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Home My WebLink About200508311st staff request to PAC.pdfECEIVED KIRA DALE PFISTERER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0314 IDAHO BAR NO. 6571 ~--' tw. ..,. L_... "'h""'" '" J"" f~UU~ Adb \ f e\rf' I: f t r it \~ , ..~ Ci r~ ~~ ~ 1 Cd I ILl J fLJ CUr'it'tiSSlON Street Address for Express Mail: 472 W. WASHINGTON BOISE, ID 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF ACIFICORP FOR APPROVAL OF A POWER PURCHASE AGREEMENT FOR THE SALE AND PURCHASE OF ELECTRIC ENERGY BETWEEN P ACIFICORP AND SCHWENDIMAN WIND LLC CASE NO. P AC-05- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO ACIFICORP The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Kira Dale Pfisterer, Deputy Attorney General, requests that PacifiCorp (PacifiCorp; Company) provide the following documents and information on or before WEDNESDAY SEPTEMBER 7, 2005. Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder. See IDAPA 31.01.01.228. For each item, please indicate the name of the person(s) preparing the answers, along with the job title of such person(s) and the witness who can sponsor the answer at hearing. FIRST PRODUCTION REQUEST TO P ACIFICORP AUGUST 31 , 2005 This Production Request is to be considered as continuing, and PacifiCorp 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 produced. Request No.1: Please provide evidence that Schwendiman submitted a signed power purchase agreement to PacifiCorp on June 26 2005 as alleged in the Application, Exhibit A, and page 2 of 3 , section 1. Please state why PacifiCorp was not willing to sign the document at the time it was submitted by Schwendiman on June 26, 2005. Please identify and describe those points that were revised and finalized during further negotiations in July to reach a negotiated final contract agreement agreeable to both parties. Request No.2: Please provide PacifiCorp s judgment as to whether the grandfathering criteria as spelled out in Order No. 29839 have been satisfied. Request No.3: Please provide a copy of the wind study referenced in the Application Exhibit A, and page 2 of 3 , section Request No.4: Please provide a copy of the Turbine Purchase Order as referenced in the Application, Exhibit A, and page 2 of3, section 2. Request No.5: Please provide evidence that financing has been arranged for the project. Request No.6: Please provide a copy of the conditional use permit approved by the Bonneville County Planning and Zoning Commission as referenced in the Application, Exhibit , and page 2 of3, section 3. Request No.7: Please provide a copy of the FERC self-certification filing made by Schwendiman in accordance with 18 CFR 292.207. Request No.8: Please explain why the 90/110% banding provisions as required by Order No. 29632 have not been included in the Agreement. Request No.9: Please explain whether the Index Price as defined in the Application Section 1.20 is the Mid-C index, the Palo Verde index or some type of average of the two. Request No. 10: As stated in the Application, Recital E on page 1 , this Agreement will be categorized as a "New QF" under the terms of the PacifiCorp Inter-Jurisdictional Cost Allocation Revised Protocol (RP). The RP states that the costs of "any NEW QF contract which exceed the costs PacifiCorp would have otherwise incurred acquiring a comparable resource will be assigned on a situs basis to the State approving such contract" (emphasis FIRST PRODUCTION REQUEST TO P ACIFICORP AUGUST 31 , 2005 added). Costs not in excess of a "comparable resource" will be system assigned. Note that the RP defines a "comparable resource" to mean "resources with similar capacity factors, start-up costs, and other output and operating characteristics." Please indicate whether PacifiCorp believes this Agreement will result in costs in excess of what PacifiCorp would otherwise incur acquiring a "comparable resource." If so, please define the "comparable resource" and estimate what PacifiCorp believes the situs assigned costs (if any) will be. Respectfully submitted this ~ ,st day of August 2005. ~d. Kira Dale Pfistere Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreq/paceO5.lswrps prl FIRST PRODUCTION REQUEST TO P ACIFICORP AUGUST 31 , 2005 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 31 sT DAY OF AUGUST 2005 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO PACIFICORP, IN CASE NO. PAC-05-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE FOLLOWING: BRUCE GRISWOLD MANAGER ORIGINATION ACIFCORP 825 NE MUL TNOMAH STE 1800 PORTLAND OR 97232 LISA NORDSTROM OFFICE OF THE GENERAL COUNSEL ACIFICORP 825 NE MUL TNOMAH SUITE 1800 PORTLAND OR 97232 DATA REQUEST RESPONSE CENTER ACIFICORP 825 NE MUL TNOMAH SUITE 800 PORTLAND OR 97232 MAILED TO datarequest~pacificorp.com BRIAN D. JACKSON, P . 7800 ALF ALF A LANE MELBA, ID 83641 SECRET CERTIFICATE OF SERVICE