20070620Staff to IPC 15-18.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
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
CASSIA GULCH WIND PARK, LLC AND
CASSIA WIND FARM, LLC,CASE NO. IPC-06-
COMPLAINANTS,
IDAHO POWER COMPANY,
RESPONDENT.
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 (Company;
IPC) provide the following documents and information as soon as possible, but no later than
THURSDAY, JULY 5, 2007.
This Production Request is to be considered as continuing, and Idaho Power Company 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.
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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 20, 2007
REQUEST NO. 15: If all projects in the queue commit to redispatch, participate in the
network upgrade and obtain full refund within the ten year period, what is the estimated Idaho
Power transmission investment subject to rate base for the Twin Falls cluster? What is the
estimated additional cost per kWh incurred by Idaho Power to provide transmission for these
PURP A projects over the ten-year period?
REQUEST NO. 16: How does Idaho Power s investment commitment in Network
upgrades with redispatch change if only Cassia commits to participate?
REQUEST NO. 17: Under what circumstances would a project developer not receive a
full refund ofthe transmission cost advance at the end of the ten-year refund period?
REQUEST NO. 18: How will transmission network upgrade costs be allocated
(including those borne by Idaho Power) ifprojects in the queue continue to request firm network
interconnection services but do not commit to redispatch?
DATED at Boise, Idaho, this
C)1J
day of June 2007.
Scott' oodbury
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Deputy Attorney General
Technical Staff: Rick Sterling
i :umisc:prodreq/ipceO6.21 SW11Js ipc 1
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY JUNE 20, 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF JUNE 2007
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-06-, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DEAN J. MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
RONALD K ARRINGTON
ASSOC. CHIEF COUNSEL
JOHN DEERE CREDIT
6400 NW 86TH ST
JOHNSTON IA 50131
BARTON L KLINE
LISA NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
DAVID SIKES
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
DAVID J MEYER
SENIOR VICE PRESIDENT
AVISTA UTILITIES
PO BOX 3727
SPOKANE W A 99220
BRIAN DICKMAN
DEAN S BROCKBANK
ROCKY MOUNTAIN POWER
201 S MAIN ST SUITE 2300
SALT LAKE CITY UT 84111
PETER J RICHARDSON
RICHARDSON & O'LEARY
PO BOX 7218
BOISE ID 83702
LA WRENCE R LIEB
EXERGY DEVELOPMENT GROUP
OF IDAHO LLC
910 WMAIN ST SUITE 310
BOISE ID 83702
R. BLAIR STRONG
PAINE HAMBLEN ET AL
STE 1200
717 W SPRAGUE AVE
SPOKANE WA 99201
.1
SECRET AR Y
CERTIFICATE OF SERVICE