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
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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