20121003Staff 1-5 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
E CE IV F D
29191 fli'T U
P0 BOX 83720
BOISE, IDAHO 83720-0074
-.
[phone]
ISB NO. 6864
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 ROCKY MOUNTAIN POWER FOR ) CASE NO. PAC-E-12-12
AUTHORITY TO CANCEL SCHEDULE )
NO. 17 AND IMPLEMENT A NEW )
PARTIAL REQUIREMENTS TARIFF ) 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,
Neil Price, Deputy Attorney General, requests that Rocky Mountain Power (Company; Rocky
Mountain) provide the following documents and information as soon as possible, but no later
than WEDNESDAY, OCTOBER 24, 2012.
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 and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain 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.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 3, 2012
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.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: On page 2 of Joelle Steward's Testimony, she discusses a recent
customer inquiry that led the Company to evaluate Schedule 17 in comparison to its partial
requirements service options in other states. Following the evaluation, it was determined that
Idaho may benefit from a similar option. Please describe the Company's evaluation and the
benefits to Idaho customers of being on Schedule 31 as compared to Schedule 17. As part of
your response, please provide a billing example using the two tariffs and similar usage profiles.
REQUEST NO. 2: Please explain the method used to calculate the Back-Up Power
Rates. As part of your response, please explain how the Company evaluated Schedule 9
customer's loads to develop the rates.
REQUEST NO. 3: On page 5 of Joelle Steward's Testimony, after discussing the
portion of demand-related generation costs used to calculate the Back-Up Facilities Rate, she
states: "The 13 percent for demand-related generation is based on the Company's generation
planning reserve margin and represents the costs incurred by the Company to back-up the
customers generation." Please explain how the Company's generation planning reserve margin
is representative of the costs incurred to provide back-up service.
REQUEST NO. 4: For each month in 2011, please provide the maximum hourly load
for each Schedule 9 customer. Additionally, please provide each Schedule 9 customer's average
maximum hourly load by day and by month.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 3, 2012
REQUEST NO. 5: On page 3 of the Application, the Company states: "The proposed
Schedule 31 rates are based on and aligned with Schedule 9 and the cost of service results from
the last general rate case, Case No. PAC-E-11-12." When developing the tariff, did the
Company consider the cost of service results for other eligible schedules, such as Schedules 6
and 35? If not, why not?
DATED at Boise, Idaho, this3cA day of October 2012.
Neil Price
Deputy Attorney General
Technical Staff: Matt Elam/1-5
i:umisc:prodreq/pace12. I 2npme prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 3, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3R0 DAY OF OCTOBER 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC -E-12-
12, 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:
datareguestcpacificorp.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 5 MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
\' 4'a"V~'_
SECRETA
CERTIFICATE OF SERVICE