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Home My WebLink About20101021PAC 2 (1-16) to Staff.pdf'I ~ Mark C. Moench Daniel E. Solander 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone No. (801) 220-4014 Facsimile No. (801) 220-3299 mark.moenchCipacificorp.com daniel.solanderCÐpacificorp.com CE iuii OCT 2 l A~19: 33 Paul J. Hickey Hickey & Evans, LLP 1800 Carey Avenue, Suite 700 P.O. Box 467 Cheyenne, WY 82003-0467 Ph. 307-634-1525 FX.307-638-7335 phickeyCihickeyevans.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 AND A PRICE ) INCREASE OF $27.7 MILLION,OR APPROXIMATELY 13.7 PERCENT CASE NO. PAC-E-I0-07 DISCOVERY REQUESTS ROCKY MOUNTAIN POWER'S SECOND SET OF DISCOVERY REQUESTS TO COMMISSION STAFF COMES NOW, Rocky Mountain Power and hereby serves its second set of data requests on Idaho Public Utilty Commission Staff ("Staff) regarding the above docketed application of Rocky Mountain Power, pursuant to Rule 225 of the Idaho Public Utilties Commission's Rules of Procedure, IDAPA 31.01.01, as follows: 1 , DEFINITIONS AND INSTRUCTIONS The following definitions and instrctions apply to each of the requests for production set forth herein and are deemed to be incorporated therein. (1) "Document" and "documentation" should be interpreted as broadly as possible to include, but not be limited to, the original or any copy, regardless of origin or location, of any book, pamphlet, periodical publication, letter, scrapbook, diar, calendar, canceled check, photograph, form, memorandum, schedule, tax retu, telegram, telex, report, record, order or notice of governental action of any kind, study, minutes, logs, graph, index, tape, disc, internal operating manual, data sheet or data processing card, or any other.wrtten, recorded, trnscribed, punched, taped, filmed, graphic or retrevable matter or data of any kind, however produced or reproduced, to which you have Qr have had access. This definition is intended to include, but not be limited to, all documents which have been created and/or which reside in any tye of electronic format and is to be constred in its most comprehensive sense as contemplated by the Idaho Rules of Civil Procedure. (2) "Person or Entity" should be interpreted to denote, unless otherwise specified, any natual person, firm, corporation, association, group, individual or organization of any tye whatsoever. (3) Any request to "identify" or "provide" should be interpreted to mean: a) With respect to a natual person, that person's full name, title, job description, and business and home address. Where the identification pertains to a past period, as to each person identified who is stil in your employ, or the employment of the group with which such person is identified in response to any requests, provided, in addition, that person's 2 " title and job description as of the time of such past period. Where the person is no longer in your employ or the employment of the group with which such person is identified in response to any request, provide that person's affiiate, position, home and business address, if known, or if not known, such person's last known affiliâtion, position, home and business address, or portions thereof as may be known. b) With respect to an entity other than a natual person, that entity's name, business, type of entity, present status and present or last known address. c) With respect to a document, that document's title, date, author (and, if different, the signer), addresses, recipients, or other persons who assisted in the preparation, subject matter or general natue, and any amendments thereto, present location and custodian, whether or not such document is in the respondent's possession, custody or control and whether or not the document is claimed to be privileged. The final version and each draft of each document should be identified and produced separately. Each original and each non-identical copy (bearig marks or notations not found on the original) of each final version and draft of each document should be identified and produced separately. d) With respect to a physical facility, the location of the facilty, the intended purose of the facility, the actual use of such facility, the operating dates of the facility, ,the installation date of the facility, the date utilization of the facility terminated if applicable, and whether the facility is subject to the jursdiction of the Federal Energy Regulatory Commission, the Idaho Public Utilities Commission, or ,any other regulatory body. (4) "Communication" should be interpreted to include, but not be limited to, all forms of communication, whether wrtten, printed, oral, pictorial, electronic or otherwise, including testimony or sworn statement, or any means or tye whatsoever. 3 .. (5) "Relating To" or "Related To" means pertaining to, presenting, discussing, commenting on, analyzing, or mentioning in any way. (6) The term "and" and "or" should be constred either disjunctively or conjunctively whenever appropriate in order to bring within the scope of each request any information or document which might otherwise be considered to be beyond its scope. (7) The singular form of a word should be interpreted as plural, and the plural form of a word should be interpreted as singular, whenever appropriate in order to bring within the scope of each request any information or document which might otherwise be considered to be beyond its scope. DATA REQUESTS To Mr. Lanspery . RM 2.1 Refer to page 2 line 24 to page 3 line 1. To the extent not already provided, please provide all workpapers supporting the adjusted NPC with formulas and links to other fies intact. Please also identify the source of the data. RMP 2.2 Refer to page 5, lines 7-8. Does Mr. Lanspery believe that the prices for the two contracts are not appropriate? Please explain. RM 2.3 Refer to page 5, lines 12-14. What is Mr. Lanspery's definition of "internal costs" in this context? RM 2.4 Refer to page 5, lines 12-14. Please provide support and explain the statement. RM 2.5 Refer to page 5, lines 24-25. Please identify and explain the costs that should be part of the GRID modeling. RMP 2.6 Refer to page 6, lines 3-5. Is it correct to state that Mr. Lanspery believes that only accurate and predictable estimates can be included in the pro forma test year? Please explain. RMP 2.7 Refer to page 6, lines 3-5. Please provide a list of estimates in Mr. Lanspery recommended NPC that are accurate and predictable estimates. Please explain why and how they are accurate and predictable. RMP 2.8 Refer to page 6, lines 6-14. Assuming that the impact of volatilty in wind generation would not be estimated/captue in the pro forma NPC, and the actual impact 4 would be $30m on a total Company basis. How much does Mr. Lanspery believe that the Company should be authorized to recover? Please explain. RMP 2.9 Refer to page 6, lines 23-25. Please explain Mr: Lanspery's understanding of why BP A charges for wind integration costs. RMP 2.10 Refer to page 6, lines 23-25. To the extent not already provided, please provide all workpapers supporting the adjustment with formulas and links to other fies intact. Please also identify the source of the data. RM 2.11 Refer to page 7, lines 3-6. Please define the "inconsistencies" in the context. Does it refer to different modeling by the Company? Please explain. RM 2.12 Refer to page 7, lines 22-24. To the extent not already provided, please provide all workpapers supporting the adjustment with formulas and links to other files intact. Please also identify the source of the data. RM 2.13 Refer to page 8, lines 19-20. To the extent not already provided, please provide all workpapers supporting the adjustment with formulas and link to other fies intact. Please also identify the source of the data. RM 2.14 Refer to page 9, lines 15-17. To the extent not already provided, please provide all workpapers supporting the adjustment with formulas and link to other files intact. Please also identify the source of the data. RM 2.15 Given the similarity between adjustments proposed by Mr. Lanspery and Mr. Widmer, who is the consultant for Monsanto, please explain if Mr. Lanspery believes that his adjustments are more accurate, and ifhe would agree to any other adjustments proposed by Mr. Widmer. For Mr. Leckie RM 2.16 Please provide calculations and workpapers showing how Mr. Leckie arrved at the $875,226 reduction to depreciation expense referenced on page 4 of his direct testimony? DATED this 19th day of October 2010. Respectfully submitted, ROCKY MOUNTAIN POWER lsI Mark C. Moench Daniel E. Solander 5 201 South Main Street, Suite 2300 Salt Lake City, Utah 84111 Telephone No. (801) 220-4014 Facsimile No. (801) 220-3299 mark.moenchCipacificorp.com daniel.solanderCipacificorp.com Paul 1. Hickey Hickey & Evans, LLP 1800 Carey Avenue, Suite 700 P.O. Box 467 Cheyenne, WY 82003-0467 Ph. 307-634-1525 Fx.307-638-7335 phickeyCihickeyevans.coin Attorneys for Rocky Mountain Power 6 , CERTIFICATE OF SERVICE I hereby certify that on this 19th day of October, 2010, I caused to be served, via E-mail, a tre and correct copy of Rocky Mountain Power's Second Set of Discovery Requests to IPUC Staff in PAC-E-1O-07 to the following: Eric L. Olsen Racine, Olson, Nye, Budge & Bailey, Chartered 201 E. Center P.O. Box 1391 Pocatello,ID 83204-1391 E-Mail: elo(æ.racinelaw.net Randall C. Budge Racine, Olson, Nye, Budge & Bailey, Charered 201 E. Center P.O. Box 1391 Pocatello,ID 83204-1391 E-Mail: rcb(iracinelaw.net Tim Buller Jason Harrs Agrium, Inc. 3010 Conda Road Soda Springs, ID 83276 E-Mail: tbullerCiagrium.com J AHarrsCiagrium.com Paul J. Hickey Hickey & Evans, LLP 1800 Carey Ave. , Suite 700 PO Box 467 Cheyenne, WY 82003 E-Mail: phickeyCihickeyevans.com Brad Purdy CAPAI 2019 N. 17th St. Boise, ID. 83702 E-mail: bmpurdy(Ghotmail.com Benjamin 1. Otto Idaho Conservation League 710 N. 6th St. P.O. Box 844 Boise, Idaho 83702 E-mail: botto(ã)idahoconservation.org Anthony Yanel 29814 Lake Road Bay Vilage, Ohio 44140 E-mail: tonyCivankel.net Katie Iverson (E-mail only) Brubaker & Associates 17244 W. Cordova Cour Sunise, Arzona 85387 E-Mail: kiversonCiconsultbai.com James R. Smith (E-mail only) Monsanto Company P.O. Box 816 Soda Springs, Idaho 83276 E-Mail: jim.r.smithCimonsanto.com Melinda J. Davison Davison Van Cleve, P.C. 333 S.W. Taylor, Suite 400 Portland, OR 97204 E-mail: mjdCidvc1aw.com Ronald L. Wiliams Willams Bradbur, P.C. 1015 W. Hays St. Boise ID, 83702 E-mail: ronCiwillamsbradbury.com Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 .: Boise, ID 83720-0074 E-Mail: scott.woodburCipuc.daho.gov Dr. Don Reading (E-mail Only) Idaho Conservation League 6070 Hil Road Boise, ID 83703 E-mail: dreadingCimindspring.com lsI Carre Meyer Coordinator, Administrative Services