20210715PAC to IIPA 1-3.pdf

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POWER
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1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
RE
Jtily 15,2021
Eric L. Olsen (ISB# 4811)
ECHO [{AWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6l l9
Pocatello, Idaho 83205
[e-mail] (C)
Anthony YankeYIIPA [e-mail] (C)
ID PAC-E-21.07
IIPA Set I (1-3)
Please find enclosed Rocky Mountain Power's Responses to IIPA I't Set Data Requests l-3.
Also provided are Attachments IIPA 1,2-1,2-3 and 24. Provided via encryption is Confidential
Attachment llPA2-2. Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of Procedure No.
67 - Information Exempt from Public Review, and further subject to the Non-Disclosure
Agreement (NDA) executed in this proceeding.
If you have any questions, please feel free to call me at [phone].
Sincerely
-Jsl-J. Ted Weston
Manager, Regulation
Enclosures
C.c. : Jan Noriyuki/IPUC ian.norivuki(@puc. idaho. eov (C)
Ronald L. Williams/PIIC ron@williamsbradburv. com
Bradley G. Mullins/PIIC brmull [e-mail]
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC val. [e-mail] (W)
Ben Otto/ICL bottof)idahoconservat ion. ors (c)
Randall C. Budge/Bayer randy@racineolson. conr (C)
Thomas J. Budge/Bayer ti @rac ineolson. com (W)(C)
Brian C. Collins/Bayer bcollins@.consultbai. com (WXC)
Maurice Brubaker/B ayer mbrubaker@c onsultba i. com (C)
Kevin Higgins/Bayer khieeins@.enerevstrat.com (C)
Lance KaufrnanlBayer lance@.aeeisinsieht.com (C)
James R. SmithlBayer i im. r. smith@ic loud. com (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
July 15,2021
IIPA Data Request 1
IIPA Data Request I
On page 25 of McDougal's direct testimony, lines 5-7, it states that page 3.1 of
Tab 3 of Exhibit 40 contains temperature normalization adjustnents. With respect
to pages 3 . I .3d and 3.1 .4, please answer the following and provide tabular data in
Excel format:
(a) Where on these pages are the adjustnents for temperature normalization
contained?
(b) Please provide the meaning of the alphanumeric terms in the first column
entitled "Schedule".
(c) Please explain the meaning of the term "Unbilled" in the first column entitled
"Schedule". Assuming that the "Unbilled" values listed are (primarily) for
December of 2020, how have the values for the "Unbilled" from December
2019 reflected on these sheets? Please explain.
(d) According to Footnote 2, the values in the column entitled "Reconciling
Adjustnents" are "Type 1" adjustnents. 'oType 1" adjustnents consist of a
number of different types of adjustments. For each "Schedule" please list the
individual adjustnents that make up the total "Type l" adjustments found for
each "Schedule".
(e) According to Footrote 3, the values in the column entitled o'Normalization"
are "Type 2" adjustments. "Type 2" adjustments consist of the difference
between actual revenues and "the calculated billing determinants developed
by Pricing". For each "Schedule", for each month, please provide the billing
determinants, pricing and revenue associated with both the actual revenues
and the values provided by Pricing.
(f) What is the meaning/purpose of the values in the column entitled "blocking"?
(g) Where are the o'temperature normalizing adjusfinents", what were the actual
and normalized temperatures for each "Schedule", and what were the amounts
of the normalized revenue adjustments for each "Schedule"?
Response to IIPA Data Request I
Please refer to Attachment IIPA l.
Recordholder James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
Ju,ly 16,2021
IIPA Data Request 2
IIPA Data Request 2
Exhibit 45 contains, by rate schedule and rate block, all of the Idaho "normalized
billing determinants" for 2019 and2020.Information is sought with respect to the
development of these values. Please provide all data in Excel format.
(a) For each billing unit listed for 2019 and,2020, please provide the actual billing
determinants for each month of 2019 and2020.
(b) For each billing unit listed for 2019 and2020, please provide the weather
normalizing adjustnent for each billing determinant for each month of 2019
and2020.
(c) For each billing unit listed for 2019 and2020, please provide the weather
normalizing adjustnent for each month of 2019 and2020.
(d) For each billing unit listed for 2019 and2020, please provide the normal
weather values and the actual weather values that were used to develop the
weather normalized adjustnent for each month of 2019 and2020.
(e) What is the source data used to establish the normalized weather figures?
Over what period was this data gathered?
(f) Please provide the source data utilized to develop the source data used for
weather normalization in this case.
(g) What equation(s) were used to convert the normalized weather values into
normalized billing units in Exhibit 45?
(h) For each billing unit listed for 2019 and2020, please provide the value for any
non-weather normalizing adjustments used for each month of 2019 and2020.
Please specifr the reason for these normalizing adjustments.
Response to IIPA Data Request 2
(a) The Company has only developed the annual billing determinants for 2019
and2020 in the general rate case (GRC). The monthly billing determinants for
2019 and2020 are not readily available.
(b) The Company has only developed the annual billing determinants for 2019
artd2020 in the GRC. The monthly billing determinants and the weather
normalizing adjustment for 2019 and2020 are not readily available.
(c) Please refer to Attachment IIPA 2-1. In this GRC, the 2020 weather
normalizing adjustnent are not used in the billing determinants of 2020.
PAC-E-21-07 / Rocky Mountain Power
Jluly 16,2021
IIPA Data Request 2
Instead, all the billing determinants of 2020 are ratioed based on 2019 billing
determinants and the total number of customers and energy sales in 2020 as
the Company's witness, Robert M. Meredith, explained in his direct
testimony.
(d) Please refer to Attachment IIPA 2-l which provides the actual and normal
monthly heating degree day (HDD) and cooling degree day (CDD) data used
to develop the weather normalized adjusfrnent for each month of 2019. Please
refer to the Company's response to subpart (c) above regarding 2020 weather
normalizing adjustnents.
(e) The source data used to establish the normalized weather figures is the actual
daily HDD and CDD data for the preceding 20 years (1999 through 2018 for
2019). Please refer to the Company's response to subpart (c) above regarding
2020 weather normalizing adjustrnents. The data is gathered from daily
information provided by the Company's weather vendor.
(f1 Please refer to Confidential Attachment IIPA 2-2 for the daily HDD, CDD
and average dry bulb (AvgDB) data utilized to develop the source data used
for weather normalization in this GRC.
(g) Please refer to Attachment IIPA 2-3. Tab "TempRev-2019" shows how the
monthly weather normalizing adjustnents in 2019 were assigned into seasons
and tier blocks by class and schedules and put into normalized billing units in
Exhibit 45.
(h) Please refer to Attachment llPA2-4. The Company has only developed the
annual billing determinants for 2019 and2020 in this GRC. The monthly
billing determinants for 2019 and2020 are not readily available. In the
attachment, the normalizing adjusfinent for the number of customers reflects
the diflerence between number of customers booked in the Company's
revenue report system and the number of customers developed and calculated
from the Company's customer billing system. Column "Normalization"
reflects the adjustment on kilowatt-hours (kWh) includes out of period
adjustment, and normalization of Schedule 400 (buy-through out, curtailment
in). Column "Unbilled" reflects the proportionally allocation of the annual
unbilled kWh to each tariffschedule. Column "Temperature" reflects the
weather normalization adjustrnent kWh. Column "Blocking" reflects the
differences between the actual energy usage kWh from the customer billing
system and the calculated energy usage kWh based on the billing determinants
developed by the Company in this GRC.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and 31.01.01.233, the Idaho Public Utilities Commission's Rules of
PAC-E-21-07 / Rocky Mormtain Power
July 15,2021
IIPA DataRequest 2
Proceduro No. 67 - Information Exempt from Public Review, and firther subject
to the Non-Disolosure Agreoment (NDA) exocuted in this proceedirrg.
Recordholder: James Zbangl Lee Elder
Sponsor: Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
Ju,ly 15,2021
IIPA Data Request 3
IIPA Data Request 3
For each month from January 2014 ttrru the most recent month available, please
provide all Idaho billing determinants in a format similar to Exhibit 45. Please
provide in Excel format.
Response to IIPA Data Request 3
The Company objects to this request because developing monthly billing
determinants for a time period from 2014 -2021is unduly burdensome and
includes information not relevant to the current proceeding.
The Company has only developed the annual billing determinants for 2019 and
2020 rul,the general rate case (GRC). The monthly billing determinants from 2014
through the most recent month are not readily available.
Recordholder:James Zhang
Robert MeredithSponsor: