20050714IP Objection 1st Exergy.pdf

BARTON L. KLINE, ISB # 1526
MONICA B. MOEN , ISB # 5734
Idaho Power Company
1221 West Idaho Street
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]FAX: [phone]
E-mail: BKline
(g)
idahopower.com
MMoen
(g)
idahopower.com
Attorneys for Idaho Power Company
€EIYED 0. -
lUOSJUl 14 PH ~:48
T .. IDAi~fO PUBLICILlTtES COrfHtsslON
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MA TIER OF THE PETITION OF
IDAHO POWER COMPANY FOR AN
ORDER TEMPORARilY SUSPENDING
IDAHO POWER'S PURPA OBLIGATION
TO ENTER INTO CONTRACTS TO
PURCHASE ENERGY GENERATED BY
WIND-POWERED SMALL POWER
PRODUCTION FACiliTIES.
CASE NO. IPC-05-
IDAHO POWER COMPANY'
OBJECTIONS TO CERTAIN
REQUESTS PROPOUNDED IN THE
FIRST REQUEST FOR WRITTEN
INTERROGATORIES AND
REQUEST FOR PRODUCTION OF
DOCUMENTS OF EXERGY
DEVELOPMENT GROUP OF IDAHO
LlC TO IDAHO POWER
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and , in accordance with IPUC Rule 225.03, herewith respectfully objects to certain
requests for responses to written interrogatories and production of documents propounded
by Exergy Development Group of Idaho LLC to Idaho Power on or about June 30 2005.
Submission of this objection is not intended as a refusal to respond to the
remaining requests for written interrogatories and production of documents propounded by
Exergy Development Group of Idaho LLC for which the Company has no objections.
IDAHO POWER COMPANY'S OBJECTIONS TO CERTAIN REQUESTS PROPOUNDED IN THE FIRST
REQUEST FOR WRITTEN INTERROGATORIES AND REQUEST FOR PRODUCTION OF
DOCUMENTS OF EXERGY DEVELOPMENT GROUP OF IDAHO LLC TO IDAHO POWER Page
Idaho Power intends to respond to those requests in accordance with the provisions of
IPUC Rule 225.03.
Idaho Power objects to providing responses to the following written
interrogatories and production of documents on the basis that the information sought is
either protected by a duly authorized confidentiality agreement between Idaho Power
Company and certain third parties who have submitted responses to Idaho Power
Request for Proposals , issued on January 13, 2005, for up to 200 MW of wind-powered
electrical generation as identified in Idaho Power s 2004 Integrated Resource Plan or
protected by confidential inquiries from potential qualifying small power production facilities
(QFs) concerning potential QFdevelopment:
Bgguest for Production of Documents No.Please provide all
workpapers and other supporting documents used to support the statement that "Idaho
(P)ower 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.
Bgguest for Production of Documents No.: Please provide all supporting
documents and workpapers used to support the statement in the Petition at pages 5-
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
MW h.
Interroqatorv No.How many MW of wind-generation were bid to Idaho
Power in response to its 2005 RFP?
IDAHO POWER COMPANY'S OBJECTIONS TO CERTAIN REQUESTS PROPOUNDED IN THE FIRST
REQUEST FOR WRITTEN INTERROGATORIES AND REQUEST FOR PRODUCTION OF
DOCUMENTS OF EXERGY DEVELOPMENT GROUP OF IDAHO LLC TO IDAHO POWER Page 2
Interroqatorv 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(d) 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?
DATED: This 14th day of July 2005.
IB.
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S OBJECTIONS TO CERTAIN REQUESTS PROPOUNDED IN THE FIRST
REQUEST FOR WRITTEN INTERROGATORIES AND REQUEST FOR PRODUCTION OF
DOCUMENTS OF EXERGY DEVELOPMENT GROUP OF IDAHO LLC TO IDAHO POWER Page 3
CERTIFICA TE OF SERVICE
HEREBY CERTIFY that on this 14h day of July 2005 , I served a true and
correct copy of IDAHO POWER COMPANY'S OBJECTIONS TO CERTAIN REQUESTS
PROPOUNDED IN THE FIRST REQUEST FOR WRITTEN INTERROGATORIES AND
REQUEST FOR PRODUCTION OF DOCUMENTS OF EXERGY DEVELOPMENT GROUP
OF IDAHO LLC TO IDAHO POWER on the following named parties by the method indicated
below, and addressed to the following:
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ID 83720-0074
Peter J. Richardson
Richardson & O'Leary PLLC
515 N. 27th Street
O. Box 7218
Boise, ID 83707
e-mail: peter(g)richardsonandoleary.com
Mr. James T. Carkuli
Exergy Development Group of Idaho LLC
1424 Dodge A venue
O. Box 5212
Helena, MT 59604
Richard L. StOff
Director, Power Supply
A vista Corporation
1411 E. Mission Avenue
O. Box 3727 , MSC-
Spokane, W A 99220-3727
R. Blair Strong
Paine, Hamblen, Coffin , Brooke & Miller
717West Sprague Avenue, Suite 1200
Spokane, W A 99201-3505
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(f;.
MONICA B. MOEN