200508021st staff request to Idaho Power.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
4 72 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 APPROVAL
OF A FIRM ENERGY SALES AGREEMENT
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY BETWEEN IDAHO
POWER COMPANY AND ARROW ROCK
WIND, INC.
CASE NO. IPC-05-
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 AUGUST 16 2005.
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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER AUGUST 2, 2005
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 a copy of the lease agreement between Arrow Rock
Wind, Inc. and the owner of the specific generation equipment as specified in Appendix B of the
Agreement.
Request No.2: Please provide a map to scale of the Judith Gap area showing the
locations of the thirteen individual turbines numbered 41-53 in Appendix B of the Agreement in
relation to any other turbines now installed or to be installed by the owner of the generation
facility in the same general vicinity. Please describe how the thirteen turbines constituting the
Arrow Rock proj ect are separate and distinct from other turbines in the vicinity owned by the
same owner or installed in the same approximate time frame.
Request No.3: Please provide a copy of the Qualifying Facility Certificate issued by the
FERC for the Arrow Rock project, or alternatively provide a copy in accordance with 18 CFR
~292.207 (a)(ii) of the Qualifying Facility self-certification filing made with the FERC.
Respectfully submitted this uP day of August 2005.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
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FIRST PRODUCTION REQUEST
TO IDAHO POWER AUGUST 2, 2005
CERTIFICA TE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF AUGUST 2005
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER, IN CASE NO. IPC-05-, BY MAILING A COpy
THEREOF POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
MONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RANDY ALLPHIN
CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
TED SORENSEN
ARROW ROCK WIND INC
5203 SOUTH 11 TH EAST
IDAHO FALLS ID 83404
CERTIFICATE OF SERVICE