20110602Staff 1-5 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
RECENED
in\\ JUN -2 M~ 9: 4 \
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 A
DETERMINATION REGARDING A FIRM
ENERGY SALES AGREEMENT BETWEEN
IDAHO POWER AND RAINBOW RANCH
WIND,LLC
)
) CASE NO. IPC-E-11-09
)
) 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,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information on or before THURSDAY, JUNE 23, 2011.
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.
Please provide answers to each question and any 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 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.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 JUE 2, 2011
REQUEST NO.1: Please provide a copy of the Environmental Attributes agreement
between Idaho Power and Clark Canyon LLC referred to in Section 8.1 of the Firm Energy Sales
Agreement.
REQUEST NO.2: This Firm Energy Sales Agreement appears to be the first for Idaho
Power in which a separate agreement has been executed concerning Environmental Attributes. Please
explain why a separate agreement for Environmental Attributes was executed. Please generally
describe the ownership arrangement and financial considerations between the paries as reflected in
the Environmental Attributes agreement.
REQUEST NO.3: Please provide a map showing the location of the proposed point of
interconnection (Peterson substation) in relation to the location of the Clark Canyon facility and any
other utility substations and transmission facilities of 69 kV and higher. Please clearly identify those
facilties owned by Idaho Power and those owned by other utilities.
REQUEST NO.4: Please provide a copy of the transmission feasibility study and any other
transmission studies completed for this project.
REQUEST NO.5: Reference the following prior Commission Cases and associated Orders:
IPC-E-92-29 Earh Power Energy and Minerals, Inc. vs. Idaho Power Company; Order Nos.
25174, 25249
UPL-E-93-4 Island Power Company, Inc. vs. PacifiCorp, dba Utah Power & Light Company;
Order Nos. 25245, 25528
WWP-E-94-6 Vaagen Bros. Lumber, Inc. vs. The Washington Water Power Company; Order
No. 25176
Please discuss whether Idaho Power considered any of these cases and orders in determining whether:
a. the Idaho Commission has jurisdictional authority to approve a PURP A agreement for a
facility not located in Idaho and not delivering power to an substation located in Idaho,
and
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JUNE 2, 2011
b. whether Clark Canyon is entitled to published avoided cost rates in Idaho when the facility
is not located in Idaho and does not deliver power to a substation located in Idaho.
~~Dated at Boise, Idaho, this (/-day of June 2011.
~a..~DA.
KriS; A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqlipce i I.9ksrps prod req i
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 JUE 2, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF JUE 2011, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-ll-09, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOV AN E WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalkerCiidahopower.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMIN
IDAHO POWER COMPANY
POBOX 70
BOISE ID 83707-0070
E-MAIL: rallphinCiidahopower.com
JJ~
SECRETAR
CERTIFICATE OF SERVICE