200311131st Request of Staff to Idaho Power.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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UTILITIES cor'H..nSSION
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 A PETITION FILED BY
IDAHO POWER COMPANY FOR APPROV AL )
OF MODIFICATIONS TO THE SECURITY
PROVISIONS REQUIRED TO BE INCLUDED
IN AGREEMENTS BETWEEN IDAHO POWER
AND CO-GENERATORS AND SMALL POWERPRODUCERS.
CASE NO. IPC-03-
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 (Idaho Power;
Company) provide the following documents and information on or before THURSDAY,
DECEMBER 11, 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 behalfmay later obtain that will augment the documents produced.
FIRST PRODUCTION REQUEST TO
IDAHO POWER NOVEMBER 13, 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 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.
Request No.1: Please identify all PURPA QFs with existing levelized contracts.
A. For each QF please provide project name and nameplate capacity.
B. For each QF please provide a contact person and that person s address.
Request No.2: Please identify all QFs identified as non-compliant with current
insurance requirements.
Request No.3: Please identify all insurance companies utilized by QFs with levelized
PURP A contracts.
Request No.4: Please identify all insurance companies contacted by Idaho Power
Company regarding Case -292 insurance requirements.
Request No.5: Please identify all QFs with levelized Idaho Power PURP A contracts
that have defaulted and ceased operations with outstanding overpayment liability.
A. Please provide specifics on amounts owed the Company by said QFs.
B. Please provide specifics on contract enforcement measures pursued by the
Company to collect any outstanding overpayment liability.
Request No.6: Please provide a copy of all responses received by Idaho Power in reply
to the notices of non-compliance that have been sent to various projects.
FIRST PRODUCTION REQUEST TO
IDAHO POWER NOVEMBER 13 , 2003
Respectfully submitted this
.".,
/3
day of November 2003.
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Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
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FIRST PRODUCTION REQUEST TO
IDAHO POWER NOVEMBER 13 2003
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF NOVEMBER 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-03-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L. KLINE, SENIOR ATTORNEY
MONICA B. MOEN, ATTORNEY II
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RANDY C. ALLPHIN
CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
CERTIFICATE OF SERVICE