20230213Staff 21-26 to IPC.pdf.pdf

CHRIS BURDIN ED
DEPUTYATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION '"''°
PO BOX 83720
BOISE,IDAHO 83720-0074 'E CION
[phone]
IDAHO BAR NO.9810
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-22-29
APPROVAL OF A POWER PURCHASE )AGREEMENT WITH PLEASANT VALLEY )SOLAR,LLC.)REDACTED SECOND
)PRODUCTION REQUESTOF
)THE COMMISSION STAFF
)TO IDAHO POWER COMPANY
STAFF of the Idaho Public Utilities Commission ("Staff"),by and through its attorney of
record,Chris Burdin,Deputy AttorneyGeneral,hereby requests that Idaho Power Company
("Company"or "Idaho Power")provide the followingdocuments and information as soon as
possible,but no later than THURSDAY,FEBRUARY 23,2023."Staffisrequestinganexpeditedresponse.If responding by this date will be problematic,please call Staff's attorneyat(208)334-0314.
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY l FEBRUARY 13,2023
This Production Request is continuing,and Idaho Power is requested to provide,by way of
supplementaryresponses,additional documents that it,or any person acting on its behalf,may later
obtain that will augment the documents or informationproduced.
Please provide answers to each question;supporting workpapers that provide detail or are
the source of informationused in calculations;and the name,job title,and telephone number of
the person preparing the documents.Please also identify 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 with formulas intact and enabled.
REQUESTNO.21:Please respond to the followingquestions regarding the Excel File
in Confidential Response to Staff's Production Request No.4:
REQUESTNO.22:Section 6.1.1 describes Test Energy and Net Output before
Commercial Operation Date.What is the difference between Test Energy and Net Output for the
period before Commercial Operation Date?
REQUESTNO.23:Brisbie forecasts commencing operations in
.The Pleasant Valleyproject is expected to deliver Test Energy
before the Commercial Operation Date.Please respond to the following.
a.Please describe the rates Brisbie will be charged (1)before Test Energy is delivered
and (2)after Test Energy is delivered but before the Commercial Operation Date and
the locations of such descriptions in the PPA and/or the Special Contract.For Point
(2),please answer the question in two scenarios:when Test Energy is greater than
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY 2 FEBRUARY 13,2023
Brisbie's load,resulting in excessive energy,and when Test Energy is lower than
Brisbie's load,with no excessive energy.
b.The Test Energy will be paid at .Please explain
whether this payment from Idaho Power to Pleasant Valley will be
,justlike how
.If not,please explain why not.
REQUESTNO.24:Section 7.12.1 uses the difference between of the Expected
Energy of the Facility for such month and any quantities of Output constituting Seller
Uncontrollable Minutes to determine the Net Output capable of being delivered.Please explain
why is used,instead of
REQUESTNO.25:
Please confirm that,under Section 7.12.2.3,when the Seller
does not meet the Output Guarantee,Idaho Power (and therefore ratepayers)will have to pay for
the transmission to move replacement energy to the Point of Deliveryinstead of the Seller.
REQUESTNO.26:The Green Tags Price Component is not considered in Section
1.130 "Seller's Cost to Cover,"but is considered in Section 1.58 "Idaho Power's Cost to Cover."
Please explain whether other customers will pay the additional cost when the Green Tags Price
Component is not considered in Seller's Cost to Cover.[For example,assuming Idaho Power is
not able to purchase the Net Output and the Seller sells the Net Output into the market at
Idaho Power will need to pay the Seller -for
the Net Output.However,if the Green Tags Price Component is considered,Idaho Power will
pay less than
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY 3 FEBRUARY 13,2023
DATED at Boise,Idaho,this ay of February 2023.
Chris Burdin
Deputy AttorneyGeneral
i:umisc:prodreq/ipce22.29cbyy prod req2
REDACTED SECOND PRODUCTION
REQUEST TO IDAHO POWER COMPANY 4 FEBRUARY 13,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 13TH DAY OF FEBRUARY 2023,SERVED THE FOREGOING REDACTED SECOND PRODUCTION REQUESTOFTHECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-22-29,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER TIM TATUM
IDAHO POWER COMPANY CONNIE ASCHENBRENNERPOBOX70IDAHOPOWERCOMPANYBOISEID83707-0070 PO BOX 70E-MAIL:[e-mail] BOISE ID [e-mail] E-MAIL:[e-mail]
[e-mail] [e-mail]
SECRE Y
CERTIFICATEOF SERVICE