20110208Staff 1-15 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
REeE
ZûH FEB -8 PM l: 58
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER'S REQUEST FOR APPROVAL OF )
REVISIONS TO ITS DISPATCHABLE )
IRRGATION LOAD CONTROL PROGRAM. )
)
)
)
CASE NO. PAC-E-11-6
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; PacifiCorp; Rocky Mountain Power) provide the following documents and
information as soon as possible, but no later than TUESDAY, FEBRUARY 22, 2011.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
FIRST PRODUCTION REQUEST TO
PACIFICORP DBA ROCKY MOUNTAIN POWER 1 FEBRUARY 8, 2011
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide a copy of the 2010 Idaho Irrigation Load Control
Program Report.
REQUEST NO.2: Please confirm that the Company proposes limiting participating
sites to a minimum 50 hp pump size, resulting in an estimated elimination of 13 MW from the
Program.
REQUEST NO.3: If the previous inquiry is confirmed, does the Company believe it is
appropriate to include minimum pump size in the tariff language?
REQUEST NO.4: Please calculate the cost effectiveness of the Program, for 2010,
implementing only the Company's proposed change to the opt-out penalty. Please provide all
workpapers used in the calculation.
REQUEST NO.5: Please provide a detailed list of each Control Event, time, date,
number of sites interrpted, number of opt-outs, amount of MW curiled, and amount of MW
opted out, for the 2010 Program.
REQUEST NO.6: Please calculate the cost effectiveness of the Program, for 2010,
implementing only the Company's proposed change to the credit payment. Please provide all
workpapers used in the calculation.
REQUEST NO.7: Please list any additional criteria beyond that included in the
proposed tariff language the Company may consider in the paricipation selection process.
FIRST PRODUCTION REQUEST TO
PACIFICORP DBA ROCKY MOUNTAIN POWER 2 FEBRUARY 8, 2011
REQUEST NO.8: Please provide a copy of the February 15 letter sent to prospective
paricipants.
REQUEST NO.9: When wil the Company inform prospective participants of selection
or exclusion from the Program prior to the star of the season?
REQUEST NO. 10: Please list the substations and circuits experiencing voltage
excursions AND provide a map locating the substations, circuits and participating irrigation
customers. What percentage of participating substations does this represent?
REQUEST NO. 11: Please define the types of voltage excursion the system undergoes
during Program dispatch events. Explain the impact of each voltage excursion to the system.
REQUEST NO. 12: What mitigation methods had the Company considered and/or tried
to address the voltage excursions and load loss?
REQUEST NO. 13: Does the Company have any type of Voltage Regulators in place in
any of the circuits affected to maintain a constant voltage level? Explain why this method of
voltage regulation does or does not work to address the voltage excursions and load loss.
Identify which circuit does or does not have installed voltage control equipment.
REQUEST NO. 14: On page 2 of the Application, the Company stated "the dominance
of the participating agricultural pump loads on some circuits is simply beyond the compensatory
abilities of the Company's installed voltage control equipment." What is the threshold point i.e.,
a percentage of the substation/circuit capacity, of each circuit when this circumstace wil occur?
Please identify the threshold points separately for each circuit if they differ from each other.
REQUEST NO. 15: Please explain how the Company determined the threshold points
for the circuits.
FIRST PRODUCTION REQUEST TO
PACIFICORP DBA ROCKY MOUNTAIN POWER 3 FEBRUARY 8, 2011
DATED at Boise, Idaho, this ~~day of February 2011.
IlJL~
-Neil Price
Deputy Attorney General
Technical Staff: Bryan Lanspery/l-9
TJ Golo/l 0- 15
i:umisc:prodreq/pace i i .6npbltj prod req i
FIRST PRODUCTION REQUEST TO
PACIFICORP DBA ROCKY MOUNTAIN POWER 4 FEBRUARY 8, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF FEBRUARY 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP, IN CASE NO. PAC-E-11-06, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MGR
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: ted.weston(fpacificorp.com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SAL T LAKE CITY UT 841 1 I
E-MAIL: daniel.solanderaYpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
dataequestßYpacificorp.com
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SECRETARY
CERTIFICATE OF SERVICE