20210128Staff 26 to PAC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 5470
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE,ID83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR
AUTHORIZATION TO UPDATE THE WIND
AND SOLAR INTEGRATION RATE FOR
SMALL POWER GENERATION QUALIFYING
FACILITIES
CASE NO. PAC.E.aO.I4
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, John R. Hammond, Jr., Deputy Attorney General, requests that Rocky Mountain Power
provide the following documents and information as soon as possible, but no later than
THURSDAY, FEBRUARY 4, 202L.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 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER JANUARY 28,202I
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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 and electronic files on CD with formulas activated.
REQUEST NO.26: Regarding the Company's response to Production Request No. 17
(part a), please provide an updated "App F-Flex Study PaR results" file showing the correct
value of 8.76 and the approximate 1 percent increase in wind integration charge.
DATED at Boise,Idaho, this ,gKrofJanuary zo2r.
J Hammond, Jr.
Attorney General
i:umisc:prodreq/pace20. l4jhme prod req 3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JANUARY 28,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF JANUARY 2021,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO. pAC-E-20-r4, 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:
datarequest @ pacific orp. c om
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE