20200804Staff 3 to IPC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.007 4
(208) 334-03s7
IDAHO BAR NO,5470
IN THE MATTER OF APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH BIG WOOD CANAL
COMPANY FOR THE SALE AND PURCHASE
OF ELECTRIC ENERGY FROM THE
SAGEBRUSH ITYDRO PROJECT
CASE NO. IPC.E-19.38
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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Street Address for Express Mail:
1 133I W CHINDEN BVLD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTTLITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
John R. Hammond Jr., Deputy Attomey General, request that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, or by THURSDAY '
AUGUST 6,,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 to Request No. 3. tfresponding by thisdatewill is problematic, please
contact Stafls attomey, John R. Hammond Jr. at [phone],
SECOND PRODUCTION REQUEST
TO IDAHO POWERCOMPANY I AUGUST 4,2020
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. 3: In Staff Production Request No. 2, Staff requested actual hourly
generation data for years 2018 and 2019 for the Sagebrush QF. In hour 14:00 on 7l30l20l9,the
data shows that the Facility generated 363.612 kWhs. Over the two-year period, the most the
Facility generated is about 310 KWhs for all other hours and the hours adjacent to the 14:00 hout on
7130/2019 are 265 kWh plus or minus 5 kWhs. Is the 363.612 kWhs an error in the data? Ifso,
what is the cause and what is an estimate for t}re generation during that hour?
4-*ofAugust 2020.Respectfu lly submitted this
i:umisc:pro&eq/ipce l9-3 Sjh}? pIod req2
SECOND PRODUCTION REQUEST
TO IDAHO POWER COMPANY
J Hammond, Jr.
Attomey General
2 AUGUST 4, 2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 4th DAY OF AUGUST 2020, SERVED
THE FOREGOTNG SECOND PRODUCTION REQUEST OF TIIE COMMTSSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC.E-I9.38, BY E.MAILING
A COPY TTMREOF, TO THE FOLLOWING:
DONOVAN E WALKER
REGI]LATORY DOCKETS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: dwalker@idahopowcl'.corr.r
dockets @) idahopower.com
DAVID STEP}IENSON
BIGWOOD CANAL CO
409 N APPLE ST
SHOSHONE ID 83352
E-MAIL: davidsteohenson @)cablcone.net
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 837U-OO70
E-MAIL: encrsvcontracts @ i dahopower.conr
TED SORENSON
WOOD HYDRO LLC
1032 GRANDVIEW DR
IVINS UT 84738
E-MAIL: ted @ tsorenson.net
SECRET Y
CERTIFICATE OF SERVICE