20111118Magic Wind 1-5 to IPC.pdf

McDevitt & Miller LLP
Lawyers RECEIVED
[phone]
[phone] (Fax)
420 W. Bannock Str~ l NOV '8 pM I: 1.1.
P.O. Box 2564-8370ï" ll 'l'l
Boise, Idaho 83702
Chas. F. McDevitt
Dean J. (Joe) Miler
November 18, 2011
Via Hand Delivery
Jean Jewell, Secreta
Idaho Public Utities Comnssion
472 W. Washigton St.
Boise, Idaho 83720
.
Re: Case No. IPC-E-11-20
Magc Wind, LLC
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of Magic Wind, LLC's First Production Requests to
Idaho Power Company.
Kidly retu a fie staped copy to me.
Very Truy Yours,
McDevitt & Mier UP
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Encl.
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....OC('t.!\ir=ni "ti J t.... j "t. toe", ~.,~~Dean J. Miler (/SE No. 1968)
Chas. F. McDevitt (ISE No. 835)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, il 83702
Tel: [phone]
Fax: [phone]
ioe~cdevitt-miler.com
cha~cdevitt-mi1er.com
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ZOll NOV 18 PH 1= 44
.
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Attorneys for Magic Wind, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION.
OF IDAHO POWER COMPANY FOR
APPROVAL AND/OR
ACKNOWLEDGEMENT OF THE
TERMNATION OF THE FIRM ENERGY
SALES AGREEMENT, REMOVAL FROM
THE INTERCONNCTION QUEUE, AND
DISPOSITION OF THE CLUSTER GROUP
NETWORK UPGRADE FUNDS FOR MAGIC
WIND,LLC.
)
) CASE NO. IPC-E-11-20
)
)
) FIRST PRODUCTION
) REQUEST OF MAGIC WIND,
) LLC TO IDAHO POWER
) COMPAN
)
)
COMES NOW, Magic Wind, LLC ("Magic Wind") by and though its attorneys
of record, McDevitt & Miler, LLP., request that Idaho Power Company ("Idaho Power
Company; Company; IPCo") provide the following documents and inormation on or
before FRIDAY, DECEMBER 2, 2011.
Ths Production Request is continuing, and Idaho Power Company is requested to
provide, by way of supplementa responses, additional documents tht it or any person
acting on its behalf may later obtan that wil augment the documents produced.
Please provide answers to each question, supporting workpapers that provide
detal or are the source of inormation used in calculations. The Company is reminded
that responses pursuat to Commission Rules of Procedure must include the name and
FIRST PRODUCTION REQUEST OF MAGIC WIND, LLC TO IDAHO POWER COMPANY-l
phone number of the person preparg 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 wrtten copies provided as response to the questions, please r'O'
provide all Excel and electronic files on CD with formulas activated.
REQUEST NO.1: At Page 8-9, Paragraph 16 (a), of the Application on file
herein, the Company proposes to deduct from the Magic Wind deposit of $562,536 the
sum of $76,569.33, which the Company considers non-refudable. Please explain in ful
the rationale and legal authority for considering that sum non-refudable.
REQUEST NO.2: At Page 8-9, Paragraph 16 (b), of the Application on file
herein the Company proposes to make a refua without interest. Please explai in ful
the rationale and legal authority for refuding the prepayment without interest.
REQUEST NO.3: Please adt tht if interest is due upon the amount to be
refuded, interest should be calculated in accordace with the methodology contaned at
18 C.F.R. 35.l9a.
REQUEST NO.4: If you have denied the proceeding request please state the
rational and legal authority for your denial.
REQUEST NO.5: Please produce all documents that support or pertn to
your answers to Request Nos. 1 though 4.
DATED this \ \( day of November, 2011.
FIRT PRODUCTION REQUEST OF MAGIC WIND, LLC TO IDAHO POWER COMPANY-2
CERTIFICATE OF SERVICE
I he~ebý!certify that on the ~ay of November, 2011, I caused to be served,
via the methodes) indicated below, tre and correct copies of the foregoing document,
upon:
Jean Jewell, Secreta
Idaho Public Utilties Commssion
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjeweiicmpuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Donovan E. Waler
Jason B. Wiliams
. Idao Power Company
1221 W. Idaho Street
P.O. Box 70
Boise, ID 83707
dwalkercmidahopower.com
iwillmascmidahopower.com
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
~I.
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..I.
..I.f:ùù¥-
Krstie Sasser
Idaho Public Utities Comnssion
472 West Washigton Street
P.O. Box 83720
Boise,ID 83720-0074
krs.sasser!gpuc.idaho.gov
Hand Delivered ~
U.S. Mail ..I.
Fax ..I.
Fed. Express ..
;kEmail
FIRST PRODUCTION REQUEST OF MAGIC WIND, LLC TO IDAHO POWER COMPAN-3