20210421Staff 6-7 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:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLTC 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
CASE NO. PAC-E.2I.08
SECOND 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 WEDNESDAY,
MAY 12,2021.
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
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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. 6: Referencing Production Request No. 1, please provide the number of
RECs and the value of the RECS that would be allocated to Bayer if a SE (Energy) allocation
factor was used for each year from 2017 to 2021. Please provide the calculations in Excel
format, with formulas enabled.
REQUEST NO. 7: Please provide specific explanations and direct evidence to support
each of the requirements identified under ldaho Code $ 6l-328(3):
a. That the transaction is consistent with the public interest;
b. That the cost and rates for supplying service will not be increased by reason of
such transaction; and
c. That the applicant for such acquisition or transfer has the bona-fide intent and
financial ability to operate and maintain said property in the public service.
DATED at Boise, Idaho, this Artt day of Apr 1l2o2l.
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Edward
Deputy
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Att#rey General
i:umisc:prodreq/pace2l.8ejtt prod req2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 2I,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2I't DAY OF APRIL 2021,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC-E-2I-08, BY E-MAILTNG A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOI.JNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi coro.com
idahodockets@pac ifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@oaci fi corp.com
ADAM LOWNEY
MCDOWELL RACKNER GIBSON PC
419 SW 1lth AVE., SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
RANDY BUDGE
RACINE OLSON, PLLC
2OI EAST CENTER
POCATELLO ID 83204
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE