20220610Staff 1-3 to PAC.pdf

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CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 8026
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorneys for the Commission Staff
BEFORE THB 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
AMY FAMILY HOLDINGS, LLC
CASE NO. PAC.E,-22.08
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,
Claire Sharp, Deputy Attorney General, requests that Rocky Mountain Power provide the
following documents and information as soon as possible, but no later than FRIDAY,
JULY 1,2022.
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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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JUNE IO,2O22
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. l: Order No. 35262 conditionally approved the Amendment to extend
the original 1985 contract between the Company and Amy Family Holdings. However, the
Company has never filed an updated Amendment with the Commission. Please respond to the
following.
a. Have the parties executed an updated Amendment to comply with Order
No. 35262?
b. [f yes, please provide a copy of the updated Amendment and explain why the
Company has not submitted the updated Amendment to the Commission. If no,
please explain why not.
c. Page 4 of the Application states "[d]uring the extension period PacifiCorp and the
Seller agreed to updated pricing for energy sales." Please describe the form of the
agreement and provide evidence to support the answer.
d. The order requires the parties to use bifurcated rates for payments during the
extension period. Have the parties complied with this requirement during the
extension period? Please provide evidence supporting the answer.
REQUEST NO.2: The originally proposed Amendment in Case No. PAC-E-20-18
states that Article I of the original 1985 contract is amended and restated to read as follows:
"Unless terminated earlier pursuant to the terms of this Agreement, this Agreement shall expire
upon the earlier of (i) the ffictive date of a new power purchase agreement between PacifiCorp
and Seller pertaining to the Facility; or (ii) December 3 l, 2022. " Please respond to the
following.
a. If the parties have executed an updated Amendment to comply with Order
No. 35262, is the paragraph in italics included in the updated Amendment?
b. If the parties have not executed an updated Amendment to comply with Order
No. 35262, but have entered some form of agreement after the order was issued,
does the agreement include the paragraph in italics or the meaning of it?
c. Do both parties agree to the paragraph in italics? Please explain.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 JUNE 10,2022
REQUEST NO.3: The proposed renewal Power Purchase Agreement ("PPA') states:
(1) Scheduled Initial Delivery Date is January 1,2022; (2) all Net Output produced by the
Facility prior to the Initial Delivery Date is Non-Conforming Energy; and (3) the bifrucated rates
for Conforming Energy contained in Exhibit K will be applied starting ftomlanrlpirv 1.2022.
Please respond to the following.
a. Between January 1,2022, and Commission approval of the PPA, is the Facility
operating (i) within the original 1985 extension period using the bifurcated rates
determined in Order No. 35262, or (ii) during the lapsed contract period using the
Non-Conforming Energy rates contained in Exhibit K of the PPA that apply to all
Net Output produced prior to the Initial Delivery Date, or (iii) within the contract
term using the Conforming Energy rates contained in Exhibit K? Please explain.
b. If it is (ii) or (iii), please explain why Table I in Exhibit K does not contain
avoided cost rates for Year 2022.
DATED at Boise, Idaho, this 1O'h day of Jwre2022
Claire Sharp
Deputy Attorney General
i:umisc:prodreq/pace22.8csyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER J JUNE IO,2O22
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS IOth DAY OF JT'NE 2022, SERVED
THE FOREGOTNG FIRST PRODUCTION REQUEST OF TrrE COMMTSSTON STAFF
TO ROCKY MOUNTAIN POWER, IN CASE NO. PAC.E.22-08, BY E.MAILINC A
COPY THEREOF, TO THE FOLLOWING:
TED WESTON
ROCKY MOI,]NTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL : ted.rveston'Slpaci fi com.com
idahqdoskets@paci ficorp.com
DATA REQUEST RESPONSE CENTER
E.MAIL ONLY:
datareo uestrOnaci ficom.com
EMILY WEGENER
ROCKY MOI.JNTAIN POWER
I4O7 WN TEMPLE STE 320
SALT LAKE CITY UT 84I 16
E-MAIL: emi ly.rvEsener,B'oaqifi corp.com
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CERTIFICATE OF SERVICE