20190430PIIC 1-10 to PAC.pdf

Ronald L. Williams,ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone : [phone]
[e-mail]
Attorneys for PIIC
IN THE MATTER OF THE APPLICATION )
oF ROCKY MOLTNTAIN POWER )
REQUESTTNG APPROVAL OF $1s.l )
MILLION DEFERRAL OF NET POWER )
COSTS, AND AUTHOzuTY TO INCREASE )
BY 0.4 PERCENT ELECTRIC SERVICE )
SCHEDULE NO. 94 (ENERGY COST )ADJUSTMENT) )
RECEIVED
?019 APR 30 Pll h: l2
il.A:-io PUBLIC. JT IL ITII;S COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No. PAC-E-19-04
FIRST PRODUCTION REQUEST OF
PACIFICORP IDAHO INDUSTRIAL
CUSTOMERS TO ROCKY
MOUNTAIN POWER
PacifiCorp Idaho Industrial Customers ("PIIC"), by and through its
attorney of record Ronald L. Williams and pursuant to the Rules of Procedure of the
Idaho Public Utilities Commission ("Commission"), hereby requests that Rocky
Mountain Power ("RMP") provide the following documents and information as soon as
possible, and no later than May 8. 2019. The abbreviated response time reflects the short
time frame provided in the Notice of Modified Procedure in this case, issued on April 17,
2019, requiring that written comments be filed by Intervenors on May 14, 2019. PIIC
intents to file written comments on May l4 and respectfully requests the period of time
from May 8 through May l3 to prepare comments, with responses to the below requests
used in preparation of those comments.
Please provide answers to each question, and supporting work papers that provide
detail or are the source of information used in calculations. In addition to the written
PIIC l't Set of Production Requests to RMP, Case No. IPUC-E-19-04 Page I
copies provided as response to the questions, please provide all Excel and electronic files
on CD with formulas activated. Please provide a copy of all responses directly to PIIC
consultant, Brad Mullins at 1750 SW Harbor Way, Suite 450, Portland, Oregon 97201
Request No. l: Please provide all questions and answers to all prior data requests
between RMP and all other parties in this case, including questions and answers that
contain confi dential information.
Request No 2: Please provide native copies of all non-confidential and
confidentialworkpapers supporting Rocky Mountain Power's filing, including the
workpapers supporting the Direct Testimony and exhibits of Rocky Mountain Power
witnesses Wilding and Meredith. Please provide the workpapers in Excel format with all
links, including links to other documents, retained. To the extent that the workpapers
link to another document, please provide a copy of the other document as well.
Request No. 3: Please provide total-Company actual net power costs detailed on
a monthly basis for calendar years 2015 through 2018. ln the response, please include
both l) the energy supply management database entries and2) the underlying fuel supply
cost calculations, supporting the actual net power cost report. Please also provide any
mapping necessary to assign the database and fuel accounts to line items in the actual net
power cost report.
Request No. 4: Please provide total-Company actual net power costs in the
manner described in PIIC Request No. 3 but for calendar years 201 9 through the most
recent month available. Please update this report and the underlying data on a monthly
basis over the course of this proceeding.
Request No. 5: Please provide Rocky Mountain Power's 2018 Idaho results of
operations in Excel format with all links and formulas intact. Please provide this
information as soon as it is available.
Request No. 6: Please provide any workpapers supporting the calculation of line
33 of Wilding Exhibit No 1, regarding the Unrecovered Deer Creek Mine lnvestment,
and please also provide the amortization schedule for the Deer Creek Mine regulatory
asset, including calculation of the remaining Idaho balance.
Request No. 7: Please discuss how the FAS 106 savings associated with the Deer
Creek mine transaction are being tracked in the Deer Creek Mine regulatory asset and
PllC l"t Set of Production Requests to RMP, Case No. IPUC-E-19-04 Page 2
identify the total amount of FAS 106 savings recognized, on a total company and Idaho
allocated basis, since the Deer Creek Mine transaction.
RequestNo. 8: Please provide all confidential and non-confidential Energy
Balancing Account ("EBA") Filing Requirements and Additional Filing Requirements
submitted in Utah P.S.C Docket l9-035-01.
Request No. 9: To the extent not included in the EBA filing requirements, please
provide the 201 8 outage log for each of Rocky Mountain Power's thermal and hydro
resource, including a narrative description field.
No. I 0:Please provide the detailed results of operations for Bridger Coal
Company, supporting the Bridger Coal Company fuel costs that PacifiCorp has included
in the cost of the Jim Bridger power plant for the period.
Dated this 30th day of April,2019.
Respectfully submitted,
lslRo,W;ll;&-t
Ronald L. Williams
Williams Bradbury, P.C
Attomeys for PIIC
PIIC 1't Set of Production Requests to RMP, Case No. IPUC-E-19-04 Page 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 3Oth day of April,2}lg,I caused to be served a true and
correct copy of the foregoing document upon the following individuals in the manner indicated
below:
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
P.O. Box 83702
472 W. Washington Street
Boise, ID 83702-0074
E-Mail: [e-mail]
I Electronic Transmission
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake Ciry, UT 84116
E-Mail: [e-mail]
Yvonne R. Hogle
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, UT 841l6
E-Mai I : yvonne.hogle@pacifi corp.com
Data Request Response Ceriter
PacificCorp
825 NE Multnomah, Suite 2000
Portland, OP.97232
E-Mail : datarequestlOpaci t'icorp.corn
KarlKline
Deputy Attorney General
Idaho Public Utilities Commission
472 W . Washington (837 02)
PO Box 83720
Boise, lD 83720
Email: Karl.Kline@puc. idaho. gov
Randall C. Budge
Racine, Olson, Nye & Budge, Chtd.
201E. Center
PO Box 1391
Pocatello, lD 83204-1391
E-Mail: [e-mail]
Attorney for Bayer
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PIIC CERTIFICATE OF MAILING
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Jim Duke
Idahoan Foods
357 Constitution Way
Idaho Falls, lD 83742
E-Mail : [e-mail]
PIIC
Kyle Williams
BYU Idaho
Email: [e-mail]
PIIC
Val Steiner
Nu-West Industries, Inc.
Email: [e-mail]
PIIC
Bradley G. Mullins
333 S.W. Taylor, St 400
Portland, OP.97204
Email: [e-mail]
PIIC
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Ronald L. Williams
Williams Bradbury, P.C.
Attorney for PIIC
PIIC CERTIFICATE OF MAILING Page 2