20070822PAC to IIPA 1-1 to 1-38 with exceptions.pdf

~!~OUNTAIN 201 South Main, Suite 2300
Salt Lake City, Utah 84111
RECEIVED
August 21 2007 ZOUl AUG 22 j A 10:
Eric Olsen UTIL
;:-
r~~::;d~a~1 ~j\~S!ONIdaho Irrigation Pumpers Assoc
Racine, Olsen, Nye, Budge & Bailey
201 East Center
Pocatello, ID 83204
RE:PAC-07-
IIPA Set 1 (1-38)
Please find enclosed Rocky Mountain Power s Responses to IIPA 1st Set Data Requests
1.1 -1.38 with the exception of 1.12, 1.13 , 1.25, 1.26 and 1.37. Provided on the enclosed
CD are Attachments IIPA 1.1-(1-2), 1.4, 1.6 1.7 1.10 1.11 , 1.15, 1.17, 1.22, 1.27, 1.28
-(A-E), 1.30 -(b, d), 1.32, 1.34 -(A-B), 1.36 and 1.38. Responses to 1.12, 1.13 , 1.25
1.26 and 1.3 7 are in process and will be provided when available.
If you have any questions, please feel free to call me at [phone].
Sincerely,
7Xdvn
M-c fI;p
Brian Dickman, Manager
Regulation
Enclosures
PAC-07-0S/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.
liP A Data Request 1.
Please answer the following with respect to information contained on McDougal'
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?
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 of the 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.
Response to lIP A Data Request 1.1
A. Yes. The top section on page 10.12 (Metered Loads-CP) and page 10.
(Metered Loads-MWh) are actual demand and energy level values. They
form the starting point for the jurisdiction load calculation.
B. Yes. Starting with the loads discussed in part (a) above, the Company has
made various demand and energy load adjustments for Monsanto to
account for curtailments/interruptions. These adjustments can be seen in
the second and fourth sections on pages 10.12 and 10.13. The second
section is entitled (adjustments for curtailments, buy-throughs and load no
longer served) and the fourth section entitled (adjustments for ancillary
contracts including reserves).
C. No, they are not simply weather related adjustments. Please see
Attachment IIP A 1.1 -1 for specific details regarding each adjustment on
pages 10.12 and 10.13. Demand related temperature adjustments can be
found on page 10., lines 133 through 149. Energy related temperature
adjustments can be found on page 10., lines 304 through 320.
D. Yes. The System Capacity (SC) allocation factor calculation can be found
on Exhibit 13 , Page 10.14, Line 31. The system energy (SE) allocation
factor calculation can be found on Exhibit 13, Page 10.15, Line 60.
P AC- E-07 -05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
E. The adjustments listed on pages 10.16 and 10.20 are used to calculate
allocation factors for the purpose of determining the Idaho revenue
requirement amount in total but not by rate schedule or special contract.
Revenue requirement by rate schedule is calculated in the cost of service
study.
F. An electronic copy of Tab 10 can be located in the JAM model, Tab
Factors" and Attachment IIP A 1.1 -1. An electronic copy of the RAM
and JAM models are provided as Attachment IIP A 1.1 -2. A hard copy of
Tab 10 is provided as the direct testimony of Steven R. McDougal, Exhibit
, and Tab 10.
(Steven R. McDougal prepared this response, is the recordholder, and is
expected to sponsor this response at hearing. Please contact Brian Dickman at
801-220-4975 to discuss this response.
ID AH
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.1-(1-
ON THE ENCLOSED CD
P AC-07-05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 1.2
Please answer the following with respect to information contained on Tucker
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 ofthose 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? If from load research data, over what timeframe was the data
collected?
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? If this data is weather
normalized, please provide an electronic as well as hard copy of all
workpapers used to support this normalization.
, Response to lIP A Data Request 1.2
A. Yes, the times listed on page 6 are the actual time of system coincident peak
during each month of the test period.
B. The times listed are in Mountain Prevailing Time.
C. Please refer to the explanation provided in the company s response to IIP A
Data Request 1.3.
D. 1) Load Research sample data is used to estimate peaks for schedules 1 6 (56),
, 23 (73), and 36. Historical Load Research data is used to estimate peaks
for schedules 19 and 35. Schedules 7, 11, 12 and 104 are calculated based on
data from a prior year. All other schedules represent census or special
contract customers.
2) Load Research sample data used in this filing was collected over the period
January 1 , 2006 through December 31 , 2006.
E. Curtailment/interruption only impacts the irrigation class and Monsanto; there
are no impacts to the Residential, Commercial, and Public Street and Highway
lighting classes. Curtailment/interruption for Monsanto is identified in
Tucker s Exhibit 30; Tab 5 "Cost of Service Allocation Factors " line 21.
Scheduled irrigation impacts are provided in the "Irrigation Load Control
Program" report provided as Attachment IIPA 1.15.
PAC-07-05/Rocky Mountain Power
August 21 , 2007
lIP A 1 st Set Data Request 1.
F. The peaks presented on pages 12 and 13 ofthe exhibit have not been weather
normalized.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
PAC-07-05/Rocky Mountain Power
August 21 , 2007
IIPA 1st Set Data Request 1.3
lIP A Data Request 1.3
Please answer the following with respect to information contained on McDougal'
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.
additional data is required to reconcile all of the Ex. 11 , Tab 10, page
10.14 figures, with Ex. 30, Tab 5, page 6, 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.
Response to lIP A Data Request 1.3
The state load data that is used for jurisdictional allocation will not reconcile to
the sum of the class loads used in the cost of service study because they are
calculated differently. Because the metering points and the treatment of losses are
different between the two calculations, the numbers will not match.
For an historical test period, the hour of system peak is based on actual metered
load data at specific metering points. For each hour of the month, all inputs into
the system such as company owned generation, purchases or interchanges are
measured. From that measurement, all deliveries outside the system or to non-
retail customers are deducted to arrive at total retail load. The coincident peak is
the hour of each month during which the combined demand of all retail customers
is the greatest.
Each state s contribution to hourly loads is determined in essentially the same
way. Each state s hourly load consists of the company owned generation within
that state, purchases or interchanges delivered into the state, plus metered flows of
energy into the state from other parts of the company s system. From that
measurement, metered and/or scheduled energy flows out of the state and
deliveries to non-retail customers are deducted to arrive at that state s retail load.
Class peak load data is either measured or estimated at the sales level (at the
customer meter) and then adjusted up to the input (generation) level by the use of
historical loss factors.
The same differences occur in measuring jurisdictional and class energy usage.
Jurisdictional energy usage is measured at the same metering points as the
system peak data. Class energy usage is based on billed energy at the customer
meter and grossed up to the input level by the use of historical loss factors.
P AC- E-07 -OS/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.3
A. While the values do not match on an individual month basis, the sum of the 12
coincident peak values in each of the two exhibits is similar. A comparison of
Exhibit 11 , Tab 10, page 10.14, line 23, (5 784.0 total MWs), with the total
from Exhibit. 30; Tab 5, page 6, line 35, (5,873.226 MWs), shows a difference
of approximately 1.5%.
B. While the values do not match on an individual month basis, the sum of the 12
coincident peak values in each of the two exhibits is similar. A comparison of
Exhibit 11 , TablO, page 10., line 52 (3 689,647 total MWhs), with the total
from Exhibit 30, Tab 5, page 16 (3 596,569 total MWhs), shows a difference
of approximately 2.6%.
(Steven R. McDougal and Mark E. Tucker prepared this response, are the
recordholders, and are expected to sponsor this response at hearing. Please
contact Brian Dickman at 801-220-4975 to discuss this response.
P AC-07-05/Rocky Mountain Power
August 21 , 2007
lIP A 1 st Set Data Request 1.4
lIP A Data Request 1.4
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;
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.
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.
Response to lIP A Data Request 1.4
Load research estimates have been developed for the calendar year 2006 test
period. Equivalent data for prior periods is not reasonably available. Also, load
research studies were not installed on Rates 019, and 035 during the test period.
Class load estimates for these rates were obtained using historical data. Street
lighting was estimated using prior year data. Please refer to Attachment IIP A 1.4
for sample data collected for each sample customer from January 2006 to
December 2006.
A. Customer identification number is contained in column A of each tab. Please
refer to Attachment IIP A 1.4.
B. Customer rate schedule is contained in column C of each tab. Please refer to
Attachment IIPA 1.4.
C. Strata to which each customer belongs are contained in column D of each tab.
Please refer to Attachment IIP A 1.4.
D. Raw hourly usage data (i.e., unadjusted, simply the data originally gathered
for each sample) is contained in columns E - AB of each tab. Please refer
Attachment IIP A 1.4.
PAC-07-05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.4
E. Hourly loss factors for each sampled rate schedule are detailed below.Rate 001 Secondary
Rate 036 Secondary
Rate 006 Secondary
Rate 023 Secondary
Rate 0 I 0 Secondary
Secondary loss factor 14.668%
Primary loss factor 10.418%
Transmission loss factor 5.697%
F. One adjustment is made to the load research hourly data prior to input into the
cost of service study. Sample data is adjusted on a monthly basis to match the
kWh energy figures that have been adjusted by the regulation department.
Please refer to Attachment IIPA 1.7 for a comparison of the estimated kWh
energy as derived from the sample against the actual kWh energy figures that
have been adjusted by the ~egulation department. Factors developed and
shown in Attachment IIP A 1.7 are applied to every hour for each month for
each rate.
G. Formulas as requested.
For any given time interval the load research estimate
(y)
is equal to the
sum of the weighted stratum averages (WnYh).
=L WhYh
Monthly billing adjustments are derived using the following formula:
Y m=(Y*(Y m/Ym (Y a!Ya
Where Y= adjusted load research estimate
Where y= unadjusted load research estimate
Where Y m= billed calendar monthly customer energy
Where Ya = regulatory annual adjusted customer energy
Strata weight factors and populations are detailed for each load research
sample in the header of Attachment lIP A 1.4.
(Scott Thornton prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 21 , 2007
lIP A 1 st Set Data Request 1.
lIP A Data Request 1.5
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.
Response to lIP A Data Request 1.5
A similar report does not exist for the Idaho jurisdiction. The 2002 Load
Research Status Report was developed at the request of the Public Service
Commission of Utah under the direction of the Utah Division of Public Utilities.
The report detailed load research activities in Utah and therefore did not relate to
Idaho.
(Scott Thornton prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
PAC-O7-05/Rocky Mountain Power
August 21 , 2007
IIP A 1st Set Data Request 1.6
lIP A Data Request 1.6
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;
B. The summation of the (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 of load); and
Any information such as difference in measuring techniques or timing of the data
that needs to be addressed when comparing the above data.
Response to liP A Data Request 1.6
A. Please refer to Attachment lIP A 1.6 for the "Operations Stat" or border
load for Idaho. It is detailed for each hour of the test period in Attachment
lIP A 1.6 in column C. Equivalent data for prior periods is not reasonably
available.
B. Please refer to Attachment IIP A 1.6 for hourly data for all rate classes in
Idaho.
C. Please refer to Attachment IIP A 1.6 for 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, in columns D, E, S
andT.
D. Please refer to Attachment IIP A 1.6. Loads that are contained in "
above but are not addressed in "" above include Street Lighting loads
detailed in columns 0, P, Q, and R.
E. When comparing Idaho border loads against actual measured loads correct
loss factors need to be applied. Please refer to Attachment IIP A 1.6, line
, columns D - T for loss factors by rate schedules. It should be noted that
load research estimates are, in fact, estimates.
PAC-07-0S/Rocky Mountain Power
August 21,2007
lIP A 1 st Set Data Request 1.
(Scott Thornton prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
P AC-07-05/Rocky Mountain Power
August 21 , 2007
UP A 1 st Set Data Request 1.
lIP A Data Request 1.7
Please provide for each month from January 2004 forward a copy of the results of
all checks that the Company makes regarding how well the load research data
reflects the actual population usage.
Response to liP A Data Request 1.7
Data detailing the monthly comparison of load research sample estimates to billed
population usage adjusted by the regulation department is provided as Attachment
IIP A 1.7. The comparisons are provided for January 2006 - December 2006.
Load research estimates for the months preceding and subsequent to this date
range are not readily available.
(Scott Thornton prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
P AC- E-O7 -OS/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 1.8
Please provide a copy of any summary reports that have been produced between
January 2004 and the present regarding Idaho Load Research data.
Response to lIP A Data Request 1.8
Load research summary reports are no longer routinely generated by the load
research computer systems and therefore are not available.
(Scott Thornton prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
PAC-07-0S/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 1.9
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.
Response to lIP A Data Request 1.9
The filing uses weather normalized data for developing allocation factors, but
does not use weather normalized information for the class cost-of-service study.
The data at class level is not currently robust enough to measure correct weather
normalization adjustments.
(Scott Thornton prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
P AC- E-07 -05/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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.
Response to lIP A Data Request 1.
This represents a temperature adjustment used in developing jurisdictional cost
allocation factors. The coincident peak data used in the cost of service study is
not normalized for temperature and so this adjustment does not flow through to
Exhibit 30. Supporting material is provided in Attachment IIP A 1.10.
(Reed Davis prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-O7-05/Rocky Mountain Power
August 21 , 2007
IIPA 1 st Set Data Request 1.11
lIP A Data Request 1.
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 PAC-05-01.
Response to IIPA Data Request 1.
a. Please refer to attachment IIP AI-II A.txt
b. Please refer to attachment IIP AI-II B.txt
c. Please refer to attachments IIPA 1-11 C, D - Jan 2004 - Dee 2005.txt, IIPA 1-
, D - Jan 2006 - Jun 2007.txt
d. Please refer to attachments IIPA 1-11 C, D - Jan 2004 - Dee 200S.txt, IIPA 1-
, D - Jan 2006 - Jun 2007.txt
e. Please refer to attachment IIPA 1-11 E, F.txt
f. Please refer to attachment IIP AI-II E, F. txt
g. Please refer to attachment IIP AI-II G. txt
h. Please refer to attachment IIP AI-II H.txt
1. Please refer to attachment IIP AI-IlL txt
j.
Please refer to CCS 2.
k. Please refer to attachment IIP AI-II K.xls
1. Please refer to attachment IIP AI-II Ltxt
m. Please refer to attachment IIPA 1-11 M.txt
n. Please refer to attachments IIPA 1-11 N Jan 2004 - Dee 2005.txt, IIPA 1-11 N Jan
2006 - Jun 2007.txt
o. PleaserefertoattachmentIIPA 1-11 O.txt
p. Please refer to attachment IIPA 1-11 P, Q.txt
q. Please refer to attachment IIPA 1-11 P, Q.txt
r. Please refer to attachment IIPA 1-11 R.txt
s. Please refer to attachment IIPA 1-11 S.txt
t. Please refer to attachment IIPA 1-11 T.txt
u. Please refer to attachment IIP AI-II U .xls
v. Please refer to attachment IIP A 1-11 V.xls
w. The company is unable to measure losses attributable to wholesale sales.
x. Please subtract the hourly values in IIP AI-II Y and IIP AI-II Z from IIP AI-
y. Please refer to attachment IIPA 1-11 YZ.xls
z. Please refer to attachment IIP AI-II YZ.xls
aa. Please refer to response to IIP AI-II J.
bb. Please refer to response to IIP AI-II J.
cc. Please refer to response to IIP AI-II J.
dd. For the period 2004 through 2006, the company had the following firm special
contract customers: Idaho 2, Utah 2, Total 4
ee. For the period 2004 through 2006, the company had the following interruptible
special contract customers: Idaho 1 , Utah 2, Total 3
PAC-07-05/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.
Note that the Idaho customer listed here is also listed in dd.
(It has not been determined who will sponsor this response at hearing.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-07-0S/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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.
Response to lIP A Data Request 1.
The weather adjustment factors are based on changing factor values over different
temperature ranges. That is, the regression equation that is used in the weather
normalization has differing factors for the cooling (summer) season between the
temperatures of 62 degrees and 65 degrees, between 65 degrees and 94 degrees
and for temperatures greater than 94 degrees. Since the temperature rarely is
above 94 degrees for the months of April, May, and September, then the weather
adjustment factors for these months would be different from the weather
adjustment factors for the months of July and August where it is more likely to
have temperatures in excess of 94 degrees.
Similarly for the heating (winter) season, there are differing factors for the
temperature ranges of between 65 degrees and 57 degrees, of between 57 degrees
and 35 degrees, and for temperatures less than 35 degrees. Since it is somewhat
unlikely for the temperature to be less than 35 degrees during the latter part of
April and during the beginning part of October, then the adjustment factors for
these months would differ from the adjustment factors for December and January
where it is more likely to have temperatures below 35 degrees.
(Mark T. Widmer prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
PAC-07-05/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 1.
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.
Response to liP A Data Request 1.15
Actual weather normalized hourly retail loads from 2006 are used to calculate the
pro- forma 2007 net power costs. The actual loads include the actual Idaho
irrigation curtailments and also include any incremental loads caused by irrigators
making up for the curtailment once the curtailment restrictions are removed. The
company has not prepared hourly load information with Idaho irrigation
curtailments and load shifting added back into the actual loads.
If requested, the company will make available a GRID computer which will allow
the Idaho Irrigation Pumpers Association (IIP A) to prepare this study using its
own assumptions about hourly load curtailments. Provided as Attachment IIP
15 is the Schedule 72 Idaho Irrigation Load Control 2006 Credit Rider Initiative
Final Report to assist IIP A in preparing this study.
(Mark T. Widmer prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
P AC-07-0S/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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 ofthe Tab 5 run.
Response to liP A Data Request 1.16
As stated in the company s response to IIPA Data Request 1., actual weather
normalized hourly retail loads from 2006 were used to make the pro-forma 2007
net power cost study. Both the actual hourly Idaho irrigation curtailments and
Monsanto curtailments are included in actual loads. To complete the requested
study, the actual hourly irrigation curtailments would need to be added back into
the actual hourly loads. The company has not prepared an hourly load forecast
with Monsanto and Idaho irrigation curtailments and load shifting added back into
the actual loads.
If requested, the company will make available a GRID computer which will allow
the Idaho Irrigation Pumpers Association to prepare this study using its own
assumptions about hourly load curtailments.
(Mark T. Widmer prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
PAC-D7-0S/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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.
Response to lIP A Data Request 1.17
Attachment IIP A 1.17 is the Jurisdictional Allocation Model with Monsanto
load separate from Idaho. To create a separate jurisdiction for Monsanto the
company utilized the old Montana section in the model. The model is saved with
Idaho results excluding Monsanto s load. To see Monsanto, click on the
Variable" tab under the "State" drop-down box, select Montana, and then push
the F9 key to recalculate the results.
By simply isolating Monsanto s load only, the allocated costs are redistributed
between all other Idaho customers and Monsanto. This study does not attempt to
split Idaho situs costs and assign the appropriate share to Monsanto as occurs in
the cost of service study. The main situs components are current and deferred
taxes, and general plant related costs. The Jurisdictional Allocation Model was
designed to allocate costs to states; the cost of service model is at a lower level of
detail to appropriately split these costs between customer classes.
(Steven R. McDougal prepared this response, is the recordholder, and is expected
to sponsor this response at hearing. Please contact Brian Dickman at 801-220-
4975 to discuss this response.
IDAHO
P AC-O7-
. ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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?
Response to lIP A Data Request 1.
Consistent with the Revised Protocol methodology, the values in Exhibit 11 , Tab
, reflect Idaho demand and energy requirements by assuming that there are no
curtailments/interruptions for Monsanto. Monsanto is treated as a special contract
customer with identifiable ancillary services components. As such, any
curtailments and/or interruptions of Monsanto s service are added back to the
actual Idaho jurisdictional demand and energy to compute the jurisdictional
allocation factors. Attachment IIP A 1.1 provides detail for the demand and
energy impacts of Monsanto curtailment during each month of the test year.
The values in Exhibit 11 , Tab 10, reflect Idaho demand and energy requirements
assuming there are curtailments to the irrigators. The reduction in load is
reflected in the actual load experienced during 2006. Details regarding the
irrigator curtailments during 2006 are provided in Attachment IIP A 1.15.
(Steven R. McDougal prepared this response, is the recordholder, and is expected
to sponsor this response at hearing. Please contact Brian Dickman at 801-220-
4975 to discuss this response.
PAC-07-05/Rocky Mountain Power
August 21 2007
IIP A I st Set Data Request 1.
lIP A Data Request 1.
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?
Response to lIP A Data Request 1.19
Consistent with Revised Protocol methodology, Monsanto is treated as a special
contract customer with identifiable ancillary services components. As such, any
curtailments and/or interruptions of Monsanto s service are added back to the
demand and energy allocation factors as if the curtailment did not occur.
Appendix D of the Revised Protocol states:
When interruptions of a Special Contract customer s service
occur, the host jurisdiction s Load-Based Dynamic Allocation
Factors and the retail service revenue are calculated as though
the interruption did not occur.
In the allocation factor calculations shown in Exhibit 30, Tab 5 , Monsanto is
shown as Contract 2. Two lines are shown for Contract 2; the first line represents
Monsanto s metered demand or energy usage, while the second line shows any
interruptions or curtailments that are added back in calculating the allocation
factors. Monsanto is the only customer in Idaho that is considered to have
identifiable ancillary service components.
Consistent with Revised Protocol, to the extent irrigators' loads are reduced as the
result of load control programs, the reduction in load is reflected in the load-based
allocation factors. No further adjustments are made. Details regarding the
irrigator curtailments during 2006 are provided in Attachment IIP A 1.15.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
P AC-O7-05/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.20
lIP A Data Request 1.20
With respect to Exhibit 30, Tab 5 , page 7, please answer the following:
A. Are all of these values actual? If not, 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?
this level of curtailment the same as occurred in 2006 or is expected to be
incurred in 20077
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?
Response to liP A Data Request 1.20
A. The loads presented on page 7 of the exhibit represent estimates of actual loads
based on sample data. No normalization ofthe data has occurred.
B. Line 20 shows the metered demand at the time of system peak each month for
customer Contract 2. Line 21 shows the amount of demand that was
interrupted for this customer in each month. Please see the response to 1.
for a detailed description of the treatment of interruptible demand.
C. The coincident peak loads shown in the cost of service study are based on the
results of the load research sample data. They provide an estimate of the load
of the entire irrigation class. An estimate of the level of curtailment of
Schedule 10 load is not available. The load control program is very well
represented within the load research sample. During the 2006 test period, 931
irrigation sites participated in the load control program, or about 20% of the
total class. Among the sites used in the load research sample, approximately
33% participated in the load control program. All load data is based on the
2006 test period; no estimates for 2007 are included.
D. Please refer to the response to part C above.
E. The dispatchable irrigation load control program started in 2007 and is
therefore not reflected in the historic test year.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
P AC-07-05/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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.
Response to IIPA Data Request 1.
Revenue credits are related to sales for resale and other electric revenue, and are
allocated to the Monsanto jurisdiction in the same manner as they are allocated to
Monsanto and all other classes in the cost of service study based on Monsanto
energy usage and contribution to coincident peak. Payments to Monsanto for
ancillary services are treated as purchased power expense which is system
allocated on the system generation factor. Monsanto s retail revenue, energy and
demand are treated as firm and are assigned to Idaho, similar to all other Idaho
retail customers. In the company s response to lIP A Data Request 1.
Monsanto s retail revenue was direct assigned to the Monsanto jurisdiction and
the system credits were allocated based on Monsanto s contribution to system
energy and demand.
(Steven R. McDougal prepared this response, is the record holder, and is expected
to sponsor this response at hearing. Please contact Brian Dickman at 801-220-
4975 to discuss this response.
P AC-07-0S/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 1.22
F or 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.
Response to lIP A Data Request 1.22
Please refer to Attachment lIP A 1.22.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 21 2007
IIP A 1st Set Data Request 1.23
lIP A Data Request 1.23
With respect to the Company s 2006 FERC Form 1 page 304., line 40 through
page 304.15, line 27 please explain how these lines are related and what each line
represents.
Response to lIP A Data Request 1.
Following are the irrigation rate schedules that were in effect for 2006.
Line
Page Number Rate Schedule Description
304.07 APSA01 OL BPA Credit for Irrigation & Pumping/Large Load
304.07APSA010L Irrigation & Pumping/Large Load
304.07 APSA01 OS BPA Credit for Irrigation & Pumping/Small Load
304.07 APSA01 OS Irrigation & Pumping/Small Load
304.07 APSAL 1 Irrigation & Pumping/Large Load - Non BPA
304.07APSAS10X Irrigation & Pumping/Small Load - Non BPA
304.07 APSC01 OL BPA Credit for Irrigation & Pumping/Large Load
304.07APSC010L Irrigation & Pumping/Large Load
304.07 APSC01 OS Irrigation & Pumping/Small Load
304.07APSCL 10X Irrigation & Pumping/Large Load - Non BPA
304.07 APSCS 1 Irrigation & Pumping/Small Load - Non BPA
304.07APSVCNLL Canal Company - Large Load
304.07APSVCNLL BPA Credit for Canal Company - Large Load
304.07APSVCNLS Canal Company - Small Load
304.07 APSVCNLS BPA Credit for Canal Company - Small Load
304.07BPADEBIT Idaho BPA Adjustment Fees
304.07LNXOO015 Line Extension
304.07LNXOO040 Line Extension
304.07LNXO0107 Line Extension
304.07LNXO031 0 Line Extension
304.07LNXQO312 Line Extension
BPA Credit for Irrigation & Pumping/Large Load/No Seasonal
304.07 APSN01 OL Discount
304.07 APSN01 OL Irrigation & Pumping/Large Load/No Seasonal Discount
BPA Credit for Irrigation & Pumping/Small Load/No Seasonal
304.07 APSN01 OS Discount
304.07APSN010S Irrigation & Pumping/Small Load/No Seasonal Discount
304.07APSNS10X Irrigation & Pumping/Small Load/No Seasonal Discount - Non BPA
304.BPA Credit Balancing Account
304.Unbilled Revenue Estimate Adjustment
(Reed C. Davis prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
P AC-07 -05/Rocky Mountain Power
August 21 , 2007
lIP A 1st Set Data Request 1.
lIP A Data Request 1.24
Regarding the loads listed on the 2006 FERC Form 1 page 304., line 40
through page 304.15 , line 27, which of these lines pertain to Schedule 10 and
which lines pertain to some other rate schedule?
Response to lIP A Data Request 1.
Page
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
304.
Line
Number
Schedule
10?
(Reed C. Davis prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
PAC-07-05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
liP A Data Request 1.
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.
Response to liP A Data Request 1.
The distribution plant from 1995 to 2006 is provided as Attachment IIP A 1.
Note: From 1995 to 1999 the distribution plant is based on calendar year end
results. In 2000, the company changed to fiscal years ending March 31. The next
reporting period used was 12 months ended March 31 2001. From March 2001
to March 2005, the distribution plant balances are as of fiscal year end. Rocky
Mountain Power is again using calendar year results at this time and the latest
year of distribution plant reported is as of year-end December 2006.
(Steve McDougal prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.28
lIP A Data Request 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 of 2% 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 of the 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.
Response to lIP A Data Request 1.28
A. Mr. Walje s testimony refers to the Company s overall base rates for the
major rate schedule customers (i., excluding special contracts) in Idaho.
Attachment IIP A 1.28 A shows the calculation used in making this statement.
It shows percentage increases in overall base rates indexed back to 1986. Line
, Proposed GRC, shows the change that would occur if the full increase
proposed in this case is approved. Column I shows the change in the National
Consumer Price Index over the same period of time.
B. Attachment IIP A 1.28 B shows similar tables for the Company s five other
jurisdictions.
C. See Attachment IIP A 1.28 C for sales information.
D. See Attachment lIP A 1.28 D for major customer class sales.
E. See Attachment IIP A 1.28 E for distribution plant additions.
(Mark E. Tucker is expected to sponsor the responses to parts A and B at hearing.
It has not been determined who will sponsor the responses to parts C, D, and E at
hearing.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
TT A CHMENT lIP A 1.28 -(A-
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 21 2007
lIPA 1st Set Data Request 1.
lIP A Data Request 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.
Response to lIP A Data Request 1.29
A. The timeframe referenced is calendar years 2006 and 2007.
B. Please refer to the direct testimony of Steven R. McDougal, Exhibit 11
Page 8.8.1 , columns entitled "Jan06 to Dec06 Plant Additions" and "Jan07
to Dec07 Plant additions.
C. Please refer to the direct testimony of Steven R. McDougal, Exhibit 11
Page 8., rows in section entitled "Distribution plant."
(Steven R. McDougal prepared this response, is the recordholder, and is
expected to sponsor this response at hearing. Please contact Brian Dickman at
801-220-4975 to discuss this response.
PAC-E.:07-05/Rocky Mountain Power
August 21 2007
lIP A 1 st Set Data Request 1.
liP A Data Request 1.30
Beginning on page 11 line 21 of Mr. 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.
Response to IIPA Data Request 1.
A. The company does not weather normalize the irrigation class and has not done
so in the past.
B. See Attachment IIPA 1-30 b.
C. This infonnation is being gathered and will be provided as a Supplemental
Response when completed.
D. See Attachment IIPA 1-30 d.
(It has not been determined who will sponsor this response at hearing.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.30 -(b, d)
ON THE ENCLOSED CD
P AC-07 -O5/Rocky Mountain Power
August 21 , 2007
lIP A 1 st Set Data Request 1.31
lIP A Data Request 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?
Response to lIP A Data Request 1.
The BPA credit for Schedule 1 is $7 085 457, for Schedule 36 is $6 016 464 and
for Schedule 10 is $17,553 537.
These credit amounts are included in Exhibit No. 11 , accompanying the Direct
Testimony of Steven R. McDougal, entitled Idaho Results of Operations Report
December 2006. Section 3 Revenue Adjustments on pages 3.2 contain
information on Schedules 1 and 36 and pages 3.1.3 contain information on
Schedule 10 under the column headings BP A Credit Adjustment.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
P AC-07-05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.32
lIP A Data Request 1.
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?
Response to lIP A Data Request 1.32
A. The O&M costs for incremental generation of$653 808 do not include fuel or
A&G expenses.
B. Please refer to the direct testimony of Steven R. McDougal, Exhibit 13. For
the Blundell bottoming cycle which is not listed on Exhibit 13, the
incremental capacity is 11 MW. Incremental generation is provided as
Attachment IIP A 1.32.
C. Please refer to the direct testimony of Steven R. McDougal, Exhibit 13. For
the Blundell bottoming cycle which is not listed on Exhibit 13, the
incremental plant investment is $27 700 643.
(Steven R. McDougal prepared this response, is the recordholder, and is expected
to sponsor this response at hearing. Please contact Brian Dickman at 801-220-
4975 to discuss this response.
IDAHO
P A C- E-O7 -
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
PAC-O7-05/Rocky Mountain Power
August 21 , 2007
lIP A 1 st Set Data Request 1.33
lIP A Data Request 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?
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?
Response to liP A Data Request 1.33
A. Yes. The $996 370 represents the amount of incentive payments paid
(revenue credit) to irrigation customers enrolled in the Irrigation Load
Control program.
B. This expense is functionalized on the Production (P) factor which is split
75% demand and 25% energy. This amount is contained in Account 557
Other Expenses in the functionalized study, in Exhibit 30, Tab 2, page 8.
C. These costs are allocated to Monsanto and to all other Idaho customers
using Factor 10. The allocation of Account 557 expenses is shown in
Exhibit 30, Tab 4.2 Generation, page 5.
D. Yes. The right to interrupt service to Monsanto is treated as a system
resource and the credits are treated as a power cost in Account 555 that is
allocated to all PacifiCorp jurisdictions and customers within those
jurisdictions, including the Idaho irrigators. The amount of the credit to
the Idaho Irrigation customers is $136 779. These costs are allocated
systemwide using the system generation factor and among customer
classes using the class cost of service factor 10.
(Steven R. McDougal and Mark E. Tucker prepared this response, are the
recordholders, and are expected to sponsor this response at hearing. Please
contact Brian Dickman at 801-220-4975 to discuss this response.
P AC-07-05/Rocky Mountain Power
August 21 2007
IIP A 1 st Set Data Request 1.34
liP A Data Request 1.
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.
Response to lIP A Data Request 1.34
For details regarding calendar year 2006 demand-side management (DSM)
activities and the associated costs please see the Company s 2006 Annual Report
of Idaho Demand Side Management Activities filed with the Idaho Public
Utilities Commission in May, 2007 provided as Attachments IIPA 1.34 A and
IIP A 1.34 B.
In Idaho docket P AC-05-1 0 the Idaho Public Utilities Commission ordered the
company to defer all Idaho DSM costs incurred after January 12 2006 to be
recovered through a DSM tariff rider surcharge that went into effect May 1 2006.
As the company receives funds from the tariff rider, the deferred balance is
amortized. Since DSM costs are recovered through the DSM tariff rider
surcharge, the amortization of the deferred DSM costs must be removed from
results to ensure that costs are not recovered twice - once through the tariff rider
and once through the revenue requirement. The DSM amortization removal
adjustment discussed on page 18 of Mr. McDougal's testimony removes from
results the amortization recorded in calendar year 2006 for deferred DSM costs.
(Steven R. McDougal prepared this response, is the recordholder, and is expected
to sponsor this response at hearing. Please contact Brian Dickman at 801-220-
4975 to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT IIPA 1.34 -(A, B)
ON THE ENCLOSED CD
P AC- E-07 -05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.3
lIP A Data Request 1.35
On page 3 of Mr. Widmer s testimony there is an estimate of impacts of 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
of the change in Irrigation demand and energy that was used as an input to
the model.
Response to lIP A Data Request 1.
A. Actual weather normalized hourly retail loads from 2005 were used to
calculate the normalized CY 2005 results. The actual loads include the actual
2005 Idaho irrigation curtailments and also include any incremental load
caused by irrigators making up for the curtailment once the curtailment
restrictions are removed.
B. Similar to the response to subpart A. above, the actual weather normalized
hourly retail loads from 2006 were used to calculate the nonnalized CY 2006
results. The actual loads include the actual Idaho irrigation curtailments and
also include any incremental loads caused by irrigators making up for the
curtailment once the curtailment restrictions are removed.
C. Please refer to the company s response to IIPA data request 1.15. Ifrequested,
the company will make available a GRID computer which will allow Idaho
Irrigation Pumpers Association (IIP A) to prepare this study using its own
assumptions about hourly load curtailments.
D. Please refer to the company s response to IIPA data request 1.15. Ifrequested
the company will make available a GRID computer which will allow IIP A to
prepare this study using its own assumptions about hourly load curtailments.
(Mark T. Widmer prepared this response, is the recordholder, and is expected to sponsor
this response at hearing. Please contact Brian Dickman at 801-220-4975 to discuss this
response. )
P AC- E-07 -05/Rocky Mountain Power
August 21 , 2007
IIP A 1 st Set Data Request 1.
lIP A Data Request 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.
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.
Response to lIP A Data Request 1.36
A. Actual weather normalized loads from 2006 are shifted one day later to align
the load day of the week with the calendar day of the week. The requested
information is provided as Attachment IIP A 1.36.
B. Please refer to the company s response to 1.36 A.
C. Please refer to the company s response to IIPA Data Request 1.15.
D. Please refer to the company s response to Monsanto Data Request 1.8. The
requested information has already been provided as Attachment Monsanto 1.
(Mark T. Widmer prepared this response, is the recordholder, and is expected to sponsor
this response at hearing. Please contact Brian Dickman at 801-220-4975 to discuss this
response. )
IDAHO
P A C- E-O7 -
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD
P AC- E-07 -05/Rocky Mountain Power
August 21 , 2007
liP A 1 st Set Data Request 1.38
lIP A Data Request 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.
Response to lIP A Data Request 1.38
The requested short term firm (STF) transactions that were executed when the
company s filing was prepared are provided as Attachment lIP A 1.38.
Please note that all STF transactions delivered to a given point of delivery for a
given hour are combined. For example, STF sales delivered to the Mid-Columbia
market hub during the month of June 2007 consists of 81 separate transactions
with the earliest transaction dated October 2004. The 81 transactions are a mix of
different products consisting of annual (15 trades), quarterly (45) and monthly
(21) trades and with different delivery patterns flat (2), HLH (53) and LLH (26).
(Mark T. Widmer prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P A C- E-O7 -
ROCKY MOUNTAIN POWER
lIP A DATA REQUESTS SET 1 (1-38)
ATTACHMENT lIP A 1.
ON THE ENCLOSED CD