HomeMy WebLinkAbout200310101st Request of Staff to Idaho Power.pdfDONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0312
IDAHO BAR NO. 3366
EECEIVED mFILED
lUa3 OCT I 0 PH 2: 01
1'10 PUULlC
UTlLlT!ES COMMISSION
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE RATE BASING OF
THE BENNETT MOUNTAIN POWER PLANT.
CASE NO. IPC-
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Donald L. Howell, II, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
NOVEMBER 7,2003.
This Production Request is to be considered as continuing, and Idaho Power 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 produced.
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
IDAHO POWER COMPANY OCTOBER 10 , 2003
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REQUEST NO.1: Please provide a load-resource balance by month reflecting as
accurately as possible Idaho Power s load-resource conditions for each of the next 10 years
including consideration of the following:
a. abandonment of the Garnet contract;
b. addition of the PPL Montana contract;
b. addition of the Danskin plant;
c. changes in the load forecast considering economic factors; and
d. any other material change in generation or load since the October
2002 Garnet report.
Include load-resource balances for energy and peak hour, for median, 70% and 90%
water and load conditions as defined in the 2002 IRP.
REQUEST NO.2: Please explain and provide supporting documentation showing how
the Company concluded that it needs energy and capacity for primarily heavy load hours in June
July, August, November and December. What water conditions were assumed in determining
these energy and capacity needs?
REQUEST NO.3: Please provide a copy ofload-resource balance data by month for
each of the years 2005-2015 for the following conditions:
Energy analysis
Energy analysis
Energy analysis
Peak hour analysis
Peak hour analysis
Peak hour analysis
50% water, 50% load
70% water, 70% load
90% water, 70% load
50% water, 50% load
70% water, 70% load
90% water, 70% load
Please provide the data under two scenarios: without the addition of Bennett Mountain or any
other new resources, and with the addition of Bennett Mountain. Please provide the data in an
Excel format, both graphical and numerical.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY
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OCTOBER 10, 2003
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REQUEST NO.4: Please provide critical peak analysis data by month for each of the
years 2005-2015 for the following conditions all assuming loads at the currently forecasted
levels:
50% water, 50% load
70% water, 70% load
90% water, 70% load
REQUEST NO.5: Please identify and describe those water and load conditions when
Idaho Power does not expect to be able to meet its energy or peak hour deficits after the Bennett
Mountain plant has been constructed. Explain how Idaho Power plans to meet its energy and
peak hour deficits under these conditions.
REQUEST NO.6: Please provide a list of representatives of potential bidders who
attended the pre-bid meeting on March 7, 2003.
REQUEST NO.7: Please provide a copy of all "Notice of Intent to Bid" forms
completed and submitted to Idaho Power by interested bidders in the 2003 RFP process.
REQUEST NO.8: Please provide a copy of any evaluations, recommendations, or other
correspondence from RW. Beck related to the February 2003 RFP , the RFP evaluation criteria
or the review and evaluation of bids.
REQUEST NO.9: Please provide copies of all bids received in response to the
February 2003 RFP.
REQUEST NO.1 0: Please provide a copy or complete description of all criteria used to
evaluate bids received in the RFP.
REQUEST NO. 11: Please provide copies of all analysis conducted by the Company in
evaluating RFP bids.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 12: Please indicate those bids eliminated in the "short listing" that
occurred during May 2003. Please state the reasons why each bid was eliminated.
REQUEST NO. 13: Please identify and provide a copy of each bid received that, on its
own or in combination with other less than full requirements bids were insufficient to satisfy the
need identified in the RFP. Are any of these bids still being considered? Does Idaho Power
expect to consider any of these bids in the future? If so, please explain.
REQUEST NO. 14: Please provide analysis demonstrating that the Bennett Mountain
project was the least cost alternative for meeting Idaho Power s needs.
REQUEST NO. 15: Please provide a copy of any firm wholesale electric and natural
gas price forecasts used in any of the analysis of bids received in the February 2003 RFP.
REQUEST NO. 16: Please provide documentation of the self-build options used for
comparison purposes in the RFP bid evaluation process. Include a complete description of the
plants; a complete description of the types, sizes and manufacturers of turbines; cost estimates of
major plant components; and a financial analysis of the alternatives that will enable ready
comparison to other alternatives.
REQUEST NO. 17: Please explain the basis for or cite the source of the figures used in
the economic analysis for the self-build options analyzed for each of the following:
a. Total book investment
b. Variable O&M
c. O&M escalation factor
d. Fixed O&M
e. Heat rates
If the cost and performance figures for any of the self-build options are based on equipment from
a specific manufacturer, please provide the name of the manufacturer and a complete description
of the equipment.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 18: In reference to page 7, lines 15-17 of Said's direct testimony,
please describe what is meant by a "... teaming arrangement consisting of Black and Veatch, TIC
and a separate group within Idaho Power s Power Supply Department." Please identify the roles
and responsibilities of each group who participated in preparing the self-build alternative
proposal.
REQUEST NO. 19: Please identify the members of Idaho Power s RFP evaluation
team.
REQUEST NO. 20: Please perform the following computer simulation runs for Idaho
Power s system using the AURORA model. Before making any runs, however, review all
assumptions for the transmission interconnections to Idaho Power s system, all assumptions for
Idaho Power s existing generating plants, power purchase and sales contracts, load shape and
any other necessary input assumptions and make any necessary adjustments so that the model
corresponds as closely as possible to actual conditions. Insure that the load and fuel price
forecasts assumed in the modeling runs are consistent with those of the 2002 IRP. It may be
desirable to use the AURORA "Portfolio" feature to model Idaho Power for purposes of the
following analyses.
a. Perform an hourly simulation beginning June 1 2005 and extending through
December 2020 under an operating mode in which no new capacity can be added
within the Idaho Power system and supply deficiencies are met through power
imports from outside Idaho Power s system. Based on the results of this run, identify
the number and timing of any hours in which transmission constraints limit the
amount of power that can be imported. In addition, identify those transmission
interconnections on which constraints occur. Identify the timing and duration of any
load curtailment predicted by the model. Report the results in graphical format
including any narrative necessary to interpret the results.
b. Perform a long-term optimization (capacity addition) study for the period June 1
2005 through December 2020 (running five years beyond the conclusion of the period
of interest as recommended by EPIS). Use hourly dispatch to fully capture peak load
hours. Confirm that the new resource choices available match those identified in the
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
Company s 2002 IRP and that the Bennett Mountain project is also available as a
choice at the prices and terms assumed in the RFP analysis for the months of June
July, August, November and December. Assume also that market purchases are an
available option. Based on the results of this run, identify the type, timing and
location of new resources added along with the amount of capacity and energy
associated with each new resource. Confirm whether the Bennett Mountain project is
chosen as an alternative to meet load. Summarize the months and the hours within
each month when the Bennett Mountain plant would be used to meet load. Identify
any other resources selected by the model.
c. Perform an hourly simulation beginning June 1 2005 and extending through
December 2020 assuming that capacity and energy is available in accordance with the
Bennett Mountain project but at zero cost. Compare the net power supply cost over
the duration of the simulation to the net power supply cost for the model run
conducted in part "b" above. Compare the difference in net power supply cost to the
cost of the Bennett Mountain project.
d. Perform an hourly simulation beginning June 1 2005 and extending through
December 2020 assuming that capacity and energy is available in accordance with the
Bennett Mountain project and that additional capacity and energy beyond that sought
in the 2003 RFP can be purchased from the Bennett Mountain plant at predicted
market prices (i.e. Bennett Mountain s output in all months other than June, July,
August, November and December is modeled as a contract option available at
prevailing market prices in the Idaho Power load-resource area). Report the amount
timing and cost of all additional capacity and energy purchased from the Bennett
Mountain plant.
REQUEST NO. 21: Please describe any transmission system additions or
improvements, including cost, which will be needed to interconnect the Bennett Mountain plant
into Idaho Power s existing system.
REQUEST NO. 22: Please describe any transmission system additions or
improvements, including cost and construction timing, which will be needed between Mountain
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
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Home and Boise. Are there any improvements being made in the general vicinity of the Bennett
Mountain plant that Idaho Power would have made whether the Bennett Mountain plant was
built or not?
REQUEST NO. 23: Please describe the transmission constraints that made it desirable
or necessary for Idaho Power to specify in the February 2003 RFP that a plant should be located
in the Boise area. Provide copies of any analysis or transmission system studies in which these
constraints were identified and described.
REQUEST NO. 24: Please provide cost estimates and a description of the
improvements that would be necessary for Idaho Power to relieve transmission constraints into
its system such that power could be imported from the market as an alternative to building the
Bennett Mountain plant. Provide a copy of any studies or analysis that has been completed.
REQUEST NO. 25: Please explain, given the transmission constraints identified in
Request No. 23, whether and how surplus energy from the plant will be transmitted outside of
Idaho Power s system and sold.
REQUEST NO. 26: Please describe in detail any transmission system improvements
upgrades or additions that have recently been made or are planned in the general vicinity of the
proposed Bennett Mountain plant. Provide a copy of any study or analysis completed that
recommended such improvements, additions or upgrades. For any upgrades that have recently
been completed, please provide records showing the total costs for the improvements, additions
or upgrades.
REQUEST NO. 27: Will it be necessary to construct a substation as a part of or in
conjunction with the Bennett Mountain project? If so, who will be responsible for paying for the
cost to construct the necessary substation, Idaho Power or Mountain View? If it will not be
necessary to construct a substation, will any improvements have to be made to nearby existing
substations? If so , please identify those substations and list and itemize the costs of the planned
improvements.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
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REQUEST NO. 28: Please discuss the status of the Southwest Intertie Project. Is the
project still being pursued, what would be the capacity and cost of the project, when would it be
completed and would it provide Idaho Power access to the market and thus eliminate the
Company s need to construct new power plants?
REQUEST NO. 29: Please provide a copy of any contracts/agreements signed by Idaho
Power to secure fuel storage and transportation rights (i.e. transportation contracts) for the
Bennett Mountain project. What is the term of the contract(s)? What are the provisions for
extending or renewing the agreements? For what period of time will fuel transportation and
storage be guaranteed?
REQUEST NO. 30: Has Idaho Power negotiated any agreements for the purchase of
natural gas fuel supplies for the Bennett Mountain plant? If so, please provide a copy of all such
agreements.
REQUEST NO. 31: Please describe the fuel procurement strategy Idaho Power intends
to employ for the Bennett Mountain plant. Discuss the following:
a. term oflikely agreements;
b. quantIty of fuel to be purchased on the spot market; and
c. hedging strategies.
REQUEST NO. 32: What is Idaho Power s forecast of expected fuel prices for the
Bennett Mountain plant for the next ten-year period? Please provide forecasts in both a
numerical and a graphical format.
REQUEST NO. 33: Does Idaho Power have a risk management policy for acquiring
natural gas fuel for any of its existing or planned gas-fired plants? If so, please provide a copy.
If not, does the Company expect to develop a risk management policy?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 34: IfIdaho Power has a gas transportation agreement for the Bennett
Mountain plant, does it require payments to Williams Pipeline or others before the Bennett
Mountain facility is finished and running? If so, which party, Idaho Power or Mountain View
will be responsible to make those payments?
REQUEST NO. 35: IfIdaho Power uses the same gas transportation and storage
contract for the Bennett Mountain plant as for some other Idaho Power facilities (Danskin, for
example), how will costs for gas transportation and storage be allocated to the various projects?
REQUEST NO. 36: Please describe the size, length and capacity of any pipelines that
will be necessary to access the Williams Northwest pipeline. Who will pay for the pipeline and
who will be the owner? Will the pipeline be oversized based on the quantity of gas expected
be needed to operate the Bennett Mountain plant?
REQUEST NO. 37: Please provide a copy of any and all agreements between Idaho
Power and Mountain View Power, Inc. Does Idaho Power anticipate any additional agreements
in the future?
REQUEST NO. 38: If an additional generating unit could be added at the Bennett
Mountain project site, how much additional capacity could be added?
REQUEST NO. 39: Is Idaho Power aware of any plans Mountain View Power may
have to build additional capacity at the Bennett Mountain site? Does Idaho Power have any
plans to build additional capacity at the site in the future?
REQUEST NO. 40: If the Bennett Mountain plant capacity is expanded in the future:
a. will an additional fuel management contract be necessary, and
b. will there be sufficient fuel storage and transportation rights available without
pipeline capacity expansions?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 41: Are there any costs of the Bennett Mountain project that will be
incurred solely to enable additional capacity should it eventually be built at the Bennett
Mountain site, e., permitting, land acquisition, pipelines, pipeline capacity, fuel handling or
storage, transmission, substations, interconnection, maintenance buildings or equipment, roads
site improvements, etc.
REQUEST NO. 42: Please provide copies of any permits Idaho Power or Mountain
View has obtained with local, state or federal air, water, solid waste or land management
agencies. Please also summarize the status of all other permits that have not yet been obtained
but that will eventually be necessary for construction and operation of the plant.
REQUEST NO. 43: If additional capacity is added at the project site in the future, will
existing permits be sufficient to permit expansion? What additional permits would have to be
obtained?
REQUEST NO. 44: If either Idaho Power or Mountain View defaults under the
Agreement, how will Idaho Power meet load both in the short-term and the long-term?
REQUEST NO. 45: Please describe any liquidated damages provisions between Idaho
Power and Mountain View.
REQUEST NO. 46: Does Idaho Power anticipate that it will be able to market output
from the plant during light load hours in those months when Idaho Power will be taking output
during heavy load hours or during months other than June, July, August, November and
December? Will the Bennett Mountain plant have to be started several times per week in order
to provide output to Idaho Power during only heavy load hours? What is Idaho Power s estimate
of the total monthly cost for starts during those months in which it will take output?
REQUEST NO. 47: Will the Company at any time be paid by Mountain View Power
Inc. to act as its agent? Does the Company assume any risk by acting as Mountain View, Inc.
agent?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 48: How much water will be purchased for plant operation from the
City of Mountain Home? What rate will be charged by the City of Mountain Home for water?
Is there a water purchase agreement between the City of Mountain Home and Mountain View
Power or Idaho Power? If so, please provide a copy.
REQUEST NO. 49: Please quantify the amount of waste expected to be discharged to
the City of Mountain Home s sewer system. What rate will be charged by the City of Mountain
Home for sewer treatment? Is there a wastewater treatment and disposal agreement between the
City of Mountain Home and Mountain View Power or Idaho Power? If so, please provide a
copy.
REQUEST NO. 50: Please individually list and quantify each of those expected or
potential project costs representing the difference between the $54.0 million commitment
estimate and the $44.6 million Mountain View contract amount, e., sales taxes, AFUDC on
progress payments made during construction, the cost ofIdaho Power oversight of the project
the cost of capitalized start-up fuel and any other costs. Where appropriate, show how the
amounts have been computed and list any assumptions used to compute the amounts.
REQUEST NO. 51: Please explain why Idaho Power is not including transmission costs
in its commitment estimate. How and when is Idaho Power proposing to recover transmission
costs?
REQUEST NO. 52: Please describe in greater detail and provide examples of what
constitutes "legally required equipment changes" mentioned on page 5 of the Application.
Provide a range of possible costs of such "required equipment."
REQUEST NO. 53: Please describe and provide the "assumed escalation rates" as that
term is used on page 5 of the Application. What costs are attributable to the "assumed escalation
rates
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 54: Please describe in detail how the income tax bonus works for
investment made before December 31 , 2004. Please describe any liquidated damage provisions
in the event Idaho Power forgoes income tax bonus amounts due to delays in construction.
REQUEST NO. 55: Please describe how construction of the Bennett Mountain plant
will be financed. Include a summary of the payment schedule Idaho Power will follow. Also
include an estimate of AFUDC and the analysis supporting the statement "Such financing by the
Company allows for a lower total cost to customers than if Mountain View Power, Inc. were to
finance the Project in a different manner." Said direct testimony, page 16, lines 5-
REQUEST NO.56: Please provide a copy ofIdaho Power s credit analysis of Mountain
View Power, Inc. Please provide documentation of the credit rating of Mountain View Power
Inc. as rated by Moody , Standard and Poor , Fitch, or other rating agency.
REQUEST NO. 57: Please describe any contractual (market) products that may be
available that could provide capacity and energy comparable, or nearly comparable, to that
which would be provided in the first five years of the Bennett Mountain plant. Please provide
the current price for these products and identify the source from which the prices have been
obtained. Please discuss how the Bennett Mountain plant would be different, better, or worse
than such products.
REQUEST NO. 58: Please provide a summary of the average price during each ofthe
months since January 2003 of the Mid-C forward prices for the period 2005-2010 for firm heavy
load hour products. Please describe the product(s) for which the prices are representative and
discuss how they differ from Idaho Power s stated needs in its June 2002 RFP.
REQUEST NO. 59: What is Idaho Power s current forecast of expected firm wholesale
electric energy prices for the next five and ten-year periods for heavy and light load hours?
Please identify the source and date on which the forecasts were made.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 60: Please discuss any demand-side management (DSM) alternatives
considered as a means of minimizing or replacing the need for new generation from the Bennett
Mountain plant. What action has Idaho Power taken to attempt to identify, quantify and price
DSM alternatives?
REQUEST NO. 61: Please provide complete program descriptions of Idaho Power
pilot residential air conditioner cycling program and its new irrigation program. Discuss the
status of these programs including participation levels, funding commitments and future
expansion plans. Describe how these programs reduce any of the peak load that would otherwise
have to be satisfied using the proposed Bennett Mountain plant.
REQUEST NO. 62: Has Idaho Power considered any additional load management
programs, rate designs or other strategies that could reduce the Company s peak load during
those months and hours when the Bennett Mountain plant is expected to operate? If so, does the
Company have any specific plans to introduce such programs? Please provide copies of any
reports, studies or analysis of any load management programs considered.
REQUEST NO. 63: Please provide data showing the monthly generation of the Danskin
plant from plant completion through the present.
REQUEST NO. 64: Please discuss how the operation of the Danskin plant will change
once the Bennett Mountain plant becomes operational. Please provide numerical data showing
the monthly difference in the amount of expected generation from the Danskin plant with and
without the Bennett Mountain plant.
REQUEST NO. 65: Please provide a copy of any analysis showing the costs associated
with converting and operating the Danskin project as a combined cycle plant.
REQUEST NO. 66: Did Idaho Power consider converting the Danskin plant to
combined cycle or adding additional units at Danskin as alternatives to the Bennett Mountain
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
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Mountain plant. What action has Idaho Power taken to attempt to identify,
DSM alternatives?
REQUEST NO. 61: Please provide complete program desc ptions of Idaho Power
pilot residential air conditioner cycling program and its new irrig on program. Discuss the
status of these programs including participation levels, funding ommitments and future
expansion plans. Describe how these programs reduce any 0 the peak load that would otherwise
have to be satisfied using the proposed Bennett Mountain ant.
REQUEST NO. 62: Has Idaho Power consid ed any additional load management
programs, rate designs or other strategies that could educe the Company s peak load during
those months and hours when the Bennett Mount n plant is expected to operate? If so, does the
Company have any specific plans to introduce ch programs? Please provide copies of any
reports, studies or analysis of any load mana ment programs considered.
REQUEST NO. 63: Please pro de data showing the monthly generation of the Danskin
plant from plant completion through t e present.
REQUEST NO. 64: Pie e discuss how the operation of the Danskin plant will change
once the Bennett Mountain pia becomes operational. Please provide numerical data showing
the monthly difference in the amount of expected generation from the Danskin plant with and
without the Bennett Moun in plant.
REQUEST N . 65: Please provide a copy of any analysis showing the costs associated
with converting an operating the Danskin project as a combined cycle plant.
REQU ST NO. 66: Did Idaho Power consider converting the Danskin plant to
combined cy, Ie or adding additional units at Danskin as alternatives to the Bennett Mountain
plant? If s , please explain why those alternatives were rejected and provide a copy of any
analysis completed by Idaho Power justifying this decision.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 67: Please provide information to document the final capital cost of the
Danskin plant. Please compare the actual capital cost for the plant to the construction cost
estimate.
REQUEST NO. 68: Please provide a complete description of any actual or proposed
energy or capacity sales to any other parties from the Bennett Mountain plant. If no sales
agreements have yet been made, when does Idaho Power expect to make them?
REQUEST NO. 69: Please discuss the status ofIdaho Power s plans as outlined in the
2002 IRP to upgrade the Brownlee - Oxbow transmission line to be in service in 2005 and the
Company s plans to upgrade the Shoshone Falls project to be in service in 2007.
REQUEST NO. 70: Please discuss any plans Idaho Power has to issue additional RFPs
in the next five years. What would be the timing of the RFPs and what type and size of resource
would the Company be seeking?
REQUEST NO. 71: Please discuss whether there will be any implications for Idaho
Power s agreement with PPL Montana for 83 MW of firm power during heavy load hours as a
result of Northwestern Energy s recent filing for Chapter 11 bankruptcy. Does Idaho Power
expect any difficulty with PPL Montana s ability to deliver, and if so, how does this affect Idaho
Power s need for power.
REQUEST NO. 72: Please provide all plans of both Idaho Power and Mountain View
Power relating to financing construction of the Bennett Mountain plant. Please provide copies of
any financing agreements.
REQUEST NO. 73: Does any financing arrangement ofIdaho Power or Mountain View
hinge on the acceptance of the Idaho Public Utilities Commission s (IPUC) approval ofldaho
Power s Application to rate base the plant? If so, provide a copy of the pertinent document.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
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REQUEST NO. 74: If the IPUC does not approve Idaho Power s Application to rate
base the plant, will Mountain View continue with the construction of the Bennett Mountain
plant?
REQUEST NO. 75: Does Mountain View intend to maintain the capability to utilize a
secondary source of fuel? If so, what is the status of those plans? Have any agreements been
negotiated for either the supply of secondary fuel, its storage or its transport? If so, please
provide a copy of those agreements.
REQUEST NO. 76: Please provide a copy of the Articles of Incorporation for Mountain
View, Inc. Please provide a list of all Mountain View partnership members. Please provide a
copy of all management agreements currently in place.
REQUEST NO. 77: Please provide copies of all operational, financial and any other
reports made to members of Mountain View s managing partnership since the inception of the
company.
REQUEST NO. 78: Please provide copies of the year-end balance sheet and income
statements for Mountain View since its inception and a copy of the statements through the
second quarter of 2003. Provide a copy of Mountain View s general ledger for all accounts since
its inception through the second quarter of2003.
REQUEST NO. 79: Please provide a summary of the prior experience of Mountain
View Power, Inc. in building power plants. Include a description of the size, type, location
owner and completion date of each plant.
REQUEST NO. 80: Please describe any contracts Mountain View has entered into or
expects to negotiate for the engineering, procurement, construction, testing or operation of the
Bennett Mountain plant. Please provide a copy of any agreements that have already been signed.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
REQUEST NO. 81: Please provide a copy of any agreements or contracts Mountain
View has with the City of Mountain Home.
REQUEST NO. 82: Please provide copies of any permits Mountain View has obtained
with local, state or federal air, water, solid waste or land management agencies. Please also
summarize the status of all other permits that have not yet been obtained but that will be
necessary to construct the plant.
DATED at Boise, Idaho, this () day of October 2003.
Don Howell
Deputy Attorney General
Technical Staff: Rick Sterling
i :umisc :prodreqlipceO3 .l2dhrps ipc1
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY OCTOBER 10, 2003
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF OCTOBER 2003
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-03-, BY MAILING A
COpy THEREOF, POSTAGE PREPAID , TO THE FOLLOWING:
BARTON L KLINE
MONICA MOEN
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
JOHN P PRESCOTT
VICE PRESIDENT - POWER SUPPLY
IDAHO POWER COMPANY
PO BOX 70
BOISE, ID 83707-0070
CERTIFICATE OF SERVICE