20050608PAC response IIPA req 55-88.pdf

PACIFIC POWER UTAH POWER
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825 E. Multnomah
Portland, Oregon 97232
[phone]
. PACIFICORP
June 7, 2005
Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAlLEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE:ID P AC-05-
IIPA Data Requests 55-
Please find enclosed PacifiCorp s Response to lIP A Data Request Numbers (55-88). Provided
on the enclosed CD are Attachments lIP A 55-66-, 71 , 76 (A-B), 77-, 82 , and 87.
If you have any questions, please call Barry Bell at [phone].
Sincerely,
""-"---'" "'"
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Bob Lively, Manag
Regulation
Enclosures
cc:Katie Iverson/Monsanto
James Fell/Stoel Rives
JllftJewellYIPUC (3 copies)
Service List
CER TIFI CA TE OF SER VI CE
I hereby certify that I caused the foregoing document to be served on the following named
person(s) on the date indicated below by mailing 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.
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l~ ~::d Patricia Lopas
Regulatory Coordinator
Dated:~/f )fJ6
JEFF LARSON
PACIFICORP
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 1. OLSEN
RACINE, OLSON, NYE
BUDGE&BAILEY, CHARTERED
201 E. CENTER
POCA TELLO, 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
R. SIMPLOTCOMPANY
999 MAIN ST.
BOISE, ID 83702
DA VID HAWK
DIRECTOR, ENREGY NATURAL RESOURCES
JR. SIMPLOT COMPANY
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
June 7, 2005
lIP A Data Request 55
lIP A Data Request 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 information by substation for any of the
substations for which the company has data available for the last 6 years.
Response to lIP A Data Request 55
Please see Attachment lIP A 55 on the enclosed CD.
(David L. Taylor will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RA TE CASE
ACIFICORP
. IIPA DATA REQUEST
TT ACHMENT lIP A 55
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 56
lIP A Data Request 56
The response to lIP A Request 16 listed the amount of irrigation interruptions for
each day of the summers of 2003 and 2004. Please provide similar information
regarding the anticipated curtailments for the summer of 2005.
Response to lIP A Data Request 56
The requested information is provided in Attachment lIP A 56 on the enclosed
CD. The 2005 data is color-coded in blue to show that it is an estimate of the
anticipated values based on data extracts prepared on May 12 2005.
Note: The summer 2003 irrigation curtailment amounts provided here agree with
those provided in the company s original response to IIPA 16, which was later
updated in a supplemental response to lIP A 16. The updated curtailments are
provided in Attachment lIP A 60.
(David L. Taylor will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IIPA DATA REQUEST
TT A CHMENT lIP A 56
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 57
lIP A Data Request 57
The response to lIP A Request 27-C indicates that the level of curtailment
expected to occur in 2005 is the same as found in the response to lIP A request 2-
, which is the 2003 report on the irrigation curtailment. (a) Does this mean that
the 2003 levels of irrigation curtailment were used as the basis for the data in this
filing? (b) What, if any adjustments were made to this data?
Response to lIP A Data Request 57
(a) Yes. In this filing both Idaho jurisdictional loads and irrigation class loads
were based on irrigation curtailments that occurred during the FY04 test
period (summer of2003).
(b) No adjustments were made to the irrigation load data.
(David L. Taylor will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 58
lIP A Data Request 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. (a) What level of curtailment was used in this
case as a foundation for the interjurisdictional allocation process? (b) Please
supply detailed support to demonstrate how this level was incorporated in the
filing.
Response to lIP A Data Request 58
(a) The Idaho loads used in jurisdictional allocation process in this filing are
based on actual metered data during the FY04 test period. These loads reflect
the actual load reductions achieved by the irrigation curtailment program
during the summer of2003. The Company s estimates of the amount of the
FY04 load reductions associated with the irrigation curtailment program were
provided in response to lIP A 16.
(b) The supporting load detail, found in Mr. Weston s Exhibit No., tab 10, pages
3 through 7, shows allocation calculations based on loads that incorporate
actual levels of curtailment.
(David L. Taylor will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 59
lIP A Data Request 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. (a)
What level of credit was used in this case as a foundation for the jurisdictional
revenue requirement? (b) Please supply detailed support to demonstrate how this
level was incorporated in the filing.
Response to lIP A Data Request 59
(a) The credit included in the case was $289 019 based on the summer of2003.
(b) Adjustment 4.18 in Mr. J. Ted Weston s exhibit identifies the adjustment for
the Idaho DSM credits. The adjustment corrects the allocation by reversing
the credits which were initially recorded on a system factor and situs assigns
them to Idaho.
(J. Ted Weston will sponsor this response at hearing.
P A C- E-O 5 -lIP acifi Corp
June 7, 2005
lIP A Data Request 60
lIP A Data Request 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. (a) What level of curtailment was used in this
case as a foundation for the class cost of service study? (b) Please supply detailed
support to demonstrate how this level was incorporated in the filing.
Response to lIP A Data Request 60
(a) Please refer to Attachment IIPA 60 on the enclosed CD. Tables 1 & 2 indicate
the amount of load curtailed during the Idaho Irrigation Season.
(b) Load Research Data was not adjusted up or down by the amounts shown
because the curtailment is already reflected in the monthly peaks. Irrigation
Load Curtailment is an ongoing, year by year, program. For additional
information please refer to response lIP A 2 D.
(David L. Taylor will sponsor this response at hearing.
IDAHO
PAC-05-
GENERAL RATE CASE
ACIFICORP
IIPA DATA REQUEST
TT A CHMENT lIP A 60
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 61
lIP A Data Request 61
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 is included in the test year and where can it be found in the filing?
Response to lIP A Data Request 61
Please refer to the response for lIP A 59.
(1. Ted Weston will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 62
lIP A Data Request 62
In lIP 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 lIP A 21 , 22, and 23 there is a total adjustment under the
Monsanto Curtailment" of-177 MWH. (a) What is the basis for this figure
and (b) why was it not listed in the original filing, but (c) listed in each of the
responses? (d) What is the significance of the negative sign and (e) why does it
add to "Net System Load"
Response to lIP A Data Request 62
( a), (b) and (c)
The "177 MWH" is not related to Monsanto Curtailment but rather is Station
Service. Station Service is included in all runs which the Company has provided.
See below:
Adjustments to Load
DSM Cool Keoeopeor
DSM Idaho Irrigation
MagCorp Curtailmeont
Monsanto Curtailment
Station ServicE'(67 177)
Total Adjustments to Load (67,177)
System Load
Net System Load
760,475
52.827.652
(d) and (e)
The Station Service adjustment is the quantity of energy used by a power plant
when it is off-line. When a plant is generating, station service reduces the plant'
net generation to the system. When a plant is off-line, the station service is an
additional load that the Company is required to serve.
(Mark T. Widmer will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 63
lIP A Data Request 63
The response to IIPA 21 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.
Response to lIP A Data Request 63
The Company provided a Supplemental Response to lIP A Data Request 21 which
explains the correct interpretation of lIP A 21. The correct impacts are a $33.
million reduction in Net Power Costs and a 1 363 049 MWH net reduction in
load.
As discussed in the Company s Supplemental Response to lIP A Data Request 21 :
Based on the updated analyses, it can be interpreted that if the Company
has no ability to curtail or interrupt customers, there would be a $18
million increase to Net Power Cost as represented in Attachment lIP A 22Revised. If the Company does not supply Monsanto load, there would be
a $51 million decrease to Net Power Cost as represented in attachment
IIPA 21 Revised. The net impact on the filed Net Power Cost would be a
decrease of approximately $33.6 million.
(Mark T. Widmer will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 64
lIP A Data Request 64
The response to lIP 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 all interruptible and curtailable load
does not exist, i.e., is made firm. If the Company disagrees with any of these
statements, please provide a detailed explanation regarding what is wrong with
these assumptions.
Response to lIP A Data Request 64
The Company provided a Supplemental Response to lIP A Data Request 22 which
explains the correct interpretation of lIP A 22. The correct impacts are an $18.3
million increase in Net Power Costs and a 39 051 MWH net increase in load.
As discussed in the Company s Supplemental Response to IIPA Data Request 22:
Based on the updated analyses, it can be interpreted that if the Company
has no ability to curtail or interrupt customers, the impact on Net Power
Cost would be an increase to Net Power Cost of approximately $18.3
million, as represented in attachment lIP A 22 Revised.
(Mark T. Widmer will sponsor this response at hearing.
. -
P AC-O5-1/PacifiCorp
June 7, 2005
lIP A Data Request 65
lIP A Data Request 65
The response to IIPA 23 indicates that by comparison to the Net Power Costs in
lIP 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 all interruptible and curtail able load
does not exist, i.e., is made firm and the irrigation load in Idaho was removed.
the Company disagrees with any of these statements, please provide a detailed
explanation regarding what is wrong with these assumptions.
Response to lIP A Data Request 65
The Company provided a Supplemental Response to lIP A Data Request 23 which
explains the correct interpretation of lIP A 23. The correct impacts are a $15.4
million increase in Net Power Costs and a 42 929 MWH net reduction in load.
As discussed in the Company s Supplemental Response to lIP A Data Request 23:
Based on the updated analyses, it can be interpreted that if the Company
has no ability to curtail or interrupt customers, there would be an increase
of $18.3 million to Net Power Cost as represented in Attachment lIP A 22
Revised. If the Company does not serve the portion of Irrigation load that
was eligible for curtailment in the summer of 2004, there would be a
decrease of $2.9 million to Net Power Cost as represented in attachment
IIPA 23 Revised.
(Mark T. Widmer will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 66
lIP A Data Request 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.
Response to lIP A Data Request 66
The requested information is provided as Attachment lIP A 66 on the enclosed
CD.
(Mark T. Widmer will sponsor this response at hearing.
IDAHO
A C- E-O5-
GENERAL RA TE CASE
ACIFICORP
IIPA DATA REQUEST
TT A CHMENT lIP A 66
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 67
lIP A Data Request 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 500/0 of the Idaho Irrigation
load.
Response to lIP A Data Request 67
The requested information is provided as Attachment lIP A 67 on the enclosed
CD.
(Mark T. Widmer will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
lIP A DATA REQUEST
TT A CHMENT lIP A 67
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 68
lIP A Data Request 68
Please provide in a summary fashion similar to that provided in Ex. 9, Tab 5 , theresults 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.
Response to lIP A Data Request 68
The requested information is provided as Attachment lIP A 68 on the enclosed
CD.
(Mark T. Widmer will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IIPA DATA REQUEST
TT A CHMENT lIP A 68
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 69
IIPA Data Request 69
The response to lIP 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?
Response to lIP A Data Request 69
In accordance with the terms of the tariff, all Schedule 9 customers with load in
excess of 1 MW in the State of Idaho are taking service at the sub-transmission
voltage level and are included in the sub-transmission groupings in both the Load
Research and Cost-of-Service analyses.
(David L. Taylor will sponsor this response at hearing.
P AC-05-1/PacifiCorp
Jupe 7, 2005
lIP A Data Request 70
lIP A Data Request 70
Regarding the response to lIP A Request 10, why is there only a temperature
adjustment for Schedule 1 customers, but not Schedule 36? (Exhibit 29, page 1)
Response to lIP A Data Request 70
As previously stated in the Supplemental Response to lIP A Data Request 10
, "
this point in the weather normalization process, no coefficients for Schedule 36
have been developed.
(William R. Griffith will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 71
lIP A Data Request 71
Please supply (a) all work papers and (b) assumptions that support the generally
declining values in the levels of Irrigation curtailment that occur through time as
demonstrated on the response to lIP A Request 16.
Response to lIP A Data Request 71
(a) PacifiCorp s customer service database (CSS) is the primary source of
information used in support of the assertion that irrigation curtailment levels
generally decline through the summer. CSS data is regularly extracted into an
enterprise data warehouse. COGNOS is then used to extract the necessary
customer data. Attachment lIP A 71 , on the enclosed CD, is an example of a
COGNOS extract from the database.
(b) In accordance with the Credit Rider Irrigation Load Control Tariff
PacifiCorp calculates the avoided demand (kW) for each Schedule 10 site
based on the three (3) year average (mean) meter reads for which the customer
has been billed.
Using the Company s CSS data warehouse, extracts are prepared for the most
immediate three years. Data is further prepared for the tariff period (June
through September) on a monthly basis, such that each of the three previous
Junes are averaged, each of the three previous Julys are averaged and so on.
When a customer agrees to participate in the Credit Rider Irrigation Load
Control Tariff, it is assigned a participation credit based on the avoided
demand (kW) values for each of its participating sites. These values are
summed to derive the avoided demand (kW) per month for the respective
program year.
The measurements that exist are the meter reads that are entered into the CSS
database and eventually migrated to the CSS data warehouse.
The work papers that exist are the extracts from the Program s database. See
Attachment lIP A 71 on enclosed CD.
Values decrease over the course of the summer (June through September)
because (1) most field crops (wheat, barley, etc.) are harvested beginning in
late July; and (2) a significant number of irrigation customers have only 3
cuttings of hay. Changes are consistent from year to year. July is usually the
heaviest pumping month, with June second, August third and September
fourth.
(David L. Taylor will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IIPA DATA REQUEST
ATTACHMENT lIP A 71
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7 , 2005
lIP A Data Request 72
lIP A Data Request 72
Please supply a copy of tariffs T-23 and T-24 for Rate Schedules 1 , 36, 10, and
23.
Response to lIP A Data Request 72
Copies of tariffs T-23 and T-24 for Rate Schedules 1 , 10, and 23 h~ye been
provided as Attachment lIP A 32 1 , in response to Data Request lIP A 32
Supplemental.
(William R. Griffith will sponsor this response at hearing.
P A C- E-O 5 -lIP acifi Corp
June 7, 2005
lIP A Data Request 73
lIP A Data Request 73
From the data presented in response to lIP A request 44, it would appear that there
were 100 substations in 1995 and only 83 in 1999. Please (a) clarify what this
data represents and (b) specifically why the number of substations appears to have
decreased.
Response to lIP A Data Request 73
(a) and (b)
As discussed in our telephone conversation of April 19, 2005, the Company
cannot explain these differences. From a combination of data sources, the
Company has recently collected FY04 monthly substation peaking information
for all 72 Idaho distribution substations. As also discussed in the telephone
conversation of April 19, 2005, the Company would be agreeable to providing
this updated information.
(David L. Taylor will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 74
lIP A Data Request 74
Regarding the response to lIP 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 lIP A 44?
Response to lIP A Data Request 74
Please refer to lIP A Data Request 45 Supplemental.
(William R. Griffith will sponsor this response at hearing.
. -
P AC-05-1/PacifiCorp
June 7, 2004
lIP A Data Request 75
lIP A Data Request 75
Regarding the response to lIP A request 52, 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. Please clarify what the difference is between these two uses of the same
term.
Response to lIP A Data Request 75
The system balancing transactions discussed in the Company s response to lIP A
Data Request 54 refers to actual transactions during the base year. The Company
models normalized wholesale sales and purchases activities in the net power cost
study.
For a description of system balancing transactions, please see the Company
response to lIP A 12 and lIP A 42.
(Stan K. Watters will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 76
lIP A Data Request 76
Regarding the response to lIP 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.e.
system treatment and not as a DSM program.
Response to lIP A Data Request 76
This response assumes the reference is to system treatment of Monsanto
interruptibility costs and revenues.
The requested electronic version of a run of the Company s jurisdictional
allocation model (JAM) with the requested assumption is provided as Attachment
lIP A 76 A on the enclosed CD. The specific load assumptions used are presented
in Attachment IIPA 76 B on the enclosed CD. This response is provided for
informational purposes only, as it represents a deviation from test period loads
revenues, and costs. The following additional assumptions were used in
preparing results.
1. For jurisdictional allocati on purposes, the jurisdictional load reductions
associated with the Irrigation Load Control Program were reversed to reflect
what Idaho loads would have been if there had been no curtailments. This is
consistent with the treatment of Monsanto loads.
2. Additional revenues associated with the curtailments have been imputed at a
rate of 4.3 cents per curtailed kilowatt hour. This reflects what the Idaho
Irrigation revenues would have been if there had been no curtailments.
3. Load Control Program payments are treated as a system expense rather than
assigned Situs to Idaho.
4. Since there was no change in net system load, the NPC study has remained
constant from the original filing.
Attachment lIP A 76A has been synced for both Revised Protocol and Rolled-
methodologies.
(J. Ted Weston will sponsor this response at hearing.
. .
IDAHO
P AC-O5-
GENERAL RATE CASE
ACIFICORP
lIP A DATA REQUEST
ATTACHMENT lIP A 76 (A-
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 77
lIP A Data Request 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.
Response to lIP A Data Request 77
Please refer to Attachment lIP A 77 on the enclosed CD for the requested inter-
jurisdictional allocation model. This response is provided for informational
purposes only, as it represents a deviation from test period loads, revenues, and
costs.
Please note the following assumptions have been used in generating the results.
1. Metered loads were reduced an additional 20 MW from June 1- September
from those reflected in the filed case. For jurisdictional allocation purposes
the jurisdictional load reductions associated with the Irrigation Load Control
Program (including the additional 20 MW) were reversed to reflect what
Idaho loads would have been if there had been no curtailments. This is
consistent with the treatment of Monsanto loads.
2. Revenues were first reduced by 4.3 cents per kilowatt hour for the additional
curtailed kWh (20 MW X 6 hours per day Monday through Thursday).
Additional revenues associated with the curtailments (including the additional
20 MW) have then been imputed at a rate of 4.3 cents per curtailed kilowatt
hour. This reflects what the Idaho Irrigation revenues would have been if
there had been no curtailments.
3. The net power cost adjustment has been updated to reflect an additional 20
MW of curtailment.
4. DSM expenses were doubled assuming twice as many customers/horsepowerparticipated in the program.
Attachment lIP A 77 has been synced for Revised Protocol and Rolled-
Methodologies.
(J. Ted Weston will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
IIPA DATA REQUEST
ATTACHMENT lIP A 77
ON THE ENCLOSED CD
P AC-05-lIPacifiCorp
June 7, 2005
lIP A Data Request 78
lIP A Data Request 78
Please provide an electronic copy of the same inter-jurisdictional 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.
Response to lIP A Data Request 78
Please refer to Attachment lIP A 78 on the enclosed CD for the requested inter-
jurisdictional allocation model. This response is provided for informational
purposes only, as it represents a deviation from test period loads, revenues, and
costs.
Please note the following assumptions were used:
1. Additional curtailments have been from June 1- September 15.
2. 20 MW curtailments were adjusted for line losses.
3. Additional MWh curtailment was calculated using 6 hours per day Monday
through Thursday.
4. Revenues were reduced by 4.3 cents per kilowatt hour for the additional
curtailed kWh.
5. DSM expenses were doubled assuming twice as many customers/horsepower
participated in the program.
6. Net Power Costs were re-run using an additional 20 MW curtailment.
Attachment lIP A 78 has been synced for both Revised Protocol and Rolled-
methodologies.
(J. Ted Weston will sponsor this response at hearing.
IDAHO
PAC-05-
GENERAL RA TE CASE
ACIFICORP
IIPA DATA REQUEST
TT ACHMENT lIP A 78
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 79
lIP A Data Request 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.
Response to lIP A Data Request 79
Attachment lIP A 79 on the enclosed CD is provided for informational 'purposesonly, as it represents a deviation from test period loads, revenues, and costs and is
not supported by the Company.
(David L. Taylor will sponsor this response at hearing.
IDAHO
P AC-O5-
GENERAL RATE CASE
ACIFICORP
IIPA DATA REQUEST
TT ACHMENT lIP A 79
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 80
lIP A Data Request 80
On page 11-5 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.e., 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.
Response to lIP A Data Request 80
a. Sixty-eight percent of the 2003 field expenses are directly associated with
the installation of control devises. This includes installation labor
installation travel/expenses, and control equipment (timers, enclosures
and transformers).
b. Field expenses for 2004 and beyond were assumed to be for maintenance
and troubleshooting. At the time of the preparation of this report there was
no basis to assume any additional participation than what was realized.
The timer technology performed well during the summer of 2003 but it
was unclear what, if any, problems might be occurring during subsequent
years. Accordingly, the volume of participation in out-years was assumed
to be constant, but maintenance/troubleshooting was increased.
(David L. Taylor will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 81
lIP A Data Request 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?
Response to lIP A Data Request 81
Nearly 100% of these costs were associated with new participants to the program.
There were only a few irrigators who wanted to change their dispatch schedule or
who were interested in discontinuing program participation altogether. Program
participation grew from 2003 to 2004. This growth in participation, coupled with
less than 6 changes in existing program participants, meant that nearly all of the
2004 field expenses were dedicated to the management of new program
participants.
(David L. Taylor will sponsor this response at hearing.
AC- E-05-/PacifiCorp
June 7, 2005
lIP A Data Request 82
lIP A Data Request 82
F or each hour in 2003 and 2004 when the Idaho Irrigation load was curtailed
please supply the price paid for the most expensive short-term firm purchase in
the Company s eastern control area as well as the quantity purchased at that price.
Response to lIP A Data Request 82
The requested information is provided as Attachment lIP A 82 on the enclosed
CD.
(Stan K. Watters will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RA TE CASE
ACIFICORP
IIPA DATA REQUEST
ATTACHMENT lIP A 82
ON THE ENCLOSED CD
P AC-05-/PacifiCorp
June 7, 2005
IIPA Data Request 83
lIP A Data Request 83
(a) 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, (b) all supporting calculations, assumptions and related analysis used in
the development of these values. (c) 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 days a week. (d) Also, please provide '
electronic copy of any model used to calculate the 2005 LCSC rate.
Response to lIP A Data Request 83
(a) Irrigation Load Control Credit - Valuation overview
From June 1st, 2005 to September 15th, 2005 , PacifiCorp will provide a credit
to Idaho Schedule 10 customers who sign up to physically curtail their load
associated with one of three different predetermined timeframes. These three
timeframes, all falling between hours ending 14 & 19 PPT (2PM to 8PM
Mountain Prevailing Time), are as follows:
1) two six-continuous-hour blocks per week (Monday & Wednesday or
Tuesday & Thursday),
2) two three-continuous hour blocks per week (Monday & Wednesday or
Tuesday & Thursday), or
3) four three-continuous hour blocks per week occurring Monday
through Thursday.
Pricing for these three products is based on PacifiCorp s next best alternative
to serve East Side load, the forward firm energy market at Mona. All three of
these products represent super peak for shoulder/graveyard exchanges, based
on the Company s forward price curve and scalars at the time of the analysis.
The mechanics of an exchange is extremely straight forward. The valuation
simply looks at the difference in wholesale value associated with the energy
not delivered to Schedule 10 customers during the curtailed load super peak
period and the wholesale value associated with the shifted energy delivered to
Schedule 10 customers during the non-curtailed period. This difference, on a
monthly basis, is the credit that PacifiCorp provides to Idaho Schedule 10
customers who sign up to physically curtail their load associated with one of
the three different predetermined timeframes, shifting their energy demand to
other hours.
(b) Please refer to Attachment IIPA 83 on the enclosed CD.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 83
(c) The monthly credits, on a $/KW-mo basis, for the three timeframes are as
follows:
1. Option 1 = ((FPC Mona M- Thurs HE 14-19 PPT $/MWh FPC Mona M-
F HE 20-13 PPT) * 6 Hrs/Day * 2 Days/Week * # W eeks/Month) + 1000
2. Option 2 = ((FPC Mona M-Thurs HE 16-18 PPT $/MWh FPC Mona M-
F HE 19-15PPT) * 3 Hrs/Day * 2 Days/Week * # Weeks/Month) + 1000
3. Option 3 = ((FPC Mona M-Thurs HE 16-18 PPT $/MWh FPC Mona M-
F HE 19-15 PPT) * 3 Hrs/Day * 4 Days/Week * # W eeks/Month) + 1000
(d) Please refer to Attachment lIP A 83 on the enclosed CD.
(Stan K. Watters will sponsor this response at hearing.
IDAHO
PAC-O5-
GENERAL RATE CASE
ACIFICORP
lIP A DATA REQUEST
TT A CHMENT lIP A 83
ON THE ENCLOSED CD
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 84
lIP A Data Request 84
Please provide the number of ( a) participant sites and (b) participant customers for
the 2005 LCSC, the total number of (c) eligible cites and (d) customers for the
2005 irrigation season, and (e) the forecast curtailed load resulting there from.
Response to lIP A Data Request 84
F or data as of May 12, 2005:
(a) 2005 Participant sites = 1 066
(b) 2005 Participant customers =462
(c) Total # of eligible sites (2005) = 95
(d) Total number of eligible customers (2005) = 2 058
(e) The anticipated curtailed load is indicated in Attachment lIP A 56.xls
broken out by month and by dispatch event control day.
(Stan K. Watters will sponsor this response at hearing.
P AC-05-/PacifiCorp
June 7, 2005
lIP A Data Request 85
lIP A Data Request 85
Please provide a description of (a) all methodologies available to calculate the
benefits of the LCSC program to the Company, (b) all supporting calculations
assumptions and related analysis. For the methodology which the Company
principally uses to measure the benefits of the LCSC program, (c) please describe
why the Company believes it is the most appropriate method.
Response to lIP A Data Request 85
(a) and (b)
The method the Company "principally uses" and all supporting calculations
assumptions and related analysis are described in detail in part (c) below. This
method, Quantec s Demand Impact Cost Effectiveness model (DICE) was applied
against the four industry standard tests - or perspectives - for analyzing costs and
benefits. The four perspectives are:
Program Participants: For participants, Program benefits include bill
reductions and the participation credit payments participants received for
demand reduction.
Utah Power: From Utah Power s perspective, the benefits are in the form of
reduced generation or power purchase costs. The costs include marketing
and administration associated with funding the Program, as well as the
equipment and installation expenses and participant credits.
Ratepayers: All ratepayers (participants and non-participants) may
experience an increase in rates to recover lost revenue, if any. This test
(referred to as the Ratepayer Impact Measure Test, or RIM) includes all
Utah Power Program costs plus lost revenues. On the benefits side, this test
includes all reduced generation or power purchase costs.
Total Resource Cost Test (TRC): This test examines the Program benefits
and costs from the perspective of the utility and its customers combined. On
the benefit side, it includes reduced generation or power purchase costs. On
the cost side, it includes costs incurred by both the utility and by the
participants, but participant credits are excluded because they are transfer
payments among customers.(c)
The aggregate demand reduction from the LCSC program was on the order of 20
MW per control day. Since this is a relatively small amount compared to total
system demand and incremental additions of this magnitude to a utility'
generation resource mix are unlikely, it was impractical to estimate its benefits in
terms of avoided demand alone. Instead, the Company calculated the benefits of
energy savings during the control periods using the IRP Decrement approach for
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 85
valuing Demand Side Management (DSM) programs. Fundamentally, the IRP
Model calculates revenue requirements based on a given set of assumptions
including an hourly load forecast. Decrements (subtractions) to the load forecast
are made based on the hourly shape of the DSM program modeled. Values are
calculated with and without the program. The difference, or decrement value
represents the most the Company would pay to avoid the load being modeled. The
resulting values for avoided energy ($/MWh) based on the anticipated load shape
of this Program were then calculated.
To estimate the savings, the Company used the characteristics of the participating
customers' loads. In 2003 , there were 207 participants with a total of 403
independent participating sites. From its participant contracts and three-year
average historical data, Utah Power knew the average historical demand of each
site during each month. The total demand reduction for each control period
(Mon/Wed and Tue/Thu) was estimated by customer and aggregated to calculate
the total load reduction induced by the Program. The avoided energy economic
benefits of the 2003 Program were calculated on a monthly basis using the
following formula:
Energy Economic Benefits
INo. of Mon/Wed Control Days Mon/Wed Control Days Avoided Demand
No. ofTue/Thu Control Days Tue/Thu Control Days Avoided Demand)
Value of Energy Savings
Cost effectiveness was calculated using Quantec s DICE model. Typically, the
model takes the first year kWh savings and allocates them over all the 8 760 hours
in a year based on load shapes appropriate for each end use being analyzed. The
achieved hourly kWh savings are then multiplied by the appropriate avoided cost
based on the time of day and season during which they occur (summer peak
summer off-peak, winter peak, etc.). The value of the savings is calculated for
each year of the measure life and then discounted back to the present.
For this program, the DICE analysis was simplified because it was only necessary
to calculate the economic benefits of the energy saved during those hours when
load control occurred. The aggregate economic benefits were calculated by
summing the discounted annual benefits, and cost-effectiveness was then
determined using the standard tests.
The Company regularly uses this basic approach to estimate the benefits of
efficiency and demand-reduction programs. It properly accounts for how the
value of saved energy varies over seasons, days, and hours of the day, and the
aggregate benefits take into account the effect of discounting future benefits based
on the relevant discount rate and measure lifetime.
(Stan K. Watters will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 86
lIP A Data Request 86
In the Company s 2004 IRP please explain how the LCSC program interruptible
load and the Monsanto interruptible load were treated (a) in determining the
Company s resource base, (b) in determining the gap between resources and the
forecast demand for the Company s eastern control area, and (c) in determining
which higher cost resources could be deferred in the various resource portfolios
considered under the 2004 IRP.
Response to lIP A Data Request 86
(a) The full capacity of both the Idaho Load Control program (35 MW, FY 2006.,.
2014) and the Monsanto interruptible load contract (67 MW, FY 2006-2007)
were used in the determination of the Company s resource base.
(b) The full capacity of the Idaho Load Control program (35 MW, FY 2006-2014)
and the Monsanto interruptible load contract (67 MW, FY 2006-2007) were
used to determine the gap between resources and forecast demand.
(c) The Idaho Load Control program and the Monsanto interruptible load contract
are considered as Existing Resources for IRP modeling, and thus have the
same effect on deferral of future resources as do all other existing resources.
Specific resource deferrals cannot be attributed to anyone existing resource.
(Stan K. Watters will sponsor this response at hearing.
P AC-05-1/PacifiCorp
June 7, 2005
lIP A Data Request 87
lIP A Data Request 87
In the Company s 2004 IRP it calls for the procurement of additional Class
DSM programs, (a) please provide any plans or methodology, (b) 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.
Response to lIP A Data Request 87
LCSC Program
(a) The LCSC applies to PacifiCorp s Idaho Irrigation Load Control program.
(b) The report to the Idaho PUC on the 2004 program is included on the
enclosed CD as Attachment IIPA 87. For 2005 , the projected load
reduction for the program is 50 MW. The participation level will vary
each year based on customer circumstances and the market based prices
offered for curtailment. As indicated in Attachment lIP A 87, for the
beginning of the 2005 irrigation season, PacifiCorp added two additional
dispatch schedules to better accommodate irrigators' preferences.
Monsanto interruptible load
(a) and (b)
The Monsanto interruptible load is expected to be continued through
successor arrangements after the current agreement terminates in 2006. While
there is no planned expansion of the interruptible products with Monsanto, the
structure and type could change depending on what has the most value.
(Stan K. Watters will sponsor this response at hearing.
IDAHO
P A C- E-O5-
GENERAL RATE CASE
ACIFICORP
lIP A DATA REQUEST
ATTACHMENT lIP A
ON THE ENCLOSED CD
P A C- E-O 5 -/Pacifi Corp
June 7, 2005
lIP A Data Request 88
lIP A Data Request 88
(a) 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? (b)
If so, please provide the results of any study, analysis, or report and all supporting
calculations and assumptions for the same.
Response to lIP A Data Request 88
(a) The Company has not done any forecasting to assess participation levels
based on different participation incentives.
(b) Please see response to part (a) above.
(David L. Taylor will sponsor this response at hearing.