20101130PAC to IIPA 134-143.pdf

"
~~~OUNTAIN i-"C
~,J ~o.=
rylln \lfW ':n M" 9: 48lJJiU r'HJ ii yoU
201 South Main, Suite 2300
Salt Lake Cit, Utah 84111
November 29, 2010
Eric L. Olsen ISB# 4811
Racine, Olson Nye, Budge & Bailey, Chaered
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
RE: ID PAC-E-10-07
IIPA Data Request (134-143)
Please find enclosed Rocky Mounta Power's responses to lIP A Data Requests ~-143.
Provided on the enclosed CD are Attchments IIPA 137 -(1-2) and 138 -(1-2). Provided on the
enclosed Confdential CD are Confdential Atthments IIPA 136, 139 -(1-2), and 142. The
Confidential Atthments are Confdenti and are provided to pares tht have signed a
protective order in ths docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
~'.Tdw~¿~
J. Ted Weston
Manger, Reguation
Enclosur:
cc: Rady Budge/Monsanto (C)
Jean JewelllUC (C)/3 copies
Anthony Y anellIP A (C)
Ben OtolICL (C)
James R. Smithonsanto (C)
Richad AndersonIonsto (C)
George C. Carer, llI/onsanto (C)
Denns PeseauIonsanto (C)
Gareth R. KajanderlMonsanto (C)
Mauce Brubaker/Monsanto (C)
Brian Collin/Monsto (C)
Michal Gormanonsanto (C)
Kathn IversonIonsto (C)
Mak Widmer/Monsanto (C)
..
P AC-E-1 0-07 !Rocky Mounta Power
November 29,2010
LIP A Data Request 134
LIP A Data Request 134
Regarding Ms. Hunter's sttement on page 6 liens 8-10 of her rebutt testimony,
is she recmmending that the Agrcultual Energy Saver program be eliminated:
1) solely by itself; 2) in conjunction with her recommendations to cut back and/or
chage the Irrgation load control progr, or 3) as a separate option tht could be
considered afer her recommendations regarding the Irgation load control
program were implemented?
Response to lIP A Data Request 134
Mr. Gryson diects the Company to "endeavor to fid ways to pursue all cost-
effective DSM while strving toward greater balance with regard to customer
segment equity". DSM expenditues to support agcultu programs (Idaho
irgation load control program and Agrcultual Energy Savers) represented 81 %
of the Company's investment in 2009. If the Commsion seeks to achieve
balance, Ms. Hunter suggested that since the Agrcultual Energy Savers
program's cost effectiveness is less th irrgation load control, suspension of the
Agricultual Energy Savers progr would be preferable.
Later in her testiony' she recommends that if the Commission is seeking to
reduce the tota costs associated with the DSM programs, based on cost-
effectiveness, suspension of the Agrcultual Energy Savers program would be
preferable to other program.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
'~~'-~
PAC-E-10-07!Rocky Mountain Power
November 29, 2010
LIP A Data Request 135
LIP A Data Request 135
Oter than chaging the overall energy effciency portfolio cost effectiveness
from 1.93 to 2.05 as measured by the utilty cost test (Hunter rebutt pages 5-6),
what other benefits would accrue if the Agrcultual Energy Saver program was
elimiated?
Response to lIP A Data Request 135
The improvement in overall energy effciency portfolio cost effectiveness from
1.93 to 2.05 is not techncally a benefit but rather suggests the portfolio's benefit
per dollar invested improves slightly provided the program is eliminated.
Eliminating the program actuly reduces the overall portfolio's net benefit by
$400,000. The Agrcultual Energy Saver program's 2009 results indicate, from a
utility perspective, the program was cost-effective, just less so than other
programs in the Company's portolio. The elimtion of the program, by virte
of reducing program expenditus in the agrcultul sector, would reduce the
percentage of portfolio investment in the agrcultual sector and increase the
percentae of portolio investment across the remaing non-agcultu customer
sectors, providing a more equa yet not equa distrbution of costs across all
customer sectors. Furer, the on-going cost ofDSM in Idao would be lower
than it otherwse will be with Agricultual Energy Savers.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
P AC-E-l 0-07 !Rocky Mountai Power
November 29,2010
LIP A Data Request 136
UP A Data Request 136
Please provide copies of the thee thid-par vendor agreements referenced on
page 6 line 13 of Ms. Hunter's testiony.
Response to UP A Data Request 136
Please refer to Confidential Attchment LIP A 136. The agreements being
provided are confdential and ar provided subject to the ters and conditions of
the protective agreement in this proceedg.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
P AC-E-1 0-07 !Rocky Mounta Power
November 29,2010
LIP A Data Request 137
LIP A Data Request 137
Please provide copies of the reques for proposal that was issued in July as
referenced on page 6 lines 15-16 of Ms. Hunter's testimony.
Response to UPA Data Request 137
Please refer to Attchments LIP A 137 -1 and LIP A 137 -2.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
PAC-E-1 0-07 !Rocky Mountai Power
November 29,2010
LIP A Data Request 138
UP A Data Request 138
Pleas provide copies of the cancellation of the request for proposal that was
issued as referenced on page 6 line 16 of Ms. Hunter's testiony.
Response to UP A Data Request 138
Please refer to Atthments liP A 138 -1 and LIP A 138-2.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
P AC-E-l 0-07/Rocky Mountain Power
November 29,2010
LIP A Data Request 139
UP A Data Request 139
Whch two agreements were exteded though 2011 as referenced on page 6 lines
19-20 of Ms. Hunter's testony? Pleae provide copies of these extensions.
Response to lIP A Data Request 139
Please refer to Confdential Atthments LIP A 139 -1 and LIP A 139 -2. These
agreements ar confdential and are provided subject to the ters and conditions
of the protective agreement in ths proceeding.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
PAC-E-I0-07!Rocky Mounta Power
November 29,2010
LIP A Data Request 140
IIPA Data Request 140
Please explai why any control unt purchased before or durg 2011 has a
reasonable probabilty of only being in servce one year as referenced on page 7
lines 5.6 of Ms. Hunter's testimony. .
Response to UPA Data Request 140
Due to the expirig delivery and equipment vendor contracts, the Company
intends to competitively rebid the program's delivery in 2011 for the 2012 control
season. Should the successfu applicant(s) choose to migrate to alternative
equipment and communcation platform at that time, any equipment the Compay
acquires in 2011 would be obsolete by 2012.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
PAC-E-10-07!Rocky Mountan Power
November 29,2010
LIP A Data Request 141
IIPA Data Request 141
On the bottom of page 10 of Ms. Hunter's testimony, there is a table. One of the
colums lists a benefit of $44/k. Please provide all work papers that
demonstrate how this value was developed and how it relates to any demand
related avoided cost values tht the Company has used in its most recent IR.
Response to IIPA Data Request 141
The $44/kW-yr is the product of $8,437,440 credit provided through the
allocation process divided by 191.76 mw provided in Mr. Eelkema's testiony.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter
P AC-E-l 0-07 !Rocky Mounta Power
November 29, 2010
LIP A Data Request 142
IIPA Data Request 142
Please provide all data reports, and anysis that were prepared in 2009 and 2010
regarding the removal of load from the varous distrbutions circuits as referenced
on page 11 of Ms. Hunter's testimony.
Response to IIPA Data Request 142
Please refer to Confdential Atthment LIP A 142. Ths inormation is
confdential and is provided subject to the terms and conditions of the protective
agreement. in this proceedig.
Recordholder:
Sponsor:
Carol Hooter
Carol Hunter
P AC-E-l 0-07/Rocky Mountan Power
November 29, 2010
LIP A Data Request 143
IIPA Data Request 143
Please list all times, all circuits, and all loads that had two dispatch periods as
referenced on page 11 lines 14-20 of Ms. Hunter's testimony.
Response to IIPA Data Request 143
11:00 AM 12:00 PM 1:00 PM 2:00PM 3:00PM 4:00PM 5:00PM 6:00PM 7:00PM
56,04.35 56,04.35 56,04.35 56,04.35
118,n6.22 118,n6.22 118,776.22 118,n6.22
2,000.00 2,000.00 2,000.00 2,000.00 2,000.00 2,000.00
91,079.43 91,079.43 91,079.43 91,079.43 91,079.43
56,04.3 56,04.3 56,04.3 149,123.8 211,855.7 211,855.7 211,855.7 211,855.7 2,000.0
In addition, staing late in July approximately 26 megawatts were dispatched at
7:00 am. asa result of contiuig issues on ciruits out of Big Grassy.
Recordholder:
Sponsor:
Carol Hunter
Carol Hunter