20220218Staff 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 COMPAI{Y FOR APPROVAL
OR REJECTION OF AII ENERGY SALES
AGREEMENT WITH SHINGLE CREEK LLC,
FOR THE SALE AND PURCHASE OF
ELECTRIC ENERGY FROM TIIE SHINGLE
CREEK HYDRO PROJECT
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CASE NO.IPC-8.22-02
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPAI\TY
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 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 Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
FRTDAY, MARCH 18,2022.
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 FEBRUARY 18,2022
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: Please explain how Idaho Power verifies nameplate capacity of its
qualifring facilities. What evidence does the Company request?
REQTIEST NO. 2: The20l7 Agreement in Case No. IPC-E-17-08 lists both the
nameplate capacity and the Maximum Capacity Amount as222 kilowaffs ("kW"). However, the
proposed energy sales agreement in Case No. IPC-E-22-02 lists the nameplate capacity and the
maximum capacity amount as224 kW and 222kW, respectively. Please reconcile the two
agreements and provide evidence of the actual nameplate capacity.
DATED at Boise, Idaho, ttis / tfr aut of February 2022
L
Riley Newton
Deputy Attorney General
i:umisc:prodreq/ipce22.2myy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 18,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ISth DAY OF FEBRUARY 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
coMMrssroN STAFF To IDAHO POWER COMPAIYY, IN CASE NO. IPC-E-22-02,
BY E-MAILING A 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
BRYAN DeVENY
MIKE DeVENY
SHINGLE CREEK LLC
PO BOX 1160
RIGGINS ID 83549
E-MAIL: [e-mail]
[e-mail]
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE