20100702AVU to Clearwater 1-3.pdf

Avista Corp.
1411 East Mission P.O. Box 3727
Spokane. Washington 99220-0500
Telephone [phone]
Toll Free 800~727~9170 RECÇII\/~D,. '''' -l. _.~ :L...,,,
Jrii'STAe
Corp.
2010JUl-2 AM 10: t 9
July 1,2010
Richardson & O'Lear, PLLC
Mr. Peter Richardson
515 N. 27th Street
Boise, il 83702
Re: Production Request of Clearater Paper Corporation in Case Nos. A VU- E-l 0-01 and
A VU-G-I 0-01
Dear Mr. Richardson,
Enclosed are an original and one copy of Avista's responses to Clearater Paper Corporation's
production requests in the above referenced docket. Included in ths mailing are Avista's
responses to production requests 001, 002 and 003.
If there are any questions regarding the enclosed information, please contact me at (509) 495-
4584 or via e-mail atpaui.kimabll~avistacorp.com
Sincerely,~2/K
Paul Kimball
Regulatory Analyst
Enclosures
CC (Email): all paries electronic
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
06/22/2010
Tara Knox
Tara Knox
State & Federal Regulation
[phone]
IDAHO
A VU-E-I0-0l / A VU-G-1O-01
Clearater Paper
Production Request
Clearater-OO 1
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
REQUEST:
On page 18 of Tara Knox's Direc Tesmony she sttes,
Historically, Avist has included transmission cost in the producton pek credt
classification. It has ben done this way largely becuse it is the accepted proces in
Washington, even though, as the interveners (sic) pointed out, 100% demand is the
more unIVersally accepte clssification of trnsmjsón' eö' in òther stte (induding
the other invesor-owned utilites in Idaho). li. IS.)
(a) Plea provie the names of the utilites, both wiin ldafiò and èlseheFet that
allocte 100% of the cost of transmission to demand as alleged by Ms. Knox in the above-
quoted Direc Testimony.
(bl Plea identify which Uinterveners" (sic) have "pointed out, 100% demand is the
more universlly accepted clasification of trnsmission costs in other stte (including the
other invesor-owned utlities in Idaho)."
RESPONSE:
a) Specifically, in the Idaho jursdiction Idaho Power Company classifies transmission costs
as 100% demand and Rocky Mountain Power classifies transmission costs as 75% demand
and 25% energy. The traditional source for cost of serce methodology for many year
has been the 1973 version of the NARUC Cost Allocation Manual. Regarding
transmission costs, that manual stated;
"In general, all costs associated with the transmission system are considered
as fixed and are classified to the demand component. Transmission lines
are designed to car a specified maximum load, and the costs are therefore
considered to be demand-related."
When the NARUC Cost Allocation Manual was updated in 1992 other approaches to
transmission cost classification were discussed in addition to 100% demand, but the bulk
of the discussion covered different specific demand allocations that could be chosen for the
transmission fuction. Also, the Company's FERC transmission tarffs have traditionally
been determined on a twelve month coincident peak demand basis.
Page 1 of2
b) In Avista's Case No. A VU-E-09-01 Dr. Dens E. Peseau on behalf of Clearater Paper
Corporation provided testimony on the use of 100% demand classification for transmission
costs with references to NERA methodology as well as the Idaho Power and FERC
. practical examples.
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A VISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
06/22/2010
Tara Knox
Tara Knox
State & Federal Regulation
[phone]
IDAHO
AVU-E-1O-01 1 AVU-G-IO~OI
Clearater Paper
Production Request
Clearater-002
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
REQUEST:
The KEMA System Lod Reserch Pròjectatthed to Tara Knox's Direc Tesmony
in Secion 2.4.5, pages 2-70 to 2-73, discsss the load characteristcs of Avist's Exa Large
General Servce - CP customer class. Pleae provide all workpapers,.data, and models,
elecronic format where possible, that were used in developing the analysis and conclusions
of this secon of the stdy.
RESPONSE:
The workpapers associated with the load study were included with the initial filing, however,
attached for your convenience are the fies specific to Schedule 25P and a verical format of the
reconciled hourly loads with the Schedule 25P data highighted. These files are included in the zip
fie titled "Clearater_PR_002-Attchment A.zip". These fies are being provided in electronic
format only as requested.
Ths individual customer is divided into two domai (as KEMA, the consultant who prepared the
load study, refers to them) consisting of the generation the Company purchases from the customer
(identified as PFIG in the workpapers) and the net load supplied by the Company (identified as
PFIL in the workpapers). As agreed to in the purchase and sales agreement, the customer is biled
for their gross load (which is the total of their generation and net load). The priar voltage loss
factor, however, is applied only to their net load.
In Attachment A, note that the file "M9 _Statistics _ Ali_ XGS025P _PFIL _ REC.xLS" contains the
data related to the net load, and the file "M9 _Statistics_AlI_XGS025P _PFIG_REC.XLS" contains
the data related to the generation. These two data sets are combined in the file
"M9 Statistics All XGS025P All REC.XLS".- - - --
The discussion in section 2.4.6 of the load study report prepared by KEMA is at the total customer
level using the statistics from "M9 _Statistics_All_XGS025P _AlI_REC.XLS". To avoid
confusion, by Company request, the consultant's wrte-up refered to it as one customer even
though the M9 Statistics report counts the generation and load as a population of two.
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AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMTION
JUSDICTION:
CASE NO:
REQUESTER:
TYE:
REQUEST NO.:
06/22/2010
Patrck Ehrbar
Patrck Ehrbar
State & Federal Regulation
[phone]
IDAHO
AVU-E-I0-01 1 AVU-G-IO-01
Clearater Paper
Production Request
Clearater-003
DATE PREPARD:
WITSS:
RESPONDER:
DEPARTMNT:
TELEPHONE:
REQUEST:
For the purpse aF the following reques, please refer to Exibit 14, Schedule 3, p. 3
of 3 (P. Ehrbar1, for Schedul ~P. Please explain, in detil, the ratnaeror the føwing:
a) The 2Qk increae in the demand change for 3,0 kva or les (from $10,0 to
$12 mothly);
b) The incr.se'of21OS in the demand chae over ~'m'(frcQm SJ.2/kva to
$'.00 J kvali
e) The increase In the Annual Minimum from $555,6 to $6'1,99;
d) The propsed de charge increase of 20% and greater, While the en,ergy
charge increase is les than 9Ok.
Pleap'f'G¥ide ai-~ ~, and mos, eleconic forma whéle paSible, tht were
us in developfn!thepr~ rate incréase for this Schedule.
RESPONSE:
a. As discussed in Mr. Ehrbar's testimony on Pages 18-19, the Company believes that it is
important to increase the demand charges by a percentage greater than the percentage
increase to the volumetrc rate. If demand charges are not increased at least
proportionately with energy charges, customers who have a poor load factor would see a
lower percentage increase in their bil than a comparable customer with a good load factor.
The increase of the monthy mimum demand charge followed ths theory, with rounding
to the nearest thousand.
b. The increase of$0.75 per kW followed the same theory outlined in the response to a.
above, with rounding to the nearest dollar.
c. The anual minimum is calculated by multiplying the base rate times 11,000,000 kWhs
($0.04309*11,000,000 = $473,990), plus twelve months times the monthly minimum
demand charge (12 * $12,000 = $144,000) for a total of$617,990. The increase to
.$617,990 from $555,600 was simply a fuction of updating the volumetrc rate and the
monthy minimum demand charge.
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Page 2
d. See the response to a. above.
All of the workpapers, data, and models were provided in Mr. Ehrbar's workpapers, in electonic
format.