20141210Staff 5 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
Attomey for the Commission Staff
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH SIMCO SOLAR, LLC,
F'OR THE SALE AND PURCHASE OF
ELECTRIC ENERGY.
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CASE NO. IPC.E-14.33
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 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.
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY DECEMBER 10, 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 the 2O-year levelized
rates under both scenarios and calculate the difference in the total 2O-year contractual obligation.
With your answer, please provide copies of all AURORA and Excel files used for the analysis.
Dated at Idaho, this lOC,dayof December 2014.
Technical Staff: Rick Sterling
Yao Yin
i :umisc:prodreq/ipce I 4.33ksrpsyy prod req 3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attorney General
DECEMBER IO, 2OI4
I HEREBY CERTIFY THAT I
SERVED THE FOREGOING THIRD
COMMISSION STAFF TO IDAHO
IPC-E-14-33, BY MAILING A COPY
FOLLOWNG:
DONOVAN E. WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
P.O. BOX 70
BOISE, ID 83707
E-MAIL: [e-mail]
dockets@ idahopower. com
SIMCO SOLAR LLC
C/O ARTHUR SNELL
I79 LINCOLN ST STE 5OO
BOSTON MA O2I1I
E-MAIL: [e-mail]
RONALD L WILLIAMS
WILLIAMS BRADBURY PC
1OI5 W HAYS ST
BOISE TD 83702
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE
HAVE THIS IOTH DAY OF DECEMBER 2014,
PRODUCTION REQUEST OF THE
POWER COMPANY, IN CASE NO.
THEREOF, POSTAGE PREPAID, TO THE
RANDY C. ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
SARAH LOVELL DIR
COMMERCIAL ASSET MGMNT
I2OO FOLSON ST STE lOO
SAN FRANCISCO CA 94103
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE