20180214Staff 41-43 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.7956
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-17-06
POWER FOR BINDING RATEMAKING )TREATMENT FOR WIND REPOWERING.)
)FIFTH PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and throughits attorney of record,
Brandon Karpen,Deputy AttorneyGeneral,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than THURSDAY,
FEBRUARY 22,2018.1
This Production Request is to be considered continuing,and Rocky Mountain Power 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 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
'Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 FEBRUARY 14,2018
the person preparing the documents.Please identify the name,job title,location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.41:Please provide all work papers with formula intact used in the
updated economic analysis for the Compliance filing.Please include the following,but not
limited to:
a.System Optimizer and PaR files containing assumptions,inputs,outputs,and
summary information for all scenarios.
b.Work papers for all the Tables included in the Compliance filing.
c.Work papers showing updated energy production estimates and project cost broken
out by wind facility.
REQUESTNO.42:Please provide a copy of the master retrofit contract with General
Electric and the supply contract with Vestas mentioned in the Compliance filling on page 4.
REQUESTNO.43:In the Compliance Filing dated February 7,2018,Item 35 states
that "the Company proposes to separately defer the net costs in excess of the cap associated with
the Tax Act changes,and seek recovery through an offset to the deferral for the impacts from the
Tax Act."How will the Company identify the impacts that will be deferred?How will the
amounts deferred be calculated?Please identify in Exhibits 12 and 13 the amounts that would be
deferred due to the Tax Act changes.
FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 FEBRUARY 14,2018
DATED at Boise,Idaho,this i 46day of February 2018.
BiaXon Karpe
Deputy AttorneyGeneral
Technical Staff:Michael Eldred (41-42)
Kathy Stockton (43)
i:umisc:prodreqlpacel7.6bkmekls prod req 5
FIFTH PRODUCTIONREQUEST
TO ROCKY MOUNTAIN POWER 3 FEBRUARY 14,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 147"DAY OF FEBRUARY 2018,
SERVED THE FOREGOING FIFTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-06,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSITANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:ted.weston pacificorp.com SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
E-MAIL ONLY:RACINE OLSON NYE &BUDGE
[e-mail] PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL:rob racinelaw.net
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:[e-mail] BOISE ID 83701
[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ELECTRONIC ONLY
JIM DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ERIC L OLSEN
VAL STEINER ECHO HAWK &OLSEN
NU-WEST INDUSTRIES INC PO BOX 6119
E-MAIL:[e-mail] POCATELLO ID 83205
E-MAIL:elo echohawk.com
ANTHONY YANKEL BRADLEY MULLINS
UNIT 2505 333 SW TAYLOR
12700 LANE AVENUE SUITE 400
LAKEWOOD OH 44107 PORTLAND OR 97204
E-MAIL:[e-mail] E
SECRETARY
CERTIFICATE OF SERVICE