20141121IPC to Staff 1-2.pdf

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An IDACORP Company
DONOVAN E. WALKER
Lead Counsel
[e-mail]
November 21,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re:Case No. IPC-E-14-26
Mountain Home Solar, LLC - ldaho Power Company's Response to the
First Production Request of the Commission Staff
Dear Ms. Jewell:
Enclosed for filing in the above matter are an original and three (3) copies of
Idaho Power Company's Response to the First Production Request of the Commission
Staff.
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An external hard drive containing the requested
provided on the external hard drive are confidential
accordance with the Protective Agreement in this matter.
yours,
DEW:csb
Enclosures
files
and
is provided. The files
should be handled in
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
DONOVAN E. WALKER (lSB No. 5921 ) i?. ij r,l I i : t :': I
ldaho Power Company
1221West ldaho Street (83702) 20llr H$V 2l PH 2: 55
P.O. Box 70
Boise, ldaho BgloT r r-; i'-;'i'i r" I ' '' '.
Terephone: (20g) 3gg-5317 l-lllltTl[:i c0i'r-lli):j;r']:'
Facsimile: [phone]
dwal ker@ idahopower. com
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
rN THE MATTER OF THE APPLTCATTON )oF IDAHO POWER COMPANY FOR ) CASE NO. tpC-E-14-26
APPROVAL OR REJECTION OF AN )
ENERGY SALES AGREEMENT WITH ) IDAHO POWER COMPANY'S
MOUNTAIN HOME SOLAR, LLC FOR THE ) RESPONSE TO THE FIRST
SALE AND PURCHASE OF ELECTRTC ) PRODUCTION REQUEST OF THE
ENERGY.) coMMrssroN STAFF To IDAHO
) POWER COMPANY
)
COMES NOW, ldaho Power Company ("ldaho Powe/'), and in response to the
First Production Request of the Commission Staff to Idaho Power Company dated
November 3, 2014, and as revised on November 20, 2014, herewith submits the
following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide copies of all AURORA input and output files
used to generate the 'SOLAR FACILITY ENERGY PRICES' in Appendix E and the
'ALTERNATIVE SOLAR FACILIW ENERGY PRICES' in Appendix F. Please provide
prices (and corresponding input and output files) generated based on all displaced
resources and monthly natural gas prlceg conslsfenf with the Commission's findings
and conclusions in Order Nos. 33779 and 33180. Please provide the files electronically
with all formulas intact.
RESPONSE TO REQUEST NO. 1: Please see the confidential directory titled
"CONFIDENTIAL-AURORA Files" on the external hard drive provided. Because of the
very large size of the requested files, they are being provided to Staff on the
accompanying external hard drive. The files and data contain dispatch costs of ldaho
Power resources, which is non-public, confidential, and proprietary information and
should be handled in accordance with the Protective Agreement. The external hard
drive and file directory are marked "CONFIDENTIAL." However, to maintain the
integrity of the files, the files themselves are not further marked or identified as
confidentia!.
ldaho Power has not made Staffs recommended adjustments to the original
Appendix F Alternative Prices. Therefore, it does not have any revised files related to
Appendix F to provide.
The response to this Request is sponsored by Jill Glenn, Senior Energy
Contracts Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCT]ON
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide copies of all Excel files used to generate the
'SOLAR FACILITY ENERGY PRICES' in Appendix E and the 'ALTERNATIVE SOLAR
FACILITY ENERGY PRICES' in AppendixF. Please provide prices (and corresponding
input and output files) generated based on all displaced resources and monthly natural
gas priceg consisfent with the Commr'ssion's findings and conclusions in Order Nos.
33179 and 33180. Please provide the files electronically with all formulas intact.
RESPONSE TO REQUEST NO. 2: Please see the confidential directory titled
"CONFIDENTIAL-IPC-E-14-26 Mountain Home Solar-Response 2" on the extemal hard
drive provided. Because of the very large size of the requested files, they are being
provided to Staff on the accompanying external hard drive. The files and data contain
dispatch costs of ldaho Power resources, which is non-public, confidential, and
proprietary information and should be handled in accordance with the Protective
Agreement. The external hard drive and file directory are marked 'CONFIDENTIAL."
However, to maintain the integrity of the files, the files themselves are not further
marked or identified as confidential.
ldaho Power has not made Staffs recommended adjustments to the original
Appendix F Alternative Prices. Therefore, it does not have any revised files related to
Appendix F to provide.
The response to this Request is sponsored by Jill Glenn, Senior Energy
Contracts Coordinator, ldaho Power Company.
DATED at Boise, ldaho, this 21"t day of November 2014.
Aftomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21"t day of November 20141 served a true and
conect copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Gommission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Mountain Home Solar, LLC
Dean J. Miller
McDEVITT & MILLER, LLP
420 West Bannock
Boise, ldaho 83702
Mark van Gulik
Mountain Home Solar, LLC
P.O. Box 7354
Boise, ldaho 83707
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Christa Bearry, Legal
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.4