20120821Staff 1 to IPC.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEIVFn
20I2AUG2I PM 2:38
IDAHO PUBa UTILITIES COMMISSION
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 COMPLAINT AND )
PETITION OF IDAHO POWER COMPANY FOR)
A DECLARATORY ORDER REGARDING THE
FIRM ENERGY SALES AGREEMENTS AND )
GENERATOR INTERCONNECTION )
AGREEMENTS WITH COTTONWOOD WIND )
PARK, LLC; DEEP CREEK WIND PARK, LLC; )
ROGERSON FLATS WIND PARK, LLC; AND )
SALMON CREEK WIND PARK, LLC. )
IN THE MATTER OF THE COMPLAINT AND )
PETITION OF IDAHO POWER COMPANY FOR)
A DECLARATORY ORDER REGARDING THE
FIRM ENERGY SALES AGREEMENT AND )
GENERATOR INTERCONNECTION )
AGREEMENT WITH NOTCH BUTTE WIND )
PARK, LLC. )
IN THE MATTER OF THE COMPLAINT AND )
PETITION OF IDAHO POWER COMPANY FOR)
A DECLARATORY ORDER REGARDING THE
FIRM ENERGY SALES AGREEMENT AND )
GENERATOR INTERCONNECTION )
AGREEMENT WITH LAVA BEDS WIND PARK,)
LLC. )
CASE NO. IPC-E-12-20
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
CASE NO. IPC-E-12-22
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
CASE NO. IPC-E-12-23
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,
Donald L. Howell, II, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
FRIDAY, AUGUST 24, 2012.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 AUGUST 2 1,2012
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 will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: For each of the six wind Qualifying Facilities (QF) included in the
proposed Settlement of these cases (Notch Butte, Lava Beds, Rogerson Flats, Salmon Creek,
Cottonwood and Deep Creek), please calculate what Idaho Power would have paid to each QF
for the twenty (20) years of each approved power purchase Agreement (PPAs) if the QF projects
were constructed and operating in conformance with their respective PPAs.
Notch Butte $_______________
Lava Beds $_____________
Rogerson Flats $________________
Salmon Creek $________________
Cottonwood $_______________
Deep Creek $________________
DATED at Boise, Idaho, this 2 / day of
Deputy Attorney General
i:umisc:prodreq/ipce 12_20_2223 prod req 1 .doc
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 AUGUST 21,2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21ST DAY OF AUGUST 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NOS, IPC-E-12-20, IPC-E-12-22
AND IPC-E-12-23 BY E-MAIL[NG AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
DONOVAN WALKER ROY EIGUREN
JASON WILLIAMS CAPITAL LAW GROUP, PLLC
IDAHO POWER COMPANY P0 BOX 1703
P0 BOX 70 BOISE ID 83701
BOISE ID 83707-0070 EMAIL: roy(royeiguren.com
EMAIL: [e-mail]
jwi11iams(idahopower.com
~ AL"
SECRETARY
CERTIFICATE OF SERVICE