20160711Staff 1-5 to IPC.pdf

DAPHNE HUANG NICEIVED
DEPUTY ATTORNEY GENERAL
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BOISE' IDAHO 83720-0074 ' i"rii"iissl0i'l
[phone]
IDAHO BAR NO. 8370
Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702.5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )coMPANy'S APPLICATION TO MODIFY ) CASE NO. IPC-E-16-13
OPTIONAL SCHEDULE 62, GREEN ENERGY )
PURCHASE PROGRAM RIDER ) FIRST 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,
Daphne Huang, Deputy Attorney General, request that Idaho Power Company (Company; Idaho
Power) provide the following documents and information as soon as possible, by MONDAY,
JULY 25,2016.1
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
Iater 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
' Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER JULY TI,2016
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
3l.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic hles on CD with formulas activated.
REQUEST NO. 1: Page 11 of Peter Pengilly's testimony states that participants who
contribute whole dollar amounts will be transferred over to the block option. Those participants
who do not contribute a whole dollar amount will be transferred over to the block option rounded
down to the nearest dollar. As the Company is offering a 100 percent of usage option, please
explain if and how existing customers will be able to enroll in this option.
REQUEST NO. 2: Please describe the proposed accounting treatment for the purchase
of Idaho Power owned RECs with funds from the Schedule 62 Green Power Purchase Program.
REQUEST NO.3: Please provide the monthly revenue provided by Schedule 62,the
Green Power Purchase Program for each month from January 2010 - present.
REQUEST NO. 4: Please provide a list of all expenses paid using Schedule 62 revenues
from January 2010 - present.
REQUEST NO. 5: The Application and the testimony of Mr. Pengilly state that
"currently, Idaho Power purchases Green-e certified RECs through BEF; however they are not
re-certified before being retired by Idaho Power. While Idaho Power certification would add to
the cost to the program, it provides an extra layer of assurance to participants that the RECs were
not used for multiple purposes."
a) Please provide the estimated costs associated with re-certiffing the RECs prior to
retirement.
b) Does Idaho Power intend to re-certify all RECs prior to retirement?
c) How long are RECs held when purchased for the program?
FIRST PRODUCTION REQUEST
TO IDAHO POWER JULY II,2016
Dated at Boise,Idaho, this lb day of July 2016.
Technical Staff: Mark Rogers/l
Donn Englisl/2-5
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FIRST PRODUCTION REQUEST
TO IDAHO POWER ruLY lt,20t6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I ITH DAY OF JULY 2016,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC.E.I6-13, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail : [e-mail]
[e-mail]
MATTHEW T. LARKIN
PETER PENGILLY
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
ppeneilly@idahopower. com
CERTIFICATE OF SERVICE