20050412IIPA 4th data request to PacifiCorp.pdf

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 FOURTH
) DATA REQUEST TO P ACIFICORP
Please answer the following with respect to infonnation:
Supplemental request regarding lIP A data Request 2-
The response indicates that census data is provided for all Schedule 9 customers over
MW. Are all Schedule 9 customers taking service at the sub-transmission level in this
category?
The response to lIP A 2-E indicates that the sample data is adjusted, up or down, in order
to tie to the Energy report in the Operating Statements. Has this data been provided
elsewhere (lIP A 4)? If it has not, please provide copies of this data and an example of its
app Ii cati on?
It is assumed that the adjustment referenced in lIP A 2-E related to the energy reports is
one where the adjustment is done on the same percentage basis for each hour of a given
month. Is this correct?
The attachment lIP A 2-E is not clear. Is this a similar adjustment to that of the Operating
Statements discussed above, i., where the adjustment is done on the same percentage
basis for each hour of a given month? What were the percentage adjustments that were
used?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 1
Supplemental request regardin~ lIP A data Request 3
In this response it is stated that "the treatment of losses are different between the two
calculations.. .. It appears that losses are used in Ex. 24, but there is no need for losses
to be addressed in Ex. 9. Is there any more significance than this to the statement
regarding the different treatment of losses?
The response to lIP A 3 did not seem to give a detailed explanation regarding the
difference in the demand of energy values between Exhibits 9 and 24, other than to state
that these values were developed differently. If one looks at the month of May 2003 it
can be seen that the cost of service study puts the coincident peak at 453 MW while the
IJA puts it at 532 MW. Because Monsanto is directly metered, one can assume that this
infonnation is as fairly accurate. The Monsanto load at the time of this peak was 150
MW. Removing this load (the same could be done for the other special contract customer
and large Schedule 9 customers) and the net result would be that the peak under the cost
of service study would be 283 MW while under the IJA it would be 362 MW-
effectively the peak load assignment to the jurisdiction is 28% greater than what can be
calculated under the data available from the load research data. This discrepancy is very
large (but not the largest) and calls into question both the quality of the load research data
as well as the jurisdictional assignment of costs. More discussion/review is requested
regarding these large differences in data.
Supplemental request re~arding lIP A data Request 4
The data included in Attachment lIP A 4-1 contains a number of data points for sample
customers where the usage is continually recorded at ". This could be due to actual
consumption or simply reflect that data was not available. Do any of the "0" entries in
this spreadsheet reflect meter problems or something other than "0" consumption by the
sample customer?
The data included in Attachment lIP A 4-1 contains a number of data points for sample
customers where the usage is continually recorded at ". This could be due to actual
consumption or simply reflect that data was not available. Do any of the "0" entries in
this spreadsheet reflect meter problems or something other than "0" consumption by the
sample customer?
According to the response to lIP A 4-, the attachment lIP A 4-5 contains infonnation
regarding two adjustments or calibrations. Looking at this attachment, it appears that the
values in attachment lIP A 4-5 are simply final numbers and in fact the reference should
have been attachment lIP A 4-6. Is this correct, and if so, what is the purpose of
attachment lIP A 4-5? If this is not correct, please point out where the calibrations on in
attachment lIP A 4-
Attachment lIP A 4-6 contains two tabs; one labeled "CaIAdj" and the other labeled
PriceAdj". Please explain the significance and source of the data for each of these tabs.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 2
Please explain how these values fit into the overall development of the load research data.
As part of attachment lIP A 4-5 there was established energy data by rate schedule by
month. For Schedule 1 in April, the energy level in attachment lIP A 4-5 was listed as
614 MWH. How does this value relate to the values in attachment lIP A 4-
Attachment lIP A 4-6 has information listed for Schedule 10 under the "PriceAdj" tab.
Why isn t there data under the "CaIAdj" tab?
Please provide an example of the calculation of the August 13 2003 peak values for
Schedules 1 , 36, and 10 found on Exhibit 24 tab 5 page 7 , based upon the information
provided in attachments 4-1 through 4-
Supplemental request regarding lIP A data Request 6
Can it be assumed that the hourly border loads listed here are the same or at least
calculated the same as the jurisdictional load listed on Exhibit 9, Tab 10, page 7 (with
Monsanto curtailments added)?
Can it be assumed that the hourly class loads listed are the results of census or load
research data after all adjustments and calibrations?
As would be expected, there is not a perfect match between loads plus losses and border
load data. A comparison of the data suggests that these mismatches are not random, but
in fact, there are patterns or times when a mismatch is more likely in one direction than in
another. Does the Company have any information or beliefs as to what may cause these
patterns to occur?
Supplemental request regarding lIP A data Request 7
The response refers to attachment lIP A 4-6 tab 1 , which does not exist.
Many of the adjustment in attachment lIP A 4-6 are quite large. Does the Company agree
that some of these adjustments are excessive? Is there any consideration regarding these
adjustments as to whether the load research data is providing accurate data? Is there any
reason why these adjustments are so large?
Supplemental request re~ardin~ lIP A data Request 8
The thrust of this question was to see if there are any reports that are routinely compiled
regarding the load research data that are a part of the ongoing effort.
Supplemental request regardin~ lIP A data Request 10
I was not looking for bill frequency data prepared for the rate case, but bill frequency
data that is generally available from the Company records. For example, the Schedule 10
has different rates for different usage levels for different times of the year. Doesn t the
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO P ACIFICORP Page 3
Company have data that lists the amount of energy consumed by customer each month
such that one can create such a bill frequency distribution?
Likewise bill frequency data for Schedules 1 and 36 would be helpful by month.
Why is there only a temperature adjustment for Schedule 1 customers, but not Schedule
36? (Exhibit 29, page 1)
Supplemental request re~ardin~ lIP A data Request 16
The data provided in attachment lIP A 16-1 generally decreases with time. How were
these values derived? What measurements exist to support this? What workpapers exist?
Supplemental request re~arding lIP A data Request 20
It appears from the load research data infonnation contained in attachments lIP A 2
through lIP A 6 that the load data is adjusted on the basis of comparisons of monthly
usages, i., each hour of the month is adjustment by the same factor. The response to
lIP A 20 suggests that there is a different weather-normalization factor/adjustment for
each hour. Is this correct? How/where do these individual hourly adjustments fit into the
development of the hourly load data that is found in attachment lIP A 6 or on Exhibit 24
Tab 5 , page 7?
Supplemental request re~arding lIP A data Request
For the sake of comparison, Exhibit 9, Tab 5, page 4 of 13 lists the Net Power Cost in the
Company s filing as $639 936 000 and the results of attachment lIP A 21 place the
amount at $611 262 000. Under this request there are no interruptions or curtailments on
the system, but the Monsanto load does not exist at all. Compared to the Company
filing, this means that the company could make all of its customers finn, and by not
supplying Monsanto, it would reduce its net power costs by $28 674 000. Does the
Company agree with this interpretation?
Supplemental request regarding lIP A data Request 22
For the sake of comparison, Exhibit 9, Tab 5, page 4 of 13 lists the Net Power Cost in the
Company s filing as $639 936 000 and the results of attachment lIP A 22 place the
amount at $663 243 000. Under this request, all interruptible/curtailable loads on the
system are being served. This suggests that this is the maximum cost to the Company if
there are not interruptions or curtailments is $23 307 000 greater than the status quo of
$639 936 000. Does the Company agree with this interpretation?
Supplemental request regarding lIP A data Request
For the sake of comparison, Exhibit 9, Tab 5, page 4 of 13 lists the Net Power Cost in the
Company s filing as $639 936 000 and the results of attachment lIP A 23 place the
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 4
amount at $640 400 000. Under this request, all interruptible/curtail able loads on the
system are being served with the exception that portion of the Irrigation load (not the
entire Irrigation load), which can be curtailed. This suggests that the difference
($22 843 000) between this response and attachment lIP A 22 ($663 243 000) is solely
attributed to the irrigation load control program. This number seems too high. Is there
something wrong or missing here?
Supplemental request re~ardin~ lIP A data Request 24
Exhibit 9, Tab 1 , page 1 places the Idaho Jurisdictional rate of return at 6.785%.
Attachment lIP A 24-2 places the Monsanto rate of return at 2.657% or well below the
jurisdictional average. Attachment lIP A 24-3 places the remainder of the Idaho rate of
return at 7.463 %. This information suggests, that according to the allocation methods
used by the Company, well over half of the increase being requested from the non-
Monsanto customers is associated with a shortfall that the Company has calculated for
Monsanto. Is this correct?
Monsanto s rates were set approximately one year before the filing in this case.
Monsanto is also being priced at its firm cost of service with a credit for interruptible
power being flowed through the purchase power costs. What has changed in the last year
or so that would cause the Monsanto s rate of return to drop so much?
Supplemental request re~arding lIP A data Request 26
This response indicates that there is less than a 1 % difference in this annual 12-CP data.
Looking at April 2003 , (no Monsanto interruptions) Exhibit 24, Tab 5, page 6 shows an
Idaho peak of 407.0 MW. Exhibit 9, Tab 10, page 5 lists the Idaho peak at 375.3 MW.
This is a difference of 8.4%. Assuming that these values are comparable, to what does
the Company attribute such a large discrepancy?
Supplemental request regarding lIP A data Request 27-
I have not looked at specific data, but it is my recollection that there were more irrigators
participating in the irrigation load management program in 2004 than in 2003. I also
thought that the company was anticipating more participation in 2005 than in 2004. Why
does the response state that: "This level of curtailment is the same as expected to be
incurred in 2005"
When will data be available regarding how many irrigators have signed up for the load
control program and how much will be curtailed by day of the week?
Supplemental request regarding lIP A data Request 32
Please supply a copy of tariffs T-23 and T-24 that support the calculation on attachment
lIP A 32.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 5
If not provided above, please supply a copy of tariffs T-23 and T-24 for Rate Schedules
, 36, 10, and 23
Supplemental request re~ardin~ lIP A data Request 39
Electronic copies of these studies were not provided with my copy of the Company
filing.
Supplemental request re~ardin~ lIP A data Request 44
Actual data by substation for each of the 5-year study period is what was sought. It is
desired to get the name of the substation (coordinated with lIP A 45) that peaked during
each month of this 5-year period. Presumably, this was the base data upon which this
analysis was based.
From the data presented, it would appear that there were 100 substations in 1995 and only
83 in 1999. Please clarify what this data represents.
Supplemental request regarding lIP A data Request
What is meant by "distribution figures for power plant substations ? Do these serve any
different function than a regular distribution substation?
, Were these power plant substations included in the study addressed in lIP A 44?
Please indicate which of the listed substations were or were not included in the analysis
addressed in lIP A 46.
Supplemental request regarding lIP A data Request 52
Further explanation is requested with respect to this request/response. It appears from the
response that the term "net system balancing activity" used here is referring to something
different than the system balancing transactions that are not netted out in the Power Cost
Model. I would like to get these two different things (assuming they are different)
clarified.
Respectfully submitted this ay of April, 2005.
ERIC L. OLSEN
Attorneys for the Idaho Irrigation
Pumpers Association, Inc.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this ay of April, 2005, I served a true
correct and complete copy of the Idaho Irrigation Pumpers Association, Inc.s Fourth
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: lean. lewell~puc.idaho.gov
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
P acifi Corp
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: john.stewart2~pacificorp.com
S. Mail
James M. Van Nostrand
Stoel Rives LLP
900 SW Fifth Avenue, Suite 2600
Portland, OR 97204
E-mail: jffell~stoe1.com
imvannostrand~stoe 1. con1
S. Mail
Lisa Nordstrom
PacifiCorp Office of the General Counsel
825 NE Multnomah Street, Suite 1800
Portland, OR 97232
E-mail: lisa.nordstrom~pacificorp.coln
S. Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ID 83276
E-mail: ji1n.r.smith~monsanto.com
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 7
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~sconsultbai. 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
c/o Lynn T omina
O. Box 2624
Boise, ID 83701-2624 S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOURTH DATA REQUEST TO PACIFICORP Page 8