20100621Staff 1-4 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
RECEf:'lEO
ZUlÐJUN 21 PH 2: 40
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF
IDAHO POWER COMPANY FOR THE
APPROVAL OF A FIRM ENERGY SALES
AGREEMENT WITH GRAND VIEW SOLAR
PV ONE, LLC, FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY.
)
) CASE NO. IPC-E-I0-19
)
) 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 (Company;
IPC) provide the following documents and information as soon as possible, but no later than
MONDAY, JULY 12,2010.
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 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 JUNE 21, 2010
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 hearng 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: On pages 5 and 6 of its Application, Idaho Power states,
With respect to the power purchase agreement criteria, Grand View and Idaho
Power had resolved all material outstanding contract issues prior to March 16,
2010. However, the Company was also evaluating an alternative, non-PURPA
power purchase agreement with Grand View regarding this Facilty. Idaho Power
completed this evaluation and review on or about May 6,2010, and elected not to
proceed with a non-PURP A contract for this project.
Please provide copies of any draf agreements, spreadsheets, analysis, correspondence or
other documentation that relates to the "evaluation and review" referred to in the Company's
statement above.
REQUEST NO.2: Please explain in greater detail why Idaho Power was considering a
non-PURP A power purchase agreement with Grand View. Had the Grand View project been bid
in any formal request for proposals or other solicitation issued by Idaho Power? Under what
circumstances might Idaho Power enter into non-PURP A power sales agreements with small
renewable energy projects?
REQUEST NO.3: Please explain why Idaho Power "elected not to proceed with a non-
PURP A contract" for the Grand View project.
REQUEST NO.4: On page 5 of its Application, Idaho Power lists criteria that it
believes should be satisfied in order for projects to be eligible for grandfathering under the rates
in Order No. 30744. Those criteria state, in par:
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JUE 21, 2010
a. Interconnection and Transmission
1. Filed an interconnection application; and
11. Received and accepted an interconnection feasibilty study report for the
project and paid any requested study deposits (or established credit) for the next phase of the
interconnection process in accordance with Schedule 72; and
ll. Received confirmation from Idaho Power that transmission capacity is
available for the project and/or received and accepted transmission capacity study results and
cost estimates.
In reference to the above criteria, please provide the following:
a) The date on which an interconnection application was received by Idaho Power;
b) A copy of the interconnection feasibilty report that was received and accepted by
Grand View;
c) A copy of written documentation from Idaho Power confirming that transmission
capacity is available for the project and/or documentation that Grand View received and
accepted transmission capacity study results and cost estimates, and
d) A summar of the amounts and dates on which Grand View paid any requested study
deposits (or established credit).
DATED at Boise, Idaho, this di ~ay of June 2010.
~,v~
Scott Woodbur
Deputy Attorney General
Technical Staff: Rick Sterling
i: umise: prodreq/ipce i o.i 9swrps ipc 1
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 JUNE 21,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF JUE 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-IO-19, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOV AN E WALKER
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(fidahopower.com
lnordstrom(fidahopower .com
RANDY C ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(fidahopower.com
,b~
SECRETAR
CERTIFICATE OF SERVICE