20101021Staff to PAC 1 (1-6).pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 1895
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
REGE¡ ;:'-¡
201BOCT 21 PHi¡: 18
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-IO-07
COMMISSION STAFF'S
RESPONSE TO PACIFICORP
DBA ROCKY MOUNTAIN
POWER'S FIRST SET OF
DISCOVERY REQUESTS TO
STAFF
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, provides the following documents and information
in response to Rocky Mountain Power's First Set of Discovery Requests to Staff dated October
15,2010.
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S FIRST DATA REQUEST 1 OCTOBER 21,2010
Request No. 1.1: Please provide all workpapers and exhibits supporting Mr.
Lanspery's testimony with all formulas and links to other fies intact, including but not
limited to the GRID scenarios, revised inputs to the scenarios, workpaper supporting the
revisions to the Company's inputs and assumptions, and the outputs demonstrating the
impact of the adjustments. Please also identify the source of the data.
Answer: Staff witness Lanspery workpapers are provided on the attached CDs. All
confidential workpapers are shown on a separate Confidential CD. Where workpapers are not
specifically identified, the numbers are supported in testimony and the calculations are reflected
within the RAM/JAM.
Request No. 1.2: Please provide all workpapers and exhibits supporting Ms.
Vaughn's testimony with all formulas and links to other fies intact. Please also identify the
source of the data.
Answer: Staff witness Vaughn workpapers are provided on the attached CDs. Where
workpapers are not specifically identified, the numbers are supported in testimony and the
calculations are reflected within the RAM/JAM.
Request No. 1.3: Please provide all workpapers and exhibits supporting Mr.
English's testimony with all formulas and links to other files intact. Please also identify the
source of the data.
Answer: Staff witness English workpapers are provided on the attached CDs. All
confidential workpapers are shown on a separate Confidential CD. Where workpapers are not
specifically identified, the numbers are supported in testimony and the calculations are reflected
within the RAM/JAM.
Request No. 1.4: Please provide all workpapers and exhibits supporting Mr. Lobb's
testimony with all formulas and links to other fies intact. Please also identify the source of
the data.
Answer: Staff witness Lobb does not have individual workpapers. Where workpapers
are not specifically identified, the numbers are supported in testimony and the calculations are
reflected within the RAM/JAM.
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S FIRST DATA REQUEST 2 OCTOBER 21,2010
Request No. 1.5: Please provide all workpapers and exhibits supporting Ms.
Carlock's testimony with all formulas and links to other files intact. Please also identify the
source of the data.
Answer: Staff witness Carlock workpapers are provided on the attached CDs. Where
workpapers are not specifically identified, the numbers are supported in testimony and the
calculations are reflected within the RAM/JAM.
Request No. 1.6: Please provide all workpapers and exhibits supporting Mr.
Leckie's testimony with all formulas and links to other files intact. Please also identify the
source of the data.
Answer: Staff witness Leckie workpapers are provided on the attached CDs. All
confidential workpapers are shown on a separate Confidential CD. Where workpapers are not
specifically identified, the numbers are supported in testimony and the calculations are reflected
within the RAM/JAM.
DATED at Boise, Idaho, this c!/5tay of October 2010.
co Woodbury
Deputy Attorney General
Technical Staff: Bryan Lanspery
Cecily Vaughn
Donn English
Randy Lobb
Terr Carlock
Joe Leckie
i:umisc:prodreq/pace I O. 7sw prod response i
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S FIRST DATA REQUEST 3 OCTOBER 21,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF OCTOBER 2010,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO PACIFICORP
DBA ROCKY MOUNTAIN POWER'S FIRST SET OF DISCOVERY REQUESTS
TO STAFF, 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
(FED EX)
E-MAIL: ted.weston(gpacificorp.com
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
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moench(fpacificorp.com
daniel.solander(gpacificorp.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: dataeguest(gpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(gracinelaw.net
E-MAIL: ONLY
KATIE IVERSON
BRUBAKER & ASSOCIATES
E-MAIL: kiverson(gconsultbai.com
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(gmonsanto.com
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(gracinelaw.net
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(fyanel.net
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbuller(fagrium.com
jaharis(fagrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
E-MAIL: ONLY
DR. DON READING
E-MAIL: dreading(gmindspring.com
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E-MAIL: mjd(gdvclaw.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(ghotmail.com
~~
SECRETARY 7
CERTIFICATE OF SERVICE