200403262nd Request of Staff to ID Power.pdf

,r-
,-
\i
,--,.,,~ - ~
SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
iLED
zon!jl'1F\R 26 Pr1 3: 23
; ,,-
J,) L- i L
,-jTll,,~r!'~~s CDr~ir'1ISSI0N
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 ANDTHE J. R. SIMPLOT COMPANY
CASE NO. IPC-04- 7
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
APRIL 9, 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 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 behalf may later obtain that will augment the documents produced.
SECOND PRODUCTION REQUEST
TO IDAHO POWER MARCH 26, 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.3: Please provide a summary of the historical monthly generation of the
project from the beginning of the firm energy agreement in January 1991 through the present.
Please list separately the monthly kWhs paid at the firm energy rate and the kWhs paid at the
non- firm energy rate.
Request No.4: Has the project ever generated in excess of 10 000 kWh per hour since it
went online? Has Idaho Power ever sent any written warnings or correspondence to the project
owner for exceeding 10 MW of capacity? If so, please provide a copy of the warnings or
correspondence.
Respectfully submitted this tt-day of March 2004.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqlipceO4.7sW11JS pr2
SECOND PRODUCTION REQUEST
TO IDAHO POWER MARCH 26, 2004
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF MARCH 2004
SERVED THE FOREGOING SECOND 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
DAVID HAWK
J R SIMPLOT COMPANY
PO BOX 27
BOISE ID 83707
-.b
SECRETAR
CERTIFICATE OF SERVICE