20120410Staff 1-17 to IPC.pdf

DONALD L. HOWELL, II
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 3366
RECEVcr)
W2 APR 10 AMU:55
1DHO PUBLiC
1JT1L1TES COMMISSIO
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5983
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS RATES AND ITS RATE )
BASE TO RECOVER ITS INVESTMENT IN )
THE LANGLEY GULCH POWER PLANT. )
)
)
CASE NO. IPC-E-12-14
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,
Donald L. Howell, II, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) provide the following documents and information as soon as possible, but no later than
TUESDAY, MAY 1, 2012.
This Production Request is to be considered as continuing, and Idaho Power 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 APRIL 10, 2012
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide all exhibits filed in the case thus far on a CD in Excel
format with formulas intact and activated.
REQUEST NO. 2: Please provide all supporting workpapers and models in electronic
format with formulas activated.
REQUEST NO. 3: Please provide the warranty terms for the equipment and services
provided by Siemens (see Porter, Di page 10, lines 4-6, Case No. IPC-E-09-03). Please provide
explanation and documentation showing how the Company adjusted maintenance costs included
in the Company's revenue requirement to compensate for equipment repair cost absorbed by the
equipment manufacturer during the warranty period that the equipment is guaranteed to be free
from defects.
REQUEST NO. 4: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $1,454 (June spend) and $151,454
(Total Project) cost overruns related to the cost of the steam turbine.
REQUEST NO. 5: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $64,431 cost overrun related to NEPA
permitting.
REQUEST NO. 6: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $45,000 (June spend) and $70,000
(Total Project) cost overruns related to air permitting.
REQUEST NO. 7: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $155,000 cost overrun related to water
line construction.
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 2 APRIL 10, 2012
REQUEST NO. 8: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $1,620,000 cost overrun related to gas
line construction.
REQUEST NO. 9: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $838,918 (June spend) and $920,000
(total project) cost overruns related to Idaho Power engineering and oversight.
REQUEST NO. 10: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $4,574,299 (June spend) and $5,074,298
(Total Project) cost overruns related to RFP pricing components (including startup fuels). Please
include the amount of fuel, cost of fuel per MMBtu, amount of energy, and energy prices used to
develop the original projection and what will be actually used/sold.
REQUEST NO. 11: Please reconcile and explain cost figure inconsistencies that make
up the $390.9 million provided on page 6, lines 22-25 and page 7, lines 1-11 in Mr. Tatum's
Direct Testimony with cost figures provided in Exhibit No. 1 of Ms. Grow's Direct Testimony.
REQUEST NO. 12: Please provide a breakdown of costs included in the" Langley
Gulch reduction to net power supply expenses" ($7,732,030) shown in Exhibit No. 4 of Mr.
Tatum's Direct Testimony used to calculate the LCAR. Please provide the breakdown of costs
so that they can be compared to the cost categories used by the LCAR calculation in the last
general rate case (see Exhibit Nos. 31, 32, 35, 37, and 39 of Mr. Larkin's Direct Testimony from
Case No. IPC-E- 11-08).
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 3 APRIL 10, 2012
REQUEST NO. 13: Please provide the following related to the Idaho Power supplied
miscellaneous equipment:
a)Justification and basis (include a breakdown of specific costs and a detailed
description of costs) for the $2,239,482 cost overrun.
b)Description of the increases incurred between cost estimates for the miscellaneous
equipment (Idaho Power supplied) category referenced on Ms. Grow's Exhibit
No. 1. Please also include a description of the type of equipment in this grouping.
c)A spreadsheet of costs associated with the miscellaneous equipment (Idaho Power
supplied) category referenced on Ms. Grow's Exhibit No. 1. Include a
description, date, an amount for each item and accounts charged. This should be
provided on a CD in excel format with formulas intact.
REQUEST NO. 14: Please provide a justification and basis (include a breakdown of
specific costs and a detailed description of costs) for the $4,313,660 cost overrun related to
transmission cost.
REQUEST NO. 15: Please describe the transmission "contingency estimates and
upgrades" referenced on page 15 of Ms. Grow's Direct Testimony that were needed above the
Commission-approved estimate. Please also indicate if this was the only cause in variation of the
cost estimates.
REQUEST NO. 16: Will the Langley plant be in commercial operation or available for
commercial operation on July 1, 2012?
REQUEST NO. 17: What was the date of the Langley plant's "first fire" referenced in
Ms. Grow's Direct Testimony on page 16?
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 4 APRIL 10, 2012
DATED at Boise, Idaho, this /&i-day of April 2012.
i6u-X'04 1 - -
onald L. Ho 11, II
Deputy Attorney General
Technical Staff: Shelby Hendrickson/I, 2, 13, 15
Mike Louis/3 - 14
Misc/16 - 17
i:umisc:prodreq/ipcel prod req I .doc
FIRST PRODUCTION REQUEST TO
IDAHO POWER COMPANY 5 APRIL 10, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10" DAY OF APRIL 2012,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER, IN CASE NO. IPC-E-12-14, BY E-
MAILING AND MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
LISA D NORDSTROM COURTNEY WAITES
JULIA A HILTON GREG SAID
IDAHO POWER COMPANY TIM TATUM
P.O. BOX 70 IDAHO POWER COMPANY
BOISE IDAHO 83707 P0 BOX 70
[e-mail] BOISE ID 83707-0070
[e-mail] gsaid(2iidahopower.com
PETER J RICHARDSON DR DON READING
GREGORY M ADAMS 6070 HILL ROAD
RICHARDSON & O'LEARY BOISE ID 83703
P0 BOX 7218 dreading(2imindspring.com
BOISE ID 83702
[e-mail]
[e-mail]
RICHARD E MALMGREN THORVALD A NELSON
MICRON TECHNOLOGY INC FREDERICK J SCHMIDT! ET AL
8005 FEDERAL WAY HOLLAND & HART
BOISE ID 83716 63805 FIDDLERS GREEN CIRCLE
rema1mgrenmicron.com STE 500
GREENWOOD VILLAGE CO 80111
[e-mail]
ERIC L OLSEN ANTHONY YANKEL
RACINE OLSON NYE ET AL 29814 LAKE ROAD
P0 BOX 1391 BAY VILLAGE OH 44140
POCATELLO ID 83204 [e-mail]
[e-mail]
SECRETARY
CERTIFICATE OF SERVICE