20141120Staff 3-4 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
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL ) CASE NO. rpC-E-14-31
OR REJECTION OF AN ENERGY SALES )
AGREEMENT WITH CLARK SOLAR A,LLC, ) SECOND PRODUCTION
FORTHE 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 attorney of record,
Kristine A. Sasser, Deputy Attomey General, requests that Idaho Power Company (Company)
provide the following documents and information AS SOON AS POSSIBLE BUT NO LATER
THAN THURSDAY, DECEMBER 11, 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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY I NOVEMBER 2O,2OL4
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.3: Idaho Power's Application states under Paragraph 15 that "[c]onsistent
and material deviations from the hourly energy estimates in the generation profile will be considered
by Idaho Power to be a material breach of the agreement--meaning that the entire pricing is
fundamentally flawed as a result of an inaccurate generation profile". Please discuss how consistent
and material the deviations need to be before the entire pricing can be considered fundamentally
flawed, and before Idaho Power would consider this to be a material breach of the agreement.
REQUEST NO. 4: If the entire pricing is considered fundamentally flawed, what actions
would Idaho Power take?
Dated at Boise, Idaho, tnis ffiay of November 2014.
Technical Staff: Rick Sterling
Yao Yin
i:umisc:prodreq/ipcel4.3 lksrpsyy prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY NOVEMBER 20, 2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2O,H DAY oF NoVEMBER 2014,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF, CASE NO. IPC.E.I4-31, 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]
dockets@idahopower. com
MARK VAN GULIK
CLARK SOLAR 4,LLC
PO BOX 7354
BOISE ID 83707
E-MAIL : mvangulik@ sunergyworld. com
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINI STRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
DEAN J MILLER
MoDEVITT & MILLER
420 W BANNOCK ST
BOISE TD 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE