20200504PIIC 1-8 to PAC.pdf

PIIC 1st Set of Production Requests to RMP, Case No. IPUC-E-20-02 Page 1
Ronald L. Williams, ISB No. 3034
Williams Bradbury, P.C.
P.O. Box 388
Boise ID, 83701
Telephone: [phone]
[e-mail]

Attorneys for PIIC

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF ROCKY MOUNTAIN
POWER REQUESTING APPROVAL OF
$21.2 MILLION NET POWER COST
DEFERRAL
)
)
)
)
)
)

Case No. PAC-E-20-02

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 Noon, MDT on May 11, 2020.
The abbreviated response time reflects the short time frame (16 days) provided in
the Notice of Modified Procedure in this case, issued on April 28, 2020, requiring that
written comments be filed by Intervenors on May 14, 2020. PIIC intends to file written
comments on May 14 and respectfully requests the period of time from the afternoon of
May 11 through May 14 to prepare and file 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
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 electronically to
PIIC consultant, Brad Mullins, via his email as shown on the attached service list.
Request No. 1: Please provide all workpapers and filing requirements associated
with PacifiCorp’s filing in Excel format with all formulas and links intact.
RECEIVED
2020 May 4,PM3:27
IDAHO PUBLIC
UTILITIES COMMISSION
PIIC 1st Set of Production Requests to RMP, Case No. IPUC-E-20-02 Page 2
Request No 2: Please provide hourly electric market prices in the deferral period
(January 1, 2019 – December 31, 2019) for the Palo Verde, Four-Corners, Mid-
Columbia, Mead, and California Oregon Border hubs.
Request No. 3: Please provide hourly generation logs and capacity factors for
each owned wind production facility in the deferral period.
Request No. 4: Please provide monthly diurnal P50 capacity factors for each
wind plant repowered, or taken out of service to conduct repowering activities, in the
deferral period.
Request No. 5: For each wind plant that was repowered or taken out of service to
conduct repowering activities in the deferral period, please state the date the wind plant
was taken out of service and the date that it returned to service. If only part of a plant was
removed from service, please provide a schedule identifying the nameplate capacity out
of service by date.
Request No. 6: Please provide PacifiCorp’s best estimate of the cost of acquiring
replacement power associated with each wind plant that was taken out of service for
repowering activities in the deferral period.
Request No. 7: Please identify all test energy that PacifiCorp recorded in the
deferral period by resource and by month. Please also provide an explanation of how the
identified test energy impacts actual net power costs.
Request No. 8: In the Stipulation in Case No. PAC-E-17-06, “[t]he Parties
requested that the Commission approve the Company's proposed ratemaking treatment
for recovery of the replaced assets, new investment, incremental energy production, and
production tax credits ("PTC") associated with the wind repowering project.” In its
request for binding rate making treatment, did PacifiCorp consider and identify the cost
of acquiring replacement power during repowering activities? If yes, please identify
where in testimony the cost of acquiring replacement power was identified.
Dated this 4th day of May, 2020.
Respectfully submitted,
/s/ Ron Williams

Ronald L. Williams
Williams Bradbury, P.C.
Attorneys for PIIC
PIIC CERTIFICATE OF MAILING Page 1
CERTIFICATE OF MAILING

I HEREBY CERTIFY that on this 4th day of May 2020, 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]
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission

Idaho Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720
Email: [e-mail]

Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, UT 84116
E-Mail: [e-mail]

Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Emily L. Wegener
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, UT 84116
E-Mail: [e-mail]

Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Data Request Response Center
PacificCorp
825 NE Multnomah, Suite 2000
Portland, OR 97232
E-Mail: [e-mail]
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Adam Lowney
McDowell Rackner Gibson PC
419 SW 11th Ave., Suite 400
Portland, OR 97205
Email: [e-mail]
Attorney for RMP
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission

PIIC CERTIFICATE OF MAILING Page 2
Randall C. Budge
Racine, Olson, Nye & Budge, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
E-Mail: [e-mail]
Attorney for Bayer

Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Jim Duke
Idahoan Foods
357 Constitution Way
Idaho Falls, ID 83742
E-Mail: [e-mail]
PIIC
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission

Kyle Williams
BYU Idaho
Email: [e-mail]
PIIC
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission
Val Steiner
Nu-West Industries, Inc.
Email: [e-mail]
PIIC
Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission

Bradley G. Mullins
333 S.W. Taylor, St 400
Portland, OR 97204
Email: [e-mail]
PIIC

Hand Delivery
US Mail (postage prepaid)
Facsimile Transmission
Federal Express
Electronic Transmission

/s/ Ronald L. Williams
Ronald L. Williams
Williams Bradbury, P.C.
Attorney for PIIC