20240815Staff 16-19 to PAC.pdf

RECEIVED
Thursday, August 15, 2024 9:37:56 AM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
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 THE APPLICATION )
OF ROCKY MOUNTAIN POWER REQUEST ) CASE NO. PAC-E-24-09
FOR APPROVAL OF THE 2024 IDAHO )
WILDFIRE MITIGATION PLAN )
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,
Adam Triplett, Deputy Attorney General, requests that Rocky Mountain Power("Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY,AUGUST 29, 2024.'
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.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 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. 16: Referencing Figures 2 and 3 on page 11 of the Idaho Wildfire
Mitigation Plan, please provide the causes that are included in the"Other" column.
Additionally, please provide what methods the Company is using to define what is included in
the Unknown category for ignition risk factors.
REQUEST NO. 17: In the Company's Response to Production Request No. 10, please
explain if the annual meteorology department expenses are an expansion of the Company's
meteorology department or if this is a new department dedicated for wildfire.
REQUEST NO. 18: In the Company's Response to Production Request No. 11, the
Company's table forecasts a large capital expenditure in 2025. Please explain why the Company
forecasts to spend $582,195 in 2025 and then $36,741 in 2026 and 2027.
REQUEST NO. 19: In the Company's Response to Production Request No. 6, the
Company's response had a footnote that said, "It is important to note that, while there is no area
designated as FHCA in Idaho, vegetation management work is nonetheless performed on circuits
identified as potentially high risk by the company's meteorology group." Emphasis added.
Please explain if the criteria used by the Company's meteorology group is the same as the
FireSight model to identify risk areas. If not the same, please explain the difference.
DATED at Boise, Idaho, this 151h day of August 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-09 PR#2.docx
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 15, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6 DAY OF AUGUST 2024,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
09, BY &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: [e-mail] PORTLAND OR 97232
E-MAIL: joseph.dallasgpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest pacificorp.com
4 d7/,
PAT ICIA J 0AN, S11CRETARY
CERTIFICATE OF SERVICE