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Home My WebLink About20060822Staff to IPC 91-103.pdfDONOV AN E. WALKER DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 5921 RECEIVED 200& AUG 22 PH 3: 24 IDF,HO FUBLIC UTILITIES COMl.iISSIOI Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff 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 POWER PLANT. CASE NO. IPC-06- FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Donovan E. Walker, Deputy Attorney General, requests that Idaho Power Company (Company; IPC) provide the following documents and information as soon as possible, but no later than MONDAY SEPTEMBER 11, 2006. This Production Request is to be considered as continuing, and Idaho Power Company 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. 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 who can sponsor the answer at hearing. For purposes of clarification, the "Evander Andrews Plant" as referred to in this request means the new proposed plant that would be constructed at the Evander Andrews site. The existing plant at the Evander Andrews site is referred to as "Danskin. FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUST 22, 2006 Questions 91-93 refer to the testimony of Greg Said beginning on pages 16 , line 22 and continuing through page 17, line 19 wherein he discusses "other attributes of the Project that you (Greg Said) believe are important to the Commission s consideration. REQUEST NO. 91: Please explain in detail the transmission improvements that "will provide capacity during all seasons and improve the reliability of the Company s transmission system." Please quantify as accurately as possible the benefits of increased transmission capacity and of improved reliability. If these attributes cannot be quantified, please explain why. REQUEST NO. 92: Please explain in detail and quantify as accurately as possible the benefits from the economies of centralizing operations at one location (Evander Andrews). If these attributes cannot be quantified, please explain why. REQUEST NO. 93: Please explain in detail and quantify as accurately as possible the benefits from simplification of environmental compliance reporting as a result of locating the new generating plant at the Evander Andrews location. REQUEST NO. 94: Is Idaho Power willing to provide a commitment estimate for transmission costs that will be incurred to integrate the proposed new Evander Andrews generating plant, similar to the Commitment Estimate offered for the plant construction? If so , what is the commitment estimate for transmission costs? If Idaho Power is not able or willing to agree to have the transmission improvements subject to a commitment estimate, please explain why. REQUEST NO. 95: A natural gas fired peaking plant was not selected as part of the preferred portfolio chosen in the Draft 2006 IRP. If 2006 IRP assumptions are used and the proposed Evander Andrews plant is assumed to be a resource option instead of part ofIdaho Power s existing generation fleet, would the Evander Andrews plant be chosen as part of the preferred portfolio? REQUEST NO. 96: In Request No.1 of the Commission Staff, Staff requested a copy of load-resource balance data by month for each of the years 2006-2026 for six different assumed water and load conditions, with and without the addition of the proposed Evander Andrews plant. The FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUST 22, 2006 requested time period was chosen specifically to correspond to the time period covered by the 2006 IRP. 2006 IRP load-resource balance data has been in use by the Company for several months during the preparation of the 2006 IRP; consequently, Staff assumed it could also be used to re-examine the need for the Evander Andrews plant. In the Company s initial response to this request, Idaho Power provided load-resource balance data for the period 2004-2013, apparently from the 2004 IRP. Please provide a response to this request using load-resource balance data consistent with the data that will be used in the 2006 IRP. REQUEST NO. 97: In response to Request No.2 of the Commission Staff, the Company states "Peak load surpluses/deficiencies are evaluated using 90th percentile water and 95th percentile peak load conditions." Has the Company changed its capacity planning criteria for the 2006 IRP, or should the response be corrected to refer to the "90th percentile water and 70th percentile peak load conditions. " REQUEST NO. 98: Assuming, hypothetically, that the Evander Andrews plant is constructed and that Idaho Power is fully utilizing all of its own resources and purchase contracts, if water and load conditions are such that Idaho Power is still unable to meet load, what other alternatives will be pursued to meet load? At what point will load curtailment be considered? REQUEST NO. 99: Staff Request No. 18 specifically asked that the load and fuel price forecasts used to perform the AURORA analysis be consistent with those of the 2006 IRP. Based on the Company s response, it appears that 2004 IRP assumptions were used with perhaps some update to fuel price forecasts. Please provide responses to parts a, b, and c of Request No. 18 using 2006 IRP assumptions, or explain why 2006 IRP assumptions cannot be used. REQUEST NO. 100: Staff Request No. 26 asked for monthly estimates for the period June 2007-December 2027 ofthe number of hours the Evander Andrews plant will be expected to operate to serve Idaho Power s load. Idaho Power did not provide any estimate of expected operating hours. For the purposes of answering this request, Staff assumed that the Evander Andrews plant would be added to Idaho Power s portfolio and dispatched in an AURORA simulation using the portfolio FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUST 22 , 2006 selected in the 2006 IRP. Please provide monthly estimates as requested, or if this cannot be done please explain why. REQUEST NO. 101: Staff Request No. 51 asked for Idaho Power s current forecast of firm wholesale electric energy prices for the next five and 1 O-year periods for heavy and light load hours. In response to the request, Idaho Power provided monthly heavy and light load hour prices for three market hubs from July 2006-December 2012 (approximately a six-year period). Does the Company prepare or purchase a forecast that extends beyond 2012? If so, please provide a copy. REQUEST NO. 102: Staff request No. 61 asked for an update on the status on the Company plans to upgrade the Borah-West transmission path. Neither in its initial or its supplemental answers to this request did Idaho Power provide an actual update on the project status as requested. Staff would like to know, for example, is the project under construction, when is completion expected, how much has/will the rated transmission capacity of the path been increased, etc. REQUEST NO. 103: In Staff Request No. 74, Staff asked Idaho Power to describe any additional costs Idaho Power expects it will incur as a result of delaying completion of the project from June 1 2007 until April 1 , 2008. If the answer to the question can be determined simply by subtracting the winning bidder s 2008 online date price from its 2007 online date price, then Staff can develop an answer without assistance. However, if there are other costs because of delaying the online date until April 2008, such as costs for acquiring replacement power for 2007 for example, then Staff requests that Idaho Power provide an answer. DATED at Boise, Idaho thiS?t~ day of August 2006. onovan E. Walker Deputy Attorney General Technical Staff: Rick Sterling i:umisc:prodreqlipceO6.09dwrps ipc4 FOURTH PRODUCTION REQUEST TO IDAHO POWER COMPANY AUGUST 22, 2006 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF AUGUST 2006 SERVED THE FOREGOING FOURTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY IN CASE NO. IPC-06- BY MAILING A COpy THEREOF, POSTAGE PREPAID, TO THE FOLLOWING: BARTON L KLINE MONICA MOEN IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 JAMES C MILLER SR. VICE PRESIDENT, GENERATION IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 PETER J RICHARDSON RICHARDSON & O'LEARY 515 N 27TH ST PO BOX 7218 BOISE ID 83702 DR DON READING 6070 HILL ROAD BOISE ID 83703 SECRET CERTIFICATE OF SERVICE