20090420ICIP 1-36 to IPC.pdf

Peter J. Richardson ISB # 3195
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter(frichardsonandoleary.com
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Attorneys for the Industrial Customers of Idaho Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A CERTIFICATE OF
PUBLIC CONVENIENCE AND
NECESSITY FOR THE LANGLEY
GULCH POWER PLANT
) CASE NO. IPC-E-09-03
)
) FIRST PRODUCTION REQUEST OF
) THE INDUSTIAL CUSTOMERS OF
) IDAHO POWER
)
Pursuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), The Industrial Customers of Idaho Power ("ICIP") by and through their
attorney of record, Peter J. Richardson, hereby requests that Idaho Power Company
("Company") provide the following documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementar responses additional documents that it or any person acting
on its behalf may later obtain that wil augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreading(fmindspring.com
i -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
F or 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 at hearing who can sponsor the answer.
Some of the following requests may include disclosures deemed by Idaho Power to be
confidentiaL. Idaho Power, along with all other paries to this case, are reminded that the
Industrial Customers of Idaho Power have entered into and fied with the Commission on July 16
and 23,2008 the Protective Agreement in connection with this case IPC-E-08-10.
REQUEST FOR PRODUCTION NO.1:
Please provide the results of the final cost model ru performed for the selected Langley
Gulch project. Results should include:
A. Load factor and/or the hours the unit is expected to be on line;
B. The times of the year when the unit is expected to be on line;
C. Variable costs associated with the unit's operation;
D. Full kwh cost of the unit;
E. Input assumptions used in the cost model rus (e.g. carying costs, fuel costs,
depreciation rates, O&M costs etc..);
F. The impact on hours of operation and costs of other Idaho Power generating units.
REQUEST FOR PRODUCTION NO.2:
Please explain in detail what plans the Company has to meet its loads that are assumed to
be met with Langley Gulch if either the financing canot be obtained or the Commission does
not approve the Company's proposed ratemaking treatment.
REQUEST FOR PRODUCTION NO.3:
2 -FIRST PRODUCTION REQUEST OF INDUSTRAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
Please provide any documents or research that the Company has evaluating or relating to
the potential for industrial combined heat and power projects in its service territory.
REQUEST FOR PRODUCTION NO.4:
Please describe any efforts Idaho Power has made to look into the use of virtal peakers
(i.e. emergency back-up generation installed throughout the region in commercial and industrial
facilities) to meet or reduce peak loads since it issued its RFP for the CCCT in this docket.
Please provide any analysis, documentation and/or correspondence.
REQUEST FOR PRODUCTION NO.5:
Please provide a copy of the RFP the Company issued to potential bidders that resulted in
the selection of the Langley Gulch project.
REQUEST FOR PRODUCTION NO.6:
In response to Staff First Production Request, #28, the Company stated:
Cash flow was not directly considered in the evaluation, however it did contribute
to the calculation of AFUDC costs which were included in the revenue requirement
calculations for the Benchmark Resource.
And,
The RFP team concluded that imputed debt costs would not be considered in the
evaluation unless it was expected to be a diferentiatingfactor between the proposals. At
the conclusion of the process, the cost diferential was suffcient that imputed debt was
not an issue.
Was a dollar amount assigned to either cash flow or imputed debt that could impact the
Company's financial ratings as outlined in Lori Smith's direct testimony? If so, please describe
3 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
in detail how the amounts were calculated. If not, please describe how the conclusion that it was
not an issue was made without a dollar amount comparison.
REQUEST FOR PRODUCTION NO.7:
On page 9 of his direct testimony, Karl Bokenkamp states:
The Proposal Evaluation Manual was finalized before any of the proposals were
received
Does his statement mean the Proposal Evaluation Manual was not finalized when the
RFP was developed and sent to prospective bidders?
REQUEST FOR PRODUCTION NO.8:
Did prospective bidders know the specific elements in the evaluation process and the
point factors for each element? Please explain fully..
REQUEST FOR PRODUCTION NO.9:
On page 7 of his direct testimony Karl Bokenkamp states, "Build-and-transfer proposals
were not considered in this RFP process." Please explain how the Company's Langley Gulch
project differs conceptully from a build-and-transfer proposal.
REQUEST FOR PRODUCTION NO. 10:
Why was Idaho Power the one entity allowed to submit a build-and-transfer proposal for
this RFP?
REQUEST FOR PRODUCTION NO. 11:
Please explain why including a "detailed specification" in the RFP would not ensure that
plants would meet Idaho Power's requirements for a build-and-transfer.
REQUEST FOR PRODUCTION NO. 12:
At page 8 of his direct testimony Karl Bokenkamp states:
4 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
Given the decision to accelerate the on-line date to 2012, information obtained regarding
critical equipment manufacturing lead times, and the aforementioned diferences in
project design, in the Company's opinion, it did not have enough time to prepare a
detailed design specifcation and release the RFP in time to meet the 2012 on-line date.
Does this mean the Langley Gulch facility does not have a "detailed design specification" at this
time?
REQUEST FOR PRODUCTION NO. 13:
Please explain how a neutral bidding evaluation can occur if bidders other than Idaho
Power were not allowed to offer projects without a "detailed design specification."
REQUEST FOR PRODUCTION NO 14:
On page of his direct testimony Karl Bokenkamp states:
The Benchmark Resource team's AFUDC estimate was calculated by applying a 7
percent annual capitalized interest charge to the funds spent on construction of the
project.
Please explain how the 7 percent capitalized interest charge was derived and what assumptions
were made in its calculation.
REQUEST FOR PRODUCTION NO. 15:
On page 12 of his direct testimony Karl Bokenkamp states that the AFUDC for the
Benchmark Resource is expected to total $49 millon. Was this value calculated under the
assumption of traditional ratemaking treatment by the IPUC?
REQUEST FOR PRODUCTION NO. 16:
If the Commission were to accept the Company's proposed treatment to include CWIP in
ratebase during construction, how would this impact the calculation of AFUDC? Please explain.
5 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
REQUEST FOR PRODUCTION NO. 17:
Please provide the workpapers, assumptions, and calculations of net present value for
each of the valid bids in electronic format.
REQUEST FOR PRODUCTION NO. 18:
On page 15 of his direct testimony Karl Bokenkamp states:
However, with the utilty-owned resource, any savings resulting from the Project
realizing a better that expected heat rate wil be shared with customers through the PCA.
Please explain the impact on customers for the utility-owned resource if the heat rate for Langley
Gulch is less than expected.
REQUEST FOR PRODUCTION NO. 19:
How many new customers, by class, did the Company add in 2008?
REQUEST FOR PRODUCTION NO. 20:
Given the current economic conditions, has the Company made any adjustments to its
load forecasts for the coming five years, and if so, what are those adjustments?
REQUEST FOR PRODUCTION NO. 21:
Has the Company considered delaying Langley Gulch due to the current economic crises,
or for any other reason, and if so please explain and document?
REQUEST FOR PRODUCTION NO. 22:
On pages 14 to 16 of Vernon Porter's direct testimony he provides an outline ofthe
governental permits that the Company must acquire for the Langley Gulch power plant. Please
provide for each ofthe actions listed by Mr. Porter the expenditures made to date and an estimate
of the expenditures the Company expects to incur between the curent date and the date of
expected IPUC approval of the plant.
6 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
REQUEST FOR PRODUCTION NO. 23:
Please provide all analysis, assumptions, workpapers and spreadsheets (in electronic
form) that were used to develop Exhibit 7 attached to Lori Smith's testimony.
REQUEST FOR PRODUCTION NO. 24:
On page 9 of Vernon Porter's testimony he states that the Company has paid Siemens
$8.7 milion to reserve equipment. Please describe in detail what equipment has been reserved
and the final dollar cost for each piece of reserved equipment.
REQUEST FOR PRODUCTION NO. 25:
With respect to Siemens' business relationship with Idaho Power in general, please
provide copies of all correspondence between Siemens and Idaho Power over the last five years.
REQUEST FOR PRODUCTION NO. 26:
Please describe and document any advantages Idaho Power has realized for the Langley
Gulch project as a result of its having done business with Siemens in the past.
REQUEST FOR PRODUCTION NO. 27:
Please provide the Large Generator Interconnection Study Reports for Langley Gulch.
REQUEST FOR PRODUCTION NO. 28:
Please provide any generator interconnection study reports for Evander Andrews and
Bennett Mountain.
REQUEST FOR PRODUCTION NO. 29:
Did the Company evaluate expansion of either the Evander Andrews or Bennett
Mountain simple cycle units to combined-cycle units? If so, provide those evaluations. If not,
why not?
REQUEST FOR PRODUCTION NO. 30:
7 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
Did the company evaluate dry cooling versus wet cooling at Langley Gulch? Please
provide the results of that evaluation if it did so.
REQUEST FOR PRODUCTION NO. 31:
Please provide copies of all written and electronic correspondence between the Company
and the IPUC related to Senate Bil 1123 that was passed by the Idaho Legislature this year.
REQUEST FOR PRODUCTION NO. 32:
Given that Langley Gulch is planed to meet future load growth, please describe, in
detail, how recovery ofCWIP for that plant would benefit existing ratepayers. See Ric Gale's
direct testimony at p. 7.
REQUEST FOR PRODUCTION NO. 33:
Has the Company conformed to the Oregon competitive bidding requirements? If not,
please explain why not.
REQUEST FOR PRODUCTION NO. 34:
Does the Company anticipate that it wil request ratemaking treatment for its Oregon
share of the Langley Gulch project if the Idaho Commission approves its application in Idaho?
REQUEST FOR PRODUCTION NO. 35:
Does Idaho Power expect the Oregon Commission to approve Langley Gulch for
ratemakng puroses if the Company does not follow Oregon's proscribed Competitive Bidding
Guidelines?
REQUEST FOR PRODUCTION NO. 36:
Please provide all correspondence between Idaho Power and the Oregon Commission
relative to the ratemaking treatment of the Langley Gulch Plant in Oregon.
8 -FIRST PRODUCTION REQUEST OF INUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
DATED this 20th day of April, 2009.
RICHARDSON & O'LEARY PLLC
By fYJQ.~
Peter J. Richardson, ISB #3195
Attorneys THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER
9 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the20th day of April, 2009, a true and correct copy of the
within and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL
CUSTOMERS OF IDAHO POWER was served in the maner shown to:
Ms. Jean Jewell
Commission Secretary
Idaho Public Utilities Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
X- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Lisa Nordstrom
Baron L. Kline
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
Inordstrom(ßidahopower .com
bkline(ßidahopower. com
X- Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington
Boise ID 83702
Scott. woodbury(ßpuc.idaho.gov
L Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Dean J. Miler
McDevitt & Miler LLP
420 W. Banock St (83702)
PO Box 2564
Boise ID 83701
joe(ßmcdevittmiler .com
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
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Wiliam Borders
Assistant General Counsel
Invenergy Thermal Development LLC
One South Wacker Dr., Suite 1900
Chicago, IL 60606
wborders(ßinvenergyllc.com
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iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
10 -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03
Eric L. Olsen
Racine, Olson, Nye, Budge & Bailey, Chtd.
201 E. Center
PO Box 1391
Pocatello, ID 83204-1391
elo(ßracinelaw.net
_ Hand Delivery
iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Anthony Yanel
29814 Lake Road
. Bay Vilage, OH 44140
tony(ßyanel.net
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iU.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Ken Miler
Clean Energy Program Director
Snake River Allance
PO Box 1731
Boise, ID 83701
kmiler(ßsnakeriverallance.org
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iU.S. Mail, postage pre-paid
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Betsy Bridge
Idaho Conservation League
710 North Sixth Street (83702)
PO Box 844
Boise, ID 83701
bbridge(ßwildidaho.org
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Electronic Mail
~~\
Administrative Assistat
i i -FIRST PRODUCTION REQUEST OF INDUSTRIAL CUSTOMERS OF IDAHO POWER - IPC-E-09-03