200311101st Response Additions of Idaho Power to Staff.pdf

BARTON L. KLINE , ISB # 1526
MONICA MOEN, ISB # 5734
Idaho Power Company
1221 West Idaho Street
O. Box 70
Boise , Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
HECEIVED 0FILED
2003 ~mv - 7 PM 4: 23
U FUULlC
UTILITIES COf'1MISSION
Attorneys for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR A
CERTIFICATE OF PUBLIC CONVENIENCE
AND NECESSITY FOR THE RATE BASING
OF THE BENNETT MOUNTAIN POWERPLANT.
CASE NO. IPC-03-
IDAHO POWER COMPANY'
FURTHER RESPONSE TO
FIRST PRODUCTION
REQUEST OF COMMISSION
STAFF
COMES NOW Idaho Power Company ("Idaho Power" or "Company ), and
herewith files its further response to the First Production Request of Commission Staff
dated October 10 , 2003. At this time the only Requests remaining unanswered are
Request Nos. 20 and 80. Idaho Power expects to provide those responses next week.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 1
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:
abandonment of the Garnet contract;
addition of the PPL Montana contract;
addition of the Danskin plant;
changes in the load forecast considering economic factors; and
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.
RESPONSE TO REQUEST NO.1: The requested load-resource
balances are attached. However, due to time constraints , the peak-hour analysis was
not extended beyond 2011 (2011 was the last year included in the analysis for the 2002
IRP). The 2002 IRP peak-hour analysis was updated to reflect Idaho Power s current
estimate for the peak-hour surplus or deficiency through 2011. The differences in peak-
hour loads between the load forecast used in the attached analysis and the 2002 IRP
load forecasts are currently under review -- specifically, the increase in forecast June
peak-hour loads. A summary of the assumptions used in the monthly energy and peak-
hour load-resource balances is included for reference.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 2
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?
RESPONSE TO REQUEST NO.2: Idaho Power s determination that it
needs energy and capacity primarily during the heavy load hours of June , July, August
November and December is based on the analysis performed in developing the 2000
and 2002 IRP's. The IRP's and the Technical Appendices for those IRP's contain the
analysis and are on file at the Commission. As noted in the 2002 IRP , Idaho Power
planned to meet this need with a Power Purchase Agreement (PPA) with Garnet Energy
LLP. The Garnet PPA was to provide up to 250 MW of energy and capacity during
heavy load hours for June, July, August and December, as well as the option of
purchasing additional energy and capacity during non-contract periods beginning in
June 2005. The Garnet PPA was included in the 2002 IRP , beginning in June of 2005
with deliveries during June , July, August and December. In addition to the Garnet PPA
the 2002 IRP's Near-Term Action Plan called for an additional peaking resource of
approximately 100 MW beginning in 2005 , as well as continued seasonal market
purchases of 100 average MW in June, July, November and December throughout the
planning period.
Cancellation of the Garnet PPA left a need of up to 250 MW of capacity
and energy to be replaced during June, July, August and December. By considering
the deficit left by removal of the Garnet PPA along with the projected market purchases
during June , July, November and December, Idaho Power concluded that the RFP
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 3
should target June, July, August, November and December. The 2002 IRP emphasized
th percentile water and 70th percentile load planning criteria.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 4
REQUEST NO.3: Please provide a copy of load-resource balance data
by month for each of the years 2005-2015 for the following conditions:
Energy analysis 50% water, 50% load
Energy analysis 70% water, 70% load
Energy analysis 90% water, 70% load
Peak hour analysis 50% water, 50% load
Peak hour analysis 70% water, 70% load
Peak hour analysis 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.
RESPONSE TO REQUEST NO.3: See Response to Request No.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 5
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
RESPONSE TO REQUEST NO.4: The requested critical peak analysis
is attached. However, due to time constraints , the peak-hour analysis was not extended
beyond 2011 (2011 was the last year included in the analysis for the 2002 IRP). Idaho
Power has assumed that the critical peak analysis requested corresponds to the
Monthly Peak-Hour Northwest Transmission Deficit shown in Figures 8 , 9, 10 and 17 in
the 2002 IRP. The forecast monthly peak-hour Northwest transmission deficits were
updated , however, it is difficult to interpret the results without further discussion of the
limitations of this analysis.
Monthly peak-hour Northwest transmission deficits were calculated in the
2002 IRP. If a transmission deficit existed during a given month , Idaho Power
Transmission Planning Group provided the IRP team with the magnitude of the deficit.
If there was not a transmission deficit during the peak-hour of a given month , consistent
with FERC non-disclosure requirements , the Transmission Planning Group did not
provide the IRP team the remaining available import capacity from the Northwest during
the peak-hour -- we just knew that we were not deficit. Recent peak-hour forecasts
show an increase in peak-hour loads during months that did not have a peak-hour
transmission deficit from the Northwest in the 2002 IRP. Until the peak-hour and the
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 6
peak-hour Northwest transmission deficit analyses are rerun in the 2004 IRP, we are
unsure whether we have a peak-hour Northwest transmission deficit during those
months. The net result is that several of the deficits identified in this production request
should be reduced or completely eliminated upon further analysis.
For example , look at the attached spreadsheet showing the results for
May 2004 in the 70% water, 70% load case. In the 2002 IRP we did not forecast a
transmission deficit during this month. However, the updated load forecast shows an
increase in peak-hour loads of 119 MW. If necessary, Danskin can supply 86
leaving a remaining deficit of 33 MW. As long as at least 33 MW of transmission
capacity is available from the Northwest, then we would not predict the deficit.
However, until the peak-hour Northwest transmission deficit analysis is rerun in
preparation of the 2004 IRP , we are unsure of this deficit.
As noted in the Response to Request No., the differences in peak-hour
loads between the current and the 2002 IRP load forecasts are currently under review --
specifically, the increase in forecast June peak-hour loads. This, combined with the
need to rerun the peak-hour Northwest transmission deficit, will most likely result in
changes to the results to the forecast peak-hour Northwest transmission deficit. The
2004 I RP will address these issues in detail. A summary of the assumptions used in the
critical peak analysis is included for reference.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 7
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.
RESPONSE TO REQUEST NO.5: Idaho Power expects that meeting its
peak hour deficits under 70th percentile and worse water conditions coupled with high
peak hour loads will present the greatest challenge. This issue will be addressed in
greater detail in the 2004 IRP. In summary, between finding a replacement for the
Garnet PPA (250 MW) and adding the 100 MW peaking resource identified in the 2002
IRP , Idaho Power needs to add at least 350 MW of capacity or firm wholesale
purchases during July 2005. So far, Idaho Power has secured an 83 MW purchase
from PPL Montana purchase which will result in 80 MW delivered to Idaho Power
system and 75 MW of firm transmission rights (on PacifiCorp s system) from Red Butte
to Borah/Brady. The Bennett Mountain Power Plant provides an additional 162 MW for
a total of 317 MW (162+83+75) of generation capacity, purchases, and firm
transmission rights available during July 2005. Idaho Power still needs to secure an
additional 33 MW of firm capacity during July to meet the needs outlined in the 2002
IRP. Additionally, to preserve sufficient capacity benefit margin and transmission
reliability margin on its transmission system during peak periods in the near term , Idaho
Power will need to add additional peaking resources , or reduce peak hour loads , as
these transmission margins were utilized during the summer of 2003 to serve native
load.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 8
Even with the addition of Bennett Mountain Power Plant , peak hour
deficiencies will continue to be experienced during June, July, August, November and
December. Please see the Response to Request No.1 for additional information on
projected peak hour and energy deficits. As noted earlier, the 2004 IRP will address this
issue in greater detail.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 9
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:
Total book investment
Variable O&M
O&M escalation factor
Fixed O&M
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.
RESPONSE TO REQUEST NO. 17: The requested material is available
in the discovery room and may be reviewed in accordance with the procedure described
in Response No.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 1
REQUEST NO. 29: Please provide a copy of any contracts/agreements
signed by Idaho Power to secure fuel storage and transportation rights (Le.
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?
RESPONSE TO REQUEST NO. 29: Idaho Power has not entered into
any contracts/agreements to secure fuel storage and/or transportation rights specifically
for the Bennett Mountain Power Plant. See Responses to Request Nos. 31 and 35.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen, attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 11
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.
RESPONSE TO REQUEST NO. 30: Idaho Power has not negotiated or
entered into any agreements for the purchase of natural gas fuel supplies for the
Bennett Mountain Power Plant. See Response to Request No. 31.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen, attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 12
REQUEST NO. 31: Please describe the fuel procurement strategy Idaho
Power intends to employ for the Bennett Mountain plant. Discuss the following:
term of likely agreements;
quantity of fuel to be purchased on the spot market; and
hedging strategies.
RESPONSE TO REQUEST NO. 31: At this point, it is premature to
discuss the term of any agreements, quantity of fuel to be purchased on the spot market
or specific hedging strategies associated with a specific fuel procurement strategy for
the Bennett Mountain Power Plant. In general , the approach Idaho Power intends to
pursue is as follows: (1) sourcing fuel from several geographic areas , (2) staggering
terms of agreements if multiple agreements are executed, (3) incorporate a mixture of
forward and spot purchases, and (4) utilize a combination of firm and non-firm or
released transportation capacity. Idaho Power is also in the process of analyzing
hedging strategies for both Danskin and Bennett Mountain Power Plants , and plans to
retain an outside consultant to assist us in this analysis.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 13
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.
RESPONSE TO REQUEST NO. 32: The requested information is
available in the discovery room and may be reviewed in accordance with the
procedures described in the Response to Request No.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 14
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?
RESPONSE TO REQUEST NO. 33: Idaho Power does have an Energy
Risk Management Policy and natural gas is listed as a permitted commodity in
Appendix E of the policy, however, the policy does not specifically address acquisition
of natural gas. Our current practice is to discuss longer-term forward gas transactions
(such as purchasing gas for July 2004 now) with the Risk Management Committee
before execution.
Idaho Power does have existing hedging guidelines for the Danskin Power
Plant. A copy of the hedging guidelines is available in the discovery room. Idaho
Power intends to develop its fuel procurement strategy for both natural gas and
transportation capacity as well as expanded hedging guidelines and risk management
strategies for both the Danskin and Bennett Mountain Power Plants. As noted in the
response to Request No. 31 , Idaho Power intends to retain an outside consultant to
assist in developing these strategies.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 15
REQUEST NO. 34: If Idaho 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?
RESPONSE TO REQUEST NO. 34: Idaho Power does not have a gas
transportation agreement specifically identified for the Bennett Mountain Power Plant
and no payments to Williams are required. See the Response to Request No. 35.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 16
REQUEST NO. 35: If Idaho 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?
RESPONSE TO REQUEST NO. 35: Idaho Power has not finalized its
transportation strategy for the Bennett Mountain Power Plant, however, it is likely that
any firm transportation capacity held by Idaho Power will be shared between the
Bennett Mountain and Danskin Power Plants. Given the anticipated sharing of capacity,
Idaho Power believes an allocation is appropriate , however, details of the allocation
have not been developed.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 17
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 to be needed to operate the Bennett Mountain plant?
RESPONSE TO REQUEST NO. 36: For the Bennett Mountain Power
Plant to access Williams Northwest Pipeline , a pipeline of approximately 3,400 feet in
length will need to be constructed. MVP's bid included an 8 inch diameter pipeline
which will have sufficient capacity to supply one 162 MW unit. Idaho Power and MVP
are currently investigating increasing the pipeline size from 8 to 12 or 16 inches in
diameter. Idaho Power will most likely elect to increase the pipeline size to 16 inches in
diameter. A 16 inch diameter line will be sufficient to fuel two 162 MW units and will
also result in a reduced pressure drop (as compared to a 12 inch line) between
Northwest Pipeline and the Bennett Mountain Power Plant.
If Idaho Power elects to increase the pipeline s size to 16 inches in
diameter line, then Idaho Power rather than MVP will be responsible for the additional
cost to increase the pipeline from 8 to 16 inches in diameter. This design change will be
handled through a Change Order under the Idaho Power-MVP Agreement. Idaho
Power will own the pipeline.
If the pipeline is increased to 16 inches in diameter, and only one unit is
constructed, then the pipeline would be oversized. However, Idaho Power considers
the Bennett Mountain site a viable candidate for an additional peaking unit. Considering
Idaho Power s anticipated future resource needs, Idaho Power believes that incurring
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 18
the relatively small incremental cost to increase the pipeline capacity at this time is
prudent.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 19
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?
RESPONSE TO REQUEST NO. 37: The requested information is
enclosed. Idaho Power may opt to out-source the construction of the line to
interconnect the Bennett Mountain Power Plant with the Company s 230-kV system.
Mountain View has submitted a proposal to construct the interconnecting line.
The Response to this Request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 20
REQUEST NO. 40: If the Bennett Mountain plant capacity is expanded in
the future:
will an additional fuel management contract be necessary, and
will there be sufficient fuel storage and transportation rights available
without pipeline capacity expansions?
RESPONSE TO REQUEST NO. 40: If the Bennett Mountain Power Plant
capacity is expanded in the future , it is unlikely that any additional fuel management
contracts would be required. Any fuel management contract that Idaho Power entered
into would, most likely, be structured to cover the plant's full requirements on an
ongoing basis.
While we have not fully investigated the availability of storage rights
sufficient transportation rights to serve the Bennett Mountain Power Plant are available
without a pipeline expansion.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen, attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 21
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.
RESPONSE TO REQUEST NO. 41: The only item in which Idaho Power
anticipates incurring additional costs solely to enable additional generation capacity to
be constructed at the Bennett Mountain site is increasing the size of the pipeline
between the Williams Northwest Pipeline and the Bennett Mountain site.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen, attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 22
REQUEST NO. 45: Please describe any liquidated damages provisions
between Idaho Power and Mountain View.
RESPONSE TO REQUEST NO. 45: The Asset Purchase and Sale
Agreement between Idaho Power and Mountain View Power (Agreement) has been
provided in response to Request No. 37. The Agreement contains liquidated damages
for the following: (1) delay in turbine delivery to the site, (2) delay in achieving
provisional acceptance, (3) failure to achieve guaranteed net capacity and net heat rate.
Please see Article 16 of the Agreement between Idaho Power and
Mountain View for the specific provisions related to liquidated damages for Mountain
View s failure to meet the above-described commitments and milestones.
The Response to this Request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 23
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?
RESPONSE TO REQUEST NO. 46: While there may be occasional
opportunities to market output of the Bennett Mountain plant during the light load hours
of June, July, August, November and December, and during heavy and light load hours
of other months, at present Idaho Power does not anticipate marketing a significant
amount of Bennett Mountain plant output during these periods. As noted in Response
No. 25, the opportunity for sales of surplus energy will depend on the difference
between the market price of power and the Bennett Mountain plant's cost of production.
Idaho Power expects that the Bennett Mountain plant will most likely be started several
times per week, and perhaps as often as daily, to provide output during heavy load
hours. However, the decision to start and stop the plant will depend on current market
conditions , system needs and reliability considerations, and the plant's estimated cost of
production. Idaho Power has not estimated total monthly start costs during the months
it expects to take output from the plant. Our initial estimates have included start costs in
variable O&M costs. These variable O&M costs are available for review in the
discovery room. See Response to Request No. 17.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 24
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 25
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.
RESPONSE TO REQUEST NO 48: There is no water purchase
agreement between the City of Mountain Home and Mountain View Power. Rather, the
water will be purchased at city rates for industrial use. The City s letter of commitment
to supply water, along with a current rate schedule , is attached. Water usage at the
plant is primarily a function of the number of hours the plant operates the evaporative
cooling system. The ambient temperature during those hours and the number of cycles
the water is used also impacts the total water use. MVP has assumed 4 cycles of
concentration, based on 38 mg/I of silica assumed in the water supply. A representation
of water usage at several differing temperatures is as follows:
at 110 F , 40 % RH: Water Usage is 91 gpm;
at 90 F, 40% RH: Water Usage is 67 gpm;
at 59 F, 40% RH: Water Usage is 38 gpm
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, based on information
provided by Mountain View Power.
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FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 26
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.
RESPONSE TO REQUEST NO. 49: There is no sewer discharge
agreement between the City of Mountain Home and Mountain View Power. The City
has constructed a sewer line to serve the Mountain View Industrial Park. The Project
will be connected to the City sewer at rates based on equivalent dwelling units.
Wastewater generated from the plant is primarily a function of the number of hours the
plant operates the evaporative cooling system. The ambient temperature during those
hours and the number of cycles the water is used also impacts total wastewater
generated by the plant. MVP has assumed 4 cycles of concentration, based on 38 mg/I
of silica assumed in the water supply. A representation of wastewater discharge at
several differing temperatures is as follows;
at 110 F , 40 % RH: Discharge of 23 gpm
at 90 F, 40% RH: Discharge of 17 gpm
at 59 F, 40% RH: Discharge of 10 gpm
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, based on information
provided by Mountain View Power.
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FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 27
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 of Idaho
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.
RESPONSE TO REQUEST NO. 50: The requested information is
available in the discovery room and may be reviewed in accordance with the procedure
described in Response No.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen, attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 28
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.
RESPONSE TO REQUEST NO. 54: Officially known as "additional first-
year depreciation allowance , bonus depreciation was made law by the Job Creation
and Worker Assistance Act of 2002. In its most basic form, the new law allows for 30%
of a qualifying asset's basis to be claimed as depreciation in its first year of service
addition to normal tax depreciation on the remaining basis. The intent of the provision is
to induce business investment (i.e. economic stimulus) by accelerating the tax
depreciation deduction and reducing the near-term taxes paid to the government. As it
is intended to be near-term stimulus, the transaction must meet specific placed-
service dates in order to be eligible for the bonus.
On May 28, 2003, the additional first-year depreciation allowance was
expanded and President Bush signed into law the Jobs and Growth Tax Relief and
Reconciliation Act of 2003. Again to induce additional business investment , Congress
revised 9168(k) and created "super bonus depreciation . For assets placed in service after
May 5 2003, the new law allows for 50% of a qualifying asset's basis to be claimed as
depreciation in its first year of service, in addition to normal tax depreciation on the
remaining basis. Placed in service date restrictions , while modified , continue to apply. If
an asset meets the applicable date restrictions , a significant portion of the project costs
would qualify for the 50% first year deduction.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 29
While there are many nuances to the application of ~ 168(k), the following
sections outline the critical points of law applying to federal taxes only. Idaho has not
adopted the 30% bonus depreciation provision and will probably not adopt the 50% bonus
depreciation.
Qualifying Property - in order to be eligible , an asset must:
. Have a tax recovery period of 20 years or less.
. Have its original use commence after May 5 , 2003.
. Be acquired after May 5, 2003 and before January 1 , 2005 or be
acquired pursuant to a binding written contract after May 5, 2003.
Self-Constructed Property - assets constructed by a taxpayer meet
the acquisition rules discussed in point number one.
Placed-In Service Date - a qualifying asset must be placed in
service by January 1 ,2005. If the asset meets the longer production period tests in
~ 168(k), it can be placed in service no later than January 1 , 2006 and still qualify for the
50% bonus.
Longer Production Period - if an asset has a recovery period of at
least 10 years , is subject to uniform capitalization, and has a production period exceeding
two years or a production period exceeding one year and a cost exceeding $1 million , then
it can qualify for bonus depreciation if placed in service by January 1 , 2006.
Qualifying Costs - the bonus only applies to an asset's basis
attributable to costs incurred by December 31 ,2004. Spending during 2005 would be
eligible for the normal tax depreciation deduction rules.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 30
It is unlikely that the construction schedule will allow 100% of the plant
equipment to qualify for bonus depreciation. The liquidated damages provision described
in Section 16.2 of the Asset Purchase Agreement between Idaho Power and MVP is
specifically intended to provide a strong incentive for Siemans and MVP to accelerate the
manufacture and delivery of the largest portion of the plant equipment in an ongoing
course of construction to maximize the qualification of assets for bonus depreciation. A
copy of the Asset Purchase Agreement is furnished in Response to Request No. 37.
The Response to this Request was prepared by Bruce E. MacMahon
Corporate Tax Director, Idaho Power Company, in consultation with Barton L. Kline
attorney for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 31
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 AIFUDC 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-
RESPONSE TO REQUEST NO. 55: There are no special and/or
separate financing arrangements for the construction of the Bennett Mountain plant.
IPCo will finance the plant's construction through its normal corporate financing
process. An estimate and analysis of AFUDC is available in the discovery room and
may be reviewed in accordance with the procedures described in Response No.
The Response to this Request was prepared by Catie Miller, Finance
Team Leader, Idaho Power Company, in consultation with Barton L. Kline , attorney for
Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 32
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.
RESPONSE TO REQUEST NO. 57: Idaho Power is not aware of any
market products that are capable of providing Idaho Power s system with capacity and
energy comparable, or nearly comparable, to the 162 MW of internal generation
provided by the Bennett Mountain plant during its first five years of operation. Several
alternatives to replace the Garnet PPA were identified in the Garnet Report. These
alternatives included firm wholesale purchases delivered to the east side of Idaho
Power s system , and a firm wholesale purchase or exchange involving an existing
resource located in Idaho Power s control area. While each alternative is possible
neither is directly comparable to 162 MW of dispatchable internal generation.
Idaho Power s ranking of these alternatives is as follows: Firm wholesale
purchases would be the least desirable because they use an increment of Idaho
Power's import capacity that, since it is being used for a purchase , would be unavailable
in the event of a system emergency. Firm wholesale purchases or an exchange
involving an existing resource located inside Idaho Power s control area would be the
next most desirable because import capacity is still available for emergencies.
Depending on contract terms , Idaho Power s ability to dispatch the existing resource
would , most likely, be limited. Finally, a dispatchable resource such as Bennett
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 33
Mountain , strategically located inside Idaho Power s Control Area, is the most desirable
for three reasons (1) the reliability benefits associated with having another generator on-
line inside the control area, and (2) preservation of import capacity for system
emergencies, and (3) the operational flexibility associated with a dispatchable unit.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 34
REQUEST NO. 58: Please provide a summary of the average price
during each of the months since January 2003 of the Mid-C forward prices for the period
2005-20 10 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.
RESPONSE TO REQUEST NO. 58: The requested information is
available in the discovery room and may be reviewed in accordance with the
procedures established in the Response to Request No.6. The requested summary
averages the individual monthly prices from a series of Idaho Power s forward price
curve s over the 2005 through 2010 time period. These prices are representative of
prices for firm energy at Mid-C with liquidated damages for non-performance. Typically,
these products are sold under the Western Systems Power Pool (WSPP) Agreement
Service Schedule C - Firm Capacity/Energy Sale or Exchange Service.
The supplied pricing summary is derived from market information and
broker quotes for monthly, quarterly and yearly products. If these products were
available inside the Idaho Power Control Area and were capable of being delivered to
the Boise area, then they are reasonably comparable to Idaho Power s stated needs in
the 2002 I RP. The problem is that a sufficient quantity of these products are not
available inside Idaho Power s Control Area , and if they were available at Idaho Power
border, internal transmission constraints could prevent them from being delivered to the
Boise area. This is why the 2003 RFP specified the product as a generating resource
located inside the Idaho Power Company control area.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 35
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 36
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.
RESPONSE TO REQUEST NO. 59: Please see the response to Request
No. 58. This is Idaho Power s current forward price curve.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 37
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.
RESPONSE TO REQUEST NO. 62: Idaho Power has contracted with
Quantum Consulting to perform a Peak Load Reduction Assessment within our service
territory. The purpose of this study is to identify potential peak reduction opportunities
within the residential and commercial customer classes. The study is scheduled to be
completed December 3, 2003. At this time the Company does not have any reports
studies , or analyses of potential load management programs.
The rate design proposal included as part of the Company s general rate
case, Case No. IPC-03-, filed on October 16 , 2003 has as one of its main
objectives providing customers price signals that reflect the variation in the costs of
providing service during different times of the year and day. In order to implement this
objective, the Company s filing includes the proposal to establish seasonal pricing for all
residential , commercial , and industrial customers and to establish time-of-use pricing in
addition to seasonal pricing for all industrial customers. Under the Company
proposal, prices for energy and demand will be higher during the three summer months
of June , July, and August and additionally for industrial customers during the peak
hours of the day. Details on the proposed rate design can be found at pages 25
through 67 of the direct testimony of Maggie Brilz filed in Case No. I PC-03-13.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 38
The Response to this Request was prepared by Maggie Brilz , Pricing
Director, Idaho Power Company, in consultation with Barton L. Kline and Monica B.
Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 39
REQUEST NO. 63: Please provide data showing the monthly generation
of the Danskin plant from plant completion through the present.
RESPONSE TO REQUEST NO. 63: Monthly generation of the Danskin
plant from completion through the September 2003 is as follows:
Danskin Combustion Turbine
Gross Generation - MWh
Aug-
Sep-
Oct-
Nov-
Dec-
Jan-
Feb-
Mar-
Apr-
May-
Jun-
Jul-
Aug-
Sep-
Oct-
Nov-
Dec-
Jan-
Feb-
Mar-
Apr-
May-
Jun-
Jul-
Aug-
Sep-
344
185
048
601
902
2,411
164
048
1 ,439
789
19,097
136
917
260
500
789
693
244
080
629
696
666
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 40
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.
RESPONSE TO REQUEST NO. 64: Once the Bennett Mountain plant
becomes operational it is likely that it will dispatch before the Danskin plant given the
difference in heat rate, or efficiency, between the two plants. At 90 degrees Fahrenheit
Danskin s heat rate is approximately 900 Btu/kWh while Bennett Mountain s heat
rate is approximately 10 600 Btu/kWh. For example, using a hypothetical natural gas
price of $4.00/MMBtu, the fuel cost per MWh generated by Danskin is $47.60/MWh
while the fuel cost for power generated by Bennett Mountain is $42.40/MWh - a savings
of over $5/MWh. Ultimately, the operation of each plant will depend on numerous
factors including power prices , system needs, transmission constraints, unit availability
and variable O&M costs.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 41
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.
RESPONSE TO REQUEST NO. 65: The requested information is in the
discovery room and may be reviewed in accordance with the procedures set forth in the
Response to Request No.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 42
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 plant? If so, please explain why those alternatives were rejected and
provide a copy of any analysis completed by Idaho Power justifying this decision.
RESPONSE TO REQUEST NO. 66: See Response to Request No. 65. In
addition , converting Danskin to a combined cycle plant was considered as one of the
Idaho location resources identified in the 2002 Integrated Resource Plan. While
converting Danskin to a combined cycle plant certainly improves plant efficiency, the
conversion only adds 39 MW of capacity at a cost of $1559/kW. Considering Idaho
Power s peaking need , and the cost of combustion turbines at the time the RFP was
being developed , converting Danskin to a combined cycle was not an economic
alternative. Adding a 501 FD unit at the Danskin plant was the alternative
recommended in the self-build proposal. The evaluation of the self-build proposal is
provided in response to Request No. 11.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 43
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.
RESPONSE TO REQUEST NO. 67: As Mr. Said noted in his testimony in
this case , the capital cost of Danskin as of the time construction was completed was
approximately $49 million. As of 9/30/03 , the capital cost for the Danskin Power Plant
was $49.9 million. The commitment cost estimate for the Danskin Power Plant was
$55.2 million.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen, attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 44
REQUEST NO. 69: Please discuss the status of Idaho 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.
RESPONSE TO REQUEST NO. 69: Idaho Power is currently
constructing the Brownlee-Oxbow #2 230 kV line. It is expected to be in service for the
summer of 2004. The June 2002 IRP contemplated completion of the project in the fall
of 2004 , however, environmental construction limitations forced the in-service date into
a summertime period. Idaho Power chose to advance the construction period slightly to
place the facility in-service for the summer of 2004 to address some of the energy
deficiencies showing in the 2002 I RP for the summer of 2004.
Idaho Power still plans to proceed with the Shoshone Falls upgrade
project identified in the 2002 IRP. At present, Idaho Power is awaiting a new FERC
license for the Shoshone Falls Power Plant. Rather than modifying the currently
pending license application, Idaho Power intends to wait until the new license is issued
before proceeding with permitting for the Shoshone Falls upgrade. Idaho Power
expected to receive the new license in late 2002; however, the new license is yet to be
issued. If the new license is received in the next month or so, then a 2007 in service
date for the upgrade is still possible. If receipt of the license continues to be delayed
the Shoshone Falls upgrade will most likely be delayed until 2008 or later.
The Response to this Request was prepared by Ronald D. Schellberg,
System Planning Leader and Karl Bokenkamp, Power Supply Planning Manager, Idaho
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 45
Power Company, in consultation with Barton L. Kline and Monica B. Moen, attorneys for
Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 46
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?
RESPONSE TO REQUEST NO. 70: At present, Idaho Power has no firm
plans to issue additional RFP's during the next five years. Idaho Power is currently in
the process of preparing the 2004 Integrated Resource Plan , which will be filed with the
IPUC in June 2004. The 2004 IRP will investigate both the magnitude and timing of
Idaho Power s future resources needs and may recommend issuance of additional
RFP's. While Idaho Power has no firm plans at present to issue additional RFP's during
the next five years, RFP's for wind generation , DSM , and additional peaking resources
have been discussed as well as the need for future base-load resources. These
alternatives will be considered in the 2004 I RP.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 47
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.
RESPONSE TO REQUEST NO. 75: No, Mountain View does not intend
to maintain the capability to utilize a secondary source of fuel. The Application For
Permit To Construct An Air Pollution Emitting Facility submitted by Mountain View to the
Idaho Department of Environmental Quality identifies the Bennett Mountain Power Plant
as a natural gas fueled plant with no secondary fuel.
The Response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning, Idaho Power Company, in consultation with Barton L.
Kline and Monica B. Moen , attorneys for Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 48
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.
RESPONSE TO REQUEST NO. 76: A copy of Mountain View Power
Inc.'s Articles of Incorporation are attached. As Mountain View is a corporation and not
an LLC or partnership, it does not have any partners. Mountain View has five
shareholders, who are: Robert D. Looper, Ronald L. Williams, Thomas Cameron
Randy Schroder and Douglas D. Wilner. This information was provided to Idaho Power
by Mountain View Power.
The Response to this Request was prepared by Barton L. Kline , Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 49
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.
RESPONSE TO REQUEST NO. 79: Please see the attached material
provided by Mountain View Power to Idaho Power.
The Response to this Request was prepared by Barton L. Kline, Senior
Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 50
DATED at Boise , Idaho, this 7th day of November, 2003.~l~
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S FURTHER RESPONSE TO
FIRST PRODUCTION REQUEST OF COMMISSION STAFF Page 51
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of November, 2003 , I served a
true and correct copy of the within and foregoing IDAHO POWER COMPANY'S
FURTHER RESPONSE FIRST PRODUCTION REQUEST OF COMMISSION STAFF
upon the following named parties by the method indicated below, and addressed to the
following:
Donald L. Howell , II
Deputy Attorney General
Idaho Public Utilities Commission
P. O. Box 83720
Boise, Idaho 83720-0074
Hand Delivered
S. Mail
Overnight Mail
FAX
Peter J. Richardson
Richardson & O'Leary
O. Box 1849
Eagle, Idaho 83616
Hand Delivered
S. Mail
Overnight Mail
FAX
Eric L. Olsen
Racine, Olson , Nye, Budge & Bailey
O. Box 1391
Pocatello , Idaho 83204-1391
Hand Delivered
S. Mail
Overnight Mail
FAX
CERTIFICATE OF SERVICE