20140820Staff 1-4 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY CONFIRMING
USE OF THE CAPACITY DEFICIENCY
PERIOD FOR THE INCREMENTAL COST,
INTEGRATED RESOURCE PLAN, AVOIDED
COST METHODOLOGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.I4.22
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 WEDNESDAY, SEPTEMBER 9,
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 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. Reference IDAPA 31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY AUGUST 2O,2OI4
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: The Company's Application at pageT refers to eight proposed projects
that had previously received initial indicative pricing that included capacity payments for the entire
term of the contract and that subsequently have received superseding and updated indicative pricing
runs with the capacity portion of the rates removed through J:urlre of 2021. For each of these eight
contracts, please provide the following:
A. The nrune, location, and developer of the project,
B. The proposed nameplate capacity of the project,
C. The proposed term of the contract,
D. A comparison showing the separate energy and capacity components of the
avoided cost rate, both under the initial indicative pricing and under the
superseding and updated indicative pricing runs with the capacity portion of the
rates removed through June of 2021 .
REQUEST NO. 2: Please provide computations supporting the estimated difference of $65
million in avoided cost rates for those eight projects that received revised indicative pricing as stated
on page 7 of the Application.
REQUEST NO.3: Please provide computations supporting the estimated difference of $170
million in avoided cost rates for all 529 MW of proposed solar projects referred to on page 8 of the
Application.
REQUEST NO. 4: Please provide copies of any written documentation or correspondence
with projects that have raised objections to Idaho Power's inclusion of a first deficit of July 2021 in
their indicative avoided cost prices as discussed on page 8 of the Application.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY AUGUST 2O,2OI4
Dated at Boise, Idaho, thk |Dqay of August 2014.
Technical Staff: Rick Sterling
i:umisc:prodreq/ipcel4.22ksrps prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attorney General
AUGUST 2O,2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2O', DAY oF AUGUST 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
TPC-E-14.22, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOVAN E. WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE,ID 83707
E-MAIL : dwalker@.idahopower.com
[e-mail]
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE