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HomeMy WebLinkAbout20060616Staff to IPC 1-75.pdfDONOV AN E. WALKER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 5921 '., ' ;?5 ,,- i, i_,) iJ,. ,. ii, ),, Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY FOR THE RATE BASING OF THE EV ANDER ANDREWS POWER PLANT. CASE NO. IPC-06- FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Donovan E. Walker, Deputy Attorney General, requests that Idaho Power Company (Company; IPC) provide the following documents and information as soon as possible, but no later than WEDNESDAY, JULY 12, 2006 or sooner if possible. This Production Request is to be considered as continuing, and Idaho Power Company 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 person(s) and the witness who can sponsor the answer at hearing. For purposes of clarification, the "Evander Andrews Plant" as referred to in this request means the new proposed plant that would be constructed at the Evander Andrews site. The existing plant at the Evander Andrews site is referred to as "Danskin. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16 2006 REQUEST NO.1: Please provide a copy ofload-resource balance data by month for each of the years 2006-2026 for the following conditions: Energy analysis 50% water, 50% load Energy analysis 70% water, 70% load Energy analysis 90% water, 70% load Peak hour analysis 50% water, 50% load Peak hour analysis 70% water, 70% load Peak hour analysis 90% water, 70% load Please provide the data under two scenarios: without the addition of Evander Andrews or any other new resources, and with the addition of Evander Andrews. Please provide the data in an Excel format, both graphical and numerical. REQUEST NO.2: Please explain and provide any other supporting documentation showing how the Company concluded that it needs energy and capacity primarily during peak periods for the Treasure Valley load center and that justified issuance of the March 2005 Request for Proposals. What water conditions were assumed in determining these energy and capacity needs? REQUEST NO.3: Please identify and describe any water and load conditions when Idaho Power does not expect to be able to meet its energy or peak hour deficits after the Evander Andrews plant has been constructed, using its own resources and all existing contracts. Explain how Idaho Power plans to meet its energy and peak hour deficits under these conditions. REQUEST NO.4: Please provide a list of representatives of potential bidders who attended the pre-bid meeting on April 21 , 2005. REQUEST NO.5: Please provide a copy of all "Notice oflntent to Bid" forms completed and submitted to Idaho Power by interested bidders in the March 2005 RFP process. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 REQUEST NO.6: Please provide a copy of any evaluations, recommendations, or other correspondence from the independent consultant related to the March 2005 RFP, the RFP evaluation criteria or the review and evaluation of bids. REQUEST NO.7: Please provide copies of all bids received in response to the March 2005 RFP. REQUEST NO.8: Please provide a copy or complete description of all criteria used to evaluate bids received in the RFP, including the Evaluation Manual as discussed on page 12, lines 6 of Greg Said's direct testimony. REQUEST NO.9: Please provide copies of all analysis conducted by the Company in evaluating RFP bids. REQUEST NO. 10: Please provide a summary of the price (including separately the capital cost, transmission and interconnection costs, and plant operating costs) and non-price scores awarded to each of the bids, both in the initial screening and in the evaluation of short-listed bids. REQUEST NO. 11: Please provide analysis demonstrating that the Evander Andrews project was the preferred alternative for meeting Idaho Power s needs. REQUEST NO. 12: Please identify and provide a copy of each bid received that, on its own or in combination with other less than full requirements bids were insufficient to satisfy the need identified in the RFP. Are any ofthese bids still being considered? Does Idaho Power expect to consider any of these bids in the future? If so, please explain. REQUEST NO. 13: Please indicate those bids eliminated in the "short listing" that occurred during September 2005. Please state the reasons why each bid was eliminated. REQUEST NO. 14: Please provide a copy of any firm wholesale electric and natural gas price forecasts used in any of the analysis of bids received in the March 2005 RFP. FIRST PRODUCTION REQUEST TO IDAHO POWER CaMP ANY JUNE 16 2006 REQUEST NO. 15: Please explain why Idaho Power did not prepare a self-build proposal for the March 2005 RFP. REQUEST NO. 16: Please explain how Idaho Power evaluated proposals of different sizes. For example, how were proposals for 80 MW compared to proposals for 200 MW ifldaho Power was targeting 88 MW of peaking generation? REQUEST NO. 17: Please identify the members ofldaho Power s RFP evaluation team. REQUEST NO. 18: Please perform the following computer simulation runs for Idaho Power s system using the AURORA model. Before making any runs, however, review all assumptions for the transmission interconnections to Idaho Power s system, all assumptions for Idaho Power s existing generating plants, power purchase and sales contracts, load shape and any other necessary input assumptions and make any necessary adjustments so that the model corresponds as closely as possible to actual conditions. Insure that the load and fuel price forecasts assumed in the modeling runs are consistent with those ofthe 2006 IRP. It may be desirable to use the AURORA "Portfolio" feature to model Idaho Power for purposes ofthe following analyses. a. Perform an hourly simulation beginning June 1 2007 and extending through December 2032 (running five years beyond the conclusion of the period of interest as recommended by EPIS) under an operating mode in which no new capacity can be added within the Idaho Power system and supply deficiencies are met through power imports from outside Idaho Power s system. Based on the results of this run, identify the number and timing of any hours in which transmission constraints limit the amount of power that can be imported. In addition, identify those transmission interconnections on which constraints occur. Identify the timing and duration of any load curtailment predicted by the model. Report the results in graphical format, including any narrative necessary to interpret the results. b. Perform a long-term optimization (capacity addition) study for the period June 1 , 2007 through December 2032. Use hourly dispatch to fully capture peak load hours. Confirm that the new resource choices available match those identified in the Company s 2006 FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 IRP and that the Evander Andrews project is also available as a choice at the prices and terms assumed in the RFP analysis. Assume also that market purchases are an available option. Based on the results of this run, identify the type, timing and location of new resources added along with the amount of capacity and energy associated with each new resource. Confirm whether the Evander Andrews project is chosen as an alternative to meet load. Summarize the months and the hours within each month when the Evander Andrews plant would be used to meet load. Identify any other resources selected by the model. c. Perform an hourly simulation beginning June 1 2007 and extending through December 2032 assuming that capacity and energy is available in accordance with the Evander Andrews project but at zero cost. Compare the net power supply cost over the duration ofthe simulation to the net power supply cost for the model run conducted in part " above. Compare the difference in net power supply cost to the cost of the Evander Andrews project. REQUEST NO. 19: Please describe any transmission system additions or improvements including cost, which will be needed to interconnect the Evander Andrews plant into Idaho Power existing system. REQUEST NO. 20: Please describe any permits that will be required for transmission system additions or improvements and provide time estimates of when such permits could be obtained. If any permits will be required, what is their status? REQUEST NO. 21: Please describe any transmission system additions or improvements including cost and construction timing, which will be needed between Mountain Home and Boise order to accommodate the Evander Andrews Plant. Are there any improvements being made in the general vicinity of the Evander Andrews plant that Idaho Power would have made whether the Evander Andrews plant was built or not? REQUEST NO. 22: Please describe the transmission constraints that made it desirable or necessary for Idaho Power to specify in the March 2005 RFP that Idaho Power is interested in FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 proposals that can provide electric capacity to the Treasure Valley load center. Provide copies any analysis or transmission system studies in which these constraints were identified and described. REQUEST NO. 23: Please provide cost estimates and a description of the improvements that would be necessary for Idaho Power to relieve transmission constraints into its system such that power could be imported from the market as an alternative to building the Evander Andrews plant. Provide a copy of any studies or analysis that has been completed. REQUEST NO. 24: Please describe in detail any transmission system improvements upgrades or additions that have recently been made or are planned in the general vicinity of the proposed Evander Andrews plant that are not contingent upon or considered a part of the Evander Andrews Plant. Provide a copy of any study or analysis completed that recommended such improvements, additions or upgrades. For any upgrades that have recently been completed, please provide records showing the total costs for the improvements, additions or upgrades. REQUEST NO. 25: Please provide information supporting the transmission costs assumed by Idaho Power for each of the bids considered. Include cost assumptions, transmission losses, and any other transmission factors considered. REQUEST NO. 26: Provide estimates by month for the period June 2007 through December 2027 of the number of hours the Evander Andrews plant will be expected to operate to serve Idaho Power s load. REQUEST NO. 27: Please provide estimates by month for the period June 2007 through December 2027 of the quantity of generation from the Evander Andrews Plant that Idaho Power expects it will not need to meet its own load but will be able to sell off-system. Include estimates of the revenue associated with such sales. REQUEST NO. 28: Please provide a copy of all studies or estimates used to develop the upper limit estimate of$22.8 million to interconnect the project to the Company s transmission FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16 , 2006 system. Has the study (referred to on page 5 of the Application) been completed to define the cost of constructing transmission and substation facilities required to interconnect the project with the Company s transmission system? If so, please provide a copy of the study. If the study has not yet been completed, when is completion expected? REQUEST NO. 29: Please provide a copy of any contracts/agreements signed by Idaho Power to secure fuel storage and transportation rights (i.e. transportation contracts) for the Evander Andrews project. What is the term of the contract(s)? What are the provisions for extending renewing the agreements? For what period of time will fuel transportation and storage be guaranteed? Do the contracts include fuel transportation and storage for either the Danskin or the Bennett Mountain plants? REQUEST NO. 30: Has Idaho Power negotiated any agreements for the purchase of natural gas fuel supplies for the Evander Andrews plant? If so, please provide a copy of all such agreements. REQUEST NO. 31: Please describe the fuel procurement strategy Idaho Power intends to employ for the Evander Andrews plant. Discuss the following: a. term of likely agreements; b. quantity of fuel to be purchased on the spot market; and c. hedging strategies. REQUEST NO. 32: What is Idaho Power s forecast of expected fuel prices for the Evander Andrews plant for the next twenty-year period? Please provide forecasts in both a numerical and a graphical format. REQUEST NO. 33: Does Idaho Power have a risk management policy for acquiring natural gas fuel for any of its existing or planned gas-fired plants? If so, please provide a copy. If not, does the Company expect to develop a risk management policy? FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 REQUEST NO. 34: Ifldaho Power has a gas transportation agreement for the Evander Andrews plant, does it require payments to Williams Pipeline or others before the Evander Andrews facility is constructed and operational? REQUEST NO. 35: If Idaho Power uses the same gas transportation and storage contract for the Evander Andrews plant as for some other Idaho Power facilities (Danskin, Bennett Mountain, for example), how will costs for gas transportation and storage be allocated to the various projects? REQUEST NO. 36: For the proposed Evander Andrews plant a. will an additional fuel management contract be necessary, and b. will there be sufficient fuel storage and transportation rights available without pipeline capacity expansions? REQUEST NO. 37: Please provide a copy of any and all agreements between Idaho Power and Siemens Power Generation, Inc. including the Engineering, Procurement and Construction agreement. Does Idaho Power anticipate any additional agreements with Siemens in the future for the Evander Andrews plant? REQUEST NO. 38: Please describe any liquidated damages provisions between Idaho Power and Siemens Power Generation, Inc. REQUEST NO. 39: If the Evander Andrews Plant is constructed, will there be any potential for additional future expansion at the site? If so, are there any costs of the Evander Andrews project that will be incurred solely to enable additional capacity should it eventually be built at the Evander Andrews site, e., permitting, land acquisition, pipelines, pipeline capacity, fuel handling or storage, transmission, substations, interconnection, maintenance buildings or equipment, roads, site improvements, etc. REQUEST NO. 40: Are existing permits for the Evander Andrews site sufficient to permit construction of the new proposed Evander Andrews plant? If so, please provide a copy of each FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 permit. If not, what additional permits or amendments to existing permits would have to be obtained? REQUEST NO. 41: Please describe and discuss any air quality attainment issues and/or operating restrictions currently in place at the Evander Andrews site. If any attainment issues and/or operating restrictions currently exist, how will they affect the proposed new plant at Evander Andrews? REQUEST NO. 42: Please provide copies of any new permits Idaho Power has obtained with local, state or federal air, water, solid waste or land management agencies. Please also summarize the status of all other permits that have not yet been obtained but that will eventually be necessary for construction and operation of the plant. REQUEST NO. 43: Please describe and provide support for any assumptions made with regard to air quality attainment issues and/or operating restrictions for any of the project sites proposed by bidders. REQUEST NO. 44: Please describe and quantify all solid and liquid wastes that will be produced by the plant. Explain how these wastes will be treated or disposed of. Will any additional on-site treatment facilities be necessary? REQUEST NO. 45: Please individually list and quantify each ofthose expected or potential project costs representing the difference between the $49.999 million Siemens contract amount and the $60 million commitment estimate, e., sales taxes, AFUDC on progress payments made during construction, the cost of Idaho Power oversight of the project, the cost of capitalized start-up fuel and any other costs. Where appropriate, show how the amounts have been computed and list any assumptions used to compute the amounts. REQUEST NO. 46: Please explain why Idaho Power is not including transmission and substation costs in its commitment estimate. How and when is Idaho Power proposing to recover transmission and substation costs? FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16 2006 REQUEST NO. 47: Please explain why the estimated transmission costs for the Evander Andrews plant are expected to be approximately double the transmission costs for the Bennett Mountain project when the locations of the two plants are only a few miles apart. REQUEST NO. 48: Will there be any tax benefits related to construction of the Evander Andrews plant? If so, please describe. REQUEST NO. 49: Please describe any contractual (market) products that may be available that could provide capacity and energy comparable, or nearly comparable, to that which would be provided in the first five years of the Evander Andrews plant. Please provide the current price for these products and identify the source from which the prices have been obtained. Please discuss how the Evander Andrews plant would be different, better, or worse than such products. REQUEST NO. 50: Please provide a summary of the average price during each of the months since January 2006 of the Mid-C forward prices for the period 2006-2010 for firm heavy load hour products. Please describe the product(s) for which the prices are representative and discuss how they differ from Idaho Power s stated needs in its March 2005 RFP. REQUEST NO. 51: What is Idaho Power s current forecast of expected firm wholesale electric energy prices for the next five and ten-year periods for heavy and light load hours? Please identify the source and date on which the forecasts were made. REQUEST NO. 52: Please discuss any demand-side management (DSM) alternatives considered as a means of minimizing or replacing the need for new generation from the Evander Andrews plant. What action has Idaho Power taken to attempt to identify, quantify and price DSM alternatives? REQUEST NO. 53: Please provide complete program descriptions ofldaho Power s DSM programs. Discuss the status of these programs including participation levels, funding FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 commitments and future expansion plans. Describe how these programs reduce any of the peak load that would otherwise have to be satisfied using the proposed Evander Andrews plant. REQUEST NO. 54: Has Idaho Power considered any additional load management programs, rate designs or other strategies that could reduce the Company s peak load during those months and hours when the Evander Andrews plant is expected to operate? If so, does the Company have any specific plans to introduce such programs? Please provide copies of any reports, studies or analysis of any load management programs considered. REQUEST NO. 55: Has the Company implemented all of the DSM programs that have been identified as cost-effective in previous IRPs or studies ofDSM potential? Ifnot, please list and describe each of the programs that have not been implemented and explain why they have yet to be implemented. What are the potential energy and capacity savings estimates associated with each of these programs? REQUEST NO. 56: Please provide data showing the monthly generation of the Danskin plant from plant completion through the present. REQUEST NO. 57: Please discuss how the operation of the Danskin plant will change once the Evander Andrews plant becomes operational. Please provide numerical data showing the monthly difference in the amount of expected generation from the Danskin plant with and without the Evander Andrews plant. REQUEST NO. 58: Did Idaho Power consider converting the Danskin plant to combined cycle as an alternative to the Evander Andrews plant? If so, please explain why that alternative was rejected and provide a copy of any analysis completed by Idaho Power justifying this decision. REQUEST NO. 59: Please provide a copy of any analysis showing the costs associated with converting and operating the Danskin project as a combined cycle plant. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16 2006 REQUEST NO. 60: Please provide a complete description of any actual or proposed energy or capacity sales to any other parties from the Evander Andrews plant. If no sales agreements have yet been made, does Idaho Power expect to make them in the future? REQUEST NO. 61: Please discuss the status ofldaho Power s plans to upgrade the Borah- West transmission path. Was an upgraded Borah-West transmission path assumed to be available in the evaluation of RFP bids? Were transmission cost estimates for proj ects east of the Treasure Valley area less in the March 2005 RPF than in previous thermal RFPs due to an assumed upgraded Borah-West transmission path? REQUEST NO. 62: Please discuss any plans Idaho Power has to issue additional RFPs in the next five years. What would be the timing of the RFPs and what type and size of resource would the Company be seeking? REQUEST NO. 63: Please provide an update on the status of the 2006 wind and geothermal RFPs. REQUEST NO. 64: Please provide all plans ofldaho Power relating to financing construction of the Evander Andrews plant. Please describe how construction ofthe Evander Andrews plant will be financed. Include a summary of the payment schedule Idaho Power will follow. Also include an estimate of AFUDC and the analysis supporting the statement "Such financing by the Company allows for a lower total cost to customers than if Siemens were to finance the Project in a different manner." Said direct testimony, page 20, lines 1-4. Please provide copies of any financing agreements. REQUEST NO. 65: Does any financing arrangement ofldaho Power depend on the acceptance of the Idaho Public Utilities Commission s (IPUC) approval of Idaho Power Application to rate base the plant? If so, provide a copy of the pertinent document. REQUEST NO. 66: If the IPUC does not approve Idaho Power s Application to rate base the plant, will Idaho Power continue with the construction of the Evander Andrews plant? FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 REQUEST NO. 67: Does Idaho Power intend for the plant to have the capability to utilize a secondary source of fuel? If so , what is the status of those plans? Have any agreements been negotiated for either the supply of secondary fuel, its storage or its transport? If so, please provide a copy of those agreements. REQUEST NO. 68: Please provide an update on the status of the negotiation with the cogenerator referred to on page 6, lines 17-20 of Greg Said's direct testimony. How much capacity and energy does Idaho Power expect will be made available if the contract with the cogenerator is executed? If the contract is executed, how will it change Idaho Power s load resource balance and need for power? REQUEST NO. 69: Please discuss the status ofldaho Power s plans to upgrade the Shoshone Falls project to be in service in 2007. REQUEST NO. 70: Please provide copies of the minutes of all Idaho Power Board of Directors meetings at which the Evander Andrews Plant or any bids received in the 2005 RFP were discussed. REQUEST NO. 71: Has the Idaho Power Board of Directors authorized expenditure of funds for construction of the Evander Andrews Plant? REQUEST NO. 72: Please elaborate on the highlighted portion of the following statement from page 17, lines2-6 of Said's direct testimony: "Although the transmission system will require additional investment in order to integrate the Project those improvements will provide capacity during all seasons and improve reliability of the Company s transmission system." Quantify, if possible, seasonal increases in transmission capacity and improvements in reliability. REQUEST NO. 73: Please quantify the anticipated economies of centralizing operations and using the present staff at the Evander Andrews site to operate the new plant. Please describe and quantify any other operational benefits of locating the plant at the Evander Andrews site near FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 the existing Danskin and Bennett Mountain plants. Please compare the operational costs of the Evander Andrews site to the sites contained in other bids. REQUEST NO. 74: Please describe any additional costs Idaho Power expects it will incur as a result of delaying completion of the project from June 1 2007 until April 1 , 2008. REQUEST NO. 75: For all intervenor requests, please provide the confidential responses to Staff even if the Company is unable to provide the information to that party. DATED at Boise, Idaho, this !b1I1day of June 2006. Donovan E. Walker Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreq/ipceO6.9dwrps ipcl FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 16, 2006 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF JUNE 2006 SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-06- BY MAILING A COpy THEREOF POSTAGE PREPAID, TO THE FOLLOWING: BARTON L KLINE MONICA MOEN IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 JAMES C MILLER SR. VICE PRESIDENT, GENERATION IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 PETER J RICHARDSON RICHARDSON & O'LEARY 515 N 27TH ST PO BOX 7218 BOISE ID 83702 DR DON READING 6070 HILL ROAD BOISE ID 83703 RONALD L WILLIAMS WILLIAMS BRADBURY PC PO BOX 2128 BOISE ID 83701 ROBERT D LOOPER PRESIDENT MOUNTAIN VIEW POWER INC 1015 W HAYS ST BOISE ID 83702 -11fSECRET CERTIFICATE OF SERVICE