20180123Staff 61-70 to PAC.pdf

REcE!VEDBRANDONKARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 20\l JAN 23 PM 12:03
PO BOX 83720 pg CBOISE,IDAHO 83720-0074 MiŠŠlON
[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-17-07
POWER FOR A CERTIFICATE OF PUBLIC )CONVENIENCE AND NECESSITY AND )
BINDING RATEMAKING TREATMENT FOR )SIXTH PRODUCTION
NEW WIND AND TRANSMISSION FACILITIES)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 TUESDAY,
JANUARY 30,2018.1
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 behalf may 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 telephone number of
'Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JANUARY 23,2018
the person preparing the documents.Please identifythe 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.61:Please provide all reports developed as part of the Proposal Bid
Evaluation.
REQUESTNO.62:Please provide a summary (in a table format,if available)of the
Proposal Bid Evaluation.At a minimum please provide the following:
a.Identify all factors and criteria (with a short description)used in evaluating the
various proposals.
b.Identify all bidders,bids,and any alternates bids submitted.
c.Provide a brief description for each of the bids or alternative bids.
d.Provide the resulting scoring for all factors and criteria for all submitted bids.Please
include the specific prices,plant size,capacity factors,amount of generation ...(etc.)
for each bid.
e.Identify any adjustment made to the bid proposal as part of the evaluation.
f.Identify all reasons bids were removed from consideration.
REQUESTNO.63:Please provide copies of all proposed Build Transfer Agreements
(BTA)associated with the selected projects.
REQUESTNO.64:Please provide copies of all proposed Purchase Power Agreements
(PPA)associated with the selected projects.
REQUESTNO.65:Please explain why the Ekola Flats project was excluded from the
final RFP selection?
REQUESTNO.66:Please explain benefits and reasoning for the Cedar Springs wind
project to be 50%Company owned and 50%NextEra owned?What are the benefits to this type
of arrangement over 100%Company ownership or 100%NextEra ownership?
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JANUARY 23,2018
REQUESTNO.67:How does the Company realize benefits of the Cedar Springs wind
project site for redeveloping transmission assets that have not been fully depreciated at the end of
30 years when the Company does not own 100%of the facility (Link,Di-Supp -17)?
REQUESTNO.68:Please provide a detailed cost breakdown (includinga short
description of individual items)for the additional network upgrades included in the supplemental
filing.
REQUESTNO.69:Please provide the modeled annual capacity factors for all existing
generation resources for both the base case and 1,170 megawatts new wind/transmission
proposal over the next 20 years.
REQUESTNO.70:In reference to the 240 MW PPA resource identified as
I WNE_EP_WDp in the SO model summary report named SO Portfolio Rl7-base-
MM_1712300840 and SO model summary report named SO Portfolio R17-WFSL-
MM 1801121945:
a.Please provide the location of this resource.
b.Since this resource is included in the base case file,SO Portfolio Rl7-base-
MM_1712300840,it is assumed the resource could be brought online without the
new transmission line.With this assumption,please explain why the Company chose
to restrict new wind resource bids in eastern Wyoming to 1,030 MW (1,270 MW less
240 MW)as stated in the supplemental direct testimony by Mr.Link on page 7,lines
14-15?
c.Please explain why the cost for the resource was not included in either the SO
Portfolio Rl7-base-MM 1712300840 and SO Portfolio Rl7-WFSL-
MM 1801121945 files?
DATED at Boise,Idaho,this ay of January 2018.
Bran o en
Deputy A rney eneral
Technical Staff:Rick Keller/61-69
Michael Eldred/70
i:umisc:prodreq/pace17.7bkrkme prod req 6
SIXTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 JANUARY 23,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23 DAY OF JANUARY 2018,
SERVED THE FOREGOING SIXTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-07,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSISTANT 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:val.steiner agrium.com POCATELLO ID 83205
E-MAIL:elo echohawk.com
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:brmullins mwanalytics.com
SECRET
CERTIFICATE OF SERVICE