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Home My WebLink About200406071st Request of ID Power to Geothermal.pdfBARTON l. KLINE ISB #1526 MONICA B. MOEN ISB #5734 Idaho Power Company O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 FAX Telephone: (208) 388-6936 RECEIVED illFlLED lOU~ JUN -4 PM ~: 02 10 i-10 PUBLiC UTILITIES COHrllSSl0N Attorney for Idaho Power Company Street Address for Express Mail 1221 West Idaho Street Boise , Idaho 83702 BEFORE THE IDAHO PUBLIC UTiliTIES COMMISSION S. GEOTHERMAL, INC. Respondent. CASE NO. IPC-04-Complainant vs. IDAHO POWER COMPANY FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO S. GEOTHERMAL, INC. COMES NOW , Idaho Power Company, by and through its attorneys of record , and hereby requests that U.S. Geothermal , Inc. ("S. Geothermal") provide the following documents and information as soon as possible , but no later than June 25 2004. This production request is to be considered as continuing, and U. Geothermal is requested to provide, by way of supplementary responses , additional documents or information that it or any person(s) acting on its behalf may later obtain FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO U.S. GEOTHERMAL Page that will augment the documents or information produced. For each item , please indicate the name of the persons preparing the answer, along with the job title of such persons , and the witness who can sponsor the answer at hearing. REQUEST NO.1: Please provide the following for each turbine generator that will be used to generate electric energy to be delivered to Idaho Power under the Firm Energy Sales Agreement U.S. Geothermal seeks to obtain from Idaho Power as a result of this complaint proceeding: (a) (b) The manufacturer s nameplate capacity rating in KW. Documentation showing how the manufacturer s nameplate rating is computed. REQUEST NO.2: Does U.S. Geothermal intend to deliver any electric energy generated by any of the turbine generators identified in Request No.1 to any entity other than Idaho Power? If the answer is yes, please identify the prospective recipients , the amounts which may be delivered to these recipients and the reason for such deliveries. REQUEST NO.3: Please provide a map showing the location of each well and turbine generator that will be used to generate electric energy to be delivered to Idaho Power under the Firm Energy Sales Agreement U.S. Geothermal seeks to obtain as a result of this complaint. The map should be to scale with the scale explicitly stated. REQUEST NO.4: Please provide a drawing showing how the wells and turbine-generators shown on the map provided in response to Request No.3 will be interconnected to deliver energy to the electrical systems of Idaho Power, BPA and Raft FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO U.S. GEOTHERMAL Page 2 River Rural Electric Co-op. REQUEST NO.5: Please identify the months, days within the months and hours within the days when U.S. Geothermal expects its energy deliveries to Idaho Power will exceed 10,000 kWh's per hour. For each month , day and hour identified please specify the amounts by which U.S. Geothermal expects its energy deliveries to exceed 10,000 kWh's per hour. REQUEST NO.6: What is the expected capacity factor of the Facility (as that term is defined in Exhibit A to your Complaint)? REQUEST NO.7: During maintenance outages or at other times when the Facility s energy loads exceed the Facility s total generation , does U.S. Geothermal expect to purchase back-up, supplemental or any other type of power from Raft River Rural Electric Co-op or from any other entities? If so, please provide the best available estimate of the amounts and timing of such purchases. REQUEST NO.8: Based upon the fuel source and the technology being used by the Facility, will the Facility operate as a flat, around-the-clock, base load generation resource or will it run as an intermittent generation resource? DATED at Boise , Idaho , this 4th day of June, 2004. BARTON L. KLINE Attorney for Idaho Power Company FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO U.S. GEOTHERMAL Page 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 4th day of June , 2004, I served a true and correct copy of the within and foregoing FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO U.S. GEOTHERMAL upon the following named parties by the method indicated below, and addressed to the following: Conley E. Ward Givens Pursley LLP 601 W. Bannock Street O. Box 2720 Boise, I D 83701-2720 Hand Delivered S. Mail Overnight Mail FAX Daniel Kunz, President S. Geothermal , Inc. 1509 Tyrell Lane , Suite B Boise , I D 83706 Hand Delivered S. Mail Overnight Mail FAX Peter J. Richardson Richardson & O'Leary PLLC 99 East State Street, Suite 200 O. Box 1849 Eagle , Idaho 83616 Hand Delivered S. Mail Overnight Mail FAX GM tY--:- BARTON L. KLINE CERTIFICATE OF SERVICE