20100305IPC to ICIP 11-12.pdf

BARTON L. KLINE
Lead Counsel
bkline(âidahopower.com
1SIDA~POR~
t~,r~c~r~An IDACORP Company
March 4,2010
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 Second Production Request ofthe Industrial Customers of Idaho Power in
the above matter.
In addition, enclosed in a separate envelope are confidential documents thatare
being provided in response to the production requests. The confidential documents have
also been provided to those parties that have signed the Protective Agreement.
Very truly yours,(l1~
Barton L. Kline
BLK:csb
Enclosures
P.O. Box 70 (B3707)
1221 W. Idaho St.
Boise, ID 83702
BARTON L. KLINE (ISB No. 1526)
LISA D. NORDSTROM (ISB No. 5733)
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
bklineCCidahopower.com
InordstromCCidahopower.com
i::,(~ E: I
2010 HAR-4
PH 4: 51
lj-r,i~ ¡ 1;.
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 SECOND
) PRODUCTION REQUEST OF THE
) INDUSTRIAL CUSTOMERS OF
) IDAHO POWER
)
COMES NOW, Idaho Power Company ("Idaho Powet' or "the Company"), and in
response to the Second Production of Request of the Industrial Customers of Idaho
Power dated February 16, 2010, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1
REQUEST NO. 11: As a follow up to ICIP's production request no. 4, please
provide the entire contract(s) for the sale of coal from Bridger Coal Company to fuel the
Bridger coal plant effective after December 31, 2009. This request refers to the "newly
negotiated agreements starting in 2010" discussed on page 9 of Scott Wright's direct.
testimony in this docket. If there is no written contract, please explain all terms of the
newly negotiated agreement(s), including the prices and the date the parties entered
into the new agreement.
RESPONSE TO REQUEST NO. 11: The "newly negotiated agreements starting
in 2010" discussed on page 4 of Scott Wright's direct testimony refer to the Black Butte
Coal Company contract that is effective after December 31, 2009. The Bridger Coal
Company Third Restated and Amended Coal Sales Agreement was not re-negotiated,
although it has been recently amended. These amendments set forth the pricing of
coaL. The pricing amendments for 2009 and 2010 are included in this response.
Since this pricing 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 Tom Harvey, Joint Projects
Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2
REQUEST NO. 12: Did Idaho Power or PacifiCorp consider ceasing the
purchase of surface-mined coal from Bridger Coal Company after the period of
historically low cost coal ended "due to long-term coal supply contracts that expire(d) at
the end of 2009," as discussed on page 9 of Scott Wright's direct testimony in this
docket? Please explain what steps the utilities took to evaluate the cost-effectiveness
and/or feasibility of purchasing coal from an alternative, non-affliate supplier when the
long term contracts ended after 2009. If the utilities took no steps to conduct such an
evaluation, please explain why.
RESPONSE TO REQUEST NO. 12: See the Company's Response to Request
No. 11. The full response to this Request also contains confidential information and wil
be provided to those parties that have executed the Protective Agreement.
The response to this Request was prepared by Tom Harvey, Joint Projects
Manager, Idaho Power Company, in consultation with Barton L. Kline, Lead Counsel,
Idaho Power Company.
DATED at Boise, Idaho, this 4th day of March 2010.
Q;~
BARTON L. KLINE
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 4th day of March 2010 I served a true and
correct copy of the foregoing IDAHO POWER COMPANY'S RESPONSE TO THE
SECOND PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO
POWER upon the following named parties by the method indicated below, and
addressed to the following:
Commission Staff
Scott Woodbury
Deputy Attomey 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.Woodbury((puc.idaho.gov
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY
515 North 27th Street
P.O. Box 7218
Boise, Idaho 83702
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email peter((richardsonandoleary.com
greg((richardsonandoleary.com
Dr. Don Reading
6070 Hil Road
Boise, Idaho 83703
_Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email dreading((mindspring.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 SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4
Anthony Yankel
Yankel & Associates, Inc.
29814 Lake Road
Bay Vilage, Ohio 44140
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email tony((yankel.net
.J~Barton L. Kline
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5
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-1 0-01
The undersigned attorney, in accordance with RP 233, hereby certifies that the
documents provided by Idaho Power Company in response to the Industrial Customers
of Idaho Power's Second 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 4th day of March 2010.
~~
Barton L. Kline
Attorney for Idaho Power Company
f"=--=3~;o?J
i.i
-0::;co-
r",'::
'""'
.:J
c.o