20150116ICIP 1-8 to PAC.pdf

Peter J. Richardson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
RICHARDSON ADAMS, PLLC
515 N. 27th Street
Boise,Idaho 83702
Telephone: [phone]
Fax: [phone]
Attorneys for the Industrial Customers of Idaho Power
IN THE MATTER OF THE
APPLICATION OF PACIFICORP DBA
ROCKY MOI-]NTAIN POWER AND
IDAHO POWER COMPANY FOR AN
ORDER AUTHORIZING THE
EXCHANGE OF CERTAIN
TRANSMISSION ASSETS
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
) CASE NOS. TPC-E-14-4I
) PAC-E-14-11
)) FIRST PRODUCTION REQUEST OF
) THE INDUSTIAL CUSTOMERS OF
) rDAHO POWER TO PACIFICORP
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "IPUC" or o'Commission"), the Industrial Customers of Idaho Power ("ICIP") by and
through their attorneys of record, Gregory M. Adams and Peter J. Richardson, hereby requests
that PacifiCorp ("PacifiCorp" or the "Company") provide the following documents.
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 produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at 6070 Hill Road, Boise, Idaho 83703, Tel:
(208) 3 42-1700 ; Fax : [phone] I ; dreading@mindspring. com.
IPC-E-14-41, PAC-E-14-1 I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO PACIFICORP
PAGE I
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer at an
evidentiary hearing. For purposes of these production requests, "PacifiCorp" refers to
PacifiCorp, any affiliated company, or any officer, director or employee of PacifiCorp, or any
affiliated company, including but not limited to Rocky Mountain Power.
If some of the following requests include disclosures reasonably deemed by PacifiCorp to
be confidential, the ICIP will enter into PacifiCorp's standard confidentiality agreement.
REOUEST FOR PRODUCTION NO. 1:
Please provide copies of all material provided to the Commission Staff regarding the Company's
application that were provided other than through formal discovery, both prior to, and after, the
frling of the Application.
REOUEST FOR PRODUCTION NO. 2:
Reference the direct testimony of Gregory Duvall at page I l, stating:
Under the current RTSA, RATFA and other agreements, PacifiCorp has east-to-west
rights across the ldaho Power transmission system of up to 1,600 MW and other various
rights at a projected 2016 cost of $20.8 million per year escalating each year thereafter.
This is made up of firm and conditional firm service. Under the JPSA, PacifiCorp will
have rights under ldaho Power's OATT to use 510 MW of firm point-to-point east-to-
west service across the ldaho Power transmission system with an initial cost of $17.1
million per year escalating each year thereafter in addition to 1090 MW of ownership.
a) Please provide the escalating rate for each year under the Legacy Agreements and the
proposed escalation rate for each year under the JPSA.b) Please explain how the escalation rates for the proposed JPSA are derived, and whether
they are subject to change in the future. Also identift the section of the JPSA attached to the
Application supporting the answer.
REOUEST FOR PRODUCTION NO. 3:
Reference Exhibit No. 8, p. l, attached to the direct testimony of PacifiCorp witness Richard
Vail. Please provide:
a) A functioning electronic copy of Exhibit No. 8, p. I with formulas intact'b) The work papers used to derive the values in Exhibit No. 8 p. 1;
IPC-E-14-41, PAC-E-14-1 1
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO PACIFICORP
PAGE 2
c) The assumptions used in the l0-year projections for the values in the table;d) For the purposes of Exhibit No. 8 does PacifiCorp assume it will not file a general rate
cases in ldaho that would impact the value such as the authorizedrate of return, revenues,
expenses, etc. over the l0 year period?
REOUEST FOR PRODUCTION NO.4:
Reference Exhibit No. 8, p.2, attached to the direct testimony of Richard Vail. Please provide:
a) A functioning electronic copy of Exhibit No. 8, p. 2 with formulas intact'b) The work papers used to derive the values in the table;c) The assumptions used in deriving the values in Exhibit No. 8, p. 2.
REOUEST FOR PRODUCTION NO. 5:
Exhibit No. 9 attached to the direct testimony of PacifiCorp witness Richard Vail displays a set
of values indicating the net exchanges between PacifiCorp and Idaho Power Company, please
provide:
a) A functioning electronic copy of Exhibit No. 9 with formulas intact;b) The work papers used to derive the values in Exhibit No. 9;c) The assumptions used in deriving the values in Exhibit No. 9;d) The labels for values in Exhibit No. 9 (i.e., are they in thousands of dollars?);e) An explanation of 'No Additions" and "Additions."
REOUEST FOR PRODUCTION NO.6:
Reference the direct testimony of Richard Vail, p. 12, stating "under the newjoint ownership
arrangements, costs for future upgrades would be shared in accordance with the JOOA,
potentially resulting in lower upgrade costs to PacifiCorp's customers." Please provide all plans
or studies, including any cost estimates, regarding upgrades that will be necessary in the next ten
years on the lines referenced in this portion of Mr. Vail's testimony.
REOUEST FOR PRODUCTION NO. 7:
Reference the direct testimony of Richard Vail, p. 14, lines I l-15, stating that the value of the
assets being exchanged is nearly equal and the ongoing expenses "will be similar to expenses
incurred today." Provide all studies, analyses and reports estimating the ongoing expenses for
the next ten years as compared to ongoing expenses with the Legacy Agreements.
REOUEST FOR PRODUCTION NO. 8:
Please provide all internal reports or memoranda presenting the terms and/or benefits of the
transaction to (a) PacifiCorp's board of directors and (b) PacifiCorp's senior officers.
IPC-E-14-41, PAC-E-14-l I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO PACIFICORP
PAGE 3
DATED this 16m day of January,2Ol5.
Of Attorneys forthe Industial
Customers of Idalro Power
IPC-E-14-41, PAC-E-l4-l I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO PACIFICORP
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 16ft day of January,2}ll, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER was served:
By hand delivery and electronic mail to the following individuals:
Julia A. Hilton
Idaho Power Company
P.O. Box 70
Boise, ID 83707
j [e-mail]
Daphne Huang
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washinglon
Boise,Idaho 83702
daphne.huang@puc. idaho. gov
Don Howell
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington
Boise, Idaho 83702
[e-mail]. gov
By U.S. Mail and electronic mail to the following individuals:
Daniel Solander
Ted Weston
Rocky Mountain Power
201 S. Main St., Suite 2300
Salt Lake City, UT 84111
danie l. soland er @p acifrcorp. com
ted. [e-mail]
IPC-E-14-41, PAC-E-14- 1 I
ICIP'S FIRST SET OF PRODUCTION REQUESTS TO PACIFICORP
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