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Home My WebLink About20070619Staff to IPC 1-14.pdf-. -.- . ,- SCOTT WOODBURY DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION 472 WEST WASHINGTON STREET PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0320 BARNO. 1895 !j i ,! - 9 i.; I: L;7 i ::, : i - , ,i':J; : =:;:. ,~)~;' Street Address for Express Mail: 472 W. WASHINGTON BOISE, IDAHO 83702-5983 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION CASSIA GULCH WIND PARK, LLC AND CASSIA WIND FARM, LLC,CASE NO. IPC-06- CO MPLAIN ANTS, FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY IDAHO POWER COMPANY RESPONDENT. The Staff of the Idaho Public Utilities Commission, by and through its attorney of record Scott Woodbury, Deputy Attorney General, requests that Idaho Power Company (Company; IPC) provide the following documents and information as soon as possible, but no later than TUESDAY, JULY 3, 2007. 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. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 19, 2007 REQUEST NO.1: What is the significance of interconnection requests submitted during the period January 2005 through June 29, 2006 as discussed in Section 4 on page 3 of the Settlement Stipulation? How does Idaho Power propose to handle interconnection requests made after the period listed above? REQUEST NO.2: Please provide a map showing Idaho Power s transmission system in the Magic Valley area, the capacity ratings and voltage of each transmission line, the locations of each project requesting transmission service, locations of relevant substations, and the proposed point of interconnection for each project. Please designate on the map the geographic boundaries for which future projects will require transmission upgrades and may be subject to similar redispatch requirements. REQUEST NO.3: Please provide a copy of the Generation Interconnection System Impact Study referred to in Section 5 of page 3 of the Settlement Stipulation. REQUEST NO.4: Please provide a copy of the "Redispatch Study" referred to in Section 5 of page 3 of the Settlement Stipulation. REQUEST NO.5: Will it be necessary for all projects in the queue to agree to be subject to redispatch? Ifnot, what cost would be assessed to projects that decline to be subject to redispatch, assuming Idaho Power makes transmission upgrades only sufficient to accommodate all projects in the queue if all projects are subject to redispatch? Please provide an example similar to the format used in Exhibit B showing capacity and cost allocations if some projects agree to redispatch and others do not. REQUEST NO.6: Please discuss how the proposed redispatch differs from the remedial action schemes discussed earlier in the negotiations. Why is Idaho Power willing to now consider redispatch when it appeared earlier in the negotiations to insist that a remedial action scheme was only a temporary solution? FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 19, 2007 REQUEST NO.7: Please describe the circumstances under which redispatch would occur. Please provide an estimate of the timing, magnitude, and frequency of when redispatch is expected to occur in the future. REQUEST NO.8: Please explain the rationale for Section 13 , Part C of the Settlement Stipulation. Does Idaho Power anticipate making a request for the Commission to authorize it to construct alternative transmission facilities that would eliminate or reduce the costs of Network Upgrades? REQUEST NO.9: What is the basis for requiring a 50% mechanical availability guarantee in Section 14 of the Settlement Stipulation, rather than some higher percentage such as the 85% that is being proposed in Case No. IPC-07-04? REQUEST NO. 10: How is Idaho Power proposing to determine mechanical availability in hours when there is little or no wind? How will Idaho Power determine the capacity available to generate in each hour when the wind is blowing? Please provide numerical examples to illustrate your answers. REQUEST NO. 11: Please explain why Idaho Power believes it is appropriate to pay full, published avoided cost rates for power received for projects subject to redispatch. redispatch is necessary at a time when Idaho Power is unable to meet load using its own resources and must make off-system purchases at costs above avoided cost rates, does Idaho Power believe that it should pay those higher costs and impose no penalty on the projects being redispatched? REQUEST NO. 12: Please explain in detail what criteria have been used in determining the available transmission capacity for each phase under the redispatch scenario, as opposed to the available transmission capacity under no redispatch. Please cite and provide a copy of any reliability criteria used as a basis for determining capacity under the redispatch scenario. FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 19 2007 REQUEST NO. 13: What level of subscription would be required before Idaho Power would proceed with a phase of transmission upgrade? For example, referencing Table B-6 of Exhibit B, would all projects 135-170 have to commit before Phase 5 would be initiated? projects 135 and 136 committed, but projects 154-170 did not, for example, would Idaho Power initiate Phase 5 and allocate all of the costs for Phase 5 to projects 135 and 136? REQUEST NO. 14: If a lower project in the queue is ready to proceed to construction much sooner than higher projects in the queue, how will its share of costs be allocated? For example, referring to Table B-6 of Exhibit B, what costs would be allocated to project number 170 ifit was ready to proceed with construction and none of the other projects in Phase 5 were ready to proceed? DATED at Boise, Idaho, this ICJ day of June 2007. Scott Woodbury Deputy Attorney General Technical Staff: Rick Sterling i :umisc:prodreqlipceO6.21 swrps ipc 1 FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY JUNE 19 2007 CERTIFICATE OF SERVICE HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF JUNE 2007 SERVED THE FOREGOING FIRST 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: DEAN J. MILLER McDEVITT & MILLER LLP PO BOX 2564 BOISE ID 83701 RONALD K ARRINGTON ASSOc. CHIEF COUNSEL JOHN DEERE CREDIT 6400 NW 86TH ST JOHNSTON IA 50131 BARTON L KLINE LISA NORDSTROM IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 DAVID SIKES IDAHO POWER COMPANY PO BOX 70 BOISE ID 83707-0070 DAVID J MEYER SENIOR VICE PRESIDENT A VISTA UTILITIES PO BOX 3727 SPOKANE W A 99220 BRIAN DICKMAN DEAN S BROCKBANK ROCKY MOUNTAIN POWER 201 S MAIN ST SUITE 2300 SALT LAKE CITY UT 84111 PETER J RICHARDSON RICHARDSON & O'LEARY PO BOX 7218 BOISE ID 83702 LAWRENCE R LIEB EXERGY DEVELOPMENT GROUP OF IDAHO LLC 910 W MAIN ST SUITE 310 BOISE ID 83702 R. BLAIR STRONG PAINE HAMBLEN ET AL STE 1200 717 W SPRAGUE AVE SPOKANE WA 99201 --b SECRET CERTIFICATE OF SERVICE