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