20120511Staff 1-5 to PAC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEIVED
2t2 MAY fI AM1O:l
IDAHO PULLlC
UTIUTIES COMMISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S )
APPLICATION FOR AN ACCOUNTING )
ORDER REGARDING COSTS INCURRED )
FOR NAUGHTON UNIT 3. )
)
)
)
CASE NO. PAC-E-12-07
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, by FRIDAY, JUNE 1, 2012.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MAY 11, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the original economic analysis including cost/benefit
analysis associated with the emissions upgrade at Naughton Unit 3. Please include all work
papers with formulas included and operational.
REQUEST NO. 2: Please provide the latest economic analysis including cost/benefit
analysis associated with the upgrade of Naughton Unit 3 that shows that the upgrade is no longer
economically supported. Please also provide all analyses of options that are economically
supported. Please include all work papers with formulas included and operational.
REQUEST NO. 3: Please provide the critical path schedule for the emissions upgrade
to Naughton Unit 3.
REQUEST NO. 4: Please provide trial balance account entries for the line items in the
following categories as provided in Attachment No. 1:
a./INTLAB
b./CONSULT
c./EPC
d./BHDEVTR
e./RESDLBRI
REQUEST NO. 5: Please provide emissions records by year for the Naughton Unit 3
plant for 2008 to date.
DATED at Boise, Idaho, this 1! day of May 2012.
Karl T. Klein
Deputy Attorney General
Technical Staff: Joe Terry/1-5
i:umise:prodreq/pace12.7kkjt prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 11, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 11TH DAY OF MAY 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-12-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 SMAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
YVONNE HOGLE
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: Yvonne.ho21e(pacificorp.corn
SECRETRY
CERTIFICATE OF SERVICE