20210205Staff 1-2 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83120-007 4
(208) 334-O3t4
IDAHO BAR NO. 10446
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Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OT-A
BOISE, D 837 T4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTAIN POWER FOR APPROVAL
OF THE TRANSFER OF THE LOWER
KLAMATH HYDROELECTRIC PROJECT
GENERATING FACILITIES
CASE NO. PAC-B,LI.OI
FIRST 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, Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than FRIDAY,
FEBRUARY 26,2021.
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.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER FEBRUARY 5,2021
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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. 1: What is the total amount the Company expects to defer in a
regulatory asset account for the plant balance of the Lower Klamath Project? Please include the
impact to each of the Company's jurisdictions and how the balance will be allocated to each
jurisdiction.
REQUEST NO.2: For each of the four dams in the Lower Klamath Project, please
provide the following in Excel format with all formulas intact:
a. All capital improvements, including amounts and in-service dates, from 2010 through
2O2l to date.
b. A list of retired assets, including amounts and dates retired, from 2010 through 2021
to date.
c. Any planned capital improvements, including amounts and expected completion
dates.
DATED at Boise,Idaho, this 5rH day of February 2021.
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Edward Jfu]}
Deputy Attorney General
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FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 FEBRUARY 5,2027
CERTIFICATE OF SERVICE
I I{EREBY CERTIFY THAT I HAVE THIS 5TH DAY oF FEBRUARY 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-2l-OI, 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: [e-mail]
idahodockets @ pacifi corp.com
JOHN HUTCHINGS
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: john.hutchings @pacificorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest @pacifi corp.com
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SECRET;:Y/
CERTIFICATE OF SERVICE