20171012PIIC 4-15 to PAC.pdf

WILLIAMS ·BRADBURY
ATTORNEYS AT LAW
October 12,2017
Ms.Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702
Re:PAC-E-17-07
Dear Ms.Hanian:
Please find enclosed for filing the original and three copies of PacifiCorp Idaho
Industrial Customers'Second Production Request to Rocky Mountain Power in the above
referenced case.
Thank you for your assistance in this matter.Please feel free to give me a call should
you have any questions.
Sincerely,
Ronald L.Williams
RLW
Enclosures
P.O.Box 388 -Boise,ID 83701
Phone:[phone] -www.williamsbradbury.com
Ronald L.Williams,ISB No.3034
P.O.Box 388,802 W.Bannock Street,Suite 900
Boise,ID 83702
Telephone:[phone]
Email:[e-mail]
Attorneys for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION OF )Case No.PAC-E-17-07
ROCKY MOUNTAIN POWER FOR )
CERTIFICATES OF PUBLIC CONVENIENCE )SECOND PRODUCTION REQUESTOF
AND NECESSITY AND BINDING )PACIFICORP IDAHO INDUSTRIAL
RATEMAKING TREATMENT FOR WIND )CUSTOMERS TO ROCKY MOUNTAIN
AND TRANSMISSION FACILITIES )POWER
PacifiCorp Idaho Industrial Customers ("PIIC"),by and through its attorney of record
Ronald L.Williams and pursuant to the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"),hereby requests that Rocky Mountain Power ("RMP")provide the
followingdocuments and information as soon as possible,and no later than November 3,2017.
This Production Request is continuing,and RMP 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 produced.
Please provide answers to each question,and supporting work papers that provide detail
or are the source of information used in calculations.RMP 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.IDAPA 31.01.01.228.
In addition to the written copies provided as response to the questions,please provide all
Excel and electronic files on CD with formulas activated.
PIIC SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN,Page l
REQUEST NO.4.Please provide permission for Mr.Mullins to use confidential
information that the Company has provided in Oregon Docket No.LC 67,or in the alternative,
please provide copies of all data requests and workpapers provided to Mr.Mullins in Oregon
Docket No.LC 67.
REQUEST NO.5.Please provide copies of each official forward price curve that the
Company has issued since December 31,2016,includingthe official forward price curve issued
on,or around,September 30,2017.
REQUEST NO.6.Reference the Company's October 2,2017 Q2 Avoided Cost
Compliance filing in Docket No.17-035-37 before the Utah Public Service Commission:
a.Please provide copies of the GRID model studies used to develop the reference
filing.
b.Please provide fully functional net power cost templates,with all macros and
links intact,that were used to calculate avoided costs in the referenced filing.
c.Please provide the Demand,Energy Charge,Fuel Price,Delivery Point,and
Market Capacity GRID workpapers files,in Excel format,with all formulas and
links retained.
d.Please provide the Partial Displacement,Wind,and Wind Shaping workpapers
relied upon in the referenced filing.
REQUEST NO.7.With respect to the official forward price curve issued on,or around,
September 30,2017,please provide the following:
a.The hourlymarket price file input into the GRID model,including 30 years of
prices.
b.Updated Fuel Price GRID workpaper,including30 years of prices.
PIIC SECOND PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 2
c.Updated Energy Charge workpaper,as used in the partial displacement deferred
revenue requirement model,with Front Office Transactions and other contracts
based on the reference price curve.
d.The GRID Market Price workpaper based on the referenced curve.
e.Any other GRID workpapers relied upon for calculating avoided costs that are
sensitive to the forward price curve.
REQUEST NO.8.If not reflected in the Company's Q2 Avoided Cost Compliance filing,
please provide the GRID Retail Load file,in .csv format,corresponding to the most recent load
forecast that Company has completed,including30 years of load data.
REQUEST NO.9.Please provide the Company's best estimate of the impact of updating
its analysis regarding the economics of its propose projects to be based on the September 30,
2017 official forward price curve,and provide workpapers supporting the Company's estimate
REQUEST NO.10.Reference the GRID studies provided to Mr.Mullins in response to
ICNU Data Request 10 in Oregon Docket No.LC 67:Please identify how the results of those
studies are incorporated into the economics of the Company's proposal as developed using the
IRP workpapers.
REQUEST NO.l1.Reference the incremental wholesale transmission volumes and
revenues that the Company has assumed in connection with completing the Aeolus to Bridger
transmission segment:
a.Please identify the amount of the referenced incremental transmission revenues
assumed in the Company's analysis.
b.Please provide workpapers supporting the referenced incremental wholesale
transmission volumes and revenues.
PIIC SECOND PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 3
c.Please explain how the referenced transmission segment will allow the Company
to make more wholesale wheeling transactions.
d.Does the Company have any existing requests for wholesale transmission service
that it is unable to fulfill in the absence of the referenced transmission segment.If
yes,please identify all such requests.
REQUEST NO.12.Reference the integration costs assumed with respect to the Company's
new wind proposal:
a.Please identify the integration costs that the Company assumed in its analysis on a
$/MWh basis.
b.Please provide workpapers supporting the integration cost assumptions used in the
Company's analysis.
c.Please identify the $/MWh cost of inter-hour wind integration included in the
Company's July update in Docket UE 323,the 2018 Transition Adjustment
Mechanism Filing,before the Oregon Public Utility Commission.
d.Please identify the $/MWh cost of intra-hour wind integration included in the
Company's Julyupdate in Docket UE 323,the 2018 Transition Adjustment
Mechanism Filing,before the Oregon Public Utility Commission.
REQUEST NO.13.Has the Company performed any analysis to quantifythe potential
impacts of tax reform on the economics of its resource proposal?If yes,please provide all
workpapers supporting its analysis.If no,please explain why the Company believes that it is not
necessary to consider such impacts.
REQUEST NO.14.Please identify the amount of incremental operations and maintenance
expense that the Company has assumed with respect to the new transmission segment,and
provide workpapers supporting the assumed amounts.
PIIC SECOND PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 4
REQUEST NO.15.Reference the capital cost of the proposed Aeolus to Bridger
transmission segment:
a.Please identify the total amount of capital cost that the Company has assumed
with respect to the referenced transmission segment.
b.Please provide an explanation of how the Company derived its capital cost estimate.
c.Please provide workpapers supporting its capital cost estimate,including
itemization of each identified component of the estimated capital costs.
d.Please identify any contingency that the Company has included in its estimate.
e.Please identify any risks that the Company has considered which might cause the
actual capital costs associated with buildingthe referenced transmission segment
to exceed the estimates the Company used in its analysis.
DATED at Boise,Idaho,this day of ,2017.
Respectfully submitted,
Ronald L.Williams
Williams Bradbury,P.C.
Attorneys for PacifiCorp Idaho Industrial Customers
PIIC SECOND PRODUCTION REQUEST TO ROCKYMOUNTAIN,Page 5
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 12th day of October ,2017,I caused to be served a
true and correct copy of the foregoing document upon the following individuals in the manner
indicated below:
Diane M.Hanian,Secretary Hand Delivery
Idaho Public Utilities Commission US Mail (postage prepaid)
P.O.Box 83702 Facsimile Transmission
472 W.Washington Street Federal Express
Boise,ID 83702-0074 Electronic Transmission
E-Mail:[e-mail]
Ted Weston
.Hand DeliveryIdahoRegulatoryAffairsManager .US Mail (postage prepaid)Rocky Mountain Power Facsimile Transmission1407WestNorthTemple,Suite 330 O Federal ExpressSaltLakeCity,UT 84116 ---...
.M Electronic TransmissionE-Mail:[e-mail]
Yvonne R.Hogle Hand DeliveryAssistantGeneralCounselUSMail(postage prepaid)Rocky Mountain Power Facsimile Transmission1407WestNorthTemple,Suite 320 Federal ExpressSaltLakeCity,UT 84l16 Electronic TransmissionE-Mail:[e-mail]
Data Request ResponseCenter
.Hand DeliveryPacificCorpUSMail(postage prepaid)825 NE Multnomah,Suite 2000 Facsimile TransmissionPortland,OR 97232
.Federal ExpressE-Mail:[e-mail]
Electronic Transmission
Brandon Karpen Hand DeliveryDeputyAttorneyGeneral
Idaho Public Utilities Commission US Mail (postage prepaid)
O Facsimile Transmission472W.Washington (83702)O Federal ExpressPOBox83720
Boise,ID 83720 Electronic Transmission
Email:[e-mail]
Randall C.Budge Hand Delivery
Racine,Olson,Nye &Budge,Chtd.US Mail (postage prepaid)
201 E.Center Facsimile Transmission
PO Box 1391 Federal Express
Pocatello,ID 83204-1391 Electronic Transmission
E-Mail:[e-mail]
Attorney for Monsanto Company
PIIC SECOND PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 6
Brubaker &Associates O Hand Delivery16690SwingleyRidgeRoad,#140 O US Mail (postage prepaid)Chesterfield,MO 63017 -
..O Facsimile TransmissionE-Mail:[e-mail] Federal [e-mail] -...Electromc TransmissionMonsantoCompany
Jim Duke Hand DeliveryIdahoanFoodsUSMail(postage prepaid)357 Constitution Way -Facsimile TransmissionIdahoFalls,ID 83742 Federal ExpressE-Mail:duke idahoan.com -Electronic TransmissionPIIC
Kyle Williams Hand DeliveryBYUIdahoUSMail(postage prepaid)Email:[e-mail] Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Val Steiner Hand DeliveryNu-West Industries,Inc.US Mail (postage prepaid)Email:[e-mail] Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Bradley Mullins Hand Delivery333S.W.Taylor,St 400 US Mail (postage prepaid)Portland,OR 97204 Facsimile TransmissionEmail:[e-mail] Federal ExpressPIICElectronicTransmission
Eric L.Olsen Hand DeliveryEchoHawk&Olsen PLLC US Mail (postage prepaid)505 Pershing Ave.,Suite 100 Facsimile TransmissionPOBox6119FederalExpressPocatello,ID 83205
Email:[e-mail] Electronic Transmission
Idaho Irrigation Pumpers Association
Anthony Yankel Hand Delivery12700LakeAvenue,Unit 2505 US Mail (postage prepaid)Lakewook,OH 44107 Facsimile TransmissionEmail:[e-mail] Federal ExpressIdahoIrrigationPumpersAssociationctronicTransmission
Ronald L.Williams
PIIC SECOND PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 7