20070904RNP-NWEC to IPC 1-3.pdf

William M. Eddie
610 SW Alder St. Suite 910
Portland, OR 97205
Jean Jewell, Commission Secretary
Idaho Public Utilities Commission
427 W. Washington St.
Boise, ID 83702-5983
Re: IPC-O7-
Dear Ms. Jewell:
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August 29, 2007
Please find enclosed for filing the three (3) copies of the First Production Requests of
Renewable Northwest Project and NW Energy Coalition. I have included a cover page of
this document to be conformed and returned to me. Thank you for your attention to this
matter.
Sincerely,
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William M. Eddie
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William M. Eddie (ISB #5800)
ADVOCATES FOR THE WEST
610 SW Alder St., Suite 910
Portland, OR 97205
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER
COMPANY'S PETITION TO INCREASE THE
PUBLISHED RATE ELIGIBILITY CAP FOR
WIND POWERED SMALL POWER
PRODUCTION FACILITIES; AND
TO ELIMIN ATE THE 90%/110%
PERFORMANCE BAND FOR WIND POWERED)
SMALL POWER PRODUCTION FACILITIES
CASE NO.IPC- E-07 -
PRODUCTION REQUESTS OF RENEWABLE NORTHWEST PROJECT AND
NW ENERGY COALITION TO IDAHO POWER COMPANY
Intervenors Renewable Northwest Project and NW Energy Coalition, by and through
counsel, request that Idaho Power Company ("Idaho Power" or "Company ) provide the
following information as soon as possible but no later than September 7, 2007.
These Production Requests are considered to be continuing, and the Company is
requested to provide, by way of supplementary responses , additional documents or information
that it or any person acting on its behalf may later obtain that will augment the information or
documents produced.
In answering each request, please provide the name of the person(s) preparing the
answers, along with the title and function such individual holds with Idaho Power and the
witness who can sponsor the answer at the hearing. The term "wind integration study" refers to
FIRST PRODUCTION REQUESTS OF RNP AND NWEC --
the study filed with the Idaho Public Utilities Commission on February 7, 2007, in support ofthe
Company s application in the above-captioned matter.
PRODUCTION REQUEST NO.1: Please provide copies of all written information
(including Powerpoint presentations and printed handouts) presented or otherwise provided to
attendees of the public workshops in the above-captioned matter held on March 15 and June 20
2007.
PRODUCTION REQUEST NO.2: Please identify all corrections, changes, or
amendments to the assumptions, data inputs, or methodologies used for the wind integration
study which Idaho Power Company believes are appropriate as of the current day, including
without limitation corrections, changes, or amendments related to (a) elimination of
inappropriate arbitrage opportunities between the west and east sides ofIdaho Power s system;
(b) the use of asymmetric up- and down-regulation reserve requirements; (c) regulatory reserve
requirements for high-resolution (less than O-minute) variability; (d) use of the Elkhorn
(Telocaset) wind project; (e) use of different or refined wind forecast techniques or assumptions;
(f) in the wind integration study "base case " any changes in the weighting of wind production in
high-load and low-load hours; (g) market price inputs for the low, median, and high water years
evaluated in the wind integration study; and (h) use of coal-fired generation units or other
generation units for regulation. Please include a brief description of each correction, change, or
amendment.
PRODUCTION REQUEST NO.3: Please state the estimated impact to wind integration
costs caused by each correction, change, or amendment identified in response to Production
Request No., above; and please state Idaho Power s net current estimated cost of wind
integration.
FIRST PRODUCTION REQUESTS OF RNP AND NWEC n 2
DA TED this 29th day of August, 2007.
William M. Eddie
On behalf of RNP and NW Energy Coalition
CERTIFICATE OF SERVICE
I hereby certify that on this 29TH day of August 2007, true and correct copies of
the foregoing FIRST PRODUCTION REQUESTS OF RNP AND NW ENERGY
COALITION were delivered to the following persons via u.s. Mail:
Jean Jewell (3 copies)
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID 83702
Brian Dickman
Rocky Mountain Power
20 I S. Main Street, Suite 2300
Salt Lake City, UT 84111
Barton Kline (email copy also provided)
Monica Moen
Idaho Power Company
O. Box 70
Boise, ID 83707-0070
Rich Rayhill
Ridgeline Energy, LLC
720 W. Idaho Street, Suite 39
Boise, ID 83702
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, 10 83702
Robert M. Ellis, Esq.
4 Nickerson, Suite 301
Seattle, W A 98109
Peter Richardson
Richardson & O'Leary
O. Box 1849
Eagle, ID 83703
Glenn Ikemoto
Idaho Windfarrns, LLC
672 Blair Avenue
Piedmont, CA 94611
Don Reading
6070 Hill Road
Boise, ID 83703
Dean J. Miller, Esq.
McDevitt & Miller, LLP
PO Box 2564
Boise, 10 83701
Dean Brockbank
Rocky Mountain Power
201 S. Main Street, Suite 2300
Salt Lake City, UT 84111
Ronald K. Arrington
Associate Chief Counsel
John Deere Renewables, LLC
6400 NW 86th Street
PO Box 6600
Johnston, IA 50131
FIRST PRODUCTION REQUESTS OF RNP AND NWEC n 3
R. Blair Strong
Paine Hamblen, LLP
717 W. Sprague, Suite 1200
Spokane, W A 99220
Michael G. Andrea
Staff Attorney
A vista Corporation
PO Box 3727
Spokane, W A 99220-3727
Ken Miller
Snake River Alliance
PO Box 1731
Boise, ID 83701
Gerald Fleischman
11535 W. Hazeldale Ct.
Boise, ID 83713
Brian D. Jackson
Renaissance Engineering & Design
2792 Desert Wind Rd.
Oasis, 10 83647-5020
M. 1. Humphries
Blue Ribbon Energy, LLC
2630 Central Ave.
Idaho Falls, ID 83406
Gary Seifert
Kurt Myers
INL Biofuels & Renewable Energy
Technologies
PO Box 1625 , MS 3810
Idaho Falls, ID 83415-3810
William M. Eddie
FIRST PRODUCTION REQUESTS OF RNP AND NWEC -- 4