20210423Staff 1-4 to IPC.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
HYDROLAND OMEGA LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY
FROM THE ELK CREEK HYDRO PROJECT
CASE NO.IPC.E.2I.O8
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
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Street Address for Express Mail:
I 1331 W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES 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 Attorney General, request that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, or by FRfDAY,
MAY 14,2021.
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 witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 APRLLZ3,202t
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: Please provide a copy of the 1984 f,rrm energy sales agreement that
Hydroland Omega LLCaI (the "QF") has operated under.
REQUEST NO. 2: Page 39 at B-3 of Appendix B to the Energy Sales Agreement ("ESA")
states that the "First Energy Date and the Operation Date for this Agreement will be at hour
beginning 00:01 on May 1,2021, 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,
2027." Please confirm that the First Energy Date and the Operation Date in this section should be
the Scheduled First Energy Date and the Scheduled Operation Date.
REQUEST NO.3: The 1984 firm energy sales agreement will expire on 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 be issued in this proceeding by May 1,2021. Please answer the following
questions:
a. Appendix B at page 38, Section B-7 of the ESA states that "ldaho 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 a Company DNR pursuant to an existing energy sales agreement. Section B-7 also
provides that" [t]he DNR status will continue if this Agreement is 1) executed and
approved by the Commission, and 2) a [Generator Interconnection Agreement
(GIA)I has been executed by both parties and 3) the Seller is in compliance with all
requirements of that GIA. Please answer the following questions:
i. Will the QF be designated as a DNR between May 1,2021 and
Commission approval of the ESA?
ii. Will Idaho Power accept generation from this Facility during this period?
iii. Will Idaho Power pay for generation from this Facility during this period?
b. Is the QF planning to deliver energy to the Company after May 1,2021even if the
Commission has not approved the ESA by that date?
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRTLZ3,2O2I
c. Have the parties agreed to the rates the QF will receive for energy generated and
delivered to the Company between May 1, 2021 andthe actual Operation Date if the
Commission approves the ESA after May 1,2021? If so, please provide the
agreement between the QF and the Company.
REQUEST NO. 4: Section 6.2.1 of the ESA lists the Monthly Estimated Net Energy
Amounts. Please explain why the generation amount is zero in months of January, February,
August, September, October, November, and December.
DATED at Boise, Idaho, this 23m day of April2}2l.
{.-r -
John R
Depgty
Jr
General
i:umisc:prodreq/ipce2l.8jhyy prod reql
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY J APRIL23,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23'd DAY OF APRIL 2021, SERVED
THE FOREGOING FIRST PRODUCTION REQUEST OF TITE COMNflSSION STAFF
TO IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-21-08, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
IDAHO POWER COMPANY
PO BOX 70
BOrSE ID 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]
-L-f,rL^.
SECRET-AfrF-
CERTIFICATE OF SERVICE