20250225Staff 1-11 to PAC.pdf

RECEIVED
Tuesday, February 25, 2025 10:05:40 AM
IDAHO PUBLIC
UTILITIES COMMISSION
CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9810
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-25-01
APPROVAL OF THE DECOMMISSIONING )
AND SALE OF THE PARIS )
HYDROELECTRIC PROJECT ) REDACTED FIRST
GENERATING FACILITIES ) PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Chris Burdin, Deputy Attorney General, requests that Rocky Mountain Power, a division of
PacifiCorp ("Company")provide the following documents and information as soon as possible,
but no later than TUESDAY, MARCH 18, 2025.
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
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 FEBRUARY 25, 2025

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. 1: Please provide the proposed accounting treatment for the cost of the
decommissioning of the Paris Hydroelectric Project.
REQUEST NO. 2: Please provide the proposed accounting treatment for the sale and
donation of the Paris Hydroelectric property.
REQUEST NO. 3: In Paragraph 20 of the Application, the Company states that the
extra water, as a result of the reduced bypassed reach, will increase generation at the Grace
Development through 2033. Please verify whether the Grace Development facility can be
designed to cover the additional water flow and generation.
REQUEST NO. 4: In the Application, the Company stated that the total cost of
decommissioning the Paris Project is approximately $1.6 million. However, by reviewing
the confidential workpaper with the financial analysis, the cost was estimated in 2020, and it
will be forecasted to■ million with cumulative inflation rate in 2024. Please clarify how
much the currently estimated decommissioning cost is.
REQUEST NO. 5: In the confidential workpaper, the Company assumed that the
generation of the Paris project will be reduced to
Please provide the basis and source of information verifying that the assumption is
reasonable.
REQUEST NO. 6: In the specific details of the Paris project decommissioning and
reclamation, please explain why the employee house will be demolished and the associated
freestanding garage will remain and be sold.
REQUEST NO. 7: Please provide an updated financial analysis in Excel format for the
two options, (1) Continuing Operation of the Paris Project and(2) decommissioning and
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 FEBRUARY 25, 2025

reduce minimum instream flow at Grace, including updated decommissioning date, inflation
forecast, discount rate, etc.
REQUEST NO. 8: Please provide a list of all assets, including land and improvements,
by ID,year in service, installed valuation, and current book value.
REQUEST NO.9: Please provide the status for the FERC conduit exemption order.
REQUEST NO. 10: Please provide the status for the amended FERC license to reduce
the minimum instream flow at the Grace development.
REQUEST NO. 11: The"Summary" tab of the Confidential Workpapers shows the
recommended solution Please explain how the
recommendation was considered in the Company's Application to decommission the Paris
Project.
DATED at Boise, Idaho, this 25`h day of February 2025.
b�,Ik��4-
Chris Burdin
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\PAC-E-25-01 PR#1-Redacted.doex
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 FEBRUARY 25, 2025

CERTIFICATE OF SERVICE
�4
I HEREBY CERTIFY THAT I HAVE THIS DAY OF FEBRUARY 2025,
SERVED THE FOREGOING REDACTED FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-
E-25-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
IDAHO REGULATORY AFFAIRS MGR. E-MAIL ONLY:
ROCKY MOUNTAIN POWER datareyuest(a�pacificorp.com
1407 WEST NORTH TEMPLE, STE 330
SALT LAKE CITY, UT 84116
E-MAIL: mark.alder(a�pacificorp.com
JOE DALLAS
ATTORNEY
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH, STE 2000
PORTLAND, OR 97232
EMAIL: ioseph.dallasApacificorp.com
PATRICIA
CERTIFICATE OF SERVICE