20100719Staff 77-111 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
RECE-l\IED
ZDlûJULl9 PM ~: f I
NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
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. PAC-E-I0-07
SECOND 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 Woodbury, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information on or before
MONDAY, AUGUST 9,2010.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 19,2010
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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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 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.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
2008RRFP
REQUEST NO. 77: Please provide a copy of an evaluation manual or other document
that describes how bids submitted in the 2008R RFP were to be evaluated. If no manual exists,
please provide a description of all price and non-price scoring criteria including guidelines
related to how scores were to be assigned and how project costs were to be computed.
REQUEST NO. 78: Please provide copies of all spreadsheets, scores and analysis used
to evaluate price and non-price factors for development of the Initial Shortlist for the 2008R RFP
(for example, PacifiCorp's Structuring and Pricing RFP Model). Please provide a summary of
the results of the Initial Shortlist evaluation. Please provide the requested information in an
electronic, executable format with formulas intact.
REQUEST NO. 79: Please provide copies of all summar spreadsheets, scores and
analysis used to evaluate price and non-price factors for development of the Final Shortlist for
the 2008R RFP. It is not necessary to provide a copy of the IRP PaR model, but Staff would like
to see the results of the IRP PaR analysis and the results of the ACC calculations for each of the
five proposals on the Initial Shortlist. Please clearly identify the Forward Price Curve used for
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 19,2010
the analysis and state the date on which it was developed. Please provide the requested
information in an electronic, executable format with formulas intact.
REQUEST NO. 80: Please provide a copy of all reports prepared by the independent
evaluator for the 2008R RFP. If an independent evaluator was not used, please explain why.
REQUEST NO. 81: Please provide a copy of the regulatory guidelines for resource
procurement as stipulated by the Oregon and Utah Commissions.
REQUEST NO. 82: Please provide monthly generation totals for the Three Buttes
project from the commercial operation date of December i, 2009 through the current month.
REQUEST NO. 83: Please separately identify and quantify all amounts paid for RECs
associated with the Three Buttes PP A.
REQUEST NO. 84: Please provide (in an electronic form only) all exhibits attached to
the Three Buttes PP A.
2008R-l RFP
REQUEST NO. 85: Please provide a copy of an evaluation manual or other document
that describes how bids submitted in the Amended 2008R-1 RFP were to be evaluated (if
different than the manual used for the 2008R RFP). If no manual exists, please provide a
description of all price and non-price scoring criteria including guidelines related to how scores
were to be assigned and how project costs were to be computed.
REQUEST NO. 86: Please provide copies of all spreadsheets, scores and analysis used
to evaluate price and non-price factors for development of the three Initial Shortlists for the
Amended 2008R-1 RFP (for example, PacifiCorp's Structuring and Pricing RFP Model). Please
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 19,2010
provide a summary of the results of the Initial Shortlist evaluation. Please provide the requested
information in an electronic, executable format with formulas intact.
REQUEST NO. 87: Please provide copies of all summar spreadsheets, scores and
analysis used to evaluate price and non-price factors for development of the Final Shortlist for
the Amended 2008R-I RFP. It is not necessar to provide a copy of the IRP PaR model, but
Staff would like to see the results of the IRP PaR analysis and the results of the ACC calculations
for each of the five proposals on the Initial Shortlist. Please clearly identify the Forward Price
Curve used for the analysis and state the date on which it was developed. Please provide the
requested information in an electronic, executable format with formulas intact.
REQUEST NO. 88: Please provide (in an electronic form only) all exhibits in the
Boston Pacific report of the Independent Evaluators in the 2008R-1 RFP.
REQUEST NO. 89: Please provide a copy of any independent evaluator's report other
than the Boston Pacific report prepared for the Oregon PUC.
REQUEST NO. 90: Please provide (in an electronic form only) all exhibits attached to
the Top of the World PPA.
REQUEST NO. 91: Please separately identify and quantify all amounts paid for RECs
associated with the Top of the World PPA.
REQUEST NO. 92: It appears that all of the bids placed on the final shortlist had
positive ACC and "Adjusted ACC" scores. Please explain why the Company stil decided to
pursue the winning bid when its ACC score was positive.
2009RRFP
REQUEST NO. 93: Please provide a copy of an evaluation manual or other document
that describes how bids submitted in the Amended 2008R-1 RFP were to be evaluated (if
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 19,2010
different than the manual used for the 2008R or 2008R-1 RFPs). Ifno manual exists, please
provide a description of all price and non-price scoring criteria including guidelines related to
how scores were to be assigned and how project costs were to be computed.
REQUEST NO. 94: Please provide copies of all spreadsheets, scores and analysis used
to evaluate price and non-price factors for development of the three Initial Shortlists for the
Amended 2009R RFP (for example, PacifiCorp's Structuring and Pricing RFP Model). Please
provide a summary of the results of the Initial Shortlist evaluation. Please provide the requested
information in an electronic, executable format with formulas intact.
REQUEST NO. 95: Please provide copies of all summary spreadsheets, scores and
analysis used to evaluate price and non-price factors for development of the Final Shortlist for
the Amended 2009R RFP. It is not necessary to provide a copy of the IRP PaR model, but Staff
would liketo see the results of the IRP PaR analysis and the results of the ACC calculations for
each of the five proposals on the Initial Shortlist. Please clearly identify the Forward Price
Cure used for the analysis and state the date on which it was developed. Please provide the
requested information in an electronic, executable format with formulas intact.
REQUEST NO. 96: Please explain why a Company Benchmark was prepared and
evaluated in the 2009R RFP, but not in either the 2008R or 2008R-1 RFPs.
REQUEST NO. 97: Please explain why it was a goal of the Company to select a mix of
PP As and BOTs in each of the three Initial Shortlists.
REQUEST NO. 98: Please explain why a Company-owned project was selected in the
2009R RFP instead of a PP A.
REQUEST NO. 99: Please provide (in an electronic form only) all exhibits in the
Boston Pacific Final Closing Report of the Independent Evaluators in the 2009R RFP.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JULY 19,2010
REQUEST NO. 100: Please provide a copy of any independent evaluator's report other
than the Boston Pacific Benchmark Memo and the Boston Pacific Closing Report prepared for
the Oregon PUC.
REQUEST NO. 101: Please provide workpapers or other documentation showing how
the estimated operation and maintenance costs of $2.4 milion for the Dunlap I project were
derived.
REQUEST NO. 102: Please describe any safeguards or controls that have been put in
place to guard against the possibility that the ultimate costs to construct the Dunlap 1 project wil
not exceed the costs assumed in the RFP bid evaluations.
REQUEST NO. 103: It appears that all of the bids placed on the final shortlist had
positive ACC and "Adjusted ACC" scores. Please explain why the Company stil decided to
pursue the winning bid when its ACC score was positive.
Wind Resources Discussed in Mark Tallman's Testimony
REQUEST NO. 104: For each of the wind resources discussed in the testimony of Mark
Tallman, please describe in detail how the projects were identified and selected. Please discuss
any RFPs that were issued and present the results of those RFPs. Please provide copies of all
spreadsheets or other analysis of both quantitative and qualitative factors, including economic
analysis used to compare proposals.
REQUEST NO. 105: Please describe how the Company decides whether to acquire new
wind generation resources through PPAs vs. through BOT arrangements. In your answer,
specifically address how the Company weighs the risks or owning and operating a project (e.g.,
online delays, generation shortfalls, equipment failures, mechanical availabilty, etc.) against
PPAs in which these types of risks are borne by the project owner.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 JULY 19,2010
REQUEST NO. 106: Please describe how transmission costs are considered in the
analysis of wind project proposals. For each wind project discussed by Company witnesses in
this case, please state the transmission costs associated with the project and describe how each
cost was determined.
REQUEST NO. 107: Please discuss the procurement process for each of the following
categories for wind projects owned and operated by the Company:
A. materials and equipment (e.g., wind turbine generators, electrical generators,
communication and control facilities, substations, transformers, etc.)
B. labor and professional services (e.g., construction contracts, engineering
contracts, permitting contracts, etc.)
C. operation and maintenance
In your answers, please specifically address whether the procurement process is
competitive, and discuss any specific practices or procedures that help to ensure that materials,
equipment, labor, professional services, and operation and maintenance are procured for the
lowest cost.
REQUEST NO. 108: Please explain why all of the wind turbine generators for the wind
resources discussed by Mark Tallman have been acquired from GE. Were bids obtained from
other turbine manufacturers?
REQUEST NO. 109: For each of the wind resources, please identify the ongoing
operation and maintenance costs associated with each project.
REQUEST NO. 110: For each of the wind resources, please compare the final cost of
each project as booked for ratemaking puroses to the costs that were assumed for each project
during the evaluations that compared the projects to other alternatives. Please explain any
instances wherein the final project costs exceeded bid costs or other initial estimates.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 JULY 19,2010
REQUEST NO. 111: Please discuss any assurances PacifiCorp can provide that all
BOT projects wil provide generation amounts on an ongoing basis that is consistent with the
assumptions made in the selection process for each resource.
DATED at Boise, Idaho, this l~ay of July 2010.
. -n¿ .~. ,'"N~~
...("Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterlingl77-111
i:umisc:prodreqlpacelO.7sw prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 8 JULY 19,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH OF JULY 2010, SERVED THE
FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF
TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-10-07,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(fpacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench(fpacificorp.com
daniel. solander(fpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(fracinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
j im.r. smith(fmonsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyanel.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickey(fhickeyevans.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: datarequest(fpacificorp.com
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA CT
SURPRISE AZ 85387
E-MAIL: kiverson(fconsultbai.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(fracinelaw.net
MICHAEL C CREAMER
KELSEY J NUNEZ
GIVENS PURSLEY LLP
PO BOX 2720
BOISE ID 83701-2720
E-MAIL: mcc(fgivenspursley.com
kelseynunez(fgivenspursley.com
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbullerrgagrium.com
jaharsrgagrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: botto($idahoconservation.org
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjdrgdvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: ron($willamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdyrghotmail.com
SECRE'k~
CERTIFICATE OF SERVICE