20081215Staff 68-101 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
POBOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
RECEIVED
2608 DEC l 5 PH ~: 30
IDAHO PU8UG ,
UTILITiES COrAMiEiSl0i!
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 APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES. )
)
)
)
)
CASE NO. P AC-E-08-7
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Scott Woodbur, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than MONDAY, JANUARY 5, 2009.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementar 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.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 DECEMBER 15,2008
REQUEST NO. 68: On page 5, line 13, of Jeff Bumgamer's pre-filed testimony is the
statement that "...a great many (customers) have directly benefitted from the programs offered."
Please provide an estimate for the number of different customers by customer class who have
participated in one or more of Rocky Mountain Power's energy efficiency programs from 2006
through 2007.
REQUEST NO. 69: Please provide a copy of all the customer communications
materials curently used by Rocky Mountain Power to promote customer paricipation in its
energy effciency and demand response programs.
REQUEST NO. 70: Please provide a copy of Rocky Mountain Power's marketing plan
for its energy efficiency and demand response programs. Please provide a description and
schedule for TV, newspaper, radio advertising, bil inserts, direct mailers, etc. used to promote
these programs. Does Rocky Mountain Power or its vendors taget high energy users and
directly contact them to offer an audit to see how energy usage can be reduced? If not, why not?
Please explain.
REQUEST NO. 71: For each Idaho-fuded DSM program please provide a breakdown
of annual and 2-year total costs, including incentive payments to paricipants, direct program
administrative costs, direct program evaluation costs, and allocated indirect administrative and
evaluation costs with a description of how such allocations were made.
REQUEST NO. 72: For each Idaho-fuded DSM program please provide the pre-
implementation estimated post-implementation evaluation budget, the amount actully spent on
post-implementation evaluations through 2007, and the amount spent for such evaluations in
2008 YTD. Where Idaho costs are an allocation of larger costs, explain how the allocation was
determined.
REQUEST NO. 73: Please list and briefly describe all post-implementation evaluations
of Idaho-fuded DSM programs or general DSM management completed by or for Rocky
Mountain Power from 2006 through 2008 to date. Include in the descriptions the evaluation
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER 15,2008
costs and the names and affiliations of the primary evaluators and the process(es) by which any
3rd part evaluators were chosen. Also provide copies of, or easily accessible references to, each
report listed. Include both internal and external evaluations of direct energy and peak demand
impacts, program processes, portfolio management, and educational and/or market
transformation effects.
REQUEST NO. 74: Please describe how post-implementation evaluations have been
used by Rocky Mountain Power to improve its DSM programs and/or to improve its overall
resource planing. Include supporting discussion notes, letters and memorandums, all whether
on paper or electronically distributed.
REQUEST NO. 75: Please provide post-implementation benefit/cost (B/C) ratios
estimated by or for Rocky Mountain Power with electronically executable cost-effectiveness
formulae. Include complete descriptions of, and bases for, all assumptions (e.g. net-to-gross
savings ratios), values (e.g. demand, energy and non-energy savings) and calculations used in
estimating the B/C ratios. Describe all sensitivity analyses of any non-firm variables and
assumptions used in estimating B/C ratios.
REQUEST NO. 76: To the extent that assumptions and variable values of post-
implementation B/C ratios differ from those used in pre-implementation DSM "potential"
studies, please describe and explain those differences.
REQUEST NO. 77: Please describe any post-implementation DSM program
evaluations that are not yet completed, but are currently in progress.
REQUEST NO. 78: Please describe any post-implementation DSM program
evaluations that are curently in a planing stage.
REQUEST NO. 79: Beginning on page 18, line 14, of Jeff Bumgamer's pre-fied
testimony is an implication that if DSM benefits exceed DSM costs, then the DSM is de facto
prudent. Is a B/C ratio greater than 1.0 Rocky Mountain Power's sole criterion for determining
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 DECEMBER 15,2008
the success of a DSM program? Or does the Company also evaluate program success based on
possible alternative demand-side costs, e.g. whether DSM administration and overhead is
reasonable and whether a program's customer incentives are set to maximize net utilty benefit?
If so, please provide documented examples of the use of such.
REQUEST NO. 80: On page 14, lines 19-21, of Jeff Bumgamer's pre-fied testimony is
an estimate of NEE A savings of 6,054 MWH in 2006 and 3,957 MWH in 2007 for Rocky
Mountain Power's Idaho service area. Please provide the assumptions and calculations the
Company and/or NEEA used to estimate those savings numbers and any Rocky Mountain Power
analyses of the veracity of those electricity savings and the value of such savings.
REQUEST NO. 81: Please provide copies of customer and vendor complaints to Rocky
Mountain Power or its contractors from 2006 through 2008 regarding any of its DSM programs.
REQUEST NO. 82: Please specifically identify and quantify any Tariff Schedule 191
fuds that have been used for personnel, administration and/or marketing expenses related to
promotion of renewable energy resources (e.g. Blue Sky and/or Tariff Schedules 70 and 135) or
expenses related to bil payment assistance (e.g. Lend A Hand).
REQUEST NO. 83: Please provide copies of all demand side management (DSM, e.g.
energy efficiency, conservation or demand response) business plans prepared by or for Rocky
Mountain Power from 2005 through 2008 in which its Idaho service area is included.
REQUEST NO. 84: Please provide an organization char of the Demand Side
Management unit, including its placement within the larger organization.
REQUEST NO. 85: Please provide names and job titles with descriptions of duties for
all Rocky Mountain Power employee positions in the Demand Side Management unit.
REQUEST NO. 86: Please provide the salary range, bonus range, and total
compensation range including benefits for each employee in the Demand Side Management unit.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 DECEMBER 15,2008
REQUEST NO. 87: Please provide resumes of all employees in the Demand Side
Management unit. (Home addresses and telephone numbers and other personal information may
be redacted).
REQUEST NO. 88: Please explain how the Company determined that a ~ mile or
greater line extension constituted a remote line extension justifying an anual service charge.
Are they any circumstaces where the service charge would be waived? Please explain.
REQUEST NO. 89: Please provide a line item detail showing the amount and how each
component (e.g. Retur on Capital, Recovery of Capital, State and Federal Income Taxes, Local
Property Taxes, Operations and Maintenance, Administrative and General, Other Taxes,
Customer Accounts and Services, and Capital Replacement Anuity) in the Facilties Charge
contributes to 0 & M expenses. In your response please make it clear what is included. For
example, is the 0 & M component based on average 0 & M expense for the entire Company,
average 0 & M expense for distribution facilties only, or 0 & M expense for the distribution
facilties associated with each paricular project.
a. Please explain how the 0.67 percent customer contribution was determined and
how each component included in the calculation relates to this percentage.
b. Similarly, please explain how the 1.67 percent Company contribution was
determined and how each component included in the calculation relates to this
percentage.
REQUEST NO. 90: For a residential line extension in a remote area, the Company's
curent Utah taiff states "the Applicant shall pay a Contract Minimum Billng for as long as
service is taken, but in no case more than 15 years nor less than five years." The Company's
curent tariff in Idaho states "the Applicant shall also pay a Contract Minimum Biling for as
long as service is taen, but in no case less than 5 years."
a. Why is it that Idaho does not have a time limitation for the Contract Minimum
Biling provision stated in its tariff? Please explain and provide supporting
information as necessary.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 DECEMBER 15,2008
b. In Idaho, does the Contract Minimum Biling provision terminate at some point?
Please explain.
c. Does the Company re-calculate the charges when additional load is added to a
line for which a customer is curently paying a facilities charge to determine
whether a Contract Minimum Bilinglacilties Charge is stil needed to cover
o & M expense on that line? Please explain.
REQUEST NO. 91: Curently, how many customers are paying a facilties charge? For
each of those customers, please provide the following information: class of service; amount of
the facilties charge; total length of line extension upon which the facilties charge is based; and
number of months the customer has paid a facilties charge.
REQUEST NO. 92: For 2006, 2007 and YTD 2008, please provide the number of
customers who paid a facilties charge for at least one month during that calendar year.
REQUEST NO. 93: As a condition of the transfer of the Site Certification Agreement
from Chehalis Power to PacifiCorp, Washington State Energy Facilty Site Evaluation Council
Order No. 836 requires PacifiCorp to provide $1.5 milion in fuding for greenhouse mitigation
projects. Does PacifiCorp intend to add or modify equipment at the plant, or change its historic
operations, such that it wil emit more greenhouse gases than it has historically? If so, is this the
basis for requiring PacifiCorp to provide the $1.5 milion? If not, what is the justification for
providing the $1.5 milion?
REQUEST NO. 94: On page 8 lines 7-8 of the testimony of Stephan Bird, a comparison
is made between the cost of the Chehalis plant and PacifiCorp's Lake Side plant. What was the
cost per kW for PacifiCorp's Curant Creek plant?
REQUEST NO. 95: With the recent global credit crisis and the dramatic downtur in
the economy, does PacifiCorp believe that the estimated costs for constructing new combined
cycle plants will be higher or lower than the costs used for comparson puroses in the Chehalis
analysis (i.e., combined cycle costs that were based on results of the Company's 2012 RFP)?
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 DECEMBER 15, 2008
REQUEST NO. 96: Please provide an unedacted copy ofthe Direct and Supplemental
Testimony of Wayne Oliver, Merrimack Energy, and all comments and reports of Merrimack
Energy Group submitted in Utah Public Service Commission Docket No. 08-035-35, Request for
Waiver of Solicitation Process and for Approval of Significant Energy Resource Decision.
REQUEST NO. 97: Please provide a copy of the Bodington & Company Report and
all comments of Bodington & Company submitted in Uta Public Service Commission Docket
No. 08-035-35.
REQUEST NO. 98: Please provide an unedacted copy of the Testimony and Exhibits
of Charles Peterson, Utah Division of Public Utilties submitted in Utah Public Service
Commission Docket No. 08-035-35.
REQUEST NO. 99: Please provide a copy ofPacifiCorp's response to data requests
IEl.ll and IE3.1 made by the independent evaluator in Utah Public Service Commission Docket
No. 08-035-35. The responses purortedly show detailed results of an economic analysis of the
Chehalis plant compared to all proposals and benchmarks submitted and evaluated in response to
the 2012 RFP. In addition, please provide specific project cost information about the Chehalis
plant along with the assumptions, inputs, and specific cost information used in the analysis.
Please provide electronic copies of all excel spreadsheets with formulas intact.
REQUEST NO. 100: Please provide a copy of the following report submitted in Docket
UM 1374 of the Oregon Public Utilties Commission: Craig R. Roach, Fran Mossburg and
Stuar Rein, Boston Pacific Company, Inc., "An Analysis ofPacifiCorp's Waiver Request for the
Chehalis Power Generating Plant," presented to the Oregon Public Utilties Commission,
June 18,2008.
REQUEST NO. 101: What efforts, ifany, are being made to reduce the number of
payment arangement agreement defaults?
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 DECEMBER J 5, 2008
DATED at Boise, Idaho, this ,ø day of December 2008.
~a'~4~A.
.. ott Woodbury
o Deputy Attorney General
Technical Staff: Lynn Anderson #68 - 87
TJ Golo #88 - 92
Rick Sterling #93 - 100
Curis Thaden # 1 0 1
i:umisc:prodreq/pace08.7swlatj prod req 4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 DECEMBER 15, 2008
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF DECEMBER 2008,
SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-08-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
TED WESTON
MGR, ID REGULATORY AFFAIRS
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(fpacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datareguest(fpacificorp.com
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA COURT
SURPRISE AZ 85387
E-MAIL: kiverson(fconsultbai.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
201 ECENTER
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(fracinelaw.net
BRADMPURDY
ATTORNEY AT LAW
2019N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
DANIEL SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solanderaYacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE & BAILEY
201 ECENTER
PO BOX 1391
POCATELLO ID 83204
E-MAIL: rcb(fracinelaw.net
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(fmonsanto.com
ELECTRONIC COPIES ONLY
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyanel.net
CONLEY E WARD
MICHAEL C CREAMER
GIVENS PURSLEY LLP
601 W BANNOCK ST
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: cew(fgivenspursley.com
CERTIFICATE OF SERVICE
DENNIS E PESEAU PhD
UTILITY RESOURCES INC
1500 LIBERTY ST SE
SUITE 250
SALEM OR 97302
E-MAIL: dpeseau(fexcite.com
\~~.~
SECRE ARY
CERTIFICATE OF SERVICE