20221123Staff 1-3 to PAC.pdf

rt''-iivEtiMICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II7I4
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Street Address for Express Mail:
I 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
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.22-18
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO ROCKY MOUNTAIN
POWER
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attomey General, requests that Rocky Mountain Power ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, DECEMBER 14, 2022.
This Production Request is to be considered as continuing, and the Company 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 identi$ the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER
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I NOVEMBERZ3,2022
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: The Application states the Seller's original contract was entered into
on January 24,1992. Section 2.2 (b) of the Power Purchase Agreement ("PPA") states that the
original contract was signed January 3, 1985. Please confirm that the correct date should be
March 4,1986.
REQUEST NO. 2: In Case No. PAC-E-22-01(the one-year extension case), the
Company stated the total nameplate capacity of the facility remains unchanged at 260 kW.
However, in this case, the nameplate capacity has changed to 188 kW. Please respond to the
following.
a. What was the actual nameplate capacity when the Facility was built?
b. Has the Facility's nameplate changed since construction? If yes, when did the
change take place? What were the nameplate capacities before and after the
change?
c. Please provide proof that the current nameplate capacity is 188 kW.
REQUEST NO. 3: Please explain why there is no expected energy delivery for the
month of May in the Initial Energy Delivery Schedule.
DATED at Boise, Idaho, this / 5*aurof Novemb er 2022.
Michael Duval
Deputy Attomey General
i:umisc:prodreq/pace22.I Smdyy prod req I
FIRST PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 NOVEMBER23,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF NOVEMBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMMISSION
STAFF TO ROCKY MOUNTAIN POWE& IN CASE NO. PAC-E-22-18, By E-MAILING
A COPY THEREOF, TO THE FOLLOWING:
MARK ALDER
ROCKY MOUNTAIN POWER
I4O7 WEST NORTH TEMPLE STE 330
SALT LAKE CITY UT 84I 16
E-MAIL: mark.alder@pacifi com.com
DATA REQUEST RESPONSE CENTER
E-MAIL ONLY:
datarequest@pacifi corp. com
JOE DALLAS
ROCKY MOUNTAIN POWER
825 NE MULTNOMAH ST, SUITE 2OOO
PORTLAND OR 97232
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE