200601312nd staff request to PAC.pdf

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SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 1895
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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. PAC-05-
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
ACIFICORP
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Scott Woodbury, Deputy Attorney General, requests that PacifiCorp (PacifiCorp; Company)
provide the following documents and information on or before TUESDAY, FEBRUARY 14
2006.
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
IDAP A 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.
SECOND PRODUCTION REQUEST
TO P ACIFICORP JANUARY 31, 2006
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. 11: Please provide a detailed narrative description of how the Non-
Conforming Energy Purchase Prices as shown on page 14 of the Amended Agreement were
computed, Include a copy of all spreadsheets, computations, analysis, data, or other information
used to derive the prices.
Request No. 12: Please discuss how the Non-Conforming Energy Purchase Prices as
shown on page 14 of the Amended Agreement provide a reasonable or equivalent substitute for
the 90/110 performance band as addressed by the Commission in Order No, 29880,
Respectfully submitted this '5'day of January 2006,
Scott Woodbury
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/paceO5,9swrps pr2
SECOND PRODUCTION REQUEST
TO P ACIFICORP JANUARY 31 , 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 31 sT DAY OF JANUARY 2006
SERVED THE FOREGOING SECOND 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 MULTNOMAH STE 1800
PORTLAND OR 97232
LISA NORDSTROM
OFFICE OF THE GENERAL COUNSEL
P ACIFICORP
825 NE MUL TNOMAH SUITE 1800
PORTLAND OR 97232
DATA REQUEST RESPONSE CENTER
P ACIFICORP
825 NE MUL TNOMAH SUITE 800
PORTLAND OR 97232
MAILED TO datarequest~JJacificorp.com
BRIAN D, JACKSON, P.
7800 ALFALFA LANE
MELBA, ID 83641
DEAN J MILLER ESQ
McDEVITT & MILLER LLP
420 W. BANNOCK
BOISE ID 83702
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SECRET AR Y
CERTIFICATE OF SERVICE