20200731Staff 9-12 to PAC.pdf

REOEIVES
20?0 JUL 3l Pl{ l: 03MATT HTJNTER
DtsPU'fY AI*I'ORNEY GENERAL
IDAI]O PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE. IDAHO 83720-007 4
(208) 334-03 r8
iDAHO BAR NO. 10655
- : r'l-.U!-l&:, j'll)*i'td9tslt8{.i
Street Address for Express Mail:
I133I W CHINDEN BVI,D, BLDG 8, SUITE 20I-A
BOISE, ID 837I4
Al.tomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION II-OR APPROVAL OF )CASE NO. PAC.E-20-07
POWER PURCHASE AGREEMENT BETWEEN
PACIFICORP AND BIRCH HYDRO COMPANY
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staffofthe Idaho Public Utilities Commission, by and through its attomey ofrecord,
Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide the
lbllowing documents and information as soon as possible, but no later than WEDNESDAY,
AUGUST s,2020.1
This Production Request is to be considered as continuing, and Rocky Mountain Power is
requested to provide, by way ofsupplemenlary responses, additional documents that it, or any
person acting on its behalf, may later obtain that will augment the documents or information
produced.
I Staff is requesting an expedited response. lfresponding by this date will be problenratic, please call Stafls
attorney at (208) 334-01I 8.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
)
)
)
)
)
)
)
JULY 31,2020
PIease provide ans\4€rs to each question. supporling workpapers that provide detail or are
the source of information used in calculations, and the namc,job title, and telephone number of
the person preparing the documents. Please identifo 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. 9: Piease provjde the f'ull rate schedule of Fixed Energy Rates lisled In
the Restated Appendix B ofthe Second Amended Power Purchase Agreement. The full schedule
should include different online years.
RtrQUIiST NO. l0: Please plovide the ordcr number and casc number that approved
the rate schedule mentioned above.
REQUEST NO. ll: Firm Market Price Index is defined on Page No. 4 of the Power
Purchase Agleement as "the hourly value calculated based on the average prices reported by the
Intercontinental Exchange. Inc. ("lCE'') Day-Ahead PV On-Peak Index and the ICE Day-Ahead
PV Ol'f-peak Index (each an "lCE Index") 1br a given day, rveighted hy the count ofhours for
each ICE Index on such day, multiplied by the hourly CAISO day-ahead market locational
marginal price for the'PACE. DGAP_PACE-APND' location and divided by the average of thc
same CAISO index over all hours in such day." Please ansn'er the tbllowing queslions.
a. The definition uses l)ay-Ahead PV On-Peak Index and Off'-Pea} Index. Does PV
refer to Palo Verde Hub?
b. Please explain why the index prices adjusted by the locational marginal prices in the
CAISO represent the best market price relative to the utilities avoided cos1.
c. Please explain rvhy the Mid-Columbia IIub is not used Io determine index prices.
d. What localion is PACE. DGAP_PACE-APND?
e. How are the hourly prices underthis method averaged al the monthly level for the
pr.lrposes of the 90/l 10 requirement? Please provide an example.
REQUEST NO. 12: [xhibit K of the I)ower Purchase Agreen]ent stales that Mid-C-85
is cqual to "8596 ol rveighted average of the average Index Price fbr the month, or portion ol'
month, ofNet Output." Please answer the lollorving qulsLions.
SECOND PRODUCTION REQUEST
1'O ROCKY MOUNTAIN POWER JUI-Y 31 , 20202
a. The Agreement does not provide a definition of Index Price. Please define Index
Price.
b. Please reconcile the use ofMid-C in Exhibit K and the use ofPV (assumed to be Palo
Verde) in the definition of Firm Market Price Index.
DATED at Boise, Idaho, this 3 / Faay of July 2020.
@
Matt Hunter
Deputy Attomey General
i:umisc:prodEq/pace20.7mhyy ptDd rEq 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J IULY 31,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3IST DAY OF JULY 2020, SERVED
THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWE& IN CASE NO. PAC.E.2O.O7, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOLINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
idahodocketst2pacilicom.com
JACOB A MCDERMOTT
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 320
SALT LAKE CITY UT 84] 16
E-MAIL: Jacob.mcdermott@pacifi com.com
ADAMLOWNEY
McDOWELL RACKNER GIBSON
4I9 SW I ITH AVE SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datareouest@oacifi corp.com
SECRETAR
CERTIFICATE OF SERVICE