20130118Staff 1-23 to PAC.pdf

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KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 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
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IDAHO PUBLK;
UTILmES
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S ) CASE NO. PAC-E-12-14
APPLICATION FOR AUTHORITY TO )
CANCEL ELECTRIC SERVICE SCHEDULE ) FIRST PRODUCTION
NOS. 72 AND 72A IRRIGATION LOAD ) REQUEST OF THE
CONTROL TARIFFS AND APPROVE A NEW COMMISSION STAFF TO
DEMAND SIDE MANAGEMENT CONTRACT) 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, FEBRUARY 1,2013.'
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
'Staff is asking for an expedited response. Please contact Staff's attorneys if you believe an expedited response will
be problematic.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JANUARY 18, 2013
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.
REQUEST NO. 1: Please explain whether the proposed contract will require the
Company to pay a capacity charge to EnerNoc regardless of whether the program is dispatched.
REQUEST NO. 2: Please explain whether the proposed contract will require the
Company to pay an energy charge to EnerNoc when the program is dispatched.
REQUEST NO. 3: Please explain whether the realized $/kW/year listed in Confidential
Attachment No. 1 excludes any energy payments to EnerNoc.
REQUEST NO. 4: What is the annual fixed payment to EnerNoc assuming no
performance adjustments, and assuming an average availability of 145 MW? Please provide any
workpapers used in providing this response.
REQUEST NO. 5: What is the maximum amount of energy payments that can be made
in any year under the Idaho Payment Cap assuming an average availability of 145 MW? How
many hours of curtailment does that translate into? Please provide any workpapers used in
providing this response.
REQUEST NO. 6: If the number of hours calculated in the response to the previous
question is below the program cap of 52 hours for Mandatory Program Events, is the Company
entitled to the remaining curtailment at no variable expense? Please explain your response.
REQUEST NO. 7: Does the Company anticipate system or situs treatment of the
EnerNoc contract?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JANUARY 18, 2013
REQUEST NO. 8: Will the Company include the EnerNoc contract as a power
purchase contract for purposes of cost recovery? If so, what dollar amount is assumed to be
included in base power supply cost (system)?
REQUEST NO. 9: If the contract will be included in base power supply, will the cost
remain constant over the 10-year period (with year-to-year fluctuations captured in the ECAM),
assuming no renegotiation? Please explain your response.
REQUEST NO. 10: Did the parties discuss a 5-year contract term, and if so, would that
have changed the cost of the contract? Please provide workpapers that support the Company's
response.
REQUEST NO. 11: Please provide a detailed estimate of annual administrative costs
per year that the Company assumes it will incur due to the EnerNoc contract.
REQUEST NO. 12: Will Company-related administrative costs be allocated in the same
manner as the EnerNoc contract itself? If not, please explain.
REQUEST NO. 13: Please demonstrate that signing a 10-year pay-for-performance
contract for the irrigation load control program is in the best interest of Company customers.
REQUEST NO. 14: Please demonstrate the need and/or value to ratepayers for
maintaining the Irrigation Load Control Program as opposed to discontinuing it.
REQUEST NO. 15: Please provide the cost-effectiveness for each program year in
2009, 2010, 2011 and 2012. Please detail all assumptions and calculations used in an executable
Excel file.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JANUARY 18, 2013
REQUEST NO. 16: For each load control event called in 2009, 2010, 2011 and 2012,
please provide the hourly demand reduction, participating load, and realization rate. Please
identify the number of substations that were used to measure the requested data.
REQUEST NO. 17: What would the total 2012 program costs have been had the
proposed program cost structure been in place? Please provide workpapers supporting the
Company's response.
REQUEST NO. 18: How did the Company decide on a target average availability of
145 MW?
REQUEST NO. 19: Have there been any additional contract revisions discussed
between the Seller, the Company or the Irrigators that may warrant additional changes to the
currently submitted contract?
REQUEST NO. 20: Please explain whether calculation of the Average Actual Electric
Demand referenced in Section 3 of Confidential Attachment No. 1 has changed. If so, please
describe the impact of the change.
REQUEST NO. 21: Please explain why the average cost per year in the bid summary in
Confidential Attachment No. 1 assumes the stated number of curtailment hours.
REQUEST NO. 22: Under what circumstances will the Company's legacy equipment
be replaced? maintained? What does the Company intend to do with any and all removed legacy
equipment? How does the Company plan to treat proceeds/expenses associated with equipment
disposition?
REQUEST NO. 23: What is the cost for the Company to install a data pulse device?
How many data pulse devices does the Company estimate will be installed in each of the first
two years of the program?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 JANUARY 18, 2013
DATED at Boise, Idaho, this I day of January 2013.
Karl T. Klein
Deputy Attorney General
Technical Staff: Bryan Lanspery/1-14
Nikki Karpavichll 5-23
i:umisc:prodreq/pace12. I4kkblnk prod req 1
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 JANUARY 18, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18 TH DAY OF JANUARY 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-12-14, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
TED WESTON
ID REGULATORY AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 5 MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 5 MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE