOR AND PARTICIPATE IN EXECUTIVE BOARD
CONFERENCE CALL REGARDING ISSUES AND STATUS OF
RMP RATE CAE
11/2/2010 ELO 185 0.20 37.00 REVIEW REVISIONS TODIRECTTESTIMONY
11/5/2010 ELO 185 2.60 481.00 REVIEW STAFF AND OTHER INTERVENOR DIRECT
TESTIMONY
11/8/2010 ELO 185 0.20 37.00 REVIEW ORDER ON PUBLIC HEARINGS; EMAIL NOTICE
EXECUTIVE BOARD
11/18/2010 ELO 185 2.00 370.00 CONTINUED REVIEW OF INTERVENOR DIRECT
TESTIMONY AND RMP REBUTTAL TESTIMONY; SEE THAT
ADDITIONAL DATA REQUESTS ARE SERVED;
CONFERENCE WITH TONY YANKEL REGARDING SAME
11/19/2010 ELO 185 3.20 592.00 PARTICIPATE IN EXECUTIVE BOARD CONFERENCE CALL
REGARDING ISSUES IN RMP RATE CASE; DRAFT MOTION
TO PROVIDE SUR REBUTTAL TESTIMONY OF MARK
MICKELSEN; TELEPHONE CONFERENCE WITH SCOTT
WOODBURY REGARDING SAME; EMAIL EXECUTIVE
COMMITTEE; DRAFT SUR REBUTTAL TESTIMONY OF
MARK MICKELSEN
11/22/2010 ELO 185 1.60 296.00 CONTINUED DRAFTING OF SUR REBUTTAL TESTIMONY
OF MARK MICKELSEN
11/22/2010 ELO 185 3.30 610.50 CONTINUED REVIEW OF RMP REBUTIAL TESTIMONY IN
PREPARATION FOR CROSS EXAMINATION
11/23/2010 ELO 185 3.80 703.00 REVIEW DIRECT TESTIMONY OF GARY GRAYSON;
REVIEW REBUTTAL TESTIMONY OF CAROL HUNTER;
CONTINUED DRAFTING OF TESTIMONY OF MARK
MICKELSEN
11/23/2010 ElO 185 3.60 666.00 CONTINUED REVIEW OF RMP BEBUTTAL TESTIMONY IN
PREPARATION FOR TECHNICAL HEARING
11/24/2010 ElO 185 2.20 407.00 CONTINUED REVIEW OF RMP REBUTTAL TESTIMONY IN
PREPARATION FOR TECHNICAL HEARING
11/26/2010 ELO 185 2.00 370.00 FINALIZE DRAFT OF SUR REBUTTAL TESTIMONY AND
EMAIL FOR REVIEW
11/26/2010 ELO 185 2.00 370.00 PREPARE CROSS EXAMINATION QUESTIONS FOR
COMPANY WITNESSES
11/27/2010 ELO 185 2.50 462.50 TELEPHONE CONFERENCE WITH YANKEL AND
MICKELSEN; REVISE SUR REBUTTAL TESTIMONY;
CONTINUED PREPARATION OF CROSS EXAMINATION
QUESTIONS
11/28/2010 ELO 185 2.40 444.00 CONTINUED PREPARATION OF CROSS EXAMINATION
QUESTIONS FOR COMPANY WITNESSES
11/29/2010 ElO 185 10.70 1,979.50 FINALIZE TESTIMONY OF MARK MICKELSEN; SEE THAT
MOTION AND SUR REBUTAL TESTIMONY ARE FILED AND
SERVED; CONTINUED PREPARATION FOR HEARING AND
CROSS EXAMINATION OF COMPANY WITNESSES
11/29/2010 ELO 185 3.50 647.50 TRAVEL TO BOISE
11/30/2010 ELO 185 9.50 1,757.50 PREPARE CROSS EXAMINATION QUESTIONS; ATTEND
TECHNICAL HEARINGS AND CROSS EXAMINE COMPANY
WITNESSES
11/30/2010 ELO 185 4.00 740.00 PREPARE FOR TECHNICAL HEARINGS AND CROSS
EXAMINATION OF COMPANY WITNESSES
12/1/2010 ELO 185 9.70 1,794.50 PREPARE FOR HEARINGS; PARTICIPATE IN HEARINGS
AND CROSS EXAMINE COMPANY WITNESSES
12/1/2010 ELO 185 3.00 555.00 PREPARE CROSS EXAMINATION FOR COMPANY
WITNESSES
12/2/2010 ELO 185 8.90 1,646.50 PARTICIPATE IN TECHNICAL HEARINGS AND CROSS
EXAMINE COMPANY WITNESSES; PRESENT IIPA CASE
AND WITNESSES
12/16/2010 ELO 185 4.50 832.50 PREPARE APPLICATION FOR INTERVENOR FUNDING
122.40 22,644.00
Trans
Date Atty
7/26/2010 no
8/19/2010 ELO
9/23/2010 no
9/23/2010 no
9/30/2010 ELO
9/30/2010 ELO
10/13/2010 no
11/17/2010 flO
12/3/2010 ELO
12/3/2010 ElO
Detail Canst Transaction File List
RACINE, OLSON, NYE, BUDGE & BAILY CHARTERED
Amount Description
152.52 TELEPHONE CONFERENCE CALL - 6/17
73.96 POSTAGE 8/10 - ANTHONY YANKEL
24.61 POSTAGE 9/14 - ANTHONY YANKEL
23.59 POSTAGE 9/17 - ANTHONY YANKEl
2.68 POSTAGE
14.20 POSTAGE
55.91 UPS POSTAGE ADJUSTMENT FROM 9/8/2010
325.67 ElO CONFERENCE CALL - 10/7/2010
234.00 RT MILEAGE POCATELLO-BOISE -11/29
748.84 lODGING AND MEALS -11/29-12/3
1,655.98
Attachment 2
APPLICATION FOR INTERVENOR FUNING OF IDAHO IRGATION PUMPERS ASSOCIATION, INC. -14
e-o(.i....
Date ~ii
June 10 3
11 6
14 6
Description
Review cost of service study fied in case; review testimony of Company witness
Walje.
Reviewtestimony and exhibits of other company witnesses.
Develop first set of interrogatories for the Company~ discuss with Olsen the
general problems I see with the Company's filing.
15 5 Continue to develop interrogatories by review the Company's filing in this case and
comparng it to some of the changes that have occUlTed since the last case.
16 2 Review filing for details regarding sales and sales adjustments; conversation with
Olsen and others regarding direction of case and issues .reviewed thus far.
18 2 Review initial data responses provide by PacifCorp to Monsanto.
21 2 Furher review initial data responses provide by PacifCorp to Monsanto and the
vaiious attchments.
23 3 Review result of cost of servce study and the variables that are contained in it.
25 4 Review data responses provided to Monsanto.
28 4 Review data responses provided to Monsanto; develop issues with respect to the
relationship between cost of service and bil/sales: review different aspects of the
treatment of the interrptible load on a system basis.
29 5 Review all of the confidential material that was finally provided by the Company.
30 3 Review data responses provided to Monsanto.
July 3 Review data responses to Irrigator's requests; review spreadsheet information
2 4 Review data responses to Irrgator's requests; review spreadsheet information
14 8 Review data responses to lnigator's requests; review spreadsheet information
provided; develop follow-up questions.
15 7 Review data responses to Irrigator's requests; review spreadsheet information
provided; develop follow-up questions.
16 7 Review data responses to Irigator's requests; review spreadsheet infoimation
provided; develop more follow-up questions.
Date
17
Aug. 3
19
2l
23
27
29
30
5
6
9
10
11
~i..~
ii
5
Description
Continue to develop additional data requests that are follow-up to what was
provided; send to Olsen.
4 Continue to review data responses in a manner to coordinate the data in the
responses that should be similar; determine what responses are missing and request
the same.
6 Review the various reports filed by the Company regarding losses by jurisdictions;
review company reports regarding demand side management projects and their
cost/benefit.
4 Review the differences in the data used in the Net Power Cost model with the
historic data regarding system load; review impact, or lack there of associated with
the Irrigation load management program on the costs calculated by the Company.
4 Review the missing data responses that had arrved; develop follow-up questions,
5 Develop follow-up interrogatories regarding the Company's cool keepter program
in Utah and what the numbers mean that were provided in response to IIPA request
12; review the historic sales levels and the projections used in this case.
3 Review development of Irrigation historic biling and compare weather noimalized
and actual.
5 Review data response regarding weather normalization of Irigation load and other
loads; compare historical IiTigation loads with normalized loads.
6 Review weather normalization adjustments of Irrigation customers in the Idaho
Power service are and compare with that proposed by PacifiCorp; develop
6 Review data responses and formulate data from various sources for consistency in
the establishment of the level of hTigation curtailment for the test year; develop
inteiTogatories.
8 Review data responses and review usage and load research data in order to
understand forecasting and weather normalization; develop additional
8 Review data responses and review usage and load research data in order to
understand forecasting and weather normalization; develop additional
2 Review hourly distribution data that was provided and how it varied and how it
was nonnalized for 2010.
Date
l2
Sept 2
13
l6
17
18
19
20
23
24
25
26
31
§ti...
gii
8
Description
Work with data provided by the Company to establish what may be going on with
the manner in which the irrigation load is normalized; investivate the difference
between hourly data between various years.
8 Review data responses to Monsanto and the Commission staff; develop additional
interrogatories.
6 Review hourly border data and compare to load survey data in order to review
losses and discrepancies.
7 Review hourly border data and compare to load survey data in order to review the
differences between the two; attempt to define the reason for the differences in the
two data sets and why the June and August data are so different than the rest ofthe
year.
6 Review material supplied by Olsen; address the direction of the credit paid to
Irrigators and the payment of that credit by the Idaho jurisdiction; conversation
with Irrigators; review discovery responses to see if more interrogatories are
needed.
8 Review the responses to all of the responses to Monsanto data requests sets i -7;
where appropriate, review associated data on CD that was provided,
7 Review hourly border data for 2009 and compare it to load research data; develop
relationships between the percentage difference in the two data sets with respect to
day of the week and time of day
7 Develop additional inten'ogatories and send them to Olsen; review ECAM and past
material to see what needs to be done about a negative LGAG.
8 Review data responses to the Commission Staff; develop and submit addition data
requests.
6 Review weatherization adjustments and load research data; write additional
interrogatories.
7 Work on load research data and border load data to coordinate the two; develop
and submit interrogatories.
5 Review some of the data responses that recently came to the Staf and Monsanto.
3 Prepare for and attend (via phone) a conference with the Irrigators and PacifCorp
regarding the treatment of the interrptibilty program in the present rate case.
Date
3
7
8
9
13
15
16
l7
20
21
22
23
8-o(,t+...
~i:
6
Description
Review alternative ways to address the treatment of the irrgation interruptibilty
that would reflect some sort of jurisdictional allocation and yet satisfy the concerns
raised by the Company that it could not continue the program without collecting all
8 Review recent data responses that came in; work on jurisdictional progras in
order to determine how to get them to work; discuss the same and other topics with
Commission Staff; get the jurisdictional models to work.
7 Continue to work on the sales level forecasts in order to determine how data is put
together and the validity of the data used in the jurisdictional model for Idaho as
well as all of the other jurisdictions such that Idaho's allocation seems to be
increasing or at least quite en-atic; prepare for an4 have conference call with the
Staff regarding the concerns regarding situs tratment that were raised by the
Company.
2 Prepare for and attend telephone conference with PacifiCorp and paries to the case
in order to get a better explanation of how the company forecasts sale and load.
5 Review sales forecast for irrigators and compare forecast to historic normalized
hTigation loads as well as variations between model predictions (based upon actual
weather) and actual usage.
7 Review the calculation of the level of sales associated with Idaho revenues and
those attributed to Idaho via the jurisdictional projection; work to develop the
relationship between border loads and those predicted by load research.
5 Develop the relationship between border loads and those predicted by load research
for 2009.
6 Review load research data for the irrigators in order to piece together how
inigation customers impact the system load for those that are on-peak as well as
those that are not.
7 Develop relationships using responses to Î1Tigation requests 5, 22, and 26 in order
to get a better, long-teim perspective of irrigation sales for use as a forecast
5 Review multiple data responses that were provided by Eric; work with irrgation
load research data to get a better understanding of what the company is refering to
regarding what it calls "free-riders".
6 Work with in-igation load research data to get a better understanding of what the
company is refering to regarding what it calls tlfree-riders".
5 Work with the Company's COS model in order to make it run; converatIons with
Staff regarding same; test the workings of the modeL.
e-o0i....
Date ~Descriptiont:
24 7 Work with JAM and RAM models in order to figure out how they work;
conversations with the Staff and the Company regarding the same; work with
model to develop test data to insure that changes can be made.
27 6 Review additional data responses that have been proviced, with emphasis on
responses to Monsanto set l3; outlne testimony to be written regarding the low
level of irrigation sales; develop possible exhibits.
28 7 Begin to draft testimony regarding the inappropriate level of nornialized sales. for
the in-igators; demonstrate how off the values are using graphs of historic data.
29 7 Develop graphs for testimony; write testimony regarding irrigation sales levels;
review impact of changing sales on irrigation demand levels.
30 7 Develop testimony regarding the problems with the residential usage data and how
it is similar to the nornialization of the iriigation data; prepare for and attend
conference call with the Company regarding the status of the Î1Tigation load
management program.
Oct 1 6 Finalize dr of normalized irrigation sales testimony.
4 9 Develop testimony and data that demonstrates the fact that Idaho is being charged
too much in the way of losses compared to what is appropriate.
5 10 Write testimony regarding the level of extra sales being assigned to Idaho and
coordinate that with the testimony regarding irrgation sales being too low.
6 9 Write testimony regarding the load management program and how it should be
treated in the case; review exhibits and possible data to incorporate.
7 8 Finalize draft of testimony; review of 3-year agreement with PacifiCorp;
discussion with Olsen and then with the Board regarding positions; discussion with
Pacificorp regarding in-igation program; rap-up with board,
11 7 Review testimony as a unit; revise wording to clarify; insure that calculations were
correct.
12 8 Go over numbers and tables; develop tables in a different format so that they go
into the text with more clarity; revise numberns appropriate.
13 7 Develop exhibits as needed; make changes to text to cOITected wording problems
to the draft per conversation with Olsen.
l4 4 Do fina review and make con-ections as needed.
l8 2 Read testimony of the Staf.
e-o0li...
Date ~i:
19 2
20 4
Description
Read testimony of the industrial intervenors.
Read testimony of Reading; converations with Olsen; develop workpapers
requested by the Company.
21 6 Find and/or develop workpapers for submittal to Company; rerun RAM and JAM
in order to give to the Company.
25 5 Read testimony of Monsanto witness Collns as it impacts the Monsanto
interruptions ánd as it impacts the credit to the Irrigators; read testimonies of
Iverson, Peseau, Smith, and Widmer for Monsanto.
27 1 Discussion with Staff regarding testimony fied last week; calculate impact of
changes to page 24 of my testimony.
Nov 3 3 Prepare for meeting regarding my testimony and workpapers in the PacifiCorp case
with the staff; meet with members of the Commission staff to discuss case and the
PacifiCorp load management program.
5 4 Meeting with the Commission staff to discuss meeting that took place with the
Company; phone conference with the Company and the Irrigators regarding the
load management program and situs treatment.
lO 1 Conversation with staff regarding workpapers and calculations as well as meetings
with the company.
18 i Develop additional interrogatories based upon Hunter's rebuttal testimony.
19 5 Develop policy type cross for Walje, develop cross for Tallman regarding used and
useful, develop some cross for Hunter regarding her proposed changes to the load
management program.
22 3 Develop additional cross for Hunter regarding the proposed changes to the load
management prograni.
23 3 Develop additional.cross for Gerrard regarding new transmission plant and for Hui
Shoo
24 7 Develop cross for Eelkema regarding his position regarding sales level for the
irrigators.
26 3 Develop cross for McDougal regarding losses assigned to Idaho.
27 4 Work with Olsen and Mickelsen to develop Mickelsen's testimony.
29 6 Review testimony and prepare for hearing; review all material needed for hearing
regarding my testimony and the crossexamination that we wil do; response to
questions bv Olsen.
e-o0t..-0
Date roi:
30 8
Dec 8
2 6
3 6
Tota 485
Description
Travel to Boise, review testimony, perpare for hearng, attend hearing.
Attend healing and assist Olsen with crossexamination.
Attend hearing and assist Olsen with crossexamInation.
Follow-up review on the hearing; review of intenuptibily credit, travel home.
(q $125 per hour = $60,625
Date
3-Nov
4-Nov
5-Nov
30-Nov
I-Dec
2-Dec
3-Dec
Subtotals
Lodging
$0.00
TRAVEL EXPENSE
Meals
$45.00
$45.00
$45.00
$45.00
$45.00
$45.00
$45.00
$315.00
Total Travel Expense
Transportation
$897.80 Air Line
$99.23 car
$5l1.80 Air Line
$106.5l car
$1~6l5.34
$1,930.34