20190215Staff 1-3 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH KOYLE HYDRO INC.
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE KOYLE
SMALL HYDRO PROJECT
RECEIVET]
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC.E.19.O3
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attorney General, request that Idaho Power Company (Company)
provide the following documents and information as soon as possible, or by MONDAY,
MARCH 4,2019.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
person preparing the document, and the name, location and phone number of the record holder
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at [phone],
FIRST PRODUCTION REQUEST
TO IDAHO POWER I FEBRUARY 75,2019
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0r.0t.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 describe how adjustments to Estimated Net Energy Amounts
reported to Idaho Power from a QF are used by the Company.
REQUEST NO.2: Please explain why Idaho Power believes adjustments to Estimated
Net Energy Amounts at least one-month in advance are not required for the Koyle Hydro project.
REQUEST NO. 3: Please describe how lack of adjustments to Estimated Net Energy
Amounts at least one-month in advance in the Koyle Hydro project affects Idaho Power's
month-ahead or longer-term ahead planning process. Please also discuss its impacts on
ratepayers.
Dated at Boise, Idaho, this tY day of Febr uary 2019.
Edward
Deputy General
i:umisc:prodreq/ipce I 9.3ejyyrftnc prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY I5,2OI9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I5TH DAY OF FEBRUARY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-I9-03,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-mail : [e-mail]
dockets@ i dahopower.com
ALAN L KOYLE
KOYLE HYDRO INC
1505 SOUTH ISOO EAST
GOODING ID 83330
E-mail: [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail: [e-mail]
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CERTIFICATE OF SERVICE