20230601Staff 1-3 to IPC.pdf

MICHAEL DUVAL
DEPUTY ATTORNEYS GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.I1714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )COMPANY'S APPLICATION FOR )CASE NO.IPC-E-23-19APPROVALORREJECTIONOFAN)ENERGY SALES AGREEMENT WITH )FIRST PRODUCTIONAMERICANFALLSRESERVOIRDISRICT)REQUESTOF THENO.2 FOR THE SALE AND PURCHASE OF )COMMISSION STAFFELECTRICENERGYFROMTHEDIETRICH)TO IDAHO POWER COMPANYDROPHYDROPROJECT)
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that Idaho Power Company ("Company"or
"Idaho Power")provide the followingdocuments and information as soon as possible,but no
later than THURSDAY,JUNE 22,2023.
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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephone number of the record holder.
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 1 JUNE 1,2023
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.1:Page 6 of the Application states that the project nameplate capacity
is 4,770 kW and that this amount is the nameplate in the 1987 Agreement.However,the copy of
the 1987 agreement Staff has in its records shows the nameplate capacity at 4,500 kW.Please
respond to the following:
a.Was the 1987 agreement amended to reflect the 4,770-kW nameplate capacity?If
so,please provide a copy of the 1987 amended agreement;and
b.If it wasn't amended,please reconcile and explain the discrepancy.
REQUESTNO.2:What various impacts would the new proposed annual period
(starting on June l for this QF's calculation of the 55%requirement)have on the Company for
this contract?Please provide an analysis that includes,but is not limited to,the impacts on the
following:
a.How these timeframes affect resource and operational planning;
b.The administrative burden to track contracts with different timeframes;
c.The ability of the Company's accounting systems to accommodate different
timeframes;and
d.Other hydro QFs that may want to change the annual period.
REQUESTNO.3:Page 3 of Sorenson Engineering,Inc.and IdaHydro'sComments
state that the QF does not receive the accounting information for August "until well into
September."Please respond to the following:
a.When does the Company currentlyprovide its accounting information for
generationdelivered in August?
b.When is the earliest the Company can provide the accounting informationfor
August to the QF?
FIRST PRODUCTION REQUEST
TO IDAHO POWER 2 JUNE 1,2023
DATED at Boise,Idaho,this day of June 2023.
Michael Duval
Deputy AttorneyGeneral
i:umise:prodreq/ipce23.19mdyy prod req 1
FIRST PRODUCTIONREQUEST
TO IDAHO POWER 3 JUNE 1,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16'DAY OF JUNE 2023,SERVEDTHEFOREGOINGFIRSTPRODUCTIONREQUESTOFTHECOMMISSIONSTAFFTOIDAHOPOWERCOMPANY,IN CASE NO.IPC-E-23-19,BY E-MAILING ACOPYTHEREOF,TO THE FOLLOWING:
DONOVAN E WALKER ENERGY CONTRACTSMEGANGOICOECHEAALLENIDAHOPOWERCOMPANYIDAHOPOWERCOMPANYPOBOX70POBOX70BOISEID83707-0070BOISEID83707-0070 E-MAIL:[e-mail]-MAIL:[e-mail]
mgoicoecheaallen¾idahopower.com
[e-mail]
MIRIAH R ELLIOTT IDAHYDRODIETRICHDROPHYDROPROJECTCTOMARKOOSH71lETURTLEPOINTDRARKOOSHLAWOFFICESIVINSUT84738POBOX2900E-MAIL:miriah tsorenson.net BOISE ID 83701
E-MAIL:[e-mail]
erin.cecil arkoosh.com
CERTIFICATE OF SERVICE