20110707PIIC 1-15 to PAC.pdf

Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays S1.
Boise ID, 83702
[phone]
[phone] (Fax)
ron~wiliamsbradbur.com
RECEIVED
2ßIJ JUL -7 PH I: 25
Attorney for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL )
OF CHANGES TO ITS ELECTRIC SERVICE )
SCHEDULES AND A PRICE INCREASE OF )
$32.7 MILLION, OR APPROXIMATELY 15.0 )PERCENT )
)
)
)
CASE NO. PAC-E-II-12
FIRST SET OF DATA REQUESTS
TO ROCKY MOUNTAIN POWER
OF THE PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS
PacifiCorp Idaho Industrial Customers ("PIIC"), by and though its attorney of record,
Ronald L. Wiliams, requests that PacifiCorp, d//a Rocky Mountain Power (the "Company"),
provide the following documents and information on or before Thursday, October 2,2011.
i. DEFINITIONS
I. "Documents" refers to all wrtings and records of every type in your possession, control,
or custody, whether or not claimed to be privileged or otherwise excludable from
discovery, including but not limited to: testimony and exhbits, memoranda, papers,
correspondence, letters, reports (including drafts, preliminar, intermediate, and final
reports), sureys, analyses, studies (including economic and market studies), sumaries,
comparisons, tabulations, bils, invoices, statements of services rendered, chars, books,
pamphlets, photographs, maps, bulletins, corporate or other minutes, notes, diaries, log
sheets, ledgers, transcripts, microfim, microfiche, computer data (including E-mail),
computer fies, computer tapes, computer inputs, computer outputs and printouts,
vouchers, accounting statements, budgets, workpapers, engineering diagrams (including
"one-line" diagrams), mechanical and electrical recordings, telephone and telegraphic
PAGE I - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
communcations, speeches, and all other records, written, electrical, mechancal, or
otherwse, and drafts of any of the above.
"Documents" includes copies of documents, where the originals are not in your
possession, custody or control.
"Documents" includes every copy of a document which contains handwrtten or other
notations or which otherwse does not duplicate the original or any other copy.
"Documents" also includes any attachments or appendices to any document.
2. "Identification" and "identify" mean:
When used with respect to a document, stating the natue of the document (~, letter,
memorandum, corporate minutes); the date, if any, appearing thereon; the date, ifknown,
on which the document was prepared; the title of the document; the general subject
matter of the document; the number of pages comprising the document; the identity of
each person who wrote, dictated, or otherwse paricipated in the preparation of the
document; the identity of each person who signed or initiated the document; the identity
of each person to whom the document was addressed; the identity of each person who
received the document or reviewed it; the location of the document; and the identity of
each person having possession, custody, or control of the document.
When used with respect to a person, stating his or her full name; his or her most recently
known home and business addresses and telephone numbers; his or her present title and
position; and his or her present and prior connections or associations with any paricipant
or pary to this proceeding.
3. "RMP" refers to Rocky Mountain Power, any affiliated company, or any officer, director
or employee of Rocky Mountain Power, or any affiliated company.
4. "Person" refers to, without limiting the generality of its meaning, every natural person,
corporation, partership, association (whether formally organzed or ad hoc), joint
venture, unt operation, cooperative, muncipality, commission, governenta body or
agency, or any other group or organzation.
5. "Studies" or "study" includes, without limitation, reports, reviews, analyses and audits.
6. The terms "and" and "or" shall be constred either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of this discovery any information
or documents which might otherwise be considered to be beyond their scope.
7. The singuar form of a word shall be interpreted as plural, and the plural form of a word
shall be interpreted as singular, whenever appropriate in order to bring within the scope
PAGE 2 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
of this discovery request any inormation or documents which might otherwise be
considered to be beyond their scope.
II. INSTRUCTIONS
I. These requests call for all information, including information contained in documents,
which relate to the subject matter of the Data Request and which is known or available to
you.
2. Where a Data Request has a number of separate subdivisions or related pars or portions,
a complete response is required to each such subdivision, par or portion. Any objection
to a Data Request should clearly indicate the subdivision, par, or portion of the Data
Request to which it is directed.
3. The time period encompassed by these Data Requests is from 200 I to the present uness
otherwse specified.
4. Each response should be fushed on a separate page. In addition to hard copy,
electronic versions of the document, including studies and analyses, must also be
fushed if available.
5. If you canot answer a Data Request in full, after exercising due diligence to secure the
information necessar to do so, state the answer to the extent possible, state why you
canot answer the Data Request in full, and state what information or knowledge you
have concerning the unanswered portions.
6. If, in answering any of these Data Requests, you feel that any Data Request or defiition
or instrction applicable thereto is ambiguous, set forth the language you feel is
ambiguous and the interpretation you are using in responding to the Data Request.
7. If a document requested is unavailable, identify the document, describe in detail the
reasons the document is unavailable, state where the document can be obtained, and
specify the number of pages it contains.
8. If you assert that any document has been destroyed, state when and why it was destroyed
and identify the person who directed the destrction. If the document was destroyed
pursuant to your document destrction program, identify and produce a copy of the
gudeline, policy, or company manua describing such document destrction program.
9. If you refuse to respond to any Data Request by reason of a claim of privilege,
confidentiality, or for any other reason, state in writing the type of privilege claimed and
the facts and circumstaces you rely upon to support the claim of privilege or the reason
for refusing to respond. With respect to requests for documents to which you refuse to
respond, identify each such document, and specify the number of pages it contains.
Please provide: (a) a brief description of the document; (b) date of document; (c) name
of each author or preparer; (d) name of each person who received the document; and (e)
PAGE 3 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
the reason for withholding it and a statement of facts constituting the justification and
basis for withholding it.
10. Identify the person from whom the information and documents supplied in response to
each Data Request were obtained, the person who prepared each response, the person
who reviewed each response, and the person who will bear ultimate responsibility for the
truth of each response.
11. If no document is responsive to a Data Request that calls for a document, then so state.
12. These requests for documents and responses are continuing in character so as to require
you to file supplemental answers as soon as possible if you obtan fuher or different
information. Any supplementa answer should refer to the date and use the number of the
original request or subpart thereof.
13. Whenever these Data Requests specifically request an answer rather than the
identification of documents, the answer is required and the production of documents in
lieu thereof will not substitute for an answer.
14. Please provide the responses to these Data Requests by Thursday, August 4,2011, to:
Ronald L. Wiliams
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
Telephone: [phone]
Facsimile: 208-344-0077
E-mail: ron~willamsbradbur.com
Don Schoenbeck
RCS, Inc.
900 Washington St, Suite 780
Vancouver W A, 98660
E-Mail: dws~r-c-s-inc.com
III. DATA REQUESTS
1. Please provide a complete copy of your responses to data requests from
Commission staff and all other paries to this proceeding. Please consider this an
ongoing request for the duration of this proceeding.
2. With regard to the EXCEL filed entitled 3.5 - REC Revenues - ID GRC Dec
2010.xlsx, please provide an EXCEL fie for each transaction comprising the REC
revenue amount for CY 2010 of $1 0 1.1 milion including the associated REC
quantity.
3. With regard to the EXCEL filed entitled 3.5 - REC Revenues - ID GRC Dec
2010.xlsx, please provide an EXCEL fie showing each transaction for the known
wind, vintage and non-wind sales in each portion of worksheet 3.5.2, including
the associated REC quantity.
PAGE 4 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
4. With regard to the EXCEL fied entitled 3.5 - REC Revenues - ID GRC Dec
2010.xlsx, please provide an explanation and all supporting documents of the $7
value used for the remaining available wind credits indicated on worksheet 3.5.2.
5. With regard to the prefied testimony of Mr. Duvall, page 4, lines 4-7, please
provide copies of all analysis and workpapers of the 629 MWs of regulation
reserves in 2010, including identifying the specific unites) that provided the
reserves each hour.
6. With regard to the prefied testimony of Mr. Duvall, page 10, lines 20 and 21,
addressing hydro normalization, does this mean the flood control years for the
Bear hydro system were excluded in deriving the expected generation form these
facilties?
7. If the answer to question 6 above is yes, please provide an EXCEL fie showing
the historical generation by month for each of the thirt years used in the
normalization process for each Bear system facilty. As par of ths response,
please identify each flood control year that was excluded in the hydro
normalization process.
8. If the answer to question 6 above is yes, please provide the GRID hydro hourly
input EXCEL csv fie with all Bear system flood control years included.
9. Please provide EXCEL workbook files to replicate the method in which the
Company converts forward electrcity prices into hourly values used as input to
the GRID modeL. Include in these workbook fies the associated MW s or MWhs
of any historical transaction used in the analysis as the Company provided in the
Oregon UE 227 proceeding.
10. With regard to question 9 above, please provide the third pary reported hourly
price transactions and the associated MW s for any additional hub modeled within
GRID for the same historical period of time used by the Company. If there are
any questions regarding this request, please call Don Schoenbeck (360-737-3877).
11. For each of the gas swap transactions contained withn the EXCEL fie provided
as attchment to Monsanto 2.34, please provide a detailed explanation on why the
Company executed the transaction along with any supporting documents. As par
of this response, provide the forward price cure for gas as of the execution date
("Done Date") for the tenor of each transaction.
12. With regard to the EXCEL workpaper fie entitled Bil Grifth Exhibits
Workpaper.xlsx, please provide the biling determinants for Schedule 6 separated
into secondar and primar voltage subclasses.
13. With regard to the EXCEL cost-of-service model file entitled COS ID GRC DEC
11.xlsm, please explain why the total values in row 132 of the Unit Cost-earned
PAGE 5 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
worksheet do not match the curent revenue for several of the classes. If it is a
structural error in the model, as par of this response, please provide a corrected
spreadsheet.
14. Please provide a complete copy of the Company's hedging policy (both gas and
electric) as of May 2007 and any subsequent revision.
15. Please provide a copy of any Idaho Commission order approving the Company's
hedging strategy in place as of May 2007 and any subsequent orders from the
Commission addressing the Company's hedging strategy.
DATED: Ths 1 day of July, 2011
j(~LiJMr
Ronald L. Willams
PAGE 6 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1 day of July, 2011, I caused to be served a true and
correct copy of the foregoing document upon the following individuals in the manner indicated
below:
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: ted.weston~pacificorp.com
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: daniel.solander(ßpacificorp.com
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello,ID 83204-1391
E-Mail: rcb(ßracinelaw.net
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Road, # 140
Chesterfeld, MO 63017
E-Mail: bcollns(ßconsultbai.com
Monsanto Company
James R. Smith
Monsanto Company
PO Box 816
Soda Springs, ID 83276
E-mail: jim.r.smith(ßmonsanto.com
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PAGE 7 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Eric L. Olson
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello,ID 83204-1391
E-Mail: elo(ßracinelaw.net
Attorney for Idaho Irrigation Pumpers
Association
Anthony Yankel
29814 Lake Road
Bay Vilage, OH 44140
E-Mail: tony(ßyankeLnet
Idaho Irrigation Pumpers Association
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-mail: bmpurdy(ßhotmaiLcom
Attorney for CAPAI
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
E-mail: botto(ßidahoconservation.org
Neil D. Price
Idaho Public Utilties Commission
472 W. Washington Street
Boise,ID 83720-0074
E-mail: neiLprice(ßpuc.daho.gov
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f!J1Lh)~
Ronald L. Wiliams
PAGE 8 - PIIC'S FIRST SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER