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Home My WebLink About20120319ICIP 1-4 to IPC.pdfPeter J. Richardson (ISB # 3195) Gregory M. Adams (ISB # 7454) Richardson & O'Leary, PLLC 515 N. 27th Street P.O. Box 7218 Boise, Idaho 83702 Telephone: (208) 938-7901 Fax: (208) 938-7904 peter!Irichardsonandoleary.com greg($chardsonandolear.com RECEIVED 20ft MAR 19 PH I: f 9 Attorneys for the Industral Customers of Idaho Power BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION )IN THE MATTER OF IDAHO POWER ) COMPANY'S APPLICATION FOR ) AUTHORITY TO INCREASE ITS RATES ) AND CHAGES FOR ELECTRIC SERVICE ) DUE TO THE INCLUSION OF THE ) LANGLEY GULCH POWER PLANT INVESTMENT IN RATE BASE CASE NO. IPC-E-12-14 FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER Pursuat to Rule 225 of the Rules of Procedure of the Idaho Public Utilities Commission (the "Commission"), the Industrial Customers ofIdaho Power ("ICIP") hereby requests that Idaho Power Company ("Idaho Power" or the "Company") provide responses to the following with supporting documents, where applicable. The response to this production request is due on or before April 9, 2012. This production request is to be considered as continuig, and Idaho Power is requested to provide by way of supplementar 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 electronic copies, or if unavailable a physical copy, to Mr. Richardson and Mr. Adams at the address noted above, and to Dr. Don Readg at: 6070 Hil Road, Boise, Idaho 83703, Tel: (208) 342-1700; Fax: (208) 384-1511; dreading(gmindsprig.com. For each item, please indicate the nae of the person(s) preparg the answers, along with the job title of such person(s) and the witness at hearing who can sponsor the anwer. Some of the following requests may include disclosures deemed by Idaho Power to be confdentiaL. Counsel and the expert witness for the Industral Customers of Idao Power will enter into any reasonably necessar protective agreement to obtain and use such materials according the terms of that agreement. REQUEST FOR PRODUCTION NO.1: Reference the direct testimony of Timothy Tatu, p. 10, stating, "The revised base level net 20 power supply expense was determined using the AURORA model with the original 2010 load and resource inputs, with the exception of the addition of Langley Gulch as a resource." For each of Idaho Power's gas-fired generation plants included in the AURORA analysis pedormed to derive net power expenses, please list by plant and by year the anua MWh output and capacity factor at the begining date of the study through the end of the analysis period. REQUEST FOR PRODUCTION NO.2: Reference the direct testimony of Timothy Tatu, p. i O. Please provide copies of all input and output files used in the AURORA model ru discussed. REQUEST FOR PRODUCTION NO.3: Please provide the dollar per MWh the cost of Langley Gulch using the same procedures and assumptions that the Company would apply to a QF requesting prices for a contract under the IPR methodology approved for Idaho Power on the date of its filing of ths case, and under the methodology proposed in the direct testimony of Karl Bokenkamp in Case No. GNR-E-II-03. Please include all workpapers and assumptions of the: a. Natual gas fuel forecast, b. Firm load forecast, c. Surlus sales, d. Firm purchases, e. Power supply expenses. REQUEST FOR PRODUCTION NO.4: Reference the direct testimony of Lisa Grow, p. 15, stating: "Q. Does the Company's request in this docket include its tota investment of $401 millon in the Langley Gulch project? A. No, not at this time. Whle the $401 milion is $26 milion less than the Company's originally fied Commitment Estimate, the Company is only requesting recovery of the amount of investment that will be closed to books by June 30, 2012, or $398,133,778." Please indicate when the Company will request any additional amounts for rate base treatment above the $398.1 milion requested in ths docket. Than you for your prompt attention to this First Requests for Production. Sincerely yours, Cl~ Gregory Adams RICHARDSON & O'LEARY, PLLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19th day of March, 2012, a tre and correct copy of the withn and foregoing FIRST PRODUCTION REQUEST OF THE INDUSTRIAL CUSTOMERS OF IDAHO POWER TO IDAHO POWER COMPANY IN CASE NO.IPC-E-12-14 was served in the maner shown to: Jean D. Jewell, Secretar Idaho Public Utilities Commission 472 West Washington Boise, Idaho 83702 jean.jewell~uc.idaho.gov X- Hand Delivery _U.S. Mail, postage pre-paid Facsimile Electronic Mail Lisa D Nordstrom Julia A Hilton Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 lnordstrom($idahopower.com jhilton!Iidahopower .com _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile .. Electronic Mail Courey Waites Greg Said Tim Tatum Idaho Power Company PO Box 70 Boise, Idaho 83707-0070 cwaites!Iidahopower.com gsaid!Iidahopower.com ttatum!Iidahopower.com _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile X Electronic Mail Eric Olson Racine, Olson, Nye, Budge & Bailey, Charered PO Box 1391 Pocatello, Idaho 83204-1391 elo!Iracinelaw.net _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile .. Electronic Mail Anthony Yanel 29814 Lake Road Bay Vilage, Ohio 44140 tony!Iyanel.net _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile .. Electronic Mail Richard E. Malmgren Micron Technology, Inc. 800 S. Federal Way Boise,ID 83706 remalgren!Imicron.com Thorvald A. Nelson Frederick J. Schmidt Sara K. Rundell Brian T. Hansen Pamela S. Howland Holland & Har, LLP 6380 S. Fiddlers Green Circle Ste 500 Greenwood Vilage, CO 80111 tnelson!Ihollandhar.com fschmidt(fhollandhar.com sakdell!Ihollandhar.com bhansen!Ihollandhar.com phowland!Ihollandhar.com Ibuchanan(fhollandhar.com Signed _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile .. Electronic Mail _ Hand Delivery XU.S. Mail, postage pre-paid Facsimile .. Electronic Mail