20230406Bayer 1-5 to PAC.pdf

BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 1
Thomas J. Budge, ISB No. 7465 Elisheva M. Patterson, ISB No. 11746
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 [phone] [e-mail]
[e-mail]
Attorney for P4 Production, L.L.C., a subsidiary of Bayer Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR A CERTIFICATE OF CONVENIENCE AND
NECESSITY AUTHORIZING
CONSTRUCTION OF THE BOARDMAN-TO-HEMINGWAY 500-KV TRANSMISSION
CASE NO. PAC-E-23-01 BAYER’S FIRST SET OF
PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER
P4 Production, L.L.C., an affiliate of Bayer Corporation (“Bayer”), by and through
counsel, submits this first set of production requests to Rocky Mountain Power (“RMP”)
pursuant to Rule 225 of the Commission’s Rules of Procedure, IDAPA 31.01.01.225.
These productions request are to be considered continuing; therefore, RMP should
provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that are responsive to these requests.
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 identify the name, job title, location, and telephone
number of the record holder. Please provide all Excel and other electronic files on a thumb drive
or via email or other electric communication with formulas intact and activated.
The term “production requests” as used herein includes written interrogatories and
requests for admission.

RECEIVED
Thursday, April 6, 2023 2:36:48 PM
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 2
Production Requests
Request No. 1: Please provide all production requests served on RMP by Commission
Staff or other parties. Request No. 2: Please provide a copy of your responses to production requests received from Commission Staff and other parties.
Request No. 3: Please provide a copy of the workpapers supporting the Application filed in this matter. To the extent that the workpapers include any spreadsheets or models, please provide in executable native format with all formulas intact.
Request No. 4: Please identify by name and case number all applications filed by RMP
or an affiliate in other jurisdictions for a certificate of public convenience and necessity or similar approval for the Boardman to Hemmingway project. Request No. 5: If RMP anticipates filing an application in other jurisdictions for a
certificate of public convenience and necessity or similar approval for the Boardman to
Hemingway project, please identify the jurisdiction in which RMP anticipates filing such application and the anticipated filing date. DATED this 6th day of April, 2023.

RACINE OLSON, PLLP
By: ___________________________
THOMAS J. BUDGE
BAYER’S FIRST SET OF PRODUCTION REQUESTS TO ROCKY MOUNTAIN POWER 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of April, 2023, I served a true, correct and
complete copy of the foregoing document by email to each of the following: Idaho Public Utilities Commission Commission Secretary
P.O. Box 83720
Boise, ID 83720-0074 [e-mail] Chris Burdin, Deputy Attorney General
[e-mail]
PacifiCorp Data Request Response Center [e-mail]

Mark Alder Idaho Regulatory Affairs Manager Rocky Mountain Power [e-mail]

John Hutchings Carla Scarsella Rocky Mountain Power [e-mail]
[e-mail]
Katherine McDowell Adam Lowney (ID #10456) McDowell Rackner & Gibson PC
[e-mail]
[e-mail] Idaho Irrigation Pumpers Association Eric L. Olsen
Echo Hawk & Olsen, PLLC
[e-mail] Lance Kaufman, Ph.D.

_________________________________ THOMAS J. BUDGE