20220307Sierra Club 3-9 to PAC.pdf

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION - -l -i:i -.i PI it:22
TN THE MAT'TER OF PACIFICORP'S
APPLICATION FOR APPROVAL OF TTS
2021 INTEGRATED RESOURCE PLAN
CASE NO. PAC-E-21-19
SECOND SET OF PRODUCTION REQUESTS OF SIERRA CLT]B TO
PACIFICORP
Sierra Club hereby serves its second set of production requests regarding the above-mentioned
docket. Sierra Club requests that PacifiCorp provide expedited responses no later than Fridav.
March 11. If this will not be possible, please contact Sierra Club's counsel, Rose Monahan, at
the contact information listed below.
INSTRUCTIONS
Please provide copies of responses to the following contacts:
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Rose Monahan
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA946l2
rose. monahan@sierraclub. org
Ana Boyd
Sierra Club Environmental Law Program
2101 Webster Street, Suite 1300
Oakland, CA946l2
ana.boyd@sierraclub. org
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Whenever possible, Sierra Club prefers to receive electronic copies of production
responses either by email or on CD.
Responses to any and all of Sierra Club's production requests should be supplied to
Sierra Club as soon as they become available to PacifiCorp.
The requests herein shall be deemed to be continuing in nature and PacifiCorp is
requested to supplement its responses as necessary and as additional information
becomes available.
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.
For each response, idartify the person who prepared the answer to the production request
as well as their position with PacifiCorp or any PacifiCorp affiliate or parent.
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Please reproduce the production request being responded to before the response.
If the responses include computer modeling input and output files, please provide those
data files in electronic machine readable or txt format.
If the responses include spreadsheet files, please provide those spreadsheet files in
useable electronic Excel readable format.
ln responses providing computer files, list the file names with cross-reference to the data
request, and if necessary to the understanding of the datq 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.
For each dollar arnount provided in response to a discovery request please state ifthe
amount is in nominal or constant dollars and what years dollar
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SECOND SET OF PRODUCTION REOUESTS
Please provide an unredacted copy of PacifiCorp's responses to Administrative Law Judge
Mapes and Administrative Law Judge Rowe's Bench Request issued on February 17,2022
in PacifiCorp's2021IRP filing in Oregon, Docket No. LC-77.
Please provide an unredacted copy, including associated workpapers, of the sensitivity
model run PacifiCorp conducted on behalf of Oregon Commission Staffin Docket No. LC-
TT,whichremoved minimum take requirements at certain coal plants and was titled "ST
OR Studyno JB Minimum."
What is the maximum amount of coal that can be currently stockpiled at both the Bridger
Coal Company mine and at the Jim Bridger plant?
Please refer to attachment ALJ Bench Request 1-l CONF. Please refer to tabs "ST OR
Study no JB Minimum", "ST P02-MM", "ST P02-MM-CETA". Using the same template,
please provide the nameplate and firm capacity provided by each resource.
Please explain whether any of the operating characteristics of the Jim Bridger units were
changed for the Oregon sensitivity run ("ST OR Study no JB Minimum"). Please provide a
list ofany changes and detailed explanation ofeach.
Please explain whether the ST OR Study no JB Minimum required additional adjustments
for the LT portfolio due to unserved energy. If so, please provide a list of any resources that
were added to the final portfolio.
Please refer to Response to ALJ Bench Request l, which states that coal units were allowed
to retire endogenously. Please provide the revenue requirement, FOM, and VOM costs that
were used for the two units in the same format as the "Plexos Input_Existing coal cost_
2IIRP_JB#_20#]0210601 CONF" type of files from the Master Assumptions
workpapers.
CERTIFICATE OF SERYICE
I hereby certify that on this 7th day of March2022,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
secretarv@puc. idaho. sov
PactfiCory
Ted Weston
EmilyWegener
ted. weston@f acifi corp. com
[e-mail]
emilv. weeener@pacifi corp. com
datarequest@pacifi corp. com
Commission Staff
RileyNewton
[e-mail]. eov
Idaho Cons ervation League
Benjamin J. Otto
botto@idahoconservation. ors
/s/ Rose Monahan
Rose Monahan
StaffAttorney
Sierra Club Environmental Law Program
2101 Webster St., Suite 1300
Oakland, CA946l2
Phone: [phone]
[e-mail]