20120510IIPA 20-30 to IPC.pdf

LAW OFFICES OF
RACINE OLSON NYE BUDGE & BAILEY
W. MARCUS W. NYE CHARTERED RANDALL C. BUDGE
JOHN A. BAILEY, JR. BOISE OFFICE
JOHN R. G000ELL 201 EAST CENTER STREET lOt SOUTH CAPITOL
JOHN B. INGELSTROM POST OFFICE BOX 1391 BOULEVARD, SUITE 300
DANIEL C. GREEN POCATELLO, IDAHO 83204-1391 BOISE, IDAHO 83702
BRENT 0. ROCHE TELEPHONE: [phone]
FACSIMILE: [phone]
KIRK B. HADLEY
FRED J. LEWIS TELEPHONE [phone]
ERIC L. OLSEN FACSIMILE [phone] IDAHO FALLS OFFICE
CONRAD J. AIKEN 477 SHOUP AVENUE
RICHARD A. HEARN, M.D. SUITE 107
LANE V. ERICKSON www.racinelaw.net POST OFFICE BOX 50698
FREDERICK J. HAHN, III IDAHO FALLS, ID 63405
PATRICK N. GEORGE TELEPHONE: [phone]
FACSIMILE: [phone]
SCOTT J. SMITH
JOSHUA D. JOHNSON
DAVID E. ALEXANDER ALL OFFICES TOLL FREE
STEPHEN J. MUHONEN [phone]
CANDICE M. MCHUGH SENDER'S E-MAIL ADDRESS: eo©racineaw.net
CAROL TIPPI VOLYN
JONATHAN M. VOLYN
THOMAS J. BUDGE LOUIS F. RACINE (1917-2005)
BRENT L. WHITING -- WILLIAM D. OLSON, OF COUNSEL
DAVE BAGLEY JONATHON S. BYINGTON, OF COUNSEL
JEFFREY A. WARR, OF COUNSEL
JASON E. FLAIG
FERRELL S. RYAN, III May 8, 2012 AARON A. CRARY
JOHN J. BULGER
BRETT R. CAHOON
Jean J. Jewell, Secretary
Idaho Public Utilities Commission z
P.O. Box 83720 - m
Boise, Idaho 83720-0084 rn
Re Case No IPC 3 P91lLZ14
co
Dear Mrs. Jewell: 0)
Enclosed for filing in the captioned case please find the original and three copies of Idaho
Irrigation Pumpers Association, Inc. Fourth Data Requests to Idaho Power Company. Thank you
for your assistance
ince
ERIC - OLSEN
ELO:rr
Enclosures
cc: Service List (Via Email)
Eric L. Olsen ISB# 4811 RECE!VED
RACINE, OLSON, NYE, BUDGE & 2012 MAY BAILEY, CHARTERED 3 52
P.O. Box 1391; 201 E. Center iDAj.) PUL Pocatello, Idaho 83204-1391 1' I S COM1:SSIC
Telephone: [phone]
Fax: [phone]
Attorneys for the Idaho Irrigation Pumpers Association, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES )
AND RATE BASE TO RECOVER ITS )
INVESTMENT IN THE LANGLEY )
GULCH POWER PLANT )
)
CASE NO. IPC-E-12-14
IDAHO IRRIGATION PUMPERS
ASSOCIATION, INC.'S FOURTH
DATA REQUEST TO IDAHO
POWER COMPANY
20. Regarding the calculations made by the Company in order to develop the response to
IIPA Request 8, please specify:
a.The natural gas price(s) used.
b.Please indicate if these were Henry Hub prices or delivered prices.
C. Please indicate the assume price of delivery in $/MCF.
21. Please provide a similar "revised" power supply expense calculation as provided in
IIPA Request 8, but assuming a natural gas price at Henry Hub of $5/MCF.
22. With respect to the Response to IIPA Request 8, please-supply:
a.On an hourly basis (or the smallest time increment available if hourly data is not
used) the individual output for all categories listed for each of the 81 years of
data. Please supply both energy and pricing information in a format similar to
that provided in Response to IIPA Request 8.
b.Please list any restraints placed upon the thermal units regarding length of time to
start-up, minimum run times, cost of start-up versus using other alternative,
minimum operation levels, etc.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY
c. Please list any restraints placed upon the Purchase Power and Surplus Sales such
as transmission constraints, availability, etc.
23. Please provide a copy of that portion of the contract between Idaho Power and the
other owner of the Valmy plant that outlines who gets the unused capacity/output of
the plant and at what price/terms.
24. Regarding the output of Valmy from January 1, 2011 through the most recent data
available, please provide:
a.Please provide the hourly output at Valmy.
b.Please provide the hourly output of Valmy that went to Idaho Power.
c.Please provide the hourly price Idaho Power received for any of its 50% share of
the Valmy output that went to Idaho Power's partner in Valmy.
25. IIPA Request 2-a asked for "a copy of the original 2010 load and resource inputs,
workpapers, and results." The Company's response references its Response to ICIP
Request 2 as well as providing and Excel file as Attachment 1 to IIPA Request 2.
The summary page of this Excel file (Average) lists a net power supply cost of
$ 146,295,000. On Mr. Wright's Exhibit No. 1, page 1 in Case No. IPC-E-10-01,
there is listed a net power supply cost of $133,051,500. Why are these net power
supply costs different when it was expected that these came from the same models
and the same inputs?
26. Please supply the output files used in the Aurora model used in Case No. IPC-E-11-
08 with all inputs except with Hoku removed and with natural gas prices set at the
same level as used in the response to IIPA Request 8
27. Please supply the output files used in the Aurora model used in Case No. IPC-E-1 1-
08 with all inputs except with Hoku removed, with natural gas prices set at the same
level as used in the response to IIPA Request 8, and Langley Gulch added. Please
supply this output on the standard monthly basis over 83 water years (plus average) as
well as the short term (hourly if available) outputs similar to that requested in IIPA
Request 22-a.
28. Please clarify the $7.7 million difference suggested in Mr. Tatum's testimony at page
10 lines 10-12 with respect to the source of the data without Langley Gulch and with
Langley Gulch as presumably detailed in the Attachment 2 to the Response to ICIP
Request 2. Please provide the similar output data that was used to develop the $7.7
million difference.
29. The hydroelectric generation listed in the Aurora output file contained in the
Company's 2010 normalized water conditions is different than the hydroelectric
generation listed in the Aurora output contained in the Company's Case No. IPC-E-
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY 2
11-08. The 2010 data is based upon 81 years of water conditions while the Case No.
IPC-E-11-08 data is based upon 83 years of water conditions. Please indicate if that
is the only difference between these two sets of numbers. If there are additional
reasons for the differences, please specify.
30. Regarding the headings for the Aurora output provided in Attachment 2 to the
Response to ICIP Request 2, please answer the following:
a.What is meant by "Staff PURPA Adjustment"? Please explain why the
adjustment was made and in what case.
b.What were the unadjusted values for these "Staff PURPA Adjustments"?
c.What is meant by "Hoku Removed"?
d.When was Hoku included and what were the values?
DATED this 8th day of May, 2012.
RACINE OLSON NYE BUDGE
& BAILC1RTERED
V(-!a-
ERIC L.
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 20th day of April, 2012, I served a true, correct
and complete copy of the foregoing document, to each of the following, via the method
so indicated:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
P.O. Box 83720
472 WI Washington Street
Boise, Idaho 83720-0074
[e-mail]
Lisa fl Nordstrom
Julia A. Hilton
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0072
[e-mail]
jhilton(idahopower.com
Greg W. Said
Courtney Waites
Tim Tatum
Idaho Power Company
P.O. Box 70
Boise, Idaho 83707-0071
gsaid(idahpower.com
[e-mail]
[e-mail]
Donald L. Howell, II
Karl Klein
Deputy Attorneys General
Idaho Public Utilities Commission
P.O. Box 83720
Boise, Idaho 83720-0074
Don.howell(puc.idaho.gov
Karl.k1ein(2ipuc.idaho.gov
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IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY 4
Peter J. Richardson
Gregory M. Adams
Richardson & O'Leary
P0 Box 7218
Boise, ID 83702
[e-mail]
greg(2irichardsonandoleary.com
Don Reading
6070 Hill Road
Boise, ID 83703
dreadingmindsnring.com
Thorvald a. Nelson
Frederick J. Schmidt
Sara K. Rundell
Holland & Hart, LLP
6380 S. Fiddlers Green Circle, Ste 500
Greenwood Village, CO 80111
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Richard E. Malmgren
Micron Technology, Inc.
800 S. Federal Way
Boise, ID 83716
remalmgrenmicron.com
Anthony Yankel
29814 Lake Road
Bay Village, OH 44140
[e-mail]
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L. OLSEN
IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH
DATA REQUESTS TO IDAHO POWER COMPANY 5