20200623Staff 1-7 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BAR NO. 9917
ftgCEIVf;B
ii?t JU-'{ aS pH 3: l9
.. ,] ",:'i ;rl-'.:;i-l$ti' l i,*$ C{}iJh{tb*Sl&l{
Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys 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
FALL RIVER ELECTRIC COOPERATIVE, INC.
CASE NO. PAC.E-20-10
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,
Dayn Hardie, 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
the person preparing the documents. Please also identifr the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
)
)
)
)
)
)
)
1 JLrNE 23,2020
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic hles on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide a copy of the approved agreement the parties are
currently operating under with all amendments.
REQUEST NO. 2: Please provide the full schedule of Fixed Energy Rates, if they are
used in the agreement the parties are currently operating under.
REQUEST NO. 3: Please provide the order number and case number that approved the
schedule mentioned above.
REQUEST NO. 4: When was the current nameplate capacity of 7 .45 MW installed?
Has the current nameplate capacity been approved by the Commission in previous orders?
REQUEST NO. 5: Since the QF installed the 7.45 MW nameplate capacity, 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 the
any periods of deficiency.
REQUEST NO. 6: 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.
REQUEST NO. 7: Please explain why the Firm Market Price is calculated differently
than in prior PURPA contracts, including Case Nos. PAC-E-I7-08 and PAC-E-17-14.
FIRST PRODUCTION REQUEST
TO ROCKY MOLTNTAIN POWER JI-INE 23,20202
DATED at Boise, Idaho, thtsLS day of June 2020.
Deputy Attorney General
i:umisc:prodreq/pace20. I 0dhyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOTJNTAIN POWER 3 JUNE 23,2020
CERTIFICATE OF SERVICE
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, IN CASE NO. PAC-E-20-10, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWNG:
TED WESTON
ROCKY MOLINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi com.com
JACOB A MoDERMOTT
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: Jacob.
[e-mail]
CERTIFICATE OF SERVICE