20240625Staff 16-17 to PAC.pdf

RECEIVED
Tuesday, June 25, 2024 3:05:38 PM
IDAHO PUBLIC
UTILITIES COMMISSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-24-06
OF THE TRANSFER OF PORTIONS OF THE )
NORTH TEMPLE PROPERTY AND )
ACCOUNTING ORDER ) 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,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY,JULY 9, 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)334-0312.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 JUNE 25, 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. 16: In the Company's response to Production Request No. 5, please
explain what the term "Pause Fee" is and how it is implemented.
REQUEST NO. 17: Please supplement the Company's response to Production Request
No. 10 by explaining the estimated costs of the transmission line relocation and/or transmission
line upgrades as listed in Confidential Schedule 11 for the asset transfer.
DATED at Boise, Idaho, this 251h day of June 2024.
LA-
Dayn Hardie
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-06 PR#2.docx
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JUNE 25, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS�/ DAY OF JUNE 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
06, 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&acificorp.com PORTLAND OR 97232
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest&acificorp.com
\��-
PA RICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE