20160210Staff 1-2 to PAC.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 5156
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP DBA )
ROCKY MOUNTATN POWER',S APPLICATION ) CASE NO. PAC-E-16-05
FOR APPROVAL OF rrs $16.7 MTLLTON )
DEFERRAL OF NET POWER COSTS, AND ) nlRSr pRODUCTION
AUTHORITY TO DECREASE RATES BY $9.0 ) nBeuEST OF THE
MILLION.) cOTUMISSION STAFF TO
) ROCKY MOUNTAIN POWER
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that PacifiCorp dba Rocky Mountain Power
(Company; Rocky Mountain) provide the following documents and information by
WEDNESDAY, FEBRUARY 24, 2016.1
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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER FEBRUARY 10,2016
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: In Workpaper Exhibit 1 on the tab titled *2013 Base NPC_PAC-E-
ll-12 DC," the average cost per megawatt hour for the Georgia-Pacific Camas long term
purchase was $78.76. For this ECAM period the average cost per megawatt hour was $97.59.
Please provide a copy of the contract and explain this increase.
REQUEST NO. 2: In Workpaper Exhibit I on the tab titled *2013 Base NPC_PAC-E-
11-12 DC," the average cost per megawatt hour for the Tri-State Purchase long term purchase
was $66.85. For this ECAM period the average cost per megawatt hour was $82.47. Please
provide a copy of the contract and explain this increase.
DATED at Boise, Idaho, thi, lOyday of Febru ary 2016.
Technical Staff: Joe Terry/Mike Louis/l-2
i:umisc:prodreq/pacel6.5kkjtml prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER
Deputy Attorney General
FEBRUARY 10, 2OI6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1OTH DAY OF FEBRUARY 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E.16-05, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi com. com
WONNE HOGLE
ASSISTANT GENERAL COUNSEL
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE