20170928PIIC 1-12 to PAC.pdf

WILLIAMS ·BRADBURY
ATTORNEYS AT LAW
September 28,2017
Ms.Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702
Re:PAC-E-17-06
Dear Ms.Hanian:
Please find enclosed for filing the original and three copies of PacifiCorp Idaho
IndustrialCustomers'First Production Request to Rocky Mountain Power in the above
referenced case.
Thank you for your assistance in this matter.Please feel free to give me a call should
you have any questions.
Sincerely,
Ronald L.Williams
RLW
Enclosures
P.O.Box 388 -Boise,ID 83701
Phone:[phone] -www.williamsbradbury.com
Ronald L.Williams,ISB No.3034
P.O.Box 388,802 W.Bannock Street,Suite 900
Boise,ID 83702
Telephone:[phone]
Email:[e-mail]
Attorneys for PacifiCorp Idaho Industrial Customers
BEFORE THE IDAHO PUBLIC UTILITES COMMISSION
IN THE MATTER OF THE APPLICATION OF )Case No.PAC-E-17-06
ROCKY MOUNTAIN POWER FOR BINDING )
RATEMAKING TREATMENT FOR WIND )FIRST PRODUCTION REQUESTOF
REPOWERING )PACIFICORP IDAHO INDUSTRIAL
)CUSTOMERS TO ROCKY MOUNTAIN
)POWER
PacifiCorp Idaho Industrial Customers ("PIIC"),by and through its attorney of record
Ronald L.Williams and pursuant to the Rules of Procedure of the Idaho Public Utilities
Commission ("Commission"),hereby requests that Rocky Mountain Power ("RMP")provide the
followingdocuments and information as soon as possible,and no later than October 20,2017.
This Production Request is continuing,and RMP is requested to provide,by way of
supplementaryresponses,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,and supporting work papers that provide detail
or are the source of information used in calculations.RMP 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.IDAPA 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.
PIIC FIRSTPRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 1
REQUEST NO.1.Please provide a copy of all prefilled testimony and exhibits in un-
redacted format,to Mr.Williams and Mr.Mullins.Please provide one of these as a physical copy
to Mr.Williams.
REQUEST NO.2.Please provide to Mr.Mullins copies of all responses previously
provided by the Company to all Staff's and Intervenor's data requests.
REQUEST NO.3.Please provide all Company workpapers,includingelectronic
workpapers,and all confidential documents in this matter to Mr.Mullins.Please provide the
workpapers in Microsoft Excel format with all links intact and provide copies of any linked
workpapers.If the workpapers contain any hard-coded numbers,please identify the source of
the hard-coded numbers and provide a copy of the source documentation.
REQUEST NO.4.Please provide a copy of Link Exhibit 6 updated based upon the most
recent estimates of capital expendituresand repower capacity factors.
REQUEST NO.5.Please provide any supplemental analysis that the Company has
performed on the repowering case,which was not reflected in the Company's filing in this
matter.
REQUEST NO.6.Please identify the removal costs for existing equipment associated with
each resource that will be repowered.
REQUEST NO.7.Please identify how the Company accounted for removal costs in its
analysis supporting the repowering strategy.
REQUEST NO.8.Do the capital costs in the repower case identified in Link Exhibit 6
include removal costs?If yes,please identify all such amounts included in capital costs for each
resource in the repower case.
PIIC FIRST PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 2
REQUEST NO.9.For each resource identified in Link Exhibit 6,please identify the gross
book value,depreciation reserve,and accumulated deferred income taxes as of December 31,
2016.
REQUEST NO.10.For each resource identified in Link Exhibit 6,please identify the gross
book value,depreciation reserve,and accumulated deferred income taxes expected as of the date
that the resource will be repowered.
REQUEST NO.I1.For each resource identified in Link Exhibit 6,please identify the gross
book value,depreciation reserve,and accumulated deferred income taxes associated with the
plant which will be removed from services as a result of the repowering as of the date that the
resource will be repowered.
REQUEST NO.12.What ratemaking does the Company propose for the unrecovered
investment in plant that will be taken out of service as a result of the repowering?
DATED at Boise,Idaho,this 28th day of September ,2017.
Resp etfully submitted,
Ronald L.Williams
Williams Bradbury,P.C.
Attorneys for PacifiCorp Idaho Industrial Customers
PIIC FIRSTPRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 28th day of September ,2017,I caused to be
served a true and correct copy of the foregoing document upon the followingindividuals in the
manner indicated below:
Diane M.Hanian,Secretary Hand Delivery
Idaho Public Utilities Commission US Mail (postage prepaid)
P.O.Box 83702 Facsimile Transmission
472 W.Washington Street Federal Express
Boise,ID 83702-0074 Electronic Transmission
E-Mail:[e-mail]
Ted Weston .Hand DeliveryIdahoRegulatoryAffairsManager .US Mail (postage prepaid)Rocky Mountain Power -
[__]Facsimile Transmission1407WestNorthTemple,Suite 330 O Federal ExpressSaltLakeCity,UT 84116 Electronic TransmissionE-Mail:[e-mail]
Yvonne R.Hogle O Hand DeliveryAssistantGeneralCounselOUSMail(postage prepaid)Rocky Mountain Power Facsimile Transmission1407WestNorthTemple,Suite 320 Federal ExpressSaltLakeCity,UT 84116 -
.
L×']Electronic TransmissionE-Mail:[e-mail]
Randall C.Budge Hand Delivery
Racine,Olson,Nye &Budge,Chtd.US Mail (postage prepaid)
201 E.Center Facsimile Transmission
PO Box 1391 Federal Express
Pocatello,ID 83204-1391 Electronic Transmission
E-Mail:[e-mail]
Attorney for Monsanto Company
Brubaker &Associates .
.Hand Delivery16690SwingleyRidgeRoad,#140 O US Mail (postage prepaid)Chesterfield,MO 63017 -..
..\__Facsimile TransmissionE-Mail:[e-mail] Federal [e-mail] Electronic TransmissionMonsantoCompany
Hand DeliveryJimDukeUSMail(postage prepaid)Idahoan Foods ..Facsimile Transmission357ConstitutionWayFederalExpress
PIIC FIRST PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 4
Idaho Falls,ID 83742 Electronic Transmission
E-Mail:[e-mail]
PIIC
Kyle Williams Hand DeliveryBYUIdahoUSMail(postage prepaid)Email:[e-mail] -Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Val Steiner Hand DeliveryNu-West Industries,Inc.US Mail (postage prepaid)Email:[e-mail] -Facsimile TransmissionPIICFederalExpress
Electronic Transmission
Bradley Mullins Hand Delivery333S.W.Taylor,St 400 US Mail (postage prepaid)Portland,OR 97204 Facsimile TransmissionEmail:[e-mail] Federal ExpressPIICElectronicTransmission
Ronald L.Williams
PIIC FIRST PRODUCTIONREQUEST TO ROCKY MOUNTAIN,Page 5