20240315Staff 38-39 to PAC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
2024 LIAR 15 PN 2: 03
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION REQUESTING
AUTHORIZATION TO UPDATE THE WIND
AND SOLAR INTEGRATION RATE FOR
SMALL POWER GENERATION
QUALIFYING FACILITIES
CASE NO. PAC-E-23-24
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
FRIDAY, MARCH 22, 2024.1
This Production Request is to be considered as continuing, and the Company 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 telephone number of
1 Staff is requesting an expedited response. If responding by this date will be problematic, please contact Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MARCH 15, 2024

the person preparing the documents. Please also 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 spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO.38: Please confirm that the marginal regulation reserve cost calculated
by the PLEXOS model only reflects variable production costs (such as fuel costs and variable
O&M costs) and does not reflect fixed costs (such as capital costs and fixed O&M costs).
REQUEST NO.39: Please confirm that the proposed integration charges do not capture
capital costs and fixed O&M costs of regulation reserves. If confirmed, please explain why the
proposed integration charges should not capture capital costs and fixed O&M costs of regulation
reserves.
DATED at Boise, Idaho, this 15'h day of March 2024.
Michael Duval
Deputy Attorney General
I:\Utility\UNUSC\PRDREQ\PAC-E-23-24 PR# 3 docx
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MARCH 15, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15th DAY OF MARCH 2O24,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-
23-24, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: mark. alder(&i)acifi corn. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest(apacificom.com
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST
STE 2000
PORTLAND OR 97232
E-MAIL: ioseph.dallasaa t)acificom.com
vj� 4�9" .-"Vkb,.V
Secretary
CERTIFICATE OF SERVICE