20171011Staff 1-2 to PAC.pdf

CAMILLE CHRISTEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0014
[phone]
ISB NO. 10177
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )
POWER FOR AUTHORIZATTON TO REVTSE )
THE WIND INTEGRATION RATE AND )
IMPLEMENT A SOLAR INTEGRATION RATE )
FOR SMALL POWER GENERATION )
QUALIFYING FACILITIES )
CASE NO. PAC-E-I7-II
ti:'; I l\,/ED
jil iri::i I I PII 2: 30
FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Camille Christen, Deputy Attomey General, requests that PacifiCorp dba Rocky Mountain
Power, (Company; Rocky Mountain) provide the following documents and information as soon
as possible, but no later than WEDNESDAY, NOVEMBER 1, 2017,
The Company 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. Reference IDAPA 31.01.01.228.
This Production Request is to be considered as continuing, and Rocky Mountain 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.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER 1 ocToBER ll,20l7
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
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
Please provide all Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please list and quantify the primary reasons for the reduction of the
wind integration charge from2014 to 2017.
REQUEST NO. 2: Please include how much of the decrease is attributable to: (1) the
change in the NERC standard; (2) the EIM market; (3) the adjustments to account for the
changing portfolio of solar and wind; and (4) the adjustments to account for diversity benefits,
and any other quantifiable reason.
DATED at Boise, Idaho, this lt r+
day of October 2017.
(r,"i[h Ur*"*
Camille Christen
Deputy Attorney General
Technical Staff: Yao Yin
i:umisc:prodreq/pacel 7. I lccyy req I
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 ocroBER tt,20t7
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IITHDAY OF OCTOBER 2017,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-17-11, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: ted.weston@pacifi corp.com
DANIEL E SOLANDER
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: Daniel.solander@pacif,rcorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@paci fi corp. com
SECRETARY
CERTIFICATE OF SERVICE
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