20121102Staff 20-24 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
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
RECEftFFO
2012H0V-2 AMIO:56
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I ITU !Tu:c' Li I i....i
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
FOURTH PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission requests that PacifiCorp dba Rocky
Mountain Power (Company; Rocky Mountain) provide the following documents and information
as soon as possible, by FRIDAY, NOVEMBER 23, 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.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 NOVEMBER 2, 2012
REQUEST NO. 20: Please explain how costs were adjusted in the CPCN PVRR
analysis (Wyoming Docket No. 20000-400-EA-11) for shared facilities in scenarios where they
are no longer needed by Naughton Unit 3 (see IPUC Production Request No. 18).
REQUEST NO. 21: Please indicate and provide an explanation regarding which of the
following were reasonably available at the time of the initial Wyoming CPCN application
(Wyoming Docket No. 20000-400-EA-1 1):
a)Operating cost and run-rate capital cost assumptions included in the 2012 business plan
with correctly applied tax depreciation life assumptions for certain environmental capital
investments (see Rick Link Rebuttal Testimony, page 14, lines 12-16, Wyoming Docket
No. 20000-400-EA-1 1);
b)Power requirements of the SCR and baghouse investments in the event that Naughton
unit 3 continues operation as a coal-fueled facility (see Rick Link Rebuttal Testimony,
page 14, lines 17-19, Wyoming Docket No. 20000-400-BA-1 1);
c)Potential costs that might arise from provisions in the coal supply agreement that is in
place for the Naughton plant facility (see Rick Link Rebuttal Testimony, page 16, lines
4-17, Wyoming Docket No. 20000-400-EA-1 1);
d)Forecasted average coal costs for Naughton #1 and #2 that might be affected by a change
in volumetric deliveries in case Naughton #3 is retired early or converted to a natural gas
facility (see Rick Link Rebuttal Testimony, page 16, lines 16-23 and page 17, lines 1-3,
Wyoming Docket No. 20000-400-BA-1 1).
REQUEST NO. 22: Please provide the base, low, and high case (as described in the
original application) PVRR System Optimizer results comparing the optimized simulation
(operation of Naughton #3 as a coal plant with emission control investments) with the change
case simulation (natural gas conversion) as described on page ii of Rick Link's rebuttal
testimony (Wyoming Docket No. 20000-400-EA-1 1). In both simulations, please use June 2011
forward price curves and any assumptions that were reasonably available when the CPCN
application was initially submitted (Wyoming Docket No. 20000-400-EA- 11), including
assumptions that the Company indicated as "reasonably available" in Production Request No. 21,
above. The intent of this request is to quantify the PVRR difference that the Company would
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 2, 2012
have calculated at the time of the initial application comparing the continued operation of
Naughton #3 as a coal plant (with necessary emission controls) with the natural gas conversion
alternative capturing both energy and capacity costs and benefits.
REQUEST NO. 23: Please provide an update on the Wyoming regional haze SIP. Has
final EPA action occurred and, if so, what was the result?
REQUEST NO. 24: Please provide the status of the Company's efforts to extend the
Wyoming regional haze compliance timeframe.
DATED at Boise, Idaho, this day of November 2012.
v1/
Karl T. Klein
Deputy Attorney General
Technical Staff: Mike Louis/20-24
i:umisc:prodreq/pace127kkm1 prod req4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 2, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2 " DAY OF NOVEMBER 2012,
SERVED THE FOREGOING FOURTH 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 YVONNE HOGLE
ID REGULATORY AFFAIRS MANAGER SENIOR COUNSEL
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
201 5 MAIN ST STE 2300 201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111 SALT LAKE CITY UT 84111
E-MAIL ted weston@pacificorp corn E-MAIL Yvonne hog1e()pacificorp corn
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY
datareguest(pacificorp corn
SECRETARY
CERTIFICATE OF SERVICE