20241016Staff 277-280 to PAC.pdf

RECEIVED
Wednesday, October 16, 2024 9:13:53 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 ) NINETEENTH 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 23, 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.
NINETEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 16, 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. 277: Please provide the Company's cost-assignment policy when a
customer requests a large load increase that requires a new or upgraded line extension at
transmission level voltages. The discussion should include the following issues:
a) Please explain the Company's policy for allocating the project costs between direct-
assigned to the customer and network-assigned to all ratepayers;
b) Please explain how line extension allowances are determined, how the Company
recovers revenue for those allowances, and how the Company accounts for the
additional new revenue from the customer;
c) Please explain if and how the above policies differ if the requesting customer is a
transmission and interconnection customer such as a municipal power agency; and
d) Please explain if and how the above policies differ if the load increase is caused by the
collective impact of small customer growth.
REQUEST NO. 278: Please provide the Company's cost-assignment policy when it
executes a generation interconnection request. Please explain how the Company allocates the
project cost between direct-assigned to the generator, and network-assigned to all ratepayers.
REQUEST NO. 279: Please provide the following information about the
"TJOR/2018/C/003 - C7 Data Centers Load Increase"project:
a) Please provide the initial Appropriation Request("APR") document and subsequent
changes;
b) Please provide the current project schedule, showing the major work breakdown
structure, the current progress, and the critical path for substantial completion;
c) Please explain how much of the project budget was allocated between direct-assigned
and network-assigned, and the Company's basis for that allocation;
NINETEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 16, 2024

d) Please explain if a line extension allowance was granted to the customer, and if so,
provide the worksheet calculations for that allowance; and
e) Please explain if the network-assigned costs will be offset by any corresponding
sources of revenue for the network ratepayers, and if so, please explain the method
used.
REQUEST NO. 280: Please provide the following information about the
"TIUT/2020/C/004 - Q0155 UAMPS Heber Light& Power"project:
a) Please provide the initial Appropriation Request ("APR") document and subsequent
changes;
b) Please explain how much of the project costs were allocated between direct-assigned
and network-assigned, and the Company's basis for that allocation; and
c) Please explain if the network-assigned costs will be offset by any corresponding
sources of revenue for the network ratepayers, and if so, please explain the method
used.
DATED at Boise, Idaho, this 161h day of October 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\PAC-E-24-04 PR#19.docx
NINETEENTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 16, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ODAY OF OCTOBER 2024,
SERVED THE FOREGOING NINETEENTH 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.alderkpacificorp.com Portland, OR 97232
E-MAIL: joseph.dallas@,pacificorp.com
carla.scarsella(c-)pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
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: lancega,aegisinsi hg t.com
E-MAIL: [e-mail]
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveldga 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: tjkracineolson.com CHESTERFIELD MO 63017
E-MAIL: [e-mail]
mg_eyer&consultbai.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(&energystrat.com BOISE ID 83701
ntownsendgenergystrat.com E-MAIL: rwilliamskhawleytroxell.com
bhel eg songhawleytroxell.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: brmullins@mwanal ics.com E-MAIL: [e-mail]
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: [e-mail]
PATRICIA JORDAT4, SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2