20171012Staff 38-40 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 )
)FOURTH PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its 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 WENDESDAY,
OCTOBER 18,2017.1
This Production Request is to be considered continuing,and Rocky Mountain Power is
requested to provide,by way of supplementaryresponses,additional documents that it or any
person acting on its behalfmay 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 telephonenumber of
'Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 12,2017
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.
REQUESTNO.38:In reference to the wind integration cost that is calculated on line
61 of the Repower Data 20170516 LGIA Limit vl3 file in the Summary tab,please explain
where this wind integration cost is found in the Project Net Costs calculated on lines 88-93 of the
Repower Results Direct Testimony in the Price-Policy Annual -PaR tab.
a.If wind integration cost is included in the Project Net Cost,please explain where it is
included and provide workpapers,model output,etc.to show how it is included.
b.If wind integration cost is not included in the Project Net Cost,please explain where
in the PVRR(d)analysis,lines 87-102 of the Repower Results Direct Testimony file
in the Price-Policy Annual -PaR tab,it is included.In addition,provide the file
where it is calculated and the total wind integration project cost value.
c.If wind integration cost is not included in the PVRR(d)analysis,please explain why it
was not included.
REQUESTNO.39:In reference to IPUC Production Request response 36 part (c),
please provide the input assumptions used to calculate the production tax credit portion of the
Proposed Station Fixed Costs.This should include,but not limited to the percent (100%,80%,
etc)of PTC received and the $/MWh for each year in service.
REQUESTNO.40:Please explain why the Company's models (System Optimizer and
PaR)included the 300 MW of Wyoming wind in year 2021 in the Company's baseline scenario
used for comparison of the Company's proposal to calculate the PVRR(d).Please provide the
specific driver(s)for includingit into the baseline.For example,was it included to meet capacity
deficits,RPS requirements in other states,etc.Please provide documentation,workpapers,
and/or model outputs that illustrates the Company's explanation.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 12,2017
DATED at Boise,Idaho,this i day of October 2017.
ranÀo arpen .
D ty AttorneyGeneral
Technical Staff:Michael Eldred/38-39
Rick Keller/40
i:umise:prodreqlpace17.6bkmerk prod req 4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 12,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF OCTOBER 2017,
SERVED THE FOREGOING FOURTH 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:rcb racinelaw.net
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:[e-mail]
ELECTRONIC ONLY ELECTRONIC ONLY
JIM DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ERIC L OLSEN
VAL STEINER ECHO HAWK &OLSEN
NU-WEST INDUSTRIES INC PO BOX 6119
E-MAIL:[e-mail] POCATELLO ID 83205
E-MAIL:[e-mail]
ANTHONY YANKEL BRADLEY MULLINS
UNIT 2505 333 SW TAYLOR
12700 LANE AVENUE SUITE 400
LAKEWOOD OH 44107 PORTLAND OR 97204
E-MAIL:[e-mail] E-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE