HomeMy WebLinkAbout20090416IPC to Staff 33-35.pdf$SIDA~POR~
An IDACORP Company
BARTON L. KLINE
Lead Counsel
April 15, 2009
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-09-03
LANGLEY GULCH POWER PLANT
Dear Ms. Jewell:
Enclosed for filing are an original and three (3) copies of the fourth portion of Idaho
Power Company's responses to the Commission Staffs First Production Request.
Also, enclosed are four (4) copies of a disk containing critical energy
infrastructure information and other confidential information in response to Staffs
production requests. Please note, this information should be handled in accordance with
the Protective Agreement.ve~~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (B3707)
1221 W. Idaho St.
Boise..ID 83702
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BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: 208-388-2682
Facsimile: 208-338-6936
bkline(gidahopower.com
Inordstrom(gidahopower.com
Z003 APR l 5 PM~: 46
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 IDAHO POWER
COMPANY'S APPLICATION FOR A
CERTIFICATE OF PUBLIC
CONVENIENCE AND NECESSITY FOR
THE LANGLEY GULCH POWER PLANT.
)
) CASE NO. IPC-E-09-03
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE COMMISSION
) STAFF'S FIRST PRODUCTION
) REQUEST TO IDAHO POWER
) COMPANY
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 March 25, 2009, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 1
REQUEST NO. 33: Please describe the transmission constraints that made it
desirable or necessary for Idaho Power to specify in the 2012 Baseload RFP that Idaho
Power is interested in proposals that can provide electric capacity to the Treasure
Valley load center. Provide copies of any analysis or transmission system studies in
which these constraints were identified and described.
RESPONSE TO REQUEST NO. 33: Idaho Powets 2006 Integrated Resource
Plan contains descriptive information and IRP analysis regarding Idaho Powets
transmission constraints. A description of the transmission constraints are located on
pages 20-23, a description of the IRP Transmission Forecast analysis are located on
pages 32-33, and the results are located on pages 41-42, each of which are included on
the enclosed CD. The Langley Gulch project transmission system impact study report,
provided in Response to Staffs Request No. 36, provides an analysis of the
transmission system upgrades required to reliably integrate the project into the
transmission system. The Company is also providing recently performed system impact
studies for generation interconnection projects that demonstrate the inability to
interconnect additional generation both east and west of the Treasure Valley without
transmission upgrades. These system impact studies contain Critical Energy
Infrastructure Information ("CEil") and are being provided to those parties that have
executed both the Nondisclosure Agreement and the Protective Agreement.
The response to this Request was prepared by Dave Angell, Manager, Delivery
Planning, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 2
REQUEST NO. 34: Please describe in detail any transmission system
improvements, upgrades or additions that have recently been made or are planned in
the general vicinity of the proposed Langley Gulch plant that are not contingent upon or
considered a part of the Langley Gulch plant. Provide a copy of any study or analysis
completed that recommended such improvements, additions or upgrades. For any
upgrades that have recently been completed, please provide records showing the total
costs for the improvements, additions or upgrades.
RESPONSE TO REQUEST NO. 34: In 2008, one project was completed in the
general vicinity of Langley Gulch. It increased the ampacity rating of the Ontario-
Brownlee 230 kV line series capacitor as identified in the Elkhorn Wind Project system
impact study report. The project increased the nominal rating from 1430 to 1589
amperes at a cost of $124,294. The above-referenced system impact study report
contains CEil and is being provided to only those parties that have executed both the
Nondisclosure Agreement and the Protective Agreement.
The response to this Request was prepared by Dave Angell, Manager, Delivery
Planning, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 3
REQUEST NO. 35: Please provide information supporting. the transmission
costs assumed by Idaho Power for each of the bids considered (Interconnection
Feasibility studies, System Impact studies, etc.).Include cost assumptions,
transmission losses, and any other transmission factors considered.
RESPONSE TO REQUEST NO. 35:The RFP bidders' generation
interconnection feasibility study reports and cost estimate spreadsheets contain CEil
and are being provided to those parties that have executed both the Nondisclosure
Agreement and the Protective Agreement.
The response to this Request was prepared by Dave Angell, Manager, Delivery
Planning, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
DATED at Boise, Idaho, this 15th day of April 2009.
,
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 15th day of April 2009 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Scott Woodbury
Deputy Attomey General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 2th Street
P.O. Box 7218
Boise, Idaho 83702
Dr. Don Reading
Ben Johnson Associates
6070 Hil Road
Boise, Idaho 83703
Invenergy Thermal Development
LLC
Dean J. Miler
McDEVITT & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, Idaho 83701
Wiliam Borders
Assistant General Counsel
Invenergy Thermal Development LLC
One South Wacker Drive, Suite 1900
Chicago, Ilinois 60606
Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 5
Idaho Irrigation Pumpers
Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391
201 East Center
Pocatello, Idaho 83204-1391
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Idaho Conservation League
Betsy Bridge
Idaho Conservation League
710 North Sixth Street
P.O. Box 844
Boise, Idaho 83701
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Qk~
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE COMMISSION
STAFF'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 6