20100715Staff 5-9 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 1895
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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
)
) SECOND 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
THURSDAY, AUGUST 4, 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 will augment the documents produced.
F or 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
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY JULY 15,2010
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 hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.5: With respect to the negotiation of a PURP A agreement, please
provide copies of any draft power sales agreement(s) exchanged between the parties,
correspondence, or other documentation that demonstrates that Idaho Power and Grand View
Solar had resolved all material outstanding contract issues prior to March 16,2010.
REQUEST NO.6: Please provide copies of any documentation, correspondence or
other evidence showing the date on which Grand View requested to negotiate a PURPA power
sales agreement with Idaho Power.
REQUEST NO.7: Please explain, in layman's terms, the significance of the
Acknowledgement Acceptance letter dated July 7, 2010 provided as an attachment in response to
Staffs Request No. 4(c). Please explain how the letter satisfies the following criteria identified
by Idaho Power that it believes should be satisfied in order for projects to be eligible for
grandfathering under the rates in Order No. 30744:
iii. 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.
REQUEST NO.8: Please provide any evidence that Idaho Power believes conclusively
demonstrates that a PURP A agreement with Grand View Solar was materially complete prior to
March 16, 2010, except for routine Idaho Power final processing.
REQUEST NO.9: Please explain how long it normally takes for Idaho Power to
complete "routine Idaho Power final processing" for PURP A agreements. Does Idaho Power
consider the time between March 16,2010 and June 14,2010, the date on which Idaho Power
fied its Application in this case, to be typical to accomplish routine final processing?
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 15,2010
~DATED at Boise, Idaho, this iS day of July 2010.
Technical Staff: Rick Sterling
i:umisc:prodreq/ipcel O. i 9swrps ipc2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
-4~~Scott Woodbur
Deputy Attorney General .
3 JULY 15,2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF JUNE 2010,
SERVED THE FOREGOING SECOND 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:
DONOVAN E WALKER
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(iidahopower.com
lnordstrom(iidahopower. com
RANDY C ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(iidahopower.com
Qi~
SECRETA
CERTIFICATE OF SERVICE