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Home My WebLink About20070824Staff to PAC 56-66.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 ISB NO. 1895 RECEIVED Zlifi1 AUG 2LJ \ 2: 51 d~;1J(i.;\ \ li s ! I) N 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. P AC-07- FOURTH 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 FRIDAY, SEPTEMBER 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, location FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER AUGUST 24, 2007 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. 56: Please provide a summary of all green tag or Renewable Energy Credit (REe) purchases or sales for the Wolverine Creek, Marengo, Leaning Juniper and Goodnoe Hills projects. For each project and for each purchase or sale, list the date of the transaction, the quantity of green tags or RECs purchased or sold, the price and the term of the purchase or sale. Please compare the actual purchase or sale price of the green tags or RECs to the price assumed in the economic analysis for the project. REQUEST NO. 57: Please explain the interconnection/transmission credits and the Energy Trust of Oregon credits associated with the Goodnoe Hills project. What is the basis for the credits? How are the credit amounts computed? Have any funds yet been received from the Energy Trust of Oregon? If not, has the Energy Trust made a firm commitment of funds to the Goodnoe Hills project? REQUEST NO. 58: The differential present value revenue requirement of the Goodnoe Hills project is $0 on the total project basis (inclusive of avoided market purchases) if the value of green tags or the cost of compliance with renewable portfolio standards (RPS) rise to approximately $6.37 per MWh during each year of the project's life. The comparative assumption in PacifiCorp most recently published Integrated Resource Plan is $5 per MWh for 5-years or $1.79 per MWh FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER AUGUST 24, 2007 during each year of the project's life. Please provide any evidence or analysis supporting a value for green tags or RPS compliance of$6.37 or greater over the next 20 years. REQUEST NO. 59: Please compute the present value revenue requirement and the levelized cost of energy for the Goodnoe Hills proj ect assuming a value for green tags of $5 per MWh for the first five years of the proj ect life. REQUEST NO. 60: Please provide information describing the BP A Conservation and Renewable Discount Program, the amounts of funding available under the program and the requirements for projects to qualify or be awarded funding. REQUEST NO. 61: What is the typical length oftime before an account is sent to an outside collection agency after it has gone through the automated customer match program? REQUEST NO. 62: Please provide copies of tariff pages for Schedule 300 for California Oregon, Utah, Washington, and Wyoming. REQUEST NO. 63: In reference to the Company s response to IPUC Production Request No. 41 , how many after-hours reconnections require pole work? How many after-hours reconnections were performed on three-phase service? REQUEST NO. 64: Please explain why collectors are not made available to perform after- hours reconnections? REQUEST NO. 65: Please provide all analyses the Company conducted to deduce the Demand and Energy Loss Factors. If applicable, include all workpapers in executable format. REQUEST NO. 66: With regard to Electric Service Schedules 6 and 23 a. Please state how the Company determines which schedule a customer would fall under. FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER AUGUST 24, 2007 b. Please provide language in the tariff that would direct or dictate which schedule a customer may fall under? c. Did the Company transfer any customers from Schedule 23 to Schedule 6 during the test year, or vise versa? If so, how many, when and why? d. How many customers in each schedule qualified for the Voltage Discount in the test year 2006, and what was the associated dollar amount paid out during 2006? DATED at Boise, Idaho, this ;;..., %ay of August 2007. ~~~~~ Neil Price Deputy Attorney General Technical Staff: Rick Sterling Daniel Klein Bryan Lanspery i:umisc:prodreq/paceO7.5nprpsdkbl prod req4 FOURTH PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER AUGUST 24, 2007 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF AUGUST 2007 SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, CASE NO. PAC-07-, BY MAILING A COpy THEREOF, POSTAGE PREPAID TO THE FOLLOWING: DEAN BROCKBANK mSTIN BROWN ROCKY MOUNTAIN POWER 201 S MAIN ST STE 2300 SALT LAKE CITY UT 84111 MAIL: dean.brockbank~pacificorp.com iustin. brown~pacificorp. com DATA REQUEST RESPONSE CENTER P ACIFICORP 825 NE MUL TNOMAH STE 2000 PORTLAND OR 97232 MAIL: datarequest~pacificorp.com (ELECTORNIC COPIES ONLY) JAMES R SMITH MONSANTO COMPANY PO BOX 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 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~racine1aw.net MAURICE BRUBAKER KATIE IVERSON BRUBAKER & ASSOCIATES 1215 FERN RIDGE P ARKW A Y SUITE 208 ST LOUIS MO 63141 MAIL: mbrubaker~consu1tbai.com kiverson~consu1tbai.com ANTHONY Y ANKEL 29814 LAKE ROAD BAY VILLAGE OH 44140 MAIL: tony~yanke1.net DENNIS E PESEAU, Ph. UTILITY RESOURCES INC 1500 LIBERTY ST SE STE 250 SALEM OR 97302 MAIL: dpeseau~excite.com CERTIFICATE OF SERVICE BRAD M PURDY ATTORNEY AT LAW 2019 N 17TH STREET BOISE ID 83702 MAIL: bmpurdy~hotmai1.com TIMOTHY SHURTZ 411 S. MAIN FIRTH ID 83236 MAIL: tim~idahosupreme.com Jd~ SECRET CERTIFICATE OF SERVICE