20221123Staff 1 to IPC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II7I4
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OR REJECTION OF AN
ENERGY SALES AGREEMENT WITH
LOWER LOWLINE LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC ENERGY
FROM THE LOWLINE #2 HYDRO PROJECT
CASE NO. IPC.E.22.28
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER COMPANY
IiFCEIVED
:$:i ru*y ?3 Pff 2: 5?
t i:i\ '.:, tar r\'-*.it '/ i-Lriji-ll,., i' i (.l0ili,{lSStOtl
Street Address for Express Mail:
1 1331 W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
)
Staff of the ldaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, requests that Idaho Power Company ("Company")
provide the following documents and information as soon as possible, but no later than
WEDNESDAY, DECEMBER 14, 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 NOVEMBER23,2022
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: The Decision Memo dated October 24, 1986, stated the rates used in
the 1986 contract were established in Order No. 20350 in Case No. U-1006-248. Please respond
to the following.
a. Please confirm the rates used in the 1986 contract were determined in Order
No.20350.
b. If yes, please explain why the rates used in the 1986 contract did not match the
rates determined in Order No. 20350. (The avoided cost rates without
seasonalization were listed on Page 23 of Order No. 20350. For seasonalization,
Order No. 20350 determined that the October-February weighting was 1.0, the
June-September weighting was l.2,andthe March-May weighting was 0.75.)
c. If not, please provide the orders that determined the rates used in the 1986
contract.
DATED at Boise,Idaho, tnis 2Z&aay of Nove mber2022.
Duval
Deputy Attorney General
i:umisc:prodreq/ipce21.28mdyy prod req I
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 NOVEMBERZ3,2022
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23,d DAY OF NovembeT 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
CoMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-22-28,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
DONOVAN E WALKER
MEGAN GOICOECHEA ALLEN
IDAHO POWER COMPANY
PO BOX 70
BOrSE rD 83707-0070
E-MAIL: [e-mail]
mgoicoecheaallen@ idahopower. com
[e-mail]
LOUIS ZAMORA
TWIN FALLS CANAL CO
PO BOX 326
TWIN FALLS ID 83303
E-MAIL : lzamor a@tfc anal. c om
ENERGY CONTRACTS
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
Y
CERTIFICATE OF SERVICE