20241018Staff 281-286 to PAC.pdf

RECEIVED
Friday, October 18, 2024 11.30.39 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 ) TWENTIETH 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 FRIDAY, OCTOBER 25, 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.
TWENTHIETH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 18, 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. 281: Please provide the Company's most recent sales and load forecast
for the 12-month periods ending December 31, 2024 and December 31, 2025. Please include the
forecasts by total Company and by customer class in each state.
REQUEST NO. 282: In reference to Meredith's Workpaper labeled "ID GRC Blocking
2024" and the tab labeled"Comparison". Please provide similar data contained in this tab for
the years 2020-2021.
REQUEST NO. 283: In reference to Meredith's Workpaper labeled"ID GRC Blocking
2024" and the tabs labeled"Table 1 Rev", "Table 1 MWh", "Table 2", and"Table 3". Please
provide similar data contained in these tabs for the years 2020-2022.
REQUEST NO. 284: In reference to Meredith's Workpaper labeled"ID GRC
Blocking 2024" and the tabs labeled"Table 1 Rev", "Table 1 MWh", "Table 2", and"Table 3".
Please provide similar data for the most recent 12-month period in 2024 that is available. Please
treat this as an ongoing request as amounts are quantified at the end of each month.
REQUEST NO. 285: In reference to Meredith's Workpaper labeled"ID GRC
Blocking 2024" and the tabs labeled"Table 1 Rev", "Table 1 MWh", "Table 2", and"Table 3".
Please provide similar data for January 2024 through September 2024 or the most recent month
in 2024 that is available. Please treat this as an ongoing request as amounts are quantified at the
end of each month.
REQUEST NO. 286: In reference to the Company's response to Staff Production
Request No. 253 and Attachment IPUC 253,please provide the same information by class and
month for the years 2020-2023.
TWENTHIETH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 OCTOBER 18, 2024

DATED at Boise, Idaho, this 18th day of October 2024.
(-�' & /— �zAk
Adam Triplett
Deputy Attorney General
I:AUtility\UMISC\PRDREQ\PAC-E-24-04 PR#20.docx
TWENTHIETH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 OCTOBER 18, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS _A DAY OF OCTOBER 2024,
SERVED THE FOREGOING TWENTIETH 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.dallaskpacificorp.com
carla.scarsellakpacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequestkl2aci ficorp.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(kae isg insi hg t.com
E-MAIL: elogechohawk.com
BRAD HEUSINKVELD
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL:
heusinkveldnidahoconservation.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: ti(a,racineolson.com CHESTERFIELD MO 63017
E-MAIL: bcollinskeonsultbai.com
gmeyer(k 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: khigginsnenergystrat.com BOISE ID 83701
ntownsendgenergystrat.com E-MAIL: rwilliamskhawleytroxell.com
bhel eg sonkhawley1roxell.com
CERTIFICATE OF SERVICE Page 1 of 2

Electronic Service Only: Electronic Service Only:
BRADLEY MULLINS VAL STEINER
MW ANALYTICS ITArFOS CONDA LLC
E-MAIL: bnnullinsAmwanalytics.com E-MAIL: Val.steiner(kitafos.com
Electronic Service Only:
KYLE WILLIAMS
BYU Idaho
E-MAIL: williamsk(a�b u
109
PATRICIA JORDA , SECRETARY
CERTIFICATE OF SERVICE Page 2 of 2