20060712IPC to MVP 1-16.pdf

. .
An IDACORP Company
IDAHO POWER COMPANY
PO. BOX 70
BOISE, IDAHO 83707
RECEIVED
2006 JUL II PM 4: 44
IDAHO PUBLIC
UTILITIES COMMISSION
July 11 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 Mountain View Power, Inc.
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 Mountain View Power, Inc.
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.
Very truly yours
iJ-
Monica B. Moen
MBM:sh
Enclosures
Telephone [phone] Fax [phone], E-mail MMoenrBJidahopower.com
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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IDAHO PltB:LI~S\ON
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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
MOUNTAIN VIEW POWER, INC.
COMES NOW , Idaho Power Company ("Idaho Power" or "the Company
and , in response to the First Production Request of Mountain View Power, Inc. to Idaho
Power Company dated June 19, 2006, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER, INC.Page
REQUEST NO.1. 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):
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 of 2008.
RESPONSE TO REQUEST NO.1: Combustion turbine and generation
equipment (CTG) cost information contained in the Siemens proposal is confidential.
Idaho Power does not have permission from Siemens Power Generation to release this
proprietary information. The balance of the requested information is as follows:
Based on a 2008 inline date:
CTG Price confidential
Capitalized Property Taxes
307 500.
250 361.
Air and Use Permitting Costs
Required IPC Transmission $ 22 550 000.
Required IPC Gas Supply Construction 169 125.
The estimated total fixed operating costs for the new turbine at Evander
Andrews Power Complex is $1.2 million. This proposal received 318 points out of 360
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER, INC.Page 2
total price points and 219 points out of 240 total non-price points. The total score for this
proposal was 537 points out of a possible 600.
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 of 2008.
Based on a 2008 online date:
CTG $57 993,000.
Capitalized Property Taxes
153 750.
257 614.
Air and Use Permitting Costs
Required IPC Transmission $ 3 075,000.
Required I PC Gas Supply Construction $ 1 043 141.
Total:$ 62 522 505.
Annual estimated operating costs for the proposed sites other than the existing Evander
Andrews or Bennett Mountain site were derived from actual operating cost information for
2004 and 2005 for the existing first two units at the Evander Andrews plant. It was
determined that locating the proposed plant at a site other than at one of the existing CT
locations would result in an additional $600,000 per year in fixed operating and
maintenance costs to the Company. This is primarily due to the need for additional staff
and overhead for a new location. Total fixed operating costs for the Gateway site was
estimated to be $1.8 million which includes the $600 000 per year cost. This proposal
received 328 points out of 360 for a price score and 199 points out of 240 for a non price
score. The total score for this proposal was 527 points out of 600 possible.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER, INC.Page 3
The MVP proposal to construct a new Siemens Westinghouse
170MW 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
of 2008.
Based on a 2008 online date:
CTG $62 623,000.
Capitalized Property Taxes
153 750.
309 540.
Air and Use Permitting Costs
Required IPC Transmission $ 2 767 500.
$ 65,853 790.Total:
Estimated annual operating costs for the proposed sites other than the
existing Danskin or Bennett Mountain site were derived from actual operating cost
information for the existing Danskin plant in 2004 and 2005. It was determined that
locating the proposed plant at a site other than one of the existing CT locations would
result in an additional $600 000 per year in fixed operating and maintenance costs to the
Company. This is primarily due to the need for additional staff and overhead for a new
location. Total fixed operating costs for the Middleton site was estimated to be $2.0 million
including the $600 000 per year cost. This proposal received 322 points for a price score
out of 360 total price points and 198 points out of 240 for a non price score. The total score
is 520 points out of a possible 600.
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 MOUNTAIN VIEW POWER, INC.Page 4
REQUEST NO.2. 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 of 2007 and 2008.
Idaho Power submitted eleven Generation Interconnection Applications for a
variety of MW capacities and multiple sites. The feasibility study for a 200 MW Simple
Cycle Gas Turbine Peaking Project at Evander Andrews is 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 MVP proposal to construct a new Siemens Westinghouse
170 MW turbine at the Gateway site with on-line dates of 2007 and 20088.
The feasibility study for a 200 MW or 85 MW Simple Cycle Gas Turbine
Peaking Project at an East Boise Site is 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 MVP proposal to construct a new Siemens Westinghouse
170 MW turbine at the Middleton site with on-line dates of 2007 and 2008.
The feasibility study for a 200 MW or 94 MW Simple Cycle Gas Turbine
Peaking Project at the Middleton Site is available for examination in the Idaho Power
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER, INC.Page 5
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 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 MOUNTAIN VIEW POWER , INC.Page 6
REQUEST NO.3. Please provide a copy of the Company s response to
Staff Requests No. 19 28,, and 72 concerning the Company
electrical transmission system.
RESPONSE TO REQUEST NO.3: Responses to Staff Requests 19, 20
, 22 , 23 , 24, 28 , 61 and 72 have been provided.
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 MOUNTAIN VIEW POWER, INC.Page 7
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.
RESPONSE TO REQUEST NO.4: Please refer to the Responses to
Request No.
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 MOUNTAIN VIEW POWER, INC.Page 8
REQUEST NO.5. 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.
RESPONSE TO REQUEST NO.5: Please refer to the Company
response to Request No. 26.
The response to this request was prepared by Monica Moen, Attorney II
Idaho Power Company, in consultation with Barton L. Kline, Senior Attorney, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER , INC.Page 9
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.
RESPONSE TO REQUEST NO.6: The existing Evander Andrews Power
Complex is located in the Ag B2 Zone as established by the Elmore County Zoning
Ordinance. The power plant is a permitted use in this zone and a conditional use permit
is not required to construct the proposed plant at the Evander Andrews Power Complex
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 MOUNTAIN VIEW POWER , INC.Page 1 0
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?
RESPONSE TO REQUEST NO.7: Please refer to the Company
response to Request No.6. The phrase "more likely" refers to any project that would
not be permitted by right within a particular zoning classification.
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 MOUNTAIN VIEW POWER, INC.Page
REQUEST NO.8. 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.
RESPONSE TO REQUEST NO.8: Idaho Power does not have the
requested information.
The two 45MW generators at the Danskin/Evander Andrews site were
and , continue to be, permitted uses in the Elmore County zone in which they are
located.
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 MOUNTAIN VIEW POWER, INC.Page 12
REQUEST NO.9. 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 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.
RESPONSE TO REQUEST NO.9: No communication between the
Company and IDEQ has been exchanged concerning the proposed 170 MW addition at
the Evander Andrews site and no permits have been issued by IDEQ concerning the
Company s intent to add the new Siemens 170 MW generation facility at the Evander
Andrews 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 MOUNTAIN VIEW POWER, INC.Page 13
REQUEST NO.O. 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.
RESPONSE TO REQUEST NO. 10: No correspondence (written
electronic or otherwise) has been transmitted between the Company and IDEQ
concerning MVP's proposed construction at the Gateway power 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 MOUNTAIN VIEW POWER, INC.Page 14
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 45 MW existing Danskin generating units. Please also
provide a copy of the Company s response to Staff Request No. 41 concerning this similar
request.
RESPONSE TO REQUEST NO. 11: See the Company s response to
Staff 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 RESPO~SE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER, INC.Page 15
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.
RESPONSE TO REQUEST NO. 12: No correspondence, memoranda, or
materials have been transmitted between the Company and IDEQ and no permits have
been issued by IDEQ concerning the proposed 170 MW addition at the Evander
Andrews site. Please refer to the Company s response to Staff Request Nos. 42 and 43
concerning air permitting at Evander Andrews.
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 MOUNTAIN VIEW POWER, INC.Page 16
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.
RESPONSE TO REQUEST NO. 13: Elimination of the "middle man" as
described in by Greg Said's pre-filed direct testimony in this matter refers to the fact that
the selected proposal is located at an existing Idaho Power facility and does not require
non-Idaho power professional services to obtain control of the property or other
development needs that would likely be required at an undeveloped site not under the
Company s control.
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 MOUNTAIN VIEW POWER, INC.Page 17
REQUEST NO 14. Please provide a copy of the Company s response to
Staff Requests 45 47 and 48 related to the Company s "commitment estimate " sales
tax, AFUDC, progress 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.
RESPONSE TO REQUEST NO. 14: Please refer to Idaho Power
responses to Staff Request Nos. 46 , 47 and 48. The Company s response to Staff
Request No. 45 contains information pertaining to Siemens power Generation that
Idaho Power cannot reveal to Mountain View Power, Inc.
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 MOUNTAIN VIEW POWER, INC.Page 18
REQUEST NO 15. Please provide a copy of the 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.
RESPONSE TO REQUEST NO. 15: Please refer to Idaho Power
response to Staff Request no. 73 and to the Company s response to MVP's Request for
Production No.
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 MOUNTAIN VIEW POWER, INC.Page 19
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
methodology or analysis process for evaluating non-price factors that would unduly
advantage MVP in future RFPs issued by the Company.
RESPONSE TO REQUEST NO. 16: The Company s responses to the
IPUC Staff's Requests for Production and the Industrial Customers of Idaho s Requests
for Production have been provided to MVP. Any confidential or proprietary information
contained in those responses has been removed from the copies of the responses
provided to MVP.
The response to this request was prepared by Monica Moen , Attorney II
Idaho Power Company.
DATED at Boise, Idaho , this 11th day of July, 2006.
(p-
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO FIRST PRODUCTION REQUEST
OF MOUNTAIN VIEW POWER, INC.Page 20
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11th day of July, 2006, I served a true and
correct copy of the within and foregoing IDAHO POWER COMPANY'S RESPONSE TO
THE FIRST PRODUCTION REQUEST OF MOUNTAIN VIEW POWER, INC. upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff -1L Hand Delivered
Donovan Walker u.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
472 W. Washington (83702)Email: Donovan.walker(g)puc.idaho.gov
O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power Hand Delivered
Peter 1. Richardson, Esq.u.S. Mail
Richardson & O'Leary Overnight Mail
515 N. 27th Street FAX
O. Box 7218 Email: peter(g)richardsonandoleary.com
Boise, Idaho 83702
Don Reading
Ben Johnson Associates Hand Delivered
6070 Hill Road u.S. Mail
Boise, Idaho 83702 Overnight Mail
FAX
Email: dreading (g) mindspring.com
Mountain View Power, Inc.Hand Deli vered
Ronald L. Williams u.S. Mail
Williams Bradbury, P.Overnight Mail
O. Box 2128 FAX
Boise, Idaho 83701 Email: ron (g)williamsbradbury.com
Robert D. Looper, President Hand Delivered
Mountain View Power, Inc.u.S. Mail
1015 W. Hays Street Overnight Mail
Boise, Idaho 83702 FAX
Email: rlooper(g)spellc.com
Monica B. Moen
CERTIFICATE OF SERVICE, Page