20110624IIPA 1-25 to PAC.pdf

LAW 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
FREDERICK J. HAHN, III
PATRICK N. GEORGE
SCOTT J. SMITH
DAVID E. ALEXNDER
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL T1PPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN
BRENT L. WHITING
DAVE BAGLEY
THOMAS J. BUDGE
JASON E. FLAIG
FERRELL S. RYAN, II
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
Jean D. Jewell, Secreta
Idaho Public Utilties Commission
POBox 83720
Boise, Idaho 83720-0074
Re: Case No. PACE-E-11-12
Dear Ms. Jewell:
201 EAST CENTER STREET
POST OFFICE BOX 1391
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racìnelaw.net
SENDER'S E-MAIL ADDREss:elol!racìnelaw.net
June 22, 2011
BOISE OFFICE
101 SOUTH CAPITOL
BOULEVARD, SUITE 300
BOISE, IDAHO 8370.2
TELEPHONE: (208) 3.S~OOt 1
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUESUITltt07
POST OFFICE BOX 50688
iDAHO FALLS, ID 83405
TELEPHONE: [phone]'0'
FACSIMILE: (208) 528-8.08
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917.20)
WILLIAM D. OLSON, OF COUNSEL,.=--2 :i% mN ().i m
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Enclosed for fiing in the captioned matter, please find the original and thee copies of Idaho
Irrigation Pumpers Association, Inc. 's First Data Request to Rocky Mountain Power Company.
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Enclosures
cc: Service List
ta
Eric L. Olsen ISB# 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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2311 JUlI2!l Art 8= 31
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Attorneys for the Idaho Irrigation 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 $32.7 MILLION
OR APPROXIMATELY 15.0 PERCENT
) CASE NO. PAC-E-l1-12
)
) IDAHO IRRGATION PUMPERS
) ASSOCIATION, INC.'S FIRST
) DATA REQUEST TO ROCKY
) MOUNTAIN POWER
)
1. Please answer the following with respect to information contaned on McDougal's
Exhibit 2, Tab 10 entitled "Allocation Factors":
A. On pages 10.13 through 10.16, are these actual generation level energy and
demand values recorded for each jursdiction durng each of the months
specified? If not, please provide the actual values.
B. Do the demand values on page 10.13 for Idaho include Monsanto load that has
been interrpted?
C. Are the values/adjustments on page 10.13 though 10.16 simply weather related
adjustments? If these adjustments are more than simply weather related
adjustments, please provide a breakdown of these values that relate to weather
adjustments and those that relate to other adjustments (please provide specific
detail for each "other" adjustment).
D. Are the demand and energy values on pages 10.13 though 10.16 the ones used to
form the basis for such system allocators as SC and SE?
E. For each of the adjustments listed on pages 10.13 and 10.14, how are these
adjustments reflected by rate schedules or special contrct customer consumptions
in each month?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 1
F. Please provide an electronic as well as hard copy of all workpapers that support
the calculations on Tab 10.
G. Please provide an electronic copy of all workpapers and/or calculations that
support the adjustments to actual values for both demand and energy for each
jursdiction listed in Tab 10.
2. Please answer the following with respect to information contaned on Paice's Exhibit
42, Tab 5 "Cost of Service Allocation Factors":
A. Are the times of the system peaks listed on page 6 the same as the actual
coincident system peaks durng each of those months?
B. Are the times listed on page 6 on Pacific or Mountan time?
C. How do the total jursdictional values for each month on page 6 relate to the Idaho
values on McDougal's Exhibit 2, Tab 1O?
D. With respect to the data listed on pages 7 and 10, which data came from the
Company's load research data and which data came from census data? Iffrom
load research data, over what timeframe was the data collected? If the data came
from load research data, but was adjusted, please provide an electronic copy of all
workpapers and/or calculations that support the adjustments to actual values.
E. With respect to the data listed on page 11, which data came from the Company's
load research data and which data came from biling data? If the data came from
biliing data, but was adjusted, please provide an electronic copy of all
workpapers and/or calculations that support the adjustments to actu values.
F. What was the level of curlment/interrption for each customer class or
Monsanto durng the times of each of the monthy peaks listed on page 6? (Please
specify at input leveL.)
G. Is there any weather normalization of the Distrbution Peak data on page 10 or the
Non-Coincident Peak data on page II? If ths data is weather normalized, please
provide an electronic as well as hard copy of all workpapers used to support ths
normalization.
3. With respect to the Company's Load Research data please provide for each sample
customer with valid data that was sampled between Januar 2010 and the most recent
month available the following:
A. Customer identification number;
B. Customer rate schedule;
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 2
C. Strata to which it belongs and weighting factors of each strata;
D. Raw hourly usage data (i.e., unadjusted, simply the data originally gathered for
each sample);
E. Raw hourly usage data modified to reflect losses;
F. On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company's cost of service study in this case.
G. Please provide copies of the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of servce
study in ths case. This information should include number of customers in the
population of each class.
4. Previously the Company developed hourly calibrations that calibrated the Load
Research data such that the sumation of the (population expanded) Load Research
data and the Census data equaled the Company's "Operations Stat" or border loads.
The Company may no longer be applying these calibrations to the Load Research
data but the data is stil of interest. On an hourly basis from Janua 2010 though
the most recent month available, please provide:
A. The "Operations Stat" or border load for the Idaho Jursdiction;
B. The sumation of the (population expanded) Load Research data and the Census
data that would reflect what the Company measured or estimated as its internal
customer load for each rate schedule or customer group;
C. The hourly load for each rate schedule or special contract customer that is
measured or calculated on a census basis as opposed to using load research data;
D. Any other load that is contained in "a" above but is not addressed in "c" above
(please specify the type of load); and
E. Any information such as difference in measurng technques or timig of the data
that needs to be addressed when comparng the above data.
5. Please provide for each month from Janua 2010 forward a copy of the results of all
checks that the Company makes regarding how well the load research data reflects
the actu population usage.
6. For the Irgation load research samples, what is the range (kW or kWh) cut-offfor
each stratu?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 3
7. This filing used weather-normalized data for developing allocation factors in the
jursdictional allocations and presumably the class cost-of-service study. For each
rate schedule, please provide all workpapers as well as a description of the flow
(manpulation) of data from historic load research or consensus data to projected test
year energy, coincident demands, and non-coincident demands. Please supply this
data in Excel format.
8. Is the data source for peak values for Exhibit 2, tab 10 the same as the data source for
the peak values on Exhbit 42, tab 5?
9. Please provide in electronic format for the period Januar 1, 2010 though the most
recent month available hourly data similar to that provided in LIP A Request 9 in P AC-
E-tO-07.
10. Please provide in electronic format for the period Januar 1, 2010 through the most
recent month available, hourly Salt Lake City temperatue data or other relevant data
that the Company uses to make weather normalization adjustments.
11. Please provide in electronic format a listing of the date, time, and estimated
magitude of all actu hourly curtlments/interrptions that occured durng 2010
though the most recent month available in Idaho separated by rate schedule or
special contract customer. If outrght curlments/interrptions are treated differently
than "buy-throughs", please state each separately.
i 2. Please provide in electronic format a listing of the date, time, and estimated
magnitude of all actua hourly curlments/interrptions that occured durng 2010
through the most recent month available in each of the other jursdictions. If outrght
curailments/interrptions are treated differently than "buy-thoughs", please state
each separately.
13. Do the values in Exhbit 2, Tab 10, reflect Idaho demand and energy requirements by
assuming that there are no curlments/interrptions to Monsanto? If
curlments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
14. Do the values in Exhbit 42, Tab 5, reflect Idaho demand and energy requirements by
assuming that there are no curlments/interrptions to Monsanto? If
curailments/interrptions are assumed, what is the energy and demand impact of
each for each month of the test year?
15. With respect to Exhbit 42, Tab 5, page 7, please answer the following:
A. Are all of these values actual? If not, please provide and explanation of how they
were normalized and the workpapers that support the normalization.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 4
B. What level of curailment of Schedule 10 load is reflected on line 22? Is this level
of curailment the same as occured in 2008, 2009, 2010 or is expected to be
incured in 2011 ?
16. Please explain how any revenue credits to Monsanto are addressed in ths case in
relationship to Monsanto's inclusion/exclusion in/from the Idaho Jursdiction and
how Monsanto is treated in the class cost of service study.
17. Please provide a copy of the Company's Char of Accounts.
18. Please supply in electronic format for each month since Januar 2006 the calendar
month biling determents (and associated revenue) of each of the rate categories listed
in Exhibit 29 in the Idaho jursdiction.
19. From Januar 2006 though the most recent month available, what was the date and
time and magnitude of the monthly system peak that would have occured, had there
been no curailment of Residential, Commercial, and/or Irrgation load?
20. Durng the hour of the monthly peak from Janua 2008 though the most recent
month available, please provide the following:
a. How many megawatts of generation were out of service for planed maintenance?
b. How much electrcity was generated from Company owned hydro?
c. How much electrcity was purchased from Company owned thermal power?
d. How much electrcity was purchased from QF suppliers?
e. How much electrcity was brought in or sent out though exchanges? How much
(non-QF electricity was purchased and at what price? Please list each transaction
separately, stating name of seller, MWH purchased, purchase price, and type of
purchase (LF, RQ, SF, OS, etc.)?
f. How much electrcity was sold off-system and at what price? Please list each
transaction separtely, stating name of seller, MWH sold, sale price, and ty of
sale (LF, RQ, SF, OS, etc.)?
g. How much load was interrpted via the Irrgation Load Management program or
other similar programs? Please specify each program separately.
21. Please provide a copy ofPacifiCorp's FERC Form 1 for 2010.
22. Please provide a copy ofPacifiCorp's most recent IRP.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 5
23. Under which FERC accounts and/or subaccounts are the capital, operation, and
maintenance costs of wind tubine generators?
24. Please provide in electronic format outage data for each substation and each circuit in
each substation for each of the last four years:
a. The date, time and duration of any outage.
b. The number of customers impacted by rate schedule.
c. The estimated kW of load impacted.
d. Any other data the Company routinely keeps regarding outages such as cause of
the outage.
25. Please provide electronically any SAIDI, SAIFI, MAIDI, or CAIDI information that
the Company has collected over the past four years. Such data should be provided at
the least aggregated level it is maintained by the Company.
RACINE OLSON NYE BUDGE
& BAILEY, CHARTERED
By2J~
ERIC L. OLSEN
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 6
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 2ZJ_ day of June, 2011, 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, Secreta
Idaho Public Utilties Commission
P.O. Box 83720
472 W / Washington Street
Boise, Idaho 83720-0074
j j ewell cmpuc. state.id. us
vCS. Mail/Postae Prepaid
E-Mail
Facsimile
Overnight Mail
Hand Delivered
Ted Weston
Idaho Reguatory Affairs Manager
201 South Mai, Suite 2300
Salt Lake City, UT 84111
ted. westoncmpacificorp.com
U.S. Mail/ostage Prepaid
~E-Mail
Facsimile
Overnight Mail
Hand Delivered
Danel E. Solander
PacifiCorp/dba Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
daniel.solander(facificorp.com
U.S. Mail/Postae Prepaid
,,¿E-Mail
Facsimile
Overnight Mail
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Data Request Response Center
Pacificorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
dataequestcmpacificorp.com
U.S. Mail/ostae Prepaid
7Ê-Mail
Facsimile
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Tim Buller
Agrium Inc.
3010 Conda Road
Soda Springs, ID 83276
TBullercmagrium.com
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Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise, Idaho 83702
roncmwillamsbradbur.com
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V E-Mail
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IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 7
Don Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, W A 98660
dws(ßr-c-sinc.com
U.S. Mail/Postage Prepaid~-Mail
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Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
POBox 844
Boise, Idaho 83702
botto(ßidahoconservation.org
u.s. Mail/Postage Prepaid~Mail
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Randal C. Budge
Racine Olson Nye Budge & Bailey Chtd.
P.O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204
rcb(ßracinelaw.net
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E-Mail
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i:and Delivered
Brubaker & Associates
17244 W. Cordova Cour
Surrise, AZ 85387
bcollins(ßconsultbai.com
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V:Mail
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James R. Smith
Monsato Company
P.O. Box 816
Soda Sprigs, ID 83276
jim.r.smith(ßonsanto.com
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ibMail
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Brad M. Pudy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
bmpurdy(ßhotmail.com
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
FIRST DATA REQUEST TO ROCKY MOUNTAIN POWER 8