20210422Staff 1-3 to IPC.pdf

Street Address for Express Mail:
I I331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
DAYN HARDIE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 9917
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF AN ENERGY SALES
AGREEMENT WITH REYNOLDS IRRIGATION
DISTRICT FOR THE SALE AND PURCHASE
OF ELECTRIC ENERGY FROM THE
REYNOLDS IRRIGATION HYDRO PROJECT.
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CASE NO. IPC.E.2I.O7
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
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The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Dayn Hardie, Deputy Attorney General, requests that Idaho Power Company provide the
following documents and information as soon as possible, but no later than THURSDAY,
MAY 13,2021.
This Production Request is to be considered as continuing, and Idaho Power 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 or information
produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
FIRST PRODUCTION REQUEST
TO IDAHO POWER I APzuL 22,2021
the person preparing the documents. Please also identiff the name, job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Has the Maximum Capacity Amount for the facility been 300 kW
since the construction of the project? If not, when was the 300-kW step-up transformer
installed? In addition, please list the capacities of all former transformers and when they were
installed.
RBQUEST NO. 2: Page 39 of the Energy Sales Agreement states that the First Energy
Date and the Operation Date for this Agreement will be at hour beginning 00:01 on May I ,2021,
provided that the Commission approves the replacement Agreement, and the Seller completes all
of the Article IV and Article V requirements prior to May 1,2021. Please confirm that the First
Energy Date and the Operation Date in the statement should have been the Scheduled First
Energy Date and the Scheduled Operation Date.
REQUEST NO. 3: The original contract will expire April 30, 2021. The Scheduled
First Energy Date and the Scheduled Operation Date is May 1, 2021. Given that a final order is
unlikely to issue in this proceeding by May 1,2021. Please answer the following questions:
a. Appendix B of the ESA states that Idaho Power cannot accept or pay for generation
from this Facility if the Facility has not achieved the status of being an Idaho Power
Designated Network Resource (DNR). This Facility is an Idaho Power DNR
pursuant to an existing energy sales agreement. The DNR status will continue if this
Agreement is 1) executed and approved by the Commission,2) a Generator
Interconnection Agreement (GIA) has been executed by both parties and, 3) the Seller
is in compliance with all requirements of that GIA. Please answer the following
questions:
3.a.L Will the QF be designated as a DNR between May 1,2021and Commission
approval of the ESA?
3.a.2. Will Idaho Power accept generation from this Facility during this period?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 APRIL 22,2021
3.a.3. Will Idaho Power pay for generation from this Facility during this period?
b. Is the QF planning to deliver energy between May l, 2021 and the actual Operation
Date granted by Idaho Power after the Commission approves the ESA?
c. Have the parties agreed to the rates the Seller will receive for energy generated and
delivered to Idaho Power between May l, 2021 andthe actual Operation Date granted
by Idaho Power after the Commission approves the ESA? If so, please provide the
agreement between the QF and the Company.
uyDATED at Boise, ldaho, this day of April2lZl.
Deputy Attorney General
i:umisc:prodreq/ipce2l.7dhyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER aJ APRIL 22,2021
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF APRIL 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPAIYY, IN CASE NO.
IPC.E-21-07, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
dockets@ idahopower. com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : [e-mail]
SECRET
CERTIFICATE OF SERVICE