20201120Staff 18-19 to PAC.pdf

MATT HLTNTER
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
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey 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 FRIDAY,
DECEMBER 4, 2O2O.I
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.
1 Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attomey at [phone].
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER NOVEMBEP.}O,2O2O
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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 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. 18: Please provide updated system capacity Load and Resource
Balances for both summer peak and winter peak that meet the following criteria:
a. The most recent load forecast completed in June 2020 and mentioned in Response
to Staff s Production Request No. 10 that reflects the COVID-19 pandemic.
b. Updated planning reseryes based on the load forecast discussed above.
c. The latest contract information of both PURPA contracts and non-PURPA
contracts as of filing the response to this request. In addition, please explain the
difference between the latest contract information and the contract information
used in the Application.
d. Cumulative coal plant derate adjustments that would be applied in each year,
independently, so that the "Sufficiency/Deficiency w/o Early Retirements" are
accurate for each year, instead of only providing cumulative derates for 2029.
REQUEST NO. 19: Please explain how'ouncommitted FOTs to meet remaining need"
values are determined and define and explain the significance of "uncommitted FOTs to meet
remaining need".
DATED at Boise, Idaho, tnisLyi/aay of Nove mber 2020
Matt Hunter
Deputy Attorney General
i:umisc:prodreq/pace20.l3mhyy prod req 2
THIRD PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 NOVEMBER20,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF NOVEMBER 2020,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
CoMMISSION STAFF 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 MOI.]NTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
RON SCHEIRER
PACIFICORP
825 NE MULTNOMAH STE 600
PORTLAND OR 97232
E-MAIL: [e-mail]
com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
.com
Jo,4J,*.,
SECRETARY/
CERTIFICATE OF SERVICE