20150416Staff 1-2 to IPC.pdf

DAPHNE HUANG
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8370
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 )
OF THE FIRST AMENDMENT TO THE POWER)
PURCHASE SALES AGREEMENT BETWEEN )
IDAHO POWER COMPANY AND TELOCASET )
WIND POWER PARTNERS, LLC.
')nii apl? liLi:u rit l' I '
CASE NO.IPC.E.15.O9
FIRST PRODUCTION
RE,QUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
:3
a.'.iJiliillil
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (Company; Idaho
Power) provide the following documents and information as soon as possible, by THURSDAY,
APRIL 23,2015.r
This Production Request is continuing, and the 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, 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
t Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-03 18.
FIRST PRODUCTION REQUEST
TO IDAHO POWER APRIL 16,2OI5
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 if need be. IDAPA
31.01.01.228.
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. 1: Please provide a copy of Idaho Power's November 29,2012letter to
Seller, as referenced on page 7 of the Company's Application, which described Idaho Power's
review of the accuracy of the invoice, events that caused the curtailment events, quantification of
Lost Output associated with 66 MW, and interpretation of Lost Output responsibilities.
REQUEST NO.2: Please provide a copy of Seller's December 18,2012 response to
Idaho Power, as referenced on pageT of the Company's Application, documenting the Seller's
interpretation of the parties' responsibilities for Lost Output.
Dated at Boise, Idaho, this l, (rPhurof April 2015.
Daphne
Deputy Attorney General
Technical Rick Sterling
i:umisc:prodreq/ipcel5.9dhdjhrps prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER APRIL 16,2OI5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF APRIL 2015,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E.I5-09, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOVAN E WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
[e-mail]
TELOCASET WIND POWER PARTNERS
ATTN: VP, ASSET OPERATIONS
C/O EDP RENEWABLES NORTH
AMEzuCAN LLC
808 TRAVIS STE 7OO
HOUSTON TX77OO2
RANDY C ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
TELOCASET WIND POWER PARTNERS
ATTN: GENERAL COUNSEL
C/O EDP RENEWABLES NORTH
AMERICAN LLC
808 TRAVIS STE 7OO
HOUSTON TX77OO2
CERTIFICATE OF SERVICE