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Home My WebLink About20060816ICIP to IPC 31-46.pdfRECEIVED 2006 AUG 16 AM 8: _(Q~~QJlNr &: (();ATTORNEYS AT LAW IDAHO PU8L1C UTILITIES COi\HtJISSION Peter Richardson Tel: 208-938-7901 Fax: 208-938-7904 peterC1!' rich ardso nand oleary.com O. Box 7218 Boise, 10 83707 - 515 N. 27th St. Boise, ID 83702 15 August 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 THIRD 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. An extra copy is also enclosed to be stamped & returned to our office. Sincerely, CW\~S Nina Curtis Administrative Assistant encl. Peter J. Richardson RICHARDSON & O'LEARY PLLC 515 N. 2ih Street Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter~richardsonandoleary .com Attorneys for the Industrial Customers of Idaho Power RECEIVED 2006 AUG 16 AM 8: 09 IDAHO PUBLIC UTILITIES COMMISSION 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- THIRD 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. 1 - THIRD PRODUCTION REQUEST OF ICIP TO IDAHO POWER 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. 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. 31: In response to ICIP's Production Request No., Idaho Power stated Given the competitiveness of the pricing in the Bennett Mountain RFP, Idaho Power was able to acquire the incremental 85 MW of capacity (I 73 MW-88 MW = 85 MW) at an extremely competitive price providing additional generation at minimal cost while improving reliability for customers. Please explain how the "additional generation" acquired, above the 88 MW called for in the 2004 IRP, will change IPC's projected need for future resources as set forth in the 2004 IRP? For example, will the additional generation acquired obviate the need for any specific RFPs that were called for in the 2004 IRP? REQUEST FOR PRODUCTION NO. 32: In response to ICIP Production Request No., Idaho Power stated that ". . . by incorporating a range of sizes in the RFP and ultimately selecting a 173 MW combustion turbine, Idaho Power has an opportunity to defer additional generation resources in future resource plans. . ," Please provide a copy of all resource plans in which Idaho Power has deferred, or would defer, additional generation due to the proposed Evander Andrews plant's having more generation capabilities than the 88 MW called for in the 2004 IRP. Also, please provide a description of how the additional generation (above the 88 MW) 2 - THIRD PRODUCTION REQUEST OF ICIP TO IDAHO POWER called for in the 2004 IRP) will affect Idaho Power s projected resource needs in the future. If possible, please describe the types of resources that will be deferred due to the additional generation. REQUEST FOR PRODUCTION NO. 33: In response to ICIP Production Request No. 18, Idaho Power stated that if the Commission denied Idaho Power s request for a certificate of public convenience and necessity for the Evander Andrews plant, one option it would most likely pursue would be "utilizing diesel or temporary gensets." Please describe what diesel or temporary gensets IPC could use, and provide copies of any studies or documentation regarding the costs of using those resources. REQUEST FOR PRODUCTION NO. 34: Please describe any cap that Idaho Power has placed on its spending for Demand Side Management programs. If there are any caps placed on Demand Side Management programs, please explain how the company determines such cap if the program has proven to be cost-effective (having a savings in energy costs that is greater than the cost ofthe program). REQUEST FOR PRODUCTION NO. 35 Please provide copies of all budgets and supporting work papers for Idaho Power s DSM programs over the past five years. REQUEST FOR PRODUCTION NO, 36: Please provide any analyses conducted by Idaho Power into how the transmission that will be required to bring the Evander Andrews output to load will affect the Company s loads and resources. 3 - THIRD PRODUCTION REQUEST OF ICIP TO IDAHO POWER REQUEST FOR PRODUCTION NO. 37: In Idaho Power s Response to Staffs Request No. 81 , Idaho Power provided a copy of the Company s 2003 evaluation manual for the peaking resource RFP. Page 29 of that document sets forth a "Cogen and Small Power Forecast (aMW)." Please provide a copy of the Company s current "Cogen and Small Power Forecast (aMW)." If one is not available, please fully explain why, and how the Company s decisions with regard to the 2005 RFP took into account the generation the Company would receive from Cogen and Small Power Producers. REQUEST FOR PRODUCTION NO. 38: With regard to the "Cogen and Small Power Forecast (aMW)" referred to above in Request for Production No. 40, please explain fully why the document shows no increase in Cogen and Small Power generation after 2004. Additionally, please explain whether the Company forecasts any increase in Cogen and Small Power generation after 2006 and beyond. REQUEST FOR PRODUCTION NO, 39: With regard to the "Cogen and Small Power Forecast (aMW)" referred to above in Request for Production No, 40, please explain why the 2005 RFP evaluation manual did not contain a similar chart or forecast. REQUEST FOR PRODUCTION NO. 40: In response to ICIP Request for Production No. 18, Idaho Power describes five alternatives for meeting peak demand that it would consider if the Commission denies its request for a certificate of public convenience and necessity for the Evander Andrews plant. Please describe what efforts the Company has made to determine the costs of those 4 - THIRD PRODUCTION REQUEST OF ICIP TO IDAHO POWER alternatives and any estimates the Company has developed of the costs for implementing these alternatives instead of constructing the Evander Andrews plant. REQUEST FOR PRODUCTION NO. 41: Please explain what assumptions the company is making for the future regarding the Conservation Reserve Enhancement Program (CREP program), through which farmlands will be set aside, and irrigation pumps turned off. Specifically, please describe any assumptions the Company is making regarding decreased peak power requirements as compared to what they would be without the CREP program. Please explain whether these assumptions affected the Company s decisions with regard to the 2005 RFP or Evander Andrews power plant. REQUEST FOR PRODUCTION NO. 42: Please explain why the 2005 RFP did not include a power purchase option. REQUEST FOR PRODUCTION NO. 43: Please provide any long-term transmission planning documents the Company has developed that support any claim by the Company that it was planning on building any of transmission facilities that will be required to bring the proposed Evander Andrews plant output to load regardless of whether the Evander Andrews plant was built. REQUEST FOR PRODUCTION NO. 44: Please clarify whether Idaho Power has a signed contract to receive the natural gas necessary to run the proposed Evander Andrews plant. If so, please provide a copy of the contract, and any other documentation or description required to determine the terms of the contract, including duration and price. If not, please describe what arrangements will be necessary to secure the required natural gas. 5 - THIRD PRODUCTION REQUEST OF ICIP TO IDAHO POWER REQUEST FOR PRODUCTION NO. 45: Please provide any documents or research that Idaho Power has which evaluates or relates to the potential for industrial combined heat and power projects in the Treasure Valley. REQUEST FOR PRODUCTION NO. 46: Please describe any efforts Idaho Power has made to look into the use of emergency generators (i.e. emergency back-up generation installed throughout the region in commercial or industrial facilities) to meet or reduce peak loads. Please provide any relevant analyses, documentation, and correspondence. DATED this 15th day of August, 2006. RICHARDSON & O'LEARY PLLC 6 - THIRD PRODUCTION REQUEST OF ICIP TO IDAHO POWER ICIP PRODUCTION REQUESTS 47 - 53 TO IDAHO POWER CO. ARE CO NFID E NTIAL AND ARE FILED SEP ARA TEL Y CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 15th day of August, 2006, I caused a true and correct copy of the foregoing THIRD 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~idahopower. 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~wi1liamsbradbury .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: ~\ C0J\ ti ~ Nina M. Curtis CERTIFICATE OF SERVICE - 2