20100823Staff 1-5 to IPC.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
ISB NO. 6864
RECE
iU\tllUG 23 ~t\ \0: 04
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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 THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL )
OF A FIRM ENERGY SALES AGREEMENT )
WITH YELLOWSTONE POWER, INC. FOR )
THE SALE AND PURCHASE OF ELECTRIC )ENERGY. )
)
)
CASE NO. IPC-E-10-22
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 Woodbury, Deputy Attorney General, requests that Idaho Power Company (Idaho Power;
Company) provide the following documents and information as soon as possible, but no later
than SEPTEMBER 13, 2010.
This Production Request is to be considered as continuing, and Idaho Power 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.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Idaho Power is reminded that responses pursuant
to Commission Rules of Procedure must include the name and phone number of the person
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY AUGUST 23,2010
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 IDAPA
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.1: Were any draft power sales agreements prepared and exchanged
between the paries prior to March 15, 201 O? If so, please provide a copy of the draft agreements
and cite the dates on which each draft was mailed to either Idaho Power or to Yellowstone
Power, Inc. (Yellowstone).
REQUEST NO.2: Did Yellowstone ever sign either a draft or final power sales
agreement prior to March 16,2010 (either with or without a corresponding signature by Idaho
Power)? If so, please provide a copy of the agreement.
REQUEST NO.3: On what date did Idaho Power first provide to Yellowstone a final
agreement requesting signature by Yellowstone?
REQUEST NO.4: At p. 8, ~ 13, the Application states the following:
Since early June 2010, Idaho Power has been working through internal
contract drafting and review processes. Any perceived delays from early
June 2010 to an execution date of July 28,2010, were not due to
reconsideration of Idaho Power's agreement to pursue the attached
Agreement. Instead the perceived delays were due to change in personnel,
internal review processes, and the efforts being expended on other PURP A
contracts and issues. (emphasis added).
Please discuss what activity, if any, occured involving either pary between March 16, 2010 and
early June 2010 relating to execution of the power sales agreement. Please explain why contract
drafting and review did not occur prior to early June 2010, and also why contract drafting and
review did not occur prior to March 16,2010.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 AUGUST 23,2010
REQUEST NO.5: Please provide any written documentation or other evidence Idaho
Power has that it believes demonstrates that Idaho Power and Yellowstone had agreed prior to
March 16, 2010 to all terms and conditions identical to those contained in the final Agreement.
DATED at Boise, Idaho, this~day of August 2010.~
~~
Nfil Price
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqlipcelO.22nprps prl
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 AUGUST 23, 2010
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23RD DAY OF AUGUST 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-1O-22, 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(ßidahopower.com
lnordstrom(ßidahopower .com
RANDY C ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(ßidahopower.com
DICK VINSON
YELLOWSTONE POWER, INC.
PO BOX 1539
THOMPSON FALLS MT 59873
E-MAIL: dick(ßblackfoot.net
DEAN J. MILLER
MCDEVITT & MILLER LLP
420 WEST BANNOCK ST
BOISE ID 83701
E-MAIL: joe(ßmcdevitt-miler.com
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SECRETARY
CERTIFICATE OF SERVICE