20090515IPC to Invenergy 1-50.pdf

esIDA~POR~
An IDACORP Company
BARTON L. KLINE
Lead Counsel
May 14, 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 Idaho Power Company's
Responses to Invenergy Ttiermal Development LLC's First Discovery Requests in the
above matter.
In addition, also enclosed are three (3) disks (four (4) copies of each) containing
information in response to Invenergy's discovery requests. Two of the disks contain
confidential information and have been provided to those parties that have executed the
Protective Agreement. Please handle this confidential information in accordance with the
Protective Agreement in place between the parties. The remaining disk is non-confidential
and wil be provided to all the parties.
If you have any questions about the enclosed information, please let me know.ve~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (B3707)
1221 W. Idaho St.
Boise. 10 B3702
BARTON L. KLINE, ISB #1526
LISA D. NORDSTROM, ISB #5733
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: 208-338-6936
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Inordstrom((idahopower.com
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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 MAnER 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
) RESPONSES TO INVENERGY
) THERMAL DEVELOPMENT LLC'S
) FIRST DISCOVERY REQUESTS
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the First Discovery Requests of Invenergy Thermal Development LLC
dated April 23, 2009, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 1
REQUEST NO.1: Please provide a copy of the job description for General
Manager of Power Production. (DTVP pg. 1).
RESPONSE TO REQUEST NO.1: The General Manager of Power Production
is responsible for the management and oversight of operation, maintenance, and
construction activities related to Idaho Power's generation facilities. In addition, the
General Manager of Power Production also manages Idaho Powets interest in jointly
owned coal-fired plants and coal mine.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 2
REQUEST NO.2: Please provide an organizational chart showing the reporting
chain of General Manager of Power Production. (DTVP pg. 1).
RESPONSE TO REQUEST NO.2: A copy of the organizational chart is included
on the enclosed CD.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 3
REQUEST NO.3: Please provide the name, job title and job description of each
member of the "Benchmark Resource Team". (DTVP pg. 2).
RESPONSE TO REQUEST NO.3:
Vern Porter GM, Power
Production
Scott
Larrondo
Manager,
Power Plant
Engineer &
Construction
Jim Leonard Engineering
Leader
Responsible for leading an engineering team in
providing construction, operation, and maintenance
engineering services for Idaho Power's hydroelectric
and combustion turbine facilities.
Engineering supervisor responsible for a wide variety
of civil and mechanical design and construction
projects within the Power Production Department.
Also provides leadership in mechanical engineering
aspects of hydroelectric power plants and combustion
turbines.
Ryan
Adelman
Engineering
Leader Project management of the Langley Gulch Project.
Trevor
Mahlum Engineer II
Under limited supervision, in a team environment,
provides mechanical engineering services to the
Power Production Department. Performs regulatory
and compliance activities and operational
investigations. Performs construction management
services for plant betterment projects.
SeniorJeff Nofsinger Engineer
Under limited supervision, in a team environment,
provides electrical engineering services to the Power
Production Department. Performs regulatory and
compliance activities and operational investigations.
Performs construction management services for plant
betterment ro'ects.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 4
Albert
Izaguirre
Leader,
Power Plant
Control
System
Senior
Lead in the development of an overall project plan and
a control and protection philosophy. Leads the review,
evaluation, and troubleshooting of power plant control
circuits, components, and equipment. Leads
specialists, technicians, mechanics, engineers, and
various other IPC teams outside of Power Production
to design, test and commission control and protection
systems, relays, and other equipment. Manages
project timelines and directs teams in the proper
sequencing of tasks ensuring that the proper safety
procedures are followed throughout the construction
and commission phase of the projects.
Randy
Henderson
Leader,
Finance
Team i
Coordinates and supervises the daily activities of a
team of business support, technical, or production as
well as professional employees responsible for
accounting functions and some financial analysis.
Develops, interprets, and implements highly complex
financial/accounting concepts and advanced
techniques for financial planning and control.
Responsible for selection, performance, and results of
a team as well as for budget development.
Christ
Baerlocher
Financial
Analyst II
Under general direction, responsible for multiple
assignments involving complex financial analysis
projects. Acts as a consultant to management on
financial policy, procedure, and application. Prepares
and presents reports of findings and recommendations
to management. Performs specialized financial,
accounting, or planning activities, investigations,
coordination, and analysis and applies specialized
knowledge of various financial functions such as
budgeting, auditing, financial planning, taxes,
consolidations, regulatory recovery methods, and the
like to support provide financial support to a given
problem.
Other assistance at various stages in the development of the Benchmark
Resource Proposal was requested through other Idaho Power departments. Refer to
the Company's Response to Request NO.5 for other support.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 5
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
,
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 6
REQUEST NO.4: Please provide the name, job title and job description for each
member of Idaho Power's Power Production group. (DTVP pg. 4).
RESPONSE TO REQUEST NO.4: Invenergy agreed to withdraw this Request.
The response to this Request was prepared by Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 7
REQUEST NO.5: Please provide the name, job title and job description of each
member of the Company's Land Management, Legal, Environmental and Water
Management Departments who provided assistance to the Benchmark Resource Team.
(DTVP pg. 5).
RESPONSE TO REQUEST NO.5:
Michele Miler
Senior
Strategic
Sourcing
Professional
Under broad direction, responsible for the planning
and formation of contracts for goods and/or services
for Idaho Power Company. Lead cross-functional
teams in five-step Strategic Sourcing process focusing
on total cost of ownership. Present proposed Supply
Chain solutions to gain leadership understanding and
support to improve enterprise-wide bottom line. Build
and leverages working relationships with intemal
customers and key suppliers to assure cost, quality,
and service goals are met. Advises business units in
determining type of contract to be used based on risk,
application, and budget, while ensuring compliance
with corporate policy and SOX. Analyzes, reviews,
drafts, negotiates, and finalizes contract documents to
deliver appropriate value and mitigate risks for the
company. Provides knowledge, training, and expertise
to various business units on procurement and
contracting practices.
Rex
Blackburn
Senior Vice
President,
General
Counsel
Serves as chief legal offcer and maintains oversight of
the Company's compliance activities.
Gil Green
Real Estate
Specialist,
Senior
Under broad direction, protects Idaho Power Company
property through proper formulation, negotiation, and
administration, while adhering to acceptable real
estate practices and procedures. Respond to inquiries
from customers and governmental agencies
concerning Idaho Power Company land ownership and
use. Responsible for ensuring effcient management
of company owned real estate, including acquisition,
use, exchan e, lease, and dis osal.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 8
Stacey
Baczkowski
Senior
Biologist
The primary objective of this position is to take a lead
technical and leadership role using project
management principles, in one of the primary groups
within the Environmental Department (Recreation,
Water Quality, Fisheries, or Terrestrial). Responsible
for developing, conducting, and implementing
important and complex technical investigations and
management plans and leading or directing significant
assignments and investigations. Considered a
technical expert in a specialized field. Provide expert
testimony for regulatory, legal, and public proceedings
regarding natural resource issues. Determine the
need for designs and coordinate large-scale scientific
studies or implement complex compliance projects.
Specific technical projects include those associated
with licensing, compliance, and Environmental
Services as required by the Federal Energy Regulatory
Commission or requested by other departments within
the Company.
Jon Bowling Engineering
Leader
Primary responsibility is providing supervision,
guidance, and leadership to the Operations Hydrology
Group. The Operations Hydrology Group is an
engineering and hydrology group whose function is to
provide stream flow forecasts, hydro project operations
analyses, upper Snake operations analyses, project
operational descriptions, hydrologic data analysis,
hydrologic and hydro project operations reporting,
operations coordination, and company water rights
tracking and analyses. Other duties include:
operational compliance monitoring, tracking water use
issues for the Company and determining impacts due
to institutional changes in water use, providing
engineering analysis and technical support to Legal
and Management related to state and federal water
issues, and representing the Company through
participation state and regional water forums and
committees.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 9
David Blew Hydrologist II
Within a team environment provides study and
analytical services related to the management of the
Company's water resources. Plans and conducts
hydrologic and operational studies using hydrologic
and hydraulic models and other data analysis
techni ues.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 10
REQUEST NO.6: Please provide a description of the assistance provided to the
Benchmark Resource Team by each person identified in your answer to Interrogatory
NO.3. (DTVP pg. 5).
RESPONSE TO REQUEST NO.6: Below is a list of the individuals identified by
the Company in its Response to Request No. 3 and the assistance they provided to the
Benchmark Resource Team.
1. Vern Porter - Overall review and direction of the project.
2. Scott Larrondo - Led the direction and review of the project development
and proposal preparation. Provided the overall review of the commercial and technical
contract terms.
3. Ryan Adelman - Project Manager. Coordinated preparation of the
Benchmark Resource Proposal. Coordinated commercial and technical contract terms.
Responsible for the overall coordination of permitting activities. Provided Civil
Engineering Technical Support.
4. Jim Leonard - Mechanical Engineering Technical Support.
5. Trevor Mahlum - Mechanical Engineering Technical Support.
6. Jeff Nofsinger - Electrical Engineering Technical Support.
7. Albert Izaguirre - Electrical Engineering / Control Technical Support.
8. Randy Henderson - Lead financial analyst. Supported contract review of
the commercial terms.
9. Chris Baerlocher - Technical financial analyst assisting with site selection.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 11
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 12
REQUEST NO.7: Please provide a copy of the Option to Purchase Land.
(DTVP pg. 6).
RESPONSE TO REQUEST NO.7: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 77. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 13
REQUEST NO.8: Please provide a copy of the Contract to Purchase Water
Rights from Cottonwood Irrigation District. (DTVP pg. 8).
RESPONSE TO REQUEST NO.8: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 77. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 14
REQUEST NO.9: Please provide a copy of the Siemens' Reservation
Agreements. (DTVP pg. 8).
RESPONSE TO REQUEST NO.9: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 77. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 15
REQUEST NO. 10: If different from the Reservation Agreements, please provide
copies of final contracts relating to the purchase of Siemens' equipment. (DTVP pg. 9).
RESPONSE TO REQUEST NO. 10: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 77. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 16
REQUEST NO. 11: In negotiations or discussions with Siemens regarding price
and contract terms for equipment for the Langley Gulch project, were any issues related
to the operation or contractual obligations regarding Siemens' equipment located at
other Idaho Power Company generation projects taken into account? (DTVP pg. 9).
RESPONSE TO REQUEST NO. 11: No, this project was considered an
independent stand-alone project. All maintenance and service internals, including spare
parts, were accounted for as part of the Benchmark price.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 17
REQUEST NO. 12: If your answer to the preceding Request is "Yes" please
provide a complete description and provide any written correspondence documenting
the same. (DTVP pg. 9).
RESPONSE TO REQUEST NO. 12: This Request is not applicable as the
answer to the preceding Request was "No."
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 18
REQUEST NO. 13:Please provide a copy of the Memorandum of
Understanding with the EPC joint venture. (DTVP pg. 11).
RESPONSE TO REQUEST NO. 13: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 76. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 19
REQUEST NO. 14: Please provide a copy of the final EPC contract. (DTVP pg.
12).
RESPONSE TO REQUEST NO. 14: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 76. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 20
REQUEST NO. 15: Please provide a schedule showing preliminary engineering
services performed and amounts paidfor said services. (DTVP pg. 12).
RESPONSE TO REQUEST NO. 15: Preliminary engineering services were
performed by the EPC Contractor to maintain the project schedule. Services included
developing specifications, competitive bidding long-lead equipment, and starting
contract negotiations with potential vendors. Equipment included items such as the
heat recovery steam generator, condenser, cooling tower, and step-up transformers.
Idaho Power Company has paid the EPC Contractor the following payments for
services performed:
1/28/09 $ 95,927.20
$177,989.10
$256,144.73
$ 18.467.55
$548,528.58
2/10/09
4/6/09
4/20/09
TOTAL
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 21
REQUEST NO. 16: Please provide a copy of separate Engineering Services
Agreements. (DTVP pg. 12).
RESPONSE TO REQUEST NO. 16: The requested information is confidential
and has been provided by the Company in its supplemental response to Staffs
Production Request No. 76. The supplemental response has been provided to those
parties that have executed the Protective Agreement, including Exhibits Band C.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 22
REQUEST NO. 17: Please provide a schedule showing charges by Tetra Tech
for preliminary air-shed modeling and preparation of the Meteorological Monitoring Plan.
(DTVP pg. 14).
RESPONSE TO REQUEST NO. 17: The payments made by Idaho Power
Company to Tetra Tech are summarized below:
4/9/08:$20,117
8/28/08:$60,949
10/14/08:$ 9,968
12/8108:$10,358
12/16/08:$ 2,078
2/10109:$11,447
2/19/09:$ 1,575
4/2109:$22,584
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 23
REQUEST NO. 18: Please provide a copy of the contract with EDAW to perform
NEPA compliance services. (DTVP pg. 14).
RESPONSE TO REQUEST NO. 18: This information is considered confidential
information and is subject to the Protective Agreement in place for this proceeding. A
copy is enclosed for those that have signed the Protective Agreement.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 24
REQUEST NO. 19: Please provide a schedule showing the amounts of non-
refundable expense, investment, and contractual obligations incurred by Idaho Power
Company for construction of the Langley Gulch project as of the following dates:
a) October 30, 2008;
b) January 30,2008;
c) March 30, 2009.
The following Requests for Production relate to the Direct Testimony of Mr. John R.
Gale.
RESPONSE TO REQUEST NO. 19:
a) As of October 30,2008:
. 3DiWest:
. Cottonwood Mutual Canal Co.:
. Idaho State Historical Society:
. JUB Engineers:
. Knipe Land Co. - Land Option:
. Materials Testing and Inspection:
. McMillen Engineering:
. Power Engineers:
. Siemens Energy:
. Tetra Tech:
$3790.00
$104,063.00
$87.12
$6,297.89
$22,166.67
$19,961.50
$13,495.20
$289,809.40
$5,631,900.00
$91,034.06
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 25
b) As of January 30,2008, the expenses listed above plus the following:
. Boise Power Partners JV:$273,916.30
. JUB Engineers:$986.89
. Knipe Land Co. - Land Option:$ 22,166.67
. Materials Testing and Inspection:$ 2,742.79
. McMilen Engineering:$480.00
. Power Engineers:$ 21,234.20
$ 23,883.49. Tetra Tech:
c) As of March 30, 2009, the expenses listed above plus the following:
. Boise Power Partners JV:$ 256,144.73
. Cottonwood Mutual Canal Co.:$ 1,977,206.00
$ 22,166.67
$ 4,164.16
$3,089,801.00
. Knipe Land Co. - Land Option:
. Power Engineers:
. Siemens Energy:
. Tetra Tech:$ 24,159.06
. Payette Co. Filing Fee/Advertising: $996.00
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 26
REQUEST NO. 20: Identify by name and title the Idaho Power Company
employee(s) to whom the RFP team was responsible to report.
RESPONSE TO REQUEST NO. 20: The Company's RFP Evaluation Team was
staffed by a number of employees from several different areas of the Company.
Representatives from Power Supply Operations, Power Supply Planning, Power Supply
Reporting, Water Management, Rates and Regulatory Services, and Legal were
members of the team. Representatives from Credit and Corporate Planning also
participated on the RFP Evaluation Team. The RFP Evaluation Team operated
independently. After the RFP Evaluation Team had completed its review of the
proposals received, it presented its findings and recommendations to the Company's
senior management. The Company's senior managers invited to one or more of the
meetings in which the RFP Evaluation Team's recommendation was presented
included: LaMont Keen, President and CEO; Darrel Anderson, Senior Vice President
and CFO; Tom Saldin, Senior Vice President and General Counsel; Dan Minor, Senior
Vice President, Delivery; Steve Keen, Vice President and Treasurer; and Jim Miler,
Senior Vice President, Power Supply; Jeff Malmen, Vice President Public Affairs; Ric
Gale, Vice President Regulatory Affairs; and Lori Smith, Vice President Corporate
Planning and Chief Risk Officer. Members of the Benchmark Resource development
team did not participate in the RFP Evaluation Team's presentation of its
recommendations to the Company's senior management.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 27
REQUEST NO. 21: Provide all written communications between members of
the RFP team and the person(s) identified in Request No. 20.
RESPONSE TO REQUEST NO. 21: The requested information is included on
the enclo$ed CD.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 28
REQUEST NO. 22:Did the RFP team provide a written final
reportrecommendation to the person(s) identified in Response No. 20? If so, provide a
copy.
RESPONSE TO REQUEST NO. 22: Yes. The requested report is included on
the enclosed CD as a part of the Company's Response to Request No. 21.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 29
REQUEST NO. 23: If the RFP team did not provide a final written report to the
person(s) identified in Response No. 20, describe how the recommendations of the RFP
team were communicated to the person(s) identified in Response No. 20.
RESPONSE TO REQUEST NO. 23: See the Company's Response to
Invenergy's Request No. 22.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 30
REQUEST NO. 24: To the extent different than the person(s) identified in
Response No. 20, 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.
RESPONSE TO REQUEST NO. 24: The Idaho Power Company employees that
reviewed the RFP Team recommendations and formulated a recommendation to the
Idaho Power Board of Directors are the same senior management personnel identified
in the Company's Response to Request No. 20.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 31
REQUEST NO. 25:To the extent they exist, provide minutes or
contemporaneously prepared summaries of any meetings or conferences of the
persons identified in Request No. 24 regarding the RFP team recommendations.
RESPONSE TO REQUEST NO. 25: See the materials produced in the
Company's Response to Request No. 21 on the enclosed CD.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 32
REQUEST NO. 26: Provide copies of all written communications between the
persons identified in Response No. 24 regarding the RFP team recommendations.
RESPONSE TO REQUEST NO. 26: See the Company's Response to Request
No. 21 on the enclosed CD.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 33
REQUEST NO. 27: Identify by name and title the Idaho Power Company
employee(s) responsible to present management's recommendation regarding the
Langley Gulch project to the Idaho Power Company Board of Directors.
RESPONSE TO REQUEST NO. 27: See the Company's Response to Request
No. 24.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 34
REQUEST NO. 28: Provide all written communications and presentation
materials from the persons identified in Response No. 27 to the Idaho Power Company
Board of Directors.
RESPONSE TO REQUEST NO. 28: Copies of the presentation materials are
included with the Company's Response to Request No. 21 on the enclosed CD.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, and Vern Porter, General Manager,
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 35
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).
RESPONSE TO REQUEST NO. 29: See the Company's Response to Staffs
Request No. 66.
The response to this Request was prepared by Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 36
REQUEST NO. 30: Please provide a copy of the Proposal Evaluation ManuaL.
(DTKB pg. 9).
RESPONSE TO REQUEST NO. 30: The requested information is confidential,
and may be subject to both attorney-client and accountant-client privilege.
Notwithstanding the foregoing, Idaho Power is willng to make the requested information
available for review by persons covered by the Protective Agreement in place for this
proceeding. Review wil take place at the offces of Idaho Power Company. Please
contact Doug Jones (338-2615) or Cathy Culp (388-2637) to make an appointment to
review this information. Staff, Invenergy, and ICIP have been provided with copies of
this document.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 37
REQUEST NO. 31: Please identify which of the project proposals submitted by
Invenergy passed Stage 2 screening. (DTKB pg. 9).
RESPONSE TO REQUEST NO. 31: The project proposals submitted by
Invenergy that passed Stage 2 screening were its Emmett CCCT project, Mountain
Home CCCT project, Emmett LMS 100 project and the Mountain Home LMS 100 project.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 38
REQUEST NO. 32: For each project identified in the answer to the preceding
request provide copies of cost calculations (DTKB pg. 10).
RESPONSE TO REQUEST NO. 32: The requested materials are in the
Company's Discovery Room. With the exception of the portions of the above-described
documents relating to the bids from other competing bidders, Idaho Power Company
made the above-requested documents available to Invenergy during their visit to its
Company offces on April 30, 2009. Additionally, as a result of their visit, Invenergy
requested paper and electronic copies of the information made available on April 30,
which were provided on May 4,2009.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 39
REQUEST NO. 33: Please provide Stage 2 cost calculations for Idaho Power
Company's Benchmark Resource. (DTKB pg. 10).
RESPONSE TO REQUEST NO. 33: The requested information is available in
the Company's Discovery Room. Idaho Power Company has made the above-
requested information available to Invenergy, the Industrial Customers of Idaho Power
("ICIP"), and Staff.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 40
REQUEST NO. 34: Please identify each of the project proposals submitted by
Invenergy which were evaluated in Stage 3 screening (DTKB pg.10).
RESPONSE TO REQUEST NO. 34: The project proposals submitted by
Invenergy which were evaluated in Stage 3 Screening were its Emmett CCCT project,
the Mountain Home CCCT project, the Emmett LMS100 project, and the Mountain
Home LMS 100 project.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 41
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 Electric Market Model simulations. (DTKB pg. 10).
RESPONSE TO REQUEST NO. 35: The files are provided in electronic format
on the enclosed CD. It is not practical to print all the data associated with the input and
output from the Aurora simulations on paper.
The response to this Request was prepared by Rick Haener, Planning Analyst,
Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 42
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 portolio of resources. (DTKB pg. 10).
RESPONSE TO REQUEST NO. 36: The requested information is in the
Company's Discovery Room. With the exception of the portions of the above-described
documents relating to the bids from other competing bidders, Idaho Power Company
made the above-requested information available to Invenergy during its visit to the
Company's offces on April 30, 2009. Additionally, as a result of its visit, Invenergy
requested paper and electronic copies of the information made available on April 30,
which were provided on May 4,2009.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 43
REQUEST NO. 37: Please provide in paper and electronic format the input and
output files resulting from the Aurora Electric Market Model for Idaho Power Company's
benchmark resource. (DTKB pg. 10).
RESPONSE TO REQUEST NO. 37: The files are provided in electronic format
on the enclosed CD. It is not practical to print all the data associated with the input and
output from the Aurora simulations on paper.
The response to this Request was prepared by Rick Haener, Planning Analyst,
Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 44
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 portolio of resources. (DTKB pg.
10).
RESPONSE TO REQUEST NO. 38: The requested information is in the
Company's Discovery Room. Staff, Invenergy, and ICIP have had access to or
received a copy of the requested information.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 45
REQUEST NO. 39: Please provide a copy of the Interconnection Feasibility
Study Report for Idaho Power Company's Benchmark Resource. (DTKB pg. 11).
RESPONSE TO REQUEST NO. 39: The requested information is confidential,
contains CEil, and has been provided by the Company in its supplemental response to
Staffs Request No. 77. The supplemental response is being provided to those parties
that have executed the Nondisclosure Agreement and the Protective Agreement.
The response to this Request was prepared by Vern Porter, General Manager
Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 46
REQUEST NO. 40: Please provide a copy of the natural gas price forecast(s)
from which Exhibit NO.1 is derived (DTKB pg. 11).
RESPONSE TO REQUEST NO. 40: The requested information contains
proprietary data from Global Insight and is confidentiaL. A copy is included on the
enclosed CD for those parties that have signed the Protective Agreement.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Planning and Operations, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 47
REQUEST NO. 41: Please provide in MS Excel format a file (with formula cells
active) that calculates the gas price curve shown in Exhibit NO.1. (DTKB pg. 12).
RESPONSE TO REQUEST NO. 41: The requested information is included on
the enclosed CD.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 48
REQUEST NO. 42: Please provide in MS Excel format a file (with formula cells
active) that calculates the revenue requirements for the three short listed projects
shown on Exhibit NO.2. If one of the projects shown on Exhibit. NO.2 was submitted by
Invenergy, please identify the project. (DTKB pg. 12).
RESPONSE TO REQUEST NO. 42: The requested data is in the Company's
Discovery Room. With the exception of the portions of the above-described documents
relating to the bids from other competing bidders, Idaho Power Company has provided
the above-requested documents to Invenergy. Project E on Exhibit 2 is an Invenergy
Project. Staff and ICIP have also had access to or received copies of the requested
materiaL.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 49
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 three short listed
projects shown on Exhibit NO.3. If one of the projects shown on Exhibit No. 2 was
submitted by Invenergy, please identify the project. (DTKB pg. 12).
RESPONSE TO REQUEST NO. 43: The requested information is in the
Company's Discovery Room. With the exception of the portions of the above-described
documents relating to the bids from other competing bidders, Idaho Power has provided
the above-requested documents to Invenergy. Project E on Exhibit 3 is an Invenergy
Project. Staff and ICIP have also had access to or received copies of the requested
materiaL.
The response to this Request was prepared by Celeste Schwendiman, Senior
Pricing & Regulatory Analyst, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 50
REQUEST NO. 44: Please provide a copy of the independent consultant RFP.
(DTKB (Exhibit 4).
RESPONSE TO REQUEST NO. 44: A formal RFP was not conducted. A
description of the process the Company used to choose its independent consultant, R.
W. Beck, is contained in the Company's Response to Staffs Request No. 27.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 51
REQUEST NO. 45: Did RW. Beck function as an "Independent Monitot' or as
an "Independent Contractor" as those terms are understood in the electric utility industry
procurement process?
RESPONSE TO REQUEST NO. 45: Idaho Power is not familiar with the precise
meaning Invenergy is assigning to the term "Independent Monitor." Assuming that the
term "Independent Monitor" is functionally equivalent to the "Independent Evaluator," as
that term is used in the Oregon Guidelines relating to competitive bidding, R W. Beck
performed some but not all of the functions that would be performed by an independent
evaluator under the Oregon Guidelines. RW. Beck was retained by Idaho Power as an
independent consultant to assist and advise Idaho Power in the following areas:
preparation of the 2012 RFP; preparation of the associated draft power purchase and
tollng agreements; development of the evaluation criteria and the evaluation manual;
evaluation of the proposals received in response to the RFP; if necessary, perform an
independent evaluation of the proposals; and provide expert testimony to the Idaho and
Oregon PUCs regarding the Company's RFP process and evaluation. A more detailed
description of the function R W. Beck played in the 2012 RFP design and
implementation is contained in Exhibit No. 4 to the Company's direct case in this
proceeding.
The response to this Request was prepared by Steven Stein, Principal and
Senior Director, R W. Beck, Inc., and Karl Bokenkamp, General Manager Power
Supply Operations and Planning, Idaho Power Company, in consultation with Barton L.
Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 52
REQUEST NO. 46: Exhibit NO.4 (pg 1) recites: "RW. Beck was not requested
to perform tasks 3 and 4 described above." Please provide all written 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.
RESPONSE TO REQUEST NO. 46: There is no written correspondence
between Idaho Power employees and R W. Beck employees regarding the decision or
direction to R W. Beck not to perform tasks 3 and 4 as outlined in Exhibit NO.4.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 53
REQUEST NO. 47: Please state whether the gas price forecast contained in
Exhibit No. 1 is the same as the gas prices forecast contained 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 Exhibit 1).
RESPONSE TO REQUEST NO. 47: The gas forecast contained in Exhibit No. 1
to Mr. Bokenkamp's testimony is the not exactly the same as the gas price forecast
contained in the RFP. It appears that there were two inadvertent entries inserted in the
2017 through 2019 time period. If these are removed, and the 2020 entry becomes
2018, the 2021 entry becomes 2019, and so on, the forecasts match through 2028.
This inadvertently modified version of the gas forecast identified in Addendum 2 to the
RFP was used in the busbar (Stage 2) screening analysis. The gas forecast used to
determine the price factor scoring (Stage 3) matched the gas forecast Identified in
Addendum 2 to the RFP. Addendum 2 was issued on October 17, 2008. Respondents
were not notified of the inadvertent modifications to the gas forecast used in the (Stage
2) busbar screening.
If the gas forecast indentified in Addendum 2 (without the inadvertent
modifications) had been used in the busbar analysis, it would not have changed the
projects selected for Stage 3 screening.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 54
REQUEST NO. 48: When did Idaho Power Company make the decision to
defer the Commercial Operation Date for the Langley Gulch from the summer of 2012 to
December 31, 2008. Please provide all written correspondence between Idaho Power
Company employees relating to this decision. (DTKB pg. 16).
RESPONSE TO REQUEST NO. 48: The decision to defer the commercial
operation date for the Langley Gulch project was made on or about February 12, 2009,
contemporaneously with the Company's senior management's decision to accept the
recommendation of the RFP Evaluation Team to accept the Benchmark Resource
proposaL. The decision to defer the commercial operation date for the Langley Gulch
project was based on the estimated time that would be needed to obtain from the
Commission a determination that Idaho Power could utilze recently enacted ratemaking
tools to enhance the likelihood of Idaho Power's being able to utilze traditional utility
financing to fund the construction of Langley Gulch. As noted in the Company's direct
testimony, the ability to use traditional utility financing to fund the construction of the
Langley Gulch project could save customers a substantial amount of money. The
written correspondence relating to this decision is included with the material provided in
response to Request No. 21.
The response to this Request was prepared by Ric Gale, Vice President of
Regulatory Affairs, Idaho Power Company, in consultation with Barton L. Kline, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 55
REQUEST NO. 49: Please describe how Idaho Power Company proposes to
meet the peak summer load requirements for 2012 without the Langley Gulch or some
other facility online and in operation by April 1 ,2012. (DTKB pg 16).
RESPONSE TO REQUEST NO. 49: As noted in Idaho Power's response to the
Industrial Customers of Idaho Power's Production Request No.2, the Company would
attempt to meet its most critical summertime loads through a combination of the
following: (1) short-term demand management programs, (2) market purchases
delivered to the eastern side of Idaho Power's system, (3) market purchases delivered
at Mona or Red Butte (both in Utah) and delivered to Idaho Power's system via Idaho
Power's firm transmission rights from Red Butte to BorahlBrady, (4) reductions in
deliveries to Hoku during the summer of 2012, or (5) purchases delivered to Jim Bridger
for loss repayment. Market purchases from the Pacific Northwest are also a possibility
when transmission is not constrained. PPAs from generation resources are another
possibility. This approach would apply for the summer of 2012 and subsequent years if
the project was subject to longer delays.
Idaho Power has received proposals from a number of suppliers to supply energy
to various points of delivery east of Brownlee to cover projected summertime deficits
from 2009 through 2012. As a result of the proposals received, Idaho Power has
recently purchased 83 MW for HL hours in July and August of 2012.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 56
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.
RESPONSE TO REQUEST NO. 50: No. Delay of the Boardman to Hemingway
project wil not cause delay in the interconnection of the Langley Gulch project.
The response to this Request was prepared by Karl Bokenkamp, General
Manager Power Supply Operations and Planning, Idaho Power Company, in
consultation with Barton L. Kline, Lead Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 14th day of May 2009.
Qi
BARTON L. KLINE
Attorney for Idaho Power Company
~
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 57
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 14th day of May 2009 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSES TO INVENERGY THERMAL
DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS upon the following named
parties by the method indicated below, and addressed to the following:
Commission Staff
Scott Woodbury
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-L Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-L Email Scott.Woodburytâpuc.idaho.gov
Industrial Customers of Idaho Power
and Northwest and Intermountain
Power Producers Coalition
Peter J. Richardson, Esq.
RICHARDSON & O'LEARY PLLC
515 North 2ih Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email petertârichardsonandoleary.com
Dr. Don Reading
Ben Johnson Associates
6070 Hill Road
Boise, Idaho 83703
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email dreadingcæmindspring.com
Invenergy Thermal Development LLC
Dean J. Miler
McDEVln & MILLER LLP
420 West Bannock Street
P.O. Box 2564
Boise, Idaho 83701
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email joetâmcdevitt-miler.com
Wiliam Borders
Assistant General Counsel
Invenergy Thermal Development LLC
One South Wacker Drive, Suite 1900
Chicago, Ilinois 60606
Hand Delivered
-L U.S. Mail
_ Overnight Mail
FAX
-L Email wborders((invenergyllc.com
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 58
Snake River Allance
Ken Miler
Snake River Allance
P.O. Box 1731
Boise, Idaho 83701
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
Northwest and Intermountain Power
Producers Coalition
Susan K. Ackerman
9883 NW Nottage Drive
Portland, Oregon 97229
Hand Delivered
~U.S.Mail
_ Overnight Mail
FAX
~ Email kmilerCâsnakeriverallance.org
Hand Delivered
~U.S.Mail
_ Overnight Mail
FAX
~ Email elo((racinelaw.net
Hand Delivered~U.S.Mail
_ Overnight Mail
FAX
~ Email tonyCâyankel.net
Hand Delivered~U.S.Mail
_ Overnight Mail
FAX
~ Email bbridgeCâwildidaho.org
Hand Delivered~U.S.Mail
_ Overnight Mail
FAX~Email
Susan. k. ackermanCâcomcast. net
_(Slie ·
Barton L. Kline
IDAHO POWER COMPANY'S RESPONSES TO INVENERGY
THERMAL DEVELOPMENT LLC'S FIRST DISCOVERY REQUESTS - 59