20130510Staff 9-16 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
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IDAHO U3U•O L IT' I_c -''s 4tL
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 PACIFICORP DBA )
ROCKY MOUNTAIN POWER'S APPLICATION )
TO CHANGE THE DEPRECIATION RATES )
APPLICABLE TO ITS ELECTRIC PROPERTY. )
)
)
)
CASE NO. PAC-E-13-02
THIRD 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 PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than TUESDAY, MAY 28, 2013.
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.
THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 1 MAY 10, 2013
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. 9: Please provide documentation supporting the retirement date of
2029 for the Naughton plant. Please include any cost/benefit analysis which was included in the
study for the planned additions in this depreciation study and the planned costs associated with
the conversion of the Naughton Unit 3 to gas in 2017. Please include any additional data that
would support the closing date of 2029.
REQUEST NO. 10: Please provide additional information for assets with an estimated
in-service date of September 1 -December 31, 2013 and "various" as included in your file IPUC
8-1. Include documentation to support the in-service date, including current percentage of
completion data, estimated interim completion dates, billings to date, commitments/contracts for
completion and any other data which would support the in-service date.
REQUEST NO. 11: Please provide additional information regarding Hydro North-
Merwin project which has an estimated completion date of December 31, 2013 as provided in
your file IPUC 8-1. Please include any documentation supporting the estimated $55.6M as well
as the percentage of completion, estimated interim completion dates, billings to date,
commitments/contracts for completion and any other data which would support the in-service
date.
REQUEST NO. 12: Please provide additional information regarding the Deer Creek
Mine CAP forecast of $14M as provided in your file IPUC 8-1. Include documentation
clarifying what assets/projects are included in the $14M, percentage completion data and an
estimated completion date.
THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 2 MAY 10, 2013
REQUEST NO. 13: Please provide additional information regarding the Cholla
Chimney Block Liner-Phase 1 with an estimated in-service date of December 31, 2013 on your
file IPUC 8-1. Please provide documentation describing phase I details and information on any
other phases to complete, as well as an estimate of total cost, completion date, and current
percentage of completion.
REQUEST NO. 14: Please provide a schedule by year showing the dollar changes
estimated for Carbon. Include all additions, retirements, depreciation, etc. Please also provide
an explanation of the additions and retirements.
REQUEST NO. 15: Please provide a schedule(s) showing the depreciation components
if Naughton Unit 3 is separated from the other two units when converted to gas. Explain
assumptions and impacts.
REQUEST NO. 16: Please provide a listing of production request questions asked, by
state, for this depreciation study.
DATED at Boise, Idaho, thiskday of May 2013.
Neil Price
Deputy Attorney General
Technical Staff: Sandra Walker/9 - 13
Terri Carlock/14 - 16
i:umisc:prodreq/pace13.2npsw prod req3
THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 3 MAY 10, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF MAY 2013,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-13-02, BY E-MAILING AND 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(2ipacificorp.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
P0 BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
TIM BULLER
AGRIUM US INC/NU-WEST
E-MAIL: tbu11er(agrium.com
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: j [e-mail]
DON SCHOENBECK
RCS INC
900 WASHINGTON ST
STE 780
VANCOUVER WA 98660
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE