20180420Staff 81-85 to PAC.pdf

BRANDON KARPEN RE CE\VED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074 SION
[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-17-07
POWER FOR A CERTIFICATE OF PUBLIC )
CONVENIENCE AND NECESSITY AND )
BINDING RATEMAKING TREATMENT FOR )EIGHTH PRODUCTION
NEW WIND AND TRANSMISSION FACILITIES)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 end of day
MONDAY,APRIL 23,2018.1
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
I Staffis requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 APRIL 20,2018
the person preparing the documents.Please identifythe 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.81:Please provide the System Optimizer and PAR results and the
nominal and levelized PVRR(d)results for the Combined Projects without Uinta for each of the
nine price-policyscenarios.Please provide workpapers with all formulas intact.
REQUESTNO.82:Please explain and quantifywhat causes the change in net benefits
[nominal PVRR(d)]between the Combined Projects with the Uinta wind project and without
Uinta for each of the 9 price-policy scenarios.Please provide workpapers with formulas intact to
quantifythe difference in net benefits.
REQUESTNO.83:Please provide the calculations for all the amounts in Paragraphs 6
and 7 of Rocky Mountain Power's proposed Settlement Term Sheet dated April 18,2018.Please
provide workpapers with all formulas intact.
REQUESTNO.84:Has the Company discovered any changes to the costs and benefit
assumptions for the wind repower project (Case No.PAC-E-17-06)since the compliance filing
that was submitted on February 7,2018?If so,please provide the changes with an explanation
of the changes and the cost and benefit impact to the overall project.
REQUESTNO.85:Please provide the calculations for the pre-tax and after-tax return-
on-investment amounts contained in Paragraph 3 of Rocky Mountain Power's proposed
Settlement Term Sheet dated April 18,2018.Please provide workpapers with all formulas
I
intact.
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 20,2018
DATED at Boise,Idaho,this day of April 2018.
Brg Karpen
Deputy AttorneyGeneral
Technical Staff:Mike Louis/81-85
i:umisc:prodreqlpace17.7bkml prod reg 8
EIGHTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 APRIL 20,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF APRIL 2018,
SERVED THE FOREGOING EIGHTH PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-07,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSISTANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:[e-mail] 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:[e-mail]
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:kiverson consultbai.com BOISE ID 83701
bcollins consultbai.com E-MAIL:ron williamsbradbury.com
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:[e-mail]
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-MAIL:[e-mail]
SECRETARY
CERTIFICATE OF SERVICE