20070627Staff to IPC 1 and 2.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
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TO ELIMINATE THE 90%/110%
PERFORMANCE BAND FOR WIND POWERED)
SMALL POWER PRODUCTION FACILITIES
IN THE MATTER OF IDAHO POWER
COMP ANY'S PETITION TO INCREASE THE
PUBLISHED RATE ELIGIBILITY CAP FOR
WIND POWERED SMALL POWER
PRODUCTION FACILITIES; AND
CASE NO. IPC-07-
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 (Company;
IPC) provide the following documents and infonnation as soon as possible, but no later than
WEDNESDAY, JULY 18, 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.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JUNE 27, 2007
REQUEST NO.1: Please provide an estimate of the cost to purchase state-of-the-art
wind forecasting services as referenced in the Company s Petition. Please provide a detailed
description of how each QF's share ofthe on-going cost of the wind forecasting services will be
detennined. For what length of time would QFs be required to make a contribution for the cost
of forecasting services? How would costs be allocated amongst QFs that are built at different
points in time?
REQUEST NO.2: Please explain how the proposed "mechanical availability
guarantee" will be computed during periods of time when there is not enough wind blowing for
wind turbines to generate.
DATED at Boise, Idaho, this d7 ~ay of June 2007.
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqlipceO7.3swrps prod reg
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY JUNE 27 2007
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 27TH DAY OF JUNE 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-07-, 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
PETER J RICHARDSON
RICHARDSON & O'LEARY PLLC
515 N 27TH STREET
PO BOX 7218
BOISE ID 83702
DR. DON READING
6070 HILL ROAD
BOISE ID 83703
WILLIAM M EDDIE
ADVOCATES FOR THE WEST
610 SW ALDER ST STE 910
PORTLAND OR 97205
NATALIE McINTIRE
RENEWABLE NORTHWEST PROJECT
917 SW OAK ST STE 303
PORTLAND OR 97205
DEAN BROCKBANK
ROCKY MOUNTAIN POWER
201 S MAIN ST SUITE 2300
SALT LAKE CITY UT 84111
BRIAN DICKMAN
ROCKY MOUNTAIN POWER
201 S MAIN ST SUITE 2300
SALT LAKE CITY UT 84111
RIDGELINE ENERGY LLC
C/O RICH RA YHILL
720 W IDAHO ST. SUITE 39
BOISE ID 83702
ROBERT MELLIS
4 NICKERSON
SUITE 301
SEATTLE WA 98109
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CERTIFICATE OF SERVICE