20100805Staff 202-222 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
r-i-\",t:
26m AUG -5 PH.~: 02
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-10-07
SIXTH 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
TUESDAY, AUGUST 24, 2010.
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 5, 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
IDAP A 31.01.01.228.
In addition to the wrtten copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 202: For the Populus to Terminal Transmission Line Project, please
provide the following:
a. Please forward all non-confidential and confidential discovery responses
from Wyoming Docket No. 2000-352ER-09, Utah Docket NO.1 0-035-13,
Oregon Docket No. UE-217, and California Docket No. A0911015.
b. Please provide before and after load flow analysis results and other related
analyses with brief descriptions.
c. Show how this project enhances reliabilty.
d. Show how it meets the Path C Upgrade Commitments from Case
No. PAC-E-05-08.
REQUEST NO. 203: In Case No. PAC-E-08-03, in response to Staff Production
Request No. 10, instead of Alternative 2, the Company chose to build a double circuit 345 kV
line to maximize the corrdor. Please provide justification showing how the extra capacity from
maximizing the corridor wil be utilized immediately.
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 5, 2010
REQUEST NO. 204: Please provide cost and transfer capacity comparisons if the
Company had chosen a different circuit configuration for the Path C Upgrade, for example, 230
kV single or double circuit, 345 kV single circuit or a 500 kV single or double circuit or other
appropriate transmission configurations.
REQUEST NO. 205: In Gerrard's testimony, page 7, lines 19-20, "the Company
committed to increase_the transmission capacity by 300 MW from southeast Idaho to northern
Utah." Based on the Company's 2008 IRP, page 283, the planed rating (initial completion) of
Populus to Terminal transmission line is 700 MW. Please justify the necessity of the additional
400 MW of transmission capacity in the absence of the other segments of Energy Gateway West.
REQUEST NO. 206: What is the maximum megawatt line rating or capacity of the 345
kV ,Populus to Terminal facilty based on engineering design?
REQUEST NO. 207: Without other Energy Gateway segments, the transfer capacity of
Populus to Terminal northbound direction is 350 MW and southbound direction is 700 MW.
Please explain how this capacity increases to 1400 MW in both directions once Gateway South is
completed without modifying the existing Populus to Terminal transmission line.
REQUEST NO. 208: Please describe and quantify the reliability requirements that the
Populus to Terminal line fulfills.
REQUEST NO. 209: The Populus to Terminal line will also be used to integrate
potential new energy resources in Wyoming, Utah, Idaho and Oregon. Please provide a list of
these resources and identify which are in-service, under construction and planed.
a. What % of sizing of the Populus-Terminal line was designed to accept
PURP A mandated purchases?
b. What % of the Populus-Terminal line cost is or wil be allocated to RFP and
PURP A contracts?
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 5, 2010
REQUEST NO. 210: In Company witness McDougal workpaper Page 8.6.2 under Rate
Base Adjustments, there are 10 transmission projects added to Rate Base under the Transmission
category besides the Populus to Terminal Line transmission related costs. For each project:
a. Please provide the project description and its purose.
b. Please explain how each project is prioritized.
c. Please quantify its impact on the system.
d. Please explain how the Company undertakes the construction of these projects
to assure reasonable cost. Are the projects contracted in-house, competitively
bid, or sole sourced?
e. Please provide the schedule of these projects and their respective costs.
REQUEST NO. 211: Please provide the amount ofIdaho irrigation load curailment
that occurred during the system coincident peak hours of 2009. What percentage of potential
curtailment does this represent? What percentage of CP does this represent? Where is this
referenced in jurisdictional allocation factors, class allocation factors, power supply and rate
design?
REQUEST NO. 212: Please provide the five years of data, in electronic executable
format, used to derive the test year peak and sales curailment for Idaho and Utah programs.
REQUEST NO. 213: What supply side resource(s) would the Company consider as an
appropriate replacement for the Idaho and Utah Irrigation Load Control Programs should these
programs be discontinued?
REQUEST NO. 214: Please explain the system benefits, pertaining to all jurisdictions,
of the Idaho Irrigation Load Control Program.
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 5, 2010
REQUEST NO. 215: On page 4, lines 14-15 of Eelkema's Testimony, regarding the
methodology used to develop test year loads, please provide:
a. An electronic list and detailed explanation of all the variables used to fit the
sales of each class to weather and economic drivers (HIS Global Insights,
etc.).
b. All executable electronic regression models, along with descriptions of the
accuracy for each class (Le.-descriptive statistics).
REQUEST NO. 216: On page 5, lines 12-20 of Eelkema's Testimony, regarding the
methodology used to develop test year number of customers, please provide:
a. A detailed explanation of why a 13-year time period (January 1997- Januar
2010) was used to develop the number of customers for the non-industrial
classes.
b. An electronic list and detailed explanation of all the variables used to model
each class (Le.-IHS Global Insights, etc.).
c. A detailed explanation of why economic drivers were not used to model the
irrigation class.
d. All executable electronic regression models, along with descriptions of
accuracy for each class (i.e.-descriptive statistics).
REQUEST NO. 217: On page 5-6, lines 22-23 & 1-9 of Eelkema's Testimony,
regarding the methodology used to develop test year average use per customer, please provide:
a. A detailed explanation of why the specific time frame was used to develop
average use per customer for the non-industrial classes.
b. An electronic list and detailed explanation of all the variables used to model
each class (i.e.-IHS Global Insights, etc.).
c. A detailed explanation of the time trend variables used to model the "other
classes."
d. All executable electronic regression models, along with descriptions of
accuracy for each class (Le.-descriptive statistics).
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 5, 2010
REQUEST NO. 218: On page 6, lines 13-22 of Eelkema's Testimony, regarding the
development oftest year sales for industrial customers, please provide:
a. A detailed explanation ilustrating the process used by CCMs to determine
customer's future plans for business process changes.
b. All backcast studies used to evaluate the accuracy of this process in
determining future industrial sales. If there are no studies, please explain
why.
REQUEST NO. 219: On page 7, lines 1-5 of Eelkema's Testimony, regarding the
development of test year sales for new industrial customers and expansions of existing large
customers, please provide:
a. A detailed explanation of the Company's process for collecting input from
customers.
b. A detailed explanation of the Company's load factor analysis.
c. A detailed explanation of how the Company uses probabilties to determine
the likelihood of project occurence.
REQUEST NO. 220: On page 8, lines 1-6 of Eelkema's Testimony, regarding the
development of test year hourly loads, please provide a detailed explanation of why the
Company used a 19-year range of average monthly peak-producing weather instead of the
13-year range used to develop test year number of customers, or some other range.
REQUEST NO. 221: Please provide the percentage of customers under each irrigation
load control schedule. As par of your response, please provide the 2009 and 2010 average
monthly savings associated with each.
REQUEST NO. 222: On Page 9, lines 17;.21 of Eelkema's Testimony, it says "Test year
sales is not adjusted to reflect the effects of the irrigation program because the Company is
assuming 100 percent take-back. Irrigators knowing they may be curtailed during the 2:00 p.m.
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 5, 2010
to 6:00 p.m. window wil irrigate around the curtailment hours. As a result, energy wil be shifted
away from curtailment hours, but the daily energy wil not change appreciably." Please provide
all "take-back" studies the Company's completed supporting the conclusion that "daily energy
wil not change appreciably."
DATED at Boise, Idaho, this
Technical Staff: TJ Golo/202 - 210
Bryan Lanspery/211 - 213
Matt Elam/214 - 222
i:umisc:prodreqlpace i o. 7swtjblme prod req6
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 5, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF AUGUST 2010,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-I0-07, 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
E-MAIL: jim.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
17Z44 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: tbuller(fagrium.com
j aharis(fagrium. com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjd(fdvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: ron(fwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(fhotmail.com
\.V~
SECRETARY
CERTIFICATE OF SERVICE