20090306Staff 1-8 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
Street Address for Express Maìl:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECE ~:rì
in09 MAR -6 PM 2: 20
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL)
OF AN ENERGY COST ADJUSTMENT )MECHANISM. )
)
)
)
)
CASE NO. P AC-E-08-8
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
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 Rocky Mountain Power (Company;
Rocky Mountain) provide the following documents and information as soon as possible, but no
later than FRIDAY, MARCH 27, 2009.
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 wil 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. In
addition to the written copies provided as response to the questions, please provide all Excel and
electronic fies on CD with formulas activated and operationaL.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER MARCH 6, 2009
REQUEST NO.1: Please provide a backcast of the methodology that the Company is
proposing for the period January 2006 to present. Show how the accounts included in the
ECAM mechanism would have changed over the period and why the calculation of the Energy
Cost Adjustment Mechanism (ECAM) rate for each anual period and how the monthly deferral
balance would have changed during the period when ECAM rates were in effect.
REQUEST NO.2: Please provide the same backcast information provided for Request
No. 1 with ECAM methodology modified to include:
a) 90/1 0 customer/company sharing of deferred power supply costs
b) An adjustment of $30/MWH for load above or below monthly normalized
loads approved by the Commission
c) An anual interest rate of 2% applied to the deferral balance
REQUEST NO.3: Please provide a description of power supply tracking mechanisms
either existing or proposed in other PacifiCorp state jurisdictions. Include in the description the
power supply accounts tracked and the history of rate adjustments since inception.
REQUEST NO.4: Please describe the risk management strategy employed by the
Company for market energy/capacity purchases and how that strategy could/wil impact the
power supply costs that flow through the proposed ECAM mechanism.
REQUEST NO.5: Please provide the unbundled production revenue requirement per
kWh on a system basis that is curently embedded in rates.
REQUEST NO.6: To evaluate the impact of an Idaho ECAM on corporate financial
statements, please quantify and provide the workpapers showing the anual impact on total
Company earings. Please include at least the impact in dollars, cash flow impact, change in
percent or basis points of retur on equity, etc. Please provide workpapers in Excel with
formulas activated and operationaL.
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 2 MARCH 6, 2009
REQUEST NO.7: Gregory Duvall on page 2 of testimony discusses volatUity largely
outside the Company's control. For each factor please provide a list of each process and
description of that process utilized by the Company to control the volatilty. In the answer also
identify the areas where the process is completed, for instance a process for planning, modeling,
operations, etc.
REQUEST NO.8: Please provide analyses showing why a 90/1 0 customer/Company
sharing of deferred power supply costs is inadequate or not appropriate.
DATED at Boise, Idaho, this 6 ~ay of March 2009.
Technical Staff:
i:umisc:prodreq/pace08.8swkhrltc prod req i
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 3 MARCH 6, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF MARCH 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-08-8, 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(ipacificorp.com
DATA REQUEST RESPONSE CENTER
PACIFICORP
825 NE MUL TNOMAH STE 2000
PORTLAND OR 97232
E-MAIL: datareguest(ipacificorp.com
KA TIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA COURT
SURPRISE AZ 85387
E-MAIL: kiverson(iconsultbai.com
ERIC L OLSEN
RACINE OLSON NYE BUDGE & BAILEY
201 E CENTER
PO BOX 1391
POCATELLO ID 83204
E-MAIL: elo(iracinelaw.net
DANIEL SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander(ipacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE & BAILEY
201 E CENTER
PO BOX 1391
POCATELLO ID 83204
E-MAIL: rcb(iracinelaw.net
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithaYmonsanto.com
ELECTRONIC COPIES ONLY
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(iyanel.net
SECRETARY
CERTIFICATE OF SERVICE