20111116Staff to IPC 1-10.pdf

KARL T. KLEIN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 5156
RECEI 0
20 II NOV l 6 AM If: 49
1)T1
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S REQUEST FOR ACCEPTANCE )
OF ITS REGULATORY PLAN REGARDING )
THE EARLY SHUTDOWN OF THE )BOARDMAN POWER PLANT. )
)
)
CASE NO. IPC-E-11-18
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
IDAHO POWER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Karl T. Klein, Deputy Attorney General, requests that Idaho Power Company (Company; IPC)
provide the following documents and information as soon as possible, by WEDNESDAY,
NOVEMBER 30, 2011, if feasible.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it or any person acting
on its behalf may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title and telephone number of
the person preparing the documents. Please identify the name, job title, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 1 NOVEMBER 16, 2011
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic fies on CD with formulas activated.
REQUEST NO.1: Please provide a copy of the 1976 Boardman operating agreement,
as amended and supplemented.
REQUEST NO.2: Related to the Boardman shut-down plan, please provide the
following:
a. Factors driving early shut down;
b. A list of paries paricipating in the discussions, and
c. Explanations and copies of all analyses conducted by IPC pertaining to evaluation
options considered with early shut down and the Consent Decree. (Case No. 3:08-
CV-01136-HA in the U.S. District Cour for the District of Oregon, Portland
Division)
REQUEST NO.3: Please explain the Company's involvement in this process.
REQUEST NO.4: Please explain why the Consent Decree is the best outcome for
Idaho customers. What benefits will be experienced/received by Idaho customers?
REQUEST NO.5: Please provide a schedule showing the historical actual operation of
the Boardman power plant and power taken by the Company in the last 5 years. Please also
show the projected operation of the plant through closure and expected power to be received by
the Company.
REQUEST NO.6: Please provide the cost/enefit analysis related to the emission
controls to be installed. Please also list all the clean air requirements or possible requirements
that wil be met with each installation. Please provide a tabular sumar of the different state
and federal environmental regulations that are driving environmental/emission control
investments at the Boardman plant and the corresponding pollutants they intend to control (and
at what level). Please include the approximate cost of each investment.
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 NOVEMBER 16, 2011
REQUEST NO.7: Please explain the process to explore the possibilty of obtaning
waivers for a plant that wil be retired. Were any requests made?
REQUEST NO.8: Please provide a list of each tye of cost liabilties (and estimates)
that will be booked to the balancing account related to the shutdown (i.e. what expenses and
what share of expenses).
REQUEST NO.9: Please provide an analysis of all alternatives considered by Idaho
Power along with the proposed balancing account method for accounting for the costs. What are
the pros and cons of each alternative?
REQUEST NO. 10: Please explain Idaho Power's proposal/expectation/projection
related to total dollar amounts to be reflected in the balancing account over the remaining life of
the Boardman facility, timing and amortization period for the balancing account, and magnitude
of the expected amounts to be included in rates. Include curent investment, futue investment,
decommission costs, salvage values and amortization amounts.
DATED at Boise, Idaho, this t íc-t day of November 201 1.
jL/ ItL
Karl T. Klein
Deputy Attorney General
Technical Staff: Terri Carlock/l-l 0
i:umisc:prodreq/ipcel 1.1 8kkc prod req 1
FIRST PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 NOVEMBER 16, 2011
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16TH DAY OF NOVEMBER 2011,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, IN CASE NO.
IPC-E-II-18, BY E-MAILING AND MAILING A COPY THEREOF, POSTAGE
PREPAID, TO THE FOLLOWING:
JASON B. WILLIAMS
LISA D NORDSTROM
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: jwiliams(ßidahopower.com
lnordstrom(fidahopower .com
COURTNEY WAITES
GREGORY W. SAID
TIM TATUM
IDAHO POWER COMPANY
P.O. BOX 70
BOISE IDAHO 83707
E-MAIL: cwaites(fidahopower.com
gsaid(ßidahopower .com
ttatu(ßidahopower.com
JJ~n1
SECRETARY
CERTIFICATE OF SERVICE