20090528Staff 90-93 to IPC.pdf

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 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
)
) FOURTH 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 11, 2009.
This Production Request is to be considered as continuing, and Idaho Power 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 will 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 hearng.
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
pursuant to Commission Rules of Procedure must include the name and phone number of the
FOURTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 MAY 28, 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 IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO. 90: For each of the short-listed proposals, please describe and discuss
the results of the sensitivity analyses conducted as par of the Stage 3 evaluation process.
REQUEST NO. 91: Please clarify the amount of AFUDC used in price scoring for the
Benchmark proposal and explain why the AFUDC amounts included in early versions of the
Benchmark proposal were less than half of the AFUDC amount included in the final
Commitment Estimate.
REQUEST NO. 92: Please identify, explain and provide justification for every cost
item and amount included in the Commitment Estimate that was not included in the Benchmark
proposal costs that were used in the final price scoring of the bids.
FOURTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 MAY 28, 2009
REQUEST NO.
93 CONTAINS
CONFIDENTIAL
INFORMATION SUBJECT
TO PROTECTIVE
AGREEMENT.
FOURTH PRODUCTION REQUEST TOIDAHO POWER COMPANY 3 MAY 28, 2009
-IL.
DATED at Boise, Idaho, thisn?l day-of May 2009.
-J!ia~i
Scott Woodbur
Deputy Attorney General ~
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce09.3swrs ipc4
FOURTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 MAY 28, 2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28TH DAY OF MAY 2009,
SERVED THE FOREGOING FOURTH 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
POBOX 70
BOISE ID 83707-0070
(CONFIDENTIAL INFORMATION)
E-MAIL: bklinetiidahopower.com
lnordstromtiidahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
(CONFIDENTIAL INFORMATION)
E-MAIL: dreadingtimindspring.com
WILLIAM BORDERS
ASSISTANT GENERAL COUNSEL
INVENERGY THERMAL DEVELOPMENT
ONE SOUTH WACKER DR
SUITE 1900
CHICAGO IL 60606
(CONFIDENTIAL INFORMATION)
E-MAIL: wborderstiinvenergyllc.com
ANTHONY Y ANKEL
29814 LAKE ROAD
BAY VILLAGE OH 44140
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: tonytiyanel.net
PETER J RICHARDSON
RICHARDSON & O'LEARY
515 N 17TH STREET
PO BOX 7218
BOISE ID 83702
(CONFIDENTIAL INFORMATION)
E-MAIL: petertirichardsonandolear.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: joetimcdevitt-miler.com
ERIC L. OLSEN
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
PO BOX 1391
POCATELLO ID 83204-1391
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: elotiracinelaw.net
KEN MILLER
CLEAN ENERGY PROGRAM DIRECTOR
SNAKE RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: kmilertisnakeriverallance.org
CERTIFICATE OF SERVICE
BETSY BRIDGE
IDAHO CONSERVATION LEAGUE
710 N SIXTH ST (83702)
POBOX 844
BOISE ID 83701
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: bbridgetiwildidaho.org
ELECTRONIC COPIES ONLY
ROBERT KAHN
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: rkahntinippc.org
SUSAN K. ACKERMAN
9883 NW NOTTAGE DR
PORTLAND OR 97229
(NON-CONFIDENTIAL INFORMATION)
E-MAIL: susan.k.ackermanticomcast.net
Jo~
SECRETARY:
CERTIFICATE OF SERVICE