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Home My WebLink About20100225ICIP 13-24 to IPC.pdf_ r .Qlr.~~ PUATTORNEYS AT LAW Tel: 208-938-7900 Fax: 208.938-7904 P.O. Box n18 Boise. ID 83707 - 515 N. 27th St. Boise, ID 83702 24 February 2010 Ms. Jean Jewell Commission Secretary Idaho Public Utilities Commission 472 W. Washington Boise, 10 83702 RE: IPC-E-10-01 Dear Ms. Jewell: Rr-Cl"¡-i f:,JC ~ 2010 FEB 2S AM 8: 10 We are enclosing three (3) copies of the THIRD 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 encl. Peter J. Richadson iss # 3195 Gregory M. Adams ISB # 7454 . RICHASON & O'LEARY PLLC 515 N. 27tA Street Boise, Idaho 83702 Telephone.: (208) 938-2236 Fa,: (208).938-:7904 peter!&chardsonandoleary.com greg~richardsonatdolear.com Attorneys for the Industral Customers of Idaho Power RECEf\Jf: f) 2010 FEB 25 AM 8: '0 iDß\fi() UTiLITIES B:EFORE TJl IIAlO PUBLICUTILITIKS COMMSSIQN IN THE MATTER OF THE ) CASE NO. IPC-E-IO..Ol ~llLICATION OF IDAHOPOWtR ) CC)MPÂN TO ESTAlLISFfITS ) TH PRODUCTION REQUEST OF SAS;E WV;EL ~qR.NET POWJR. SUPPL Y ) THE INPlJSTl CUSTOMERS OF EXPENSES FOR 2010. ) IDAHO POWER ) PUrSllt to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Coi:ission"), the Industral Customers of Idaho Power ("ICIP") hereby requests tht Idaho Power Company ("Idaho Power") provide responses to the following with supportg documents, where applicable. Ths production request is to be considered as contiuing, and the Idaho Power is requestd to provide by way of supplementa responses additional documents that it or any person actig on its behalf may later obtai 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 - TI PRODUCTION REQUEST OF THE INUSTRL CUSTOMERS OF IDAHO POWER - lPC-E-l 0-0 1 unavailable a physical copy, to Dr. Don Readig at: 6070 Hil Road, Boise, Idaho 83703, Tel: (208) 342-1700; Fax: (208) 384-1511; dreading(gmidsprig.com. For 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 sponsortheanswer. Some of the following requests may include disclosures deemed by IdaøPowertobe confdential. Counel and the expert witness of the Ind.usal CusomersofIdaø Power have signed and submitted the protective agreement in ths proceeding, and are therefore entitled to receive confdential inornontelevant tö this proceeg, subjeCt tö thê tei'llS of thåt agreement. These requests Jorproduction are identical in substa to Oregon PUC Sta.s Data Request Nos. 25 to 36 in OregollPUC Docket No. UE 214, due in th.docet,onMarh3, 2010. Thus, Idaho Power's production to the pares in ths case of its responses to those requests in the Oregon HE 214 docket will be sufcient responses to the followig requests for prochction. Page 2 - THI PRODUCTION REQUESl OF TH INUSTR. CUSTOMERS OF IDAHO POwER.. IPC.;E-I0~01 REQUEST FOR PRODUCTION NO. 13 Please provide the average cost and tonnage of coal delivered from Bridger Coal Company (BCC) and Black Butte (BB) Mines for each year 2005 though 2009. a. For the years 2007 and 2009, please provide costs and tons delivered per month p.er year from both BCC and BE. REQIJ:EST F9RPRODUCTION NO. 14 Please explai the purose of "mixing" BCC surace and underground coal to achieve requied qnaty levels. a. Whatare the quaty metrcsthat are being achieved (i.e., Btu SOi, other)? b. How is "mixig" performed durg the months that BCC does not provide surace coal? c. Is.the BB coal used for "mixig"? Please explain. REQUEST. FOR PRODUCTION NO. 15 Please outline any specifications I quality dierences (Btu, SOi, etc.) between BCC and BB coal. a. Is BB coal of a suffcient specification I quaity to bur at Bridger or is there some ty of mixing or treatment requied to bur BB coal that is not requied for BCC coal? Please explai. REQUEST FOR PRODUCTION NO. 16 As a follow-up ICIP's Request for Production No.2 in this docket (Oregon PUC Stas Data Request No. 20 in Oregon PUC Docket No. UE 214), please explain the November 2010 BB tonne, Which is higher than the other eleven months. a. What in BB's contract allows for increased tonnage durg ths month? Please explai. Page 3 - TH PRODUCTION REQUEST OF TH INUSTR CVSTOMERS OF IDAHO POWER -- lPC-E-l 0-01 b. What in BB's contract limts ths increased supply for only one month? Please explai. REQUEST FOR PRODUCTION NO.17 Pleae provide copies of any correspondence withBB that discusses the possibility of increasing supplies to Bridger over the amounts listed in Idao Power's response to ICIP's Request for Production NO.2 in ths docket (Oregon PUC Stas Data Request No. 20 inOre-gon PUC Docket No. HE 214). a. Has Idaho Power, IERCO, Pacific Minerals, or PacifiCorp specificalydnquied about .increasing supplies to Bridger to. provirlemore .thanone;.thd of Bridger's coal? Pleae expla and provide copies of relevantcorrespondeiice. REQUEST FOR PRODUCTION NO. 18 Pleae provide copies of any correspondence in which BB ha specifically declined to or has been unable to increase supplies to Bridger in 2008 and 2009, based on request fromldao Power, IERCO, Pacific Mierals, or PacifiCorp. REQUEST FOR PRODUCTION NO. 19 Please explain the increased BCC underground tons supplied durg the months tht surace coal is not provided to Bridger. Please explai why ths underground supply is not susable over the 12-month period. REQUEST FOR PRODUCTION NO. 20 As an update to Idaho Power's response to Oregon PUC Stas Data Request No. 172 in Oregon PUC Docket No. UE 213, please provide the IERCO Operatig Cost Sum for 2009. Concerng the Operatig Sumaries: Page 4 - TH PRODUCTION REQUESTOF TH INUSTRI CUSTOMERS OF IDAHO POWER - IPC-E-I0-01 a. Please stte which line items (i.e., management fee, other) is alocated between underground and surace operations? b. Please provide the allocation percent and method (i.e., tons, operating expenses, etc.) between surface and underground operations. c. For each line item for surface tons delivered, which line item costs are diectly allocated tp surl;ce operatiops? d. Wht surace line item cost (i.e., management fee, other) would be transferredt9 undergrund operations if the surace operation ceased? Please explai. e. What is the calculated fixed cost per ton for surace operations? REQUEST FOR PRODUCTION NO. 21 As a follow-up to Idaho Power's response to ICIP's Request for Production NO.1 in ths docket (Oregon plJC Stas Data Request NO.1 in Oregon PUC Docket No. UE 214), please explain the difference in BCe tota production cost per ton and BCC sale price per ton. REQUEST FOR PRODUCTION NO. 22 How is BB coal delivered to Bridger (i.e., ral, trck, both, other)? REQUEST FOR PRODUCTION NO. 23 What are the physical limitations, in both quaitative and quatitative terms, of the maximum amount oftonnage regardig delivery ofBB coal if higher delivery amounts were needed? Please explai. REQUEST FOR PRODUCTION NO. 24 As a fol1ow..up to Idao Power's response to Oregon PUC Stas Dat Request NO.6 in Oregon PUC Docket No. DE 214, is there a more recent amendment (afer the Eight Amendment) that Page 5 - THI PRODUCTION REUEST OF THE INUSTRl CUSTOMERS OF IDAHO POWER. -- IPC-E-l 0-01 outlines BeC prices for coal cost staing or includig Janua 2010 or later? Pleae explain. If so, please provide a copy. Than you for your prompt attention to ths Thd Request for Production. y yours,~2-i~-2Jd Dateams SON & O'LEARY, PLLC Page 6 - THI PRODUCTION REQUEST'~F THElNUSTR CUSTOMERS OF IDAHO POWER. - IPC-E-, 1 0-01 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 24th day of Febru, 2010, a tre and correct copy of the withi and foregoing SECOND PRODUCTION REQUEST OF THE INDUSTR CUSTOMERS OF IDAHO POWER COMPANY was served in the maner shown to: Ms. Jean Jewell Commsion Seceta Idao Public Utities Commssion POBox 83720 Boise, ID 83720-0074 _ Hand Delivery i U.S. Mail, postage pre-paid Facsimle Electronic Mail Lisa Nordstrom Baron L. Kline Idaho Power Company POBox 70 Boise, Idaho 83707-0070 Inordstrom(ßidaopower.com bkline(ßidaopower.com _ Hand Delivery X U.S. Mail, postage pre-paid Facsimle lL Electronic Mail Gregory W. Said Idaho Power Company POBox 70 Boise, Idaho 83707-0070 gsaidWdaopower.com _ Hand Delivery X U.S. Mail, postage pre-paid Facsimle lL Electronic Mail ~Nina Curs Admnistrative Assistant