20141121IPC to Staff 1-2.pdf

38ffi*.
An IDACORP Companv
DONOVAN E. WALKER
Lead Gounsel
20lr{ ti0v 2l
li- _l -' 1
I r'lli l-i'ri:'- i;i,
PH 2:59
November 21,2014
VIA HAND DELIVERY
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-14-34
American Falls Solar, LLC - ldaho Power Company's Response to the
First Production Request of the Commission Staff
Dear Ms. Jewel!:
Enclosed for filing in the above matter are an original and three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
An external hard drive containing the requested files is provided. The files
provided on the external hard drive are confidential and should be handled in
accordance with the Protective Agreement in this matter.
DEW:csb
Enclosures
122 1 W. ldaho St. (83702)
PO. Box 70
8oise. lD 83707
Db-n6van E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]'t7
Facsimile: [phone]
dwalker@ idahopower.com
Attomey for ldaho Power Company
!N THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
AMERICAN FALLS SOLAR, LLC FOR THE
SALE AND PURCHASE OF ELECTRIC
ENERGY.
COMES NOW, ldaho
First Production Request of
,f Lr\ .-:r \'-. U l.
Z$iE HOV 2 I PH $OO
.',,j1 '",,;
BEFORE THE IDAHO PUBLIC UTILITIES COMM]SSION
CASE NO. |PC-E-14-34
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
Power Company ("!daho Powe/'), and in response to the
the Commission Staff to ldaho Power Company dated
November 3, 2014, and as revised on November 20, 2014, herewith submits the
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REOUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO. 1: Please provide copies of a!! AURORA input and output files
used to generate the 'SOLAR FACILITY ENERGY PRICES' in Appendix E. Please
provide prices (and corresponding input and output files) generated based on all
displaced resources and monthly naturalgas prlceg consisfenf with the Commrsslon's
findings and conclusrbns in Order Nos. 33779 and 33180. Please provide the files
electronically with all formulas intact.
RESPONSE TO REQUEST NO. 1: Please see the confidentia! directory titled
.CONFIDENTIAL-AURORA Files" on the external hard drive provided. Because of the
very large size of the requested files, they are being provided to Staff on the
accompanying external hard drive. The files and data contain dispatch costs of ldaho
Power resources, which is non-public, confidential, and proprietary information and
should be handled in accordance with the Protective Agreement. The external hard
drive and file directory are marked .CONFIDENTIAL.' However, to maintain the
integrity of the files, the files themselves are not further marked or identified as
confidential.
The response to this Request is sponsored by Jill Glenn, Senior Energy
Contracts Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO. 2: Please provide copies of all Excel files used to generate the
'SOLAR FACILITY ENERGY PRICES' in Appendix E. Please provide prices (and
corresponding input and output files) generated based on all displaced resources and
monthly natural gas prices, consrsfenf with the Commission's findings and conclusions
in Order Nos. 33179 and 33180. Please provide the files electronically with all formulas
intact.
RESPONSE TO REQUEST NO. 2: Please see the confidential directory titled
"CONFIDENTIAL-IPC-E-14-34-American Falls Solar-Response 2" on the extemal hard
drive provided. Because of the very large size of the requested files, they are being
provided to Staff on the accompanying external hard drive. The files and data contain
dispatch costs of ldaho Power resources, which is non-public, confidential, and
proprietary information and should be handled in accordance with the Protective
Agreement. The extemal hard drive and file directory are marked "CONFIDENTIAL."
However, to maintain the integrity of the files, the files themselves are not further
marked or identified as confidential.
The response to this Request is sponsored by Jill Glenn, Senior Energy
Contracts Coordinator, ldaho Power Company.
DATED at Boise, tdaho, this 21"t day of November 2014.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
DONOVAN E. WALKER
Attomey for ldaho Power Company
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 21st day of November 20141 served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER
COMPANY upon the following named parties by the method indicated below, and
addressed to the following:
Gommission Staff
Kristine A. Sasser
Deputy Attomey General
ldaho Public Utilities Commission
47 2 W est Washington (83702)
P.O. Box 83720
Boise, ldaho 8372O-OO7 4
American Falls Solar, LLC
Ron Williams
Williams Bradbury, P.C
1015 West Hays Street
Boise, ldaho 83702
Ben Fairbanks
Director, Development
First Wind
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Ovemight Mail
FAXX Email [e-mail]
Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO ]DAHO POWER COMPANY - 4