20210318Staff 3-6 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837T4
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.E-21-01
SECOND PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney 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 THURSDAY'
APRrL 8,2021.
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
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER MARCH I8,2O2I
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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 and electronic files on CD with formulas activated.
REQUEST NO.3: Please provide all workpapers in Excel format with all formulae
enabled used in the economic analysis provided in Hemstreet Exhibit No. 3. Please also include
the following:
a) A detailed description of each workpaper and how it was used in the study.
b) The Relicense FERC Alternative and Final Settlement Alternative scenario files used
in the analysis. A list of all the assumptions and inputs included in each alternative
scenario, and a summary of the parameters that were changed for each alternative
scenario performed.
REQUEST NO. 4: Regarding the Company's response to Production Request No. 1,
please provide in Excel format a detailed list of all expenses the Company currently has deferred
to the regulatory asset for relicensing costs. Please include vendor name, invoice number,
invoice amount, invoice date, payment date, and a brief description of the expense.
REQUEST NO. 5: Regarding the Company's response to Production Request No. 2,
please provide any and all documentation supporting the necessity of any planned capital
expenditures for 2022 and beyond.
REQUEST NO. 6: Please identifr the entity responsible to pay for any capital
expenditures for the Lower Klamath Project after approval of transfer to Klamath River Renewal
Corporation.
SECOND PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER MARCH I8,2O2I2
DATED at Boise,Idaho, this t€+t^- day of Marchz}2l.
Edward J
Deputy General
i:umiso:prodreq/pace2l. lejmetno prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J MARCH I8,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18TH DAY OF MARCH 2021,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
coMMrssloN STAFF TO ROCKY MOUNTATN POWER, N CASE NO.
PAC-E-2I-OI, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOI.INTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pacifi com. com
JOHN HUTCHINGS
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL : [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@paci fi corp. com
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SECRETARY /
CERTIFICATE OF SERVICE