20240828Staff 217-240 to PAC (Redacted).pdf

RECEIVED
Wednesday, August 28, 2024 11:16:26 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
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF ROCKY MOUNTAIN POWER FOR ) CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES IN IDAHO AND APPROVAL ) REDACTED TWELVTH
OF PROPOSED ELECTRIC SERVICE ) PRODUCTION REQUEST OF
SCHEDULES AND REGULATIONS ) 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 PacifiCorp d/b/a Rocky Mountain Power
("Rocky Mountain Power" or the "Company")provide the following documents and information
as soon as possible,but no later than WEDNESDAY, SEPTEMBER 11, 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.
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 28, 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. 217: Please provide a description of the savings expected from the
Field Ai-Field Asset Intelligence project referenced in Production Request No. 15 —Attachment
and how they are being realized.
REQUEST NO. 218: Please provide the actual in-service date for the Field Ai-Field
Asset Intelligence project referenced in Production Request No. 15 —Attachment. If this has not
been placed in-service, please provide a new estimated in-service date.
REQUEST NO. 219: Please provide the actual spending in 2024 through July 31 for the
Field Ai-Field Asset Intelligence project referenced in Production Request No. 15 —Attachment.
REQUEST NO. 220: Please provide the actual in-service date for the Field Ai-Field
Asset Intelligence - GWD project referenced by Shelley E. McCoy in Workpaper 8.5.3 —Major
Plant Additions. If this has not been placed in-service,please provide a new estimated in-service
date.
REQUEST NO. 221: Please provide the actual spending in 2024 through July 31 for the
Field Ai-Field Asset Intelligence - GWD project referenced by Shelley E. McCoy in Workpaper
8.5.3 —Major Plant Additions.
REQUEST NO. 222: Please provide the cost savings the Company has gained or is
expected to gain from the roll out of AMI. Please show where this is represented in the
Company's rate case filing.
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 28, 2024

REQUEST NO. 223: Regarding the Company's REC Option Program, please answer
the following:
a. Please explain if there are any controls that prevent program participants from
being able to retire more RECs than they currently receive in the form of REC
revenue; and
b. Please explain if there are any controls that prevent non-participants from
receiving less REC revenue than they currently receive.
REQUEST NO. 224: For each year in 2020 through 2023,please provide total RECs
generated for that year and the total system load for the same year for the Company's system.
REQUEST NO. 225: Regarding the Company's REC Option Program, please provide
the Company's method of calculating the percentage of participants' load available for REC
retirement each Program Year. Please describe how the Company plans to update the calculation
as the Company's resource portfolio changes.
REQUEST NO. 226: Referring to proposed Electric Service Schedule No. 74, Special
Condition No. 2,please explain the Company's criteria and processes for selecting RECs to be
retired on behalf of the Program.
REQUEST NO. 227: Page 4 of Eller's Direct Testimony states that the Company has
been approached by customers that are interested in making renewable energy claims and the
retirement of RECs. Please provide the results of any surveys administered by the Company for
customers seeking out REC retirement programs, if any.
REQUEST NO. 228: Regarding the Company's REC Option Program, please explain
the Company's criteria and processes for selecting RECs that are sold on behalf of Idaho
customers.
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 28, 2024

REQUEST NO. 229: Please respond to the following regarding the CCA costs
associated with the Chehalis plant.
a. Please provide the dispatch cost in $/MWh for the Chehalis plant used in the Aurora
model;
b. Please explain whether the dispatch cost includes any allowance cost in$/MWh;
c. If so,please provide the allowance cost in $/MWh assumed in the dispatch cost;
d. Please provide the CCA allowance price in"$/allowance"that was used to calculate
the CCA allowance unit price in"$/MWh";
e. Please explain how the $/allowance unit price is determined;
f. Please explain and provide workpapers showing how the CCA unit price is converted
from $/allowance to $/MWh;
g. Please explain whether the CCA unit price included in the dispatch cost is the same as
the CCA unit price stated in Response to Production Request No. 117 (a); and
h. If not, please reconcile and explain the causes for any difference.
REQUEST NO. 230: Please re-run Aurora model and provide updated workpaper
"ID_GRC_2025_2023 Normalized Load.xlsm" and updated McCoy's workpaper"5.1 —
NPC.xlsx"to reflect the result of each scenario below:
Scenario Modifications
1 • Remove the CCA allowance cost from the dispatch cost of the
Chehalis plant in the Aurora model; and
• Remove the post-modeling CCA costs2, which were calculated
based on the multiplication of Chehalis's generation amounts and
the CCA allowance cost.
2 • Use the official forward price curve ("OFPC") dated on June 28,
2024, from Response to Production Request No. 107 in the Aurora
model;
• Remove the CCA allowance cost from the dispatch cost of the
Chehalis plant in the Aurora model; and
• Remove the post-modeling CCA costs, which were calculated based
on the multiplication of Chehalis's generation amounts and the CCA
allowance cost.
2 In the Application,"post-modeling CCA costs"were reflected on Line 4"Allowances"of Exhibit No.51.
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 28, 2024

3 • Use the OFPC dated on June 28, 2024, from Response to
Production Request No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the
Chehalis plant in the Aurora model;
• Remove the post-modeling CCA costs, which were calculated based
on the multiplication of Chehalis's generation amounts and the CCA
allowance cost.
• Production Request No. 184 e .
4 • Use the OFPC dated on June 28, 2024, from Response to
Production Request No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the
Chehalis plant in the Aurora model; and
• Remove the post-modeling CCA costs, which were calculated based
on the multiplication of Chehalis's generation amounts and the CCA
allowance cost.
• Production Request No. 185
5 • Use the OFPC dated on June 28, 2024, from Response to
Production Request No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the
Chehalis plant in the Aurora model; and
• Remove the post-modeling CCA costs, which were calculated based
on the multiplication of Chehalis's generation amounts and the CCA
allowance cost.
• Production Request No. 186.
REQUEST NO. 231: Please explain whether the Aurora model run in response to
Production Request No. 107 uses an updated gas price forecast and an updated electricity price
forecast, both of which came from the latest OFPC of June 28, 2024.
REQUEST NO. 232: Please explain whether the proposed Net Power Cost is
determined based on the expected resources in 2025,under the expected system conditions for
2025, and against a 2023 weather-normalized load.
REQUEST NO. 233: Response to Production Request No. 108 states that Section
"Historical Dollars vs Indexed Dollars" and Section"Historical Dollars vs Indexed Dollars-
Monthly Average" on Tab "Adder Source" of the confidential file "Aurora GN Market Prices
CONF" show that"[t]he average price difference as seen in the above referenced sections for
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 28, 2024

sales transactions show that the Company transacted at prices that were below market prices for
sales of its electricity." Please respond to the following:
a. The two sections contain both positive and negative values, meaning the Company
transacted at prices that were both above and below market prices for sales of its
electricity. Please explain why the Company believes that these two sections show
the Company transacted at prices that were below market prices for sales of its
electricity; and
b. Please explain why the price difference is due to unavailable buyers, instead of
inaccurate forecasts and provide evidence supporting the explanation.
REQUEST NO. 234: Please explain and reconcile the difference between the proposed
WRAP fee in 2024 ($1,354,358) and the forecasted WRAP fee in 2024 ($9,774,000) included in
Attachment IPUC 112.
REQUEST NO. 235: In reference to Response to Production Request No. 61(e)—
Confidential Attachment 61-5 for the Swift 1 Spillway Gate Bulkhead Project, the Contractor
requested the change order(CO-PRMT) for an increase of
Please
explain why
Also, please provide workpapers with the calculation of the increase and the basis used for the
increase.
REQUEST NO. 236: In reference to Response to Production Request No. 61(a) -
Confidential Attachment 61-1 for the Swift 1 Spillway Gate Bulkhead Project, please reconcile
the difference between the— budget shown in the Confidential Attachment 6 1-1 and
the $5,991,111 budget in Response to Production Request No. 55 —Attachment 55-1.
REQUEST NO. 237: Please answer the following in reference to the Swift 1 Spillway
Gate Bulkhead Project:
a. Please reconcile the difference between the— actual cost shown in
Response to Production Request No. 61(f)(i) and the total project cost of—
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 6 AUGUST 28, 2024

with Change Orders#6 from Response to Production Request No. 61 —Confidential
Attachment 61-5, and provide a cost breakdown by category(i.e. Internal Labor,
Contract Services, Capital Surcharge, AFUDC, etc.) of the APR(Appropriation
Request) budget and actual cost to explain the difference; and
b. Please reconcile the above costs with the$6,153,991 cost on Page 8.5.3, Exhibit No.
48 of McCoy's Testimony.
REQUEST NO. 238: For the Culter Relicensing Project, please reconcile the difference
between the� budget in Response to Production Request No. 64 and the $8,446,875
cost in Exhibit No. 48, Page 8.5.3, of McCoy's Testimony.
REQUEST NO. 239: In reference to the IKL-Fall Creek Hatchery Construction Project,
the total contract cost including change orders i as shown in Response to
Production Request No. 65(e)-vi—Confidential Attachment 65-9. Please explain and reconcile
that amount with the actual cost for Contract Services(including Removal,
Materials & Supplies, Contingency) as shown in Response to Production Request No. 65(f)—
Confidential Attachment 65-10. Please include workpapers with a detailed breakdown to explain
your answer.
REQUEST NO. 240: In reference to Response to Production Request No. 65(f) -
Confidential Attachment 65-10 for the IKL-Fall Creek Hatchery Construction Project, please
clarify whether there will be actual costs incurred after July 1, 2024.
DATED at Boise, Idaho, this 281h day of August 2024.
Adam Triplett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#12 Redacted.dom
TWELVTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 7 AUGUST 28, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS Z DAY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED TWELVTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-
E-24-04, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER CARLA SCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 825 NE Multnomah, Suite 2000
E-MAIL: mark.alder(a-)pacificorp.com Portland, OR 97232
E-MAIL: joseph.dallas Apacificorp.com
carla.scarsel la(&pacificorp.corn
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareg uest6cD paci ficorp.com
ERIC L OLSON LANCE KAUFMAN PhD
ECHO HAWK& OLSON PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance(a)ae isg insi hg t.com
E-MAIL: elo(o,echohawk.com
MATTHEW NYKIEL BRAD HEUSINKVELD
ID CONSERVATION LEAGUE ID CONSERVATION LEAGUE
710 N 6TH STREET 710 N 6TH STREET
BOISE ID 83702 BOISE ID 83702
E-MAIL: matthew.nykielAgmail.com E-MAIL:
heusinkveld(i,idahoconservation.org
THOMAS J BUDGE BRIAN C COLILINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER & ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD #140
E-MAIL: ti(i4acineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollins(d,consultbai.com
gmeyera,consultbai.com
Electronic Service Only: RONALD L WILLIAMS
KEVIN HIGGINS BRANDON HELGESON
NEAL TOWNSEND HAWLEY TROXELL ET AL
ENERGY STRATEGIES LLC 877 W MAIN ST
E-MAIL: khig ins ,energystrat.com BOISE ID 83701
ntownsendna,energystrat.com E-MAIL: rwilliamsAhawleytroxell.com
bhel eg sonAhawleZroxell.com
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITAFOS CONDA LLC
E-MAIL: brmullins(&mwanal ics.com E-MAIL: Val.steiner(iNtafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk(d,)byui.edu
PA ICIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE Page 2 of 2