20071009PAC to Staff 1-30.pdf

John R. Hammond, Jr., ISB No. 5470
FISHER PUSCH & ALDERMAN LLP
U S Bank Plaza, 5th Floor
101 South Capitol Boulevard
O. Box 1308
Boise, Idaho 83701
[phone]
[phone] facsimile
irh~fpa-law .com.com
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Justin Lee Brown
Pro Hac Vice Admission Pending
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Fax: [phone]
Email: iustin.brown~pacificorp.com
Attorneys for Rocky Mountain Power
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-O7-
DATA REQUESTS
ROCKY MOUNTAIN POWER'
FIRST SET OF DATA REQUESTS TO STAFF
Pursuant to Rules 222 and 225 of the Idaho Public Utilities Commission Rules of
Procedure, Rocky Mountain Power, a division of PacifiCorp (herein
, "
Rocky Mountain
Power" or "Company ), by and through its counsel, herein submits its first set of data
requests to the Idaho Public Utilities Commission Staff ("Staff') and requests that Staff
respond, in writing, within fourteen (14) days after service hereof, to the following data
requests:
ROCKY MOUNTAIN POWER'S FIRST Page
SET OF DATA REQUESTS TO STAFF
DEFINITIONS AND INSTRUCTIONS
The following definitions and instructions apply to each of the requests for production
set forth herein and are deemed to be incorporated therein.
(1)Document" and "documentation" should be interpreted as broadly as
possible to include, but not be limited to, the original or any copy, regardless of origin or
location, of any book, pamphlet, periodical publication, letter, scrapbook, diary, calendar
canceled check, photograph, form, memorandum, schedule, tax return, telegram, telex
report, record, order or notice of governmental action of any kind, study, minutes, logs
graph, index, tape, disc, internal operating manual, data sheet or data processing card, or any
other written, recorded, transcribed, punched, taped, filmed, graphic or retrievable matter or
data of any kind, however produced or reproduced, to which you have or have had access.
This definition is intended to include, but not be limited to, all documents which have been
created and/or which reside in any type of electronic format and is to be construed in its most
comprehensive sense as contemplated by the Idaho Rules of Civil Procedure.
(2)You" shall mean the Staff; and the employees, officers, directors, agents
consultants, attorneys and all persons acting under contractual arrangement with or acting or
purporting to act on behalf of Staff.
(3)Person or Entity" should be interpreted to denote, unless otherwise
specified, any natural person, firm, corporation, association, group, individual or organization
of any type whatsoever.
(4)Any request to "identify" or "provide" should be interpreted to mean:
With respect to a natural person, that person s full name, title, job
description, and business and home address. Where the identification pertains to a past
ROCKY MOUNTAIN POWER'S FIRST Page 2
SET OF DATA REQUESTS TO STAFF
period, as to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided, in addition
that person s title and job description as ofthe time of such past period. Where the person is
no longer in your employ or the employment of the group with which such person is
identified in response to any request, provide that person s affiliate, position, home and
business address, if known, or if not known, such person s last known affiliation, position
home and business address, or portions thereof as may be known.
With respect to an entity other than a natural person, that entity's name
business, type of entity, present status and present or last known address.
With respect to a document, that document's title, date, author (and, if
different, the signer), addresses, recipients, or other persons who assisted in the preparation
subject matter or general nature, and any amendments thereto, present location and
custodian, whether or not such document is in the respondent's possession, custody or
control and whether or not the document is claimed to be privileged. The final version and
each draft of each document should be identified and produced separately. Each original and
each non-identical copy (bearing marks or notations not found on the original) of each final
version and draft of each document should be identified and produced separately.
With respect to a physical facility, the location of the facility, the
intended purpose of the facility, the actual use of such facility, the operating dates of the
facility, the installation date of the facility, the date utilization of the facility terminated if
applicable, and whether the facility is subject to the jurisdiction of the Federal Energy
Regulatory Commission, the Idaho Public Utilities Commission, or any other regulatory
body.
ROCKY MOUNTAIN POWER'S FIRST Page 3
SET OF DATA REQUESTS TO STAFF
(5)Communication" should be interpreted to include, but not be limited to, all
forms of communication, whether written, printed, oral, pictorial, electronic or otherwise
including testimony or sworn statement, or any means or type whatsoever.
(6)Relating To" or "Related To" means pertaining to, presenting, discussing,
commenting on, analyzing, or mentioning in any way.
(7)The term "and" and "" should be construed either disjunctively or
conjunctively whenever appropriate in order to bring within the scope of each request any
information or document which might otherwise be considered to be beyond its scope.
(8)The singular form of a word should be interpreted as plural, and the plural
form of a word should be interpreted as singular, whenever appropriate in order to bring
within the scope of each request any information or document which might otherwise be
considered to be beyond its scope.
DATA REQUESTS
Bryan Lanspery. Please explain how the IRP serves as a guide for the future
acquisition of new resources (page 26, lines 21-23) and provide all documents relied upon or
that reasonably relate to this position.
Bryan Lanspery. Please provide all documents relied upon or that reasonably
relate to your statement on page 26 (lines 23-25) of your prefiled direct testimony that the
decision to pursue acquisition of new wind generation is based on the cost and risk analysis
included in the Company s IRPs." Which specific IRPs are included in this statement?
Bryan Lanspery. Please quantitatively define the word "consistent" as used by
you in your prefiled direct testimony on page 27 , line 3. What percentage do you consider
consistent" as that term is used by you on page 27, line 3 of your prefiled direct testimony?
ROCKY MOUNTAIN POWER'S FIRST Page 4
SET OF DATA REQUESTS TO STAFF
Bryan Lanspery. Please define the word "best" as that term is used by you on
page 27, line 5 of your prefiled direct testimony.
Bryan Lanspery. Regarding Staffs testimony at page 27, lines 5-, would,
such "refreshing" of prices require a full IRP update or be handled in some other manner?
Does Staff maintain the position that the IRP cost assumptions for all new resource types
(wind, coal, and natural gas) should also be "refTeshed" if bid prices are below the IRP
assumptions when acquiring new resources? Please explain your responses.
Bryan Lanspery. In your pre filed direct testimony at page 10, lines 23-, you
imply that the irrigation curtailment credit is currently priced "at or near marginal costs." Is
your position that the current level of the curtailment credit is reasonable because it is priced
at marginal costs? Please explain your response.
Bryan Lanspery. If the irrigation curtailment credit was treated as a system
expense, would it be appropriate to add back the curtailed demand to the JAM and the cost of
service model, as is currently done with Monsanto s load curtailment? Please explain.
Bryan Lanspery. Please explain how you propose Rocky Mountain Power
recover the cost of Idaho demand-side management incentive payments to irrigators if other
states do not agree that the payments should be system-allocated?
Bryan Lanspery. Does Staff believe that Idaho should be allocated its share of
system-allocated costs for demand side management programs similar to Idaho s irrigation
load control program in other states? Please explain.
10.Bryan Lanspery. Please provide all documentation or other evidentiary
support for Staff s position at page 7, line 13 that Staff s allocation proposal for the irrigation
load control program is not contrary to the guidelines ofthe Revised Protocol.
ROCKY MOUNTAIN POWER'S FIRST Page 5
SET OF DATA REQUESTS TO STAFF
11.Bryan Lanspery. Please identify all parties to whom you would expect to
participate in a new docket on line extension policies if the Idaho Public Utilities
Commission accepted your recommendation to open a subsequent docket to address this
Issue.
12.Bryan Lanspery. Would you agree that one reason why the irrigation load
should remain situs is because there is no loss of revenue to the company, because load is
simply shifted to off-peak times? If no, please explain.
13.Bryan Lanspery. Please explain what an adequate sample load consists of as
referenced by you on page 16 of your prefiled direct testimony.
14.Bryan Lanspery. Regarding your testimony at page 4, lines 1-, is Staffs
position that an increase in Monsanto s rates should change the credit provided to Monsanto
for interruptibility? Please explain your response.
15.Bryan Lanspery. Please specifically identify the "methods of valuation
approved in Order No. 30197 which Staff used to determine the increase in economic
curtailment and system integrity components of the Monsanto credit in this case. Please
provide any documents from this case which reflect Staff s position on these methods of
valuation and any calculations of the Monsanto credit using these methods.
16.Bryan Lanspery. Please provide all workpapers for Staffs proposed increase
of 14% for the Monsanto credit in this case.
17.Bryan Lanspery. What additional information would have been required to
calculate the operating reserve component? Why does Staff believe that a 14% increase is
conservative, as indicated on page 5, line 15 of Staff s testimony?
ROCKY MOUNTAIN POWER'S FIRST Page 6
SET OF DATA REQUESTS TO STAFF
18.Bryan Lanspery. Regarding Staffs testimony at page 5 , lines 17-, please
explain the relationship between increases in the forward price curve and the valuation of the
Monsanto credit. Is Staff s position that increases in the forward price curve should always
result in a corresponding increase in the Monsanto credit?
19.Joe Leckie. Please explain why you are viewing the company s incentive pay
in the short term as opposed to the long term. How is this position consistent with your
position on page 9 of your testimony that over the long term customers benefit fTom meeting
budgets, but viewed in short run the immediate benefits go to shareholder?
20.Joe Leckie. Do you agree that operating within budget is an essential element
of achieving financial objectives that benefit customers? Please explain.
21.Patricia Harms. Please indicate the policy you are referring to on page 9 of
your testimony when you indicate that Staffs recommendation regarding major plant
additions is consistent with policy used for major plant additions in other cases. Please
identify any and all supporting documentation for this policy.
22.Pactricia Harms. Please provide workpapers, analysis, documents used for
preparing Exhibits 108-113.
23.Terri Carlock. Please provide copies of all work papers, analyses, documents
or other references/citations used by Ms. Carlock in preparing Exhibit 120.
24.Terri Carlock. Please provide Ms. Carlock's imputed system revenues on a
$/MWh basis for each referenced project in Exhibit 120.
25.Terri Carlock. Please provide the energy (in MWh) on a per project basis
associated with Ms. Carlock's imputed system revenues in Exhibit 120.
ROCKY MOUNTAIN POWER'S FIRST Page 7
SET OF DATA REQUESTS TO STAFF
26.Terri Carlock.Please identify the reference for each of Ms. Carlock'
calculation assumptions in preparing Exhibit 120.
27.Terri Carlock. Please provide copies of all work papers, analyses, documents
and other material relied upon or that Staff anticipates relying upon in support (including
electronic with active formulas) of its REC adjustment.
28.Terri Carlock. In your REC adjustment, what review was done on the need
for the pro forma REC adjustment? Was the pro forma adjustment caused by additional sales
related to the new wind plants, and does doing both adjustments cause a double count?
29.Terri Carlock. Please provide copies of all work papers, analyses, documents
and other material relied upon or that Staff anticipates relying upon in support (including
electronic with active formulas) of its return on equity recommendations.
30.Please produce anYJ and all documents that Staff expects or reasonably
anticipates introducing into evidence at a hearing in the above-captioned docket.
DATED this 9th day of October, 2007.
ROCKY MOUNTAIN POWER'S FIRST Page 8
SET OF DATA REQUESTS TO STAFF
Respectfully submitted
ROCKY MOUNTAIN POWER
John . ammond, Jr., ISB No. 5470
FIS E PUSCH & ALDERMAN LLP
ank Plaza, 5th Floor
101 South Capitol Boulevard
O. Box 1308
Boise, Idaho 83701
[phone]
[phone] facsimile
irh~f-pa-law .com
-and-
Justin Lee Brown
Rocky Mountain Power
201 South Main Street, Suite 2300
Salt Lake City, Utah 84111
Telephone: [phone]
Fax: [phone]
Email: iustin.brown0J,pacificorp.com
ROCKY MOUNTAIN POWER'S FIRST Page 9
SET OF DATA REQUESTS TO STAFF
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 9th day of October, 2007, a true and correct copy of
the foregoing document was served by first-class mail, postage prepaid, and addressed to; by
fax transmission to; by overnight delivery to; or by personally delivering to or leaving with a
person in charge of the office as indicated below:
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, Idaho 83720-0074
Email: iean.iewellC?0puc.idaho.gov
J U.S. Mail
J Facsimile
( J Overnight Delivery
K) Hand Delivery
~. l' Email
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise, ill 83720-0074
neil. price~puc.idaho. gov
J U.S. Mail
J Facsimile
( J Overnight Delivery
LXI Hand Delivery
l Email
Data Request Response Center
PacifiCorp
825 N. E. Multnomah, Suite 2000
Portland, OR 97232
e-mail: datarequest0!pacificorp.com
J U.S. Mail
J Facsimile
J Overnight Delivery
J Hand Delivery
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Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
O. Box 83720
Boise, ill 83720-0074
scott. woodburv0J,puc.idaho. gov
Attorney for Commission Staff
( J U.S. Mail
J Facsimile
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( 1 Email
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ill 83276
E-mail: iim.r.smith0!monsanto.com
J U.S. Mail
J Facsimile
( J Overnight Delivery
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Email Only
ROCKY MOUNTAIN POWER'S FIRST Page 10
SET OF DATA REQUESTS TO STAFF
Randall C. Budge
Racine, Olson, Nye, Budge
& Bailey, Chtd.
O. Box 1391
Pocatello, Idaho 83204- 1391
Email: rcb(0racinelaw.net
Attorneys for Monsanto Company
( J u.S. Mail
( J Facsimile
( J Overnight Delivery
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(,1(1 Email
Maurice Brubaker
Katie Iverson
Brubaker & Associates
17244 W. Cordova Court
Surprise, AZ 85387
Email: mbrubaker0J,consultbai.com
ki v erson~consul tbai. com
Consultant for Monsanto Company
( J u.S. Mail
( J Facsimile
( J Overnight Delivery
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(Xl Email
Eric L. Olsen
Racine, Olson, Nye, Budge
& Bailey, Chtd.
201 E. Center
O. Box 1391
Pocatello, Idaho 83204-1391
Email: eloC?0racinelaw.net
Attorneys for Idaho Irrigation Pumpers Association, Inc.
( J u.S. Mail
( J Facsimile-
J Overnight Delivery
( J Hand Delivery
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Email
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
E-mail: tony0J,yankel.net
Consultant for Idaho Irrigation Pumpers
Association, Inc.
J u.S. Mail
J Facsimile
( J Overnight Delivery
( J Hand Delivery
D(J Email
Idaho Irrigation Pumpers
Association, Inc.
c/o Lynn Tominaga
O. Box 2624
Boise, ill 83701-2624
E-mail: Ivnn tominaga0!,hotmail.com
( J u.S. Mail
J Facsimile
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( J Hand Delivery
Email
Tim Buller
Agrium, Inc.
3010 Conda Road
Soda Springs, Idaho 83276
E-mail: tbullerC?0agrium.com
( J U.S. Mail
( J Facsimile
J Overnight Delivery
( J Hand Delivery
Email
ROCKY MOUNTAIN POWER'S FIRST Page 11
SET OF DATA REQUESTS TO STAFF
Conley E. Ward
Michael C. Creamer
Givens Pursley LLP
608 W. Bannock Street
P. O. Box 2720
Boise, ill 83701-2720
E-mail: cewC?0givenspurslev.com
Attorneys for Agrium, Inc.
J u.S. Mail
( J Facsimile
( J Overnight Delivery
( J Hand Delivery
Email
Dennis Peseau, Ph.
Utility Resources, Inc.
1500 Liberty Street S, Ste. 250
Salem, OR 97302
E-mail: dpeseau~excite.com
Consultant for Agrium, Inc.
J U.S. Mail
J Facsimile
( J Overnight Delivery
J Hand Delivery
(X'J Email
Brad M. Purdy
Attorney at Law
2019N.17thStreet
Boise, ill 83702
Email: bmpurdv~hotmail.com
Attorneys for Community Action
Partnership Association of Idaho
( J U.S. Mail
J Facsimile
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( J Hand Delivery
()Q Email
Kevin B. Homer, Esq.
1565 South Boulevard
Idaho Falls, ill 83404
Email: kbhC?0khomerlaw.com
Attorney for Timothy Shurtz
Tim Shurtz
411 S. Main
Firth, Idaho 83236
Email: tim~idahosupreme.com
J U.S. Mail
J Facsimile
J Overnight Delivery
J Hand Delivery
(yJ Email
J u.S. Mail
( J Facsimile
( J Overnight Delivery
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(Xl Email
ROCKY MOUNTAIN POWER'S FIRST Page 12
SET OF DATA REQUESTS TO STAFF