20070108Staff to IPC 1-7.pdf

CECELIA A. GASSNER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6977
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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
IDAHO WINDS LLC FOR THE ALKALI WINDGENERATION FACILITY.
CASE NO. IPC-06-
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
Cecelia A. Gassner, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
TUESDAY, JANUARY 23, 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. For each
request, it is only necessary to provide copies of information dated later than August 19, 2005
because Idaho Winds provided to Staff on that date copies of all of its prior documentation in
support of grandfathering under Order No. 29839.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JANUARY 8, 2007
REQUEST 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? Ifno 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.
REQUEST NO.2: Please provide correspondence or similar documentation that financing
for the project was secured prior to August 4 2005.
REQUEST NO.3: Please provide documentation that Application for Interconnection has
been made and indicate the date on which Idaho Power received the application.
REQUEST NO.4: Please provide documentation that a signed Firm Energy Sales
Agreement had been tendered to Idaho Power prior to August 5, 2005.
REQUEST 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.
REQUEST 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.
REQUEST 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.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JANUARY 8, 2007
DATED at Boise, Idaho, this day of January 2007.
Deputy Attorney General
Technical Staff: Rick Sterling
i: umisc :prodreq/i pceO6.3 6c grps
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JANUARY 8, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 8TH DAY OF JANUARY 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER IN CASE NO. IPC-06-, BY
MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
MONICA B MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
RIC GALE
VP - PRICING & REGULATORY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
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SECRETARY
CERTIFICATE OF SERVICE