20011120Staff 1-5 to IPC.pdf

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EJilSCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPAI\"Y TO AMEND
SCHEDULE 86 - COGENERATION AND
SMALL POWER PRODUCTION - NON-FIRM
ENERGY.
CASE NO.IPC.E.Ol.4O
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information on or before FRIDAY, DECEMBER 7, 2001.
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
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 who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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1 NOVEMBER 20, 2OO1
Request No. l.: Please explain the statement on page 3 of the Application that states, in
part"... but Qualifyrng Facilities larger than one megawatt are required to negotiate contracts with
Idaho Power and to negotiate appropriate power purchase prices as part of that contracting
process." Explain how this comports with Order No. 25884 that describes the methodology to be
used in establishing rates for projects one megawatt and greater. Could the process established to
calculate rates for one megawatt and greater projects be successfully utilized for non-firm energy
purchases?
Request No. 2: Please explain why it is inappropriate to continue using Schedule 86 as it
is now written to set rates for non-firm energy purchases for projects one megawatt or greater.
Also, please pxplain why it is inappropriate to use Schedule 86, assuming the Commission agrees
to 85%o of Mid-C as the basis for rates, for non-firm energy purchases for projects one megawatt or
greater.
Request No. 3: What is the basis for 85% of market price (as opposed to some other
percentage)? Why should the percentage negotiated in prior non-firm contracts with Schedule 19
or special contract customers serve as the basis for rates to be paid for all future contracts?
Request No. 4: What are Idaho Power's transmission costs and other transaction costs for
non-firm energy purchases from the market? Please list and quantiff all costs associated with re-
selling non-firm energy purchased from customer generators.
Request No. 5: Please explain how setting the purchase price for non-firm energy at an
amount equal to 85o/o of Mid-C fairly reflects Idaho Power's avoided cost as defined by PURPA.
DATED at Boise, Idaho, tnis ;)ffday of November 2001.
cott
Deputy Attorney General
Technical Staff: Rick Sterling
SW: RPS/umisc/prdreqVipce0 1 .40swrps
FIRST PRODUCTION REQUEST
TO IDAHO POWER
2 NOVEMBER 20, 2OO1
I
CERTIF'ICATE Of,' SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF NOVEMBER 2001,
SERVED TIrE FOREGOING X'rRST PRODUCTION REQTTEST OF THE
coMlvflssroN STAFF To rDAHO POWER COMPAI\"Y, IN CASE NO. IPC-E-01-40,
BY MAILING A COPY TIMREOF, POSTAGE PREPAID, TO TIIE FOLLOWING:
BARTON L KLINE
SENIOR ATTORNEY
IDAHO POWER COMPA}IY
PO BOX 70
BOISE rD 83707-0070
MAGGIE BRILZ
DIRECTOR OF PRICING
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
CERTIFICATE OF SERVICE