20110926Staff to PAC 229,230.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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zon SEP 26 P~l I: 30
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
NINTH 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
MONDAY, OCTOBER 17, 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 the document, and the name, location and phone number of the record holder
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 26,2011
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. 229: Please reconcile discrepancies in the following two statements as
to why Bridger Coal Company production is reduced in 2011.
a) "The increase in cost is primarily the result of reduced Bridger coal production in 2011
due to reduced generating requirements at the Bridger plant." (See Company's response
to IPUC Data Request No. 162)
b) "Q. What are the primar drivers for the increase in the underground mine costs? A.
The increase in underground costs is due to several factors, including higher operating
costs, reduced mine deliveries and increased manpower associated with mine
development, conveying and blending costs. Q. Please explain the mine production
changes. A. 2011 test period underground mine deliveries are approximately 200,00
tons lower than the 2010 test period. The lower delivery level is the result of two
longwall moves in 2011 versus only one longwall move in 2010." (See C. Crane direct
testimony - p.1 0, lines 20-23; p. 11, lines 3 - 5).
REQUEST NO. 230: Please provide a detailed explanation why Bridger plant
Generation and Capacity Factor decreased from 10.55 M (MWh) to 9.5 M (MWh) and 85% to
76.9%, respectively, in the GRID model from 2010 to 2011. Please include dates and a
description of any planned downtime if included in reasons given.
DATED at Boise, Idao, ths ~y of September 20 i i.
N~
Deputy Attorney General
Technical Staff: Mike Louis/229-230
i:umisc:prodreqlpacel 1.2np prod req9
NINTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 26, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF SEPTEMBER 2011,
SERVED THE FOREGOING NINTH 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.weston(ipacificorp.com
DANIEL E SOLANDER
REGULATORY COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: daniel.solander(ipacificorp.com
E-MAIL ONLY:
DATA REQUEST RESPONSE CENTER
datarequest(apacificorp.com
RANDALL C BUDGE
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: rcb(iracinelaw.net
BRUBAKER & ASSOCIATES
16690 SWIGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: bcollns(iconsultbai.com
E-MAIL ONLY:
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: jim.r.smith(imonsanto.com
ERICLOLSEN
RACINE OLSON NYE ET AL
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo(iracinelaw.net
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: tony(iyankel.net
BRAD M PURDY
ATTORNEY AT LAW
2019 N 17TH STREET
BOISE ID 83702
E-MAIL: bmpurdy(ihotmail.com
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL: botto(iidahoconservation.org
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS STREET
BOISE ID 83702
E-MAIL: ron(iwiliamsbradbury.com
DON SCHOENBECK
RCS INC
900 WASHINGTON STREET
STE 780
VANCOUVER WA 98660
E-MAIL: dws(ir-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(iagrium.com
JD~SECRETAR- ~
CERTIFICATE OF SERVICE