200503112nd Response of PacifiCorp to Staff.pdf

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March 10, 2005
SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 W Washington
Boise, ID 83702-5983
RE:ID P AC-05-
IPUC Staff Production Data Requests 34-
Please find enclosed an original and one copy of PacifiCorp s Response to IPUC Staff
Production Data Requests 34-38. Provided on the enclose CD are Attachments IPUC 34 (A-B),
35 B, and 38.
If you have any questions, please call Barry Bell at [phone].
Sincerely,~0t/
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Jt.
Bob Lively, Manager
Regulation
Enclosures
cc:Jean Jewell (3 copies)
James Fell/Stoel Rives
P AC-05-l/PacifiCorp
March 10, 2005
IPUC Staff Production Request 34
IPUC Staff Production Request 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.
Response to IPUC Staff Production Request 34
Attached on the enclosed CD for reference purposes as Attachment IPUC 34 A is
a copy of the 1991 Loss Study and as Attachment IPUC 34 B the 2001 Loss Study
with various identified quantities circled.
Losses at the transmission level have been calculated on a rolled-in basis and are
therefore subject to changes in use ofPacifiCorp s transmission system during
time period between the 1991 Loss Study and the 2001 Loss Study. Significant
changes have occurred during this time period, including Open Access of
transmission systems by the Federal Energy Regulatory Commission. In addition
there have been significant increases in the use of PacifiCorp s distribution system
in Idaho. Below is a summary of these differences.
1991 Loss Study 2001 Loss Study
Transmission Energy (input)
Transmission Demand (input)
Idaho Primary Sales Energy
Idaho Primary Sales Demand
Idaho Secondary Sales Energy
Idaho Secondary Sales Demand
969 984 MWh
348 MW
840 MWh
5.18 MW
242 813 MWh
174.67
985 214 MWh
293 MW
974 MWh
73
1,473 548 MWh
181.43 MW
The above information was extracted from pages 1 and 33 of the 1991 Loss Study
and pages 18 and 34 of the 2001 Loss Study. In the time that elapsed between the
1991 Loss Study and the 2001 Loss Study, system usage is up by 250/0 for the
transmission system, 68% for the primary distribution system and 18% for the
secondary distribution system. The information from the studies indicates that
load growth is driving the increases to the loss percentages.
(David L. Taylor will sponsor this response at hearing.
IDAHO
P AC-O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENTS IPUC 34 (A-
ON THE ENCLOSED CD
P AC-05-l/PacifiCorp
March 10, 2005
IPUC Staff Production Request 35
IPUC Staff Production Request 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, PAC-01-, Order Nos. 29157 and 29206 and related Minute
Order dated May 23 2003.
Response to IPUC Staff Production Request 35
The summary of the Class-Cost-of-Service study with Monsanto included as a
separate customer class is included as Attachment IPUC 35 A. An electronic
copy of the full model is included as Attachment IPUC 35 B on the enclosed CD.
Attachments IPUC 35 A and B are based on the results of operations filed in Ted
Weston Exhibit No.
In both the results of operations and in the Class-Cost-of-Service, the loads and
revenues associated with service to Monsanto were treated consistently with
Appendix D of the Revised Protocol which is included as Attachment IPUC 35 C.
As shown in William R. Griffith Exhibit 25 and Exhibit 29, page 9, Monsanto
present revenues used in the this case are $42.9 million which reflects all of its
usage priced at the firm service rate. The $4.51 per kW discount for ancillary
services is included as a resource purchase in Net Power Costs and allocated to
among all states.
Consistent with reflecting Monsanto s revenues at the firm service equivalent
rate, Monsanto s loads are included at its full requirements level and do not reflect
any curtailments due to System Integrity, Operating Reserves, and Economic
Curtailment.
Any load reductions associated with Economic Curtailment or the call for
reserves are normalized back into the Idaho jurisdictional loads in the Results
Operations and back into Monsanto s loads in the Cost of Service study. See
Attachment IPUC 35 D.
Assumptions that differ from the Commission s findings in the Monsanto contract
case, PAC-01-, Order Nos. 29157 and 29206 and related Minute Order are:
(1) The Commission s order in PAC-01-16 found that Monsanto s non-firm
load should be treated as a system customer pending the conclusion of the Multi-
State Process. In compliance with the now approved MSP Revised Protocol
Monsanto is now treated as an Idaho Situs customer. (2) The Commission s order
P AC-05-l/PacifiCorp
March 10, 2005
IPUC Staff Production Request 35
in PAC-16-0l also provided two cost-of-service adjustments, a 1 mill/kWh rate
ofretum adjustment and a 0.12 mill/kWh fuel shaping adjustment. Neither of
these adjustments are incorporated in the cost of service study provided in
response to this data request.
(David L. Taylor will sponsor this response at hearing.
IDAHO
P A C- O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
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IDAHO
A C- O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC 35 B
ON THE ENCLOSED CD
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC 35 C
PacifiCorp
Exhibit UP&L (DLT-3S) Page 1 of3
Docket No. 02-035-
Witness: David L. Taylor
Protocol Appendix D
Special Contracts
Special Contracts without Ancillary Service Contract Attributes
For allocation purposes Special Contracts without identifiable Ancillary Service Contract attributes are
viewed as one transaction.
Loads of Special Contract customers will be included in all Load-Based Dynamic Allocation Factors.
When interruptions of a Special Contract customer s service occur, the reduction in load will be reflected in
the host jurisdiction s Load-Based Dynamic Allocation Factors.
Actual revenues received from Special Contract customer will be assigned to the State where the Special
Contract customer is located.
See example in Table
Special Contracts with Ancillary Service Contract Attributes
For allocation purposes Special Contracts with Ancillary Service Contract attributes are viewed as two
transactions. PacifiCorp sells the customer electricity at the retail service rate and then buys the electricity
back during the interruption period at the Ancillary Service Contract rate.
Loads of Special Contract customers will be included in all Load-Based Dynamic Allocation Factors.
When interruptions of a Special Contract customer s service occur, the host jurisdiction s Load-Based
Dynamic Allocation Factors and the retail service revenue are calculated as though the interruption did not
occur.
Revenues received from Special Contract customer, before any discounts for Customer Ancillary Service
attributes of the Special Contract, will be assigned to the State where the Special Contract customer islocated.
Discounts from tariff prices provided for in Special Contracts that recognize the Customer Ancillary
Service Contract attributes of the Contract, and payments to retail customers for Customer Ancillary
Services will be allocated among States on the same basis as System Resources.
See example in Table 2
Buy-through of Economic Curtailment.
When a buy-through option is provided with economic curtailment, the load, costs and revenue associated
with a customer buying through economic curtailment will be excluded from the calculation of State
revenue requirements. The cost associated with the buy-through will be removed from the calculation of
net power costs, the Special Contract customer load associated with the buy-through will be not be included
in the calculation of Load-Based Dynamic Allocation Factors, and the revenue associated with the buy-
through will not be included in State revenues.
IDAHO
PAC-O5-
GENERAL RA TE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC 35 D
COINCIDENTAL PEAKS
Month
Jan-
Feb-
Mar-
Apr-
May-
Jun-
Jul-
Aug-
Sep-
Oet-
Nov-
Dee-
Check values
Day Time
1800
0800
0800
0800
1600
1500
1500
1600
1600
0800
1800
1800
METERED LOADS (CP)
Non~FERC FERC
E. WY Total UT WWY NET UT
525,890.145,935,051,366,157,26,026
2,407,701,163,930,830,416,147,22,808
238,627,137,920,553,390.145,21,532
178,583,137,830,445,375,118,22,2,422
920,599.49 150,859.646,533,112,21,625
101,671,152,861,556,594,109.40 33,524
359,773,155,901.038.573,120,34.49 004
020.41 666.40 155,920,924,498,125,38,885
154,744.41 115,874,520,416,122.46 34,3,485
233,677,115,847,579,395,121.21,601
160.47 657.46 125,919,998,418,148.26,025
343,719,132,931.45 001,417.45 151,24,026
13051 914 208644 208644
26644 8314 1688 10 735 38147 5395 1580 327 37820
(less)
Adjustments for Buy Through of Curtailment (Reduction)
Non.FERC FERC
Month Day Time WWY NET UT
Jan-1800
Feb-0800
Mar-0800
Apr-0800
May-1600
Jun-1500 (86)
Jul-1500 (89)
Aug-1600 (91)
Sep-1600 (92)
Oet-0800
Nov-1800
Dee-1800
(357,908)(358)
equals
Month
Jan-
Feb-
Mar-
Apr-
May-
Jun-
Jul-
Aug-
Sep-
Oet-
Nov-
Dee-
Month
Jan-
Feb-
Mar-
Apr-
May-
Jun-
Jul-
Aug-
Sep-
Oet-
Nov-
Dee-
Day Time
1800
0800
0800
0800
1600
1500
1500
1600
1600
0800
1800
1800
COINCIDENTAL PEAK SERVED FROM COMPANY RESOURCES
Non.FERC I FERC
WWY NET UT
525 891 146 936 052 367 157 026
2,407 702 164 931 831 416 148 808
239 628 137 921 553 390 146 532
178 583 138 831 2,445 375 119 422
921 599 150 860 646 533 112 625
102 672 153 862 3,470 594 109 3,437
360 774 155 902 950 573 121 915
020 666 156 920 833 498 125 794
155 744 115 875 3,428 416 122 393
234 678 116 847 580 396 121 559
160 657 126 920 999 418 148 973
343 719 133 931 002 417 151 977
26644 8314 688 735 37 789 5395 1580 327 37,462
plus
Day Time
1800
0800
0800
0800
1600
1500
1500
1600
1600
0800
1800
1800
Adjustments for Ancilary Services Contracts (Add backs) excluding Buy Through
Non-FERC FERC
E. WY WWY NET UT
70.
70,
70,
70,
70,
70,
420.
equals
LOADS FOR JURISDICTIONAL ALLOCATION (CP)
Nol1~FERC FERC
Month Day Time E. WY WWY NET UT
Jan-1800 525 891 146 936 052 437 157 026
Feb-0800 2,407 702 164 931 831 416 148 808
Mar-0800 239 628 137 921 553 390 146 532
Apr-0800 178 583 138 831 445 375 119 2,422
May-1600 921 599 150 860 646 603 112 625
Jun-1500 102 672 153 862 3,470 664 109 3,437
Jul-1500 360 774 155 902 950 643 121 915
Aug-1600 020 666 156 920 833 568 125 794
Sep-1600 155 744 115 875 3,428 486 122 393
Oet-0800 234 678 116 847 580 396 121 559
Nov-1800 160 657 126 920 999 418 148 973
Dee-1800 343 719 133 931 002 417 151 977
644 314 688 735 789 814,580 327 37,462
P AC-05-l/PacifiCorp
March 10, 2005
IPUC Staff Production Request 36
IPUc Staff Production Request 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 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.
Response to IPUC Staff Production Request 36
The requested information is not different from the jurisdictional model provided
in the Company s filing which is based on the Revised Protocol methodology
with Monsanto allocated to the Idaho jurisdiction.
(David L. Taylor will sponsor this response at hearing.
P AC-05-l/PacifiCorp
March 10, 2005
IPUC Staff Production Request 37
IPUc Staff Production Request 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. F or 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?
Response to IPUc Staff Production Request 37
There are several reasons for the cost of service increases for most
schedules in the 2004 study as compared to the cost of service decreases
for those same schedules in PAC-01-, Taylor Exhibit No.
First. In the four years from 1999 to 2004 , overall Company costs have
increased which increases the cost of service for all customer classes.
This is reflected in cost of service results shown in P AC-05-0 1 , Taylor
Exhibit No. 22.
Second. The PAC-01-16 docket, in contrast to this proceeding, was not
a general rate case designed to recover general cost increases, but rather a
proceeding to align the contract price for service for one customer
Monsanto, with its cost of service. To accomplish this, Monsanto was
changed from a system customer to a situs customer. The cost, loads, and
revenues for Monsanto, which previously were not included in Idaho
results, were now included in both the Idaho result of operations and the
cost of service study. In the P AC- E-O 1-16 cost of service study, the target
cost of service for Monsanto was the rate level at which the Idaho
jurisdiction would be producing the same return on investment - with
Monsanto included as a situs customer - as the Idaho jurisdiction was
providing in the analysis where Monsanto was treated as a system
customer.
The $18 million cost of service shortfall for Monsanto shown on P AC-
01-, Taylor Exhibit No., page 1 of 4, line 11 is greater than the
additional $15 million in Idaho revenue requirement associated with
including Monsanto in the Idaho results of operations shown on line 13.
P AC-05-lIPacifiCorp
March 10, 2005
IPUC Staff Production Request 37
Therefore most other customer classes are shown needing a small
decrease.
Third. The Rate Mitigation Adjustment, Schedule 94, which was
established in June 2002, reduced rates for most schedules and increased
rates for some. This has altered the cost of service relationships for those
classes in this case as compared to P A C- E-O 1-16.
Fourth. The irrigation class is now more closely aligned with cost of
service, while in P AC-O 1-, Taylor Exhibit No., page 1 of 4, line 6
this class was shown needing an $8.7 million rate increase. The higher
rates for the irrigation class coupled with a better load factor than in
previous studies have improved cost of service performance for the
irrigation class in the FY2004 test period. A major shift in cost of service
performance for one class such as this will alter the cost of service
relationships for all classes.
Fifth. In PAC-05-, Taylor Exhibit No., Monsanto results are not
included. The costs associated with Monsanto s loads are included and
allocated to all other classes. Those allocated costs are then offset by the
allocation of Monsanto s revenues as a state-specific revenue credit.
Because the cost of service for Monsanto is greater than the current
revenues produced, the revenue shortfall from Monsanto is included in the
cost of service for the other classes.
Total cost of service in 2004 was less than in 1999 for Schedules 9 and
because (1) kWh sales to those schedules has declined (which lowers total
cost of service), and (2) their load factors have improved (which lowers
per kWh cost of service). The cost service for Schedule 12, Traffic
Signals, is lower because of a change in the way we have reflected the
number of customers in the study.
Annual revenue decreased from 1999 to 2004 for Schedule 9 and Nu- West
because of lower kWh sales; for Schedules 7, 11 , and 12 Traffic Signals
because of the lower prices associated with the Rate Mitigation
Adjustment; and for Schedule 19 because of both lower kWh sales and the
lower prices from the Rate Mitigation Adjustment.
(David L. Taylor will sponsor this response at hearing.
P AC-05-l/PacifiCorp
March 10, 2005
IPUC Staff Production Request 38
IPUc Staff Production Request 38
Please provide a jurisdictional allocation model run using rolled-in methodology
and treating Monsanto as a system customer. All other inputs and assumptions
should be the same as filed in the Company s case.
Response to IPUC Staff Production Request 38
See Attachment IPUC 38 on the enclosed CD.
In this study Monsanto s non-firm revenues have been removed from Idaho situs
revenue and allocated across all states using the SE (system energy) allocation
factor. In the calculation of jurisdictional allocation factors, Monsanto s non- frim
coincident peak and energy load, as metered, was removed from the Idaho
jurisdictional loads. This system treatment of revenue and load is consistent with
the Modified Accord method for interruptible special contracts.
This response is provided for informational purposes only. The Idaho
Commission has adopted the MSP Revised Protocol which specifies that all
special contract customers should be treated on a situs basis. In all of the revenue
requirement impact analysis included with the MSP filings and the Idaho MSP
Stipulation, all special contracts, including Monsanto, were treated as situs
customers. Monsanto was included as a situs customer in all of the Idaho revenue
requirement estimates calculated using the Rolled-, Modified Accord, and the
MSP Revised Protocol methodologies.
(J. Ted Weston will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC
ON THE ENCLOSED CD