20220506Staff 1-8 to PAC.pdf

r:j,- -!r.1 ti1. .. i-'.. r _t v 1_,JDAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t2
IDAHO BARNO.9917
Street Address for Express Mail:
1I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomeys 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 BETWEEN PACIFICORP AND
GEORGETOWN IRRIGATION
CASE NO. PAC-8.22.06
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,
Dayn Hardie, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
MAY 27,2021.
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 behall 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
the person preparing the documents. Please also identi$ the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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MAY 6,2022
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: Both the original contract and Application in Case No. PAC-E-21-11
stated that the nameplate of the Facility is 330 kW. However, the renewal Power Purchase
Agreement ("PPA") states that the nameplate of the Facility is 480 kW. Please respond to the
following:
a. What was the actual nameplate installed when the Facility was first constructed?
b. Have there been any modifications to the Facility that increased its nameplate size
since it was first constructed?
c. Please reconcile the 330 kW and the 480 kW.
REQUEST NO.2: Page 4 of the Application states that the Seller secured a new stand-
alone transmission interconnection agreement on September 1,2027, but the Seller continued
working through March 24,2022, to secure and provide information and proof of insurance to
support the execution of the renewal PPA. Please respond to the following:
a. Please list and provide all the information that the Seller was required to provide
between September 1,2021, and March 24,2022.
b. Please explain why the information was required.
c. Did any of the information required depend on the completion of the transmission
interconnection agreement?
d. Is the insurance information required by previous Commission order? If so,
please provide the order number.
e. If the information required did not depend on the transmission interconnection
agreement, why couldn't the information be obtained earlier so that the renewal
PPA could be submitted to the Commission prior to the expiration date of the
original PPA on March 31,2022?
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 MAY 6,2022
REQUEST NO.3: Page 15 of the PPA defines the period between the expiration date of
the Prior PPA and the Initial Delivery Date as "Lapse Period." Please answer the following
questions.
a. Did the project generate and sell energy to the Company during the Lapse Period?
b. Is the project planning to generate energy and sell to the Company from now until
the end of the Lapse Period?
c. What price has the Company paid for the energy delivered during the Lapse
Period?
REQUEST NO. 4: Page l0 of the PPA states that the Seller is obligated to sell its Net
Output from the Scheduled Initial Delivery Date, which is April 1,2022, through March 31,
2042. However, Page 15 states that during the Lapse Period Seller shall be prohibited from
delivering Output without the Company's prior written consent, and the Company will not be
obligated to pay Seller for any power. Please respond to the following questions:
a. Should the "Scheduled Initial Delivery Date" have been "Initial Delivery Date"?
b. Is the Seller obligated to sell energy during the Lapse Period, or is the Seller
allowed to sell energy with the Company's prior written consent during the Lapse
Period? Please explain.
c. If the Seller is prohibited from delivering energy by default during the Lapse
Period, are the parties deviating from the Commission's expectations established
in prior ordersl for QFs' continuous operations when they request capacity
payments in their renewal contracts?
d. If the Seller is delivering energy during the Lapse Period, did the Seller receive
the Company's prior written consent? If so, please provide a copy of the consent.
REQUEST NO. 5: Regarding the Company's Transmission Provider and
lnterconnection Provider:
a. Please describe the responsibilities of Transmission Provider and Interconnection
Provider.
I See example Order Nos. 33357, 34792,34692,34887,35067,35060, and 35303.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 MAY 6,2022
b. Please describe the role each plays in this PPA.
c. Please describe the role each plays in the Transmission Interconnection
Agreement.
REQUEST NO. 6: Page23 of the PPA requires the Seller to "provide an annual update
to the expected long-term monthly/diurnal mean net energy and net capacity factor estimates (12
X24 profile)" by December I't of each year during the contract term. Please respond to the
following:
a. Please explain the role of the annual 12X24 profile plays.
b. Please explain the relationship between the 12X24 profile and the monthly
estimates used for the 90/l l0 rule.
REQUEST NO. 7: Please explain why the contract does not contain provisions that:
a. requires an "As-Built Supplement", which provides the final as-built
characteristics of the Facility such as Nameplate Capacity Rating, Net Output,
technology type, generator fuel type, etc., after it becomes operational under the
proposed renewal PPA;
b. addresses potential deviations that could affect the contract materially (such as
pricing) between the final characteristics contained in an "As-Built Supplement"
and the proposed facility characteristics in the renewal PPA approved by the
Commission;
c. declares that Seller would be in default of the contract if the Seller materially
modifies the Facility from the "As-Built Supplement" during the contract term
without promptly notifuing the Company; and
d. requires that the Company is required to file an amendment for Commission
approval if the Seller materially modifies the Facility per the As-Built
Supplement.
FIRST PRODUCTTON REQUEST
TO ROCKY MOUNTAIN POWER 4 MAY 6,2022
REQUEST NO.8: Page2 of the PPA defines Contract Year as "any consecutive twelve
(12) month period during the Term, commencing at 00:00 hours on April 1,2022 or any of its
anniversaries and ending at24:00 hours on the last day of such twelve (12) month period." Page
2l of the PPA describes how "Contract Year" is used in the annual forecast of Planned Outages.
With the final Effective Date being later than April 1, 2022, does the definition of Contract Year
need to be changed? Please explain.
DATED at Boise,Idaho, tti. 66day of May 2022.
Deputy Attomey General
i:umisc:prodreq/pace22.6dhyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 5 MAY 6,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 6ft pAY oF MAY 2022, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION STAFF
TO ROCKY MOUNTAIN POWE& IN CASE NO. PAC-E-22-06, By E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOUNTAIN POWER
1407 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.weston@.pacifi corp.com
idahodockets @nac ifi corp. com
DATA REQUEST RESPONSE CENTER
E.MAIL ONILY:
datarequest@pacifi corp.com
EMILY WEGENER
ROCKY MOUNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: emily.wegener@f'acificorp.com
Y
CERTIFICATE OF SERVICE