20200924Staff 1 to Shawpatin.pdf

MATT HUNTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10655
Street Address for Express Mail:
1133I W CHINDEN BVLD, BLDG 8, SUITE 2OT-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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IN THE MATTER OF IDAHO POWER
COMPANY'S APPLICATION FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH SHAWPATIN AGCAP,
LLC,FOR TIIE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM THE MUD CREEK
WHITE HYDRO PROJECT
CASE NO. IPC.E.2O-34
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
SHAWPATIN AGCAP, LLC
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The Staff of the Idaho Public Utilities Commission requests that Shawpatin AgCap,LLC
("Shawpatin") provide the following documents and information as soon as possible, by
THURSDAY, OCTOBER 8, 2020.r
This Production Request is continuing, and Shawpatin 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. Shawpatin 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 Stuff is requesting an expedited response. If responding by this date will be problematic, please call Staff's
attorney at [phone].
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 SEPTEMBERZ4,2O2O
different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.o1.228.
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. 1: Appendix B to the Energy Sales Agreement states that the facility
has 2 units. Please answer the following:
a. What is the nameplate capacity of each unit?
b. When was each unit installed?
c. Please provide a diagram of the facility labeling the different units.
d. Please describe the configuration of the two units and how they will be operated
under different situations regarding water availability.
Dated at Boise, Idaho, this f f a day of September 2O2O.
Matt Hunter
Deputy Attorney General
i:umisc:prodreq/ipce20.34mhyy prod reql to Mud Creek White
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBER24,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24th DAY OF SEPTEMBER 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO SAWPATIN AGCAP, LLC, IN CASE NO. IPC-E-2O-34, By E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE rD 83707-0070
E-MAIL: [e-mail]
dockets @ idahopower.com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 83707-0070
E-MAIL: [e-mail]
LESLIE IVERSEN
PO BOX 446
TWIN FALLS ID 83303
E-MAIL: ShawpatinAgCap @ gmail.com
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CERTIFICATE OF SERVICE