20200917Staff 1-4 to IPC.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10655
IN THE MATTER OF IDAIIO POWER
COMPAI\Y'S APPLICATION FOR APPROVAL
OR REJECTION OF AI\ ENERGY SALES
AGREEMENT WITH SHAWPATIN AGCAP,
LLC, FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE MUD CREEK
WHITE HYDRO PROJECT
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Street Address for Express Mail:
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BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. IPC-E.20-34
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAIIO POWER COMPAI[Y
The Staffof the Idaho Public Utilities Commission requests that Idaho power Company
(Idaho Power; Company) provide the following documents and information as soon as possible,
by THURSDAY, OCTOBER 8,2020.
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 witress who can sponsor the answer at hearing if need be. Reference IDApA
3t.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER SEPTEMBERIT,2O2O1
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. 1: The nameplate capacity of Mud Creek White Hydro Project stated in
the Energy Sales Agreement is 268.6 kW. However, the Company's Quarterly Cogeneration and
Small Power Production Report ending March 31,2020 shows that the nameplate capacity is
205 kW. Please explain and reconcile the difference.
REQUEST NO.2: The nameplate capacity described in the 1985 contract was 178 kW.
Please list all the nameplate changes throughout the history of the project and discuss actions
taken by the Company, including amending the contract, obtaining approval of a new contract,
etc. Please provide documentation or other forms of evidence for actions taken.
REQUEST NO.3: Please provide the project resource capacity conffibution in the load
and resource balance during the last five Company Integrated Resource Plans, and how was the
conffibution determined? Please provide any calculations in Excel format with formula enabled'
REQUEST NO.4: Please provide all available hourly generation data for the project.
For periods when hourly generation data is not available, please provide the data for the smallest
time interval available.
Dated at Boise, Idaho, this 1 Vh Auy of Septemb er 2020.
Matt Hunter
Deputy Attorney General
i:umisc:prodreq/ipce20.34mhyy prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER SEPTEMBERIT,2O2O2
CERTIF'ICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 176 DAY OF SEPTEMBER2O2O,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMTSSTONSTAFF TO IDAIIO POWER COMPAIYY, IN CASE NO. IPC-E-20-34, BY E-MAILINGA COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
LESLIE IVERSEN
PO BOX 446
TWIN FALLS ID 83303
E-MAIL: [e-mail]
L
SECRETARY
CERTIFICATE OF SERVICE