20050513IIPA 5th data request to PAC.pdf

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co_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 STATE OF IDAHO
) CASE NO. PAC-05-
) IDAHO IRRIGATION PUMPERS
) ASSOCIATION, INC.S FIFTH
) DATA REQUEST TO P ACIFICORP
Please answer the following with respect to infonnation:
55. In response to Irrigation request 16-e in Case No. UPL-90-, the Company
provided a list for each distribution substation of the month in which the substation
peak demand occurred, as well as the level of the peak demand for each of five
years. Please provide similar infonnation by substation for any of the substations
for which the company has data available for the last 6 years.
56. The response to IIP A Request 16 listed the amount of irrigation interruptions for
each day of the summers of 2003 and 2004. Please provide similar infonnation
regarding the anticipated curtailments for the summer of 2005.
57. The response to IIP A Request 27-C indicates that the level of curtailment expected
to occur in 2005 is the same as found in the response to IIP A request 2- E, which is
the 2003 report on the irrigation curtailment. Does this mean that the 2003 levels of
irrigation curtailment were used as the basis for the data in this filing? What, if any
adjustments were made to this data?
58. Page 8 of Mr. Stewart's testimony talks of the irrigation curtailment program
resulting in excess of 20 megawatts per day of curtailment in 2003 and in excess of
30 megawatts per day in 2004. What level of curtailment was used in this case as a
foundation for the interjurisdictional allocation process? Please supply detailed
support to demonstrate how this level was incorporated in the filing.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 1.
59. Page 8 of Mr. Stewart's testimony talks of the irrigation curtailment program
resulting in $277 584 of credit in 2003 and in $410 325 of credit in 2004. What
level of credit was used in this case as a foundation for the jurisdictional revenue
requirement? Please supply detailed support to demonstrate how this level was
incorporated in the filing.
60. Page 8 of Mr. Stewart's testimony talks of the irrigation curtailment program
resulting in excess of 20 megawatts per day of curtailment in 2003 and in excess of
30 megawatts per day in 2004. What level of curtailment was used in this case as a
foundation for the class cost of service study? Please supply detailed support
demonstrate how this level was incorporated in the filing.
61. Page 8 ofMr. Stewart's testimony talks of the irrigation curtailment program
resulting in $277 584 of credit in 2003 and in $410 325 of credit in 2004. What
level of credit is included in the test year and where can it be found in the filing?
62. InIIP A requests 21 , 22, and 23 computer runs were requested that were similar to
Exhibit 9 Tab 5 of the filing. On Exhibit 9 Tab 5 page 5 of the filing there is a
category listed as "Adjustments to Load" but there are no entries. In a similar area
in the responses to IIP A 21 , 22, and 23 there is a total adjustment under the
Monsanto Curtailment" of -177 MWH. What is the basis for this figure and
why was it not listed in the original filing, but listed in each of the responses? What
is the significance of the negative sign and why does it addto "Net System Load"
63. The response to IIP A21 indicates that by comparison to the Net Power Costs in the
filing, "Net System Load" decreased by 1 289 303 MWH and Net Power Costs
decreased by $28 674 000. It is also the Irrigator s understanding that this scenario
simply represents a situation where the Monsanto interruptible load does not exist.
If the Company disagrees with any of these statements, please provide a detailed
explanation regarding what is wrong with these assumptions.
64. The response to IIP A 22 indicates that by comparison to the Net Power Costs in the
filing, "Net System Load" increased by 112 796 MWH and Net Power Costs
increased by $23 306 000. It is also the Irrigator s understanding that this scenario
simply represents a situation where aU interruptible and curtailable load does not
exist, i., is made finn. If the Company disagrees with any of these statements
please provide a detailed explanation regarding what is wrong with these
assumptions.
65. The response to IIP A 23 indicates that by comparison to the Net Power Costs in
IIP A 22 above
, "
Net System Load" decreased by 680 220 MWH and Net Power
Cost decreased by $22 842 000. It is also the Irrigator s understanding that this
scenario simply represents a situation where aU interruptible and curtailable load
does not exist, i., is made finn and the irrigation load in Idaho was removed.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 2
the Company disagrees with any of these statements, please provide a detailed
explanation regarding what is wrong with these assumptions.
66. 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 customers in the filing, except excluding the entire Idaho Irrigation
load.
67. 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 customers in the filing, except excluding 50% of the Idaho Irrigation
load.
68. 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 customers in the filing, except excluding 25% of the Idaho Irrigation
load.
69. The response to IIP A Request 2-C indicates that census data is provided for all
Schedule 9 customers over 1 MW. Are all Schedule 9 customers taking service at
the sub-transmission level in this category?
70. Regarding the response to IIP A Request 10, why is there only a temperature
adjustment for Schedule 1 customers, but not Schedule 36? (Exhibit 29, page 1)
71. Please supply all workpapers and assumptions that support the generally declining
values in the levels of Irrigation curtailment that occur through time as
demonstrated on the response to IIP A Request 16.
72. Please supply a copy of tariffs T-23 and T-24 for Rate Schedules 1 , 36, 10, and 23.
73. From the data presented in response to IIP A request 44, it would appear that there
were 100 substations in 1995 and only 83 in 1999. Please clarify what this data
represents and specifically why the number of substations appears to have
decreased.
74. Regarding the response to IIP A request 45, 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 IIP A 44?
75. Regarding the response to IIP A request 52, it appears from the response that the
tenn "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. Please clarify what the difference is between these two uses of the same
tenn.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO P ACIFICORP Page 3
76.Regarding the response to IIP A request 43, please provide an electronic version of a
run of the Company s jurisdictional allocation model assuming that the Idaho
Irrigation Load Control Program is treated in the same manner as Monsanto, i.
system treatment and not as a DSM program.
77. With respect to the above interrogatory, please provide a copy of a similar
electronic version assuming that the Irrigation customers in Idaho are curtailed 20
MW more per day than assumed in the above model.
78. Please provide an electronic copy of the same intetjurisdictional allocation model as
filed in this case, but assuming that the Idaho Irrigators are curtailed 20 MW more
per day than assumed in the Company s original filing.
79. Please provide an electronic copy of the Company s "as filed" class cost of service
study with the additional assumption that the Idaho Irrigations are curtailed 20 MW
more per day than assumed in the Company s original filing.
80.On page II-5 of the Quantec report entitled "Idaho 2003 Irrigation Load Control
Credit Rider Program Impact Evaluation" there are listed "Field Expenses" for 2003
and beyond.
a. Was essentially the entire amount of 2003 "Field Expenses" associated
with the installation of control devices?
b. Please provide a breakdown of what was included in the 2004 and beyond
figures, i., what portion of this expense was assumed to be associated
with the installation of equipment for new participants and what portion of
this expense was assumed to be related to on-going expenses associated
with existing participants.
81. In the Company s "Schedule 72 Idaho Irrigation Load Control Program 2004
Report" it is stated that the 2004 "Field Expenses" were $239 807. What portion of
these costs was associated with new participants to the program?
82. For each hour in 2003 and 2004 when the Idaho Irrigation load was curtailed, please
supply the price paid for the most expensive short-tenn finn purchase in the
Company s eastern control area as well as the quantity purchased at that price.
83.Please provide a description of the methodology used the calculate the 2005 Load
Control Service Credit ("LCSC") rate for each of the three load control options, all
supporting calculations, assumptions and related analysis used in the development
of these values. Also please provide a description of the methodology causing the
differences in the credit amount for the different curtailment blocks, e., the 6
hours of curtailment two days a week versus the 3 hours of curtailment two or four
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 4
days a week. Also, please provide an electronic copy of any model used to calculate
the 2005 LCSC rate.
84. Please provide the number of participant sites and participant customers for the
2005 LCSC, the total number of eligible cites and customers for the 2005 irrigation
season, and the forecast curtailed load resulting therefrom.
85. Please provide a description of all methodologies available to calculate the benefits
of the LCSC program to the Company, all supporting calculations, assumptions and
related analysis. For the methodology which the Company principally uses to
measure the benefits of the LCSC program, please describe why the Company
believes it is the most appropriate method.
86. In the Company s 2004 IRP please explain how the LCSC program interruptible
load and the Monsanto interruptible load were treated (a) in detennining the
Company s resource base, (b) in detennining the gap between resources and the
forecast demand for the Company s eastern control area, and (c) in detennining
which higher cost resources could be deferred in the various resource portfolios
considered under the 2004 IRP.
87. In the Company s 2004 IRP it calls for the procurement of additional Class 1 DSM
programs, please provide any plans or methodology, all supporting calculations
assumptions, and related analysis of how the Company plans to expand the LCSC
program and/or the Monsanto interruptible load for these purposes.
88. Has the Company done any study or analysis of what the forecast participation and
the resulting curtailed demand would be at different levels of the LCSC? If so
please provide the results of any study, analysis, or report and all supporting
calculations and assumptions for the same.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 5
Respectfully submitted this ay of May, 2005.
ERIC . LSEN
Attorneys for the Idaho Irrigation
Pumpers Association, Inc.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11 th day of May, 2005 , I served a true, correct
and complete copy of the Idaho Irrigation Pumpers Association, Inc. 's Fifth 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.jewell~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
Jeff Larsen
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: iohn.stewart2~pacificorp.com
S. Mail
James M. Van Nostrand
Stoel Rives LLP
900 SW Fifth Avenue, Suite 2600
Portland, OR 97204
E-mail: iffell~stoel.com
jm vannostrand~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~paciticorp.com
S. Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ID 83276
E-mail: iim.smith~monsanto.com
S. Mail
Monsanto Company S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 7
c/o Mark Boswell, Legal Dept.
800 N. Lindburg Blvd.
Mailzone E2NR
St. Louis, MO 63167
Katie Iverson
Brubaker & Associates
7244 W. Cordova Court
Surprise, AZ 85387
ki verson~sconsul tbai. COIn
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. 17th 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
ERIC L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIFTH DATA REQUEST TO PACIFICORP Page 8