20141210Staff 5 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITTES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
BAR NO. 6618
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attomey for the Commission Staff
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL ) CASE NO. IPC-E,-14-28
OR REJECTION OF AN ENERGY SALES )
AGREEMENT WITH CLARK SOLAR 1, LLC, ) THIRD PRODUCTION
FOR THE SALE AND PURCHASE OF ) REQUEST OF THE
ELECTRIC ENERGY.) coMMrssroN STAFF To
) rDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company)
provide the following documents and information AS SOON AS POSSIBLE BUT NO LATER
THAN TUESDAY, DECEMBER 16, 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 3t.01.01.228.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 DECEMBER IO,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. 5: Please re-calculate the rates for the project by using in AURORA the
exact generation quantities and hourly and monthly shapes as are represented in Appendix I of the
Agreement. Please compare the resulting rates to those contained in Replacement Appendix E
included as Attachment 1 to Idaho Power's Initial Comments. Please compare the 2O-year levelized
rates under both scenarios and calculate the difference in the total 20-year contractual obligation.
With your answer, please provide copies of all AURORA and Excel files used for the analysis.
Dated at Boise, Idaho, tti" lPday of December 2014.
Technical Staff: Rick Sterling
Yao Yin
i:umisc:prodreq/ipce l4.28ksrpsyy prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 DECEMBER IO,2OI4
I HEREBY CERTIFY THAT I
SERVED THE FOREGOING THIRI)
COMMISSION STAFF TO IDAHO
IPC-E-14-28, BY MAILING A COPY
FOLLOWING:
DONOVAN E. WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, TD 83707
E-MAIL: [e-mail]
dockets@ idahopower.com
MARK VAN GULIK
CLARK SOLAR 1, LLC
PO BOX 7354
BOISE ID 83707
E-MAIL : mvangulik@,sunereyworld. com
CERTIFICATE OF SERVICE
HAVE THIS IOTH DAY OF DECEMBER 2014,
PRODUCTION REQUEST OF THE
POWER COMPANY, N CASE NO.
THEREOF, POSTAGE PREPAID, TO THE
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
DEAN J MILLER
MoDEVITT & MILLER
420 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE