20200731Staff 8-14 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAIIO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
(208) 334-03 l2
IDAHO BAR NO. 99I7
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Street Address for Express Mail:
I I 331 W CHINDEN BLVD, BLDG 8, SUITE 20I.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 POWERPURCHASE
AGREEMENT BETWEEN PACIFICORP AND
}.ALL RJVER ELEC'IRIC COOPERATIVE, INC,
CASE NO. PAC-E-2O.IO
SECOND PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff olthe Idaho Public Utilities Comrnission, by and through its attomey of record,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mounlain Power provide the
following documcnts and inlormation as soon as possible, but no later than MONDAY'
AUGUST 10,2020,1
This Production Request is to be considered as continuing. and Rocky Mountain Power is
requested to provide, by u'ay ofsupplementary responses, additional documenls that it, or any
person acting on its behalf, Inay later obtain lhat will augment the documents or information
produccd.
Please provide answers to each question, supporting workpapers fiat provide detail or are
the source of informalion used in calculations, and the name, job title, and lelephone number of
I Staffis requesting an expedited response. lfresponding by this date will bc problematic, please call Stafls
attomcy at [phone].
SECOND PRODUCTION REQUEST
TO ROCKY MOUF-TAIN POWER
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JULY 3I,2O2O
the person preparing the docr.rments. Please also identi$, the narne, job title, location, and
telephone number of the record holder.
In addition to the w tten copies provided as respons€ to the requesls, please provide all
Excel spreadsheets and electronic files on CD u.ith fbrmulas intact and enabled.
REQUEST NO,8: Please provide the full rate schcdule for Fixed Energy Rates listed rn
Appendix B ofthe 1984 contract. The full schedule should include difflerent online years.
REQUEST NO. 9: Please provide the Order Number and Case Number that approved
the rate schedule nrenlioned above.
REQUEST NO. l0: Firm Market Price Index is defined on Page No.4 of the Porver
Purchase Agreement ("PPA') as ''the hourly value calculated based on the average prices
reported by the Interconlinental Exchange, Inc. ("lClJ") Day-Ahead PV On-Peak Index and the
ICE Day-Ahead PV Ofl'-Peak Index (each an "lCE lndex") lor a given day, weighted by the
count ofhours for each ICE [ndex on such day. multiplied by the hourly CAISO day-ahead
markct locarional marginal pricc fbr thc ''PACE. DOAP_PACE-APND" iocation. and divided by
the average ofthe same CAISO index overall hours in such day." Please ansll'er the follou'ing:
a. The definition uses Day-Ahead PV On-Peak lndex and Ofl'-Peak 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 narkct pricc relative to the utilities avoided cost.
c. Please explain why the Mid-Columbia Hub ("Mid-C'') is not used to determine index
prices.
d. What localion is PACE. DGAP PACE-APND?
e. llow are the hourly prices under this method averaged at the monthly level for the
pr.lrposes ofthe 90/l l0 requirement? Please provide an exanrple.
REQUEST NO. I l: Exhibit K olthe PPA states thal Mid-C-85 is cqual to "85% of
weightcd average ofthc avcragc Firm Nlarkct Pricc Index fbr the month, or portion ofmonth, of
Net Output." Please reconcile the use of Mid-C in Exhibit K and the use of Palo Verde in the
definition of Firm Market Price Index.
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 7 JULY 3I, 2O2O
REQUEST NO. l2: This QF is 7.45 MW, which includes Powerhouse #l (1,950 kW)
and Powerhouse #2 (5,500 kW). Does each powerhouse have its oun meter to measure the
output of each powerhouse?
REQUEST NO. l3: The 1984 contract used levelized rates for the Fixed Energy Rates
and Appendix C ofthe contract states that "the payment Buyer makes to Seller for power
generated is based on Seller's performance during the full term of this Agreement." However,
Powerhouse #1 has not operated since 2006. Please answer the following questions.
a. Due to the nature oflevelized rates, did the parties adjust payment 1o refund the extra
payment because ofoperation of Powerhouse #l ending earlier than the expiration
date?
b. If so, please illustrate how the relund was calculated. lf not, please explain why.
REQUEST NO. 14: Page No. 3 of the Application states that "the Seller has
demonstrated to the Company's reasonable satisfaction that (l) the facility's net energy will
equal the energy delivery schedules for the full tenn of this Agreement; and (2) the likelihood
that the facility. under average design conditions, will generate at no more than 2.5 aMW in any
calendar month." However, the Energy Delivery Schedule on Page No. l6ofthePPAshows
that the months olApril, May, June, and July exceed the 2.5 aMW. Please reconcile the
statement in the Application and the monthly estimates under the Energy Delivery Schedule
section of the contract.
DATED at Boise. Ia*o. tt'rir 3?tFaay of July 2020.
Dayn Hardie
Deputy Atlomey General
irum isc:prodrcq/pac.20. lodhyy prod req 2
SECOND PRODUCTION REQUEST
TO ROCKY MOLINTAIN POWER 3 JULY 31,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31'I DAY OF JULY 2020, SERVED
THE FOREGOTNG FrRST PRODUCTTON REQUEST OF THE COMMISSION
STAFF TO ROCKY MOUNTAIN POWE& IN CASE NO. PAC.E-2O.IO, BY
E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOLINTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston@pacifi com.com
[e-mail]
ADAM LOWNEY
MoDOWELL RACKNER CIBSON
419 SW I ITH AVE SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
GREGORY M ADAMS
PETER J RICHARDSON
zuCHARDSON ADAMS PI-I,C
515 N 27TH STREEI'
BOISE ID 83702
E-MAIL: [e-mail]
peter@richardsonadams,com
JACOB A McDERMOTT
ROCKY MOLINTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I I6
E-MAIL: [e-mail]
DATA RtrQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@naci ficom.com
.to t/,A,*,
SECRETARY_.
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CERTIFICATE OF SERVICE