20210921Staff 1-2 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. II2O2
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR APPROVAL
OR REJECTION OF THE SECOND
AMENDMENT TO THE ENERGY SALES
AGREEMENT WTH MC6 HYDRO LLC FOR
THE SALE AND PURCHASE OF ELECTRIC
ENERGY FROM THE MC6 HYDRO PROJECT
CASE NO.IPC-E-2I-30
FIRST PRODUCTION
REQUEST OF TIIE
COMMISSION STAFF
TO IDAHO POWER COMPAIIY
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Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE,ID 83714
Attomey 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,
Riley Newton, Deputy Attomey General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
TUESDAY, OCTOBER 12, 2021.
This Production Request is to be considered as 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 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
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER I SEPTEMBER2I,2O2I
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: OrderNo. 34425 allowed delayed damages to be calculated from the
original Scheduled Operation Date of July 30,2019. Please provide the period of time that the
Seller was assessed delayed damages and the time period that the QF was allowed to claim force
majeure? Please explain the rationale used for establishing the dates.
REQUEST NO. 2: Please provide all actual hourly generation data (number of kilowatt-
hours for each hour generated by the project) starting from the Operation Date to the most recent
date that data is available.
DATED at Boise, Idaho, this 2 lt+ duyof Septemb er 2O2l
Riley
Deputy Attorney General
i:umisc:prodreq/ipce2l.30myy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 SEPTEMBERZI,2O2I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21't DAY OF SEPTEMBER 2021,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO rDAHO POWER COMPATIY, IN CASE NO. IPC-E-21-30, 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
TED SORENSON
MC6HYDRO LLC
7II E TURTLE POINT DR
IVINS UT 84738
E-MAIL: ted@.tsorenson.net
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE