20200803Staff 1-8 to PAC.pdf

;iTCEIVEE
tiZil AUG - 3 Pl{ 2: 03DA\}I HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
(208) 334-03 r 2
IDAHO BAR NO. 99I7
1 't :,1
:l..il,J*'i&818f,i
Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO INCREASE ITS
RATES AND CHARGES IN IDAHO AND FOR
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND REGULATIONS
CASE NO. PAC-E.20.03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
llle Staff of the Idaho Public Utililies Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General. requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY,
AUGUST 24,2020,
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way ofsupplementary responses, additional documents that it. or any
person acting on its behalf, may later obtain that will augment the documents or intbrrnation
produced.
Please provide ans!!€rs to each question, supporting ll'orkpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identily the name, job title, Iocation, and
telephone number ofthe record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUN'I'AIN POWER
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AUGUST 3,2020
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic flles on CD with lornrulas intact and enabled.
REQUEST NO. l: Please provide the Company's net present value (NPV) economic
and risk analysis/analyses, including al1 rvorkpapers in Excel lbrmat wilh formulas intact and
enabled lbr the Foote Creek I repora,ering projecl. Please also include the lbllowing:
a) A detailed dcscription ofthe scopc and the process used to perform the
analysis/analyses.
b) A list o{'all the assumplions and inputs included in the analysis/analyses. and a
summary olthe parameters that were changed for each risk scenario and/or sensitivity
analysis perlbrmed.
c) An NPV comparison of the analysis/analyses results with and wilhout the projecl. lor
each risk scenario and/or sensitivity analysis, including an annual breakdown ofthe
costs and benefits for each scenario. The breakdown should include all major cost
and benefit categories including, but not limited to, annual generation (MWh), fixed
and variable O&M cost (net power cost broken out separately), Production Tax
Credits, Wyoming Wind Production tax, e1c.
REQLIIIST NO.2: Please provide the Company's NPV economic and risk
analysis/analvses, irrcluding all workpapers in Excel format with formulas intact and enabled, fbr
the Pryor Mountain rvind project. Please also include the lbllo*ing:
a) A detailed descriprion of the scope and the process used to perform the
analysis/analyses.
b) A list ofall the assurnptions and inputs included in the analysis/analyses, and a
summary ofthe parameters that uere changcd lor each risk scenario andior sensitivity
analysis performed.
c) An NPV comparison oflhe analysis/analyses rcsuhs rvith and wilhout the project, for
each risk scenario and/or sensitivity analysis, including an annual breakdown of the
costs and benefits for the system and for ldaho's share. The brcakdown should
include all major cost and benefil categories including, but not limited to, annual
generation lMWh). fixed and variable O&M cost (net power cost broken out
separately), Production Tax Credits, Wyoming Wind Production tax, etc.
REQUEST N0.3: Pleasc provide an actual-to-estimatc project cost conrparison fbr the
Foote Creek I re-powering rvind project broken dorvn by major cosl category. Ilor each cost
category, please indicate the basis used to provide tlle estimate, and how the Compan-v ensured
that it was incurred at least cost. Please provide responscs in Excel lbrmat with formulas intact
and enabled.
FIRST PRODUCTION REQUIST
TO ROCKY MOLTI\iTA.IN POWER 2 AUGUST 3, 2O2O
REQUEST NO. 4: Please provide an actual-to-estimate project cost comparison for the
Pryor Mountain wind project broken doun by major cost categories. For each cost catcgory,
please indicate the basis used to provide the estimate, and hou'the Company ensured that it was
incurred at least cost. Please provide responses in Excel fbrmat with formulas intact and
enabled.
REQUEST NO. 5: Please provide the Company's NPV economic and risk
analysis/analyses. including all workpapers in Excel lbrmat with formulas intacl and enabled, for
the closure of Cholla Unit No.4. Plcase also include the following:
a) A detailed description ofthe scope and the process used to pertbrm the
analysis/analyses.
b) A list olall the assumptions and inFuts included in the analysis/analyses, and a
summary of the parameters thal were changed for each risk scenario and/or scnsitivity
analysis performed,
c) An NPV comparison ofthe analysis/analyscs results ttsing closure dates at thc end ol
2020,2025. and 2042. Include all results for each risk scenario and/or sensitivity
analysis, including an annual breakdou.n ofthe costs and benefits for the system and
for Idaho's share. The breakdoun should include all major cost and benefit
categories including, but not limited lo. annual generation (MWh), fixed and variable
O&M cost (net power cost broken out separately). decommissioning cost, etc Please
also inctude comparisons that the Contpany perfbrmed tbr other closure dates if
different from those specified.
REQUEST NO. 6: Please provide any supporting documentation including any
contracts for the following amounts listed in Table I:
Gross EPIS
Accumulated Depreciation
CWIP
M&S
Liquidated Damages
GE safe harbor lease termination paymenl
Savings due to O&M Expense
Savings due to Depreciation Expense
REQUEST NO, 7: Plcase provide the nrethodoiogy and process the Company used to
estimate the decommissioning costs. Please include any workpapers used to estimate the
decommissioning costs.
FIRST PRODUC-IION REQUEST
TO ROCKY MOLTNTAIN POWER
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3 AUGUST 3.2020
REQUEST NO. 8: In reference to Production Request No. 7, please provide a schedule
showing the estimated expens€ per year. Please include which major tasks will be performed in
each year.
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DATED at Boise, tdaho, this day ofAugust 2020.
Deputy Attomey General
i rumisc:p.odEq/pac!20.3dhjt prod req I
FIRST PRODUCTION RIQUEST
TO ROCKY MOTJNTAIN POWER 4 AUGUST 3,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY OF AUGUST 2020,
SERVED THE FOREGOING TIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC.E.2O-03, BY E.MAILING A COPY THEREOF, TO THE FOLLOWINC:
TED WESTON
ROCKY MOTJNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAILONLYT
datareouest@pacifi corp.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
505 PERSHING AVE STE IOO
PO BOX 6l 19
POCATELLO ID 83205
E-MAIL: [e-mail]
EMILY WECENER
ROCKY MOTJNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY LTT 84I 16
E-MAIL: emilv.weeener@pacifi corp.com
[e-mail]
ANTHONY YANKEL
12700 LAKE AVENUE
UNIT 2505
LAKEWOOD OH44IO7
E-MAIL: [e-mail]
SECRETARY,
CERTIFICATE OF SERVICE