20070813IIPA to PAC 4-1 to 4-16.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTEREDW. 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
Jean Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
Re:PAC-O7-
Dear Jean:
20 I EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]FACSIMILE [phone]
www.racinelaw.net
SENDER'S E-MAIL ADDRESS: elo(!j)racinelaw.net
August 9, 2007
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702
TELEPHONE: (208) 38S-0011
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 108A
COEUR D'ALENE, ID 838 I 4
TELEPHONE: [phone]
ALL OFFICES TOLL FREE(877) 232-8'0'
LOUIS F. RACINE (1917-2005)WIL#,AM D, OL ~"; OF COUNSEL
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Enclosed for filing please find the original and three (3) copies ofIdaho Irrigation Pumpers
Association, Inc.'s Fourth Data Request to Pacificorp.
Enclosurescc: Service list (via e-mail)
Sincerely,~/4k
KATHERINE J. BYBEE
Assistant to Eric Olsen
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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)
PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES
CASE NO. PAC-07-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INe.'s FOURTH DATA REQUEST
TO P ACIFICORP
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and through its
attorneys, hereby submits this Fourth Data Request to Pacificorp dba Rocky Mountain Power
pursuant to Rule 225 of the Idaho Public Utility Commission s Rules of Procedure, IDAPA
31.01.01 , as follows:
IIPA 4-1: Please provide electronically a listing of the most recent data available of
all dates, times, and expected magnitude of all dispatched curtailments when Idaho irrigation
load was curtailed under the pilot program of Schedule 72A.
lIP A 4-2: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I, near the bottom of page ES-l 0
there is a reference to the fact that participant incentives are currently capped at approximately
50% of "incremental measure costs" of Class 2 DSM resources.
a. Please explain what "incremental measure costs" are and give an example.
b. If "incremental measure costs" are not an appropriate term, please explain what the 50%
is related to.
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
ACIFICORP -
c. What is the basis for the 50% cap?
d. Is there a related cap applied to Class 1 or 3 DSM resources? Please explain the
relationship between such a cap for Class 1 and 3 resources compared to Class 2.
lIP A 4-3: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 12 that PacifiCorp
provided "2000-2005 hourly profiles by rate class . Please provide an electronic copy of this
information.
lIP A 4-4: On July 11 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 12 that PacifiCorp
provided cost information regarding "PacifiCorp program experience . Please provide an
electronic copy of this information.
lIP A 4-5: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 12 that PacifiCorp provided
cost information regarding "the system hourly shape for 2006, Figure 3. . .
a. Was this "system" load data for Retail only, or did it include Retail and Wholesale Sales?
b. If this was for Retail load only, please provide an electronic copy of this load data
specifying date, hour, and load.
c. If this was for Retail plus Wholesale sales, please provide an electronic copy of this load
data broken out between Retail and Wholesale sales specifying date, hour, and load.
lIP A 4-6: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 13 there is a statement at
the bottom of the page that loads based on the highest 40 hours for the winter and summer were
estimated and then spread over end-use hourly load profiles and calibrated. Please provide a
detailed example of what was done, based upon the Idaho Irrigation load.
lIP A 4-7: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 17 there is a statement that
Rocky Mountain Power s avoided cost of capacity is $98.
a. Is this value of$98 based on a "kW-year" basis? Please explain what these units
represent.
b. Is this capacity value only related to the peak hour ofthe year, the highest 40 hours of the
year, the peak hour of each month, etc.
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.S FOURTH DATA REQUESTS TO
P ACIFICORP - 2
c. Please provide all calculations and studies used to develop this value of$98.
IIPA 4-8: On July 11 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 22 the levelized cost for
irrigation in RMP is listed at $47.
a. Please provide a breakdown of the dollars associated with each component that makes up
this value (i.e. installation, administration, incentives, etc.
b. If this cost is based upon both Schedule 72 and 72A, please provide a breakdown of the
dollars associated with each component that makes up this $47 value based upon
Schedule 72 and 72A separately (i.e. installation, administration, incentives, etc.
IIPA 4-9: On July 11 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 22 the levelized cost for
Residential DLC AC in RMP is listed at $93. Please provide a breakdown ofthe dollars
associated with each component that makes up this value (i.e. installation, administration
incentives, etc.
IIPA 4-10: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 24 the levelized cost for
Residential TOU in RMP is listed at $166.
a. Please provide a breakdown of the dollars associated with each component that makes up
this value (i.e. installation, administration, incentives, etc.
b. Ifthis price reflects the cost of Schedule 36 in Idaho, what adjustments should be made to
get these costs under the $98 kW-year figure in the study?
c. The Company is proposing to give Schedule 36 the "standard" rate increase in this case.
This suggests that the Company does not feel that the rate-of-return for this customer
group is that far from normal. Given this, on what basis does the July 11 th report come
up with such different conclusions?
d. If the Company were going to change Schedule 36 to be more in line with the July 11 th
study recommendation, what rates (presumably a three tiered rate) would it suggest?
lIP A 4-11: On July 11, 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 36 it states that 100 MW of
irrigation load has been contracted for load management, but "less than half are available at any
time due to the alternating schedules of program participants." It is also stated that: "only 75% of
the load will be available. Please supply in electronic format, any data upon which these
statements are based.
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
ACIFICORP - 3
lIP A 4-12: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume I page 46 it states that newer TOU
programs tend to have a differential of greater than 10 cents /kWh. IfPacifiCorp were to revise
its Schedule 36 in order to be compatible with these newer TOU programs, what rates would be
appropriate for winter and summer usage?
lIP A 13: On July 11 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume II page B-13 there is a listing of
information for the Irrigation demand side management program.
e. How do these costs and assumptions compare with those recently experienced regarding
the Company s experience with Schedule 72 in Idaho?
f. How do these costs and assumptions compare with those recently experienced regarding
the Company s experience with Schedule 72A in Idaho?
g. What is contained in the $10 figure for "Incentives (annual costs per participating kW)?
lIP A 4-14: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. With respect to that report, in Volume II page B-24 there is a listing of
information for the Residential TOU program.
a. The incremental cost of meters is listed as $100. What is the maximum load a meter of
this cost is designed to carry?
b. Will this meter handle 3 phase power?
c. Why does "this analysis assume revenue neutrality for the utility" when some customers
will accrue bill savings?
d. How should the rates for Schedule 36 be designed in order to be revenue neutral for the
Company and show a differential of 10 cents or more per kWh?
lIP A 15: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. In addition to the two volume report, there was some supplemental
material provided. As a part ofthat material there was a Figure 29 that related to an Irrigation
forecast for Idaho between 2006 and 2027. It appears that the 2006 value for Idaho Irrigators at
generation was less than 72 aMW. What was the actual value for 2006? What loss factor was
assumed?
lIP A 4-16: On July 11 , 2007 there was a report issued by PacifiCorp assessing
demand side resources. In addition to the two volume report, there was some supplemental
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
ACIFICORP - 4
material provided. As a part ofthat material there was a Figure 42 that related to Idaho Single
Family Heating load. Is this data for Schedule 1 , or both?
Respectfully submitted this 8th day of August, 2007.
ERIC L. OLSEN
Attorneys for the Idaho Irrigation Pumpers
Association, Inc.
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA REQUESTS TO
ACIFICORP - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of August, 2007, I served a true, correct
and complete copy of the Idaho Irrigation Pumpers Association, Inc.'s Second 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.iewell(Zi),puc.idaho.gov
S. Mail and
via E-mail
Data Request Response Center
PacifiCorp
825 NE Multnomah St., Suite 800
Portland, OR 97232
E-mail: datarequest~pacificorp.com
via E-mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ID 83276
E-mail: iim.r.smith~monsanto.com
via E-mail
Maurice Brubaker
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, ill 85387
ki verson~sconsul tbai. com
via E-mail
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony~yanke1.net
via E-mail
Idaho Irrigation Pumpers
Association, Inc.
c/o Lynn Tominaga
O. Box 2624
Boise, ID 83701-2624
E-mail: lvnn tominaga~hotmail.com
via E-mail
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA
REQUEST TO P ACIFICORP - 6
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~pacificorp.com
via E-mail
Dean Brockbank
Justin Brown
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: dean.brockbank~pacificorp.com
E-mail: justin.brown~pacificorp.com
via E-mail
Tim Buller
Agrium, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbuller~agrium.com
via E-mail
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
608 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
E-mail: cew~givenspurslev.com
via E-mail
Dennis Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S., Ste. 250
Salem, OR 97302
E-mail: dpeseau~excite.com
via E-mail
IDAHO IRRIGATION PUMPERS ASSOCIATION INC.'S FOURTH DATA
REQUEST TO P ACIFICORP - 7