20110721PIIC 16-38 to PAC.pdf

WILLIAMS . BRADBURY
ATTORNEYS AT LAW
RECEIVED
20ll JUL 21 AM 8= 26
July 20,2011
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
Re: PAC-E-ll-12
Dear Ms. Jewell:
Please find enclosed an original and three copies of the Second Set of Data Requests
to Rocky Mountan Power of the PacifiCorp Idaho Industrial Customers for filing in the
above referenced case.
Than you for your assistance in this matter. Please feelfree to give me a call should
you have any questions.
Sincerely,
fltA U~
Ronald L. Wiliams
RLW/jr
Enclosures
1015 W. Hays Street - Boise, ID 83702
Phone: [phone] - Fax: [phone] - ww.wiamsbradbur.com
Ronald L. Wiliams, ISB No. 3034
Wiliams Bradbur, P.C.
1015 W. Hays St.
Boise ID, 83702
[phone]
[phone] (Fax)
ron~willamsbradbury.com
RECEI D
zon JUL 21 AM 8: 26
i..""t
\..1
Attorney for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICA nON 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-11-12
SECOND SET OF DATA
REQUESTS TO ROCKY
MOUNTAIN POWER OF THE
PACIFICORP IDAHO
INDUSTRIAL CUSTOMERS
PacifiCorp Idaho Industrial Customers ("PUC"), by and through 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 Wednesday, August 17, 2011.
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementa responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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
PAGE 1 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAI POWER
and, if different, the witness who can sponsor the answer at hearng if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic fied on CD with formulas activated.
DATA REQUESTS:
For Data Requests 16 through 38 below, please also provide a copy of your response
directly to Randall Falkenberg.
16. Please provide all documents supporting the figues quoted in Duvall Di-4, specifically,
the figures 533 and 629 on lines 5 and 6.
17. Please provide all documents supporting the figues quoted in Duvall Di-4, specifically,
the figures 2183 and 6.50 on lines 19 and 21.
18. Please provide the complete GRID database used to produce the NPC study used in this
case.
19. Please provide workpapers for GRID inputs comparable to those provided in Wyoming
Docket 20000-384-ER-10, in response to the Stadardized Data Requests provided to
WIEC.
20. Please provide copies of all NPC related data request answers posed by WIEC in
Wyoming Docket No. 20000-384-ER-10, or please provide Mr. Falkenberg permission
to use the answers he already has in his possession.
21. Please provide copies of all NPC related data request answers posed by WIEC in
Wyoming Docket No. 20000-389-ER-11, or please provide Mr. Falkenberg permission
to use the answers he already has in his possession.
22. Please provide copies of all NPC related data request answers posed by OCS in Uta
Docket No. 10-035-124 or please provide Mr. Falkenberg permission to use the answers
he already has in his possession.
23. Please provide copies of the NPC related filing requirements provided by the Company to
paries in Uta Docket No. 10-035-124, or please provide Mr. Falkenberg permission to
use the data he has in his possession.
PAGE 2 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
24. Please explain how to remove all wind integration costs from the test year used in this
case, including a description of the GRID input changes required.
25. Please provide all documents supporting the regulating margin inputs modeled in the
GRID study including the East and West Regulating Margin Max, Regulating Margin
Min and Reguating Margin Base.
26. Please provide a comparison of the Company's requested charges for wind integration
services as requested in its curent FERC Transmission Rate Case ("TRC") and the
Company's requested wind integration charges in this case.
27. Please provide workpapers and all documents supporting the Company's request for tariff
charges related to recovery of wind integration costs in the curent TRC.
28. Please provide all documents supporting the GRID input called Minimum Resource
Contribution (MWH).
29. Please provide all documents used to compute the intra hour and inter hour wind
integration related inputs used in this case.
30. Please provide the actual wind integration costs paid to BPA for Goodnoe and Leaning
Juniper for each month since the projects began operation to present.
31. Please provide copies of any testimony the PacifiCorp fied (or was filed on behalf of
PacifiCorp) in the curent and prior BP A Wholesale rate cases.
32. Please provide all documents used to compute the screens used in GRID in this case.
33. Please provide the hourly generator logs for all thermal, hydro and wind resources for the
period staing Januar 1,2007 to June 30, 2011. Please provide the wind data for all
wind projects included in the GRID output report. Include all Company owned,
purchased and non-owned wind projects operating in the test period.
34. Please provide accurate ten minute generation data for all wind projects included in the
test year for the period January 1, 2007-June 30, 2011. Please provide in a format
comparable to WIEC 3.2 from Wyoming Docket No. 20000-389-EP-1 1. Include all
Company owned, purchased and non-owned wind projects operating in the test period.
PAGE 3 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
35. Please provide hourly spinning and non-spinnng reserves allocations for all resources
available to PacifiCorp for the period January 1,2007 to June 30, 2011. Please provide
in the same format as WIEC 8.14 from Wyoming Docket 20000-384-ER-10.
36. Please provide the hourly spinnng and non-spinnng contingency reserve requirements
for the period Janua 1,2007 to June 30, 2011. Please provide in the same format as
WIEC 8.15 from Wyoming Docket 20000-384-ER-10.
37. Please provide the PACE and PACW CPS2 results for the period Janua 1,2007 to June
30,2011. Please use the same format as WIEC 8.8 from Wyoming PSC Docket
No.0000-384-ER-1O.
38. Please provide all documents supporting the requested transmission wheeling costs
included in the test year.
ì'"DATED: Ths ':Oday of July, 2011
xll LLj~
Ronald L. Wiliams
PAGE 4 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
l..I HEREBY CERTIFY that on this 10 day of July, 2011, I caused to be served a tre 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. So lander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: daniei.solander~pacificorp.com
Data Request Response Center
PacifiCorp
825 NE Multonomah St., Suite 2000
Portland, OR 97232
E-Mail: datarequest~pacificorp.com
Randall C. Budge
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: rcb~acinelaw.net
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Road, # 140
Chesterfeld, MO 63017
E-Mail: bcollns~consultbai.com
Monsanto Company
James R. Smith
Monsanto Company
POBox 816
Soda Springs, ID 83276
E-mail: jim.r.smith~monsanto.com
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PAGE 5 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
Eric L. Olsen
Racine Olson Nye Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: elo~racinelaw.net
Attorney for Idaho Irrigation Pumpers
Association
Anthony Yanke i
29814 Lake Road
Bay Vilage, OH 44140
E-Mail: tony~yankei.net
Idaho Irrigation Pumpers Association
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-mail: bmpurdy~hotmaii.com
Attorney for CAP AI
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
E-mail: botto~idahoconservation.org
Neil D. Price
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83720-0074
E-mail: neii.price~puc.daho.gov
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/7 Jd L hI))
Ronald L. Wiliams
PAGE 6 - PIIC'S SECOND SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER