20231013Staff 11-12 to PAC.pdf

ADAM TRIPLETT ED
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION AÑ ÍÛ'bl
PO BOX 83720
BOISE, IDAHO 83720-0074 MMISS!ON
[phone]
IDAHO BAR NO. 10221
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 ROCKY MOUNTAIN )POWER'S APPLICATION FOR A )CASE NO.PAC-E-23-18
DEFERRED ACCOUNTING ORDER )RELATED TO INSURANCE COSTS )
)SECOND PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Adam Triplett,Deputy AttorneyGeneral, requests that Rocky Mountain Power ("Company")
provide the followingdocuments and information as soon as possible,but no later than FRIDAY
NOVEMBER 3,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 OCTOBER 13,2023
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 11: Regarding the confidential attachment "IPUC 1-1" please provide
the FERC account that each expense is booked to. Please indicate the Idaho allocation factors for
each account.
REQUEST NO. 12: Please provide insurance expenses that are currently approved and
embedded in Idaho base rates.
./"' DATED at Boise, Idaho, this / --g day of October 2023.
i:umisc:prodreq/PAC-E-23-18 PR #2
SECOND PRODUCTION REQUEST TO ROCKY MOUNTAIN POWER 2
Adam Triplett Deputy Attorney General
OCTOBER 13, 2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13th DAY OF OCTOBER 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO. PAC-E-23-
18,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
MARK ALDER JOE DALLAS
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 825 NE MULTNOMAH ST
SALT LAKE CITY UT 84116 STE 2000
E-MAIL:[e-mail] PORTLAND OR 97232
E-MAIL:[e-mail]
DATAREQUESTRESPONSECENTER
E-MAIL ONLY:
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE