200302061st Request of Staff.pdf

')..3/
SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
ECEIVED
LED
'2nn3 fEE -6 Pii 3: 33
,,-;:""';
UTIL\'r\ES coi,\vl!ss\m~.
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
PACIFICORP DBA UTAH POWER & LIGHT
COMPANY FOR APPROVAL OF AN
AMENDED ELECTRIC SCHEDULE 72
IRRIGATION LOAD CONTROL CREDIT RIDER PROGRAM.
CASE NO. PAC-03-
FIRST PRODUCTION
RKQUEST OF THE
COMMISSION STAFF
TO P ACIFICORP
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 ofthe Idaho Public Utilities Commission
Rules of Procedure, IDAPA 31.01.01 , on or before WEDNESDAY, FEBRUARY 19,2003.
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 ofthe 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.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
ACIFICORP
FEBRUARY 6, 2003
Request No.1: Please provide the proposed amount (rate or rates) for the Load Control
Service Credit (LCSC) in 2003.
Request No.2: Please provide a description of the methodology used to calculate the
LCSC rate, all the supporting calculations, assumptions and related analysis used in the
development of this value.
Request No.3: Please provide a copy of the Load Control Service Agreement and the
Intent to Participate notification. Please verify if they will be standardized forms.
Request No.4: Would an irrigation pump motor ever be scheduled for interruption on
two consecutive days in the Load Control Schedule? Did the irrigators identify this as a
concern?
Request No.5: In the event of a utility system power failure of an hour or more would
the Load Control Schedule be altered? If so, how? Is this explained in the Service Agreement?
Request No.6: In order to give the irrigator a better idea of what the cost of early
termination would be, could the Company quantify some of the anticipated costs and include
them as a fixed amount in the tariff?
Request No.7: Please provide an itemized estimate of typical costs that would be
incurred by the Company for early termination.
Request No.8: Specifically would there be a cost for replacement power if an irrigator
terminated early?
Request No.9: How would the cost of the replacement power be calculated?
Request No. 10: Instead of allowing the load control service credit to go to zero, does it
make sense to always offer an LCSC of at least the forward market price less 2 mills? This
might encourage some irrigator investment in pumping capacity modifications that would allow
the irrigator to commit to this program. Please explain your answer.
Request No. 11: How will the Company factor early terminations into the analysis to
determine the future value of interruption based on reliability?
Request No. 12: Procedurally, would the Company prefer to 1) file an Application in
the fall of each year to review the proposed methodology and LCSC rate with approval by the
Commission, or 2) haye the methodology approved in this case with a tariff advice filed and
reviewed on an annual basis to establish the LCSC rate? Note: Method one should allow 3-
months to process and method two 1 month to process.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
ACIFICORP
FEBRUARY 6, 2003
Request No. 13: Why does the program require the customer to file an Intent to
Participate letter or form along with signing a Load Control Service Agreement? It seems that
two formal actions with deadlines complicate the process and in all probability reduce
participation.
Request No. 14: Program participation is proposed to be subject to meter availability.
How many meters will be available for 2003? What is the Company s educated guess as to the
probability that there will be more irrigators interested in participating than there are meters
available?
Request No. 15: What is the penalty for "Load Shifting ? This could result from pump,
motor or well failure as well as an attempt to defraud the Company.
Request No. 16: Has the Company identified "free rider" possibilities, that is irrigators
who would not be using the power even without this program, and how does the Company plan
to minimize "free riders
Technical Staff: Dave Schunke
Keith Hessing
Terri Carlock
i: umisc :prodreq/paceO3.3 swdeskhtc
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
ACIFICORP
FEBRUARY 6, 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF FEBRUARY 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP, IN CASE NO. PAC-03-, BY MAILING
A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DOUG LARSON
VICE PRESIDENT REGULATION
ACIFICORP
1407 W NORTH TEMPLE
SALT LAKE CITY UT 84116
DATA REQUEST RESPONSE CENTER
ACIFICORP
825 NE MUL TNOMAH, SUITE 800
PORTLAND, OR 97232
MAILED TO datarequest(fYpacificorp.com
MAILED TO BOB LIVELY AT
bob .livel y(fYpacificorp. com
SECRET AR Y
CERTIFICATE OF SERVICE