20150618Staff 1-7 to PAC.pdf

NEIL PRICE : I',
DEPUTY ATTORNEY GENERAL ^fIDAHO PUBLIC UTILITIES COMMISSION ?lli J1-;; I ll fri{ li: ur
POBOX 83720 i .
B|lilil?flHo
83720-0074 ii.ri' 'r i.i- '' ' :"
ISB NO. 6864
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFTCORP DBA ROCKY MOUNTAIN ) CASE NO. PAC-E-15-09
POWER TO MODIFY THE ENERGY COST )
ADJUSTMENT MECHANISM AND INCREASE )
RATES By $10.2 MILLTON, OR ) FrRST PRODUCTION REQUEST
APPROXIMATELY 3.9 PERCENT. ) 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 THURSDAY, JULY 9,2015.
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 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 produced.
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY
MOUNTAIN POWER JUNE I8,2015
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 identiff the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide the actual net power costs for the 12 months ending
December 3I,2014 in similar format as witness Wilding's Exhibit No. 1.
REQUEST NO. 2: Using the actual net power costs derived above in Response to
Production Request No. 1, please show how this actual 2014 data is linked to Wilding's Exhibit
No. 2 and provide a new spreadsheet of Wilding's Exhibit No. 2 with the actual 2014 net power
costs.
REQUEST NO.3: Please provide monthly base and actual Production Tax Credit
amounts for both the System and Idaho Jurisdiction for the past three ECAM deferral periods.
REQUEST NO. 4: Please provide monthly base and actual DSM cost amounts for both
the System and Idaho Jurisdiction for the past three ECAM deferral periods.
REQUEST NO. 5: Please provide monthly base and actual loads measured at customer
meter for the system and Idaho Jurisdiction for past three ECAM deferral periods.
REQUEST NO. 6: Please provide monthly base and actual Qualifying Facility (QF)
costs included in NPC for both System and Idaho Jurisdiction for the past three ECAM deferral
periods.
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY
MOUNTAIN POWER JUNE I8,2015
REQUEST NO. z: Please provide an explanation and the analysis used to determine the
loads at customer meter for determining customer rates. Please reconcile this with loads used to
determine the proposed NPC of $1.514 million to be embedded in base rates. Please provide all
work papers with formulas intact.
DATED at Boise,Idaho, this I {O^rof June 2015.
Technical Staff: Joe Terryl I -2
Mike Louis/3-7
i :umisc:prodreq/pace I 5.9npjtml prod req I
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY
MOUNTAIN POWER 3
Deputy Attorney General
JUNE 18,2015
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY oF JUNE 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-15-09, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MAIN ST STE 23OO
SALT LAKE CITY UT 84111
E-MAIL: ted.weston@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
d atarequest@pacifi corp. com
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS ST
BOISE TD 83702
E-MAIL: [e-mail]
ELECTRONIC ONLY
JIM DUKE
IDAHOAN FOODS
E-MAIL: [e-mail]
YVONNE HOGLE
ROCKY MOI-INTAIN POWER
2OI S MAIN ST STE 23OO
SALT LAKE CITY UT 84I I1
E-MAIL: vvonne.hogel@nacifi corp.com
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
ELECTRONIC ONLY
VAL STEINER
AGRIUM US INCAIU-WEST INDUSTRIES
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE