20090921Staff 1-5 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
RECEIVED
20R9 SEP 21 PH 2: 20
iDAHO PU¡31~F:;;",
UTILITIES COMlv\¡;)\)i
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF
IDAHO POWER COMPANY FOR THE
APPROVAL OF A FIRM ENERGY SALES
AGREEMENT FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
BETWEEN IDAHO POWER COMPANY
AND IDAHO WINDS LLC.
)
) CASE NO. IPC-E-09-25
)
) FIRST PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbur, Deputy Attorney General, requests that Idaho Power Company (Coinpany;
IPC) provide the following documents and information as soon as possible, but no later than
TUESDAY, OCTOBER 13,2009.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementar responses, additional documents that it or any
person acting on its behalf may later obtain that wil 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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 SEPTEMBER 21, 2009
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the wrtten copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please confirm whether the proposed Sawtooth Wind Project is, in
fact, substantially the same as the Alkali Wind Project that formerly held a power sales
agreement with Idaho Power. Reference Case No. IPC-E-06-36, Order No. 30253.
REQUEST NO.2: Please describe all circumstances, features, characteristics or other
factors associated with the Sawtooth Wind Project that Idaho Power believes distinguish it from
other projects included in the QF transmission and interconnection studies for proposed facilties
to be located in the Magic Valley. Please explain why Idaho Power believes the circumstaces,
features, characteristics or other factors justify offering Idaho Winds LLC a new power sales
agreement for the Sawtooth Wind Project.
REQUEST NO.3: Please list and identify all other QF projects included in the QF
transmission and interconnection studies for the Magic Valley that now have power sales
agreements with Idaho Power. Please identify those projects that negotiated extensions to their
proposed online dates due to delays in completing the transmission and interconnection studies.
For these projects, please explain why each could not terminate their existing contracts and seek
new contracts at higher avoided cost rates in the same maner in which Idaho Winds LLC has
done for the Sawtooth Project.
REQUEST NO.4: The power sales agreement for the Alkali Wind Project was
terminated by mutual agreement of the paries by way of a May 6, 2008 letter agreement. Is it
the Company's belief that filing of the termination agreement with the Commission on May 20,
2008 constitutes "acceptance of the termination" by the Commission? Please explain. Please
discuss why Idaho Power believes the Sawtooth Wind Project should not be bound by the same
rates, terms and conditions as were included in the Alkali contract.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 SEPTEMBER 21, 2009
REQUEST NO.5: Please describe any actions or contract provisions included in new
QF contracts that Idaho Power believes will deter QF contract holders from terminating or
defaulting on existing contracts in order to negotiate new contracts at higher avoided cost rates.
sr
DATED at Boise, Idaho, thisdJ I day of September 2009.
~u~~~Woodbu~
Deputy Attorney General
-
Technical Staff: Rick Sterling
i:umise:prodreq/ipce09.25swrps ipel
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 SEPTEMBER 21, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF SEPTEMBER 2009,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-09-25, BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOV AN WALKER
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalkerCiidahopower.com
bklineCiidahopower .com
RANDY C ALLPHIN
CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphinCiidahopower.com
TOM FETZER
IDAHO WIND FARMS LLC
4255 S NICKEL CREEK PLACE
MERIDIAN ID 83642
~b~SECRETAR --
CERTIFICATE OF SERVICE