20050728Application for intervenor funding.pdf

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Eric L. Olsen, ISB No. 4811
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
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10 InJ PUBLiC
UTILITIES COHr'1ISSION
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA UTAH POWER & LIGHT
COMP ANY FOR AUTHORITY TO INCREASE
ITS RATES FOR ELECTRIC SERVICE TO
ELECTRIC CUSTOMERS IN THE STATE OF rnmo
CASE NO. PAC-O5-
APPLI CA TI 0 N FOR INTER VEN 0 R FUND IN G OF
THE IDAHO IRRIGATION PUMPERS ASSOCIA TION~ INC.
COMES NOW the Idaho Irrigation Pumpers Association, Inc. ("Irrigators ), by and through
counsel of record, Eric L. Olsen, and hereby respectfully makes application to the Idaho Public
Utilities Commission ("Commission ) for intervenor funding pursuant to Idaho Code 9 61-617 A and
IDAPA 31.01.01.161 through .165 as follows:
(A)A summary of the expenses that the Irrigators request to recover broken down into
legal fees, consultant fees and other costs and expenses is set forth in Exhibit "A" attached hereto
and incorporated by reference. Itemized statements are also included as Attachments 1 and 2 to
Exhibit "A" in support of said summary and are incorporated by reference.
(B)The Irrigators' counsel , Eric L. Olsen, and Consultant, Anthony J. Yankel, P ., fully
participated in this proceeding. Procedurally, this case began as a full blown rate case. Mr. Olsen
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 1
and Mr. Yankel were active in reviewing the filing, preparing and reviewing approximately 90 data
requests and responses, and drafting direct testimony. However, once the Irrigators and other parties
objected to the inclusion of costs associated with Monsanto Company s ("Monsanto ) special
contract in this case, PacifiCorp s focus clearly changed from continuing on with the case to a
settlement posture. Thereafter, Irrigators participated fully in the settlement discussions, were parties
to the resulting stipulation, and filed comments in support thereof with the Commission. Because
it was not known until late in the process that any party would propose settlement, and even later
before one was reached, the Irrigators still had to substantially prepare for the presentation of their
direct case before the Commission. The proposed findings or positions that the Irrigators would
have urged the Commission adopt are contained in the draft direct testimony of Mr. Yankel which
is attached hereto as Exhibit and incorporated by this reference herein.The Irrigators
independently but concurrently with staff, determined that PacifiCorp had inappropriately included
the Monsanto special contract costs in this case, and the Irrigators' obj ection was noted in the
Stipulation.
(C)The expenses and costs incurred by the Irrigators set forth in Exhibit and
accompanying attachments are reasonable in amount and were necessarily incurred in reviewing and
evaluating PacifiCorp s filing, preparing data requests and reviewing data responses, developing
direct testimony for the scheduled technical hearings, evaluating the merits of the proposed
settlement in this case, participating in the settlement discussions, and communicating with its
members regarding the same. The fact that the parties settled the case does not lessen the fact that
the Irrigators had to prepare as though the case was going to hearing.
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 2
(D)The costs described in Paragraph (A) above constitute a financial hardship for the
Irrigators. The Irrigators currently have approximately $12 392.00in the bank. Accounts payable
for legal and consultant fees and costs in this case total $38 197.40 as set out in Exhibit ", none
of which have been paid.
The Irrigators are an Idaho nonprofit corporation qualified under I.R.C. 9 501(c)(5)
representing farm interests in electric utility rate matters affecting farmers in southern and central
Idaho. The Irrigators rely solely upon dues and contributions voluntarily paid by members, together
with intervenor funding to support activities and participate in rate cases. Each year mailings are
sent to approximately 7500 Idaho Irrigators (approximately two-thirds in the Idaho Power Company
service area and one-third in the PacifiCorp service area), soliciting annual dues. The Irrigators
recommend members make a voluntary contributions based on acres irrigated or horsepower per
pump. Member contributions have been falling which are believed to be attributable to the
depressed agricultural economy and increased operating costs and threats, particularly those relating
to water right protection issues. From member contributions the Irrigators must pay all expenses
which generally include mailing expenses, meeting expenses and shared office space in Boise, Idaho
in addition to the expenses relating to participation in rate cases. The Executive Director, Lynn
Tominaga, is the only part-time paid employee, receiving a retainer plus expenses for office space
office equipment, and secretarial services. Officers and directors are elected annually and serve
without compensation.
It has been and continues to be a financial hardship for the Irrigators to fully participate in
all rate matters affecting its members. As a result of financial constraints, participation in past rate
cases and in this case has been selective and, primarily, on a limited basis.
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 3
(E)Where the case is settled before direct testimony has been filed or a complete record
otherwise being established, it may not be apparent how the Irrigators' positions would materially
differ from the Commission Staff s positions. However, as shown in Mr. Yankel' s draft testimony
(Exhibit "), the Irrigators pointed out (1) that PacifiCorp was not including known and measurable
adjustments in its filing with respect to the actual irrigation curtailment, (2) that there other ways of
modeling how the curtailment credit can be derived based on straight forward cost of service
principles and how the credit should be treated on a system or situs basis, (3) that there are problems
with PacifiCorp s load research data from a quality prospective and from taking into account the
curtailment that the Irrigators are providing under the load control program, and (4) that there were
problems with allocation of costs associated with PacifiCorp s substations and primary distribution
lines. Based on the foregoing and its discussions with Commission Staff during the case, the
Irrigators believe that these issues were not going to be directly addressed by Commission Staff in
this case. Thus, the Irrigators 'positions and recommendations did materially differ from those
which the Irrigators believed that the Commission Staff were going to focus on, notwithstanding the
fact that the vast majority of all parties ' positions converged with the ultimate negotiation and
presentation of the Stipulation.
(F)The Irrigators' participation addressed issues of concern to the general body of users
or consumers on PacifiCorp s system. It has been approximately two decades since there as been
a full blown rate case. Although there were interruptible rates for the Irrigators at the time of the last
rate case, there was not any consistent, annual curtailment of the Irrigators until implementation
the current load control program in 2003. This case gave the Irrigators the chance to analyze the
effects of actual curtailment in the context of what it accomplished for the jurisdiction as a whole
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 4
and for the Irrigators specifically. The curtailment of the Irrigators reduces the summer coincident
peak for the system and the Idaho jurisdiction, as well as for the irrigation class. A reduction of this
summer peak not only benefits the Irrigators as a class by reducing its demand, but it also reduces
the Idaho system demand and the resulting system costs that are allocated to all PacifiCorp s Idaho
tariff customers. Continuation and expansion of the irrigation load control program may also defer
the building of additional generation plant as indicated in PacifiCorp s 2004 Integrated resource
plan. Avoiding these type of costs is also a benefit to all PacifiCorp s Idaho tariff customers.
(G)The Irrigators represent the irrigation class of customers under Schedule 10.
Based on the foregoing, it is respectfully submitted that the Irrigators are a qualifying
intervenor and should be entitled to an award of costs of intervention in the amount of$38 197.40
pursuant to Idaho Code 9 61-617A and IDAP A 31.01.01.161 through .165.
DATED this 27th day of July, 2005.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
~9~
ERIC L. OLSEN
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC. - 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 27th day of July, 2005, I served a true, correct and
complete copy of the Idaho Irrigation Pumpers Association, Inc.s Application for Intervenor
Funding to each of the following, via U.S. Mail or private courier, e-mail or hand delivery:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
E-mail: ; ean. i ewell ~puc.idaho. gov
UPS Next Day Letter
Jeff Larsen
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84111
S. Mail
James M. Van Nostrand
Stoel Rives LLP
900 SW Fifth Avenue, Suite 2600
Portland, OR 97204
S. Mail
Scott Woodbury
Kira Phisterer
Idaho Public Utilities Commission
O. Box 83720
Boise, ID 83720-0074
E-mail: scottwoodbury~puc.idaho.gov
krapfisterer~puc. idaho. gov
S. Mail
James R. Smith
Monsanto Company
O. Box 816
Soda Springs , ID 83276
S. Mail
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
O. Box 1391
Pocatello, ID 83204
Hand delivered
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 6
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony0),yankel.net
S. Mail
Conley E. Ward
Givens Pursley LLP
601 W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
S. Mail
J .R. Simplot Company
Att: David Hawk & R. Scott Pasley
999 Main Street, Suite 1300
O. Box 27
Boise, ID 83707-0027
S. Mail
Timothy J. Schurtz
411 S. Main
Firth, ID 83236
S. Mail
Brad M. Purdy
Attorney at Law
2019N.17th St.
Boise, ID 83702
S. Mail
Idaho Irrigation Pumpers Association, Inc.
c/o Lynn T ominaga
O. Box 2624
Boise, ID 83701-2624
S. Mail
APPLICATION FOR INTERVENOR FUNDING OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INc. - 7
EXHIBIT A
SUMMARY OF EXPENSES INCURRED BY IRRIGATORS
IN CASE NO. P AC-O5-
Legal Fees:
Eric L. Olsen: 70.9 hours at $175 =
Costs:
Long distance/Postage:
Travel:
Total Work and Costs:
Consultant Anthony J. Yankel:
193 hours at $125 per hour
Expenses:
Travel, room and meals
Total Work and Costs:
TOT AL FEES AND EXPENSES:
$13 860.
212.40
$14 072.40
$24 125.
$24 125.
$38 197.40
Exhibit A
Attachment
710.1518527 IDAHO IRRIGATION PUMPERS ASSOCIATION INC.
DATE RATE HOURS AMOUNT DESCRIPTION
1/12/2005 175 52.TELEPHONE CONFERENCE WITH BOB LIVELY RE: FILING
OF RATE CASE BY PACIFICORP AND OVERVIEW OF SAME
1/13/2005 175 87.TELEPHONE CONFERENCE WITH TONY YANKEL RE:
PACIFICORP'S RATE CASE FILING
1/21/2005 175 REVIEW PETITION FOR LEAVE TO INTERVENE AND
EXECUTE SAME AND COVER LETTER
1/27/2005 175 262.TELEPHONE CONFERENCE WITH RANDY LOBB RE:
MEETING; TELEPHONE CONFERENCE WITH TONY
YANKEL RE: ISSUE IN THE PACIFICORP RATE CASE; CALL
AND LEAVE MESSAGE WITH BOB LIVELY RE: GETTING
COpy OF FILING TO YANKEL; TELEPHONE CONFERENCEW
WITH LYNN TOMINOGA RE: RATE CASE
1/28/2005 175 52.TELEPHONE CONFERENCE WITH TONYYANKEL RE:
ISSUES TO BE RAISED IN RATE CASE AND PRELIMINARY
ISSUES
1/31/2005 175 315 REVIEW SUMMARY OF RATE CASE; CONFERENCE WITH
RANDY LOBB OF PUC RE; PACIFICORP RATE CASE
2/4/2005 175 140 TELEPHONE CONFERENCE WITH SCOTT WOODBURY AT
PUC RE: PACIFICORP HEARING;
TELEPHONE CONFERENCE WITH TONY
YANKEL RE: PARTICIPATING VIA CONFERENCE CALL;
CALL AND LEAVE MESSAGE WITH BOB LIVELY RE: SAME
2/6/2005 175 262.REVIEW PACIFICORP RATE CASE TESTIMONY IN
PREPARATION FOR MEETING
2/7/2005 175 525 TRAVEL TO BOISE
2/7/2005 175 490 ATTEND PACIFICORP PRESENTATION ON RATE CASE
2/22/2005 175 87.REVIEW DATA REQUESTS AND SEE THAT SAME GET
PREPARED FOR SERVICE UPON PACIFICORP
3/11/2005 175 FINALIZE DATA REQUESTS AND SEE THAT SAME ARE
SENT OUT
3/15/2005 175 0.4 REVIEW COMMISSION ORDERS RE: PARTIES AND
DISCOVERY REQUEST OF AGRIUM; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: GETTING COPIES
OF DATA REQUESTS
3/18/2005 175 87.REVIEW SCHEDULING ORDER AND CALENDAR
DEADLINES FOR HEARING
4/6/2005 175 87.TELEPHONE CONFERENCE WITH TONYYANKEL RE:
REVIEWING DATA REQUESTS AND NEEDING TO FOLLOW
UP ON QUESTIONS AND PRESENTING BASES FOR
INCREASING PAYMENT FOR AMOUNT OF CREDIT FOR
CURTAILMENT
4/11/2005 175 MAIL TONYYANKEL RE: SUPPLEMENTAL DATA
REQUESTS
4/22/2005 175 REVIEW LETTER FROM PACIFICORP; CALL AND LEAVE
MESSAGE WITH TONY YANKEL RE: 4TH DATA REQUEST
4/22/2005 175 735 REVIEW PAST FILING MATERIALS ON DEVELOPMENT OF
LOAD CONTROL PROGRAM; REVIEW PAST PUC ORDERS
RE: USE OF DEMAND SIDE RESOURCES; TELEPHONE
CONFERENCE WITH TONY YANKEL RE: DEVELOPING
DATA REQUESTS RE: SAME
4/25/2005 175 122,GATHER MATERIALS FOR DATA REQUESTS ON LOAD
CONTROL CREDIT; TELEPHONE CONFERENCE WITH
TONY Y ANKEL RE: ITEMS THAT ARE STILL OPEN ON
DATA REQUEST; GATHER INFORMATION FROM PRIOR
FILINGS ON LOAD CONTROL CREDIT; DICTATE LETTER
TO BOB LIVELY RE: 4TH DATA REQUEST
5/3/2005 175 157.CONTINUED REVIEW OF LOAD CONTROL FILES FOR
PREPARING DATE REQUESTS
5/5/2005 175 787.REVIEW LOAD CONTROL CREDIT PAST FILINGS IN
PREPARING DATA REQUESTS; REVIEW PACIFICORP'
IRP AND TREATMENT OF INTERRUPTIBILITY OF DSM
RESOURCES
5/6/2005 175 122.REVIEW DATA REQUESTS FROM TONY YANKEL AND
PREPARE DISCOVERY REQUESTS
5/9/2005 175 52,REVIEW E-MAIL FROM Y ANKEL RE: STAFF DATA
REQUEST 55 AND GETTING COpy OF FILE; TELEPHONE
CONFERENCE WITH BARRY BELL AT PACIFICORP RE:
SAME
5/9/2005 175 367.CONTINUED REVIEW OF PACIFICORP'S IRP; DRAFT DATA
REQUESTS
5/1 0/2005 175 525 CONTINUED DRAFTING OF DATA REQUESTS
5/11/2005 175 752.CONTINUED DRAFTING OF DATA REQUESTS AND SEE
THAT SAME ARE SENT OUT; REVIEW CONFIDENTIALITY
AGREEMENT AND REVISE AND E-MAIL TO YANKEL FOR
SIGNING; E-MAIL DISCOVERY REQUESTS TO TONY
Y ANKEL
5/12/2005 175 1,4 245 EXECUTE CONFIDENTIALITY AGREEMENT AND SEE THAT
SAME IS FAXED TO PACIFICORP AND LEGAL COUNSEL;
TELEPHONE CONFERENCE WITH TONY Y ANKEL RE:
STATUS OF CASE AND REVIEW OF ISSUES TO BE RAISED
IN RATE CASE; SEND OUT ADDITIONAL DISCOVERY
REQUESTS
5/13/2005 175 280 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
REVIEW OF CONFIDENTIAL DISCOVERY REQUESTS AND
RESPONSES TO STAFF DISCOVERY THAT HE HAD NOT
RECEIVED; SEE ABOUT GETTING ADDITIONAL COpy OF
FILES; SEE THAT MISSING STAFF DATA REQUEST
RESPONSES ARE SENT TO TONY YANKEL; TELEPHONE
CONFERENCE WITH YANKEL RE: SETTLEMENT
CONFERENCE IN PACIFICORP RATE CASE; TELEPHONE
CONFERENCE WITH DAVE SCHUNKE RE: PACIFICORP
RATE CASE; TELEPHONE CONFERENCE WITH BARB
BARROWS RE: CALL IN NUMBER FOR SETTLEMENT
CONFERENCE
5/16/2005 175 REVIEW INFORMATION FOR SETTLEMENT CONFERENCE
AND E-MAIL YANKEL RE: SAME AND RECEIPT OF
CONFIDENTIAL DATA REQUESTS
5/16/2005 175 4,4 770 PREPARE FOR SETTLEMENT CONFERENCE;
PARTICIPATE IN SETTLEMENT CONFERENCE;
CONTINUED PARTICIPATION IN PACIFICORP
SETTLEMENT CONFERENCE; TELEPHONE CONFERENCE
WITH TONY Y ANKEL RE: OUTCOME OF SAME
5/25/2005 175 87.MULTIPLE TELEPHONE CONFERENCE WITH BOB LIVELY
RE: MEETING TO REVIEW PROPOSED STIPULATION;
TELEPHONE CONFERENCE WITH TONY YANKEL RE:
SAME
5/25/2005 175 297.LUNCH AND CONFERENCE WITH MARK MICKELSEN AND
BOB LIVELY RE: PROPOSED SETTLEMENT OF IDAHO
RATE CASE
5/25/2005 175 210 CONFERENCE WITH PARTIES RE: PACIFICORP SETTLEMENT
OFFER; TELEPHONE CONFERENCE WITH TONYYANKEL
RE: SAME
5/31/2005 175 192.CALL AND LEAVE MESSAGE WITH TONY YANKEL, BOB
LIVELY AND RANDY LOBB; TELEPHONE CONFERENCE
WITH TONY YANKEL RE: PACIFICORP PROPOSAL FOR
SETTLEMENT AND TIMING OF TESTIMONY FOR RATE
CASE; TELEPHONE CONFERENCE WITH BOB LIVELY RE:
PROPOSED SETTLEMENT OF RATE CASE AND
APPROACHING THE IRRIGATOR INTERRUPTIBILITY
CREDIT
6/1/2005 175 1,4 245 TELEPHONE CONFERENCE WITH RANDY LOBB RE:
TERMS OF PACIFICORP'S SETTLEMENT OFFER;
TELEPHONE CONFERENCE WITH TONY Y ANKEL RE:
CURRENT SETTLEMENT OFFER FOR PACIFICORP AND
DIRECTION OF HIS TESTIMONY; CALL AND LEAVE
MESSAGE WITH CONLEY WARD; TELEPHONE
CONFERENCE WITH RANDY LOBB RE: CURRENT STATUS OF
PACIFICORP SETTLEMENT NEGOTIATIONS; TELEPHONE
CONFERENCE WITH MARK MICKELSON RE: SAME
6/2/2005 175 665 TELEPHONE CONFERENCE WITH TONY YANKEL RE:
SETTLEMENT NUMBERS OFFERED BY PACIFICORP AND HIS
CONVERSATION WITH STAFF; TELEPHONE CONFERENCE
WITH RANDY LOBB RE: SETTLEMENT AND RISKS AND
BENEFITS AND SETTING UP CONFERENCE CALL; CALL
AND LEAVE MESSAGE WITH CONLEY WARD; ARRANGE
CONFERENCE CALL WITH ALL INTERVENORS;
CONFERENCE WITH MARK MICKELSON RE: SAME
6/3/2005 175 472.5 TELEPHONE CONFERENCE WITH TONY Y ANKEL RE:
REVENUE ADJUSTMENTS TO ASSERT IN RATE CASE;
PREPARE FOR CONFERENCE CALL WITH COMMISSION STAFF
AND OTHER INTERVENERS RE: MERITS OF PACIFICORP
SETTLEMENT; TELEPHONE CONFERENCE WITH MARK
MICKELSON RE: OUTCOME OF PACIFICORP MEETING
WITH IRRIGATORS
6/6/2005 175 262.TELEPHONE CONFERENCE WITH MARK MICKELSON RE:
STANCE ON SETTLING RATE CASE WITH PACIFICORP;
TELEPHONE CONFERENCE WITH SCOTT WOODBURY RE:
STATUS OF SETTLEMENT NEGOTIATIONS AND
CIRCULATION OF STIPULATION; CONFERENCE WITH RCB
RE: SAME
6/8/2005 175 3.4 595 REVIEW PROPOSED SETTLEMENT STIPULATION; REVIEW
STIPULATION AND CALL AND LEAVE MESSAGE WITH
TONY YANKEL RE: SAME; TELEPHONE CONFERENCE
WITH RANDY LOBB RE: LANGUAGE DEALING WITH RMA
TELEPHONE CONFERENCE WITH BOB LIVELY RE: SAME
AND LANGUAGE RE: LOAD CONTROL CREDIT; REVIEW
STIPULATION AND ORDER IN PAC-02-1 CASE AND
DRAFT EMAIL TO PARTIES RE: SAME; TELEPHONE
CONFERENCE WITH YANKEL RE: STIPULATION AND
AFFECT OF PRIOR RMA LANGUAGE
6/9/2005 175 437.REVIEW SUGGESTED CHANGES TO STIPULATION FROM
YANKEL; CONFERENCE WITH BOB LIVELY RE: WANTING
IIPA TO SIGN AND DISCUSS CHANGES; REVIEW
CHANGES TO STIPULATION AND CONFERENCE WITH
BOB LIVELY AND SIGN STIPULATION
6/14/2005 175 17.TELEPHONE CONFERENCE WITH SCOTT WOODBURY RE:
TESTIMONY DEADLINE, ETC.
6/17/2005 175 227.TELEPHONE CONFERENCE WITH TONY YANKEL RE:
STATUS OF PACIFICORP'S SETTLEMENT; REVIEW
STIPULATION AND OUTLINE COMMENTS IN SUPPORT OF
STIPULATION
6/28/2005 175 0.4 REVIEW DRAFT OF TESTIMONY FROM YANKEL; OUTLINE
COMMENTS IN SUPPORT OF STIPULATION
7/1/2005 175 647.CONTINUED DRAFTING OF COMMENTS IN SUPPORT OF
STIPULATION AND SEE THAT SAME ARE FILED
7/5/2005 175 52.REVIEW TESTIMONY FILED BY OTHER SIGNATORIES OF
STIPULATION AND ORGANIZE FILE
7/25/2005 175 140 REVIEW COMMISION FINAL ORDER; CALL AND LEAVE MESSAGE
WITH S, WOODBURY; TCW S. WOODBURY RE: TIMING FOR FILING
INTERVENOR FUNDING REQUEST; CALL AN LEAVE MESSAGE
YANKEL RE: INFORMATION
7/26/2005 175 787.DRAFT APPLICATION FOR INTERVENOR FUNDING; TCW
YANKEL RE: SAME
7/27/2005 175 525 FINALIZE INTERVENOR FUNDING REQUEST AND SEE THAT SAME
IS FILED
TOTALS 79.13860
710.1518517 IDAHO IRRIGATION PUMPERS ASSOCIATION
DATE AMOUNT DESCRIPTION
1/31/2005 LONG OIST ANCE TELEPHONE
1/31/2005 LONG OIST ANCE TELEPHONE
2/28/2005 LONG OIST ANCE TELEPHONE
4/30/2005 LONG OIST ANCE TELEPHONE
5/13/2005 LONG OIST ANCE TELEPHONE
5/16/2005 44.LONG OIST ANCE TELEPHONE
5/26/2005 60.POSTAGE
5/31/2005 29.4 CLIENT LUNCH - ELO
5/31 /2005 18.48 LONG OIST ANCE TELEPHONE
6/1/2005 LONG 018T ANCE TELEPHONE
6/6/2005 POSTAGE
6/30/2005 26.46 LONG 018T ANCE TELEPHONE
TOTAL 212.4
Exhibit A
Attachment 2
Date
Jan
Feb.
Mar
Apr
OCJ0.0
(,)(,)
Description
3 Make an initial review ofPacifiCorp s filing in order to determine the overall
impact on irrigators.
Prepare for and attend via phone a workshop regarding an initial review of the
Company s rate filing in Idaho.
Review company s filing regarding Taylor s testimony, cost of service exhibits
and the implementation of MSP.
Review relationship between cost of service and interruptibilty of Monsanto.
Review cost of service study and interruptibility; develop interrogatories.
Review cost of service study and interruptibility; develop interrogatories.
Review Company filing and staff data requests; review loss study in Utah;
compare Utah rates and cost of service for Generation with that in the
Company s filing for Idaho.
Review Company filing and staff data requests; compare Utah rates and cost of
service for Generation with that in the Company s filing for Idaho; develop
data requests.
Review Company filing and staff data requests; compare Utah rates and cost of
service for Generation with that in the Company s filing for Idaho; develop
data requests.
Review net power cost calculation in this case and associated data from the
Utah case; develop data requests.
Review filing and develop production requests regarding cost of service and
the cost of production and purchase of energy.
Develop additional data requests regarding historical usage and the Company
revenue numbers.
Review data responses from the Company; prepare for and attend
teleconference between various interveners.
Review data responses regarding development of cost of service study data and
the treatment of interruptible load.
Date
rJ)
01)
:::.....---(,.).....(,.)
C\!
A.;Description
Reviewing data responses; writing supplemental questions regarding
coincident demand data and energy data by class and by jurisdiction.
Reviewing data responses; writing supplemental questions regarding treatment
of Monsanto and irrigation interruptibility.
Reviewing data responses; writing supplemental questions regarding short-
term firm and balancing transactions.
Manipulate hourly wholesale STF and economy sales and purchases in order to
summarize the data into a workable level.
Develop data and then compare actual and modeled STF and economy sales
and purchases of wholesale power.
Review present data and data from Case UPL-90-1 re: distr. costs.
Cont. rev. of present data and data from Case UPL- E-90-1 re: distr. costs.
Review distribution data from this and other cases and develop data requests.
Review load research data and jurisdictional load data in order to get numbers
to match or to see where the holes are.
Review data regarding load research; talk with Taylor, Anderson, Davis of
PacifiCorp as well as Hessing of the Staff; continue to work through load
research data to define how raw data is used and why discrepancies exist.
Review data responses associated with load research data; try to coordinate
additional information provided in order to make data fit what was provided in
the company s filing.
Review data responses associated with irrigation load research data; attempt to
match data with that used by the company; send memo to the company;
conversation with Olsen regarding direction of case and need for data.
Perform calculations to check the validity of the coincident peak data used for
the Irrigation customers; consolidate problem and email company regarding
Review data regarding overall revenue requirement; summarize positions;
conference call with various parties regarding same.
Date
June
Total
r:n
OL)
I=:
.....(,)
1.+::
.....(,)
Description
Reviewing load research data and the Company s second set of correction with
respect to the Irrigator coincident and distribution peak data.
Review load research data to check the Company s values for non-coincident
peaks; review how irrigation load management data is carried into the
jurisdictional cost of service study.
Continue to draft testimony regarding treatment of the rate for interruptions;
develop testimony regarding load research problems.
Conversation with Carlock regarding my revenue adjustment; conversations
with Olsen regarding settlement; develop data regarding impact on peak usage
of removing load during irrigation curtailment periods.
Discussion with Olsen and various parties regarding the possibility of
Review data responses that came in to determine their value in the future;
review and comment on latest draft of stipulation.
Draft comments to be used in Brief regarding settlement.
193
Exhibit B
-~~~~ ~
PLEASE STATE YOUR NAME, ADDRESS, AND EMPLOYMENT.
I am Anthony J. Yankel. I am President ofYankel and Associates, Inc. My
address is 29814 Lake Road, Bay Village, Ohio, 44140.
WOULD YOU BRIEFLY DESCRIBE YOUR EDUCATIONAL
BACKGROUND AND PROFESSIONAL EXPERIENCE?
I received a Bachelor of Science Degree in Electrical Engineering from Carnegie
Institute of Technology in 1969 and a Master of Science Degree in Chemical Engineering from
the University of Idaho in 1972. From 1969 through 1972, I was employed by the Air
Correction Division of Universal Oil Products as a product design engineer. My chief
responsibilities were in the areas of design, start-up, and repair of new and existing product lines
for coal-fired power plants. From 1973 through 1977, I was employed by the Bureau of Air
Quality for the Idaho Department of Health & Welfare, Division of Environment. As Chief
Engineer of the Bureau, my responsibilities covered a wide range of investigative functions.
From 1978 through June 1979, I was employed as the Director of the Idaho Electrical Consumers
Office. In that capacity, I was responsible for all organizational and technical aspects of
advocating a variety of positions before various governmental bodies that represented the
interests of the consumers in the State of Idaho. From July 1979 through October 1980, I was a
partner in the firm of Yanke 1, Eddy, and Associates. Since that time, I have been in business for
myself. I am a registered Professional Engineer in the states of Ohio and Idaho. I have
presented testimony before the Federal Energy Regulatory Commission (FERC), as well as the
Yankel, D I
Irrigators
-~-~~ ~
State Public Utility Commissions of Idaho , Montana, Ohio, Pennsylvania, Utah, and West
Virginia.
ON WHOSE BEHALF ARE YOU TESTIFYING?
I am testifying on behalf of the Idaho Irrigation Pumpers Association (IIP A).
WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING?
Yankel, D I
Irrigators
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KNOWN AND MEASURABLE ADJUSTMENTS
DOES THE COMPANY'S FILING TAKE INTO ACCOUNT ALL KNOWN
AND MEASURABLE ADJUSTMENTS?
No. The Company has included adjustments in its filing for known
and measurable changes that will occur "before this requested rate change is effective
Although the Company s filing addresses many known and measurable changes, it
ignores one known and measurable change that is significant to Idaho. As stated in Mr.
Stewart's testimony:
The purpose of known and measurable adjustments is to match as closely
as possible the changes in rates with related costs being incurred to serve
Idaho customers.
Mr. Stewart's testimony talks about the implementation of an Irrigation Load Control
Program in 2003 , the growth of that program in 2004, and the anticipation (as of the date of the
filing) of additional growth in that program for 2005. In spite of the known growth in this
program between 2003 and 2004, and in spite of the fact that the 2005 curtailment levels will be
history by the time a rate change from this case will go into effect, the Company s filing only
used the curtailment levels from 2003-the first year of this program.
HOW MUCH ADDITIONAL IRRIGATION CURTAILMENT HAS
OCCURRED SINCE THIS PROGRAM WAS IMPLEMENTED IN 2003?
Direct testimony of Weston, page 121ines 9-11.
Yankel, DI
Irrigators
---~~ ~
According to Mr. Stewart's testimony, the program curtailed in excess of20 Mw
per day in 2003 and in excess of 30 Mw per day in 2004. During 2005 , the curtailment of
irrigation load was - Mw2 per day or Mw more than in 2003.
The curtailment program in 2003 occurred on Monday through Thursday. Likewise the
summer system peaks during June through September 2003 only occurred during these days as
well (which is typical of the summer coincident peak). Thus, during each of the June-September
coincident peaks in 2003 , it can be assumed that approximately 20 Mw of curtailment took place
in the Idaho jurisdictional and that this reduction is reflected in the Company s filing and
interjurisdictional allocation process. However, a more appropriate figure to use would be
Mw as reflected by the level of curtailment in 2005 , which is known and measurable. The Idaho
jurisdiction should be allocated costs based upon the additional curtailment of - Mw for these
four months in the Company s filing, which is the difference between the 2003 level of
curtailment and the 2005 level of curtailment.
WHAT IS THE SPECIFIC DIFFERENCE IN THE LEVEL OF
CURTAILMENT BETWEEN 2003 AND 2005?
The specific level of curtailment varies each day because there are different
customers signed up to be curtailed each day and some are not active in some months. The
Company provided the following with respect to the Mw s of curtailments that occurred in 2003:
July
23.
21.8
22.
20.
21.0
18.
Mon/Wed.
Tue/Thurs.
June
20.
19.
2 Company Response it Request lIP A
Yankel, D I
Irrigators
-~-~~ ~
If one takes a simple average of these numbers, the average curtailment comes out to be
21 Mw. The following figures were provided by the Company for the curtailment of Irrigation
load scheduled for 2005:
July
1.8
21.0
18.
Mon/W ed.
Tue/Thurs.
June
If one takes a simple average of these numbers, the average curtailment is Mw. The
average increase in Mw s of curtailment is Mw.
ARE THESE LEVELS OF CURTAILMENT ACTUALLY REFLECTED IN
REDUCTIONS IN LOAD AT THE TIME OF THE SYSTEM PEAKS?
During the test year, the Company had load research meters on only three of the
403 meter sites where curtailment was employed. Thus, one can only make very limited
conclusions. All three of these load-metered pumps were subject to curtailment during the June
and July 2003 coincident peaks. During each of the coincident peaks in August and September
2003 , one of these three pumps was not operating, and thus, the load that could have been subject
to curtailment from these pumps was zero. The simple conclusion that can be drawn from this
limited data is that all of the pumps were 83% (10 out of 12) available for curtailment during the
summer coincident peaks.
HOW DOES THIS AVAILABILITY TO CURTAIL IMP ACT THE LOADS
THAT SHOULD BE ASSIGNED TO THE IDAHO JURISDICTION IN THE TEST YEAR?
Yankel, D I
Irrigators
--~-- -
As pointed out above, there was on average - MW of additional curtailment
that occurred this year over that which occurred during 2003-the first year of the Irrigation
Load Control program. As a known and measurable change, the Idaho Jurisdictional load (as
well as the System load) should be reduced by 83% of the additional curtailment that is presently
taking place. A precise calculation of the change in each monthly load is detailed in Exhibit A.
recommend that these known and measurable adjustments be included in the calculation of the
Company s revenue requirement in this case.
SHOULD A SIMILAR ADJUSTMENT BE MADE WITH RESPECT TO THE
IRRIGATION CONTRIBUTION TO COINCIDENT PEAK DATA THAT IS CONTAINED IN
THE COMPANY'S CLASS COST OF SERVICE STUDY?
With respect to the additional curtailment that is taking place compared to 2003
levels, the answer is yes. This is additional reductions in the Irrigation contribution to coincident
peak load that is not shown in the Company s class cost of service study.
I will address later in my testimony the need to make additional adjustments to the 2003
level of Irrigation curtailment reflected in the Company s cost of service study. This additional
adjustment is required because the Company s load research data of only three curtailable
customers grossly underestimated the level of curtailment that took place.
Yankel, D I
Irrigators
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DERIVATION OF IRRIGATION CURTAILMENT CREDIT
IS THE IRRIGATION CURTAILMENT CREDIT SET AT A PROPER LEVEL?
No. The credit given to Irrigation customers is far below the benefit that is
provided to the system and even to the jurisdiction. For example, the credits presently given for
Irrigators that are curtailed 2-days per week for 6-hours per day ranges from $2.62 to $2.82 per
kW of billing demand for June-August and $0.68 per kW for September. According to Mr.
Stewart's testimony , during the 2003 test year paid a total of$277 585 in curtailment credits to
Irrigators. This credit is merely 7-tenths of one percent of the $39 709 324 test year Irrigation
revenues listed on Company Exhibit 29 page 5.
There are two very important reasons for setting a curtailment credit for the Irrigators (or
any other group or customer) at an appropriate level. First, it is important to be fair to the
customer receiving the credit-a credit too high will over-reward the customer, while a credit too
low will under-reward the customer s efforts. Second, from the perspective of the other
customers, no one wants to pay a larger credit than the benefit received, however, no one wants
to pay too little with the resulting lower participation and lower system benefit.
HAS THE COMMISSION PREVIOUSLY REVIEWED THESE CREDITS FOR
THOSE IRRIGATION CUSTOMERS THAT HAVE PARTICIPATED IN THE IRRIGATION
LOAD CURTAILMENT PROGRAM?
3 Stewart's Direct testimony at page 8 lines 10-14.
Yankel, D I
Irrigators
-~-~~ -
No. This is the first opportunity the Commission has had to review these rates in
the context of a full rate case, as opposed to the simple establishment of what has, up until this
time, amounted to little more than a pilot program that began just two years ago.
HAS THE IRRIGATION CURTAILMENT PROGRAM BEEN GROWING
UNDER THE PRESENT CREDITS THAT HAVE BEEN OFFERED BY THE COMPANY?
Yes, it has. When the program first started in 2003 , the program had a little over
20 Mw of daily curtailment. In 2005 it has grown to approximately - Mw of daily
curtailment.
IS THERE A SIMPLE AND DIRECT WAY TO CALCULATE A MINIMUM
CREDIT THAT SHOULD BE GIVEN TO IRRIGATION CUSTOMERS FOR THE
CURTAILMENT OPPORTUNITIES THEY PROVIDE?
Yes there is. By allowing their load to be curtailed during the summer peak
hours, Irrigators are saving the system costs at the margin. An appropriate credit would be to
reflect these marginal cost savings. However, a minimum reduction in the customer s bill should
be the average cost if serving these customers. I will address only this minimal rate reduction
based upon average, embedded cost savings.
The simplest way to estimate the average, embedded cost savings of such a program is to
assume that all of the Irrigation load is subject to curtailment and that no other changes occur
4 Assume the same customer count, energy usage, nonOcoincident demand, distribution costs, etc.
Yankel, DI
Irrigators
--~-- -
This sets a simple framework by which to follow how costs are allocated through the Company
existing cost-of-service study, without making speculative assumptions regarding costs, level of
curtailment, load factors, etc. Based upon the Company s filed cost-of-service study and
associated data, the simple questions to be answered is: On an average, embedded cost basis
how much cost savings is there, if the only change in costs and billing determinants is that the
summer system coincident peak demands is reduced by full Irrigation participation?
IS IT REASONABLE TO ASSUME THAT THE IRRIGATION
CURTAILMENTS WILL CAPTURE THE TIME OF ALL OF THE SUMMER SYSTEM
PEAKS?
Very reasonable estimates/assumptions can be made with respect to the ability of
these curtailments to capture the time of the present summer peak. The Option where Irrigators
are interrupted on four separate days (Monday-Thursday) for three hours each day is a good
example. A look at the pattern of summer peak loads demonstrates how well this Option will
capture the time and days of the summer peaks. The following table lists the days of the week
when these peaks have occurred in the past:
Table 1
1999 2000 2001 2002 2003
June
July
Aug.
Sept.
Yankel, D I
Irrigators
-~-~~ ~
As can be seen from the above, the summer peaks have only been occurring during the four days
Monday-Thursday. Presumably, this is why the Company set up this program in order to
address these four specific days and not a 5-day week.
A look at the hours when the summer peaks occurred also gives a good indication of how
precise the Company s program has been geared to curtail Irrigation load at the hour of the
summer peaks:
Table 2
June
July
Aug.
Sept.
1999 2000 2001 2002 2003
With the exception of August 2001 , all of these summer peaks fell within a 3-hour time slot that
would be covered by the 4-days per week, three hours per day Option. This equates to 93 %
(14/15) of the time that this Option would result in a reduction in the summer coincident peak.
With the 6-hours per day, two days per week option, the Company spaces the customer
out on different days (Monday-Wednesday or Tuesday-Thursday) such that it covers each of
these four days with 6-hours of curtailment. This will result in an assumed 100% capture of the
day and hour of the peak, but only 500/0 of the load would be curtailed at those times.
PLEASE PROVIDE MORE DETAIL REGARDING HOW THESE
SIMPLIFYING ASSUMPTIONS CAN BE INCORPORATED INTO THE COMPANY'
COST OF SERVICE STUDY IN ORDER TO DEVELOP A MINIMUM RATE REDUCTION
FOR IRRIGATION CUSTOMERS THAT JOIN THE CURTAILMENT PROGRAM.
Yankel, DI
Irrigators
----- -
By making separate runs of the Company s cost of service program and by
assuming that there is full participation in each Option under review, it is possible to quantify the
impact of each Option in isolation. Thus, a minimum rate reduction can be established for each
Option under consideration. Each Option is different and provides a different level of impact
upon the system. By doing a cost of service run assuming that each Option is fully in place, it is
possible to quantify the average embedded cost impact of each Option upon the cost of service
that would be allocated to the Irrigators. This is not the full marginal cost benefit of the Option
to the system, but it does reflect what the impact would be if the benefits of a given Option were
flowed back to the customers on that Option.
WHAT ASSUMPTIONS WILL YOU USE IN THE COMPANY'S COST OF
SERVICE STUDY TO REFLECT THE IMPACT OF IRRIGATION CUSTOMERS THAT
ARE ON THE 6-HOUR PER DAY, 2-DA Y PER WEEK OPTION?
As demonstrated in the Tables 1 and 2 above, the 6-hour per day, 2-day a week
Option captures the days of the week of the summer system peaks as well as all of the hours in
which these peaks occur. Because only half of the customers on this Option are curtailed on any
given day, it can be assumed that if all Irrigation customers were on this Option that the
contribution to system peak for the Irrigators would be 50% of what is presently listed in the
Company s cost of service study. In order to calculate the impact upon cost of service of this
Option, it is necessary to cut in half the coincident peak demand in the Company s model ~or the
Irrigators during the 4-summer months (and change no other billing determinants or input data).
Yankel, DI
Irrigators
----- -
WHAT IS THE IMPACT THAT THE COMPANY'S COST OF SERVICE
STUDY CALCULATES UNDER THE ASSUMPTION THAT ALL IRRIGATORS WOULD
BE OPERATING UNDER THE 6-HOUR PER DAY, 2-DA Y PER WEEK OPTION?
Under the 6-hour per day, 2-day per week curtailment Option the Irrigators would
reduce their contribution to the summer system peaks by 50% in the Company s cost of service
study. A summary of the results of a cost of service run that only reduced Irrigation load by 50%
in the 4-summer months is contained on Exhibit C, Page 1. Page 2 of that exhibit contains a
copy of the similar pageS filed by the Company in this case, but without any additional
curtailment on the part of Irrigators. For the Irrigators, the Company s cost of service study
demonstrates the following impact on the Irrigation customers:
$46 090 820 Irrigation COS as filed by the Company
.$.11.090.679 COS with Irrigation summer peaks reduced by 500/0
$ 5 000 141 Impact on COS of2-day per week curtailment
Basically, the Company s embedded cost of service study confirms that a reduction in
contribution to summer peaks from this program equates to a 10.80/0 reduction6 in cost of service
for these customers. If only 25% of the Irrigation customers signed up for such a program, the
benefit would be 25% on a jurisdictional and system basis, but the reduction in cost of service for
the 25% group of custolners would still be the 10.8% that is calculated above. Basically, these
customers should get a 10.8% decrease in their rates because of their participation in the 2-day
per week Option as this is reflective of the average embedded cost reduction that their actions
bring.
5 Exhibit 22, Page 26 ($5 000 141/ $46 090 820 = 10.8%)
Yankel, D I
Irrigators
--~-- -
This reduction of 10.8% could be spread across all rate components for those customers
taking service under the 2-day per week Option. The Company seems to prefer that the credit be
given only on the demand component of a customer s bill. In this case, the $5 000 141 reduction
in cost would need to be spread over the 1 304 799 kW7 of summer billing demand for Irrigation
customers. The average savings (credit) that could be spread across the Irrigation billing demand
would be $3.83 per kW8 of billing demand. Once again, this is simply an average rate reduction
based upon the Company s embedded cost of service study or even a credit to reflect system
savings. It does not reflect the marginal cost savings to the Company. This is simply the
minimum rate reduction that should be offered to those customers choosing to be on the 2-day
per week curtailment option.
HOW DOES THIS RATE REDUTION OF $3.83 PER KW OF BILLING
DEMAND COMPARE TO THE CREDIT THAT THE COMPANY IS PRESENTLY
OFFERING CUSTOMERS THAT ARE CURTAILED 2-DAYS PER WEEK FOR 6-HOURS
PER DAY?
At present the Company offers a different "credit" for each of the four summer
months. The difference between months is based upon what the Company calculates from its
forward price curves" at the time that the credit is established prior to the Irrigation season
The present credits are as follows:
$2.62 per kW
$2.86 per kW
$2.70 per kW
June
July
August
7 Company Exhibit 29 page 5
8 $5 000 141 / 1 304 799 kW = $3.83 per kW9 This year s credits were submitted to the Commission on November 12 2004
Yankel, D I
Irrigators
--~-- -
September $0.68 per kW
Although these different rates may make sense to some rate analyst, they do not prompt clarity
for the customers. The Irrigator primarily cares about the total impact on his bill, which is best
defined by the average credit. Additionally, if a customer curtailed in August and September as
opposed to June and July, it would have the same impact upon the Company s cost of service
results. The average monthly "credit" that is presently given by the Company is $2.215 per kW
of billing demand. Increasing this amount up to the rate reduction of$3.83 per kW of billing
demand (that comes from the Company s own embedded cost of service study) is not only the
minimum that should be done to reflect fairness, but it would also greatly increase participation
in the program. Increased participation would mean that additional savings (the difference
between marginal costs and average embedded costs) would be realized by all of the system
customers.
SHOULD THE IRRIGATION CUSTOMERS BEING CURTAILED 4-DAYS
PER WEEK AND 3-HOURS PER DAY BE GIVEN THE SAME RATE REDUCTION AS
THOSE THAT ARE BEING CURTAILED 2-DAYS PER WEEK AND 6-HOURS PER DAY?
, the rate reduction should not be the same, but the reduction that they are
given should be calculated the same way. Specifically, by making a separate run of the
Company s cost of service program and by assuming that there is full participation in the 4-day
per week, 3-hour per day Option under review, it is possible to quantify the impact of this Option
in isolation. By making this assumption, it is possible to quantify the average embedded cost
impact of this Option upon the cost of service that would be allocated to the Irrigators.
Yankel, D I
Irrigators
--~~~ ~
WHAT ASSUMPTIONS WILL YOU USE IN THE COMPANY'S COST OF
SERVICE STUDY TO REFLECT THE IMPACT OF IRRIGATION CUSTOMERS THAT
ARE ON THE 3-HOUR PER DAY, 4-DA Y PER WEEK OPTION?
As demonstrated in Tables 1 and 2 above, the 3-hour per day, 4-day a week
Option captures the days of the week of the summer system peaks as well as 14 of the 15 hours
(93.3%) in which these peaks occur. Unlike the 6-hour per day, 2-day per week Option, these
customers are all curtailed each day so we have 100% participation that impactions 93.3 % of the
peaks. In order to calculate the impact upon cost of service of this Option, it is necessary to
assume that the Irrigation contribution to the 4-summer coincident peak demands in the
Company s model is reduced by 93.3% (and change no other billing determinants or input data).
WHAT IS THE IMPACT THAT THE COMPANY'S COST OF SERVICE
STUDY CALCULATES UNDER THE ASSUMPTION THAT ALL IRRIGATORS WOULD
BE OPERATING UNDER THE 3-HOUR PER DAY, 4-DA Y PER WEEK OPTION?
Under the 3-hour per day, 4-day per week curtailment Option, the Irrigators
would reduce their contribution to the summer system peaks by 93.3% in the Company s cost of
service study. A summary of the results of a cost of service run that only reduced Irrigation load
by 93.30/0 in the 4-summer months is contained on Exhibit D, Page 1. The Company s cost of
service study demonstrates the following impact on the Irrigation customers:
$46 090 820 Irrigation COS as filed by the Company
$35.155.003 COS with Irrigation summer peaks reduced by 93.
Yankel, D I
Irrigators
----- -
$10 935 817 Impact on COS of 4-day per week curtailment
,.,
Basically, the Company s embedded cost of service study confirms that a reduction in
contribution to summer peaks from this program should equate to a 23.70/0 reductionlO in cost of
service for these customers. If only 25% of the Irrigation customers signed up for such a
program, the benefit would be 25% on a jurisdictional and system basis, but the reduction in cost
of service for the 25% group of customers would still be the 23.7% that is calculated above.
Basically, these customers should get a 23.7% decrease in their rates because of their
participation in the 4-day per week Option as this is reflective of the average embedded cost
reduction that their actions bring.
This reduction of 23.70/0 could be spread across all rate components for those customers
taking service under the 4-day per week Option. However, as pointed out above, the Company
seems to prefer that the credit be given only on the demand component of a customer s bill. In
this case, the $10 935 817 reduction in cost would need to be spread over the 1 304 799 kW11
summer billing demand for Irrigation customers. The resulting average savings that could be
spread across the Irrigation billing demand would be $8.38 per kW12 of billing demand.
However, the present demand charge for Irrigation customers is only $4.05 per billing
demand. It would be inappropriate to have a rate reduction for a rate component that would be
larger than the base charge. For this reason, I recommend that the demand charge for these
customers be set at zero with the remainder of the credit being collected over the in-season
energy rates. Assuming a demand charge/reduction of $4.05 per kW of billing demand, this
would mean that $5 284,43613 of the rate reduction would come from the demand component
10 ($10 935 817 / $46 090 820 = 23.7%)
11 Company Exhibit 29 page 512 $10 935 817 /1 304 799 kW = $8.38 per kW
13 $4.05 x 1 304 799 kW billing demand = $5 284 436
Yankel, DI
Irrigators
--~-- -
and the other $5 651 381 would come as a rate reduction to the summer energy rates. From
Company Exhibit 29 page 5 it can be calculated that there is presently $22 669 714 of in-season
energy charges being collected. The remaining rate reduction of$5 651 381 equates to 250/0
this in-season energy revenue. In order to reflect the rest of the rate reduction that is deserving
of customers that are curtailed four days per week, their energy rates should be lowered by 25%
as well as having the billing demand charge set at zero.
Once again, this is simply an average credit based upon the Company s embedded cost of
service study. It does not reflect the marginal cost savings to the Company. This is simply the
minimum rate reduction that should be offered to those customers choosing to be on the 4-day
per week curtailment option.
Yankel, DI
Irrigators
----- -
JURISDICTIONAL TREATMENT OF
MONSANTO AND IRRIGATION LOAD INTERRUPTIONS
ARE THE TERMS AND CONDITIONS OF THE MONSANTO AND
IRRIGATION LOAD INTERRUPTIONS SIMILAR?
There are obvious differences. Monsanto is a single point load, while the
Irrigation curtailable customers are scattered around the jurisdiction. Within contract limits
Monsanto is curtailed at the will of the Company, while Irrigators have load control meters that
automatically reduce load at a prearranged time and for a number of hours each week. Because
of these basic differences, there is a different value that can be placed upon the Monsanto
curtailments compared to that for the Irrigation customers.
However, there are many similarities as well as. Both the Monsanto load and the
Irrigation curtailable load are obtained under a contract. Although the Irrigation load is not
significantly curtailable at all times of the year, the hours of curtailment are designed to reduce
the summer coincident peak load as well as reduce the overall system load (and thus system
costs) during the summer, super-peak hours. Thus, the benefit of these curtailments is similar to
the economic curtailments incurred by Monsanto. Additionally, in the aggregate, the Irrigation
Load Control Program presently curtails - Mw of load, which is on a par with the 70 Mw of
economic curtailment that takes place on the Monsanto load.
ARE THE MONSANTO AND IRRIGATION CURTAILMENTS TREATED
THE SAME ON A JURISDICTIONAL BASIS?
Yankel, D I
Irrigators
-~~~~ ~
A. No. Although both Monsanto and the Irrigation curtailable load are both treated as
situs , the treatment of the credits associated with each of these curtailment options is treated
differently. Within the context of the MSP allocation method, I agree with the treatment of the
Monsanto curtailment credits. However, the treatment of the credits for the Irrigation Load
Control Program do not properly reflective of system benefits. The Irrigation Load Control
Program benefits the entire system. The highest priced resources for the system, not just for the
jurisdiction are reduced because of these curtailments. Because the system benefits, the system
should pick up the cost of "credits" that it pays to Irrigation customers in a manner similar to the
credit" that is paid to Monsanto for the curtailment opportunities that arise out of that contract.
WHAT BRINGS ABOUT THIS DIFFERENCE IN TREATMENT OF THE
CREDIT THAT IS PAID FOR THE MONSANTO CURTAILMENT COMPARED TO THAT
FOR THE CREDITS ASSOCIATED WITH IRRIGATION CURTAILMENTS?
This difference in treatment of the "credit" associated with these two forms of
curtailment in the Inter-Jurisdictional Allocation (IJA) process comes about simply because
PacifiCorp designates the Monsanto curtailments to fall under the heading of "Special Contracts
With Ancillary Service Attributes . Unlike Monsanto, the contracts under the Irrigation Load
Control Program are considered to be simply a form of a DSM program 14 and thus fall under the
heading of "Interruptible Contract Without Ancillary Service Contract Attributes
14 Response to lIP A Request 43-
Yankel, DI
Irrigators
--~-- -
WHAT IS THE IMP ACT OF ASSUMING THAT A GIVEN AMOUNT OF
CURTAILMENT IS TREATED AS DSM COMPARED TO HOW MONSANTO IS
TREA TED?
For a jurisdiction the size of Idaho these credits can have a large impact. The
Company s calculation for the test year amount of the credit to Monsanto 15 is $9 885 417.
Presently, this credit is spread to all jurisdictions as a purchase power cost. Because this credit is
treated as a purchase power costs, approximately 6.6% or $650 000 becomes Idaho
responsibility. This is appropriate because all jurisdictions share in the benefit of these
curtailments. However, if the credits for the Monsanto curtailments were treated the same as that
proposed for the credits for the Irrigation curtailments, the Idaho jurisdiction would be
responsible for this entire $10 million of credit, in spite of the fact that it only enjoyed 6-7% of
the jurisdictional benefit (cost reduction).
With the Irrigation curtailment credits being designated as a DSM project, the Idaho
jurisdiction is effectively being required to pay the entire amount of the credit that is resulting in
a benefit to the entire system. The size of the Irrigation curtailment is presently - Mw
about half of the 70 Mw of economic curtailment available from Monsanto. Although having
different parameters, the Irrigation curtailment program is similar to that of Monsanto in one
very important way-they both curtail load at the time of the peak and either require less
generation to be built and/or reduce the marginal cost of energy during critical hours. Why
should Idaho customers pay for the full credit associated with the Irrigation curtailments of
Mw when it rightfully pays for 6-70/0 of the credit associated with the Monsanto curtailments?
15 Exhibit 29 page 9 of 9 listed as "Non-Finn kW Discount"
Yankel, D I
Irrigators
----- -
GIVEN THE MINIMUM RATE REDUCTION THAT YOU HAVE
CALCULATED ABOVE FOR IRRIGATORS (BASED UPON THE COMPANY'
EMBEDDED COST OF SERVICE STUDY), IS JURISDICTIONAL TREATMENT OR
SYSTEM TREATMENT APPROPRIATE?
Generally speaking, for the case where a customer (or customer group) is
curtailed for the benefit of the system, the "credit" should be allocated on a system basis. It is
inappropriate for a single jurisdiction to absorb the responsibility of "credits" that are being
incurred for the benefit of the entire system. This aspect of the MSP protocol should be
addressed before this methodology is approved by the Commission.
However, for the particular minimum rate reduction that I have proposed for the
Irrigators in this case, neither treatment is appropriate. The minimum rate reduction is simply a
reflection in the cost of service between Irrigators that are curtailed and those that are not. There
is no additional amount associated with this that is a "credit" to reflect the price that would be
paid to achieve additional curtailments for the marginal cost benefits. If the Company were
paying for something (marginal cost or system benefits) with "credits" that were in excess of that
which would result from an embedded cost of service calculation, then those additional "credits
should be addressed on a system as opposed to a jurisdictional basis.
The Commission needs to address the treatment of curtailments "credits" on a system
basis. However, a curtailment "credit" for Irrigators would only be something in excess of the
rate reduction that simply flows through the Company s cost of service study. Until a true
Yankel, D I
Irrigators
-~-~~ ~
credit" is established that is above the minimum rate impact, there is not "credit" to be paid for
by other customers.
Yankel, D I
Irrigators
---~~ ~
LOAD RESEARCH DATA QUALITY
IS THE LOAD RESEARCH DATA USED IN THIS CASE OF SUFFICIENT
QUALITY TO USE FOR ESTABLISHING CLASS RATES OF RETURN UPON WHICH
THERE IS EVEN THE LEAST BIT OF CREDIBILITY?
No. Although the Company employees may do a good job of collecting and
analyzing load research data in its larger jurisdictions, the combination of Idaho being a very
small jurisdiction and not having a rate case to almost 20 years seems to have resulted in data
that is unacceptable for use in determining class cost of service in this case.
recommendation is an even percentage increase be given to all customer classes in this case with
the hope that some of these data problems can be rectified before PacifiCorp files its next Idaho
rate case. I suggest this in spite of the fact the Company s present cost of service study shows
the Irrigation class very near the average rate of return, and that a few simple and obvious
corrections to the data would yield a return above average and thus the need to give the Irrigators
less than the average increase.
DOES THE COMPANY COLLECT LOAD RESEARCH DATA FOR ALL OF
ITS CUSTOMER CLASSES?
No. Load research data is simply a sampling procedure used when the Company
does not have hourly demand data for each customer. In such cases the Company gathers data
from a limited number of customers on a rate schedule and expands that data to reflect the entire
population of the rate schedule.
Yankel, D I
Irrigators
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Because of cost considerations (and possibly lack of rate cases) the Company has not
been continually operating a load research program for all classes in Idaho that need one. For
purposes of this case the Company does not have test year load research data for Schedules 006
023 , 019, 008, and 035 (Schedule 009 is the only commercial/industrial schedule for which it has
current load research data. Additionally, it did not have current load research data for April-
July of the test year for both Residential Schedules 001 and 036.
IF THE COMPANY DOES NOT HAVE CURRENT LOAD RESEARCH FOR
ALL OF THESE SCHEDULES, WHAT IS THE SOURCE OF THE DATA USED?
The Company uses average historical data where it does not have current load
research data available. For example, for Residential Schedules 001 and 036 the Company used
the average 1991-1994 data (over 10 years old). The data was not nearly as antient for the
commercial schedules with that data generally coming from the 1998-2000 timeframe (about 5
years old).
Aside from the obvious concern regarding the age of this data, the averaging technique is
also of concern. The Irrigation demand data reflected actual conditions during the test year as
did the Residential data starting in August (after the summer peak). Development of peak data
from an average of historical data (that certainly is not a reflection of the test year temperatures
and usage patterns) would tend to produce different (and I believe lower) peak results than if
actual data were collected during the test year. Thus, the load research data that is currently
collected for some customer classes would tend to bias this data upward, by comparison to all of
the customer classes where average historical data is used.
Yankel, DI
Irrigators
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ARE THERE OTHER PROBLEMS WITH THE LOAD RESEARCH DATA AS
USED IN THE FILING BY THE COMPANY?
Yes. There were technical problems with the way the Company s computer
program analyzed the load research data. The computer program occasionally left out portions
of the data collected for the Residential 001 and Irrigation customers. Basically, this problem
was random. It is my understanding that this problem was fixed after it was revealed through the
discovery process.
DID THIS ELIMINATION OF DATA RESULT IN LARGE SHIFTS IN THE
RESULTS THAT WERE OBTAINED BY THE COMPANY?
It depends on how one s views the data and how much faith one puts in the
entire load research process. If one assumes that in spite of its age and any other thing that may
be going against this load research data that it is a 100% reflection of the population, then the
fixing of this problem is small. Fixing the problem resulted in an increase in the rates of return
generated for both the Residential 001 and the Irrigation customers as demonstrated on Exhibit
However, fixing the problem exposes the sensitivity of the data to a calibration problem
Data Calibration Problem
Yankel, D I
Irrigators
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REFLECTING IRRIGATION CURTAILMENTS
IN LOAD RESEARCH DATA
DOES THE COMPANY'S LOAD RESEARCH DATA PROPERLY REFLECT
THE AMOUNT OF IRRIGATION CURTAILMENT THAT OCCURRED IN 2003?
No. Aside from the issue that there is far more Irrigation curtailment that is
taking place today than in 2003 , the curtailment actually reflected in the 2003 load research data
is approximately half of what actually took place on a total population basis. The reason for this
is quite simple. The load research program was not designed to capture the effect of the
Irrigation curtailment program. Out of the 403 pumps that were on the curtailment program in
2003 , there was only load research data available from three of these pumps. The Company
response to IIP A Request 47 recognizes this shortcoming:
The load research sample in place at this time was developed to predict the
class average load for the irrigation class in Idaho. The sample was installed prior
to the implementation of the load control project. As such, the current sample
design, and the sample point (customer) representation in the load research study
is insufficient to predict with a reasonable accuracy the impact of the load control
project. However, since the irrigation class is affected by the load control
program, decreases in usage on a class basis should reasonably be picked up in
the class load research study. The study however will not accurately report the
impact on the irrigation class load shape.
If it is determined that load control impact needs to be more accurately
measured, more sample points would be needed and a completely new sample
design may need to be developed.
PLEASE QUANTIFY THE LEVEL OF IRRIGATION CURTAILMENT THAT
IS REFLECTED IN THE COMPANY'S LOAD RESEARCH DATA AND THUS IN THE
COMPANY'S COST OF SERVICE STUDY DATA.
Yankel, D I
Irrigators
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Exhibit B contains the calculations used to calculate the actual level of Irrigation
curtailment that is reflected in the Company s cost of service study data. There were only three
curtailable customers contained in this data and they were all in Strata 3. These three customers
had loads of approximately 110 and 167 kW for the two that were interrupted on Monday s and
Wednesday s and 155 kW for the one that was interrupted on Tuesday s and Thursday s. There
were 19 sample customers in Strata 3. In order to extract the amount of interruptible load that
the load research data reflected in the general population, it is necessary to multiply the loads of
these customers by the number of customers in the population as well as the Strata weighting
factor and divide by the number of customers in the Strata. As can be seen from Exhibit B , the
average curtailable load that is reflected in the total population is 9 Mw-a far cry from the 21
Mw that was signed up in 2003.
ARE YOU RECOMMENDING A CHANGE IN THE COMPANY'S COST OF
SERVICE STUDY TO BETTER REFLECT THE AMOUNT OF CURTAILMENT THAT
WAS INCLUDED IN THE COMPANY'S DATA?
No. I have recommended an even spread in the rate increase for this case.
Correcting the amount of interruptibility reflected in the Company s data only serves to increase
the rate of return for the Irrigation class and further justifies an average increase for the Irrigation
class. I bring attention to this shortcoming in the Company s data so that it can be addressed
before the Company s next rate case.
Yankel, D I
Irrigators
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TREATMENT OF THE COSTS ASSOCIATED WITH
SUBSTATIONS AND PRIMARY DISTRIBUTION LINES
HOW DOES THE COMPANY ALLOCATE COSTS ASSOCIATED WITH
SUBSTATIONS AND PRIMARY DISTRIBUTION LINES?
The Company uses the monthly distribution peaks of each class, weighted by the
percentage of Substations that peaked in each month. By way of example, if only 1 % of the
Substations peaked in a given month, the individual class distribution peaks for that month
would be weighted by 1 %, and if 50% of the Substations peaked in a given month, then the
individual class distribution peaks for that month would be weighed by 50%. The general theory
being that Substation and Primary line costs are peak related, and as more substation are peaking
during certain months of the year, the usage by the various classes should be weighed more
during those months. SEE IN TAYLOR SAYS THIS BETTER
IS THE COMPANY'S METHODOLOGY FOR ADDRESSING THE COST
CAUSATION OF SUBSTATIONS AND PRIMARY LINES APPROPRIATE?
Generally speaking, I agree with the intent or direction of the Company
approach. These costs are primarily distribution demand related, and peak demand on a given
Substation or Primary line would tend to drive costs. However, there is one shortcoming with
the Company s method that could be easily fixes and be more in line with the intent of the
methodology proposed.
Yankel, D I
Irrigators
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The Company s methodology assumes that costs are related to how many substations peak in a
given month. If all Substations cost the same, the Company s method may be a good link with
cost causation. However, all Substations are not the same. The size of these Substations vary
from 400 KV A (Holbrook) to 32 500 KV A (Rexburg). The cost of these substations varies over
a wide range as well with costing and costing
HOW DO YOU RECOMMEND RECTIFING THIS SHORTCOMING IN THE
COMPANY'S ALLOCATION METHODOLOGY?
Very simply by not assuming that each Substation is equal, but by using the cost
of each Substation that peaks in a given month as the basis for the development of the weighting
factors.
CAN THIS WEIGHTING BE DONE IN THIS CASE?
No. In developing it distribution weighting factors in this case, the Company
relied upon 5-years of data The use of multiple years of data for this purpose is
preferable to using only a single year. Unfortunately, the data does not include information
regarding which Substations peaked when-simply the number of substations that peaked in a
given month. The Company only has I-year of recent data that lists which Substations peaked in
which month. I recommend that the Company continue to collect data that identifies the
individual Substations that peak in a given month for purposes of the next rate case.
Yankel, D I
Irrigators
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Yankel, D I
Irrigators