20220202Staff 1-4 to PAC.pdf

RILEY NEWTON.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
1I331 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 THE APPLICATION FOR
APPROVAL OR REJECTION OF THE POWER
PURCHASE AGREEMENT BETWEEN
PACIFICORP AND OJA, LLC
CASE NO. PAC-E-22.0I
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,
Riley Newton, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
FEBRUARY 23,2022.
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 MOLTNTAIN POWER
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I FEBRUARY 2,2022
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 spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: The proposed Second Amendment states that it was dated December
15,2021. However, the signature pages show that the Seller signed the Second Amendment on
December 6,202I. Please provide evidence that the Company signed the Second Amendment
on December 15, 2021.
REQUEST NO.2: The proposed Second Amendment states "[n]otwithstanding any
provision in the PPA to the contrary, PacifiCorp shall not be responsible to purchase the output
of the Facility during periods that the Facility is curtailed due to construction and completion of
the distribution system upgrades called for in the final, new stand-alone interconnection
agreement between Seller and PacifiCorp's transmission function." Please answer the following
questions:
a. Has the Facility been curtailed due to completion of the distribution system
upgrades?
b. If so, has the Company purchased any output of the Facility during the
curtailment period?
c. If the Company has purchased any output during the curtailment period, what
price was paid to the Seller?
REQUEST NO.3: The proposed Second Amendment states "[t]his Amendment shall
be effective once signed and delivered by both PacifiCorp and Seller and approved by the Idaho
Public Utilities Commission." Please answer the following questions:
a. Between February 7,2022, when the Seller no longer is operating under the
current contract, and when the Commission issues its final order, does the
Company expect the Facility to generate energy during this period without a
contract?
b. What price will the Company pay to the Seller during this period?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 FEBRUARY 2,2022
REQUEST NO. 4: The Application states that the Company began contacting the Seller
regarding contract renewal on October 20,2020, and the Seller filed the Application for
Transmission Interconnection August 31,2021, with data to begin a transmission interconnection
fast-track study finally deemed complete December 30,2021. Please answer the following
questions:
a. Please provide a timeline of historic and future events regarding the transmission
interconnection including but not limited to: (l) when the Seller was first notified
of the need for an Application for Transmission Interconnection, (2) when the
Application was first submitted, (3) when the Application was considered
complete, (3) when the transmission interconnection fast-track study was
initiated, (4) when the study is targeted for completion, and (5) when construction
ofinterconnection upgrades should be done.
b. Please provide copies of all correspondence between the Company and the Seller
regarding the Transmission Interconnection reflecting events included in the
timeline above.
c. Please explain why it took approximately four months for the Interconnection
Application data to be complete.
d. Please explain how delays in completing the interconnection process could have
been prevented so that an extension Amendment would not be necessary.
DATED at Boise,Idaho, tni"Ld day of February 2022.
ewton
Deputy Attorney General{rr',
i :umisc:prodreq/p ace22. ltbyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J FEBRUARY 2,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2Nd DAY OF FEBRUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
C0MMISSION STAFF TO ROCKY MOUNTAIN POWER, IN CASE
NO. PAC.E.22-OI, BY E-MAILING A COPY THEREOF, TO TIIE 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.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84116
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE