20210630Staff 1-3 to PAC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
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Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 837I4
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 AMENDED POWER
PURCHASE AGREEMENT BETWEEN
PACIFICORP AND MINK CREEK HYDRO
LLC.
CASE NO. PAC.E,-21-14
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,
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,
JULY 21,2021.
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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I JUNE 30,2O2I
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: The proposed Power Purchase Agreement lists the Facility's
nameplate capacity rating at2.95 megawatts ("MW"), while the nameplate capacity rating in the
1985 contract lists the Facility's nameplate capacity rating at2.70 MW. Please explain the
difference between these two amounts. In the response, please indicate if the Facility's
nameplate capacity rating has been 2.95 MW since initial construction and whether the Facility
has ever been upgraded.
REQUEST NO.2: Please provide the actual generation amounts in average annual MW
for each year over the 1985 contract's term.
REQUEST NO.3: What is the peak capacity contribution of this Facility that the
Company has assumed in the Integrated Resource Plan? How is the contribution determined?
iltDATED at Boise, Idaho, this Jo day of June 2021.
Hunter
Deputy Attorney General
i:umisc:prodreq/pace2 l. l4mhyy prod req I
FTRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JUNE 3O,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 30th DAY OF JUNE 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION STAFF
TO ROCKY MOUNTATN POWER, N CASE NO. PAC-E-21-14, 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 OITLY:
datareq uest@paci fi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE