20200910Staff 24-30 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.9917
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-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 )CASE NO.PAC-E-20-IO
AGREEMENT BETWEEN PACIFICORP AND )
FALL RIVER ELECTRIC COOPERATIVE,INC.)FOURTH 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 if possible by Monday,September 14,but no later than
THURSDAY,SEPTEMBER 17,2020.’
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
Staff is requesting an expedited response since these questions have been provided lo the Company informally.If
responding by this dale will be problematic,please call Siafl’s attorney at [phone].
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 10,2020
RECEIVED
September 10, 2020 4:02:53 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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.24:Please provide Felt Hydro’s hourly generation for year 2020.
REQUEST NO.25:Please provide Felt Hydro’s monthly generation for years 2006,
and 2010 through 2014.
REQUEST NO.26:Order No.29632 requires that the lesser of 85%of the market price
or the contract price is used for energy generated outside the 90/110 band.Please explain and
provide an example of how the Company determines the contract price at each month,while the
proposed contract only includes an annual price and heavy load/light load adjusting factors.
REQUEST NO.27:The Company’s response to Production Request No.17 describes
the Settlecore system,which “sets up all the calculations specific to the contract parameters and
produces the statement for the vendor at each rate and range of megawatt hours generated for the
calendar month.”Please explain if the Settlecore system can be configured to apply different
rates for each hour of metered data from a Qualifying Facility depending on whether actual
generation is above or below a specified amount.
REQUEST NO.29:The Company’s response to Production Request No.20 provided
the amount of generation in each hour from the Felt Hydro project for the past five years—2015
to 2019.Please answer the following:
a.Please explain negative values in the data.Examples include:5/13/20 17 hours 1
through 8;5/12/2017 hour 13;and 6/10/2017 hour 5.
b.Please explain zero values in the data.Do zero values represent no generation,
unavailable data,or something else.Examples include:5/24/20 17 hours 18
through 24;and 6/10/2017 hours 1,2,and 4.
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 10,2020
c.Please explain why January through April of 2017,Januan’and February of 2018,
and February through December of 2019 have the same generation amount for
every hour across each month,instead of the actual (and unique)generation
amounts for each hour.If these amounts are derived or estimated,please show
the calculations or method of derivation or estimation.
d.Generation for hour 3 of November 6,2016 is 7206.72 kWh which is significantly
above the nameplate capacity of Powerhouse #2.Please explain the irregularity
of this data point and if this is an error,an adjusted amount,or some other
modification/anomaly.
e.Generation for hour 3 of November 5,2017 is 9550.08 kWh,which is
significantly above the nameplate capacity of Powerhouse #2.There are also two
generation amounts for the same proceeding hour (hour 2).Please explain the
irregularities of these data points and if these are errors,adjusted amounts,or
some other modification/anomaly.
f.Generation for hour 2 of April 1,2017 is 5025 kWh.Please explain if this is an
error,an adjusted amount,or some other modification/anomaly given the fact that
the hours proceeding this data point for the entire month of March 2017 are 4321
kWh and the hours after this data point for the rest of April 2017 are 4686 kWh.
REQUEST NO.30:Fall River’s response to Production Request No.3 stated “On
July 5,2020,Fall River’s data shows that Powerhouse #2 generated gross production of 127,000
kwh,which would equate to average hourly generation over that 24-hour period of 5,292 kWh.”
Please verify this amount with the Company’s meter data and identify and explain any anomalies
with the data for this time period.
DATED at Boise,Idaho,this
iuniiscprodreq/pace2O.Iodhvy prod req 4
FOURTH PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
IOtday of September 2020.
Deputy Attorney General
3 SEPTEMBER 10,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10 DAY OF SEPTEMBER 2020,
SERVED THE FOREGOING FOURTH 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 FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
JACOB A McDERMOTT
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
[e-mail]
ADAM LOWNEY
McDOWELL RACKNER GIBSON
419 SW 11T11 AVE SUITE 400
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
PORTLAND OR 97205
E-MAIL:[e-mail]
GREGORY M ADAMS
PETER J RICHARDSON
RICHARDSON ADAMS PLLC
515 N 27TH STREET
BOISE ID 83702
E-MAIL:[e-mail]
[e-mail]
CERTIFICATE OF SERVICE