20220413Staff 1-4 to PAC.pdf

CHRIS BURDIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
Q08) 334-0314
IDAHO BAR NO. 98IO
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Street Address for Express Mail:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 837I4
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ROCKY MOUNTATN POWER REQUESTING
APPROVAL OF $28.4 MILLION ECAM
DEFERRAL
CASE NO. PAC.E-22.05
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOT]NTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Chris Burdin, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than
WEDNESDAY, APRrL 27, 2022.r
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 Strffir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 APRIL 13,2022
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 also 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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide a schedule showing the amount of energy imbalance
market ("EIM") benefits, on a system and ldaho basis, the Company has received per year since
the Company joined the EIM. In the response, please include the total benefits to all participants
in the EIM for each year.
REQUEST NO.2: Please provide the Califomia Independent System Operator
("CAISO") report on the benefits of the EIM for 2018,2019,2020, and202l.
REQUEST NO.3: Please provide the journal entries and invoices supporting the EIM
body of state regulators ("BOSR") expenses and the Western Resource Adequacy Program
("WRAP") expenses the Company is requesting to recover in this Application.
REQUEST NO. 4: Please provide supporting documentation for the ID REP QF
Adjustment as referenced on page 1l of Jack Painter's Direct Testimony. In the response, please
include the calculation for the reasonable energy price, the costs for the QF projects, and the case
numbers approving those contracts.
DATED at Boise, Idaho, this l5& day of April2022
Chris Burdin
Deputy Attorney General
i:umisc:prodreq/pace22.5 cbjt prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 2 APRIL 13,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF APRIL 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
C0MMISSTON STAFF TO ROCKY MOUNTAIN POWE& IN CASE NO.
PAC.E-22-05, BY E.MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL : ted.weston@.pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
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SECRETARY/
CERTIFICATE OF SERVICE