20200805IPC to Staff 3.pdf

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August 5, 2020
ELEGTRONIC FILING
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
1 1331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, tdaho 83714
Case No. IPC-E-19-38
Big Wood Canal Company - Sagebrush Hydro Project
ldaho Power Company's Application Regarding Energy Sales Agreement
Dear Ms. Noriyuki:
Attached for elechonic filing is ldaho Power Company's Response to the Second
Production Request of the Commission Staff. Please handle the mnfidential information in
accordance with the Protective Agreement executed in this matter. lf you have any
questions about the attached documents, please do not hesitate to contiact me.
Very truly yours,
DONOVAN WALKER
L6ad Counsel
[e-mail]
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Attachments
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Donovan Walker
DONOVAN E. WALKER (lSB No. 5921)
ldaho Power Company
1221 West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa [e-mail]
Attomey for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE 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 HYDRO
PROJECT
CASE NO. tPC-E-19-38
IDAHO POWER COMPANY'S
RESPONSE TO SECOND
PRODUCTION REOUEST OF
THE COMMISSION STAFF
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COMES NOW, ldaho Power Company ("ldaho Powe/ or "Company"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
Company dated August 4, 2020, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF - 1
REQU NO.3:ln Staff Production Request No. 2, Staff requested actual hourly
generation data for years 2018 and 2019 for the Sagebrush QF. ln hour 14:00 on
713012019, 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 hour on 7/30/2019 are 265 kWh plus or minus 5 kWhs. ls the
363.612 kWhs an enor in the data? lf so, what is the cause and what is an estimate for
the generation during that hour?
RESPONSE TO REOUEST NO. t: The713012019 value for hour 14:00 was based
on an estimated interval. ldaho Power's register read does not include decimals but
interval data do, so estimations can potentially be off by 0.999 times the meter multiplier.
ldaho Power's practice for adjusting estimated intervals consists of looking at the previous
hourly value and next hour value. ln this case, the estimate for net generation on
713012019, hour 14:00, would have been adjusted to approximately 267.876.
The response to this Request is sponsored by Michael Danington, Energy
Contracts Leader, ldaho Power Company.
DATED at Boise, ldaho, this 5s day of August 2020.
8*-tdcoLL---
DONOVAN E. WALKER
Attomey for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF . 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 5b day of August 2020 I served a true and conect
copy of IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
John R. Hammond, Jr.
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, ldaho 83714
_Hand Delivered
-U.S.
Mail
_Ovemight Mail
_FAX
-f,Email [e-mail]
Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF . 3