20111220Staff to IPC 1-2.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BARNO. 6618
F t:
O P'i,l 3: \ 92mi GEC 2 1
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 ITS FIRM
ENERGY SALES AGREEMENT WITH HIGH
MESA ENERGY, LLC
)
) CASE NO. IPC-E-1l-26
)
) 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 TUESDAY, JANUARY 10,2012.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementar responses, additional documents that it or any person
acting on its behalf may later obtain that will 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 IDAPA 31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER 20,2011
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 files used in the analysis (input, output, data, etc.). Please provide all files in an electronic,
executable format with formulas intact.
REQUEST NO.2: Please explain the rationale for the Parial Completion Damages
specified in §5.l0. Please explain whether the $10,000 per MW amount is a negotiated amount or
whether there is some other basis for that specific amount.
1f\iH
Dated at Boise, Idaho, this d- day of December 20,2011.
~k..j1. ~M1 "-
Kr stine A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqlipcel 1.26ksrps prod req I
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, IN CASE NO. IPC-E-II-26, 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(fidahopower.com
jwilliams(fidahopower .com
HIGH MESA ENERGY LLC
C/O EXELON WIND
4601 WESTOWNPKWY
STE 300
WEST DES MOINES IA 50266
E-MAIL: urps(fexeloncom.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMIN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: rallphin(fidahopower.com
HIGH MESA ENERGY LLC
RICHARD A CUMMINGS
COUNSEL FOR SELLER
PO BOX 1545
BOISE ID 83701
E-MAIL:
rcummings(fcummingslawidaho.com
CHRISTI RITCHIE
E-MAIL ONLY:cjritchie(fnorthrim.net
\ 9ÆJk .\(
SECRETARY
CERTIFICATE OF SERVICE