200506291st Exergy request to IPC.pdf

Peter J. Richardson ISB 3195
RICHARDSON & O'LEARY PLLC
515 N. 2ih St (83702)
PO Box 7218 (83707)
Boise, Idaho 8370-
Telephone: [phone]
Fax: [phone]
peter(fYrichrdsonando leary. com
Attorneys for Exergy Development Group of Idaho LLC
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN ORDER)
TEMPORARILY SUSPENDING IDAHO
POWER'S PURPA OBLIGATION TO ENTERINTO CONTRACTS TO PURCHASE
ENERGY GENERATED BY WIND-
POWERED SMALL POWER PRODUCTIONFACILITIES
CASE NO. IPC-005-
FIRST REQUEST FOR WRITTEN
INTERROGATORIES AND REQUEST
FOR PRODUCTION OF
DOCUMENTS OF EXERGY
DEVELOPMENT GROUP OF IDAHO
LLC TO ID AH 0 POWER
COMES NOW Exergy Development Group of Idaho LLC by and through its attorney
of record, Peter J. Richardson, and pursuant to Rules 221 - 229 of the Rules of Procedure issued
by the Idaho Public Utilities Commission ("Commission ) and hereby lodges its First Request
for Written Interrogatories and Request for Production of Documents to Idaho Power.
This production request is to be considered as continuing, and Idaho Power 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
FIRST PRODUCTION REQUEST OF EXERGY
DEVELOPMENT GROUP OF IDAHO-
person(s) and the witness at hearing who can sponsor the answer at hearing. When the "Petition
is referred to herein, it is a reference to the Petition Idaho Power filed on June 24, 2005 , that
initiated this Docket No. IPC-05-22.
Request for Production of Documents No.1: Please provide all workpapers and other
supporting documents used in the preparation of Attachment 1 to the Petition.
Interrogatory No.1: Please identify the individual or individuals who prepared or
assisted in the preparation of Attachment
Request for Production of Documents No.2: Please provide all workpapers and other
supporting documents used to support the statement that "Idaho power has received contacts
from developers to pursue new QF projects with a nameplate capacity of 267.5 MW including
193 MW of new wind-powered projects." For each project please provide a copy of its QF
certification and any other documentation that may be used do identify said project.
Interrogatory No.2: When was the decision to file the Petition made?
Interrogatory No.3: Identify all individuals who are not employed by Idaho Power
Company who had knowledge that the Petition or similar filing was going to be made prior to
June 17, 2005 at 2:44 p.
Request for Production of Documents No.3: Please provide all supporting documents
and workpapers used to support the statement in the Petition at pages 5-6 that "Idaho Power has
recently reviewed the bid responses received in the 2005 RFP. The bids received, on average
propose purchase rates of approximately $55.00 per MWh"
Request for Production of Documents No.4: Please provide all documents and
workpapers relied upon to support the belief, stated at the top of page 6 of the Petition that
, "
the
FIRST PRODUCTION REQUEST OF EX~RGY
DEVELOPMENT GROUP OF IDAHO- 2
bids the Company has received in the 2005 RFP are not reflective of the market prices for wind
generation
" .
Request for Production of Documents No.5: Please provide all documents and
workpapers relied upon to support the assertion at the top of page 6 of the Petition that
, "
the bids
the Company has received. . . are being unduly influenced by the current published avoided cost
rates. "
Request for Production of Documents No.6: Please provide copies of all of the "recent
announcements by other regional utilities of power purchase agreements with wind resource
developers with substantially lower pricing structures" that are referenced at the top of page 6 of
the Petition.
Request for Production of Documents No.7: Please provide copies of all material in the
Company s possession dealing with the Judith Gap agreement referenced at the top of page 6 of
the Petition. For those documents on file and publicly available please only provide a reference
to said publicly available documents and identify the public body from which said documents
may be obtained.
Interrogatory No.4: Please quantify, in terms of dollars per MWh, all of the tax
incentives offered or provided to the developer of Judith Gap by any state, local, municipal, or
other non-federal taxing entity including any income, sales, use, and/or property taxes as well as
any incentives or relaxation of any state, local, municipal licensing and/or regulatory fees.
Interrogatory No.5: What is the capacity factor of the Judith Gap wind facility?
Interrogatory No.6: Please state, in terms of dollars per MWh, the interconnection costs
associated with the Judith Gap wind facility.
FIRST PRODUCTION REQUEST OF EXERGY
DEVELOPMENT GROUP OF IDAHO- 3
Interrogatory No.7: Please identify all individuals, not employees of Idaho Power, who
have been consulted with respect to the Judith Gap agreement referenced at the top of page 6 of
the Petition.
Interrogatory No. 8: Please explain why "In light of the large number ofMWs ofQF
wind resources already acquired and proposed and the high bid prices received in the 2005 RFP"
Idaho Power will "be required to reduce the amount of wind generation acquired through the
2005 RFP." Petition page 6, center paragraph.
Interrogatory No.9: How many MW of wind-generation were bid to Idaho Power in
response to its 2005 RFP?
Interrogatory No.1 0: Please describe the process yet to be completed in the 2005 RFP
for example, is there a short list? How many MW are on the short list? Have the "unsuccessful
bidders" reference at the top of page 7 of the Petition been notified of their status? How many
unsuccessful bidders are there?; How many MW did the unsuccessful bidders bid into the 2005
RFP?
Request for Production of Documents No.8: Please provide all workpapers and
supporting documents to support and quantify the phrase "at above-market prices" as it is used in
the first paragraph on page 7 of the Petition.
Interrogatory No. 11: Please list each of the "ancillary services" referenced toward the
bottom of page 7 of the Petition.
Interrogatory No. 12: For each ancillary service listed in response to Interrogatory No.
please describe its function in assuring "system reliability" and its cost in terms of dollars per
MWh.
FIRST PRODUCTION REQUEST OF EXERGY
DEVELOPMENT GROUP OF IDAHO- 4
Request for Production No.9: Please provide all workpapers and documentation relied
upon in responding to Interrogatory No. 12.
Request for Production No. 10: Please provide a copy of the analysis referred to at the
bottom of page 7 of the Petition relative to the cost and risks associated with a resource portfolio
consisting of 1 000 MW of wind. Please include all workpapers and documents used to prepare
said analysis and the names of the authors of said analysis.
Interrogatory No. 13: Please identify all "third-party consultant(sJ" Idaho Power has
contacted with respect to conducting the "thorough analysis" referenced in the second paragraph
on page 8 of the Petition. If the answer is none, please identify such "third-party" consultants
Idaho Power has identified who are qualified to conduct such an analysis.
Interrogatory No. 14: In light of the fact that the Commission did not temporarily
suspend new QF wind projects at its decision meeting on June , 2005, what is Idaho Power
position relative to signing new wind contracts at this time?
InterrogatoryNo. 15: Please identify the source of the statement at the top of page 10 of
the Petition that "municipalities and co-ops remain unwilling to purchase QF resources
Request for Production No. 15: Please provide copies of all documents referred to or
relied upon in your answer to Interrogatory No. 11.
DATED this 29th day of June 2005.RICHARDSON & O'LEA
Peter J. Rich Qson
Attorneys for Exergy Development Group
FIRST PRODUCTION REQUEST OF EXERGY
DEVELOPMENT GROUP OF IDAHO- 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this day, June 29, 2005 , I caused a true and correct
copy of the foregoing FIRST PRODUCTION REQUEST OF EXERGY DEVELOPMENT
GROUP OF IDAHO LLC TO IDAHO POWER COMPANY to be served by the method
indicated below, and addressed to the following:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise 1083720-0074
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Barton L. Kline
Idaho Power Company
PO Box 70
Boise ID 83707-0070
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John R Gale
Idaho Power Company
PO Box 70
Boise ID 83707-0070 .
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Monica Moen
Idaho Power Company
PO Box 70
Boise ID 83707-0070
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Scott Woodbury
Idaho Public Utilities Commission
424 W Washington Street
Boise ID 83702
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EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE -
Richard L. Storro
Director, Power Supply
1411 E Mission Ave
PO Box 3727 MSC-
Spokane WA 99201
R. Blair Strong
Paine, Hamblen, Coffin, Brooke & Miller LLP
717 West Sprague Avenue Ste 1200
Spokane WA 99201-3505
EXERGY DEVELOPMENT GROUP, LLC
CERTIFICATE OF SERVICE - 2
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Signed: J'f\. ~-'h
Nina M. Curtis