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:
472 W , 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 AMERICAN FALLS
SOLAR II, LLC, FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY.
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
25
CASE NO. IPC.E.14-35
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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.
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY NOVEMBEP.ZO,2OI4
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 l5 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 /fiiayofNovemb er2Ol4.
Technical Staff: Rick Sterling
Yao Yin
i:umisc:prodreq/ipce I 4.35ksrpsyy prod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
Deputy Attorney General
NOVEMBER20,2OI4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY oF NoVEMBER 2014,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF, IN CASE NO, IPC-E-14-35, 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]
[e-mail]
AMERICAN FALLS SOLAR II LLC
C/O ARTHUR SNELL
I79 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
I2OO FOLSON ST STE IOO
SAN FRANCISCO CA 94103
E-MAIL: [e-mail]
SECRETAR
CERTIFICATE OF SERVICE