20070724Staff to PAC 18-35.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSIONPO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
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NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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. P AC-07-
SECOND PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO P ACIFICORP DBA ROCKY
MOUNTAIN 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, AUGUST 14 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
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JULY 24, 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 IDAP A 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. 18: Please provide the full 2006 Long-Term Outlook for Coal and
Competing Fuels Report from Energy Ventures Analysis referenced on page 5 of Company
witness Widmer s testimony.
REQUEST NO. 19: Please provide the Company s Official Price Forecasts used as the
market price inputs for the net power cost calculation. Please explain why two price forecasts
were used?
REQUEST NO. 20: Please provide further explanation into the development of the
market price hourly scalars. Please include the scalars in the response to this request.
REQUEST NO. 21: Why does the Company use historical data since 1996 to develop
the market price hourly scalars? Please recalculate the scalars using historical data from 2002 to
December 31 2006 and apply to the Official Price Forecasts used by the Company in this filing.
REQUEST NO. 22: On page 21 of Company witness Widmer s testimony, it is stated
that the VISTA model uses the same market price input as the GRID model. Do both models use
the December 31 , 2006 forecast and the March 31 , 2007 forecast, or only the former?
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JULY 24, 2007
REQUEST NO. 23: The GRID model uses normalized retail load by jurisdiction as an
input. How is this information collected, i., at the substation level? Are there any instances in
which the Company has to use its judgment in assigning partial load to multiple states due to
how the load data is collected? Please explain.
REQUEST NO. 24: Please explain how the Idaho Irrigation Load Control program is
modeled in GRID. Have the net power costs been adjusted to reflect the dispatchable pilot
program approved in Case No. PAC-06-12? Have any adjustments been made to the Idaho
jurisdictional loads and the irrigation Schedule 10 loads to account for the approved pilot
program? How does the monthly peak reduction (actual and expected) for 2007 compare with
2006 peak reduction?
REQUEST NO. 25: It is Staffs understanding that the load profile meters used to
collect sampling data for residential Schedules 1 and 36 were installed in 2001 and in 1999 for
irrigation Schedule 10. Have there been additional load profile meters installed for these classes
since then? Have the meters installed in 1999 and 2001 remained at one location, or does the
Company rotate meters within the respective customer class after a period of time? Has the
Company done any studies to determine if its sampling size is adequate? Please explain your
answers.
REQUEST NO. 26: Please describe the metering equipment in place for residential
Schedule 36 customers. What information is collected to facilitate time-of-use billing? What
information is available to the customer; is it available in real-time or only at billing?
REQUEST NO. 27: On page 10 of Company witness Griffith's testimony, it is stated
that the on-peak/off-peak rate differentials for Schedule 36 customers is consistent with the
differential in wholesale cost differences, yet the rate differential is nearly twice as high in
percentage terms as the wholesale differential. Please provide further support of the prices and
differentials proposed by the Company. Also, provide any analysis the Company has done with
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JULY 24, 2007
respect to the impact Schedule 36 has had on participating customers' bills, total usage, use
pattern, peak load and Company revenues.
REQUEST NO. 28: Please compare the cost of meter reading for Schedule 1 customers
with that of Schedule 36 customers. Please provide a business case analysis of the costslbenefits
of installing automatic or advanced meter reading capability for Schedule 36 customers.
REQUEST NO. 29: Please describe the Company s efforts to promote the Schedule 36
time-of-use billing to residential customers.
REQUEST NO. 30: In the class cost of service models, are residential customers
partitioned by Schedules 1 and 36, or does that occur when the Company does its rate spread and
rate design? Please explain your answer.
REQUEST NO. 31: On page 5 , lines 7 through 9 of Company witness Bennion
testimony, it is stated that "(t)he Company must also build transmission facilities to move power
generated by others (i.e. qualifying facilities) to substations and load centers." Consistent with
Revised Protocol, Section C3, please provide the following:
(a) a list of all QF contracts included in the case;
(b)
(c)
the location of each QF;
the embedded cost differential calculation for each existing QF under the Revised
Protocol;
the Comparable Resource calculation for each new QF;(d)
(e)
(f)
the dollar amount allocated as a system cost for each project, and
the dollar amount allocated as a situs cost for each project.
REQUEST NO. 32: Please provide transmission costs associated with qualifying
facilities referenced on page 5 in Company witness Bennion s testimony, along with any
additional costs included in this rate filing. Please list the transmission costs by QF, specifying
the location of each QF.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JULY 24, 2007
REQUEST NO. 33: Please describe in greater detail the gas procurement strategies for
the Currant Creek and Lakeside projects. Has the Company negotiated a contract to supply the
Lakeside proj ect with natural gas, and if so, please provide it with your response. Also, if the
plant is not online when anticipated, please provide the Company s plan for marketing/utilizing
otherwise unused natural gas?
REQUEST NO. 34: Please describe how the Renewable Energy Tax credit for wind
generation additions was calculated in Company witness McDougal's Exhibit No. 13. Is the
Blundell bottoming cycle project eligible for the Renewable Energy Tax credit, and if so, how
has the Company incorporated it into this rate filing?
REQUEST NO. 35: Please provide an explanation and any supporting materials
including any contract information regarding the Company s share of the Jim Bridger mine that
would support and quantify the projected increase in costs for 2007.
rl.
DATED at Boise, Idaho , this
cJ 'I' day of July 2007.
c4J Neil Price
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:prodreq/paceO7,5npbl prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JULY 24, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF JULY 2007
SERVED THE FOREGOING SECOND 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~pacificorp. com
DATA REQUEST RESPONSE CENTER
ACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
MAIL: datarequest~pacificorp. com
JAMES R SMITH
MONSANTO COMPANY
POBOX 816
SODA SPRINGS ID 83276
MAIL: iim.r.smith~monsanto.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
PO BOX 1391
POCATELLO ID 83201-1391
MAIL: elo~racinelaw.net
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E- MAIL: cew~givenspursley.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
MAURICE BRUBAKER
KATIE IVERSON
BRUBAKER & ASSOCIATES
1215 FERN RIDGE PARKWAY
SUITE 208
ST LOUIS MO 63141
MAIL: mbrubaker~consultbai.com
ki verson~consultbai. com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
MAIL: yankel~attbi.com
DENNIS E PESEAU, Ph.
UTILITY RESOURCES INC
1500 LIBERTY ST SE STE 250
SALEM OR 97302
MAIL: dpeseau~excite.com
SECRET AR
CERTIFICATE OF SERVICE