20110707IIPA 26-48 to PAC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE & 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. ALEXANDER
JOSHUA D. JOHNSON
STEPHEN J. MUHONEN
CANDICE M. MCHUGH
CAROL TlPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN
BRENT L. WHITING
DAVE BAGLEY
THOMAS J. BUDGE
JASON E. FLAIG
FERRELL S. RYAN, III
AARON A. CRARY
JOHN J. BULGER
BRETT R CAHOON
Jean D. Jewell, Secreta
Idaho Public Utilities Commission
POBox 83720
Boise, Idaho 83720-0074
Re: Case No. PAC-E-II-12
Dear Ms. Jewell:
201 EAST CENTER STREET
POST OFFICE BOX 139 I
POCATELLO, IDAHO 83204-1391
TELEPHONE [phone]
FACSIMILE [phone]
ww.racinelaw.net
SENDER'S E-MAIL ADDREss:elo\2racinelaw.net
July 5, 2011
BOISE OFFICE
iot SOUTH CAPITOL
BOULEVARD~ SUITE.300
BOISE, IDAHO 83702
TELEPHONE: [phone]
FACSIMILE: [phone]
IDAHO FALLS OFFICE
477 SHOUP AVENUE
SUITE 107
POST OFFICE BOX 50698
IDAHO FALLS, ID 83405
TELEPHONE: (208) S28~610t
FACSIMILE: [phone]
ALL OFFICES TOLL FREE
[phone]
LOUIS F. RACINE (1917-2005)
WILLIAM D. OLSON. OF COUNSEL
~~
ce~:.
~~Z
'\~o~
ce
tP
Enclosed for filing in the captioned matter, please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's Second Data Request to Rocky Mountain Power Company.
ELO:rg
Enclosures
cc: Service List
gJ~
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]
RECEIVED
lOll JUl - 7 AM 8: 23
:';..!
1~~3 !
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 SECOND
) DATA REQUEST TO ROCKY
) MOUNTAIN POWER
)
26. On Exhbit 2, page 4.4 there is a tota Company figure of$11,632,374. Please list the
varous expenses (administrative, credits, etc.) that make up this cost as well as which
program and in which jurisdiction these expenses are derived.
27. On Exhibit 2, page 4.4 there is a total Company figure of negative $2,460,474. Please
list the varous expenses (administrative, credits, etc.) that make up ths cost as well
as which program and in which jursdiction these expenses are derived.
28. On Exhibit 2, page 3.1.2 is listed energy normalization adjustments by rate group.
Please answer the following:
a. According to footnote 1, these adjustments include several different types of
adjustments. For each type of adjustment, please list by month the amount of
adjustment for each rate schedule within each rate group.
b. In the "temperatue adjustment and normalization" monthy values from "a"
above do not equate to the Idaho monthly temperature adjustments listed in
the middle of page 10.16 of Exhibit 2, the please reconcile the difference.
c. Please provide a copy of the actual Historic 12 Months Ended December 2010
Booked usage levels on a monthly basis.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 1
d. For the '"temperature adjustment and normalization" portion of the
adjustments, please list for each month the temperature variation and equation
used for each month to derive a change in usage from a change in temperatue
for each rate schedule.
e. With respect to the equations listed in "d" above, please site any differences
between these monthly equations used in this case and similar equations that
were used in Case PAC-E-10-07.
f. Please provide copies fied by the Company in the last 12 months in other
jurisdictions of pages similar to Exhbit 2 pages 3.1.2 and 10.16 in this case.
29. On Exhibit 2 pages 3.1.3 and 3.1.4 are listed the magnitude of varous adjustments by
detailed rate schedule. Footnote 2 indications that the "Normalization" adjustment
includes "out of period adjustments, SMUD and special contract normalization (buy-
thoughout, curtailment in)." Please break this adjustment down into the amount
associated with each category, i.e. "out of period adjustment", SMUD, etc.
30. In Case No. PAC-E-10-07 on page 5 line 22 ofMr. Eelkema's testimony there was a
discussion regarding the development of the company's models for sales per
residential customer. Please answer the following for this case on a consistent
"calendar" or "biling" month basis:
a. Please provide in electronic format (Excel) the historical and/or projected
data/drivers used to develop the Residential model in the present case.
b. In ths case, was there a single model for the residential class, or a separate one
for Schedule 1 and Schedule 36 customers? If only one model was ru, how was
the projected usage spread between the two rate schedules?
c. Please provide the actual, historical sales per residential customer data, schedule 1
customer data, and schedule 36 customer data used to develop the model in ths
case. If separate customer and usage data was combined to form the usage per
customer data, then please supply that data as well.
d. For each of the last 20 years, what has been the weather normalized monthly sales
per residential customer, schedule 1 customer, and schedule 36 customer?
f. For each of the last 20 years, what has been the calculated/utilzed monthly HDD
and CDD data used by the Company for the Idaho jursdiction?
g. What are the test year monthly weather normalized sales per residential customer,
schedule 1 customer, and schedule 36 customer?
h. What does the company consider normal monthly HDD and CDD values for its
Idaho service territory?
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 2
31. In Case No. PAC-E-10-07, beginning on page 6 line 8 of Mr. Eelkema's testimony
there was a discussion regarding the development of the company's models for sales
per "other" customer classes. Please answer the following for this case on a
consistent "calendar" or "biling" month basis:
a. Please provide in electronic format (Excel) the historical and/or projected
data/drivers used to develop the Irrgation model used in this case.
b. Please provide all work papers that support the weather or other normalizing
adjustment to monthly Irrgation revenues in this case.
c. Please provide the actual, historical sales per irrgation customer data used to
develop the model in this case. If separate customer and usage data was
combined to form the usage per customer data, then please supply that data as
welL.
d. Please provide all work papers that support the monthly weather normalizing
adjustment to the Irrigation monthly demands in this case.
e. For each of the last 20 years, what has been the monthly weather normalized sales
per Irrgation customer?
f. For each of the last 20 years, please provide copies of any calculated/utilized
monthly precipitation data that was developed by, available to, and/or used by the
Company for the Idaho jursdiction?
g. What does the company consider normal monthly precipitation values for its
Idaho service terrtory?
h. What are the test year weather normalized sales per Irrigation customer?
32. On Exhibit 2 pages 3.1.3 and 3.1.4 are listed the magntude of various adjustments by
detailed rate schedule. For each adjustment listed, please provide the magnitude of an
kWh or kW change associated with these adjustments.
33. On Exhbit 2, page 10.14 there is a different coincident peak value for Idaho (470) for
Januar 2010 than the value used on Exhibit 42, Tab 5, pages 6. Please provide all
data, equations, and assumptions used to develop the figue on both Exhibit 2 and
Exhibit 42. Please supply this data in Excel format. Explain how, if at all, the
jursdictional data from Exhibit 42, Tab 5, pages 6 flows through or is incorporated in
Exhibit 2 Tab 10.
34. Please provide electronically a listing of all dates, times, and expected magnitude of
all dispatched and scheduled day curailments when Idaho irrigation load was
curled under Schedule 72A since Januar 2009.
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 3
35. Please provide a biling sumar for the Irrgation customers for each month since
January 2009 showing; total revenue, KWh, revenue based on energy, biling
demand, revenue based upon biling demand, customers biled, and revenue based
upon customers biled. Please provide similar information for the test year as well.
36. For each hour since Januar 1 2007 to the most recent data available please provide
the following information in $lMwh for both the entire system and for the East
System:
a. The market value of energy;
b. The incremental cost associated with the most expensive resource dispatched;
c. The purchase price for the most expensive short-term resource purchased; and
d. The revenue received from the most expensive sale made.
37. For each month since Januar 2009, please supply the level (as well as mechansm
such as mils per kWh etc.) of the BPA credit that was applied to each rate schedule.
38. Regarding the values on page 10.13 of Company Exhibit 2, please answer the
following:
a. What were the specific equations used to calculate the Metered Loads at the top of
the page for each state? Please present information by rate schedule or customer
class.
b. For each month since Januar 2009, what was the actual time of the system
coincident peak and each jursdictions contrbution to the coincident peak
39. Regarding the DSM programs on page 4.4 of Company Exhibit 2, please provide for
each state the most recent study/assessment of each program involved.
40. Please provide a listing by size the number of the line transformers that are presently
used in the field to service customers. If available, please list the customer type (Res,
Comm., Irr., Ind., other) that is served.
41. Please provide a listing by size the number of single phase line transformers that are
grouped for a single customer that are presently used in the field to service 3-phase
customers.
42. What size range of line transformers are normally used to serve residential load?
43. For new line transformers that have been ordered by the Company over the last few
years (for any of the jurisdictions), please provide a typical price for each size and
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 4
type of line transformers. This data is being requested in relationship to the typical
sizes and types of line transformers listed in '"41" above and need only reflect these
types of line transformers.
44. Please provide a copy of all loss studies that were developed and presently being used
for each of the Company's jursdictions.
45. Please list all benefits reflected in the Company's case for the system as a whole of
the Idaho Irrgation Load Control Program. Please quantify these benefits by
reruing the Company's Net Power Cost Model and other appropriate models
without the Idaho Irrgation Load Control Program.
46. On July 11, 2007 Quantec provided a report to the Company entitled '"Assessment of
Long-Term, System-Wide Potential for Demand-Side and Other Supplemental
Resources". That report on page 17 and elsewhere lists an avoided cost of capacity of
$98 per kW-year for Rocky Mountain Power and $58 per kW-year for Pacific Power.
Are there any new values for these avoided costs? If there are, please provide a copy
of the study of analysis that contans the new values.
47. On July 11,2007 Quantec provided a report to the Company entitled '"Assessment of
Long-Term, System-Wide Potential for Demand-Side and Other Supplemental
Resources". That report on page 22 found that there was a levelized cost for the
Residential direct load control program of$93 per kW in the Rocky Mountain service
area. Are there any new values for this levelized cost? If there are, please provide a
copy of the study of analysis that contains the new value.
48. On July 11, 2007 Quantec provided a report to the Company entitled '"Assessment of
Long-Term, System-Wide Potential for Demand-Side and Other Supplemental
Resources". That report on page 22 found that there was a levelized cost for the
Irrgation direct load control program of $47 per k W in the Rocky Mountain service
area. Are there any new values for this levelized cost? If there are, please provide a
copy of the study of analysis that contans the new value.
RACINE OLSON NYE BUDGE
& BAILEY, CHARTERED
BY:
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 5
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this sJY\ day of July, 2011, I served a true,
correct and complete copy of the foregoing document, to each of the following, via the
method so indicated:
Jean D. Jewell, Secreta
Idaho Public Utilities Commission
P.O. Box 83720
472 W / Washington Street
Boise, Idaho 83720-0074
j jewell (ipuc.state.id. us
V:.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnght Mail
Hand Delivered
Ted Weston
Idaho Regulatory Affairs Manager
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted. weston(iacificorp.com
U.S. Mail/Postage Prepaid
""E-Mail
Facsimile
Overnght Mail
Hand Delivered
Daniel E. Solander
PacifiCorp/dba Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
danel.solander(iacificorp.com
U.S. MaiVPostage Prepaid
i/-Mail
Facsimile
Overnight Mail
Hand Delivered
Data Request Response Center
Pacificorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
dataequest(iacificorp.com
U.S. MaiVPostage Prepaid
vE-Mail
Facsimile
Overnight Mail
Hand Delivered
Tim Buller
Agrium Inc.
3010 Conda Road
Soda Springs, ID 83276
TBu1ler(iagrium.com
U.S. MaiVPostage Prepaid
i- E-Mail
Facsimile
Overnight Mail
Hand Delivered
Ronald L. Wiliams
Willams Bradbur, P.C.
1015 W. Hays St.
Boise, Idaho 83702
ron(iwiliamsbradbur.com
,U.S. Mail/Postage Prepaid
L7 E-Mail
Facsimile
Overnght Mail
Hand Delivered
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 6
I ' , fJ
Don Schoenbeck
RCS, Inc.
900 Washington Street, Suite 780
Vancouver, WA 98660
dws(ßr-c-s-inc.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
POBox 844
Boise, Idaho 83702
botto(ßidahoconservation.org
Randall C. Budge
Racine Olson Nye Budge & Bailey Chtd.
P.O. Box 1391; 201 E. Center Street
Pocatello, Idaho 83204
rcb(ßracinelaw.net
Brubaker & Associates
17244 W. Cordova Cour
Surrise, AZ 85387
bcollns(ßconsultbai.com
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
j im.r.smith(ßmonsanto.com
Brad M. Purdy
Attorney at Law
2019 N. 17th Street
Boise, Idaho 83702
bmpurdy(ßhotmail.com
U.S. Mail/Postage Prepaid
VB-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
V'E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
E-Mail
Facsimile
Overnght Mail
vJand Delivered
U.S. Mail/Postage Prepaid
k/E-Mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mai1/ostage Prepaid
L¿É-MailFacsimile
Overnight Mail
Hand Delivered
IDAHO IRRGATION PUMPERS ASSOCIATION, INC.'S
SECOND DATA REQUEST TO ROCKY MOUNTAIN POWER 7