20130419Staff 1-11 to PAC.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
E C
7-311 APR 19 M 9:59
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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
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR )
AUTHORITY TO SELL THE ST. ANTHONY )
HYDROELECTRIC GENERATION PLANT )
LOCATED IN FREMONT COUNTY, IDAHO. )
)
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR )
APPROVAL OF A POWER PURCHASE )
AGREEMENT BETWEEN PACIFICORP AND
ST. ANTHONY HYDRO LLC. )
)
)
CASE NO. PAC-E-13-06
CASE NO. PAC-E-13-07
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,
Karl T. Klein, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information by FRIDAY,
MAY 10, 2013.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER APRIL 19, 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
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 provide copies of the continuing property records for the St.
Anthony Hydro Project.
REQUEST NO. 2: Please provide the full set of estimated closing entries associated
with the sale and retirement. We acknowledge that the final entries may differ based on the
actual book value at the time of closing.
REQUEST NO. 3: Please provide an electronic copy of Confidential Exhibit No. 1 with
formulas intact. Also include all data input files used in the calculations for Confidential Exhibit
No. 1.
REQUEST NO. 4: Did the Company include a value for RECs in its analysis in
Confidential Exhibit No. 1? If so, please provide as part of your response to Production Request
No. 3. If not, why?
REQUEST NO. 5: Please provide a copy of the RFP referenced on page 5 of the
Company's Application.
REQUEST NO. 6: Please provide the RFP scoring/evaluation for the six submissions
that led the Company to select the winning bid.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 19, 2013
REQUEST NO. 7: Please provide information, including calculations and formulas, of
"Lost Generation" for all four alternatives included in Confidential Exhibit No. 1. Please
provide for both 40-year costs in thousands of 2012 dollars and 40-year PVRR.
REQUEST NO. 8: Please provide information regarding your calculation of "Base
Generation Forecast" in MWh for all four alternatives included in Confidential Exhibit No. 1.
REQUEST NO. 9: Please provide a detail listing of costs included in the sales expense
of $188,000 as included in Confidential Exhibit No. 1.
REQUEST NO. 10: Please provide documentation to support the calculation of the
market value of replacement power for all four alternatives as included in Confidential Exhibit
No. 1.
REQUEST NO. 11: Please provide additional information regarding assumptions and
calculations regarding Alternative No. 1, Full Capital Operations. Include all information
regarding capital cost estimates, operations capital, and power provided as included in
Confidential Exhibit No. 1.
DATED at Boise, Idaho, this jtday of April 2013.
Karl T. Klein
Deputy Attorney General
Technical Staff: Terri Carlockll & 2
Bryan Lanspery/3 —6
Sandra Walker/7 - 11
i:umisc:prodreq/pacel 3.6kktcblsw prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 APRIL 19, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF APRIL 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP DBA ROCKY MOUNTAIN POWER, IN
CASE NO. PAC-E-13-06, BY E-MAILING AND 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:
datareguestpacificorp.com
DANIEL E SOLANDER
SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 5 MAIN ST STE 2300
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
BRUCE GRISWOLD
DIRECTOR, SHORT-TERM ORIGINATION
PACIFICORP
825 NE MULTNOMAH SUITE 1800
PORTLAND OR 97232
bruce. griswoldpacificorp.com
FA wj
CERTIFICATE OF SERVICE