20090601Staff 94-96 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
Attotney 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
)
) FIFTH 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
MONDAY, JUNE 15, 2009.
This Production Request is to be considered as continuing, and Idaho 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 wil augment the documents produced.
For 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 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
pursuant to Commission Rules of Procedure must include the name and phone number of the
FIFTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 1 JUE 1,2009
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. 94: Please provide a workpaper comparng the Commitment Estimate
cost breakdown to the cost breakdowns in the final Benchmark proposal bid, the breakdown
presented to the Idaho Power Board and the breakdown presented to the Commission Staff.
REQUEST NO. 95: Please provide a revised proposal scoring sumar for the
Benchmark proposal and proposal "B" based on the costs included in the Commitment Estimate.
Please briefly describe any other adjustments in the analysis that affected the price scores.
REQUEST NO. 96: Please provide a revised proposal scoring summar for the
Benchmark proposal and proposal "B" based on the costs included in the Commitment Estimate
(similar to Request No. 95), but with the terminal value of the Benchmark proposal included in
the scoring analysis.
DATED at Boise, Idaho, this ~
( day of June 2009.
Scott Woodbur
Deputy Attorney General
Technical Staff: Rick Sterling
i:umise:prodreq/ipee09.3swrs ipe5
FIFTH PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 JUE 1,2009
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1ST DAY OF JUE 2009, SERVED
THE FOREGOING FIFTH 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
E-MAIL: bkline~idahopower.com
lnordstrom~idahopower.com
DR DON READING
6070 HILL ROAD
BOISE ID 83703
E-MAIL: dreading~mindspring.com
WILLIAM BORDERS
ASSISTANT GENERAL COUNSEL
INVENERGY THERMAL DEVELOPMENT
ONE SOUTH WACKER DR
SUITE 1900
CHICAGO IL 60606
E-MAIL: wborders~invenergyllc.com
ANTHONY Y ANKEL
29814 LAK ROAD
BAY VILLAGE OH 44140
E-MAIL: tony~yanei.net
BETSY BRIDGE
IDAHO CONSERVATION LEAGUE
710 N SIXTH ST (83702)
PO BOX 844
BOISE ID 83701
E-MAIL: bbridge~wildidaho.org
PETER J RICHARDSON
RICHARDSON & O'LEARY
515 N 17TH STREET
PO BOX 7218
BOISE ID 83702
E-MAIL: peter~richardsonandolear.com
DEAN J MILLER
McDEVITT & MILLER LLP
PO BOX 2564
BOISE ID 83701
E-MAIL: joe~mcdevitt-miler.com
ERIC L. OLSEN
RACINE, OLSON, NYE, BUDGE
& BAILEY, CHARTERED
PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL: elo~racinelaw.net
KEN MILLER
CLEAN ENERGY PROGRA DIRECTOR
SNAK RIVER ALLIANCE
PO BOX 1731
BOISE ID 83701
E-MAIL: kmiler~snakeriverallance.org
SUSAN K. ACKERMAN
9883 NW NOTTAGE DR
PORTLAND OR 97229
E-MAIL: susan.k.ackerman~comcast.net
CERTIFICATE OF SERVICE
ELECTRONIC COPIES ONLY
ROBERT KAHN
E-MAIL: rkah~nippc.org
-.~SECRETA ..
CERTIFICATE OF SERVICE