20150423IPC to Staff Redacted 1-2.pdf

SEffi*.
DONOVAN E. WALKER
Lead Counsel
[e-mail]
April 23, 2015
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VIA HAND DELIVERY
Jean D. Jewell, Secretary
!daho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. IPC-E-15-09
Telocaset Wind Power Partners, LLC (Elkhorn Wind Park) - ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Jewell:
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.
ln addition, enclosed in a separate envelope are an originaland three (3) copies of
the confidential attachments responsive to Staff s production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
DEW:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise. lD 83707
Sincerely,
hovan E. Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for ldaho Power Company
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.
:[]i X,fR X;
CASE NO. IPC-E-15-09
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
COMES NOW, Idaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff to ldaho Power
Company dated April 16,2015, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 1: Please provide a copy of Idaho Power's November 29,2012
letter to Seller, as referenced on page 7 of the Company's Application, which described
Idaho Poweds 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 responsibil ities.
RESPONSE TO REQUEST NO. 1: Please see Idaho Power's November 29,
2012,letter to Seller provided with this response. This letter is confidential and will only
be provided to those parties that have signed the Protective Agreement in this matter.
The response to this Request is sponsored by Jill Glenn, Energy Contracts
Senior Coordinator, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please provide a copy of Selle/s December 18, 2012
response to ldaho Power, as referenced on page 7 of the Company's Application,
documenting the Selle/s interpretation of the parties' responsibilities for Lost Output.
RESPONSE TO REQUEST NO. 2: Please see Selle/s December 18, 2012,
letter responding to Idaho Power provided with this response. This letter is confidential
and will only be provided to those parties that have signed the Protective Agreement in
this matter.
The response to this Request is sponsored by Ji!! Glenn, Energy Contracts
Senior Coordinator, ldaho Power Company.
DATED at Boise, ldaho, this 23'd day of April 2015.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REOUEST OF THE COMMISSION STAFF.3
Attorney for ldaho Power Company
CERTIFICATE OF SERVICE
! HEREBY CERTIFY that on this 23'd day of April 2015 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Daphne Huang
Deputy Attomey General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
Attn: Vice President, Asset Operations
Telocaset Wind Power Partners, LLC
c/o EDP Renewables North American LLC
808 Travis, Suite 700
Houston, Texas 77002
Attn: General Counsel
Telocaset Wind Power Partners, LLC
c/o EDP Renewables North American LLC
808 Travis, Suite 700
Houston, Texas 77002
X Hand Delivered
U.S. Mail
Overnight Mail
FAXX Email [e-mail]
Hand DeliveredX U.S. Mail
Overnight Mail
FAX
Email
Hand DeliveredX U.S. Mail
_Overnight Mail
_FAX
Email
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I5-09
IDAHO POWER COMPANY
RESPONSE TO STAFF'S REQUEST NO. 1
THIS ATTACHMENT IS
CONFIDENTIAL
AND WI LL BE PROVI DED
TO THOSE PARTIES THAT
HAVE SIGNED THE
PROTECTIVE
AGREEMENT
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-I5-09
IDAHO POWER COMPANY
RESPONSE TO STAFF'S REQUEST NO. 2
THIS ATTACHMENT IS
CONFIDENTIAL
AND WI LL BE PROVI DED
TO THOSE PARTIES THAT
HAVE SIGNED THE
PROTEGTIVE
AGREEMENT