HomeMy WebLinkAbout20221005Staff 1 to IPC.pdfMICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0320
IDAHO BARNO. II7I4
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF A SECOND AMENDMENT
TO THE ENERGY SALES AGREEMENT
WITH CASSIA WIND FARM, LLC.
CASE NO.IPC.E.22.23
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Michael Duval, Deputy Attomey General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, OCTOBER 19, 2022.1
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
l Stuff ir requesting an expedited response. If responding by this date will be problematic, please call Staff s
attorney at (208) 334-0320.
FIRST PRODUCTION REQUEST
TO IDAHO POWER
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I OCTOBER 5,2022
the person preparing the documents. Please also identifu 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. l: The Application states "[t]he Seller has remained compliant with the
Mechanical Availability Guarantee and has adjusted its estimated net energy deliveries pursuant
to the terms of the contract." Please respond to the following:
a. Please identifu where the Mechanical Availability Guarantee ("MAG") was stated in
the original Agreement and explain why the loss of Tower 5 does not affect
compliance with the MAG.
b. Please explain in detail how the Seller has adjusted its estimated net energy deliveries
pursuant to the terms of the contract and provide the updated estimated net energy
deliveries.
DATED at Boise,Idaho, this 5
+h
day of October2022
Michael
Deputy Attomey General
i:umisc:prodreq/ipce22.23mdyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 OCTOBER 5,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 5TH DAY OF OCTOBER 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPAI\Y, IN CASE NO.IPC-E-22-23,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL : dwalker@idahopower.com
mgoicoecheaallen@ idahopower. com
dockets@ idahopower. com
CASSIA WIND FARM, LLC
C/O CONSTELLATION POWER
ATTN: DAVID DUEKER
E-MAIL: david.dueker@constellation.com
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: energycontracts@idahopower.com
CASSIA WTND FARM, LLC
C/O CONSTELLATION POWER
ATTN: RYON SWANN
E-MAIL : ryon.swann@.constellation.com
SECRET
CERTIFICATE OF SERVICE