20210812PAC to IIPA 21-26.pdf

ROCKY MOUNTAIN
POWER
.,,'.';:i:.:i--il
,; i ;.:. .; i :j Fll i2: I I
'1407 W North Temple, Suite 330
Salt Lake City, Utah 84116
. ,': "r t:.\!n Ll.-.",-ilLrlr
August 12,2021
Eric L. Olsen (ISB# 481l)
ECHO HAWK & OLSEN, PLLC
505 Pershing Ave., Ste. 100
P.O. Box 6119
Pocatello, Idaho 83205
[e-mail] (C)
Anthony Yankel/IPA [e-mail] (C)
ID PAC.E-21-07
IIPA Set 4 (21-26)
Please find enclosed Rocky Mountain Power's Responses to IIPA 4ft Set Data Requests 21-26.
Also provided are Attachments IIPA 2l and23.
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 [e-mail] (C)
Ronald L. Williams/PIIC ron@williamsbradburv. com
Bradley G. Mullins/PIIC [e-mail]
Adam Gardner/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/PIIC [e-mail] (W)
Ben Otto/ICL botto@idahoconservation. ors (C)
Randall C. Budge/Bayer randy@racineolson. com (C)
Thomas J. Budge/Bayer ti @racineolson.com (WXC)
Brian C. Collins/Bayer bcollins@.consultbai. com (WXC)
Maurice Brubaker/B ayer mbrubaker@consultbai. com (C )
Kevin Higgins/Bayer [e-mail] (C)
L ance Kaufrnan/B ayer lance @,ae e is insi ghj. cam (C)
James R. SmithlBayer i im. r. smith@ic loud. com (C)
Brad Purdy [e-mail] (C)
RE
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
IIPA Data Request 2l
IIPA Data Request 21
On McDougal's Exhibit 40, page 43, the total revenue figure for the Residential
Class is $78,360 (x 1,000). Column B lists total "Reconciling Adjustnents" of
$2,855(x 1,000). Please list all reconciling adjustnents separately and the dollar
value of each. If there are kWh adjusfinents that go along with these components,
please list them as well.
Response to IIPA Data Request 21
Please refer to Attachment IIPA 2 I . Tabs "3. l. 1 ", "3. 1.3 - 3 .1.4', "Table 3
Dec20" and "BW Revenues Reconciliation" contain the detailed development and
calculations of column B lists total "Reconciling Adjustnents" of $2,855(x
1,000).
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
IIPA Data Request 22
IIPA Data Request22
On McDougal's Exhibit 40, page 45 for Residential Schedule 07RESD0001 (frst
line) there is listed a "Booked" figure of $57,107,038. For each of the adjustnent
figures listed on that line for Residential Schedule 07R8SD000, please list each
component that make up the ""Reconciliating" and "Normalization" adjustment
and the dollars associated with each component. Please list each component by
month. If there are kWh adjustnents that go along with these components, please
list them as well.
Response to IIPA Data RequestZ2
Please refer to the work papers supporting the direct testimony of Company
witness, Robert M. Meredith, specifically file "ID GRC Blocking 2020.x1sx", as
well as the Company's response to IIPA Data Request2l, specifically Attachment
IIPA 21 . In Attachment IIPA 2l , tabs *3 .l .3 - 3.1 .4" and "Table 3 Dec20" contain
the detailed development and calculations of the adjusfrnents. In file "ID GRC
Blocking 2020.x1sx", tab "Table 3 Inpuf is the data sources for tab "Table 3
Dec20" in Attachment IIPA 2l and provides further detailed development and
calculations of the adjustnents.
Recordholder: James Zhang
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
ffiA DataRequest 23
trPA Deta Request 23
On McDougal's Exhibit 40, pages 45 and 46, in the first column there is list€d
alpha-nrmreric figures for specific (Schedules) within each olass" Please provide a
definition of each of these alpha-numeric figures.
Rerponse to IIPA Data Request 23
Please refer to Attachment trPA 23.
Recordholder:James Zhang
Robert MeredithSponsor:
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
IIPA Data Request 24
IIPA Data Request24
The Company's response to IIPA request 1, states for Residential 07RESD000I
that there was a temperature adjustnent that resulted in an increase in usage of
1,829,347 kWh with a revenue increase of $132,152. This equates to a rate of
7.224 cents/kWh which is far below any rate block for the Residential Class.
Please explain this discrepancy.
Response to IIPA Data Request}4
The values referenced in this request are annual temperature adjustnents that
were based on monthly temperature usage and revenue adjustrnents. Please refer
to the work papers supporting the direct testimony of Company witress, Robert
M. Meredith, specifically file "ID GRC Blocking 2020.x1sx", tab "TempREV" for
the detailed calculations.
Recordholder: James Zhatg
Sponsor:Robert Meredith
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
IIPA Data Request 25
IIPA Data Request 25
In Meredith's workpapers, Table I - year over year load and average price
change, Tab *2020", the "I-Inbilled" for the Residential Class lists 6,136,000 kWh
and $380,000. This equates to 6.193 cents/kWh which is far below any rate block
for the Residential Class. Please explain this discrepancy.
Response to IIPA Data Request 25
Unbilled revenue is the calculation of an estimated receivable for the portion of
delivered kilowatt-hours (kWh) that will not be billed before the end of the
month. The receivable is reversed the following month and a new estimated
receivable is calculated.
The "Unbilled" numbers in the work papers supporting the direct testimony of
Company witness, Robert M. Meredith, represent the difference between the
receivable calculated December 2020 andthe receivable calculated December
2019, plus the bad debt reserve estimated :.ll,2020. The average rate for the
unbilled receivable calculated December 2020 is 9.962 cents per kilowatt-hour
(cents/kWh), and December 2019 is 9.655 cents/kWh which is within the range of
the energy rates of the residential customer class.
kwh S cent/kWh
December 2020 75,727,194 S7,484,000 s 0.0995
December 20L9 8L,263,324 s7,845,000 S o.oses
Difference (5,136,130)s (362,000)
Bad Debt Reserve 2020 S (18,ooo)
(6,135,130)s (380,000)
Recordholder:James Zhang / Mike McCoy
Robert MeredithSponsor
PAC-E-21-07 / Rocky Mountain Power
August 12,2021
IIPA Data Request 26
IIPA Data Request 26
As a follow-up to the Response to IIPA Interrogatory I - l, please answer the
following:
(a) Request l-l b sought information on the meaning/definition of all of the
alphanumeric terms in the first column of pages 3.1.3d and 3.1.4 of Exhibit
40. This information was not provided. Please provide.
(b) Request l-1 d sought information regarding the "individual adjustnents that
make up the total 'Type 1' adjusfrnents found for each 'Schedule"'. What was
provided was only the names of the adjustnents. Please provide the actual
value ofeach adjustnent under each category for each Schedule listed on
pages 3.1.3d and 3.1.4 of Exhibit 40.
(c) Request l-1 e sought information regarding the difference in the data provided
by "Pricing" compared to the billed data. This information was not provided.
For each month that makes up the annual data for each schedule listed on
pages 3.1.3d and 3.1.4 of Exhibit 40, the values from pricing is requested.
Additionally, similar information is sought for the "actual" billing month data
that this was compared with this pricing data, i.e., the data that was adjusted
by "Type2"
Response to IIPA Data Request 26
(a) Please refer to Attachment IIPA 23.
(b) Please refer to the work papers supporting the direct testimony of Company
wiuress, Robert M. Meredith, specifically file "ID GRC Blocking 2020.x1sl<",
as well as the Company's response to IIPA Data Request2l, specifically
Attachment IIPA 21. In Attachment IIPA 21, tabs *3.1.3 -3.1.4" and "Table 3
Dec20" contain the detailed development and calculations of all the
adjustnents. In file "ID GRC Blocking 2020.x1sx", tab "Table 3 Input" is the
data sources for tab "Table 3 Dec20" in Attachment IIPA 2l and provides
further detailed development and calculations of all the adjustments.
(c) Please refer to the work papers supporting Mr. Meredith's direct testimony,
specifically file "ID GRC Blocking2020.xlsx", as well as Attachment IIPA
2l.lnAttachment IIPA 21, tabs "3.1.3 - 3.1.4" and "Table 3 Dec2O" contain
the detailed development and calculations of all the adjusfinents. [n file "ID
GRC Blockng2020.xlsx", tab "Table 3 Inpuf is the data sources for tab
"Table 3 Dec20" in Attachment IIPA 2l and provides further detailed
development and calculations of all the adjustments. Specifically, in file "ID
GRC Blockng2020.xlsx", tab "Table 3 Input", column O contains the annual
revenues by schedule from the billing determinants developed by Pricing,
PAC-E 1-07 / Rocky Mountain Power
August 12,2021
IIPA DataRequest 26
column C to oohrmn N contain the annual acfiral booked revenues and
normalization adjusturents. The Company has only developed the annual
billing determinants for this geneml rate oase (GRC). The monthly billing
determinants are not readily available.
Recordholder:James ZMng
Robert MercdithSponsor: