20070131IPC to Staff 1-20, 22-23, 25, 28, 30-32, 34-36.pdf

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IDAHO~POWER~
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Monica B. Moen
Attorney II
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January 31 , 2007
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-
In the Matter of the Application of Idaho Power Company for an Accounting
Order Authorizing the Inclusion of Power Supply Expenses Associated With
the Purchase of Capacity and Energy From Telocaset Wind Power Partners
LLC in the Company s Power Cost Adjustment
Dear Ms. Jewell:
Please find enclosed for filing an original and two (2) copies of Idaho Power
Company Partial Response to the First Production Request of Commission Staff
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
~- ~,
Monica B. Moen
MBM
Enclosures
O. Box 70 (83707)
1221 W. Idaho St.
Boise, ID 83702
MONICA MOEN ISB # 5734
BARTON L. KLINE ISB # 1526
Idaho Power Company
P. O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
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UTiLITIES CQ;\:iHiSSiC
Attorneys 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 APPROVAL OF A
POWER PURCHASE AGREEMENT
WITH TELOCASET WIND POWER
PARTNERS, LLC AND TO INCLUDE
THE ASSOCIATED EXPENSES IN THE
COMPANY'S ANNUAL POWER COSTADJUSTMENT.
CASE NO. IPC-06-
IDAHO POWER COMPANY'
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE
COMMISSION STAFF
COMES NOW, Idaho Power Company ("Idaho Power" or "the Company") and, in
response to the First Production Request of the Commission Staff to Idaho Power
Company dated January 19, 2007, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page
REQUEST FOR PRODUCTION NO.1: Please provide a copy of the 2005 RFP
Evaluation Manual.
RESPONSE TO REQUEST NO.1: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 2
REQUEST FOR PRODUCTION NO.2: Please provide a summary list showing
those persons or firms who submitted Notices of Intent to Bid forms.
RESPONSE TO REQUEST NO.2: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, prepared by Tom Noll , Customer Load and Research Leader, Idaho
Power Company, in consultation with Monica Moen , Attorney II , Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 3
REQUEST FOR PRODUCTION NO.3: Please make available for review all
proposals submitted in response to the 2005 RFP.
RESPONSE TO REQUEST NO.3: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 4
REQUEST FOR PRODUCTION NO.4: Please provide a copy of any preliminary
cost estimate summaries used for PPA comparisons.
RESPONSE TO REQUEST NO.4: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices.
The response to this request was prepared by Tom Noll, Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 5
REQUEST FOR PRODUCTION 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 PPA price and any
associated pricing details , and the totallevelized cost per MWh reflecting updated pricing.
RESPONSE TO REQUEST NO.5: Please refer to the response to Request for
Production No.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 6
REQUEST FOR PRODUCTION NO.Please provide a copy of any wind
evaluation summaries used to compare bids.
RESPONSE TO REQUEST NO.6: Garrad-Hassan America , Inc. performed wind
evaluations on the proposals submitted by the short-listed bidders. That confidential
information is available for examination in the Idaho Power Company Legal Department
located in the Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 7
REQUEST FOR PRODUCTION NO.Please provide any bid evaluation
summaries prepared by Garrad-Hassan. Provide any reports prepared by Garrad-Hassan
for each short-listed proposal reviewing the predicated energy production of each project.
RESPONSE TO REQUEST NO.7: Please refer to the Response to Request for
Production No.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, in consultation with Monica Moen , Attorney II , Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 8
REQUEST FOR PRODUCTION NO.8: Please provide an electronic copy of all
spreadsheets used to compute levelized costs and to make a cost comparison of the bids.
RESPONSE TO REQUEST NO.An electronic copy of the confidential
information requested is provided herewith and is labeled
, "
Response to Request for
Production No.
The response to this request was prepared by Randall Henderson , Business
Analyst, Idaho Power Company in consultation with Monica Moen, Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 9
REQUEST FOR PRODUCTION NO.9: Please provide a summary of the Stage
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 1 Screening scores.
RESPONSE TO REQUEST NO.9: Idaho Power s 2005 Wind RFP Evaluation
Team performed the Stage 1 Screening on all of the proposals submitted in response to
the RFP. A financial review of the proposals indicated that the proposals could be
grouped into two categories based on pricing. The proposals from four bidders were
selected for additional analysis as part of the RFP "short-list."Please refer to the
Response to Production Request No.4 for the confidential pricing summary information
requested.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 10
REQUEST FOR PRODUCTION NO.1 0: 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.
RESPONSE TO REQUEST NO.1 0: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices. Please note that, during negotiation of the PPA, updated
pricing information received from Telocaset Wind Power Partners , LLC made that
bidder s 100 MW offer more competitive than its original 66 MW offer.
The response to this request was prepared by Tom Noll, Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 11
REQUEST FOR PRODUCTION NO. 11: Please provide a copy (electronic if
available) of any sensitivity analysis that was performed to evaluate proposals in the Stage
2 Screening.
RESPONSE TO REQUEST NO. 11: Please refer to the Response to Request for
Production No.1 O. Idaho Power did not perform any formal sensitivity analyses during the
bid evaluation process.
The response to this request was prepared by Tom Noll , Customer Load
and Research Leader, Idaho Power Company, in consultation with Monica Moen
Attorney Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 12
REQUEST FOR PRODUCTION NO. 12: Please provide information 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.
RESPONSE TO REQUEST NO. 12:Idaho Power Company requested price
updates from the proposals throughout the course of the RFP evaluation process. The
final request for price updates was sent to selected bidders via e-mail on June 20, 2006. A
copy of that e-mail is attached hereto as "Response to Request for Production No. 12.
Idaho Power incorporated the information received in response to the bid update
request in its final evaluation and is reflected in the Stages 2 and 3 bid evaluation scoring
spreadsheet. Please refer to the Response to Request for Production No.1 O.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 13
REQUEST FOR PRODUCTION NO. 13: Please provide a copy of any analysis
performed as part of the bid evaluation comparing the expected seasonal generation
output for short-listed proposals to Idaho Power s seasonal load shape.
RESPONSE TO REQUEST NO. 13: The confidential information was prepared
by Garrad-Hassan America, Inc. That analysis included a comparison of the projected
generation from the proposals with the Company s seasonal requirements. Please refer
to the Response to Request for Production No.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 14
REQUEST FOR PRODUCTION NO. 14: If any short-listed bidders voluntarily
withdrew projects from further consideration , please state the reasons for withdrawal.
RESPONSE TO REQUEST NO. 14: One short-listed bidder withdrew its proposal
from further consideration on June 20, 2006 via a telephonic voice mail message to Idaho
Power. A transcript of this confidential information is available for examination in the
Idaho Power Company Legal Department located in the Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen, Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 15
REQUEST FOR PRODUCTION NO. 15:Please provide analysis to support
continued use in this agreement of the same seasonalization adjustment factors as are
currently being used for PURPA agreements.In the analysis, provide support or
justification for each of the months included in each of the three seasons.
RESPONSE TO REQUEST NO. 15: The following are the seasonal factors
contained within the Telocaset PPA:
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dee
100.00%
100.00%
73.50%
73.50%
73.50%
100.00%
120.00%
120.00%
100.00%
100.00%
120,00%
120.00%
The seasonal factors within this agreement duplicate the seasonal factors that
are currently being used in new Idaho Power PURPA agreements.The current
assignment of these seasonal factors to the various months was first used in the Tiber
Firm Energy Sales agreement that was approved in Commission Order 29232 , dated
April 28, 2003.
The Company s 2004 and 2006 Integrated Resource Plans identify that Idaho
Power continues to experience both summer and winter peaks. The various seasonal
factors and assignment to specific months is consistent with current PURPA
agreements , they reflect the summer and winter peaking nature of Idaho Power energy
requirements and provide an incentive for the project to be available during these
periods. Likewise, the reduced prices during March , April and May should provide
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 16
incentive for scheduling maintenance outages during these months.
The response to this request was prepared by Randy Allphin , Power Supply
Planning Administration , Idaho Power Company, in consultation with Monica Moen
Attorney II , Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 17
REQUEST FOR PRODUCTION 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 ability to transmit
power form 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.
RESPONSE TO REQUEST NO. 16: A copy of the Feasibility Study Report for
each short-listed proposal is included with each bidder s proposal. That confidential
information is available for examination in the Idaho Power Company Legal Department
located in the Company s corporate offices. A copy of the confidential Facilities Study
prepared for the Telocaset project is also available for examination in the Idaho Power
Legal Department located in the Company s corporate offices. Please also refer to the
Response to Production Request No. 17.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen, Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 18
REQUEST FOR PRODUCTION 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?
RESPONSE TO REQUEST NO. 17: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 19
REQUEST FOR PRODUCTION NO. 18: Has a Large Generator Interconnection
Agreement been negotiated and signed for the project? If so, please provide a copy.
RESPONSE TO REQUEST NO. 18: Idaho Power Company s transmission group
has provided Telocaset representatives with a draft Large Generator Interconnection
Agreement ("LGIA"copy of that confidential draft agreement is available for
examination in the Idaho Power Company Legal Department located in the Company
corporate offices.
On January 23, 2007 , Telocaset representatives met with representatives of the
Company s transmission group to discuss the draft LGIA. Telocaset intents to submit
proposed revisions to the draft LGIA to Idaho Power s transmission group the week of
January 29 2007. The parties expect to finalize the document within the next few weeks.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 20
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST NO. 19: Idaho Power Company s transmission group
intends to designate the first 66 MW of capacity from the Telocaset project as a network
resource. Because of that designation , firm transmission rights will be attributed to the first
66 MW of capacity from that wind facility. The cost of the network upgrades necessary to
acquire 66 MW of firm transmission rights are expected to cost approximately $3.5 Million.
The cost of those improvements will be borne by Telocaset but are subject to
reimbu rsement.
According to the Interconnection Feasibility Study prepared by the Company
transmission analysts for the Telocaset project, transmission upgrades required for the full
100 MW of capacity from the Telocaset wind project are estimated to cost approximately
$25 Million. Please refer to the Response to Request No. 16.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 21
REQUEST FOR PRODUCTION NO. 20: Please explain why Telocaset is only
responsible for network upgrade costs for the first 66 MW of capacity.
RESPONSE TO REQUEST NO. 20: Please refer to the Response to Request for
Production No. 19.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen, Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF , Page 22
REQUEST FOR PRODUCTION NO. 22:Please provide any estimates of
interconnection costs that were made for the short-listed proposals.
RESPONSE TO REQUEST NO. 22: The 2005 Wind RFP Evaluation Team used
the Large Generator Interconnection Feasibility Studies prepared for each of the short-
listed bidders to compare the transmission costs for these proposals. Please refer to the
Response to Request for Production No. 16.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen, Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 23
REQUEST FOR PRODUCTION NO. 23: Please list and describe any permits that
must be obtained for the Telocaset project to be constructed and describe the status of
those permits.
RESPONSE TO REQUEST NO. 23:A copy of the confidential information
requested is available for examination in the Idaho Power Company Legal Department
located in the Company s corporate offices.
The response to this request was prepared by Monica Moen , Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 24
REQUEST FOR PRODUCTION NO. 25:Please discuss any
consequences or implications if T elocaset Wind Power Partners LLC or Horizon Wind
Energy is sold to another owner.
RESPONSE TO REQUEST NO. 25: Article 25 of the Telocaset PPA sets forth the
credit requirements of the new owner should Telocaset Wind Power Partners LLC assign
the PPA to either an affiliate of Telocaset or to a third party. Should Telocaset assign the
PPA to an affiliate , the affiliate or its guarantor must meet the credit requirements originally
set forth for Telocaset's Guarantor , Goldman Sachs Group, Inc. In the event Telocaset
should assign the PPA to a third party, certain requirements set forth in Article 25.4.3 of
the PPA have to be satisfied, including the minimum credit requirements set forth for
Telocaset's Guarantor.
The response to this request was prepared by Monica Moen , Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 25
REQUEST FOR PRODUCTION NO. 28: Please provide the estimated generation
amounts by month for each year of the Agreement.
RESPONSE TO REQUEST NO. 28: The confidential information requested is
available for examination in the Idaho Power Company Legal Department located in the
Company s corporate offices.
The response to this request was prepared by Tom Noll , Customer Load and
Research Leader, Idaho Power Company, in consultation with Monica Moen , Attorney
, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 26
REQUEST FOR PRODUCTION NO. 30: Please discuss the basis for the
damages and cap amounts for net energy shortfall as shown in Appendix F.
RESPONSE TO REQUEST NO. 30: In any bilateral agreement, the terms and
conditions of the agreement are negotiated by the parties to that contract. The liquidated
damage caps identified in Appendix F to the agreement were negotiated by Idaho Power
and Telocaset. The purchase price for the energy sold by the Telocaset project would
likely have been higher had Idaho Power negotiated damage caps higher than the
amounts identified in Appendix F.
Under the terms of the agreement, Idaho Power is only obligated to pay for energy
successfully delivered to the Company s point of delivery. However, if Telocaset fails to
deliver the established annual amount of energy to be produced and delivered to Idaho
Power s point of delivery, Telocaset is subject to liquidated damages.
The response to this request was prepared by Monica Moen , Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 27
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST NO. 31:Idaho Power and its customers are
advantaged by the energy forecasting information that Telocaset will provide the
Company. At its expense , Telocaset will provide, for the term of the PPA, forecasts of the
wind facility's hourly, daily, next day and next week generation amounts. Telocaset will
also provide monthly net energy targets on an annual basis. Should Telocaset default on
its obligations to provide forecasts consistent with good utility practices , Idaho Power may
invoke the provisions of Appendix E. As with the liquidated damages provisions of
Appendix F, the limits associated with Appendix E were negotiated by the parties to the
PPA.
The response to this request was prepared by Monica Moen , Attorney II, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 28
REQUEST FOR PRODUCTION NO. 32: Please discuss the basis for the required
Performance Assurance amounts as contained in Section 12.2 of the Agreement.
RESPONSE TO REQUEST NO. 32:Unlike its agreements with PURPA
developers, Idaho Power has secured certain performance assurances in the Telocaset
PPA. Under the terms of Article 12.2 of the PPA, Telocaset's obligations to Idaho Power
must be secured by one or a combination of assurances set forth in the agreement. The
amounts established in the PPA were negotiated by the parties. Higher amounts would
have increased Telocaset's risk of performance under the agreement. That elevated risk
to Telocaset would have manifested itself in increased prices for the energy delivered from
the facility to the Company.
The response to this request was prepared by Monica Moen, Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 29
REQUEST FOR PRODUCTION NO. 34: Please discuss the basis for the
Limitations on Sellers Damages amounts as contained in Section 21.5 of the Agreement.
RESPONSE TO REQUEST NO. 34: The limitations on Telocaset's potential
damages as contained in Article 21.5 of the PPA were negotiated by the parties. The
limits established in the agreement were the maximum amounts agreeable to the parties
without affecting the cost of the purchase price for the energy produced by the Telocaset
facility.
The response to this request was prepared by Monica Moen, Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 30
REQUEST FOR PRODUCTION NO. 35:Please discuss the basis for the
termination payment amounts as contained in Sections 22., 22.2 and 22.3 of
the Agreement.
RESPONSE TO REQUEST NO. 35:At the time the T elocaset PP A was
negotiated by the parties, Federal Production Tax Credits (PTCs) were only available until
the end of December 2007. To take advantage of those tax credits that would benefit both
parties, Telocaset and Idaho Power agreed that the wind facility should be placed in
service before expiration of the Federal PTCs in December 2007. To meet this operation
date it was necessary for Telocaset to make certain financial commitments and
expenditures during the period between the date the PPA was executed by the parties and
the date of consideration of the PPA by the Commission.
To this end , Idaho Power agreed to reimburse Telocaset for certain documented
expenditures up to an established amount in the event Idaho Power elected to terminate
the PPA for lack of Commission approval of the agreement by February 28, 2007. If
approval of the PPA is not obtained from the Commission and Idaho Power terminates the
agreement with Telocaset, right, title and interest in the assets acquired by Telocaset
pursuant to the PPA will be transferred to Idaho Power.
Although the Federal PTCs have been extended through 2008 , Telocaset and
Idaho Power continue to anticipate that the project will be operational by year end 2007.
The response to this request was prepared by Monica Moen , Attorney II , Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF , Page 31
REQUEST FOR PRODUCTION NO. 36: Please describe what happens to the
performance assurance guaranty if Horizon is sold by Goldman Sachs.
RESPONSE TO REQUEST NO. 36: Telocaset Wind Power Partners , LLC is a
subsidiary of Horizon Wind Energy LLC. Goldman Sachs Wind Holdings, LLC is the
parent company of Horizon Wind Energy, LLC. Should Goldman Sachs sell its interests in
either Horizon Wind Energy, LLC and/or Telocaset Wind Power Partners , LLC , Goldman
Sachs could include the Telocaset/ldaho Power PPA in the sale of the assets of
Telocaset. In that event, the rights, title and interest in the Telocaset PPA would have to
be assigned to the new owner. Article 25.4 of the PPA establishes that either the new
owner or its guarantor must meet the credit requirements originally set forth for Goldman
Sachs, Telocaset's guarantor.
The response to this request was prepared by Monica Moen , Attorney II , Idaho
Power Company.
DATED at Boise, Idaho , this 31st day of January 2007.
Id-
MONICA B. MOEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 32
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 31st day of January 2007, I served a true and
correct copy of the within and foregoing upon the following named parties by the
method indicated below , and addressed to the following:
Donovan E. Walker
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington Street
Post Office Box 83720
Boise , Idaho 83720-0074
) U.S. Mail, Postage Prepaid
(X) Hand Delivered
) Overnight Mail
) Facsimile
(X) Email donovan.walkerCtYpuc.idaho.qov
(/J-
Monica B. Moen
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF, Page 33
IDAHO POWER COMPANY
CASE NO. IPC-O6-
FIRST PRODUCTION REQUEST
OF COMMISSION STAFF
RESPONSE TO
REQUEST NO.
Noll, Tom
From:
Sent:
Subject:
Noll, Tom
Tuesday, June 20, 2006 1 :31 PM
Idaho Power Company Wind RFP - Final Call
Greetings:
The deadline to submit any proposal revisions or updates has been extended to the close of business on Monday, June
26, 2006. You may submit proposal updates or revisions via email. Idaho Power Company anticipates no further
extensions and Idaho Power Company intends to conclude the selection process based on information submitted no later
than the close of business on Monday June 26, 2006.
Please carefully review your proposal and the Large Generator Interconnection Feasibility Study Report for your project.
Please be certain that you have included the correct substation and interconnection costs in your proposal and in your
pricing. Be sure to identify and quantify any interconnection cost differences between your proposal and the Large
Generator Interconnection Feasibility Study Report. The Wind RFP identifies the interconnection information requirements
on page 26 of the RFP document:
2. Proposal prices must reflect and explicitly identify any and all costs that Respondent expects Idaho Power
Company to pay for power delivered to the Idaho Power Company transmission system...
Please direct all questions and comments regarding the Wind RFP to Tom Noll at Idaho Power Company.
Best Regards
T om Noll
Idaho Power Company
208-388-2623