20081211Staff 39-67 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
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2nos DEC \ \ AM \I: \ 6
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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-E-08-7
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbur, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than FRIDAY, JANUARY 2, 2009.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 DECEMBER 11,2008
REQUEST NO. 39: Please provide all analysis in executable electronic format that
supports the Company's decisions on rate design and rates (e.g. - elasticity analysis, customer
sureys and findings or conclusions, load shifting data, cost/enefit studies).
REQUEST NO. 40: In the Company's most recent 2007 IRP Update, Table 9, titled
"Load Resource Capacity Balance" ilustrates an immediate "East Position" deficit of which
Idaho is par. Aside from Schedules 35, 35A, and 36, please provide a detailed explanation of
how the Company's current and proposed Idaho rate design provides an incentive for customers
to conserve and use energy wisely in order to reduce this deficit.
REQUEST NO. 41: For the schedules with available time-of-use (TOU) metering
capability, please provide an explanation of how long this metering capabilty has been available
and the extent to which it has been used by the Company and customers.
REQUEST NO. 42: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating why the Company has not chosen to implement
mandatory time-of-use (TOU) or tiered rates for each Residential, Commercial, and Industrial
Schedule in Idaho but has determined to implement these designs in some other states. Include in
this response how the Company differentiates its mandatory and voluntar rate design policy
decisions and priorities across the states it serves.
REQUEST NO. 43: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating how the Schedule 36 optional residential time-of-
use (TOU) rates have been successful in remediating peak load deficits in Idaho compared to
Oregon and Uta. Include any electronically formatted data or analysis on load profies and load
shifting.
REQUEST NO. 44: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating how optional time-of-use (TOU) rates for Schedules
35 and 35A have been successful in remediating peak load deficits and how they have grown
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2
I
DECEMBER 11, 2008
over the life of the program. Include any electronically formatted data or analysis on load
profies and load shifting.
REQUEST NO. 45: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating why the Company has chosen not to implement a
Mid-Peak time-of-use (TOU) rate for its applicable schedules.
REQUEST NO. 46: Please provide a detailed explanation and an! supporting executable
electronically formatted analysis ilustrating how the Company has detenrined the sumer and
non-summer biling seasons for each schedule.
REQUEST NO. 47: On page 5, lines 13-15, Zimmerman says "Fpr residential
customers (Schedule 1 and 36), the Monthly Biling Comparisons show that the Company's rate
design proposals produce uniform percentage impacts across usage levels", how has the
Company determined that uniform percentage impacts across usage levels are appropriate when
greater impacts across higher usage levels might encourage the effcient use of energy?
(Zimmerman Testimony, page 5, lines 13-15)
REQUEST NO. 48: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating why the Company has chosen its Schedule 1
proposal to keep "the present differentials between summer and winter energy charges."
(Zimmerman Testimony, page 5, lines 3-5) Include any electronically formatted data and
analysis on energy price differentials between the two seasons.
REQUEST NO. 49: Please provide all bil frequency analysis completed by the
Company in executable electronic format. To the extent possible, please convert these to actual
usage months. Provide the usage in as small of increments as possible.
REQUEST NO. 50: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating why the Company has proposed "to implement the
Schedules 6, 6A, and 9 price changes on a uniform percentage basis to each of three components;
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 DECEMBER 11, 2008
customer, demand, and energy charges, and to maintain the curent relationships between the
energy blocks and the curent ratio of on-season and off-season revenues." (Zimmerman
Testimony, page 6, lines 8-12)
REQUEST NO. 51: Has the Company done analysis on elasticity given different
sumer/winter energy differentials or between other billng component differentials in order to
design rates tö encourage efficient energy use? If so, please explain and provide all executable
electronically formatted copies of the analysis. If not, please explain why not.
REQUEST NO. 52: Please provide a detailed explanation and all supporting executable
electronically formatted analysis of how the Company has monitored the changes in load
associated with Schedule 36 customers both prior to and following the transfer from Schedule 1
to Schedule 36.
REQUEST NO. 53: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating how the Company expects to utilze the Schedule
35, 35A, and 36 load research information to strctue and determine the Company's future rate
design initiatives.
REQUEST NO. 54: Please provide a detailed explanation and all supporting executable
electronically formatted analysis ilustrating the Company's Schedule 36 decision "to keep the
present ratios between summer/winter energy charges and on-peakoff-peak energy charges."
(Zimmerman Testimony, page 5, lines 5-9)
REQUEST NO. 55: Please provide the supporting data and analysis in executable
electronic format used to support Zimmerman's response to the question, "Including the effects
of the requested increase, how have the Company's rates in Idaho changed over time?" (Page 4,
lines 9 & 10) Specifically, include the supporting data and analysis on the following:
A. Less than a 1 % historical overall base rate increase over the last three rate
increases;
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 DECEMBER 11,2008
B. Less than a 5% historical overall base rate increase since 1986. (including the
Company proposal);
C. 96% increase in the Consumer Price Index over 22 years;
D. 46% overall "real basis" decline in base rates since 1986. (including the
Company proposal);
E. 43% "real basis" decline in base residential rates since 1986. (including the
Company proposal);
F. 40% "real basis" decline in base irrigation rates since 1986. (including the
Company proposal);
G. 58% "real basis" decline in base general service rates since 1986. (including
the Company proposal);
H. 56% "real basis" decline in base large general service base rates since 1986.
(including the Company proposal).
REQUEST NO. 56: Please provide a list of the rate designs for the commercial and
industrial schedules for each jursdiction. If the general design has changed in the past 3 years,
please summarize in what ways.
REQUEST NO. 57: With respect to the Company's Load Research data, please provide
for each sample customer, in executable electronic format, with valid data that was sampled
between January 2007 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.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 methodologies used to extrapolate the Load
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 DECEMBER 11, 2008
Research data to the entire rate schedule 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.
REQUEST NO. 58: Where the Company hired independent third-pary evaluators to
assess DSM program operations, savings contributions and cost effectiveness, please provide a
detailed explanation of each third-party evaluator, what the evaluation findings were, and how
the Company used these findings. With this, please provide all executable electronically
formatted cost/enefit analysis related to each program and the Company's decision of
implementation. (Bumgarer Testimony, page 3, lines 11-14)
REQUEST NO. 59: Please provide a detailed explanation of what "other delivery
support is provided by the Company's business centers, corporate deparments (legal,
procurement, etc.), local trade ally networks, and contracted program delivery vendors i.e. Jaco
Environmental, PECI, low income community action agencies, energy engineering contractors,
etc." (Bumgarer Testimony, page 15, lines 9-13)
REQUEST NO. 60: Please describe page 11, lines 13-15 of Bumgarer's testimony in
more detal, specifically describing the measures where the Energy FinAswer Program
availabilty and incentive levels var and to what degree these var for retrofit and new
constrction installations according to codes, stadards, and standard practices.
REQUEST NO. 61: Please provide a detailed explanation and any supporting
executable electronically formatted analysis of the Company's decision to utilze a one year
simple payback to limit the available incentive on a project specific basis? (Bumgarner
Testimony, page 12, lines 5-9)
REQUEST NO. 62: Please provide evidence of where "Irrgators are showing an
interest in the installation of drives on their systems" and how "requests for system consultation
and system analysis increased substantially between 2006 and 2007." (Bumgarer Testimony,
page 17, lines 3-6)
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 DECEMBER 11, 2008
REQUEST NO. 63: Please elaborate on the second bullet point regarding the drop in
the NEEA's results between 2006 and 2007, despite almost identical program expenditues.
(Bumgarer Testimony, page 17, lines 7-14)
REQUEST NO. 64: Please provide a detailed explanation of all education programs
initiated for customers, including but not limited to those treated as a component of DSM
programs, specifically targeting energy efficiency through rate design strctures. An example of
some key educational program points might be a description of, (1) the rates and usage levels
within tiers of the Company's rate structue (2) the purpose of the rate structure; and (3) the steps
customers can tae to reduce usage.
REQUEST NO. 65: As a condition of the transfer of the Site Certification Agreement
from Chehalis Power to PacifiCorp, Washington State Energy Facilty Site Evaluation Council
Order No. 836 requires PacifiCorp to provide $1.5 milion in fuding for greenhouse mitigation
projects. Does PacifiCorp intend to add or modify equipment at the plant, or change its historic
operations, such that it wil emit more greenhouse gases than it has historically? If so, is this the
basis for requiring Pacifi Corp to provide the $1. 5 milion? If not, what is the justification for
providing the $1.5 milion?
REQUEST NO. 66: On page 8, lines 7-8 of the testimony of Stephan Bird, a comparison
is made between the cost of the Chehalis plant and PacifiCorp's Lake Side plant. What was the
cost per kW for PacifiCorp's Curant Creek Plant?
REQUEST NO. 67: With the recent global credit crisis and the dramatic downturn in
the economy, does PacifiCorp believe that the estimated costs for constructing new combined
cycle plants will be higher or lower than the costs used for comparson purposes in the Chehalis
analysis (i.e., combined cycle costs that were based on results of the Company's 2012 RFP)?
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 DECEMBER 11,2008
'f
DATED at Boise, Idaho, this /1 day of December 2008.
Scott Woo bur
Deputy Attorney General
Technical Staff: Matt Elam #39 - 64
Rick Sterling #65 - 67
i:umisc:prodreq/pace08.7swmerps prod req 3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 DECEMBER 11, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF DECEMBER 2008,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-08-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
MGR, ID REGULATORY AFFAIRS
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.westonØ&pacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datarequestØ&pacificorp.com
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 WCORDOVACOURT
SURPRISE AZ 85387
E-MAIL: kiversonØ&consultbai.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
201 ECENTER
PO BOX 1391
POCATELLO ID 83204
E-MAIL: eloØ&racinelaw.net
BRAD MPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyØ&hotmaiLcom
DANIEL SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: danieLsolanderØ&pacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE & BAILEY
201 ECENTER
PO BOX 1391
POCATELLO ID 83204
E-MAIL: rcbØ&racinelaw.net
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithØ&monsanto.com
ELECTRONIC COPIES ONLY
ANTHONY YANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonyØ&yaneLnet
CONLEY E WAR
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 WBANNOCKST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cewØ&givenspursley.com
CERTIFICATE OF SERVICE
DENNIS E PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY ST SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseauØ&excite.com
~~
SECRETARY:
CERTIFICATE OF SERVICE