20110726Staff 114-135 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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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 FOR APPROVAL OF CHANGES TO )
ITS ELECTRIC SERVICE SCHEDULES )
)
)
)
)
CASE NO. PAC-E-l1-12
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
PACIFICORP DBA 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 PacifiCorp dba Rocky Mountain Power (Company;
Rocky Mountain) provide the following documents and information on or before TUESDAY,
AUGUST 16,2011.
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.
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
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JULY 26,2011
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 IDAP A 31.01.01.228.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 114: Please provide a NPC GRID ru utilzing the Company's wind
integration method from the previous general rate case (PAC-E-10-07), assuming an integration cost
of $9.70 per MWh.
REQUEST NO. 115: Please provide a list of all wind resources included in the Company's
NPC calculation. Please note which are Company-owned, PPA, or QF (and state).
REQUEST NO. 116: Please calculate the net Idaho revenue requirement (benefit or cost) of
the Company's wind resources. Please include within your response the detail calculations and
models in Excel format with formulas intact that include:
a. Rate base, depreciation, property tax, maintenance and operations, wind integration costs,
and any other costs associated with the Company's wind resources.
b. Renewable energy credits retured to customers associated with the wind resources.
c. Power supply expense with wind included as a resource and wind excluded as a resource
(please both models).
d. Any other cost or benefit not explicitly referenced above that is relevant to calculation of
net benefit or cost.
e. Annual cost associated with wind energy purchase contracts.
REQUEST NO. 117: Please provide, in MWh, the amount of renewable generation used to
meet all RPS requirements for each state in 2010. If specific resources were used to meet the RPS
requirements, please provide a list.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JULY 26,2011
REQUEST NO. 118: Please provide the analysis performed by the Company, referenced on
page 20 of Mr. Duvall's direct testimony, which calculated actual reserves for 2010.
REQUEST NO. 119: Does the Company believe day-ahead wind generation forecast errors
are reduced as more historic data points become available? Please explain your response.
REQUEST NO. 120: How much of the $0.72/MWh (Duvall Direct, p. 19) included for day-
ahead forecast error is associated with wind?
REQUEST NO. 121: How much of the $0.72/MWh (Duvall Direct, p. 19) included for day-
ahead forecast error is associated with load?
REQUEST NO. 122: What cost has the Company historically included for day-ahead
forecast error associated with load?
REQUEST NO. 123: The total nameplate capacity of the Company's thermal resource
generation was shown in GRID as 8,455 MW in Case PAC-E-1O-07, but now is shown as 8,410 MW
in this case. Please provide an explanation to the overall reduction in nameplate capacity for the
Company's thermal generation when compared to the previous NPC fiing. Provide any supporting
documentation with your response.
REQUEST NO. 124: Please provide actual monthly wheeling expenses incurred from 2008
through the most currently available period.
REQUEST NO. 125: Please provide actual monthly wheeling revenues incurred from 2008
through the most currently available period.
REQUEST NO. 126: Please provide an analysis of wheeling revenues that explains the
underlying reasons for the decline and whether that trend is expected to continue in 2011.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JULY 26,2011
REQUEST NO. 127: Please provide actual monthly off-system sales revenues incurred from
2008 through the most currently available period.
REQUEST NO. 128: Please provide actual monthly off-system purchases incured from
2008 through the most currently available period.
REQUEST NO. 129: Has the Company excluded flood years from the calculation of Bear
River hydro generation as it did in the previous case?
REQUEST NO. 130: Please provide a detailed explanation of AGA revenue, found
throughout Mr. Griffth's exhibits, including how these revenues are generated.
REQUEST NO. 131: Please provide the source data for AGA revenues included in this case.
REQUEST NO. 132: Please provide AGA revenues by class for the past five years.
REQUEST NO. 133: Please provide a copy of the NV Energy Wholesale Contract.
REQUEST NO. 134: Please explain how the NV Energy contract is modeled in GRID. If
not included in GRID, please explain why.
REQUEST NO. 135: Please provide a copy of all natural gas procurement and hedging
policies the Company utilizes for fueling its gas-fired generation.
DATED at Boise, Idaho, this;~day of July 201 1.
~.rJ .' 'NeiiPrc~
Deputy Attorney General
Technical Staff: Bryan LansperyIl14-135
i:umisc:prodreq/pacel1.2npbl prod req4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JULY 26, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF JULY 2011, SERVED
THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION
STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER,
IN CASE NO. PAC-E-11-12, 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.westonCÐpacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solanderCÐpacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datarequestCÐpacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcbCÐracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWIGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollnsCÐconsultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smithCÐmonsanto.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: eloCÐracinelaw.net
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tonYCÐyanel.net
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdYCÐhotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: botto(fidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
iois W HAYS STREET
BOISE ID 83702
E-MAIL: ronCÐwiliamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dwsCÐr-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INCINU- WEST INDUSTRIES
E-MAIL: tbullerCÐagrium.com
Jo~
SECRETARY
CERTIFICATE OF SERVICE