20090423Invenergy 1-50 to IPC.pdf

McDevitt & Miller LLP
Lawyers
'" r,~~l"~ ',-,
[phone]
[phone] (Fax)
420 W. Bannock Street
P.O. Box 2564.83701 2009 ~lR 23 Pt~ 3: 06 Chas. F. McDevitt
Boise, Idaho 83702 Dean J. (Joe) Miler
Apri 23, 2009
Via Hand Delvery
Jean Jewell Secreta
Idao Public Utities Commssion
472 W. Washigton St.
Boise, Idaho 83720
Re: Invenergy Thermal Development LLC
Case No. IPC-E-09-03
Dear Ms. Jewell:
Enclosed for fig in the above matter please fid an orial and thee (3) copies of Invenergy Therm
Development's First Production Requests to Idaho Power Company.
An additional copy of the docuent and ths letter is included for retu to me with your fie stap thereon.
Very Truy Yours,
Çi~LLPDean J. Mier
DJM/hh
Enclosures
ORIGINAL
Dean J. Miler (ISB No. 1968)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. BOX 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
joecæmcdevitt-miler.com
("',:i~i...; h,'"_'; C'.
ZOû9APR 23 PH 3: 06
Attorney for Invenergy Thermal Development LLC
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
INVENERGY THERMAL
DEVELOPMENT LLC'S FIRST
DISCOVERY REQUESTS
Pursuat to RP 221-229, Invenergy Thermal Development LLC propounds the
following Discovery Requests to Idaho Power Company.
For each Response please include the name and phone number of the person preparng
the document, and the name, location and phone number of the record holder and the name of
persons who will be able to answer questions about the response at hearg.
This Discovery Request is to be considered as continuing, and Idao Power Company is
requested to provide, by way of supplementa responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
If you believe that a Discovery Request contaned herein has been fuly answered by a
Response to Staffs Production Requests dated March 25,2009, you may answer requests
contaned herein by reference to a previous answer to Sta s requests.
INVENERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 1
As used herein "wrtten communcation" includes all notes, memorandums, and letters
whether in paper or electronic format.
The following Discovery Requests relate to the Direct Testimony of Mr. Vernon Porter
(DTVP).
REOUEST NO.1: Please provide a copy of the job description for General Manager of
Power Production. (DTVP pg. 1).
REOUEST NO.2: Please provide an organzational char showig the reporting chai
of General Manager of Power Production. (DTVP pg. I).
REOUEST NO.3: Please provide the name, job title and job description of each
member of the "Benchmark Resource Team". (DTVP pg. 2).
REOUEST NO.4: Please provide the name, job title and job description for each
member of Idaho Power's Power Production group. (DTVP pg. 4).
REQUEST NO.5: Please provide the name, job title and job description of each
member of the Company's Land Management, Legal, Environmenta and Water Management
Deparents who provided assistace to the Benchmark Resource Team. (DTVP pg. 5).
REQUEST NO.6: Please provide a description of the assistace provided to the
Benchmark Resource Team by each person identified in your answer to Interrogatory NO.3.
(DTVP pg. 5).
REQUEST NO.7: Please provide a copy of the Option to Purchase Land. (DTVP pg.
6).
REQUEST NO.8: Please provide a copy of the Contract to Purchase Water Rights from
Cottonwood Irrigation Distrct. (DTVP pg. 8).
INENERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 2
REQUEST NO.9: Please provide a copy of the Siemans' Reservation Agreements.
(DTVP pg. 8).
REQUEST NO. 10: If different from the Reservation Agreements, please provide
copies offinal contracts relating to the purchase ofSiemans' equipment. (DTVP pg. 9).
REQUEST NO. 11: In negotiations or discussions with Siemans regarding price and
contract terms for equipment for the Langley Gulch project, were any issues related to the
operation or contractu obligations regarding Siemans' equipment located at other Idaho Power
Company generation projects taken into account? (DTVP pg. 9).
REQUEST NO. 12: If your answer to the preceding Request is "Yes" please provide a
complete description and provide any wrtten correspondence documenting the same. (DTVP
pg.9).
REQUEST NO 13: Please provide a copy of the Memorandum of Understading with
the EPC joint ventue. (DTVP pg. 11).
REOUEST NO. 14: Please provide a copy of the final EPC contract. (DTVP pg. 12).
REQUEST NO. 15: Please provide a schedule showing preliminar engineering services
performed and amounts paid for said servces. (DTVP pg. 12).
REQUEST NO. 16: Please provide a copy of separate Engineering Services
Agreements. (DTVP pg. 12).
REQUEST NO. 17: Please provide a schedule showing charges by Tetra Tech for
preliminar air-shed modeling and preparation of the Meteorological Monitorig Plan. (DTVP
pg.14).
REQUEST NO. 18: Please provide a copy of the contract with EDA W to perform
NEPA compliance services. (DTVP pg. 14).
INNERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 3
REQUEST NO. 19: Please provide a schedule showing the amounts of non-refudable
expense, investment, and contractu obligations incured by Idaho Power Company for
constrction ofthe Langley Gulch project as of the following dates:
a) October 30, 2008;
b) Janua 30, 2008;
c) March 30, 2009.
The following Requests for Production relate to the Direct Testimony of Mr. John R.
Gale.
REQUEST NO. 20: Identify by name and title the Idaho Power Company
employee(s) to whom the RFP team was responsible to report.
REQUEST NO. 21: Provide all wrtten communcations between members of the RFP
team and the person(s) identified in Request No. 20.
REQUEST NO. 22: Did the RFP team provide a wrtten final reportrecommendation to
the person(s) identified in Response No. 20? If so, provide a copy.
REQUEST NO. 23: If the RFP team did not provide a final wrtten report to the
person(s) identified in Response No. 20, describe how the recommendations of the RFP team
were communcated to the person(s) identified in Response No. 20.
REQUEST NO. 24: To the extent different than the person(s) identified in Response
No. 220, identify by name and title Idaho Power Company employees who were responsible to
review the RFP team recommendations and to formulate a recommendation to the Idaho Power
Company Board of Directors.
INVNERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 4
REQUEST NO. 25: To the extent they exist, provide minutes or contemporaneously
prepared sumares of any meetings or conferences of the persons identified in Request No. 24
regarding the RFP team recommendations.
REQUEST NO. 26: Provide copies of all wrtten communications between the persons
identified in Response No. 24 regarding the RFP team recommendations.
REQUEST NO. 27: Identify by name and title the Idao Power Company employee(s)
responsible to present management's recommendation regarding the Langley Gulch project to
the Idaho Power Company Board of Directors.
REQUEST NO. 28: Provide all wrtten communcations and presentation materials
from the persons identified in Response No. 27 to the Idaho Power Company Board of Directors.
REQUEST NO. 29: Provide all Resolutions of the Idaho Power Company Board of
Directors relating to the Langley Gulch project and Minutes of the Idaho Power Company Board
of Directors meetings at which Langley Gulch or the RFP process was discussed.
The Following discovery requests relate to the Direct Testimony of Mr. Karl Bokenkamp
(DTKB).
REQUEST NO. 30: Please provide a copy of the Proposal Evaluation ManuaL. (DTKB
pg.9).
REQUEST NO. 31: Please identify which of the project proposals submitted by
Invenergy passed Stage 2 screening. (DTKB pg. 9).
REQUEST NO. 32: For each project identified in the answer to the preceding request
provide copies of cost calculations (DTKB pg. 10).
REQUEST NO. 33: Please provide Stage 2 cost calculations for Idaho Power
Company's Benchmark Resource. (DTKB pg. 10).
INVNERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 5
REQUEST NO. 34: Please identify each of the project proposals submitted by
Invenergy which were evaluated in Stage 3 screening (DTKB pg.l 0).
REQUEST NO. 35: For each project indentified in the answer to the preceding request,
please provide in paper and electronic format the input and output files resulting from the Aurora
Electrc Market Model simulations. (DTKB pg. 10).
REQUEST NO. 36: For each project identified in the answer to Request No. 34, please
provide in paper and electronic format (with formula cells active) calculations of the NPV of the
revenue requirement associated with adding the project to Idaho Power Company's portfolio of
resources. (DTKB pg. 10).
REQUEST NO. 37: Please provide in paper and electronic format the input and output
fies resulting from the Aurora Electrc Market Model for Idaho Power Company's benchmark
resource. (DTKB pg. 10).
REQUEST NO. 38: Please provide in paper and electronic format (with formula cells
active) calculations of the NPV of the revenue requirement associated with adding the
Benchmark Resource to Idaho Power Company's portfolio of resources. (DTKB pg. 10).
REQUEST NO. 39: Please provide a copy ofthe Interconnection Feasibilty Study
Report for Idao Power Company's Benchmark Resource. (DTKB pg. 11).
REQUEST NO. 40: Please provide a copy of the natual gas price forecast(s) from
which Exhbit No. 1 is derived (DTKB pg. 11).
REQUEST NO. 41: Please provide in MS Excel format a file (with formula cells
active) that calculates the gas price cure shown in Exhbit No.1. (DTKB pg. 12).
REQUEST NO. 42: Please provide in MS Excel format a fie (with formula cells
active) that calculates the revenue requirements for the thee short listed projects shown on
INVNERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 6
Exhibit NO.2. If one of the projects shown on Exhibit NO.2 was submitted by Invenergy, please
identify the project. (DTKB pg. 12).
REQUEST NO. 43: Please provide in MS Excel format a file (with formula cells
active) that calculates the difference in net present value for the thee short listed projects shown
on Exhbit NO.3. If one of the projects shown on Exhibit NO.2 was submitted by Invenergy,
please identify the project. (DTKB pg. 12).
REQUEST NO. 44: Please provide a copy of the independent consultat RFP. (DTKB
(Exhbit 4).
REQUEST NO. 45: Did RW. Beck fuction as an "Independent Monitor" or as an
"Independent Contractor" as those terms are understood in the electric utilty industr
procurement process?
REQUEST NO. 46: Exhibit NO.4 (pg 1) recites: "R.W. Beck was not requested to
perform tasks 3 and 4 described above." Please provide all wrtten correspondence between
Idaho Power Company employees and RW. Beck employees regarding the decision or direction
to RW. Beck not to perform tasks 3 and 4.
REQUEST NO. 47: Please state whether the gas price forecast contaned in Exhbit No.
1 is the same as the gas prices forecast contaned in the RFP. If it is different, please explain
when the decision to use a different gas price forecast was made and describe fully the reasons
for changing the gas price forecast. Please describe when RFP respondents were notified of the
change in gas price forecasts. (DTKB Exhbit 1).
INVENERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 7
REQUEST NO. 48: When did Idaho Power Company make the decision to defer the
Commercial Operation Date for the Langley Gulch from the sumer of 20 12 to December 31,
2008. Please provide all written correspondence between Idaho Power Company employees
relating to ths decision. (DTKB pg. 16).
REQUEST NO. 49: Please describe how Idaho Power Company proposes to meet the
peak sumer load requirements for 2012 without the Langley Gulch or some other facilty on-
line and in operation by April 1,2012. (DTKB pg 16).
REQUEST NO. 50: At the Pre-Hearing Conference held Tuesday April 14,2008 Idaho
Power Company representatives stated that the Boardman to Hemingway transmission line has
been delayed. Wil delay of Boardman to Hemingway cause delay in the interconnection of the
Langley Gulch project? If yes, it what way has Idaho Power Company evaluated the financial
consequences to its ratepayers.
DATED this 2-3 day of April, 2009.
INVENERGY THERMAL DEVELOPMENT LLC
BY:(JlL
Dean J. Miler
Attorney for Invenergy Thermal Development LLC.
INVENERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 8
CERTIFICATE OF SERVICE
I hereby certify that on the&~y of April, 2009, I caused to be served, via the
methodes) indicated below, tre and correct copies of the foregoing document, upon:
Jean Jewell, Secretar
Scott Woodbur, Esq.
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
j jeweiie,puc.state.id. us
scott. woodbure,puc.idaho.gov
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
Bar Kline, Esq.
Lisa D. Nordstrom
Idaho Power
P.O. Box 70
Boise, ID 83702
bklinee,idahopower .com
Inordstome,idahopower.com
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U.S. Mail
Fax
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Email
Peter J. Richardson
Richardson & O'Lear
515 N. 17th Street
P.O. Box 7218
Boise, ID 83702
petere,richardsonandolear.com
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U.S. Mail
Fax
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Dr. Don Reading
6070 Hil Road
Boise, ID 83703
dreadinge,mindspring.com
Eric L. Olsen
Racine, Olson, Nye, Budge
& Bailey, Charered
201 E. Center
PO Box 1391
Pocatello, ID 83204-1 391
eloe,racinelaw.net
INENERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 9
Anthony Yanel Hand Delivered i.
29814 Lake Road u.s. Mail i.
Bay Vilage, OH 44 14 Fax i.
tonyaYyanel.net Fed. Express ~Email
Ken Miler Hand Delivered i.
Clean Energy Program Director U.S. Mail i.
Snake River Allance Fax i.
PO Box 1731 Fed. Express i.
Boise, ID 83701 Email K
kmileraYsnakeriverallance.org
Betsy Bridge Hand Delivered i.
Idaho Conservation League U.S. Mail i.
71 0 Nort Sixth Street (83702)Fax i.
POBox 844 Fed. Express i.
Boise, ID 83701 Email ~
bbridgeaYwildidaho.org
Susan K. Ackerman Hand Delivered i.
9883 NW Nottage Dr.U.S. Mail i.
Portland, OR 97229 Fax i.
susan.k.ackermanaYcomcast.net Fed. Express i.
Email ~
INVENERGY THERMAL DEVELOPMENT LLC'S FIRST REQUESTS FOR PRODUCTION OF
DOCUMENTS - 10