20141203Staff 5 to IPC.pdf

KRISTINEA'SASSER r'[crirj 'i1
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 2[Il NTC -3 PIl 3: 3II
PO BOX 83720
BOISE, IDAHO g3720-0074 , ,,,, i,,1;--,-'-..',.;,, . r:.r*:,ri ,
(zog) 334-03s7 iJl ill ll:;ti it'-l*:'t' :iLi: lr"r''
BAR NO. 6618
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR APPROVAL ) CASE NO. rpc-E-r4-32
OR REJECTION OF AN ENERGY SALES )
AGREEMENT WITH MURPHY TLAT ) THIRD PRODUCTION
POWER, LLC, FOR THE SALE AND ) RB,QUEST OF THE
PURCHASE OF ELECTRIC ENERGY. ) COMMISSION 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 9, 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 I 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 I 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 3&duyof Decemb er 2014.
Technical Staff: Rick Sterling
Yao Yin
i :umisc:prodreq/ipce I 4.32ksrpsyy prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attorney 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, IN CASE NO, IPC-E-14-32, 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
MURPHY FLAT POWER LLC
C/O ARTHUR SNELL
179 LINCOLN ST STE 5OO
BOSTON MA 02111
E-MAIL: [e-mail]
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
SARAH LOVELL DIR
COMMERCIAL ASSET MGMNT
12OO FOLSON ST STE 1OO
SAN FRANCISCO CA 94103
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE