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Home My WebLink About200406071st Request of IPC to Complainants.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 iH... 1... t:' ,...,'.. . . -'........., ?f!l'Ifi . f"-J ,. 14 ,. "'JV'1 vUPi -If. ..: riD F'UHI if' UTILITiES COrfr1iSSlON Attorney for Idaho Power Company Street Address for Express Mail 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION BOB LEWANDOWSKI and MARK SCHROEDER IDAHO POWER COMPANY, an Idaho corporation CASE NO. IPC-04- Complainants vs. FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO BOB LEWANDOWSKI AND MARK SCHROEDER Respondent. COMES NOW , Idaho Power Company, by and through its attorneys of record , and hereby requests that Bob Lewandowski and Mark Schroeder Lewandowski and Schroeder") 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 Lewandowski and Schroeder are requested to provide, by way of supplementary FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO BOB LEWANDOWSKI AND MARK SCHROEDER Page responses, additional documents or information that it or any person(s) acting on its behalf may later obtain 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 Agreements Lewandowski and Schroeder seek 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. (c)Expected capacity factor. REQUEST NO.2: Do Lewandowski and Schroeder 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 turbine generator that will be used to generate electric energy to be delivered to Idaho Power under the Firm Energy Sales Agreements Lewandowski and Schroeder seek to obtain as a result of this complaint proceeding. If possible, the map should be to scale with the scale explicitly stated. FIRST PRODUCTION REQUEST OF IDAHO POWER COMPANY TO BOB LEWANDOWSKI AND MARK SCHROEDER Page 2 REQUEST NO.4: Please provide a drawing showing how the 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 or any other entity. REQUEST NO.5: Do either Lewandowski or Schroeder expect that energy deliveries from their respective Facilities (as the term "Facility" is defined in Exhibit A to the Complaint) will ever exceed 10 000 kWh's per hour? If so, please identify the months, days within the months, and hours within the days when either Lewandowski or Schroeder expects their 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 such energy deliveries would exceed 10 000 kWh's per hour. REQUEST NO.6: What is the expected capacity factor of each of the Lewandowski and Schroeder Facilities (as the term "Facility" is defined in Exhibit A to your Complaint)? REQUEST NO.7: Will either the Lewandowski Facility or the Schroeder Facility operate as a flat, around-the-clock, base load generation resource or will they run as intermittent generation resources? 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 BOB LEWANDOWSKI AND MARK SCHROEDER 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 LEWANDOWSKI AND SCHROEDER 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 , Idaho 83701-2720 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 Scott Woodbury Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Street O. Box 83720 Boise, Idaho 83720-0074 Hand Delivered S. Mail Overnight Mail FAX BARTON L. KLINE ----- CERTIFICATE OF SERVICE