20150707Staff 8-13 to PAC.pdf

NEIL PzuCE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACTFICORP DBA ROCKY MOUNTATN ) CASE NO. PAC-E-15-09
POWER TO MODTFY THE ENERGY COST )
ADJUSTMENT MECHANISM AND INCREASE )
RATES By $10.2 MILLION, OR ) SECOND PRODUCTION
APPROXIMATELY 3.9 PERCENT. ) REQUEST OF THE COMMISSION
) sTAFr ro RocKY MOUNTATN
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, JULY 28,2015.
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.
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY
MOUNTAIN POWER JULY 7,2015
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 identiff 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. 8: For the Production Tax Credit (PTC) amounts requested in Staff
Production Request No. 3, please provide a schedule(s) with the following information:
a) A detailed list of all facilities eligible for the Company to claim PTC;
b) For each facility, identifu it by type; i.e. a Qualifying Facility (QF), (non-QF) power
purchase agreements/contracts, Company-owned assets;
c) Provide the percentage of output from each facility where the Company may claim
available PTC;
d) Provide the dollar amounts of PTC and MWh produced by month for each facility.
REQUEST NO. 9: Please provide Idaho monthly actual REC revenue for December
2014 through May 2015.
REQUEST NO. 10: On page 5 of the Application, the Company says "Sharing bands
and dead bands have been eliminated in almost all other states in the country...." Please provide
all relevant articles, studies and research supporting this statement, particularly for non-
restructured power markets.
REQUEST NO. 11: On page 6 of the Application, the Company says it "updated its
hedging policy by incorporating guidelines that allow a reasonable percentage of natural gas and
power requirements to maintain open and short-term market price exposure." Please describe the
updated hedging policy in more detail, particularly why maintaining short-term market price
exposure supports modifuing the sharing portion of the ECAM.
REQUEST NO. 12: On page 10, lines 12-15, of Wilding's testimony, he says "Out of
all states with non-restructured power markets, only eight - Wyoming, Utah, Idaho, Oregon,
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY
MOLINTATN POWER 2 ruLY 7,2015
Washington, Missouri, Montan4 and Vermont - have sharing mechanisms built into their
respective power cost true-up mechanisms." Please provide a detailed description of the sharing
mechanisms in each state.
REQUEST NO. 13: On page 4, lines 15-17, of Wilding's testimony, he says 'ono
evidence has been provided in the annual ECAM's to show that the Company is not making
prudent decisions or that disallowance is required to incent the Company to make the right
decisions." Have the Company's other jurisdictions disallowed net power costs? If so, please
explain the circumstances for disallowance.
DATED at Boise, Idaho, tfri, ?&aay of July 2015.
Technical Staff: Joe Terry/I\4ike Louis/8-9
Matt Elam/l0-13
i:umisc:prodreq/pacel5.9npjtmlme prod req2
SECOND PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY
MOUNTAIN POWER
Deputy Attorney General
ruLY 7,20t5
CBRTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 7TH DAY OF JULY 2015, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-15-09, BY
MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 8411 1
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp. com
BRUBAKER & ASSOCIATES
16690 SWINGLEY zuDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
IO15 W HAYS ST
BOISE ID 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
JIM DUKE
IDAHOAN FOODS
E-MAIL: [e-mail]
ERIC L OLSEN
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: [e-mail]
YVONNE HOGLE
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 841I1
E-MAIL: [e-mail]
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
ELECTRONIC ONLY
VAL STEINER
AGRIUM US INCAIU.WEST INDUSTRIES
E-MAIL: [e-mail]
ANTHONY YANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44104
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE