20090521Staff 84-86 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. 1895
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Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
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
)
) THIRD PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilties Commission, by and through its attorney of record,
Scott Woodbur, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
THURSDAY, JUNE 4, 2009.
This Production Request is to be considered as continuing, and Idaho Power Company is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that wil augment the documents produced.
For each item, please indicate the name of the person(s) preparng the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuat to Commission Rules of Procedure must include the name and phone number of the
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 MAY 21, 2009
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAP A
31.01.01.228.
In addition to the wrtten copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 84: In Request No. 20 of the Industrial Customers ofIdaho Power, the
Company was asked "Given the economic conditions, has the Company made any adjustments to
its load forecasts for the coming five years, and if so, what are those adjustments?" Idaho Power
responded that in December 2008, it made adjustments to the load forecasts of the residential and
commercial sectors. However, in its response, Idaho Power but did not provide any data
quantifying the adjustments. Please quantify the adjustments made in December and provide a
numerical and graphical comparison of the load resource balance for the same conditions
ilustrated in Idaho Power's response to Staff Request NO.2.
REQUEST NO. 85: In response to Request No. 20 of the Industrial Customers of Idaho
Power, the Company stated that it is working on developing a new load forecast that will be
available in late summer of2009. Given the significance of the proposed Langley Gulch project
in terms of cost and added generation capacity, and given that the need for the Langley Gulch
project was presumably based on a prior load forecast, please explain why Idaho Power has not
prepared a more curent load forecast. Can the load forecast update that is expected to be
completed in late sumer be expedited for use in the curent Langley Gulch case? If so, please
provide a copy of the revised load forecast.
REQUEST NO. 86: The direct testimony of Karl Bokenkamp, on page 10, lines 20-21,
states "Sensitivity analyses were ru for high and low gas price scenarios, but these results did
not impact the price and non-price scores." Please provide a copy by year of the high and low
gas prices used for the analysis. What was the source or basis for the adjustments to the gas
prices? Please discuss the results of the analysis and explain why the price scores were not
impacted. Please specifically contrast the effect of higher and lower gas prices on proposals with
higher vs. lower heat rates.
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 MAY 21, 2009
REQUEST NOS.
87,88 AND 89 CONTAIN
CONFIDENTIAL
INFORMATION SUBJECT
TO PROTECTIVE
AGREEMENT.
THIRD PRODUCTION REQUEST TOIDAHO POWER COMPANY 3 MAY 21,2009
DATED at Boise, Idaho, this~l.i day of May 2009.
~;"Qja.~..~co oodbur
l) Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreqfipce09.3swrps ipc2
THIRD PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 MAY 21, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21sT DAY OF MAY 2009, SERVED
THE FOREGOING THIRD PRODUCTION REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER COMPANY, IN CASE NO. IPC-E-09-3, BY MAILING
A COPY THEREOF, POSTAGE PREPAID, TO THE FOLLOWING:
BARTON L KLINE
LISA D NORDSTROM
IDAHO POWER COMPANY
PO BOX 70
BOISE ID 83707-0070
(CONFIDENTIAL INFORMTION)
E-MAIL: bkline(iidahopower.com
lnordstrom(iidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
(CONFIDENTIAL INFORMATION)
E-MAIL: dreading(imindspring.com
WILLIAM BORDERS
ASSISTANT GENERAL COUNSEL
INVENERGY THERMAL DEVELOPMENT
ONE SOUTH WACKER DR
SUITE 1900
CHICAGO IL 60606
(CONFIDENTIAL INFORMATION)
E-MAIL: wborders(iinvenergy.com
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: tony(iyaneLnet
PETER J RICHARDSON
RICHARDSON & O'LEARY
515 N 17TH STREET
PO BOX 7218
BOISE ID 83702
(CONFIDENTIAL INFORMATION)
E-MAIL: peter(irichardsonandoleary.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
(CONFIDENTIAL INFORMATION)
E-MAIL: joe(imcdevitt-miler.com
ERIC L. OLSEN
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
PO BOX 1391
POCATELLO ID 83204-1391
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: elo(iracinelaw.net
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
POBOX 1731
BOISE ID 83701
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: kmiler(isnakeriverallance.org
CERTIFICATE OF SERVICE
BETSY BRIDGE
IDAHO CONSERVATION LEAGUE
710 N SIXTH ST (83702)
POBOX 844
BOISE ID 83701
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: bbridge(iwildidaho.org
ELECTRONIC COPIES ONLY
ROBERT KAHN
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: rkahn(inippc.org
SUSAN K. ACKERMAN
9883 NW NOTTAGE DR
PORTLAND OR 97229
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: susan.k.ackerman(icomcast.net
¿2an
SECRET4t
CERTIFICATE OF SERVICE