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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 n - - - -- -- - _ n - 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 - - -- -- - -- OCTOBER 10, 2003 - -- n - - -- -- ---- - 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 - -- 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 - - - - 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 - -- 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 - - _ n - 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