20170810Staff 1-4 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.7956
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 )
PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-17-06
POWER FOR BINDING RATEMAKING )TREATMENT FOR WIND REPOWERING.)
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and throughits attorney of record,
Brandon Karpen,Deputy AttorneyGeneral,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than THURSDAY,
AUGUST 31,2017.
This Production Request is to be considered as continuing,and Rocky Mountain Power is
requested to provide,by way of supplementaryresponses,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 workpapersthat 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 identifythe name,job title,location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER l AUGUST 10,2017
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.1:Please provide a copy of the evaluation completed by Black &
Veatch,Inc.regarding the increased energy production expected from the repowered wind
turbines.
REQUESTNO.2:Please provide a copy of all completed evaluations performed
regarding the ability of the existing foundations to handle the new turbines.This should include
assessment of handling new turbine loads and the additional 30-year service life.
REQUESTNO.3:Please provide System Optimizer and PaR files containing
assumptions,inputs,outputs,and summary information for all scenarios and sensitivities used in
PacifiCorp's economic analysis.For each scenario and sensitivity,provide a summary of the
parameters changed for each run.
REQUESTNO.4:Please provide annual cost and revenue for all the wind projects
being considered for wind repowering from installation date to present.This should include,
where applicable,line items for fixed and variable O&M cost,Production Tax Credits,Wyoming
Wind Production tax,and annual generation (MWh).
DATED at Boise,Idaho,this W day of August 2017.
and n en '
Depu y AttorneyGeneral
Technical Staff:Michael Eldred (1-4)
i:umisc:prodreq/pace16.14bkdesdbrjk prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 10,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10th DAY OF AUGUST 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-06,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSITANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:[e-mail] SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
E-MAIL ONLY:RACINE OLSON NYE &BUDGE
[e-mail] PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL:[e-mail]
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:[e-mail] BOISE ID 83701
E-MAIL:[e-mail]
ELECTRONIC ONLY ELECTRONIC ONLY
JOHN DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY
VAL STEINER
NU-WEST INDUSTRIESINC
E-MAIL:val.steiner agrium.com
SECRE ARY
CERTIFICATE OF SERVICE