20210408Staff 1-5 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTTLITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
nii
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT
APPLICATION OF ROCKY MOUNTAIN
POWER AND P4 PRODUCTION, L.L.C.
REQUESTING APPROVAL OF AN
AGREEMENT TO RETIRE RECS FIRST 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, Edward Jewell, Deputy Attomey General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than THURSDAY,
APRrL 29,2021.
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
)
)
)
)
)
)
)
)
)
CASE NO. PAC.E-21.08
1 APRIL 8,2021
the person preparing the documents. Please identifu 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: On page 2 of the P4 REC Agreement, the Company states that "P4's
share of RECs allocated to Idaho will be proportional to P4's Idaho load for the Reporting Year."
Under the Company's proposal, what would have been Bayer's allocation of RECs for each year
2017-2020? Please provide the calculations in Excel format, with formulas enabled.
REQUEST NO.2: Please provide the number of RECs set to be retired for P4 in202l.
REQUEST NO.3: Please provide the number of RECs for the Company dedicated to
Idaho in202l.
REQUEST NO. 4: Please provide the proposed accounting treatment for the $15,000
annual payment from P4 to cover the Company's additional administrative burden for
administering the program.
REQUEST NO. 5: Please provide the controls the Company will use to ensure that Net
Power Costs will not increase for other customers.
DATED at Boise,Idaho, this 8S auy of April 2021.
r(
Edward J
i:umisc:prodreq/pace2l.8ejtt prod reql
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2
Deputy General
APRIL 8,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 8S DAY OF APRIL 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TITE COMMISSION STAF'F
TO ROCKY MOUNTAIN POWER, N CASE NO. PAC-E-21-08, 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: [e-mail]
idahodockets@oac ifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL OIILY:
datareque st@nacifi corp. com
ADAM LOWNEY
MCDOWELL RACKNER GIBSON PC
419 SW 1ld'AVE., SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL : [e-mail]
RANDY BUDGE
RACINE OLSON, PLLC
201 EAST CENTER
POCATELLO ID 83204
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE