20240416Staff 1-5 to PAC.pdf

RECEIVED
Tuesday,April 16,2024 3:45:05 PM
IDAHO PUBLIC
ADAM TRIPLETT UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION REQUESTING ) CASE NO. PAC-E-24-05
APPROVAL OF $62.4 MILLION ECAM )
DEFERRAL )
FIRST 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
TUESDAY,APRIL 23, 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 call Staff's
attorney at(208)334-0318.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 APRIL 16, 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 responses to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 1: In his testimony, Company witness Painter asserted that, "coal
pricing more than doubled in 2022 and remained high into 2023." Painter Direct at 21. Please
provide historical coal pricing data from 2021 to present for a range of coal types used by the
Company's plants.
REQUEST NO. 2: In his testimony, Company witness Painter asserted that the
Company, "continued to transport coal from the Rock Garden safety pile to the Huntington
plant...through September 2023 when the Rock Garden inventory was completely depleted."
Painter Direct at 21-22. Please describe the purpose of the Rock Garden safety pile, its current
status, and the Company's long-term plan for it.
REQUEST NO. 3: In his testimony, Company witness Painter asserted that the
Company contracted for new coal supplier for its Utah plants in 2023 and amended its existing
coal contracts with Bronco and Wolverine. Painter Direct at 21-24. Please provide the
following concerning the coal supply inventory for the Utah plants:
a. The contracted delivery tonnage for each month in 2024 for each of the Utah coal
plants;
b. The forecasted generation output for each of the Utah coal plants and the resulting
coal inventory,by month in 2024;
c. An analysis of any coal-supply constraints on the output for each of the Utah coal
plants for 2024; and
d. An analysis of any coal-supply constraints on the output for each of the Utah coal
plants beyond 2024.
REQUEST NO. 4: In his Testimony, Company witness Painter explained the problems
with coal delivery for the Utah plants and Jim Bridger. Four other coal plants under-produced by
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 16, 2024

20 percent or more from their base threshold (Craig, Dave Johnston,Naughton,Wyodak).
Please explain why each of these 4 coal plants under-produced by such wide margins.
REQUEST NO. 5: Please provide the 2023 outage data for each resource type
(Thermal, Wind, Hydro) in sortable spreadsheets. Please explain the differences between the
three outage types (Forced, Maintenance, Planned).
DATED at Boise, Idaho, this 16th day of April 2024.
1
A m Trip t
Deputy At mey General
I:\Utility\UMISC\PRDREQ\PAC-E-24-05 PR#l.docx
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 APRIL 16, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS DAY OF APRIL 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
05, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL: mark.alder(2,12acificorp.com PORTLAND OR 97232
E-MAIL: josepli.dallasCa)pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
-4
PATRICIA JORDAN
CERTIFICATE OF SERVICE