20160923Staff 1-5 to PAC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO.
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RECE IVED
t01SS~P 23 PH 1:29
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER TO UPDATE BASE NET POWER )
COSTS AND IMPLEMENT A RA TE ST ABILITY )
PLAN. )
) ___________________ )
CASE NO. PAC-E-16-12
FIRST 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,
Camille Christen, 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 FRIDAY, OCTOBER 14, 2016.
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
TO ROCKY MOUNTAIN POWER SEPTEMBER 23 , 2016
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.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide all workpapers identifying any incremental changes
to the Commission approved depreciation deferral throughout the period of the proposed "Rate
Stability Plan." Please provide work papers in Excel format with formulae intact.
REQUEST NO. 2: Please provide all workpapers used to develop, estimate, and support
the Company's proposed "Rate Stability Plan." Please provide work papers in Excel format with
formulae intact.
REQUEST NO. 3: Please provide all workpapers supporting the Company estimate of
the ECAM reduction on June 1, 2017 of$4.5 to $5.5 million. Please provide work papers in
Excel format with formulae intact.
REQUEST NO. 4: Please provide a projection of the 2018 ECAM deferral (January
2017 through December 2017) if the Company has completed an estimate. Please provide work
papers in Excel format with formulae intact.
REQUEST NO. 5: Please provide a schedule showing the depreciation deferral from its
inception to present by year. Please split out the balances of the different asset categories as
defined by the depreciation study.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 23, 2016
. .rb
DATED at Boise, Idaho, this 1 '!J day of September 2016.
Technical Staff: Rick Keller ( 1-4)
Joe Terry (5)
i:umisc:prodreq/pace 16.12ccrkmrjttcdkprod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3
Camille Christen
Deputy Attorney General
SEPTEMBER 23, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23rct DAY OF SEPTEMBER 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-16-12, 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]
DA TA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
ELECTRONIC ONLY
VAL STEINER
AGRIUM US INC/NU-WEST
INDUSTRIES
E-MAIL: [e-mail]
RANDALL C BUDGE
RACINE OLSON NYE BUDGE
&BAILEY
PO BOX 1391
POCATELLO ID 83204
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
ANTHONY Y ANKEL
12700 BLAKE A VE
UNIT 2505
LAKEWOOD OH 44107
DANIELE SOLANDER
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1015 W HAYS ST
BOISE ID 83702
ELECTRONIC ONLY
JIM DUKE
IDAHOAN FOODS
E-MAIL: [e-mail]
BRUBAKER & AS SOCIA TES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
ERIC L OLSEN
ECOH HA WK & OLSEN
PO BOX 6119
POCATELLO ID 83205
~@JD SC ARY
CERTIFICATE OF SERVICE