20200623Staff 1-2 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
I 1331 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 THE APPLICATION FOR
APPROVAL OF TIIE POWER PURCHASE
AGREEMENT BETWEEN PACIFICORP AND
COMMERCIAL ENERGY MANAGEMENT,
INC.
CASE NO. PAC.E.2O.O9
FIRST PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of
record, Edward Jewell, 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 MOUNTAIN POWER
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I JLrNE 23,2020
the person preparing the documents. Please identifi, 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 and electronic files on CD with formulas activated.
REQUEST NO. 1: Since the approval of the 1991 contract, has the Company
encountered actual capacity deficiency period(s)? Please provide a list of all generation facilities
or power purchase agreements that were added to meet the need for capacity during the
period(s).
REQUEST NO. 2: Please submit the signature page of the Amendment with complete
signatures from the QF and the Company.
DATED at Boise, Idaho, this 1\,)
day ofJune 2020
Edward J
Deputy A General
i:umisc:prodreq lpac*}.9eyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JI-jNE 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 POWE& IN CASE NO. PAC-E-20-09, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
JACOB A McDERMOTT
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Jacob.mcdermott@f acifi corp. com
idahg.dockets @pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareqqeqt@papifi corp. com
ADAM LOWNEY
McDOWELL RACKNER GIBSON
4I9 SW I ITH AVE SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
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CERTIFICATE OF SERVICE