20221213IPC to Staff 1.pdf

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MEGAL GOICOEGHEA-ALLEN
Corporate Gounsel
[e-mail]
December 13,2022
VIA ELECTRONIC MAIL
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 2O1-A
Boise, ldaho 83714
Case No. IPC-E-22-28
Lower Lowline, LLC - Lowline #2Hydro Project
ldaho Power Company's Application re Energy Sales Agreement
Dear Ms. Noriyuki
Attached for electronic filing is ldaho Power Company's Response to First
Production Request of the Commission Staff in the above entitled matter. lf you have any
questions about the attached documents, please do not hesitate to contact me.
Very truly yours,
Re
WT.ou)M^fi0lo,,r
Megan Goicoechea-Allen
MGA:cld
Enclosures
DONOVAN E. WALKER (lSB No. 5921)
MEGAN GOICOECHEA ALLEN (lSB No. 7623)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
dwa lker@ idahopower.com
mootcoecheaal idahooower.com
Attomeys for ldaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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. |PC-E-22-28
IDAHO POWER COMPANY'S
RESPONSE TO FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF TO
IDAHO POWER COMPANY
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COMES NOW, ldaho Power Company ("ldaho Powe/' or "Company"), and in
response to the First Production Request of the Commission Staff ('IPUC or
Commission") dated November 23,2022, herewith submits the following information
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION 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. lf 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 1 .2, and the March-May
weighting was 0.75.)
c. lf not, please provide the orders that determined the rates used in the 1986
contract.
RESPONSE TO REQUEST FOR PRODUCTION NO. 1: ldaho Power objects to
this request on the basis that it requests information not relevant to the Application in this
proceeding, which requests approval of a replacement Energy Sales Agreement ('ESA')
for the Lowline #2 Hydro Project ("Facility"), and further objects on the basis that ldaho
Power does not have possession of, or access to, the Decision Memo referenced in the
request. The existing ESA for the Facility, which was entered into on September 12,
1986, was approved by the Commission on November 14, 1986, in Order No. 20823 and
was explicitly found to be "in conformity with applicable Commission Orders.'Order No.
20823 does not specifically reference Order No. 20350, and ldaho Power does not
possess or have access to the Decision Memo referenced in the request, which in any
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 2
case does not constitute binding Commission precedent. ln an effort to understand the
full context of this request, ldaho Power requested a copy of the Decision Memo from the
attorney for Commission Stiaff, but it has not been provided as of the date of this response.
Subject to and without waiving its objections and pursuant to the above
explanation, ldaho Power responds as follows:
(a) Based on the information available to ldaho Power, it appears the rates
initially used in the 1986 agreement were consistent with those approved in Order
No. 20350 under the heading "1987 Avoided Costs'. ldaho Power has no
information as to why the 1987 Avoided Costs rates were used, vercus the 1986
Avoided Costs. Regardless, as noted above, the 1986 ESA was approved by the
Commission in Order No. 20823:
The Commission finds that the Agreement as signed and submitted by
the parties contains avoided cost rates in conformity with applicable
Commission Orders. The terms of the contract are reasonable and we
approve them. We also approve payments made under this Agreement
as prudently incurred expenses for ratemaking purposes.
It appears the adjustable portion of the rates in section 7 .1 .2 of the 1 986 agreement
was later revised and ultimately approved by the Commission in a minute entry
order in Case No. IPC-E-96-8, dated June 7, 1996. ldaho Power has no further
information regarding the amendment beyond what is stated in the amendment
itself and in the minute entry order.
(b) Please see the response to part (a). ldaho Power has no other information
as to whether or why the rates do or do not match the rates in Order No. 20350.
The rates were approved by the Commission as described in part (a).
(c) Please see the responses to parts (a) and (b).
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 3
The response to fflis Request is sponsored by Camille Christen, Resource
Aoquisition, Planning, and Coordination Manager, ldaho Power Company.
Respec{fi.rlly submitted this 13m day of December 2022.
'l-ryTiuilr-ooft,r
MEGAN GOICOECHEA ALLEN
Attomey for ldaho Power Company
IDAHO POVVER COMPAI.IYS RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPATIY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13h day of December 2022,1 served a true and
correct copy of the within and foregoing ldaho Power Company's Response to the First
Production Request of the Commission Staff to ldaho Power Company upon the following
named parties by the method indicated below, and addressed to the following:
Michael Duval
Deputy Attomey Genera!
ldaho Public Utilities Commission
11331 W. Chinden Blvd., BIdg No.8,
Suite 201-A(83714)
PO Box 83720
Boise, lD 83720-0074
Louis Zamora
Twin Fa!!s Canal Company
P.O. Box 326
Twin Falls, ldaho 83303
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Christy Davenport, Legal Assistant
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY - 5