20210318Staff 1-6 to PAC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
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Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
PACIFICORP FOR APPROVAL OR
REJECTION OF THE PURCHASE POWER
AGREEMENT WITH COMMERCIAL ENERGY
MANAGEMENT,INC.
CASE NO. PAC.E.2I.Os
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
The Staff of the Idaho Public Utilities Commission, by and through its attomey of
record, Edward Jewell, Deputy Attorney General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than THURSDAY,
APRrL 1,2021.r
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.
I Stuffit requesting an expedited response. tf responding by this date will be problematic, please call Stafls
attorney at [phone].
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER MARCH I8,2O2I
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the person preparing the documents. Please identifu 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.
REQUEST NO. 1: The original contract expired on March 1,2021, and the Application
in PAC-E-21-05 was filed on March 3,2021. Please explain why the Application was filed late.
REQUEST NO. 2: The QF is currently not under an approved contract since the
original contract expired on March 1,2021. Has the QF been operating and supplying energy to
the Company since the contract expired? If so, what prices is the Company planning to pay the
QF during this period without an approved contract?
REQUEST NO.3: The Application states that the Facility's estimated annual net output
over the term is 2,187 megawatt-hours per year. Page 3 of the proposed Power Purchase
Agreement (PPA) states Expected Net Output is 2,300 MWh. Page 15 of the proposed PPA
shows the monthly estimates, which results in an estimated annual amount of 2,310 MWh.
Please explain why there is a difference between each of these amounts and which of these
amounts should be used as the Expected Net Output for the QF.
REQUEST NO. 4: The Company listed 3 mechanisms for updating the estimated
amount of generation in the PPA. The first mechanism is detailed on page 3 of the definition for
"Expected Net Output" based on the "Contract Year" starting on April 1,2021and included in
Exhibit A-1. The second mechanism is detailed on page 16, Section 4.9.2, which requires 3
months of additional updates on a 3-month rolling schedule. The third mechanism allows the QF
to update changes to monthly estimates 5 to 10 days in advance of the next month. Please
answer the following questions:
a. What is the purpose of each of the 3 mechanisms and explain why each of these
mechanisms is necessary?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER MARCH I8,2O2I2
b. The first mechanism references Exhibit A-1, which is also used to define the
Maximum Delivery Rate. The PPA does not contain an Exhibit A-1. If it should be
included, please provide the exhibit.
c. Please provide the value for the Maximum Delivery Rate. Also, please explain how
Maximum Delivery Rate is determined, what is meant by Actual Nameplate Capacity
Rating, and whether each or both consider water availability.
REQUEST NO. 5: Page2l of the proposed PPA requires the QF to provide al2X24
generation profile. Please explain why this provision is a requirement given that the PPA utilizes
published avoided cost rates.
REQUEST NO.6: Page2l of the proposed PPA requires day-ahead forecasts and
updates. Please explain why this provision is needed.
DATED at Boise,Idaho, this Lf day of Mar ch202l.
Edward
Deputy General
i:umisc:prodreq/pace2l.3ejyy prod reql
FIRST PRODUCTION REQUEST
TO ROCKY MOI-]NTAIN POWER -l MARCH T8,2O2T
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I8TH DAY OF MARCH 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE NO.
PAC-E-21-05, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pacifi com. com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL : emily.wegener@pasi{icorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pacifi corp.com
Jo,4A,r^
SECRETARY/
CERTIFICATE OF SERVICE