20200623Staff 1-8 to PAC.pdf

MATT HI]NTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
1 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BBFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR APPROVAL OF
POWER PURCHASE AGRBEMENT BETWEEN
PACIFICORP AND BIRCH HYDRO COMPANY
CASE NO. PAC.E-20-07
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than TUESDAY'
JULY 14,2020.
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.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER
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1 JUNE 23,2020
the person preparing the documents. Please identifu 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.
REQUEST NO. 1: Is the Second Amended Power Purchase Agreement included in the
Application the current approved contract? If not, please provide a copy of the complete
currently approved contract with all amendments.
REQUEST NO.2: Please provide the full schedule of Fixed Energy Rates listed in the
Restated Appendix B of the Second Amended Power Purchase Agreement.
REQUEST NO.3: Please provide the order number and case number that approved the
schedule mentioned above.
REQUEST NO. 4: What is the most recently approved nameplate capacity of this
project? Please provide proofofthe approval.
REQUEST NO. 5: When was the current 2,650 kW turbine-generator installed? Has
the current nameplate capacity of 2,650 kW been approved by the Commission?
REQUEST NO. 6: Since the QF installed the new 2,650 kW turbine-generator, has the
Company encountered actual capacity deficiency periods? Please provide a list all generation
facilities or power purchase agreements that were added to meet the need for capacity during this
periodIs].
REQUEST NO. 7: Please provide an example of how the Firm Market Price Index is
calculated as described on page 4 of the proposed Power Purchase Agreement included in the
Application.
FIRST PRODUCTION REQUEST
TO ROCKY MOLINTATN POWER 2 JUNE 23,2020
REQUEST NO. 8: Please explain why the Firm Market Price is calculated differently
than in prior PURPA contracts such as in Case Nos. PAC-E-17-08 and PAC-E-1,7-14.
DATED at Boise,Idaho, tns /$daay of June 2020.
Matt Hunter
Deputy Attorney General
i:umisc:prodreq/pace20.7mhyy prod rcq I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J JUNE 23,2020
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF JUNE 2020, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF' THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, N CASE NO. PAC-E-2Q-07, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
JACOB A MoDERMOTT
ROCKY MOI.INTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.westqn@nacifi corp. com
Jacob.mcde{mott@pacifi com. com
idahodockets@pacifi corp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
4atarequest@nacifi corp. com
ADAM LOWNEY
McDOWELL RACKNER GIBSON
419 SW l ITH AVE SUITE 4OO
PORTLAND OR 97205
E-MAIL:-law.com
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SECRETo*Y
CERTIFICATE OF SERVICE