The URL can be used to link to this page

Home My WebLink About20100211ICIP 1-10 to IPC.pdfRECFll~r.QJiJr.~ ~ATTORNEYS AT LAW Peter Richardson 20'0 FEB l I AM 8: 17 Tel; 208-938-7901 Fax: 208-938-7904 IDAHO P.o. Box 7218 B~~S::ri~ri;:7a;;s~n~~;o~~~:;hC~~ Boise, 1D 83702UTlUTl ES 10 February 2010 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Washington Boise, ID 83702 RE: IPC-E-10-01 Dear Ms. Jewell: We are enclosing three (3) copies of the FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER in the above case. The original has been delivered to Idaho Power Company. An additional copy is enclosed for you to stamp for our records. Sincerely,~ Richardson & O'Leary PLLC Peter J. RichaonlSB # 3195 Gregory M. Adams ISB # 7454 RICHASON & O'LEARY PLLC 515 N. 27th Street Boise, I(.o 8370l Telephone: (08) 938-2236 Fax: (08).93R-7904 peter(iichardsonaolear.comgtei(â~dolAA.com Or:,.,-.~.~.1,.\..L.:1 201U FEB II AM 8: 17it, ' UTidTíHsU Attorneys for th Industral Customer of Idaho Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE ) CASE NO. IPC-E-IO..Ol APPLICATION OF IDAHO POWER ) COMPANY TO ESTABLISH ITS ) FIRST PRODUCTION REQUEST OF BASE LEVEL FOR NET POWER SUPPLY) THE INDUSTRIAL CUSTOMERS OF EXPENSES FOR 2010. ) IDAHO POWER ) Pusuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commssion (the "Commssion"), the Industral Customers ofIdaho Power ("ICIP") hereby requests that Idaho Power Company ("Idaho Power") provide responses to the followig with supportng documents, where applicable. Ths production request is to be considered as continuing, and the Idaho Power is requested to provide by way of supplementa responses additional documents that it or any person actig on its behalf may later obtan that will augment the responses or documents produced. Please provide one physical copy and one electronic copy, if available, of your answer to Mr. Adams at the address noted above. Please provide an additional electronic copy, or if Page 1 - FIRST PRODUCTION REQUEST OF THElNUSTRI CUSTOMERS OF IDAHO POWER-IPC-E-I0-Ql unavailable a physical copy, to Dr. Don Readg at: 6070 Hil Road, Boise, Idaho 83703, Tel: (208) 342-1700; Fax: (208) 384-1511; dreadingCÐmindspring.com. F or each item, please indicate the name of the person( s) preparg the answers, along with the job title of such person(s) and the witness at hearng who can sponsor the answer. Some of the followig requests may include disclosures deemed by Idao Powêr to be confidential. Counsel for the Industral Customers of Idao Power contacted counsel for Idaho Power regarding a confidentiality agreement prior to sending these Requests for Production. Counsel and the expert witness of the Industral Customers of Idaho Power are prepared to sign any such agreement to obtan the materials relevant to ths proceeding, and expect that executing such a confidentiality agreement will not delay Idaho Power's responses to these Requests for Production. Page 2 - FIRST PRODUCTION REQUEST OF THEINDUSTRML CUSTOMERS OF IDAHO POWER- IPC-E-I0-01 (' REQUEST FOR PRODUCTION NO.1 For eah mont in 2010, pleae provide inormation in the followig tablefönnat. (BCC.equas Bridger Coal Compan,y.) January February March Etc BCC Surace cost per ton with EITF 04~6 effect) Bee Underground cost per ton BCC Incrementa cost per ton if a.pp~icable) Bce Total cost per ton 3rd Par coal cost per ton list separately for each supplier) 3rd par coal trporttion cost per ton list separately for each supplier) lotalB:ridger Costs BC.C Surace Cost per ton (without EITF 04~6 effect) REQUEST FOR PRODUCTION NO.2 As a follow up to pröduction Request No. 1, please.also explai any thd par deferred pricing. a. Is ths price a.dded to the spot price to determine the cost for the associated delivery or is it a stad~alone price per ton? b. For each month, please provide the total cost and average cost per ton for the thd par mine based on tons delivered. Page 3 - FIRST PRODUCTION REQUEST OF TH INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E-IO~Ol \ REQUEST FOR PRODUCTION NO.3 For each month in 2010, please provide the following inormation in the following table format. (BCC equals Bridger Coal Company.) Please provide IPC shae (33.33 percent). January February March Etc BCC Surace tons BCC Underground tons BCC Incremental tons if applicable) BCC Tota tons 3rd Par tons (list separate1y for each supplier) . Total tons supplied to Bridger REQUEST FOR PRODUCTION NO.4 Concernng the Direct Testimony of Scott Wright at pages 8-9, please provide the 2007, 2008, 2009, and 2010 cost per ton for each (afliate and third par) coal.supplier for Bridger Ínthe following table format. Please list each supplier separately. Please providë applicable pages, of each contract that lists pricing. ~~fged pay 2007 2008 2009 2010 REQUEST FOR PRODUCTION NO.5 As a follow up to Request for Production No.4, please explain why the costs for BCC coal have increased. Page 4 - FIRST PRODUCTION REQUEST OF THE INDUS"mL . CUSTOMERS OF IDAHO POWER- IPC-E-IO-Ol REQUEST FOR PRODUCTION NO.6 Concernng the Direct Testimony of Scott Wright at page. 9 regardig the new contract to purchas BCC coal after 20Q9, pleas explai why Idaho Power entered into a contrçt to purcha.ttsaflia,te's (BeC's) surace-mined coal (with EITF 04-6 effect) when that çost is substtially higher than the cost of coal available though the Bridger thd par. REQUEST FOR PRODUCTION NO. 7 Please provide a list of the values of the fuel prices, trsporttion costs, maintenace outages, heat rates and forced outage rate varables for all the coal and gas thermal genei-tion.plantsus in the AURORA model ru. Please explain the varation for any of the varables that are more th 3% different from the value used in the previous NPSE analysis authorized in Idao Public Utilties Commssion Order No. 30722 from the 2008 General Rate Case. REQUEST FOR PRODUCTION NO.8 Please provide an updted list of the PURA contracts modeled in the AURORA ru including anua output and unt cost. Indicate which are existing contracts and which are new. REQUEST FOR PRODUCTION NO.9 As a follow up to Request for Production No.8, please list each new PURP A contrct, and state the online date in the contract and whether the project is online curently. For new PURPA contracts that are not online curntly, please provide information in possession of the Company regardig any delays in the likely online date from that set fort in the applicable contract. Page 5 - FIRST PRODUCTION REQUEST OF THE INDUSTRI CUSTOMERS OF IDAHO POWER - IPC-E:.I0-01 REQUEST FOR PRODUCTION NO. 10 Idaho Power recently leased some water rights in the upper Snake River watershed for August and September. Please demonstrte where the benefit to hydro power output can be seen from this investment. Than you for your prompt attention to this First Request for Production. e dams HARSON & O'LEARY, PLLC Page 6 - FIRST PRODUCTION REQUEST OPTHE INDUSTRIL CUSTOMERS OF IDAHO POWER - IPC-E:CIO-Ol CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 10th day of Febru, 2010, a true and correct copy of the withn and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER COMPANY was served in the maner shown to: Ms. Jean Jewell Commsion Secreta Idao Public Utilities Commssion POBox83720 Boise, ID 83720-0074 Lisa Nordstrom Baron L. Kline Idaho Power Company POBox 70 Boise, Idaho 83707-0070 lnordstromimidahopower.com bklineimidaopower.com Gregory W. Said Idao Power Company POBox 70 Boise, Idaho 83707-0070 gsad~idahopower.com ~ÚJçh. Nina Curs Administrative Assistat _ Hand Delivery _X_ U.S. Mail, postage pre-paid Facsimile Electronic Mail X- Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail X Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail