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Home My WebLink About20100716IIPA 54-66 to PAC.pdfLAW OFFICES OF RACINE OLSON NYE BUDGE Be BAILEY CHARTEREDW. 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 ERIC L. OLSEN CONRAD J. AIKEN RICHARD A. HEARN, M.D. LANE V. ERICKSON DAVID E. ALEXANDER PATRICK N. GEORGE SCOTT J. SMITH JOSHUA D. JOHNSON STEPHEN J. MUHONEN BRENT L. WHITING JONATHON S. BYINGTON DAVE BAGLEY CAROL TlPPI VOLYN THOMAS J. BUDGE CANDICE M. MCHUGH JONATHAN M. VOLYN MARK A. SHAFFER Jean D. Jewell, Secretar Idaho Public Utilities Commission PO Box 83720 Boise, Idaho 83720-0074 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 23~6101 FACSIMILE (208) 232-6109 ww.racinelaw.net SENDER'S E-MAIL ADDREss:elo(§racinelaw.net July 14,2010 Re: Case No. PACt.E-I0-7 Dear Ms. Jewell: BOISE OFFICE 10t SOUTH CAPITOL BOULEVARD, SUITE 208 BOISE, IDAHO 83702 TELEPHONE: (208) 395-00' 'I FACSIMILE: (208) 433~0167 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 203A IDAHO FALLS, ID 83402TELEPHONE: (208) 528-6101 FACSIMILE: (208) 528-6109 COEUR D'ALENE OFFICE 250 NORTHWEST BOULEVARD, SUITE t06A COEUR D'ALENE, ID 83814TELEPHONE: (208) 765-6888 ALL OFFICES TOLL FREE (877) 232-6101 LOUIS F. RACINE (1917-2005)WILLIAM D. OLSON, OF COUNSEL ~--c: s; 0'rn i::i 9?oN ,'.~,:.;i Enclosed for fiing in the captioned matter, please find the original and three copies of Idaho Irrigation Pumpers Association, Inc. 's Second Data Requests to Rocky Mountain Power Company. ELO:rg Enclosures cc: Service List Eric L. Olsen ISB# 481 1 RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: (208) 232-6101 Fax: (208) 232-6109 R-.r- -rt.~ j. 't..Cl D 28fU JUt l 6 AM 8= 02 I Di'J1C' UTIIITlt-c:iLI. jCv Attorneys for the Idaho Irrgation Pumpers Association, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF ROCKY MOUNTAIN POWER FOR ) APPROV AL OF CHANGES TO ITS ) ELECTRIC SERVICE SCHEDULE AND A ) PRICE INCREASE OF $27.7 MILLION OR ) APPROXIMATELY 13.7 PERCENT ) ) ) ) CASE NO. PAC-E-10-07 IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER COMPANY IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S SECOND DATA REQUESTS TO ROCKY MOUNTAIN POWER COMPANY IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and through its attorneys, hereby submits this Second Data Requests to Rocky Mountain Power Company ("RMPC"), pursuant to Rule 225 of the Idaho Public Utility Commission's Rules of Procedure, IDAPA 31.01.01, as follows: 54. With respect to IIPA Data Request 12, information was not requested by individual customer. Please provide the requested information on an aggregated or system basis. 55. Regarding the data provided in response to IIPA Data Requests 33a and 33b, please provide the following: A. What level are the values listed at (Generation, Transmission, Sales, etc.)? B. Assuming that these values were the actual levels served, please provide in electronic format the level of interrption and/or curailment that took place durng each hour. IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 1 C. Is it possible to add all values for a given month and come up with the published monthly energy figures or does some adjustment need to be made? Please specify. 56. The response to IIP A Data Request 3 included summar data for Irrgation customers which was a 5 year average for (presumably) the average customer. Please provide the actual load research information by sample customer for the Irrgation class for each of these five years as was provided for the other customer classes as listed in the response to Request 3. 57. Because the Company appears to be proposing the usage of the average of 5 years of irrgation data for the Irrgation customers, please provide load research data (similar to that provided in the response to IIPA Data Request 3) for Schedules i, 36, 6, and 23. 58. Because the Company appears to be proposing the usage of the average of 5 years of irrgation data for the Irrgation customers, please provide the five year average data (similar to that provided in the response to IIP A Data Request 3 for the Irrgation customers) for Schedules 1,36,6, and 23. Please describe the method used and all calculations that were used to tae the individual load research data for each sample customer in order to develop the average for the rate schedule over the five years. 59. Regarding the tab labeled" Adjfactors" in the Company's response to IIPA request 3, please explain how the following figures are calculated and/or what they represent: A. kWh sample B. Pricing kWh C. Fore. kWh 60. The response to IIPA Data Request 6 indicated that new strata boundares for the lITigation class were determined in 2008-2009. Please explain (if a new sample was not developed) which sample customers (by sample number or some other identification process) were associated with each of the previous four strta and which are now associated with each of the present thee strata. 61. The response to IIP A Data Request 7 contained by rate schedule the weather normalized change in kWh usage and the price of those kWh. Please provide the "normal weather" values, the difference from "normal" that had to be normalized, and the equations and/or assumptions used to establish the prices used in that response. IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 2 62. The response to IIP A Data Request 16a indicates that base year load measurements and estimates were adjusted to match test year energy. Does this mean that a ratio is established between a given monthly demand figure for a given rate schedule and the monthly energy, and then that ratio is simply applied to the new test year energy level? 63. The response to IIP A Data Request 16b indicates that the irrigation curtailment is based upon a five year average. Please supply for each month the specific averages that went into making up the five year average curailment that was used. 64. The response to IIP A Request 25 contained the 2008 report on the Irrgation Load Management Program. On page 11 of that report there-is listed 192,542.4 kW of dispatchable program load that was interrpted on June 18, 2008. Please answer the following: A. Is this the actual k W of load that was reduced, or is it the potential load (depending upon if the load was actually being served at the time)? B. If this figure was the potential load, how does the Company calculate the actul/estimated load that was interrpted, and what would that figure be in this case? C. Is the 192,542.4 figure based upon sale level, transmission level, or generation level? D. Please provide a generalized response to requests a, b, and c above for the data listed on pages 12- 1 5 of the 2009 Load Management Report. 65. With respect to the Response to IIPA Request 38, please answer the following: A. With respect to tab "EstNCP's" of the spreadsheet, at cell G27 the June 2009 value for the Irrgators is 349,732. What is meant by the NCP value, how was this value derived, and how does it relate to the June values listed tabs "NCP1", "NCP2", and "NCP3"? B. With respect to tab "EstNCP's" of the spreadsheet, at cell G27 the June 2009 value for the Irrgators is 349,732. How is this value for 2009 incorporated into the class cost of service study in this case? C. With respect to tab "NCP3" of the spreadsheet, at cell G27 the June 2008 value for the Irrgators is 454,766. How is this value ultimately incorporated into the class cost of service study in this case? D. With respect to tab "NCP3" of the spreadsheet, at cell G27 the June 2008 value for the Irrgators is 454,766. How is this value derived/calculated? IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 3 E. With respect to tab "NCP3" of the spreadsheet the 2008 values on line 27 for the Irrgators totals 1,760,244. How does this value relate to the values ofkW biling for 2008 for the Irrigators of only 1,323,028 found in the Company's response to IIPA Request 26? We are seeking a reconciliation of the vast difference in these two values. F. With respect to tab "RateSch" of the spreadsheet, at cell G27 the June 2009 value for the Irrgators is 286,224. What is meant by this schedule peak value, how was this value derived, and how does it relate to the June values listed tabs ""RateSch1", "RateSch2", and "RateSch3"? G. With respect to tab "RateSch" of the spreadsheet, at cell G27 the June 2009 value for the Irrigators is 286,224. How is this value for 2009 incorporated into the class cost of service study in this case? H. With respect to tab "RateSch" of the spreadsheet, at cell G27 the June 2009 value for the Irrgators is 286,224. How is this value derived/calculated? 66. With respect to the Response to IIP A Request 40, par "c" asked for the time and date of each substations monthly peak. If this information is available, please provide it. It this information is not available, please so indicate. RACINE OLSON NYE BUDGE & BAILEY, CHARTERED ~BY.~ ERIC L. OLSEN IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 4 CERTICATE OF MAING . i£-lfAi HEREBY CERTIFY that on this day of July, 2010, 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 jewelicmpuc.state.id. us vt.S. Mail/Postage Prepaid l/-Mail Facsimile Overnight Mail Hand Delivered Ted Weston Idaho Regulatory Affairs Manager 201 South Main, Suite 2300 Salt Lake City, UT 84111 ted. westoncmpacificorp.com ¿U.S. Mail/Postage Prepaidl--Mail Facsimile Overnight Mail Hand Delivered Electronic Copies Only: Mark C. Moench Daniel E. Solander PacifiCorp/dba Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, UT 84111 mark.moenchcmpacificorp.com daniel.solandercmpacificorp.com U.S. Mail/Postage Prepaid7E-Mail Facsimile Overnight Mail Hand Delivered Data Request Response Center Pacificorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 datareguestcmpaciíìcorp.com U.S. Mail/Postage Prepaid vP-Mail Facsimile Overnight Mail Hand Delivered Scott Woodbur Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 Boise, Idaho 83720-0074 scott. woodbur(âpuc.idaho.gov U.S. Mail/Postage Prepaid~-Mail Facsimile Overnight Mail Hand Delivered Randall C. Budge Racine Olson Nye Budge & Bailey Chtd. U.S. Mail/Postage Prepaid E-Mail IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 5 P.O. Box 1391; 201 E. Center Street Pocatello, Idaho 83204 rcb(£racinelaw.net Facsimile Overnight Mail l ~d Delivered VÚ.S. Mail/Postage Prepaid~Mail Facsimile Overnight Mail Hand Delivered Katie Iverson Brubaker & Associates 17244 W. Cordova Cour Surrise, AZ 85387 kiverson(fconsultbai .com Electrnic Copies Only: James R. Smith Monsanto Company P.O. Box 816 Soda Springs, ID 83276 Jim.r .smith(fmonsanto.com U.S. Mail/Postage Prepaid~-Mail Facsimile Overnight Mail Hand Delivered Michael C. Creamer Kelsey J. Nunez GIVENS PURSLEY LLP 601 W. Banock Street P.O. Box 2720 Boise, ID 83701-2720 mcc(fgivenspursley.com KelseyN unez(fGivensPursley .com VU.S. Mail/Postage Prepaid i/-Mail Facsimile Overnight Mail Hand Delivered Tim Buller Jason Hars Agrium Inc. 3010 Conda Road Soda Springs, ID 83276 TBuller(iagrium.com J AHars(fagrum .com l/U .S. Mail/Postage Prepaid~Mail Facsimile Overnight Mail Hand Delivered Benjamin J. Otto Idaho Conservation League 710 N. 6th Street PO Box 844 Boise, Idaho 83702 botto(iidahoconservation.org V=U.S. Mail/Postage PrepaidV1-Mail Facsimile Overnight Mail Hand Delivered Melinda J. Davison Davison Van Cleve, P.C. 333 SW Taylor, Suite 400 Portland, OR 97204 mjd(idvclaw.com ~y.s. Mail/Postage Prepaid t,E- Mail Facsimile Overnight Mail Hand Delivered IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 6 .. f , ., Ronald L. Williams Wiliams Bradbur, P.C. 1015 W. Hays St. Boise, Idaho 83702 ron((williamsbradbury .com i/.s. Mail/Postage Prepaid VE-Mail Facsimile Overnight Mail Hand Delivered Brad M. Purdy Attorney at Law 2019 N. 17th Street Boise, Idaho 83702 bmpurdy'ihotmail.com ~ U... Mail/Postage Prepaid ~-Mail Facsimile Overnight Mail Hand Delivered IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S SECOND DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 7