20070220Staff to IPC 1-5.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 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
IN THE MATTER OF IDAHO POWER
COMP ANY'S PETITION TO REVISE THE
PUBLISHED AVOIDED COST RATES TO
INCLUDE A DAILY LOAD SHAPE; AND
TO CLARIFY THE RULES GOVERNING
ENTITLEMENT TO PUBLISHED AVOIDED
COST RATES.
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 information as soon as possible, but no later than
MARCH 13, 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 FEBRUARY 20, 2007
REQUEST NO.1: Please provide, in an Excel spreadsheet in electronic format, the raw
data used to compute the weighted heavy and light load hour Mid-Columbia prices as shown on
page 1 of Attachment I to the Company s Application.
REQUEST NO.2: Please provide, in an Excel spreadsheet in electronic format, a copy of
the spreadsheets attached as pages 3-6 of Attachment 1 to the Company s Application.
REQUEST NO.3: With regard to the proposed "Definition of a Small Power Production
Facility Eligible to Receive Published Rates " what rate would be paid to a facility that fails part
way through the term of its power sales agreement to maintain its eligibility? How would such a
rate be determined?
REQUEST NO.4: If the proposed "Definition of a Small Power Production Facility
Eligible to Receive Published Rates" had been in place in the past, would any projects that now
have power sales agreements have been precluded from obtaining them under the proposed
definition? If so, which ones?
REQUEST NO.5: Are there any pending power sales agreements (i., those that are at
some stage in the negotiation process) that might be affected by the proposed "Definition of a Small
Power Production Facility Eligible to Receive Published Rates ? If so, which ones?
DATED at Boise, Idaho, this J~~ay of February 2007.
sco
Deputy Attorney General
Technical Staff: Rick Sterling
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FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY FEBRUARY 20, 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF FEBRUARY 2007
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, 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
SE TARY
CERTIFICATE OF SERVICE