20230505Staff 18 to PAC.pdf

CHRIS BURDIN ED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION ÃM U:5POBOX83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )ROCKY MOUNTATN POWER FOR A )CASE NO.PAC-E-23-01
CERTIFICATE OF PUBLIC CONVENIENCE )AND NECESSITY AUTHORIZING )CONTRUCTION OF THE BOARDMAN-TO-)SECOND PRODUCTIONHEMMINGWAY500-KV TRANSMISSION )REQUESTOF THE
LINE PROJECT )COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Chris Burdin,Deputy Attorney General,requests that Rocky Mountain Power provide the
followingdocuments and information as soon as possible,but no later than
FRIDAY,MAY 12,2023.1
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.
Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff'sattorneyat(208)334-0314.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 MAY 5,2023
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 identify 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.
REQUESTNO.18:The Company's Application included Exhibit 1,the Term Sheet,
listing multipleagreements between the Company,Bonneville Power Administration ("BPA")
and Idaho Power Company ("IPC").Many of the agreements were set to be executed after BPA
completed its environmental review process and decided how to proceed.BPA issued its
affirmative decision on March 23,2023.Please provide the following:
a.a narrative update on the status of each agreement outlined in the Term Sheet,
with special thoroughness provided to the various agreements in line item 1 of the
Term Sheet (agreements related to service delivery in central Oregon);and
b.a text-searchable copy of each finalized agreement.
DATED at Boise,Idaho,this day of May 2023.
Chris Bur m
Deputy Attorney General
i:umisc:prodreq/pace23.lcbms prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 5,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5th DAY OF MAY 2023,SERVED
THE FOREGOING SECOND PRODUCTION REQUESTOF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-23-01,BY
E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOHN HUTCHINGS
ROCKY MOUNTAIN POWER CARLA SCARSELLA
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WEST NORTH TEMPLE STE 330
E-MAIL:[e-mail] SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER KATHERINE McDOWELL
E-MAIL ONLY:ADAM LOWNEY
[e-mail] McDOWELL RACKNER GIBSON
419 SW llTHAVE STE 400
PORTLAND OR 97205
E-MAIL:katherine mre-law.com
adam mrg-law.com
ERIC L OLSEN LANCE KAUFMAN PhD
ECHO HAWK &OLSEN PLLC 2623 NW BLUEBELL PLACE
PO BOX 6119 CORVALLIS OR 97330
POCATELLO ID 83205 E-MAIL:lance aegisinsight.com
E-MAIL:[e-mail]
THOMAS J BUDGE BRIAN C COLLINS
RACINE OLSON PLLP GREG MEYER
PO BOX 1391 BRUBAKER &ASSOCIATES
POCATELLO ID 83204-1391 16690 SWINGLEY RIDGE RD,#140
E-MAIL:[e-mail] CHESTERFIELD MO 63017
E-MAIL:bcollins consultbai.com
emeverŠconsultbai.com
SECRE ARY
CERTIFICATE OF SERVICE