20240814Staff 9-13 to PAC.pdf

RECEIVED
Wednesday, August 14, 2024 3:37:03 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 )
THIRD 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,AUGUST 28, 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.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 AUGUST 14, 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. 9: Please provide a schedule showing the full revenue requirement for
the Chehalis natural gas plant in 2022 and 2023. Please break out the costs by O&M,
depreciation, rate base, return on rate base, etc.
REQUEST NO. 10: Please explain if there are any statutory requirements that mandate
the use of CCA funds, general government fund, low-income assistance, etc.
REQUEST NO. 11: Please provide the amount of free allowances the Company
received for the CCA. Please include how those amounts were calculated.
REQUEST NO. 12: Please provide a schedule showing the compliance cost the
Company has incurred to comply with CETA in each of the following years 2021, 2022, 2023,
and 2024.
REQUEST NO. 13: Please provide a schedule showing the EIM dispatch price for 2023
for the Company's Eastern BAA.
DATED at Boise, Idaho, this 14'b day of August 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-05 PR#3.docx
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST 14, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10 DAY OF AUGUST 2024,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-24-
05, 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: mark.aldergpacificorp.com PORTLAND OR 97232
E-MAIL: joseph.dallas(cr�,pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@,pacificorp.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(kconsultbai.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: brmullinsnmwanal ics.com
E-MAIL: rwilliams(cr�,hawleytroxell.com
bhel eson ,hawleytroxell.com
Electronic Service Only: Electronic Service Only:
VAL STEINER KYLE WILLIAMS
ITAFOS CONDA LLC BYU Idaho
E-MAIL: Val.steinergitafos.com E-MAIL: williamskkb u
:1-1 -x �Imo/,
PA RICIA JORDAN, S RETARY
CERTIFICATE OF SERVICE