20141121IPC to Staff 1-2.pdf

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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-14-28
Clark Solar 1, 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
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
An extemal hard drive containing the requested files is provided. The files
provided on the external hard drive are confidential and should be handled in
accordance with the Protective Agreement in this matter.
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Enclosures
1221 W. ldaho St. (83702)
P.O. Box 70
Boise, lD 83707
Very truly yours,
-onovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
Idaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
CLARK SOLAR I, LLC FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY.
First Production Request of
November 3, 2014, and as
following information:
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BEFORE THE IDAHO PUBL]C UTILITIES COMMISSION
COMES NOW, ldaho Power Company ("ldaho Powe/'), and in response to the
CASE NO. IPC-E-14-28
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
the Commission Staff to ldaho Power Company dated
revised on November 20, 2014, herewith submits the
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 FACILIry 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 prices, consisfenf 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-AUROM 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
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.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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
FAClLlry ENERGY PRICES' in AppendixF. Please provide prices (and conesponding
input and output files) generated based on all displaced resources and monthly natural
gas prices, consisfent with the Commission's findings and conclusions in Order Nos.
33179 and 33180. Please provide the files electronically with all fornulas intact
RESPONSE TO REQUEST NO. 2: Please see the confidential directory titled
'CONFIDENTIAL-IPC-E-14-28-C|ark Solar 1-Response 2" on the extemal hard drive
provided. Because of the very Iarge size of the requested files, they are being provided
to Staff on the accompanying extemal 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
extemal 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.
Idaho 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, tdaho, this 21"t day of November 2014.
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
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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:
Commission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Clark Solar 1, 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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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.4