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HomeMy WebLinkAbout20100512IPC to ICIP 1-9.pdfLISA D. NORDSTROM Lead Counsel InordstromCãidahopower.com 1SIDA~POR~ An IDACORP Company May 11, 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-10-12 2010-2011 peA Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Response to the First Production Request of the Industrial Customers of Idaho Power in the above matter. In addition, four (4) disks containing electronic information responsive to the Industrial Customers' Production Request Nos. 8 and 9 have also been enclosed. Also, enclosed in a separate envelope are an original and three (3) copies of Idaho Power's Confidential Response to the First Production Request of the Industrial Customers of Idaho Power. Please note this information should be handled in accordance with the Protective Agreement executed in this matter. Very truly yours, Jt~~.'V~ Lisa D. Nordstrom LDN:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 LISA D. NORDSTROM (ISB No. 5733) DONOVAN E. WALKER (ISB No. 5921) Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5825 Facsimile: (208) 388-6936 Inordstromtâidahopower.com dwalkertâidahopower.com \ \ RECEIVED iow HAY" 'PH 1.: 56 fun ol I.;"', pI '.--1 '" f, _ ' ' ,-rt!À.v.J UL~ ~ 1 \~!UTllIT¡ i:~ cn~;t\41';; ç:¡ir,,,'... i¡. 'f'..u,~_vl"J 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 FOR ) CASE NO. IPC-E-10-12 AUTHORITY TO IMPLEMENT POWER ) COST ADJUSTMENT ("PCA") RATES FOR ) IDAHO POWER COMPANY'S ELECTRIC SERVICE FROM JUNE 1, ) RESPONSE TO THE FIRST 2010, THROUGH MAY 31, 2011. ) PRODUCTION REQUEST OF THE ) INDUSTRIAL CUSTOMERS OF ) IDAHO POWER ) COMES NOW, Idaho Power Company ("Idaho Powet' or the "Company"), and in response to the First Production Request of the Industrial Customers of Idaho Power to Idaho Power Company dated April 19, 2010, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 1 REQUEST NO.1: In the Company's reply comments on pages 7-8 in Case No. IPC~E-1 0-01, the Company states that it used its "most currently available mine plan" for the Company's decremental cost analysis. Please also refer to page 8, lines 11-12, of Tom Harvey's confidential reply testimony filed in Oregon PUC Docket No. UE 214, which is Attachment NO.3 in Idaho Power's reply comments in IPC-E-1 0-01, and which describes the decremental 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 filed 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 useful comparison when its base input of cost per ton of BCC coal is different from the filed costs in the NPSE case. (e) If the cost per ton in (a) is lower than the cost per ton in (b), please also explain how the NPSE that the Company proposes to recover in base rates starting June 1, 2010 is fair, just and reasonable when the most currently 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 Harvey's reply testimony) multiplied by Idaho's allocation of the total tons of BCC coal the Company plans to mine during the 2010 NPSE test year. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 2 (g) Please explain why, even assuming continued mining of BCC surface coal is prudent, the 2010 NPSE should not be reduced by the amount in (f). RESPONSE TO REQUEST NO.1: The response to this Request contains confidential information and wil be provided to those parties that have executed the Protective Agreement in place in this matter. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, and Timothy E. Tatum, Cost of Service Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 3 REQUEST NO.2: Did the Company's decremental cost analysis in IPC-E-10-01 use the sales price of BCC coal that includes the Company's return on its costs of mining BCC coal? If not, please explain how the Company's decremental cost provides a useful comparison to a sales price for Black Butte coal, which presumably includes Black Butte Mine's profit margin. RESPONSE TO REQUEST NO.2: Idaho Power Company did not perform a decremental cost analysis for use in Case No. IPC-E-10-01. The decremental cost analysis referred to was provided to Oregon Staff in Case No. UE 214. Again, it must be noted that the decremental cost analysis and NPSE filings are based on different test periods and mine operating plans. As explained in the Company's Response to Request No. 1(e) above, the use of an operating margin for NPSE purposes is accurate. It would not be accurate to use the BCC sales price (including the margin) as the decremental cost because the operating margin could only be eliminated if the entirety of coal deliveries from BCC were eliminated. Discontinuing delivery of only surface coal does not eliminate the need for a return on BCC rate base. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 4 REQUEST NO.3: Please explain the discrepancy between the 2010 Forecast All-in Contract costs for BCC coal provided in response to Staff's production request no. 3 in IPC-E-10-01 and the sales price for BCC coal provided in response to ICIP's production request no. 1 in IPC-E-10-01. Which was used in the calculation of 2010 NPSE in the Company's application, and why? RESPONSE TO REQUEST NO.3: The response to this Request contains confidential information and wil be provided to those parties that have executed the Protective Agreement in place in this matter. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 5 REQUEST NO.4: Please explain the discrepancy between the 2010 Forecast All-in Contract costs for Black Butte coal provided in response to Staff's 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-10-01. Which was used in the calculation of 2010 NPSE in the Company's application, and why? RESPONSE TO REQUEST NO.4: The response to this Request contains confidential information and wil be provided to those parties that have executed the Protective Agreement in place in this matter. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 6 REQUEST NO.5: Please provide the communications, and all documentation thereof, with Kiewit Mining as of February 5, 2010 regarding the possibilty of obtaining additional supplies of Black Butte coal, as referred to on page 8 of Idaho Power's White Paper in Case No. IPC-E-10-01. RESPONSE TO REQUEST NO.5: The response to this Request contains confidential information and wil be provided to those parties that have executed the Protective Agreement in place in this matter. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 7 REQUEST NO.6: Please provide a decremental cost for BCC surface coal calculated with the BCC coal cost used in the Company's application in IPC-E-10-01. RESPONSE TO REQUEST NO.6: A decremental cost analysis was not prepared using the BCC coal cost used in the Company's Application in Case No. IPC- E-10-01. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 8 REQUEST NO.7: Did PacifiCorp or Idaho Power conduct further inquiries after February 5, 2010 regarding availabilty of Black Butte coal? If so, please provide those communications. RESPONSE TO REQUEST NO.7: No. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 9 REQUEST NO.8: Please provide in electronic format S. Wright Exhibit NO.1. RESPONSE TO REQUEST NO.8: Please see the attached Excel spreadsheet included on the enclosed CD. The response to this Request was prepared by Scott Wright, Pricing Analyst, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 10 REQUEST NO.9: Please provide in electronic format T. Tatum Exhibit No. 2 pages 1, 12, 13, and 14. RESPONSE TO REQUEST NO.9: Please see the attached Excel file included on the enclosed CD. The response to this Request was prepared by Timothy E. Tatum, Cost of Service Manager, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 11th day of May 2010. g~()~~ LISA D. NoRDšTM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 11 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of May 2010 I served a true and correct copy of the foregoing IDAHO POWER COMPANY'S RESPONSE TO THE FIRST 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 Weldon B. Stutzman Deputy Attorney General Idaho Public Utilties Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email Weldon.stutzmantâpuc.idaho.gov Industrial Customers of Idaho Power Peter J. Richardson Gregory M. Adams RICHARDSON & O'LEARY, PLLC 515 North 27th Street P.O. Box 7218 Boise, Idaho 83702 -2 Hand Delivered U.S. Mail _ Overnight Mail FAX -2 Email petertârichardsonandoleary.com gregtârichardsonandoleary.com Dr. Don Reading 6070 Hil Road Boise, Idaho 83703 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email dreadingCCmindspring.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 -2 U.S. Mail _ Overnight Mail FAX -2 Email eloCCracinelaw.net IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 12 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Hand Delivered -2 U.S. Mail _ Overnight Mail FAX -2 Email tonYCCyankel.net IDAHO POWER COMPANY'S RESPONSE TO THE FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER - 13