20201204Staff 1-7 to PAC.pdf

JOHN R.HAMMOND,JR.
DEPUTY ATTORNEY GENERAL 52IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.5470
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )FOR APPROVAL OR REJECTION OF THE )CASE NO.PAC-E-20-17
AMENDED POWER PURCHASE AGREEMENT )BETWEEN PACIFICORP AND SUNNY BAR )RANCH )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission,by and through its attorney of
record,John R.Hammond,Deputy AttorneyGeneral,requests that Rocky Mountain Power
provide the followingdocuments and information as soon as possible,but no later than
MONDAY,DECEMBER 28,2020.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 DECEMBER 4,2020
the person preparing the documents.Please 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 and electronic files on CD with formulas activated.
REQUESTNO.1:Please provide justification for excluding the 90/110 requirements
not included in the proposed amended contract.
REQUESTNO.2:Please provide a copy of the existing contract between the Company
and Sunny Bar Ranch dated June 27,1985.
REQUESTNO.3:Please provide the order number that established the rates in the
existing contract dated June 27,1985.
REQUESTNO.4:Is the QF currentlyreceiving capacity payments through the current
contract?Please explain.
REQUESTNO.5:Page 3 of the Application states that,"the Seller and PacifiCorp are
in the process of securing a new stand-alone interconnection agreement that,after all distribution
system upgrades are constructed and in-service,will replace the interconnection provisions in the
current PURPA contract."Please answer the followingquestions.
a.Please specify each of the distribution system upgrades and explain the necessity of
the upgrade.
b.Please provide the date when the need for the distribution system upgrades were first
identified.
c.Please provide a time schedule showing the major milestones for completing the
upgrades and when the upgrades are expected to be in-service?
REQUESTNO.6:Page 4 of the Application states that the total nameplate capacity of
the facility remains unchanged at 350 kilowatts (kw)and that the Facility's estimated net output
over the 1-year extended term is 219 megawatt-hours.This equates to 25 average kw or a 7%
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 DECEMBER 4,2020
annual capacity factor.Please explain the low capacity factor for this project when most small
hydro facilities operate with a 30%to 50%annual capacity factor.
REQUESTNO.7:Please provide the QF's capacity contribution at peak used in the
IRP and explain how it is determined.Will the capacity contribution change under the
Amendment?If so,please provide the new amount and explain how it is determined.Please
provide any workpapers in Excel format with formula intact.
DATED at Boise,Idaho,this y of December 2020.
J R.Hammond,Jr.
uty Attorney General
i:umisc:prodreq/pace20.17jhme prod req l
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 DECEMBER 4,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4TH DAY OF DECEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-20-17,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
TED WESTON EMILY WEGENER
ROCKY MOUNTAIN POWER ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330 1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116 SALT LAKE CITY UT 84116
E-MAIL:[e-mail] E-MAIL:[e-mail]
[e-mail]
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
[e-mail]
SECRETAR
CERTIFICATE OF SERVICE