200307231st Request of Staff to PacifiCorp.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP FOR APPROVAL OF A NEW
RENEWABLE ENERGY TARIFF, I.E.
ELECTRIC SERVICE SCHEDULE NO. 70, NEW )
WIND, GEOTHERMAL AND SOLAR POWERRIDER - OPTIONAL.
CASE NO. P AC-03-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ACIFICORP
The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Scott Woodbury, Deputy Attorney General, requests that PacifiCorp (PacifiCorp;
Company) provide the following documents and information on or before THURSDAY,
JULY 31, 2003.
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. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and PacifiCorp 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.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF JULY 23 2003
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Request No.1: PacifiCorp initially proposed a similar program in Idaho in 2000
(Reference P AC-OO-l), but that program was rejected by the Commission. Please briefly
explain how this new program is different, including why the proposed price per 100 kWh block
is so much less than in the year 2000 proposal.
Request No.2: Please provide workpapers or other information showing how the
proposed price premium of $1.95 per 100 kWh block has been determined. Clearly state any
assumptions used in the analysis. Also clearly state the basis for any assumed values used in the
analysis.
Request No.3: Please provide a program budget showing a detailed breakdown of
program costs, including management and administrative costs, marketing costs, bundled green
energy costs and green tag costs.
Request No.4: Please explain why PacifiCorp is proposing to acquire bundled green
energy and/or green tags in this program, rather than just one type of product.
Request No.5: What is the relative value of bundled green energy vs. green tags?
Would the price per block be different ifit was based on purchase of bundled green energy than
on green tags? Is so, explain why.
Request No.6: Are there additional costs associated with acquiring bundled green
energy as opposed to acquiring green tags?
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF JULY 23 2003
Request No.7: What participation level does PacifiCorp expect in Idaho during each of
the first four years? What is the current participation level in Oregon, Utah, Washington and
Wyoming?
Request No.8: Please explain how the program will be marketed in Idaho. What
proportion of marketing costs will be spent in Idaho?
Request No.9: IfPacifiCorp collects more or less than necessary from participants in
order to cover program costs, will the Company propose changes in the price charged per 100
kWh block? How will the Company balance purchases and sales to avoid a net gain or loss on
the program?
Request No. 10: Page 2 of the Company s Application states the following:
PacifiCorp will keep interested parties informed of purchases
for the program on a twice per year basis. If there is not
availability at the right price to purchase at a level (capped
within the $1.95 retail price) then PacifiCorp will attempt to
make purchases at the next level. The reports will summarize
purchases and note reasons for choosing a "tier" and, if
applicable, foregoing more preferred options in light of
available tag supply.
Please explain what is meant by "levels" and "tiers." Please provide copies of
informational notices provided to Blue Sky program participants in Oregon, Utah, Washington
and Wyoming.
Dated at Boise, Idaho, this
a3
vrlday of July 2003.
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Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/paceO3_9swrps prl
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF JULY 23 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF JULY 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO. PAC-03-, BY MAILING A COpy
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DOUG LARSON
VICE PRESIDENT REGULATION
ACIFICORP
201 S MAIN ST, SUITE 2300
SALT LAKE CITY UT 84111
E- MAILED TO doug.1arson(q?pacificorp. com
DATA REQUEST RESPONSE CENTER
ACIFICORP
825 NE MUL TNOMAH, SUITE 800
PORTLAND, OR 97232
MAILED TO datarequest(q?pacificorp.com
~.;D , ICQcL
SECRETARY
CERTIFICATE OF SERVICE