200306101st Request of Staff to Idaho Power.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 1895
2QDJ JUN lO AM 9: 05
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UTILlTit~S CDhhiSSiON
Street Address for Express Mail:
472 W. 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 COMPANY FOR AN
ACCOUNTING ORDER AUTHORIZING
INCLUSION OF POWER SUPPLY EXPENSES
ASSOCIATED WITH THE PURCHASE,
PROFIT CAPACITY AND ENERGY FROM PPL )
MONTANA, LLC IN THE POWER COST ADJUSTMENT.
CASE NO. IPC-03-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STATT 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 (Idaho
Power; Company) provide the following documents and information on or before TUESDAY,
JUNE 17, 2003.
The Company is reminded that responses pursuant to Commission Rules of Procedure
must include the name and phone number of the person preparing the document, and the name
location and phone number of the record holder. Reference IDAP A 31.01.01.228.
This Production Request is to be considered as continuing, and Idaho 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 produced.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF JUNE 10 2003
Please provide answers to each question; supporting workpapers that provide detail or are
the source of information used in calculations; the name and telephone number of the person
preparing the documents; and the name, location and telephone number of the record holder.
For each item, please indicate the name ofthe person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Request No.1: Please discuss whether transmission capacity is available from Mid-
Columbia and Palo Verde during the hours covered by the proposed agreement with PPL
Montana. If transmission capacity is available, please describe the transmission path. Provide
copies of any analysis or other evidence to support your answer.
Request No.2: Assuming transmission capacity is available, please provide an estimate
of the additional costs that would be incurred for transmission to the Idaho Power system for
purchases made at Mid-Columbia and Palo Verde during the term of the proposed agreement
with PPL Montana. (Reference page 11 , lines 5-15 of Greg Said's direct testimony).
Request No.3: Please provide forward price curves for Q3 heavy load hour products (or
other products more comparable to the PPL Montana agreement) for delivery during the term of
the proposed contract, that have been developed by Idaho Power based on market price quotes
obtained and compiled during the period January 2 2003 to the present. Please provide this
information in both a graphical and a tabular format.
Request No.4: Please provide a description of the information used by the Company to
develop the forward price curves, along with a description of how this information is used to
develop the forward price curves.
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF JUNE 10, 2003
Respectfully submitted this Cjtk.. day of June 2003.
Technical Staff: Rick Sterling
i:umisc:prodreq/ipceO3.8swrps prl
FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF JUNE 10, 2003
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS
TH DAY OF JUNE 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-03-
BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
SENIOR ATTORNEY
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
JOHNP. PRESCOTT
VICE PRESIDENT - POWER SUPPLY
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
SECRETARY
CERTIFICATE OF SERVICE