20241009Staff 275-276 to PAC.pdf

RECEIVED
Wednesday, October 9, 2024 10.28.25 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 ) EIGHTEENTH PRODUCTION
OF PROPOSED ELECTRIC SERVICE ) REQUEST OF THE
SCHEDULES AND REGULATIONS ) 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 WEDNESDAY, OCTOBER 16, 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.
EIGHTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 9, 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. 275: In its response to Staff Production Request No. 130, the Company
provided schedules for several sub-projects that collectively comprise the Gateway South
("GWS")project. For example, the Company submitted separate schedules for transmission line
segments titled"Element A", "Element B", and"Element C." The Company also submitted
schedules for the substations (named"A1"through "A5")that connect the transmission
elements. Please provide the following information about these sub-projects:
a) Please provide a map that depicts all these sub-projects in relation to the entire GWS
project; and
b) Please elaborate on the interdependencies between each sub-project and the
usefulness of the entire GWS project. For example,please clarify if Substation A3
must be substantially complete to enable the transmission of power from Aeolus to
Mona, or if the substation is only necessary to take-off power to other portions of the
grid.
REQUEST NO. 276: In its response to Staff Production Request No. 131, the Company
provided information about seven smaller projects that it collectively calls the Gateway South
Supporting Projects. Please provide the following information about this group of projects:
a) The sub-allocation of the project budget for each of the seven smaller projects;
b) The budgeted amounts for each of the shunt capacitor projects bundled into the
first support project (i.e. Riverton, Mustang, Bonanza); and
c) The current estimated in-service date for each project or major sub-project.
EIGHTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 9, 2024

DATED at Boise, Idaho, this 91h day of October 2024.
Adam Triplett
Deputy Attorney Gener
:7
L•\Utility\UM1SC\PRDREQ\PAC-E-24-04 PR#18.docx
EIGHTEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 9, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 91h DAY OF OCTOBER 2024,
SERVED THE FOREGOING EIGHTEENTH 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.alder(c.,,pacificorp.com Portland, OR 97232
E-MAIL: joseph.dallas&pacificom.com
carla.scarsellakpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestgpacificorp.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(cr�,ae isg insi ht.com
E-MAIL: elogechohawk.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveld(.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: tj(kracineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollinsgconsultbai.com
gm eyerkconsultbai.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: khig inskenergystrat.com BOISE ID 83701
ntownsendkenergystrat.com E-MAIL: rwilliams(khawleytroxell.com
bhel eg son(khawleytroxell.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: [e-mail] E-MAIL: [e-mail]
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk ct,b. u
PATRICIA JORDAN, S CRETARY
CERTIFICATE OF SERVICE Page 2 of 2