20100422ICIP 1-9 to IPC.pdf

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Peter 1. Richardson ISB # 3195
Gregory M. Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~chadsonad:olew.com
gregØ)ncliardsonadolear.com
22 ¡;.t~ 8: 09LOW ~PR - i'
Attorneys for the Industrial Customers of Idao Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN TH MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY TO IMPLEMENT POWER
COST ADJUSTMENT ("PCA") RATES
FOR ELECTRIC RATES FROM JUE 1,
2010 THOUGH MAY 31, 2011.
) CASE NO.IPC-E-IO-12
)
) FIRST PRODUCTION REQUEST OF
) THE INDUSTRI CUSTOMERS OF
) IDAHO POWER
)
Pusuant to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission
(the "Commission"), the Industral Customers ofIdao Power ("ICIP") hereby requests that
Idaho Power Company ("Idaho Power") provide responses to the following with supporting
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 acting 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 anwer to
Mr. Adas at the address noted above. Please provide an additional electronic copy, or if
unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel:
Page 1 - FIRST PRODUCTION REQUEST OF THE INDUSTRI
CUSTOMERS OF IDAHO POWER- IPC-E-IO-12
[phone]; Fax: [phone]; dreading~mindspring.com.
For each item, please indicate the name of the person(s) preparng the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
Some of the followig requests may include disclosures deemed by Idaho Power to be
confidential. Counsel and the expert witness for the Industrial Customers of Idaho Power signed
a protective agreement to obtain the materials relevant to ths proceeding, and are therefore
entitled to review any confidential materials necessary to adequately respond to ths Production
Request.
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CUSTOMERS OF IDAHO POWER- IPC-E-IO-12
REQUEST FOR PRODUCTION NO.1
In the Company's reply comments on pages 7-8 in Case No. IPC-E-1O-01, the Company states
that it used its "most curently available mine plan" for the Company's decrementa cost
analysis. Please also refer to page 8, lines 11-12, of Tom Harey's confdential reply testimony
fied in Oregon PUC Docket No. UE 214, which is Attachment NO.3 in Idaho Power's reply
comments in IPC-E-10-01, and which describes the decrementa cost analysis in more detaiL.
(a) What was the cost per ton of BCC coal used in the decremental cost analysis?
(b) What is the cost per ton of BCC coal included in the Company's calculation of
2010 NPSE fied in its application in Case No. IPC-E-10-01?
(c) If the answers to (a) and (b) are different costs per ton for BCC coal, please
explain why.
(d) If the answers to (a) and (b) are different, please also explain how the decremental
cost analysis could provide a usefu comparson when its base input of cost per
ton of BCC coal is different from the fied costs in the NPSE case.
(e) If the cost per ton in (a) is lower than the cost per ton in (b), pleae also explain
how the NPSE that the Company proposes to recover in base rates staing June 1,
2010 is fair, just and reasonable when the most curently available mine plan
calls for lower BCC coal costs per ton.
(f) Please provide the product of the difference from the costs per ton in (a) and (b)
(which is available at page 8, line 12 of Harey's reply testimony) multiplied by
Idaho's allocation of the total tons ofBCC coal the Company plans to mine
durng the 2010 NPSE test year.
(g) Please explain why, even assuming continued mining of BCC surface coal is
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CUSTOMERS OF IDAHO POWER- IPC-E-IO-12
prudent, the 2010 NPSE should not be reduced by the amount in (f).
REQUEST FOR PRODUCTION NO.2
Did the Company's decrementa cost analysis in IPC-E-10-01 use the sales pnce ofBCC coal
that includes the Company's retur on its costs of mining BCC coal? Ifnot, please explain how
the Company's decremental cost provides a useful comparson to a sales price for Black Butte
coal, which presumably includes Black Butte Mine's profit margin.
REQUEST FOR PRODUCTION NO.3
Please explain the discrepancy between the 2010 Forecast All-in Contract costs for BCC coal
provided in response to Stas production request no. 3 in IPC-E-1O-01 and the sales price for
BCC coal provided in response to ICIP's production request no. 1 in IPC-E-10-01. Whch was
used in the calculation of 2010 NPSE in the Company's application, and why?
REQUEST FOR PRODUCTION NO.4
Please explain the discrepancy between the 2010 Forecast All-in Contract costs for Black Butte
coal provided in response to Stafs production request no. 3 in IPC-E-10-01 and the sales price
for Black Butte coal provided in response to ICIP's production request no. 4 in IPC-E-1O-01.
Whch was used in the calculation of2010 NPSE in the Company's application, and why?
REQUEST FOR PRODUCTION NO.5
Please provide the communcations, and all documentation thereof, with Kiewit Mining as of
Februar 5, 2010 regarding the possibility of obtaining additional supplies of Black Butte coal,
Page 4 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER- IPC-E-IO-12
as referred to on page 8 of Idaho Power's Whte Paper in Case No. IPC-E-1 0-0 1.
REQUEST FOR PRODUCTION NO.6
Please provide a decremental costfor BCC surace coal calculated with the BCC coal cost used
in the Company's application in IPC-E-10-01.
REQUEST FOR PRODUCTION NO.7
Did PacifiCorp or Idao Power conduct fuher inquines after Febru 5, 2010 regarding
availabilty of Black Butte coal? If so, please provide those communcations.
REQUEST FOR PRODUCTION NO.8
Please provide in electronic format S. Wnght Exhibit NO.1.
REQUEST FOR PRODUCTION NO.9
Please provide in electronic format T. Tatu Exhbit NO.2 pages 1, 12, 13, and 14.
Than you for your prompt attention to ths First Request for Production.
erely yours,~
s
RDSON & O'LEARY, PLLC
Page 5 - FIRST PRODUCTION REQUEST OF THE INDUSTRIL
CUSTOMERS OF IDAHO POWER - IPC-E-1 0-12
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the19th day of April, 2010, a tre and correct copy ofthe
withn and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS
OF IDAHO POWER, was served in the maner shown to:
Ms. Jean Jewell
Commssion Secreta
Idao Public Utilities Commssion
POBox 83720
Boise, ID 83720-0074
_ Hand Delivery
2L U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
Lisa D Nordstrom
Donovan E Waler
Idaho Power Company
POBox 70
Boise, Idaho 83707-0070
InordstomØ)idaopower.com
dwalerØ)idahopower.com
X Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
Electronic Mail
~1l1
Nina Curis
Administrative Assistant