20101013PAC to Staff 319-321, 323.pdf

~~l MOUNTAIN RECEIVED
-2010 OCT 13 AM 10: l 8 201 South Main, Suite 2300
Salt Lake City, Utah 84111
October 12, 2010
i i 1~~~lPi'" TIll ¡ \L.,;Scott Woodbur
Idaho Public Utilties Commission
472 W. Washigton
Boise, ID 83702-5918
Neil Price
Idaho Public Utilties Commssion
472 W. Washington
Boise, il 83702-5918
RE: ID PAC-E-I0-07
IPUC Data Request (302-317)
Please fid enclosed Rocky Mountan Power's Responses to IPUC Data Requests 319-323,
excluding IPUC 322. This response will be provided separately. Provided on the enclosed CD is
Atthment IPUC 319. Provided on the enclosed Confdential CD are Confdential Attchments
IPUC 320 -(a-d). The Confdential Atthments are Confdential and are provided to paries that
have signed a protective order in this docket.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J. TId rv~/hv
J. Ted Weston
Manager, Regulation
Enclosure:
cc: Jean Jewell/UC (C)/3 copies
Eric Olsen/IP A (C)
Ben Otto/ICL (C)
Radall Budge/Monsanto (C)
James R. Smithonsanto (C)
Richard Anderson/onsanto (C)
George C. Carer, III/onsanto (C)
Denns Peseau/onsanto (C)
Gareth R. Kajander/Monsanto (C)
Maurce Brubaker/Monsanto (C)
Brian Collns/Monsanto (C)
Michael Gormanonsanto (C)
Kathr Iverson/onsanto (C)
Mark Widmer/Monsanto (C)
P AC-E-l 0-07/Rocky Mountan Power
October 12, 2010
IPUC Production Data Request 319
IPUC Production Data Request 319
Please describe and provide schedules detaling the charges for "Admstration"
in the amount of $1,662,029 in 2009 and the amount of$I,836,148 for 2010 Pro
Forma in the Incremental Generation O&M (see page 4.6.1 of Exhbit 2 to Steve
McDougal testimony).
Response to IPUC Production Data Request 319
Please refer to Attachment IPUC 319.
Recordholder:
Sponsor:
Chad Teply
Chad Teply
P AC-E-1 0-07/Rocky Mountain Power
October 12,2010
IPUC Production Data Request 320
IPUC Production Data Request 320
Please provide all studies done by the Company or by any external soure that the
Company has tht examnes and determines the potential and capacity for wind
generation of the Dunap Rach.
Response to IPUC Production Data Request 320
Please refer to Confdential Atthments IPUC 320a throug IPUC 320d. Ths
inormation is confdential and is provided subject to the terms and conditions of
the protective agreement in this proceeding.
An attorney attestation of confdentiality for these documents is attched to ths
response.
Recordholder:
Sponsor:
Mark Tallman
Stefan Bird
Mark C. Moench
Danel E. Solander
Yvonne R Hogle
Rocky Mountan Power
201 South Mai Street, Suite 2300
Salt Lake City, Uta 84111
Telephone: [phone]
Email: mark.moench(ipacificorp.com
daniel.solander(fpacificorp.com
yvonne.hogle(fpacificorp.com
Attorneys for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF ROCKY
MOUNTAIN POWER FOR
APPROVAL OF CHANGES TO ITS
ELECTRIC SERVICE SCHEDULES
AN A PRICE INCREASE OF $27.7
MILLION, OR APPROXIMATELY
13.7 PERCENT
)
)
)
)
)
)
)
CASE NO. PAC-E-10-07
Attorney's Certifcate Claim
of Confidentiality Relatig
to Discovery Responses
I, Danel E. Solander, represent Rocky Mountain Power in the above captioned
matter. I am Senior Counsel for Rocky Mountain Power and am appearg on its behalf in
this proceeding.
I make this certification and claim of confidentiality regarding responses to discover
request IPUC 320 pursuat to IDAPA 31.01.01 because Rocky Mounta Power, though its
supportg workpapers, is disclosing certn inormation that is Confidentil and constitutes
Trade Secrets as defined by Idao Code Section 9-340 and 48-801 and protected under
IDAP A 31.01.01.067 and 31.01.01.233.
Rocky Mounta Power herein assert tht the aforementioned response is
confdential in that the information is associated with bids submitt as par of a competitive
request for proposal (RFP) process. The Company maitains such information associated
with RFPs as confidential. Disclosing ths information will give entities access to
Attorny Attestation ¡PUC 320.pdf Pag 1 of2
competitive information on future RFPs and Rocky Mountain Power believes the information
could be used to disadvantage its customers.
I am of the opinion that this information is "Confidential," as defined by Idaho Code
Section 9-340 and 48-801, and should therefore be protected from public inspection,
examination and copying, and should be utilzed only in accordace with the terms of the
Protective Agreement between Rocky Mounta Power and Idaho Public Utilities
Commission Sta.
DATED this 12th day of October, 2010.
Respectfuly submittd,
By ~~~AMark C. Moenèh ~
Daniel E. Solander
Yvonne R. Hogle
Attorneys for Rocky Mountan Power
Attorny Attestation ¡PUC 320.pdf ~ag2øf2
P AC-E- I 0-07/Rocky Mountan Power
October 12, 2010
IPUC Production Data Request 321
IPUC Production Data Request 321
What is the potential wid generation capacity of the Dunap Ranch. What
portion of the tota capacity for wid generation is represented by the construction
of the 74 tubine sites that are included in the curent rate case?
Response to IPUC Production Data Request 321
Please refer to the Company's response to IPUC Data Request 185. The potential
generation capacity of the Dunap Rach is unown.
The Company curently has no defitive plang projection for the placement or
futue use of generation, transmission or distrbution facilties at the Dunap
propert. The decision to place any such facilties in the future on the Dunap
property will be based on then-curent information.
Recordholder:
Sponsor:
Mark Tallman
Stefan Bird
. .
P AC-E-l 0-07/Rocky Mountan Power
October 12,2010
IPUC Production Data Request 323
IPUC Production Data Request 323
The Dunap Rach Wind Project is referred to in the Company's testimony and
exhbits as "Dunap I" (Bird Testimony, pages 22-25, Exhbit 2, Page 4.6.1);
"Dunap I Wind Project" (Exhbit 2, page 4.6.3 and page 8.6.2) and finaly as
"Dunap Rach Wind Far Phase I" (Exhbit 2, page 8.6.2). Please explai why
ths facilty was given a name with the designation of "I" and "Phase I"?
Response to IPUC Production Data Request 323
Consistent with pruent utilty practices, the Company pursued applicable permts
for the Dunap ranch site to provide for the option of adding additiona facilties in
the futue if in the interest of customers.
Please refer to the Company's response to IPUC Data Request 185. The
Company curently has no definitive planng projection for the placement or
futue use of generation, trsmission or distrbution facilties at the Dunap
property. The decision to place any such facilties in the futue on the Dunap
property will be based on then-curent informtion.
Recordholder:
Sponsor:
Mark Tallman
Stefan Bird