20060620ICIP to IPC 1-19.pdf

(Q;~s.(!l\1Nf & (i)J~'ATTORNEYS AT LAW
Peter Richardson oJ ,. i,",. J
Tel: [phone] Fax: [phone]
peter~ richardso nando\eary.co m
O. Box 7218 Boise, ID 83707 - 515 N. 27th St. Boise, ID 83702
19 June 2006
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
POBox 83720
Boise 10 83720-0074
RE: Case No.lPC-O6-
Dear Ms. Jewell:
Enclosed please find three (3) copies of the FIRST PRODUCTION
REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO
POWER COMPANY in the above case. The original request has been sent to
Idaho Power Company.
Sincerely,~i,
Administrative Assistant
encl.
Peter J. Richardson
RICHARDSON & O'LEARY PLLC
515 N.
tb Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peterCfYrichardsonando1eary .com
- ,,;:~; ;: -: .' '~' :
Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
CERTIFICATE OF CONVENIENCE AND
NECESSITY FOR THE EV ANDER ANDREWSPOWER PLANT
CASE NO. IPC-06-
FIRST PRODUCTION
REQUEST OF THE
INDUSTRIAL CUSTOMERS
OF IDAHO POWER TO IDAHO
POWER COMPANY
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission ), the Industrial Customers of Idaho Power (ICIP) , by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho
Power ) provide the following documents.
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 xting
on its behalf may later obtain that will augment the documents produced.
Please provide one copy of your answer to Mr. Richardson at the address noted above and
one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. Please provide Dr. Reading
copy in electronic format, if available.
1 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
For each item, please indicate the name of the person(s) preparing the answers, along with
the job title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO.
On page 10 of Greg Said's direct testimony he states:
Among the actions recommended by the 2004 IRP was the acquisition of a
targeted 88 MW simple-cycle, natural gas-fired combustion turbine. Consistent
with the recommendations of the 2004IRP, the peaking resource RFP requested
proposals for an 80 MW 200 MW turnkey electric generation resources located
within the Company s service territory that would meet anticipated peak energy
demands. The flexibility in plant capacity permitted under the RFP allowed the
developers to respond to the RFP with their most cost-effective proposals.
Please explain in greater detail how the "flexibility in plant capacity" in the RFP is
consistent with the Company s 2004 IRP. Please explain why a simple-cycle resource of nearly
twice the size of the 88 MW facility stated in the Near-Term Action Plan is consistent with the
IRP.
REQUEST FOR PRODUCTION NO.
On page 10 of Greg Said's direct testimony he states:
The RFP directed respondents to locate the proposed facility at either the Company
Evander Andrews Power Complex or the Bennett Mountain Power Plant site or at a site of a
respondent's choosing.
Please explain why the specific sites of Bennett Mountain and Evander Andrews were
specified in the RFP. In the evaluation process were these two sites given preference over other
sites? If yes, please explain how and why.
REQUESTFOR PRODUCTION NO.
On page 15 of Greg Said's direct testimony he states:
Forecasted natural gas prices from the 2004 IRP were used in the bid
evaluation. Forecasted natural gas prices have gone up substantially since the
2 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
issuance of the 2004 IRP, but the same price forecast was utilized in the
evaluation of all of the natural gas-fired project proposals and, as a result
projects with lower guaranteed heat rates had lower fuel costs on a dollar per
megawatt basis.
Since natUi:11 gas prices have "gone up substantially" from those found in the 2004 IRP
was any consideration given by the Company as to the type of unit included in the RFP? Please
fully explain.
REQUEST FOR PRODUCTION NO.
On page 20 of Greg Said's direct testimony he states: However, when consideration of
the non-price attributes of the bids were included, the Siemens proposal received the best
combined price and non-price score.Please explain in detail all of the "non-price attributes
that were considered by the Company in the evaluation process. Please indicate the weight given
each of the "non-price attributes" in the evaluation process.
REQUEST FOR PRODUCTION NO.
Were any of the non-price attributes given more weight in the evaluation process than
other non-price attributes? If so, please fully explain.
REQUEST FOR PRODUCTION NO.
Please provide the results of final cost model run performed for the selected Siemens unit.
Results provided should include (A) Load factor and/or the hours the unit is expected to be on
line; (B) The times ofthe year when the unit is expected to be on line; (C) Variable costs
associated with the unit's operation; (D) Full kwh costs ofthe unit; (E) Input assumptions used in
the cost model runs such as carrying costs, fuel costs, depreciation rates, M&O costs, etc.
REQUEST FOR PRODUCTION NO.
3 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
In "Response ofIdaho Power Company to Filed Comments" in Docket No. IPC-04-
Idaho Power s 2004 IRP docket, Idaho Power stated:
New generating resource additions in the Pacific Northwest are expected
utilize coal, natural gas, or possibly wind, since no new large hydro-power
projects are anticipated. If new natural gas-fired projects are to be built to serve
loads in southwest Idaho, there are two obvious options; build or acquire
additional natural gas pipeline capacity from the Pacific Northwest to southwest
Idaho and locate the generator near the load in southwest Idaho, or locate the
generator near the existing natural gas pipelines in the Pacific Northwest,
acquire pipeline capacity and then build additional electric transmission line
capacity to southwest Idaho. Studies indicate that over the lifetime of the
lJro;ects. it is less expensive to build the natural f!as pipeline capacity and locate
the f!enerator at the load
Page 6 , underscoring added.
Please provide copies of the referenced studies, including all Aurora model runs, etc.
supporting that statement.
REQUEST FOR PRODUCTION NO.
In the same "Response ofIdaho Power Company to Filed Comments" at page 5 , Idaho
Power stated:
Finally, the ability to fund DSM programs at levels indicated by the IRP is an
ongoing concern. While Idaho Power believes that an increase in the DSM Tariff
Rider is an appropriate mechanism for recovery of program costs, ongoing
funding for these DSM program costs is unresolved at this time.
Please detail what steps Idaho Power has taken to resolve its "ongoing concern" relative
to "the ability to fund DSM programs at levels indicated by the IRP" since it filed its Response in
December 2004?
REQUEST FOR PRODUCTION NO.
4 - FIRST PRODUCTION REQUEST OF TCIP TO IDAHO POWER
Reference the same passage ofthe "Response" quoted in No.8 above. Please explain
what is meant by the phrase "ongoing funding for these DSM program costs is unresolved at this
time" and detail (quantify) the impact the unresolved ongoing funding has had on Idaho Power
DSM programs.
REQUEST FOR PRODUCTION NO.1 0
Please provide an organizational chart indicating all of the personnel at Idaho Power who
are responsible for creating and implementing DSM programs as of January 1 2004; January 1
2005; and January 1 2006; please include the individual's name , job description and job title.
REQUEST FOR PRODUCTION NO.
Please reconcile Mr. Said's direct testimony at page 10 to the effect that the selected
winning proposal to construct a 170 MW simple cycle is "consistent" with the IRP of "a targeted
88 MW simple cycle
REQUEST FOR PRODUCTION NO. 12
Please explain why PURP A generation additions occur outside of the IRP process.
REQUEST FOR PRODUCTION NO. 13
In response to a question at the bottom of page 13 of his direct testimony about the
decision to delay the peaking project by one year, Mr. Said states that "the Company evaluated
the most prudent use of its resources and determined that other short-term alternatives other than
this project could meet the projected peak energy needs for the summer of 2007." Please provide
copies of the reverenced evaluation(s) and determination(s). Include any work papers, studies
AURORA model runs and economic evaluations.
REQUEST FOR PRODUCTION NO. 14.
5 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
When and by whom was the determination referenced in No. 13 above made? Please
provide all available documentation relative to said determination, including notes, memoranda
and correspondence.
REQUEST FOR PRODUCTION NO. 15
On page 14 of his direct testimony, Mr. Said refers to an additional 50 megawatts of
market purchases and associated transmission. Please provide details of these transactions
including counter party(ies), price, transmission path, cost of power and cost of transmission.
Please provide copies of all relevant documentation, including contracts, agreements, term sheets
etc.
REQUEST FOR PRODUCTION NO. 16
Please provide documentation supporting the 22,8 million dollar figure referenced on the
top of page 19 of Mr. Said's testimony.
REQUEST FOR PRODUCTION NO. 17
Please provide copies of all transmission studies, whether definitive or preliminary,
related to the proposed project.
REQUEST FOR PRODUCTION NO. 18
Should the Commission deny Idaho Power s request for a certificate of public
convenience and necessity, what supply or demand reduction alternative options would the
Company turn to in the summer of 20077
REQUEST FOR PRODUCTION NO. ,
What is the retail rate impact of Mr. Said's request at page 20 for the Commission to
approve inclusion of the total project investment in the Company s rate base for ratemaking
purposes? Assume for purposes of answering this question that the total project investment
6 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
includes 60 million dollars for the generating plant and 22.8 million dollars for associated
transmission and substation improvements. Please provide supporting work papers.
DATED this 19th day of June 2006.
RICHARDSON & O'LEARY PLLC
By: .:;/t)
Peter J. Richardson, ISB #3195
Attorneys for the Industrial Customers
of Idaho Power
7 - FIRST PRODUCTION REQUEST OF ICIP TO IDAHO POWER
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 19th day of June, 2006, I caused a true and
correct copy of the foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER to be served by the method indicated below, and
addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 West Washington Street (83702)
Post Office Box 83720
Boise, Idaho 83720-0074
(X) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( )
Overnight Mail
( ) Facsimile
( ) Electronic Mail
Barton L. Kline
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, Idaho 83707
bklineCfYidahopower. com
mmoen~idahopower.com
( ) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( ) Facsimile
(X) Electronic Mail
Donovan Walker
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
Donovan. walkerCfYpuc. idaho. gov
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( ) Facsimile
(X) Electronic Mail
James C. Miller
Sr. Vice President, Generation
Idaho Power Company
1221 W. Idaho St. (83702)
PO Box 70
Boise, Idaho 83707
i immiller~idahopower .com
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( ) Hand Delivered
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( ) Facsimile
(X) Electronic Mail
CERTIFICATE OF SERVICE - 1
-- ==-
Ronald L. Williams
Williams Bradbury, P.
PO Box 2128
Boise, ID 83701
ronCfYwilliams bradburv . com
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( ) Hand Delivered
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(X) Electronic Mail
Robert D. Looper
President
Mountain View Power, Inc.
1015 W Hays Street
Boise, ID 83702
rlooperCfYspellc.com
( ) U.S. Mail, Postage Prepaid
( ) Hand Delivered
( ) Overnight Mail
( )
Facsimile
(X) Electronic Mail
Signed ~(\C\ Q..u\
Nina M. Curtis
CERTIFICATE OF SERVICE - 2