20120510Staff 1-6 to PAC.pdf

2012 MAY 10 PM 2:28
KRIST1NE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
IDAHO UT1LmESCOMMS 1ON
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 A DEFERRED ACCOUNTING
ORDER.
CASE NO. PAC-E-12-08
FIRST 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,
Kristine A. Sasser, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain
Power (Company; Rocky Mountain) provide the following documents and information on or
before THURSDAY, MAY 31, 2012.
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 will augment the documents produced.
Please provide answers to each question, including 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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MAY 10, 2012
holder and, if different, the witness who can sponsor the answer at hearing. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the economic analysis including cost/benefit analysis
associated with retrofitting the Carbon plant with emissions control equipment. Please include
all workpapers with formulas included and operational.
REQUEST NO. 2: Please provide the economic analysis including cost/benefit analysis
associated with the conversion to natural gas for the Carbon plant. Please include all workpapers
with formulas included and operational.
REQUEST NO. 3: Please provide emissions records by year for the Carbon plant for
2008 to date.
REQUEST NO. 4: Please provide schedules showing book value by year, including at a
minimum: initial cost, additions, retirements and accumulated depreciation for the Carbon plant
from initial construction to date.
REQUEST NO. 5: Please provide schedules with supporting documentation showing
the detail of the estimates to decommission the facility and remediate the site.
REQUEST NO. 6: Please provide topographic maps and airflow maps of the Carbon
plant site.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 10, 2012
Dated at Boise, Idaho, this 10 T- day of May.
Kristine A. Sasser
Deputy Attorney General
Technical Staff: Joseph Terry/i -6
Terri Carlock
i:umisc:prodreq/pace I 2.8ksjttc prod req I .doc
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MAY 10, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10th DAY OF MAY 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP, IN CASE NO. PAC-E-12-08, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguest(pacificorp.com
YVONNE HOGLE
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: Yvonne.hog1ecpacificorp.com
S CRETARY
CERTIFICATE OF SERVICE