20230425Staff 1-7 to PAC.pdf

DAYN HARDIE ED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION a PM (:9
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION REQUESTING )CASE NO.PAC-E-23-09
APPROVAL OF $32.5 MILLION ECAM )DEFERRAL )
)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY,MAY 2,2023.1
This Production Request is to be considered as continuing,and the Company 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.
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 telephonenumber of
Staffis 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 l APRIL 25,2023
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
In addition to the written copies provided as responses to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please explain the Company's acceleration toward dispatching
natural gas fueled generation in late 2022 (i.e.Sep,Oct,Nov,and Dec)compared to its coal fired
generation,when considering the higher dispatch cost of natural gas generationrelative to coal
generation during this period.
REQUESTNO.2:Please provide the duration and amount of generation (in MWh(s))
lost for forced downtime (unscheduled)that Company-owned generation facilities/units
experienced each month during the deferral period.For each forced downtime,please explain the
cause and resolution of the downtime.
REQUESTNO.3:For each of the Company's coal plants,please describe the typical
timeline experienced for placing an order for coal to receiving the coal delivery at the plant.
REQUESTNO.4:For all Company coal plants,please describe the Company's
guidelines for maintaining adequate coal supplies and quantify,for each unit,the supply of coal
held on-site for fuelingthe unit.Please provide this information in the followingunits:ton(s),
MMBtu(s),and equivalent MWh(s).
REQUESTNO.5:For each of the Company's coal units please provide the average
coal supply held for generationper month from 2017 through 2022.Please provide these values
in units of ton(s),MMBtu(s),and MWh(s).
REQUESTNO.6:Please provide details of any coal supply issues in 2022 that
prevented the economic dispatch of a Company coal unit.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 APRIL 25,2023
REQUESTNO.7:Please provide the supporting documentation for the Wind
AvailabilityLiquidated Damages on line 27 of Exhibit No.1.
DATED at Boise,Idaho,this day of April 2023.
Deputy Attorney General
i:umisc:prodreq/pace23.9dhtj prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 APRIL 25,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 25th DAY OF APRIL 2023,SERVED
THE FOREGOING FIRST PRODUCTION REQUESTOF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-23-09,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
MARK ALDER DATA REQUEST RESPONSE CENTER
JOE DALLAS E-MAIL ONLY:
ROCKY MOUNTAIN POWER [e-mail]
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
SECRE
CERTIFICATE OF SERVICE