20161028Staff 7 to PAC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
/\ECE IVED
Z0 /6 OCT 28 PM 2: I 9
i·' '' -. ' ' -. -, . ::.> . _ · _ -' r<J 8 Li C 11 i: :; COM;HSS /ON
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 STABILITY )
PLAN. )
) ___________________ )
CASE NO. PAC-E-16-12
THIRD 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, NOVEMBER 11, 2016.1
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 phor:ie number of the
person preparing the document, and the name, location and phone number of the record holder
1 Staff is requesting an expedited response. lfresponding by this date will be problematic, please call Staffs
attorney at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 28, 2016
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
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. 7: Please provide the Idaho jurisdictional energy at input associated
with the 2015 Results of Operations loads used to derive Net Power Costs proposed in the
Company's application.
DATED at Boise, Idaho, this z.i~day of October 2016.
Technical Staff: Rick Keller (7)
i:umisc:prodreq/pace l 6. l 2ccrkmrjncdkprod req 3
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2
Camille Christen
Deputy Attorney General
OCTOBER 28, 2016
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 281h DAY OF OCTOBER 2016,
SERVED THE FOREGOING THIRD 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
POCA TELLO 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
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 & AS SOCIA TES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
ERIC L OLSEN
ECOH HA WK & OLSEN
PO BOX 6119
POCA TELLO ID 83205
CERTIFICATE OF SERVICE