20210420Staff 1 to PAC.pdf

, , lt a I JMATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION REQUESTING
APPROVAL OF $16.1 MILLION NET POWER
COST DEFERRAL (ECAM)
CASE NO. PAC-E-21-09
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of
record, Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than TUESDAY,
MAY 4,2021.1
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behalf, may later obtain that will augment the documents or information
produced.
I Stuffir requesting an expedited response. If responding by this date will be problematic, please call Staffls
attomey at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
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APRIL 2O,2O2I
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please identi$ 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. l: In Painter's workpaperslPAC-E-21-09 CONFIDENTIAL
Workpapers 3-31-217, please explain the 439,801 megawatt-hour difference in the referenced
total Net System Load identified in Cell *FI8}",Tab"Adjusted Actual NPC'to the summed
monthly values for Total Company Load in Cells "Bl1:Ml1", Tab "ID Actual Loads".
DATED at Boise,Idaho, tnis )faay of April 2021.
Matt Hunter
Deputy Attomey General
i:umisc:prodreq/pace2l. I 0mhyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 2O,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF APRIL 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
CoMMISSION STAFF TO ROCKY MOIINTAIN POWER, IN CASE NO.
PAC-E-21.09, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL OIILY:
datareq uest@pacifi com.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE