20201029Staff 14-17 to PAC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
1 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR APPROVAL
OF A CAPACITY DEFICIENCY PERIOD TO BE
USED FOR AVOIDED COST CALCULATIONS
CASE NO. PAC.E.2O.13
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,
Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than MONDAY'
NOVEMBER 9, 2020.r
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.
I Stuffi. requesting an expedited response. If responding by this date will be problematic, please call Staffls
attorney at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER ocroBER 29,2020
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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 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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 14: Tab: "Tbl5.12" of the Excel file named "PAC-E-20-13 RMP
Workpapers CONFIDENTIAL 10-6-20- submitted electronically with the Application includes
an item "Adjustment for Derates" for all the coal plant early shutdowns. Please describe the
purpose of this adjustment relative to establishing the capacity deficiency date and explain how it
is determined. In addition, please answer if all coal plants included in the Load and Resource
Balance are adjusted for derates.
REQUEST NO. 15: Tab: "Tbl 5.12" of the Excel file named "PAC-E-20-13 RMP
Workpapers CONFIDENTIAL 10-6-20" submitted electronically with the Application shows
that the Company has removed early coal plant retirements (see rows 72 tl'rough 79), which were
originally included in rows 7 and 29. Please explain the discrepancy in the amount of capacity
that was originally included in rows 7 and 9 and the amounts that were removed (see rows 72
through 79). If accurate, please explain why the Company believes the amounts backed out of
existing resources are appropriate. For example, the change in the amount of thermal capacity
from year 2023 to 2024 for both East (row 7) and West (row 29) regions in total is equal to 312
MW; however, the amount deducted in year 2024 (rows 72 through 79) was 351 MW.
Similarly, the change in the amount of thermal capacity from year 2025 to 2026 for both East
(row 7) and West (row 29) regions in total is equal to 416 MW; however, the amount deducted in
year 2026 (rows 72 through 79) was 439 MW.
REQUEST NO. 16: Please explain why the Company has included "Sales" in the Load
and Resource Balance for determining the capacity deficiency date for avoided cost rates.
SECOND PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER ocroBER 29,20202
REQUEST NO. 17: Please explain why the Company has included "Non-owned
Reserves" in the load and resource balance for determining the capacity deficiency date for
avoided cost rates.
DATED at Boise,Idaho, this L?
g,
day of October2020.
Matt Hunter
Deputy Attorney General
i:umisc:prodreq/pace20. I 3mhyy prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOI.'NTAIN POWER J ocToBER 29,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 29TH DAY OF OCTOBER 2020,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
coMMrssroN srAFF To RocKY MOUNTAIN POWER, IN CASE NO.
PAC-E-20-13, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
EMILY WEGENER
ROCKY MOLTNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL : ted.weston@pacit'icom.com
emily. we gener@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@paci fi corp. com
RON SCHEIRER
PACIFICORP
825 NE MULTNOMAH STE 600
PORTLAND OR 97232
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE