20140512Staff 1-3 to IPC.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
Street Address for Express Mail:
472 W . WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
TN THE MATTER OF THE APPLICATION OF
TDAHO POWER COMPANY FOR AN
ACCOUNTING ORDER.
mEC El\/{: t}
?Blq ilAY l2 ptt Zr SB
IDTI'|O I ulll."r,.,uTtLld,F$ cs[1F;tissto]i
CASE NO. IPC.E.14-08
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
BEFORE THE IDAHO PUBLIC UTILTTIES COMMISSION
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
MONDAY, MAY 26,2014.
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 identi$ the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY May 12,2014
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. l: Please provide electronic executable copies of all spreadsheets and
analysis used to derive the $1,884,406.85 amount of the overpayment to Simplot. Please show
the monthly estimated generation, the monthly actual generation, and the alternative prices that
were applied. Please also include copies of any other supporting work papers used to derive the
amount.
REQUEST NO.2: Please explain how it was determined that Simplot would pay
$1,564,503 .76 and Idaho Power would pay the remaining $319,903.09 of the $1,884,406.85 total
amount of the overpayment.
REQUEST NO.3: Please explain whether Simplot's monthly generation estimates
assumed planned maintenance in May and June of every year.
DATED at Boise, Idaho, this lh^rof May 201,4.
Deputy Attorney General
Technical Staff: Rick Sterling
umisc:prodreq/ipce l4.8dhrps prod req I
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY May 12,2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I2TH DAY OF MAY 2014, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-14-08, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN E. WALKER
JULIA A. HILTON
IDAHO POWER COMPANY
P.O. BOX 70
BOISE,IDAHO 83707
E-MAIL: [e-mail]
i [e-mail]
MICHAEL J. YOUNGBLOOD
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, IDAHO 83707
E-MAIL: [e-mail]
dockets@ idahopower. com
CERTIFICATE OF SERVICE