20231117Staff 11-14 to PAC.pdf

ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL ou 9.09
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.10221
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )POWER'S APPLICATION TO UPDATE )CASE NO.PAC-E-23-20LOADANDGASFORECASTSUSEDINTHE)INTEGRATED RESOURCE PLAN AVOIDED )COST MODEL )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 24,2023.1
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
I Staff is requesting an expedited response.If responding by this date will be problematic,please call Staff's
attorney at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 NOVEMBER 17,2023
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 response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
RESPONSE NO.11:Response to Staff Production Request No.1 states "[a]ll customers
are expected to stop taking wholesale service under Federal Energy Regulatory Commission
(FERC)tariffs by July 1,2027.Please respond to the following:
a.Please list all the customers that are currentlytaking wholesale service under the
FERC tariffs;
b.Please explain the difference between customers under FERC tariffs and
customers under retail tariffs;
c.Please explain why all customers are expected to stop taking wholesale service by
July 1,2027;
d.Please explain the significance of July 1,2027;and
e.Table 1 of the Application shows that there is a small amount of FERC wholesale
load after 2027 in last year's load forecast.Please explain why there is still some
amount of FERC wholesale load after 2027 in last year's load forecast,but not in
the most recent proposed load forecast,and explain how that amount is
determined.
RESPONSE NO.12:Response to Staff Production Request No.3 states that one of the
reasons whythe 2023 load forecast is lower than the 2022 load forecast is due to lower
expectations for a large customer.Please respond to the following:
a.Please provide the identity of the large customer;and
b.Please explain why there is a lower expectation for its load.
RESPONSE NO.13:Response to Staff Production Request No.5 (a)states that
secondary prices use a basis estimate to the most relevantprimary curve in the market period.
Please respond to the following.
a.Please define "secondary prices";and
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER 17,2023
b.Please explain the purposes of developing "secondary prices"and how
"secondary prices"are used for each purpose.
RESPONSE NO.14:Response to Staff Production Request No.5 (c)states that the
Company uses a basis differential to a nearby market point to derive the prices of less liquid
market points.Please respond to the following:
a.Please define "market points"and list all the "market points";
b.Please define "less liquid market points"and list all the "less liquid market
points";
c.Please explain how a basis differential is determined;and
d.Please provide an example to illustrate how the Company uses a basis differential
to a nearby market point to derive the prices of less liquid market points.
DATED at Boise,Idaho,this day of November 2023.
Adam Triplett
Deputy AttorneyGeneral
i:umise:prodreq/PAC-E-23-20 PR#2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 NOVEMBER 17,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 17th DAY OF NOVEMBER 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.PAC-E-
23-20,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]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE