20100916PAC to PIIC 56-62.pdf

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RECE
September 15,2010 20lnSEP l 6 Ati to: l 5
Melinda Davison
Davison Van Cleve, P.e.
333 S.W. Taylor St., Ste. 400
Portland, Oregon 97204
201 South Main, Suite 2300
Salt Lake City, Utah 84111
Randall J. Falkenberg
RFI Consulting, Inc.
PMB362
8343 Roswell Road
Sandy Springs, GA 30350
RE: ID PAC-E-10-07
PIIC Data Request (56-62)
Please find enclosed Rocky Mountain Power's responses to PIIC Data Requests 56-62. Provided
on the enclosed CD are Attachments PIIC 57, 58, 59 -(1-2), and 60.
If you have any questions, please feel free to call me at [phone].
Sincerely,
::T.¿d Iv~~
J. Ted Weston
Manager, Reguation
Enclosure:
cc: Jean JewelllPUC (C)/3 copies
Eric Olsen/IP A (C)
Ben Otto/ICL (C)
Radall Budge/Monsanto (C)
James R. Smith!onsanto (C)
Richard Anderson/onsanto (C)
George C. Carer, III/Monsanto (C)
Denns Peseau/onsanto (C)
Gareth R. Kajander/Monsanto (C)
Maurce Brubaker/Monsanto (C)
Brian Collins/Monsanto (C)
Michael Gormanonsanto (C)
Kath Iverson/onsanto (C)
Mark Widmer/Monsanto (C)
PAC-E-10-07/Rocky Mountain Power
September 15,2010
PIIC Data Request 56
PIIC Data Request 56
Please provide a working copy of the PacifiCorp JAM model used for this case.
Response to PIIC Data Request 56
Please refer to previously provided Attachment Monsanto 1.19 for a copy of the
JAM revenue requirement modeL.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
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PAC-E-10-07/Rocky Mountain Power
September 15,2010
PIIC Data Request 57
PIIC Data Request 57
Please refer to McDougal exhibit 2, tab 10. Please provide the same information
as shown on this tab, except provide for the 2009 actual loads for Idaho and the
other states. Please provide working electronic spreadsheet format (excel with all
cells and formulae intact).
Response to PIle Data Request 57
Please refer to Attachment PIIC 57.
Recordholder:
Sponsor:
Steven R. McDougal
Steven R. McDougal
PAC-E-10-07/Rocky Mountain Power
September 15,2010
PIIC Data Request 58
PIle Data Request 58
Please identify the changes to the test year that would occur if 2009 actualloads~
rather than 2010 forecast loads were used. Please quantify the change to the :
Idaho revenue requirement for this case if 2009 actual loads were used instead of
2010 forecast loads. Please provide the detail by category.
Response to PIle Data Request 58
The Company objects to this question on the grounds that it is overly broad.
Without waiving its objection, the Company states that its case has been prepar~d
using forecasted loads for the twelve months ending December 2010.
Consequently, the requested quantification has not been performed. However, tpe
necessar changes that would need to be made to the test year fiing would
include but are not limited to the following:
a) The actual loads for the twelve months ended December 2009 would need
replace the forecast loads utilized in the JAM model, factors tab. Please
to Attachment PIIC 58 for the actual peak and energy loads.
b) Adjustment No. 3.4 (Forecast price change) would be impacted.
c) Adjustment No. 5.1 (Net power cost) would also be impacted.
Recordholder:
Sponsor:
Steven R. McÒbùgal"
Steven R. McQo\.ßal
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P AC-E- 10-07 /Rocky Mountain Power
September 15,2010
PIIC Data Request 59
PIIC Data Request 59
Please provide load inputs for GRID based on 2009 actual loads as opposed to
2010 forecast loads.
Response to PIle Data Request 59
Please refer to Attachments PUC 59 - I and 59 -2 for the requested information:
the hourly load and the mapping of the load by state to topology in GRID.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E- 1 0-07/Rocky Mountain Power
September 15,2010
PIIC Data Request 60
PIIC Data Request 60
Please provide all of the spreadsheets used by the Company for computation of
the information provided in McDougal exhibit 2, tab 10. Please provide with all
cells and formula intact in full working order.
Response to PIIC Data Request 60
Please refer to Attachment PIIC 60.
Recordholder:
Sponsor:
Steven R. McDOl"gal
Steven R. McDougal
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PAC-E-I0-07/Rocky Mountain Power
September 15,2010
PIIC Data Request 61
PIle Data Request 61
Explain the basis for the Company's assumption that in 2010 the load reductions
due to the curent recession wil be reversed.
Response to PIIC Data Request 61
The Company has not assumed that the i,nciease in test year loads is only driven
by changes in the economic climate. Instead, the Company relies on other inputs
such as information from its Customer and Community Managers. Please refer to
the testimony of Dr. Peter C. Eelkema for additional details on the development
of test year sales and load.
Recordholder:
Sponsor:
Pete Eelkema
Pete Eelkema
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. PAC-E-I0-07/Rocky Mountain Power
September 15,2010
PIIC Data Request 62
PIIC Data Request 62
Does the Company agree to allow PIIC to use discovery responses Mr.
Falkenberg has in his possession for the following cases: UE 170, UE 179, UM
1355, UM 1208, UM 1429, UM 1467, UM 1396, UM 1129, UE 191, UE 199, UE
207, UE 216, Utah PSC Docket Nos. 07-035-93, 08-035-38, 09-035-23, 10-013-
35, Washington Docket Nos. UE -061546,080220,090205, 100749, and
Wyoming PSC docket Nos. 20000. 341-EP-09, 333-ER-08, 315-ER-08, 27i-ER-
07 ,352-ER-09 and 363-EP-I0?
Response to PUC Data Request 62
PIIC may use the Company's responses provided to Mr. Falkenberg in the above-
referenced cases, subject to the Company's reservation of all evidentiary
objections.
Use of the Company's confidential data provided in the above-referenced dockets
is subject to maintaining the confidentiality of the data on the terms and
conditions of the protective orders and confidentiality agreements in those
dockets. Use of confidential responses from other proceedings is also subject to
the terms and conditions of the protective agreement in this docket.
Recordholder: N/ A
Sponsor: N/ A
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