20240924Staff 261-267 to PAC.pdf

RECEIVED
Tuesday, September 24, 2024 10:24:53 AM
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 SIXTEENTH
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 TUESDAY, OCTOBER 8, 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.
SIXTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 24, 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. 261: Referencing the Company's response to Production Request No.
130,please provide the documents describing the reasons for the Little Snake Shoo-Fly change
order and the resolution of the change order.
REQUEST NO. 262: Following up on Production Request Nos. 167 and 168,please
provide the actual coal inventory in dollars and tons as well as the tons of coal needed for 30-,
45-, 60- and 75-day supply for the following plants:
a. Naughton
b. Wyodak
c. Colstrip
d. Hayden
REQUEST NO. 263: Please provide the capacity factor for each coal plant used in the
Company's net power costs in this case.
REQUEST NO. 264: In calculating wheeling revenues, the Company has provided
inconsistent information as shown below. Please identify which set of information is the correct
version and why it is correct.
SIXTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 24, 2024

Attach IPUC
Proposed in Attach IPUC 145 1st
McCoy's 145 REVISED
Workpaper CONF.xlsx CONF.xlsx
Line "Total"
Line "Incremental Adjustments"
Line"Accum Totals"
How Incremental Adjustments Are Calculated
Remove Refunds and Other
Out-of-Period Adjustments*
Annualized Charges
Proforma Adjustments
Incremental Adjustments
REQUEST NO. 265: Please re-run the Aurora model and provide updated workpaper
"ID—GRC-2025-2023 Normalized Load.xlsm" and updated McCoy's workpaper"5.1 —
NPC.xlsx"to reflect the result of the scenario below:
• Use the OFPC dated on June 28, 2024, from Response to Production
Request No. 107 in the Aurora model;
• Remove the CCA allowance cost from the dispatch cost of the Chehalis
Scenario plant in the Aurora model;
• Remove the post-modeling CCA costs, which were calculated based
on the multiplication of Chehalis's generation amounts and the CCA
allowance cost; and
• Use 101% of market prices to value Emergency Purchases
SIXTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 24, 2024

REQUEST NO. 266: As a follow up to Response to Production Request No. 212
Attachments 212-2, 212-3, and 212-4, please explain if the Company made payment before or
after delivery of each item. If before, please provide the delivery date of each item.
REQUEST NO. 267: Please provide the Company's vehicle replacement policy.
DATED at Boise, Idaho, this 24th day of September 2024.
Adam plett
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#16.doex
SIXTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 SEPTEMBER 24, 2024

CERTIFICATE OF SERVICE
i
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF SEPTEMBER 2024,
SERVED THE FOREGOING REDACTED SIXTEENTH PRODUCTION REQUEST
OF THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-24-04, BY &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.aldergpacificorp.com Portland, OR 97232
E-MAIL: joseph.dallasa,pacificorp.com
carla.scars ellanpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestgpacifi core.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: lancegae isg insight.com
E-MAIL: elogechohawk.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveldgidahoconservatio n.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: tj ,racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollins(cr�,consultbai.com
g_mee r(k consultb ai.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: khiggins(a-,energ_ystrat.com BOISE ID 83701
ntownsend(kenergystrat.com E-MAIL: [e-mail]
bhel eg [e-mail]
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,mwanalytics.com E-MAIL: Val.steinerkitafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: wi1hamskgb u
PATRICIA JORDAN ECRETARY
CERTIFICATE OF SERVICE Page 2 of 2