20070110IPC to Staff 1-7.pdf

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IDAHO~POWER~
An IDACORP Company
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Barton L. Kline
Senior Attorney
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January 9 2007
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-06-
In the Matter of the Application of Idaho Power Company for Approval
of a Firm Energy Sales Agreement for the Sale and Purchase
Electric Energy Between Idaho Power Company and Hot Springs
Windfarm LLC
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company s Response to the First Production Request of Commission Staff regarding the
above-referenced matter.
I would appreciate it if you would return a stamped copy of this transmittal letter
to me in the enclosed self-addressed stamped envelope.
Very truly yours
~\~
Barton L. Kline
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Enclosures
O. Box 70 (83707)
1221 W. Idaho St.
Boise, 1083702
BARTON L. KLINE, ISB # 1526
MONICA B. MOEN , ISB # 5734
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
Attorneys for Idaho Power Company
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2001 JMJ - 9 Pi'1 4: 36
IDi\i'iO i LiC
UTILITIES CC ;..:1381(::
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 HOT SPRINGS WINDFARM LLC
) CASE NO. IPC-06-
IDAHO POWER COMPANY'
RESPONSE TO FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company ) and, in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated January 3 2007, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 1
REQUEST FOR PRODUCTION NO.1: Please provide a copy of the Uniform
Interconnection Agreement if one has been signed.If a Uniform Interconnection
Agreement has not been signed , when is a signed agreement expected? If no Uniform
Interconnection Agreement will be signed for this project, please indicate whether a
different interconnection agreement will be executed. If already executed, please provide
a copy.
RESPONSE TO REQUEST NO.Hot Springs has not signed a Uniform
Interconnection Agreement.Idaho Power has no reason to believe that a Uniform
Interconnection Agreement will not be signed for this project. If there are no cluster or
queue issues that arise requiring additional studies, it is anticipated that the Uniform
Interconnection Agreement could be signed by year-end 2007.
The response to this request was prepared by David "Kip" Sikes Manager
Commercial Development in consultation with Barton L. Kline, Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF ' Page 2
REQUEST FOR PRODUCTION NO.2: Please provide correspondence or similar
documentation that financing for the project was secured prior to August 4 2005.
RESPONSE TO REQUEST NO.2: The developer of the Hot Springs Windfarm
project has advised the Company that all or some portions of the documentation and
correspondence associated with the requested information are valuable trade secrets and
as such has requested that Idaho Power maintain the confidentiality of this information.
Idaho Power will make copies of the requested information available for review, in
accordance with the Protective Order in effect for this case, in Idaho Power s discovery
room. To schedule an appointment to review information in the discovery room please
contact Sandra Holmes at [phone].
Idaho Power further advises that some of the documentation and correspondence
which Idaho Power reviewed in its analysis of this issue is not currently in its possession.
This information has , at Hot Spring s request, been returned to Hot Springs and may be
reviewed at the offices of Hot Spring s legal counsel , Dean J. Miller. Please contact Mr.
Miller office to schedule an appointment to review this portion of the information
concerning Hot Spring s financing efforts prior to August 4, 2005.
The response to this request was prepared by Randy Allphin, Administrator
Power Supply Planning in consultation with Barton L. Kline, Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 3
REQUEST FOR PRODUCTION NO.Please provide documentation that
Application for Interconnection has been made and indicate the date on which Idaho
Power received the application.
RESPONSE TO REQUEST NO.3: The developer of the Hot Springs Windfarm
project has advised the Company that all or some portions of the documentation and
correspondence associated with the requested information are valuable trade secrets and
as such has requested that Idaho Power maintain the confidentiality of this information.
Idaho Power will make copies of the requested information available for review , in
accordance with the Protective Order in effect for this case , in Idaho Power s discovery
room. To schedule an appointment to review information in the discovery room please
contact Sandra Holmes at [phone].
The response to this request was prepared by David "Kip" Sikes Manager
Commercial Development in consultation with Barton L. Kline, Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 4
REQUEST FOR PRODUCTION NO.4: Please provide documentation that a
signed Firm Energy Sales Agreement had been tendered to Idaho Power prior to August
, 2005.
RESPONSE TO REQUEST NO.4: Idaho Power will make copies of the requested
information available for review, in accordance with the Protective Order in effect for this
case , in Idaho Power s discovery room. To schedule an appointment to review information
in the discovery room please contact Sandra Holmes at [phone].
The response to this request was prepared by Randy Allphin , Administrator
Power Supply Planning in consultation with Barton L. Kline , Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 5
REQUEST FOR PRODUCTION NO.5: Please provide evidence that the Facility,
as of August 5 , 2005, had made substantial progress on the other secondary criteria as
described in Order No. 29839.
RESPONSE TO REQUEST NO.5: The developer of the Hot Springs Windfarm
project has advised the Company that all or some portions of the documentation and
correspondence associated with the requested information are valuable trade secrets and
as such has requested that Idaho Power maintain the confidentiality of this information.
Idaho Power will make copies of the requested information available for review, in
accordance with the Protective Order in effect for this case , in Idaho Power s discovery
room. To schedule an appointment to review information in the discovery room please
contact Sandra Holmes at [phone].
The response to this request was prepared by Randy Allphin, Administrator
Power Supply Planning in consultation with Barton L. Kline, Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 6
REQUEST FOR PRODUCTION NO.6: Please provide copies of letters, emails
agreements or other written communications between Idaho Power and the project
representative related to any requirements that needed to be completed in order for Idaho
Power to provide a Firm Energy Sales Agreement for the project.
RESPONSE TO REQUEST NO.6: The developer of the Hot Springs Windfarm
project has advised the Company that all or some portions of the documentation and
correspondence associated with the requested information are valuable trade secrets and
as such has requested that Idaho Power maintain the confidentiality of this information.
Idaho Power will make copies of the requested information available for review, in
accordance with the Protective Order in effect for this case, in Idaho Power s discovery
room. To schedule an appointment to review information in the discovery room please
contact Sandra Holmes at [phone].
The response to this request was prepared by Randy Allphin , Administrator
Power Supply Planning in consultation with Barton L. Kline, Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 7
REQUEST FOR PRODUCTION NO.7: Please provide any other documentation
or evidence relied upon by Idaho Power in making its determination that the project is
entitled to be grandfathered under Order No. 29839.
RESPONSE TO REQUEST NO.7: The developer of the Hot Springs Windfarm
project has advised the Company that all or some portions of the documentation and
correspondence associated with the requested information are valuable trade secrets and
as such has requested that Idaho Power maintain the confidentiality of this information.
Idaho Power will make copies of the requested information available for review, in
accordance with the Protective Order in effect for this case, in Idaho Power s discovery
room. To schedule an appointment to review information in the discovery room please
contact Sandra Holmes at [phone].
The response to this request was prepared by Randy Allphin, Administrator
Power Supply Planning in consultation with Barton L. Kline , Senior Attorney, Idaho
Power Company.
Respectfully submitted this day of January, 2007.
JJ~~
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 8
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day of January, 2007, I served a true and
correct copy of the within and foregoing upon the following named parties by the
method indicated below, and addressed to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
) U.S. Mail , Postage Prepaid
(X) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email Scott.woodbury(g2puc.idaho.Qov
Dean J. Miller
Attorney for Hot Springs
McDevitt & Miller LLP
420 W. Bannock
Boise , ID 83701
) U.S. Mail, Postage Prepaid
) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email: ioe(g2mcdevitt-miller.com
f)Jd Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF, Page 9