20101021IPC to Staff 1-10.pdf

1SIDA~POR~
An IDACORP Company
DONOVAN E. WALKER
Senior Counsel
dwalkercæidahopower.com
October 21, 2010
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-10-24
IN THE MATTER OF THE APPLICATION OF IDAHO POWER COMPANY
FOR APPROVAL OF A FIRM ENERGY SALES AGREEMENT FOR THE
SALE AND PURCHASE OF ELECTRIC ENERGY BETWEEN IDAHO
POWER COMPANY AND ROCKLAND WIND PROJECT, LLC
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Response to the First Production Request of the Commission Staff to Idaho
Power Company in the above matter. Also enclosed are four (4) copies of a CD
containing information responsive to Staffs production requests.
Donovan E. Walker
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalkertãidahopower.com
Inordstromtãidahopower.com
Attorneys for Idaho Power Company
Street Address for Express Mail:
1221 West Idaho Street
Boise, Idaho 83702
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ZOlûnCT 21 PM ~:40
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MAnER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
APPROVAL OF A FIRM ENERGY SALES
AGREEMENT FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
BETWEEN IDAHO POWER COMPANY
AND ROCKLAND WIND PROJECT, LLC
)
) CASE NO. IPC-E-10-24
)
) IDAHO POWER COMPANY'S
) RESPONSE TO THE FIRST
) PRODUCTION REQUEST OF
) THE COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "Company"), and in
response to the First Production of Request of the Commission Staff to Idaho Power
Company dated September 30,2010, 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 the following interconnection and
transmission documents when available:
a. Feasibilty study
b. Facilty Study
c. Generation Interconnection Agreement
d. Transmission Service Request and the corresponding response
from Idaho Powets Transmission group that transmission capacity is available.
RESPONSE TO REQUEST NO.1:
a. Feasibilitv Study. At Rockland's request, no Feasibilty study was
performed. The project requested to go directly to a System Impact Study, which is
included on the enclosed CD as Attachment 1A
b. Facilty Study. Please see Attachment 18 included on the enclosed CD.
c. Generation Interconnection Agreement ("GIA"). The GIA is currently in the
final stages of being executed by the parties. Once executed, a copy of the GIA wil be
provided in a supplemental response to Staff's Production Request NO.1.
d. Transmission Service Request. Because this PURPA project must serve
Idaho Powets system native load, it must be a Designated Network Resource ("DNR")
on the system. To be a DNR, the Firm Energy Sales Agreement (power purchase
agreement) and the GIA must be completed and executed. For PURPA projects, Idaho
Power-Power Supply submits the Transmission Service Request ("TSR") and the DNR.
The March 18, 2010, letter included on the enclosed CD as Attachment 1D indicates
acceptance of the TSR by Idaho Power-Delivery (TSR has been put in study and wil be
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2
acted upon), conditioned upon receipt of the network resource designation (DNR) from
Idaho Power-Power Supply (wil be acted upon once a DNR is received).
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior 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.2: Please provide a copy of the Aurora project and output files
supporting the levelized Aurora energy price result of $56.21 per MWh as referred to on
page 6 of the Application. Please provide computations showing how the price of
$56.21 was computed using the Aurora results.
RESPONSE TO REQUEST NO.2: Please see the following attachments on the
enclosed CD:
1. Attachment 2A, which describes the methodology used to execute
the AURORA runs for the Rockland project;
2. Attachments 281 and 282 for the requested AURORA output
files; and
3. Attachment 2C for the requested computations.
The response to this Request was prepared by Rich Pagoago Jr., Planning
Analyst, Idaho Power Company, and Randy C. Allphin, Senior Energy Contracts
Coordinator, Idaho Power Company, in consultation with Donovan E. Walker, Senior
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.3: The Application states that the 25-year levelized price in the
Agreement calculates to be $71.29 per MWh. Please explain in detail how the
Company got from a 25-year levelized Aurora price of $56.21 per MWh to a negotiated
25-year levelized rate of $71.29 per MWh. Please identify and quantify each additional
benefit that Idaho Power believes is not captured in the Aurora price.
RESPONSE TO REQUEST NO.3: The avoided cost methodology for qualifying
facilty ("QF") projects 1 0 aMW and larger is an Integrated Resource Plan ("IRP") based
methodology requiring the utilty to make two runs of its power supply model, one using
assumptions consistent with its most recent IRP, and a second with the proposed QF
included as a no-cost resource. The difference in net power supply cost computed by
the model over the term of the proposed contract represents the value of the QF to the
utilty and is supposed to serve as the basis for establishing an avoided cost rate for the
proposed QF. The methodology is intended to capture and fairly value the different
individual generation characteristics of proposed projects. The IRP-based methodology
was set forth in a settlement Stipulation approved by the Commission in Order No.
26576 issued September 1996 in Case No. IPC-E-95-9. Order No. 29487, Case No.
IPC-E-04-5. Please see Attachment 2A on the enclosed CD for the AURORA
methodology utilzed for the Rockland project.
As indicated above, the I RP-based, AURORA methodology establishes the
avoided cost basis for the negotiated rate for the particular QF project that is larger than
10 aMW. Because the AURORA-generated avoided cost rate simply represents a
market price alternative, the Company recognizes that a PURPA agreement may
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5
provide additional benefis over a market purchase, and that value should be reflected
in a negotiated rate.
As stated in the Application for this case, although the $71.29 levelized energy
price within this Agreement is greater than the base AURORA value of $56.21, it is also
lower than the Published Avoided Cost rate of $75.88. This Agreement provides many
additional items of value to Idaho Power and its customers in comparison to a standard
PURPA agreement for QFs 10 MW and under. Some of those items being REC
ownership, greater security and damage provisions, wind forecasting data, additional
contract years at comparatively lower cost, and the right of first offer for ownership or
expansion of this site. In addition, the $71.29 price is considerably lower than prices bid
into the 2012 Wind RFP issued in May 2009, which Idaho Power recently concluded
without awarding a contract. Rockland made this unsolicited proposal of a large 80 MW
PURPA project to Idaho Power and requested Idaho Power negotiate this Agreement
as required by the applicable PURPA rules and regulations. Historically, many
developers have avoided or attempted to avoid this large PURPA contracting process
by dividing a large project into multiple, less than 10 average MW projects, thus
invoking application of the Published Avoided Cost Rate and the more prescriptive
contracting process applicable to those smaller QF projects. Idaho Power believes that
the negotiations with Rockland, which resulted in the present Agreement, evidence the
fact that the large PURPA negotiation process is viable and can result in a project that is
both feasible for the developer and more favorable to Idaho Power customers as
compared to Firm Energy Sales Agreements ("FESA") for 1 0 average MW or smaller
QF projects.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6
Consequently, many of the benefits that Idaho Power believes are not captured
in the AURORA price modeling correspond to those items identified in the Application
as adding additional value above and beyond the typical PURPA FESA that is approved
by the Commission for PURPA projects less than 10 aMW. Many, if not all, of these
additional items of value are difficult, if not impossible, to quantify precisely.
Nevertheless, they do add value that is not sufficiently captured in the pure
mathematical calculation done by the AURORA modeling when determining the 25-year
levelized AURORA price. A summary of those beneficial items of value follows. These
items are more fully summarized in the Application.
. Renewable Energy Certificate ownership
. Mechanical Availabilty Guarantee
. Wind forecasting data
· Greater security and damage provisions
· Right of first offer for ownership or expansion of the site
· Extended term at reduced cost
Further, there is additional value in a long-term fixed priced contract as compared
to volatile market prices over the same period. Again, the removal of market price risk
is difficult to quantify. However, it does some value which should be reflected in the
contract price.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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REQUEST NO.4: The Agreement provides that all Renewable Energy Credits
(RECs) wil be provided to Idaho Power after year 2021. Has Idaho Power attempted to
quantify the value of these RECs? If so, please state the estimated value and show
how it was derived.
RESPONSE TO REQUEST NO.4: As stated in the Company's Response to
Staffs Production Request NO.3, many, if not all, of the additional items of value -
including RECs - are diffcult, if not impossible, to quantify precisely. However, Idaho
Power used available information about REC pricing to gauge the range of REC pricing
from a low of approximately $4.00-$5.00 to a high of $50.00. The Idaho Power 2009
IRP estimated forward REC prices to be approximately $20 in the expected case, and
$50 in the high case. Currently, REC prices for WECC wind short- term current
transactions are being quoted in the $5.00-$6.00 range. Idaho Power is currently
engaged in a hydro REC sale to another utility with a price of $17.50. Califomia Energy
Commission certified RECs are currently trading at approximately $15.
Here, the project retains the rights to all RECs through the end of calendar year
2021. Idaho Power wil own the rights to all RECs from the beginning of calendar year
2022 through the remaining term of the Agreement (a minimum of 15 years). This
allows the QF developer to retain the RECs for the initial ten years of the Agreement
and obtain what value it can for them to help offset the cost of development for the
project at a time when the Company does not have a Renewable Portolio Standard
("RPS") obligation for the RECs. At the same time, it also allows the Company to retain
the RECs for the last 15 years of the Agreement, after the project is developed and
mature, and when a future RPS may require the Company to obtain and have RECs.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9
REQUEST NO.5: The contract term specified in the Agreement is 25 years.
Does Idaho Power have any evidence that the project wil be able to perform for the full
25 years? Can Idaho Power cite other contracts in the U.S. with a term of 25 years for
projects utilzing similar wind turbines as are proposed to be used for the Rockland
project?
RESPONSE TO REQUEST NO.5: Idaho Power has no firsthand experience
with a 25-year wind farm or evidence in regards to the expected life of the wind turbines
to be used at this site. The Facilty has made arrangements to use the Vestas V100
wind turbine. Vestas is one of the oldest manufacturers of wind turbines and supplies
them worldwide. Vestas wind turbines are in use at the Elkhorn Wind Farm and
numerous other wind farms here in the Northwest. Performance requirements within
this Agreement provide financial motivation for the project to maintain, operate, and
replace the wind turbines as required to meet the Mechanical Availabilty Guarantee for
the full 25-year contract term.
In addition, Robert Zdebski, Vice President of Development, Construction, and
Procurement for Ridgeline has provided the following information:
We're confident we can achieve and exceed the 25 year life of the
PPA based on:
1) Proven and reliable design. The V100 is based on
the proven design of the V80 and V90 1 .8. These are
mature platforms using conventional technology and
have long track records of operating worldwide in a
wide range of conditions.
2) Large, stable manufacturer to provide support and
spares. With a large installed base of V80's and
V90's we can be confident that support and spares
wil continue into the future. Wide use of these
machines also ensures a strong aftermarket of
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10
services including engineering support, service
providers and replacement parts manufacturers.
3) Turbine has been selected on a conservative basis
with the site operating conditions significantly below
normal turbine operating limits. Operating at lower
load levels greatly reduces the forces experienced by
the unit and increases the operating life. The turbine
selected has a nominal wind speed limit of 7.5m/s and
a turbulence limit of 0.18% while the actual operating
conditions are (O.Om/s and 0.10%).
4) This site is not subject to extreme weather events
which also increases turbine life and reduces
maintenance issues.
5) Project is being designed with all manufacturers'
recommendations for installation and turbine spacing
which reduces wake induced loads.
6) Project wil interconnect at a strong and reliable point
of the grid. This reduces transient and other electrical
disturbances which can negatively impact turbine
performance and component life.
7) Robust maintenance program. The turbine
manufacturer is providing site-based maintenance
and operation services under a 10-year agreement
ensuring that all maintenance and operations are
carried out per the manufacturets recommendations
and requirements.
8) A project operating plan is being developed for
planned replacement and overhaul of critical
components which wil extend the useful life of the
turbine and ensure safe and reliable operation.
9) Vestas wind turbines that were installed 25 to 30
years ago in California are stil operating today (for
example at the Vicory Garden and Sky River sites in
Tehachapi).
Mr. Zdebski leads turbine procurement, late-stage development, construction,
and operations for Ridgeline. He was previously vice president of business
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11
development at Vestas Americas, the world's leading supplier of wind power solutions,
where he was responsible for managing the company's business development
activities. Mr. Zdebski started his energy career as a field engineer with Dresser-Rand
and has commissioned and worked on steam, gas, geothermal, and hydro plants all
over the world. His career at Dresser-Rand included leading the application
engineering group for the Electric Machinery division focusing on large motors and
generators. Robert holds a Bachelor of Science in Aeronautics from St. Louis
University. Mr. Zdebski's contact information is as follows: [phone] and rzdtãr1-
en.com.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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REQUEST NO.6: Many of the terms of the Agreement are different than in
standard PURPA contracts for projects smaller than 10 aMW (partial completion
damages, simplified MAG, IPCo ownership of RECs, increased security, more
forecasting). How do these unique terms and conditions compare to the terms and
conditions that were being negotiated with a different project in the Company's 2012
Wind RFP wherein no contract was awarded?
RESPONSE TO REQUEST NO.6: Both Idaho Power and the party selected to
negotiate a potential wind purchase power agreement through the request for proposal
("RFP") process consider the specific negotiation details and their discussions to be
confidential information. A summary of the general RFP bid responses is contained in
the Company's Response to Staffs Production Request NO.9. As can be seen in the
provided summary, the lowest energy pricing received in the RFP bid process was an
approximate levelized energy price of $85, whereas the levelized energy price in this
Agreement is $71.29.
In comparing the terms and conditions of this Agreement against the routine
PURPA agreement, numerous items are clearly more favorable, some of those being:
. Energy price
· Security Requirements
. REC Ownership
. Wind forecasting requirements
· Performance Guarantee (MAG)
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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REQUEST NO.7: Please explain the rationale for the Signing Security
($300,000) and Operational Security ($1,500,000) required under the Agreement. What
damages is each type of security intended to recompense?
RESPONSE TO REQUEST NO.7: With regard to the Signing Security of
$300,000, Rockland is working with another party to secure a REC sale for the first ten
years of this Agreement. Throughout the negotiations of this Agreement, Rockland has
expressed that without the REC sales agreement with the third part, Rockland could
not justify the pricing included in this Agreement. Rockland has been working on that
REC sales agreement simultaneously during the negotiations of this Agreement with
Idaho Power and has advised Idaho Power that the REC sales agreement was moving
forward as expected. However, Rockland has advised that they could not execute the
final REC sales agreement until such time as this Agreement was completed due to the
risk that if this Agreement was not completed and approved by the Commission,
Rockland could be subject to supply RECs from a project that was not built. As this
may be a viable concern by Rockland, Idaho Power and Rockland also agreed that the
project could not simply have a "free" out if this occurred since Idaho Power has no
control of this REC sale process and termination of this Agreement at this time would
cause Idaho Power to incur various revised resource planning costs. The $300,000
security and the associated $300,000 damages was a negotiated value.
With regard to the Operational Security of $1,500,000, throughout the term of this
Agreement, the Agreement provides for the calculation of damages due Idaho Power if
the project fails to meet various performance and other contract requirements. Past
history on PURPA agreements has indicated that as damages can contractually be
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 14
calculated and accessed, quite often recovery of those calculated damages can be very
difficult as the projects quite often do not have liquid assets available. Security of
$1,500,000 was a negotiated value for this Operational Security and provides a
certainty that Idaho Power can collect calculated damages, at least up to this amount of
Operational Security. This value was a negotiated amount that the project was able to
provide without requiring substantial impact to the energy pricing.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 15
REQUEST NO.8: Please provide computations showing how the negotiated
prices in the Agreement equate to a levelized rate of $71.29 per MWh.
RESPONSE TO REQUEST NO.8: Please see the Excel file provided on the
enclosed CD.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 16
REQUEST NO.9: Please compare the rates in the Rockland contract to the
prices that were bid in Idaho Powets 2012 Wind RFP wherein no contract was
awarded. Please list the total energy price by year for each of the bids received in the
2012 Wind RFP.
RESPONSE TO REQUEST NO.9: Bidders in the 2012 Wind RFP requested
that the terms and conditions of their bids remain confidentiaL. Even with the
confidentiality restriction, an analysis of the bid prices presents sufficient information to
address this request for information. Idaho Power received bids from 25 projects, or
project configurations, from 14 different bidders in the 2012 Wind RFP. The bids
included projects in Idaho, Utah, Wyoming, Montana, Washington, and Oregon. The
20-year levelized prices ranged from approximately $85.00 per MWh to almost $150 per
MWh. Sixteen of the 25 project configurations had calculated 20-year levelized costs
less than $100 per MWh. All of the calculated 20-year levelized costs include transfer
of the RECs, or Green Tags, to Idaho Power. All of the calculated 20-year levelized
costs include the estimated transmission charges, if necessary, to deliver the energy to
the Idaho Power system. The bid requirement was that the project must be on-line in
2012.
All confidential RRP information is available for review at Idaho Power upon
execution of a Protective Agreement.
The response to this Request was prepared by Tom Noll, Project Manager, Idaho
Power Company, in consultation with Donovan E. Walker, Senior Counsel, Idaho Power
Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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REQUEST NO. 10: Appendix E of the Agreement states that Idaho Power wil
make use of a Wind Energy Production Forecasting model to forecast the energy
production from the Rockland facilty and other wind QF resources. Has Idaho Power
acquired or developed such a model? If so, is Idaho Power currently using the model?
What is the estimated cost to Idaho Power of using and maintaining such a model?
RESPONSE TO REQUEST NO. 10: In prior Idaho Public Utilities Commission
rulings, Idaho Power received authority to make use of a wind forecasting model to
estimate wind generation from the various wind projects that were interconnecting to the
Idaho Power system and for Idaho Power to collect at least a portion of the cost of that
wind forecasting model from the individual wind projects. Initially, Idaho Power had
anticipated acquiring a wind forecasting model from one of the recognized industry
providers.However, initial inquires indicated that potential costs would be
approximately $100,000 for the initial setup, then $2,000-$5,000 for each individual
project that forecasting would be required. At the same time, Idaho Power was
discussing the wind forecasting needs with internal meteorological personnel and other
industry experts. Everyone agreed that the wind forecasting softare suppliers have
very sophisticated, state-of-the-art forecasting tools and would most likely be able to
provide a more exact wind forecast than a forecast created internally. However, the
high supplier cost and the fact that Idaho Power already gathers a lot of weather data
for hydro and load forecasting warranted that Idaho Power explore the potential of
developing a wind forecast internally.
At this time, Idaho Power at an initial cost of approximately $15,000, and an
estimated monthly cost of approximately $500, has developed a wind forecasting tool
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 18
that is based on both project specific persistence forecasting and also general weather
data. The forecasts have been very acceptable in comparison to other available
forecast data from the wind industry suppliers. Idaho Power is currently working with
the schedulers and dispatchers to make better use of the forecasting tool in their daily
operations. In addition, to take the next step in the wind forecasting model, additional,
more detailed weather data is needed. Idaho Power is researching the cost of acquiring
that data and the cost/benefit of going to that next step. The historical wind data and
ongoing weather data that wil be provided by this Facilty wil be very useful in further
develop of an effective wind forecasting tool.
The response to this Request was prepared by Randy C. Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, in consultation with Donovan E. Walker,
Senior Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 21st day of October 2010.
~Ktt~
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 19
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 21st day of October 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
Scott Woodbury
Deputy Attomey General
Idaho Public Utilties Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-2 Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-2 Email Scott.Woodburytãpuc.idaho.gov
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IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION
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