20160930Staff 6 to PAC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 3 34-0314
IDAHO BAR NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
RE CE IVED
2016 SEP 30 PH 2: 12 ,
if .~ 1 _. ~ua uc
· · .-· , e; '· 1r' ilSSI01 l , I . 1.,..,.11 If:
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 RATE STABILITY )
PLAN. )
) __________________ )
CASE NO. PAC-E-16-12
SECOND PRODUCTION
REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission requests that Rocky Mountain Power
(Company) provide the following documents and information as soon as possible, and no later
than FRIDAY, OCTOBER 21, 2016.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. 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 IDAP A
31.01.01.228.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 30, 2016
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 6: The Company provided CONFIDENTIAL workpapers supporting
the normalized Net Power Cost (NPC) for the 2015 Results of Operation (ROO) relative to
Exhibit 1 of Mr. Wilding's testimony. Please provide this equivalent information for the year
2014. Please provide work papers in Excel format with formulae intact.
f""'""
DATED at Boise, Idaho, this Jo day of September 2016.
Technical Staff: Rick Keller (6)
i:umisc:prodreq/pace I 6.12ccrkmrjttcdkprod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2
Camille Christen
Deputy Attorney General
SEPTEMBER 30, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 301h DAY OF SEPTEMBER 2016,
SERVED THE FOREGOING SECOND 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]
DAT A 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
POCA TELLO ID 83204
ELECTRONIC ONLY
JAMES R SMITH
MONSANTO COMPANY
E-MAIL: [e-mail]
ANTHONY Y ANKEL
12700 BLAKE AVE
UNIT 2505
LAKEWOOD OH 44107
DANIEL E 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 & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
ERIC L OLSEN
ECOH HA WK & OLSEN
PO BOX 6119
POCATELLO ID 83205
CERTIFICATE OF SERVICE
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