20230203Staff 1-4 to IPC.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11202
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-23-02
APPROVAL OR REJECTION OF AN )ENERGY SALES AGREEMENT WITH )NORTH SIDE ENERGY COMPANY,INC.)FIRST PRODUCTION
FOR THE SALE AND PURCHASE OF )REQUESTOF THE
ELECTRIC ENERGY FROM THE BYPASS )COMMISSION STAFF
HYDRO PROJECT )TO IDAHO POWER COMPANY
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
RileyNewton,Deputy Attorney General,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than FRIDAY,FEBRUARY 24,2023.
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 identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 1 FEBRUARY 3,2023
RECEIVED
2023 February 3, 1:27PM
IDAHO PUBLIC
UTILITIES COMMISSION
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.
REQUESTNO.1:Please respond to the followingregarding Article XXIII
Modification under the proposed energy sales agreement:
a.Please confirm that between the time the Seller notifies Idaho Power of an
intention of modifyingthe Facility and the time the modification actually occurs,
the Parties do not plan to seek Commission approval of the intendedmodification.
b.Please confirm that the Parties will seek Commission approval of the modification
after the modification actually occurs.
c.Please explain how the language in the contract ensures that the QF is paid the
proper rate as of the first operation date after modifications to the Facility are
made and that the description of the Facility reflected in the final approved
amendment describe the Facility as actually modified.
REQUESTNO.2:Please respond to the followingregarding the Facility's nameplate
capacity.
a.Please provide evidence that each of the three generators has a nameplate capacity
of 3333 kW as stated in Appendix B.
b.Appendix B states "Facility Nameplate Capacity:9960 kW."Please confirm that
9960 kW should have been 9999 kW.If not,please explain.
c.According to Appendix B,the station service uses 39 kW out of 9999 kW.Please
provide evidence to support the 39-kW usage.
REQUESTNO.3:The Application states "should the Facility exceed 10 aMW on a
monthlybasis or 2790 kW on an hourlybasis,Idaho Power will accept the energy,defined as
Inadvertent Energy,but will not purchase or pay for it."Please confirm that 2790 kW should
have been 9960 kW (or 9999 kW depending on the actual nameplate capacity),which is the
Maximum Capacity Amount.
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 FEBRUARY 3,2023
REQUESTNO.4:Prices for 2023 in Section E-2 of Appendix E (Base Energy Light
Load Purchase Price)on Page 53 of the Energy Sales Agreement are not fully shown due to a
formatting issue.What are the proposed prices for 2023 in Section E-2?
DATED at Boise,Idaho,this day of February 2023.
Riley N on
Deputy ttorney General
i:umisc:prodreq/ipce23.2rnyy prod req l
FIRST PRODUCTION REQUEST
TO IDAHO POWER 3 FEBRUARY 3,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3rd DAY OF FEBRUARY 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO IDAHO POWER COMPANY,IN CASE NO.IPC-E-23-02,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
DONOVAN E WALKER ENERGY CONTRACTS
MEGAN GOICOECHEA ALLEN IDAHO POWER COMPANY
IDAHO POWER COMPANY PO BOX 70
PO BOX 70 BOISE ID 83707-0070
BOISE ID 83707-0070 E-MAIL:[e-mail]
E-MAIL:[e-mail]
[e-mail]
[e-mail]
SECRE RY
CERTIFICATE OF SERVICE