Staff/SWC-1

Referring to Exhibit No. SWC-1, page 3, lines 16-24, does SWP have hydroelectric plants, other than those listed here, that may be used to provide energy to third parties?  If yes, please list each plant.

Staff/SWC-2

Referring to Exhibit No. SWC-1, page 5, lines 21-24, Exhibit No. SWC-4, Schedule B and Exhibit No. SWC-5 showing purchased power costs, will any of the costs shown for purchases from the California PX change as a result of applying the MMCP?  If no, please explain.

Staff/SWC-3

Please refer to Exhibit No. SWC-1, page 7, lines 6-7, which states “through energy purchases and exchanges, the SWP obtained sufficient power during off-peak periods...”  In each month, what percentage of the power was obtained through exchanges and what percentage was purchased?

Staff/SWC-4

Referring to Exhibit No. SWC-1, page 7, lines 12-15, are SWP’s exchanges being mitigated in this proceeding?  If no, please explain why it is appropriate to compute pump-storage generation costs related to exchanges.

Staff/SWC-5

Referring to Exhibit No. SWC-1, page 5, lines 14-15 and Exhibit SWC-4, SWP states that for every 1 MWh of energy used to pump water up and into Lake Oroville, the SWP is able to produce only approximately 0.7 MWh of energy.  Please provide the derivation of the 0.7 factor or indicate where this is derived in Exhibit SWC-4.  Include all supporting workpapers. 

Staff/SWC-6

Referring to Exhibit No. SWC-4, Schedule A-2, have the performance curves been updated since November 1991?  If yes, please provide.

Staff/SWC-7

Please refer to Exhibit No. SWC-4, Schedule D.

a)	As shown on Schedule D, it appears that SWP estimates the average per unit price for Exchange Energy based on its purchases during the month.  Please explain why this is reasonable.

b)	It appears that SWP purchased energy from the California PX through December 17, 2000.  Do the unit costs shown reflect the MMCPs to be applied to the California PX transactions in this proceeding?

Staff/SWC-8

Please refer to Exhibit No. SWC-1, page 8, lines 1-6.  In comparing “the unit cost of energy” in line 4 to the “MMCP” in line 6, is the unit cost of energy based on actual amounts billed during the refund period or, for the spot market purchases,  mitigated amounts derived from the California ISO's MMCPs for the relevant intervals?

Staff/SWC-9

Please refer to Exhibit No. SWC-4, Schedule A, page 4, which states that SWP acquired energy from SCE “under an existing contract whereby the SWP provides to SCE on-peak capacity and energy in exchange for SCE providing off-peak energy to SWP.”  Please provide the formulas and/or contractual provisions which show how SCE and SWP valued the on-peak and off-peak capacity and energy.

Staff/SWC-10

Referring to Exhibit No. SWC-4, Schedule A, page 4, and Schedule C, page 1, was the amount of energy exchanged greater than 280 MWh?  If yes, please explain why Exchange Energy was not used first rather than including the lower priced 3 MWh ($73/MWh).

Staff/SWC-11

Referring to Exhibit No. SWC-4, page 5, item 5, what is SWP’s actual per unit O&M expense?.  Provide all supporting workpapers.

Staff/SWC-12

Referring to Exhibit No. SWC-4, page 5, item 6,

a)	please describe the uncertainty associated with the use of estimated pump/generation factors based on historical unit tests.

b)	please provide the basis for the 15% adjustment.

c)	if SWP adopts the Commission’s $6/MWh O&M expense, please explain why it is reasonable to include a 15% adjustment factor.

Staff/SWC-13
		
Referring to Exhibit No. SWC-4, Schedule E, were all of the charge type 401 energy sales shown made through energy supplied by the Hyatt-Thermalito power plants?  If no, please explain why it is reasonable to exclude SWP’s other resources (e.g., Devil Canyon) from its comparison of the MMCP and SWP costs.

Staff/SWC-14

Is there any reason other than electricity generation for pumping at the Hyatt-Thermalito  pump-storage facilities (e.g, water storage for non-electric generation purposes)?  If yes, please explain each reason.

Staff/SWC-15
Referring to Exhibit SWC-1, page 9, lines 14-17, for those transactions where CDWR bid into the imbalance energy market and ancillary services market, did the California ISO request CDWR (SWP) to bid into the markets?  If yes, please provide all supporting documentation including e-mails, phone logs, etc.

Staff/SWC-16

Exhibit No. SWC-4, Schedule F and Schedule G show transactions for January 9, 2001.  The January 5, 2001 DOE Order established a $64/MWh limit on the price the California ISO could agree upon for its requested energy or service pursuant to the DOE Orders.  Did the price for any SWP transaction provided on this date exceed $64/MWh?  If yes, did SWP ask the California ISO to refer the rate issue to FERC?  If no, please explain how this complies with the DOE Order.

Staff/SWC-17

Referring to Exhibit No. SWC-1, page 12, lines 22-24 and page 13, lines 1-2, please provide all phone logs, e-mails, memoranda, etc., relating to calls received from the California ISO’s generation dispatcher on DOE certification days.

Staff/SWC-18

Are the transactions shown on Exhibit No. SWC-4, Schedule L for DOE certification days included under Exhibit No. SWC-4, Schedule F?  If no, does SWP contend that none of these transactions were made pursuant to the DOE Orders?