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Home My WebLink About20100816IIPA 99-102 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 TIPPI 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 Re: Case No. PAC-E-I0-7 Dear Ms. Jewell: 201 EAST CENTER STREET POST OFFICE BOX 1391 POCATELLO, IDAHO 83204-1391 TELEPHONE (208) 232-6101 FACSIMILE (208) 232-6109 ww.racinelaw.net SENDER'S E-MAIL ADDREss:elo§!racinelaw.net August 13,2010 BOISE OFFICE 101 SOUTH CAPITOL BOULEVARD, SUITE 208 BOISE, IDAHO 83702 TELEPHONE: (208) 395-001 1 FACSIMILE: (208).433-0167 IDAHO FALLS OFFICE 477 SHOUP AVENUE SUITE 203A IDAHO FALLS, tD 83402TELEPHONE: (208) 528-6101 FACSIMILE: (208) .528-6 ioè COEUR D'ALENE OFFICE 250 NORTHWEST BOULEVARD, SUITE 106A COEUR D"ALENE. 1083814TELEPHONE: (208) 765-6888 ALL OFFICES TOLL FREE (877) 232-6101 LOUIS F. RACINE (1917.2005)WILLIAM D. OLSON. OF COUNSEL~~a:~c;..Cf ~ Cf.. '£ Enclosed for fiing in the captioned matter, please find the original and thee copies of Idaho Irrigation Pumpers Association, Inc_ 's Sixth Data Requests to Rocky Mountain Power Company. ELO:rg Enclosures cc: Service List ¡¡~£~ ;¡z-CJ-a:o Eric L. Olsen ISB# 4811 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 f1 r":4 t: 1 ¡".iJ Z8tOAUG 16 Al1 8: 2 I Attorneys for the Idaho Irrigation Pupers 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 SIXTH DATA REQUEST TO ROCKY MOUNTAIN POWER COMPANY IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S SIXTH DATA REQUESTS TO ROCKY MOUNTAIN POWER COMPANY IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. ("IIPA"), by and though its attorneys, hereby submits this Sixth Data Requests to Rocky Mountain Power Company ("RMPC"), pursuant to Rule 225 ofthe Idaho Public Utility Commission's Rules of Procedure, IDAPA 31.01.01, as follows: 99. The response to Monsanto Request 5.5 was designed to explain how the normalized revenues were developed to each group of customers. Under a colum entitled "Booked" revenue, the total Irrigation amount is $37,541,443. Please answer the following: a. Is the $37,541,443 actual 2009 Irrgation revenue? Ifnot, what is it? b. What is the basis for the "Normalization" adjustments that totaled $233,778? c. Please provide all calculations that produced the $233,778 figure, including the rates, biling determinants, and equations and data used to develop the normalized- biling determinants. d. Please explain the basis and provide the calculation for the "BP A" adjustments. IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SIXTH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 1 100. The responses to IIPA Requests 56 and 72 contain a disclaimer that: "Note: The MV90 Load Research System used to calculate class averages and class loads does not save the individual customer data used to generate the class averages and class loads..." Please answer the following: a. Historically, the Company has "cleaned up" its raw load research data in order to remove data that may be incomplete or of suspicious quality. Was this "cleanup" done prior to the data being entered into the MV90 Load Research System and then used to calculate class averages and class loads? If it was "cleaned up", please provide the original data and the "cleaned up" data that served as input to the MV90 Load Research System. b. If the Company was able to supply individual hourly load research data by sample customer in the response to LIP A Request 56, why doesn't the Company know what data was supplied to the MV90 Load Research System prior to making its calculations? c. What evidence or basis does the Company have for assuming that the MV90 Load Research System data (and thus results) is more accurate than what can be derived from the hourly load research data that was supplied in response to lIP A Request 56? 101. The responses to lIP A 38 and lIP A 65 indicate that three years of data (2006, 2007, and 2008) were used to establish distribution factors such as NCP and Schedule peak data. Please answer the following: a. Why wasn't 2009 data used? b. What was the source that was used to derive the NCP data and the Schedule peak data the sample data that was provided in response to lIP A Request 56 or did it come from the MV90 Load Research System? If the NCP and Schedule peak values were not derived from either of the above, please provide a copy of the Irrigation sample data sets that were used. 102. Regarding the response to lIP A Request 67 regarding the cost of the Cool Keeper program in Utah, please answer the following: a. What was the "levelized cost of Rocky Mountain Power's Cool Keeper program that was procured and implemented in 2003 under a 10 year pay-for-performance program strcture"? Please provide a copy of any report that was produced in 2003 that supports this levelized costs and explains the assumptions involved. IDAHO IRGATION PUMPERS ASSOCIATION, INC.'S SIXTH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 2 b. On a similar basis as the above justification for the Utah Cool Keeper program requested in "a" above, what was the levelized cost of the Idaho Irrgation curtailment program? Please provide a copy of any report that was produced when the designated day program was implemented that supports this levelized costs and explains the assumptions involved. Please provide a copy of any report that was produced when the Company Option program was implemented that supports this levelized costs and explains the assumptions involved. c. With respect to the Cool Keeper program as addressed by the Quantec Report and the response to lIP A Request 67, what was the cost associated with "new resources" and what was the cost of "operating" the system? d. With respect to the Idaho Irrgation Curtailment program( s) as addressed by the Quantec Report and the response to lIP A Request 67, what was the cost associated with "new resources" and what was the cost of "operating" the system? RACINE OLSON NYE BUDGE & BAILEY, CHARTERED ByliL IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SIXH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 3 CERTICATE OF MAING I HEREBY CERTIFY that on this L ß.t~ay 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 WI Washington Street Boise, Idaho 83720-0074 i jewell (ßpuc. state.i d. us Vú.S. Mail/Postage Prepaid~Mail Facsimile Overnight Mail Hand Delivered Ted Weston Idaho Regulatory Affairs Manager 201 South Main, Suite 2300 Salt Lake City, UT 84111 ted. weston(ßpacificorp.com Vt.S. Mail/Postage Prepaid LA-MailFacsimile Overnght Mail Hand Delivered Elednic Copies Only: Mark C. Moench Daniel E. Solander PacifiCorp/dba Rocky Mountain Power 201 South Main, Suite 2300 Salt Lake City, UT 84111 mark.moench(iacificorp.com daniel.solanderCiacificorp.com U.S. Mail/Postage Prepaid~Mail Facsimile Overnight Mail Hand Delivered Data Request Response Center Pacificorp 825 NE Multnomah, Suite 2000 Portland, OR 97232 datarequest(ßpacificorp.com _ U $. Maillostage Prepaid~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(ßpuc.idaho.gov a. U.S. Maillostage Prepaid ~-Mail Facsimile Overnght 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 SIX DATA REQUEST TO ROCK MOUNAI POWER COMPAN 4 P.O. Box 1391; 201 E. Center Street Pocatello, Idaho 83204 rcb(fracìnelaw.net Facsimile Overnight Mail ~d Delivered Katie Iverson Brubaker & Associates 17244 W. Cordova Cour Surrise, AZ 85387 kiverson(fconsultbai.com ~ Mail/ostage Prepaid v"-Mail Facsimile Overnight Mail Hand Delivered Electonic Copies Only: James R. Smith Monsanto Company P.O. Box 816 Soda Springs, ID 83276 Jim.r.smith(fmonsanto.com U.S. Mail/ostage Prepaid::E-Mail Facsimile Overnight Mail Hand Delivered Tim Buller Jason Haris Agriumlnc. 3010 Conda Road Soda Springs, ID 83276 TBuller(fagrium.com JAHars(fagrum.com v-.S. Mail/Postage Prepaid~ail Facsimile Overnight Mail Hand Delivered Benjamin J. Otto Idaho Conservation League 710 N. 6th Street PO Box 844 Boise, Idaho 83702 botto(fidahoconservation.org L¿J.S. Mail/Postage Prepaid~ail Facsimile Overnight Mail Hand Delivered Melinda J. Davison Davison Van Cleve, P.C. 333 SW Taylor, Suite 400 Portland, OR 97204 mjd(idvclaw.com v= .S. Mail/Postage Prepaid~Mail Facsimile Overnight Mail Hand Delivered Ronald L. Wiliams Wiliams Bradbury, P.C. 1015 W. Hays St. Boise, Idaho 83702 ron(fwilliamsbradbur .com lL_l!ail/Postage Prepaidi.-Mail Facsimile Overnight Mail Hand Delivered IDAHO IRGATION PUMERS ASSOCIATION, INC.'S SIXH DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 5 . Brad M. Purdy Attorney at Law 2019N. 17th Street Boise, Idaho 83702 bmpurdy(chotmail.com vU.S. MaillPostage Prepaid¿:Mail Facsimile Overnight Mail d Delivered IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S SIX DATA REQUEST TO ROCKY MOUNAI POWER COMPAN 6