The URL can be used to link to this page

Home My WebLink About20090604IPC to IIPA 1-6.pdfBARTON L. KLINE Lead Counsel esIDA~PO~ An IDACORP Company June 3,2009 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 the Idaho Irrigation Pumpers Association, Inc.'s First Data Requests in the above matter. In addition, also enclosed are four (4) copies of a disk containing confidential information in response to the Irrigators' requests. Please handle this confidential information in accordance with the Protective Agreement and Nondisclosure Agreement in place between the parties. If you have any questions about the enclosed information, please let me know.very~/~ Barton L. Kline BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: 208-388-2682 Facsimile: 208-388-6936 bklinecæidahopower.com Inordstromcæidahopower.com c- r:!" ; \.l~.. '!:,~.. II i\¡ OJJut - J P¡"j 4: l¡ 7 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 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 ) ) IDAHO POWER COMPANY'S ) RESPONSES TO THE IDAHO ) IRRIGATION PUMPERS ) ASSOCIATIONS, INC.'S FIRST DATA ) REQUESTS TO IDAHO POWER ) COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s First Data Requests to Idaho Power Company dated May 22, 2009, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 1 REQUEST NO.1: Please provide IIPA a copy of the Proposal Evaluation Manual which was the subject of Invenergy's Request No. 30 and which has been provided by the Company to Staff, Invenergy and ICIP. RESPONSE TO REQUEST NO.1: The requested information is voluminous, 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 who have executed both the Protective Agreement and CEil Nondisclosure Agreement in place for this proceeding. The information is included on the enclosed CD submitted with this response. 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 THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 2 REQUEST NO.2: Please provide IIPA with the Stage 2 Cost Calculations for Idaho Power Company's Benchmark Resource. This has been addressed in the Company's Response to Invenergy's Request No. 33. RESPONSE TO REQUEST NO.2: The requested information is voluminous, 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 who have executed both the Protective Agreement and CEil Nondisclosure Agreement in place for this proceeding. The information is included on the enclosed CD submitted with this response. 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 THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 3 REQUEST NO.3: Please provide to IIPA in paper and electronic format (with formula cells active) the NPV calculations of the revenue requirement associated with adding the project to the Company's portolio of resources. This was addressed in the Conpany's response to Invenergy's Request No. 36. RESPONSE TO REQUEST NO.3: The requested information is voluminous, 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 who have executed both the Protective Agreement and CEil Nondisclosure Agreement in place for this proceeding. The information is included on the enclosed CD submitted with this response. 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 THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 4 REQUEST NO.4: Please provide IIPA in paper and electronic format (with formula cells active) calculations of the NPV of the revenue requirement associated with adding the Benchmark Resource to the Company's portolio resources. This was addressed in the Conpany's response to Invenergy's Request No. 38. RESPONSE TO REQUEST NO.4: The requested information is voluminous, 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 who have executed both the Protective Agreement and CEil Nondisclosure Agreement in place for this proceeding. The information is included on the enclosed CD submitted with this response. 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 THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 5 REQUEST NO.5: Please provide in MS Excell format a file (with formula cells active) that calculates the revenue requirements for the three short listed projects shown on Exhibit NO.2. This was addressed in the Conpany's response to Invenergy's Request No. 42. RESPONSE TO REQUEST NO.5: The requested information is voluminous, confidential, and may be subject to both attorney-client and accountant-client privilege. Notwithstanding the foregoing, Idaho Power is wiling to make the requested information available for review by persons who have executed both the Protective Agreement and CEil Nondisclosure Agreement in place for this proceeding. The information is included on the enclosed CD submitted with this response. 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 THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 6 REQUEST NO.6: Please provide in MS Excell format a file (with formula cells active) that calculates the difference in the net present value of the three short listed projects shown on Exhibit NO.3. This was addressed in the Conpany's response to Invenergy's Request No. 43. RESPONSE TO REQUEST NO.6: The requested information is voluminous, confidential, and may be subject to both attorney-client and accountant-client privilege. Notwithstanding the foregoing, Idaho Power is wiling to make the requested information available for review by persons who have executed both the Protective Agreement and CEil Nondisclosure Agreement in place for this proceeding. The information is included on the enclosed CD submitted with this response. 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. DATED at Boise, Idaho, this 3rd day of June 2009. ßf.BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 3rd day of June 2009 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY 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 Industrial Customers of Idaho Power and Northwest and Intermountain Power Producers Coalition Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Dr. Don Reading Ben Johnson Associates 6070 Hil Road Boise, Idaho 83703 Snake River Allance Ken Miller 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 -X Hand Delivered U.S. Mail _ Overnight Mail FAX -X Email Scott.Woodburvcæpuc.idaho.gov Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email petercærichardsonandoleary.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email dreadingcæmindspring.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email kmillercæsnakeriveralliance.org Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email elocæracinelaw.net IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 8 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Village, Ohio 44140 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email tonycæyankel.net Idaho Conservation League Betsy Bridge Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email bbridgecæwildidaho.org Northwest and Intermountain Power Producers Coalition Susan K. Ackerman 9883 NW Nottage Drive Portland, Oregon 97229 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email Susan.k.ackermancæcomcast.net~~ Barton L. Kline IDAHO POWER COMPANY'S RESPONSES TO THE IDAHO IRRIGATION PUMPERS ASSOCIATIONS, INC.'S FIRST DATA REQUESTS TO IDAHO POWER COMPANY - 9