20050314IIPA 2nd Request to PacifiCorp.pdf

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L.J.
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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UTILITIES coH~ifISSION
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 STATE OF IDAHO
) CASE NO. PAC-05-
) IDAHO IRRIGATION PUMPERS
) ASSOCIATION, INC.~ SECOND
) DATA REQUEST TO P ACIFICORP
Please answer the following with respect to information:
41. On page 7, line 23 of Mr. Stewart's testimony it is stated that the BP A credit for
2007-2011 will be $8.6 - $21.3 million. Please answer the following with respect to
this proj ection:
a. Given the Net Power Cost calculation in the Company s filing, under what
circumstances will the BP A Credit be at the low end of this range and under what
circumstances will it be a the high end of this range?
b. Given the Company s present forecast of market prices for 2007, would the BP A
Credit be at the upper or lower end of this range?
c. At the low end of this range, what would the credit be for the average irrigation
customer?
d. At the upper end of this range, what would the credit be for the average irrigation
customer?
42. In the Company s Net Power Cost results (Exhibit 9, Tab 5) there are listed Short
Term Firm Sales and Purchases as well as System Balancing Sales and Purchases for
a number of "locations" such as COB, Colorado , DSW, East Main, Mid Columbia
SP15, West Main, Wyoming, and "Emergency . Please answer the following:
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC:S
SECOND DATA REQUEST TO P ACIFICORP
a. For each of the above-mentioned locations, please supply on a total hourly basis
from 1 :00 a.m. on January 1 , 2000 through the most recent data available, the
actual megawatthours and dollar value of all Short-Term Firm Sales.
b. For each of the above-mentioned locations, please supply on a total hourly basis
from 1 :00 a.m. on January 1 , 2000 through the most recent data available, the
actual megawatthours and dollar value of all Short-Term Firm Purchases.
c. For each of the above-mentioned locations, please supply on a total hourly basis
from 1 :00 a.m. on January 1 2000 through the most recent data available, the
actual megawatthours and dollar value of all Non-Firm Sales.
d. For each of the above-mentioned locations, please supply on a total hourly basis
from 1 :00 a.m. on January 1 , 2000 through the most recent data available, the
actual megawatthours and dollar value of all Non-Firm Purchases.
e. For each of the above-mentioned locations, please supply on a total hourly basis
from 1 :00 a.m. on January 1 , 2000 through the most recent data available, the
actual megawatthours and dollar value of all System Balancing Sales.
f. For each of the above-mentioned locations, please supply on a total hourly basis
from 1 :00 a.m. on January 1 , 2000 through the most recent data available, the
actual megawatthours and dollar value of all System Balancing Purchases.
g.
Please describe how System Balancing transactions in the Net Power Cost model
are similar to as well as different from actual Non-Firm transactions.
h. Please describe how Short-Term Firm transactions in the Net Power Cost model
are similar to as well as different from actual Short-Term Firm transactions.
i. What is meant by "Emergency Purchases" in the Power Cost Model and what
actual purchase are simulated by these purchases? Please provide specific
examples as well as quantify the actual purchases that are simulated.
j. What is meant by "Trapped Energy" in the Power Cost Model and what actual
sales are simulated by these sales? Please provide specific examples as well
quantify the actual sales that are simulated.
43. On February 28, 2005 in Case Number P AC-02-, the Company filed its "Revised
Protocol Interjurisdictional Cost Allocation Methodology . With respect to Appendix
D of that filing, please provide the following:
a. An electronic copy of Tables 1 and 2;
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC:S
SECOND DATA REQUEST TO P ACIFICORP
b. Please indicate under which (in any) of these two tables the Monsanto load falls
and why; and
c. Please indicate under which (in any) of these two tables the Idaho Irrigation Load
Control Program falls and why.
44. Exhibit 24, Tab5, Page 11 lists substation peak weighting factors. Please provide in
electronic format all data that supports the development of these weighting factors, as
well as similar data going back two more years. It is expected that monthly peak data
by substation will be provided.
45. Please provide for each substation listed in the above interrogatory, by FERC
account, the most recent year s plant-in-service figures.
46. With respect to the Company s load research data requested in Irrigator
Interrogatory 4, please indicate which irrigation sample customers (identify by
customer identification number) were participating in the irrigation load control
program and which days each of them participated.
47. Please indicate how the data for the irrigation customers in the Company s load
research program that were also included in the load control program were expanded
to reflect the entire population of irrigation customers.
48. On page 8 of Mr. Stewart's testimony is a discussion of the results of the Irrigation
Load Control Credit Rider for 2003 and 2004. For each of these years, please provide
by day of the week and hour of the day, the number of irrigation customers
participating in the program, the number of individually metered sites, and the
amount of load being curtailed.
Respectfully submitted this / rP'11ay of March, 2005.
RACINE, OLSON, NYE, BUDGE &BAILEY TERED
ERIC L. OLSEN
Attorneys for the Idaho Irrigation
Pumpers Association, Inc.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC:S
SECOND DATA REQUEST TO P ACIFICORP
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 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: ;ean. iewell~puc.idaho.gov
E-mail
s. Mail
Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 800
Portland, OR 97232
E-mail: datarequest~pacificorp.com
E-mail
John Stewart
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
E-mail: john.stewart2~pacificorp.com
S. Mail
James M. Van Nostrand
S toel Rives LLP
900 SW Fifth Avenue, Suite 2600
Portland, OR 97204
E-mail: iffell~stoel.com
im vann 0 strand~stoel. com
S. Mail
Lisa Nordstrom
PacifiCorp Office of the General Counsel
825 NE Multnomah Street, Suite 1800
Portland, OR 97232
E- mail: lisa. nordstrom~paci ficorp. com
S. Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ID 83276
E-mail: iim.smith~monsanto.com
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC:S
SECOND DATA REQUEST TO P ACIFICORP
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~sconsul tbai. com
s. Mail
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony~yankel.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, I
c/o Lynn T ominaga
O. Box 2624
Boise, ID 83701-2624
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC:S
SECOND DATA REQUEST TO P ACIFICORP