20020301Production Requests.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA UTAH POWER & LIGHT
COMPANY FOR APPROVAL OF CHANGES
TO ITS ELECTRIC SERVICE SCHEDULES. )
CASE NO. PAC-02-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO PACIFICORP
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that PacifiCorp provide the following
documents and information, pursuant to Rule 225 of the Idaho Public Utilities Commission
Rules of Procedure, IDAPA 31.01.01 , on or before FRIDAY, MARCH 15, 2002.
This Production Request is to be considered as continuing, and PacifiCorp is requested to
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing. For
all responses to the following requests, please provide all workpapers, diskettes (3.5 in.) and all
underlying formulas in Excel (2000 version) language.
SECOND PRODUCTION REQUEST
TO P ACIFICORP
March 1 2002
Request No.8: Please provide the
amount ofinigation Schedule
No. 10 B & C load that
Was inteITUpted in each
month between April I
2000 and December
, 200 I, Also include any
other interruption that was due to the irrigation buy-
back program as a separate item from thetariff allowed intemption, Include
both demand (k W) and energy (k Wh) figures in each monthfor each program.
Request No.9: What is the total connected load by month of irrigation Schedule JOe for
the 12 months ending October 31
, 2001?
Request No. 10: What is
the total connected load by month of inigatian Schedule lOBfor the 12 months ending October 31
2001?
Request No. 11; What is
the maximum demand and total euergy (kWh)
iutelTUpted
system wide through buy.
back programs or other special
Coutracts duriug test years eudiugOctober 31 , 200 I? Please separate your response by pro gram and jnrisdiction,
Request No. 12: What amounts of
intelTUptability are included in each
class for the cost
of service study?
Request No. 13: What is the
projected construction and start-up schedule for the Gadsbyproject?
Request No. 14: Please
provide the annual production records for the Hunter I plant forthe two years prior to its failure and aU Production records siuce its restart
Request No. 15:
Please provide the forward market curve for the week the Hunter IPlant failed (week of November 24
2001), Include prices for a 24-hour product on the real timeand day ahead market Provide the purchases the Company made at that time to cover the
Hunter outage.
SECOND PRODUCTION REQUEST
TO P ACIFICORP
March 1 , 2002
Request No. 16;
Please
Provide the repair
schedule developed
for the Hunter rebuild
once the
Problem Was diagnosed.
Request No. 17:
Please provide the forward
market curve on the date
the repair schedule
Was submitted. include
prices for a 24-
hour Product on the
day ahead and tem markets for the
period Hunter Was scheduled to be down and the purchases the Company made at that time tocover the Hunter outage.
Requ est No. 18: Please
provide the detailed j ustiflealion forthe
defelTed costs labeled
DSM (Load Curtailment) and
20/20
Customer Challenge on Exhibit No,S and No.6 of Mark T.
Widmer s testimony, Include
the energy reduction and the
COst associated with each progran,.
Request No. 19:
Please explain any difference
that may exist between the deferred costs
in Request No. 18 and the
SUmmary
Reports filed with the
Idaho Commission which include the
following data:
CUstomer Ener
Table 1 Line 1
Total Administrative
Costs = $348 534Total Credits Paid
$10 085 436
Total 20/20
!I'Vc Staff COI11Dilation of
DSM Pro~ra,!!!Total Irrigation PaYments ~ $22
170 020T otal Demand
Exchange PaYments ~ Total DSM $43
263 804
Request No. 20:
Please
Provide the Weather nol1nalized test year ending in March 2001
and the detail of
the Weather adjustments.
SECOND PRODUCTION
REQUEsTTO P ACIFICORP
March 1 2002
Request No. 30: Please provide an analysis by month and unit for the thermal fuel burn
expenses for the Hunter units for 2000 and 2001.
Request No. 31: Please explain why the thermal fuel burn expenses allocated to Hunter
for March 2001 ($12 676 237) are almost two to four times higher than in other months of the
deferral period.
Request No. 32: What portion ofthe thermal fuel burn expenses for the months ofthe
deferral are attributable to Hunter 1 coming back on line in May 2001. Please provide an
analysis of this information on a monthly basis.
Request No. 33: The Net Power Cost Energy Analysis for 2001 states that the
generation for the Hunter plants in the month of April 2001 was 154
794 kwh. This was
significantly lower than the generation from the Hunter plants during the other months of the
deferral period. Please explain why the generation from the Hunter plants was lower for the
month of April 2001 than it was during the other months of the deferral.
Request No. 34: Wheeling charges in 1998 were $74 244 410 and wheeling charges for
the 12-month deferral period are $113 426 351 , please provide a written explanation of the
increase in wheeling.
Request No. 35: Please provide an analysis for the deferral period wheeling charges
showing the charges associated with the wheeling of power for the long-
term contracts and the
wheeling of power for the short-term purchases.
Request No. 36: Please provide a copy of all the wheeling contracts and wheeling tariffs
during the deferral period.
Request No. 37: Please provide an analysis of all revenues received during the deferral
period from wheeling including the account numbers where they were booked.
SECOND PRODUCTION REQUEST
TO P ACIFICORP March 1 , 2002
CERTIFICA TE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 ST DAY OF MARCH 2002SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THECOMMISSION STAFF TO PACIFICORP, IN CASE NO. PAC-02-, BY MAILING
A COpy THEREOF, POSTAGE PREPAID , TO THE FOLLOWING:
DOUG LARSON
VICE PRESIDENT REGULATION
ACIFICORP
201 S MAIN, SUITE 2300
SALT LAKE CITY UT 84140
RANDALL C BUDGE
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
TIMOTHY SHURTZ
FIRTH CITY COUNCILMAN
411 SOUTH MAIN
FIRTH ID 83236
JOHN ERIKSSON
STOEL RNES LLP
201 S MAIN ST STE 1100
SALT LAKE CITY UT 84111
JAMES R SMITH
MONSANTO COMPANY
PO BOX 816
SODA SPRINGS ID 83276
ANTHONY J Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
CITY OF FIRTH
PO BOX 46
FIRTH ID 83236
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CERTIFICATE OF SERVICE
F?ECEIVED
FILED
L1/ tI Jt SCOTT WOODBURy
DEPUTY
ATTORNEy GENERALIDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720BOISEIDAHO 83720-0074(208) 334-0320
IDAHO BAR
NO. 1895
off:
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Street Address for Express Mail:
472 W WASHINGTONBOISEIDAHO 83702-5983
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PUeLIC
UTILITiES COi"'H~JlSS10N
Attorney
for the Commission Staff
IN TIlE MATTER OF
THE APPLICATION OF PACIFICORP DBA VTA.II
POWER & LICHTCOJlip ANY FOR
APPROVAL OF CHANGES TO)ITS ELECTRIC SERVICE
SCHEDULES.
BEFORE
TIlE IDAlIO
PUBLIC UTILITIES
COl\1M:ISSION
CASE NO. P AC-E-
O2-1
FIRST PRODUCTION
REQUEST OF THECOMMISSION STAFF
TO ACIFICORP
This Production Reqnest is to be considered as
Continuing, and PacifiCorp is requested
provide, by Way of
supplementary responses
, additional documents that it or any
person acting
on its behalf !Day later obtam that
will augment
the doCUlDents Produced,
The Staff of the Idaho Public Utilities Commissiou, by and throUgh its attorney of record,
Scott WOodbury, Deputy Attorney General
, requests that Pa,;ifiCorp Provide
the following
documents and infonnation
, PDrsuant to Rule 225 of
the Idaho Public Utilities CommissionRules of Procedure, lDAP A 3 L 0
L 0 on Or before WEDNESDAY
, F'EBRV AR Y 27 2002.
For each item
please indicate the name of the person(s) preparing the answers
, along
wi th the job
title of such
person( s) and
the witness who can sponsor
the answer at hearing, For
all responses to the following requests
, please provide
all workpapers
diskettes (3.5 in.and al1
underlying formulas in Excel (2000 version) language.
FIRST PRODUCTION REQUESTTO P ACIFICORP
JANuARY 30 2002
Special Contracts (Monsanto and Nu-West): Situs customers and an integral part of the
model.
Irrigation: Include interruptibility credit as determined in Case No. UPL-90-, Order
No. 23508.
Run 5
Test Year: 12 Months ending December 31 1999
Jurisdictional Allocation: Fully Rolled-
Special Contracts (Monsanto and Nu-West): Input results from Case Nos. PAC-01-
(Monsanto) and PAC-01-17 (Nu-West).
Irrigation: Include interruptibility credit as determined in Case No. UPL-90-, Order
No. 23508.
Run 6
Test Year: 12 Months ending December 31 1999
Jurisdictional Allocation: Fully Rolled-
Special Contracts (Monsanto and Nu-West): Situs customers and an integral part ofthe
model.
Irrigation: Do not include interruptibility credit as determined in Case No. UPL-90-
Order No. 23508.
Request No.2: Are all allocators used in the Cost of Service Study in Case No.
PAC-02-1 the same as the allocators used in the Cost of Service Study in Case No.
PAC-01-16 (Monsanto), and PAC-01-17 (Nu-West).
Request No.3: If the answer to Request No.2 is no, then please provide a complete
description of the differences.
Request No.4: Please provide (paper and electronic) all load data for the test year
ending December 1999.
FIRST PRODUCTION REQUEST
TO P ACIFICORP JANUARY 30 2002
Request No.5: Please explain why the Company has chosen to use an unaudited test
year for its filing in Case No. P AC-02-01.
Request No.6: Please explain any and all adjustments the Company has performed to
normalize the test year ending March 31 , 2001 and to remove all effects of the extreme market
events that would have occurred during that period.
Request No.7: Please describe and provide justification for the revenue allocation
method for the two non-tariff customers mentioned on page 7 & 8 of direct testimony of David
L. Taylor.
Dated at Boise, Idaho , this
30
day of January 2002.
Scott Woodbury
Deputy Attorney General
Technical Staff: Michael Fuss
SW:MF:jo/umisc/prdregipaceO2.1 swmfuss
FIRST PRODUCTION REQUEST
TO P ACIFICORP JANUARY 30, 2002
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 30TH DAY OF JANUARY 2002
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THECOMMISSION STAFF TO PACIFICORP IN CASE NO. PAC-02-, BY MAILINGA COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DOUG LARSON
VICE PRESIDENT REGULATION
ACIFICORP
201 S MAIN, SUITE 2300
SALT LAKE CITY UT 84140
RANDALL C BUDGE
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
JOHN ERIKSSON
STOEL RIVES LLP
201 S MAIN ST STE 1100
SALT LAKE CITY UT 84111
JAMES R SMITH
MONSANTO COMPANY
PO BOX 816
SODA SPRINGS ID 83276
ANTHONY J Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
SECRE 1\R
CERTIFICATE OF SERVICE
Eric L. Olsen
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.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP, DBA UTAH POWER &
LIGHT COl\.1P ANY FOR APPROVAL OF ITS
PROPOSED ELECTRIC SERVICE SCHEDULES)
Case No. PAC-02-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
THIRD DATA REQUEST TO PACIFICORP
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys
hereby submit this Third Data Requests to PACIFICORP, DBA UTAH POWER & LIGHT
COl\.1PANY pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure
IDAPA 31.01.01 , as follows:1. In the Company s last rate case in Utah (Case No. 01-035-01) there was filed a cost
of service study labeled as Exhibit DL T -3. On Tab 5, Page 6 of that cost of service study in the Utah
case there are listed the days and times ofthe coincident peaks. Six of the months in that study are
also included in the cost of service study in this case. The dates of the coincident peaks are the same
for these six months in both studies, but not all of the times are the same. Please provide an
explanation regarding why the times ofthe coincident peaks are different in this case than in the Utah
case. Also, please provide the coincident peak values at input for page 186 of Exhibit 16 in this case
ifthe peak hours were changed to reflect the times used in the Utah study.2. On page 191 of Exhibit 16 are listed the Distribution Non-coincident peaks.
(a) With respect to the lighting schedules on lines 4, 10, 34, 35 , and 36 (assuming
that all lights under these schedules are generally "" after dark), why is there a
THIRD DATA REQUESTS - 1
variation of as much as a factor of "2" in the values listed on these lines? In
addition to an explanation of how this comes about, please provide a numerical
(b)
example.
The November and December coincident peaks listed on page 186 of Exhibit 16
are listed as occurring at 19:00 which should be after dark. Although "lighting
values are listed on lines 4, 10, 35, and 36, they are not the same as the
comparable NCP values on page 191. Please explain why there are these
(c)
differences for coincident and non-coincident demands for "lighting" schedules.
The November non-coincident peak for Sch. 104 on page 191 of Exhibit 16 line
35 is listed as 39 kW while the comparable distribution peak value on page 190
of Exhibit 16 is listed as 31 kW. Please explain why there is such a difference in
the two figures for a lighting rate schedule.3. The cost of service study at page 186 of Exhibit 16 lists the sum of the 12 coincident
peaks for Idaho as 3 005 071 kW. Tab "Factors" of the JAM model for Idaho that allocates total
Company costs to Idaho, lists the sum of the 12 CP's for Idaho at 5 124 800 kW. Of this amount
there is listed 1 701 500 kW as belonging to Special Contracts. The difference between the two
figures is 3 423 300 kW. Please provide an explanation (and reconciliation for each month) between
this figure of3 423 300 kW in the JAM model and the 3 005 071 kW figure in Exhibit 16.
Please provide a similar explanation as "3" above, regarding the total Idaho allocated
energy of3 443 672 MWh (less 1 285 529 MWh) in the JAM model with the Idaho energy value of
834 864 MWh found on page 192 of Exhibit 16.
With respect to Exhibit 16 page 188 lines 21 and 23 for the factors regarding line-
transformers, what was the source of the data (Idaho, UP&L, or system) and when was it gathered?6. With respect to Exhibit 16 page 195, what was the source of the weighting data (Idaho
UP&L, or system) and when was it gathered?7. Please provide a detailed explanation regarding why the Acct. 902 weighting factors for
Schedule 9, Monsanto, and Nu West, are so much lower than what was calculated for Schedule 8
customers?
THIRD DATA REQUESTS - 2
it i'
Please provide a detailed explanation regarding why the Ace!. 902 weighting factor for
Schedule 19, is so much less than for residential customers?9. With respect to Exhibit 16
, page 198 for the weightings regarding average Meter costswhat Was the source oflhe data (Idaho, uP&L, or system) and when was it gathered?In the most recent PacifiCorp rate case in Utah
, the average meters costs were differentthan listed page 198 of Exhibit 16 (1. e., the residential cost of meters is $82.73 on page 198
, but
$115. 14 in Utah, What is the basis for this dilference in average costs?11. Please reconcile the difference between the Total Metering Costs on line 22 of page
of Exhibit 16 of $7 243, 128 with the jurisdictional total cost
of $11 , 150 846 on line 832 of page 85of Exhibit
12. With respect to Exhibit 16 page 198 for the weighting, regarding average Services costs
what Was the source oftbe data (Idaho UP&L, or system) and
when Was it gathered?In the most recent PacifiCorp rate case in Utah, the average Services costs Were different
than listed page I 98 of Exhibit 16 (i. e.
, the residential COst of Services is $277. 66 on page 198
, but
$326 25 in Utah. What is tbe basis fur this difference in average costs?
Please reconcile the difference between the Total Services Cost on line 22 of page
198
of Exhibit 16 of $15 555 986 with the jurisdictional total cost of $ 12
457 393 on line 828 of page 85of Exhibit 16.
With fespectto lines 7, 10, and 11 00 page 198 ofExhibit 16
, please explain why the totalmetering cost in column "E" does not eqnal the prodnct of column "
c" (Average Customers) andcolumn "D" (Average Metering Cost)?
16. With respect to line 16 of page 198 of Exhibit 16
, why is the average cost of an liTigationmeter listed as $499
58 in this case while it was
listed as $91.00 in the most recent Utah rate case?Please contrast the type of meters
, age of meters, or other distinctions that bring about this difference.With respect to line 19 of page
198 of Exhibit 16
, it is suggested that area lightingschedule 7 has no metering Costs which suggests that these lights
are simply "
" during the dark
hours of the day. Please Contrast
this to the demand fuctor vaInes listed on pages 186
, 189, and 190
that suggests that the usage uuder this schedule varies trom hour to hour
THIRD DATA REQUESTS
- 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this ~6"';'b.day of February, 2002, I served a true, correct and
complete copy of the foregoing document, bye-mail and first class mail, postage prepaid, to each
of the following:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
E-mail: jjewell(0puc. state.id. us
John M. Eriksson
Stoel Rives, LLP
201 South Main Street, Suite 1100
Salt Lake City, UT 84111-4904
E-mail: mjeriksson(0stoe1.com
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, UT 84140-0023
E-mail: doug.larson(0pacificorp.
THIRD DATA REQUESTS - 5
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 Idaho Irrigation Pumpers Association, Inc.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER OF THE APPLICATION
OF PACIFICORP, DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF ITS
PROPOSED ELECTRIC SERVICE SCHEDULES)
Case No. PAC-O2-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
_____~ -- ---------
SECONDDATA-REQUEST-TO PACIFICORP
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC., by and through their attorneys,
----
hereby-submit this Second Data..Requests_to..EACIEICORP, DBA_ill AH EnWER LIGHT -
- -
COMPANY, pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure, -
IDAPA 31.01.01 , as follows:1. Please provide a copy of the Company s FERC Form 1 for 2000 and a copy of the
2001 Fonn 1 when it is available.
Please provide copies of the Idaho Jurisdictional Fonn 1 that the Company files with
the Idaho PUC for the years 1997 through 2000 plus 2001 when available.3. On David L. Taylor Exhibit 16, pages 12-49, the first column entitled 'IDAHO-UPL
Normalized", please answer the following:
What are the "actual" as opposed to "nonnalized" values for this column?
Please provide the detail and workpapers that support the development of
these nonnalized values.4. On David L. Taylor Exhibit 16, page 75 , line 126, there are two figures that reflect
approximately $42 000,000 in revenue from the Residential customers. Please answer the following:
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO PACIFICORP-
.--___m_-
customers after the BP A Exchange Credit?
What was the Exchange Credit during the test year, in 2000, and 2001 for the
Idaho Residential customers and where can it be found in the corresponding
FERC Form I?
How does the BP A Exchange Credit impact/relate to the residential revenue
in the Form 1 generally?
For each of the last 10 calendar years, what was the actual revenue for each
Residential rate schedules (1 and 36)?
- ~-~ - - -~ - - ~-- -,--
- on
_--,-
For each of the last 10 calendar years, on a monthly basis, what was MWH at
sales level for each Residential rate schedules (1 and 36)?
- -----~-
5. -On-David LTaylorExhibit-16, page'7-line-118,there-is arevenuevaluefol"-~----
Irrigation of $32 326,584. Please answer the following:
- -. --
What was the "actual" test year revenue and MWH for each Residential rate
schedule?
Please provide the detail and work papers that support the development of the
nonnalized values for each Residential rate schedule.
Is the "actual" and "nonnalized" amounts what is paid by residential
What was the "actual" test year revenue and MWH for the Irrigators?
Please provide the detail and work papers that support the development of the
nonnalized values for the Irrigation class.
Is this "actual" and "nonnalized" amount what is paid after the BP
Exchange Credit?
What was the Exchange Credit that year for the test year, in 2000, and in
2001 for the Irrigators and where can it be found in the Fonn 1?
How does the BP A Exchange Credit impact/relate to the revenue in the Fonn
For each of the last 10 calendar years, what was the actual revenue for the
Irrigation class?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
SECOND DATA REQUEST TO PACIFICORP - 2
For each of the last 10 calendar years, by month, what was the MWH at sales
level for the Irrigator class?
For each of the last 10 calendar years, by month, what was the billing demand
for the Irrigator class?
In the 1998 FERC Fonn 1 on page 304., line 31, is reported the Idaho Irrigation
Schedule 10 usage and revenue. Please answer the following:a. Is this all of the Irrigation usage in Idaho in 1998? If not, where else in the
Fonn 1 is the rest of the Irrigation usage recorded?
-------- __un
The revenue listed is $17,829 097. Is this amount what is paid after the BPA
Exchange Credit? What was the Exchange Credit that year for the Irrigators
and where can it be found in the Fonn I? How does the BP A Exchange
Credit impact/relate to the revenue of $17,829 ,097?
In the 1999 FERC Form 1 on page 304., line 36, is reported the Idaho Irrigation
-- - ,
__n
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Schedule 10 usage and revenue. Please answer the following:a. Is this all of the Irrigation usage in Idaho in 1999? If not, where else in the
-----
FonnLis therestof-theJrrigation usage recorded?-
----~~-
b. The revenue listed is $18,936,397. Is this amount what is paid before or after -
the BP A Exchange Credit? What was the Exchange Credit that year for the
Irrigators and where can it be found in the Form1? How does the BPA
Exchange Credit impact/relate to the revenue of$18,936 397?
In the 1998 FERC Fonn 1 on page 304, lines 29 and 31 is reported the Idaho
---"
~-_n
Residential Schedules 1 and 36 usage and revenue respectively. Please answer the following:a. Is this all of the Residential class usage in Idaho in 1998? Ifnot, where else
in the Fonn 1 is the rest of the Residential usage recorded?
The revenue listed is $19 593,190 for Schedule 1 and $17 542,873 for
Schedule 36. Are these the amounts paid before or after the BP A Exchange
Credit is applied? What was the Exchange Credit that year for the Residential
customers and where can it be found in the Fonn
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
SECOND DATA REQUEST TO PACIFICORP-
9. In the 1999 FERC Fonn 1 on page 304, lines 29 and 31 is reported the Idaho
Residential Schedules 1 and 36 usage and revenue respectively. Please answer the following:a. Is this all of the Residential class usage in Idaho in 1998? Ifnot, where else
in the Fonn 1 is the rest of the Residential usage recorded?
The revenue listed is $20 498,792 for Schedule 1 and $18,127 898 for
Schedule 36. Are these amounts paid before or after the BP A Exchange
Credit is applied? What was the Exchange Credit that year for the Residential
customers and where can it be found in the Fonn
10. Widmer Exhibit 4 lists Net Power Costs for the year ending 1998 with Type 3
adjustments for Idaho. Page 5.1 of the Company s Results of Operation (December 1998) for Idaho
list summary results for Net Power Costs under Type 3 adjustments. There are some slight variations
in-the values between these two sets of numbers as listed below:
Exhibit 4 in this Case 1998 Results of Qperation
- Sales for Resale - u
--------
$99I~50g,02Tn_$99r 96r,556-
~----
Purchase Power $868 181 092 $868 195,097Wheeling $ 75 937 216 $ 75 937,216
Fuel Cost $500.961.035 $501.005.855
-- - -- --- '
Net Power Cost----------$45 571 321 -$4)3-:-27Delta $294 679
Please explain the basis for each difference between these two sets of numbers.
11. It is stated on page 2, lines 11-14 of Mr. Widmer s testimony that the last audited net
power cost study was for the 12 months ended December 31, 1998. What portions of the remainder
of the Company s Results of Operation December 1998 for the Idaho jurisdiction were audited?
12. If corrections or changes have been made to the Company s Results of Operation-
December 1998 for the Idaho jurisdiction, please provide copies of those corrections or changes.
13. Please provide a hard copy as well as an electronic copy of any class cost of service
studies that may have been run for the Idaho jurisdiction associated with the Company s Results of
Operation-December 1998
, -
December 1999, -December 2000, and-December2001 when available.
14. Please provide a hard copy of the Idaho Jurisdictional Results of Operation-December
1999
, -
December 2000, and -December 2001 when available.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO P AClFlCORP - 4
15. Please provide an electronic copy of the Idaho Jurisdictional Results of Operation-
December 1998, -December 1999
, -
December 2000, and -December 2001 when available.
16. With respect to the Company s Load Research Program in Idaho for the period
January 1, 1998 through October 2001 for the residential and irrigation classes:a. Please provide a description of the usage range of the various stratum.b. Please provide the weighting factors given to each stratum.c. For each year, please indicate the percentage of customers in each class that
fell within the usage range of each stratum.
Please provide in electronic format the actual hourly load data for each Idaho
residential and irrigation customer (broken down by strata) that was included
in the sample.
Please provide a detailed explanation and an example (using the peak hour of
January 17, 2001 at 19:00) of how the sample data from the residential load
- -- ---------,----~,----
research program is used to develop the "actual" hourly weighted load for the
class.
-- ---
- f.
- - -- --
Please- provide-adetailedexplanation.andan.example (using. thepeakhouroL_
June 28, 2000 at 17:00) of how the sample data from the irrigation load -
research program is used to develop the "actual" hourly weighted load for the
class.
- '
With respect to "" and "f' above, what was the specific value of the
multiplier used to take the load research sample results up to the population
estimate for each month from January 1998 through October 2001?
Please provide in electronic format the "actual" hourly load data (weighted)
for residential and irrigation classes from January 1998 through October 200
Please provide in electronic format the "calibrated" hourly load data
(weighted) for residential and irrigation classes from January 1998 through
October 2001.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
SECOND DATA REQUEST TO PACIFICORP - 5
,---.-----
Please provide in electronic fonnat the "percentage calibration" ofhourly load
data (weighted) for residential and irrigation classes from January 1998
through October 2001
With respect to the "calibrated" hourly load data for the residential and
irrigation classes contained in "i" above, if these values are different than the
peak hourly data listed on David L. Taylor Exhibit 16, page 187, please
17.
provide an explanation as well as a reconciliation of any differences.
Please provide a working electronic copy of the cost-of-service study contained in
David L. Taylor Exhibit 16.
DATED this 'i'4~y of February, 2002.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
--__' - ----
un -
---,--- ---,-
- n ---___n_-
----~
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
SECOND DATA REQUEST TO PACIFICORP - 6
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this fitlA day of February, 2002, I served a true, correct and
complete copy of the foregoing document, to each of the following:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
John M. Eriksson
Stoel Rives, LLP
201 South Main Street, Suite 1100
Salt Lake City, UT 84111-4904
Doug Larson
PacifiCorp
201 South Main, Suite 2300
- -- ____
Salt Lakeeity~UT-84140..0023-
- --,------- -~--- -
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
SECOND DATA REQUEST TO PAClFlCORP - 7
_.-
Eric L. Olsen
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.
U/ P" /.c
l~ECE!VED
'::-:LEO
'1(1'1 cn -r.... 1',,9: LOJ~ Ll v
/-' j
" u Fu
unlit IES COi'If'1ISSION
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-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP
Please provide a listing of all Firm sales-for-resale contracts with duration of one
month or more that were either initiated or revised after December 31 , 1997. For each such contract
or contract revision, please provide:
A copy of the contract (in case of new) and! or the original contract as well as
contract revision (in the case of a revision);
A copy of the previous contract that may have been in place (even if it was
not the same type of contract or contract revision);
A listing of the normalized MWH, MW, and dollars for each month from
January 1999 through December 2001;
A listing of the actual MWH, MW, and dollars for each month from January
1999 through December 2001.
Please provide a listing of all Firm purchase power contracts with duration of one
month or more that were either initiated or revised after December 31 , 1997. For each such contract
or contract revision, please provide:
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 1
A copy of the contract (in case of new) and! or the original contract as well as
contract revision (in the case of a revision);
A copy of the previous contract that may have been in place (even if it was
not the same type of contract or contract revision);
A listing of the normalized MWH, MW, and dollars for each month from
January 1999 through December 2001;
A listing of the actual MWH, MW, and dollars for each month from January
1999 through December 2001.
On page 4 lines 1-3 of Mr. Watters' testimony there is a reference to a short-term
purchase price in rates of$21.50 per MWH and $139 per MWH of actual cost. Please answer the
following:
Please provide a listing of all firm MWH, MW, dollars and $/MWH for each
month that went into the development of the $21.50 per MWH figure;
Please provide a listing of all non-fIrm MWH, MW, dollars, and $/MWH for
each month that went into the development of the $21.50 per MWH figure;
Were the figures listed in "" and "b" above normalized?
If the figures in "" and "b" above were normalized, please supply a listing
of the actual firm and non-firm MWH, MW, dollars and $/MWH for each
month.
For each of the months ofthe deferral period, please provide the MWH, MW
dollars and $/MWH for any additional categories (stated separately) that went
into the development ofthe $139 per MWH figure.
On page 4 lines 4-9 ofMr. Watters' testimony there is reference to the "Company
strategy of relying on the market to fill in during the 'peaks' of a generally balanced load and
resource situation..." Please answer the following:
When was this policy of "relying on the market to fill in during the peaks
first introduced?
Please provide a copy of any internal or external statements that reference
such a policy of "relying on the market to fill in during the peaks
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP - 2
For each month from January 1998 through the most recent month available
what was the MWH and dollar amount of super-peak, on-peak, shoulder-
peak, and off-peak purchases (broken down between short-term-firm
intermediate-teIm-firm, long,;term-firm, and non-firm).
For each month from January 1998 through the most recent month available
what was the MWH and dollar amount of super-peak, on-peak, shoulder-
peak, and off-peak sales for resale (broken down between short-term-firm
intermediate-term-firm, long-term-firm, and non-firm).
Please define the times of super-peak, on-peak, shoulder-peak, and off-peak
used by the Company in its response to "" and "d" above.
With respect to the "generally balanced load and resource situation , for each
month from January 1998 through the most recent month available, please
list the energy and monthly peak demand levels associated with the loads in
the following groupings:
11.
111.
IV.
VI.
V11.
Firm retail load
Non-firm retail load
Long-term-firm wholesale load
Intermediate-term-firm Wholesale load
Short-term-firm Wholesale load
Non-firm Wholesale load
Other
With respect to the "generally balanced load and resource situation , for each
month from January 1998 through the most recent month available, please
list the energy and monthly peak demand levels associated with the resources
in the following groupings:
11.
Company-owned generation
Long-term-firm purchases
Intermediate-term- firm purchases
Short-term-firm purchases
Non-firm purchases
Other
111.
IV.
VI.
Please supply the information requested in "" through "" above in both
hard copy as well as in an electronic version.
On page 4 lines 12-16 of Mr. Watters' testimony there is a discussion of two options
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO PACIFICORP - 3
that the Company had for meeting near term resource requirements; buy forward to cover the bulk
of the requirements or rely upon the day-ahead and real time markets. Please answer the following:
Please provide a copy of any memo, analysis, or communications that address
the Company s review of these two options.
What is the timeframe over which these options were reviewed and when
were the decisions made as to what course of action(s) to take?
Please define what is meant by the statement "the Company could buy
forward to cover the bulk of resource requirements." How (and to whatmagnitude) is this different or the same as the practices of the Company
during the timeframe leading up to this period?
Please define what is meant by the statement "or leave most ofthe balancing
to the extremely volatile day-ahead and real-time markets." How (and towhat magnitude) is this different or the same as the practices of the Company
during the timeframe leading up to this period?
F or each month considered, what was the anticipated cost, MWH, and timingof any forward purchases that were reviewed?
F or each month considered, what was the anticipated cost, MWH, and timingof any day-ahead or real time purchases that were reviewed?
F or each month from January 1998 through the most recent month available
what was the MWH, dollars, and $/MWH associated with all "forwardpurchasesSufficient detail is requested so that the impact of theCompanys decision to use "forward purchases" can be quantified. A format
similar to Mr. Watters' Exhibit 2 is requested.
For each month from January 1998 through the most recent month available
what was the MWH, dollars, and $/MWH associated with Heavy Load Hours
and Light Load Hours for all "day-ahead purchases Please provide
sufficient detail so that the impact of the Company s decision to use "forwardpurchases" can be quantified.
For each month from January 1998 through the most-recent month available
what was the MWH, dollars, and $/MWH associated with Heavy Load Hours
and Light Load Hours for all "real-time purchases Please provide
sufficient detail so that the impact of the Company s decision to use "forwardpurchases" can be quantified.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO P ACIFICORP - 4
On pages 6 and 8 of Mr. Watters' testimony there is a listing of "non-traditional
transactions" that the Company undertook. If the cost of those transactions is directly or indirectly
included in the Company s $38 million excess power cost recovery request, then please answer the
following:
For each month that these non-traditional transactions were in place, please
list the MWH and dollars associated with each transaction.
If the dollars listed in "" above were not the full dollars of the transaction
please list the full dollars and the reason for any offset or reduction.
With respect to page 9 lines 11-17 of Mr. Watters' testimony, please answer the
following:
When was the sale of Centralia finalized?
What was the monthly amount of energy eliminated because of the sale in
2000 and 2001 ?
What has been the monthly peak load and energy requirement for each month from
January 1991 through the most recent month available for each of the following (please supply
electronically and hard copy):
The firm retail system load.
The total retail system load.
The total system load.
The Idaho special contract load.
The total Idaho retail load.
Table 1 on page 12 of Mr. Watters' testimony lists the net short-term purchases
. between 1996 and October 2001. For each month from January 1996 through the most recent month
available, please supply the following:
The total system load.
Short-term firm purchases.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP - 5
10.
Short-term firm sales for resale.
Non-firm purchases.
Non-firm sales for resale.
Any other data that would have gone into the Company s calculation of "Net
Short Term Purchases" as used in Table 1 on page 12 of Mr. Watters
testimony.
mark-to-market value. Please answer the following:
On page 13 lines 1-12 of Mr. Watters' testimony is a discussion ofthe Company
11.
Please provide a copy of the analysis that determined the mark-to-market
value was $700 million on March 6, 2001.
Please provide the results of all other mark-to-market analysis that were
conducted by the Company between January 1999 and the present. If these
analysis were conducted more than once a month, then only provide the
results ofthe first analysis conducted each month.
What is the source and basis of "the then current forward price curve prices
If not already included in "" above, on a monthly basis, what were the
amounts (MWH and dollars) of all forward purchases on March 6, 2001 ?
Please provide an explanation regarding how the anticipation of Hunter
coming back on-line impacted forward purchases. Qualitative and
quantitative information is sought on how the expected restart date of Hunter
impacted these decisions.
Sometimes we enter into near-term contracts..." Please answer the following:
On page 17 lines 4-5 of Mr. Watters ' testimony there is a discussion that starts:
When did this general policy or activity begin regarding buying a standard
product to meet the peak needs and then selling the excess during the
shoulder periods?
Please provide any policy statements that qualify or quantify this activity.
Please add some specificity and quantification to the term "sometimes
What percentage of days does this form of activity represent?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 6
12.
What is the criteria for determining whether this activity will be utilized
versus not making the purchase of the standard product and then selling
during the shoulder periods?
For each month from January 1999 through the most recent data available
what were the number of days this policy was utilized to meet peak?
uses its "shoulder position . Please answer the following:
On page 17lines 4-15 of Mr. Watters' testimony is a discussion of how the Company
13.
Please explain the difference between the hourly market shoulder positions
that are sold and non-firm sales.
From January 1999 through the most recent data available please provide on
a monthly basis a quantification of the Company s anticipated shoulder
position for future months. A format similar to Watters ' Exhibits 1 and 2 is
requested, showing the expected MWH and dollars and how that expectation
changed through time.
From January 1999 through the most recent data available please provide on
a monthly basis the actual shoulder position sold in terms of MWH, dollars
and $/MWH.
From January 1999 through the most recent data available please provide on
a monthly basis the actual non-firm sales that were sold (MWH. dollars, and
$/MWH) during the shoulder period that are not included in "" above.
From January 1999 through the most recent data available please provide on
a monthly basis the actual non-firm sales that were sold (MWH, dollars, and
$/MWH) other than during the shoulder period. Please provide this
information on the basis on "non 6 x 16" times and "super-peak" times stated
separately.
Please provide a copy ofthe WUTC comments filed with the FERC on August 17
2001 referenced on page 18 ofMr. Watters' testimony.
14. For each month from January 1995 through the most recent month available please
provide (in hard copy and electronic copy) the Company s Net Power Cost in a format similar to
Widmer s Exhibit 4 data that reflects:
Actual data.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO PACIFICORP - 7
Type 1 data.
Type 2 data.
Type 3 data.
Please provide a description of the differences between actual, Type 1 , Type
, and Type 3 data.
15. In a format similar to Mr. Widmer s Exhibit 4 please provide a copy (hard and
electronic) of the Company s Net Power Cost as utilized by:
16.
following:
The Utah Commission in its Order in Docket No. 01-035-01.
The Oregon Commission in ints Order in Case UE-116.
With respect to the footnotes found in Widmer s Exhibit 7 please answer the
Please provide a detailed explanation and quantification of the data that went
into formulating the figures associated with footnote 2. Emphasis should be
placed upon the treatment from eachjurisdiction of jurisdictional customers
system firm customers, and system non-firm customers.
Please reconcile the 1998 Net System Load listed in footnote 2 with the
system loads listed on page 304 of the 1998 FERC Form 1. Please provide
this on a sales as well as a generation level basis.
Please provide a detailed explanation and quantification of the data that went
into formulating the figures associated with footnote 4. Emphasis should be
placed upon the treatment from Idaho of jurisdictional customers, system
firm customers, and system non-firm customers.
Please reconcile the 1998 Idaho Retail Load listed in footnote 4 with the
Idaho loads listed on page 304 of the 1998 FERC Form 1. Please provide
this on a sales as well as a generation basis.
Please provide a detailed explanation and quantification of the data that went
into formulating the figures associated with footnote 6. Emphasis should be
placed upon the treatment from each jurisdiction of jurisdictional customers
system firm customers, and system non-firm customers.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP - 8
What is the timeframe associated with the values included in footnote 6?
F or each month during the November 1 , 2000 through October 31 , 2001
timeframe, what was the actual Idaho Retail Load on the same basis as
footnote 4?
F or each month during the November 1 , 2000 through October 31 , 2001
timeframe, what was the actual Idaho Retail Load (stating special contracts
separately) as would appear on the FERC Form I? Please provide this
information on a sales as well as generation level basis.
'5/~ay of January, 2002.DATED this
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO PACIFICORP - 9
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this ~day of January, 2002, I served a true, correct and
complete copy of the foregoing document, to each of the following:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
o. Box 83720
Boise, Idaho 83720-0074
John M. Eriksson
Stoel Rives, LLP
201 South Main Street, Suite 1100
Salt Lake City, Utah 84111-4904
Fax: [phone]
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
Fax: [phone]
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO PACIFICORP - 10