20100211IPC to Staff 1, 4, 6-9.pdf

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BARTON L. KLINE
Lead Counsel
bkline~idahopower.com
An IDACORP Company
February 10, 2010
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-09-34
IN THE MA TTER OF THE APPLICA TlON OF IDAHO POWER COMPANY
FOR AN ACCOUNTING ORDER AUTHORIZING THE INCLUSION OF
POWER SUPPL Y EXPENSES ASSOCIA TED WITH THE PURCHASE OF
CAPACITY AND ENERGY FROM USG OREGON LLC IN THE COMPANY'S
POWER COST ADJUSTMENT
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of the second portion
of Idaho Power Company's Response to the First Production Request of the Commission
Staff to Idaho Power Company.
If you have any questions, please do not hesitate to contact me.ve~~
Barton L. Kline
BLK:csb
Enclosures
BARTON L. KLINE (ISB No. 1526)
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
P.O. Box 70
1221 West Idaho Street
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
bklineæRidahopower.com
dwalkeræRidahopower.com
RE:tt ¡, '
ZOIB FEB I 0 P~1 4: 56
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 THE APPLICATION )
OF IDAHO POWER COMPANY FOR AN ) CASE NO. IPC-E-09-34
ACCOUNTING ORDER AUTHORIZING )
THE INCLUSION OF POWER SUPPLY ) IDAHO POWER COMPANY'S
EXPENSES ASSOCIATED WITH THE ) RESPONSE TO THE FIRST
PURCHASE OF CAPACITY AND ENERGY ) PRODUCTION REQUEST OF THE
FROM USG OREGON LLC IN THE ) COMMISSION STAFF TO IDAHO
COMPANY'S POWER COST ) POWER COMPANYADJUSTMENT. )
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the First Production of Request of the Commission Staff to Idaho Power
Company dated January 14, 2010, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1
REQUEST NO.1: Please provide a copy of all bids received by Idaho Power in
the 2006 and 2008 geothermal Requests for Proposals (RFPs).
RESPONSE TO REQUEST NO.1: The requested materials contain confidential
information and are voluminous. As a result, Idaho Power is willng to make the
requested information that is stil in its possession available for review at the offices of
Idaho Power Company by persons covered by the Protective Agreement in place for
this proceeding. Please contact Doug Jones (388-2615) or Camila Victoria (388-5821)
to make an appointment to review this information.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
REQUEST NO.2: Please provide a copy of all supplemental information
submitted by bidders in either the 2006 or 2008 geothermal RFPs that was not part of
the bidders' original bids. For U.S. Geothermal, please provide a copy of all revisions to
its original bid, including revised price offers.
RESPONSE TO REQUEST NO.2: The requested materials contain confidential
information and are voluminous. As a result, Idaho Power is willng to make the
requested information that is stil in its possession available for review at the offices of
Idaho Power Company by persons covered by the Protective Agreement in place for
this proceeding. Please contact Doug Jones (388-2615) or Camila Victoria (388-5821)
to make an appointment to review this information.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3
REQUEST NO.4: On page 3 of its Application, Idaho Power states "However
after further review of escalating construction costs, U.S. Geothermal concluded that its
fixed-price bid was not viable and withdrew its offer to sell power from the Neal Hot
Springs site as submitted." Please provide all information submitted by U.S.
Geothermal relating to the withdrawal of its Neal Hot Springs offer.
RESPONSE TO REQUEST NO.4: The communications between Idaho Power
and U.S. Geothermal concerning U.S. Geothermal's withdrawal of its bid proposal to
sell power from the Neal Hot Springs project were all oraL.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4
REQUEST NO.6: Please provide a copy of any information provided by Idaho
Power to U.S. Geothermal notifying U.S. Geothermal that it was selected as the
successful bidder in the 2006 geothermal RFP.
RESPONSE TO REQUEST NO.6: The requested materials contain confidential
information and are voluminous. As a result, Idaho Power is willng to make the
requested information that is stil in its possession available for review at the offces of
Idaho Power Company by persons covered by the Protective Agreement in place for
this proceeding. Please contact Doug Jones (388-2615) or Camila Victoria (388-5821)
to make an appointment to review this information.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
REQUEST NO.7: Please provide a copy of all analysis completed by Idaho
Power (or any experts or consultants hired by the Company) of bids from either the
2006 or 2008 RFPs and for any other proposals received outside of the RFP process.
For any spreadsheets used in the analysis, please provide copies with formulas intact.
RESPONSE TO REQUEST NO.7: The requested materials contain confidential
information and are voluminous. As a result, Idaho Power is willng to make the
requested information that is stil in its possession available for review at the offices of
Idaho Power Company by persons covered by the Protective Agreement in place for
this proceeding. Please contact Doug Jones (388-2615) or Camila Victoria (388-5821)
to make an appointment to review this information.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
REQUEST NO.8: On page 3 of its Application, Idaho Power states "This 2008
RFP received three responses, two of which were shortly withdrawn by the bidders prior
to Idaho Power fully evaluating the bids." Please provide documentation demonstrating
that two bids were withdrawn.
RESPONSE TO REQUEST NO.8: The requested materials contain confidential
information and are voluminous. As a result, Idaho Power is willng to make the
requested information that is still in its possession available for review at the offices of
Idaho Power Company by persons covered by the Protective Agreement in place for
this proceeding. Please contact Doug Jones (388-2615) or Camila Victoria (388-5821)
to make an appointment to review this information.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7
REQUEST NO.9: On page 3 of its Application, in discussing the 2008 RFP bids,
Idaho Power states "Idaho Power concluded that the third bid was too speculative and
therefore unacceptable." Please provide documentation of any analysis, reports or
other information prepared or obtained by Idaho Power or other experts confirming the
speculative and unacceptable nature of the proposaL.
RESPONSE TO REQUEST NO.9: The requested materials contain confidential
information and are voluminous. As a result, Idaho Power is wiling to make the
requested information that is stil in its possession available for review at the offces of
Idaho Power Company by persons covered by the Protective Agreement in place for
this proceeding. Please contact Doug Jones (388-2615) or Camila Victoria (388-5821)
to make an appointment to review this information.
The response to this Request was prepared by Tom Harvey, Manager, Joint
Projects, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
DATED at Boise, Idaho this 10th day of February 2009.
~~
BARTON L. KLINE
Attomey for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on the 10th day of February 2010 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
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
Weldon B. Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
X Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Weldon.stutzmanæRpuc.idaho.gov
~IlbBartoLK
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9