20101108NIPPC 1-4 to Joint Utilities.pdf

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ATTORNEYS AT LAW 201B NOV -8 AM 9= 2 l
Peter Richardson
Tel: [phone] Fax: [phone]
petet¡¡ richards onandol ea 'y. com
P.O. Box 7218 Boise,ID 83707 - 515 N. 27th St. Boise, ID 83702
8 November 2010
Ms. Jean Jewell
Commission Secretar
Idaho Public Utilties Commission
472 W. Washington
Boise, ID 83702
RE: GNR-E-IO-04
Dear Ms. Jewell:
We are enclosing three copies of the FIRST PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION
TO THE JOINT UTILITIES in the above case. Would you please fie the same?
Than you for your attention to this matter. Please feel free to give me a call if you have
any questions.
Sitjl,
Peter J. Richardson
Richardson & O'Leary PLLC
Peter 1. Richadson (ISB # 3195)
Gregory M. Adams (ISB # 7454)
Richadson & O'Lear, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~chadsonadolea.com
greg~charsonandolear.com
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znmNOV -8 AM 9: 21
Attorneys for Nortwest and Intermountan
Power Producers Coalition
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE JOINT PETITION
OF IDAHO POWER COMPANY, AVISTA
CORPORATION AND ROCKY MOUNTAIN
POWER TO ADDRESS AVOIDED COST
ISSUES AND JOINT MOTION TO ADJUST
THE PUBLISHED AVOIDED COST RATE
ELIGIBILITY CAP
)
) CASE NO. GNR-E-IO..04
)
)) FIRST PRODUCTION REQUEST OF THE
NORTHWEST AND INTERMOUNTAIN
~ POWER PRODUCERS COALITION TO
) THE JOINT UTILITIES
)
)
)
)
Pursuat to Rule 225 of the Rules of Procedure of the Idao Public Utilties Commission
(the "Conuission"), the Nortwest and Intermountan Power Producers Coalition ("NIPPC")
hereby requests that Idaho Power Company ("Idaho Power"), Rocky Mountain Power, and
Avist Corporation (collectively the "Joint Utilties") provide responses to the following with
supporting documents, where applicable. Because the subject matter ofthese requests is relevant
to Joint Utilties' Joint Motion for expedited Commission determination of the eligibility cap for
published avoided cost rates, NIPPC requests expedited processing of these production requests.
Page 1.. FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN
POWER PRODUCERS COALITION - GNR-E-IO-04
This production request is to be considered as continuing, and the Joint Utilties are
requested to provide by way of supplementar responses additional documents that they or any
person acting on their behalf may later obtain that will augment the responses or documents
produced.
Please provide one physical copy and electronic copies, if available, of your answer to
Mr. Richardson and Mr. Adams at the address noted above.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed by the Joint Utilties to
be confidentiaL. Counsel for NIPPC is prepared to sign any such agreement to obtan the
materials relevant to this proceeding, and expects that executing such a confdentiality agreement
will not delay the responses to these Requests for Production.
Page 2 - FIRST PRODUCTION REQUEST OF THE NORTHWESTAND INTERMOUNTAIN
POWER PRODUCERS COALITION - GNR-E-IO-04
REQUeST FOR PRODUCTION NO.1
Reference Joint Petition and Joint Motion, at p. 7, stating Idaho Power is experiencing an "influx
of requests for contracts" which are occurg on a "nearly daily basis." Please provide
documentation and evidence supporting these clais for requests intiated in the past month.
REQUEST FOR PRODUCTION NO.2
Reference Joint Petition and Joint Motion, at p. 4, stating Idaho Power has over 570 MW of new
wind contract requests.
a. Please provide a list of all such requests, including the name of the requesting entity,
nameplate capacity of the wind project, point of initial contact with Idaho Power, and date and
natue of the last communication between the paries.
b. For each requesting entity, please provide supporting evidence that the project is stil
being pursued. Such evidence may include a recent correspondence from the requesting entity
requesting a contract.
c. If the documents and information requested in items (a) and (b) are unavailable, please
explain the basis for asserton regarding 570 MW of new wind contract requests.
REQUEST FOR PRODUCTION NO.3
Reference Joint Petition and Joint Motion, at p. 4, stating Rocky Mountan Power has 358 MW
of new wid contract requests.
a. Please provide a list of all such requests, including the name of the requesting entity,
nameplate capacity of the wid project, point of initial contact with Rocky Mountain Power, and
date and natue of the last communcation between the paries.
b. For each requesting entity, please provide supportng evidence that the project is stil
being pursued. Such evidence may include a recent correspondence from the requesting entity
requesting a contract.
c. If the documents and information requested in items (a) and (b) are unavailable, please
explain the basis for assertion regarding 358 MW of new wind contract requests.
REQUEST FOR PRODUCTION NO.4
Reference Joint Petition and Joint Motion Attachment No.1.
a. Please provide, in electronic format where possible, all work papers, spreadsheets, and
data used in the generation of this char.
Page 3.. FIRST PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN
POWER PRODUCERS COALITION - GNR-E-IO~04
b. Please state the nane of the person who can sponsor this attchment at a hearng.
Than you for your prompt attention to ths First Request for Production.
Sincerely yours,
~
Page 4 - FIRST PRODUCTION REQUEST OF THE NORTHWEST AN INTERMOUNTAIN
POWER PRODUCERS COALITION ~ GNR~E~lO-04
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th day of November, 2010, a tre and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF THE NORTHWEST AND
INTERMOUNTAIN POWER PRODUCERS COALITION TO THE JOINT UTILITIES
BY THE NORTHWEST AND INTERMOUNTAIN POWER PRODUCERS COALITION was
served by ELECTRONIC MAIL and US MAIL, to:
Donovan E. Walker
Lisa Nordstrom
Idaho Power Company
1221 West Idaho Street
Boise, Idaho 83707~0070
dwalkerÇgidaopower.com
lnordstromÇgidahopower .com
Danel E. Solander
Rocky Mountan Power
201 South Main
Salt Lake City, UT 84111
Danel.solanderÇgpacificom.com
Michael G. Andrea
A vista Corporation
1411 East Mission Avenue ~ MSC-23
Spokane, W A 99202
Michael.andrea(qavistacom.com
Page 5 - FIRST PRODUCTION REQUEST OF THE NORTHWEST AND INTERMOUNTAIN
POWER PRODUCERS COALITION - GNR-E-IO-04