20100701PAC partial to IIPA 1-53.pdf

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RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-10-07
lIPA Data Request (1-53)
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Please find enclosed Rocky Mountain Power's responses to lIP A Data Requests I, 2, 8, 14, 17,
19,20-22,32, and 46-48. The remaining responses will be provided separately. Provided on the
enclosed CD are Attchments lIPA la, If, 2d, 8a, 19,20, 21c, 21d, 2'lg, 21h, 22c, 22e, and 22h.
Provided on the enclosed Confdential CD are Confidential Attchments LIP A 21-( a,f) and 22a.
Confdential Attachments are Confdential and are provided to paries that have signed a
protective order in this docket.
If you have any questions, please feel free tocall me at [phone].
Sincerely,
J. r'td tv.eWkw
J. Ted Weston
Manger, Regulation
Enclosure:
C.c. Rady budge/Monsanto
Michael C. Creamer/ Agrium
Jean Jewell/UC
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 1
lIP A Data Request 1
Please answer the following with respect to information contaned on McDougal's
Exbit 2, Tab 10 entitled "Allocation Factors":
A. On pages 10.13 through 10.18, are these actual generation level energy and
demand values recorded for each jursdiction durng each of the months
specified? If not, please provide the actual values.
B. Do the demand values on page 10.13 for Idaho include Monsanto load that has
been interrpted?
C. Are the values/adjustments on page 10.13 though 10.18 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
detal for each "other" adjustment).
D. Are the demand and energy values. on pages 10.13 though 10.1 8 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 10.14, 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 tht
support the calculations on Tab 10.
G. Please provide an electronic copy of all workpapers and/or calculations that
support the adjustments to actu values for both demand and energy for each
jursdiction listed in Tab 10.
Response to lIP A Data Request 1
A. The energy and demand values on pages 10.13 though 10.18 are for the 12
months ended December 31, 2010. These were used in the fiing instead of
the 2009 actu values in order to reflect load at a normalized level for the test
penod as descnbed in Mr. Peter C. Eelkema's testimony. Pleae refer to
Atthment IIP A 1 a for the actu energy and demand values for the 12
month ended December 31, 2009.
B. The demand values for the Idao jursdiction are reflected as if there is no
interrption to Monsanto load.
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 1
C. The values/adjustments shown on pages 10.13 though 10.18 are not weather
(temperature) adjustments. The adjustments shown are to properly reflect
curilment of irrgation and Monsanto load for cost allocation purposes. The
adjustments to Idao load on page 10.13 are related to the irrgation load
control program, and the adjustments to Idaho load on page 10.14 are related
to Monsanto curlment. Adjustments to Uta load represent load
curlment related to special contract customers and demand side
management programs in Uta.
D. Yes.
E. The adjustments to Idaho load on pages 10.13 and 10.14 represent
curailments to irrgation class and Monsanto load. These adjust the
jursdictional load for allocating costs between jursdictions.
F. Please refer to Attchment lIP A 1 f.
G. Electronic copies of work papers to support Tab 10 are provided as
Attachment lIPA If. . The calculations of Tab 10 are preformed in the
Jurisdictional Allocation Model (JAM) which was provided as Attachment
Monsanto 1.19 and as par of Steve McDougal's Exhbit NO.2 workpapers.
Hard copies of Tab 10 were provided as par of the Exhbit 2.
Recordholder:
Sponsor:
Steven R. McDougal / Peter Eelkema
Steven R. McDougal / Peter Eelkema
P AC-E-1 0-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 2
lIP A Data Request 2
Please answer the following with respect to information contained on Paice's
Exhbit 49, 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 Mounta time?
C. How do the total jursdictional values for each month on page 6 relate to the
Idaho values on McDougal's Exhibit 2, 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? If the data
came from load research data but was adjusted, please provide an electronic
copy of all workpapers and/or calculations that support the adjustments to
actual values.
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? If the
data came from biliing data, but was adjusted, please provide an electronic
copy of all workpapers and/or calculations that support the adjustments to
act values.
F. What was the level of curilment/interrption for each customer class or
Monsanto durng the times of each of the monthy peak listed on page 7?
(Please specify at input leveL.)
G. Is there any weather normalization of the Distrbution 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 ths normalization. '
Response to lIP A Data Request 2
A. Yes.
B. Mounta time.
C. Pleas refer to the Company's response to lIP A Data Request 8.
D. Schedule 001
Schedule 036
Load Reseh Data
Load Reseah Data
Jan09-Dec09
Jan09-Dec09
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
UP A Data Request 2
Schedule 006 Load Research Data Jan09-Dec09
Schedule 023 Load Research Data Jan09-Dec09
Schedule 019 Load Research Data 1996, 1998, 1999
Schedule 010 Load Research Data '05-'09 Irrg. Seasons
Schedule 009 Census Data Jan09-Dec09
Contract 1 Census Data Jan06-Dec08
Contract 2 Census Data Jan09-Dec09
Please refer to Attchment LIP A 2d for a listing of adjustments to actul values.
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
Jan06-Dec08
E. Schedule 001 Est. From Load Research Data
Schedule 036 Est. From Load Research Data
Schedule 006 Est. From Load Research Data
Schedule 023 Est. From Load Research Data
Schedule 019 Est. From Load Research Data
Schedule 010 Est. From Load Research Data
Schedule 009 Est. From Load Research Data
Contract 1 Est. From Load Research Data
Contract 2 Est. From Load Research DataSchedule 007 Biling DataSchedule 011 Biling Data
Schedule 0 l2 Biling Data
Please refer to Attchment LIP A 2d for a listing of adjustments to actu values.
F . Please refer to the Company's responses to IIP A Data Requests 15 and 16(b).
G. There is no weather normalization of the distrbution peak data or non-
coincident data.
Recordholder:
Sponsor:
C. Craig Paice / Scott D. Thornton
C. Craig Paice
P AC-E-1 0-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 8
LIP A Data Request 8
On Exhibit 2, page 10.13 there is a different coincident peak value for Idaho (406)
for Januar 2010 than the value used on Exhbit 49 pages 6 and 7. Please provide
all data equations, and assumptions used to develop the figue on both Exhbit 2
and Exhbit 49. Please supply ths data in Excel format. Explain how, if at all,
the jursdictional data from Exhbit 49 (pages 6 and 7) flows through or is
incorporated in Exhibit 2 Tab 10.
Response to lIP A Data Request 8
Idaho jursdiction loads on Exhbit 2, page 10.13 were developed from adjusted
state jursdictional loads as explained in Company witness Peter C. Eelkema's
testimony. Class loads on Exhbit 49, Tab 5, pages 6 and 7 were developed from
both sample and direct census Load Research data. Therefore, because they are
from different data soures and used for different puroses, class loads do not
directly flow though to the Idaho state jursdiction load.
Please refer to Attachment lIP A 8a for the support for class loads and Atthment
lIP A If for support for page 10.13 of Exhibit i.
Recordholder:
Sponsor:
C. Craig Paice
C. Craig Paice
P AC-E-1 0-07/Rocky Mountain Power
June 30, 2010
UP A. Data Request 14
IIPA Data Request 14
Do the values in Exhbit 2, Tab 10, reflect Idaho demand and energy requiements
by assuming that there are no curlments/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 14
For the puroses of allocating costs among the Company's jursdictions Idaho's
demand and energy requirements are computed in Exhbit 2, Tab 10, to reflect
Idaho load assuming that there are no curlments/interrptions to Monsanto.
Please refer to the Company's response provided to lIP A Data Request 1,
specifically par b.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
LIPl\ Data Request 17
LIP A Data Request 17
Please explain how any revenue credits to Monsanto are addressed in ths case in
relationship to Monsanto's inclusion/exclusion infrom the Idao Jursdiction and
how Monsanto is treated in the class cost of service study.
Response to lIP A Data Request 17
This answer assumes that the term "revenue credits" in this data request refers to
bil credits given to Monsanto in exchange for the nght to interrpt or curl
service under the terms of its service contract.
These credits are treated as a system power cost because the curailments are an
acquisition of power to meet system load. This cost is allocated to all states and
all customers based on jursdictional and cost of service allocation factors just as
other system power costs are allocated.
Because Monsanto's "revenue credit" or purchased power cost is system allocated
any peak or energy reduction achieved by the curailment is not reflected in Idaho
load for jursdictional and cost of service allocation puroses. Please refer to the
Company's responses to lIPA Data Requests 1b and 15.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
lIPA Data Request 19
LIP A Data Request 19
For the year 2005--2009 list by FERC account the amount of Distnbution plant
that is associated (allocated or directly assigned) with each jurisdiction.
Response to lIP A Data Request 19
Please refer to Attachment lIP A 19.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
lIPA Data Request 20
LIP A Data Request 20
For the year 2005--2009 list by FERC account the amount of Transmission plant
that is associated (allocated or directly assigned) with each jursdiction.
Response to lIP A Data Request 20
Please refer to Attchment lIPA 20.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R.. McDougal
PAC-E-1O-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 21
IIPA Data Request 21
Beginnng on page 5 line 22 of Mr. Eelkema' s testimony there is a discussion
regarding the development of the company's models for sales per residential
customer:
a. Please provide in electronic format (Excel) the historical and/or projected
data/drivers used to develop the Residential modeL.
b. Was there a single model for the residential class, or a separate one for Schedule 1
and Schedule 36 customers? If only one model was ru, how was the projected
usage spread between the two rate schedules?
c. For each of the last 20 years, what has been the actul sales per residential
customer, schedule 1 customer, and schedule 36 customer?
d. For each of the last 20 years, what has been the weather normalized sales per
residential customer, schedule 1 customer, and schedule 36 customer?
f. For each of the last 20 years, what has been the calculated/utilized HDD and CDD
data used by the Company for the Idaho jurisdiction?
. g. What are the test year weather normalized sales per residential customer, schedule
1 customer, and schedule 36 customer?
h. What does the company consider normal anual HDD andCDD values for its
Idaho service terrtory?
Response to lIP A Data Request 21
a. Please refer to Confidential Attchment lIPA 21a for the relevant data used to
develop the Residential ModeL.
b. There is one residential class modeL. Please refer to page 10 lines 9-21 of Dr.
Eelkema's direct testimony for the discussion of the development of test year rate
schedules sales.
c. Please refer to Attchment IIP A 21 c for the actu sales per residential customer
for the most recent 20 years, actual sales per Schedule 1 bil for the most recent
13 years, and actul sales per Schedule 36 bil for the most recent 13 years. Only
i 3 years of actu sales per Schedule 1 and Schedule 36 bil is available.
d. Please refer to Attchment lI A 2 i d for the weather normalized sales per
residential customer for the most recent i 2 years, weather normalized sales per
residential schedule 1 bil for the most recent 4 years, and weather normalized
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 21
sales per residential schedule 36 bil for the most recent 4 years. The Company
has calculated weather normalized anual per customer values for the residential
customer class for only the most recent 12 years. The Company has calculated
weather normalized anual per bil values for the residential schedules 1 and 36
for only the most recent 4 years.
e. No Question.
f. Please refer to Confidential Attchment LIP A 21 t for the weighted CDD and
weighted HDD used by the Company to develop Idaho Residential test year sales.
g. Please refer to Attachment lIP A 21 g for the relevant test year weather normalized
sales.
h. Please refer to Attchment LIP A 21h for the normal weighted CDD and normal
weighted HDD data used by the Company for the development of residential
Idaho customer class sales.
Confidential information is provided subject to the terms and conditions ofthe
protective agreement in this proceeding.
Recordholder:
Sponsor:
Peter C. Eelkema
Peter C. Eelkema
P AC-E-1 0-07/Rocky Mountain Power
June 30, 2010
UP A Data Request 22
LIP A Data Request 22
Beginng on page 6 line 8 of Mr. Eelkema's testimony there is a discussion
regarding the development of the company's models for sales per "other"
customer classes:
a. Please provide in electronic format (Excel) the histoncal and/or projected
data/dnversused to develop the Irrgation model used in this case.
b. Please provide all workpapers that support the weather or other normalizing
adjustment to monthy Irgation revenues in ths case.
c. For each of the last 20 years, what has been the actul monthly sales per
Irgation customer?
d. Please provide all workpapers that support the monthy weather normalizing
adjustment to the Irgation monthy demands in this case.
e. For each of the last 20.years, what has been the monthly weather normalized
sales per Irrgation customer?
f. For each ofthe last 20 years, what has been the calculated/utilzed monthy
precipitation data available to and/or used by the Company for the Idaho
jursdiction?
g. What does the company consider normal monthly precipitation values for its
Idaho service terrtory?
h. What are the test year weather normalized sales per Irrgation customer?
Response to lIP A Data Request 22
a. Please refer to Confdential Attchment lIP A 22a for the relevant data used to
develop the Irgation ModeL. Confdential inormation is provided subject to
the term and conditions of the protective agreement in this proceeding.
b. There are no weather or other normalizing adjustments to test year irrgation
revenues in ths case.
c. Pleae refer to Attchment LIP A 22c for the actu monthy sales per irgation
cusomer.
d. The test year is pased on sales tht would occur given normal weather. Hence
no weather adjustment was made to irgation monthy demand.
P AC-E-1 0-07/Rocky Mountain Power
June 30, 2010
IIP A Data Request 22
e. Please refer to Attchment LIP A 22e for the weather normalized monthly sales
per irrgation customer.
f. Precipitation data was not used by the Company to develop irrgation sales.
g. Please refer to the Company's response to lIP A Data Request 22f above.
h. Please refer to Attchment LIP A 22h for the test year weather normalized sales
per irrigation customer.
Recordholder:
Sponsor:
Peter C. Eelkema
Peter C. Eelkema
PAC-E-10-07/Rocky Mountain Power
June 30, 201 0
LIP A Data Request 32
LIP A Data Request 32
Regarding the values on page 10.13 of Company Exhibit 2, please answer the
following:
a. Are the "Metered Loads" at the top of the page actua (unaltered in any way)
values for each junsdiction at the time of the monthly system energy in 2009?
b. What is the specific basis for the first set of adjustments to the Utah energy
load?
c. Why are there no adjustments in the first set of adjustments (decreases) to the
Idaho energy load?
d. Why.are there values each month for both Idaho and Uta shown for the
second set of adjustments which is suppose to include the "normalization of
Irrgation and Monsanto"?
Response to lIP A Data Request 32
a. The metered loads at the top of the page are the forecasted values for 2010.
They are not altered by curlments or buy"'though.
b. These adjustments are made to reflect curilment at the time ofPacifiCorp's
monthy coincident peak for US MagCorp.
c. Adjustments required to Idaho energy were addressed in the second set of
adjustments.
d. The second set of adjustments is related to Ancilar Services Contracts
including reserves. Affected customers are in both Idaho and Utah.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
UP A Data Request 46
LIP A Data Request 46
Please list all benefits reflected in the Company's case for the system as a whole
of the Idaho Irrgation Load Control Program. Please quantify these benefits by
reruing the Company's Net Power Cost Model and other appropnate models
without the Idaho Irrigation Load Control Program.
Response to lIP A Data Request 46
The Company objects to ths question on the grounds that it is overly broad and
vague. Without waivig its objection, the Company states that its case is
compnsed of costs and revenues and the Company does not attempt to assign any
specific benefits to the system or any paricular state. Consequently, the
requested studies have not been performed. The Company assigns the Idaho
Irrgation Load Control Program costs situs to Idaho, and Idaho's allocation factor
is calculated using coincident peaks that reflect reduced irrgation load based on
program paricipation durng the irgation season. Because the Idaho Irrgation
Load Control Program is designed to shift energy and not reduce consumption, it
is expected to have little effect on net power costs.
The Company has estimated the system value of the Idao Irgation Load Control
Program for cost-effectiveness evaluation using a methodology first developed in
2007 and reviewed by the LIP A. Ths methodology captues the capacity deferral
benefit of the resource via displacement of simple cycle combustion tubine proxy
resources and firm market purchases. The latest estimate, $73.09 kW-year, was
prepared in April 2009 and cited in the Company's 2009 dispatchable irgation
progr report.
Recordholder:
Sponsor:
Gregory N. Duvall
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
LIP A Data Request 47
IIPAData Request 47
Please list all benefits reflected in the Company's case for the Idaho jursdiction
of the Idaho Irgation Load Control Program. Please quatify these benefits by
reruing the Company's Net Power Cost Model, Jurisdictional Allocation
Model, and other appropnate models without the Idaho Irgation Load Control
Program.
Response to lIP A Data Request 47
Please refer to the Company's response to IIPA Data Request 46.
Recordholder:
Sponsor:
Gregory N. Duvall
Hui Shu
PAC-E-10-07/Rocky Mountain Power
June 30, 2010
IIPA Data Request 48
LIP A Data Request 48
Please list all benefits reflected in the Company's case for the Idaho Irgation
Schedule 10 of the Idaho Irgation Load Control Program. Please quatify these
benefits by rerung the Company's Net Power Cost Model, Jursdictional
Allocation Model, Class Cost-of-Service Model, and otherappropnate models
without the Idao Irrigation Load.Control Program.
Response to lIP A Data Request 48
Please refer to the Company's response to lIP A Data Request 46.
Recordholder:
Sponsor:.
Gregory N. Duvall
Hui Shu