200606161stStaff to MVP 1-7.pdf

DONOV AN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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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
MOUNTAIN VIEW POWER
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record
Donovan E. Walker, Deputy Attorney General, requests that Mountain View Power (Mountain
View) 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 Mountain View 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 person(s) and the witness who can sponsor the answer at hearing.
FIRST PRODUCTION REQUEST TO
MOUNTAIN VIEW POWER JUNE 16 2006
REQUEST NO.1: In its petition to intervene, Mountain View Power (MVP) states that
it has reason to believe that it may have submitted the lowest cost bid to Idaho Power to
construct the identical Siemens Westinghouse power plant for Idaho Power at the Boise City
Gateway Industrial Park site (Gateway plant). Please explain the basis for this belief and provide
any supporting evidence.
REQUEST NO.2: In its petition to intervene, MVP states that it believes the non-price
scoring attributes in the Idaho Power bid process may have been inappropriately biased against
MVP. Please explain the basis for this belief and provide any supporting evidence.
REQUEST NO.3: IfMVP believes that its Gateway project bid is superior to the other
bids received and considered by Idaho Power, please provide evidence, analysis, and support for
this belief.
REQUEST NO.4: Please describe any transmission system additions or improvements
including cost, which would be needed to interconnect the Gateway plant into Idaho Power
existing system.
REQUEST NO.5: Please provide copies of any permits Mountain View 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.6: Will any of the permits MVP has obtained or will obtain restrict the
operation of the proposed Gateway plant? If so, please describe the timing, duration and nature
of such restrictions.
FIRST PRODUCTION REQUEST TO
MOUNTAIN VIEW POWER JUNE 16 , 2006
REQUEST NO.7: Please provide a copy of all correspondence between MVP and
Idaho Power concerning bids MVP made in response to the RFP.
DATED at Boise, Idaho, this I&rf. day of June 2006.
onovan E. Walker
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqlipceO6.09dwrps mvpl
FIRST PRODUCTION REQUEST TO
MOUNTAIN VIEW POWER JUNE 16, 2006
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF JUNE 2006
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO MOUNTAIN VIEW POWER 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 BRAD BURY PC
PO BOX 2128
BOISE ID 83701
ROBERT D LOOPER
PRESIDENT
MOUNTAIN VIEW POWER INC
1015 WHAYS ST
BOISE ID 83702
Jo
f1h0- SECRETARY
CERTIFICATE OF SERVICE