20111220Staff to IPC 1-4.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
REC r".~"",'.
201 I DEC 20 PH 3= 08
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION REGARDING ITS FIRM
ENERGY SALES AGREEMENT WITH
DYNAMIS ENERGY, LLC
)
) CASE NO. IPC-E-1l-25
)
) 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,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company;
Idaho Power) provide the following documents and information on or before TUESDAY,
JANUARY 10,2012.
This Production Request is to be considered as continuing, and Idaho Power is requested
to provide, by way of supplementay 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, including 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
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 20, 2011
holder and if different the witness who can sponsor the answer at hearing 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: Please provide a narrative describing how the rates included in
Appendix F have been computed. Please provide a copy of all spreadsheets and analysis used to
derive the rates. If any component of the rates was developed using AURORA, please provide a
copy of all AURORA fies used in the analysis (input, output, data, etc.). Please provide all fies
in an electronic, executable format with formulas intact.
REQUEST NO.2: Please explain the rationale for establishing a minimum Delay Price
as specified in § 1.6. What is the basis for specifically choosing $15 per MWh as the minimum
Delay Price?
REQUEST NO.3: Please explain the rationale for a 15% reduction in applicable energy
prices if Net Energy deliveries exceed plus or minus 10% for the time periods specified in §6.3
and §6.3.1.
REQUEST NO.4: As specified in §6.4, please explain the rationale for considering the
Seller's failure to deliver 30,000 MWh in any Contract Year to be an event of default. How was
the 30,000 MWh amount chosen?
Dated at Boise, Idaho, this )J)rtday of December 2011.
t¡fiz:rfb â. £z-d4 n'\KriS Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce i i .25ksrps prod req i .doc
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 DECEMBER 20,2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 20TH DAY OF DECEMBER 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-11-25, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOV AN E WALKER
JASON B. WILLIAMS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: dwalker(ßidahopower.com
jwiliams(ßidahopower.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(ßidahopower.com
C LLOYD MAHAFFEY
WADE D THOMAS
DYNAMIS ENERGY LLC
776 E RIVERSIDE DR STE 150
EAGLE ID 83616
E-MAIL: Lloyd(ßdynamisenergy.com
wthomas(ßdynamisenergy.com
SECRE~~~
CERTIFICATE OF SERVICE