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Home My WebLink About20100304IPC to Staff 3-5.pdfBARTON L. KLINE Lead Counsel bkline(âidahopower.com esIDA~POR(I An IDACORP Company iDj~r'"j() UTILITIES March 3, 2010 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-10-01 BASE LEVEL FOR NET POWER SUPPL Y EXPENSES FOR 2010 Dear Ms. Jewell: Enclosed for filing are an original and three (3) copies of Idaho Power Company's Response to the Third Production Request of the Commission Staff in the above matter. The confidential documents responsive to these requests have been sealed in a separate envelope and have also been provided to those parties that have signed .the Protective Agreement. Very truly yours,0JLL Barton L. Kline BLK:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 CERTIFICATE OF ATTORNEY ASSERTION THAT MATERIALS REQUESTED AND PROVIDED DURING THE COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION PROCEEDING ARE PROTECTED FROM PUBLIC INSPECTION Case No. IPC-E-10-01 The undersigned attorney, in accordance with RP 233, hereby certifies that the attachments provided by Idaho Power Company in response to Staffs Third Production Request propounded during the course of the above-referenced case contain 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 are exempt from public inspection, examination, or copying. DATED this 3rd day of March 2010. ßJ~ Barton L. Kline Attorney for Idaho Power Company ~-t.::i:;:: I.. ;.:J !ri""-_.-"".~":i.i.,..:\. (" '= I,j t,.. : BARTON L. KLINE (ISB No. 1526) LISA D. NORDSTROM (ISB No. 5733) Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 Facsimile: (208) 388-6936 bklinecæidahopower.com Inordstromcæidahopower.com 2U10 MAR -3 PM 5: 04 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 THE APPLICATION OF IDAHO POWER COMPANY TO ESTABLISH ITS BASE LEVEL FOR NET POWER SUPPLY EXPENSES FOR 2010. ) ) CASE NO. IPC-E-10-01 ) ) IDAHO POWER COMPANY'S ) RESPONSE TO THE THIRD ) PRODUCTION REQUEST OF THE ) COMMISSION STAFF TO IDAHO ) POWER COMPANY ) COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in response to the Third Production Request of the Commission Staff to Idaho Power Company dated February 17, 2010, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 1 REQUEST NO.3: Please provide an analysis showing the current all-in cost of coal for Bridger by coal source (Le. Bridger coal, Black Butte coal, market, etc.) RESPONSE TO REQUEST NO.3: Please see the attached spreadsheet showing the current all-in cost of coal for Bridger by coal source. The Bridger Plant does not rely on any market purchases of coaL. The actual sales price per ton for January Black Butte deliveries reflects amounts of coal deferred from prior periods of time at prior contract prices into the January 2010 time period. Since this data is confidential, Idaho Power is providing this information only to parties that have executed the Protective Agreement. The response to this Request was prepared by Kent Christensen, Joint Venture Analyst, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 2 REQUEST NO.4: Please provide all cost/benefit criteria and analyses showing that the coal purchased for Bridger is at the lower cost or market. RESPONSE TO REQUEST NO.4: In response to this Request, the Company has developed a white paper that discusses the total coal sourcing strategy for the Bridger plant. The white paper is attached. The response to this Request was prepared by Donovan E. Walker, Senior Counsel, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 3 REQUEST NO.5: Please provide analysis, documentation, or reports comparing the costs and benefits of water to be leased from the ShoBan Tribe in 2010. RESPONSE TO REQUEST NO.5: Attached is the analysis that provides the net benefit of the water lease agreement. Since this data is confidential, Idaho Power is providing this information only to parties that have executed the Protective Agreement. The response to this Request was prepared by Scott Wright, Pricing Analyst I, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 3rd day of March 2010. ~ BARTON L. KLINE Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 3rd day of March 2010 I served a true and correct copy of the foregoing IDAHO POWER COMPANY'S RESPONSE TO THE THIRD 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 Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Scott.Woodburycæpuc.idaho.gov Industrial Customers of Idaho Power Peter J. Richarcson Gregory Adams RICHARDSON & O'LEARY 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email petercærichardsonandoleary.com gregcærichardsonandoleary.com Dr. Don Reading 6070 Hil Road Boise, Idaho 83703 _Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dreadingcæmindspring.com 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 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email elocæracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 5 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email tonycæyankel.net ~i~ Barton L. Kline IDAHO POWER COMPANY'S RESPONSE TO THE THIRD PRODUCTION REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY - 6