20150320Staff 28-31 to PAC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER AND IDAHO POWER COMPANY FOR
AN ORDER AUTHORIZING THE EXCHANGE
OF CERTAIN TRANSMISSION ASSETS.
All ll: li5
CASE NOS. IPC.E-14.41
PAC-E-14-11
SECOND PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN
POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIOI\
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Daphne Huang, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Rocky Mountain) provide the following documents and information as soon as possible, but no
later than FRIDAY, APRIL 3,2015.r
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. IDAPA 31.01.01 .062,31.01.01.228.
' Staff is asking for an expedited response. If responding by this date will
attorney at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOI.]NTAIN POWER 1
be problematic, please call Staff s
MARCH 20,2OI5
This Production Request is to be considered as continuing, and Rocky Mountain is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 28: In response to Staff s Production Request No. 9 the Company
states that "PacifiCorp's Transmission Planningorganization will continue to perform ongoing
reliability, load, and interconnection studies that identify future transmission investments."
Please provide copies of the most current transmission planning studies for transmission lines
owner, or co-owned by PacifiCorp, extending into and across Idaho, including the Idaho -
Northwest and Midpoint - Hemingway transmission lines.
REQUEST NO. 29: In response to Staff s Production Request No. 33 the Company
referred to Idaho Power's response which states that there are oono anticipated changes to the cost
and benefits of the proposed Boardman to Hemingway project." Please explain whether
PacifiCorp's most current and most up-to-date B2H economic analysis considers the asset
exchanges and upgrades. Please provide PacifiCorp's most current and up-to-date economic
analysis of B2H that includes all costs and all benefits.
REQUEST NO.30: Please explain any changes to PacifiCorp's projected first year
transmission capacity deficit as a result of the asset exchange. Please explain why there are, or
are not, changes to PacifiCorp's first year transmission capacity deficit and provide a copy of the
current transmission capacity deficit projections.
REQUEST NO. 31: In reference to Exhibit No. 8, p. l, line 20, attached to the direct
testimony of PacifiCorp witness Richard Vail, please provide supporting calculations for the
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER MARCH 20,2OI5
estimated reduction in wheeling expense, along with whether the estimated savings are
associated with any of the specific transmission assets listed in Exhibit C of the JOOA.
DATED at Boise,Idaho, this ?CV day of March 2015.
Technical Staff: Johanna Bell
Umisc/prod req/ipcel4.4l jac-e-14-l ldjhjbkls prodreq2 rpm
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
Deputy Attorney General
MARCH 2O,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF MARCH 2015,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NOS.
IPC-E-14.4I /PAC-E-14.11, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
JULIA A HILTON
IDAHO POWER CO
PO BOX 70
BOISE ID 83707
E-MAIL: [e-mail]
INDUSTRIAL CUSTOMERS OF IDAHO
POWER
C/O PETER J. RICHARDSON
RICHARDSON ADAMS PLLC
515 N. 27TH ST
BOISE, IDAHO 83702
E-MAIL: [e-mail]
DANIEL SOLANDER
TED WESTON
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 841I1
E-MAIL: [e-mail]
ted.weston@pacifi com. com
DR. DON READING
6070 HILL ROAD
BOISE,IDAHO 83703
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE