HomeMy WebLinkAboutIPCE0107.11prodreq.docLISA D. NORDSTROM
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-0314
BAR NO. 5733
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE IDAHO POWER COMPANY APPLICATION FOR A REFUNDABLE EMERGENCY ENERGY CHARGE FOR THE RECOVERY OF EXTRAORDINARY POWER SUPPLY EXPENSES. )
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CASE NO. IPC-E 01-7
IN THE MATTER OF THE IDAHO POWER COMPANY APPLICATION FOR AUTHORITY TO IMPLEMENT A POWER COST ADJUSTMENT (PCA) RATE FOR ELECTRIC SERVICE FROM MAY 1, 2001 THROUGH MAY 15, 2002. )
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CASE NO. IPC-E 01-11
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO IDAHO POWER
COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record, Lisa D. Nordstrom, Deputy Attorney General, requests that Idaho Power Company (Idaho Power; Company) provide the following documents and information on or before FRIDAY, APRIL 6, 2001.
This Production Request is to be considered as continuing, and Idaho Power Company is requested to provide, by way of supplementary responses, additional documents that it or any person acting on its behalf may later obtain that will 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.
Request No. 1: Has Idaho Power maintained the same planning reserve from 1991 through 2001? If not, when was the planning reserve changed, how was it changed and why? Please distinguish between planning reserve and operating reserve.
Request No. 2: Please list all key Idaho Power personnel involved in preparation of the 1997 Integrated Resource Plan (IRP). Which, if any, of these personnel were involved in preparation of the 2000 IRP? Please indicate the current job responsibilities of those personnel involved in preparation of the 1997 IRP but not in preparation of the 2000 IRP.
Request No. 3: How does Idaho Power define the terms “critical water” and “median water”?
Request No. 4: How does the low water scenario analyzed in the 2000 IRP compare relative to water conditions during the last 60 plus water years used in the Company’s power supply modeling? How does the low water scenario compare to median and critical water conditions?
Request No. 5: What analysis has Idaho Power (or its agents) done at any time within the past ten years to assess the risks of relying on the market to meet short term and seasonal deficits? Please provide documentation of any such analysis.
Request No. 6: Please provide documentation of any studies or analysis completed by Idaho Power (or its agents) assessing the future price and availability of non-firm market resources.
Request No. 7: Please explain why Idaho Power has not provided annual updates to the 1997 IRP as discussed on page 48 of the 1997 IRP.
Request No. 8: Please provide documentation or evidence of any power supply planning activity engaged in by Idaho Power since the completion of the 1997 IRP. If none exists, please summarize any power planning activity that occurred. When did the activity take place, what was its specific purpose, and what was the outcome?
Request No. 9: Does Idaho Power have now, or has it had at any time in the past, criteria for an acceptable level of reliance on the market? How did the Company determine what level of market reliance was acceptable?
Request No. 10: Please provide a copy of any risk management policies followed by Idaho Power.
Request No. 11: What have been the generation reserve margins in the Western Systems Coordinating Council (WSCC) for each of the past ten years? What have been the generation reserve margins in the past ten years in the Northwest Power Pool specifically?
Request No. 12: What has been Idaho Power’s reserve margin during each of the past ten years? Please distinguish between operating reserves and planning reserves. Please also describe how the reserve margin is calculated.
Request No. 13: Please explain how much Idaho Power’s reliance on the market in the year 2000 deviated from the level of reliance anticipated in the 2000 IRP. Please compare Idaho Power’s actual energy and capacity surpluses and deficits for each month in 2000 and 2001 to the level of energy and capacity surplus and deficit planned in the 2000 IRP.
Request No. 14: Please indicate Idaho Power’s planned level of reliance on market resources for each of the past ten years by showing the expected level of market purchases by month.
Request No. 15: Please provide records showing the actual market purchases by Idaho Power (or its agents on behalf of Idaho Power) by month for each of the past ten years. Please include the amount of each purchase, a description of the product, and the amount paid.
Request No. 16: Please provide documentation of any plans prepared by Idaho Power (or its agents) within the past five years to meet load under low water conditions.
Request No. 17: Please provide documentation of any risk analysis prepared by Idaho Power (or its agents) to address high market prices.
Request No. 18: Please describe any planning processes (e.g., planning for annual and seasonal events, planning for conditions that deviate from IRPs, planning during the interim between IRPs, etc.) followed by Idaho Power for short-term planning.
Request No. 19: Did Idaho Power consider other alternatives besides relying on market purchases to meet short-term deficits in 2000 and thus far in 2001? If so, what other alternatives were considered? What were the prices and risks of other alternatives? If Idaho Power chose not to use these alternatives, why?
Request No. 20: What plans does Idaho Power have to meet short-term deficits in the coming year? What plans does Idaho Power have to meet short-term deficits in subsequent years?
Request No. 21: Does Idaho Power believe that continued reliance on the market to meet short-term deficits is prudent? Have recent high market prices caused Idaho Power to re-evaluate or change its planned level of reliance on the market? If so, how? What level of reliance does the Company believe is appropriate?
Request No. 22: Please explain how the IRP is used internally by Idaho Power for power supply planning. Does Idaho Power prepare any other documents, such as business plans, that it uses in making power supply decisions? If so, please provide a copy of them.
Request No. 23: Please provide a bill frequency analysis for each customer class using billing intervals of 100 kWhs. This data is requested in electronic Microsoft Excel format.
Request No. 24: Please provide an estimate of the time required to modify the Company’s billing procedure to accommodate billing based in part on historical usage.
Request No. 25: Please provide any and all planning information utilized or developed by the Company after July 2000 that projects loads/resources for November and December of 2000 and January of 2001 and specifies how loads would be met and at what price.
Request No. 26: Please provide a breakdown of monthly actual load and resource portfolio used to meet load for the months of November and December of 2000 and January of 2001.
DATED at Boise, Idaho, this day of March 2001.
______________________________
Lisa D. Nordstrom
Deputy Attorney General
Technical Staff: Rick Sterling
LN:RPS:gdk/umisc/prdreq\/ipce01.7 & 11Lnrps
FIRST PRODUCTION REQUEST 2 MARCH 23, 2001
TO IDAHO POWER