20130408IIPA 1-14 to PAC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE & BAILEY
W. MARCUS W. NYE CHARTERED RANDALL C. BUDGE
JOHN A. BAILEY, JR. BOISE OFFICE
JOHN R. GOODELL 201 EAST CENTER STREET 101 SOUTH CAPITOL
JOHN B. INGELSTROM POST OFFICE BOX 1391 BOULEVARD, SUITE 300
DANIEL C. GREEN POCATELLO, IDAHO 83204-1391 BOISE, IDAHO 83702
BRENT 0. ROCHE ______________ TELEPHONE, [phone]
KIRK B. HADLEY FACSIMILE: [phone]
FRED J. LEWIS TELEPHONE [phone]
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.radnelaw.net POST OFFICE BOX $0808
FREDERICK J. HAHN, III IDAHO FALLS, ID 83405
PATRICK N. GEORGE TELEPHONE: [phone]
FACSIMILE: [phone] SCOTT J. SMITH
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 April 4, 2013 FERRELL S. RYAN, III
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-13-04,- ORDER NO. 32779
Dear Mrs. Jewell:
Enclosed for filing in the captioned case please find the original and seven copies of
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST DATA REQUEST TO
ROCKY MOUNTAIN POWER.
Thank you for your assistance.
ELO:tjl
Enclosures
C: Service List (Via Email)
Eric L. Olsen (ISB#: 4811)
RACINE, OLSON, NYE,
BUDGE & BAILEY, CHARTERED
P.O. Box 1391
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY MOUNTAIN
POWER TO INITIATE DISCUSSIONS
WITH INTERESTED PARTIES ON
ALTERNATIVE RATE PLAN
PROPOSALS
CASE NO. PAC-E-13-04
ORDER NO. 32779
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FIRST DATA
REQUEST TO ROCKY MOUNTAIN
POWER
1.What were the dates, times, and levels of curtailment/interruption for each customer class in
each jurisdiction as well as Monsanto during 2012? (Please specify at input level.)
2.Please list the actual monthly jurisdictional peak levels and energy usages at input as well as
the resulting allocation factors.
3.Please list the normalized monthly jurisdictional peak levels and energy usages at input as
well as the resulting allocation factors.
4.Please list the normalized monthly jurisdictional peak levels and energy usages at input as
well as the resulting allocation factors, taking curtailment/interruptions into account.
5.When will the Company's 2012 Load Research data be available?
6.What were the monthly coincident peaks and energy usage at input for each of the Idaho
customer classes? What were the resulting allocation factors?
7.Please provide in electronic format for the period January 1, 2011 through the most recent
month available hourly data similar to that provided in IIPA Request 9 in PAC-E-10-07.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - PAGE 1
8. From January 2006 through the most recent month available, what was the date and time and
magnitude of the monthly system peak that would have occurred, had there been no
curtailment of load in any jurisdiction?
9. During the hour of the monthly peak from January 2011 through the most recent month
available, please provide the following:
a. How many megawatts of generation were out of service for planned maintenance?
a.How much electricity was generated from Company owned hydro?
b.How much electricity was purchased from Company owned thermal power?
c.How much electricity was purchased from QF suppliers?
d.How much electricity was brought in or sent out through 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.)?
e.How much electricity was sold off-system and at what price? Please list each transaction
separately, stating name of seller, MWH sold, sale price, and type of sale (LF, RQ, SF,
OS, etc.)?
f.How much load was interrupted via the Irrigation Load Management program or other
similar programs? Please specify each program separately.
10. Please provide electronically a listing of all dates, times, and expected magnitude of all
dispatched and scheduled day curtailments when Idaho irrigation load was curtailed under
Schedule 72A since January 2011.
11. For each hour since January 12011 to the most recent data available please provide the
following information in $/Mwh 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.
IDAHO IRRIGATION PUMPERS ASSOCIATION, 114C.'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - PAGE 2
12.For each hour of 2012, please list the system retail demand as well as the non-retail demand.
13.For each hour of 2010, please provide for each jurisdiction the estimated magnitude of the
aggregated load that was associated with buy-tbroughs.
14.In this case, how does the Company propose to treat the Idaho Jurisdictional load in the
jurisdictional allocation model under each of the following:
I.When the Irrigation load has been curtailed during a the hour of the recorded system
peak; and
II.When the Irrigation load has not been curtailed during a the hour of the recorded
system peak.
DATED this L/ of April, 2013.
' • i''' :s -
I V113 11-4 1:01 I
Sin
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - PAGE 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 14&day of April, 2013 I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.'s First Data Request to Rocky
Mountain Power to each of the following, via U.S. Mail or private courier, e-mail or hand
delivery, as indicated below:
Jean D. Jewell, Secretary Mail/Postage Prepaid
Idaho Public Utilities Commission E-Mail
P.O. Box 83720 Fax
472 W. Washington Street Overnight Mail
Boise, Idaho 83720-0074 Hand Delivered
iiewellpuc.state.id.us
Brad M. Purdy ____ U.S. Mail/Postage Prepaid
Attorney at Law -Mail
2019 N 171h Street Fax
Boise, ID 83702 Overnight Mail
[e-mail] Hand Delivered
Ronald L. Williams U.S. Mail/Postage Prepaid
Williams Bradury, P.C. L_ EM-ail
1015 W. Hays Street ____ Fax
Boise, ID 83702
Overnight Mail [e-mail] Hand Delivered
Don Schoenbeck U.S. Mail/Postage Prepaid
RCS, Inc. LE-Mail
900 Washington Street, Suite 780 Fax
Vancouver, WA 98660 ____ Overnight Mail
[e-mail] Hand Delivered
Benjamin J. Otto U.S. Mail/Postage Prepaid
Idaho Conservation League Mail
710 N 6th Street Fax
Boise, ID 83702 Overnight Mail
[e-mail] Hand Delivered
Tim Buller X Email ONLY
PacifiCorp Idaho Industrial Customers
Agrium Us Inc./Nu-West Industries
E-mail: tbuller(agrium.com
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - PAGE 4
Daniel E. Solander
Ted Weston
Rocky Mountain Power
201 S Main Street, Suite 2300
Salt Lake City, UT 84111
danieLso1ander(2ipacificorp.com
ted.weston(pacificorp.com
Data Request Response Center
Pacificorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
datareguestpacificorp.com
Randy C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E Center
P.O. Box 1391
Pocatello, ID 83204-1391
[e-mail]
Brubanker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
[e-mail]
X Email ONLY
- U.S. Mail/Postage Prepaid
t--Mail
Fax
- Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
Fax
Overnight Mail
Hand Delivered
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
[e-mail]
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
P.O. Box 83720
Boise, ID 83720-0074
neil.price(puc.idaho.gov
- U.S. Mail/Postage Prepaid
..-1Mail
Fax
Overnight Mail
Hand Delivered
U.S. Mail/Postage Prepaid
-E-Mail
Fax
Overnight Mail
Hand Delivered
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FIRST
DATA REQUEST TO ROCKY MOUNTAIN POWER - PAGE 5