20070723IIPA to PAC 1, 1-38.pdf

LAW OFFICES OF
W. MARCUS W. NYE
RANDALL C. BUDGE
JOHN A. BAILEY, JR.
JOHN R. GOODELL
JOHN B. INGELSTROM
DANIEL C. GREEN
BRENT O. ROCHE
KIRK B. HADLEY
FRED J. LEWIS
MITCHELL W. BROWN
ERIC L. OLSEN
CONRAD J. AIKEN
RICHARD A. HEARN, M.
DAVID E. ALEXANDER
LANE V. ERICKSON
PATRICK N. GEORGE
SCOTT J. SMITH
STEPHEN J. MUHONEN
BRENT L. WHITING
JUSTIN R. ELLIS
JOSHUA D. JOHNSON
JONATHON S. BYINGTON
DAVE BAGLEY
CAROL TIPPI VOLYN
THOMAS J. BUDGE
CANDICE M. MCHUGH
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED
20, EAST CENTER STREET
POST OFFICE BOX, 391
POCATELLO, IDAHO 83204-1391
TELEPHON E (208) 232-610'
FACSIMILE [phone]
www.racinelaw.net
SENDER'S E-MAIL ADDRESS: elo(!j)racinelaw.net
July 19, 2007
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
pAL
;IPC-O7-Re:
Dear Jean:
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE: (208) 395'001 I
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, ID 83402
TELEPHONE: [phone]
FACSIMILE: [phone]
COEUR 'D ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE 106A
COEUR D'ALENE, ID 83814TELEPHONE: [phone]
ALL OFFICES TOLL FREE(877) 232-6101
LOUIS F. RACINE (1917'2005)
WILLIAM O. OLSON. OF COUNSEL
r-,
c_-
~..,"'":. ,!"'-, ._....
en:.,-
e/)
C"'
0,:)
cr,
Enclosed please find the original and three (3) copies ofIdaho Irrigation Pumpers Association, Inc.' s
R€sponse to Pru;:ifieorp First Data Request. to fltc:L~C)tVl
Sincerely,
J)wc
ERIC L. OLSEN
ELO:rr
Enclosurescc: Data Requst Response Center/Pacificorp
James R. Smith/Monsanto Co.
Maurice Brubaker, Katie Iverson/Brubaker & Associates
Anthony Yankel
Idaho Irrigation Pumpers Assoc.
Randall C. Budge
Brian Dickman, Rocky Mountain Power
Dean Brockbank, Justin Brown/Rocky Mountain Power
Tim Buller/ Agrium, Inc.
fiR-
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]
zmJi jUL 22 i\;; 8: i
" ,
,i;
(iLiI i
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF)
PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES
CASE NO. PAC-07-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.S FIRST DATA REQUEST TO
ACIFICORP
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("lIP A"), by and through its
attorneys, hereby submits this First Data Request to Pacificorp dba Rocky Mountain Power
pursuant to Rule 225 ofthe Idaho Public Utility Commission s Rules of Procedure, IDAP A
31.01.01 , as follows:
liP A 1-Please answer the following with respect to information contained on
McDougal's Exhibit 11 , Tab 10 entitled "Allocation Factors
A. On pages 10.12 through 10., are these actual generation level energy and
demand values recorded for each jurisdiction during each of the months
specified?
B. Do the energy and demand values for Idaho include Monsanto load that has been
interrupted?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP-
C. Are the values/adjustments on page 10.12 through 10.22 simply weather related
adjustments? If these adjustments are more than simply weather related
adjustments, please provide a breakdown of these values that relate to weather
adjustments and those that relate to other adjustments (please provide specific
detail for each "other" adjustment).
D. Are the demand and energy values on pages 10.12 through 10.22 the ones used to
form the basis for such system allocators as SC and SE?
E. For each ofthe adjustments listed on pages 10.16 and 10., how are these
adjustments reflected by rate schedules or special contract customer consumptions
in each month?
F. Please provide an electronic as well as hard copy of all workpapers that support
the calculations on Tab 10.
liP A 1-Please answer the following with respect to information contained on
Tucker s Exhibit 30, Tab 5 "Cost of Service Allocation Factors
A. Are the times of the system peaks listed on page 6 the same as the actual
coincident system peaks during each of those months?
B. Are the times listed on page 6 on Pacific or Mountain time?
C. How do the total jurisdictional values for each month on page 6 relate to the Idaho
values on McDougal's Exhibit 11 , Tab 10?
D. With respect to the data listed on pages 7, 12, and 13 , which data came from the
Company s load research data and which data came from census data? Iffrom
load research data, over what timeframe was the data collected?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST TO PACIFICORP - 2
E. What was the level of curtailment/interruption for each customer class or
Monsanto during the times of each of the monthly peaks listed on page 7? (Please
specify at input level.)
F. Is there any weather normalization of the Distribution Peak data on page 12 or the
Non-Coincident Peak data on page 13? Ifthis data is weather normalized, please
provide an electronic as well as hard copy of all workpapers used to support this
normalization.
liP A 1-Please answer the following with respect to information contained on
McDougal's Exhibit 11 , Tab 10 entitled "Allocation Factors" and Tucker s Exhibit 30, Tab 5
Cost of Service Allocation Factors
A. The demand value for January 2006 for Idaho on Ex. 11 , Tab 10, page 10.14 is
420.8 MW, while the total Idaho value on Ex. 30, Tab 5 , page 6 for January 2006
is 401.840 MW. Please reconcile these two figures. If additional data is required
to reconcile all ofthe Ex. 11 , Tab 10, page 10.14 figures, with Ex. 30, Tab 5 , page
, please provide that data.
B. On Ex. 30, Tab 5 , page 16 there is listed a total Idaho energy figure for January
2006 of289 794 MWH at input. On Ex. 11 , Tab 10, page 10.14 the total Idaho
January 2006 energy is listed as 295 850 MWH at input. Please reconcile these
two figures.
liP A 1-With respect to the Company s Load Research data, please provide for
each sample customer with valid data that was sampled between January 2004 and the most
recent month available the following:
A. Customer identification number;
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 3
B. Customer rate schedule;
C. Strata to which it belongs and weighting factors of each strata;
D. Raw hourly usage data (i., unadjusted, simply the data originally gathered for
each sample);
E. Raw hourly usage data modified to reflect losses;
F. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company s cost of service study in this case.
G. Please provide copies ofthe formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of service
study in this case. This information should include number of customers in the
population of each class.
liP A 1-In January 2002 the Company developed/presented a "Load Research
Status" report in Utah. Does something similar exist for the Idaho jurisdiction? If so, please
provide a copy and indicate if there have been any changes to the Load Research Program since
that report was written.
liP A 1-Previously the Company developed hourly calibrations that calibrated the
Load Research data such that the summation of the (population expanded) Load Research data
and the Census data equaled the Company s "Operations Stat" or border loads. The Company
may no longer be applying these calibrations to the Load Research data, but the data is still of
interest. On an hourly basis from January 2004 through the most recent month available, please
provide:
A. The "Operations Stat" or border load for the Idaho Jurisdiction;
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 4
B. The summation ofthe (population expanded) Load Research data and the Census
data that would reflect what the Company measured or estimated as its internal
customer load for each rate schedule or customer group;
C. The hourly load for each rate schedule or special contract customer that is
measured or calculated on a census basis as opposed to using load research data;
D. Any other load that is contained in "" above but is not addressed in "" above
(please specify the type ofload); and
E. Any information such as difference in measuring techniques or timing of the data
that needs to be addressed when comparing the above data.
liP A 1-Please provide for each month from January 2004 forward a copy ofthe
results of all checks that the Company makes regarding how well the load research data reflects
the actual population usage.
liP A 1-Please provide a copy of any summary reports that have been produced
between January 2004 and the present regarding Idaho Load Research data.
liP A 1-This filing used weather-normalized data for developing allocation factors
in the jurisdictional allocations and presumably the class cost-of-service study. For each rate
schedule, please provide all workpapers as well as a description of the flow (manipulation) of
data from historic load research or consensus data to projected test year energy, coincident
demands, and non-coincident demands.
liP A 1-10:On Exhibit 11 , page 10.16 there is an adjustment for the August 2006
Idaho coincident peak of a negative 6.9 MW. Please provide all data, equations, and
assumptions used to develop this figure. Explain how, if at all, this adjustment flows through or
is incorporated in Exhibit 30 Tab 5 , page 7.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO PACIFICORP - 5
IIPA 1-11:Please provide in electronic format for the period January 1 , 2004 through
the most recent month available hourly data similar to that provided in CCS Request 11 in P AC-
05-01.
IIPA 1-12:Please provide in electronic format a listing of the date, time, and
estimated magnitude of all actual hourly curtailments/interruptions that occurred during the test
year in Idaho separated by rate schedule or special contract customer. If outright
curtailmentslinterruptions are treated differently than "buy-throughs , please state each
separately.
IIPA 1-13:Please provide in electronic format a listing of the date, time, and
estimated magnitude of all actual hourly curtailments/interruptions that occurred during the test
year in each of the other jurisdictions. If outright curtailments/interruptions are treated
differently than "buy-throughs , please state each separately.
liP A 1-14:If the Company s net power cost model was run using weather normalized
loads, how were those weather-normalizing adjustments spread out for each hour used in the net
power cost model? Were the same adjustment factors applied on an hourly basis to each hour in
each day, each week, each month, etc.
liP A 1-15:Please provide in a summary fashion similar to that provided in Ex. 11
Tab 5, the results of the Company s net power cost model assuming that the Company was also
supplying all ofthe curtailment for the Idaho Irrigation load that occurred in 2006.
liP A 1-16:Please provide in a summary fashion similar to that provided in Ex. 11
Tab 5 , the results of the Company s net power cost model assuming that the Company was also
supplying all of the curtailment for the Idaho Irrigation load that occurred in 2006 as well as any
interruptible Monsanto load that was left out of the Tab 5 run.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 6
IIPA 1-17:Please provide a copy or copies of the Company s Jurisdictional
Allocation Model (in a manner similar to that of Exhibit 11 Tabs 1 , 2 and 10) stating the Idaho
Jurisdiction without Monsanto and the Monsanto load as two separate jurisdictions.
IIPA 1-18:Do the values in Exhibit 11 , Tab 10, reflect Idaho demand and energy
requirements by assuming that there are no curtailments/interruptions to Monsanto and/or the
Idaho Irrigators? If curtailments/interruptions are assumed, what is the energy and demand
impact of each for each month of the test year?
IIPA 1-19:Do the values in Exhibit 30, Tab 5, reflect Idaho demand and energy
requirements by assuming that there are no curtailments/interruptions to Monsanto and/or the
Idaho Irrigators? If curtailments/interruptions are assumed, what is the energy and demand
impact of each for each month of the test year?
liP A 1-20:With respect to Exhibit 30, Tab 5, page 7, please answer the following:
A. Are all ofthese values actual? Ifnot, please provide and explanation of how they
were normalized and the workpapers that support the normalization.
B. Please explain the difference between the figures on lines 20 and 21.
C. What level of curtailment of Schedule 10 load is reflected on line 26? Is this level
of curtailment the same as occurred in 2006 or is expected to be incurred in 20017
D. What is the level of curtailment that is reflected in each month on line 26 for the
Irrigation load?
E. Is there any reflection of the dispatchable curtailment of Schedule 10 load
reflected in line 26?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 7
IIPA 1-21:Please explain how any revenue credits to Monsanto are addressed in this
case in relationship to Monsanto s inclusion/exclusion in/from the Idaho Jurisdiction and how
Monsanto is treated in the class cost of service study.
liP A 1-22:For each rate schedule and special contract customer listed in Exhibit 31
for each year since 2003 , please list the amount of energy consumed and the revenue collected.
liP A 1-23:With respect to the Company s 2006 FERC Form 1 page 304., line 40
through page 304., line 27 please explain how these lines are related and what each line
represents.
liP A 1-24:Regarding the loads listed on the 2006 FERC Form 1 page 304., line 40
through page 304., line 27, which of these lines pertain to Schedule 10 and which lines pertain
to some other rate schedule?
IIPA 1-25:Statistics for Monsanto appear to be contained on the 2006 FERC Form
at page 304., line 23. Do the revenues include the interruptibility credit approved by the
Commission in Order 29157? If affirmative, what was the MWh and revenue associated with the
interruptibility credit? If negative, where in the FERC Form 1 is this interruptibility credit
addressed?
liP A 1-26:Mr. Walje indicated on page 15 lines 5-12 of his testimony that Rocky
Mountain Power has successfully delivered its System Average Interruption Frequency Index
(SAIFI) target during 2006 and is on tract to deliver its SAIDI target for 2007. Please provide
what the 2006 and 2007 SAIFI and SAIDI targets are. Also please provide the SAIFI and SAIDI
actual values by jurisdiction and for the system as a whole for each year from 2001 through
2006.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST TO PACIFICORP - 8
IIPA 1-27:For each year from 1995 through 2006 list by FERC account the amount
of Distribution plant that is associated (allocated or directly assigned) with each jurisdiction.
IIPA 1-28:Mr. Walje states on page 17 lines 1-10 of his testimony that the
Company s major rate schedules have only seen a price increase of2% since 1986.
A. Please provide all supporting rate changes by year for each major rate schedule
that supports this contention.
B. Please supply similar information as "" above, over the same timeframe for the
Company s other jurisdictions.
C. Please supply the level of sales to each jurisdiction for each year from 1986 to the
present. Indicate if the data is provided at sales or generation level.
D. Please supply the level of sales for each ofthe major rate schedules in Idaho for
each year since 1986.
E. Please supply by jurisdiction the level of new distribution plant investment for
each year since 1986.
IIPA 1-29:On page 10 lines 18-21 of Mr. McDougal's testimony it is stated that plant
investment has increased $1.8 Billion since the last filing in Idaho. Please indicate
A. Please specify more specifically the timeframe referenced by providing the
beginning and ending month and year to which this reference is being made.
B. Please provide a breakdown of this $1.8 billion into categories such as
Production, Transmission, Distribution, and Other.
C. For the Distribution portion of this $1.8 billion, please provide a breakdown of
these investments by jurisdiction.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 9
liP A 1-30:Beginning on page 11 line 21 ofMr. McDougal's testimony it is stated
that only Residential and Commercial loads were weather normalized.
A. Did the Company weather normalize irrigation load, and if it did in the past, why
did it not do so in this case?
B. Please provide all workpapers that support the weather normalizing adjustment to
monthly revenues in this case.
C. Please provide all workpapers that support the weather normalizing adjustment to
monthly energy in this case.
D. Please provide all workpapers that support the weather normalizing adjustment to
monthly demands in this case.
IIPA 1-31:On page 12 line 16 of Mr. McDougal's testimony it is stated that there was
an increase in revenues of $41 million. Regarding the BP A credit, how much of this $41 million
is associated with each of the following schedules; 1 , 36, and 10?
IIPA 1-32:On page 17 of Mr. McDougal's testimony there is a discussion regarding
Incremental Generation O&M.
A. Does this $653 808 include Fuel and/or A&G expenses?
B. What is the incremental energy associated with this incremental generation?
C. What is the incremental plant investment associated with this incremental
generation?
liP A 1-33:Regarding the Irrigation Load Control Program credit addressed on Page
17 of Mr. McDougal's testimony, please answer the following:
A. Is the revenue credit $996 370?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST TO PACIFICORP -
B. Is this credit allocated within the class cost of service study on a demand or
energy basis?
C. Are these costs allocated to Monsanto?
D. Are any similar credits to Monsanto allocated to the Idaho Irrigation customers
and if so, what is the dollar amount and the basis for the allocation?
liP A 1-34:Regarding the DSM Amortization Removal discussed on page 18 of Mr.
McDougal's testimony, please provide a breakdown of the DSM activities and associated costs.
liP A 1-35:On page 3 of Mr. Widmer s testimony there is an estimate of impacts
different adjustments on the net power cost.
A. What level of irrigation load management was assumed in the Normalized CY
2005 results?
B. What level of irrigation load management was assumed in the Normalized CY
2006 results?
C. Please rerun the Normalized CY 2006 NPC model and assume that participation
of the irrigation load management went to zero. Please provide results in a format
similar to Exhibit 14. Please provide a listing by month of the change in
Irrigation demand and energy that was used as an input to the model.
D. Please rerun the Normalized CY 2006 NPC model and assume that participation
of the irrigation load management doubled. Please provide results in a format
similar to Exhibit 14. Please provide a listing by month ofthe change in
Irrigation demand and energy that was used as an input to the model.
liP A 1-36:On page 8 lines 19-23 of Mr. Widmer s testimony, it is indicated that NPC
are calculated hourly and the retail load and market prices are some of the inputs.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FIRST DATA REQUEST TO PACIFICORP - 11
A. Please provide the hourly system retail load data that was used to develop the
NPC used in this case.
B. Please provide the hourly Idaho retail load data that was used to develop the NPC
used in this case.
C. Please provide the hourly Idaho Irrigation retail load data that was used to
develop the NPC used in this case.
D. Please provide the hourly market price data that was used to develop the NPC
used in this case.
liP A 1-37:Please provide a list of the "scalars" developed by the Company as
addressed On page 19 lines 3-18 ofMr. Widmer s testimony.
liP A 1-38:On page 26 lines 11-13 of Mr. Widmer s testimony it is indicated that
detailed analyses are available on an hourly basis. If the Company has available hourly
Wholesale (sales and purchase) quantities and prices, please supply this data for June-September.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST TO PACIFICORP-
Respectfully submitted this 19th day of July, 2007.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
ERIC L. OLSEN
Attorneys for the
Association, Inc.
gation Pumpers
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
FIRST DATA REQUEST TO P ACIFICORP - 13
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of July, 2007, 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 postage prepaid, e-mail or hand
delivery:
Jean Jewell (original and 3)
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
E-mail: iean.iewellcmpuc.idaho.gov
S. Mail
Data Request Response Center
P acifi Corp
825 NE Multnomah St., Suite 800
Portland, OR 97232
E-mail: datarequest~pacificorp.com
S. Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ID 83276
E-mail: iim.r.smith~monsanto.com
S. Mail
Maurice Brubaker
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise 85387
ki verson~sconsul tbai. com
S. Mail
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tonvcmvankel.net
S. Mail
Idaho Irrigation Pumpers
Association, Inc.
c/o Lynn Tominaga
O. Box 2624
Boise, ID 83701-2624
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INc.'
RESPONSE TO P ACIFICORP'S FIRST DATA REQUEST
Randall C. Budge
Racine, Olson, Nye, Budge
& Bailey, Chtd.
O. Box 1391
Pocatello, Idaho 83204-1391
Hand Delivery
Brian Dickman
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Email: brian.dickman(fYpacificorp.com
S. Mail
Dean Brockbank
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Email: dean.brockbank(fYpacificorp.com
Email: justin.brown(fYpacificorp.com
S. Mail
Tim Buller
Agrium, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
Email: tbuller(fYagrium.com
S. Mail
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
RESPONSE TO PACIFICORP'S FIRST DATA REQUEST