20210323Staff 1-5 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:
1I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR APPROVAL
OR REJECTION OF THE POWER PURCHASE
AGREEMENT WITH CHESTER DIVERSION
PROJECT
CASE NO. PAC.E,-2I.06
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, Edward Jewell, Deputy Attomey General, requests that Rocky Mountain Power provide
the following documents and information as soon as possible, but no later than TUESDAY,
APRIL 13,2021.
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
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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1 MARCH 23,2021
the person preparing the documents. Please identiff 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: Please explain how the Maximum Delivery Rate of 2.0 MWh listed
in Exhibit A is determined.
REQUEST NO. 2: Page 15 and Exhibit A of the Power Purchase Agreement ("PPA")
list Expected Monthly Net Output, where the output in January (10,000 kwh) is significantly
lower than that in February (170,000 kwh) or in December (175,200 kwh). Please explain the
difference.
REQUEST NO.3: Page 15 and Exhibit A of the PPA and Page 3 of the Application
show that the expected annual generation amount is 6,580 MWh. However, Page 3 of the PPA
states that Expected Net Output is 5,481,400 kwh. Please reconcile the two numbers and
provide the expected annual generation amount for the facility. If the January estimate needs to
be corrected, please provide the updated expected annual generation amount.
REQUEST NO. 4: The Company listed two mechanisms for updating the estimated
amount of generation in the PPA. The first mechanism is detailed on Page 3 in the definition for
"Expected Net Output" based on the "Contract Year". The second mechanism is detailed on
Page 15, Section 4.9.1, which allows the QF to update changes to monthly estimates at least 10
days in advance of the delivery month. What is the purpose of each of the two mechanisms and
explain why each of these mechanisms is necessary?
REQUEST NO. 5: Page20 of the PPA requires the QF to provide al2X24 generation
profile. Please explain why this provision is a requirement.
FIRST PRODUCTION REQUEST
TO ROCKY MOTINTAIN POWER MARCH 23,20212
DATED at Boise,Idaho, this L}rA day of Mar ch202l.
&pfuLt
Edward 6vAlt
Deputy eh*ey General
i:umisc:prodreq/pace2l.6ejyy prod reql
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J MARCH 23,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF MARCH 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC-E-2I-06, 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]
idahodockets@pacifi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: emil)[e-mail]
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@pac i fi corp. com
CERTIFICATE OF SERVICE