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825 E. Multnomah
Portland, Oregon 97232
(503) 813-5000
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May 5, 2005
SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 W Washington
Boise, ID 83702-5983
RE:ID PAC-O5-
IPUC Staff Production Data Requests 50-
Please find enclosed an original and one copy ofPacifiCorp s Response to IPUC Staff
Production Data Requests 50-63. Provided on the enclosed CD are Attachments IPUC 56, 57
and 63 (A-B). Provided on the enclosed Confidential CD is Confidential Attachment IPUC 55.
If you have any questions, please call Barry Bell at (801) 220-4985.
Sincerely,
~~~~ If,
Bob Lively, Manager
Regulation
Enclosures
cc:Katie Iverson/lIP A
Jean'JeweU(3 copies)
James Fell/Stoel Rives
Service List
CERTIFICATE OF SERVICE
I hereby certify that I caused the foregoing document to be served on the following
named person(s) on the date indicated below by overnight mail to said person(s) a true copy
thereof, contained in a sealed envelope, addressed to said person(s) at their last known
addressees) indicated below.
:J+
? ;t lLv~ LC C/~ p0.)
Patricia A. Lopas
Regulatory Coordinator
Dated:/ 6 / tJ
JOHN STEWARTPACIFICORP
201 S. MAIN STREET. SUITE 2300
SALT LAKE CITY, UT 84140
JAMES M. V AN NOSTRAND
STOEL RIVES LLP
900 SW FIFTH AVE., SUITE 2600
PORTLAND, OR 97204
SCOTT WOODBURY
IDAHO PUBLIC UTILITIES COMMISION
472 W. WASHINGTON
BOISE, ID 83702-5983
KIRA PFISTERER
IDAHO PUBLIC UTILITIES COMMISION
472 W. WASHINGTON
BOISE, ID 83702-5983
RANDALL C. BUDGE
RACINE, OLSON, NYE
BUDGE&BAILEY, CHARTERED
201 E. CENTER
POCA TELLO, ID 83204
JAMES R. SMITH
MONSANTO COMPANY
HIGHWAY 34 NORTH
SODA SPRINGS, ID 83276
ERIC L. OLSEN
RACINE, OLSON, NYE
BUDGE&BAILEY, CHARTERED
201 E. CENTER
POCATELLO, ID 83204
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE, OH 44140
CONLEY E. WARD
GIVENS PURSLEY LLP
601 W. BANNOCK ST.
BOISE, ID 83702
DENNIS E. PESEAU
UTILITY RESOURCES, INC.
1500 LIBERTY ST. SE, SUITE 250
SALEM, OR 97302
R. SCOTT PASLEY
ASSISTANT GENERAL COUNSEL
J.R. SIMPLOTCOMPANY
999 MAIN ST.
BOISE, ID 83702
DA VID HAWK
DIRECTOR, ENREGY NATURAL RESOURCES
J. R. S IMPLOT CO MP ANY
999 MAIN ST.
BOISE, ID 83702
TIMOTHY 1. SHURTZ
411 S. MAIN
FIRTH, ID 83236
BRADY M. PURDY
A TTORNEY AT LAW
2019 N. 17TH STREET
BOISE, ID 83702
P AC-05-1/PacifiCorp
May 5 , 2005
IPUC Staff Production Request 50
IPUC Staff Production Request 50
In PacifiCorp s response to Staff Production Request No. 47, it is confirmed that
meters are typically left on between occupants unless at the next meter
reading/billing date there is no new occupant and usage has crossed the threshold
of 400 kWh. Pacifi Corp has stated that at that point, the meter is disconnected.
Who is billed for the electricity between the time that the meter is read for the
occupant who closed the account and the point at which the meter is disconnected
after crossing the 400 kWh threshold?
Response to IPUC Staff Production Request 50
Due to efficiency considerations related to cost and work force deployment, meters
are left on between occupants up to an established threshold of usage. PacifiCorp
makes every attempt to bill the customer(s) responsible for the usage. Please note
that the Company is revising Response No. 47 to reflect the fact that 1 000 kWh is
the current usage threshold used by the Company instead of 400 kWh.
(It's is undetermined at this time who will sponsor this response at hearing.
P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request
IPUC Staff Production Request
During 2004, how many meters fall in this category where the occupant has
closed the account but the meter is not disconnected?
Response to IPUC Staff Production Request 51
In 2004, in PacifiCorp s Idaho service territory, 7 079 agreements were closed by
the occupant and not disconnected.
(It's is undetermined at this time who will sponsor this response at hearing.
P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request 52
IPUC Staff Production Request 52
Chronologically, what is the process after the 400 kWh threshold is determined to
have been crossed? Does the meter reader turn the meter off? Is a separate order
generated and a different employee dispatched to turn off the meter?
Response to IPUC Staff Production Request 52
Please note that the current threshold is 1 000 kWh, as noted in the response to
IPUC Staff Production Request 50. When the 1 000 kWh usage threshold
described above is reached, a separate using order is generated. At that point the
order is put in queue to be scheduled for our employee to make a disconnect visit.
The order will remain open for 20 days to allow the disconnect visit to take place.
If a customer signs up in the interim, the order is voided.
(It's is undetermined at this time who will sponsor this response at hearing.
P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request 53
IPUC Staff Production Request 53
How is unbilled revenue booked?
Response to IPUC Staff Production Request 53
Unbilled revenues are calculated by removing from the system input the amount
of energy that will be included in bills during the specific calendar month. The
amount that will not be billed is then distributed to the different states and classes
using the latest numbers of customers and usage information and priced at current
tariff levels. This is then booked into the revenue accounts by class and state.
Unbilled revenue is booked to account 173 Accrued Utility Revenue and
corresponding income accounts 301XXX based on customer class.
301109 - Unbilled Revenue - Residential
301209 - Unbilled Revenue - Commercial
301309 - Unbilled Revenue - Industrial
301459 - Unbilled Revenue - Irrigation/Farm
301609 - Unbilled Revenue - Public St/Hwy Lighting
301709 - Unbilled Revenue - Other Sales to Public Authority
(Stan K. Watters will sponsor this response at hearing.
P AC-05-1/PacifiCorp
May 5 , 2005
IPUC Staff Production Request 54
IPUC Staff Production Request 54
During 2004, how many meters were disconnected after crossing the 400 kWh
threshold?
Response to IPUC Staff Production Request 54
Please note that the current threshold is 1 000 kWh, as noted in the response to
IPUC Staff Production Request 50. During 2004, in PacifiCorp s Idaho service
territory, 611 meters were disconnected where usage was above the established
000 kWh threshold.
(I t' s is undetermined at this time who will sponsor this response at hearing.
P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request 55
IPUC Staff Production Request 55
Please provide a current valuation of the three ancillary services that Monsanto
provides to PacifiCorp. Show them individually and provide associated
workpapers.
Response to IPUC Staff Production Request 55
Please see Confidential Attachment IPUC 55 , on the enclosed CD, for the current
valuation of the three ancillary services provided by Monsanto to PacifiCorp.
This data is confidential and is provided subject to the terms and conditions of the
protective agreement in this proceeding. While the data request was not specific
regarding term, the aforementioned attachment assumes a starting date of January
1 st, 2007 and an ending date of December 31 st, 2011 , along with a forward price
curve date of 4/25/05. As can be seen in this attachment, the value of non-spin
reserves for this term, with 95 MWs, is $1.93/KW-mo, the value of 500 hours of
curtailment for this term, with 67 MWs, is $3.26/KW-mo, and the value of system
integrity for 1 hour per month for this term, with 172 MWs, is $.25/KW-mo.
(Stan K. Watters will sponsor this response at hearing.
IDAHO
A C- O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
CONFIDENTIAL ATTACHMENT
IPUC
CONFIDENTIAL (LEVEL YELLOW)
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request 56
IPUC Staff Production Request 56
In Case No. UPL-01-16 the Commission established Monsanto contract rates at
what it deemed to be full cost of service. In that case Monsanto s full cost of
service as an uninterrupted customer was calculated to be $43 971 090 based on a
1999 test year. In the current case, the Company calculates Monsanto s full cost
of service to be $53 885 831. A number of things have changed that have led to
the cost of service difference. They are:a) Test year accounting data was 1999 and now is 2004.b) Jurisdictional and class allocators were based on 1999 data and
now are based on 2004 data.
Jurisdictional allocation methodology was "rolled-" and now is
revised protocol"
Please provide a series of jurisdictional allocation and cost of service model runs
that capture the differences caused by each of these factors individually. If there
are other factors that the Company believes to be significant in defining the
change in cost of service, model runs that establish their value should also be
provided. The model runs that capture the jurisdictional allocation methodology
difference should be run last.
Response to IPUC Staff Production Request 56
The Company concurs with the statement that "(i)n Case No. UPL-01-16 the
Commission established Monsanto contract rates at what it deemed to be full cost
of service." On page 8 of that Order, the Commission stated that the rates and
charges approved therein "reasonably reflect the Company s cost of service to
Monsanto going forward." The Company does not agree that "(i)n the current
case, the Company calculates Monsanto s full cost of service to be $53 885 831."
The cost of service study used by the Company in its direct testimony in this
proceeding to allocate the requested rate increase to customer classes gives full
effect to Final Order No. 29157, and any assumed departure from the findings in
that Order would be pure speculation. The cost of service for this customer, for
the duration of the contract for this customer - through December 31 , 2006 - has
been determined by Final Order No. 29157, and that finding is binding for
purposes of the cost of service in this proceeding. The Company, by operation of
law, cannot presume that the cost of service for Monsanto is anything other than
as determined by the Commission in Final Order No. 29157.
Therefore the response below is provided for informational purposes only. To the
extent the Company identifies any "other factors that the Company believes to be
significant in defining the change in cost of service" in response to this data
request, it is for discussion purposes only, as there can be no "change in cost of
service" as a matter of law.
P AC-05-I/PacifiCorp
May 5 , 2005
IPUC Staff Production Request 56
Please see Attachment IPUC 56, on the enclosed CD, which contains the
following:
1999 - Rolled-In with Special Contracts Situs (Basis for existing
Monsanto contract)
Idaho Results of Operations Report Tab
Cost of Service Summary Tables Earned and Target Return
Cost of Service Class Summary
Cost of Service Detail
FY 2004 - Rolled-In with Special Contracts Situs
Idaho Results of Operations Report Tab
Cost of Service Summary Tables Earned and Target Return
Cost of Service Class Summary
Cost of Service Detail
FY 2004 - MSP Revised Protocol (Current filing)
Idaho Results of Operations Report Tab
Cost of Service Summary Tables Earned and Target Return
Cost of Service Class Summary
Cost of Service Detail
The effects of the changes identified in (a) and (b) have been combined. It is
neither reasonable nor appropriate to allocate total Company costs from one test
period with jurisdictional and class loads from another test period because
changes in loads is one of the causes of increased costs. Therefore, we have not
computed these two effects separately. Their combined effect is determined by
comparing the "1999" tabs with the "FY 04 (RI)" tabs. The effect of the changes
identified in (c) is determined by comparing the "FY 04 (RI)" tabs with the
FY 04 (MSP)" tabs.
The primary factors contributing to the change in costs of service that could be
allocable to Monsanto are increases in Net Power Costs and other Generation and
Transmission O&M Expenses as well as the impact of the Embedded Cost
Differential allocation adjustment. As shown in the table below, these three items
account for over $10 million, or nearly $7.00 per MWh (7 mills per kWh), of the
increase in cost of service that could be allocable to Monsanto.
P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request 56
PacifiCorp
Cost Of Service
State of Idaho
12 Months Endin March 2004 12 Months Ending Dec 31, 1999 Diff 2004 - 1999
Idaho Idaho Idaho
DESCRIP Jurisdiction Jurisdiction Jurisdiction
Nonnalized Monsanto Nonnalized Monsanto Nonnalized Inc Monsanto Inc
Rolled-ln Revised Protocol
Contracts situs Contracts situs
Net Power Costs 770,277 18,460,525 31,608,954 13,739,674 14,161.323 45%720,851 34%
Embedded Cost Differential 354,324 705 267 354,324 705,267
Other G& T O&M 26,328,724 10,306,850 15,212,601 161,033 11,116,123 73%145.817 67%
$/ MWH
12 Months Endin March 2004 12 Months Ending Dec 31, 1999 Diff 2004 . 1999
MWH 383,000 439,284 137,496 400,846 245,504 438
Net Power Costs $13.$12.$10.$9.$3.34%$3.31%
Embedded Cost Differential $1.$1.18 $0.$0.$1.$1.
OtherG&TO&M $7.$7.$4.$4.$2.61%$2.63%
(David L. Taylor will sponsor this response at hearing.
IDAHO
O5-
GENERAL RA TE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC
ON THE ENCLOSED CD
AC- E-05-/PacifiCorp
May 5, 2005
IPUC Staff Production Request 57
IPUC Staff Production Request 57
Please provide the cost of meter reading and billing for each of the rate schedules.
Response to IPUC Staff Production Request 57
The requested information is provided as Attachment IPUC 57 on the enclosed
CD.
(David L. Taylor will sponsor this response at hearing.
IDAHO
A C- O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
May 5, 2005
IPU C Staff Prod~ction Request 58
IPUC Staff Production Request 58
Please provide any analysis justifying the proposed increase in the monthly
minimum bill Customer Service Charge for each of the schedules.
Response to IPUC Staff Production Request 58
Schedule 1: The proposed increase in the minimum charge from $9.57 to $11.
per month corresponds to the underlying changes in the proposed energy charges
as shown in Attachment IPUC 58.
For the other rate schedules: The Company proposed changes to the Customer
Service Charges in order to simplify rate administration by rounding up the
customer service charges to whole dollars.
(William R. Griffith will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
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P AC-05-1/PacifiCorp
May 5, 2005
IPUC Staff Production Request 59
IPUC Staff Production Request 59
Please provide the analysis that supports the seasonal price differential
Schedule No.1. Include justification for the specific months included in each
season and the specific rates as proposed.
Response to IPUC Staff Production Request 59
As stated in Mr. Griffith's direct testimony, Exhibit No. 25, page 6, line 9 "the
company proposed to implement the price increase on a uniform percentage basis
while keeping the current ratios between summer/winter energy charges." The
seasonal price differential ratio used by PacifiCorp in this filing has been in place
since the approval of Tariff No. 13 effective March 21 1978. Consequently, no
analysis was prepared for this case.
(William R. Griffith will sponsor this response at hearing.
P Ac-05-1/Pacificorp
May 5 , 2005
IPUC Staff Production Request 60
IPUC Staff Production Request 60
Please provide an analysis that supports the time of use rate differentials on
Schedule 36. Include justification for the time periods chosen and the specific
rates proposed.
Response to IPUC Staff Production Request 60
As stated in Mr. Griffith's direct testimony, Exhibit No. 25, page 6, line 9 "the
company proposed to implement the price increase on a uniform percentage basis
while keeping the current ratios between summer/winter energy charges and on-
peak/off-peak energy charges for optional time of day Schedule 36." The time of
use rate differential ratio has been applicable since the approval of Tariff No. 21
effective September 13 , 1984. The time periods for on-peak/off-peak have been
applicable since the approval of Tariff No. 17 effective May 27, 1981.
Consequently, no analysis was prepared for this case.
(William R. Griffith will sponsor this response at hearing.
P AC-05-1/PacifiCorp
May 5 , 2005
IPUC Staff Production Request 61
IPUC Staff Production Request 61
Please provide the analysis that supports the seasonal price differential in
Schedule Nos. 6, 6A, 8, 9, 10, 23 and 23A. Include justification for the specific
months included in each season and the specific rates as proposed.
Response to IPUC Staff Production Request 61
Schedule 6, 6A, 8 and 9: As stated in Mr. Griffith's direct testimony, page 7, line
, "
the company proposes to implement the price change uniformly to both
energy and demand charges, while keeping the current seasonal ratios between
summer and winter demand charges." The current seasonal price differential ratio
has been applicable since the approval of Tariff No. 16 effective April 1 , 1980.
Consequently, no analyses regarding Schedules 6, 6A, 8 and 9 were prepared for
this case.
Schedule 23 , 23A: As stated in Mr. Griffith's direct testimony, page 7, line 15
the company proposes to implement the price change uniformly to energy
charges, while keeping the current seasonal ratios between summer and winter
energy charges." The current seasonal ratio is calculated after combining the
present RMA rates with the present base energy rates. The current seasonal price
differential ratio has been applicable since the approval of Tariff No. 16 effective
April 1 , 1980. Consequently, no analyses regarding Schedules 23 and 23A were
prepared for this case.
Schedule 10: As stated in Mr. Griffith's direct testimony, page 8, lines 11 through
, "
the company also proposes to implement the price change for schedule lOon
a uniform percentage basis to both demand and energy charges in order to
maintain current relationships between the energy blocks and the current ratio
on-season to off-season average revenues." The present time period for the
irrigation season has been applicable since the approval of Tariff No. 17 effective
May 27, 1981. The current structure of the seasonal demand and energy charges
has been applicable since June 8, 2002, pursuant to IPUC Order No. 29034
regarding Case No. PAC-02-1. Consequently, no analysis regarding Schedule
10 was prepared for this case.
(William R. Griffith will sponsor this response at hearing.
P AC-05-1/Pacificorp
May 5, 2005
IPUC Staff Production Request 62
IPUC Staff Production Request 62
Please provide an analysis that supports the time of use rate differentials on
Schedule Nos. 35 and 35A. Include justification for the time periods chosen and
the specific rates proposed.
Response to IPUC Staff Production Request 62
Schedule 35, 35A: The Company proposes to implement price changes for
schedules 35 and 35A uniformly to both energy and on-peak demand charges
while keeping the current on-peak and off-peak time periods. The current on-
peak and off-peak time period has been applicable since the approval of Tariff
No. 23 effective April 10, 1986. Consequently, no analyses regarding Schedules
35 and 35A were prepared for this case.
(William R. Griffith will sponsor this response at hearing.
P Ac-05-1/PacifiCorp
May 5, 2005
IPUc Staff Production Request 63
IPUC Staff Production Request
Please provide a bill frequency analysis for Service Schedules 1 and 36 for each
month with incremental blocks of 100 kWh for usage from 0 to 1200 kWh; then
1200 to 1500 kWh; 1500 to 2000 kWh; 2000 to 2500 kWh; 2500 to 3000 kWh;
3000 to 4000 kWh; 4000 to 5000 kWh and over 5000 kWh. Include both
numbers of bills in that block and energy use the block. Please provide this in
Excel 2000 format.
Response to IPUC Staff Production Request 63
Bill frequency analyses for Service Schedules 1 and 36 with the requested
incremental blocks have been included as Attachment IPUC 63 A (Schedule 1)
and Attachment IPUC 63 B (Schedule 36) on the enclosed CD. The analyses
include both number of bills and energy used in each block. The detail data used
in preparing to the above attachments was previously provided as Attachment
lIP A 10 1 Supplemental.
(William R. Griffith will sponsor this response at hearing.
IDAHO
P AC-O5-
GENERAL RATE CASE
ACIFICORP
IPUC STAFF PRODUCTION
DATA REQUEST
ATTACHMENT IPUC 63 (A-
ON THE ENCLOSED CD