HomeMy WebLinkAbout20120508IPC to PUC 18-24.pdfIHO
POWER®
RECEIVED An IDACORP Company
L -o rn 95 I
LISA D. NORDSTROM
Lead Counsel UA}- r.J.I3LR,i
Inordstrom(idahopower.com UTILIfl COMMISSION
May 8, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-12-14
Langley Gulch Recovery - Response to the Second Production Request of
the Idaho Public Utilities Commission Staff
Dear Ms. Jewell:
Enclosed for filing please find an original and three (3) copies of Idaho Power
Company's Response to the Second Production Request of the Commission Staff ("Staff')
to Idaho Power Company in the above matter.
Also enclosed are four (4) copies of a non-confidential disk containing information
responsive to Staff's Second Production Request.
Very truly yours,
1IhJ
Lisa D. Nordstrom
LDN :csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
LISA D. NORDSTROM (ISB No. 5733)
JULIA A. HILTON (ISB No. 7740)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
Inordstromidahopower.com
jhiIton(idahopower.com
RECEIVED
2012 MAY -8 PM : 57
DAHO PUBLk; UT1LTIES COMMISS10N
Attorneys for Idaho Power Company
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
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the Second Production Request of the Commission Staff to Idaho Power
Company dated April 18, 2012, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -1
1!
REQUEST NO. 18: Please provide workpapers and other underlying
documentation that substantiate the known and measurable plant costs contained within
the Company's filing. Include within your response the actual costs to date by work
order number/project ID, the date by which the work orders closed to plant, and any
contributions and/or advances associated with the projects (if any). This should be
provided on a CD in Excel format with formulas intact.
RESPONSE TO REQUEST NO. 18: Please see the attached Excel file for a list
of Langley Gulch power plant ("Langley Gulch") project identifications ("IDs") with total
charges through March 31, 2012, and amounts that have closed to plant. Please see
the Company's response to Staffs Production Request No. 19 below for detailed
transaction information for these project lOs.
The response to this Request was prepared by Larry Tuckness, Finance Team
Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -2
REQUEST NO. 19: If not provided in response to the previous Request No. 18,
please provide a schedule of Langley Gulch plant expenditures posted by amount, date,
document number, account number and type of expenditure (vendor payment, AFUDC,
payroll, benefits, and the like). This should be provided on a CD in Excel format with
formulas intact.
RESPONSE TO REQUEST NO. 19: Please see the attached Excel file for a
detail transaction list of Langley Gulch total charges by work order through March 31,
2012.
The response to this Request was prepared by Chris Baerlocher, Financial
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -3
REQUEST NO. 20: Please provide copies of all contracts, change orders,
invoices and other supporting documentation for all Langley Gulch plant and operating
expenditures. Please correlate these with the response to the previous Request Nos.
18 and 19.
RESPONSE TO REQUEST NO. 20: Please see the Excel file provided in the
Company's response to Staffs Production Request No. 19 above that lists the
transactions that have been recorded to the various Langley Gulch construction work
orders through March 31, 2012. Idaho Power will make contracts, change orders,
invoices, and other documentation for any of these line item transactions available to
the Idaho Public Utilities Commission ("Commission") Staff to inspect at its Corporate
Headquarters in Boise and/or at the project site. Due to the large scope of the project
and sheer volume of transactions recorded, Idaho Power asks that the Commission
Staff select specific transactions to review. The Company can then prepare the specific
subset of documentation for inspection more timely if an on-site visit is requested. The
contracts and change orders that reside at the Langley Gulch site are as following:
Siemens Steam Turbine Contract
Siemens Gas Turbine Contract
Engineering, Procurement, and Construction Contract
Water Line Contract
Gas Line Contract
Williams Gas Tap Contract
All other contracts reside at Idaho Power's Corporate Headquarters.
This response was prepared from guidance per a telephone call with Tern
Carlock on April 24, 2012.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -4
The response to this Request was prepared by Chris Baerlocher, Financial
Analyst II, Idaho Power Company, and Randall Henderson, Finance Team Leader II,
Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho
Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -5
REQUEST NO. 21: Please update Exhibit No. 2 estimates with actual amounts
through March 31, 2012 and when available, through April 30, 2012. Please provide on
a CD in Excel format with formulas intact.
RESPONSE TO REQUEST NO. 21: Please see the attached Excel file for an
updated Exhibit No. 2 with actual Langley Gulch plant balances through March 31,
2012, and estimates for April 2012 through September 2012. Actual plant balances
through April 30, 2012, are expected to be available by May 18, 2012. The attached
Excel file will be updated with actual April 30, 2012, plant values and provided at that
time.
The response to this Request was prepared by Courtney Waites, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -6
REQUEST NO. 22: Please provide all the documentation supporting the
calculation of deferred income taxes contained within Exhibit No. 3. Please include
within your response a description of the calculation to include the documentation of the
underlying components of the calculation. Please provide all calculations on a CD in
Excel format with formulas intact.
RESPONSE TO REQUEST NO. 22: Please see the "Timing Duff & Deferred
Tax" tab in the attached Excel file. The amounts presented are on a total system basis.
The response to this Request was prepared by Gene Marchioro, Corporate Tax
Director, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -7
REQUEST NO. 23: Please provide all the documentation supporting the
calculation of the investment tax credit contained within Exhibit No. 3. Please include
within your response a description of the calculation to include the documentation of
the underlying components of the calculation. Please provide all calculations on a CD
in Excel format with formulas intact.
RESPONSE TO REQUEST NO. 23: Please see the "Idaho ITC" tab in the Excel
file provided in the Company's response to Staff's Production Request No. 22 above.
The amounts presented are on a total system basis.
The response to this Request was prepared by Gene Marchioro, Corporate Tax
Director, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel,
Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -8
REQUEST NO. 24: Please calculate the deferred income taxes and investment
tax credit associated with Langley Gulch plant expenditures through April 30, 2012.
Please include within your response a description of the calculation to include the
documentation of the underlying components of the calculation. Please provide all
calculations on a CD in Excel format with formulas intact.
RESPONSE TO REQUEST NO. 24: Idaho Power does not have the necessary
information available at this time to calculate the deferred income taxes and investment
tax credit associated with Langley Gulch plant expenditures through April 30, 2012. The
Company anticipates it will have the calculations completed on May 18, 2012, but will
provide the information earlier if the data becomes available.
The response to this Request was prepared by Courtney Waites, Regulatory
Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead
Counsel, Idaho Power Company.
DATED at Boise, Idaho, this 8th day of May 2012.
"Z,- '. - O
LISA D. NORDTROM
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 8th day of May 2012 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY upon the
following named parties by the method indicated below, and addressed to the following:
Commission Staff
Donald L. Howell, II
Karl T. Klein
Deputy Attorneys General
Idaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, Idaho 83720-0074
Industrial Customers of Idaho Power
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, Idaho 83707
Dr. Don Reading
Ben Johnson Associates, Inc.
6070 Hill Road
Boise, Idaho 83703
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
201 East Center
P.O. Box 1391
Pocatello, Idaho 83204-1391
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email don. howelIcpuc.idaho.cov
Karl. kleinpuc.idaho.qov
Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email peterrichardsonandoleary.com
crecirichardsonandoleary.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email dread ing mind spring.com
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email eloracinelaw.net
_Hand Delivered
U.S. Mail
_Overnight Mail
FAX
X Email tony(äyankel.net
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -10
Micron Technology, Inc.
Thorvald A. Nelson
Frederick J. Schmidt
Sara K. Rundell
HOLLAND & HART, LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, Colorado 80111
Richard E. Malmgren
Senior Assistant General Counsel
Micron Technology, Inc.
800 South Federal Way
Boise, Idaho 83716
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email tneIsonchoIIandhart.com
fschmidthoIlandhart.com
sakrundeIl(hoI land hart.com
lnbuchanancD-holIandhart. corn
Hand Delivered
U.S. Mail
Overnight Mail
FAX
X Email remalrnqrenmicron.com
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF TO IDAHO POWER COMPANY -11