20101101PIIC to PAC 3 (1-19).pdf

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Melinda J. Davison, OSB No. 930572
Davison Van Cleve, P.C.
333 SW Taylor, Suite 300
Portland, OR 97204
Telephone: [phone]
Fax: [phone]
mjd~dvclaw.com
2010 NOV - I Ali 8= 52
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Fax: [phone]
ron~wiliamsbradbury.com
Attorneys for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICA nON )
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-10-07
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS' RESPONSE TO ROCKY
MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
Pursuant to Rule 228 of the Idaho Public Utilties Commission's Rules of
Practice and Procedure, PacifiCorp Idaho Industrial Customers' ("PIIC") responses to Rocky
Mountain Power ("RMP") Third Set of Discovery Requests are as follows:
PAGE 1 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
C\.t..
i¡\n ll6'i - \ l\~ 8: 52
GENERAL OBJECTIONS
1. PIIC objects to the instructions set forth in Rocky Mountain Power's Third Set of
Data Requests to the extent that these instructions impose obligations on PIIC that exceed, are
unauthorized by or are inconsistent with the discovery rules.
2. PIIC objects to the request to the extent that the data requested is not relevant to
the issues identified in this proceeding.
3. PIIC objects to the requestto the extent that production of the data requested
would be unduly burdensome and that the request is overly broad.
4. PIIC objects to the request to the extent that production of the requested data
would reveal information protected by the attorney-client privilege, and/or the work product doctrine,
and/or any other privilege.
5. Each of the preceding general objections is incorporated by reference in the
specific response below.
PAGE 2 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
For Mr. Meyer:
DATA REOUEST RMP 3.1
Please provide calculations, assumptions, and work papers on how Mr. Meyer
arved at the $665.8 milion reduction (revenue requirement reduction of $4 milion) to post
test year plant adjustments, referenced on page 8 of his direct testimony?
PUC RESPONSE TO RMP 3.1
The workpapers previously provided to the Company contain the requested
information.
PAGE 3 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.2
Please provide calculations, assumptions, and work papers on how Mr. Meyer
arived at the $361,744 milion reduction to depreciation expense referenced on page 8 of his
direct testimony?
PUC RESPONSE TO RMP 3.2
The workpapers previously provided to the Company contain the requested
information.
PAGE 4 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.3
Refer to page 13 lines 8 & 9 of Mr. Meyer's testimony. Please provide
calculations and workpapers supporting the $1.2 milion of additional residential revenue.
Please include quantitative support for the statement: "This amount is net of additional fuel
cost."
PIle RESPONSE TO RMP 3.3
The workpapers previously provided to the Company contain the requested
information.
PAGE 5 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.4
Refer to page 13 lines 8 & 9 of Mr. Meyer's testimony. Does Mr. Meyer's
recommended adjustment include the impact to jurisdictional allocation factors caused by
increasing residential load?
PIIC RESPONSE TO RMP 3.4
No.
PAGE 6 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
For Mr. Falkenberg:
DATA REQUEST RMP 3.5
Referring to page 1, line 23 to page 2 line 2. Please provide the list of
adjustments to the Company's NPC that Mr. Falkenberg would propose if not for the ECAM
mechanism. Please explain their exclusion.
PIIC RESPONSE TO RMP 3.5
No list is available at this time. Normally, Mr. Falkenberg reviews a filing to
identify pertinent issues. If modeling issues are identified, then they are quantified and
evaluated. In this case, the presence of the ECAM resulted in less focus on modeling issues, so
the fullest possible identification process was not performed. Consequently, Mr. Falkenberg
does not know what additional issues he might have identified had circumstances been different.
Given the presence of the ECAM, a different approach was followed as is explained in Mr.
Falkenberg's testimony.
PAGE 7 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.6
Referring to page 2, lines 17-19. Please explain when Mr. Falkenberg wil
complete his analysis of the Company's NPC in this case.
PIle RESPONSE TO RMP 3.6
Mr. Falkenberg plans to review testimony of other WItinesses and determine if he
is in agreement with their adjustments. Mr. Falkenberg may recommend that PIIC support
some of those adjustments at the technical hearing in this case.
PAGE 8 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.7
Referrng to Table 1 on page 3. To the extent not already provided, please
provide all workpapers supporting the adjustments with formulas and links to other fies intact.
Please also identify the source of the data.
PIIC RESPONSE TO RMP 3.7
The workpapers previously provided to the Company contain the requested
information.
PAGE 9 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.8
Referring to page 9, lines 17-19. What is the correct amount of incremental non-
fuel O&M Mr. Falkenberg believes the Company should include?
PIle RESPONSE TO RMP 3.8
The Company's screens appear to produce additionaL. stars relative to the no-
screen case. Consequently, use of the Company screens would be consistent with an upwards
adjustment to sta up O&M of $460,000. Since Mr. Falkenberg's screens result in fewer stars,
he recommends a reduction compared to the Company screen case of$950,000. The net of
these two numbers is Mr. Falkenberg's recommended adjustment to star up O&M ($490,000).
Note all figures are on a Total Company basis.
PAGE 10 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.9
Referrng to page 14, lines 16-19. What other adjustments that Mr. Falkenberg
proposed are based on or for items that the Company "may not be doing?"
PIle RESPONSE TO RMP 3.9
PIIC objects to this request on the basis that it is vague and ambiguous.
Notwithstading this objection, PIIC states as follows. Table 1 in Mr. Falkenberg's testimony
provides the adjustments Mr. Falkenberg recommends. In each and every case these are
intended to address an issue the Company has not addressed in its filing.
PAGE 11 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.10
Referrng to Figure 1 on page 17. To the extent not already proyided, please
provide all workpapers supporting the chart with formulas and links to other fies intact. Please
also identify the source of the data.
PIIC RESPONSE TO RMP 3.10
See the response to RMP Data Request 3.7.
PAGE 12 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.11
Referrng to page 19, lines 11-14. Please explain if GRID is "flying blind" on
other normalized inputs, such as load, hydro and wind generation, and thermal availabilty.
PIle RESPONSE TO RMP 3.11
PIIC objects to this request on the basis that it is vague, ambiguous and overly
broad. Notwithstanding this objection, PIIC states as follows. No. GRID is not flying blind for
such inputs as they are derived from historical data and forecasts prepared by the Company
using its own models and assumptions and techniques. This is in contrast to the case with
SMUD where the Company does not model constraints, actual load forecasts, hyrdo conditions,
thermal availabilty or the like for SMUD (data which in all likelihood the Company does not
even possess).
PAGE 13 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.12
Referring to page 19, lines 11-14. Please provide a list of contracts that should
be modeled similarly as the SMUD contract, using historical information. Please explain why.
PIle RESPONSE TO RMP 3.12
PIIC objects to this request on the basis that it is vague, ambiguous and overly
broad. Notwithstanding this objection, PIIC states as follows. Mr. Falkenberg has not prepared
a complete list. It does appear that Mr. Widmer has addressed the shaping for the Black Hils
contract. Other contracts that may require a shaping adjustment include GP Camas, UMP A II
and Public Service Colorado, based on Mr. Falkenberg's experience in prior cases. However, in
prior cases the impact of these adjustments was not as substantial compared to SMUD.
PAGE 14 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.13
Referring to page 22, lines 7-10. Please explain why it's appropriate to use the
Company's 2010 wind study to prorate the $6.50/MWh.
PIIC RESPONSE TO RMP 3.13
The question suggests the Company does not understand Mr. Falkenberg's
approach. Mr. Falkenberg did not use the results of the 2010 Wind Integration study, which are
posited in the question. Rather, Mr. Falkenberg used the prior (2009) wind integration study
result for 2010, to prorate the $6.50/MWH wind integration cost between inter and intra hour
components because the test year selected by the Company is 2010. While there were
numerous problems with the Company's 2009 study for intra-hour wind integration costs, the
inter-hour costs were developed using a different method, which Mr. Falkenberg adopted for
puroses of this case, lacking a better analysis.
PAGE 15 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.14
Referring to page 24, lines 14-16: What is the definition of "extremely rare
event?" Is the definition different with respect to plant outages or plant availabilties?
PIle RESPONSE TO RMP 3.14
There is no fine line that differentiates between ordinar events, extraordinar
events, rare events and extremely rare events. Having said that a one in four year event is clearly
ordinar. A one in ten year event could probably be considered extraordinar. A one in twenty
year event would likely be considered rare, and a one in 80 year event might be considered
"once in a lifetime" or extremely rare.
In this context, the discussion is regarding the probabilty of an outage of a
particular duration. The events in question have occured, as shown on Figure 2 with a
probabilty of (1-.998) or less. This is a one in 500 or less outage duration event.
PAGE 16 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.15
Referring to Figure 2 on page 25. To the extent not already provided, please
provide all workpapers supporting the char with formulas and links to other fies intact. Please
also identify the source of the data.
PIle RESPONSE TO RMP 3.15
See the response to 3.7.
PAGE 17 -PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.16
Referrng to page 26, lines 16-17. Which PacifiCorp proposal is Mr. Falkenberg
referring to in the context of this statement? Please identify the documents that sponsored the
proposaL.
PIle RESPONSE TO RMP 3.16
The PacifiCorp proposal and related documents Mr. Falkenberg was referring to
is identified in footnote 14.
PAGE 18 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.17
Referring to Figure 3 on page 32. To the extent not already provided, please
provide all workpapers supporting the char with formulas and links to other fies intact. Please
also identify the source of the data.
PIle RESPONSE TO RMP 3.17
The figue presents a self evident mathematical example. The documents
supporting it would include the Company's GRID Algorithm Manual and the figures presented
in the testimony. Note that this generic char has been provided in several other cases to the
Company. The Company has Mr. Falkenberg's permission to use the documents already
provided in previous cases.
PAGE 19 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.18
Referring to Confidential Table 2 on page 34. To the extent not already
provided, please provide all workpapers supporting the table with formulas and links to other
files intact. Please also identify the source of the data.
PIIC RESPONSE TO RMP 3.18
See the response to 3.7. Note, however, that Table 2 contains a minor error. The
term "WCA" should be deleted from the next to the last line. This wil either be corrected in an
errata, or when Mr. Falkenberg testifies at the hearing.
PAGE 20 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS
DATA REQUEST RMP 3.19
Referrng to page 36, lines 12-14. Is it correct to state that Mr. Falkenberg
believes that as soon as a contract no longer demonstrates obvious benefits, the Company
should seek to terminate it regardless of the terms of the contract?
PIIC RESPONSE TO RMP 3.19
If a contract no longer provides benefits, then the Company should examine its
options and opportunities for renegotiation of the contract, sale of the rights, or termination if
possible. Mr. Falkenberg has no objection to continuation of the contract if the Company can
demonstrate that it has prudently managed the contract, and examined its options and
opportities. Note that in this case, the adjustment is made to match costs and benefits in the
test year, not as a remedy for imprudence.
Prepared by Melinda J. Davison, PUC representative and attorney.
Dated: October 29,2010
PAGE 21 - PIIC'S RESPONSE TO ROCKY MOUNTAIN POWER'S THIRD SET OF
DISCOVERY REQUESTS