20101026Staff to PAC 2 (1-16).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
POBOX 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
RECEi\!E:D
2010 OCT 26 PH 12: l 5
IDAHC
UTILITIES
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 SECOND 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 Second Set of Discovery Requests to Staff dated October 19,
2010.
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S SECOND DATA REQUEST 1 OCTOBER 26,2010
Request Nos. 2.1 through 2.15 for Bryan Lanspery
Request No. 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 files intact. Please also identify the source of the data.
Answer: Please refer to confidential RMP Data Response 1.1. For adjustments to short
term firm transmission, see PAC to Monsanto 2.50. For Bear River normalization, see PAC to
WIEC 5.2-2 in Wyoming Case No. 20000-352-ER-09.
Request No. 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.
Answer: No, the contracts were approved by the Commission (Order No. 32084) and reflect
the curent PURP A published rate paid to qualified facilities such as the Windland projects.
Request No. 2.3: Refer to page 5, lines 12-14. What is Mr. Lanspery's definition of
"internal costs" in this context?
Answer: Internal costs refer to costs incurred due to operating the power supply system in a
less than optimal fashion due to wind output variabilty. These costs would be reflected in power
supply through, for example, additional purchases/sales or additional fuel bum for other generation
resources. These costs may vary greatly from year to year. (or alternatively, see testimony, page 5,
lines 22-24.)
Request No. 2.4: Refer to page 5, lines 12-14. Please provide support and explain the
statement.
Answer: Please refer to RMP Data Response 2.3.
Request No. 2.5: Refer to page 5, lines 24-25. Please identify and explain the costs that
should be part of the GRID modeling. .
Answer: Wind is modeled as a "must~take" resource in GRID, therefore dispatch of the
resource is unaffected by inclusion of a fuel cost. That said, if there is a fuel cost associated with a
resource, it should be included in the GRID modeling.
Request No. 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.
Answer: With regard to wind integration expense, yes.
Request No. 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.
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S SECOND DATA REQUEST 2 OCTOBER 26, 2010
Answer: Other than payments made to BP A, there are none.
Request No. 2.8: Refer to page 6, lines 6-14. Assuming that the impact of volatilty in
wind generation would not be estimated/capture in the pro forma NPC, and the actual impact
would be $30m on a total Company basis. How much does Mr. Lanspery believe that the
Company should be authorized to recover? Please explain.
Answer: Any power supply-related costs above those included in base rates that accrue in
accounts covered by the Company's ECAM should be recovered subject to the provisions of the
mechanism. .
Request No. 2.9: Refer to page 6, lines 23-25. Please explain Mr. Lanspery's
understanding of why BP A charges for wind integration costs.
Answer: Staff understands that BP A has a tariff that charges a wind integration rate since it
"provides the generation capability to follow within-hour variations of (non-owned) wind resources
in the BP A Control Area and to maintain the power system frequency at 60 Hz in conformance with
NERC and WECC reliability standads." (BPA Wind Integration-Within-Hour Balancing Service,
Section III E)
Request No. 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.
Answer: The reduction in NPC can be found by setting the value for wind integration costs
to zero in the wind integration tab of the Company's fied net power cost study.
Request No. 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.
Answer: "Inconsistencies" refers to the issues Staff addresses in Lanspery direct testimony
pages 7 through 10. These inconsistencies are defined as inappropriate modeling of a contract,
subjectively removing high water years in a 30 year average, and a mismatch of benefits with
expenses paid by ratepayers.
Request No. 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
fies intact. Please also identify the source of the data.
Answer: Please refer to confidential RMP Data Response 2.12.
Request No. 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 links to other
fies intact. Please also identify the. source of the data.
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S SECOND DATA REQUEST 3 OCTOBER 26, 2010
Answer: Please refer to confidential RMP Data Response 2.13.
Request No. 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 links to other
fies intact. Please also identify the source of the data.
Answer: Please refer to confidential RMP Data Response 1.1.
Request No. 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 if he would agree to any other
adjustments proposed by Mr. Widmer.
Answer: Staff does not have access to Monsanto's GRID runs and therefore canot
compare the accuracy of Monsanto's adjustments to Staffs. After review of Mr. Widmer's
testimony and/or after review of Monsanto's GRID runs, Staff may agree or disagree with
Monsanto's recommendations.
Request No. 2.16 for Joe Leckie
Request No. 2.16: Please provide calculations and workpapers showing how Mr.
Leckie arrived at the $875,226 reduction to depreciation expense referenced on page 4 of his
direct testimony?
Answer: The depreciation expense of $875,226 was calculated as shown in Leckie
Worksheet on Depreciation NO.2. This worksheet also contains the correct method for calculating
the depreciation expense. The corrected amount of the depreciation expense should be $1,022,396.
These workpapers were provided with RMP Data Response 1.6.
DATED at Boise, Idaho, this~day of October 2010.
~ r Scott Woodbury
Deputy Attorney General
Technical Staff: Bryan Lanspery
Joe Leckie
i: umisc: prodreq/pace io. 7 swb Ij I prod response2
STAFF'S RESPONSE TO ROCKY MOUNTAIN
POWER'S SECOND DATA REQUEST 4 OCTOBER 26,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF OCTOBER 2010,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO PACIFICORP
DBA ROCKY MOUNTAIN POWER'S SECOND 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.westoncmpacificorp.com
E-MAIL: ONLY
MARK C MOENCH
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
E-MAIL: mark.moenchcmpacificorp.com
daniel. solandercmpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbcmracinelaw.net
E-MAIL: ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithcmmonsanto.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAYVILLAGEOH 44140
E-MAIL: tonycmyanel.net
PAUL J HICKEY
HICKEY & EVANS LLP
1800 CAREY AVE., SUITE 700
PO BOX 467
CHEYENNE WY 82003
E-MAIL: phickeycmhickeyevans.com
E-MAIL: ONLY
DATA REQUEST RESPONSE CENTER
PACIFICORP
E-MAIL: datarequestcmpacificorp.com
E-MAIL: ONLY
KATIE IVERSON
BRUBAKER & ASSOCIATES
E-MAIL: kiversoncmconsultbai.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elocmracinelaw.net
CERTIFICATE OF SERVICE
TIM BULLER
JASON HARRIS
AGRIUMINC
3010 CONDA RD
SODA SPRINGS ID 83276
E-MAIL: tbullercmagrium.com
jahariscmagrium.com
BENJAMIN J OTTO
IDAHO CONSERVATION LEAGUE
710 N 6TH STREET
POBOX 844
BOISE ID 83702
E-MAIL: bottocmidahoconservation.org
E-MAIL: ONLY
DR. DON READING
E-MAIL: dreadingcmmindspring.com
MELINDA J DAVISON
DAVISON VAN CLEVE, P.C.
333 SW TAYLOR, SUITE 400
PORTLAND, OR 97204
E..MAIL: mjdcmdvclaw.com
RONALD L WILLIAMS
WILLIAMS BRADBURY, P.C.
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: roncmwiliamsbradbury.com
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdycmhotmail.com
JJ~
SECRETA
CERTIFICATE OF SERVICE