20141121IPC to Staff 1-2.pdf

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November 21,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Case No. IPC-E-14-30
Clark Solar 3, LLC - Idaho Power Company's Response to the First
Production Request of the Commission Staff
Dear Ms. Jewel!:
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 extemal 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
Verylply yours,
./onovan E. Walker
DONOVAN E. WALKER (lSB No. 5921) p :: rl ir rt i r- "
ldaho Power Company
1221 West ldaho Street (83702) ?flltr Fl6y Z I pFl ?: FTP.O. Box 70
Boise, ldaho 83707 i,.r,'r,i"i:-r ;'. .
Telephone: (2og) 3gg-s317 ilTil-il"ii:i:' t-)'.,i',i',i.:lsii.'
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
!N THE MATTER OF THE APPLICATION )
oF IDAHO POWER COMPANY FOR ) CASE NO. IPC-E-14-30
APPROVAL OR REJECTION OF AN )
ENERGY SALES AGREEMENT WITH ) IDAHO POWER COMPANY'S
CLARK SOLAR 3, LLC FOR THE SALE ) RESPONSE TO THE FIRST
AND PURCHASE OF ELECTRTC ENERGY. ) PRODUCTTON REQUEST OF THE) coMMrssroN srAFF To rDAHo
) POWER COMPANY
)
COMES NOW, Idaho Power Company ("ldaho Powe/'), and in response to the
First Production Request of the Commission Staff to ldaho 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 FACILITY ENERGY PRICES' in Appendix F. Please provide
prices (and corresponding input and output files) generated based on all displaced
resources and monthly natural gas prceg 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 confidentia! 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 externa! 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 PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY.2
REQUEST NO. 2: Please provide copies of all Exce! 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 prbeg consisfenf with the Commission's findings and conclusions rn 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-14-30-Clark Solar 3-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
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 21st day of November 2014.
DONOVAN E. WALKER
Attomey 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" d"y of November 2014 t served a true and
correct 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 Attorney General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Clark Solar 3, 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