June 30, 2015
Via Email post2017process@powerauthority.org
Arizona Power Authority
Attn: Post 2017 Allocation Process
1810 West Adams Street
Phoenix, Arizona 85007-2697
RE:
APA Calculations and Data Issues with the Post-2017 Preliminary Proposal
Ladies/Gentlemen:
These comments are submitted on behalf of K. R. Saline & Associates, PLC, addressing the Arizona
Power Authority’s (“APA”) Hoover Power Marketing Post-2017 Preliminary Proposal dated June 15, 2015
(the “Preliminary Proposal”). These comments include the comments emailed to the APA consultants on
June 17, 2015.
Upon review of the Preliminary Proposal spreadsheet, we identified several numerical errors
and data errors which we request be corrected in the final proposal.
1.
The Columns “Adjusted 1987” for Schedule A and Schedule B appear to have incorrect energy
calculations. Based upon our understanding of the columns, they should reflect current APA
Hoover A and Hoover B Entitlements adjusted for the Hoover Power Allocation Act (HPPA)
changes in nameplate capacity and creation of the new Hoover D pool.
a. The typical formula used by USBR/WAPA is to take the individual Capacity Allocation
(kW) /Total Capacity Entitlement (kW) x Total Energy Entitlement (kWh) for each
resource.
b. APA should use 613,689,000 kWh from the HPPA rather than the 613,689,550 kWh as
used by the APA in the allocation.
c. For Hoover A, the corrected formula would be each entity’s kW allocation/ 190,869 kW
x 613,689,000 kWh.
d. For example: Aguila’s Adjusted 1987 Hoover A should be 2,474/190,869 x 613,689,000
= 7,954,495 kWh. The APA’s table has 7,969,550.
e. The same is true on the Schedule B calculations for Adjusted 1987.
2. The Columns “Allocated 2017” for Schedule A, Schedule B, and Schedule D appear to have the
same Energy calculation errors in the Preliminary Proposal. You cannot take the 2017 Capacity
allocations from the Preliminary Proposal and derive the appropriate Energy allocations.
Page 2
a. For example: Aguila should be: 2,449 kW / 190,869 kW x 613,689,000 kWh = 7,873,949.
b. The APA’s Schedule A, Allocated 2017 Energy for Aguila is 7,889,855 kWh.
3. There appear to be other columns that when added up from the printed numbers do not equal
the Total printed on the page. Since the customers do not have the spread sheets and
embedded formulas the numbers should add up so the customers can follow the numbers and
the individual numbers should add up to the Totals.
4. Regarding allocation numbers, the sum of the individual Hoover A, Hoover B, and Hoover D
allocations needs to sum to the APA’s total entitlements. Therefore we believe the
mathematical rounding should be fixed and corrected.
5. Other resource Issues:
a. For SLCA/IP power, many of the APA’s customers have to use Parker-Davis transmission
to deliver SLCA/IP power, and that transmission is part of their SLCA/IP contract. This
issue was discussed at length with the APA’s staff in the preliminary process. For those
entities, we provided the contractual SHP capacity and energy in their Applications
adjusted to the APA Point of Delivery (less 3% losses) in yellow.
b. For ED3, ED4, ED5, ED7, MWD, Safford, Thatcher, Wellton and possibly ED2; the APA’s
numbers for Federal Power Received do not reduce their SLCA/IP capacity and energy
that is available to serve load for the 3% Parker Davis Project transmission losses.
c. The APA Staff previously examined averaging the SLCA/IP seasonal capacity to compare
to the 5 year peak demands that were also averaged. The SLCA/IP amounts are from
contractual exhibits and cannot be moved into the peak month. For example ED4 has
its peak SLCA/IP capacity available in March and not June, July, or August when they
actually peak. OWCD recently peaks in October when they are under their winter
season SLCA/IP entitlements and their Summer SLCA/IP capacity is not available to serve
their October loads. The APA should either average the SLCA/IP SHP capacity like
previously discussed or use the SLCA/IP capacity in the months of peak demand so as to
not penalize the customers for excess resources when in reality the customer does not
have sufficient resources to serve their load in their peak months.
d. Hohokam does not have 12 MW of Parker-Davis power, it has 1 MW.
e. AEPCO and SRP have federal resources, which are not indicated in the data sheets.
We thank you for the opportunity to comment on the Preliminary Proposal and respond to any
questions on our comments.
Sincerely,
Kenneth R. Saline
K. R. Saline & Associates, PLC
__________________________
K. R. Saline & Associates, PLC
160 N. Pasadena, Suite 101  Mesa, AZ 85201-6764  Phone 480.610.8741