20210421Staff 1-2 to PAC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
Street Address for Express Mail:
I I331 W CHINDEN BVLD, BLDG 8, SUITE 20 I -A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION FOR )
APPROVAL OR REJECTION OF THE
AMENDED POWER PURCHASE AGREEMENT
BETWEEN PACIFICORP AND GEORGETOWN
IRRIGATION
CASE NO. PAC.E-2I-II
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, John R. Hammond, Jr., Deputy Attorney General, requests that Rocky Mountain Power
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, MAY 12, 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 27,2021
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 why 90/l l0 related provisions are not included in the
Amended Power Purchase Agreement ("Amendment").
REQUEST NO.2: The 1984 Power Purchase Agreement expires on March 31,2021.
Paragraph 4 of the Amendment states that it shall be effective once signed and delivered by both
PacifiCorp and Seller and approved by the Idaho Public Utilities Commission ("Effective Date").
Please answer the following questions:
a. Have the parties agreed on the rates the Seller will receive for energy generated and
delivered to PacifiCorp between April 1, 2021 and the Effective Date?
b. If yes to (a), please provide the agreement between the Seller and PacifiCorp.
c. Has the Seller delivered energy since April 1,2021?
d. Is the Seller planning to continuously operate through the Effective Date?
!DATED at Boise, Idaho, tniso?/ day of April202l.
John
General
i:umisc:prodreq/pace2l. I ljhyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOI-]NTAIN POWER
Jr
2 APRIL 2I,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I2TH DAY OF APRIL 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO ROCKY MOUNTAIN POWER, N CASE NO.
PAC-E.2I.Il, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
idahodockets@pacifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datarequest@pacifi corp. c om
EMILY WEGENER
ROCKY MOI.]NTAIN POWER
1407 WN TEMPLE STE 320
SALT LAKE CITY UT 84I16
E-MAIL: [e-mail]
Jnz^,,
CERTIFICATE OF SERVICE