20100903Staff 271-286 to PAC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
r"1Ll
2910 SEP - 3 PM '2=r ,
IOAHC
UTILITIES
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
NINTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties 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 on or before
MONDAY, SEPTEMBER 13, 2010.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 3,2010
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 fies on CD with formulas activated.
REQUEST NO. 271: In WPSC Production Request 1.48, ACCC conductor is being
utilzed on a limited basis instead of the traditional ACSR conductor in the Populus-Terminal
transmission line.
a. How much of this conductor is being utilzed on this transmission line?
b. What is the cost difference ($/mile) between ACCC and ACSR?
c. What are the advantages of using an ACCC conductor?
d. Please quantify the cost benefits of using this type of conductor.
REQUEST NO. 272: Please provide any study that identifies the capacity constraints
(shortfall) over this transmission path before the construction of this line and how the
construction of this line satisfies that shortfall.
REQUEST NO. 273: Please provide power flow modeling study results which
specifically identify when this transmission line has constraints other than the study provided in
Staff Production Request No. 202b.
a. Please quantify these constraints.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 3,2010
REQUEST NO. 274: In response to Staff Production Request No. 208, the Company
identified the reliabilty standards required for this project. Please explain how this project meets
those standards.
REQUEST NO. 275: Using Alternative 2 referenced in Staff Production Request No.
203, constructing a single circuit 345 kV line, wil the Company stil meet reliabilty
requirements identified in Staff Production Request No. 208? If not, why not?
REQUEST NO. 276: What is the cost per mile difference between constructing a single
circuit 345 kV line and a double circuit 345 kV line?
REQUEST NO. 277: Please compare the cost per mile of the Camp Wiliams-90th
South line to the cost per mile for the Populus-Terminal line. Please explain the cost per mile
difference between these two projects.
REQUEST NO. 278: The original estimate for the Path C upgrade is $78 milion. The
updated project is about $800 milion. The cost per megawatt increased from $250,000/MW to
about $570,000/MW, how does this project capture the economies of scale?
REQUEST NO. 279: Please explain how the new Populus to Terminal transmission line
would have prevented or minimized the disturbance events described by the Company in
response to Monsanto's Data Request 6.6.
REQUEST NO. 280: To the extent possible, please describe the additional cost incurred
by Pacificorp and its customers due to the distubance events described by the Company in
response to Monsanto's Data Request No 6.6. How do these costs compare to Populus to
Terminal transmission costs incured to prevent or minimize the events?
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 3,2010
REQUEST NOS. 281 THROUGH 283 CONTAIN CONFIDENTIAL INFORMATION
SUBJECT TO PROTECTIVE AGREEMENT
REQUEST NO. 281: THIS REQUEST CONTAINS CONFIDENTIAL
INFORMATION SUBJECT TO PROTECTIVE AGREEMENT.
REQUEST NO. 282: Please provide a copy of the Company's analysis referred
to in the following paragraph from page 22 of the confidential report "The Oregon
Independent Evaluator's Final Closing Report on PacifiCorp's 2009R Renewables RFP"
dated November 5, 2009:
THIS PART OF THE REQUEST CONTAINS CONFIDENTIAL
INFORMATION SUBJECT TO PROTECTIVE AGREEMENT.
REQUEST NO. 283: Please provide a copy of the Company's analysis referred to in the
following paragraphs from pages 26-27 of the confidential report "The Oregon Independent
Evaluator's Final Closing Report on PacifiCorp's 2008R-l Renewables RFP" dated May 15,
2009:
THIS PART OF THE REQUEST CONTAINS CONFIDENTIAL
INFORMATION SUBJECT TO PROTECTIVE AGREEMENT.
REQUEST NO. 284: Please provide a copy of all exhibits to the confidential report
"Report of the Independent Evaluator on Negotiations in PacifiCorp's 2008R-l Request for
Proposals for Renewable Electric Resources" prepared by Boston Pacific, Inc., and dated
September 18,2009.
REQUEST NO. 285: Please provide the methodology, and all executable electronic
analysis used to determine the curailment credit amounts paid to the Irrigation Load Control
Program paricipants. As par of your response, include an explanation of how these credits have
changed given changes in program paricipation and administrative costs.
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 3,2010
REQUEST NO. 286: Please provide all executable electronic studies used to compare
the Irrigation Load Control Program to market purchase and other resource options. As par of
this response, please include all inputs and assumptions used to calculate the "Benefit Value"
shown in table ten of the 2009 Idaho Irrigation Load Control Quantitative Review.
DATED at Boise, Idaho, thi~~day of September 2010.
~
~ Scott Woodbur
Deputy Attorney General
Technical Staff: TJ Golo/271-281
Rick Sterling/282-284
Matt Elar285-286
i:umisc:prodreq/pacelO.7swtjrpsme prod req9
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 SEPTEMBER 3,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF SEPTEMBER 2010,
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-IO-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.westonaYpacificorp.com
(Confidential)
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench(fpacificorp.com
daniel.solander(fpacificorp.com
(Confidential)
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbaYracinelaw.net
(Non-Confidential)
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(fmonsanto.com
(N on-Confidential)
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyanel.net
(Non-Confidential)
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickey(fhickeyevans.com
(Non-Confidential)
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: datareguest(fpacificorp.com
(Confidential)
KATIE IVERSON
BRUBAKER & ASSOCIATES
17244 W CORDOVA CT
SURPRISE AZ 85387
E-MAIL: kiverson(fconsultbai.com
(Non-Confidential)
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(fracinelaw.net
(Non-Confidential)
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbulleraYagrium.com
jaharris(ßagrium.com
(Non-Confidential)
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: botto(ßidahoconservation.org
(Non-Confidential)
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjdaYdvclaw.com
(Non-Confidential)
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 WHAYS STREET
BOISE ID 83702
E-MAIL: ronaYwiliamsbradbury.com
(N on-Confidential)
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ßhotmaiL.com
(N on-Confidential)
,b/Ý6SECRE~Y
CERTIFICATE OF SERVICE