20101122PIIC 150-176 to PAC.pdf

Melinda J. Davison, OSB No. 930572
Davison Van Cleve, P.C.
333 SW Taylor, Suite 300
Portland, OR 97204
[phone]
[phone] (Fax)
mjd~dvclaw.com
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Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
[phone]
[phone] (Fax)
ron~willamsbradbur.com
Attorneys for PacifiCorp Idaho Industrial Customers
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-1O-07
)
) NINETEENTH SET OF DATA
) REQUESTS TO ROCKY
) MOUNTAIN POWER OF THE
) PACIFICORP IDAHO
) INDUSTRIAL CUSTOMERS
)
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its attorney of
record, Melinda Davison, requests that PacifiCorp, d//a Rocky Mountain Power (the
"Company"), provide the following documents and information on or before Friday,
November 26, 2010. For the definitions and instructions that apply to these data requests, please
refer to PIIC's First Set of Data Requests dated August 12,2010.
PAGE 1 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
Please provide the responses to these Data Requests by no later than Friday,
November 26,2010, to:
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portland, Oregon 97204
[phone]
mjd~dvclaw.com
Randall J. Falkenberg
RFI Consulting, Inc.
PMB 362
8343 Roswell Road
Sandy Springs, GA 30350
[phone]
consultrf~aoi.com
DATA REQUESTS
150. Please refer to Teply Di-Reb-5, line 23. Explain how the liquidated damages
payment was credited to Idaho retail customers. Explain where the adjustment was
made in this case or in a prior case.
151. Please refer to Teply Di-Reb-6, lines 1-4. Does Mr. Teply acknowledge that, if
prudent, the costs of this incident will be recovered in an ECAM filing that has been
or wil be fied by the Company. If so, explain the justification for additional
collection of these costs via inclusion in the NPC baseline.
152. Please refer to Teply Di-Reb-6, lines 1-12. Explain Mr. Teply's understanding of the
recovery of outage costs as occurs in the ECAM and in the setting of the NPC
baseline. Doesn't Mr. Teply's proposal result in double recovery of the costs of
outages? If not, please explain why.
153. Please refer to Shu-Di~Reb-3, lines 6-8. Do the figures quoted reflect regulatory
adjustments, such as imputation of SMUD contract revenues, and removal of out of
period costs? If so, please restate the figures with those adjustments.
154. Please refer to Shu-Di-Reb-3, lines 6-8. Please provide copies of all actual Net
Power Cost reports and transaction level detail supporting the figures quoted.
155. Please refer to Shu-Di-Reb-3, lines 6-8. Has Dr. Shu made any analysis of the extent
to which load variations, hydro and wind generation deviations, or the like have
impacted the level ofNPC for the periods referenced.
PAGE 2 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
156. Please refer to Shu-Di-Reb-3, lines 6-8. Has Dr. Shu performed any analysis of and
demonstrated the prudence of the costs referenced? Ifnot, what is Dr. Shu's basis for
assuming the costs listed were in fact, all prudent?
157. Please refer to Shu-Di-Reb-3, lines 6-8. Does Dr. Shu agree that in all of the
Wyoming PCAM cases the Company has agreed to reductions to its requested actual
net power costs, as par of a stipulation?
158. Please refer to Shu-Di-Reb-3, line 10. Is it Dr. Shu's position that so long as actual
NPC is less than normalized NPC that no adjustment or even correction to GRID
model results is reasonable? For example, would correction of a math error in GRID
be uneasonable in Dr. Shu's view under curent circumstances?
159. Please refer to Shu-Di-Reb-3, lines 20-23. Is it Dr. Shu's position that only a
complete "cost plus" type of ECAM arangement provides the Company a fair
opportity to recover its power costs?
160. Please refer to Shu-Di-Reb-3, lines 20-23. Has Dr. Shu, or the Company performed
any analysis to examine why it has under-recovered Net Power Costs in Idaho, or in
any other state? Has the Company performed any tye of analysis to det~rmine why
its GRID (normalized NPC) is lower than actual NPC? If so, please provide all
documents.
161. Please refer to Shu-Di-Reb-3, lines 20-23 top page 4, line 1. Does Dr. Shu
acknowledge that at the time the Company made its Idaho fiing it was aware that its
projected NPC durng the rate effective period was much higher than the amount it
was requesting in the test year?
162. Please refer to Shu-Di-Reb-5, lines 4-10. Did Dr. Shu apply the modified screening
analysis to all gas fired plants? Identify the resources to which the screens were
applied. To the extent not provided previously, please provide the workpapers for the
new screens.
163. Please refer to Shu-Di-Reb-8, lines 7-10. Please provide copies of any prior
testimony or discovery responses made by Dr. Shu in the 2008 and 2009 Washington
general rate cases which discuss the issue of the time period (i.e., one year vs. multi-
year average) used for modeling of transmission costs and capacity.
PAGE 3 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
164. Please refer to Shu-Di-Reb-14, lines 9-11. Please explain the basis for Dr. Shu's
assumption that BP A provides a valid benchmark for judging the reasonableness of
wind integration charges. Does Dr. Shu acknowledge that BPA set's its own rates
without a conventional public service commission review?
165. Please refer to Shu-Di-Reb-14, lines 9-11. Does Dr. Shu consider BPA's pra,ctice of
charging wholesale transmission customers for wind integration services reasonable?
Please explain why PacifiCorp's transmission tarffs contain no charge for wind
integration services.
166. Please refer to Shu-Di-Reb-15, lines 15-20. Please provide copies ofPacifiCorp's
2004 and subsequent IRP documents. Indicate the level of wind integration charges
included in the Company's 2004 and subsequent IRPs.
167. Please refer to Shu-Di-Reb-16, lines 6-9. Please provide the documents Dr. Shu
relied upon in framing her discussion of the PSE and Westar cases.
168. Please refer to Shu-Di-Reb-16, line 23. Provide copies of all documents the
Company has reviewed in its tracking of FERC wind integration issues.
169. Please refer to Shu-Di-Reb-23 Figure 1. Does Dr. Shu acknowledge that Bear River
energy production in 1994 was approximately the same as the most level shown on
the char and that by 1996 Bear River was operating in Flood Control mode.
170. Please refer to Shu-Di-Reb-23 Figure 1. Does Dr. Shu believe that in 1986 it would
have been proper to assume that the Company would never be in draught conditions
in preparing its NPC forecasts?
171. Please refer to Shu-Di-Reb-23 Figure 1. Does Dr. Shu see any evidence in this figue
to demonstrate that recent prior history is useful in predicting the presence or absence
of flood control operations of the Bear River facilty? If so, please indicate how she
would use this data to make such predictions.
172. Please refer to Shu-Di-Reb-24 line 17. Provide workpapers supporting the figure
$4.7 milion.
PAGE 4 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
173. Please refer to Shu-Di-Reb-24 line 17. Explain how the $4.7 milion figure is
relevant given the fact that the Company has changed is screening methodology in
this case.
174. Please refer to Shu-Di-Reb-24 line 17. Provide the same analysis as applies to the
$4.7 milion but for the Company's rebuttal NPC fiing.
175. Please refer to Shu-Di-Reb-38 line 1-11. Please state Dr. Shu's understanding of the
purpose of a pro-forma adjustment. Is it Dr. Shu's view that a pro-forma adjustment
for the new transmission line should include all of the costs of the line, but only some
of the benefits it produces?
176. Please refer to Shu-Di-Reb-38 line 1-11. Does Dr. Shu agree that one of the ultimate
benefits of the new transmission line would be to eliminate the need for short-term
transmission purchases, such as the contract in question?
PAGE 5 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this day served the foregoing Nineteenth Set of
Data Requests to Rocky Mountain Power on behalf of the PacifiCorp Idaho Industrial Customers
upon the paries, on the official service list shown below for PAC-E-1 0-07, via electronic maiL.
Dated at Portland, Oregon, this 18th day of November, 2010.~../~
Sarah A. Kohler
Ted Weston
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
ted. weston~pacificorp.com
Paul J. Hickey
Hickey & Evans, LLP
1800 Carey Ave., Suite 700
PO Box 467
Cheyenne, WY 82003
phickey~hickeyevans.com
Mark C~ Moench
Daniel Solander
PacifiCorp/dba Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
mark.moench~pacificorp.com
daniel.solander~pacificorp.com
(ELECTRONIC COPIES ONLY)
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
datarequest~pacificorp.com
Scott Woodbury
Deputy Attorney General
Idaho Public Utilties Commission
427 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
scott. woodbury~puc.idaho.gov
Randall C. Budge
Monsanto Company
Racine Olson Nye Budge & Bailey
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
rcb~racinelaw .net
PAGE 6 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER
Eric L. Olson
Idaho Irrigation Pumpers Association, Inc.
Racine Olson Nye Budge & Bailey
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
elo~racinelaw.net
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
PO Box 844
Boise, ID 83702
botto~idahoconservation.org
Brad M. Purdy
Community Action Partnership Association of
Idaho
Attorney at law
2019 N. 17th Street
Boise, ID 83702
bmpurdy~hotmail.com
Tim Buller
Jason Harris
Agrium, Inc.
3010 Conda Road
Soda Springs, ID 83276
tbuller~agrium.com
jahars~agrium.com
Anthony Yankel
Idaho Irrigation Pumpers Association, Inc.
29814 Lake Road
Bay Vilage, OH 44140
tony~yankei.net
Dr. Don Reading
Idaho Conservation League
6070 Hil Road
Boise, ID 83603
dreading~mindspring.com
(ELECTRONIC COPIES ONLY)
Ronald L. Wiliams
PacifiCorp Idaho Industrial Customers
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise, ID 83702
ron~wiliamsbradbury .com
PAGE 7 - PIIC'S NINETEENTH SET OF DATA REQUESTS TO ROCKY MOUNTAIN
POWER