20050309IIPA 1st Request to PacifiCorp.pdf

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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]
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Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA UTAH POWER &
LIGHT COMPANY FOR AUTHORITY TO
INCREASE ITS RATES FOR ELECTRIC
SERVICE TO ELECTRIC CUSTOMERS
IN THE ST ATE OF IDAHO
) CASE NO. PAC-05-
) IDAHO IRRIGATION PUMPERS
) ASSOCIATION, INC.S FIRST
DATA REQUEST TO P ACIFICORP
1. Please answer the following with respect to information contained on Weston s Exhibit 9
Tab 10 entitled "Allocation Factors
A. On page 3, are these the actual generation level energy and demand values recorded for
each jurisdiction during each of the months specified?
B. Do the energy and demand values for Idaho on page 3 include Monsanto?
C. Are the values/adjustments on page 4 simply weather related adjustments? If these
adjustments are more than simply weather related adjustments, please provide a
breakdown of these values that relate to weather adjustments and those that relate to other
adjustments (please provide specific detail for each "other" adjustment).
D. Are the demand and energy values on page 5 the ones used to form the basis for such
system allocators as SC and SE?
E. Are the values on page 5 simply the summation of the actual data on page 3 plus the
adjustments on page 4? If this is not the case, please explain.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP
F. The Idaho demand value for January 2004 on page 3 is 366.91 MW and the adjustment
for demand for January 2004 on page 4 is -15.22 MW. How is the figure of 421.7 MW
on page 5 for January 2004 derived?
G. For each of the adjustments listed on page 4, what rate schedules or special contract
customer consumptions were adjusted in each month?
H. Please provide an electronic as well as hard copy of all workpapers that support the
adjustments on page 4.
2. Please answer the following with respect to information contained on Taylor s Exhibit 24
Tab 5 "Cost of Service Allocation Factors
A. Are the times of the system peaks listed on page 6 the same as the actual coincident
system peaks during each of those months?
B. Are the times listed on page 6 on Pacific or Mountain time?
C. With respect to the data listed on pages 7 and 10, which data came from the Company
load research data and which data came from census data?
D. What was the level of curtailment/interruption for each customer class or Monsanto
during the times of each of the monthly peaks listed on page 7?
E. Is there any weather normalization of the Distribution Peak data on page 11 or the Non-
Coincident Peak data on page 13? If this data is weather normalized, please provide an
electronic as well as hard copy of all workpapers used to support this normalization.
3. Please answer the following with respect to information contained on Weston s Exhibit 9
Tab 10 entitled "Allocation Factors" and Taylor s Exhibit 24, Tab 5 "Cost of Service
Allocation Factors
A. The demand value for January 2004 for Idaho on Ex. 9, Tab 10, page 5 is 421.7 MW
while the total value on Ex. 24, Tab 5, page 6 for January 2004 is 465.361 MW. Please
reconcile these two figures. If additional data is required to reconcile all of Ex. 9, Tab
, page 5 figures, with Ex. 24, Tab 5, page 6, please provide that data.
B. On Ex. 24, Tab 5, page 14 there is listed a total annual energy figure of2 147 807 MWH.
On Ex. 9 , Tab 10, page 5 the total Idaho annual energy is listed as 3 719 256 MWH.
Please reconcile these two figures.
4. With respect to the Company s Load Research data, please provide for each sample customer
with valid data that was sampled between January 2002 and the most recent month available
the following:
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP
A. Customer identification number;
B. Customer rate schedule;
C. Strata to which it belongs;
D. Raw hourly usage data (i., unadjusted, simply the data originally gathered for each
sample);
E. Raw hourly usage data modified to reflect losses;
F. On an hourly basis, any additional calibrations that are applied to the Load Research data
before it is applied to develop the allocation factors used in the Company s cost of
service study in this case.
G. Please provide copies of the formulas (and data) used to expand the Load Research data
up to the population as a whole as used in the class cost of service study in this case.
This information should include number of customers in the population of each class.
5. In January 2002 the Company developed/presented a "Load Research Status" report in Utah.
Does something similar exist for the Idaho jurisdiction? If so, please provide a copy and
indicate if there have been any changes to the Load Research Program since that report was
written.
6. Previously the Company developed hourly calibrations that calibrated the Load Research
data such that the summation of the (population expanded) Load Research data and the
Census data equaled the Company s "Operations Stat" or border loads. The Company may
no longer be applying these calibrations to the Load Research data, but the data is still of
interest. On an hourly basis from January 2002 through the most recent month available
please provide:
A. The "Operations Stat" or border load;
B. The summation of the (population expanded) Load Research data and the Census data
that would reflect what the Company measured or estimated as its internal customer load
for each rate schedule or customer group;
C. The hourly load for each rate schedule or special contract customer that is measured or
calculated on a census basis as opposed to using load research data;
D. Any other load that is contained in "" above but is not addressed in "" above (please
specify the type of load); and
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP
E. Any information such as difference in measuring techniques or timing of the data that
needs to be addressed when comparing the above data.
7. Please provide for each month from January 2002 forward a copy of the results of all checks
that the Company makes regarding how well the load research data reflects the actual
population usage.
8. Please provide a copy of any summary reports that have been produced between January
2002 and the present.
9. This filing used weather-normalized data for developing allocation factors in the
jurisdictional allocations and presumably the class cost-of-service study. For each rate
schedule, please provide all workpapers as well as a description of the flow (manipulation) of
data from historic load research or consensus data to projected test year energy, coincident
demands, and non-coincident demands.
10. Please provide a copy of the bill frequency distribution for each month of the test year as
well as each month from January 2002 through the most recent month available for each rate
schedule that is weather normalized. Distributions can be provided in a manner that
convenient for the Company.
11. Please provide in electronic format for the period January 1 , 2003 through the most recent
month available hourly data similar to that provided in CCS Request 9.2 in the most recent
Utah rate case Docket 04-035-42.
12. Are the Short Term Firm Sales listed on Ex. 9, Tab 5, page 5 related to actual test year sales
or are they simply a function of the net power cost model picking this source of supply at any
given hour?
13. With respect to Ex. 9, Tab 5, page 5, do the System Balancing Sales relate to actual sales that
may have occurred during the test year, or are they something picked by the net power cost
model?
14. In actual operation, would the "Balancing Sales" used in the net power cost model be
Opportunity Sales, Short-Term Firm, or something else? Please specify the approximate
percentage of different types of actual sales that would make up the "Balancing Sales" used
in the net power cost model.
15. In actual operation, would the "Balancing Purchases" used in the net power cost model be
Opportunity Purchases, Short-Term Firm, or something else? Please specify the approximate
percentage of different types of actual sales that would make up the "Balancing Purchases
used in the net power cost model.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP
16. Please provide in electronic format a listing of the date, time, and estimated magnitude of all
actual hourly curtailments/interruptions that occurred during the test year in Idaho separated
by rate schedule or special contract customer. If outright curtailments/interruptions are
treated differently than "buy-throughs , please state each separately.
17. Please provide in electronic format a listing of the date, time, and estimated magnitude of all
actual hourly curtailments/interruptions that occurred during the test year in each of the other
jurisdictions. If outright curtailments/interruptions are treated differently than "buy-
throughs , please state each separately.
18. Please reconcile the total system load of52 721 424 MWH listed on Ex. 9, Tab 5 (Net Power
Costs), page 5, with the difference between the actual system energy of53 184 855 MWH on
Ex. 9, Tab 10, page 3 , less the adjustment of 432 150 MWH found on Ex. 9, Tab 10, page 4
(53 184 855 - 432 150 = 52 752 705).
19. How was actual test year hourly data incorporated into the Company s net power cost model
and the values used in this case?
20. If the Company s net power cost model was run using weather normalized loads, how were
those weather-normalizing adjustments spread out for each hour used in the net power cost
model?
21. Please provide in a summary fashion similar to that provided in Ex. 9, Tab 5, the results of
the Company s net power cost model assuming that the Company was supplying all of the
curtailments/interruptions/buy-throughs from all jurisdictions, less the Monsanto load.
22. Please provide in a summary fashion similar to that provided in Ex. 9, Tab 5, the results of
the Company s net power cost model assuming that the Company was supplying all of the
curtailments/interruptions/buy-throughs from all jurisdictions as well as the Monsanto load.
23. Please provide in a summary fashion similar to that provided in Ex. 9, Tab 5, the results of
the Company s net power cost model assuming that the Company was supplying all of the
curtailments/interruptions/buy-throughs from all jurisdictions as well as the Monsanto load
excluding the Irrigation loads that are curtailed/interrupted.
24. Please provide a copy or copies of the Company s Jurisdictional Allocation Model (in a
manner similar to that of Exhibit 9 Tabs 1 , 2 and 10) stating the Idaho Jurisdiction without
Monsanto and the Monsanto load as two separate jurisdictions.
25. Exhibit 9, Tab 10, page 3 lists a total Idaho energy requirement of3 688 337 MWH and
Exhibit 24, Tab 5 , page 5 lists a total Idaho energy requirement for class cost of service
purposes as 2 147 807 MWH. Please reconcile the difference between these two figures.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP
26. Exhibit 9, Tab 10, page 3 lists a total Idaho 12-CP demand requirement of5 394 640 KW and
Exhibit 24, Tab 5 , page 6 lists a total 12-CP demand requirement for class cost of service
purposes as 5 612 924 KW. Please reconcile the difference between these two figures.
27. With respect to Exhibit 24, Tab 5, page 6 , please answer the following:
A. Are all of these values actual? If not, please provide and explanation of how they were
normalized and the workpapers that support the normalization.
B. Please explain the difference between the figures on lines 20 and 21.
C. What level of curtailment of Schedule 10 load is reflected on line 26? Is this level of
curtailment the same as occurred in 2004 or is expected to be incurred in 2005?
28. Please reconcile the total Idaho Operating Revenue figure of $133, 904 000 on Exhibit 9, Tab
, page 7 with the revenue figures on Exhibit 9, Tab 2, page 2.
29. Please reconcile the total Idaho Operating Revenue figure of $120,460 798 on Exhibit 24
Tab 5, page 26 with the revenue figures on Exhibit 9 , Tab 2, page 2.
30. Please provide the test year billing determinants, rates and calculations used to support the
Monsanto revenue (actual and normalized) that was credited to the Idaho Jurisdiction.
31. Commission Order No. 29157 set an interruptible credit of7.48 mills/kWh for Monsanto.
How was this credit address in this case? Further information is clearly needed for the
Commission, the Commission Staff, and the Irrigators to thoughtfully make such a
determination.
32. On page 3 of Mr. Stewart's testimony it is stated that "base rates are actually about 7 percent
lower today than they were in 1986." Please supply whatever data or source there is that
supports this calculation.
33. For each rate schedule and special contract customer listed in Exhibit 25, for each year since
the last rate case, please list the amount of energy consumed and the revenue collected.
34. With respect to the Company s 2003 FERC Form 1 page 304., please explain how lines 2
and 6-9 are related.
35. With respect to the Company s 2003 FERc Form 1 page 304., line 22 through page
304., line 13 please explain how these lines are related and what each line represents.
36. Regarding the irrigation loads listed on the 2003 FERc Form 1 page 304., line 22 through
page 304., line 13, which of these lines pertain to Schedule 10 and which lines pertain to
some other rate schedule?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP
37. Statistics for Monsanto appear to be contained on the 2003 FERC Form 1 at page 304., line
25. Please answer the following:
a. Do the revenues and MWh listed include both firm and interruptible deliveries?
affirmative, please list the revenues for the firm and interruptible deliveries separately.
b. Do the revenues and MWh listed include buy-through purchases? If affirmative, please
list the MWh and the revenues for the buy-through separately.
c. Do the revenues include any amount due from a previous timeframe? If affirmative
please specify the amount and the reason for the payment.
d. Do the revenues include the interruptibility credit approved by the Commission in Order
29157? If affirmative, what was the MWh and revenue associated with the
interruptibility credit? If negative, where in the FERC Form 1 is this interruptibility
credit addressed?
38. Please provide a copy of the Company s recent study entitled "PacifiCorp Idaho 2001
Analysis of System Losses
39. Please provide in electronic format a copy of all interjurisdictional and class cost of
service studies conducted by the Company in this case.
40. Please provide an electronic copy as well as a hard copy of any cost of service studies
(similar to Exhibit 24 in this case) that were fun by the Company in Case PCA-01-
that support the results listed in Taylor s Exhibit 1 page one of that case.
Respectfully submitted this 1.J1~ay of March, 2005.
RACINE, OLSON, NYE, BUDGE &BAILE RED
ERIC L. OLSEN
Attorneys for the Idaho Irrigation Pumpers
Association, Inc.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO P ACIFICORP
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 7--1/1\day of March, 2005, I served a true
correct and complete copy of the Idaho Irrigation Pumpers Association, Inc. 's First Data
Request to Pacificorp to each of the following, via U.S. Mail, e-mail or hand delivery:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
E-mail: jean. iewell(illpuc.idaho.gov
E-mail
S. Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 800
Portland, OR 97232
E-mail: datarequest(illpacificorp. COlli
E-mail
John Stewart
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
E-mail: iohn.stewart2(illpacificorp.com
S. Mail
James M. Van Nostrand
Stoel Rives LLP
900 SW Fifth Avenue, Suite 2600
Portland, OR 97204
E-mail: jffell(illstoel.com
i m vanno strand(illstoel. com
S. Mail
Lisa Nordstrom
PacifiCorp Office of the General Counsel
825 NE Multnomah Street, Suite 1800
Portland, OR 97232
E-mail: lisa.nordstrom(illpaci fi corp. com
S. Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ID 83276
E-mail: iim.r.smith(illilionsanto.colli
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
RESPONSE TO P ACIFICORP'S FIRST DATA REQUEST
Monsanto Company
c/o Mark Boswell, Legal Dept.
800 N. Lindburg Blvd.
Mailzone E2NR
St. Louis, MO 63167
S. Mail
Katie Iverson
Brubaker & Associates
7244 W. Cordova Court
Surprise, AZ 85387
ki verson(illsconsul tbai. com
S. Mail
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony(illyankel.net
S. Mail
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
S. Mail
J .R. Simplot Company
Att: David Hawk & R. Scott Pasley
999 Main Street, Suite 1300
O. Box 27
Boise, ID 83707-0027
S. Mail
Timothy J. Schurtz
411 S. Main
Firth, ID 83236
S. Mail
Brad M. Purdy
Attorney at Law
2019 N. ih St.
Boise, ID 83702
S. Mail
Idaho Irrigation Pumpers
Association, Inc.
c/o Lynn T ominaga
O. Box 2624
Boise, ID 83701-2624
S. Mail
RIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
RESPONSE TO P ACIFICORP'S FIRST DATA REQUEST