20070823PAC to Agrium 1-5, 7-8.pdf

~~OUNTAIN 201 South Main. Suite 2300
Salt Lake City. Utah 84111
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August 21 , 2007 zaa~1 flUS 23 i A
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Conley E. Ward
GIVENS PURSLEY LLP
601W. Bannock Street
O. Box 2720
Boise, ID 83701-2720
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Agrium Data Requests (1-
Please find enclosed Rocky Mountain Power s Responses to Agrium Data Requests 1 - 8
with the exception of 6. Provided on the enclosed CD are Attachments Agrium 1 , 2, 4A
, 5 & 7. Response to 6 is in process and will be provided when available.
If you have any questions, please feel free to call me at [phone].
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Brian Dickman, Manager
Regulation
Enclosures
PAC-07-05/Rocky Mountain Power
August 22, 2007
Agrium Data Request
Agrium Data Request 1
Please provide copies of all prior and subsequent responses to Staffs or
intervenors' formal or informal production or information requests relating to this
case.
Response to Agrium Data Request 1
Agrium has been copied on all formal data requests to date in this docket.
Provided on the enclosed CD as Attachment Agrium 1 are the Responses to IPUC
Audit requests. All Confidential Attachments will be provided upon receipt of a
signed protective order in this docket.
(Please contact Brian Dickman at 801-220-4975 to discuss this response.
IDAHO
AC- E-07 -
ROCKY MOUNTAIN POWER
AGRIUM DATA REQUESTS (1-
ATTACHMENT AGRIUM
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 22, 2007
Agrium Data Request 2
Agrium Data Request 2
Provide the most recent LOLP or other capacity risk study prepared by or for
Rocky Mountain Power and/or PacifiCorp.
Response to Agrium Data Request 2
The company s most recent Loss of Load Probability study was conducted as part
of the 2007 Integrated Resource Plan. The study methodology, documented on
pages 135-6 of the 2007 IRP report, was applied to the resource portfolios
developed for detailed stochastic production cost simulation. The LOLP results
for the portfolios are provided on pages 177-8 and 199-200 of the 2007 IRP
report. These pages are provided on the enclosed CD as Attachment Agrium 2.
(Gregory N. Duvall prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
AGRIUM DATA REQUESTS (1-
ATTACHMENT AGRIUM2
ON THE ENCLOSED CD
P AC-07-05/Rocky Mountain Power
August 22, 2007
Agrium Data Request 3
Agrium Data Request 3
Provide the last two Integrated Resource Plans completed by or for Rocky
Mountain Power and/or PacifiCorp.
Response to Agrium Data Request 3
The 2003,2004, and 2007 IRPs are available on PacifiCorp s website. Please go
to www.pacificoro.com, then to Energy Resources, then to Integrated Resource
Plan.
(Gregory N. Duvall prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
AC- E-07 -05/Rocky Mountain Power
August 22, 2007
Agrium Data Request 4
Agrium Data Request 4
Provide the last incremental cost or marginal cost study completed by or for
Rocky Mountain Power and/or PacifiCorp.
Response to Agrium Data Request 4
Rocky Mountain Power has not filed an incremental or marginal cost study for its
Idaho jurisdiction. Idaho rates are based on embedded costs and only embedded
cost studies have been prepared and filed for Idaho.
The company has two jurisdictions that set rates based on marginal costs, Oregon
and California. Provided on the enclosed CD as attachments are the most recent
marginal cost studies filed in those states. Attachment Agrium 4A is the marginal
cost study filed in November 2005 in our most recent California general rate case
Docket 05-11-22. Attachment Agrium 4B is the marginal cost study filed in
February 2006 in the company s most recent Oregon general rate case, UE 179.
(Mark E. Tucker prepared this response, is the recordholder, and is expected to
sponsor this response at hearing. Please contact Brian Dickman at 801-220-4975
to discuss this response.
IDAHO
P AC-O7-
ROCKY MOUNTAIN POWER
AGRIUM DATA REQUESTS (1-
ATTACHMENTS AGRIUM 4A & 4B
ON THE ENCLOSED CD
P AC- E-07 -05/Rocky Mountain Power
August 22, 2007
Agrium Data Request 5
Agrium Data Request 5
Provide monthly system coincident peak loads for the last 10 years.
Response to Agrium Data Request 5
The monthly system coincident peak loads for the last 10 years are provided on
the enclosed CD as Attachment Agrium 5.
(Reed C. Davis prepared this response and is the recordholder. It has not been
determined who will sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
IDAHO
P AC-07-
ROCKY MOUNTAIN POWER
AGRIUM DATA REQUESTS (1-
ATTACHMENT AGRIUM 5
ON THE ENCLOSED CD
PAC-07-0S/Rocky Mountain Power
August 22, 2007
Agrium Data Request 7
Agrium Data Request 7
Provide all work papers used to normalize revenues as shown in Tab 3 of Exhibit
11. Include metered test year loads and revenues and all adjustments with
explanations to adjust actual loads and revenues.
Response to Agrium Data Request 7
Please see Attachment Agrium 7 on the enclosed CD for work papers used to
normalize revenues as shown in Tab 3 of Exhibit 11. The work paper labeled
Billing Determinants" includes the metered test loads and revenues, the work
paper labeled "Table 3" contains the revenue adjustments with footnoted
explanations and the work paper labeled "Table 2" contains the load adjustments
with footnoted explanations. The attachment also contains additional supporting
work papers used to normalize revenues.
(Michael Zimmerman prepared this response and is the recordholder. William R.
Griffith is expected to sponsor this response at hearing. Please contact Brian
Dickman at 801-220-4975 to discuss this response.
IDAHO
P A C- E-07 -
ROCKY MOUNTAIN POWER
AGRIUM DATA REQUESTS (1-
TT ACHMENT AGRIUM 7
ON THE ENCLOSED CD
PAC-07-05/Rocky Mountain Power
August 22, 2007
Agrium Data Request 8
Agrium Data Request 8
Please provide all work papers related to the testimony ofPacifiCorp s witnesses.
Response to Agrium Data Request 8
The requested work papers were provided in response to Monsanto Set 1 , a copy
of which was provided to Agrium.
(Please contact Brian Dickman at 801-220-4975 to discuss this response.