20090106PAC to IIPA 1-35.pdf

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R" EC. Ei\n::. \ _ _, '¡.,,,201 South Main. Suite 2300
Salt Lake City. Utah 84111
2009 JAN -6 PH 12: 51
ID'AH'''' oiin' ii-l v' , '-' L. ~,
UTILITii-S CA' .,,1''-''"1(-''. . . .' : ..' ' ..' t: +. . \.j l~/H-~;'; ~ '~J t,"' l".,r¡ '~
December 31, 2008
Eric Olsen
Idaho Irrigation Pumpers Assoc
Racine, Olsen, Nye, Budge & Bailey
201 'East Center
Pocatello, ID 83204
RE: PAC-E-08-07
IIPA Data Request (1-35)
Please find enclosed Rocky Mountain Power's Responses to IIPA Data Requests 1 - 35,
excluding IIPA 8 - 11,21,24,26-32, and 34. Provided on the enclosed CD are Attchments
IIPA 1,3,4,5, 12, 17, 18, 19b, 22-(1-2),23, and 25.
If you have any questions, please feel free to call me at [phone].
Sincerely,
-1£1 tk~/~
Ted Weston,
Manager, Regulation
Enclosures
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
IIPA Data Request 1
LIP A Data Request 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 during 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 10,13 through 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 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 10.
Response to I1PA Data Request 1
a. The energy and demand values recorded for each jurisdiction are shown at the
generation or input leveL.
b. The loads reflect the removal of Monsanto buy-throughs and the addition of
Monsanto curtailments to reflect à normalized leveL.
c, No, The values / adjustments shown on pages 10,13 through 10.20 reflect both
weather (temperature) and non-weather adjustments. The demand or peak
weather related adjustment is shown on page 10.14, table 4 and the energy
weather related adjustment is shown on page 10.16, table 2. All other
adjustments are non-weather adjustments.
d, Yes
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 1
e. The adjustments shown on page 10,13 represent curtailments and buy-though
amounts to Monsanto, These same adjustments are made to the coincident
peak demands in the cost of service study on the Demand Factors sheet.
The normalized energy used in the cost of service study is weather normalized
by schedule and by month using the same data shown on page 10. i 6, This
adjustment is not made in the cost of service study, however, it is made before
the data is entered into the modeL.
f. Electronic copies of workpapers to support Tab i 0 are provided as
Attachment IIPA i as well as the JAM model which was included on the CD
when we fied the GRC. The JAM model was included in Brian Dickman's
exhibit no. 12 workpapers. Hard copies of Tab i 0 were provided as part of the
Exhibit i 2, Tab 10.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 1
ON THE ENCLOSED CD
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 2
LIP A Data Request 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 jursdictional values for each month on page 6 relate to the Idaho
values on Dickman's Exhibit 12, Tab 10?
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? If from
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 inpuUeveL)
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.
Response to I1PA Data Request 2
A. Yes
B. Mountain time
C.
The state load data that is used for jurisdictional allocation wil 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 wil 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
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
liP A Data Request 2
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 pars of the company's system. From that
measurement, metered and/or scheduled energy flows out of the state and
deliveries to non-retail customers arc deducted to arive 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 biled energy at the customer
meter and grossed up to the input level by the use of historical loss factors.
D, The coincident peak and distribution peak data used in the cost of service
study is from load research data with the exception of Contract 2 which
comes from bill data. The load research data is from calendar year 2007.
E. The energy factors on page 13 are based on biling data.
F. Curtailments and interrptions are shown for Schedule 10 (Irrigation) and
Contract 2 (Monsanto). Please refer to the response to LIP A 15c for details on the
level of curtailment reflected in irrigation load. Curtailment of Monsanto's load
is shown on the Demand Factors sheet of the electronic version of the cost of
service model, and on Tab 5, Pages 6 and 7 of printed Exhibit 22. Line 21 on
Page 6 shows the amount of curtailment at input level that occured at the time of
system peak. This amount is added backto Monsanto's metered load adjusted for
buy-throughs.
G. No, the distribution peaks and non-coincident peaks are based on load
research data and are not weather normalized.
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 3
LIP A Data Request 3
With respect to the Company's Load Research data, please provide for each sample
customer 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 foreach 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.
Response to lIP A Data Request 3
Load research estimates have been developed for the test period only and therefore
will be provided for January 2007 to December 2007.
A. Customer identification number is contained in column A, tabs SchOO 1,
Sch036, Sch006, Sch023 and SchlO of Attachment IIPA 3.
B. Customer rate schedule is contained in column C, tabs SchOOl, Sch036,
Sch006, Sch023 and SchlO of Attachment IIPA 3.
C. Strata to which each customer belongs are contained in column D, tabs
SchOOl, Sch036, Sch006, Sch023 and SchlO of Attachment IIPA 3.
D. Raw hourly usage data (i.e., unadjusted, simply the data originally gathered
for each sample) is contained in columns E - AB, tabs SchOOl, Sch036,
Sch006, Sch023 and SchlO of Attachment IIPA 3.
E, Because of the large volume of data involved, the Company is providing the
factors necessary to adjust the data supplied in Part D to estimates plus losses.
P AC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 3
Multiplying the data by these factors wil satisfy the requirements of this
request. Hourly loss factors for each sampled rate schedule are detailed
below.
Rate 001
Rate 036
Rate 006
Rate 023
Rate 010
Secondary
Secondary
Secondary
Secondar
Secondary
Secondary loss factor 14.668%
Primary loss factor 10.418%
Transmission loss factor 5.697%
F. Because of the large volume of data involved, the Company is providing the
factors necessary to adjust the data supplied in Par D to estimates plus losses.
Multiplying the data by these factors wil satisfy the requirements of this
request. 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 by an Annual Adjustment Factor to match the kWh energy figures that
have been adjusted by the Regulation Group. Please refer to Attachment LIP A
3, tab Adjustment Factors 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 Regulation Group. Factors developed and shown in
Attachment lIP A 3 are applied to every hour for each month for each rate.
Note: Because the irrigation season only rus from June i to September 15,
the irrigation sample data is adjusted on a monthly basis according to a
monthly adjustment factor rather than an anual adjustment factor.
G. Formulas as requested:
For any given time interval the load research estimate (y) is equal to the
sum of the weighted stratum averages (W nYh).
Y=L WhYh
Monthly billng adjustments are derived using the following formula:
y m=(Y*(Y m IYm)*(Ya/Ya))
Where Y= adjusted load research estimate
Where y= unadjusted load research estimate
Where Y m= Biled 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 3.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 3
ON THE ENCLOSED CD
PAC-E-08-07/Rocky Mountain Power
December 3 i ,2008
LIP A Data Request 4
LIP A Data Request 4
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 stil of interest. On an hourly basis from January 2007 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 "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.
Response to liP A Data Request 4
Please refer to Attachment lIP A 4.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 4
ON THE' ENCLOSED CD
P AC-E-08-07 /Rocky Mountain Power
December 31, 2008
LIP A Data Request 5
LIP A Data Request 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.
Response to lIP A Data Request 5
Please refer to Attachment IIPA 5.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 5
ON THE ENCLOSED CD
P AC-E-08-07 /Rocky Mountain Power
December 31, 2008
LIP A Data Request 6
I1PA Data Request 6
For the Irrigation load research samples, what is the range (kW or kWh) cut-off
for each strata?
Response to lIP A Data Request 6
Strata size cut offlevels were determined based on a customer's cumulative kWh
for the months May-September. Strata size cut off levels are shown below.
Strata I
Strata 2
Strata 3
Strata 4
250- 50,000
50,001 -1 00,000
100,001-400,000
GT-400,000
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 7
liP A Data Request 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
(manipulation) 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.
Response to lIP A Data Request 7
Please refer to the response to LIP A i 9c for workpapers showing the weather
normalization of energy data. This normalized data is used in developing
jurisdictional and cost of service allocation factors, but no additional weather
normalization is performed to load research data.
PAC-E-08-07/Rocky Mountain Power
December 31,2008
LIP A Data Request 12
lIP A Data Request 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 10) stating the
Idaho Jurisdiction without Monsanto and the Monsanto load as two separate
jurisdictions.
Response to IIPA Data Request 12
Attachment IlPA 12 is the Jurisdictional Allocation Model with Monsanto's load
separate from Idaho. To create a separate jurisdiction for Monsanto, the company
utilized the former Montana section ofthe 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, 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
taxes, 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.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 12
ON THE ENCLOSED CD
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 13
LIP A Data Request 13
Do the values in Exhibit 12, Tab 10, 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?
Response to lIP A Data Request 13
Yes, Please refer to the response provided to LIP A Data Request i, specifically
part b.
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 14
liP A Data Request 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
curtailments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
Response to LIP A Data Request 14
Monsanto's metered energy and demand totals are adjusted in the cost of service
model to remove the effect of any curtailments, interrptions and buy-throughs
that occurred during the test period. Monsanto's load is therefore presented as if
there are no curtailments or interrptions to Monsanto. This is consistent with
prior procedure.
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
lIP A Data Request 15
liP A Data Request 15
With respect to Exhibit 22, 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? Is this level
of curtailment the same as occured in 2007 or is expected to be incurred in 2009?
0, What is the level of curtailment that is reflected in each month on line 26 for the
Irrigation load?
Response to IIPA Data Request 15
A. Values for Contract 2 are from meter data adjusted for curtailments and buy-
throughs. Please see the response to lIP A 14 for details. In addition, the
Schedule 10 coincident peaks are adjusted to account for increased load control
under the dispatchable irrigation load control program. Please see response to
Part C. The rest of the data is based on load research data and adjusted for load
losses. No normalization is done to this data.
B. Line 20 shows Monsanto's metered load at the time of system peak reduced by
any buy-through that was occurring at that time. Line 21 shows curtailment of
service to Monsanto that was occurring at the time of system peak. These two
numbers are added together to produce Monsanto's adjusted load.
C. The level of the adjustment made to Schedule 10 load to account for load control
is shown in Mr. Dickman's Exhibit 12, Page 4.3.2. These values are listed below.
This adjustment is based on the additional estimated level of curtailment that
occurred during 2008 due to the expansion of the dispatchable irrgation load
control program.
June: (109,016)
July: (148,356)
August: (95,942)
September: (94,271)
D. The total curtailment for Schedule 10 is shown on Page 4.3.2 of Exhibit 12, and is
shown below. This amount includes actual curtailment that occurred during the
2007 test period and the estimated increase in curtailment described in Part C
above.
June: (127,973)
July: (173,420)
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
lIP A Data Request 15
August: (120,129)
September: (114,594)
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 16
LIP A Data Request 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 Jurisdiction and
how Monsanto is treated in the class cost of service study.
Response to IIPA Data Request 16
This answer assumes that the term "revenue credits" in this data requests refers to
bil credits given to Monsanto in exchange for the right to interrpt or curtail
service under the terms of its service contract.
These credits are treated as a system power cost because the curtailments are an
acquisition of power to meet system load. This cost is allocated to all states and
all customers based on jurisdictional and cost of service allocation factors just as
other system power costs are allocated.
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 17
LIP A Data Request 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.
Response to I1PA Data Request 17
Please refer to Attachment LIP A 17, rows i 7 and i 8, columns 4 and 5 for the 2006
energy consumed and revenue collected. This attachment is a copy of Exhibit 31
fied in the previous general rate case, PAC-E-07-05. Exhibit 23, columns 5 and 6
are the energy consumed and revenues collected for 2007.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT LIP A 17
ON THE ENCLOSED CD
PAC.E.08-07/Rocky Mountain Power
December 31, 2008
lIP A Data Request 18
LIP A Data Request 18
For the year 2007 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 18
Please refer to Attachment IIPA i 8.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 18
ON THE ENCLOSED CD
PAC~E-08-071R0cky Mountain Power
December 31, 2008
lIPA Data Request 19
I1PA Data Request 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 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 19
a, No, and it has not weather normalized irrigation load in the past.
b. Please refer to Attachment lIP A 19 b.
c, Please refer to Attachment LIP A 1 9 b.
d. Demand is not weather normalized.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 19b
ON THE ENCLOSED CD
P AC-E-08-07/Rocky Mountain Power
December 31, 2008
lIP A Data Request 20
LIP A Data Request 20
Regarding the Irrigation Load Control Program credit addressed on Page 1 I 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?
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 20
a. Yes. The $6,570,000 represents the proforma revenue credits for calendar year
2008.
b. This credit is allocated to customer classes on the composite energy/demand cost
of service allocation factor, FlO.
c. Yes, these costs are allocated to all customer classes according to their FlO
allocation factor. The complete list of cost of service allocation factors can be
found on Tab 5, Page 1 of Exhibit 22.
d. Credits to Monsanto are treated as a system power cost and are allocated to all
customers in PacifiCorp's six-state system. Please refer to the response to LIP A
Data Request 16 for more details,
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 22
IIPA Data Request 22
Please provide electronically a listing of all dates, times, and expected magnitude
of all dispatched and scheduled day curtailments when Idaho irrigation load was
curtailed under Schedule 72A since January 2007.
Response to lIP A Data Request 22
Please refer to Attachment IIPA 22 -1 and Attachment LIP A 22 -2.
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 22 -(1-2)
ON THE ENCLOSED CD
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
UP A Data Request 23
IIPA Data Request 23
Please provide a biling summar for the Irrigation customers for each month
since January 2003 showing; total revenue, KWh, revenue based on energy,
biling demand, revenue based upon biling demand, customers biled, and
revenue based upon customers biled.
Response to lIP A Data Request 23
Please refer to Attachment UP A 23. The requested information is readily
available only for the period from Januar 2004 through November 2008.
IDAHO
PAC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT IIPA 23
ON THE ENCLOSED CD
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
LIP A Data Request 25
LIP A Data Request 25
For each month since January 2007, please supply the level (as well as
mechanism such as mils per kWh etc.) of the BPA credit that was applied to each
rate schedule.
Response to lIP A Data Request 25
Please refer to Attachment IIPA 25. The Non-Irrigation rate was reduced to zero
effective June 1, 2007 and the Irrigation rate was reduced to zero effective July
13,2007. BPA revenues continued through the remainder of the year due to pro-
ration of bils, the processing of lingering bils and the correction of bils for
periods when the BP A credit was not equal to zero.
"
IDAHO
P AC-E-08-07
2008 GENERAL RATE CASE
ROCKY MOUNTAIN POWER
IIPA DATA REQUEST (1-35)
ATTACHMENT LIP A 25
ON THE ENCLOSED CD
I,
PAC-E-08-07/Rocky Mountain Power
December 31, 2008
IIPA Data Request 33
LIP A Data Request 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 Irrigation peak load from Sales level to Input level?
Why would these loss percentages not be the same?
Response to lIP A Data Request 33
The line loss figure used in Exhibit 12 is the transmission voltage line loss factor,
because loads used in the JAM are measured at transmission voltage. The cost of
service study uses a demand loss factor for secondary lines of 1,1467, based on
the Company's most recent line loss study, because the irrigation loads in the
COS are based on metered loads at the secondar voltage leveL. This input is
shown on the Inputs tab of the cost of service model in cell C 17. The loss figures
are not the same because the loads are measured at different voltage levels.
"
PAC-E-08-07/Rocky Mountain Power
December 3 i, 2008
IlPA Data Request 35
lIP A Data Request 35
Please provide a copy of Rocky Mountain Power's 2007 FERC Form 1.
Response to liP A Data Request 35
Please refer to Attachment IIPA 35. A hard copy is being provided to the
requesting party.