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Home My WebLink About20120524IPC to IIPA 20-30.pdfIHO POWER RECEIVE" 'N An IDACORP Company LISA D. NORDSTROM Lead Counsel Inordstrom(idahopower.com `Mk 31 LI 1TIUV(UM 10 May 24, 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 Idaho Irrigation Pumpers Association, Inc.'s Fourth Data Request Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Fourth Data Request to Idaho Power Company in the above matter. Also enclosed are four (4) copies each of non-confidential and confidential disks containing information being produced in response to IIPA's Fourth Data Request. Please handle the enclosed confidential information in accordance with the Protective Agreement executed in this matter. Very truly yours, & Lisa D. Nordstrom LDN:kkt Enclosures 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 Inordstrom(idahopower.com jhiIton(idahopower.com Attorneys for Idaho Power Company RECEIVED 2012 MAY 24 PM t: 37 UTIUTIES COMMISSION 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in response to the Idaho Irrigation Pumpers Association, Inc.'s Fourth Data Request to Idaho Power Company dated May 8, 2012, herewith submits the following information: IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -1 REQUEST NO. 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. RESPONSE TO REQUEST NO. 20: a.The natural gas prices used by the Company in the Company's response to the Idaho Irrigation Pumpers Association, Inc.'s ("IIPA") Request No. 8 are contained in the confidential Excel file provided on the confidential CD. The confidential CD will be provided to those parties that have executed the Protective Agreement in this matter. The natural gas prices are input into the AURORA model as $/MMBtu; therefore, the information provided is in $/MMBtu. b.The natural gas prices used were a 2012 average for Henry Hub as well as a delivered price at Danskin. C. Please refer to the confidential Excel file provided in the Company's response to subpart a. of this Request for the natural gas prices. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -2 REQUEST NO. 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. RESPONSE TO REQUEST NO. 21: Please see the attached Excel file which contains the AURORA output using the same inputs as in the Company's response to IIPA's Request No. 8, with the exception of a natural gas price at Henry Hub of $5 per MMBtu. As mentioned in the Company's response to IIPA's Request No. 20 above, the natural gas prices are input into the AURORA model as $/MMBtu. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -3 REQUEST NO. 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. C. Please list any restraints placed upon the Purchase Power and Surplus Sales such as transmission constraints, availability, etc. RESPONSE TO REQUEST NO. 22: a.Monthly output is the smallest time increment available. The monthly output was already supplied in the Company's response to IIPA's Request No. 8. b.The following table contains the restraints placed upon the Company's thermal units. Plant Minimum Run Time Minimum Down Time Minimum Capacity Boardman 96 hours 24 hours 30.8% Jim Bridger 48 hours 12 hours 39.6% Valmy 48 hours 12 hours 34.6% C. No restraints are placed upon purchased power or surplus sales. The AURORA model does contain some transmission input constraints that are typically never met. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -4 REQUEST NO. 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. RESPONSE TO REQUEST NO. 23: Please see the confidential PDF document provided on the confidential CD containing a portion of the contract between Idaho Power and Sierra Pacific Power Company that relates to unused capacity/output of the Valmy plant (Section 111.2.4). The confidential CD will be provided to those parties that have executed the Protective Agreement in this matter. Section V.2.1.2.2 describes the price charged to the utilizing company for fuel consumed in the other company's capacity. 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 IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -5 REQUEST NO. 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. RESPONSE TO REQUEST NO. 24: a-c. Please see the confidential Excel file provided on the confidential CD. The confidential CD will be provided to those parties that have executed the Protective Agreement in this matter. The response to this Request was prepared by Tom Harvey, Joint Projects Manager, Idaho Power Company, and John Carstensen, Engineering Project Leader, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -6 REQUEST NO. 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 I 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 a listed 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 modes and the same inputs? RESPONSE TO REQUEST NO. 25: The difference between the $146.3 million and the $133.1 million is a result of the Idaho Public Utilities Commission ("Commission") Order No. 31042, which removed the Hoku Materials, Inc. ("Hoku") load, as well as 11 Public Utility Regulatory Policies Act of 1978 ("PURPA") projects, thereby changing the Company's original filing of $133.1 million to $146.3 million. The response to this Request was prepared by Scoff Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -7 REQUEST NO. 26: 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 and with natural gas prices set at the same level as sued in the response to IIPA Request 8. RESPONSE TO REQUEST NO. 26: Please see the attached Excel file which contains the AURORA output using all inputs from Case No. IPC-E-11-08, with the Hoku load removed, and using the same natural gas prices used in the Company's response to IIPA's Request No. 8. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -8 REQUEST NO. 27: 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, 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 22-1. RESPONSE TO REQUEST NO. 27: Please see the attached Excel file which contains the AURORA output using all inputs from Case No. IPC-E-11-08, with the Hoku load removed, the same natural gas prices used in the Company's response to IIPA's Request No. 8, and Langley Gulch added. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -9 REQUEST NO. 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. RESPONSE TO REQUEST NO. 28: The power supply expenses included in the Company's response to the Industrial Customers of Idaho Power's ("ICIP") Request No. 2, which included Langley Gulch, was $138.2 million. The power supply expenses included in the Company's response to ICIP's Request No. 2, which did not include Langley Gulch, was $146.3 million. The difference between the $138.2 million and the $146.3 million equates to a system benefit of $8.1 million. The Idaho jurisdictional basis is calculated by multiplying the $8.1 million by the energy allocation for the Idaho jurisdiction, which equates to $7.7 million. As Mr. Timothy E. Tatum described in his Direct Testimony on page 10, line 16, the $7.7 million is on an Idaho jurisdictional basis. The response to this Request was prepared by Timothy E. Tatum, Senior Manager, Cost of Service, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -10 REQUEST NO. 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-1 1-08. The 2010 data is based upon the 81 years of water conditions while the Case No. IPC-E-1 1-08 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. RESPONSE TO REQUEST NO. 29: The two test periods contain a different number of water year conditions, as well as different test period inputs that go into the hydro model. For example, the loads between each test period are different; therefore, generation is different for each test period. Other than the input differences, the hydro modeling remains the same between the two test periods. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -11 REQUEST NO. 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? RESPONSE TO REQUEST NO. 30: a.The "Staff PURPA adjustment" was made in Case No. IPC-E-10-01 in order to remove 11 wind PURPA projects from the Company's original filing. b.The Company's original filing included 169 average megawatts ("aMW") of PURPA generation, while the Commission Staff removed 11 projects, reducing it to 119 aMW. C. The "Hoku Removed" adjustment was also recommended by the Commission Staff in the same proceeding as above. The Hoku load was removed during the test period of 2010. d. Hoku was included in the Company's original filing during the 2010 test period as 52 aMW. The response to this Request was prepared by Scott Wright, Regulatory Analyst II, Idaho Power Company, in consultation with Lisa D. Nordstrom, Lead Counsel, Idaho Power Company. DATED at Boise, Idaho, this 24th day of May 2012. LISA D. NORD TROM Attorney for Idaho Power Company IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -12 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of May 2012 I served a true and correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST 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 Hand Delivered U.S. Mail Overnight Mail FAX X Email don. howelkuc.idaho.qov Karl.kleinpuc. idaho.ciov Hand Delivered U.S. Mail Overnight Mail FAX X Email peter(richardsonandoleary.com qrecrichardsonandoIearv.com Dr. Don Reading Hand Delivered Ben Johnson Associates, Inc. U.S. Mail 6070 Hill Road Overnight Mail Boise, Idaho 83703 FAX X Email dread inqmindsprinQ.com 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 eIoracineIaw.net Hand Delivered U.S. Mail Overnight Mail FAX X Email tony(äyankel.net IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -13 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 tnelson(ähollandhart.com fschmidt(hollandharLcom sakrundeIkholland hart.com lnbuchananchoIland hart. corn Hand Delivered U.S. Mail Overnight Mail FAX X Email remaImqrenmicron.com Kiniberly Towelljecutive Assistant IDAHO POWER COMPANY'S RESPONSE TO THE IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.'S FOURTH DATA REQUEST TO IDAHO POWER COMPANY -14 CERTIFICATE OF ATTORNEY RECEIVED ASSERTION THAT MATERIALS REQUESTED AND PRO tir4f +AV COURSE OF AN IDAHO PUBLIC UTILITIES COMMISSION ARE PROTECTED FROM PUBLIC INSPECKfl4IflES COMPSSION Case No. IPC-E-12-14 The undersigned attorney, in accordance with RP 233, hereby certifies that the attachments provided in Idaho Power Company's responses to the Idaho Irrigation Pumpers Association, Inc.'s Data Request Nos. 20, 23, and 24 contain information that is a trade secret or privileged or confidential as described in Idaho Code § 9-340, et seq., and § 48-801, et seq., and as such are exempt from public inspection, examination, or copying. DATED this 24th day of May 2012. Lisa D. Nordstronj Counsel for Idaho Power Company