20240829Staff 241-249 to PAC (Redacted).pdf

RECEIVED
Thursday, August 29, 2024 3:41:30 PM
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 THIRTEENTH
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 THURSDAY, SEPTEMBER 12, 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.
THIRTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 29, 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. 241: In reference to the Company's response to Staff Production
Request No. 82 and Attachment IPUC 82-1, please provide an update to Attachment IPUC 82-1
using 20 years of daily heating degree day ("HDD") and cooling degree day("CDD")
information from years 2004 through 2023 in a similar format as Attachment IPUC 82-1. Also,
please respond to the following:
a. Please explain how the date range for daily HDD and CDD were determined for
Attachment IPUC 82-1; and
b. Please explain why Attachment IPUC 82-1 does not include the years 2022 and 2023
in the calculation.
REQUEST NO. 242: In reference to the Company's response to Staff Production
Request No. 82 and Confidential Attachment IPUC 82-2, please provide an update to
Confidential Attachment IPUC 82-2 using input data from 1/1/2017 through 12/31/23 in a
similar format as Confidential Attachment IPUC 82-2. Also, please respond to the following:
a. Please explain how the date range for the input data was determined for Confidential
Attachment IPUC 82-2;
b. Please explain why Confidential Attachment IPUC 82-2 does not include the years
2021, 2022, and 2023 in the model;
c. Please explain why variables that are not statistically significant(P-values greater
than .05%)were included in the weather spline models;
d. Please explain why autoregressive terms are required in the weather spline models;
and
e. Please provide weather spline models and model output using input data from
1/1/2017 through 12/31/23 in a similar format as Confidential Attachment IPUC 82-2
using only statistically significant(P-values greater than .05%) variables and no
autoregressive terms.
THIRTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 29, 2024

REQUEST NO. 243: In reference to the Company's response to Staff Production
Request No. 82 and Attachment IPUC 82-3, please provide the models used to determine the
coefficients used to calculate the class level weather adjustments in Attachment IPUC 82-3. For
example, the residential calculation used coefficients of.474035693 for the XHeat and
.463221166 XCool variables. Also, please respond to the following:
a. Please explain how the date range for the input data was determined for this model;
b. If variables included in these models include variables that are not statistically
significant(P-values greater than .05%),please explain why the variables were
included in the models;
c. If autoregressive terms are used in the models, please explain why autoregressive
terms were necessary;
d. Please provide linear regression models and model output using the most recent 20
years (2004-2023) for input data, only statistically significant(P-values greater than
.05%) variables, and no autoregressive terms; and
e. Please provide an update to Attachment IPUC 82-3 using the updated data provided
in Production Request No(s) 241 and 242 in a similar format as Attachment IPUC 82-
3.
REQUEST NO. 244: In reference to the Company's response to Staff Production
Request No. 82 and Attachment IPUC 82-3, please provide the workpapers showing the
calculation for the 2023 actual HDD_PerDay and CDD_PerDay values found on the "Splines"
tab of Attachment IPUC 82-3.
REQUEST NO. 245: In reference to the Company's response to Staff Production
Request No. 82 and Attachment IPUC 82-4, please provide an update to Attachment IPUC 82-4
using the updated Attachment IPUC 82-3 provided in response to Production Request No. 243
part e.
THIRTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST 29, 2024

REQUEST NO. 246: If any proceeds from insurance claims were received for any
damages or repairs that involved capitalized plant or initiated additional capital expenditures,
please provide the associated capital project and accounting treatment.
REQUEST NO. 247: In reference to response to Production Request No. 58(e)-ii and
59(e)-ii Confidential Files -U1/U2 project budget by WBS CONF for the Unit 1 and Unit 2
conversion to Natural Gas project, please reconcile and explain the three total cost amounts from
the Application, and the Budget, and Actuals from Production Request No. 58 and 59, as shown
in the table below.
Application Budget(From Response to PR No. 58 and 59) Actual
(From (From
McCoy's
APR1 003 0 1 1 0/APR10030111 APR90001601/ARP90001602 Response to
Total
Testimony)
APR10030053/APR10030054 APR90001716/APR90001717 PR No. 58
and 59)
17,307,777 -
17,267,132 -
34,574,909 -
REQUEST NO. 248: In reference to response to Production Request No. 58(e) -
Confidential Attachment IPUC 58 1st Supplemental for the UI/U2 Conversion to Natural Gas
Project, please explain the— Change Order Increase with , given that
the initial contract cost was only
REQUEST NO. 249: In reference to response to Production Request No. 58—
Confidential Attachments for the U1/U2 Conversion to Natural Gas Project,please explain the
reason for the difference between the Unit I— project budget by WBS in the excel file
and the— budget shown on page 4 of the APR#90001601 Project Proposal.
THIRTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST 29, 2024

DATED at Boise, Idaho, this 29th day of August 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#13 Redacted.docx
THIRTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST 29, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I DAY OF AUGUST 2024,
SERVED THE FOREGOING REDACTED THIRTEENTH 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.alderapacificorp.com Portland, OR 97232
E-MAIL: joseph.dallasapacificorp.com
carla.scarsellaamacificorp.corn
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest(a`)pacificorp.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK & OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL: lance ,ae isg insi t.com
E-MAIL: eloaechohawk.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveld(a,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: tjaa,racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollins(a),consultbai.com
gmm eyer@,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: khigginsaenergystrat.com BOISE ID 83701
ntownsenda,energystrat.com E-MAIL: rwilliamsahawleytroxell.com
bhel e� son(&hawleytroxell.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(a mwanal ics.com E-MAIL: Val.steiner a itafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk(a-byui.edu
k
jt�
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2