200402271st Request of Staff to ID Power.pdf

RECEIVED
FiLED
ITJ
SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
ZOGy FE8 27 Pr'; 2: f 5
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UTILITiES COf'H'i!SSION
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 APPROVAL
OF AN AGREEMENT FOR SALE AND
PURCHASE OF ELECTRIC ENERGY
BETWEEN IDAHO POWER COMPANY AND
RENEWABLE ENERGY OF IDAHO, INc.
CASE NO. IPC-04-
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 FRIDAY,
MARCH 19, 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 27 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 ofthe 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 provide a description of how the Optional Base Energy Prices
have been established.
Request No.2: Please explain how the method used to establish the Optional Base
Energy Prices conforms with the methodology described in the Settlement Stipulation in Case
No. IPC-95-9. The Settlement Stipulation describes in detail how avoided cost rates are to be
negotiated with Qualifying Facilities larger than 1 MW (now 10 MW as per Order Nos. 29029
and 29069).
Request No.3: Please provide the avoided cost rates that result from analysis according
to the methodology described in the Settlement Stipulation in Case No. IPC-95-9. In the
analysis, consider the full 17.5 MW capacity of the project. Staff presumes that the AURORA
model will be used for this analysis.
Request No.4: Please provide copies of any market price data used as the basis for
establishing the Optional Base Energy Prices. Include market price data for any specific day or
days used as the basis for the prices, as well as market price data for any other time frames
examined. Please identify the market products represented by the market prices (firm, non-firm
on-peak, off-peak). Please provide any analysis used by the Company to compare market prices
to the Optional Base Energy Prices contained in the Agreement between Idaho Power and
Renewable Energy of Idaho, Inc.
Request No.5: Please provide any analysis done by the Company to compare the
Optional Base Energy Prices to other Idaho Power alternatives, such as the recent PPL Montana
agreement.
FIRST PRODUCTION REQUEST
TO IDAHO POWER FEBRUARY 27, 2004
Respectfully submitted this
Technical Staff: Rick Sterling
i:umisc:prodreqlipceO4.5swrps prl
FIRST PRODUCTION REQUEST
TO IDAHO POWER
07
day of February 2004.
Scott Wood ury
Deputy Attorney General
FEBRUARY 27 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF FEBRUARY 2004
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-04-
BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
MONICA MOEN
BARTON L KLINE
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
SECRETAR
CERTIFICATE OF SERVICE