20130402Staff 1 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
•......
23PR-2 flH1I:32
iC;H, UTIL!yj COMM
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 AMENDMENT TO )
THE FIRM ENERGY SALES AGREEMENT ) CASE NO. IPC-E-13-07
BETWEEN IDAHO POWER COMPANY AND )
CLARK CANYON HYDRO, LLC. ) 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, APRIL 23, 2013.
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 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.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 APRIL 2, 2013
REQUEST NO. 1: On page 3 of the Company's Application, it states:
The Amendment is a fair and equitable resolution to this matter, and is in the
public interest. The avoided cost rates contained in Clark Canyon's FESA are
substantially similar to the avoided cost rates the project would receive in a new
contract today. In addition, Idaho Power and its customers receive half of the
Renewable Energy Credits associated with the project with the current FESA.
a.Please provide analysis supporting the statement that the avoided cost rates contained in
Clark Canyon's FESA are substantially similar to the avoided cost rates the project would receive in a
new contract today. Please quantify the net present value difference between the rates in 2013
dollars.
b.Please estimate in 2013 dollars the net present value of the Renewable Energy Credits
Idaho Power will receive over the life of the amended FESA.
Dated at Boise, Idaho, this NA day of April 2013.
a .
Kris ne A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce 13.7ksrps prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 2, 2013
CERTI!ICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2ND DAY OF APRIL 2013,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-13-07, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOVAN E WALKER
LEAD COUNSEL
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
EMAIL: dwa1ker(idahopower.com
dockets(,idahopower.eom
KIM L JOHNSON
CLARK CANYON HYDRO
2000 5 OCEAN BLVD #703
DELRAY BEACH FL 33438
EMAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE