20181221Staff 13-20 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4
IDAHO BAR NO. 10446
RICEIVED
/li: i]iil ? I [H ll: 08
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO CHANGE
DEPRECIATION RATES APPLICABLE TO
ELECTRIC PROPERTY.
CASE NO. PAC-E.18.08
THIRD 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,
Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
JANUARY 11,2019.
This Production Request is to be considered as continuing, and Rocky Mountain Power 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 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
THIRD PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
)
)
)
)
)
)
)
)
)
I DECEMBER 21, 201 8
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.
REQUEST NO. 13: According to Exhibit No 7, page l, in Timothy Hemstreet
testimony, Viva Naughton is exempt from FERC License. Please explain what makes Viva
Naughton exempt.
REQUEST NO. 14: On line 54 in the spreadsheet titled AWEC 0013 exhibit 2 CONF
that has capital additions identified on Cell 161, which states "VivaNaughton FERC Compliance
CYlT -20," please provide a listing of all projects and their projected costs to achieve FERC
compliance.
REQUEST NO. 15: Please provide a schedule showing all capital projects planned for
2018, 2019, and2020, including the planned cost for each the following plants:
a. Naughton
b. Dave Johnston
c. Hunter
d. Huntington
e. Jim Bridger
f. Wyodak
REQUEST NO. 16: Please reconcile the schedule above with the amounts in the
Attachment Monsanto 14-1, as provided in response to Monsanto's Production Request No. 14
REQUEST NO. 17: Please update the 2018 capital additions and retirements as
provided in response to Monsanto's Production Request No. l4 with actual amounts.
REQUEST NO. 18: Please provide the Ownership and Operating Agreements for each
of the coal units not fully owned by the Company.
THIRD PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 2 DECEMBER 2I, 2018
REQUEST NO. 19: For each of the coal units referenced in Request No. 18, please
provide a detailed explanation by unit of any contractual limitations the Company has for
shortening the operating life of the unit to match the depreciation lives provided in the
Company's filing.
REQUEST NO. 20: Please provide all analyses conducted by PacifiCorp that supports
the proposed sequence of depreciation end-dates: Cholla Unit 4 and Craig Unit 1 in2025, Craig
Unit2 in2026, Colstrip Units 3 and 4 in2027, and Jim Bridger Unit 1 in2028. Please explain to
what extent this date sequence is based on the age of plants, PVRR, reliability, operating
agreements, or other factors?
DATED at Boise, Idaho, thisTlsf
day of December 2018.
Edward J
Deputy General
i:umisc:prodreq/pace I S.Sejtncjtrkbe prod req 3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J DECEMBER 2I, 2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF DECEMBER 2018,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-18-08, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
YVONNE R HOGLE
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
ted. weston@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@racifi corp. com
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON PLLP
PO BOX 1391
POCATELLO ID 83204
E-MAIL: [e-mail]
[e-mail]
ERIC L OLSEN
ECHO HAWK & OLSEN
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ELECTRONIC ONLY
KYLE WILLIAMS
BYU IDAHO
E-MAIL: [e-mail]
D MATTHEW MOSCON
LAUREN SHURMAN
STOEL RIVES LLP
201 S MAIN ST STE I lOO
SALT LAKE CITY UT 84111
E-MAIL: [e-mail]
lauren. [e-mail]
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD
#140
CHESTERFIELD MO 63017
E-MAIL : [e-mail]
[e-mail]
DR LANCE D KAUFMAN
48OI W YALE AVE
DENVER CO 80219
E-MAIL: [e-mail]
ELECTRONIC ONLY
JIM DUKE
IDAHOAN FOODS
E-MAIL: [e-mail]
ELECTRONIC ONLY
VAL STEINER
NU-WEST INDUSTRIES INC
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
710 N 6TH STREET
BOISE ID 83702
E-MAIL : botto@idahoconservation. org
ANA BOYD
SIERRA CLUB
2101 WEBSTER ST STE I3OO
OAKLAND CA94612
E-MAIL: [e-mail]
MATTHEW GERHART
SIERRA CLUB
1536 WYNKOOP ST STE 2OO
DENVER CO 80202
E-MAIL: matt. [e-mail]
. L, /)a--,nseCffin7/
CERTIFICATE OF SERVICE