The URL can be used to link to this page

Home My WebLink About20060621MVP to IPC 1-16.pdf- J Ronald L. Williams ISB 3034 Williams Bradbury, P. PO Box 2128 Boise, Idaho 83701-2128 Telephone: (208) 344-6633 Telecopier: (208) 344-0077 :? i O. )' i'; - _ ;:i'i,_~L'i,:j:~:!J Attorney for Mountain View Power, Inc. 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 ANDREWS POWER PLANT CASE NO. IPC-06- FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER,INc. TO IDAHO POWER COMPANY Mountain View Power, Inc., (MVP) by and through its attorney of record, Ronald L. Williams, requests that Idaho Power Company (Company or IPCo) respond to the following questions and provide the documents as described below. This production request is to be considered as continuing for the duration of this case. REQUEST NO.Please provide an excerpt of the ranking sheet or evaluation matrix of the price (including separately the capital cost, transmission and interconnection costs and plant operating costs) and non-price scores awarded both in the initial screening and in the evaluation of the short listed bids for the following (note: please provide only the summary, matrix or rankings of the three bids listed below and not the analysis, internal memorandum or the evaluation manual used by the Company to derive the rankings): First Request for Production of Documents from MVP to IPCo - The Siemens proposal to construct a new Siemens Westinghouse 170 MW SGT6-5000F simple cycle turbine with ultra-dry low NOx combustion system and with balance of plant at the Evander Andrews site with an on-line date of2008. The MVP proposal to construct a new Siemens Westinghouse 170 MW SGT6- 5000F simple cycle turbine with ultra-dry low NOx combustion system and with balance of plant at the Boise City Gateway Industrial Park (Gateway) site with an on-line date of2008. The MVP proposal to construct a new Siemens Westinghouse 170 MW SGT6- 5000F simple cycle turbine with ultra-dry low NOx combustion system and with balance of plant at the Middleton site owned by Ida-West Energy with an on-line date of2008. REQUEST NO.Please provide the interconnection and transmission requests submitted by the Company s bid evaluation team (the Company) to Idaho Power Delivery Services (IPDS), and the interconnection and transmission studies and estimated costs/prices provided by IPDS to the Company in response to such requests for the following: The Siemens proposal to construct a new Siemens Westinghouse 170 MW turbine at the Evander Andrews site with on-line dates of2007 and 2008. The MVP proposal to construct a new Siemens Westinghouse 170 MW turbine at the Gateway site with an on-line dates of2007 and 20088. The MVP proposal to construct a new Siemens Westinghouse 170 MW turbine at the Middleton site 0 with an on-line date of2007 and 2008. REQUEST NO.Please provide a copy of the Company s response to Staff Requests No. 19,28,, and 72 concerning the Company s electrical transmission system. First Request for Production of Documents from MVP to IPCo - REQUEST NO 4.Please provide information supporting the transmission costs assumed by Idaho Power for the Evander Andrews, Gateway and Middleton sites. Include costs assumptions transmission losses and any other transmission factors considered. REQUEST NO.Please provide a copy of the Company s response to Staff Request No. 26 as to the expected hours of operation of the Evander Andrews Plant. REQUEST NO 6.Please provide all documentation, including but not limited to Elmore County permits, conditional use applications, zoning ordinances or comprehensive plans that support the statement by Company witness Greg Said that "the Company will not be required to seek approval of a conditional use permit in order to construct the new facility. REQUEST NO. 7.Please provide all documents, memorandum or analysis dated on or before January 9, 2006 supporting the statement by Company Witness Greg Said that "Local approval and acceptance of the Project at the Evander Andrews site is more likely since combustion turbines are a permitted use in this Elmore County location." With respect to the phrase underline above, what comparative ' project, situation or example does the phrase "more likely" refer to? REQUEST NO.Please provide a copy of the following documents related to the original permitting of the two 45 MW generators at the Danskin/Evander Andrews site by Elmore County Planning and Zoning Commission and the Elmore County Commission: Hearing records, records of decision, finding of facts and conclusions. Written testimony, transcripts of oral testimony and briefs of all participants in that Elmore County permitting processes. REQUEST NO.Please provide all documents dated on or before January 9, 2006 evidencing communication between the Company and Elmore County and the City of Mountain Home concerning the Company s intent to add the new Siemens 170 MW generation facility at the First Request for Production of Documents from MVP to IPCo - Evander Andrews site to the two 45 MW generating facilities. Please describe any public meetings held in Mountain Home or Elmore County concerning the Company s soliciting public comment on the possibility of expanding the Evander Andrews site to include the new 170 MW of generation, and provide copies of notices of all such meetings and sign-in sheets. REQUEST NO. 10. Please provide copies of all correspondence (written, electronic or otherwise) from the Company to the Idaho Department of Environmental Quality (IDEQ) concerning MVP's minor source air permit application filed January 31, 2006 with respect to MVP's proposed Gateway power plant. REQUEST NO. 11. Please provide a copy of all correspondence, memorandum or materials transmitted between the Company and IDEQ and all permits issued by IDEQ concerning the two 45MW existing Danskin generating units. Please also provide a copy of the Company s response to Staff Request No. 41 concerning this similar request. REQUEST NO 12. Please provide all correspondence, memorandum or materials transmitted between the Company and IDEQ and all permits issued by IDEQ concerning the proposed 170 MW addition at the Evander Andrews site. Please also provide a copy of the Company response to Staff Request 42 and 43 concerning air permitting at Evander Andrews. REQUEST NO 13. Please provide all documents, materials, memorandum, non-prIce scoring or analysis comparing the Siemens proposal at Evander Andrews site and the MVP proposal at the Gateway site as it relates to elimination of the "middle man" function MVP would have provided at the Gateway site; as described by Company witness Greg Said at p. 16 of his pre-filed direct testimony. REQUEST NO 14. Please provide a copy ofthe Company s response to Staff Requests 45 , 47 and 48 related to the Company s "commitment estimate , sales tax, AFUDC, progress First Request for Production of Documents from MVP to IPCo - payments, project oversight costs, transmission and substation costs and tax benefits related to construction of the Siemens 170 MW proposal at the Evander Andrews site. REQUEST NO 15. Please provide a copy ofthe Company s response to Staff Request No. 73 relating to the economies of centralized operations and using the present Company employees at the Evander Andrews site to operate the new plant, compared to the economics of operating the same plant at the Gateway site. REQUEST NO. 16. Please provide a copy of all responses by the Company to Staff or other parties in this case; except for information concerning the Company s methodology or analysis process for evaluating non-price factors that would unduly advantage MVP in future RFPs issued by the Company. DATED this 19th day of June, 2006. Mountain View Power, Inc. /ti R~ L. Ronald L. Williams Williams Bradbury, P. First Request for Production of Documents from MVP to IPCo - CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19th day of June, 2006, I served a true and correct copy of the within and foregoing document, via email at the email addresses shown below, upon all parties of record, and addressed to the following: Barton L. Kline James C. Miller Monica B. Moen Sr. Vice President, Generation Attorneys for Idaho Power Company Idaho Power Company O. Box 70 O. Box 70 Boise Idaho 83707-0070 Boise Idaho 83707 b lkl ine~i dahopower. com i imiller~idahopower.com mmoen~idahopower.com Donovan Walker Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington Boise ID 83702 Donovan. walker~puc. idaho. gov Peter J. Richardson, Esq Don Reading Richardson & O'Leary Ben Johnson Associates 515 N. 27th St 6070 Hill Road PO Box 7218 Boise ID 83703 Boise ID 83702 dread ing~mindspring .com peter~richardsonandoleary .com lti R~ L. Ronald L. Williams Williams Bradbury, P. First Request for Production of Documents from MVP to IPCo -