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Home My WebLink About200502252nd Request of Staff to PacifiCorp.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 ECEJVEO :~ 11, ll:) r'"'" t'),nf1 , , ~ ? 3: O~H..tJ Lv"", ;; ,;;; FUbL1L UT'LYi'IES~' COHt'"i\SStOH 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 AUTHORITY TO INCREASE ITS RATES FOR ELECTRIC SERVICE TO ELECTRIC CUSTOMERS IN THE STATE OF IDAHO. CASE NO. PAC-05- SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO ACIFICORP The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that PacifiCorp (PacifiCorp; Company) provide the following documents and information on or before FRIDAY, MARCH 11,2005. 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. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. SECOND PRODUCTION REQUEST TO ACIFICORP FEBRUARY 25 , 2005 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. Reference IDAP A 31.01.01.228. For documents provided please include the name and phone number of the person preparing the document, and the name, location and phone number of the record holder. For all responses to the following requests, please provide all workpapers, diskettes (3.5 in.), CDs with all underlying formulas intact in Excel 2000 compatible language. REQUEST NO. 34: In its jurisdictional and class cost of service studies PacifiCorp has used loss factors from its "PacifiCorp Idaho 2001 Analysis of System Losses" Study dated June 11 , 2004. Page 2 of that study compares 2001 loss factors with 1991 loss factors for demand and energy which are further broken down into transmission, primary and secondary categories. All six of the loss factors have increased in the 2001 study. Given that transformer efficiencies are improving and that irrigators ' electrical efficiencies are generally improving, what is driving the increases in loss percentages? It seems that the reasons for the increases could be different by voltage level, therefore, to the extent that the reasons are different, please answer the question for each of the six components. Please provide the data that supports the answers. REQUEST NO. 35: Please provide a Class-Cost-of-Service model run, based on the Revised Protocol jurisdictional allocation, with Monsanto included as a separate customer class. Provide a complete description and all the supporting calculations of how the value of System integrity, Operating Reserves and Economic Curtailment are calculated and credited. Include load data necessary to make the calculations and any assumptions that differ from the Commission s findings in the Monsanto contract case, P AC-01-, Order Nos. 29157 and 29206 and related Minute Order dated May 23 , 2003. REQUEST NO. 36: If different from the jurisdictional allocation model run provided in the Company s filing, please provide a Revised Protocol Jurisdictional Allocation model run with Monsanto included in the Idaho jurisdiction. Provide a complete description and all the SECOND PRODUCTION REQUEST TO ACIFICORP FEBRUARY 25 , 2005 supporting calculations of how the value of System integrity, Operating Reserves and Economic Curtailment are calculated and credited. Include load data and any assumptions that differ from the Commission s findings in the Monsanto contract case, PAC-01-, Order Nos. 29157 and 29206. REQUEST NO. 37: Please compare Taylor Exhibit No.22 page 2 of2 (Cost of Service by Rate Schedule) in this case with Taylor Exhibit No.1 page 1 of 4 (Cost of Service by Rate Schedule) in PAC-01-16. Given that the overall increase and target return on rate base is similar, please reconcile the differences in revenue requirement change by schedule. a. For example, why did the Cost of service study show a decrease in rates for a number of schedules in 1999 and an increase for the same schedules in 2004? b. Also, why is the total cost of service in 2004 less than in 1999 for the following schedules: 9, 12 traffic signal, and 19? c. Also why has the annual revenue decreased from 1999 to 2004 for the following schedules: 9 , 12 traffic signals, 19, and Nu-West? REQUEST NO. 38: Please provide a jurisdictional allocation model run using rolled- methodology and treating Monsanto as a system customer. All other inputs and assumptions should be the same as filed in the Company s case. Dated at Boise, Idaho , this c9 ~ day of February 2005. 0 t oodbury Deputy Attorney General Technical Staff: Keith Hessing Dave Schunke i:umisc:prodreq/paceO5.1 sw pr 2 kh- des-35- SECOND PRODUCTION REQUEST TO ACIFICORP FEBRUARY 25, 2005 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 25TH DAY OF FEBRUARY 2005 SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP IN CASE NO. PAC-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID , TO THE FOLLOWING: JOHN STEWART ACIFICORP 201 S MAIN ST., SUITE 2300 SALT LAKE CITY, UT 84140 MAIL: iohn.stewart2~pacificorp.com LISA NORDSTROM ACIFICORP 825 NE MUL TNOMAH ST STE 1800 PORTLAND OR 97232 MAIL: lisa.nordstrom~pacificorp.com DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MUL TNOMAH SUITE 800 PORTLAND OR 97232 MAIL: datarequest~pacificorp.com ERIC L OLSEN RACINE OLSON NYE BUDGE & BAILEY, CHARTERED PO BOX 1391 POCATELLO ID 83204-1391 MAIL: elo~racinelaw.net ANTHONY YANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 MAIL: tony~yanke1.net RANDALL C. BUDGE RACINE OLSON NYE BUDGE & BAILEY, CHARTERED PO BOX 1391 POCATELLO ID 83204-1391 MAIL: rcb~racinelaw.net JAMES R SMITH MONSANTO COMPANY PO BOX 816 SODA SPRINGS ID 83276 MAIL: iim.smith~monsanto.com CONLEY E WARD GIVENS PURSLEY LLP 601 W BANNOCK ST PO BOX 2720 BOISE ID 83701-2720 MAIL: cew~givenspursley.com R. SCOTT PASLEY ASSISTANT GENERAL COUNSEL J R SIMPLOT COMPANY 999 MAIN ST (83702) PO BOX 27 BOISE ID 83707 MAIL: spasley~simplot.com DAVID HAWK ,DIRECTOR ENERGY NATURAL RESOURCES J R SIMPLOT COMPANY 999 MAIN ST (83702) PO BOX 27 BOISE ID 83707 MAIL: dhawk~simplot.com CERTIFICATE OF SERVICE