20240828Staff No. 14 to PAC.pdf

RECEIVED
Wednesday, August 28, 2024 4:24:11 PM
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 ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL ) CASE NO. PAC-E-24-05
OF $62.4 MILLION ECAM DEFERRAL )
FOURTH 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 PacifiCorp dba Rocky Mountain Power
("Company")provide the following documents and information as soon as possible, but no later
than WEDNESDAY, SEPTEMBER 4, 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.
FOURTH 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. 14: In the Company's response to the Interlocutory Order No 36274,
the Company states that the CCA cost of allowances are included in the dispatch of Chehalis.
Using the Chehalis fuel costs from Witness Painter's testimony, the Company's fuel cost per
megawatt hour("MWh") for Chehalis is reasonably close to the energy bid price for Chehalis
supplied in response to Audit Request No. 16. This is without the CCA allowance costs which
were recorded in Account 555. After adding in the CCA allowance costs, the energy dispatch
price is always below the fuel cost and CCA allowance costs on a per MWh basis. This is shown
in Staff s Confidential Attachment No. PR14. Please explain how the Company's bid price
would be below the costs of the fuel plus CCA allowance costs, if cost of allowances are
included as an adder to the Company's Energy bid.
DATED at Boise, Idaho, this 281h day of August 2024.
Adam Tnplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-05 PR#4.docx
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 28, 2024

CERTIFICATE OF SERVICE
H
I HEREBY CERTIFY THAT I HAVE THIS DAY OF AUGUST 2024,
SERVED THE FOREGOING FOURTH 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.alderkpacificorp.com PORTLAND OR 97232
E-MAIL: josoh.dallasgpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestgpacificorp.com
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: tjgracineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollinsgconsultbai.com
gmeyer!k consultbai.com
RONALD L WILLIAMS BRADLEY MULLINS
BRANDON HELGESON MW ANALYTICS
HAWLEY TROXELL ET AL TEITOTIE 2, SUITE 208
877 W MAIN ST OULUNSALO FINLAND, FI-90460
BOISE ID 83701 E-MAIL: brmullinsgmwanalytics.com
E-MAIL: rwilliamsghawleytroxell.com
bhel eg songhawleytroxell.com
Electronic Service Only: Electronic Service Only:
VAL STEINER KYLE WILLIAMS
ITAFOS CONDA LLC BYU Idaho
E-MAIL: Val.steinergitafos.com E-MAIL: williamsk b i.edu
PAT CIA JORDAN, SE RETARY
CERTIFICATE OF SERVICE