20201022Staff 12-15 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03t2
IDAHO BAR NO. 9917
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 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-20,03
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,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than THURSDAY,
NOVEMBER 5, 2020.1
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
I Stuffi. requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
THIRD PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER ocroBER 22,2020
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the person preparing the documents. Please also identiff 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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 12: Please provide the baseline resource portfolios without incremental
wind generation used in the PVRR(d) analysis for the Pryor Mountain and Foote Creek I wind
projects provided in Response to Staff Production Request Nos. I and2. Please include the
following in the response.
a) The source of the baseline portfolios. Specifically, were the portfolios identified in
the2017IRP, the 2019 IRP, or were the portfolios created outside of the IRP
process?
b) Were any resources removed or modified in the baseline portfolios when the
incremental wind generation was added? If so, please explain why.
REQUEST NO. 13: Please provide the source and/or explain the derivation of the
inflation rate used in extrapolating the system values for the Pryor Mountain and Foote Creek I
wind projects in the Responses to Staff Production Request Nos. I and2.
REQUEST NO. 14: Please provide the workpapers showing the System PVRR (with
and without Foote Creek I) and the calculation for extrapolating the system values for the Foote
Creek I project similar to the analysis provided in the "System Value" tab of the'oAttach IPUC
2-1 CONF" file provided for Pryor Mountain in Response to Staff Production Request No. 2.
REQUEST NO. 15: Please explain the cause of the large increase in net benefits in year
2037 for the Pryor Mountain wind project in the Medium Gas/Medium CO2 case that was
provided in Response to Staff Production Request No. 2.
DATED at Boise, Idaho, thisZL day of October 2020.
Deputy Attorney General
hJ
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 ocToBER 22,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF OCTOBER 2020,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION 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 84I 16
E-MAIL: [e-mail]
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
adam@,mrg-law.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareque st@pacifi corp. com
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
505 PERSHING AVE STE IOO
PO BOX 6119
POCATELLO ID 83205
E-MAIL: [e-mail]
ANTHONY YANKEL
I27OO LAKE AVENUE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
SECRET
CERTIFICATE OF SERVICE