20210804PAC to IIPA 6-20.pdf

ROCKY MOUNTAIN
BP,YY.EB.*"
., -l+ PH 2: !3
1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
August 4,2021
Eric L. Olsen (ISB# 481l)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6l 19
Pocatello, Idaho 83205
[e-mail] (C)
Anthony Yankel/IIPA tonv (@vankel.net (C)
RE: ID PAC-E-21-07
IIPA Set 3 (6-20)
Please find enclosed Rocky Mountain Power's Responses to IIPA 3'd Set Data Requests 6-14 and
20. The remaining responses will be provided separately. Also provided are Attachments IIPA
6,ll,l4-4, and20 a1,4-15, l7). Provided via BOX are Confidential Attachments IIPA 9 aL2),
10 {1-2), 14 {l-3,5), and 20 {l-13, 16). Confidential information is provided subject to
protection under IDAPA 31.01.01.067 and 31.01.01.233, the Idatro 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(Epuc.idaho.eov (C)
Ronald L. Williams/PIIC ron@williamsbradbury. com
Bradley G. Mullins/PIIC bmrull ins@mwanalvtics. com
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Ben Otto/ICL botto @idahoconservation. ore (C)
Randall C. Budge/Bayer randy (D.racineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson. com (WXC)
Brian C. Collins/Bayer bcoll ins@.consultbai. com OD(C)
Ivlaurice BrubakerrBayer [e-mail] (C)
Kevin HigginslBayer khieeins@enersvsratcom (C)
Lance Kaufinan/Bayer [e-mail] (C)
Jamcs R. Smith/Bayer iim.r.smith@.icloud.com (C)
Brad Purdy [e-mail] (C)
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA DataRequest 6
IIPA Data Request 6
In Meredith's work paper there is a spreadsheet entitled: Table I - Year Over
Year Load and Avg Price Change. Under the "Summary" tab it suggested that the
original worksheet included data for 2016 - 2018. Please provide all of this data in
the same format as provided for 2019 and2020 for Table l, including graphs. If
similar data is available for 2014 and 2015, please provide that also.
Response to IIPA Data Request 6
Please refer to Attachment IIPA 6.
Recordholder: James Zhang
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 7
IIPA Data Request 7
McDougal's Exhibit 39, page 1.0, line 2 lists General Business Revenues at
$271,491,123 and McDougal's Exhibit 40, atpage 46lists the same total Idaho
adjusted test year revenue. In Meredith's work paper there is a spreadsheet
entitled: Table 1 - Year Over Year Load and Avg Price Change. On tab '2019" of
that work paper it lists the total adjusted revenue as$271,416,358. Please explain
the basis for the small difference between the two values.
Response to IIPA Data Request 7
Those two values reflect two different test periods. McDougal's Exhibit 39,page
1.0, line 2, General Business Revenues at$271,491,123 is for the 2020 test
period. On tab *2019" of Meredith's work paper, Table I - Year Over Year Load
and Avg Price Change, total adjusted revenue *s5271,416,358 is for the historic
period 2019 as the tab indicates.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 8
IIPA Data Request 8
Why are the billing determinants and revenues used by Meredith for cost-of-
service purposes not being used by McDougal for revenue requirement purposes?
Response to IIPA Data Request 8
The revenues used by Company witress, Robert M. Meredith for cost of service
(COS) purposes are also used by Company witress, Steven R McDougal for
revenue requirement purposes. The actual billing determinants themselves are not
specifically used for revenue requirement.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 9
IIPA Data Request 9
With respect to the Company's Load Research data please provide, for each
sample customer the valid data that was sampled between January 2014 and the
most recent month available, the following in Excel:
(a) Customer identification number;
(b) Customer rate schedule;
(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;
(0 On an hourly basis, any additional calibrations that are applied to the Load
Research data before it is applied to develop the allocation factors used in the
Company's cost of service study in this case;
(g) Please provide any weatherization adjustnents that are applied; and
(h) Please provide copies of the formulas (and data) used to expand the Load
Research data up to the population as a whole as used in the class cost of
service study in this case. This information should include number of
customers in the population of each class.
Response to IIPA Data Request 9
Load research estimates have only been developed for 2019 and 2020. Equivalent
data for prior periods is not readily available.
(a) Please refer to Confidential Attachment IIPA 9-1. Customer identification is
contained in column A, tabs "Sch0Ol", "Sch036", "Sch006", "Sch023", and
"Sch0l0".
(b) Please refer to Confidential Attachment IIPA 9-1. Customer rate schedule is
contained in column C, tabs "Sch001", "Sch036", "Sch006", "Sch023", and
"Sch0l0".
(c) Please refer to Confidential Attachment IIPA 9-1. The strata to which each
customer belongs are contained in column B, tabs "Sch001", "Sch036",
"Sch006", o'Sch023", and "Sch010".
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 9
Schedule 001
Schedule 006
Schedule 010
Schedule 023
Schedule 036
Secondary: 1.09061
Blended primary and secondary: 1.08833
Secondary: 1.09061
Blended primary and secondary : 1.09048
Secondary: 1.09061
(d) Please refer to Confidential Attachment IIPA 9-1. Raw hourly usage data (i.e.,
unadjusted, (simply the data originally gathered for each sample) is contained
in columns E through AB, tabs "Sch0ol", "sch036", "Sch006", "Sch023",
and "Sch010".
(e) Because of the large volume of data involved, the Company is providing the
factors necessary to adjust the data supplied in the Company's response to
subpart (d) above to estimate losses. Multiplying the data by these factors will
satisfr the requirements of this request. Loss factors for each sampled rate
schedule are detailed below:
(f) The Company calibrated average load research profiles to monthly weather
normalized retail sales. This adjusfrnent involves dividing use in each hour by
the total use in that hour's month. The Company then multiply this factor by
the weather normalized retail sales in that month to produce a calibrated
value. Specifically:
caltbrated lJselou- = ,Y.?,t?"d ut"\.o:' x weather Normalized lJse*rngttLr - 2monthMetered Ilse1, rY cwb'Le' tt
Where:
Calibrated Useno,r,: The use in the hour, calibrated to monthly weather
normalized retail sales.
Metered Usenes.: The unadjusted use in that hour, as indicated by the
unadjusted average load research profile
lff!-ith Uetered. lI selr: The sum of metered use across all hours in the month
Weather N ormaltzed U se^orsL = Weather normalized retail sales for the
month.
Please refer to Confidential Attachment IIPA 9-2 for this calculation.
(g) Please refer to the Company's response to IIPA Data Request 2 subpart (g)
(h) The Company frst uses individual customer load profile data to calculate a
weighted average profile for each class. For any given time interval, the mean
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 9
unadjusted load research estimate (9) is equal to the sum of the weighted
stratum averages (Wrin):
I =l wnfn
The Company expands load research profiles to the population through the
calibration process described in the Company's response to subpart ((f)) above
This process does not require the population sizes for each class.
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.
Recordholder:Lee Elder
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request l0
IIPA Data Request 10
Previously the Company developed hourly calibrations that calibrated the Load
Research data such that the summation of the (population expanded) Load
Research data and the Census data equaled the Company's'oOperations Stat" or
border loads. The Company may no longer be applying these calibrations to the
Load Research data, but the data is still of interest. On an hourly basis from
January 2014 through the most recent month available, please provide:
(a) The "Operations Stat" or border loads for the Idaho Jurisdiction by location;
(b) The summation of the (population expanded) Load Research data and the
Census data that would reflect what the Company measured or estimated as its
internal customer load for each rate schedule or customer group;
(c) The hourly load for each rate schedule or special contract customer that is
measured or calculated on a census basis as opposed to using load research
data;
(d) Any other load that is contained in subpart (a) above but is not addressed in
subpart (c) above (please specifu the type of load); and
(e) Any information such as difference in measuring techniques or timing of the
data that needs to be addressed when comparing the above data.
Response to IIPA Data Request 10
(a) Please refer to Confidential Attachment IIPA 10-1 which provides
PacifiCorp's Idaho jurisdictional hourly load for calendar years 2014 through
2020.
(b) Please refer to Confidential Attachment IIPA l0-2 for the requested load
research data for 2019 and2020. Equivalent data for prior periods is not
readily available.
(c) Please refer to the Company's response to subpart (b) above.
(d) Please refer to the Company's responses to subpart (a) and subpart (c) above.
(e) Data within Confidential Attachment IIPA 10-1 is in Pacific Prevailing Time
(PPT), whereas the data provided within Confidential Attachment IIPA l0-2
is in Mountain Standard Time (MST).
PAC-E-2I -07 1 Rocky Mountain Power
Augnst 4,2A21
IIPADataRequest 10
Confidential information isprovided subject to proteotion under IDAPA
31.01.01.067 and31.01.01.233, the Idaho Public Utilities Commission's Rules of
Procedure No. 57 - Information Exempt from Public Review, aud fiuths subject
to the Non-Disclosure Agreement (NDA) executed in this procoeding.
Recordholder:David Novom / Lee Elder
Sponsor:Robert Meredith
PAC-E-2147 / Rocky Mountain Power
August 4,242L
IIPA DataRequest 1l
IIPA Ilatn Request 11
Ploase provide f,or each month from January 2014 forward a €opy of the results of
all checks that the Company makes regardiog how well the load researeh data
refleats the actual population usage.
Response to IIPA Data Request 11
Please refer to Attachment IIPA l1 for a compadson of load research sample data
fst 2019 and2020 to actual filling cycle data. Equivalent data for prior periods is
not readily available.
Recordholder: Lee Elder
Sponsor:Robert Mercdith
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA DataRequest 12
IIPA Data Request 12
For thE Inigation load researoh samples, what is the mnge ft\M or k$fh) cts-off
for each statum?
Response to IIPA Deta Request 12
The irrigation load research sanrple shata raxrge out-offs arie as follows:
o Stata 1: Up to 28,000 kilowat-hours (kWh)o Stata 2: Between 28,000 and 120,000 kWho Stata 3: Over 120,000 kWh
Recordholder:Lee Elder
Sponsor:Robert Meredith
PAC-E-2I-07 / Rocky Mountain Power
August 3,2021
IIPA Data Request 13
IIPA Data Request 13
This filing used "normalized" and weather-normalized data for developing
allocation factors in the jurisdictional allocations and presumably the class cost-
of-service study. For each rate schedule, please provide all work papers as well as
a description of the flow (manipulation) of data from historic load research or
consensus data to projected test year energy, coincident demands, and non-
coincident demands. Please supply this data in Excel format.
Response to IIPA Data Request 13
Please refer to the Company's response to IIPA Data Request 2 subpart (g) for the
temperature adjusfrnent megawatt-hours (MWh) by rate schedule used in this
general rate case (GRC) proceeding.
Please refer to the Company's response to IIPA Data Request 9 subpart (f) for an
explanation of how the Company applies load research data to monthly weather
normalized sales for the historic test year. Confidential Attachment IIPA 9-2
shows how the Company calibrates load research profiles to monthly historic
weather normalized sales. These calibrated profiles are the basis for energy and
demand in the test year.
Recordholder: Lee Elder
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 14
IIPA Data Request 14
Please provide in electronic format for the period January 1,2014 through the
most recent month available, relevant hourly temperafure data, HDD data, CDD
data, or other relevant data that the Company uses to make weather normalization
adjusfrnents for the Idaho jurisdiction's energy and monthly coincident peak
values.
Response to IIPA Data Request 14
Please refer to Confidential Attachment IIPA l4-l for the hourly temperature data
the Company uses to make weather normalization adjusftnents for the Idaho
jurisdiction's energy and monthly coincident peak (CP) values.
Please refer to the Company's response to IIPA Data Request 2, specifically
Confidential Attachment IIPA 2-2 for the daily heating degree day (HDD) data
and cooling degree day (CDD) data from January 1,2014 through December 31,
2019, and Confidential Attachment IIPA l4-2 for the daily HDD data and CDD
data from January 1,2020 through December 31,2020 that the Company uses to
make weather normalization adjustrnents for the Idaho jurisdiction's energy and
monthly CP values.
Please refer to Confidential Attachment IIPA l4-3 for the daily class level load
data that the Company uses to make weather normalization adjustrnents for the
Idaho jurisdiction's energy and monthly CP values.
Please refer to Attachment IIPA 14-4 for the residential customer, residential
sales, commercial sales and irrigation sale monthly cycle data that the Company
uses to calculate weather normalization adjustnents for the Idaho jurisdiction's
energy and monthly CP values.
Please refer to Confidential Attachment IIPA l4-5 for the annual economic driver
data that the Company uses to make weather normalization adjustnents for the
Idaho jurisdiction's energy and monthly CP values.
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.
Recordholder:Lee Elder
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 20
IIPA Data Request 20
Please provide in electronic format, on an hourly basis, for the period January 1,
2014 through the most recent month available the following data:
(a) Total system input;
(b) System input from Company owned generation (stating hydro, coal, wind,
and other generation separately);
(c) System input from frm purchases, stating each purchase separately by
source and type of purchase (LF, IF, SF, etc.);
(d) The cost of each firm purchase listed in subpart (c) above;
(e) System input from non-firm andlor economy purchases, stating each
purchase separately;
(f) The cost of each non-firm and/or economy purchase listed in subpart (e)
above;
(g) System input from exchanges into ttre system, stating each exchange
separately;
(h) System input from Unit purchases;
(i) Other system inputs, stating for each 'oother" input the type and the source of
the input;
0) Jurisdictional sales;
(k) System losses;
(l) Requirements Wholesale sales (RQ);
(m) Long-term firm Wholesale sales (LF), stating each on separately;
(n) Intermediate-term firm Wholesale sales (IF), stating each one separately;
(o) Short-term Wholesale sales (SF), stating each one separately;
(p) Unit sales, Wholesale (LU) or otherwise, stated separately;
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 20
(q) Non-firm and/or economy Wholesale sales (OS), stated separately;
(r) The revenue collected each hour from each non-firm andlor economy
purchased listed in subpart (q) above;
(s) Exchanges out of the system, stating each exchange separately;
(t) Other system outputs, stating for each "other" output the type and recipient
of the output;
(u) Inadvertent power flows into or out of the system;
(v) The power available (at input level) to supply retail load once Wholesale,
Exchange, Wheeling, and Inadvertent has been subfacted;
(w) Losses assigned to each retail jurisdiction;
(x) Losses assigned to Wholesale sales; and
0) Total retail load by jurisdiction.
Response to IIPA Data Request 20
The Company objects to this request as overly broad and burdensome with regard
to compiling hourly granular data for calendar years2014 through 2020. As
agreed between representatives of the Company and the Idaho Inigation Pumpers
Association (IIPA), this request is limited to seeking the requested information for
three calendar years (2018 through 2020). Based on the foregoing objection and
clarification, the Company responds as follows with data for calendar years 2018
through 2020, where applicable:
(a) Please refer to the Company's responses to subparts (b), (c), (e), (g), (h) and
(i) below.
(b) Please refer to Confidential Attachment IIPA 20-1.
(c) Please refer to Confidential Attachment IIPA 20-2.
(d) Please refer to the Company's response to subpart (c) above.
(e) Please refer to Confidential Attachment IIPA 20-3.
(0 Please refer to the Company's response to subpart (e) above.
PAC-E-21-07 / Rocky Mountain Power
August 4,2021
IIPA Data Request 20
(e) Please refer to Confidential Attachment IIPA 20-4.
(h) Please refer to Confidential Attachment IIPA 20-5.
O Please refer to Confidential Attachment IIPA 20-6.
0) The Company does not have the ability to track jurisdictional sales on an
hourly basis. Retail meters are read on a cycle count basis and hourly
interval data for retail customers is not obtained. Please refer to Attachment
lIPA20-7 which provides monthly data.
(k) Losses cannot be directly measured. Losses are calculated as the difference
between the net input to the system and the retail sales. The losses can be
calculated from the net inputs to the system and the retail/jurisdictional sales
that have been supplied in the responses to this data request. As reported in
the Company's Federal Energy Regulatory Commission (FERC) Form I for
calendar years 2018 through 2020, the calculated total energy losses
reported on page 401a line 27 werc3,484,684 megawatt-hours (MWh),
3,63 6,7 63 MWIL and 3,7 94,23 I MWlt, respectively.
0) Please refer to Confidential Attachment IIPA 20-8.
(m) Please refer to Confidential Attachment IIPA 20-9.
(n) Please refer to Confidential Attachment IIPA 20-10.
(o) Please refer to Confidential Attachment IIPA 20-tl.
(p) Please refer to Confidential Attachment IIPA 20-12.
(q) There is nothing to provide.
G) Please refer to the Company's response to subpart (q) above.
(s) Please refer to Confidential Attachment IIPA 20-13.
(t) Please refer to the Company's response to subpart (i) above.
(u) Please refer to Attachment IIPA-2O-14.
(v) Please refer to the Company's responses to subparts (a) through (u) above.
(w) The Company does not have the ability to tack jurisdictional losses on an
hourly basis. Please refer to Attachment IIPA 20-15 for the Company's
PAC-E-21-07 / Rocky Motrntain Power
August 4,2021
IIPA Data Request 20
annual line losses by jurisdiction.
(x) The Company does not have the ability to fack losses specifically
associated with wholesale sales tansactions. Please refer to the Company's
response to subpart (k) above regarding system losses.
(y) Please refer to the Confidential Attachment IIPA 20-16.
In addition to the information provided below, please refer to Attachment IIPA
20-17 which provides copies of PacifiCorp's FERC Form I for calendar years
2018 through2020.
Confidential information is provided subject to protection under IDAPA
31.01.01.067 and31.01.01.233, 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.
Recordholder:Various
Sponsor To Be Determined