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HomeMy WebLinkAbout20241002Staff 1-1 to IPC.pdf RECEIVED Wednesday, October 2, 2024 1:58:11 PM IDAHO PUBLIC UTILITIES COMMISSION MICHAEL DUVAL DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 IDAHO BAR NO. 11714 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION ) OF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-24-36 APPROVAL OF A FIRST AMENDMENT TO ) THE ENERGY SALES AGREEMENT FOR ) THE SALE AND PURCHASE OF ELECTRIC ) FIRST PRODUCTION ENERGY FROM THE MILE 28 HYDRO ) REQUEST OF THE PROJECT ) COMMISSION STAFF TO IDAHO POWER COMPANY Staff of the Idaho Public Utilities Commission,by and through its attorney of record, Michael Duval, Deputy Attorney General, requests that Idaho Power Company("Company") provide the following documents and information as soon as possible, but no later than WEDNESDAY, OCTOBER 23, 2024. 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 identify the name,job title, location, and telephone number of the record holder. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 1 OCTOBER 2, 2024 In addition to the written copies provided as response to the requests,please provide all Excel spreadsheets and electronic files with formulas intact and enabled. REQUEST NO. 1: Page 3 of the Application states that Wood Hydro "has proposed an alternative insurance arrangement that Idaho Power has determined creates equivalent protection to the specified insurance requirements currently described in the ESA." Please respond to the following: a. Please explain the details of the alternative insurance arrangement; b. Please explain why Idaho Power believed that the alternative insurance arrangement created equivalent protection; c. Please list all the criteria Idaho Power used in determining that the alternative arrangement is equivalent to the insurance requirements in the ESA; and d. After the execution of the ESA in 1993, the Commission issued Order No. 29482 in 2004, which approved new insurance requirements. Please explain why Parties did not base the alternative insurance arrangement on the updated insurance requirements approved in Order No. 29482 but instead based the alternative insurance arrangement on the original insurance requirements in the ESA. DATED at Boise, Idaho, this 2nd day of October 2024. Michae Duv 1 Deputy Attorney General I:\Utility\UMISC\PRDREQ\IPC-E-24-36 PR#Ldocx FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY 2 OCTOBER 2, 2024 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS Z ODAY OF OCTOBER 2024, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-24-36, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING: DONOVAN E WALKER ENERGY CONTRACTS MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY IDAHO POWER COMPANY PO BOX 70 PO BOX 70 BOISE ID 83707-0070 BOISE ID 83707-0070 E-MAIL: energycontracts&idahopower.com E-MAIL: dwalker(cr�,idahopower.com mgoicoecheaallen(a�idahopower.com dockets(kidahopower.com PATRICIA JORDAN, CRETARY CERTIFICATE OF SERVICE