20200818Staff 15-23 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-O3r2
IDAHO BAR NO. 9917
it{:# ilvfi 0
iiir LLiS l8 Pl{ 3: 56
i.' n .'l,i; lj i.liii ii;
. ; i i: i; i-;*i,t F,t tS$loli
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, D 83714
Attomeys 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-8.20.10
THIRD 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,
SEPTEMBER 1, 2O2O.I
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 behall 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
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff's
attorney at [phone].
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
)
)
)
)
)
)
)
)
1 AUGUST T8,2O2O
the person preparing the documents. Please also identify 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. 15: Please describe how the Company processes payments when a QF
produces energy outside the monthly 9Oll10 band. In addition, please answer the following:
a. Does the Company examine every hour that falls outside the 90/110 band and
determine its contract price depending on whether that hour is an On-Peak hour or
an Off-Peak hour? If yes, does the Company do this before comparing against the
85Vo of the market price of that month?
b. Please provide examples to illustrate how the Company identifies hours outside
the 90/110 band and processes payment for these hours, with contract prices that
are below 85Vo of the market price and when they are above 85Vo of the market
price.
REQUEST NO. 16: What level of generation data (frequency, time resolution, etc.) can
the Company collect from the meter installed at the Felt Hydro QF? What kind of data is
actually retained by the Company?
REQUEST NO. 17: Please describe the capabilities of the Company's Accounts
Payable system to process payments to QFs using different rates depending on the amount of
generation over set intervals. Specifically, can the system process payments by applying
different rates based on different ranges of MWhs generated in each hour?
REQUEST NO. 18: Please describe the peak hours used to determine capacity needs in
the Company's IRP. Specifically, please describe how the peak hours are identified and when
these hours occur in the latest IRP.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 AUGUST I8,2O2O
REQUEST NO. 19: In calculating the Load and Resource Balance to identify the first
capacity deficit date in the IRP process, how does the Company determine an existing QF's
resource contribution at peak to meet the Company's need for capacity?
RBQUBST NO.20: Please provide the amount of generation in each hour from the Felt
Hydro QF for the past five years (from 2015 to 2OI9) and indicate how far above or below each
year is to normal water conditions. (If hourly meter data are not available, please provide the
data at the minimal time interval available.)
REQUEST NO.21: On what date in 2006 did Powerhouse #l stop operating?
REQUEST NO.22: Please provide the amount of generation in each hour from the Felt
Hydro QF from 2O03 to 2005 and from2007 to 20[9 and indicate how far above or below each
year is to normal water conditions. (If hourly meter data are not available, please provide the
data at the minimal time interval available.)
REQUEST NO.23: Powerhouse #1 has been offline since 2006. Please answer the
following:
a. When and how did the Company find out that Powerhouse #1 was offline?
b. What does the Company do to ensure that QFs operate normally?
c. What actions does the Company usually take, when the Company finds out that
QFs do not operate normally?
d. Has the Company updated Felt Hydro's contribution at peak in its IRP to reflect
the fact that Powerhouse #1 has been offline since 2006? If so, when did the
Company update it? If not, why not?
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 AUGUST I8,2O2O
,b|ADATED at Boise, Idaho, this day ofAugust 2020.
Dayn
Deputy Attorney General
i:umisc:prodreq@ceZ). lOdhyy prod rcq 3
THrRD PRODUCTION REQLJEST
TO ROCKY MOIJNTAIN POWER 4 AUGUST 18,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 18th DAY OF AUGUST 2020, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-}}-IO, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL: ted.weston @pacificorp.com
idahodockets @ pacifl corp.com
ADAM LOWNEY
McDOWELL RACKNER GIBSON
419 SW 1lTH AVE SUITE 4OO
PORTLAND OR 97205
E-MAIL: adam@ mrg-law.com
GREGORY M ADAMS
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL: [e-mail]
peter@ richardsonadams.com
JACOB A McDERMOTT
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: J acob.mcdern-rott @ pacificorp.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datar eq uest @ paci ficorp.com
SECRET
CERTIFICATE OF SERVICE