20171101PIIC 16-18 to PAC.pdf

WILLIAMS ·BRADBURY
ATTORNEYS AT LAW RECEIVED
2017NOV-!PMI2:3I
MHO PUBLICNovember1,2017 T S COMMISSION
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'Third 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.
Si rely,
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 )THIRD 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 15,
20171.
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
i PIIC is aware that the standard rule is to allow the Company 21 days to respond.However,PIIC request the
Company to respond by November15th in order to allow PIIC time to review this informationprior to when
testimonies are due on November20th
PIIC THIRD PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 1
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.
REQUEST NO.16.Reference the accuracy of Company's Official Forward Price
Curve ("OFPC"):
a.Has the Company ever performed an analysis to quantifythe forecast error
associated with previously-issued long-term official forward price curves?If
yes,please provide any such analyses.
b.Please provide each OFPC the Company issued over the period December
2006 through January 2017 (inclusive),including all power and natural gas
hubs where the Company transacts.Please include forward prices for each
month and year for which the forecast was prepared.Please provide this
data in format similar to the Company's response to ICNU Data Request
001 in Or.PUC Docket No.UE 307.
c.Please provide actual spot market prices,on a monthlybasis over the period
January 2007 through September 2017 (inclusive),includingall power and
natural gas hubs where the Company transacts.
d.When evaluating the forecast error associated with previouslyissued
Official Forward Price Curves,does the Company agree that such an
analysis may be reasonably performed using price curves issued over the
period 2007 through 2017?If no,please identify the period which the
Company believes would provide the most reasonable basis for measuring
the forecast error associated with previously issued OFPCs.
e.If the Company believes that the forecast error associated with its OFPCs
would be more reasonably measured over a longer period of time than 2007
through 2017,please provide each OFPC issued and monthlyspot market
prices,in the same manner as identified subparts (b)and (c)to this request,
over the period the Company believes would be more reasonable for
measuring the forecast error of previously issued OFPCs.
REQUEST NO.17.Reference the long-term gas contracts executed pursuant to the
Company's 2012 Gas RFP,as discussed in Ut.PSC Docket 12-035-102:
a.Does the Company agree that it ultimatelyexecuted two gas transactions
pursuant to the referenced 2012 Gas RFP?If yes,please provide a brief
overview of these transactions.
b.Please identify the counterparty associated the referenced transactions.
c.Does the Company agree that the referenced transactions were subject to a
requirement that the levelized price of the gas contracts not exceed the
PIIC THIRD PRODUCTION REQUEST TO ROCKY MOUNTAIN,Page 2
levelized market price in the Company's forward price curve (just as the
economics of the Company's Energy Vision 2020 project are highly
dependent upon the prices in the Company's OFPC)?
d.How accurate has the OFPC that the Company relied upon when executing
the referenced transactions been?
e.Please identify the OFPC the Company relied upon when executing the
referenced transactions,and if not already provided in response to another
request,please provide a copy of the OFPC.
f.Please provide the actual monthlysettlements data associated with the
referenced transactions over the period 2013 (includingthe earliest month
where settlements were made)through the most recent month with available
settlement data.Please provide the settlement data in the same format as
provided in "Attach ECAM MFR 3 -3 CONF"in the ongoing Energy Cost
Adjustment Mechanism Proceeding before the Wyoming Public Service
Commission (Docket No.20000-514-EA-17).
g.Please provide the deal tracking data from the Company's energy trading
system over the period August 2017 through the term of the referenced
agreements (based on a ten-year term,approximately 2023).Please provide
the deal tracking data in a manner substantially similar to the Company's
GRID modeling Gas Swaps workpaper (See e.g."ORTAMl8w_GasSwaps
(1612)FEB17 CONF").
h.If not readily apparent from the data provided in response to this request
please identify the monthly fixed prices associated with the referenced
transactions over the term of the transactions.
REQUEST NO.18.Reference the Company's wind shaping methodology:
a.When modeling the new wind resources in the System Optimizer and PaR
models,did the Company use the same hourlywind shaping methodology
that it uses in the GRID model for forecasting net power costs in general
rate case,and other related,proceedings?
b.Please provide a description of how the hourlywind profiles for the new
wind resources were modeled in the SO and PaR models.
c.Please provide the hourlywind profiles for each of the new wind resources
as input into the System Optimizer and PaR models.
PIIC THIRD PRODUCTION REQUEST TO ROCKY MOUNTAIN,Page 3
DATED at Boise,Idaho,this lst day of November ,2017.
Respectfully submitted,
Ronald L.Williams
Williams Bradbury,P.C.
Attorneys for PacifiCorp Idaho Industrial Customers
PIIC THIRD PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 4
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1st day of November ,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 .O US Mail (postage prepaid)Rocky Mountain Power Facsimile Transmission1407WestNorthTemple,Suite 330 Federal ExpressSaltLakeCity,UT 84 ll 6 ..
.Electronic TransmissionE-Mail:[e-mail]
Yvonne R.Hogle .O Hand DeliveryAssistantGeneralCounsel .US Mail (postage prepaid)Rocky Mountain Power Facsimile Transmission1407WestNorthTemple,Suite 320 Federal ExpressSaltLakeCity,UT 84116
.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)
Facsimile Transmission472W.Washington (83702)Federal ExpressPOBox83720
Boise,ID 83720 Electronic Transmission
Email:[e-mail]
Randall C.Budge Hand Delivery
Racine,Olson,Nye &Budge,Chtd.US Mail (postage prepaid)
20l E.Center Facsimile Transmission
PO Box 1391 Federal Express
Pocatello,ID 83204-1391 Electronic Transmission
E-Mail:[e-mail]
Attorney for Monsanto Company
PIIC THIRD PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 5
Brubaker &Associates Hand Delivery16690SwingleyRidgeRoad,#140 US Mail (postage prepaid)Chesterfield,MO 63017
.Facsimile TransmissionE-Mail:[e-mail] Federal [e-mail] .Electronic TransmissionMonsantoCompany
Jim Duke Hand DeliveryIdahoanFoodsOUSMail(postage prepaid)357 Constitution Way -U Facsimile TransmissionIdahoFalls,ID 83742 O Federal ExpressE-Mail:[e-mail] -
.M 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 Electronic TransmissionEmail:[e-mail]
Idaho Irrigation Pumpers Association
AnthonyYankel Hand Delivery12700LakeAvenue,Unit 2505 US Mail (postage prepaid)Lakewook,OH 44107 Facsimile TransmissionEmail:[e-mail] Federal ExpressIdahoIrrigationPumpersAssociationElectronicTransmission
Ronald L.Williams
PIIC THIRD PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 6