20100901PAC to IIPA 83-98.pdf

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201 South Main, Suite 2300
Salt Lake City, Utah 84111
August 31,2010
Eric L. Olsen ISB# 4811
Raine, Olson Nye, Budge & Bailey, Charered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: il PAC-E-1O-07
LIP A Data Request (83-98)
Please fid enclosed Rocky Mounta Power's responses to lI A Data Reques 83-98. Provided
on the enclosed CD are Atthments IIPA 84, 85, 86,87, 88c, 91b --1-2),92, and 95-(a-b). .
Provided in hard copy to the requesting par only ar Attchments lIP A 95 -- a-b). Provided on
the enclosed Confdential CD is Confdential Attchment IipA 91a. The Confdential
Attchment is Confdential and is provided to paries tht have signed a protective order in this
docket.
If you have any questions, pleas feel fr to call me at [phone].
Sincerly,
J(T.dÚ/~/~i
J. Ted Weston
Manager, Reguation
Enclosur:
cc: Rady Budge/Monsto (C)
Jea Jewell/UC (C)! 3 copies
Anthony Y anel/IP A (C)
Ben OtIICL (C)
James R. Smithonsto (C)
Richad AndersnIonsto (C)
Gerge C. Carer, III/onsto (C)
Denns PeseauIonsanto (C)
Ga R. Kajander/Monsato (C)
Maurce Brubaker/Monsto (C)
Brian Collonsato (C)
Michal Gormonsanto (C)
Ka IversnIonsto (C)
Ma Widmer/Monsanto (C)
P AC-E-1 0-07/Rocky Mountain Power
August 31,2010
LIP A Data Request 83
LIP A Data Request 83
Regarding the Response to lIP A 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) Irigation
curilments?
Response to lIP A Data Request 83
a. Please refer to Attchment LIP A 56.
b. The 5 year average represeIits a normalized year, rather than a simple
averaging of the system peak. Each of the contributing years (2005-2009) was
adjusted to fit the 2009 day-of-the-week profie. For instance, June 1,2009
occured on a Monday. The closest corresponding Monday to June I in the 2005
data was June 6th. So the 2005 data was shifted 5 days (+ 4 years) to align with
the 2009 data. In 2007, the closest corresponding Monday to June 1 was June 4,
so the data was shifted 3 days (+ 2 y,ears). Once this alignent of all the
contrbuting years was complete, the years were averaged together to obtain a
normalized, on-season representation for the 2009 irrgation average/customer
and the 2009 irrgation population of 4834 was used to expand the averages. At
that point, kWh for the 2009 normalized year (5 yr. avg.) was compared to the
test period kWh (forecasted kWh) and adjustment factors were calculated. These
adjustment factors were used to ratio¿up:or down, the normalized year (5 yr. avg.)
to tie to the testperiod kWh.
Please refer to the Company's response LIP A Data Request 72 for an example of
the flow of calculations.
c. Since a forecast test period was used in this filing, it was felt tht a
normalization of the irrgation class loads was most appropriate' as representative
of what might occur in the futue. Because the load curlment program operated
durg most of this five year period, the load curailment program impact is
reflected in the five year average dat. The level of curlment is based on ths
five year average and does not represent any individua year or any specific
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PAC-E-10-07/Rocky Mountain Power
August 31,2010
LIP A Data Request 83
curtailment amount that would havep~en reflected in a future test period had the
normalization not been performed. .'
d. See answer to c. above.
Recordholder:
Sponsor:
Scott Thornton
To Be Determined
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P AC-E-1 0-07/Rocky Mountain Power
August 31,2010
LIP A Data Request 84
LIP A Data Request 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 lIP A Request 22-e.
Response to IIPA Data Request 84
Please refer to Attachment LIP A 84.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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PAC-E-10-07/Rocky Mountain Power
August 31,2010
LIP A Data Request 85
LIP A Data Request 85
What are the number ofIrrigation customers used/assumed during each month in
test year?
Response to lIP A Data Request 85
Please refer to Attachment LIP A 85.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
PAC-E-10-07/Rocky Mountan Power
August 31, 2010
LIP A Data Request 86
LIP A Data Request 86
Please provide the meter reading and biling schedules for Irigation customers for
each month from Januay 2000 through December 2010.
Response to lIP A Data Request 86
Please refer to Attachment LIP A 86.
Recordholder:
Sponsor:
Arc MuhlsteIn
To Be Determined
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P AC-E-l 0-07/Rocky Mountain Power
August 31,2010
LIP A Data Request 87
LIP A Data Request 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 Irrgation customers.
Response to lIP A Data Request 87
Please refer to Attchment IIP A 87. The Company has data from Januar 2000
forward.
Recordholder:
Sponsor:
Aric Muhlstein
Aric Muhlstein
PAC-E-l 0-07/Rocky Mountain Power
August 31,2010
LIP A Data Request 88
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LIP A Data Request 88
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According to the Company's Response to, lIP A Request 22, it weather normalizes
Irrigation usage:
a. Please provide in Excel format all input data used to weather normalized
Irrigation 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 normalizelrngation data.
d. Please provide a copy of the statistical results of the regression analysis that
was ru upon which the Irrigation usage levels were normalized in this case
(R-square, t-statistic, residuals, etc.).
e. With respect to the response to lIP A Request 22- f, what was the formula used
to weather normalize the actual data that was provided in response to 22-c?
f. Was the data provided in response to IIPA Requests 22-c and 22-e on a
calendar or biling month basis?
Response to lIP A Data Request 88, n, "
a. Please refer to the Company's response to IPUC Data Request 215,
specificially the sheet labeled "Input" on the spreadsheet "Irrigation UPC per
day.xls."
b. The Company purchases weather data from MDA Federal, Inc., Rockville,
Marland.
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c. Please refer to Attachment 88b ~hicil c~ntains data from the Company's
biling system. In addition, please refer to the response to (a) above which has
the monthly weather data that ha$ been calculated from the purchased weather
data.
d. Please refer to the Company's response to IPUC 215, specifically the sheet
labeled "Input" on the spreadsheet "Irgation UPC per day.xls."
e. The formula used was: Weather normalized sales = actual sales + CDD, base
40 coeffcient * (normal CDD,base 40:- actul CDD, base 40).
f. The data ~rovided was on a calerlclar basis.
Recordholder:Pete Eelkema
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PAC-E-10-07IRocky Mountain Power
August 31, 2010
IIP A Data Request 88
Sponsor:Pete Eelkema
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LIP A Data Request 89
If the Company has ever considered/attempted to weather normalize Idao
Irrgation data based upon other weather variables in addition to cooling degree
day, please answer the following:
IIPA Data Request 89
a. Why has the Company chosen to not include those weather variables in the
normalization used in this case?
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b. Please provide copies (in Excel fomia,t if available) of the data associated with
these other weather varables that theCo~pany considered before.
Response to lIP A Data Request 89
a. The Company did consider using other weather variables but decided to only use
temperatue as the basis for its weather normalization adjustment. This decision
was made in par because of the diffièultyiii defining a "normal" non-temperature
variable that corresponds with the normal temperature varable.
b. Please refer to (a) above.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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PAC-E-I0-071R0cky Mountain Power
August 31,2010
LIP A Data Request 90
LIP A Data Request 90
The response to lIP A Request 64-b indicates that the Company used a "potential"
curailment for Irrigators of229 MW in its development of the class peaks. The
potential available load for curailment from the November 14, 2009 curailment
report at Table Twenty is approximately 240 MW. Please answer the following:
a. What is the amount of curailment that is available (at sales level) for the
dispatchable program for the 2010 Irrigation season in Idaho?
b. Why was a value of only 229 MW of potential interrptibilty chosen for the test
year as opposed to the level availablein 2009 or 201 O?
a. Please refer to Attachment lIP A 23a for the expected 2010 paricipation.
Response to lIP A Data Request 90
.b. The value reflects the level of potential interrptibilty of paricipating loads
during a given dispatch event. It's the maximum paricipating load that can be
scheduled to shed during a dispatch.event and stil maintain adequate system
voltage to the remaining non-irrgation loads. The heavy dominance of
irrgation load on some of the Company's circuits creates an unacceptable
spike in voltage if dispatched in its entirety. The Company is investigating
system voltage automation upgraâès that would allow for a greater utilization
of paricipating loads while stil maintaning acceptable system voltages.
Should these upgrades be implemented, it's anticipated a greater potential
contrbution from the program would be realized.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema .1 \..
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PAC-E-I0-07/Rocky Mountain Power
August 31, 2010
LIP A Data Request 91
LIP A Data Request 91
Please provide for each hour from J¡muar 1, 2005 through the most recent data
available:
a. The actual jurisdictional loads on the same basis as that presented in Exhibit 2,
Tab 10 for jurisdictional allocation puroses.
b. If there were interrptions/curilment of non-contract customer load during any
of these hours, what was the level of that curtilment or what would the
jurisdictional load have been, absent each of those interrptions/curilments?
Response to lIP A Data Request 91
a. The Company assumes this request refers to Page 10.13 of Exhibit 2 Tab 10.
Please refer to Confidential Attachment LIP A 91 a Confidential information is
provided subject to the terms and conditions of the protective order in this
proceeding.
b. For Cool Keeper information~ please refer to Attchment IIPA 91b -1 for 2005,
2006 and 2007 information, and to the Company's response to lIP A Data Request
12 -1 1st Supplemental for 2008,200.9 anEi2010 information.
For Uta Irrgation information, please refer to the Company's response to LIP A
Data Request 12 _21st Supplemental". '
For Idaho Irrigation information, please refer to Attachment IIPA 91b -2 for 2005
and 2006 information, and the Company's response to lIPA Data Request 25 for
2007, 2008 and 2009 information.
With the information provided in (a) and (b) above, IIPA will be able to calculate
the jursdictional load absent each of those interrption/curailments.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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PAC-E-I0-071R0cky Mountain Power
August 31, 2010
LIP A Data Request 92
LIP A Data Request 92
The response to lIP A Request 38 contans NCP data and schedule peak data for
2006,2007, and 2008 for all rate schedules. Please supply simlar NCP and
schedule peak data for 2009.
Response to lIP A Data Request 92
Please refer to Attchment LIP A 92.
Recordholder:
Sponsor:
Joe Ahlberg
To Be Determined
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PAC-E-I0-07/Rocky Mountain Power
August 31, 2010
LIP A Data Request 93
LIP A Data Request 93
Regarding the Irrigation 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.
Response to lIP A Data Request 93
Recordholder:
Sponsor:
To Be Determined
To Be Determined
The Company objects to this request on the grounds that it is overly burdensome.
The Company has not matched up irrigation customers in the maner requested;
to do so would require an inordinat~ :uo:it of resources.
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P AC-E-l 0-071R0cky Mountain Power
August 31,2010
LIP A Data Request 94
LIP A Data Request 94
An explanation is sought regarding the response to lIP A Request 3 and the
development of the load research data for the Irrigation customers:
a. Attachment UP A 3 for the Irrigators generally lists five years of data (6-Jun-05, 5-
Jun-06, 4-Jun-07, 2-Jun-08, and I-Jun-09) for 1-Jun-09:
i. How are each ofthese 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 I-Jun-09 data as opposed to some other grouping of days
from each ofthe five years?
b. How are the five, years of data used/averaged/incorporated in order to produce the
hourly data for 2009?
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c. How is the derived 2009 hourly data'incqrporated into the data that is used in the
filing? Is ths data used to develop demand and/or energy values, and where in
the filing 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 lIP A
Request 56. Using the weightings provided, a value of 15.645 at sales level can
be calculated for the 1 :00 tie on 2-J;une-QS. Why are these values so different?(. " ',-.'i i.1. . ,
e. June 18, 2008 was a day when approximately 200 MW of dispatchable Irrigation
load control was curailed. The data in LIP A Request 3 does not appear to show
ths curlment on June 18, 2008. Please explain how this data was developed
with respet to curilment (dispatchable and scheduled) on the system.
Response to lIP A Data Request 94 .', ,I ,.'.
Response:
a.
1.These values are derived from io~ research customer sample data from
eah specific year.
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P AC-E-l 0-071R0cky Mountain Power .f.
August 31,2010
LIP A Data Request 94 ';
11. The individual years that went into the 2009 normalized estimates were
based on average customer usage. The 5 years of average customer data
was averaged together and the data was expanded using 2009 irrgation
population of 4834.
11. Please refer to Attachment lIP A 56. for a listing of weight factors.
iv. Please refer to the Company's response to lIPA Data Request 83.
b. Please refer to the Company's response to LIP A Data Request 83.
c. The derived 2009 hourly data for irrigation represents the class load data for
irrgation and is used to develop demand values for Merged Company Peaks and
Distrbution Peaks as shown in exhibit 49, tabs 7 and 12.
d. The 2008 averages have been ratioed to pricing energy which has been
adjusted for unbiled energy. The adjustment factors needed for 2008 averages
are:June .8967751 'July .761522 ' .'
August 1.1129362
September 1.4821801
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e. Irrigation loads provided in LIP A Request 3 are based on a normalized load
cure comprised of 5 years of historical data. This cure has been ratioed to
match the forecast monthy energy le~~ls specified in the test period. Insofar
as that forecast energy includes c\nailment at the monthy level, the class
loads will also include that cUÌÌmen( 'The forecast class loads are not,
however, adjusted to reflect c~lment at the daily leveL.
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Recordholder:
Sponsor:
Scott Thornton
To Be Determned
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PAC-E-I0-071R0cky Mountain Power
August 31, 2010
LIP A Data Request 95
I1PA Data Request 95
Please provide copies of the Company's 2008, and 2009 FERC Form 1.
Response to LIP A Data Request 95
Please see hardcopies of the Company's 2008 and 2009 Form 1, or electronic
copies in Attachments lIP A 95a and lIP A 95b.
Recordholder: Ryan Weems
Sponsor: To Be Determined
P AC-E-l 0-071R0cky Mountai Power
August 31, 2010
LIP A Data Request 96
liP A Data Request 96
With respect to the response to lIP A Request 21-a, the Company provided various
data for a number of months. What is the meaning of and the significance of the
values listed in the colum entitled "Number of Households"?
Response to lIP A Data Request 96
"Number of Households" is the IHS Global Insight historical and test year county
number of households (in thousands)'that best fits the Company's Idaho service
terrtory. This is the economic driver for the test year residential number of
customers.
Recordholder:
Sponsor:
Pete Eelkema
Pete Ee1kema
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PAC-E-10-07/Rocky Mountan Power
August 3 1,2010
LIP A Data Request 97
LIP A Data Request 97
Please explain as well as provide all supporting data that serves as the basis for
the monthly forecasted Irigation salès in this case. We are looking for the data
that was utilzed and the calculations use to tae this data and derive the forecast
values.
Response to lIP A Data Request 97
Please refer to the Company's response to IPUC Data Request 215. The
calculations were performed using a proprietary software package, MetrxND.
The model can by demonstrated at the Company's Portland offices or by web link
at the Company's Salt Lake City offices.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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P AC-E-1 0-07/Rocky Mountain Power
August 31, 2010
LIP A Data Request 98
LIP A Data Request 98
The response to lIP A 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 LIP A Request indicates that for June 2007 there were
115,178,683 kWh of sales to 4,721 Irrgation customers. This equates to 32,872
kWh per customer (115,178,683/4,721). Please reconcile these two
"use/customer" values as well as the other use/customer values in Response 22-c
and those that can be calculated from IIPA 26.
Response to lIP A Data Request 98
The monthly data in the response to lIP A Request 22-c was obtained from the
Company's revenue report system 305 Report. It includes not only the biled
kWh in that month, but also the unbiled kWh for each revenue month.
Since LIP A Request 26 requested detaled usage information for each customer,
rather than aggregate data provided by the 305 Report, the monthly data for lIPA
Request 26 were obtaned from the Company's customer billng system rather
than the 305 report. The Company's customer billng system contains individual
customer usage data for each month based on a customer's meter reading date.
The monthy individual customer data can 'also be revised to reflect any biling
adjustments or other changes that occur to a customer's bil at a later date.
In sumar, the data in the two responses differed in the following thee main
areas:
(1) the data in lIPA Request 22-c was based on the biled month at the aggregate
level while the data in LIP A Request 26 was based on meter reading month at
the individual customer level; .
(2) the data in LIP A Request 22-c included unbiled kWh while the data in IIP A
Request 26 did not include any unbiled kWh and
(3) the data in lIPA Request22-c is not subject to change or revision once it is
published while the monthly data in lIP A Request 26 can be changed at a later
date if there are any billng adjustments.
Recordholder:
Sponsor:
James Zhang. ", ,.
Wiliam R. Grffth' .
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