20240920Staff 257-260 to PAC (Redacted).pdf

FIFTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 20, 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
)
)
)
)
)
)
)
)
CASE NO. PAC-E-24-04
FIFTEENTH 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, OCTOBER 4, 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
2024 September 20
IDAHO PUBLIC
UTILITIES COMMISSION

FIFTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 20, 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. 257: In reference to Response to Production Request No. 189 and
Attachment 55-1 in Response to Production Request No. 55, the actual cost ($2.5 million) for the
U0 – Mill Blanket – 2023 project is over the $1.6 million project budget by $0.9 million. Please
explain the causes for the cost overage and provide any documents or evidence supporting them.

REQUEST NO. 258: In reference to Response to Production Request No. 190 for the
301 Generator Stator Rewind project, please provide the contract agreement with Siemens
including the scope of work, contract price, a breakdown of the price by the work breakdown
structure, and schedule.

REQUEST NO. 259: In reference to Response to Production Request No. 192 for the
U2 Stator Rewind CY 22-23 project,
Please explain whether the
Stator Repair Forced Outage Change Order is part of the U2 Stator Rewind project or if the
Change Order is for a different project, altogether. Please provide the details of this credit
including which project will be credited, the name and number of the project, the change order
number, and whether this project is one that has already been implemented, currently being
implemented, or for a future project.

REQUEST NO. 260: Please provide the confidential information that was redacted
from Response to Production Request No. 192. Additionally, please provide a breakdown of the
actual cost of the U2 Stator Rewind CY 22-23 project by the contract costs, internal labor,
AFUDC, etc.

FIFTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 20, 2024

DATED at Boise, Idaho, this 20th day of September 2024.

_________________________________
Adam Triplett
Deputy Attorney General

I:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR #15.docx

CERTIFICATE OF SERVICE Page 1 of 2
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF SEPTEMBER 2024,
SERVED THE FOREGOING FIFTEENTH 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]

JOE DALLAS
CARLA SCARSELLA
ROCKY MOUNTAIN POWER
825 NE Multnomah, Suite 2000
Portland, OR 97232
E-MAIL: [e-mail]
[e-mail]

DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]

ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 6119
POCATELLO ID 83205
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]

THOMAS J BUDGE
RACINE OLSON PLLP
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: [e-mail]

BRIAN C COLILINS
GREG MEYER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
[e-mail]

Electronic Service Only:
KEVIN HIGGINS
NEAL TOWNSEND
ENERGY STRATEGIES LLC
E-MAIL: [e-mail]
[e-mail]
RONALD L WILLIAMS
BRANDON HELGESON
HAWLEY TROXELL ET AL
877 W MAIN ST
BOISE ID 83701
E-MAIL: [e-mail]
[e-mail]

CERTIFICATE OF SERVICE Page 2 of 2
Electronic Service Only:

BRADLEY MULLINS
MW ANALYTICS
E-MAIL: [e-mail]
Electronic Service Only:

VAL STEINER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
Electronic Service Only:

KYLE WILLIAMS
BYU Idaho
E-MAIL: [e-mail]

KERI HAWKER, SECRETARY