20121214IIPA 1-21 to PAC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE &iBMLEY
W. MARCUS W. NYE CHARTERED RANDALL C. BUDGE
JOHN A. BAILEY, JR. flI fl CD [4 AM 8: BOISE OFFICE
JOHN R. GOODELL 201 EAST CENTER STREET LU) 1. uLt. ) (01 SOUTH CAPITOL
JOHN B. INGELSTROM POST OFFICE BOX 1391 BOULEVARD, SUITE 300
DANIEL C. GREEN POCATELLO, IDAHO 83204-1391 BOISE, IDAHO 53702
BRENTO ROCHE TELEPHONE [phone]
KIRK B HADLEY FACSIMILE (20$) 4330187
FRED J. LEWIS TELEPHONE [phone]I0i
ERIC L. OLSEN FACSIMILE [phone] IDAHO FALLS OFFICE CONRAD J. AIKEN 477 SHOUP AVENUE
RICHARD A. HEARN, M.D. SUITE 107
LANE V. ERICKSON www.racinelaw.net POST OFFICE BOX 50885
FREDERICK J. HAHN, III IDAHO FALLS, ID $3405
PATRICK N. GEORGE TELEPHONE, [phone]
SCOTT J. SMITH FACSIMILE, (208) 52$-6109
JOSHUA D. JOHNSON
DAVID E. ALEXANDER ALL OFFICES TOLL FREE STEPHEN J. MUHONEN [phone]
CANDICE M. MCHUGH SENDER'S E-MAIL ADDRESS: [e-mail]
CAROL TIPPI VOLYN
JONATHON S. BYINGTON
JONATHAN M. VOLYN LOUIS F. RACINE (1917-2005)
THOMAS J. BUDGE WILLIAM D. OLSON, OF COUNSEL
BRENT L. WHITING
DAVE BAGLEY
JASON E. FLAIG December 1 ' ecemuer FERRELL S. RYAN, III is.,
AARON A. CRARY
JOHN J BULGER
BRETT R CAHOON
JEFFREY A. WARR
Jean J. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0084
Re.- Case No. PAC-E- 12-14
Dear Mrs. Jewell:
Enclosed for filing in the captioned case please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. 's First Data Request to Rocky Mountain Power.
Thank you for your assistance.
.Süçerely,
ERIC L. OLSEN
ELO:tjl
Enclosures
c: Service List (Via Email)
Eric L. Olsen (ISB#: 481 1)
RACINE, OLSON, NYE,
BUDGE & BAILEY, CHARTERED
P.O. Box 1391
Pocatello, Idaho 83204-1391 JTLIT3 COM;
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Intervenor Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION)
OF ROCKY MOUNTAIN POWER FOR)
AUTHORITY TO CANCEL ELECTRIC)
SERVICE SCHEDULE NOS 72 AND 72A)
IRRIGATION LOAN CONTROL TARIFFS)
AND APPROVE A NEW DEMAND SIDE)
MANAGEMENT CONTRACT
CASE NO. PAC-E-12-14
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC'S FIRST DATA
REQUEST TO ROCKY MOUNTAIN
POWER
Idaho Irrigation Pumpers Association, Inc., by and through its attorneys, hereby submits
this First Data Request to Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public
Utility Commission's Rules of Procedure, IDAPA 31.01.01, as follows:
1.Please supply copies of the annual reports for 2011 and 2012 regarding the operation of the
Idaho Irrigation load control program that usually goes by the title of "Schedule 72 & 72A
Idaho Irrigation Load Control Programs".
2.Please provide for 2011 and 2012 (unless already provide in #1 above) similar data to that
provided in Tables 15 through 21 and Table 23 of the 2010 report entitled "Schedule 72 &
72A Idaho Irrigation Load Control Programs".
3.What was the system load during each hour of the 2011 and 2012 summer periods? If any of
these values contain "buy-through" energy for any large customer that was
interrupted/curtailed and chose to have power bought for it off-system, what was the level of
such buy-through power?
1D4HO IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - Page 1
4. Please provide in electronic format for the summers of 2010 and 2011 hourly data similar to
that provided in IIPA Request 9 in PAC-E-10-07 and IIPA Request 9 in PAC-E-1 1-12.
5. What was the level and time of curtailment/interruption for each customer class or large
industrial customers by state, during each hour of the 2011 and 2012 summer periods?
(Please specify at input level.)
6. With respect to the Company's Load Research data, please provide for each sample irrigation
customer with valid data that was sampled during 2011 and 2012 and following:
a.Customer identification number;
b.Customer rate schedule (72 or 72A);
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.
g.Please provide copies of the formulas (and data) used to expand the Load Research data
up to the population as a whole. This information should include number of customers in
the population of each class.
7. For the Irrigation load research samples, what is the range (kW or kWh) cut-off for each
stratum?
8. Please provide a copy of PacifiCorp's FERC Form 1 for 2011.
9. Please provide a copy of PacifiCorp's most recent IRP.
10. On page 5 of the Company's Application at paragraph 13, it states: "...The Company had the
ability to evaluate the week-to- week availability of actual controllable load in Idaho."
a.Please supply the specific data used to develop this week-to-week availability.
b.Please provide an example by demonstrating how the availability was calculated for the
first week.
c.What was the specific availability that was calculated for each week?
d.How was this availability data incorporated into the chart on page 6?
11. On page 6 of the Company's Application there is a chart. Please answer the following:
a.What are the values, times, and dates of each of the points shown on the chart?
b.What specific data was used to develop each of these points?
c.Please provide the data that formed the "10-YR system Peak Period" listed.
d.Please provide a similar chart for 2010 and 2011.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - Page 2
e. The "Participating Load" is said to be developed from "the most recent two-year Program
Seasons". Please provide the data separately for both 2011 and 2012.
12. On page 6 of the Company's Application at paragraph 14 it states: "The Company has been
able to reduce operation costs of the program ..." Please answer the following:
a.What has been the Company's "operating costs of the program" for each of the years
2006 through 2012?
b.What has been the scope and cost of the third party service provider for each of the years
2006 through 2012?
c.Please explain what is meant by "utilizing inventoried equipment as it readied for the
reprocurement of control equipment and series."
13. On page 7 of the Company's Application at paragraph 15 it states: "...in an effort to identify
program delivery alternatives ..." There are two "Options" listed in paragraph 16.
a.Were these two Options the only "delivery alternatives" considered?
b.Which of these Options is pay-for-performance?
c.Please provide any memos and/or emails that deal with the desire to "identify program
delivery alternatives."
14. With respect to paragraph 16, over each year 2007 through 2012 what was the amount of
money the Company spent on the following:
a. Equipment
b. Equipment installation
c. Operation
d. Maintenance
e. Customer service
f. Customer incentives
g. Third-party contractor(s)
h. Incentive payments
15.On page 8 of the Company's Application at paragraph 16 it states that five proposals were
received. It further states that a pricing analysis of the five proposals can be found in
Confidential Attachment No. 1. That attachment gives different treatment to the two Options
(i.e. 10 years vs. 5 years and other format differences). Please provide an analysis for both
Options on the same basis.
16.On page 10 it states that: "the vendor has been provided an incentive to optimize the amount
of load curtailment during historical peak time period..."
a. What does the Company consider this incentive to be?
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - Page 3
b.What has prevented the Company from optimizing the amount of load curtailment during
historical peak time period?
c.Given the general shape of the irrigation usage over the summer months, how will a
contractor optimize the load curtailment better than the Company has in the past?
17. On page 10 of the Company's Application at paragraph 17 it states that: "the Company
determined that the most efficient and effective manner to continue to offer the irrigation
load control program is through a pay-for-performance bi-lateral contract model ..."
a.What is meant by "efficient"?
b.What is meant by "effective"?
c.Why can't the Company provide a similar efficient and effective program?
d.How does adding a third party into the mix (that needs to be compensated) result in lower
costs than the Company could incur on its own?
18. Under the proposed use of a third party contractor and under pay-for-performance, will the
terms of the contracts be different than those found in the existing Schedule 72A? If so,
please describe what would or could be different. Also describe if different terms could
apply to customers of the same size and/or different sizes.
19. How will the Company and/or the Commission be assured that the resulting contracts will be
just and reasonable for all customers?
20. On confidential attachment 1 there is listed a "Target Realized kW/year". Is this figure to
represent the total of the:
a.Load signed-up to participate in the program?
b.The maximum load to be called upon and delivered at any given time?
21. Under the confidential attachment 1 there is listed the pricing analysis for the five proposals
that were received. Please provide a similar analysis for the program operated by the
Company for each of the past five years and as projected for each of the 10 future years.
DATED this 2.day of December, 2012.
RAC1NE OLSON NYE BUDGE
& BAILEY, CHARTERED
1 11 I V Za - WIN V~
!C -IL:-0iL7SEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - Page 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 1Z'lay of December, 2012 I served a true, correct
and complete copy of the Petition of Idaho Irrigation Pumpers Association, Inc. For Leave to
Intervene to each of the following, via U.S. Mail or private courier, e-mail or hand delivery, as
indicated below:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 W. Washington Street
Boise, Idaho 83720-0074
jjewell(,puc.state.id.us
Mark C. Moench
Daniel E. Solander
201 South Main, Suite 2300
Salt Lake City, UT 74111
Phone: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Ted Weston
Rocky Mountain Power
Manager, Idaho Regulatory Affairs
201 South Main Street, Suite 2300
Salt Lake City, UT 84111
Phone: [phone]
Fax: [phone]
Email: [e-mail]
PacifiCorp
Data Request Response Center
825 NE Multnomah, Suite 2000
Portland, OR 97232
Email: datareguest(pacificorp.com
X U.S. Mail/Postage Prepaid
E-mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-mail
Facsimile
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
X E-mail
Facsimile
Overnight Mail
Hand Delivered
2az',~
E CL.OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - Page 5