20150112Staff 1-16 to PAC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03 14
ISB NO. 6864
Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR APPROVAL )
OF THE TRANSACTION TO CLOSE THE DEER )
CREEK MINE AND FOR A DEFERRED )
ACCOUNTING ORDER. )
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E.14.1O
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 PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than MONDAY, FEBRUARY 2,2015.
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.
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
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP I JANUARY I2,2OI5
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: P1ease provide an itemized breakdown ofNet Power Cost (NPC) for
the 2015 ECAM deferral period for the Hunter and Huntington plants separating cost associated
with this Application (Deer Creek Mine) for each plant from other costs not associated with the
Application. For the Application related costs, identifr the costs that will be ongoing,
eliminated, and/or added in the future. Please include all worksheets with formulas intact.
REQUEST NO. 2: For each of the cost categories in the previous request (by plant),
provide an annual cost forecast over a20 year time horizon.
REQUEST NO.3: Please provide the historical actual burn rates (MMBtu's of coal
consumed per MWh produced) for the Huntington and Hunter plants over the past 12 months.
REQUEST NO. 4: Please provide all of the cost assumptions and worksheets (with
formula's intact) used to perform the Present Value Revenue Requirement analysis included in
Exhibit No. 6 of witness Crane's testimony.
REQUEST NO. 5: Please provide an analysis of the overall revenue requirement and
rate impact comparing "all-in" costs associated with the implementation of the Deer Creek
"Transaction" against current revenue requirement and rates. Please include all worksheets with
formulas intact.
REQUEST NO. 6: Please explain why the Company's proposed calculation of NPC
difference multiplies the base-to-actual weighted-average cost per MMBtu difference times the
"total MMBTU consumed for the two plants included in base net power costs" instead of actual
total MMBtu consumed for the two plants. (See Crane, Di, Page 25, lines 19-23 and Page 26,
lines 1-3).
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 2 JANUARY 12,2OI5
REQUEST NO. 7: Please explain how the NPC Deferral calculation of "Incremental
Costs/Benefits of Fueling Costs related to the Transaction" shown in Cindy Crane's testimony
differs from how the NPC Deferral is calculated using the IPUC authorized methodology in the
ECAM. Please illustrate using an example. (See Crane, Di, Page 25, lines 19-23 andPage26,
lines l-3).
REQUEST NO. 8: Please explain the reason(s) and/or dependency(s) for the Trail
Mountain Mine being part of the "Transaction".
REQUEST NO. 9: Please explain the dependency of the Retiree Medical Obligation
Settlement to the overall "Transaction." Is the settlement of this cost obligation dependent upon
any further action by the Company?
REQUEST NO. l0: How did the Company ensure that asset prices in the Asset
Purchase Agreements (APA's) are the highest the Company could obtain? Was there a
competitive bidding process for example? Please describe the methods used and provide
documentation showing the results, including bids by interested parties.
REQUEST NO. 11: Is the Company seeking a determination of prudency for the Coal
Supply Agreements (CSAs)? If so, is the request for a determination of prudency compelled by
Bowie or by the Company, and why?
REQUEST NO. 12: Please explain how the Company is ensuring that the Bowie
contracted coal prices in the CSAs are least cost and least risk compared to other coal fueling
strategies (e.g., market) or contracts with other coal suppliers (e.g., competitive bidding process).
Please describe the methods used and provide documentation showing the results, including any
bids by interested parties.
REQUESTO NO. 13: Did the Company investigate CSAs with shorter or longer
contract terms with prospective coal suppliers? If so, please provide documentation between the
parties demonstrating that it was investigated and outlining the terms.
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 3 JANUARY I2,2OI5
REQUEST NO. 14: Please explain how the Company evaluated the risks and tradeoffs
associated with CSAs of varying contract term lengths. Please provide the analysis.
REQUEST NO. 15: In case of scaled back operation at the Huntington Plant due to
environmental regulations, the Right of First Refusal language in the CSA may require
PacifiCorp to take delivery of coal from Bowie for open positions of coal at the Company's other
Utah Plants. Please describe the feasibility of transporting coal to the Company's other plants
and an estimated quantification of additional cost using comparable current cost estimates.
REQUEST NO. 16: Please provide a schedule of all current and potential capital
investments (including descriptions and dollar amounts) necessary for operating the Hunter and
Huntington Facilities through their remaining lives. Please include all investment necessary to
meet current and prospective environmental regulations.
DATED at Boise, Idaho, tfris $.paay of Janua ry 2015.
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Neil Price
Deputy Attorney General
Technical Staff: Mike Louis (1-16)
i:umisc:prodreq/pace 14. I 0npmlphjtde prod req I
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 4 JANUARY I2,2OI5
CERTIFICATE OF SERVICE
I HEREBy cERTrFy rHAT I HAvE THIS 12th DAy oF JANUARy 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO. PAC-E-l4-IO, BY E-MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWNG:
TED WESTON DANIEL E SOLANDER
ID REGULATORY AFFAIRS MANAGER SENIOR COUNSEL
ROCKY MOUNTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I1
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@nacificorp. com
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 841I I
E-MAIL: [e-mail]
RICHARD R HALL
STOEL RIVES LLP
SUITE 19OO
101 S CAPITOL BLVD.
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE