200403151st Request of Staff to ID 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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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 APPROV AL )
OF AN AGREEMENT FOR SALE AND
PURCHASE OF ELECTRIC ENERGY
BETWEEN IDAHO POWER COMPANY ANDTHE J. R. SIMPLOT COMPANY
CASE NO. IPC-04- 7
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 TUESDAY,
APRIL 6, 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 MARCH 15 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.1: 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. 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).
the analysis, consider the full 15.9 MW capacity of the project. Staff presumes that the
AURORA model will be used for this analysis.
Request No.2: Please explain how the proposed energy prices in the Agreement
comport with the methodology described in the Settlement Stipulation in Case No. IPC-95-
Request No.3: Please provide copies of January and February 2004 extensions of the
1991 Agreement. Please explain why energy purchased from Simp lot during the January and
February 2004 extensions should not be treated as purchases pursuant to a voluntary supply
contract, rather than mandatory purchases under PURP A.
Respectfully submitted this /5" day of March 2004.
Deputy Attorney General
Technical Staff: Rick Sterling
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FIRST PRODUCTION REQUEST
TO IDAHO POWER MARCH 15 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF MARCH 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
DA VID HAWK
J R SIMPLOT COMPANY
PO BOX 27
BOISE ID 83707
SECRE
CERTIFICATE OF SERVICE