20190215Staff 1-2 to IPC.pdf

EDWARD JEWELL
DEPUTY ATTORNEYS 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 WOOD HYDRO LLC FOR
THE SALE AND PURCHASE OF ELECTRIC
ENERGY FROM THE BLACK CANYON #3
HYDRO PROJECT.
F.ECTIVED
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Street Address for Express Mail:
472W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO.IPC.E.I9.O4
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,
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 and if
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0r.01.228.
I Staff is requesting an expedited response. If responding by this date will be problematic, please call Staffs attorney at
(208) 334-03 14.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 FEBRUARY L5,2OI9
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. l: Page 4 of the Application states "Wood Hydro plans to continue
operating and maintaining a 150 kilowatt ("kW") (Maximum Capacity Amount, paragraph B-4,
Appendix B) energy facility located near the city of Gooding, Idaho." However, Appendix B states
"The Maximum Capacity Amount is 130 kW..." Please reconcile these two numbers.
REQUEST NO.2: Page 4 of the Application states'oThe nameplate rating of this Facility
is 150 kW". However, Appendix B states "Nameplate: 130 kW". Please reconcile these two
numbers.
DATED at Boise, Idaho, this I 5tL- day of Febru ary 2Ol9
Deputy General
i :umisc: prodreq/ipce 1 9.4ejyytncrf prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER
JEd
2 FEBRUARY 15,2019
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF FEBRUARY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-E-19-04,
BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
DONOVAN WALKER
REGULATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-mail : dwalker@idahopower. com
dockets@ idahopower. com
TED SORENSON
WOOD HYDRO LLC
1032 GRAND VIEW DR
IVINS UT 84738
E-mail: [e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE