20070119Staff to IPC 1-36.pdf

DONOVAN E. WALKER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5921
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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 APPROV AL )
OF A POWER PURCHASE AGREEMENT WITH)
TELOCASET WIND POWER PARTNERS, LLC
AND TO INCLUDE THE ASSOCIATED
EXPENSES IN THE COMPANY'S ANNUAL
POWER COST ADJUSTMENT.
CASE NO. IPC-06-
FIRST 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 (Idaho
Power; Company) provide the following documents and infonnation as soon as possible, but no
later than FRIDAY, FEBRUARY 9, 2007.
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.
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 JANUARY 19 2007
REQUEST NO.1: Please provide a copy of the 2005 RFP Evaluation Manual.
REQUEST NO.2: Please provide a summary list showing those persons or finns who
submitted Notices of Intent to Bid fonns.
REQUEST NO.3: Please make available for review all proposals submitted in response
to the 2005 RFP.
REQUEST NO.4: Please provide a copy of any preliminary cost estimate summaries
used for PP A comparisons.
REQUEST NO.5: Please provide the Short-listed Bids PPA Comparisons. Include a
summary showing for each short-listed bid the capacity, the annual energy output, the assumed
transmission cost, the quoted PP A price and any associated pricing details, and the totallevelized
cost per MWh reflecting updated pricing.
REQUEST NO.6: Please provide a copy of any wind evaluation summaries used to
compare bids.
REQUEST NO.7: Please provide any bid evaluation summaries prepared by Garrad-
Hassan. Provide any reports prepared by Garrad-Hassan for each short-listed proposal reviewing
the predicted energy production of each project.
REQUEST NO.8: Please provide an electronic copy of all spreadsheets used to
compute levelized costs and to make a cost comparison of the bids.
REQUEST NO.9: Please provide a summary of the Stage 1 Screening scores for all of
the proposals. Include any written explanation for the scores that were awarded to each
proposal. Identify all proposals eliminated from further consideration as a result of Stage
Screening scores.
FIRST PRODUCTION REQUEST
TO IDAHO POWER JANUARY 19 2007
REQUEST NO. 10: Please provide a summary of the Stage 2 Screening scores for all of
the proposals considered in Stage 2. Include any written explanation for the scores that were
awarded to each proposal. Include scores, and written explanations and spreadsheets if any, for
all non-price categories. In addition, include scores awarded to each proposal for wind energy
evaluation criteria.
REQUEST NO. 11: Please provide a copy (electronic if available) of any sensitivity
analysis that was perfonned to evaluate proposals in the Stage 2 Screening.
REQUEST NO. 12: Please provide infonnation showing the amount and date of any
updated prices that may have been considered in the proposal analysis. .For any updated prices
that may have been considered, show or explain how any evaluation scores may have changed.
REQUEST NO. 13: Please provide a copy of any analysis perfonned as part of the bid
evaluation comparing the expected seasonal generation output for short-listed proposals to Idaho
Power s seasonal load shape.
REQUEST NO. 14: If any short-listed bidders voluntarily withdrew projects from
further consideration, please state the reasons for withdrawal.
REQUEST NO. 15: Please provide analysis to support continued use in this agreement
of the same seasonalization adjustment factors as are currently being used for PURP A
agreements. In the analysis, provide support or justification for each of the months included in
each of the three seasons.
REQUEST NO. 16: Please provide a copy of any transmission studies (Interconnection
Feasibility Study, System Impact Study, or Facilities Study) completed for short-listed projects
to assess the Company s ability to transmit power from the project site to Idaho Power s system
to identify any transmission constraints, and to identify and estimate the costs of any necessary
transmission system upgrades.
FIRST PRODUCTION REQUEST
TO IDAHO POWER JANUARY 19 2007
REQUEST NO. 17: Has a System Impact Study been completed for the Telocaset
Project? If so, please provide a copy. If not, when is the study expected to be completed?
REQUEST NO. 18: Has a Large Generator Interconnection Agreement been negotiated
and signed for the project? If so, please provide a copy.
REQUEST NO. 19: Please explain why no network upgrades are required for the 34
MW increment of capacity and why Telocaset shall have no obligation to contract for or pay for
upgrade costs associated with the 34 MW increment.
REQUEST NO. 20: Please explain why Telocaset is only responsible for network
upgrade costs for the first 66 MW of capacity.
REQUEST NO. 21: Will any of the network upgrade payments to be made by Telocaset
be subject to refund or reimbursement? Is so, please describe how the reimbursement will be
made.
REQUEST NO. 22: Please provide any estimates of interconnection costs that were
made for the short-listed proposals.
REQUEST NO. 23: Please list and describe any pennits that must be obtained for the
Telocaset project to be constructed and describe the status ofthose pennits.
REQUEST NO. 24: Will there be any costs that Idaho Power will incur in order to
make use of the forecasts provided for the Telocaset project? If so, please describe and estimate
those costs.
REQUEST NO. 25: Please discuss any consequences or implications if Telocaset Wind
Power Partners LLC or Horizon Wind Energy is sold to another owner.
FIRST PRODUCTION REQUEST
TO IDAHO POWER JANUARY 19 2007
REQUEST NO. 26: What is Idaho Power s most recent forecast of expected finn
wholesale electric energy prices for the next five and ten-year periods for heavy and light load
hours? Please identify the source and date on which the forecasts were made.
REQUEST NO. 27: Please provide estimates of the timing, frequency and duration of
expected curtailmeni under Section 9.22 of the Telocaset Agreement for: a) the first 66 MW of
generation capacity, and b) the next 34 MW increment of generation capacity. Also provide
copies of any written or electronic communications between Idaho Power and Horizon
concerning the timing, frequency and duration of expected curtailment due to transmission
constraints.
REQUEST NO. 28: Please provide the estimate generation amounts by month for each
year of the Agreement.
REQUEST NO. 29: What does Idaho Power intend to do with the Environmental and
Renewable Energy credits from the project? What is the estimated value of the credits?
REQUEST NO. 30: Please discuss the basis for the damages and cap amounts for net
energy shortfall as shown in Appendix F.
REQUEST NO. 31: Please explain the basis for the Aggregate Price Adjustment limit
associated with Appendix E and the limit on the aggregate amount of an Aggregate Price
Adjustment when combined with any Net Energy Shortfall Damages.
REQUEST NO. 32: Please discuss the basis for the required Perfonnance Assurance
amounts as contained in Section 12.2 of the Agreement.
REQUEST NO. 33: Please discuss the basis for the Delay Damage amounts as
contained in Section 21.4 of the Agreement.
FIRST PRODUCTION REQUEST
TO IDAHO POWER JANUARY 19 2007
REQUEST NO. 34: Please discuss the basis for the Limitations on Sellers Damages
amounts as contained in Section 21.5 of the Agreement.
REQUEST NO. 35: Please discuss the basis for the tennination payment amounts as
contained in Sections 22., 22.2 and 22.3 of the Agreement.
REQUEST NO. 36: Please describe what happens to the perfonnance assurance
guaranty if Horizon is sold by Goldman Sachs.
DATED at Boise, Idaho, this 1% day of January 2007.
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreg/ipceO6.31dwrpskls prod reg 1
FIRST PRODUCTION REQUEST
TO IDAHO POWER JANUARY 19 2007
CERTIFICATE OF SERVICE
HEREBY CERTIFY THAT I HAVE THIS 19TH DAY OF JANUARY 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:
MONICA B MOEN
BARTON L KLINE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
JIM MILLER
RIC GALE
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
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SECRETARY
CERTIFICATE OF SERVICE