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HomeMy WebLinkAbout20090612IPC to Staff 97-103.pdf1SIDA~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 Sixth Production Request of the Commission Staff in the above matter. Also, enclosed in a separate envelope are an original and three (3) copies of Idaho Power Company's Confidential Response to the ComlTission Staffs Sixth Production Request and 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.vrm)~ 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 PROVIDED DURlJM~ l PM It: itS COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDIMHO PUBLIC.. M ARE PROTECTED FROM PUBLIC INSPECTION UTu..1'lËS COMMISSìOi,\ Case No. IPC-E-09-03 The undersigned attorney, in accordance with RP 233, hereby certifies as follows: 1. The Response to Production Request No. 98 propounded by the Commission Staff during the course of the above-referenced case contains 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. C\ ~-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 bkline(Çidahopower.com Inordstrom(Çidahopower.com RECEI\lr-rlc,"' 1l1g JON I ,I PH 4: 48 L1T,d9ft~oC~UBL¡G MM/S$lûN 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 SIXTH ) PRODUCTION REQUEST OF THE ) COMMISSION STAFF TO IDAHO ) POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), and in response to the Sixth Production Request of the Commission Staff to Idaho Power Company dated June 4, 2009, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO. 97: Please provide documentation to support the amount included in the Commitment Estimate for Air Permitting. Please provide copies of contracts as well as documentation showing amounts spent to date. RESPONSE TO REQUEST NO. 97: The contracts responsive to this Request have been provided to those parties that have executed the Protective Agreement in place in this matter. The amount shown in the Commitment Estimate for air permitting was $320,000.00. A breakdown of the air permitting costs is as follows: Contract Spent to Date Tetra Tech Original Siting Air Study $ 91,033.00 $91,034.06 Tetra Tech Actual Site Air Study $ 11,000.00 $7,788.71 Tetra Tech - MET Station and monitoring $ 99,976.00 $48,440.74 Anvil Fence Company - MET Fencing $7,970.00 $7,970.00 CH2M Hil - Permit to Construct $134,828.00 $61.496.41 Totals:$ 344,807.00 $216,729.92 The response to this Request was prepared by Vern Porter, General Manager, Power Production, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO. 98: Idaho Power has included an amount in its Commitment Estimate to cover the cost of "start-up test fueL." Please provide documentation showing whether "start-up test fuel" was or was not included in the final bid price for each of the short listed bids. RESPONSE TO REQUEST NO. 98: The response to this Request is confidential and is being provided to those parties that have executed 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 SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO. 99: Reference Idaho Power's response to ICIP Production Request No. 23. Please state these percentage increases in current 2009 dollars (or some other identified comparable basis) so that the traditional ratemaking illustrative example increase of 7.88% is comparable to the total illustrative example of AFUDC increase of 6.9%. Please extend all percentages to two decimal places in your response containing the Excel file with formulas activated. RESPONSE TO REQUEST NO. 99: Idaho Power's response to ICIP's Request for Production No. 23 reads as follows: Included on the enclosed CD is the electronic spreadsheet developed under my direction to demonstrate the potential to reduce rate shock by employing either AFUDC Pay Currently or CWIP in Rate Base versus the third alternative to place in service at the end of construction the entire CWIP balance, including AFUDC of the Langley Gulch Power Plant. The analysis is for ilustrative purposes only and does not predict the future impact of these alternatives. Idaho Power is unable to provide the requested information because the request is not sufficiently specific. The above-described analysis was produced in response to ICIP's Request No. 23 to portray the difference in annual rate increases given two additional alternatives to traditional ratemaking between the time period 2010 and 2013, the first full year of the Langley Gulch project in rate base. To produce an additional example per the request would require the Staff to provide additional data assumptions and clarification of the request. The response to this Request was prepared by Lori Smith, Vice President of Finance and Chief Risk Officer, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 REQUEST NO. 100: Reference Idaho Power's response to ICIP Production Request No. 23. If the preparer of this spreadsheet were calculating the relative results of traditional ratemaking, AFUDC similar to Hells Canyon Relicensing in Order No. 30722, and "CWIP (including AFUDC) in Rate Base" would anything on the spreadsheet change? If so, please provide an Excel spreadsheet with formulas intact with all changed items identified (such as with yellow fill in the cell) and the final result of those changes. RESPONSE TO REQUEST NO. 100: Idaho Power's response to ICIP's Request for Production No. 23 reads as follows: Included on the enclosed CD is the electronic spreadsheet developed under my direction to demonstrate the potential to reduce rate shock by employing either AFUDC Pay Currently or CWIP in Rate Base versus the third alternative to place in service at the end of construction the entire CWIP balance, including AFUDC of the Langley Gulch Power Plant. The analysis is for ilustrative purposes only and does not predict the future impact of these alternatives. No. Nothing in the spreadsheet would change. The intent of the spreadsheet provided in ICIP's Production Request No. 23 is to, for ilustrative purposes, compare the annual rate increase differences between AFUDC: Pay Currently, CWIP in Rate Base, and Traditional Rate Making that would not allow for increases prior to the close of the Langley Gulch project. The response to this Request was prepared by Lori Smith, Vice President of Finance and Chief Risk Offcer, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 REQUEST NO. 101: Reference Idaho Power's response to ICIP Production Request No. 23. What would be the relative results of traditional ratemaking, AFUDC similar to Order No. 30722, and CWIP in rate base when income taxes, deferred federal income taxes associated with depreciation differences, and using a ~-year convention to recognize accumulated depreciation in traditional ratemaking were incorporated into the spreadsheets? Please include within your response an Excel spreadsheet with formulas intact that include these components and the final result of incorporating those components. If any other elements should be incorporated into the spreadsheet, please do so and state why. RESPONSE TO REQUEST NO. 101: Idaho Power's response to ICIP's Request for Production No. 23 reads as follows: Included on the enclosed CD is the electronic spreadsheet developed under my direction to demonstrate the potential to reduce rate shock by employing either AFUDC Pay Currently or CWIP in Rate Base versus the third alternative to place in service at the end of construction the entire CWIP balance, including AFUDC of the Langley Gulch Power Plant. The analysis is for ilustrative purposes only and does not predict the future impact of these alternatives. Idaho Power has not prepared the analysis requested and the requested analysis is beyond the capability of this ilustrative example to demonstrate the annual differences in rate making treatments available to the Commission in this proceeding. The Request asks the Company to make the hypothetical assumption that the rate base of the Langley Gulch project would be filed with a ~ year convention associated with depreciation expense. This assumption is beyond the capabilty of the ilustrative example and implies that there is only one way to rate base significant plant estimates like the Langley Gulch project. For example, the regulatory filngs for both Bennett IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6 Mountain Power Plant and Danskin Power Plants provided regulatory relief not based on ~ year convention associated with depreciation. The response to this Request was prepared by Lori Smith, Vice President of Finance and Chief Risk Officer, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 7 REQUEST NO. 102: Reference Idaho Power's response to ICIP Production Request No. 23. Please identify and provide the analysis from which it was determined that revenues would grow 1 % each year. RESPONSE TO REQUEST NO. 102: Idaho Power's response to ICIP's Request for Production No. 23 reads as follows: Included on the enclosed CD is the electronic spreadsheet developed under my direction to demonstrate the potential to reduce rate shock by employing either AFUDC Pay Currently or CWIP in Rate Base versus the third alternative to place in service at the end of construction the entire CWIP balance, including AFUDC of the Langley Gulch Power Plant. The analysis is for ilustrative purposes only and does not predict the future impact of these alternatives. The assumption in the ilustrative example that revenues would grow 1 percent each year was not intended to portray any expectation by Idaho Power. This was a simplifying assumption for the hypothetical illustration of the annual differences between the regulatory treatments of AFUDC Pay Currently, CWIP in Rate Base and Traditional Ratemaking. The response to this Request was prepared by Lori Smith, Vice President of Finance and Chief Risk Officer, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 8 REQUEST NO. 103: Reference Idaho Power's response to ICIP Production Request No. 23 and its response to Staffs Production Request Nos. 99 through 102. Please make the preparer of the ICIP Production Request responses available no later than June 17th for discussing all components of the spreadsheet and in order to provide all/any related documentation (memos, e-mails, other spreadsheets, correspondence, and so forth) not previously provided associated with this issue. RESPONSE TO REQUEST NO. 103: Idaho Power's response to ICIP's Request for Production No. 23 reads as follows: Included on the enclosed CD is the electronic spreadsheet developed under my direction to demonstrate the potential to reduce rate shock by employing either AFUDC Pay Currently or CWIP in Rate Base versus the third alternative to place in service at the end of construction the entire CWIP balance, including AFUDC of the Langley Gulch Power Plant. The analysis is for ilustrative purposes only and does not predict the future impact of these alternatives. Idaho Power is wiling to meet with Staff to discuss its response to the above- referenced Requests. Please call Doug Jones at 388-2615 or Cathy Culp at 388-2637 to arrange a meeting time and place. The response to this Request was prepared by Lori Smith, Vice President of Finance and Chief Risk Officer, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 11 th day of June 2009. QètL BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 9 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 SIXTH 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 Attorney General Idaho Public Utilties 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 -X Hand Delivered U.S. Mail _ Overnight Mail FAX -X Email Scott.Woodbury(Çpuc.idaho.gov Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email peter(Çrichardsonandoleary.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email dreading(Çmindspring.com Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email kmiler(Çsnakeriveralliance.org Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email elo(Çracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 10 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email tony(Çyankel.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 bbridge(Çwildidaho.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.ackerman(Çcomcast.net Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 1 ¡th Street Boise, Idaho 83702 Hand Delivered -X U.S. Mail _ Overnight Mail FAX -X Email bmpurdy(Çhotmail.com J)¿gBarton L. Kline -- IDAHO POWER COMPANY'S RESPONSE TO THE SIXTH PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 11