20120521Staff 34-43 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
21 p
DPHC PUc -
COMS
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
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
FOURTH 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 or by
Thursday, May 24, 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.
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER I MAY 21, 2012
For the following questions, documentation means any and all invoices, emails, contracts,
and correspondence, including documentation for amounts or items that are used for interim
calculations that are needed to substantiate the final calculation and/or documentation.
Request No. 34: Staff Production Request No. 32, requests all the documentation
supporting the calculation of O&M expenses contained within Exhibit No. 3. Please provide the
following to supplement the response:
a.Please provide copies of the actual source documentation for the insurance expenses,
as shown to Staff at Idaho Power's offices on Friday, May 18, 2012.
b.Please provide the job descriptions, including pay ranges, for the 17 new positions for
Langley Gulch described in the Labor O&M section of Response to Production Request 32, as
discussed with Staff at Idaho Power's offices on Friday, May 18, 2012.
c.Please provide a narrative describing how, and in what manner, the estimates were
arrived at for the Non-Labor O&M, as described to Staff at Idaho Power's offices on Friday,
May 18, 2012.
Request No. 35: Please provide an updated JSS to include changes in depreciation for
Langley Gulch filed in the settlement stipulation for Case No. IPC-E-12-08.
Request No. 36: Please identify all aspects of each early completion bonus contained
within the Company's rate filing. Please include within your response:
a.the recipient of the bonus,
b.the terms that must be met by the recipient to receive the bonus,
c.photocopies of all relevant excerpts from the legal documents outlining each bonus,
d.if a bonus exists that does not stem from a legal document, provide all documents that
outline the bonus terms,
e.whether the terms that must be met to receive the bonus have been met,
f.the amount of each early completion bonus by account,
FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER 2 MAY 21, 2012
g.how the amount of each early completion bonus is included within the filing, and
h.the net financial cost of each early completion bonus.
Request No. 37: Please provide the Early Completion Bonus cost contained in the
filing's revenue requirement for Boise Power Partners Joint Venture ($750,000 lump sum and
$10,000 per day) by account. Please include within your response how the early completion
bonus is included within the filing.
Request No. 38: Please individually identify the net benefit to customers of each early
completion bonus contained within the Company's filing.
Request No. 39: Please prepare excel spreadsheets that remove early completion
bonuses from the revenue requirement filed in this case. Please include within your response the
removal of the bonuses and gRy other related costs (investment tax credits, deferred taxes,
income taxes, and depreciation) from the JSS and all exhibits in the filing. Please provide the
spreadsheets in excel format with formulas activated.
Request No. 40: Please provide photocopies of the contract excerpts identified and
requested during the Langley Gulch on-site visits.
Request No. 41: Please provide the detailed reconciliation for the EPC contract, current
change orders, and anticipated change orders (not currently included in the current scope of
work) relative to the expected amount to be spent on the total project shown to Staff during the
on-site visit 5/17/12. In addition to the reconciliation detail, please provide a short description
of the scope of work and dollar amounts related to each anticipated change order.
Request No. 42: Please provide the basis used to calculate the net fuel cost for the test
year (up to June 3Øth) and for contingency net fuel cost for the period after June 30th
Specifically, provide the actual and estimated fuel/energy prices and amounts of fuel/energy to
determine the basis distinguishing actual from estimated.
FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER 3 MAY 21, 2012
Request No. 43: Please provide a copy of the DEQ air permit application.
DATED at Boise, Idaho, thisTday of May 2012.
.49t

1362-m L. Howell, II
9 Deputy Attorney General
Technical Staff: Kathy Stockton/34
Shelby Hendrickson/3 5
Patricia Harms/36-43
Mike Louis/36-43
i:umisc:prodreq/ipcel2. l4dhklsshphml prod req 4.doc
FOURTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER 4 MAY 21, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 21 s' DAY OF MAY 2012,
SERVED THE FOREGOING FOURTH 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(mindspring.com
BOISE ID 83702
[e-mail]
greg(richardsonando1eary.com
RICHARD E MALMGREN THORVALD A NELSON
MICRON TECHNOLOGY INC FREDERICK J SCHMIDT! ET AL
800 S FEDERAL WAY HOLLAND & HART
BOISE ID 83716 63805 FIDDLERS GREEN CIRCLE
rema1mgrenmicron.com STE 500
GREENWOOD VILLAGE CO 80111
[e-mail]
[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