20110811Staff 181-193 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
\
RECEIVED
ZOU AUG I I PM 2: 2 l
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
SIXTH PRODUCTION REQUEST
OF THE COMMISSION STAFF
TO PACIFICORP DBA ROCKY
MOUNTAIN POWER
The Staff of the Idaho Public Utilties 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
THURSDAY, SEPTEMBER 1,2011.
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 preparng the document, and the name, location and phone number of the record holder
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 11,2011
and, if different, the witness who can sponsor the answer at hearing if need be. Reference
IDAPA 31.01.01.228.
Please provide all Excel and electronic fies on CD with formulas activated.
REQUEST NO. 181: Please provide a volume and percentage breakdown of
underground versus surface mined coal at Bridger Coal Company.
REQUEST NO. 182: Please provide a detailed breakdown of the cost increases
associated with both underground and surface mining operations at Bridger Coal Company.
REQUEST NO. 183: According to Company testimony (Cindy Crane, page 11, line 2),
reduced volume from the Bridger mine caused by downtime from two longwall moves in 2011
wil result in significant underground mining cost increases. Please provide a historical record of
the number of longwall moves completed at the Bridger mine since longwall operations began as
well as the amount of downtime, volume of production, and associated cost lost each year. Also,
please provide a forecast for the same type of downtime for 10 years into the future.
REQUEST NO. 184: Please provide a breakdown of the wage, material, and supply
costs that make up the increase in coal cost per ton from the Trapper mine.
REQUEST NO. 185: Please explain how the Coal Daily index changed (according to
direct testimony by Cindy Crane, page 6, line 8) and provide an explanation of the Company and
Sufco's different interpretations of the index and how it lead to different coal price estimates.
REQUEST NO. 186: Please provide a copy of any analysis used to determine optimal
/lowest cost coal supply chains to PacifiCorp generation plants. Include tradeoffs between
supply options relative to transportation cost, undelivered coal cost, coal qualitylheat content,
and any other factors critical to selecting the alternatives.
REQUEST NO. 187: According to direct testimony (Cindy Crane, page 8, line 22
through page 9, line 3), an agreement between the Company and Chevron Mining was made to
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 11,2011
exchange an advanced effective date for a new contract price (advanced 6 months) for current
price protections and also for future price resets that adjust the contract price to Chevron's actual
mining costs. With the Februar 2011 anouncement by Chevron to sell the mine, please
provide an explanation of how the Company will guarantee that this price arrangement will be
honored by the new owner?
REQUEST NO. 188: Direct testimony (Cindy Crane, pagel4, lines 12-17) shows that
the "Company does not anticipate any reduction from curent target ranges (of inventory) that are
in line with policy." However, in the following sentence, testimony indicates that Utah and
Colorado are experiencing depleting coal reserves and that the Company faces uncertain labor
negotiations at the Deer Creek mine which is a significant supply of the company's fuel supply
for Utah plants. Please reconcile the two statements and provide a time frame that reductions are
not anticipated.
REQUEST NO. 189: Are the coal balance figures for the Bridger plant included in
Exhibit No. 38 equal to the total inventory for the plant or is this PacifiCorp's share of the
inventory?
REQUEST NO. 190: Please provide a copy of the Pincock, Allen, & Holt supply chain
analysis mentioned in Cindy Crane's direct testimony (page 12, line 22).
REQUEST NO. 191: How much coal (tons and dollars)wil the Company use/consume
from Arch Coal, Inc.' s Sufco mine under the 2010 pricing agreement/schedule versus the new
2011 pricing agreement/schedule. Please break usage by contract year and by tier. Also provide
the amount of coal (tons and dollars) that would be purchased under each agreement (by tier) at a
level required to maintain the midpoint of the Company's long-term inventory goal.
REQUEST NO. 192: Please refer to Company Exhibit No.2, Adjustment 8.12 and
related pages 8.12.1 and 8.12.2. Please provide all supporting documentation that identifies the
Klamath Hydroelectric Settlement Agreement (KHSA) provisions and how each O&M project
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 11,2011
amount on 8.12.1 and capital amount on 8.12.2 were derived. Please include within your
response the KHSA required timing of the projects and activities on both pages.
REQUEST NO. 193: Please provide the actual expenditures incured to date for each
activity and project on 8.12.1 and 8.12. Please include within your response a detail listing of
transactions that includes invoice number, description of payment, vendor name, date posted,
FERC account posted and dollar amount.
DATED at Boise, Idaho, this ~l~ay of August 2011.
rJ~
Neil Price
Deputy Attorney General
Technical Staff: Mike Louis/181-191
Patricia Hars/192-193
i:umisc:prodreq/pacel I. 12np prod req6
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 11,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF AUGUST 2011,
SERVED THE FOREGOING SIXTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER,
IN CASE NO. PAC-E-II-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.weston~pacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniei.solander~pacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datarequest~pacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb~racinelaw.net
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollns~consultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: iim.r.smith~monsanto.com
ERIC L OLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo~racinelaw.net
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
E-MAIL: tony~yanel.net
BRAD MPURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy~hotmaii.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: botto~idahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 WHAYS STREET
BOISE ID 83702
E-MAIL: ron~wiliamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dws~r-c-s-inc.com
CERTIFICATE OF SERVICE
E-MAIL: ONLY
TIM BULLER
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS
AGRIUM US INC/NU- WEST INDUSTRIES
E-MAIL: tbuller~agrium.com
,b~
SECRETARY
CERTIFICATE OF SERVICE