20141203Staff 5 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTTLITIES 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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CASE NO. IPC.E.14.31
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
The Staff of the Idaho Public Utilities Commission, by and through its attorney 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 FRTDAY, DECEMBER 12, 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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY DECEMBER 3, 2014
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 the2}-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, this #O*of Decemb er2014.
Technical Rick Sterling
Yao Yin
i :umisc:prodreq/ipce I 4.3 I ksrpsyy prod req3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY
ine A. Sasser
Deputy Attomey General
DECEMBER 3, 2014
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3'd DAY OF DECEMBER 2014,
SERVED THE FOREGOING THIRD 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]
dockets@ idahopower. com
MARK VAN GULIK
CLARK SOLAR 4,LLC
PO BOX 7354
BOISE ID 83707
E-MAIL : mvaneulik@ sunereyworld.com
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 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