20141103Staff 1-2 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES 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
Attorney for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH CLARK SOLAR 4,LLC,
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC.E.14.3T
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 Attomey General, requests that tdaho Power Company (Company)
provide the following documents and information AS SOON AS POSSIBLE BUT NO LATER
THAN MONDAY, NOVEMBER 24, 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 NOVEMBER 3, 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: 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 the files electronically with
all formulas intact.
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 Appendix F. Please provide the files electronically with all formulas intact.
Dated at Boise, Idaho, this Pday of November 2014.
Technical Staff: Rick Sterling
Yao Yin
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FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Krirtfne A. Sasser
Deputy Attomey General
NOVEMBER 3, 2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3RD DAY oF NoVEMBER 2014,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF, CASE NO. IPC-E-14-31, 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: [e-mail]
[e-mail]
MARK VAN GULIK
CLARK SOLAR 4,LLC
PO BOX 7354
BOISE ID 83707
E-MAIL : [e-mail]
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINI STRATOR
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
DEAN J MILLER
McDEVITT & MILLER
420 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE