20121017PAC to PIIC 1-13.pdf

ROCKY MOUNTAIN
POWER
A DIVISION OFPACIICORP
October 17, 2012
t5 7 HI 419
201 South Main, Suite 2300
Salt Lake City, Utah 84111
VL4 EMAIL
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
1015 W. Hays St.
Boise ID, 83702
[e-mail]
Don Schoenbeck
RCS, Inc.
900 Washington St, Suite 780
Vancouver WA, 98660
[e-mail]
RE: ID PAC-E-12-12
PIIC Set Data Request (1-13)
Please find enclosed Rocky Mountain Power's responses to PIIC Set Data Requests 1.1-1.13.
Also provided electronically are Attachments PIIC 1. 1, 1.2, 1.4, and 1.6.
If you have any questions, please feel free to call me at [phone].
Sincerely,
7'd
J. Ted Weston
Manager, Regulation
Enclosure
C.c.: Jean Jewe1IIIPUC pwpucidaho.gov
Neil Price/IPUC [e-mail]
Ted WestonJRMP [e-mail]
Daniel E. Solander/RMP [e-mail]
Data Request Response CenterIPacifiCorp [e-mail]
Randall C. Budge/Monsanto [e-mail]
Brubaker & Associates/ Monsanto [e-mail]
James R. Smith/Monsanto jjr.srnith@rn
Tim Buller/PIIC TBuller(agrium.com
PAC-B-12-12fRocky Mountain Power
October 17, 2012
PIIC Data Request 1.1
PIIC Data Request 1.1
With regard to the prefiled testimony of Ms. Joelle Steward page 3, lines 11-14,
please provide an electronic copy of all the workpapers in the original software
with all formulae intact used to determine all the Year 2 rate charges for Schedule
9 and the Company's proposed Schedule 31 charges.
Response to PIIC Data Request 1.1
Attachment PIIC 1.1 contains the requested workpapers.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-l2IRocky Mountain Power
October 17, 2012
PIIC Data Request 1.2
PIIC Data Request 1.2
With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 6, please
provide an electronic EXCEL file containing the back-up power supplied by the
Company for each customer served under Schedule 31 in Utah for the last four
years (2008 —2011) showing the year, month, day and time the backup power was
provided in fifteen minute intervals.
Response to PIIC Data Request 1.2
Please refer to Attachment PIIC 1.2. Not all customers shown were on Schedule
31 for the full four years.
Record holder: Bob McCarthy
Sponsor: Joelle Steward
PAC-E-12-12/Rocky Mountain Power
October 17, 2012
PIIC Data Request 1.3
PHC Data Request 1.3
With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 6, please
provide an electronic EXCEL file containing the maintenance power supplied by
the Company for each customer served under Schedule 31 in Utah for the last four
years (2008 —2011) showing the year, month, day and time the maintenance
power was provided in fifteen minute intervals.
Response to PIIC Data Request 1.3
Please refer to Attachment PIIC 1.2. Not all customers shown were on Schedule
31 for the full four years.
Record holder: Bob McCarthy
Sponsor: Joelle Steward
PAC-E-12-12/Rocky Mountain Power
October 17, 2012
PIIC Data Request 1.4
PHC Data Request 1.4
With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 7, please
provide an electronic EXCEL file containing the back-up power supplied by the
Company for each customer served under Schedule 33 in Wyoming for the last
four years (2008 —2011) showing the year, month, day and time the backup
power was provided in fifteen minute intervals.
Response to PIIC Data Request 1.4
Please refer to Attachment PIIC 1.4. Not all customers shown were on Schedule
33 for the full four years.
Record holder: Bob McCarthy
Sponsor: Joelle Steward
PAC-E-12-l2fRocky Mountain Power
October 17, 2012
PIIC Data Request 1.5
PIIC Data Request 1.5
With regard to the prefiled testimony of Ms. Joelle Steward page 2, line 7, please
provide an electronic EXCEL file containing the maintenance power supplied by
the Company for each customer served under Schedule 33 in Wyoming for the
last four years (2008 —2011) showing the year, month, day and time the
maintenance power was provided in fifteen minute intervals.
Response to PIIC Data Request 1.5
Please refer to Attachment PIIC 1.4. Not all customers shown were on Schedule
33 for the full four years.
Record holder: Bob McCarthy
Sponsor: Joelle Steward
PAC-E-12-12/Rocky Mountain Power
October 17, 2012
PIIC Data Request 1.6
PIIC Data Request 1.6
Please provide copies of select workpapers or pages from any reports prepared by
the Company indicating the actual system peak load (and the time at which it
occurred) and all available resources (load/resource balance indicating surplus
capacity) by month from January 2008 to date.
Response to PIIC Data Request 1.6
Please refer to Attachment PHC 1.6, which provides actual system monthly peak
(MW) and energy (MWh) data for calendar years 2008 through 2011.
The Company does not compute an actual monthly load and resource balance.
Further, there is no surplus on an actual basis because loads and resources must
match.
Record holder: Matt Hastings / Greg Duvall
Sponsor: Joelle Steward
PAC-E-12-12/Rocky Mountain Power
October 17, 2012
PIIC Data Request 1.7
PIIC Data Request 1.7
With regard to the preflied testimony of Ms. Joelle Steward page 5, lines 6-9,
please provide any analysis done by the Company to support the application of
the Company's generation planning reserve margin for customer owned
generation facilities. In other words, please provide any documentation that
shows the additional resources acquired by the Company in order to provide back-
up or maintenance services for customer owned generation.
Response to PIIC Data Request 1.7
In the Company's integrated resource plan (IRP), the planning reserve margin
accounts for operating reserves, load forecast errors and other long-term resource
adequacy planning uncertainties (see the 2011 IRP, page 99). Back-up Service,
which is designed for service during unplanned outages at the customer's
generation facility is not reflected in the Company's load obligation for resource
planning and therefore the provision of this service would be captured through
planning reserves. Accordingly, the Company believes that the 13 percent reserve
margin used in the IRP applied to the demand-related generation costs reasonably
approximates the costs incurred by the Company to back-up the customer's
generation.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-12fRocky Mountain Power
October 17, 2012
PIIC Data Request 1.8
PIIC Data Request 1.8
With regard to the prefiled testimony of Ms. Joelle Steward page 5, lines 17-19,
please provide an explanation and documentation on why the Company is
proposing to restrict scheduled maintenance to just one 30 day period or two
fifteen day periods.
Response to PIIC Data Request 1.8
The Company believes that the proposed Maintenance Service and the related
conditions properly represent the balance of the resource, market, system
condition, and the customer's need. The Company's experience in both Utah and
Wyoming has been that the Maintenance Service provisions have not been
problematic. The proposed scheduled maintenance periods are the same as what
have been implemented in the Company's Partial Requirement Schedule 33 in
Wyoming and Partial Requirement Schedule 31 in Utah.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-l2IRocky Mountain Power
October 17, 2012
PIIC Data Request 1.9
PIIC Data Request 1.9
With regard to the prefiled testimony of Ms. Joelle Steward page 5, lines 19-20,
please provide an explanation and documentation on why the Company is
proposing that scheduled maintenance power is at one-half of the Back-up Power
rate.
Response to PIIC Data Request 1.9
The Company believes that the power costs in the Scheduled Maintenance periods
would generally be less than the costs in the unscheduled outage periods served
by Back-up Power. The proposed one-half relationship between Scheduled
Maintenance Power rate and the Back-up Power rate is the same as what has been
implemented in the Company's Partial Requirement Schedule 33 in Wyoming and
Partial Requirement Schedule 31 in Utah.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-12/Rocky Mountain Power
October 17, 2012
PIIC Data Request 1.10
PIIC Data Request 1.10
It appears that the Company's proposed Schedule 31 back-up and scheduled
maintenance demand charges in Idaho are not limited to just on-peak hours as is
the case with regard to the Company's Utah and Wyoming tariffs. Please explain
why the Company is proposing to assess demand costs for back-up and schedule
maintenance service during off-peak hours in Idaho.
Response to PIIC Data Request 1.10
The proposed Schedule 31 rates are based on and aligned with Idaho Electric
Service Schedule 9 which has a seasonal non-time of use Power Rate and Energy
Rate. The Company's partial requirement Schedule 33 in Wyoming and partial
requirements Schedule 31 in Utah have time of use rates because their
corresponding full service schedules have time of use rates.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-l2fRocky Mountain Power
October 17, 2012
PIIC Data Request 1.11
PIIC Data Request 1.11
With regard to the prefiled testimony of Ms. Joelle Steward page 5, line 21 to
page 6, line 2, please provide an explanation and documentation on why the
Company is proposing that the Excess Power Rates be twice the Supplemental
Power Rate.
Response to PIIC Data Request 1.11
The Excess Power rate is designed to encourage the customer to establish accurate
and appropriate contract levels to protect other customers and the Company from
higher potential costs as a result of serving load in excess of the contract. The
proposed relationship between Excess Power rate and the Supplemental Power
rate is the same as what has been implemented in the Company's Partial
Requirement Schedule 33 in Wyoming and Partial Requirement Schedule 31 in
Utah.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-l2fRocky Mountain Power
October 17, 2012
PIIC Data Request 1.12
PIIC Data Request 1.12
With regard to the prefiled testimony of Ms. Joelle Steward page 5, line 21 to
page 6, line 2, please provide an explanation on why the Company is proposing to
include an Excess Power Rate in Schedule 31 when no such charge exists under
Schedule 9 service.
Response to PIIC Data Request 1.12
Please refer to the Company's response to PIIC Data Request 1.11. There is not
an Excess Power rate on Schedule 9 because customers on Schedule 9 take full
service and do not take back-up services. The Excess Power rate has also been
implemented in the Company's other Rocky Mountain States - Partial
Requirements Schedule 33 in Wyoming and Partial Requirements Schedule 31 in
Utah.
Record holder: James Zhang
Sponsor: Joelle Steward
PAC-E-12-12IRocky Mountain Power
October 17, 2012
PIIC Data Request. 1.13
PIIC Data Request 1.13
With regard to Exhibit 1, Page 8 of 13, Definitions: Back-Up Contract Power, the
sentence reading: "The Back-up Contract Power shall be established by
agreement between the Customer and the Company." Please explain the
circumstances under which the customer would not have the unilateral right to
specify or elect the exact amount of Back-up Power it requires. In other words,
under what circumstances would the Company not agree to the amount requested
by the customer?
Response to PIIC Data Request 1.13
As long as the Back-up Contract Power request is consistent with the terms of
Schedule 31, the Company would not object, but the Back-up Contract Power
amount must be identified in the agreement between the Customer and the
Company.
Record holder: Paul Clements
Sponsor: Joelle Steward