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
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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
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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
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FAX
-X Email dreading(Çmindspring.com
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-X Email kmiler(Çsnakeriveralliance.org
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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
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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