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Home My WebLink About20070703Staff to PAC 1-17.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 ISB NO. 1895 NEIL PRICE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 ISB NO. 6864 Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorneys for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF PACIFICORP DBA ROCKY MOUNTAIN POWER FOR APPROVAL OF CHANGES TO ITS ELECTRIC SERVICE SCHEDULES. CASE NO. PAC-07- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO P ACIFICORP DBA ROCKY MOUNT AIN POWER The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power (Company; Rocky Mountain) provide the following documents and information on or before TUESDAY, JULY 24, 2007. 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 FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER JULY 3, 2007 location and phone number of the record holder and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA 31.01.01.228. This Production Request is to be considered as continuing, and Rocky Mountain Power 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 and telephone number of the person preparing the documents. Please identify 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). REQUEST NO.1: Please provide a copy of the Navigant report referred to on pages 4- 5 of the direct testimony of William Fehrman. The Navigant report was an assessment of the evaluation process for RFP 2003-A in which the Lake Side project was chosen as the best alternative. REQUEST NO.2: Please provide a copy ofRFP 2003-B issued in February 2004. Please identify or provide a list of amendments to RFP 2003-B following the acquisition of PacifiCorp by MidAmerican Energy Holdings Company. REQUEST NO.3: Please explain why RFP 2003-B was re-opened to allow previous bidders to update their proposals and to invite new bidders to participate. How many bids were updated and how many new bidders chose to participate as a result. REQUEST NO.4: Please provide a summary of all bids received in response to RFP 2003- REQUEST NO.5: Please provide a summary of all projects short-listed in the evaluation process for RFP 2003- FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER JULY 3, 2007 REQUEST NO.6: For each short-listed bid not selected in RFP 2003-, please provide an explanation and supporting documentation of why the bid was not selected. REQUEST NO.7: Please provide all analysis performed to evaluate and compare short- listed bids, including bids for the Leaning Juniper, Marengo, and Goodnoe Hills projects. The analysis may include computations ofPVRR, energy cost and capacity cost; comparisons between bids and against wind cost assumptions included in the 2003 IRP; and risk analysis. For spreadsheet analysis, please provide electronic copies of all spreadsheets with formulas intact. REQUEST NO.8: Please provide cost analysis, similar to that described in Request No. , for the Wolverine Creek wind project. REQUEST NO.9: In discussing the Leaning Juniper, Marengo, and Goodnoe Hills projects, the direct testimony of William Fehrman states "The Company was provided with a detailed overview of the project, the contract support and counterparty guarantees for executing upon the project, a comparison against the risks associated with an alternative bidder, the risks associated with the project, the need for the project as established by the IRP, the financial assessment of the project and the justification of the project due to the results ofRFP 2003-A." To the extent not provided in response to Request No., please provide the information referred to in the quoted testimony for each of these three projects. REQUEST NO. 10: On page 11 , lines 7-10 of William Fehrman s direct testimony, he states , " RFP 2003-B resulted in the acquisition of the 100.5 megawatt Leaning Juniper wind plant, the acquisition and subsequent construction of the 140.4 megawatt Marengo wind plant and served as a benchmark to compare other wind resource alternatives against (such as the Goodnoe Hills wind proj ect)." Please explain in more detail what is meant by " . . . served as a benchmark to compare other wind resource alternatives against." Was the Goodnoe Hills project not bid in RFP 2003-B? If not, how was the proposal received? Have other wind proposals been received outside of the RFP 2003-B process? FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER JULY 3 , 2007 REQUEST NO. 11: Please provide a summary of the wind generation that PacifiCorp purchases through power purchase agreements (PP As). In the summary, include at least the name and location of the wind facility, the nameplate capacity and capacity factor for each proj ect, the quantity of annual energy purchased, the term of the PP A, and all pertinent purchase price information. REQUEST NO. 12: Please identify the amount of federal production tax credits or equivalent deductions on an annual basis PacifiCorp expects to receive for the renewable projects (Leaning Juniper, Marengo , Goodnoe Hills, Blundell). Please also identify any state tax credits or other state incentives that have been received or will be received for these proj ects and discuss how these credits or incentives will be jurisdictionally allocated. Please indicate where in the Results of Operations these credits are accounted for. REQUEST NO. 13: Please list any funds received by PacifiCorp from the BP A Conservation and Renewable Resource Credit Program and from the Energy Trust of Oregon that are being used for any ofPacifiCorp s renewable generation projects. Please state the amounts received from each program and the corresponding projects to which they have been or will be applied. REQUEST NO. 14: What are the contractual Guaranteed Operation Dates for the Lake Side, Leaning Juniper, Marengo, and Goodnoe Hills projects? Please provide a construction schedule for each of these projects and discuss whether the construction is on schedule for each project. REQUEST NO. 15: Please compare the costs of the Leaning Juniper, Marengo and Goodnoe Hills projects to the cost assumption for wind generation included in PacifiCorp s 2003 and 2007 IRPs. If the costs of any of these projects exceed the wind generation costs assumed in either the 2003 or 2007 IRPs, please provide justification for why the Company still decided to acquire the resources and discuss whether there is any cost limit that the Company would not be willing to exceed in order to meet its renewable resource targets. FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER JULY 3 , 2007 REQUEST NO. 16: The testimony of Carole Rockney discusses a proposed change to the methodology used for line extension refunds. In her testimony on page 10, lines 13-, she states , " Transferring the contract is an administrative burden that is time consuming and is not a requirement in any other state served by the Company." How many contracts were transferred in Idaho in each of the past two years? Please provide an estimate of the time and expense of transferring a contract, or otherwise provide some evidence of the administrative burden. REQUEST NO. 17: Please explain the method used to temperature normalize residential and small commercial revenues as per Adjustment 3.1 (McDougal, Exhibit 11). Please provide the model and input data used to determine temperature normalized revenues. DATED at Boise, Idaho, this day of July 2007. f:!~Neil Price Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreq/paceO7 .5nprps prod reg 1 FIRST PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER JULY 3, 2007 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF illLY 2007 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID TO THE FOLLOWING: DEAN BROCKBANK SENIOR COUNSEL ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 MAIL: dean. brockbank~JJacificorp. com DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MUL TNOMAH STE 2000 PORTLAND OR 97232 MAIL: datarequest~pacificorp. com JAMES R SMITH MONSANTO COMPANY PO BOX 816 SODA SPRINGS ID 83276 MAIL: iim.r.smith~monsanto.com BRIAN DICKMAN MANAGER, ID REGULATORY AFFAIRS ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 MAIL: brian.dickman~pacificorp.com RANDALL C BUDGE RACINE OLSON NYE BUDGE & BAILEY PO BOX 1391 POCATELLO ID 83201-1391 MAIL: rcb~racinelaw.net CERTIFICATE OF SERVICE