200406251st Response of Lewandowski to IPC.pdf

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PH 3:
Peter J. Richardson
ISB No. 3195
Richardson & O'leary
99 East State Street, Suite 200
O. Box 1849
Eagle, Idaho 83616
Telephone: [phone]
Fax: [phone]
peter~ richa rd sona ndolea ry. com
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U flLiTiES C i~1i';iJ SSl0N
Attorney for Bob Lewandowski and Mark Schroeder
BEFORE THE
IDAHO PUBLIC UTiliTIES COMMISSION
BOB lEW ANDOWSKI AND MARK
SCHROEDER
Complainants
CASE NO. IPC-04-08/10
ANSWER TO THE FIRST
PRODUCTION REQUEST OF
IDAHO POWER COMPANY TO
BOB LEWANDOWSKI
vs.
IDAHO POWER COMPANY, an Idaho
corporation
Respondent.
The following answers were prepared by Bob Lewandowski in consultation with
legal counsel.
BOB LEW ANOOWSKI'S ANSWER TO IPCo FIRST PRODUCTION REQUEST
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.
RESPONSE: (a)08 kw
(b)These machines have been out of production for many years and
have been refurbished. Therefore documentation is not available.
The motor generator nameplate on the generator itself specifies
that it is a 108 kw machine Micon 108. It uses a stall regulated
blade that is designed to go into a stall about 108 kw.
(c)Fifteen to twenty-five percent.
BOB LEWANDOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
REQUEST NO.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.
RESPONSE:
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
REQUEST NO.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.
RESPONSE:See attached.
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
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.
RESPONSE: Idaho Power Company employee John Barrutia has that in his
possession. 388-2222
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
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
Complain) 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.
RESPONSE: No.
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
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)?
RESPONSE: Fifteen to twenty five percent.
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
REQUEST NO.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 resourced?
RESPONSE: As the wind blows. In the future , hydrogen leveling and capacity
increase may be considered as a future enhancement, but it is not part of this
complaint.
BOB LEWANDOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24th day of June, 2004, I caused a true and
correct copy of the foregoing ANSWER TO THE FIRST PRODUCTION REQUEST OF
IDAHO POWER COMPANY TO BOB LEWANDOWSKI to be served by the method
indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise, Idaho 83720-0074
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( )
Electronic Mail
Monica B. Moen, Attorney II
Barton L. Kline, Seniior Attorney
Idaho Power Company
PO Box 70
Boise, ID 83707-0070
bkline~idahopower. com
mmoen~idahopower.com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
PO Box 83720
Boise, ID 83720-0074
swoodbu~puc.state.id. us
( ) U.S. Mail, Postage Prepaid
(X) Hand Delivered
( )
Overnight Mail
( )
Facsimile
( )
Electronic Mail
John Prescott
Vice-President - Power Supply
Idaho Power Company
Post Office Box 70
Boise, Idaho 83707-0070
jprescott~idahopower. com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Conley E. Ward
Givens Pursley LLP
601 West Bannock
Po Box 2720
Boise, Idaho 83701-2720
cew~gi venspurslev. com
(X) U.S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST
Daniel Kunz, President
S, Geothennal
1509 Tyrell Lane, Suite B
Boise, Idaho 83706
(X) V,S, Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
( )
Electronic Mail
Dr, Don Reading
6070 Hill Road
Boise, ill 83703
dreading~mindsprin~. com
(X) V,S. Mail, Postage Prepaid
( )
Hand Delivered
( )
Overnight Mail
( )
Facsimile
(X) Electronic Mail
Signed Ct-v\
Nina Curtis
BOB LEW ANOOWSKI'S ANSWER TO IPCo S FIRST PRODUCTION REQUEST