20240906Staff 250-256 to PAC.pdf

FOURTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 6, 2024
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
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND APPROVAL
OF PROPOSED ELECTRIC SERVICE
SCHEDULES AND REGULATIONS
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CASE NO. PAC-E-24-04

FOURTEENTH 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 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 FRIDAY, SEPTEMBER 20, 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 [phone].
RECEIVED
Friday, September 6, 2024 12:50:53 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FOURTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 6, 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. 250: In support of a virtual meeting on August 27, 2024, between Staff
and the Company, the Company provided a worksheet of transmission plant additions titled
“2022 through June 2024 plant additions – projects > $5million.” Six of the projects were
generation interconnection projects associated with “EV2024.” Identifying information for the
six projects is listed in the table below:
Project Name / Title Project Definition
TMP EV2024 Q0835 Rock Creek Wind
LLC–Rock Crk Wind I
TIWY/2021/C/003
TMP EV2024 Q0713 Cedar Springs IV Wind TIWY/2021/C/004
TMP EV2024 Q0836 Rock Creek Wind II TIWY/2022/C/003
TMP EV2024 Q0409 Boswell Springs Wind TIWY/2022/C/004
TMP EV2024 Q0785 Anticline Wind TIWY/2022/C/008
TMP EV2024 Q0719 Two Rivers Wind TIWY/2022/C/012
Please provide the following information for each of these six projects:
a. Please provide the current estimated in-service date;
b. Please provide a copy of the most current project schedule (Gantt chart) showing the
duration and dependencies of the major work elements, the critical path, and the in-
service date;
c. Please identify the corresponding new resource (and its Project Definition number)
that is being supported by each of these interconnection projects; and
d. Please provide the current estimated completion date for each of the new resources
identified in part (c).

FOURTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 6, 2024
REQUEST NO. 251: During the virtual meeting on August 26, 2024, between Staff and
the Company, the following three new-revenue transmission projects were discussed:
Project Name / Title Project Definition
Customer 8 - UT - Trans (1) TJOR/2021/C/006
Customer 22 - UT - Trans DMET/2022/C/015
Customer 27 - UT - Trans DAME/2022/C/002

Please provide the following information for each of these three projects:
a. Please provide workpapers that determined which elements of work and associated
costs were direct assigned to the customer requesting service and which elements and
associated costs were classified as network upgrades;
b. Please provide accounting documentation that shows how the anticipated plant-in-
service amount correlates to the network upgrade work;
c. Please provide the current estimated in-service date; and
d. Please provide a copy of the most current project schedule (Gantt chart) showing the
duration and dependencies of the major work elements, the critical path, and the in-
service date.
REQUEST NO. 252: During the virtual meeting on August 26, 2024, between Staff and
the Company, the following project was discussed:
Project Name / Title Project Definition
Project Specialized TPEN/2021/C/001

Please provide the following information for this project:
a. Please explain how the budgeted cost for this project changed from $72.7 million in
June (McCoy’s Exhibit 48, Page 8.5.3 Major Plant Detail) to $38.9 million in August
(worksheet provided by Mr. Alder for the subject virtual meeting);
b. Please confirm the Company’s assertion in the virtual meeting that this amount
represents the line extension allowance determined by Oregon policy (because the

FOURTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 6, 2024
line extension supplies an Oregon customer). If confirmed, please provide the
Company’s worksheets that calculate this amount in accordance with the policy;
c. If not confirmed, please explain the Company’s basis for determining the amount that
it assigned to the network upgrades, and provide worksheets showing these
calculations;
d. Please provide the current estimated in-service date; and
e. Please provide a copy of the most current project schedule (Gantt chart) showing the
duration and dependencies of the major work elements, the critical path, and the in-
service date.

REQUEST NO. 253: Please provide known and measurable changes (actuals) to
revenue, by customer class and schedule (as shown in Company Exhibit No. 48), that occurred
from January 2024 through July 2024 to include but not limited to the following:
i. Change in the number of actual customers in 2024 using 2023 weather normalized
consumption per customer;
ii. Wheeling revenue;
iii. Fly Ash revenue; and
iv. REC revenue
Please provide workpapers with all formulas intact showing the calculations. Please treat
this as an ongoing request as actual amounts are quantified at the end of each month.

REQUEST NO. 254: Please provide an updated Company Exhibit No. 60 using updated
billing determinants from proforma changes in the number of actual customers (from the above
request) that occurred from January 2024 through July 2024 using 2023 weather normalized
consumption per customer. Please provide all workpapers with all formula intact showing the
calculations. Please treat this as an ongoing request as actual amounts are quantified at the end
of each month.

REQUEST NO. 255: Please reconcile Cell I96 on Tab “IPUC 145 Support” of File
“Attach IPUC 145 CONF. xlsx” and Cell AL 95 on Tab 3.5.1. of File “3.5-Wheeling
Revenue.xlsx” proposed in the Application.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l9�Y OF SEPTEMBER 2024, SERVED THE FOREGOING FOURTEENTH 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
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DA TA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
ERIC L OLSEN
ECHO HA WK & OLSEN PLLC
PO BOX 6119
POCA TELLO ID 83205
E-MAIL: [e-mail]
THOMASJ BUDGE
RACINE OLSON PLLP
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: [e-mail]
Electronic Service Only:
KEVIN HIGGINS
NEAL TOWNSEND
ENERGY STRATEGIES LLC
E-MAIL: [e-mail]
[e-mail]
JOE DALLAS
CARLA SCARSELLA
ROCKY MOUNTAIN POWER
825 NE Multnomah, Suite 2000
Portland, OR 97232
E-MAIL: [e-mail]
[e-mail]
LANCE KAUFMAN PhD
2623 NW BLUEBELL PLACE
CORVALLIS OR 97330
E-MAIL: [e-mail]
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
[e-mail]
BRIAN C COLILINS
GREG MEYER
BRUBAKER & AS SOCIA TES
16690 SWINGLEY RIDGE RD #140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
BRANDON HELGESON
HAWLEY TROXELL ET AL
877 WMAIN ST
BOISE ID 83701
E-MAIL: [e-mail]
[e-mail]
CERTIFICATE OF SERVICE Page 1 of 2