20150210Staff 23-25 to PAC .pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
ISB NO. 6864
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR APPROVAL
OF THE TRANSACTION TO CLOSE THE DEER
CREEK MINE AND FOR A DEFERRED
ACCOUNTING ORDER.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-14.10
THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Neil Price, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power,
(Company; Rocky Mountain) provide the following documents and information as soon as
possible, but no later than TUESDAY, MARCH 3,2015.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name,
location and phone number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain
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 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
THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP I FEBRUARY 1O,2OI5
the person preparing the documents. Please
number of the record holder.
the name, job title, location and telephone
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.23: Please provide an electronic copy, with formulas intact, of
Confidential Exhibit No. 7.
REQUEST NO. 24: Please provide documentation that supports and from which is
derived, the dollar amounts in Confidential Exhibit No. 7 and the Company's Application and
testimony. Please include within your response copies of the source documentation and
explanatory notes.
REQUEST NO. 25: Please provide a list of any and all services along with a description
of the service that Energy West will continue to provide PacifiCorp should the transaction be
completed. If no services will be provided, please explain any ongoing affiliated relationships.
DATED at Boise, Idaho, this Dlt"y of February 2015.
Neil Price
Deputy Attorney General
Technical Staff: Patricia Harms (23-24)
Joe Terry (25)
i : umisc :prodreq/pace I 4. I 0npmlphjtde prod req3
THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO PACIFICORP 2 FEBRUARY 1O,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IO.h DAY OF FEBRUARY 2015,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF' THE
CoMMISSION STAFF, IN CASE NO. PAC-E-14-10, BY E-MAILING A COPY
THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
TED WESTON DANIEL E SOLANDER
ID REGULATORY AFFAIRS MANAGER SENIOR COUNSEL
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareqqest@nacifi corp. com
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
RICHARD R HALL
STOEL RIVES LLP
SUITE 19OO
101 S CAPITOL BLVD.
BOISE TD 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE