20070627Staff to PAC 1-3.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
,' '
:' r' ,i" L.
' '" '; : ,
,' , 1 ::.
..
.. i"
:~ , ,
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
ROCKY MOUNTAIN POWER FOR AN ORDER)
REVISING CERTAIN OBLIGATIONS TO
ENTER INTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-POWERED
SMALL POWER GENERATION QUALIFYINGFACILITIES
CASE NO. P AC-07- 7
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain Power) provide the following documents and information as soon
as possible, but no later than WEDNESDAY, JULY 18, 2007.
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.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person( s) and the witness who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER JUNE 27 , 2007
REQUEST NO.1: Please provide an estimate of the cost to purchase state-of-the-art
wind forecasting services as referenced in the Company s Petition. Please provide a detailed
description of how each QF's share ofthe on-going cost of the wind forecasting services will be
determined. For what length of time would QFs be required to make a contribution for the cost
of forecasting services? How would costs be allocated amongst QFs that are built at different
points in time?
REQUEST NO.2: Among other things, the Company s Petition seeks a Commission
order "Clarifying that the cap on entitlement to published avoided cost rates shall be restored to
10 aMW only until PacifiCorp s renewable targets for each calendar year in the most recently
acknowledged Integrated Resource Plan are met." Please clarify whether the Company
proposal as stated in its Petition is intended to mean that the Company will recompute its wind
integration cost when its IRP renewable targets are met or whether it is intended to mean that a
new cap on entitlement to published avoided cost rates would be restored at that time.
REQUEST NO.3: Please explain how the proposed "mechanical availability
guarantee" will be computed during periods of time when there is not enough wind blowing for
wind turbines to generate.
DATED at Boise, Idaho , this c;tday of June 2007.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/paceO7,7swrps prod reg!
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER JUNE 27, 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF JUNE 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:
BRIAN DICKMAN
P ACIFICORP
DBA ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
MAIL: brian. dickman~pacificorp. com
DATA REQUEST RESPONSE CENTER
P ACIFICORP
825 NE MULTNOMAH STE 2000
PORTLAND OR 97232
MAIL: datarequest~pacificorp. com
DEAN 1. MILLER
McDEVITT & MILER LLP
PO BOX 2564
BOISE, ID 83701-2564
MAIL: ioe~mcdevitt-miller.com
STEPHEN E. MARTIN
INTERM 0 UNT AIN WIND LLC
425 S. HOMES
PO BOX 3189
IDAHO FALLS , ID 83403-3189
SECRETAR
CERTIFICATE OF SERVICE