20060629IPC to Staff 4-13, 15, 17, 37-44, 46.pdf

IDAHO POWER COMPANY
O, BOX 70
BOISE, IDAHO 83707
BARTON L. KLINE
Senior Attorney
An IDACORP Company
June 28 2006
" ,
Jean D. Jewell , Secretary
Idaho Public Utilities Commission
472 West Washington Street
P. O. Box 83720
Boise, Idaho 83720-0074
Re:Case No. IPC-06-
Idaho Power Company s Response to the First Production
Request of Commission Staff
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company s Response to the First Production Request of Commission Staff regarding
the above-described case.
I would appreciate it if you would return a stamped copy of this transmittal letter
to me in the enclosed self-addressed stamped envelope.
ve~
Barton L. Kline
BLK:sh
Enclosures
Telephone [phone] Fax [phone] E-mail BKlinefBiidahopower.com
': L.
BARTON L. KLINE ISB #1526
MONICA B. MOEN ISB #5734
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
FAX Telephone: [phone]
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Attorney for Idaho Power Company
Street Address for Express Mail
1221 West Idaho Street
Boise , Idaho 83702
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 POWERPLANT.
CASE NO. IPC-06-
IDAHO POWER COMPANY'
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
COMMISSION STAFF
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and in response to the First Production Request of the Commission Staff to Idaho Power
Company dated June 16 , 2006, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page
REQUEST NO.4: Please provide a list of RFP representatives of
potential bidders who attended the pre-bid meeting on April 21 , 2005.
RESPONSE TO REQUEST NO.4: The information requested is attached
hereto as "Response to Request No.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 2
IDAHO POWER COMPANY
CASE NO. IPC-O6-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO.
Name Company Name Phone Number Email Address
J.R. Cook Aker Kvaerner Industrial Constructors (AKIC)[phone] jack. cook(Q1a kerkva erne r. com
Nick Laporte Calpine [phone] nickl(Q1calpine.com
Stuart Sobol Calpine [phone] ssobol(Q1calpine.com
Barbara Ehrlich Calpine Power Services [phone] behrlich(Q1calpine.com
Jeff Osterman CH2MHili [phone] jeff.osterman(Q1ch2m. com
Van C. Wilgus Colorado Energy Management, LLC [phone] vwilgus(Q1coloradoenergy.com
Donald Hammond Continental Energy Services, Inc.[phone] hammond(Q1cesacq1.com
Mike Elliott David Evans & Associates [phone] mde(Q1deaidc.com
Lorne Whittles EPCOR [phone] Iwhittles(Q1epcor.
David Alexander GE Energy [phone] david .alexander(Q1ps .ge .com
Edward Portaro Harris Group, Inc.[phone] ed. portaro(Q1harrisgrou p .com
Steve Munn Heinz [phone] steve. munn(Q1us. h jheinz.com
Mark Stokes Ida-West Energy [phone] msto kes (Q1id a-west co m
Clay Hales Inco Services [phone] chales(Q1incoservices. com
Rick Sterling IPUC [phone] rick.sterling(Q1ipuc. idaho .gov
Kitty Looper Mountain View Power [phone] kitty(Q1spella.com
Leonard Hutterman Mountain View Power [phone] tallerman(Q1velocitus.n et
Lawrence J. Becker National Energy Systems Company [phone] larryb(Q1national-energy. com
John Baker Power Engineers [phone] jbaker(Q1powereng .com
Mike Lidinsky Power Engineers [phone] mlidinsky(Q1powereng. com
Bob Scott Quality Electric [phone] bobscott(Q1rmcLnet
Lou Capelli Quality Electric [phone] bobscott(Q1rmci.net
David De Young Rolls Royce Energy Systems [phone] dave(Q1keyroute.net
David Bergstrom Rolls-Royce [phone] david. bergstrom(Q1rolis-royce.com
John Alsip Rolls-Royce [phone] jalsip(Q1cinci.rr.com
Ed Scott Siemens Westinghouse [phone] ed .scott(Q1siemens.com
James. McDaniel Siemens Westinghouse [phone] james. m cd a n ie! (Q1 si e mens. com
Kendall Howington Siemens Westinghouse [phone] kendall. howington(Q1s iemens.com
Nicholas F. Viscount SNC Lavalin Thermal Power [phone] Nick. Viscount(Q1slthermal.com
Mark B. Gilliss, PE Spectrum Energy, Inc.[phone] ma rkg i II iss(Q1spectru me n ergy. com
Doug Brooks Stanley Consultants [phone] brooksdoug (Q1stan leygrou p .com
Walt Jones Stanley Consultants [phone] joneswalt(Q1stanleygrou p .com
John Uphoff Tenaska, Inc.[phone] juphoff(Q1tenaska.com
Lou Graving The Industrial Company (TIC)[phone] Igraving(Q1ticus.com
Thomas Wos Utility Engineering [phone] Thomas. G. Wos(Q1 ue-corp.com
Dennis Finn Wartsila North America, Inc.[phone] dennis.finn(Q1wartsila.com
Randy Hill Washington Group International, Inc.[phone] randy.hill(Q1wgintcom
Scott Wilson Washington Group International, Inc.[phone] scott. wilson(Q1wg i ntcom
John K. Smith Wood Group Power Solutions [phone] jk.smith (Q1woodg roup. com
REQUEST NO.5: Please provide a copy of all "Notice of Intent to Bid"
forms completed and submitted to Idaho Power by interested bidders in the March 2005
RFP process.
RESPONSE TO REQUEST NO.5: The confidential information requested
is attached hereto as "Response to Request No.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 3
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.
RESPONSE TO REQUEST NO.6: The confidential information
requested is voluminous and as a result will be made available for examination in the
Idaho Power Company Legal Department located in the Company s corporate offices.
Please contact Sandra Holmes at 388-2688 to arrange a time to review the requested
material.
The response to this request was prepared by Monica Moen , Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 4
REQUEST NO.7: Please provide copies of all bids received in response
to the March 2005 RFP.
RESPONSE TO REQUEST NO.7: The confidential information
requested is voluminous and as a result will be made available for examination in the
Idaho Power Company Legal Department located in the Company s corporate offices.
Please contact Sandra Holmes at 388-2688 to arrange a time to review the requested
material.
The response to this request was prepared by Monica Moen , Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 5
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 2-6 of Greg Said's direct testimony.
RESPONSE TO REQUEST NO.8: The confidential information
requested is voluminous and as a result will be made available for examination in the
Idaho Power Company Legal Department located in the Company s corporate offices.
Please contact Sandra Holmes at 388-2688 to arrange a time to review the requested
material.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 6
REQUEST NO.9: Please provide copies of all analysis conducted by the
Company in evaluating RFP bids.
RESPONSE TO REQUEST NO.9: The confidential information
requested is attached hereto as "Response to Request No.
The response to this request was prepared by Monica Moen , Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 7
REQUEST NO.1 0: 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.
RESPONSE TO REQUEST NO.0: Please refer to the Response to
Request No.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 8
REQUEST NO. 11: Please provide analysis demonstrating that the
Evander Andrews project was the preferred alternative for meeting Idaho Power
needs.
RESPONSE TO REQUEST NO. 11: Pease refer to the Response to
Request No.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 9
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 of these bids still
being considered? Does Idaho Power expect to consider any of these bids in the
future? If so, please explain.
RESPONSE TO REQUEST NO. 12: Please refer to the Response to
Request No.9. These bids are no longer being considered and the Company does not
expect to consider any of these bids in the future.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 10
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.
RESPONSE TO REQUEST NO. 13: Please refer to the Response to
Request No.9. The bids that advanced to the "short list" ranked higher in the
Company s evaluation analysis than did the eliminated bids.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 11
REQUEST NO. 15: Please explain why Idaho Power did not prepare a
self-build proposal for the March 2005 RFP.
RESPONSE TO REQUEST NO. 15: Idaho Power Company previously
issued an RFP for a peaking resource in February 2003. A self-build proposal was
prepared during that RFP; however, the Company does not maintain a significant power
plant design and construction workforce. As a result, the self-build option represented
Idaho Power as a general contractor that subcontracted for materials , design and labor.
Idaho Power ultimately determined that not only were bids received in the 2003 RFP
process competitive, but also the selected Mountain View Power bid was superior to the
self-build option.
With the 2005 RFP , the Company was convinced that based upon recent
experience with the 2003 RFP process , it would receive sufficient competitive bids , the
Company had reasonable benchmarks for peaking unit prices and that expenses
associated with self-build bid preparation could be avoided. The Company reserved the
right to reject all bids if they were deemed unacceptable.
The response to this request was prepared by Gregory W. Said , Manager
of Revenue Requirement, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 12
IDAHO POWER COMPANY
CASE NO. IPC-O6-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO.
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST
REQUEST NO. 17: Please identify the members of Idaho Power s RFP
evaluation team.
RESPONSE TO REQUEST NO. 17: The information requested is
attached hereto as "Response to Request No. 17.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 13
IDAHO POWER COMPANY
CASE NO. IPC-O6-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO.
IDAHO POWER COMPANY
2005 PEAKING RESOURCE
EV ALVA TION TEAM
Greg Hall , Chair, Engineer, Power Production
Garrett Bishop, Engineer, Power Production
Randy Henderson, Business Analyst, Power Supply Reporting
Barr Smith, Planning Analyst, Load Research
Pete Stewart, Project Manager, Power Production
Mike Youngblood, Pricing and Regulatory Services
ADVISORS
Power Engineers (Mike Lidinsky, John Baker) - Third Party Consultant
Monica Moen, Idaho Power Legal Department
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?
RESPONSE TO REQUEST NO. 37: The confidential information
requested is voluminous and as a result will be made available for examination in the
Idaho Power Company Legal Department located in the Company s corporate offices.
Please contact Sandra Holmes at 388-2688 to arrange a time to review the requested
material.
The response to this request was prepared by Monica Moen , Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 14
REQUEST NO. 38: Please describe any liquidated damages provisions
between Idaho Power and Siemens Power Generation, Inc.
RESPONSE TO REQUEST NO. 38 The confidential information
requested is voluminous and as a result will be made available for examination in the
Idaho Power Company Legal Department located in the Company s corporate offices.
Please contact Sandra Holmes at 388-2688 to arrange a time to review the requested
material.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 15
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.
? .
RESPONSE TO REQUEST NO. 39: Yes , it is possible to expand the site.
The existing simple cycle units could be converted to combined cycle units. However
from a practical perspective , the ability to expand the site will likely be limited by the
economics of expanding pipeline and transmission line capacity and the ability to secure
acceptable operating permits. None of the costs of the Evander Andrews project
included in the commitment estimate are solely to permit future expansions of the site.
At present , there are no future expansion plans for the site.
The response to this request was prepared by F. Gregory Hall, Principal
Engineer, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 16
IDAHO POWER COMPANY
CASE NO. IPC-O6-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 39
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST
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 permit. If not, what additional permits or amendments to
existing permits would have to be obtained?
RESPONSE TO REQUEST NO. 40: , it will be necessary to obtain
new permits for the project. It would not be prudent for the Company to begin acquiring
needed permits for the new plant prior to receiving approval by the Commission. The
following is a list of the permits that are to be attained for the construction of the plant.
These permits are typical of any site.
Agency Permit/Citation/Approval Reasons
Required
US Fish and Threatened &Demonstrate
Wildlife Endangered Species no impact
Act Compliance
Acknowledgment
DOT Equipment and Highway
Materials Handling,transportation
Including Materials for supplied
Disposal equipment.
DEQ State Pollutant Storm water
Discharge Elimination discharges
System Permit
DEQ Modification of existing Approval to
Air Quality/Synthetic emit air
Minor Air Permit pollutants
under state
permit
DEQ Waste To confirm no
Management/Clean up pre-existing
site
contamination
DOT Equipment and Highway/road
Materials Handling,transportation
Including Materials
Disposal
DEQ Excavation Materials Permit to
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 17
Disposal dispose of
excavated
materials
Historical Confirmation of no Confirmation
Society Artifacts or sites of of no
Archaeological , Cultural interference
or Historic Significance for
construction
IPUC Certificate of Authorization
Convenience and to include
Necessity Project in rate
base.
Building Construction/Building Authorization
Department Permit to construct
Fire & Police Construction Secu rity Approval of
Chiefs and Safety Procedures site
and Equipment procedures
Police Chief Equipment and Street
& Traffic Materials Handling,transportation
Department including Material and delivery
Disposal for Contractor
supplied
Equipment
Railroad Approval for Utilization Approval for
of Railroad Spur or rail haulage
Railroad Lines and
unloading of
large
equipment
Fire Chief Approval of On-site Approval to
and storage of chemicals allow storage
Emergency lubricants , etc. used and usage
Management during construction
Coordinator
Building Certificate of Occupancy of
Department Occupancy structures
The response to this request was prepared by F. Gregory Hall , Principal
Engineer , Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 18
IDAHO POWER COMPANY
CASE NO. IPC-06-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 40
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST
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?
RESPONSE TO REQUEST NO. 41: At the request of Idaho Power, Tetra
Tech EM Inc., an independent consultant evaluated sites in Ada, Canyon and Elmore
counties. A copy of this report is available for examination in the Idaho Power
Company Legal Department located in the Company s corporate offices. On page 17 of
the report, Tetra Tech notes that "Elmore County air quality is in attainment for all
criteria pollutants and there are no significant permitting issues according to Mr. Bill
Rogers at the Idaho Department of Environmental Quality.
Currently, the Evander Andrews Power Complex has been issued a Tier
Title V operating permit for the existing sources. This permit allows the existing sources
to emit up to 248 tons of NOx and 150 tons of CO during a calendar year. Under
existing Idaho Administrative Procedures Act (IDAPA) and the federal New Source
Review programs, an additional simple cycle unit can be added as a "synthetic minor"
source if the emission of any criteria pollutant is less than 250 tons of year. This means
that another simple cycle source can be added to the existing permit. The permit will be
granted an additional 250 tons of any criteria pollutant for this new source. Last year
during normal operations, the existing Danskin Power plant emitted a total of 0 tons of
Sulfur Dioxide , 5.72 tons of NOx and 1.5 tons of CO.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 19
The response to this request was prepared by F. Gregory Hall, Principal
Engineer , Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 20
IDAHO POWER COMPANY
CASE NO. IPC-06-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 41
A copy of this report is available for examination
in the Idaho Power Company Legal Department
located in the Company s corporate offices.
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.
RESPONSE TO REQUEST NO. 42: No new permits have been obtained.
Please refer to Request No. 40 for a listing of all permits that are necessary for
construction and operation of the plant.
The response to this request was prepared by F. Gregory Hall , Principal
Engineer, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 21
IDAHO POWER COMPANY
CASE NO. IPC-06-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 42
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST
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.
RESPONSE TO REQUEST NO. 43: Please refer to the response to
Request No. 41
The response to this request was prepared by F. Gregory Hall , Principal
Engineer, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 22
IDAHO POWER COMPANY
CASE NO. IPC-06-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 43
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST
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?
RESPONSE TO REQUEST NO. 44: The plant will discharge
approximately 65 gallons per minute of evaporative cooler blow down during the
summer months. The evaporative cooler is used for power augmentation and is only
used when the ambient temperature is above 59 F. This application is currently being
used for the existing combustion turbines. The water will be disposed of in the same
way as the existing blow down by being retained in an existing lined retention pond and
then pumped out for irrigating landscaping.
The response to this request was prepared by F. Gregory Hall , Principal
Engineer, Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 23
IDAHO POWER COMPANY
CASE NO. IPC-06-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 44
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST
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?
RESPONSE TO REQUEST NO. 46: Idaho Power Company is requesting
a Certificate of Convenience and Necessity to construct a generation facility as required
by Idaho Code 961-625. In support of that request, the Company has included a
commitment estimate such that if costs of the generation facility exceed the commitment
estimate , the Company will not request inclusion of the amounts in excess of the
commitment estimate in the Company s rates.
Construction of transmission and substation facilities do not generally
require the acquisition of a Certificate of Convenience and Necessity. Prior to inclusion
in rates, the Company must, however, demonstrate the prudence of costs incurred to
construct such transmission and substation facilities. The Company has included
estimates of the costs for transmission and substation facilities to be constructed in
conjunction with the Evander Andrews power plant to insure that the Commission is
aware that there are costs above and beyond the costs of the power plant addressed by
the Certificate of Convenience and Necessity. While the Company believes that the
costs of transmission and substation facilities will not exceed the $22.8 million , no
definitive cost studies have been completed and the Company recognizes that it bears
the burden of demonstrating that the actual costs that the Company incurs to build such
facilities are prudent and reasonable for inclusion in rates.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 24
The response to this request was prepared by Gregory W. Said , Manager
of Revenue Requirement, Idaho Power Company, in consultation with Barton L. Kline
Senior Attorney, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST
PRODUCTION REQUEST OF COMMISSION STAFF Page 25
IDAHO POWER COMPANY
CASE NO. IPC-06-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO. 46
NO DOCUMENTS REQUESTED AND/OR NO
DOCUMENTS RESPONSIVE TO THIS REQUEST