20110602Staff 1-8 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 6864
RECEIVED
2011 JUN -2 AM 9: S5
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 PACIFICORP DBA
ROCKY MOUNTAIN POWER'S 2011
INTEGRATED RESOURCE PLAN.
)
) CASE NO. PAC-E-11-10
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) ROCKY MOUNTAIN POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that Rocky Mountain Power (Company; Rocky
Mountain) provide the following documents and information as soon as possible, but no later
than THURSDAY, JUNE 23, 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 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
ROCKY MOUNTAIN POWER 1 JUE 2, 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 preparng the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: What assumptions are made regarding load growth in service
territories throughout the West during the IRP timeline? How do these assumptions affect
market purchase availabilty?
REQUEST NO.2: Does PacifiCorp curently have the transmission or transmission
rights to procure the level of market purchases listed in the preferred portfolio?
REQUEST NO.3: What natural gas price forecast (low, medium, high) does the market
reliance 'stress test' included in Appendix H utilze?
REQUEST NO.4: For utilty solar projects, is it accurate to say that the IRP
incorporates both the 30% investment tax credit (Emergency Economic Stabilzation Act of
2008) or cash grant in lieu of the ITC and production tax credits extended in 2009?
REQUEST NO.5: Why was a heat rate of 11,750 Btu/Wh selected as the heat rate for
gas backup of solar?
REQUEST NO.6: With regard to Action Item 6 on page 261, what is the capacity
savings associated with the 499,059 MWh savings from Class 2 DSM?
REQUEST NO.7: Please provide further explanation of how interrptible industrial
loads are treated in load forecasting. Are the interrptible products assumed to be available
through the planing horizon, and if so, at what cost?
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 2 JUNE 2, 2011
REQUEST NO.8: How does PacifiCorp address within the 2011 IRP the risk
associated with the loss of one or several interruptible products provided by industrial
customers?
DATED at Boise, Idaho, this ?'rJday of June 2011.~
tJ '-.¡(/~~
Neil Price
Deputy Attorney General
Technical Staff: Bryan Lanspery
i:umisc:prodreq/pace 11. Onpblrps prod req l.doc
FIRST PRODUCTION REQUEST TO
ROCKY MOUNTAIN POWER 3 JUE 2, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF JUNE 2011, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-ll-lO,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY 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
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander(fpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguest(fpacificorp.com
CERTIFICATE OF SERVICE