20150317Staff 1-4 to PAC.pdf

DONALD L. HOWELL, II
DAPHNE HUANG
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 3 34-0 3 12t 33 4-03 18
IDAHO BAR NOS ,336618370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorneys for the Commission Staff
IN THE MATTER OF ROCKY MOUNTAIN
POWER COMPANY'S PETITION TO MODIFY
TERMS AND CONDITIONS OF PURPA
PURCHASE AGREEMENTS.
CASE NO. PAC-E.15.03
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ROCKY MOUNTAIN POWER
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attomeys of
record, Donald L. Howell and Daphne Huang, Deputy Attorneys General, request that Rocky
Mountain Power (Company; Rocky Mountain; PacifiCorp) provide the following documents and
information as soon as possible, by TUESDAY, APRIL 7,2015.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER MARCH 17 ,2015
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
3l.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please clarify whether PacifiCorp's request to limit PURPA contract
length to a maximum of 20 years is limited to IRP-based contracts only, or whether it is intended
to include published rate contracts. If it is limited to only IRP-based contracts, please explain
why published rate contracts do not present the same price risk as discussed in the Company's
Petition, and why PacifiCorp is not requesting to limit contract length for published rate
contracts.
REQUEST NO.2: On page 10, lines 7-15 of Brian Dickman's direct testimony, Mr.
Dickman discusses the impact on avoided cost rates if proposed QFs are included in the
calculation of the IRP-based avoided cost rates. Please provide spreadsheets, analysis, models or
other documentation supporting calculation of the $18 per MWh difference between including
and not including approximately 3,000 MW of proposed QFs in the pricing queue.
REQUEST NO.3: Please provide a list of proposed Idaho PURPA projects currently
seeking contracts with PacifiCorp. For each project, please indicate the following: name of the
project, developer, project location, the utility service territory in which the proposed project is
located, nameplate capacity, technology type (e.g., solar PV, hydro, wind, etc.), proposed online
date, date of indicative pricing request, and date on which indicative prices were provided to the
project developer.
REQUEST NO. 4: If the Commission were to approve PacifiCorp's request to include
proposed QFs in the calculation of the indicative pricing to be provided QFs in the queue, has the
Company developed criteria to address management of the queue? For example, what criteria
would be applied to determine such things as when projects enter the queue, when projects drop
out of the queue, when recalculation of prices occurs, which projects are subject to re-pricing,
etc?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER MARCH I7,2OI5
Dated at Boise, Idaho, this l'(\rrof March 2015.
Technical Staff: Rick Sterling
Yao Yin
i:umisc:prodrcqlpacclS.3dhdjhrpsyy prod rcql
FIRST PRODUCTIOII REQUEST
TO ROCKY MOUNTAIN POWER
Deputy Attorney General
MARCH I7,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITTH DAY oF MARCH 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
C0MMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE NOS.
IPC-E-I5-O1iPAC-E-15-03/AVU-E-15-OI, BY MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail: [e-mail]
dockets@idahopower. com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-mail: [e-mail]
DEAN J MILLER
McDEVITT & MILLER LLP
420 W BANNOCK ST
BOISE TD 83702
E-mail: ioe(Emcdevitt-miller.com
KELSEY JAE NUNEZ
SNAKE RIVER ALLIANCE
PO BOX l73l
BOISE ID 83701
E-mail: [e-mail]
TED WESTON
ID REG AFFAIRS MANAGER
ROCKY MOUNTAIN POWER
201 S MATN ST STE 23OO
SALT LAKE CITY UT 84I11
E-mail: [e-mail]
PETER J RICHARDSON
GREGORY M ADAMS
RICHARDSON ADAMS PLLC
PO BOX 7218
BOISE ID 83702
E-mail: [e-mail]
gre [e-mail]
BENJAMIN J OTTO
ID CONSERVATION LEAGUE
7IO N 6TH STREET
BOISE TD 83702
E-mail: [e-mail]
LEIF ELGETHI.IN
INTERMOUNTAIN ENERGY PARTNERS
LLC
PO BOX 7354
BOISE ID 83707
E-mail: [e-mail]
KEN MILLER
SNAKE RIVER ALLIANCE
E-MAIL ONLY:
kmiller@ snakeriveralliance. org
DANTEL E SOLANDER
WONNE R HOGLE
ROCKY MOLINTAIN POWER
201 S MATN ST STE 24OO
SALT LAKE CITY UT 84I I1
E-mail : [e-mail]
yvonne. ho gel @pac i fi corp. com
CERTIFICATE OF SERVICE
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. com
ERIN CECIL
ARKOOSH LAW OFFICES
E.MAIL ONLY
erin. cecil@arkoosh. com
ANTHONY YANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44104
E-mail: tonv@.yankel.net
IRION SANGER
SANGER LAW PC
I117 SW 53RD AVE
PORTLAND OR 97215
E-mail : [e-mail]
CLINT KALICH
AVISTA CORPORATION
I411 E MISSION AVE
MSC-23
SPOKANE W A 99202
E-mail: [e-mail]
RTCHARD MALMGREN
SR ASSIST GEN COUNSEL
MICRON TECHNOLOGY INC
8OO S FEDERAL WAY
BOISE ID 83716
E-mail: [e-mail]
C TOM ARKOOSH
ARKOOSH LAW OFFICES
PO BOX 2900
BOISE ID 83701
E-mail : [e-mail]
ERIC L OLSEN
RACINE OLSON NYE BUDGE
& BAILEY
PO BOX 1391
POCATELLO ID 83204-1391
E-mail: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
IO15 W HAYS ST
BOISE ID 83702
E-mail: [e-mail]
MICHAEL G ANDREA
AVISTA CORPORATION
14118 MISSION AVE
MSC-23
SPOKANE WA992O2
E-mail : [e-mail]
MATT VESPA
SIERRA CLUB
85 SECOND ST 2ND FLOOR
SAN FRANCISCO CA 94105
E-mail: [e-mail]
FREDERICK J SCHMIDT
PAMELA S HOWLAND
HOLLAND & HART LLP
377 S NEVADA ST
CARSON CITY NV 89703
E-mail : [e-mail]
CERTIFICATE OF SERVICE
SCOTT DALE BLICKENSTAFF
AMALGAMATED SUGAR CO
1951 S SATURN WAY
sTE 100
BOISE TD 83702
E-mail : [e-mail]
CERTIFICATE OF SERVICE