20170926Staff 2-4 to PAC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITTES COMMISSTON
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-I7-09
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney 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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 I 8.
SECOND PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER
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SEPTEMBER26,2OI7I
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
3r.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. 2: Please explain why the first capacity deficiency year moves from the
currently authorized date of July 2025 to July 2028 as proposed by the Company in this case.
REQUEST NO. 3: Please explain the drivers that cause the differences in the load
resource balance between the 2015 IRP and2017 IRP for months luly 2025, July 2026, July
2027, and July 2028.
REQUEST NO. 4: Specifically, please explain why:
a. thermal generation decreased in the 2017 IRP;
b. load decreased in the 2017 IRP;
c. existing Class 2 DSM increased in the 2017 IRP.
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Dated at Boise, Idaho, this 2[ ?auV of Septemb er 2017
Daphne
Deputy Attorney General
Technical Staff: Yao Yin
i : umisc:prodreq/pace I 7.9djhyy prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER 2 SEPTEMBER26,2OI7
CERTIFICATE OF SERVTCE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF SEPTEMBER 2017,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER COMPANY, N CASE
NO. PAC-8,-17-09, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
YVONNE R HOGLE
ROCKY MOLINTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 841 16
E-MAIL : ted.weston@paciflcorp. com
yvonne. ho gle@paci f-rcorp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq ue st @paci ticolp. c om
RON SCHEIRER
PACIFICORP
825 NE MULTNOMAH STE 600
PORTLAND OR 97232
E-MAIL : rsn [e-mail]!10
.. I
SECRETARf
CERTIFICATE OF SERVICE