20211013Staff 1-3 to PAC.pdf

DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 9917
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Street Address for Express Mail:
1133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
Attorneys for the Commission Staff
BEFORB THE IDAHO PUBLIC UTILITIES COMMISSION
IN TIIE MATTER OF ROCKY MOUNTAIN )
POWER'S APPLICATION FOR APPROVAL OR )CASE NO. PAC-E-20-18
REJECTION OF AN ENERGY SALES
AGREEMENT WITH AMY FAMILY
HOLDINGS, LLC
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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 Attomey General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
NOVEMBER 3, 2021.
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 identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 ocToBER t3,2021
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. 1: Order No. 21018 in Case No. U-1009-174 approved an increase of
nameplate capacity from 450 kW to 600 kW but required the use of a two-part rate structure: the
first 45O-kilowatt ("kW") of nameplate capacity uses avoided cost rates established in Order No.
16048 and the remaining 150-kW uses avoided cost rates established in Order No. 20637. Please
answer the following questions.
a. The Application states that the Facility has a 450-kW nameplate capacity rating.
Please confirm if this is correct or whether the actual nameplate capacity installed
is 600 kW.
b. Please provide a list of all nameplate capacity changes and the dates of the
changes for the history of the Facility.
c. Please confirm that the QF has been and is being paid using the two-part rate
structure per Order No. 21018.
REQUEST NO. 2: The Application states that the likelihood that the Facility, under
average design conditions, will generate at no more than 2.5 aMW in any calendar month, and
that the Facility's estimated net output over the one-year extended term is 2,087 MWh. If these
numbers are not based on the installed nameplate capacity, please update these numbers.
REQUEST NO. 3: Page2 of the Unopposed Motion to Lift Stay states that "the
transmission upgrades necessary for a long-tefin power purchase agreement will not be
completed until May 2022. The existing contract must be extended so that Amy Family
Holdings can maintain its current interconnection rights until the transmission upgrades are
complete." Please answer the following questions.
a. Which specific transmission upgrades are needed in this case?
b. Why will the transmission upgrades will not be completed until May 2022?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 ocroBER t3,2021
t*DATED at Boise, Idaho, this day of Octobet202l.
Dayn
Deputy Attornoy General
i:umiscprodrodpaee20.lSdhtty prod q 1
FIRST PRODUCTION REQUEST
TO ROCKY h{O{JNTAIN POWER 3 ocToBER 13,202t
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS l3th DAY OF OCTOBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO ROCKY MOI]NTAIN POWER, IN CASE
NO. PAC-E-20-I8, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL : ted.weston@pacificorp. com
idahodockets@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@f'acificorp. com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE