20220104Sierra Club 1-2 to PAC.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF PACIFICORP’S
APPLICATION FOR APPROVAL OF ITS
2021 INTEGRATED RESOURCE PLAN
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CASE NO. PAC-E-21-19
Sierra Club hereby serves its first set of production requests regarding the above-mentioned
docket. Sierra Club requests that PacifiCorp provide responses as expeditiously as possible, but
not later than the deadline of 21 days, which is .
1.Please provide copies of responses to the following contacts:
Rose Monahan
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]
Ana Boyd
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA 94612
[e-mail]
2.Whenever possible, Sierra Club prefers to receive electronic copies of production
responses either by email or on CD.
3.Responses to any and all of Sierra Club’s production requests should be supplied to
Sierra Club as soon as they become available to Idaho Power Company.
4.The requests herein shall be deemed to be continuing in nature and Idaho Power
Company is requested to supplement its responses as necessary and as additional
information becomes available.
5.In responding to each production request, please consult every document source which is
in your possession, custody, or control, including all documents in the possession of
experts or consultants.
6.For each response, identify the person who prepared the answer to the production request
as well as their position with Idaho Power Company or any Idaho Power Company
affiliate or parent.
7.Please reproduce the production request being responded to before the response.

RECEIVED
2022 JAN 04 AM 10:51
IDAHO PUBLIC
UTILITIES COMMISSION
8. If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
9. If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
10. In responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the data, provide a record layout of the
computer files. Computer files provided with a response must be in or compatible with
the current version, or the immediately prior version, of Microsoft Office.
11. For each dollar amount provided in response to a discovery request please state if the
amount is in nominal or constant dollars and what years dollar

FIRST SET OF PRODUCTION REQUESTS

SC 1. Please provide copies of all data requests from and responses to other parties in this
proceeding. This request is continuing in nature.

SC 2. Please provide all materials produced by PacifiCorp in response to data requests
promulgated by Sierra Club in PacifiCorp’s contemporaneous 2021 IRP filing in Oregon
(OPUC Docket No. LC 77).

CERTIFICATE OF SERVICE

I hereby certify that on this 4th day of January 2022, I delivered true and correct copies of
the foregoing to the following persons via the method of service indicated below:

Electronic mail only (see Order 35058)

Idaho Public Utilities Commission
Jan Noriyuki, Secretary
[e-mail]

PacifiCorp
Ted Weston
Emily Wegener
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Commission Staff
Riley Newton
[e-mail]

Idaho Conservation League
Benjamin J. Otto
[e-mail]

/s/ Rose Monahan
Rose Monahan
Staff Attorney
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA 94612
Phone: [phone]
[e-mail]