20110725PIIC 39-49 to PAC.pdf

WILLIAMS. BRADBURY
ATTORNEYS AT LAW REeEI 0
201 I JUL 25 PM 3: 0 I
July 22,2011
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
Re: PAC-E-11-12
Dear Ms. Jewell:
Please find enclosed an original and thee copies of the Third Set of Data Requests to
Rocky Mountain Power of the PacifiCorp Idaho Industrial Customers for filing in the above
referenced case.
Than you for your assistace in this matter. Please feel free to give me a call should
you have any questions.
Sincerely,
/7W1 hJ~
Ronald L. Willams
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)
ronCfwiliamsbradbur .com
RECEI D
lOll JUl 25 PH 3: 0 I
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-11-12
THIRD 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 Friday, August 19,2011.
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 wil 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
pursuat 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 THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN 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:
39. With regard to the EXCEL wookbook fie entitled 2nd_c2 _IDGRCw _Electric Swaps
(1103) (Confdential).xlsx, please provide the detailed transactional data for the months
of Janua, Februar and March 2011 ("settled" months) to support the mark-to-market
amounts shown on the worksheet entitled Settled Electric SWP.
40. With regard to the EXCEL wookbook file entitled 2nd_c2 _IDGRCw _Gas Swaps (1103)
(Confidential).xlsx, please provide the detailed transactional data for the months of
Janua, February and March 2011 ("settled" months) to support the mark-to-market
amounts shown on the worksheet entitled Settled Gas SWP.
41. With regard to the confidential EXCEL fie provided in response to Monsanto request
2.34, please explain why the Company used only the fixed price hedges in deriving the
hedged volume percentages shown on the Hedged Volumes worksheet.
42. With regard to the confidential EXCEL fie provided in response to Monsanto request
2.34, the Hedged Volumes worksheet, Colum I, please provide the supporting
documents in EXCEL file format for the monthy MMBTU values.
43. With regard to the Company's response to PUC request 15, please provide copies of any
materials prepared for the October 28,2009 presentation of the Company's hedging
strategy along with any supporting documents.
44. With regard to the Company's hedging strategy in place as of May 2007, please provide
copies of all documents relied on by the Company to determine the tenor (used here as
the sta and end dates of the transaction) and transaction effective period (used here to
mean the execution date to the end of the transaction) for electricity and gas hedges.
45. With regard to the Company's electricity and gas hedging strategy, please provide copies
of any documents where the Company or a consultat on its behalf have sureyed the
hedging strategies of other electric (or combination electric and gas) utilities.
46. With regard to the Company's electricity and gas hedging strategy, please provide copies
of any documents the Company has in its possession regarding hedging strategies of
other electric (or combination electric and gas) utilities.
47. With regard to the Company's electricity and gas hedging strategy, please provide a list
of counter paries the Company could hedge either electricity or gas for a transaction in
2007 for an effective period when of: a) up to 12 months, b) up to 24 months, c) up to
PAGE 2 - PIIC'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
36 months, d) up to 48 months, e) up to 60 months. Please identify any counter pary
that would require additional levels of approval as the transaction effective period is
lengthened. For this response, transaction effective period is the period of time from
when the transaction is executed ("done date") to the final date the transaction is
effective ("end date").
48. With regard to the Company's electricity and gas hedging strategy, please provide a list
of counter paries the Company could hedge either electricity or gas for a transaction as
of Januar 2011 for an effective period when of: a) up to 12 months, b) up to 24 months,
c) up to 36 months, d) up to 48 months, e) up to 60 months. Please identify any counter
par that would require additional levels of approval as the transaction effective period
is lengtened. For this response, transaction effective period is the period of time from
when the transaction is executed ("done date") to the final date the transaction is
effective ("end date").
49. With regard to the direct testimony of Mr. Duvall, page 9, line 21 though page 10,
line 2, please identify the specific GRID input file where the on and off peak Cal iso
transactions are located showing both the energy and associated price for the 4C, COB
and Mona hubs.
DATED: This 22nd day of July, 2011
kJJlwAA
Ronald L. Wiliams
PAGE 3 - PIIC'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22nd 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(fpacificorp.com
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
E-Mail: danieL.solander(fpacificorp.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~racinelaw.net
Attorney for Monsanto Company
Brubaker & Associates
16690 Swingley Ridge Road, # 140
Chesterfield, MO 630 i 7
E-Mail: bcollns~consultbai.com
Monsanto Company
James R. Smith
Monsanto Company
PO Box 816
Soda Springs, ID 83276
E-mail: jim.r.smith~monsanto.com
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
PAGE 4 - PIIC'S THIRD 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 Yankel
298 i 4 Lake Road
Bay Vilage, OH 44140
E-Mail: tony~yankel.net
Idaho Irrigation Pumpers Association
Brad M. Purdy
2019 N. 17th Street
Boise, ID 83702
E-mail: bmpurdy~hotmaiL.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: neiL.price~puc.idaho.gov
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
D Hand Delivery
D US Mail (postage prepaid)
D Facsimile Transmission
D Federal Express
i: Electronic Transmission
.j¿ LV~
Ronald L. Willams
PAGE 5 -PIIC'S THIRD SET OF DATA REQUESTS TO ROCKY MOUNTAIN POWER