20180308Staff 71-80 to PAC.pdf

BRANDON KARPEN RE CElVED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SlON
[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 )SEVENTH 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 THURSDAY,
MARCH 15,2018.1
This Production Request is to be considered continuing,and Rocky Mountain Power is
requested to provide,by way of supplementary responses,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 telephonenumber of
'Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER l MARCH 8,2018
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.71:Please provide a breakdown for all categories of costs and benefits
that are labeled as "Cost of Project"in the Corrected Second Supplemental filing for all price
policy scenarios of the levelized wind analysis referenced as tab:PaR -RFP FSL WStudies
within file:EV2020 Workpapers Second Supp Results Summary File -VOMadjustedCONF
Please use the same categories of costs and benefits in the Project Net Costs included in the
Company's Nominal PVRR(d)analysis.For each category of cost,please provide the following:
a.specific costs and benefits for each year between 2017 and 2036;
b.a detailed description of the cost or benefit;
c.the source of the data;and
d.how the costs were calculated or derived (includingthe useful life of the asset and the
number of years included if it is a capital cost,and the specific range of years of
nominal cost that were levelized).
REQUESTNO.72:Please provide a breakdown for all categories of costs and benefits
that are labeled as "Cost of Project"in the Corrected Second Supplemental filing for both the
Medium CO2/Medium Natural Gas and the zero CO2/low natural gas levelized solar sensitivity
analysis referenced as tab:PaR -RFP Solar Sensitivity within file:EV2020 Workpapers Second
Supp Results Summary File -VOM adjusted CONF.Please use the same categories of costs and
benefits in the Project Net Costs included in the Company's Nominal PVRR(d)analysis.For
each category of cost,please provide the following:
a.specific costs and benefits for each year between 2017 and 2036;
b.a detailed description of the cost or benefit;
c.the source of the data;and
d.how the costs were calculated or derived (includingthe useful life of the asset and the
number of years included if it is a capital cost,and the specific range of years of
nominal cost that were levelized).
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 8,2018
REQUESTNO.73:Reference the Corrected Second SupplementalDirect Testimony of
Rick Link,"CORRECTED Table 2-SS"and "CORRECTED Table 3-SS":Please provide a
narrative explanation for why the two referenced tables produce such different results by
identifying the drivers of the differences between NPVRR(d)benefits of $357 million in
CORRECTED Table 2-SS and $167 million in CORRECTED Table 3-SS under the medium
gas,medium CO2 scenario;and by providing a differential analysis of the different costs and
benefit categories for the two tables as reflected in the Company's nominal analysis spreadsheet
(filename:EV2020 Workpapers Second Supp Results Summary File -VOM adjusted Conf;Tab:
Par -RFP FSLW Studies).
REQUESTNO.74:For the Company's solar and new wind Nominal PVRR(d)
analysis,please describe in detail how the number of megawatt-hours used to project the System
Impacts from 2037 through 2045 for the solar scenarios and from 2037 through2050 for the
wind scenarios were derived.
REQUESTNO.75:Please provide a levelized PVRR(d)analysis for all price policy
scenarios using levelized PTC benefits in the Cost of Project similar to the levelized PVRR(d)
analysis submitted in the Company's original Application.
REQUESTNO.76:Please provide the levelized and nominal PVRR(d)analysis
relative to the base case for all price policy scenarios locking in the Company's final short-list of
Solar projects that has a comparable level of effective capacity/generationto the new wind
scenario.
REQUESTNO.77:Please provide information relative to the nominal solar PVRR(d)
analysis provided by the Company:
a.What is the useful life of assets assumed in the solar network costs?
b.Are the assets in the solar network costs dedicated to the solar project and can they be
utilized past the term of the PPA's?
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MARCH 8,2018
c.Please describe in detail how the Solar PPA costs were derived and/or calculated?
Are there any differences in inputs or derivations for the 2017 through 2036
timeframe and the 2037 through 2045 timeframe?
REQUESTNO.78:Please provide information relative to the nominal new wind
PVRR(d)analysis provided by the Company:
a.Please describe and provide a breakdown of the components contained within
Transmission Capital Recovery category.
b.What are the useful lives of the assets contained within Transmission Capital
Recovery category?
c.How far out are the Transmission Capital Recovery costs and benefits included in the
analysis?
d.Please provide a description and the method used to derive incremental transmission
revenues.
e.Please describe and provide a breakdown of the components contained within Capital
Recovery -New Wind category.
f.How far out in time are the Capital Recovery -New Wind costs and benefits included
in the analysis?
g.Please describe and provide a breakdown of the components contained within
Network -New Wind category.
h.What are the useful lives of the assets contained within Network -New Wind
category?
i.How far out are the Network -New Wind costs and benefits included in the analysis?
j.Please describe and provide a breakdown of the components contained within the
O&M/Wind Tax -New Wind category.
k.Please describe and provide a breakdown of all the components contained within the
Terminal Value -New Wind category.
1.Please describe and provide a breakdown of all the components contained within the
PPA Cost -New Wind category.
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 MARCH 8,2018
REQUESTNO.79:Is the Company proposing to recover the costs associated with the
combined projects consistently with the way the revenue requirements are modeled in its
levelized analysis?If not,please explain why not?
REQUESTNO.80:How are the revenue requirements that flow into Joelle Stewards
analysis modeled,using levelized revenue requirements or nominal revenue requirements?
Please explain the rationale for this approach in detail?
DATED at Boise,Idaho,this day of March 2018.
andon arpe
Deputy Áttorne G neral
Technical Staff:Mike Louis/71-80
i:umisc:prodreqlpacel7.7bkml prod reg 7
SEVENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 MARCH 8,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8th DAY OF MARCH 2018,
SERVED THE FOREGOING SEVENTH 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:reb racinelaw.net
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:kiverson consultbai.com BOISE ID 83701
bcollins consultbai.com E-MAIL:ron williamsbradbury.com
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 itafos.com 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