20101126PAC to PIIC 150-152, 160, etc.pdf

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l1nu 2r Mi 9: SOinmnL;' ,J 201 South Main, Suite 2300
Salt Lake City, Utah 84111
November 24,2010
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portland, Oregon 97204
RE: ID P AC-E-1O-07
PILC Data Request (150-176)
Please find enclosed Rocky Mounta Power's responses to PILC Data Requests 150-152, 160,
163-164, 166-168, and 175. Provided on the enclosed CD is Attchment 166.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J. T.¿¿( Ú/L~/~
J. Ted Weston
Manager, Reguation
Enclosure:
cc: Jean Jewell/UC (C)/ 3 copies
Enc Olsen/IIPA (C)
Ben Oto/ICL (C)
Radal Budge/Monsanto (C)
James R. Snithonsanto (C)
Richard AndersonIonsanto (C)
George C. Carer, IlI/onsanto (C)
Denns Peseau/onsanto (C)
Gareth R. Kajander/Monsanto (C)
Maunce Brubaker/Monsanto (C)
Bnan Collns/Monsanto (C)
Michal Gormanonsanto (C)
Kath IversonIonsanto (C)
Mark Widmer/Monsanto (C)
Greg MeyerlPIlC (C)
Don ShoenbekIIlC (C)
PAC-E-10-07/Rocky Mountan Power
November 24,2010
PIlC Data Request 150
PIIC Data Request 150
Please refer to Teply Di-Reb-5, line 23. Explain how the liquidated daages
payment was credited to Idaho retail customers. Explain where the adjustment
was made in ths case or in a pnor case.
Response to PIIC Data Request 150
Due to the timng of ths incident and the related payment of liquidated daages,
neither the costs of the incident nor the liquidated daages payment were passed
on to customers. The Company's first ECAM filing in Idao covered the penod
of July though November 2009, and the liquidated daages payment was not
included as a credit to customers. However, the NPC baseline set in the previous
general rate case did not reflect the cost of the event. Now that an ECAM is
established, the cost of similar events occurg in the futue, net of any liquidated
damages received, will be passed on to customers though tht mechansm.
Recordholder:
Sponsor:
Steve McDouga / Hui Shu
Steve McDougal / Hui Shu
PAC-E-I0-07/Rocky Mountain Power
November 24,2010
PILC Data Request 151
PIIC Data Request 151
Please refer to Teply Di-Reb-6, lines 1-4. Does Mr. Teply acknowledge that, if
prudent, the costs of ths incident will be recovered in an ECAM filing that ha
been or wil be filed by the Company. If so, explai the justification for
additional collection of these costs via inclusion in the NPC baseline.
Response to PIIC Data Request 151
No. Due to timig, the dirct costs of ths incident will not be recovered in an
ECAM filing. The Company's previously filed ECAM included actul costs from
July though November 2009, and the costs of ths incident were incured pnor to
July 2009; the associated liquidated daages were received subsequently but not
included in the ECAM filing.
Recordholder:
Sponsor:
Steve McDougal / Hui Shu
Steve McDougal / Hui Shu
../PAC-E-10-07/Rocky Mountai Power
November 24,2010
PILC Data Request 152
PIIC Data Request 152
Please refer to Teply Di-Reb-6, lines 1-12. Explai Mr. Teply's understding of
the recovery of outage costs as occur 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? Ifnot, please explai why.
Response to PIIC Data Request 152
Outage costs are included in the NPC baseline based on the four-year average
outage rate for thermal generating unts. Tht NPC baseline is compared to actul
NPC in the ECAM proceeding with the difference between actu costs and the
baseline either recovered from or retued to customers afr application of a 10
percent sharg band. Actu outage costs in NPC are included in the companson.
Ultimately it is actu, prudent outage costs durg each ECAM penod, less
applicable sharg, that are recovered from customers. There is no double
recovery.
Recordholder:
Sponsor:
Steve McDougal / Hui Shu
Steve McDougal / Hui Shu
PAC-E-I0-07/Rocky Mountan Power
November 24,2010
PILC Data Request 160
PIIC Data Request 160
Please refer to Shu-Di-Reb-3, lines 20-23. Has Dr. Shu, or the Company
performed any analysis to examne why it has under-recovered Net Power Costs
in Idao, or in any other state? Has the Company performed any type of analysis
to determine why its GRID (normalized NPC) is lower than actu NPC? If so,
please provide all documents.
Response to PIIC Data Request 160
The under recovery ofNPC is due to the fact tht NPC are volatile and are largely
outside the control of the Company. The Company manages its net open position
so loads and resources are balanced; however, significant vanations subsequently
occur in the net open position though the actual penod as a result of the large,
uncontrollable and unpredictable volatilty in both loads and resources tht occur
simultaeously with large, uncontrollable and unpredictable volatilty in pnces of
natual gas and electrcity. Please also refer to the Company's response to PILC
Data Request 155.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-I0-07/Rocky Mountain Power
November 24,2010
PILC Data Request 163
PIIC Data Request 163
Please refer to Shu-Di-Reb-8, lines 7-10. Please provide copies of any pnor
testimony or discovery responses made by Dr. Shu in the 2008 and 2009
Washigton general rate cases which discuss the issue of the time penod (i.e., one
year vs. multi-year average) used for modeling of transmission costs and capacity.
Response to PIICData Request 163
Copies of Dr. Shu's testimony for the 2008 and 2009 Washigton general rate
cases can be located at the below lins:
UE-080220
htt://wutc.wa.gov/rms2.nsf/fr005VwDSWeb! OpenForm&vw2005L 1 DktSh=O
80220-Documents&NA V999999
UE-090205
htt://wutc. wa.gov/rms2.nsf/fr005VwDSWeb!OpenForm&vw2005L 1 DktSh=O
90205-Documents&NA V999999
PIlC may use the Company's responses provided in Docket's UE-080220 and
UE-090205, subject to the Company's reservation of all evidentiar objections.
Use of the Company's confdential data provided in the above-referenced docket
will be subject to maintag the confdentiality of such data on the terms and
conditions of protective orders and confdentiality agreements in tht docket. Use
of confdential responses from other proceedings is also subject to the terms and
conditions of the protective order in ths docket.
Recordholder: NI A
Sponsor: N/ A
PAC-E-10-07/Rocky Mountain Power
November 24,2010
PIlC Data Request 164
PUC Data Request 164
Please refer to Shu-Di-Reb-14,lines 9-11. a.) Pleae explai the basis for Dr.
Shu's assumption tht BP A provides a valid benchmark for judgig the
reasonableness of wind integration chages. b.) Does Dr. Shu acknowledge that
BP A sets its own rates without a conventiona public service commission review?
Response to PIIC Data Request 164
a BP A is an entity that has a wind integrtion charge in its taff.
b. Yes.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-I0-07/Rocky Mounta Power
November 24,2010
PIle Data Request 166
PIIC Data Request 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 wid integration
charges included in the Company's 2004 and subsequent IRs.
Response to PUC Data Request 166
Please refer to Attchment PILC 166 for the level of wid integration charges in
the IRP documents since 2004 IR.
Recordholder:
Sponsor:
Michael Liljenwall
Hui Shu
PAC-E-l 0-07 /Rocky Mountain Power
November 24, 2010
PIlC Data Request 167
PIIC Data Request 167
Please refer to Shu-Di-Reb-16, lines 6-9. Please provide the documents Dr. Shu
relied upon in framg her discussion of the PSE and Westa cases.
Response to PUC Data Request 167
The documents relied upon for ths portion of the discussion come from two
public dockets at the Federal Energy Reguatory Commssion ("FERC"). The
PSE docket is "FERC Docket No. ERlO-1436". The Westa docket is "FERC
Docket No. ER09-1273". Both of these dockets and the publicly available
documents associated with each may be accessed through FERC's "eLibrar"
using the "General Search" lin and the docket numbers provided above:
http://ww.ferc. gov I docs- fiihg/elibrar.asp
Recordholder:
Sponsor:
Sarah E. Edmonds
Darell Gerrard
"P AC-E-l 0-07/Rocky Mounta Power
November 24,2010
PIlC Data Request 168
PIIC Data Request 168
Please refer to Shu-Di-Reb-16, line 23. Provide copies of all documents the
Company has reviewed in its trckig of FERC wind integration issues.
Response to PUC Data Request 168
Please refer to the Company's response to PILC Data Request 167. In addition,
the documents relied upon for ths portion of the discussion also include the
public ruemakg docket at the Federal Energy Reguatory Commssion
("FERC"). The docket is "FERC Docket No. RM10-11". Ths docket and the
publicly avaiable documents associated with each may be accessed though
FERC's "eLibrar" using the "Genera Search" lin and the docket number
provided above:
http://ww.ferc.gov/ docs- fiing/elibra.asp
Recordholder:
Sponsor:
Sarah E. Edonds
Darell Gerrard
,PAC-E-10-07/Rocky Mountain Power
November 24,2010
PIlC Data Request 175
PIIC Data Request 175
Please refer to Shu-Di-Reb-38 line 1-11. Please state Dr. Shu's understading of
the purose 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?
Response to PUC Data Request 175
The pro-forma adjustments are to reflect known-and-measurble chages to the
histoncal data that are expected to occur durg the test penod. The Company ha
made adjustments to the short-term fi tranmission the Company acquied
histoncally to reflect the addition of the Populus to Termal line. There are no
known chages to the terms of the transmission contract with Idao Power
Company in the test penod.
No.
Recordholder:
Sponsor:
Hui Shu
Hui Shu