20191204Staff 1 to IPC.pdf

DA\}i HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO,9917
IN THE MATTIR OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH LITTLE WOOD
IRRIGATION DISTRICT, FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY FROM
THE LITTLE WOOD RIVER RESERVOIR
HYDRO PRO.IECT
RECEIVEO
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FIRST PRODUCTION
REQUEST OF TIIE
COMMISSION STAFF
TO IDAHO POWER COMPANY
ON
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Altomeys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Dayn Hardie, Deputy Attomey General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than WEDNESDAY,
DECEMBER 18,2019.r
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it, or any
person acting on its behali may later obtain that will augment the documents or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
I Staffis requesting an expedited response. lfresponding by this date will be problematic, please call Staffs
attomey at (20E) 334-0312.
DECEMBER 4.2019
CASE NO. IPC-E-I9.35
Street Address for Express Mail:
I1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI.A
BOISE, ID 837I4
FIRST PRODUCTION REQUEST
TO IDAHO POWER I
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Order 32802 states that "the appropriate and reasonable definition of
a "seasonal hydro" project is a hydro generation facility that produces at least 55% of its arurual
generation during the months of June, July, and August." According to this definition, the Little
Wood River Reservoir Hydro Project qualifies as a "seasonal hydro" project, because the lacility
is estimated to produce 55.270 of its annual generation during the months ofJune, July, and
August. However, avoided costs lbr non-seasonal hydro projects are used in the Agreement.
Please explain why avoided costs for seasonal hydro projects are not used.
DATED at Boise, Idaho, this day of December 201 9."tb
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Attomey General
i:umisc:prodrcq/ipcel9.35dhyy prod req I
2 DECEMBER4.2019
FIRST PRODUCTION REQUEST
TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY TI-IAT I I]AVE THIS 4,I'H DAY OF DECEMBER
2019, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF
THE COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC.E.I9-35, BY MAILING A COPY THEREOF, POS'|AGE PREPAID, TO THE
FOLLOWING:
DONOVAN WALKER
REGULAI-ORY DOCKETS
IDAHO POWERCOMPANY
PO BOX 70
BOISE ID 83707-0070
E-mail: drvalkerro idahopou'er.com
dockets(d.i dahopow-er. c o m
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOTSE ID 83707-0070
E-mail : [e-mail]
CER'I'tI;ICA'TE OF SERVICE
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SECRETA(y/-