200407123rd Request of Staff to ID 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]
BAR NO. 1895
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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-GENERATORS AND SMALL POWERPRODUCERS.
CASE NO. IPC-03-
THIRD 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 MONDAY, JULY 26,
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.
THIRD PRODUCTION REQUEST TO
IDAHO POWER JULY 12, 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. 12: Regarding the Company s response to Staff prior Production Request
No., regarding Idaho Power/QF contracts with levelized rates that are in non-compliance with
292 security requirements, the Company s response to the question addressed only non-
compliance with insurance requirements.
A. Please identify all Idaho Power/QF contracts with levelized rates that are subject
to the Commission s -292 second lien security requirements.
B. Of those, please identify all projects with an existing and filed second lien.
C. For those QF projects without a second lien, please indicate whether this was a
result of a) administrative neglect by Idaho Power or b) an election by the QF to
post liquid security.
D. For each QF project out of compliance with -292 second lien security
requirements, please provide project name and present accrued overpayment
liability. For each project, please detail the Company s related enforcement
efforts.
Respectfully submitted this
I;) 1h
day of July 2004.
Technical Staff: Rick Sterling
i :umisc:prodreq/ipceO3 .16swrps3
THIRD PRODUCTION REQUEST TO
IDAHO POWER JULY 12, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF JULY 2004
SERVED THE FOREGOING THIRD 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