20170919Staff 1 to PAC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
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Street Address for Express Mail:
472 W , WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSIOI\
IN THE MATTER OF THE APPLICATION OF
PACIFICORP DBA ROCKY MOUNTAIN
POWER COMPANY TO APPROVE ITS
CAPACITY DEFICIENCY PERIOD FOR
AVOIDED COST CALCULATIONS
CASE NO. PAC-E.17.09
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Daphne Huang, Deputy Attorney General, request that Rocky Mountain Power Company
(Company; Rocky Mountain Power) provide the following documents and information as soon
as possible, but no later than THURSDAY, SEPTEMBER 28,2017.1
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 phone number of the
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER
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I SEPTEMBER 19,20I7
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
3t.01.0t.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. 1: Please provide Table 5.14 System Capacity Loads and Resources
without Resource Additions in the 2015 IRP, adjusted by signed and terminated PPAs used to
determine the capacity deficiency date in Case No. PAC-E-15-12.
Dated at Boise, Idaho, this I (9 O^rof Septemb er 2017.
uang
Deputy Attorney General
Technical Staff: Yao Yin
i :umisc:prodreq/pacel7.9 djhyry prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 SEPTEMBER19,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I9TH DAY OF SEPTEMBER 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER COMPANY, IN CASE
NO. PAC-E-77-09, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
YVONNE R HOGLE
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
yvonne. ho gle@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq ue st@pacili corp. com
RON SCHEIRER
PACIFICORP
825 NE MULTNOMAH STE 600
PORTLAND OR 97232
E-MAIL: [e-mail]
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SECRETARY,
CERTIFICATE OF SERVICE