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Home My WebLink About20050921IIPA 1st data request.pdf.~- , j v r U - - J i '1 L~J - ,- Eric L. Olsen ISB# 4811 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED O. Box 1391; 201 E. Center PocateUo, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 t') !;, t,~ g: 03 BUSSE? t- ~Ht \- -' Ii L\\\ r, kG Jo ~ I ~ ~) \ 0 H Attorneys for the Idaho Irrigation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION In the Matter of the Joint Application of MidAmerican Energy Holdings Company And PacifiCorp dba Utah Power and Light Company for an Order Authorizing MEHC To Acquire PacifiCorp ) CASE NO. P AC-05- IDAHO IRRIGATION PUMPERS ASSOCIATION ) INC.S FIRST DATA REQUEST ) TO P ACIFICORP 1. For each of the last 15 years, please provide for each of the PacifiCorp s jurisdictions for each month, the following in electronic fonnat: a. The system coincident peak demand at generation level (for the Idaho jurisdiction please state the Monsanto load separately); b. The amount of energy used at generation level (for the Idaho jurisdiction, please state the Monsanto load separately); and c. The number of customers. 2. Please provide the dollars associate with FERC Accounts 360 through 369 and Accounts 580 through 598 for each of the last 15 years, stating each jurisdiction separately in electronic fonnat. 3. Please provide the PacifiCorp forecasted dollars associate with FERC Accounts 360 through 369 and Accounts 580 through 598 for each of the next 5 years, stating each jurisdiction separately in electronic fonnat. 4. For each of the last 15 years, please provide in electronic fonnat for each of the PacifiCorp jurisdictions the usage, number of customers, and dollars charged for standard residential IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST DATA REQUEST TO PACIFICORP service (non-time-of-day or other programs) as well as standard irrigation service (non-load management, time of day, or other programs). Please state in such a manner that the PacifiCorp charges are fully listed as well as any BP A Credit. 5. For each of the last 15 years, please provide in electronic fonnat for each of the PacifiCorp jurisdictions the usage, number of customers, and dollars charged for each non-standard residential service (time-of-day or other programs) as well as non-standard irrigation service (load management, time of day, or other programs). Please state in such a manner that the PacifiCorp charges are fully listed as well as any BP A Credit. 6. In Mr. Abel's testimony, beginning on page 3 line 22 it is indicated that MWHC/MEC wants to insure that PacifiCorp customers receive certain benefits. Please demonstrate how these commitments will ensure that the Idaho jurisdictional customers will receive something more (or in some ways are better oft) than what Scottish Power had originally planned. 7. In Mr. Abel's testimony, beginning on page 11 line 1 it is indicated that MEHC plans to operate PacifiCorp much as it is today. There are two things that are not only vital to Idaho customers, but also somewhat unique with respect to PacifiCorp as well. These two things are the BP A Credit that is enjoyed by both residential as well as irrigation customers and the irrigation load management program. a. Does MEHC commit to expanding the benefits and nature of the Irrigation Load Management program? b. Does MEHC commit to aggressively pursuing BP A credits in a manner similar to or better than Scottish Power and thus producing benefits that are substantially better than those experienced throughout the Northwest? c. Does MEHC commit to aggressively expanding the benefits of the BP A Credit to residential and irrigation customers? 8. In Mr. Abel's testimony, beginning on page 13 line 7, it is indicated that the shareholders understand that they may not earn a return on the acquisition premium. What are the expectations, limits, and parameters that the shareholders expect with respect to earning a full rate of return on the total system investment, given the historic disputes that have existed regarding interjurisdictional allocation methods? 9. In Mr. Abel's testimony, beginning on page 13 line 21 , it is indicated that there will be an annual investment of at least $1 billion per year for the next five years. With respect to the distribution investment associated with this figure, what is the dollar amount for each of these five years by jurisdiction? IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST DATA REQUEST TO PACIFICORP 10. In Mr. Abel's testimony, on page 15 lines 28-, there is mentioned that PacifiCorp will initiate a process to collaboratively design similar products (similar to BP A products) for PacifiCorp. Please provide a detailed explanation of what this entails and what is envisioned. 11. In Mr. Abel's testimony, on page 15 lines 40-, there is a commitment that ifMEHC is unsuccessful in demonstrating certain savings, it will accept a reduction in revenue requirement. Is MEHC willing to make a commitment that it will maintain a certain minimal level ofBPA credit (compared to what has been historically achieved by Scottish Power) or it will accept a reduction in its Idaho jurisdictional revenue requirement? 12. In Mr. Gale s testimony, beginning on page 6 line 17 it is indicated that MWHC/MEC has experience with the types of issues and risks that confront PacifiCorp. Please answer the following with respect to the intetjurisdictional allocation process used by MEC: a. Does MEC have a jurisdictional allocation methodology that is accepted by all jurisdictions in which it operates? b. If the answer to "" above is affinnative, how are generation and transmission costs allocated between jurisdictions? c. If the answer to "" above is negative, what is the nature of the disagreement, how long has the disagreement existed, what is the dollar magnitude of the impact of the disagreement on MEC? d. If the MSP agreement that is presently in place with the various PacifiCorp jurisdictions should breakdown, what would MWHC do to prevent or minimize any revenue shortfall that may result? 13. In Mr. Gale s testimony, beginning on page 7 line 23 it is indicated that DSM investments are made to the full extent detennined to be cost-effective. Please answer the following with respect to the Irrigation Load Management Program in Idaho: a. Please provide detailed, concrete examples of how MEC detennines the appropriate level of investment in DSM and energy efficiency programs "to the full extent determined to be cost-effective . Please quantify how MEC detennines/calculates the full extent" b. Does MWHC consider the Idaho Irrigation Load Management program to be a DSM program or at least fitting under the criteria considered to be a DSM or energy efficiency program for MEC? c. Does MEC have any load management programs? If so, please provide an explanation of the program(s) and provide detailed calculations on how the costs and IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST DATA REQUEST TO P ACIFICORP benefits of the program(s) are shared between those providing the load that is controlled and the rest of the customers. d. How does MWHC believe that the investment and "credits" in the Idaho Irrigation Load Control Program should be evaluated in order to "reflect the full extent detennined to be cost-effective. 14. In Mr. Gale s testimony, beginning on page 10 line 22 it is indicated that MEC offers an interruptible credit program. Please answer the following with respect to that program: a. Generally speaking, does MEHC/MEC consider the Idaho Irrigation Load Management Program more similar to a MEC DSM program or a MEC interruptible credit program? b. Please provide a detailed description ofMEC's philosophy for pricing it interruptibility credit program. c. Please contrast MEC's philosophy for pricing interruptible credits with DSM program. d. Please provide a copy of the most resent testimony filed by MEC regarding how to price its interruptible credits. 15. In Mr. Gale s testimony, beginning on page 11 line 1 it is indicated that MEC works to insure that rates paid are based on cost of service and reflect any benefits that the customers bring to the retail system. Please answer the following in this regard: a. What classification and allocation methodologies are used by MEC in its cost of service studies? b. How are the benefits of interruptibility addressed? c. Please provide a copy of the latest cost of service study filed by MEC that reflects interruptibility as well as supporting testimony. Please supply a hard copy as well as an electronic copy of the cost of service study. 16. For each of the last 15 years, what has been the total dollar amount of the BP A credit that has been given to each Idaho jurisdictional rate schedules for residential and irrigation customers? f.J IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. FIRST DATA REQUEST TO P ACIFICORP Respectfully submitted this lcf!a of September, 2005. L. OLSEN Attorneys for the Idaho Irrigation Pumpers Association, Inc. IDAHO IRRIGATION PUMPERS ASSOCIATION INC. FIRST DATA REQUEST TO PACIFICORP CERTIFICM~JQF SERVICE I HEREBY CERTIFY that on this J!fl!: iay of September, 2005, I served a true correct and complete copy of the Idaho Irrigation Pumpers Association, Inc. 's First Data Request to Pacificorp to each of the following, via U.S. Mail, e-mail or hand delivery: Jean Jewell Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, Idaho 83720-0074 E-mail: jean. iewell(illpuc.idaho.gov S. Mail Andrea L. Kelly Managing Director-Strategy PacifiCorp 825 NE Multnomah, Suite 956 Portland, OR 97232 E-mail: andrea.ken y(illpacifi corp. com E- Mail Douglas L. Anderson, Senior VP MidAmerican Energy Holdings Co. 302 S. 36th Street, Suite 400 Omaha, Nebraska 68131 E-mail: danderson(illmidamerica.com E- Mail Mark C. Moench, Senior VP MidAmerican Energy Holdings Co. 2755 E. Cottonwood Parkway, Suite 300 Salt Lake City, UT 84171-0400 E-mail: l11cmoench(illmidamerica.com E- Mail James M. Van Nostrand James F. Fell Stoel Rives LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204 E-mail: l111vannostrand(illstoel.com ffell (illstoel. com E- Mail Data Request Response Center P aci fi Corp 825 NE Multnomah St., Suite 800 Portland, OR 97232 E-mail: datarequest(illpacificorp.com E-mail IDAHO IRRIGATION PUMPERS ASSOCIATION INC' FIRST DATA REQUEST TO P ACIFICORP Idaho Irrigation Pumpers Association, Inc. c/o Lynn Tominaga, Executive Director O. Box 2624 Boise, ID 83701-2624 S. Mail Anthony Yankel 29814 Lake Road Bay Village, Ohio 44140 E-mail: yankel(illattbi.com E- Mail IDAHO IRRIGATION PUMPERS ASSOCIATION INC' FIRST DATA REQUEST TO P ACIFICORP