20240418Staff 6-8 to PAC.pdf

RECEIVED
Thursday,April 18,2024 10:20 AM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
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 )
SECOND 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
THURSDAY,APRIL 25, 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.
1 Staff is requesting an expedited response. If responding by this date will be problematic,please call Staff s
attorney at(208)334-0318.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 APRIL 18, 2024

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
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. 6: Please provide an explanation and supporting documentation for
why the Company experienced 17%underproduction in its 2023 Wind Generation compared to
the Base MWh as referred to in"PAC-E-24-05 CONF Workpaper- Painter- Generation
Tables."
REQUEST NO. 7: According to the "PAC-E-24-05 CONF Workpaper- Painter-
Generation Tables,"the Company experienced a 221% increase in their 2023 Purchased Power
Expenses with short-term/balancing transactions from market purchases. Please answer the
following:
a. Please explain why this expense was so much higher than the amounts assumed in
base rates;
b. Please provide the amount of actual cost that could have been mitigated by securing
hedged purchases from long-term firm resources;
c. Please explain and provide the information that was available within the lead time of
the Company's hedge windows justifying the decision not to secure additional firm
resources. In the explanation, please include, but not limited to, assumptions the
Company made regarding total Company load, existing coal supply constraints,
renewable resource availability, and hydro water availability; and
d. Please explain how the Company plans to ensure that adequate long-term firm
resources are available to optimize similar situations in the future.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 18, 2024

REQUEST NO. 8: Please explain how the Company is planning to enhance its power
cost modeling for its upcoming general rate case as referred to in Painter, Direct at 14.
DATED at Boise, Idaho, this 18ffi day of April 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-05 PR#2.docx
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 APRIL 18, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS _�_DAY OF APRIL 2024,
SERVED THE FOREGOING SECOND 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(@,,pacificorp.com PORTLAND OR 97232
E-MAIL: joseph.dallas@,pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareguest(@,pacificolp.com
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE