20200916Staff 9-11 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83]20-OO7 4
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
II33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION TO INCREASE ITS
RATES AND CHARGES IN IDAHO AND FOR
APPROVAL OF PROPOSED ELECTRIC
SERVICE SCHEDULES AND REGULATIONS
CASE NO. PAC.E.2O.O3
SECOND 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,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
ocToBEll-7,2020.
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 behall 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
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER SEPTEMBER 16,2020
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In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO.9: Please provide an example of the annual Resource Tracking
Mechanism Deferral Calculation worksheet for the Pryor Mountain and Foote Creek I wind
projects. Please specify the price-policy scenario (e.g. medium natural gas and medium CO2
price) used in the example.
REQUEST NO. 10: The Company states in the Application, "The Company may
propose to include these resources in the Resource Tracking Mechanism./Energy Cost
Adjustment Mechanism, consistent with the terms agreed to in Case No. PAC-E-I7-07."
Please provide a list of all the terms from the stipulation in Case No. PAC-E -I7 -Ol that the
Company is proposing to apply to ratemaking treatment for the Pryor Mountain and Foote Creek
I wind projects.
REQUEST NO. 11: Please provide a levelized PVRR(d) analysis for Pryor Mountain
and Foote Creek I wind projects using levelized PTC benefits in the Cost of the Project similar to
the levelized PVRR(d) analysis submitted in the Company's original Application in Case No.
PAC-E-17-07.
DATED at Boise, Idaho, trris f (G ou, of Septemb er 2020.
yn
Deputy Attorney General
i:umisc:prodreq/pace20.3dhjt prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 16,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF SEPTEMBER 2020,SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THECOMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.PAC-E-20-03, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston @pacificorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequ est @ pac i fi corp.com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
505 PERSHING AVE STE 1OO
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: emil)[e-mail]
@mrs -law.com
ANTHONY YANKEL
I27OO LAKE AVENUE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE