20200709Staff 1-2 to IPC.pdf

JOHN R.HAMMOND,JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.5470
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION OF )IDAHO POWER COMPANY FOR APPROVAL )CASE NO.IPC-E-19-38
OR REJECTION OF AN ENERGY SALES )AGREEMENT WITH BIG WOOD CANAL )FIRST PRODUCTION
COMPANY FOR THE SALE AND PURCHASE )REQUEST OF THE
OF ELECTRIC ENERGY FROM THE )COMMISSION STAFF TO
SAGEBRUSH HYDRO PROJECT )IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
John R.Hammond Jr.,Deputy Attorney General,request that Idaho Power Company ("Company")
provide the followingdocuments and information as soon as possible,or by THURSDAY,
JULY 23,2020.1
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 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
i 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 COMPANY 1 JULY 9,2020
different the witness who can sponsor the answer at hearing if need be.Reference IDAPA
31.01.01.228.
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.I:Under Idaho Power's hourlymethodology to establish the proper rate,
there will be two sets of contract rates for the period 2020 through 2025 depending on the amount
of generation in each hour and whether or not it exceeds 430 kWh.Please explain how the
Company plans to pay the QF when the amount of energy in any given month is outside of the
90/110 performance band and when there are hours both above and below the 430 kWh threshold.
REQUEST NO.2:Please provide the hydrological data associatedwith the water flows
over the past five years and answer the followingquestions.
a.Identifythe years that have normal water conditions.
b.Provide the amount of generation in each hour from the SagebrushQF for the years
that have normal water conditions.
c.If such hydrological data are not availableto identify normal water years,please
provide the amount of generation in each hour from the SagebrushQF for years 2018
and 2019.
Respectfully submitted this 9 day of July 2020.
Jo .Hammond,Jr.
Dp Attorney General
i:umisc:prodreq/ipce19 38jhyy prod regl
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 JULY 9,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 96 DAY OF JULY 2020,SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF
TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-19-38,BY E-MAILING A
COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER ENERGY CONTRACTS
REGULATORY DOCKETS IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL:energycontracts idahopower.com
E-MAIL:dwalker idahopower.com
dockets idahopower.com
DAVID STEPHENSON TED SORENSON
BIG WOOD CANAL CO WOOD HYDRO LLC
409 N APPLE ST 1032 GRANDVIEW DR
SHOSHONE ID 83352 IVINS UT 84738
E-MAIL:davidstephenson cableone.net E-MAIL:tedâtsorenson.net
SECRETARY
CERTIFICATE OF SERVICE