20210812Staff 139-160 to PAC-Redacted.pdf

DAYN HARDIE (ISB No. 9917)
JOHN R. HAMMOND, JR. (ISB No. 5470)
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
Street Address for Express Mail:
1 I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR ELECTRIC SERVICE IN THE STATE OF
IDAHO
CASE NO. PAC.E.2I.O1
REDACTED FIFTH
PRODUCTION REQUEST OF
THE COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorneys of
record, Dayn Hardie and John R. Hammond, Jr., Deputy Attomeys General, request that Rocky
Mountain Power ("Company") provide the following documents and information as soon as
possible, but no later than THURSDAY, AUGUST 26,2021.1
This Production Request is to be considered as continuing, and the Company 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
I Stuff i, requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
REDACTED FIFTH PRODUCTTON REQUEST
TO ROCKY MOUNTATN POWER 1
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AUGUST I2,2O2I
the person preparing the documents. Please also identi$ 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. 139: Regarding the Company's response to Production Request No. 2,
please provide a list of all transactions booked in2020 that were allocated or directly assigned to
the Company's Idaho jurisdiction for the following FERC accounts:
a. 1513940: Employee Travel - Other;
b. 1513990: Miscellaneous General Expense;
c. 1515890: Miscellaneous General Expense;
d. 3034900: Misc - Miscellaneous;
e. 3168000: Leased Miscellaneous;
f. 3980000: Miscellaneous Equipment;
g. 3996000: Miscellaneous General Equipment;
h. 4081990: Miscellaneous Taxes - Other;
i. 9160000: Miscellaneous Sales Expenses;
j. 9302000: Misc General Expenses - Other;
k. 9040000: UncollectibleAccounts;
l. 9041000: Uncollectible Accounts;
m. 9050000: Misc Customer Accounts Expenses; and
n. 9051000: Misc Customer Accounts Expenses
REQUEST NO. 140: Please explain the Company's method and calculations for
determining Idaho's allocation of line losses in this case and for actual line losses in the
Company's most recent ECAM. Please explain how the line losses for electricity transmitted
through the state and consumed outside Idaho are excluded from Idaho's allocation of line
losses. Please include supporting workpapers in electronic format with formula intact.
REDACTED FIFTH PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 2 AUGUST I2,2O2I
REQUEST NO. 141: Page 2 of Mr. Wilding's Confidential Exhibit No. 37 shows that
the cost of energy purchased from the Cedar Springs wind III project ir I. However,
Tab "LTC" of Mr. Wilding's Confidential Excel file "ID GRC2I Testimony Support CONF"
shows that the cost of energy purchased from the Cedar Springs Wind III project is
Please reconcile the difference.
REQUEST NO. 142: Please list all qualiffing facilities subject to situs allocation per
the 2020 Protocol and provide costs allocated to Idaho. Please provide the workpapers that
calculate the costs in electronic format with formula intact.
REQUEST NO. 143: Please define Trapped Energy and describe the role it plays in the
GRID model.
REQUEST NO. 144: Please define Emergency Purchases and desuibe the role it plays
in the GRID model.
REQUEST NO. 145: Please describe how Long-Term Firm Purchases on Page 2 of
Confidential Exhibit No. 37 are determined and provide the workpapers in electronic format with
formula intact that calculate their costs.
REQUEST NO. 146: Please describe operations under the PSCo Exchange. Please
provide workpapers in electronic format with formula intact that calculate "PSCo Exchange"
listed on Page 4 of the Confidential Exhibit No. 37.
REQUEST NO. 147: Page 4 of Confidential Exhibit No. 37 shows that Short Term
Firm Purchases from Palo Verde ir I. However, Tab o'Calculation-Verification" of the
Excel file "ID GRC2I-STF (2103) APR2l CONF (2020-2023)" shows the cost it I.
Please reconcile the difference.
REDACTED FIFTH PRODUCTION REQUEST
TO ROCKY MOI.INTAIN POWER 3 AUGUST I2,2O2I
REQUEST NO. 148: Page 6 of Confidential Exhibit No. 37 shows that Firm Wheeling
Expense for the Test Period is whereas the Firm Wheeling Expense for the Test
Period shown on Tab "Wheeling Costs" of the Excel File "ID GRC2I_Wheeling CONF" is
Please reconcile the difference.
REQUEST NO. 149: Page 6 of Confidential ExhibitNo. 37 shows that ST Firm & Non-
Firm Wheeling Expense for the Test Period ir I, whereas the Non-Firm Wheeling
Expense for the Test Period shown on Tab "Wheeling Costs" of the Excel File "ID
GRC2 l_Wheeling CONF" is Please reconcile the difference.
REQUEST NO. 150: Please define *C&T EIM Admin Fee" and explain why it is
included in the wheeling expenses. Please provide the workpaper in electronic format with
formula intact that calculates the fee.
REQUEST NO. 151: Please provide workpapers in electronic format with formula
intact for calculating each coal plant's Coal Fuel Bum Expense from Page 6 of Confidential
Exhibit No. 37.
REQUEST NO. 152: Please provide workpapers in electronic format with formula
intact for calculating each gas plant's Gas Fuel Burn Expense from Page 6 of Confidential
Exhibit No. 37.
REQUEST NO. 153: From Page 6 of Confidential Exhibit No. 37, please explain why
the gas plants in the table below have no Gas Fuel Burn Expense in the months indicated.
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REDACTED FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 4 AUGUST I2,2O2I
REQUf,ST NO. 154: Please define and describe "Gas Physical", "Gas Swaps", "Clay
Basin Gas Storage", and "Pipeline Reservation Fees" and explain what negative values and
positive values represent.
REQUEST NO. 155: Please provide the workpapers in electronic format with formula
intact that calculates the costs of the Blundell project.
REQUEST NO. 156: Page l l of Mr. Wilding's Confidential Direct Testimony states
that the CAISO prices used to calculate the scalars are capped between a"dI
I Please explain how these values are determined and provide workpapers in electronic
format with formula intact that calculate the values.
REQUEST NO. 157: Page24 of Mr. Wilding's Confidential Direct Testimony states
that the NPC forecast includes approximately in EIM benefits and ln
GHG revenue. Please provide the workpapers in electronic format with formula intact that
calculate these two values.
REQUEST NO. 158: Does the recent BPA rate case have an impact on the wheeling
costs and the NPC? If so, please quantiff the impact and provide an updated "ID
GRC2l_Wheeling CONF" workpaper in electronic format with formula intact.
REQUEST NO. 159: Please quantify the impact of using the latest OFPC on the NPC
and provide updated ID GRC2I_Fuel Price (2103) CONF" and "ID GRc2l_Market Price Index
(2103) CONF" workpapers in electronic format with formula intact.
REQUEST NO. 160: Please update the following workpapers in electronic format with
formula intact to reflect the use of the latest OFPC and the recent BPA rate case.
a. Exhibit No. 37 - GRID Model NPC Report CONF
b. Confidential Exhibit No. 37 - GzuD Model NPC Report
c. ID GRC21 Testimony Support CONF
REDACTED FIFTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 AUGUST I2,2O2I
DATED at Boise, Idaho, ur6l2lF* of August 2021.
\
Deputy Attorney General
i:umisc:prodreq/paee2l.TdhmlUl prod req 5
REDACTED FIFTH PRODUCTION REQI.]EST
TO ROCKY MOUNTAIN POWER 5 AUGUST I2,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS |2th DAY OF AUGUST 2021,
SERVED THE FOREGOING REDACTED FIFTH PRODUCTION REQUEST OF
THE COMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE
NO. PAC-E-21-07, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@paci f-rcorp.con r
idahodockels@pac ifi corp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareq uest@pacifi corn.com
ANTHONY YANKEL
I27OO LAKE AVE
UNIT 2505
LAKEWOOD OH 44107
E-MAIL: [e-mail]
BRIAN C COLLINS
MAURICE BRUBAKER
BRUBAKER & ASSOCIATES
16690 SWINGLEY RIDGE RD #140
CHESTERFTELD MO 63017
E-MAIL: bcollins tbai.com
[e-mail]
LANCE KAUFMAN
AEGIS INSIGHT
E-MAIL: [e-mail]
EMILY L WEGENER
MATTHEW D McVEE
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL : emi ly.wegenerfa)pacif icorp. conl
matth e r,v. mc vee@ pac i fl co rp. c o m
ERIC L OLSEN
ECHO HAWK & OLSEN PLLC
PO BOX 61 19
POCATELLO ID 83205
E-MAIL: [e-mail]
RANDALL C BUDGE
THOMAS J BUDGE
RACINE OLSON
PO BOX 1391
POCATELLO TD 83204
E-MAIL: rand.,[e-mail]
[e-mail]
JAMES R SMITH
MIKE VEILE
BAYER CORPORATION
E-MAIL: [e-mail]
[e-mail]
KEVIN HIGGINS
COURTNEY HIGGINS
MILLI PICHARO
NEAL TOWNSEND
ENERGY STRATEGIES
E-MAIL : khi ggins(0lenergystrat.com
chiegins@energ),strat.com
[e-mail]
[e-mail]
CERTIFICATE OF SERVICE
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
PO BOX 388
BOISE ID 8370I
E-MAIL: [e-mail]
ADAM GARDNER
IDAHOAN FOODS
E-MAIL: [e-mail]
VAL STEINER
ITAFOS CONDA LLC
E-MAIL: [e-mail]
BRAD M PURDY
ATTORNEY AT LAW
2OI9 N 17TH ST
BOISE ID 83702
E-MAIL: [e-mail]
BRADLEY G MULLINS
MW ANALYTICS ENERGY
E-MAIL: [e-mail]
KYLE WILLIAMS
BYU IDAHO
E-MAIL: williamsk@.byui.edu
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH ST
BOISE TD 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE