20200731Staff 3-5 to PAC.pdf

EDWARD JEWELL
DtsPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAIIO BAR NO. I0446
Fl[e EIVEB
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 20I-A
BOISE, ID 837I4
Artorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR
APPROVAL OF THE POWER PURCHASE
AGREEMENT BETWEEN PACIFICORP AND
COMMERCIAL ENERGY MANAGEMENT,
INC.
CASE NO. PAC-E-20-09
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Smff of the Idaho Public Utilities Commission, by and through its attomey of
record. Edward Jewell, Deputy Attomey General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than FRIDAY'
AUGUST 14,2020.1
This Production Rcqucst is to bc considcrcd as continuing, and Rocky Mountain Power is
requested to provide, by uay ofsupplementary responses, additional documents that it or any
person acting on its behalfmay later oblain that will augment the documents or intbrmation
produced.
I Staffis requesting an erpedited response. lfrespondi[g by this date will be problematic, pleasc call Staffs a(omey
at (208) 334-03 14.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAiN POWER
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JTJLY 3 l, 2020
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 ol
the person preparing the documents. Please idenrifi,the name,job title, location and telephone
number ofthe record holder.
In addition to the lvritten copies providcd as response to the requesls, please provide all
lxcel and electronic files on CD with formulas activated.
REQUEST NO.3: The updated amendment the Company submitted in response to
Staffs Production Request No. 2 showed the amendmenl was dated l{arch 20,2020. However,
the Application was not filed until June 8, 2020, after the expiration ofthe original 1991
contract. Page No, 4 ofthe Application slales thal duc to no I'ault ofthe Seller the Company was
late filing this Application. Please explain why the Company filed this Application late.
REQUEST NO.4: Page No. 7 olthe 1991 contract stalcd that the scheduled operation
date was January 1992. Page No. 3 of the Application in PAC-D-20-09 stated that the contracl
was scheduled to expire on May 31.2020. Please provide the actual first operation date and the
contract length ofthe l99l contracl.
REQUEST NO. 5: Appendix I olthe l99l conhact described that the avoided cost rates
used included a variable portion and a fixed portion. Please answer the lbllowing:
a, Is the variable porlion subject to the annual update of QF variable energy prices that
occurs each .Iuly I , as in Case No. PAC-E-20-08?
b. If the contract had not expired. what rvould the variable rate have been each month
lbr the period from June 1, 2020 through February 28.2021?
c. The initial avoided cost rate was 49.64 mills per kilowatt-hour, w-hich included a
variable portion of 8,78 mills per kilowaft-hour at that time and a fixed portion of
40,86 mills per kilowatthour, Appendix I ofthe 1991 contracl showed thal this
avoided cost rale u,as for a contract length of20 years. Ifthe Jength of this 1991
contract was greater than 20 years, please explain why the conlract used the rate for a
20-year contract length. Please provide relevant evidence to support the explanation.
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER ?JULY 3I, 2O2O
DATED at Boise, Idaho, this 3(3r dayoflutyzozo.
Deputy General
i:umilo:FodEd?rcc2o9.jyy prod rrq 2
SECOND PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J ruLY 3t,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
STATF TO ROCKY MOUNTAIN PO\ryER, IN CASE NO. PAC-E-20-09, BY
E.MAILING A COPY THEREOF, TO THE FOLLOMNG:
TED WESTON
JACOB A McDERMOTT
ROCKYMOI,NTAIN POWER
I4O7 WESTNORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
Jacob.mcdermott@oacifi corp.com
idahodockets@pacifi corp.com
ADAM LOWNEY
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 com,com
SECRETAR
CERTIFiCATE OF SERVICE