20081128IIPA 1-35 to PAC.pdf

Jean D. Jewell, Secretar
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. PAC-E-OB-07
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.D.
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
JONATHAN M. VOLYN
Dear Ms. Jewell:
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 208
BOISE, IDAHO 83702TELEPHONE: (208) 395-'001 1
FACSIMILE: (208) 433~0167
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]FACSIMILE [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 203A
IDAHO FALLS, 1083402
TELEPHONE: [phone]
FACSIMILE: [phone]ww.racinelaw.net
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE106A
COEUR D'ALENE, ID 83814TELEPHONE: [phone]
SENDER'S E-MAIL ADDRESs:ELO\Qracinelaw.net
ALL OFFICES TOLL FREE
(877) 232-610'
LOUIS F. RACINE (1917..2005)
WILLIAM D. OLSON. OF COUNSEL.
November 25,2008 gcø:;;¿ÑCf
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Enclosed for filing in the captioned matter, please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's First Data Requests to Rocky Mountain Power.
ELO:nj
Enclosures
cc: Service List
.rtERIC L. OLSEN
..~-CJ-a:o
Eric L. Olsen, ISB #4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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1."1'1 UfI'J ':8 11),.4. 8: 34uuti ¡',"itt (., Hn
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF CHANGES TO ITS
ELECTRIC SERVICE SCHEDULES
)
)
)
)
)
CASE NO. PAC-E-08-7
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S FIT DATA
REQUESTS TO ROCKY MOUNAI POWER
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and
through its attorneys, hereby submits this First Data Requests to Rocky Mountain Power,
pursuant to Rule 225 of the Idaho Public Utility Commission's Rules of Procedure,
IDAPA 31.01.01, as follows:
1. Please answer the following with respect to information contained on Dickman's
Exhibit 12, Tab 10 entitled "Allocation Factors":
A. On pages 10.13 through 10.20, are these actual generation level energy and
demand values recorded for each jurisdiction durng each of the months
specified?
B. Do the energy and demand values for Idaho include Monsanto load that has been
interrpted?
C. Are the values/adjustments on page 10.1 3 though 10.20 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
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - i
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 10.13 through 10.20 the ones used to
form the basis for such system allocators as SC and SE?
E. For each of the adjustments listed on pages 10.13 and 10.16, 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 i O.
2. Please answer the following with respect to information contained on Tucker's
Exhibit 22, 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 durng 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 Dickman's Exhibit 12, Tab 1O?
D. With respect to the data listed on pages 7 and 12, 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?
E. With respect to the data listed on page 13, which data came from the Company's
load research data and which data came from biling data?
F. What was the level of curtailment/interrption for each customer class or
Monsanto during the times of each of the monthly peaks listed on page 7? (Please
specify at input leveL.)
G. 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.
3. With respect to the Company's Load Research data, please provide for each sample
customer with valid data that was sampled between Januar 2007 and the most recent
month available the following:
A. Customer identification number;
IDAHO IRRGA TION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 2
B. Customer rate schedule;
C. Strata to which it belongs and weighting factors of each strata;
D. Raw hourly usage data (i.e., 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 of the 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.
4. Previously the Company developed hourly calibrations that calibrated the Load
Research data such that the sumation 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 stil of interest. On an hourly basis from Januar 2007 though
the most recent month available, please provide:
A. The "Operations Stat" or border load for the Idaho Jursdiction;
B. The sumation 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 "a" above but is not addressed in "c" above
(please specify the type of load); 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.
5. Please provide for each month from Januar 2007 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.
6. For the Irrgation load research samples, what is the range (kW or kWh) cut-offfor
each strata?
IDAHO IRRGA TION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 3
7. 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
(manpulation) of data from historic load research or consensus data to projected test
year energy, coincident demands, and non-coincident demands. Please supply this
data in Excel format.
8. On Exhibit 12, page 10.14 there is an adjustment for the August 2007 Idaho
coincident peak of a positive 6 MW. Please provide all data, equations, and
assumptions used to develop this figue. Please supply this data in Excel format.
Explain how, if at all, this adjustment flows through or is incorporated in Exhibit 22
Tab 5, pages 6 or 7.
9. Please provide in electronic format for the period Januar 1,2007 through the most
recent month available hourly data similar to that provided in CCS Request 11 in
PAC-E-05-0L.
10. Please provide in electronic format a listing of the date, time, and estimated
magnitude of all actual hourly curtailments/interrptions that occurred during the test
year in Idaho separated by rate schedule or special contract customer. If outright
curtailments/interrptions are treated differently than "buy-throughs", please state
each separately.
11. Please provide in electronic format a listing of the date, time, and estimated
magnitude of all actual hourly curtailments/interruptions that occured durng the test
year in each of the other jursdictions. If outright curtailments/interrptions are
treated differently than "buy-throughs", please state each separately.
12. Please provide a copy or copies of the Company's Jurisdictional Allocation Model (in
a maner similar to that of Exhibit 12 Tabs 1, 2 and i 0) stating the Idaho Jursdiction
without Monsanto and the Monsanto load as two separate jurisdictions.
13. Do the values in Exhibit 12, Tab 10, reflect Idaho demand and energy requirements
by assuming that there are no curailments/interrptions to Monsanto? If
curailments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
14. Do the values in Exhibit 22, Tab 5, reflect Idaho demand and energy requirements by
assuming that there are no curtailments/interrptions to Monsanto? If
curailments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
15. With respect to Exhibit 22, Tab 5, page 7, please answer the following:
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 4
A. Are all of these values actual? If not, please provide and explanation of how they
were normalized and theworkpapers that support the normalization.
B. Please explain the difference between the figures on lines 20 and 21.
C. What level of curailment of Schedule 10 load is reflected on line 26? Is this level
of curtailment the same as occurred in 2007 or is expected to be incured in 2009?
D. What is the level of curtilment that is reflected in each month on line 26 for the
Irrgation load?
16. Please explain how any revenue credits to Monsanto are addressed in this case in
relationship to Monsanto's inclusion/exclusion in/from the Idaho Jursdiction and
how Monsanto is treated in the class cost of service study.
17. For each rate schedule and special contract customer listed in Exhibit 23, for 2006
and 2007, please list the amount of energy consumed and the revenue collected.
18. For the year 2007 list by FERC account the amount of Distrbution plant that is
associated (allocated or directly assigned) with each jursdiction.
19. Beginning on page 8 line 21 of Mr. Dickman's testimony it is stated that
adjustments were made to reflect temperature normalization.
a. Did the Company weather normalize irrgation 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.
20. Regarding the Irrigation Load Control Program credit addressed on Page 11 of
Mr. Dickman's testimony and Exhibit 12, Tab 4, page 4.3x, please answer the
following:
a. Is the total revenue credit $6,570,000?
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?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 5
d. Are any similar credits to Monsanto allocated to the Idaho Irrgation customers,
and if so, what is the dollar amount and the basis for the allocation?
21. On page 10 lines 18-20 ofMr. Duvall's testimony, it is indicated that the NPC
model uses hourly retail load as some of the inputs.
a. Please provide the hourly system retail load data that was used in the NPC model
that was used in this case.
b. Please provide the hourly system retail load data that was used/adjusted for uses
in the NPC model to develop the data in "a" above.
c. Please provide the hourly Idaho retail load data that was used in the NPC model
that was used in this case.
d. Please provide the hourly Idaho Irrgation retail load data that was used in the
NPC model that was used in this case.
e. Please provide the hourly market price data that was used in the NPC model that
was used in this case.
22. Please provide electronically a listing of all dates, times, and expected magnitude of
all dispatched and scheduled day curailments when Idaho irrgation load was
curailed under Schedule 72A since Januar 2007.
23. Please provide a biling summar for the Irrgation customers for each month since
Januar 2003 showing; total revenue, KWh, revenue based on energy, biling
demand, revenue based upon biling demand, customers biled, and revenue based
upon customers biled.
24. For each hour since Januar 1 2006 to the most recent data available please
provide the following information in $/Mwh for both the entire system and for the
East System:
a. The market value of energy;
b. The incremental cost associated with the most expensive resource dispatched;
c. The purchase price for the most expensive short-term resource purchased; and
d. The revenue received from the most expensive sale made.
25. For each month since Januar 2007, please supply the level (as well as mechanism
such as mils per kWh etc.) ofthe BPA credit that was applied to each rate schedule.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 6
26. Does the Company weather normalization summer usage of Schedule 36 customers?
27. Please provide a history of all curtilments and/or interrptions made to Monsanto
for the period Januar 1, 2006 through the present. Please detail the time and date of
the curlment or interrption, the amount and reason (economic curtilment,
operating reserves, system integrity, etc.).
28. Please provide the following for each Morgan Staley contract that is included in the
Company's Net Power Cost model:
a. Please provide a copy of each contract?
b. In the Net Power Cost model, what was the energy and dollars associated with
each month of the test year.
c. Since Januar 1,2006, what has been the dates, hours, MW, and $/MWH ofaii
purchases through each of these contracts?
29. Regarding the values on page 10.13 of Company Exhibit 12, please answer the
following:
a. Are the "Metered Loads" at the top ofthe page actual (unaltered in any way)
values for each jurisdiction at the time of the monthly system peaks in 200n
b. What is the specific basis for the first set of adjustments to the Utah load that
range from 85-92 MW?
c. What is the specific basis for the first set of adjustments (decreases) to the Idaho
load of 71 MW?
d. Why is the Idaho load only adjusted (decreased) in the months of June, July,
August, and October in the first set of adjustments?
e. What is the specific basis for the second set of adjustments (increases) to the
Idaho load of71 MW?
f. Why is the Idaho load only adjusted (increased) in the months of May, June, July,
August, and October in the first set of adjustments?
g. How do the decreases in the Idaho load relate to the increases in Idaho load and
why is there only an increase and no decrease durng the month of May?
h. The bottom table on the page is listed as being "Normalized Loads". Is the only
"normalizing" adjustment for the Idaho load on this page the fact that in some
months 71 MW was both added and subtracted for the actual coincident peak
values?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 7
30. Regarding the values on page 10.14 of Company Exhibit 12, please answer the
following:
a. What were the specific equations used to calculate the "Adjustment for
Coincidental System Peaks Temperatue Adjustments" found on the fourth table
on that page?
b. What was the specific data used to calculate the "Adjustment for Coincidental
System Peaks Temperature Adjustments" found on the fourth table on that page?
c. Please provide as an example the exact equations and data used to calculate the
July 2007 temperature adjustment for Idaho in the fourh table on that page of -5
MW?
31. Regarding the values on page 10.15 of Company Exhibit 12, please answer the
following:
A. Are the "Metered Loads" at the top of the page actual (unaltered in any way)
values for each jursdiction on a calendar or biling month basis?
B. What is the specific basis for the first set of adjustments (decreases) to the Utah
load that range from 4,330-7545 MWh?
C. How do the first set of adjustments (decreases) to the Utah load related to the
adjustments in the second set of adjustments on page 10. i 3 for peak load?
D. Why is there an adjustment in the first set of adjustments (decreases) for Utah
durng January on this page, but there is no corresponding adjustment for Utah
during Januar on page 1O.13?
E. What is the specific basis for the first set of adjustments (decreases) to the Idaho
load and why do these adjustments not conform to adjustments taing place in
similar months on page 10.13?
F. What is the specific basis for the second set of adjustments (increases) to the Utah
load that range from 167-596 MWh?
G. What is the specific basis for the second set of adjustments (increases) to the
Idaho load?
32. Regarding the values on page 10.16 of Company Exhibit 12, please answer the
following:
A. What were the specific equations used to calculate the "Temperatue
Adjustments for Energy" found on the second table on that page?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 8
B. What was the specific data used to calculate the "Temperatue Adjustments for
Energy" found on the second table on that page?
C. Please provide as an example the exact equations and data used to calculate the
July 2007 temperatue adjustment for Idaho in the second table on that page of -
4,182 MW?
33. Regarding page 4.3.2 on Company Exhibit 12, why was a line loss figure of 5.697%
used to calculate the curailment level at Input as opposed to a value on the order of
14.668% that is used on Mr. Tucker's Exhibit 22, Tab 5, pages 6 and 7 in order to
increased the Irrgation peak load from Sales level to Input level? Why would these
loss percentages not be the same?
34. Regarding the $2,048,020 DSM amortization expense removal on page 4.17 of
Company Exhibit 12, what are the programs or portions of programs that make up
this expense?
35. Please provide a copy of Rocky Mountain Power's 2007 FERC Form 1.
'?L:-f
DATED this ~ day of November, 2008.
RACINE, OLSON, NYE, BUDGE &
BAIL , C RTERED
ERIC L. OLSEN, Attorney for
Idaho Irrigation Pumpers
Association, Inc.
IDAHO IRRGA nON PUMPERS ASSOCIA nON, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 9
CERTIFCATE OF MAIING
I HEREBY CERTIFY that on this L s t-ÍA day of November, 2008, I served a
true, correct and complete copy of the foregoing document, to each of the following, via
the method so indicated:
Jean D. Jewell, Secretar
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
j j ewell§.uc.state.id. us
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Ted Weston
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Utah 84111
ted. westonrmpacificorp.com
Daniel Solander
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, Utah 84111
Daniel.solanderrmpacificorp.com
Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
P.O. Box 83720
Boise, Idaho 83720-0074
scott. woodburrmpuc.idaho. gov
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chd
201 E. Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
rcbrmracinelaw.net
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Katie Iverson
Brubaker & Associates
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IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 10
"I 1 ,. '"
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James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
Jim.r .smith(ßmonsanto .com
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Anthony Yanel
29814 Lake Road
Bay Vilage, OH 44140
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Brad M. Purdy
2019N. 17th Street
Boise, Idaho 83702
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Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
601 W. Banock St.
P.O. Box 2720
Boise, Idaho 83701-2720
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Dennis E. Peseau, Ph.D.
Utility Resources, Inc.
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Salem, OR 97302
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IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUESTS TO ROCKY MOUNTAIN POWER - 11