20150714PAC to IIPA 1-12.pdf

ROCKY MOUNTAIN i
POWER
A D|USTON OF mCFmS
Iuly 14,2015
Eric L. Olsen
RACINE, OLSON, NYE,
BUDGE & BAILEY, CHARTERED
P.O. Box 1391
Pocatello, Idaho 83204-1391
[e-mail] (C)
RE: ID PAC-E-15-09
IIPA 1't Set Data Request (1-12)
Please lind enclosed Rocky Mountain Power's Responses to IPUC Data Requests 1-12. Also
provided are Attachments IIPA 1 -{l-2),2,3,7 , 10, and 1 1 . Provided on the enclosed
Confidential CD is Confidential Attachment IIPA 12. Confidential information is provided
subject to the terms and conditions of the protective agreement between RMP and IIPA in this
proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely,
JTd tttmn/na"t
J. Ted Weston
Manager, Regulation
Enclosures
C,c.: Jean Jewell/IPUC [e-mail] (C)
Ronald L. Williams/PIIC [e-mail]
Val Steiner/Agrium val. steiner@agrium. com
Jim Duke/Idahoan Foods [e-mail]
Randall C. Budge/Monsanto [e-mail] (C)
Brian C. Collins/Brubaker & Associates bcollins@.cptsultbai. com
James R. Smith/Monsanto i [e-mail] (C)
Maurice Brubaker/Monsanto [e-mail]
Katie IversorVMonsanto [e-mail] (C)
Anthony Yankel/Yankel & Associates Inc. [e-mail] (C)
201 South Main, Suite 2300
Salt Lake City, Utah 841 I I
PAC-E-I5-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request I
IIPA Data Request I
Please supply in electronic format the monthly total company expenses charged to
each of the various components that make up the. ECAM since July 2009.
(Accounts 447,501,503, 555, and 565, as well as the LCAR, S02 sales, DSM,
and REC.
Response to IIPA Data Request I
Please refer to Attachment IIPA I -1, which provides Total Company net power
costs (NPC), and Attachment IIPA 1 -2, which provides Total Company sulfur
dioxide (SOz) sales, Type 1 Demand-Side Management (DSM) costs, the load
change adjustment rate (LCAR) and renewable energy credits (REC) revenues.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-15-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request 2
IIPA Data Request 2
Please supply in electronic format the monthly Idaho jurisdictional expenses
charged to each of the various components that make up the ECAM since July
2009. (Accounts 447, 501,503, 555, and 565, as well as the LCAR, S02 sales,
DSM, and REC.
Response to IIPA Data Request 2
The ECAM components, made up mostly of net power costs, are incurred on a
total Company basis (see Attach IIPA l-1) and then allocated to [daho based on
the demand and energy usage in each jurisdiction.
Attachment IIPA2, provides the Idaho allocated Actual net power costs (NPC)
per the Energy Cost Adjustment Mechanism (ECAM). Note: the Idaho Actual
NPC are calculated on a Total Company basis. Please refer to the Company's
response to IIPA Data Request 1; specifically Attachment IIPA I -2, which
provides Total Company sulfur dioxide (SOz) sales, Type I Demand-Side
Management (DSM) costs, and renewable energy credits (REC) revenues.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-15-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request 3
IIPA Data Request 3
Please supply in electronic format the monthly ldaho jurisdictional values (since
July 2009) that would have been incorporated in the calculation of Exhibit 2 of
Mr. Wilding's testimony.
Response to IIPA Data Request 3
Please refer to Attachment IIPA 3, which includes the net power costs (NPC)
component in rates, Idaho actual sales at meter, third party wind integration costs,
Total Company sales at meter, EITF 04-06 adjustment, Total Company and actual
production tax credits (PTCs), base PTCs in base rates, and base renewable
energy credits (REC) in rates. Please refer to the Company's response to IIPA
Data Request 1; specifically Attachment IIPA l-2, which provides REC revenue.
Note: the Lake Side 2 resource adder was not effective until January I , 201 5 and
therefore, would not have been included.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-15-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request 4
IIPA Data Request 4
Please supply in electronic format the monthly ldaho jurisdictional values (since
July 2009) that were incorporated in a document similar to Exhibit 2 of Mr.
Wilding's testimony, but based upon the methodology approved by the
Commission (including the 90-10 sharing and any other components that are
proposed to be included / excluded in Exhibit 2.
Response to IIPA Data Request 4
Please refer to the Company's response to IIPA Data Request 1; specifically
Attachment IIPA 1 -1, and Attachment IIPA l-2. In addition, please refer to the
Company's response to IIPA Data Request 2; specifically Attachment IIPA 2.
Note: the sharing bands have been 90/10 since the inception of the Energy Cost
Adjustment Mechanism (ECAM) in July 2009.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 / Rocky Mountain Power
July 14, 2015
IIPA Data Request 5
IIPA Data Request 5
On page 4 of the Application, it is stated: "Therefore, the Company proposes to
update the level of base NPC consistent with the level reported in the Annual
Results." Please answer the following:
(a) Is the NPC that is presently used and calculated in the 20l l general rate case,
based upon a normalized test year?
(b) Does the Company's statement that it proposes the new NPC to be "consistent
with the level reported in the Annual Results", mean that it would be using
actual data as opposed to normalized?
Response to IIPA Data Request 5
(a) Yes, the current base net power costs (NPC) from the 2011 general rate case
(GRC) is based on a normalized test year.
(b) No, the NPC in the Annual Results of Operations (ROO) are normalized NPC.
The NPC in the ROO project the NPC needed to serve 2014 normalized load,
incorporating known changes occurring in 2015. The NPC in the ROO
incorporates the latest forward market prices for natural gas and electricity,
signed contracts, coal costs, and other inputs to the Company's Generation
and Regulation Initiative Decision Tool (GRID); the production cost model, to
best represent expected NPC.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 / Rocky Mountain Power
July 14, 2015
IIPA Data Request 6
IIPA Data Request 6
According to the Application at page 4: "By updating base NPC and allowing that
level of expense to be included in base rates beginning January 1,2016, the
ECAM will be better aligned to track annual fluctuations in NPC rather than long-
term recovery of NPC currently being collected through the annual ECAM
surcharge." Assuming that the level of the NPC begins to fall on January 1,2016,
how would increasing base NPC in this case, cause the ECAM to be "better
aligned to track annual fluctuations in NPC?
Response to IIPA Data Request 6
The current base net power costs (NPC) is $1,385 million compared to the 2014
actual NPC of $1,607 million. The Company is proposing to raise base NPC to
$1,514 million. Updating base NPC will allow the Energy Cost Adjustment
Mechanism (ECAM) to function as a tracking mechanism rather than a long-term
recovery mechanism. In the event that 2016 actual NPC falls below the proposed
base NPC, the Company would refund the customer share of the excess NPC
collected.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 / Rocky Mountain Power
July 14, 2015
IIPA Data Request 7
IIPA Data Request 7
Please provide a mathematical example that demonstrates why the Staffs base rate
over- collection adjustment should be eliminated.
Response to IIPA Data Request 7
Idaho Public Utilities Commission (IPUC) staff s base rate over-collection
adjustment should be eliminated because it will no longer be needed in the event
the proposed Energy Cost Adjustment Mechanism (ECAM) is adopted. This is
because the same calculation that is used to determine the base rate over-
collection adjustment will be used to determine the deferral amount. Please refer
to Attachment IIPA 7, which provides an example.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request 8
IIPA Data Request 8
Please explain the differences that cause the Company to want to eliminate the
DSM and S02 sales from the ECAM and yet want to introduce the production tax
credits into the ECAM.
Response to IIPA Data Request 8
Please refer to the Direct Testimony of Company witness, Michael G. Wilding,
beginning on page 23 line 2 through page24line23.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request 9
IIPA Data Request 9
According to the Application at page 5, the "sharing band has historically
penalized the Company". Please quantifr the impact of the sharing baud for each
year that the ECAM has been in effect.
Response to IIPA Data Request 9
Please refer to the table below:
2O1O ECAM
2011 ECAM
2012 ECAM
2013 ECAM
2014 ECAM
2015 ECAM
Total
Amount
by Sharing Band
$ 1s0,074
1,115,707
1,800,90s
1,770,116
M2,059
1,301,245
$ 6,980,106
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 / Rocky Mountain Power
luly 14,2015
IIPA Data Request 10
IIPA Data Request l0
For each of the years in which the ECAM has been in effect, please provide an
explanation and quantification of how the LCR has been asymmetrical.
Response to IIPA Data Request 10
The LCAR is an adjustment to the Energy Cost Adjustment Mechanism (ECAM)
that accounts for the collection of Energy-Classified Production Cost excluding
net.power costs (NPC-ECPC) (i.e. energy-classified fixed costs from the most
recent general rate case as changes in load occur. The LCAR is calculated by
comparing the ldaho base load to Idaho actual load and multiplying the difference
by the LCAR rate which is currently $5.47 per megawatt-hour ($/IvIWh). The
Company believes this comparison is asymmetrical because the rate is frozen and
is not updated to account for changes in NPC-ECPC. Please refer to Attachment
IIPA 10.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-15-09 / Rocky Mountain Power
JuIy 14,2015
IIPA Data Request 11
IIPA Data Request 11
For each of the years in which the ECAM has been in effect, ryhat has been the
amount of inigation load control costs and other DSM cost that were included?
Response to IIPA Data Request 11
Please refer to Attachment IIPA 11, which provides the Demand-Side
Management (DSM) costs included in the Energy Cost Adjustment Mechanism
(ECAM). Note: the DSM costs were not included before December 2012.
Recordholder: Michael G. Wilding
Sponsor: Michael G. Wilding
PAC-E-I5-09 lRocky Mountain Power
July 14,2015
IiPA Data Request 12
IIPA Data Request 12
Please provide in electronic format for the period January l,20l l through the
most recent month available hourly data similar to that provided in IIPA Request
9 in PAC-E- 10-07,
Clarification to IIPA Data Request 12 - thc subparts from IIPA Data
Request 9 in Idaho Case No. PAC-E-10-07 are restated below:
A. Total system inPut;
B. System input from Company owned generation;
C. System input from firm purchases, stating each purchase separately by
source and type ofpurchase (LF, IF, SF);
D. The cost of each firm purchase listed in "C" above;
E. System input from non-firm and/or economy purchases, stating each
purchase separately;
F. The cost of each non-firm and/or economy purchase listed in "E" above;
G. System input from exchanges into the system, stating each exchange
separately;
H. System input from Unit purchases;
I. Other system inputs, stating for each "other" input the type and the source of
the input;
J. System losses;
K. Requirements Wholesale sales (RQ);
L. Long-term firm Wholesale sales (LF), stating each one separately;
M. Intermediate-term firm Wholesale sales (IF), stating each one separately;
N. Short-term firm Wholesale sales (SF), stating each one separately;
O. Unit sales, Wholesale (LU) or otherw'ise, stated separately;
P. Non-firm andlor economy Wholesale sales (OS). stated separately;
PAC-E-15-09 / Rocky Mountain Power
July 14,2015
IIPA Data Request 12
a. The revenue collected for each hour of each non-firm and/or economy
purchase listed in o'P" above;
R. Exchanges out of the system, stating each exchange separately;
S. Other system outputs, stating for each ooother" output the type and the
recipient ofthe output; and
T. [nadvertent power flows into or out of the system.
Response to IIPA Data Request 12
Please refer to Confidential Attachment IIPA 12, which provides the requested
available information for the period January l,20ll through December 31,2014.
Note: the information requested for subpart A is the sum of the information
requested for subpart B through subpart H. Therefore, information for subpart A
is not provided separately. There were no "other" input or output types and
therefore no information is provided for subparts I and S.
Confidential information is provided subject to the terms and conditions of the
protective agreement between RMP and IIPA in this proceeding.
Recordholder: Ray Zacharia I Cathy Wright
Sponsor: Michael G. Wilding