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Home My WebLink About20090612IPC to Staff 94-96.pdf?;IDA~POR~ An IDACORP Company BARTON L. KLINE Lead Counsel June 11, 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 Response to the Fifth Production Request of the Commission Staff in the above matter. Also enclosed are four (4) copies of a disk containing confidential information responsive to Staffs 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 truly yours,~~ Barton L. Kline BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise. 10 83702 CERTIFICATE OF ATTORNEY RECEIVED ASSERTION THAT MATERIALS REQUESTED AND PROVID~tWNc5 ll4: S2 COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PR~~G ARE PROTECTED FROM PUBLIC INSPECTldllLlTIES CO~~/¡ÇIY :5S/0N Case No. IPC-E-09-03 The undersigned attorney, in accordance with RP 233, hereby certifies as follows: 1. The Response to Production Requests No. 94, 95, and 96 propounded by the Commission Staff during the course of the above-referenced case contain information that is a trade secret or privileged or confidential as described in Idaho Code § 9-340, et seq., and § 48-801, et seq., and as such is exempt from public inspection, examination, or copying. DATED this 11th day of June 2009. .00 -BARTON L. KLINE Counsel for Idaho Power Company 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 RECEIVED ZOO9 JON " PH i,:52 IDAHO PUBLIC UTILITIES COMMISSION 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 ) RESPONSE TO THE FIFTH ) PRODUCTION REQUEST OF THE ) COMMISSION STAFF TO IDAHO ) POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Fifth Production Request of the Commission Staff to Idaho Power Company dated June 1, 2009, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO. 94: Please provide a workpaper comparing 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. RESPONSE TO REQUEST NO. 94: The requested information is confidential and is being provided to those persons covered by the Protective Agreement in place in this matter. The response to this Request was prepared by Vern Porter, General Manager, Power Supply, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO. 95: Please provide a revised proposal scoring summary 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. RESPONSE TO REQUEST NO. 95: The requested information is confidential and is being provided via CD to those persons covered by the Protective Agreement in place in this matter. 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 RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO. 96: Please provide a revised proposal scoring summary 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. RESPONSE TO. REQUEST NO. 96: The requested information is confidential and is being provided via CD to those persons covered by the Protective Agreement in place in this matter. The response to this Request was prepared by Celeste Schwendiman, Senior Pricing Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 11th day of June 2009. D£tL~BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of June 2009 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Scott Woodbury Deputy Attomey 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 Miler Snake River Alliance 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 -l Hand Delivered U.S. Mail _ Overnight Mail FAX -l Email Scott.Woodburycæpuc.idaho.gov Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email petercærichardsonandoleary.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email dreadingcæmindspring.com Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email kmillercæsnakeriveralliance.org Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email elocæracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 Anthony Yankel Yankel & Associates, Inc. 29814 LakeRoad Bay Vilage, Ohio.44140 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email tonycæyankel.net Idaho Conservation league Betsy Bridge Idaho Conservation League 710 North Sixth Street P.O. Box 844 Boise, Idaho 83701 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email bbridgecæwildidaho.org Northwest and Intermountain Power Producers Coalition Susan K. Ackerman 9883 NW Nottage Drive Portland, Oregon 97229 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email Susan.k.ackermancæcomcast.net Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ih Street Boise, Idaho 83702 Hand Delivered -l U.S. Mail _ Overnight Mail FAX -l Email bmpurdycæhotmail.com (J~ Barton L. Kline IDAHO POWER COMPANY'S RESPONSE TO THE FIFTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6