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Home My WebLink About20060706ICIP to IPC 20-30.pdf,':' Peter Richardson RECEIVED 200& JUL -6 AM 8: 04 IDAHO PUBLIC UTILITIES COMMISSION (C~;S~)JNf &: (I)!~YATTORNEYS AT LAW Tel: 208-938-7901 Fax: 208-938-7904 peterlB' rich ardso nandoleary.com O. Box 7218 Boise, 10 83707 - 515 N. 27th Sr. Boise, ID 83702 5 July 2006 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission POBox 83720 Boise ID 83720-0074 RE: Case No.lPC-O6- Dear Ms. Jewell: Enclosed please find three (3) copies of the SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY in the above case. The original request has been sent to Idaho Power Company. Sincerely, Nina Curtis Administrative Assistant end. Peter J. Richardson RICHARDSON & O'LEARY PLLC 515 N. 27th Street Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~richardsonando I eary. com Attorneys for the Industrial Customers of Idaho Power RECEWED LOOn JUl-t) At' 8: UT\~R~~~ J~J~\~S\ON 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 ANDREWSPOWER PLANT CASE NO. IPC-O6- SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission ), the Industrial Customers of Idaho Power (ICIP) , by and through their attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company ("Idaho Power ) provide the following documents. This production request is to be considered as continuing, and Idaho 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. Please provide one copy of your answer to Mr. Richardson at the address noted above and one copy to Dr. Reading at 6070 Hill Road, Boise, Idaho 83703. Please provide Dr. Reading s copy in electronic format, if available. 1 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER 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 at hearing who can sponsor the answer. REQUEST FOR PRODUCTION NO. 20: Please provide a copy of the most recent draft of Idaho Power s 2006 IRP. REQUEST FOR PRODUCTION NO. 20- Please explain the role gas fIred generation is expected to play in Idaho Power 2006 IRP. Please provide all work papers and documents in the Company s possession that address the role natural gas will play in supplying the Company s load in the future. REQUEST FOR PRODUCTION NO. 21: On page 19 of Mr. Said's testimony, he states While the Company is satisfied that the approximately $22.million estimate for transmission and substation costs associated with this Project is a reasonable upper limit estimate, no definitive studies have been completed and the Company is not including transmission costs in its Commitment Estimate. Please provide a timeline and description of the definitive studies that must be completed before the Company will be able to determine the actual amounts of transmission and substation costs associated with this Project. REQUEST FOR PRODUCTION NO. 21- Please explain and provide all documentation relied upon that allowed the Company to conclude that it is "satisfied" that the $22.8 million estimate is "reasonable REQUEST FOR PRODUCTION NO. 22 On page 18 of Mr. Said's testimony, he states that "(a)lthough the transmission system will require additional investment in order to integrate the Project, those 2 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER improvements will provide capacity during all seasons and improve the reliability of the Company s transmission system." Please provide all documents that Idaho Power relied on in making the determination, or which demonstrate that the improvements will provide capacity during all seasons and improve the reliability of the Company transmission system. REQUEST FOR PRODUCTION NO. 23 On page 15 ofMr. Said's testimony, he states that "(fJorecasted natural gas prices from the 2004 IRP were used in the bid evaluation." At any time during its evaluation of the various responses to Idaho Power s RFP, did Idaho Power use an updated forecast of natural gas prices? REQUEST FOR PRODUCTION NO. 24 Should the Commission deny Idaho Power s request for a certificate of public convenience and necessity, what supply or demand reduction alternative options would the company turn to in the summer of 2008? (If Idaho Power already answered, or intends to answer this question in response to ICIP's Request for Production No. 18 please disregard this request.) REQUEST FOR PRODUCTION NO. 25 On page 21 of Mr. Said's testimony, he explains that "Siemens has located an existing, new Generator Step-Up Transformer (GSU) that is available for the Project at significant cost savings in comparison to identical transformers that are being manufactured today." He also states that "(i)n order to take advantage of the cost 3 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER savings, the Company must act expeditiously." Please provide copies of all documents that Idaho Power or its employees have reviewed that demonstrate that the GSU is available at a significant cost savings in comparison to identical transformers that are being manufactured today. REQUEST FOR PRODUCTION NO. 26: Please provide all documents that have been in the possession of Idaho Power which relate to the GSU referenced on page 21 of Mr. Said's testimony. REQUEST FOR PRODUCTION NO. 27 In Response to Request No. 41 of Staff's First Production Request , the Company stated "(l)ast year during normal operations, the existing Danskin Power plant emitted a total of 0 tons Sulfur Dioxide, 5.72 tons of NO x and 1.5 tons of CO." Please indicate the estimates of pollutant emissions for each plant if both were operated to their full capacity under the existing air permits. Please indicate the hours of operation for each plant if both were operated to their full capacity under the existing air permits. REQUEST FOR PRODUCTION NO. 28: In Response to Request No. 61 of Staffs First Production Request, the Company stated "Idaho Power did not receive any bids in this RFP that would require energy to cross the Borah-West transmission constraint." Assuming the plant is constructed, does the Company anticipate there will be any impact on the Borah- West transmission constraint? If so, how much and what kind? Please explain the answer fully. REQUEST FOR PRODUCTION NO. 29 In Response to Request No. 15 of Staffs First Production Request, Idaho Power states 4 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER 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 preparation could be avoided Please provide the "reasonable benchmarks for peaking unit prices" that the Company had. Please provide a copy of all related documents, or, if none are available, a description of what the reasonable benchmarks were and how they were calculated. REQUEST FOR PRODUCTION NO. 30: In Response to Request No. 40 of Staff's First Production Request , Idaho Power describes the new permits that will need to be obtained before constructing the Evander Andrews plant. Is the cost of obtaining these permits included in the Company Commitment Estimate of $60 million? Are the expected costs of complying with permit conditions included in the Company s Commitment Estimate of$60 million? DATED this 5th day of July 2006. RICHARDSON & O'LEARY PLLC By: f24, Peter J. Richardson, ISB #3195 Attorneys for the Industrial Customers of Idaho Power 5 - SECOND PRODUCTION REQUEST OF ICIP TO IDAHO POWER CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 5th day of July, 2006, I caused a true and correct copy ofthe foregoing SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER to be served by the method indicated below, and addressed to the following: Jean Jewell Idaho Public Utilities Commission 472 West Washington Street (83702) Post Office Box 83720 Boise, Idaho 83720-0074 (X) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile ( ) Electronic Mail Barton L. Kline Idaho Power Company 1221 W. Idaho St. (83702) PO Box 70 Boise, Idaho 83707 bkline(~jdahopower .com mmoen~idahopower. com ( ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail Donovan Walker Deputy Attorney General Idaho Public Utilities Commission 472 W. Washington (83702) PO Box 83720 Boise, ID 83720-0074 Donovan. walker~puc.idaho. gov ( ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail James C. Miller Sr. Vice President, Generation Idaho Power Company 1221 W. Idaho St. (83702) PO Box 70 Boise, Idaho 83707 i immiller~idahopower .com ( ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail CERTIFICATE OF SERVICE - 1 Ronald L. Williams Williams Bradbury, P. PO Box 2128 Boise, ID 83701 ron~williamsbradbury .com ( ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail Robert D. Looper President Mountain View Power, Inc. 1015 W Hays Street Boise, ID 83702 rlooper~spellc.com ( ) U.S. Mail, Postage Prepaid ( ) Hand Delivered ( ) Overnight Mail ( ) Facsimile (X) Electronic Mail Signed: ~.a.Jn CuJ\~~ Nina M. Curtis CERTIFICATE OF SERVICE - 2