The URL can be used to link to this page

Home My WebLink About200406112nd Request of Staff to ID Power.pdfSCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BAR NO. 1895 f',r: ,f"'r\ L 'V . "j. ~ 'I . f" t" tL ~. U ill 203lt Jut~ \\ F\li \ 1: ~ 2 ., .,.,\ r;UBLIC UT\LYt\ES COMr-11SS\ON 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 APPROVAL OF MODIFICATIONS TO THE SECURITY PROVISIONS REQUIRED TO BE INCLUDED IN AGREEMENTS BETWEEN IDAHO POWER AND CO-GENERA TO RS AND SMALL POWERPRODUCERS. CASE NO. IPC-03- SECOND 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 FRIDAY, JULY 2 2004. 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 IDAPA 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. SECOND PRODUCTION REQUEST TO IDAHO POWER JUNE 11 , 2004 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.7: In response to Staff Production Request No., in Case No. IPC-03- Idaho Power Company identified "all QFs with levelized power purchase contracts that have defaulted and ceased operations with outstanding over payment liability . Production Request 5(B) requested specifics on contract enforcement measures pursued by the Company to collect any outstanding over payment liability. By way of further response, please indicate: 7(A) Whether the Company for each project in default had a filed second lien to secure over payment liability. 7(B) For each project without a second lien, please indicate whether a second lien was required under the Commission s -292 security requirements. 7(C) For each project subject to -292 security requirements but without a second lien please indicate whether a posting of liquid security was required. Request No. 8(A): Please identify the Idaho Power employee(s) who are now and who have previously had responsibility for QF contract administration and -292 security requirements compliance monitoring? For each individual please describe their specific responsibilities. 8(B) Please describe the Company s policy and procedures for QF contract administration and -292 security requirement compliance monitoring. If the policy and procedures are written please provide a copy. 8(C) Please describe the Company s policy and procedures regarding non-compliance with 292 second lien requirements? If the policy and procedures are written please provide a copy. SECOND PRODUCTION REQUEST TO IDAHO POWER JUNE 11 , 2004 Request No. 9(A): Please identify all Idaho Power/QF contracts with levelized rates that are in non-compliance with -292 security requirements and that have not posted liquid security for over payment liability. 9(B) For each instance of non-compliance, please describe the Company s related -292 security requirement enforcement efforts. Request No. 10(A): Please provide copies of all Company documents (written and electronic) of any kind or description, however created, produced, reproduced or stored relating to the Company s proposal in Case No. IPC-03-16 to eliminate the -292 second lien requirement. 10(B) Please provide copies of all Company documents (written and electronic) of any kind or description, however created, produced, reproduced or stored, relating to the Company alternate proposal in Case No. IPC-03-16 to outsource or retain outside counsel to complete the paperwork required to establish -292 second lien rights, including the basis for the estimated $1000 to $1500 legal fee for establishing a second lien on a QF project. Request No. 11: Please provide three sample copies of second liens prepared and filed by the Company for Idaho Power/QF contracts with levelized rates. Respectfully submitted this / ~ day of June 2004. cott oodbury Deputy Attorney General Technical Staff: Rick Sterling i :umisc :prodreqlipceO3 .16swrps2 SECOND PRODUCTION REQUEST TO IDAHO POWER JUNE 11 , 2004 CERTIFICA TE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 11 TH DAY OF JUNE 2004 SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-03-, BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING: BARTONL. 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