20100813IIPA 83-98 to PAC.pdf

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
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 TIPPI VOLYN
THOMAS J. BUDGE
CANDICE M. MCHUGH
JONATHAN M. VOLYN
MARK A. SHAFFER
LAW OFFICES OF
RACINE OLSON NYE BUDGE Be BAILEY
CHARTERED BOISE OFFICE
lOt SOUTH CAPITOL
BOULEVARD. SUITE 208
BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: [phone]
20\ EAST CENTER STREET
POST OFFICE BOX \39\
POCATELLO, IDAHO 83204-\39\
TELEPHONE [phone]\
FACSIMILE [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUlTE 203A
IDAHO FALLS, ID 83402
TELEPHONE: (208) 528;'6101
FACSIMILE: [phone]ww.racinelaw.net
COEUR D'ALENE OFFICE
250 NORTHWEST
BOULEVARD, SUITE tOSA
COEUR D'ALENE. ID 83814TELEPHONE: [phone]
SENDER'S E-MAIL ADDREss:elo(Qracinelaw.net
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)WILLIAM D. OLSON. OF COUNSEL
August 10, 2010
~~e:~G'-i"'n
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
w
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co..o-J
Re: Case No. PAC-E-IO-07
Dear Ms. Jewell:
Enclosed for fiing in the captioned matter, please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's Fifh Data Requests to Rocky Mountain Power Company.
ELO:rg
Enclosures
cc: Service List
:¡z-CJ-oec.)
Eric L. Olsen ISB# 481 1
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204- 1391
Telephone: [phone]
Fax: [phone]
~r_L: it)
2910 AUG 1 Q R. MS.v lin. :07
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 )
APPROVAL 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 IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIFTH
DATA REQUEST TO
ROCKY MOUNTAIN POWER
COMPANY
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S FIFTH DATA REQUESTS
TO ROCKY MOUNTAIN POWER COMPANY
IDAHO IRRGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and
through its attorneys, hereby submits this Fift 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:
83. Regarding the Response to IIPA Request 16-b, please supply:
a. The specific "actual load research sample data" that was used for each of the five
years (Please supply this information by sample customer if this was the source of
the data.).
b. Please detail how this data was "adjusted to test period energy."
c. Please explain why five years of historical data is being used where there has been
such a large change in the program over that period.
d. How does the five years of historic data incorporate (or not incorporate) Irrigation
curailments?
IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S
FIFfH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 1
84. What was the number of customers used during each month in order to establish the
use per customer data that was supplied in Response to IIP A Request 22-e.
85. What are the number ofIrrgation customers used/assumed durng each month in test
year?
86. Please provide the meter reading and biling schedules for Irrgation customers for
each month from Januar 2000 through December 2010.
87. Please provide for each month from Januar 1990 though December 2009 the
calendar (sometimes referenced by the Company as "pricing kWh") month usage
level of Irrigation customers.
88. According to the Company's Response to IIPA Request 22, it weather normalizes
Irrgation usage:
a. Please provide in Excel format all input data used to weather normalized
Irrgation usage data.
b. What is the source(s) of the weather data that is used to normalize Irrgation
usage?
c. Please provide a copy of all original documents in the Company's possession that
were used to weather normalize Irrgation data.
e. Please provide a copy of the statistical results of the regression analysis that was
ru upon which the Irrgation usage levels were normalized in this case (R-square,
t-statistic, residuals, etc.).
f. With respect to the response to IIPA Request 22-f, what was the formula used to
weather normalize the actual data that was provided in response to 22-c?
g. Was the data provided in response to IIP A Requests 22-c and 22-e on a calendar
or biling month basis?
89. If the Company has ever considered/attempted to weather normalize Idaho Irrgation
data based upon other weather variables in addition to cooling degree day, please
answer the following:
IDAHO IRRGATION PUMERS ASSOCIATION, INC.'S
FIFm DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 2
a. Why has the Company chosen to not include those weather variables in the
normalization used in this case?
b. Please provide copies (in Excel format if available) of the data associated with
these other weather varables that the Company considered before.
90. The response to IIPA Request 64-b indicates that the Company used a '"potential"
curailment for Irrgators of 229 MW in its development of the class peaks. The
potential available load for curtailment from the November 14, 2009 curtilment
report at Table Twenty is approximately 240 MW. Please answer the following:
a. What is the amount of curtailment that is available (at sales level) for the
dispatchable program for the 201 0 Irrgation season in Idaho?
b. Why was a value of only 229 MW of potential interrptibility chosen for the test
year as opposed to the level available in 2009 or 2010?
91. Please provide for each hour from Januar 1,2005 through the most recent data
available:
a. The actual jursdictional loads on the same basis as that presented in Exhibit 2,
Tab 10 for jurisdictional allocation puroses.
b. If there were interrptions/curailment of non-contract customer load durng any
of these hours, what was the level of that curtailment or what would the
jurisdictional load have been, absent each of those interrptions/curtailments?
92. The response to IIP A Request 38 contains NCP data and schedule peak data for
2006, 2007, and 2008 for all rate schedules. Please supply similar NCP and schedule
peak data for 2009.
93. Regarding the Irrgation customers in the Company's load research program(s) over
the 2005-2009 timeframe, please identify by the customer identification numbers
already supplied, which customers were in the dispatchable or designated day load
control program for each year. If on the designated day program, please indicate the
day of the scheduled interrptions.
94. An explanation is sought regarding the response to IIPA Request 3 and the
development of the load research data for the Irrigation customers:
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FI DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 3
a. Attachment IIPA 3 for the Irrgators generally lists five years of data (6-Jun-05, 5-
Jun-06, 4-Jun-07, 2-Jun-08, and 1 -Jun-09) for 1 -Jun-09:
1. How are each of these values for each year (hour and day) derived?
n. What customer count is used for each of these years?
11. What weighting factors are used for each stratum for each year's data?
iv. Why are the specific days of6-Jun-05, 5-Jun-06, 4-Jun-07, 2-Jun-08, and
1 -Jun-09 used to develop the 1 -Jun-09 data as opposed to some other
grouping of days from each of the five years?
b. How are the five years of data used/averaged/incorporated in order to produce the
hourly data for 2009?
c. How is the derived 2009 hourly data incorporated into the data that is used in the
fiing? Is this data used to develop demand and/or energy values, and where in
the fiing does it appear?
d. The data lists for 2-Jun-08 at 1 :00 a value of 14.58515 at sales leveL. The load
research data for all sample Irrgation customers was provide in response to IIP A
Request 56. Using the weightings provided, a value of 15.645 at sales level can
be calculated for the 1 :00 time on 2-June-08. Why are these values so different?
e. June 18, 2008 was a day when approximately 200 MW of dispatchable Irrgation
load control was curtailed. The data in IIP A Request 3 does not appear to show
this curilment on June 18, 2008. Please explain how this data was developed
with respect to curtailment (dispatchable and scheduled) on the system.
95. Please provide copies of the Company's 2008, and 2009 FERC Form 1.
96. With respect to the response to IIP A Request 21 -a, the Company provided varous
data for a number of months. What is the meaning of and the significance of the
values listed in the column entitled "Number of Households"?
97. Please explain as well as provide all supporting data that serves as the basis for the
monthly forecasted Irrgation sales in this case. We are looking for the data that was
utilized and the calculations use to take this data and derive the forecast values.
98. The response to IIPA Request 22-c indicated (among other things) that the actual
monthly sales per Irrigation customer for June 2007 was 38,884 kWh per customer.
The response to IIP A Request indicates that for June 2007 there were 115,178,683
kWh of sales to 4,721 Irrigation customers. This equates to 32,872 kWh per
customer (115,178,683/4,721). Please reconcile these two "use/customer" values as
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIFH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 4
well as the other use/customer values in Response 22-c and those that can be
calculated from IIP A 26.
RACINE OLSON NYE BUDGE
& BAILEY, CHARTERED
BY:~
E C L. OLSEN
IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIFfD DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 5
CERTIFICATE OF MAING
l (~V)L
I HEREBY CERTIFY that on this ~day of August, 2010, I served a tre,
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
i jeweiiæmuc.state.id. us
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Ted Weston
Idaho Regulatory Affairs Manager
201 South Main, Suite 2300
Salt Lake City, UT 841 1 1
ted. weston(ipacificorp.com
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Electonic Copies Onl:
Mark C. Moench
Daniel E. Solander
PacifiCorp/dba Rocky Mountain Power
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Scott Woodbur
Deputy Attorney General
Idaho Public Utilities Commission
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Randall C. Budge
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IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIH DATA REQUEST TO ROCKY MOUNTAI POWER COMPAN 6
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Pocatello, Idaho 83204
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IDAHO IRGATION PUMERS ASSOCIATION, INC.'S
FIFTH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 7
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IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S
FIFTH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 8