20210414Staff 1-3 to PAC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, TDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR
APPROVAL OR REJECTION OF THE POWER
PURCHASE AGREEMENT BETWEEN
PACIFICORP AND SUNNY BAR RANCH
CASE NO. PAC.E-21.10
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,
Matt Hunter, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
MAY 5,2021.
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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APRIL I4,2O2I
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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Page 6 of the Power Purchase Agreement (PPA) in Case
No. PAC-E-21-10 states that the Nameplate Capacity Rating of the facility is 0.45 MW. Page I
of the Application in Case No. PAC-E-20-17 states that the nameplate capacity rating of the
same facility is 350 kW. Please reconcile the difference providing the cause of the difference in
nameplate capacity between the two cases.
REQUEST NO.2: If the change in nameplate capacity is due to modifications of the
facility or equipment, please provide the following:
a. What modifications has the Seller made to the facility to increase its Nameplate
Capacity Rating from 350 kW to 450 kW?
b. When were the modifications made?
c. Please describe the configuration of the 350-kW facility and the configuration of
the 450-kW facility after the modification.
d. If there were multiple generators in the 350-kW facility, please describe how the
generators operated under different situations regarding water availability.
e. If there are multiple generators in the 450-kW facility, please describe how the
generators operate under different situations regarding water availability.
f. Did the 350-kW facility have a meter for each generator?
g. Does the 450-kW facility have a meter for each generator?
h. Does the facility have a separate meter that measures the output from the added
capacity?
i. What level of generation data (frequency, time resolution, etc.) can the Company
collect from the meter(s) installed at the facility?
j. Please provide the amount of generation in each hour from the facility for the past
five years (from 2016 to 2020).
FIRST PRODUCTION REQUEST
TO ROCKY MOI-INTAIN POWER 2 APRIL 14,2O2I
REQUEST NO.3: Paragraph 2.1 of the PPA states that the Effective Date occurs after a
number of events, including "approval [of the PPA] by the Commission...." Paragraph 2.2 states
that the Initial Delivery Date is May 1, 2021, and that the "Seller must begin selling and making
available to PacifiCorp Net Output under this Agreement on May 1, 2021." Given that a final
order is unlikely to issue in this proceeding by May l,202l,please answer the following
questions:
a. Have the parties agreed on what rates the Seller will receive for energy generated
and delivered to PacifiCorp between the Initial Delivery Date and the Effective
Date?
b. If yes to (a), please provide the agreement between the Seller and PacifiCorp.
c. [s the Seller planning to deliver energy between the Initial Delivery Date and the
Effective Date?
flDATED at Boise, Idaho, this lq day of Aprilz0zl.
Hunter
Deputy Attomey General
i:umisc:prodreq/pace2 l. I 0mhyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 APRIL I4,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I4d' DAY OF APRIL 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO ROCKY MOUNTAIN POWER, N CASE NO. PAC-E-21-10, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOLINTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84116
E-MAIL : ted.weston@pacifi corp.com
idahodockets@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareq uest@paci fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
ADAM LOWNEY
MCDOWELL RACKNER GIBSON PC
419 SW 11th AVE., SUITE 4OO
PORTLAND OR 97205
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE